ONTARIO SUPERIOR COURT OF JUSTICE
RE: Tyler Lock, Applicant
-and-
Aazada Lock, Respondent
BEFORE: Robert Centa J.
COUNSEL: Stacey Mintsopoulos, for the applicant A. Sam Zaslavsky, for the respondent
HEARD: July 9, 2026
ENDORSEMENT
1Tyler Lock brings this urgent motion to increase his parenting time with his daughter B. from the status quo to an equal parenting schedule, commencing immediately. He also seeks orders in respect of a family wedding scheduled for July 17, 2026. Aazada Lock opposes the motion but will consent to a much smaller increase in parenting time, which she proposes to be revisited in four months at the settlement conference.
2In my view, Mr. Lock’s request is not in the best interests of the child. It does not pay sufficient attention to the status quo and the need for stability in the life of the 17 month old. Despite his evidence, I am left with serious doubts about Mr. Lock’s ability to parent B., particularly overnight. This is due in large measure to the fact that Ms. Lock has presented clear and compelling evidence that Mr. Lock has committed intimate partner violence against her and has done so in front of B. While I am not in a position on this written record to make a final determination of whether Mr. Lock, in fact, beat Ms. Lock on more than one occasion, the cogency of the evidence presented by Ms. Lock satisfies me that it is not in B’s best interests to grant Mr. Lock’s motion. Instead, I think it is in B.’s best interests to order that the parties follow the parenting schedule proposed by Ms. Lock.
3Because of the urgent need to release my decision and reasons in advance of the wedding on July 17, 2026, these reasons will be brief. Although I have considered all of the evidence and the submissions of the parties, I will only be referring to the most relevant and important evidence and submissions.
1. Position of the parties
4The parties were married on October 4, 2024. B. was born on February 5, 2025. The parties separated for three months from October 2025 to January 2026, when they briefly reconciled. The parties permanently separated on March 24, 2026.
5At the time of this motion, Mr. Lock has had parenting time on every Tuesday and Thursday from 2:00 p.m. to 6:45 p.m. and one day each weekend on alternating Saturdays and Sundays from 10:00 a.m. to 3:00 p.m.
6Mr. Lock seeks an order that he have equal parenting time with B. on a 2-2-3 schedule, or another equal parenting schedule that the court finds to be in the best interests of the child. In the alternative, Mr. Lock seeks an order for a 9-week step up schedule as follows:
a. Weeks 1-3: Tuesdays and Thursdays from 9:00am to 6:00pm; and Fridays at 10:00am to Saturday at 3:00pm;
b. Weeks 4-6: Tuesdays at 10:00am to Wednesday at 6:00pm; Thursdays from 9:00am to 6:00pm; and Alternating weekends from Friday at 4:00pm to Sunday at 6:00pm;
c. Weeks 7-9: Tuesdays at 9:00am to Wednesday at 6:00pm; Thursdays from 9:00am to Friday at 6:00pm; and Alternating weekends from Friday at 9:00am to Sunday at 6:00pm;
d. Weeks 10+ The parties shall have equal parenting time on a 2-2-3 schedule on an ongoing basis until varied by a further order of the court or agreement.
7Mr. Lock seeks additional relief related to B. attending a family wedding, and some relief related to health care and health-related information.
8Ms. Lock objects to Mr. Lock’s proposal. She is prepared to consent to a more gradual increase in his parenting time, which would be reviewed at the conference that is booked for October 23, 2026. Ms. Lock proposes that B. would continue to have her primary residence with Ms. Lock, and that Mr. Lock would have parenting time every Tuesday and Thursday, from 12:00 noon to 6:45 p.m., and one day each weekend on alternating Saturdays and Sundays, from 10:00 a.m. to 6:00 p.m.
9Ms. Lock asks that the court order that Mr. Lock not be under the influence of any drugs while B. is in his care, complete an anger management course, and follow B.’s nap and sleep routines.
