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  • Using OCL report at motion stage....

    Hello All

    Just came across another fresh decision by Pazaratz J regarding using OCL report on motion stage in eve of the trial.

    Justice Pazaratz as always provided good analyses of both sides of the question.
    Here is the link:

    2012 ONSC 4696 (CanLII)

    I am sure Taken will provide detailed analysis of that particular decision.

    WD.

  • #2
    Originally posted by WorkingDAD View Post
    Hello All

    Just came across another fresh decision by Pazaratz J regarding using OCL report on motion stage in eve of the trial.

    Justice Pazaratz as always provided good analyses of both sides of the question.
    Here is the link:

    2012 ONSC 4696 (CanLII)

    I am sure Taken will provide detailed analysis of that particular decision.

    WD.
    With great pleasure too. So far favourite quote:

    19. There can be no presumption that an assessor’s recommendations will – or should -- inevitably prevail. The court cannot delegate decision-making authority to the assessor. Dunnett v. Punit 2006 CarswellOnt 7259 (O.C.J.). Beyond concerns about disrupting the existing status quo, the court must consider the potential impact of creating a new status quo on the eve of trial. Interim implementation of an assessor’s recommendations can be far from a benign stop-gap measure. It can affect the trial and its outcome.
    This is case law that all "custody and access" evaluators, lawyers and others should become intimately aware of.

    More details to follow.

    Good Luck!
    Tayken

    Comment


    • #3
      20. In some interim decisions courts have drawn a distinction between custody and access recommendations, more readily implementing assessor’s recommendations in relation to the latter. I prefer the analysis of Zisman J. in Benko (supra) in which she noted whether the issue is custody or access, the court should exercise great caution in relying on the untested observations and recommendations of an assessor.
      Just so many excellent observations on custody and access evaluations in this one.

      Comment


      • #4
        Notable though is that the judge referenced facts and observations from the report. Conclusions, opinions, recommendations were set aside to be examined at trial.

        The motion decision was strongly based on incidents from the report. As such, it is certainly worth bringing forward such a report.

        The applicant in this case appears to be a train wreck; something here that I see frequently is that her case suffered considerably by not providing complete information or a parenting plan. Whether it would have changed things or not, always always always address every issue in your case; don't leave things unanswered.

        Comment


        • #5
          Originally posted by Mess View Post
          Notable though is that the judge referenced facts and observations from the report. Conclusions, opinions, recommendations were set aside to be examined at trial.

          The motion decision was strongly based on incidents from the report. As such, it is certainly worth bringing forward such a report.

          The applicant in this case appears to be a train wreck; something here that I see frequently is that her case suffered considerably by not providing complete information or a parenting plan. Whether it would have changed things or not, always always always address every issue in your case; don't leave things unanswered.
          I think key part here that parties admit what OCL said in that particular area...

          36. The arrival of the s. 112 report does not in itself constitute a material change in circumstances. But the observations, situations, and worsening problems reported by the clinical investigator constitute new and troubling information. Notably, many of these ongoing problems are confirmed by the parties themselves.

          37. While caution is required, the court cannot ignore:

          a. The Applicant’s continuing problems organizing and prioritizing the children’s lives.
          b. Her completely uncertain residential plans.
          c. Her vague and unsatisfactory explanation about leaving the children unattended overnight on June 3, 2012 -- in the context of ongoing complaints about a pattern of neglect.
          d. The Applicant’s conspicuous failure to provide reassurance that she has adequately addressed employment and child-care issues.
          e. The reality that – on consent – the children will now be attending school in the Respondent’s district.
          f. The obvious benefit to the children of bringing structure and security to their situation in time for the start of the new school year.
          g. The virtual certainty that the “alternating week” status quo will eventually come to an end – no later than the November trial – based on universal comments by the Applicant, the Respondent and the clinical investigator that this arrangement is jeopardizing the emotional well being of the children.
          I am pretty sure if that would be just report order would be different... I should agree with you Mess that applicant in this case is total train wreck and she basically killed her case by her own conduct. And lets not oversee what impact lies on part of the Applicant had on judges's decision...

          Comment


          • #6
            Originally posted by Mess View Post
            Notable though is that the judge referenced facts and observations from the report. Conclusions, opinions, recommendations were set aside to be examined at trial.
            Actually, they were "untested observations" and not "facts" per-say. The only fact referenced was that both parents are causing the issue.

