COURT FILE NO.: FS-20-20652

DATE: 20210805

SUPERIOR COURT OF JUSTICE – ONTARIO

RE: M.B., Appellant

AND:

A.F., Respondent

BEFORE: C. Horkins J.

COUNSEL: M.B., acting in person

Jared Teitel, for the Respondent

HEARD at Toronto: June 29, 2021

REASONS FOR DECISION

overview

[1] The applicant mother (mother) and respondent father (father) have one child who was born in 2009. The parties have never lived together.

[2] The father pays child support. He is a salaried T4 employee who works as a driver and technician for a coffee company. The parties agreed to a final consent order on June 1, 2017 (“2017 final order”). Because the father did not yet have his 2016 income tax return, the parties agreed to an imputed income for the father of $40,000 and $300 a month for s. 7 expenses.

[3] The income tax returns show that in 2016 and 2017 the father earned in the low to mid $40,000 and in 2019 it was $43,488.55.

[4] Both parties brought motions to change the 2017 final order. Those motions were heard by Justice Finlayson (motion judge). The motion to change before Justice Finlayson was the third motion to change and the “fourth round of litigation concerning child support for their one child.

[5] In lengthy and detailed reasons, the motion judge dismissed the mother’s motion to change in its entirety. The motion judge varied the final order more or less in accordance with what the father requested.

[6] The motion judge rejected the mother’s arguments: that the father was concealing income and that $100,000 of income should be imputed to the father for the purpose of deciding child support. The motion judge was very critical of the mother’s conduct throughout the litigation.

[7] The father asked the motion judge to make orders under s. 140(1) (c) and (5) of the Courts of Justice Act, R.S.O. 1990, c. C.43 finding the mother to be a vexatious litigant and limiting her ability to commence further litigation in the Ontario Court of Justice (“OCJ”). The motion judge correctly noted that only a judge of the Superior Court may make a s. 140 order. Given the mother’s conduct that is addressed below, the motion judge made orders limiting the mother’s right to return to the court within the power afforded to the court under the Family Law Rules.

[8] The motion judge ordered the mother to pay the father costs of the motions fixed at $15,000. He ordered that this be set off against the child support arrears that the father owed ($5.563.37) for net costs of $9,436.63. The arrears arose from the motion to change that calculated the past child support.

[9] The father has continued to pay child support and owes no arrears.

[10] The mother appeals the final order of Justice Alex Finlayson dated November 3, 2020 and the costs order dated January 26, 2021. The hearing of her appeal is scheduled for October 14, 2021.

[11] The mother’s Amended Notice of Appeal is 135 pages long. Pages 9-133 consist of what the mother calls her grounds of appeal. A notice of appeal must set out the legal grounds for the appeal (Family Law Rule 38 (10)). In her Amended Notice of Appeal, the mother disagrees with almost everything the motion judge said or did. In essence, she seeks to reargue the motion she lost.

[12] The father brings a motion seeking various relief:

(a) An order that the mother is a vexatious litigant and that she shall not issue any further proceedings against the father without leave of the court pursuant to s. 140(1) (c) of the Courts of Justice Act.

(b) An order dismissing the mother’s appeal as an abuse of process pursuant to s. 140(1) (d) and 140(5) of the Courts of Justice Act.

If a & b are not granted, he seeks alternative relief:

(c) An order that the mother post security for costs of the appeal in the amount of $15,000.

(d) An order that security for costs be posted for the costs ($9,436.63) that she seeks to appeal.

(e) That no further steps be taken in this case until the security is posted; and

(f) If security for costs is not posted by a fixed date that the appeal be dismissed.

(g) Costs of this motion

[13] In response to the father’s motion, the mother has filed in excess of 3,500 pages of material. Of note her factum is 63 pages (exceeding the practice direction limit of 20 pages) and her responding affidavit dated June 7, 2021 is 1,212 pages long.

Analysis

Legal Framework

[14] Family Law Rule 38(26) allows this court to make an order for security for costs:

(26) On a motion by the respondent for security for costs, the court may make an order for security for costs that is just, if it is satisfied that,

(a) there is good reason to believe that the appeal is a waste of time, a nuisance, or an abuse of the court process and that the appellant has insufficient assets in Ontario to pay the costs of the appeal;

(b) an order for security for costs could be made against the appellant under subrule 24 (13); or

(c) for other good reason, security for costs should be ordered. O. Reg. 89/04, s. 13.

