What is the test for disclosure and support under the Chief’s Notice?

Ontario, Canada


The following excerpt is from Rossi v. Rossi, 2020 ONSC 3822 (CanLII):

Considering the “pressing importance” test set out in the Chief’s Notice, the observations of Kurz J. in Thomas v Wohleber[1] (although under the earlier iteration of the Chief’s Notice) and later refined by McGee J. in Clemente v. O’Brien,[2] it is my view that a case conference must proceed on the issues of disclosure and support. The father’s failure to adequately explain the change in his position dealing with expert evidence, his denial of the mother’s entitlement to spousal support, the significant difference in the parties incomes when combined with the father’s position that any such determination must await disclosure, including questioning, are consistent with the mother’s concerns about the father tactically delaying a more expeditious resolution of the parties’ affairs to her disadvantage.

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