            Originally posted by Mess View Post
            The motion decision was strongly based on incidents from the report. As such, it is certainly worth bringing forward such a report.
            It will be interesting to see how this one unfolds at trial under proper examination and what "assumptions" the OCL report is based on that are untested.

            Originally posted by Mess View Post
            The applicant in this case appears to be a train wreck; something here that I see frequently is that her case suffered considerably by not providing complete information or a parenting plan. Whether it would have changed things or not, always always always address every issue in your case; don't leave things unanswered.
            Often, when facing Section 30/OCL you don't know what is "unanswered" until the final report comes through. This is why they have to be tested at trial and not decided "final" on motion. They generally contain more hearsay than "facts" to the matter.

            Many parents try to "win on motion" without thinking about the larger picture that all matters are either settled final on "consent" or at trial without consent. Motions are just a step to trial...

            This is the saddest quote to have to read in the decision:

            The virtual certainty that the “alternating week” status quo will eventually come to an end – no later than the November trial – based on universal comments by the Applicant, the Respondent and the clinical investigator that this arrangement is jeopardizing the emotional well being of the children.
            What parents don't realize that all their hearsay, allegations and "one-upping" the other just demonstrates to the court that "status quo will eventually come to an end" at trial, based on their own conduct before the court.

            Good Luck!
            Tayken
            Last edited by Tayken; 09-04-2012, 06:58 PM.

            Comment


            • #7
              Well, with due respect, the judge identified the following points from the report that he considered relevant to his decision:
              28. In this case the OCL’s s. 112 report is detailed and troubling. It includes information from the parents, the children, and numerous collateral sources including CAS, the police, health care providers and educators. I am mindful that many of the facts are contentious, and the author’s conclusions and recommendations are untested.

              29. However, there are observations and undisputed facts within the report which – combined with the evidence of the parties themselves – highlight the need for immediate intervention to address urgent issues.

              30. The most pressing issue is a fundamental concern about the children’s safety while in the care of the Applicant mother:

              a. The Applicant is a single mother who, at various times, has had to work evenings or overnights.
              b. The Respondent has repeatedly expressed concern the Applicant leaves the children unattended for extended periods, including up to four hours after school each day.
              c. The children have confirmed much of what the Respondent says.
              d. At a disclosure meeting on May 11, 2012 the clinical investigator advised the parties her recommendation was going to be a continuation of the equal time sharing arrangement. While the OCL had many concerns about the Applicant, the investigator was also mindful of the long history of the children having resided primarily in the Applicant’s care.
              e. However, at the disclosure meeting the clinical investigator clearly and repeatedly advised the Applicant that she was never to leave the children alone under any circumstances.
              f. Less than a month later –before the final s. 112 report was released – the same issue dramatically arose once again.
              g. On the evening of Sunday June 3, 2012, the Applicant initially called the Respondent advising she was working that evening and asked him to keep the girls overnight and take them to school in the morning. However, the Applicant then changed her mind, and picked up the children, advising they would be left with their aunt for the night.
              h. The Applicant ended up taking the children home and leaving them unattended while she went to work overnight. (She later explained she fell asleep and when she woke up she hurried to her workplace and forgot she hadn’t called her sister to care for the children.)
              i. The police became involved, and the children were found home alone after midnight. When the police contacted the Applicant at work she attempted to deceive them, advising that the children were safe with her sister. She hurried home attempting to rectify the problem, not realizing the police were already at the house with the children.
              j. The Applicant has now been charged under the CFSA for leaving the children alone.
              k. The Applicant’s reply materials on this motion gloss over the incident – and the apparent recurring problem of her leaving the children unattended.
              l. The Applicant’s affidavit offers no explanation or reassurance this same problem will not arise again. She has provided no information about her employment, her work hours, or child care arrangements.
              m. She has shown no insight about the danger of leaving young girls alone for extended periods, notwithstanding the Respondent’s repeated complaints about this – and notwithstanding the OCL social worker’s very specific admonition on the topic.
              n. The Applicant’s efforts to deceive the police that evening are even more troubling in the context of other evidence the Applicant has also lied to CAS and to the OCL about similar problems.
              o. Following the June 3, 2012 incident, the OCL changed its position: Alternating weeks are no longer recommended. Instead, the OCL suggests the Respondent’s time should increase, primarily during weekdays (which coincides with the OCL’s separate recommendation the Respondent should have decision making over children’s issues such as education). The Applicant’s blocks of time should be decreased, and focus on weekends, to reduce her need for child care.