2. Best interests of the child and the limits of a motion for temporary parenting time
10In making a parenting order, I am to take into consideration only the best interests of the child, giving primary consideration to the child’s physical, emotional and psychological safety, security and well-being.1 In determining the best interests of B., I must consider all relevant factors, including the factors set out in s. 16(3) of the Divorce Act. The child should have as much time with each parent as is consistent with the best interests of the child. However, findings of family violence are a critical consideration in the analysis of the best interests of the child.2 Where the factors pull in different directions, I am to resolve them in favour of promoting the child’s physical, emotional, and psychological safety, security, and well-being.3
11As B. is 17-months old, I have no evidence regarding the views and preferences of B. I cannot ascertain B.’s views and give no weight to that factor.4
12To determine the best interests of B., I will consider below the factors related to the circumstances of the child.
13This motion was heard for one hour. Mr. Lock filed two affidavits, and Ms. Lock filed one affidavit. The parties did not conduct cross-examinations. The parties have presented two very different versions of events. It would not be appropriate for me to reach final conclusions on any of the issues raised between the parties.
14The purpose of a temporary motion is simply to provide a reasonably acceptable solution until later stages of the litigation. In general, the status quo should be maintained until trial, unless the best interests of the child demand an immediate change. As Kraft J. stated:
A temporary motion is meant to provide a reasonably acceptable solution on an expeditious basis for a problem that will be fully canvassed at subsequent conferences or resolved at a trial. The status quo should be maintained until trial unless there is material evidence that the child’s best interests require an immediate change. See: Coe v. Tope, 2014 ONSC 4002; Costello and McLean, 2014 ONSC 7332; Munroe v. Graham, 2021 ONCJ 253.5
15As I will explain, Ms. Lock has presented credible evidence that Mr. Lock engaged in family violence toward her. I am not making a finding that she has proven on a balance of probabilities that Mr. Lock has committed family violence. I am satisfied that she has presented credible evidence that establishes a prima facie case that Mr. Lock assaulted her on two occasions, once in front of B. Mr. Lock denied the acts of misconduct, but he did not present any documentary or independent evidence to raise significant doubts about Ms. Lock’s evidence. In these circumstances, Mr. Lock has not persuaded me that it is in the best interests of the child to adopt his proposal for parenting time.
A. Family violence
16Under the Divorce Act, I am to consider any family violence and its impact on the ability and willingness of any person who engaged in the family violence to care for and meet the needs of B., as well as the appropriateness of an order that would require Ms. Lock and Mr. Lock to cooperate on issues affecting B.6 The Divorce Act defines family violence to mean:
any conduct, whether or not the conduct constitutes a criminal offence, by a family member towards another family member, that is violent or threatening or that constitutes a pattern of coercive and controlling behaviour or that causes that other family member to fear for their own safety or for that of another person — and in the case of a child, the direct or indirect exposure to such conduct — and includes
(a) physical abuse, including forced confinement but excluding the use of reasonable force to protect themselves or another person;
(b) sexual abuse;
(c) threats to kill or cause bodily harm to any person;
(d) harassment, including stalking;
(e) the failure to provide the necessaries of life;
(f) psychological abuse;
(g) financial abuse;
(h) threats to kill or harm an animal or damage property; and
(i) the killing or harming of an animal or the damaging of property;7
17In considering the impact of family violence, I am to take the following into account:
a. the nature, seriousness and frequency of the family violence and when it occurred;
b. whether there is a pattern of coercive and controlling behaviour in relation to a family member;
c. whether the family violence is directed toward the child or whether the child is directly or indirectly exposed to the family violence;
d. the physical, emotional and psychological harm or risk of harm to the child;
e. any compromise to the safety of the child or other family member;
f. whether the family violence causes the child or other family member to fear for their own safety or for that of another person;
g. any steps taken by the person engaging in the family violence to prevent further family violence from occurring and improve their ability to care for and meet the needs of the child; and
h. any other relevant factor.8
