In Launer v. Sommerfeld, Collins J. said that security would be required from a non-resident plaintiff in the ordinary case but would not be required in the exceptional case. I think that statement reflected one aspect of the guidelines at that time. But I also think that the revocation of the five rules as they existed before the 1976 change should be taken as an indication that the makers of the 1976 Rules were content to leave the question to depend on the inherent discretionary jurisdiction of the court, unfettered by any more or less rigid guidelines from the past.
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