By definition, a court's assessment of future economic loss is, as Doherty, J.A., observed in Graham v. Rourke, "a somewhat speculative exercise" (at p. 634). What were the plaintiff's prospects for employment in the future? What were her personal circumstances likely to be? What were the risks that the future holds either generally or specifically for the individual claimant? The less certainty with respect to the plaintiff's future prospects or the greater the risk, the more likely it will be that a contingency allowance of some kind either general or specific will be required. In the end, "all reasonable possibilities" should be taken into consideration in determining whether a contingency allowance should be ordered (Graham v. Rourke, at p. 640).
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