              31. The OCL clinical investigator expressed other serious concerns:
              a. The Applicant’s decision on June 3, 2012 to leave the children home alone rather than allow them to spend an extra overnight with the Respondent reflects a broader concern about ongoing parental alienation by the mother.
              b. The Applicant openly states she believes the Respondent has nothing to offer the children, and everyone would be better off if the Respondent was simply out of their lives. She feels he is a terrible person and blames him for everything bad in her life.
              c. The clinical investigator expressed concern the Applicant is making it difficult for the children to feel free to love their father without emotional consequences from their mother. And the equal time sharing arrangement (combined with daily phone calls) gives the mother significant opportunity to undermine the children’s relationship with their father.
              d. Both parents say the week about arrangement is very disruptive for the children.
              e. Alternating weeks requires ongoing communication and co-ordination between parents. But the Applicant and the Respondent don’t communicate at all. They don’t trust each other. They can’t work together. Necessary information is not efficiently conveyed back and forth between households.
              f. The Applicant lied about a taped telephone conversation in which she pressured one of the children to talk privately, quietly, and keep secrets from the Respondent.
              g. The Applicant has lied to school authorities about the Respondent, and has interfered with the Respondent’s ability to monitor and be involved with the girls’ ongoing educational issues. The Respondent has been more consistent and effective in dealing with their school.
              h. While the Applicant emphasizes that CAS has no concerns about her, the OCL investigator feels “CAS is heavily reliant upon Ms. J.L.M.’s willingness to be forthcoming with them.” The OCL questions whether the Applicant has been any more honest with CAS than she has been with other service providers. A CAS letter dated June 26, 2012 described the Applicant as cooperative, and stated there are “no protection concerns” in relation to either parent.
              In his paragraphs 18-27 he details the circumstances and reasons when an assessment should be considered pre-trial, in order to explain and justify his inclusion of the details that follow. Again I absolute agree that the justice rejects inclusion of the recommendations, however he is absolutely allowing the details of the report to influence his decision, otherwise we wouldn't see them included in the decision.

              I don't see that this decision suggests that it is a waste to try include an assessment at a motion hearing. It suggests specific ways it should be used, to support fact, and ways not, to provide professional opinion.

              Comment


              • #8
                Originally posted by Mess View Post
                Well, with due respect, the judge identified the following points from the report that he considered relevant to his decision:


                In his paragraphs 18-27 he details the circumstances and reasons when an assessment should be considered pre-trial, in order to explain and justify his inclusion of the details that follow. Again I absolute agree that the justice rejects inclusion of the recommendations, however he is absolutely allowing the details of the report to influence his decision, otherwise we wouldn't see them included in the decision.

                I don't see that this decision suggests that it is a waste to try include an assessment at a motion hearing. It suggests specific ways it should be used, to support fact, and ways not, to provide professional opinion.
                I may be wrong ofcourse but as I read it the key is here

                29. However, there are observations and undisputed facts within the report which – combined with the evidence of the parties themselves – highlight the need for immediate intervention to address urgent issues.

                Comment


                • #9
                  28. In this case the OCL’s s. 112 report is detailed and troubling. It includes information from the parents, the children, and numerous collateral sources including CAS, the police, health care providers and educators. I am mindful that many of the facts are contentious, and the author’s conclusions and recommendations are untested.

                  29. However, there are observations and undisputed facts within the report which – combined with the evidence of the parties themselves – highlight the need for immediate intervention to address urgent issues.
                  All "observations" and "undisputed facts" will be heard at trial for final decision. The OCL report was not "FINAL" nor does the motion end the matter and it will be interesting to see how the OCL report when cross examined by both parties tests the "evidence".

                  Key point to note: The judge does not refer to the "OCL Report" as "evidence". But, as "observations" and "undisputed facts".

                  The argument isn't that the report was useful in helping the judge evaluate the "evidence of the parties" but, the determining factor was the parties own conduct before the courts and not necessarily the OCL's "report". Nor was the OCL investigator called to be cross examined.

