What is the test for close proximity to a trial?

Ontario, Canada


The following excerpt is from Lalonde v. Lalonde, 2021 ONCJ 117 (CanLII):

[20] Close is not good enough to attract the costs consequences of 18 (14). The offer must be as good as or more favourable than the trial result. See: Gurley v. Gurley, 2013 ONCJ 482. 2.4 Other factors affecting costs orders

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