UCPR r 20.26 does not apply to offers of compromise made during appeal proceedings because the necessary recrafting of trial rules into the appeal context goes beyond Part 51, r 3(2). Where an appeal is successful and damages are remitted, costs of the appeal should ordinarily follow the event and not be reserved pending the damages assessment, even where offers of compromise have been made. A successful appellant may be ordered to pay costs of an unsuccessful cross-appeal against a third party where the appellant's failure to make a timely concession rendered the joinder of that third party reasonable.
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