A Calderbank offer that does not protect the offeree against risks unrelated to the offeror's claim (such as the risk of a co-defendant's successful appeal) may be reasonably rejected. An offer that amounts to a demand to capitulate, offering no discount, will not ordinarily found an indemnity costs order. Claims against two defendants based on individual duties of care owed by each are not interdependent or alternative for the purposes of a Bullock or Sanderson order merely because some common facts underlie both claims.
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