In making that determination, a court must avoid reference to the desired “outcomes” or “goals” in place of the requisite standard of care. The analysis ought to focus on the means, or the efforts that ought to be made by a reasonable solicitor, as opposed to the results they ultimately achieved. (Fullowka v. Pinkerton’s of Canada Ltd., 2010 SCC 5,  1 S.C.R. 132 at para. 80)
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