Security for costs may be ordered against a natural person plaintiff under r 671(h) UCPR where the person has evidenced an intention to use litigation oppressively, has boasted of impecuniosity and third-party funding designed to avoid costs exposure, and has failed to comply with procedural obligations. A personal undertaking to pay costs will not be treated as valuable where the evidence shows the person has no substantial assets and has adopted a cynical approach to the litigation.
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