In what circumstances will a plaintiff not disclose the amount of a settlement made before trial?

Ontario, Canada

The following excerpt is from Laudon v. Roberts, 2009 ONCA 383 (CanLII):

In Holmes v. Hanna, [2001] BCSC 1228 at para. 26 in relation to the amount of a settlement made among the plaintiff and three of five defendants before trial, the court noted that the plaintiff was right not to disclose the amount of the settlement at that point, but he should have asked that consideration of the deduction issue be deferred, until after liability had been apportioned, and damages assessed. In my view, that is the proper time to resolve this issue.

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