18The Supreme Court of Canada recently explained that coercive and controlling conduct includes other conduct not explicitly captured by the statutory definition. Kasirer J. noted that coercive control has been “broadly described as conduct that non-exhaustively includes tactics of isolation; manipulation; humiliation; surveillance; physical, psychological, sexual, and economic abuse; and intimidation that can control, isolate, and entrap intimate partners…”9 Justice Kasirer provided some non-exhaustive examples:
…coercive and controlling conduct faced by an intimate partner can also include: psychological, sexual or emotional violence; controlling behaviour such as stalking, monitoring activities and financial control; intimidation, threats to family members, or making false allegations to the police or to employers; litigation abuse; and preventing the victim from seeing family and friends, working, or participating in other educational or recreative activities (see, e.g., Divorce Act, s. 2(1); Stark (2023), at pp. 15-16).10
19Courts must be careful when addressing allegations of family violence based on conflicting affidavit evidence. Justice Kristjanson described the difficulty this way:
It is particularly difficult to deal with allegations of family violence based only on conflicting affidavit evidence on a one-hour parenting motion. The issue of conflicting affidavits regarding allegations of family violence was addressed by Justice R.S. Jain in Pereira v. Ramos, 2021 ONSC 1207, where she ordered shared parenting. Jain J. held that she was not making any findings about the party’s credibility with respect to the allegations, but was considering the effect of any family violence on the ability and willingness of the party to care for and meet the needs of the child. The same applies here. Justice Jain held at para. 25:
The court must consider factors relating to family violence when making a parenting order as set out in s. 16 (3) (j) and (4) of the Act. In a motion, because of conflicting affidavits, it can be difficult for the court to determine credibility in regard to allegations of family violence. However, in this motion I am not making any findings regarding the party’s credibility with respect to their allegations of family violence. To be clear, I am not deciding or making findings of fact regarding each party’s versions of the family violence that has occurred. Instead, I am considering the “impact” of any family violence on the “ability and willingness of any person who engaged in the family violence to care for and meet the needs of the child, and the appropriateness of making an order that would require persons in respect of whom the order would apply to cooperate on issues affecting the child.11
20Ms. Lock alleges that Mr. Lock abused and threatened her repeatedly over an extended period of time. For the purposes of this temporary motion for parenting time, I will focus on Ms. Lock’s three most serious allegations.
1. The alleged assault with broomstick on September 18, 2024
21Ms. Lock states that on September 18, 2024, while she was four months pregnant with B., Mr. Lock, in a fit of rage “struck me with a broomstick along my pregnant abdomen.” Ms. Lock states that she feared for her safety and the health of her fetus and sought medical attention. Ms. Lock attached a photograph to her affidavit that she states accurately depicts the injury Mr. Lock inflicted on her. The photograph shows a woman’s abdomen with a significant patch of deep bruising and what appears to be a break in the skin.
22In his submissions, Mr. Lock suggested that Ms. Lock only raised the allegations of violence recently and is using them as an “excuse” to restrict his parenting time. Mr. Lock submitted that Ms. Lock recently fabricated these allegations.
23However, Ms. Lock attached clinical notes from Dr. Matthew Runnalls, at the Sunnybrook Health Sciences Centre, to her affidavit. The clinical notes record Dr. Runnalls’ clinical assessment of Ms. Lock on September 19, 2024, at 01:45. The notes record the history of present illness as reported by Ms. Lock. Dr. Runnals recorded the following:
HPI: This lady presents today with abdominal pain after she was assaulted by her partner. She is 18 weeks pregnant. She is G1, PO. She was struck with a stick in her right upper quadrant. This occurred about 21 hours ago. She went to work he went to keep the job and then came here immediately afterwards. She tells me that this is not the first time she is suffered from domestic violence. Unfortunately, she is due to marry him in 2 weeks. She does not feel comfortable seeing her family due to sociocultural pressure. She has nowhere to go. She went up to OB triage earlier today where they did a bedside ultrasound and some additional tests and were able to confirm there appeared to be no obstetrical complications.
She describes fatigue and right mild right upper quadrant abdominal pain along with a mild headache. However she was able to sleep prior to me attending to her. She thinks the pain is quite mild and Tylenol is sufficient.
