Where security for costs has been voluntarily provided rather than court-ordered, UCPR r 675 is not directly engaged, but the voluntary provision is relevant to the discretion. A corporate plaintiff trustee that has distributed trust assets to unit holders must demonstrate that the unit holders who stand behind it are also without means to resist a stultification argument. The introduction of entirely new heads of claim after security arrangements are agreed constitutes a material change in circumstances justifying further security.
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