Is a self-represented lay litigant entitled to a per diem award for time devoted to preparing and presenting a case?
Ontario, Canada
The following excerpt is from Geremia v. Harb, 2008 CanLII 19764 (ON SC):
[75] “. . . a self-represented lay litigant should receive only a ‘moderate’ or ‘reasonable’ allowance for the loss of time devoted to preparing and presenting the case. This excludes routine awards on a per diem basis to litigants who would ordinarily be in attendance at court in any event”: see Fong v. Chan, ibid.
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