24Ms. Lock’s prior consistent statements to Dr. Runnalls are prima facie inadmissible.12 The fact that a prior consistent statement was made is irrelevant because it is redundant to the testimony or evidence with which it is consistent.13 Repetition of the same claim is neither independent corroboration of that claim (as it comes from the same source) nor an indication that the claim is accurate (because a lie or mistake does not become true merely through its repetition).14
25However, I find that Ms. Lock’s statements to Dr. Runnals is admissible to rebut Mr. Lock’s submission that Ms. Lock recently fabricated her version of events to advance her position on parenting issues. Dr. Runnalls’ clinical note of what Ms. Lock said to him is admissible to rebut the allegation of recent fabrication because:
a. the prior consistent statement is consistent with the evidence it is offered to support;
b. Ms. Lock made the statement to Dr. Runnalls after the event she is testifying about, in this case Mr. Lock striking her in the abdomen with a broomstick; and
c. the statement by Ms. Lock to Dr. Runnalls predates the point in time when Mr. Lock claims that Ms. Lock first adopted the version of events to which testified.15
26For that reason, Ms. Lock’s prior consistent statements are admissible to rebut Mr. Lock’s submission that she recently fabricated the allegations of abuse. For clarity, I am not giving Dr. Runnalls’ conclusion that Ms. Lock was a victim of domestic violence and that he was very concerned “given the elevated risk of both intimate partner violence and even intimate partner homicide in pregnancy.” Whether or not that opinion will be admissible at trial, I give it no weight on this motion.
27Mr. Lock denies Ms. Lock’s allegation that he struck her with a broomstick. In his affidavit, he states as follows:
I adamantly deny the allegation that I struck Aazada with a broomstick while pregnant with [B.] as alleged at paragraph 10 of Aazada's Affidavit. The medical report Aazada provided states the alleged incident happened 12 hours prior to her attending at the hospital and that she went to work. Following her attendance at the hospital, she told my sister that these wounds were self-inflicted. Aazada struggled with anxiety and depression throughout the pregnancy and post-partum.
Aazada came home that night. We slept in the same bed. We married a few weeks later.
28I have some concerns about Mr. Lock’s evidence.
29First, the purported evidence about what his sister said to him about what Ms. Lock said to her is double hearsay and it is not admissible on this motion.16 If Mr. Lock wished to put evidence of that conversation before the court, he could have and should have tendered an affidavit from his sister.
30Second, the court will not act on myths and stereotypes about how women who have been abused will act following that abuse.17 Myths and stereotypes are properly understood as prohibited inferences.18 Mr. Lock may be able to demonstrate that this evidence is relevant for a permissible purpose at trial. However, there are well-known stereotypes that relate to a complainant’s delay in reporting and continued association with an alleged abuser after the offence in question.19 It would be impermissible to judge a complainant’s credibility based solely on the correspondence between her behaviour and the expected behaviour of a stereotypical victim.20
31Third, it is not clear what relevance Ms. Lock’s “anxiety and depression” would have to assessing her evidence that Mr. Lock hit her with a broomstick.
32In any event, it is clear that Mr. Lock denies that he committed an act of violence toward Ms. Lock on September 18, 2024.
2. The criminal charges arising out of an incident on February 15, 2025
33Ms. Lock states that on February 15, 2025, she and Mr. Lock argued over B. and her nutritional needs. The incident escalated to a point where Mr. Lock struck the glass-top stove with sufficient force to crack it. Ms. Lock attached a photo of the stove top to her affidavit.
34For his part, Mr. Lock states as follows:
- In or around February 15, 2025 when [B.] was only 10 days old, we had an argument that resulted in police involvement. During the argument I fell back and crashed heavily into the stove with my hand. Given the sudden impact, the glass on the stove top broke. Aazada was nowhere near me at the time and was in another room. She called the police and I was subsequently charged with assault and mischief. The assault charge was ultimately dropped and I plead guilty to the mischief charge related to the damage to the stove and I am currently on a one year probation.
35It is not necessary for me to make a final determination of what happened. I observe that Mr. Lock’s explanation seems somewhat implausible, given that it ended with a guilty plea to a charge of mischief. I also find that a probation order arising out of an argument with Ms. Lock that escalated to the point where police were called is a criminal order, condition, or measure that is relevant to the safety, security and well-being of B.21
36Mr. Lock correctly notes that the York Region CAS closed their investigation into this incident.