[Emphasis added.]

[15] Family Law Rule 38(27) states that “[i]f an appellant does not obey an order under subrule (26), the court may on motion dismiss the appeal”.

[16] Family Law Rules 1(8) and 2(2) to (4) set out below are also relevant.

[17] Family Law Rule 1(8) states that “If a person fails to obey an order in a case or a related case, the court may deal with the failure by making any order that it considers necessary for a just determination of the matter”. The mother has failed to pay several cost orders. Under Family Law Rule 1(8), this court can make an order that she is not allowed to proceed with the appeal until all cost orders are paid in full.

[18] Family Law Rule 2 (2) states that the “primary objective of these rules is to enable the court to deal with cases justly.” Rule 2(3) and (4) state:

(3) Dealing with a case justly includes,

(a) ensuring that the procedure is fair to all parties;

(b) saving expense and time;

(c) dealing with the case in ways that are appropriate to its importance and complexity; and

(d) giving appropriate court resources to the case while taking account of the need to give resources to other cases.

(4) The court is required to apply these rules to promote the primary objective, and parties and their lawyers are required to help the court to promote the primary objective.

[19] The relief that is granted on this motion should promote the primary objective of the Family Law Rules.

Amended Notice of Appeal

[20] The mother’s Amended Notice of Appeal does not provide a clear list of alleged errors nor does she clearly state if the alleged error is one of fact or law. As noted, this massive document is her attempt to reargue the motions.

[21] The mother also alleges procedural unfairness and bias (in paras. 384, 457, 510 and 523 of the Amended Notice of Appeal). The basis of this ground of appeal seems to be that she does not like the result and therefore it is unfair and because the father succeeded, it seems she is arguing that the motion judge is biased. The Amended Notice of Appeal for this ground is vague.

[22] Most of what the mother complains about falls into the category of an alleged error of fact and the standard of review is high.

[23] The standard of review on an appeal from the order of a judge is correctness for an error of law, palpable and overriding error for an error of fact, and correctness or palpable and overriding error for a question of mixed fact and law, depending on whether there is an extricable legal principle (Zeitoun v. Economical Insurance Group, 2009 ONCA 415 at para. 1; Wellwood v. Ontario (Provincial Police), 2010 ONCA 386 at para. 28).

[24] To succeed on an error of fact, the appellant must show that a judge has committed a palpable and overriding error or made findings of fact that are clearly wrong, unreasonable, or unsupported by the evidence” (H.L. v. Canada (Attorney General), 2005 SCC 25, [2005] 1 S.C.R. 401 at para. 4). The Supreme Court of Canada went on to say (at para. 55) that the language of “palpable and overriding error” and “clearly wrong” found in the case law “encapsulate the same principle: an appellate court will not interfere with the trial judge’s findings of fact unless it can plainly identify the imputed error, and that error is shown to have affected the result.”

[25] Justice Finlayson’s Reasons for Judgment are 73 pages long. In considerable detail Justice Finlayson reviewed the litigious history between the parties, carefully explained the two motions before him and set out why he found in favour of the father. The findings of fact are carefully supported by the evidence. The motion judge dismissed the mother’s motion and all the relief she sought. The relief that he allowed on the mother’s motion to change, favoured the father not the mother.

[26] There is good reason to believe that the mother’s appeal is “a waste of time, a nuisance, or an abuse of the court process”. The standard of review for an alleged error of fact is high. It is not enough for the mother to say that the motion judge did not consider a piece of evidence or did not accept the mother’s version of a particular piece of evidence. The mother must show that the motion judge was “clearly wrong” and that the error of fact affected the result. Despite the hundreds of pages that she has filed with the court, there is no apparent error of fact that is “clearly wrong”. All that can be said is that the mother disagrees with the entirety of the motion judge’s decision and she wants to argue the motion again. This is not the purpose of an appeal.

[27] Throughout the mother’s voluminous materials filed for this motion, she states often that her appeal has, for example, “extreme merit”, that there are “several errors” of law and these errors are “very clear”. Simply stating that there is merit to her appeal does not make it so.

