Pirani v. Esmail, 2014 ONCA 279
 In my view the appropriate amount of costs lies somewhere between the submissions of the two parties. As explained by this court in Fong v. Chan (1999),46 O.R. (3d) 330 (C.A.), lawyers who represent themselves in a lawsuit are entitled to costs. Self-represented litigants, however,
be they legally trained or not, are not entitled to costs calculated on the same basis as those of the litigant who retains counsel. … Costs should only be awarded to those lay litigants who can demonstrate that they devoted time and effort to do the work ordinarily done by a lawyer retained to conduct the litigation and that, as a result, they incurred an opportunity cost by forgoing remunerative activity.