Finally, we agree with Sproat J. that there was no error in the motion judge’s decision not to bifurcate the liability and penalty phases of the contempt motion in order to afford the appellant an opportunity to purge her contempt. Although there is good reason to bifurcate contempt proceedings (Boyd v. Carleton Condominium Corporation 145, 214 ONCA 574), given the appellant’s pattern of non-compliance and the consequences to the respondent and their daughter, it was open to the motion judge to impose the penalty immediately.
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