The onus is on the plaintiff to establish a real and substantial possibility that they will not be able to perform all of their usual and necessary household services in the future. Further, the plaintiff must show that they will be forced to hire someone to perform such services or have someone perform such services gratuitously: Menhinick v. Lobsez, 2008 BCSC 1285, B.C.J. No. 1824 at para. 55.
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