[28] Para 331 of the Amended Notice of Appeal is an example of what the mother frames as an error of law. This point deals with a motor vehicle accident that the father had in 2013. He was injured and his income declined in 2014 and 2015. The father commenced an action for damages due to his injuries and a lump sum settlement ($87,000) was agreed to in 2017 (this amount was not divided between pecuniary and non-pecuniary damages). After payment of fees and disbursements, the father received a net payment of $45,000. The motion judge had to decide what amount should be allocated to income for the purpose of deciding Guideline child support. He carefully considered this issue, reviewed the applicable case law, and decided to allocate 23% of the net payment to income in the relevant year.

[29] The mother argued that $87,000 should be attributed to income even though the father only received $45,000. Alternatively, she argued that $45,000 should be attributed to income. The motion judge rejected her position. He found that it was reasonable to find that some of this should be attributed to income and some to non-pecuniary loss.

[30] Dealing with this point, in her Amended Notice of Appeal the mother states: “At paragraph 221 of the Judgment of November 3, 2020, Justice Finlayson erred and did not consider that the Court of Appeal for Ontario has ruled otherwise.”

[31] Para. 221 of the motion judge’s decision deals with the mother’s assertion that in some cases the full amount of the lump sum settlement should be attributed to income because “the Ontario Court of Appeal has ruled otherwise”. The motion judge stated:

The mother asserts that the Ontario Court of Appeal has ruled otherwise. She says that where a payor/settlement recipient fails to provide actual evidence of his pain and suffering by way of medical records, if the settlement lacks a breakdown as to the characterization of damages, and if the respondent “carelessly dissipated” the settlement, the full amount of the settlement should be included in income. She provided me with no actual authority from the Court of Appeal that says this.

[Emphasis added]

[32] There was no such case before the motion judge and he carefully reviewed all the case law provided. There is also no case before this court to show that this is arguable error of law.

The Mother’s Conduct

[33] The mother’s conduct is relevant because she has not followed court orders. Further, she has and is pursuing the litigation without respecting the primary objective of the Family Law Rules. Every party is required to “help the court to promote the primary objective” of the Rules: to deal with cases justly. The mother’s conduct has not promoted the primary objective of the Rules as explained below.

[34] The mother’s motion to change was the parties' fourth round of litigation in the Ontario Court of Justice in the past decade, all in relation to child support. Since issuing this motion to change in April of 2018, the mother has appealed nearly every order with which she has disagreed. She has numerous costs orders against her that she has not paid. This is her sixth appeal.

[35] The motion judge made the following findings of fact about the mother’s conduct:

• "What is in issue in this litigation is entirely disproportionate to the steps and positions the mother is taking, or that she wishes to take. Quite apart from the other places across her motion material in which she claims various disclosure and other relief, the mother's Notice of Motion alone is 6 pages long. It contains some 27 paragraphs of relief. Some of those 27 paragraphs have subparagraphs." (Paragraph 21)

• "… I agree with counsel for the father that the cost of allowing additional disclosure, and likely the fallout from that (i.e. what the mother will likely do with that information), is completely out of proportion to what is at stake in this litigation." (Paragraph 205)

• "I would not depart from the mother's disclosure motion without making an observation about the mother's own conduct respecting her disclosure in this litigation. Despite the hundreds or thousands of pages of material that she filed and her many allegations about the father, the mother did not herself comply with the disclosure requirements of the rules and the Guidelines." (Paragraph 210)

• "The mother has conducted this litigation, and her related appeals, in a particular manner. She is entitled to take an aggressive approach. But she is not entitled to waste court time, cause the other side to incur unnecessary costs and engage in abusive behaviour towards the father's counsel in the process." (Paragraph 284)

• “The father is a man of modest means. History over the past few years reveals that there have been minor, but not significant, fluctuations to his income. He also has support obligations for his 9 year-old child of his new relationship. The father cannot afford to keep litigating like this with the mother. The mother is choosing to litigate, in this Court, on her own. The father, by contrast, had the right to and made the decision to retain counsel, to ensure his best position was put before the Court. That is not an inexpensive proposition. He should not have to get drawn back into expensive and protracted litigation, unless there is merit to it, and even then, it must be controlled”. (para 285)

• "There has been far too much litigation between the parties over child support. The first case began about a decade ago. The parties have been litigating on and off for 10 years, and they have been in particularly heated litigation in this round of the litigation, for the last 2 years. The litigation needs to stop. It is financially harmful." (Paragraph 286)

• "In her materials before this Court, the mother has inappropriately referenced supposed statements or alleged verbal orders by different judges, made at conferences and on the appeal." (Paragraph 288(b))

