The applicant mother sought costs arising from three case conferences, arguing they were unproductive due to the respondent father's delayed and incomplete financial disclosure.
The court found that the father's failure to comply with disclosure orders and lack of preparedness impeded progress and warranted a costs award under Rule 17(18) of the Family Law Rules.
The court awarded the mother costs on a substantial indemnity basis, fixed at $6,441.00 inclusive of HST.