Bridgette Barsalou

The applicant husband sought to bifurcate family law proceedings, separating professional liability claims (breach of fiduciary duty and intentional infliction of mental distress arising from a prior psychotherapist-patient relationship) from matrimonial claims (divorce, support, and equalization).

The respondent wife opposed bifurcation, arguing the claims were inextricably linked as part of a continuous pattern of coercive control.

The court dismissed the motion, finding that hearing the matters together was more just, efficient, expeditious, and proportionate, particularly given the respondent's intention to testify about the entire relationship in the family law proceeding and the absence of any benefit from a stepwise approach.

The Respondent, Andrew Lambden, brought a motion for an interim order requiring the Applicant, Yessica Pamela Cevallos, to pay $30,000 as security for costs of the litigation.

The court found that the Applicant habitually resides outside Ontario and has no assets in Ontario, satisfying the preliminary onus under Rule 24(13)(a) of the Family Law Rules.

The court expressed serious reservations about the merits of the Applicant's spousal support claim, specifically regarding whether the parties continuously cohabited in a conjugal relationship for the statutory three-year period, citing significant interruptions in their cohabitation and the nature of their financial arrangements.

The court also noted the Applicant's inconsistent financial disclosure and inappropriate threatening statements made to the Respondent.

Despite the Applicant's submission that the order would prevent her from continuing the proceeding, the court found she had the ability to raise funds.

The motion for security for costs was granted in the amount of $20,000.