3. Alleged assault on September 16, 2025
37Ms. Lock states that on September 16, 2025, Mr. Lock struck her on the legs. Ms. Lock states that this took place in front of B., who at this time was seven months old, and that she was “crying hysterically” during the incident.
38Ms. Lock attached three photographs to her affidavit that she says shows the bruising on her legs. The photographs appear to show large patches of bruising over both her left and right leg, as well as some distinct patches of very dark bruising.
39Mr. Lock denies that he struck Ms. Lock and caused the bruising on her legs. He states she has included the photographs of the bruising “with no context.” He states that “claims that [B.] has been frightened and distress is [sic] a blatant lie.”
40Mr. Lock has attached text messages the parties exchanged on September 16, 2025, that are affectionate, forward looking, and do not refer to any acts of violence that day. There is no evidence in the record to indicate whether those text messages, which are clearly excerpted from a longer chain, were exchanged before or after the alleged act of violence on that day. Mr. Locke does not explain whether he knew about the bruising on Ms. Lock’s legs at the time or what caused the bruising that appears present in the photos.
4. Considering the impact of the allegations of family violence
41I find that Ms. Lock has presented clear and cogent evidence of at least three serious acts of family violence. All these incidents took place in the last two years, since Ms. Lock first became pregnant with B. According to Ms. Lock, one of the incidents took place in front of B. If Ms. Lock proves at trial, on a balance of probabilities, that these incidents took place, I have no doubt the court will conclude not only that the incidents are extremely serious, but that Mr. Lock poses a serious risk harm to the physical, emotional and psychological health of B. In my view, the court would also conclude that Mr. Lock’s conduct, if proven, is relevant to the exercise of his parenting time, decision-making responsibility and contact with the child.
42As noted above, it is not possible to reach a final determination of what happened based only on conflicting affidavits and in the absence of cross-examination or live evidence. In my view, however, this is not just a “she said he said” situation. Ms. Lock has presented objective evidence to corroborate her allegations. For the alleged assault with the broomstick, Ms. Lock has presented a disturbing photo of her bruised abdomen. She has also presented a contemporaneous medical note that is strong evidence to dispute the suggestion that she recently fabricated her evidence about that assault. With respect to the February 15, 2025, incident with the stove, Ms. Lock has presented a photograph of the damaged stove. Moreover, Mr. Lock pleaded guilty to a criminal charge arising out of that incident. With respect to the alleged assault on her legs on September 16, 2025, she has presented photographs of her visibly and seriously bruised legs.
43In considering the impact of family violence, I am to take into account any steps taken Mr. Lock to prevent further family violence from occurring and to improve his ability to care for and meet the needs of the child.22 Mr. Lock provided the following evidence regarding his therapy journey:
With respect to the allegation that I have anger issues, I adamantly deny this statement. Throughout the marriage and following separation, I have been actively engaged in therapy, both in couples counselling (where Aazada never referenced any safety concern) and individual therapy. Therapy has helped me immensely in dealing with the challenges I experienced during the marriage. In February 2025 following a dispute between me and Aazada [the stove incident], I voluntarily chose to check into individual clinical treatment with Jude Okoh at New Life Counselling. I completed a 10-session psychoeducational curriculum spanning from February 21, 2025 to May 30, 2025. The program focused on emotional regulation, cognitive behavioural processing and assertive communication. Following this program, I transitioned into intensive individual personal counselling with my therapist starting in July of 2025. My long-term clinical work has continued without interruption to this day.
44It is difficult to reconcile Mr. Lock’s statement that he does not have anger issues with his decision to “check into individual clinical treatment” for a 10-session treatment program. None of the therapy appears to address issues of domestic violence, coercive control, or respectful relations with women or intimate partners. If Mr. Lock does not even agree that he has anger issues, I doubt that his therapy sessions would significantly reduce the risk of future violence or improve his ability to care for and meet the needs of B.
