SUPERIOR COURT OF JUSTICE – ONTARIO
RE: Bruce Wolframe, Applicant v. Sarah Adams, Respondent
HEARD: February 26, 2026
BEFORE: Nieckarz J.
COUNSEL: Mr. Marchak appearing for Mr. Cupello, for Mr. Wolframe Ms. Makkinga, enhanced duty counsel, appearing for Ms. Adams
Endorsement
1There are two motions before the court, as follows:
a. CRSB Law’s motion to be removed as lawyers of record for Mr. Wolframe; and
b. Ms. Adams’ motion seeking to strike Mr. Wolframe’s pleadings.
2With respect to CRSB Law’s motion:
a. I am satisfied that despite efforts to contact Mr. Wolframe, CRSB Law has not had contact with him since July 5, 2024.
b. CRSB Law has attempted to reach Mr. Wolframe by his last known email, telephone number, and address.
c. Email communication has not ‘bounced back’.
d. Mail has recently been returned from the last known address.
e. Telephone number is no longer in service.
f. CRSB Law is no longer capable of receiving instructions from Mr. Wolframe due to his lack of contact, and it is no longer reasonable to expect them to continue to act on his behalf.
g. The motion shall be granted, and an order shall issue that complies with Rule 4(15) of the Family Law Rules. No draft order was provided.
h. In accordance with the requirements of Rule 4(15)(b), the order shall be served on Ms. Adams, and on Mr. Wolframe by email, with proof of service filed with the court.
3With respect to Ms. Adams’ motion seeking to strike Mr. Wolframe’s Response to Motion to Change:
a. The motion to change child support was commenced in December 2022 and is not resolved/determined largely due to Mr. Wolframe not being responsive.
b. A settlement conference was scheduled for January 10, 2024, because attempts by Ms. Adams’ counsel to communicate with Mr. Wolframe’s counsel between June and September 2023 were unsuccessful
c. The settlement conference scheduled for January 10, 2024, was not productive because Mr. Wolframe had not complied with disclosure orders made March 24, 2023. The disclosure orders were for very basic income information such as pay stubs and an income tax return.
d. At the settlement conference on January 10, 2024, leave was granted to Ms. Adams to strike Mr. Wolframe’s pleadings and proceed with the motion to change as an uncontested proceeding if Mr. Wolframe did not comply with an order made at the conference for disclosure. The order also required Mr. Wolframe to make an offer to settle within seven days.
e. The January 10, 2024, order was complied with. An offer to settle was made January 17, 2024. Ms. Adams made a counter-offer February 14, 2024, to which there was no response.
f. A further settlement conference was scheduled by Ms. Adams for August 13, 2024. Mr. Wolframe did not attend. Further disclosure orders were made to update the income information.
g. Some further information was provided, but the August 13th order was not fully complied with. The last income information Ms. Adams has is for 2023. She does not have a 2023 income tax return. No further income information has been provided. The issues in the proceeding are retroactive and ongoing child support.
h. Other than three payments, Mr. Wolframe is not paying the temporary child support that has been ordered in this proceeding. He is in arrears in excess of $23,700. The Family Responsibility Office is now involved.
i. A further settlement conference was scheduled by Ms. Adams to proceed February 4, 2026. Mr. Wolframe did not attend. His counsel sought to be removed as counsel of record due to an inability to obtain instructions.
4It is evident that Mr. Wolframe is not participating in this proceeding in a manner that allows it to move towards a final resolution, or at all. Ms. Adams has no contact with Mr. Wolframe and does not even know if he is still working. His lack of contact and lack of participation in this proceeding makes it difficult for her to know whether the support currently ordered is appropriate. It also makes it difficult for her to enforce the support ordered on a temporary basis.
5Rule 1(8) of the Family Law Rules sets out the orders a judge may make when a party to a proceeding fails to obey a court order. This includes an order striking out a pleading such as a Response to Motion to Change. Rule 1(8.1) gives a judge that same discretion if a person fails to follow the Family Law Rules. Failing to follow the Rules includes failing to participate in the proceeding by attending court.
6Parties to a proceeding also have an obligation pursuant to Rule 2(4), as does the court, to promote the primary objective set out in Rule 2(2). The primary objective of the Family Law Rules is to deal with cases justly. That is done by ensuring the proceeding is fair to all parties, by saving expense and time, by dealing with the case in ways appropriate to the importance and complexity, and by devoting appropriate court resources. The court and Ms. Adams have devoted the time and resources necessary to this case, which Mr. Wolframe has squandered by his lack of participation and lack of compliance with court orders. At this point, it would be unfair to Ms. Adams, and a waste of hers and the court’s resources to force her to continue with this matter as a contested proceeding when Mr. Wolframe does not see fit to participate. Her request to strike his pleadings so that the matter may proceed uncontested is appropriate.
7An additional difficulty with Mr. Wolframe’s non-participation is the lack of updated income information. I have discussed with Ms. Makkinga the possibility of a motion under the Family Orders and Agreements Enforcement Assistance Act. At this point Ms. Adams simply wishes to have the proceeding concluded, and she is content to proceed based on the limited information available.
8With respect to Ms. Adams’ motion, it is ordered that:
a. Mr. Wolframe’s Response to Motion to Change is struck.
b. Any other documents filed on Mr. Wolframe’s behalf, including financial statements shall remain part of the court record.
c. Ms. Adams has leave to schedule a 1-hour uncontested hearing, to be held in-person.
d. Mr. Wolframe shall be provided with notice of the uncontested hearing date once scheduled.
e. If Mr. Wolframe attends the hearing, this order shall not preclude any orders that the trial judge deems appropriate in the circumstances.
f. If Ms. Adams does decide to proceed with an order under the FOAEAA, she shall do so on notice to Mr. Wolframe.
g. A copy of this Endorsement and the order issued pursued to this Endorsement shall be served on Mr. Wolframe by Ms. Adams’ counsel.
h. Service of any document on Mr. Wolframe shall be by email to jwolframe39@gmail.com.
i. As Ms. Adams does not seek costs of this motion, there shall be no costs payable.
The Hon. Madam Justice T. Nieckarz DATE: March 3, 2026
CITATION: Wolframe v. Adams, 2026 ONSC 1281
COURT FILE NO.: FS-16-001-001
DATE: 2026-03-03
SUPERIOR COURT OF JUSTICE - ONTARIO
RE: Bruce Wolframe, Applicant v. Sarah Adams, Respondent
HEARD: February 26, 2026
COUNSEL: Mr. Marchak appearing for Mr. Cupello, for Mr. Wolframe Ms. Makkinga, enhanced duty counsel, appearing for Ms. Adams
ENDORSEMENT
Nieckarz J.
DATE: March 3, 2026