                  The "immediate" needs of the children involved were identified and decided upon "without consent" (to quote the judge) but, a trial can overturn the whole order resulting from this motion. In this matter in particular it may be difficult as the conduct of one parent does shine through.

                  Very interesting that the order is split on what was ordered "on consent" and what was ordered "without consent" on a temporary basis.

                  All the evidence for which the decision was based on was parental conduct which was probably the "evidence of the parties themselves" for which the determination was made on affidavit evidence:

                  37. While caution is required, the court cannot ignore:

                  a. The Applicant’s continuing problems organizing and prioritizing the children’s lives.
                  b. Her completely uncertain residential plans.
                  c. Her vague and unsatisfactory explanation about leaving the children unattended overnight on June 3, 2012 -- in the context of ongoing complaints about a pattern of neglect.
                  d. The Applicant’s conspicuous failure to provide reassurance that she has adequately addressed employment and child-care issues.
                  e. The reality that – on consent – the children will now be attending school in the Respondent’s district.
                  f. The obvious benefit to the children of bringing structure and security to their situation in time for the start of the new school year.
                  g. The virtual certainty that the “alternating week” status quo will eventually come to an end – no later than the November trial – based on universal comments by the Applicant, the Respondent and the clinical investigator that this arrangement is jeopardizing the emotional well being of the children.
                  From this point forward the parent in question has one and only one option. Address items a through g or be an every other weekend.

                  Note the use of "universal comments" versus "universal evidence" in (g). Yes I am nit picking but, when reviewing case law the details of every word matters as if there is one mistake, error in law, etc... An appeal can be forthcoming. What I find interesting with the orders put forward by Justice Pazaratz is the incredible level of detail he puts in separating "observations" from "evidence" and relying upon that which is truly evidence before the court and only using OCL reports as a guide and not "fact" until tested at trial and reminds everyone of this in the decision.

                  Not trying to argue the OCL report is "useless" but, that it is as the judge clearly identifies "untested" and the only place to properly test evidence at this point and a report is... Unfortunately, at trial and with an order like this unless the other parent runs out of money (but I suspect has LAO certificate) this matter will go to trial.

                  Will the trial decision be different than this motion? Can't predict that one... We all know how trials can change the tide of "status quo" right WorkingDad?

                  Weight was given to the OCL report but, as observations. The decision in this motion was based on affidavit evidence and oral examination. The report played into it but, considering the matters it was decided upon, I am doubtful that the OCL report brought any of the cogent and relevant evidence forward as "new evidence" that the party applying for the motion didn't already have and couldn't have already gotten on motion without an OCL report.

                  Note the "her" or "Applicant" which forms the basis of the order. (a) through (e) are all based on the Applicant's own conduct. (f) is an application of CLRA "best interests" and (g) emphasizes the fact that the court as defined in case law will not order joint custody in this matter and the threshold for "parallel parent" based on the Applicant's conduct has destroyed that opportunity for these children too.

                  All of which is completely unfortunate because the patterns of behaviour outlined in this order will probably only escalate after trial as the Applicant tries to regain control of her "property" (children) from the Respondent.

                  Again, another Bruni v. Bruni situation where one (or both) of the litigants in this matter may be exhibiting a personality disorder that with treatment could solve more problems than the court could ever do in an order. But, alas the court cannot order a parent to go get proper help that isn't "litigation". This just highlights the need for real clinical intervention in Family Law. The Applicant possibly has significant mental health issues but, the court is left powerless to truly help these children other than eliminating one of the parents. Very sad considering we live in a country with universal health care but, we cannot force someone to seek help. Even after this order I highly doubt that the Applicant will do the right thing, seek help and demonstrate to the court that they can be a parent.

                  Avoidance of one's own personal issues and the projection of blame will only continue in this matter after the trial.

                  Good Luck!
                  Tayken
                  Last edited by Tayken; 09-05-2012, 07:14 AM.

                  Comment


                  • #10
                    h. While the Applicant emphasizes that CAS has no concerns about her, the OCL investigator feels “CAS is heavily reliant upon Ms. J.L.M.’s willingness to be forthcoming with them.” The OCL questions whether the Applicant has been any more honest with CAS than she has been with other service providers. A CAS letter dated June 26, 2012 described the Applicant as cooperative, and stated there are “no protection concerns” in relation to either parent.
                    This is what drives me completely bonkers with the "clinicians" (social workers) who are in the OCL, CAS and do Section 30 evaluations!

