Category Archives: Professional indemnity

Clayton Utz and the lingering smell of smoke

Posted on by
Reply

Are you a commercial litigator with an interest in client confidentiality and conflicts of interest? Or in schadenfreude?

Then you will probably appreciate Justice Elizabeth Hollingworth’s decision last month in Dale v Clayton Utz (No 2) [2013] VSC 54

A quick refresher before the summary.

Allan Myers QC and Clayton Utz both have singular reputations among Australian lawyers.

Myers is a top shelf commercial silk and philanthropist. His fame, prestige and profile are surely matched by few other practising lawyers in the nation. Apart from that, in his spare time he has dabbled in investments sufficiently to acquire, among other things, a Polish brewery, vast tracts of outback Australia and an entry in BRW’s Richest 200 list.

Clayton Utz’s reputation is more enigmatic. It is a mega firm employing hundreds of no-doubt talented and principled lawyers. But in the public mind it is arguably still best known for its murky role defending Big Tobacco against a claim by a dying ex-smoker, Mrs Rolah McCabe in 2002.

Mrs McCabe won at first instance (see decision here) after the cigarette company’s defence was struck out. The trial judge concluded, among other things, that through its “document retention policy”, the process of discovery in the case had been subverted by the defendant and its solicitors (Clayton Utz) with the deliberate intention of denying a fair trial to the plaintiff.

That decision was reversed by the Court of Appeal here but Clayton’s Utz’s judicial vindication was undermined by the PR shellacking The Age (and other media) gave Clutz and its client in stories like this and this.

How did the The Age get its material?

We now know that some of The Age’s information was leaked to it in 2006 by one time Clayton Utz litigation partner (and also 2004 Law Institute of Victoria president) Chris Dale.

For reasons which the Supreme Court might yet find were or were not related to the McCabe case, Clayton Utz had expelled Dale from its partnership a year earlier in October 2005.

Almost six years later, in September 2011, Dale sued Clayton Utz for breach of the partnership agreement.

Which brings us back to the Victorian Supreme Court’s recent decision.

Clutz filed its defence against Dale in January 2012. That defence was signed by Allan Myers QC.

Dale promptly objected to Myers’ involvement. He said that Myers had advised him in relation to his dealings with the Clutz partnership during 2004 and 2005 and accordingly Myers should not act against him now.

Clutz held its ground so Dale sought an injunction to prevent Myers acting further in the case.

Last month Dale won that argument and Myers exited the proceeding. (The wider dispute between Dale and the partnership remains to be determined.)

Justice Hollingworth’s 40 page judgment is a good read. There is something in it for you whether you are in the mood for a John Grisham-style legal who-dunnit or some pointers on how not to draw affidavits on this type of issue, lawyers’ obligations to parties they have formerly (and possibly informally as well) advised, concepts of ‘contractual’ and ‘consensual’ retainers and much else besides.

But the most confronting topic for mine is the treatment of obligations towards former clients (including people who might never have been ‘clients’ in a formal sense).

In short, Dale swore on affidavit and in cross-examination that as his relationship with the Clutz partnership frayed in 2004 and 2005 he sought and obtained Myers’ oral advice.

Myers denied this on affidavit and was not cross-examined.

Dale’s version (at least as to a single conference of about one hour’s duration in 2004) was preferred by Hollingworth J thus –

33     In so far as Mr Myers states … that he “was not retained” by Mr Dale, I read that as no more than a statement of his personal belief that he was not retained. Mr Myers cannot give evidence as to whether he was in fact retained. Whether or not there was a retainer is a legal matter for the court to determine, from the objective facts, and not from the subjective beliefs of the lawyer or the party alleging to have retained the lawyer.

….

59     In so far as Mr Myers states … that he was not asked to and did not provide legal advice to Mr Dale, given that he has no memory of this conversation at all, I read that as no more than a statement of his personal belief … that he was not retained to provide legal advice.

 ….

135   I accept that Mr Myers did not believe he was being professionally retained. But Mr Myers did not say to Mr Dale that he was seeing him other than in his capacity as senior counsel, even though the discussion lasted for about an hour and went into some detail about Mr Dale’s current predicament. Someone in Mr Myers’ position could easily have taken steps to make it clear that he was not acting in a professional capacity.

….

Conclusion

176   I propose to grant an injunction to restrain Clayton Utz from continuing to engage Mr Myers in this proceeding. Such an injunction would be justified by any of the following findings:

(a)     That a professional relationship existed between Mr Dale and Mr Myers in relation to the August 2004 meeting;

(b)     Further and alternatively, that Mr Dale communicated confidential information to Mr Dale [sic.— Myers?] in the August 2004 meeting, and there is a real and sensible possibility of a revival of recollection, about matters which are of critical importance in this proceeding;

(c)      Further and alternatively, because a fair-minded, reasonably informed member of the public would conclude that the proper administration of justice required that to occur.

The bottom line for Clayton Utz? The firm needs a new silk in for its continuing stoush with Dale.

The bottom line for the rest of us? An hour’s discussion about which you have absolutely no memory or record can be enough nine years later to have you ejected from acting in litigation against the other party to that forgotten discussion.

For the record:

  • Hollingworth J stated (at para 121) “By accepting Mr Dale’s account, I am not in any way suggesting that Mr Myers is not a truthful witness”.
  • In late 2001 or early 2002 I acted for Mrs Rolah McCabe for approximately 48 hours in her case against Clayton Utz’s then-client British and American Tobacco Australia Services Pty Ltd.

How Edelsten’s costs application against solis backfired

Posted on by
Reply

Last October I posted about Dr Edelsten’s adventures in the Supreme Court of Victoria against a lady friend in (Mainly) keeping a sugar daddy’s confidences.

