[5] In my opinion, there are four overarching factors that play into an award of costs in this case: (1) the plaintiff’s pre-trial offer to settle, which she handily surpassed; (2) the manner in which the defendant conducted its defence, which the plaintiff has aptly described as a “scorched earth” defence; (3) the complexity of the matters in issue; and (4) the reasonable expectations of the parties as to the fair and reasonable costs to be paid by the losing party. The fourth factor must be weighed against the first three factors. Again, I do not intend to repeat the case law that supports the above mentioned principles—they are captured in Evans and Bimman and repeated, in part, in paragraphs one and two of the defendant’s written argument.