decision and propose to resolve costs by including resolution of
the account assessment issue which is yet to be determined.
 As to the format of the bill of costs, there is no requirement that it coincide with the form 57B Costs Outline including
the lawyer’s certificate. The two are different documents and
I find no fault with the format used by the respondent.
 The key question for decision is the impact of the respondent’s self-represented status on entitlement to costs.
 In the Ontario Court of Appeal decision of Fong v. Chan
(1999), 46 O.R. (3d) 330,  O.J. No. 4600 (C.A.), at para. 26,
the court determined that self-represented parties, be they
lawyers or lay litigants, should be on the same footing. They
should not recover costs for the time and effort that any litigant
would have devoted to the case. This is because all litigants suffer
a loss of time through their involvement in the legal process.
Costs should only be awarded when the litigant can demonstrate
that they devoted time and effort to do the work that would ordinarily be done by a lawyer retained to conduct the litigation and
that as a result, they incurred an opportunity cost by foregoing
 The necessity of proving an opportunity cost was con-
firmed by the Divisional Court in Mustang Investigations v. Iron-
side (2010), 103 O.R. (3d) 633,  O.J. No. 3184, 2010 ONSC
3444 (Div. Ct.). Referring to Fong, the court held, at para. 23:
First, to receive costs a lay litigant must demonstrate that he or she devoted
time and effort to do the work ordinarily done by a lawyer and that as a result
he or she incurred an opportunity cost by foregoing remunerative activity.
Second, if an opportunity cost is proved, a self-represented litigant should only
receive a moderate or reasonable allowance for the loss of time devoted to
preparing and presenting the case.
 The importance of proving an opportunity cost was
emphasized when, at para. 27, the court held:
. . . I’m unable to find that the language in Fong permits an award to be made
without the self-represented litigant demonstrating that, as a result of the
lawyer-like work put in on the file, remunerative activity was foregone. Simp-
ly stated, no proof of opportunity cost, no nominal costs available.
 More recently, in Charendoff v. McLennan,  O.J. No.
6218, 2012 ONSC 7241 (S.C.J.), MacDonnell J. considered a costs
claim by the successful defendant who was a self-represented
lawyer. He endorsed the Fong and Mustang Investigations
decisions. Despite the fact that the self-represented lawyer obviously
did work ordinarily performed by a lawyer retained to conduct
the litigation, the lack of proof of opportunity cost was fatal to
the costs claim.