The applicant brought a motion in a family law proceeding seeking disclosure from the respondent and a non-party family corporation to assist a retained valuator in assessing the respondent’s corporate interest and income for support purposes.
The court held that broad disclosure is appropriate where there are concerns that income from a closely held family business may be understated or manipulated.
Applying the “semblance of relevance” test and emphasizing the importance of full financial disclosure in family law, the court found the requested corporate and personal records relevant to valuation and income analysis.
The court ordered the respondent and the corporation to produce the requested documents and directed that the confidentiality agreement governing disclosure be amended to clarify that it also covered the valuator’s income analysis.
