“The obligation to make full and frank financial disclosure in a family law case is an immediate and ongoing obligation. See: Colucci v. Colucci, 2021 SCC 24, at paragraph 42.
At paragraph 44, in Aiello v. Aiello, 2023 ONSC 2176, Justice M.D. Faieta wrote about the importance of disclosure orders being proportional as follows:
Any demands for financial disclosure beyond the specific items that are required to be produced under the Child Support Guidelines and the Family Law Rules must be relevant and proportional to the issues in the case: Mawhinney v. Ferreira, 2023 ONSC 1357, at para. 12. In weighing whether a request for disclosure is proportional, consideration should be given to the burden that the request places on the disclosing party in terms of time and expense of producing the requested disclosure: Kovachis v. Kovachis, 2013 ONCA 663, at para. 34. Also see Boyd v. Fields, [2006] O.J. No. 5762, at paras. 11-14.”