• "The mother has failed to comply with prior procedural directions of this Court, and of the Superior Court, including those which both placed limits on the amount of material that could be filed, and respecting how that material was to be filed." (Paragraph 288(d))

• "The mother has not paid at least one costs order. That is the costs order of Lederer J. dated February 28, 2020. The fact that it was only for $200, and it remains unpaid, is very telling. It remains to be seen what will transpire regarding Akbarali J.'s costs order of $500.00. And this Court has yet to hear costs submissions in connection with these motions." (Paragraph 288(d))

• "There is also evidence before the Court that mother has engaged the father and his counsel in "letter-writing campaigns". I am particularly troubled about the manner in which the mother has treated the father's counsel … Several of her communications to [the father's lawyer] are abusive. For example …" (Paragraph 289)

[36] In the motion judge’s Costs decision, he dealt with the mother’s conduct at paras. 24-28:

[24] It is important to consider the mother's behaviour in its full context. The father is a salaried, T4 employee. I would have taken no issue with the mother's conduct in the litigation, had she just pursued an adjustment to child support based on the father's new Line 150 incomes, revealed after the date of the last Final Consent Order dated June 1, 2017, plus some additional income from the receipt of his personal injury settlement. In fact, had that been the extent of her claims, this case could have easily settled, or alternatively could have been determined at a focused hearing.

[25] Instead, as I summarized in 6 to 30 and elsewhere in the Judgment, the mother:

(a) took the position that the father was concealing income;

(b) took the position that he had a more affluent lifestyle and hidden resources than those which he was disclosing;

(c) argued that the Court should now go behind two prior Consent Orders of this Court, and order more support going back several years;

(d) argued that the Court should order the father to pay an above guideline amount of child support. The amount she sought, if ordered, would have exceed his entire annual income;

(e) took the position that the father failed to provide disclosure; and

(f) submitted that the Court should order the father to provide bank statements and much other disclosure, to enable the mother to advance the arguments above.

[26] I concluded there was no basis to make any of those findings and orders. Moreover, the mother did not comply with her own disclosure obligations, particularly as they pertain to section 7 expenses. Yet she now disputes the Court's ruling on that issue, despite her failure to place the necessary information before it.

[27] At 21 of the Judgment, I found that what was in issue in the litigation was entirely disproportionate to the steps and the positions the mother was taking or wished to take. At 24, I found that the mother had filed an excessive amount of material, numbering in the hundreds if not in excess of one thousand pages, or more. The mother's conduct of filing voluminous materials continues. She blatantly ignored the Court's direction limiting the length of costs submissions. She complains that the page limit means she was only able to give "limited information". Yet she filed 45 pages of submissions, plus attachments, in any event.

[28] I have no hesitation in finding that the mother's behaviour has been neither reasonable nor proportional in relation to the importance and complexity of the issues, withing the meaning of rule 24(12)(a)(i). I do not need to address father's references to the mother's alleged bad faith behaviour, or whether her behaviour rises to that threshold, to warrant an order for full recovery costs since the father already restricted the quantum of his claimed costs.

[37] In his Costs decision, Justice Finlayson found at para 63 that "the mother conducted this litigation in a manner that has caused financial harm to the father. She behaved unreasonably and disproportionately." He went on to explain at paras. 64-66 why it was necessary to set off the arrears against the costs he ordered:

I also am aware that the mother owes the father other costs orders from other courts. Significantly, she has declared that she will not pay the father any money "under any circumstance". Specifically, at 122 of the mother's costs submissions, the mother said this about herself and about her future intentions:

The applicant mother is also a victim. I believe there are also certain restrictions that should prohibit a court from ordering that "a victim of sexual assault, rape or domestic violence" has to "pay their abusers or rapist money." (This would also include legal fees and costs) The applicant will not pay the respondent father money under any circumstance [emphasis added].

[65] This Court has not made any such finding of abuse and is unaware of any other court having made such a finding against the father. So even if the mother's statement of the law is correct (about which I will not comment), I fail to see how it would apply in this case.

[66] Absent a set off order, I find the father will not collect, certainly not in the near future or without incurring additional costs and hassle. That effectively undermines the very purposes of making a costs order.

