Confirms that an unconditional personal undertaking to the Court by the individual standing behind a corporate trustee plaintiff remains a 'very powerful consideration' that can be determinative against ordering security for costs, even where the trust's financial position is uncertain and the undertaking need not include a promise not to further encumber assets. Practitioners resisting security applications for trustee plaintiffs should proffer such undertakings early and unconditionally, supported by at least some evidence of net assets.
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