                    One governing body says no problem, the other body says there is a problem. This just highlights the need (which I bitch about) for clinical standards in evaluating parental neglect/maltreatment/abuse.

                    How can CAS say everything is fine and OCL say the opposite? Where does the accountability lie in how these clinicians conduct their "clinical practices"?

                    )*#($*#(!

                    Ombudsman where are you?

                    Good Luck!
                    Tayken

                    Comment


                    • #11
                      Originally posted by Mess View Post
                      I don't see that this decision suggests that it is a waste to try include an assessment at a motion hearing. It suggests specific ways it should be used, to support fact, and ways not, to provide professional opinion.
                      See my other post about the "facts" for which the decision was made on above.

                      With regards to the "waste", what I am refering to is the broader approach that many solicitors take with OCL reports and trying to "win" final orders or upset status quo with these reports prior to trial to gain an advantage.

                      In this matter, the immediate protection needs of the children based on the Applicant's conduct and evidence was the major factor. What I am referring to is the numerous motions going before the court every day in which motions are being made to have the report implemented as fact.

                      Some justices take the reports as "fact" and just simply order as-is on motion. Justice Pazaratz does the exact opposite and carefully balances the evidence and although the report highlights issues, the evidence for determining the decision is that of the Applicant's own conduct, evidence and evidence of the Respondent.

                      This case law, defines the requirements for pre-trial use of "reports" and sets a very strong threshold of "protective concerns" and wraps it all up into a nice tight ball for which sets the criteria when a report could even be considered on motion prior to trial.

                      Previously, the materials were scattered in case law and now litigants (and their lawyers) have a powerful template to dispute frivolous motions which happen more often before the court than examples like this one where by there is an actual and immediate need prior to trial.

                      The "mindfulness" of Justice Prazaratz in this posted decision will be echoed further as it is put into BOA's to demonstrate the "broad agreement in the cases (cited in this decision) that motions for interim implementation of assessment reports should be discouraged" and that, "parties should not perceive the arrival of an assessment report as creating an automatic strategic opportunity to secure a more favorable status quo, heading into trial."

                      Which, in general Mess is the primary objective of these motions with "reports" attached to them generally. This may not be the case in this particular matter and this is why the detailed analysis was done. Hopefully, this case law will curb some of the wasted time before the courts for which there are more and more of every day and demonstrate to solicitors and litigants what really matters on motion.

                      Good Luck!
                      Tayken

                      Comment


                      • #12
                        Originally posted by WorkingDAD View Post
                        I may be wrong ofcourse but as I read it the key is here
                        I don't see how we are contradicting each other. The assessment and the statements of the of the parties are in agreement on some matters. That gives additional weight to those facts.

                        I don't see anywhere in the decision where the judge rejected facts in the assessment because they weren't supported by the parties' statements or were in dispute.

                        Just because some details in the assessment were confirmed by the parties doesn't mean that those details would have been rejected if they had stood on their own.

                        Again, the judge gives extensive reasons and case law to support accepting the factual observations of the report, but not the opinions of the assessor.

                        And again, you would not see the report extensivelly quoted in the judge's decision if were being dissmissed as inadmissible or irrelevant.

                        Comment


                        • #13
                          Originally posted by Mess View Post
                          I don't see how we are contradicting each other. The assessment and the statements of the of the parties are in agreement on some matters. That gives additional weight to those facts.
                          But the facts stand on their own and are demonstrated not solely in the opinions of the custody and access evaluator. That is the key differentiating point of this case law from others that go unreported.

                          Originally posted by Mess View Post
                          I don't see anywhere in the decision where the judge rejected facts in the assessment because they weren't supported by the parties' statements or were in dispute.
                          Cautious approach and points to trial being the final place for matters to be determined. That is the key element. No one "won" on motion really and the report was more "icing" than the deciding factor. Conduct, which is confirmed in other evidence was the deciding factor. Not the OCL report's "recommendations".

                          Originally posted by Mess View Post
                          Just because some details in the assessment were confirmed by the parties doesn't mean that those details would have been rejected if they had stood on their own.
                          Exactly. But, on the opposite, if the parties had disputed the "details" of the report but, the evidence (even without the report) in my opinion stands on its own.

