In what circumstances will a contemnor be ordered to pay substantial indemnity costs?

In Einstoss v. Starkman, 2003 Canlii 2304, Justice Laforme, sitting as he was as a judge of this court, ordered a contemnor to pay costs on a substantial indemnity basis after reviewing the authorities that recognized contempt as a basis for awarding costs on that scale. Justice Laforme began his analysis by recognizing circumstances where substantial indemnity costs are warranted: 1) That substantial indemnity costs as opposed to partial indemnity costs will only be awarded in rare and exceptional cases; 2) Where the acts of a defendant are a deliberate attempt to frustrate the proceedings by fraud or deception; where the conduct of the defendant is calculated to harm the plaintiff; or where the unreasonable conduct of the defendant compounds the complexity of the proceedings.