A Calderbank offer that is generous, made early in proceedings, clearly expressed, and allows adequate time for consideration will support an order for indemnity costs from the date of its expiry if unreasonably rejected. A sole director who is the 'real party' behind a corporate litigant may be ordered to personally pay costs, particularly where the director has previously offered to guarantee costs and has been afforded but has not taken the opportunity to resist the order.
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