Unpaid Costs Orders/Failure to Follow Court Orders

[38] The issue of child support in this case should not be complicated. It should not require multiple court attendances. The father is a T4 employee and the mother refuses to accept this reality. His line 150 income should be used to fix child support under the Child Support Guidelines, O. Reg. 391/97. Yearly court attendances and appeals should not be necessary for this single straightforward issue. The mother continues to pursue allegations against the father and his income that have no factual basis. Costs orders against her have no impact. She has made it clear that she has no intention of paying costs, even if ordered to do so. The outstanding costs orders against her total $13,436.36 (excluding interest). This includes Justice Finlayson’s costs order of $9,436.63.

[39] The mother’s evidence that she has paid past costs orders is not reliable. She relies on two unsigned cheques to support her evidence that she paid some of the past cost orders. To the extent that the mother’s financial circumstances are relevant to her ability to pay, this was considered given the very modest amount of the costs ordered. The mother has had ample time to pay all cost orders. In her March 30, 2021 sworn financial statement, she states that she spends $10,000 a month for “court related expenses” and yet does not pay costs that the court has ordered her to pay.

[40] The evidence that I accept shows that the mother has not paid costs orders as explained by the father in his June 23, 2021 reply affidavit at paras 4-5:

Contrary to Paragraph 58 of Melissa’s Affidavit, Melissa has not paid any of her outstanding Costs Orders nor have any of these Orders been offset or set aside. In addition to the Honourable Justice Finlayson’s Final Costs Order of January 26, 2021 of $9,436.63,1 Melissa has not paid:

a. The Costs Order of the Honourable Justice Akbarali of the Superior Court of Justice (November 12, 2019 – $500.00) – Contrary to Paragraph 76 of Melissa’s Affidavit, the Honourable Justice Diamond never offset Justice Akbarali’s Costs Order in our prior proceedings in the Superior Court of Justice. Melissa knows this. If Justice Diamond had set-off this Order, Melissa would not have tried to appeal it, twice (to the Divisional Court and later to the Ontario Court of Appeal).

b. The Costs Order of Honourable Justice Lederer of the Divisional Court (February 28, 2020 – $200.00) – Contrary to Paragraph 82, Melissa never paid this Order. She attaches a cheque at Exhibit “Y” of her Affidavit presumably to feign payment, which cheque I attach again here at Exhibit “A”. I have never received this cheque, but even if I had I would not have been able to deposit it. Melissa did not sign it.

c. The two Costs Orders of the Honourable Justices Backhouse, Swinton, and Labrosse of the Divisional Court (dated October 9, 2020 – $3,000.00 total, $1,500.00 per Order). Melissa’s Affidavit is the first I am learning about her setting money aside to pay these Orders. To date she has not proposed a payment plan and I have never received any payments.

d. The Costs Order of the Honourable Justices Lauwers, Trotter, and Zarnett of the Ontario Court of Appeal (March 23, 2021 – $300.00) – Similar to Justice Lederer’s Costs Order of $200.00, Melissa attaches a cheque at Exhibit “BB” of her Affidavit, attached again at Exhibit “B”. Contrary to Paragraph 86, Melissa never sent this cheque, and I likewise would have been unable to deposit it if she had as it is also not signed.

5. I do not believe Melissa ever sent these cheques notwithstanding she has attached copies of them to her previous court materials. My lawyer has requested for Melissa to resend the cheques, or, better still, for her to e-transfer the funds. Melissa has always refused notwithstanding I advised that the cheques would be destroyed if they resurfaced.

[41] The mother’s financial statement shows that she has insufficient assets in Ontario to pay costs of the appeal and the father will be unable to recover his costs if he is successful on this appeal.

[42] The mother has ordered the transcript of the hearing before the motion judge. She has not paid for the transcript. Justice Shore stated in her April 12, 2021 case conference endorsement that “The transcripts will be required for the appeal and to be filed with the Appellant’s Appeal Record, as per the Rules”. The mother has ordered and paid for transcripts from several previous appearances in the OCJ. Somehow the mother finds the funds to pay for transcripts but will not pay the court ordered costs. In her words, she will not pay the father costs “under any circumstance” (para. 64 of the motion judge’s Costs Decision). The mother should not be allowed to continue with this appeal in the face of the unpaid cost orders. However, the father’s requested relief is focused on security for costs not payment of costs orders made before Justice Finlayson’s orders.

[43] Recently, on March 30, 2021 and June 15, 2021, the mother brought motions to increase child support in the Ontario Court of Justice. Her motions do not comply with the motion judge’s November 3, 2020 order. In these motions, the mother seeks support retroactive to January 1, 2020 notwithstanding that the motion judge fixed support as at November 30, 2020, nor did the mother provide any receipts or other documents for her Section 7 expenses as required by para. 11 of that order.

