(c) The named party is a person of straw put forward to protect the true
litigant from liability for costs.10
 The non-parties in this case, namely, Manny and Joe Marcos, submit the issue is not whether a non-party engaged in misconduct serious enough to amount to abuse of the court’s
processes, but rather it is a factual inquiry as to whether the
party of record is only a “formal” or “ostensible” litigant and
whether the non-party is the “real” or “substantial” litigant, controlling the proceedings and advancing the named party for the
purpose of deflecting liability for costs.
 The Ontario Court of Appeal in Laval has acknowledged
that the “person of straw” test is to be considered in any assessment of whether it is appropriate to order non-party costs pursuant to s. 131(1) of the CJA.11 In the same case, however, the court
also states that “Superior courts of record have inherent jurisdiction to control their own processes and protect them from abuse”,
and that while inherent jurisdiction must be exercised “sparingly
and with caution”. “The language of s. 131(1) of the CJA does not
exclude inherent jurisdiction to order costs against a non-party
who commits an abuse of process. It is ‘permissive’ in that it confers broad discretion to make costs orders”, and to consider “any
other matter relevant to the question of costs”.12
 While there is much evidence to support the finding that it
was Manny who was the perpetrator of the egregious conduct referenced in the decision in this case, there is no evidence to support a finding that Marcos was named plaintiff and utilized solely
for the purpose of insulating Manny or his brother Joe from
potential costs liability. There’s also no evidence to suggest
Marcos is a shell company with no exigible assets available to satisfy a judgment or that Marcos is not a going concern.
 With respect to Joe Marcos, the evidence does not satisfy
a finding that the plaintiff corporation was advanced to shield
Joe from personal liability for costs. Also, his involvement in
this action was not nearly to the same degree as the misconduct
which occurred on the part of Manny in the conduct of this
litigation. Although there is evidence of dishonesty on the part
of Joe as it relates to his taxes and financial dealings, on the
10 Supra, at paras. 59 and 60.
11 Ibid., at para 59.
12 Ibid., at paras. 65 to 69.