R. Tsao

The applicant father brought an urgent motion for the immediate return of the parties' 16-year-old son from an educational and therapeutic program in Utah, United States.

The urgency was predicated on the COVID-19 pandemic and the imminent closure of the Canada-US border.

The court found that it was in the child's best interests to return to Canada immediately, given the health concerns and government recommendations for citizens abroad.

The court ordered the respondent mother to turn over the child's passport and required both parties to cooperate in facilitating the child's return, after which he would self-quarantine with the applicant for 14 days.

In family litigation following separation, the applicant brought a motion seeking enforcement of prior disclosure orders and requested a daily monetary penalty for non-compliance under Rule 1(8) of the Family Law Rules.

The court reviewed the respondent’s disclosure relating to two corporations and inter‑company financial transactions and found significant deficiencies, including missing invoices, incomplete financial records, and failure to provide a detailed general ledger.

The court concluded that the respondent had not complied with earlier disclosure orders and that the explanations provided were insufficient.

The respondent was ordered to produce specified financial records and explanations by a set deadline, failing which daily penalties of $500 would apply.

The respondent was also directed to bring a motion requiring a third party associated with a related corporation to produce corporate financial records.