What is the best way to calculate a percentage discount to an award for mitigation earnings?

The plaintiff favours the trust and accounting approach as applied in Paquette v. TeraGo and Drysdale v. Panasonic as it would accurately reflect the mitigation earnings. As of today there is approximately 15 months in the notice period. Counsel submits that to impose a percentage discount to the award at this point would be quite speculative. I agree.

In Thomson v. Bechtel Canada Ltd. (1983), 3 C.C.E.L. 16, at p. 23 Osborne J. observed: The contingency of new employment within the notice period could be somewhat speculatively assessed and imposed upon the notice period to reduce it. In the circumstances of this case, I think it preferable to impose upon the plaintiff a trust, whereby any earnings of the plaintiff until the expiry of the 11 month notice period will be impressed with a trust in favour of the defendant. I am satisfied that the plaintiff has endeavoured to obtain employment throughout and that he will continue with his sincere endeavours to obtain employment.