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Presentation - Costs. Zbogar v. Dhall
In Zbogar v. Dhall (Div Ct, 2020) the Divisional Court set out the test for cost awards for presenting parties:[4] Fong v. Chan, 1999 CanLII 2052 (ON CA), provides that that costs should only be awarded to a self-represented litigant who can demonstrate that they devoted time and effort to do the work ordinarily done by a lawyer retained to conduct the litigation and that the work done by them resulted in a loss by forgoing remunerative activity. The Divisional Court in Mustang Investigations v. Ironside 2010 ONSC 3444 confirmed that Fong remains good law. . Di Geso v. Pascoe
In Di Geso v. Pascoe (Div Ct, 2022) the Divisional Court extensively considered costs awarded to presenting parties.
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