B. The care of the child
45In assessing the best interests of B., I am to consider the history of care of the child, any plans for the child’s care, and the ability and willingness of Ms. Lock and Mr. Lock to care for and meet the needs of the child.23
46In their respective affidavits, each party criticizes the parenting abilities of the other. There is very little extrinsic evidence to allow me to assess the views expressed by each party. I place little weight on the concerns expressed about appropriate sleeping arrangements, employment schedules, the extent of parenting activity pre-separation, allegations of minor drug use, disputes over sleep training, crib use, or nap times. These are all minor issues that would not, on their own, cause me to accept one party’s proposal over the other.
47It is really the allegations of family violence that cause me to have significant concerns about Mr. Lock’s ability to care for and meet the needs of B. overnight or on an equal time basis.
C. Relationships between the child, each spouse, and other family members
48In assessing the best interests of B., I am to consider the nature and strength of the child’s relationship with each spouse and grandparents, as well as the willingness of each spouse to support the development and maintenance of the child’s relationship with the other spouse.24
49I am satisfied that this factor is neutral and that each of Mr. Lock and Ms. Lock will comply with the order of the court and facilitate relationships between B. and the other parent and that parent’s extended family.
D. Communication and cooperation
50In assessing the best interests of B., I am to consider the ability and willingness of Ms. Lock and Mr. Lock to communicate and cooperate with one another on matters affecting B.25 They are currently using AppClose as the vehicle for their communications.
51Having reviewed text messages between them, I do not think Mr. Lock and Ms. Lock have yet demonstrated the ability to communicate well with each other about B. Certainly, I do not think they have developed the level of communications skills necessary to support the intricate dance of a 2-3-2 equal parenting relationship. I hope that over time, and with the support of this order, they will be able to have respectful and child-focused communications.
E. Conclusion
52In my view, it is not in B.’s best interests to adopt either of the parenting schedules proposed by Mr. Lock. The credible allegations of family violence, even if not yet proven on a balance of probabilities, are exceedingly troubling. It is in B.’s best interests to increase Mr. Lock’s parenting time slowly and to give him time to demonstrate that he is capable of caring for B. for longer stretches of time, through myriad parenting challenges, without any flareups of anger or violence. I understand that Mr. Lock seeks maximum contact, but that can and must be restricted to the extent that it conflicts with the child’s best interests.26 If Mr. Lock demonstrates that he is parenting successfully under my order, the parties can at a later date modify the parenting schedule to provide additional parenting time, including overnight visits.
53I have considered the AFCC-O Guidelines and the information it provides regarding child development research.27 In my view, the Guidelines’ recommendations must be considered in light of allegations of family violence and the risk of harm posed by future acts of violence.
54In my view, it is not in B.’s interests, at the age of 17 months, to upend her life and move to shared parenting on a 2-3-2 basis, given the credible allegations of family violence made against Mr. Lock. Instead, Ms. Lock’s proposal to increase parenting time will give B. frequent and consistent contact with both parents to ensure stability for B.28
55I make the following temporary order:
a. The child B., born February 5, 2025, shall have her primary residence with Aazada Lock.
b. Beginning on July 20, 2026, Tyler Lock shall have parenting time with B. on the following schedule:
i. Every Tuesday and Thursday from 12:00 p.m. to 6:45 p.m.;
ii. Beginning on Saturday July 25, 2026, and continuing every other Saturday thereafter, 10:00 a.m. to 6:00 p.m.; and
iii. Beginning on Sunday August 1, 2026, and every other Sunday thereafter, 10:00 a.m. to 6:00 p.m..
c. Each parent is responsible for dropping off B. to the other at the scheduled end of her or his parenting time with B.
d. Both parents shall follow B.’s usual bedtime and naptime routines.
e. Neither parent shall be intoxicated by drugs or alcohol while B. is in her or his care.
f. If B. requires emergency medical care while with one parent, that parent will promptly notify the other parent about the situation.
g. Each parent shall ensure that B. takes any prescribed medication or over-the-counter medication recommended for B. and shall keep the other parent fully advised about the details of any such medication.
3. Wedding
56Mr. Lock requested that, regardless of the parenting schedule, that he have B. with him from noon on Friday July 17, 2026, to noon on Sunday July 19, 2026, for his sister’s wedding. B. is scheduled to be the flower girl at the wedding, which is scheduled for July 18, 2026.