[44] Based on my assessment of the Amended Notice of Appeal, there is good reason to believe that the appeal is a waste of time, a nuisance, and an abuse of the court process. It is also clear that if the appeal fails, the father will have no ability to recover costs that the mother is ordered to pay. The mother is unemployed.

[45] The father estimates that his costs of the appeal are $15,000. According to the mother’s Financial Statement, she has assets of $6,078, and debts of $35,000. Her debts exceed her assets, and her assets alone are insufficient to cover any reasonable costs order that is made in his favour.

[46] The father has provided a breakdown of his counsel’s estimated fees for the appeal. The fees total $15,989.50. This is based on counsel’s hourly rate of $300 and a fair estimate of the hours required to respond to the appeal. A request that the mother post $15,000 as security for costs is fair and reasonable.

[47] I have decided not to make orders under s. 140 of the Courts of Justice Act. While I find that the mother’s conduct is unreasonable, excessive and abusive, it is the Ontario Court of Justice that should deal with her conduct. This is where the dispute between the parties is being dealt with. This court is involved in its appellate capacity.

[48] While the Ontario Court of Justice cannot issue an order under s. 140 of the Courts of Justice Act, the Family Law Rules provide extensive discretion and authority to issue orders to control the mother’s concerning behaviour. For example, procedural orders can be made under Family Law Rule 1(7.2) to control the mother’s habit of filing excessive and unnecessary material. Further, Rule 1(8) gives the court wide discretion to make orders against a party (like the mother) who does not obey court orders and whose conduct does not promote the primary objective of the Rules. A claim, motion, motion to change, financial statement, affidavit or any document that a party files can be struck. If a party fails to obey a court order, an order can be made that the party is “not entitled to any further order from that court”. Orders can also be made under Rules 1(7.2) and 2(5) to promote the primary objective of the Family Law Rules.

[49] The father has not requested an order to address the non-payment of previous costs orders. If he had I would have made the appropriate order under rule 1(8). Such an order can be considered in the Ontario Court of Justice, if the mother continues to seek further relief from that court.

[50] I am satisfied that this is a case where security for costs is required. The mother will have until October 12, 2021 to pay $24,436.63 for the security for costs. The mother has some savings and has a monthly $10,000 court related expense. If she redirects this money and uses savings, she can pay the security for costs.

[51] I make the following orders for security pursuant to Family Law Rule 38(26). As well, further orders are made if the mother complies, and posts security as ordered:

1. The appellant shall pay security for costs in the amount of $15,000 for the appeal of Justice Finlayson’s order dated November 3, 2020 and $9,436.63 for the appeal of the Justice Finlayson’s costs order dated January 26, 2021.

2. The security shall be paid no later than October 12, 2021. The appellant shall deliver a certified cheque payable to Normandin Chris LLP in trust in the amount of $24,436.63 to be held in trust pending further order of the court.

3. If the appellant fails to comply with the orders in 1 and 2, then the respondent may bring a 14B motion to dismiss the appellant’s appeal. Such motion shall be heard in writing by Justice Shore, or another judge that she assigns. Neither party shall file material that exceeds 20 pages in total. If material exceeds this page limit, it shall not be accepted for filing with the court and the 14B motion shall be decided without the material.

4. If the appellant complies with the orders in 1 and 2, then the parties shall attend a final case conference before Justice Shore to have new dates set for this appeal and the filing of appeal material, and to have page limits set for the filing of all appeal material. All dates previously set for this appeal are struck.

5. If the respondent seeks costs of his motion then he shall serve and file his costs submission with a bill of costs by August 30, 2021. In total, the submission and bill of costs shall not exceed 15 pages. The appellant shall serve and file her responding submission by September 15, 2021. Her submission shall not exceed 15 pages. Submissions that are late or that exceed the page limit shall not be considered by this court.

6. The applicant shall not bring any further motions or seek any relief in this court unless she complies with these orders and leave to seek such relief is granted by Justice Shore or her designate.

7. All submissions shall be served by email and filed with the court at through the JSO portal https://www.ontario.ca/page/file-family-court-documents-online and through the Family Intake Office email at Toronto.SCJ.FAMILYINTAKE@ontario.ca. As well the material shall be filed on CaseLines.

C. Horkins J.

Date: August 5, 2021