                          Originally posted by Mess View Post
                          Again, the judge gives extensive reasons and case law to support accepting the factual observations of the report, but not the opinions of the assessor.
                          I don't think that leaving kids home alone is a "factual observation" at all. It is a fact and the source of the "fact" isn't solely from the OCL report. It is supported by the Applicant's own testimony to the truth which had way more weight in the decision.

                          Originally posted by Mess View Post
                          And again, you would not see the report extensivelly quoted in the judge's decision if were being dissmissed as inadmissible or irrelevant.
                          Not suggesting it is "inadmissible or irrelevant". That the evidence outweighs "opinions" and "assumptions" which the vast majority of these reports depend on.

                          Leaving a child home alone at that age. With or without OCL report is a serious issue.

                          The challenge is the "white washing" that happens in many court rooms on motion with these reports. It is great that Justice Pazaratz doesn't just do the "OCL report" check mark on orders. More justices will be compelled now to do a detailed analysis on motion or move the matter to trial faster if it doesn't meet the criteria for an "emergency" for which the Respondent met when bringing forward this motion.

                          This addresses the "truism" that judges always order what the OCL recommends by default without considering the supporting evidence. The decision in this matter was not based solely on the OCL report which is a change in direction against this "truism" that is often recanted by OCL reporters and Section 30 alike...

                          Although in this matter, it didn't help the Applicant but, the case law to help others who are dragged before the court with junk OCL reports as the "only evidence" and try to pitch it as "fact". Clearly the opinions of "experts" and the reports they produce are going to have to meet a high level of standard which, in the past, as demonstrated by WorkingDad, have not been doing.

                          Call me an optimist but, I still feel that the Applicant, should the proper help be provided and accept that help, to improve her situation in the best interests of the children that a better outcome could be found for the children involved. It is a shame that we have a publicly funded health care system and parents don't leverage this opportunity to improve themselves for the sake of their children.

                          With the CAS being crown ward to the other child of the Applicant it is a shame that the courts are left powerless (my opinion) to help this person. I still believe that there are better ways to help this family transition. But, alas you can only lead a horse to water... You can't make it drink.

                          Good Luck!
                          Tayken
                          Last edited by Tayken; 09-05-2012, 10:57 AM.

                          Comment


                          • #14
                            It is my opinion, perhaps a misguided one as I'm not a legal expert, that when the OCL is ordered by a judge, it generally is on the basis of the conduct of one or both parents in the courtroom. The OCL is provided with all documentation filed with the court for a reason and, part of their assessment is to understand the drama that is taking place in the case and how it is impacting the child/ren.

                            Keep in mind that the few minutes the "evidence" is in front of a judge can be misrepresented too to gain a favourable result for that party, especially when there are children involved.

                            If there are legitimate concerns filed with the court, then a good and experienced assessor would indicate them in their report to support one party's evidence. On the reverse, "bashing" the other parent with repeating *cough* said "concerns" in motion material can certainly raise an assessor's suspicions, concluding the allegations are not in the best interests of the children, depending on the severity of those allegations and the legal outcome on the receiving party that is impacting the child/ren. They're intertwined.

                            Collateral choices in a child / custody assessment are also very important. A list of friends and family are "nice." Greater weight is likely placed on professional collateral in the assessor's conclusions.

                            In my case, the judge was intent X and I understood that he would be looking at the list of collaterals and not necessarily the overall assessment. With this in mind, I thought long and hard about who my collaterals were going to be. I suspected that Xs allegations would be a part of the investigation and I was right.

                            WorkingDad and Tayken each had great points. Although I found WorkingDad to point out the positive in the judge's remarks, I found Tayken to primarily point out the negative in the judge's remarks (with great attention to detail!). While I agree with some of Tayken's points for obvious reasons, they're almost presented as though a custody / access assessment is futile in family law.

                            So a 90-day investigation to only get an "opinion"?

                            What's the point of going through an assessment then?

                            Wouldn't it be at least an "expert" opinion?

                            When can it be "used"? How?

                            How compelling does the evidence have to be with the support of a report before things move along a bit better?

                            Comment


                            • #15
                              Recent Examples

                              Has anyone seen more recent cases where this principle has been tested by Ontario courts?

                              Specifically, because of the pandemic, there are significant delays in the completion of assessment and in reaching trial. Are there any cases where Judges have made interim changes to Orders ahead of trial?

                              Comment

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