57I accept that it is worthwhile for B. to participate in the wedding as a way of meeting and integrating with Mr. Lock’s family on a special day. I am not, however, prepared to grant overnight parenting to Mr. Lock for the wedding, or any other reason, at this time.
58In response to my questions, Ms. Lock indicated that she would be willing to transport to and from the wedding to facilitate B.’s participation.
59I make the following temporary order: Ms. Lock shall transport B. to and from Mr. Lock’s sister’s wedding
a. on Friday, July 17, 2026, if it is necessary for B. to participate in a rehearsal for the wedding ceremony. In any event, Ms. Lock shall leave for home from any wedding-related event with B. on July 17, 2026, no later than 7:00 p.m.
b. on Saturday, July 18, 2026, arriving no later than 11:00 a.m. and, in any event, leaving for home on July 18, 2026, no later than 7:00 p.m.
4. Costs
60I urge the parties to try and resolve the costs of this motion.
61If the parties are not able to resolve costs of this action, Ms. Lock may email her costs submission of no more than three double-spaced pages to my judicial assistant on or before July 21, 2026. Mr. Lock may deliver his responding submission of no more than three double-spaced pages on or before July 28, 2026. No reply submissions are to be delivered without leave.
Robert Centa J.
Date: July 14, 2026
Footnotes
- Divorce Act, R.S.C. 1985, c. 3 (2nd Supp.), ss. 16(1) and (2).
- Barendregt v. Grebliunas, 2022 SCC 22, [2022] 1 S.C.R. 517, at para. 146, citing Divorce Act, ss. 16(3)(j) and (4).
- McBennett v. Danis, 2021 ONSC 3610, 57 R.F.L. (8th) 1, at para. 82; Goja v. Goja, 2026 ONSC 869, 28 R.F.L. (9th) 86, at para. 28.
- Divorce Act, s. 16(3)(e).
- Shokoufimogiman v. Bozorgi, 2022 ONSC 5057, at para. 32.
- Divorce Act, s. 16(3)(j).
- Divorce Act, s. 2(1), definition of “family violence.”
- Divorce Act, s. 16(4).
- Ahluwalia v. Ahluwalia, 2026 SCC 16, 29 R.F.L. (9th) 1, at para. 190.
- Ahluwalia, at para. 187.
- Sadiq v. Musa, 2023 ONSC 1811, 92 R.F.L. (8th) 468, at para. 22.
- R. v. Stirling, 2008 SCC 10, [2008] 1 S.C.R. 272, at para. 5.
- R. v. J.W., 2025 ONCA 637, 178 O.R. (3d) 358, at para. 57, leave to appeal to S.C.C. refused, 41987 (April 30, 2026).
- J.W., at para. 57, citing R. v. Khan, 2017 ONCA 114, 136 O.R. (3d) 520, at paras. 25-26, leave to appeal refused, [2017] S.C.C.A. No. 139.
- R. v. Picard, 2025 ONCA 417, 177 O.R. (3d) 496, at para. 65, citing R. v. S.K., 2019 ONCA 776, 148 O.R. (3d) 1, at para. 152.
- Douglas v. Douglas, 2021 ONSC 551, at para. 36.
- J.W., at para. 21.
- R. v. Kinamore, 2025 SCC 19, 503 D.L.R. (4th) 385, at para. 81.
- J.W., at para. 25.
- R. v. A.R.J.D., 2018 SCC 6, [2018] 1 S.C.R. 218, at para. 2.
- Divorce Act, s. 16(3)(k).
- Divorce Act, s. 16(4)(g).
- Divorce Act, ss. 16(3)(d), (g), and (h).
- Divorce Act, ss. 16(3)(b) and (c).
- Divorce Act, s. 16(3)(i).
- Hatab v. Abuhatab, 2022 ONSC 1560, 69 R.F.L. (8th) 18, at para. 39, citing Tovell v. Jamieson, 2017 ONSC 5079, at para. 40.
- Ontario Chapter of the Association of Family and Conciliation Courts (AFCC-Ontario), Parenting Plan Guide (Toronto: Ontario Chapter of the Association of Family and Conciliation Courts, 2020) (the “AFCC-O Guide”).
- Hatab, at para. 51.

