Sharing the same concern, I decline to follow a lost opportunity approach to the extent it is tied directly to the income of the respondent. Even if I am incorrect, I have no sworn evidence of the respondent’s income on which to conduct this form of assessment. I note that while some courts have required evidence of lost opportunity when assessing the bill of a self-represented litigant, others have cautioned that requiring it creates a danger that assessments would become “trials about costs”: Cohlmeyer v. Ffrench, 2012 ONSC 929 at para. 13, Dechant v. Stevens, 2001 ABCA 81 at para. 19, leave refused  3 S.C.R. vi.
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