The case applies established principles on security for costs on appeal, confirming that an appellant's consistent failure to pay substantial costs orders (here over $390,000), combined with poor prospects of success and absence of material unencumbered assets, will generally warrant an order for security. An appellant's interest in disputed partnership assets does not constitute sufficient assets to resist a security application. Where the primary decision is interlocutory and leave to appeal has not been sought, this significantly undermines the prospects of success for the purpose of a security application.
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