What is the test for making an award of costs against a lawyer personally?
British Columbia, Canada
The following excerpt is from Bassett v Magee, 2018 BCSC 2322 (CanLII):
In the context of making an award of costs against a lawyer personally, in 1985 Sawridge Trust v. Alberta (Public Trustee), 2017 ABQB 530, the court commented on various means of the court controlling litigation and lawyers. At para. 56, the court held:
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