Christie v. Dickson

The court ordered production of the requested corporate records to the extent they relate to the respondent because the records are trial relevant to property division and spousal support, are discoverable corporate records, and the burden of production is proportional; confidentiality measures protect privacy; an issue raised after the hearing (securities register) was not decided.

Citation: 2026 NSSC 87
Parties: Petitioner: Shannon Christie; Respondent: Craig Dickson
Court: Supreme Court of Nova Scotia
Jurisdiction: Canada
Judgment Date: 23 March 2026
Procedural Posture: Family Law Disclosure Motion / Pre Trial Disclosure Motion
Outcome: Disclosure order granted in part between the parties; motion resolved; no costs awarded
Legal Topics: Disclosure Orders, Non Party Production, Discovery, Property Division, Spousal Support, Corporate Records
Source Language: English

Family Law Civil Procedure Corporate Law Evidence Disclosure Orders Non Party Production Discovery Property Division +2 more

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Full judgment text Legal principles 6 Authorities cited 5 Party arguments 2 Amounts and remedies 1

Parties

Shannon Christie

Petitioner

Craig Dickson

Respondent

Procedural Posture

Family Law Disclosure Motion / Pre Trial Disclosure Motion

Legal Issues

1 Whether applicant proved entitlement to disclosure order against respondent
2 Whether specific corporate records are trial relevant and proportional to require production
3 Whether privacy and proportionality considerations outweigh disclosure

Ratio Decidendi

Court Disposition

Disclosure order granted in part between the parties; motion resolved; no costs awarded

Orders

Produce shareholder registers relating to Craig Dickson from 2013 to date
Produce the Pinchin Topco Limited Partnership Agreement from the 2022 Pinchin/Keystone acquisition