the husband’s net professional income was $176,868 and his line
150 income was $329,106.
(m) The wife’s circumstances at the time of the change
 The motion judge found that the wife earned approximately $27,000 in 2012; approximately $25,000 in 2013; and
that her May 2014 financial statement reflected earnings of
less than $600 per month. The wife had not re-partnered and,
as indicated above, was apparently experiencing certain health
 The wife also had financial problems. Following the separation, she purchased a two-storey, four-bedroom house for
$442,000. To finance the house, she used her equalization payment and also obtained a mortgage for $287,300 at an interest
rate of prime less 0.6 per cent. In May 2012, she obtained a new
mortgage from the Royal Bank under which she could borrow up
to $350,000 at a rate of prime plus 7 per cent. She had two lines
of credit totalling almost $100,000, credit card debts totalling
over $10,000 and unpaid income and property taxes of approximately $10,000. Despite these issues, her financial statement
indicated she had ten cats and five dogs costing approximately
$755 per month to maintain.
(n) The parties’ positions on the change motion
( i) Submissions at the conclusion of the October 21-
22, 2014 hearing
 In oral submissions at the conclusion of the October 21-22,
2014 hearing, the wife’s counsel sought support at the high end
of the Guidelines range based on Mr. Norton’s alternate proposal, namely, that $49,865.56 per year should be imputed to
the husband on account of unequalized pension income prior to
August 1, 2024, and $43,220.33 per year thereafter.
 The husband’s counsel acknowledged that two of the
factors as identified in the appendix to the second DSW report
could be considered on the motion to change spousal support,
namely, increases in pension value due to pre- and post-separation service and retirement age earlier than assumed.
 The husband’s counsel asked that the value of the unequalized portion of the pension be fixed at $469,500: one-half of the
increased value of the pension attributable to early retirement in
the appendix to the second DSW report ($433,000 ÷ 2 = $216,500)