“On a motion for a stay pending appeal, as held in BTR Global Opportunity Trading Limited v. RBC Dexia Investor Services Trust, 2011 ONCA 620, 283 O.A.C. 321, at para. 16, the overall consideration is whether it is in the interests of justice to grant a stay. In making that determination, the court is to consider the following three factors:
a. Whether the appeal raises a serious issue;
b. Whether there will be irreparable harm if the stay is not granted; and
c. Whether the balance of convenience favours granting the stay.”