A quick reminder. In an entertaining but unflattering judgment Dr Edelsten won an order for $US5000 plus certain limited suppression orders against a Ms da Silva.

Among other things, Beach J found that “most of the evidence given by the defendant was demonstrably false and could not be believed. However, Dr Edelsten was no more an impressive witness than Ms da Silva.”

Now the aftermath (which escaped me among the distractions of the summer holidays).

The week before Christmas Dr Edelsten went back to court and sought his costs of the litigation against the defendant’s solicitors – on an indemnity basis.

Among other things, he relied upon the Civil Procedure Act.

He argued that swathes of the defendant’s case had no proper basis, her solicitors must have known this and therefore they should not have persisted with key aspects of the defendants’ case.

Beach J was not swayed.

“I am satisfied that at all times … the defendant’s solicitors were acting on the instructions of the defendant. Indeed, when the defence was eventually abandoned, it was abandoned in the face of the defendant’s evidence to the contrary.

… Having regard to the instructions the defendant’s solicitors then possessed, I see nothing improper, or in breach of any rule of conduct, or in breach of any overarching obligation or other provision of the Civil Procedure Act, in the drawing, settling and filing of the defendant’s defence. …

It is always possible to say that an issue, upon which it becomes clear that a party will ultimately be unsuccessful, could have been abandoned earlier if greater diligence had been exercised. However, the mere failure to abandon a point at the earliest possible time does not mandate a conclusion that an overarching obligation of the Civil Procedure Act has been breached.

…. In the end, I have come to the conclusion that while a counsel of perfection would have suggested that the concession made on the afternoon of the third day of the trial could (and possibly should) have been made 24 hours earlier, the failure to take this step at that time did not involve the contravention of any of the overarching obligations in the Civil Procedure Act.

And the ordeal was not yet over.  Beach J concluded with an order that Dr Edelsten pay the solicitors’ costs of his failed application on a solicitor /client basis (apparently because the judge considered the application had been sufficiently hopeless to warrant costs on more than the usual party/party basis).

The costs decision is here.

 

Tripping up on the slip rule

Posted on by
1

“Since the abolition of capital punishment there is now no mistake by a lawyer in Australia that cannot be effectively reversed.”

Or so I was told long ago after a bad day in the office as an articled clerk.

My supervising partner had in mind the slip rule.

The slip rule is the rule that allows courts to correct minor glitches in their own judgments and orders without the trouble and expense of an appellate court’s intervention.

The slip rule is within courts’ inherent jurisdiction but it is also succinctly expressed in most courts’ own rules — see for example Federal Court rule 39.05 and, in Victoria, Supreme Court rule 36.07; Magistrates’ Court rule 36.08 and VCAT Act s 119.

But the slip rule has its limits.

I was reminded of this over the Christmas break by a Retail Tenancies List decision – Versus (Aus) Pty Ltd v ANH Nominees Pty Ltd [2012] VCAT 1908.

In late 2011 the tenant-applicant won an order totalling almost $245,000 against its landlord – see Versus (Aus) Pty Ltd v ANH Nominees Pty Ltd [2011] VCAT 2273. In that case, after a 10-day hearing and a 62-page judgment, VCAT Vice-President Judge Lacava found that the landlord had failed to take reasonable steps to stop or prevent disruption to the tenant’s trading caused by, inter alia, a neighbour’s renovations.

The landlord duly paid up.

Almost a year later the tenant decided to go back to the well. It applied to VCAT under the slip rule for a further order which would have upped the original award by almost $96,000.

The application had three prongs.

Two were swiftly dealt with. Judge Lacava found both to require a total recalculation of damages in circumstances where the errors complained of and their consequences were “not readily identifiable.”

The third limb of the application was starker.

The landlord conceded that a typographical error (yes – a humble typo) in the original reasons had effectively cost the tenant $16,235. But it would not concede the slip rule application.

Quite right too ruled Judge Lacava.

He cited L Shaddock & Associates v City of Parramatta [1983] 151 CLR 590 to the effect that courts have a discretion when dealing with slip rule applications.

In my view, if there was an error capable of being corrected under s. 119 [of the VCAT Act dealing with slip rule applications], it ought to have been identified by the applicant and its accountants by the end of February 2012 at the latest and an application then made. That was not done. In my judgment, the delay in bringing this application for correction is unexplained and is too long. It is important that litigation be brought to an end. In this case, the respondent having promptly paid the amount of damages, it would be both inexpedient and inequitable for me to make the orders sought by the applicant in its further application dated 20 September 2012.

For these reasons, the applicant’s further application is dismissed.

The lessons?

Three occur to me:

  • Try to get it right the first time;
  • Don’t hang about when you (or the judge’s typist) muck it up; and
  • Don’t believe everything supervising partners tell their underlings.

Robert Hughes – a lawyer’s farewell

Posted on by
1

Celebrated art critic and historian Robert Hughes died this week.

None of the many generous obits I have read have mentioned Hughes’s obscure and incidental career as a legal critic.

Let’s fix that.

In 1999 Hughes nearly died in a car accident near Broome, Western Australia. During his painful recuperation he was charged with driving offences arising out of that accident. He initially contested the charges but ultimately pleaded guilty.

In the interim passengers from the other vehicle offered (on the sly of course) to change their evidence in exchange for payment from Hughes. They were duly charged conspiring to pervert the course of justice.

Hughes, the baby brother of ex-federal attorney general “Frosty Tom” Hughes QC, was scathing about the whole episode. Among those he took a swipe at was the barrister who prosecuted him, Indian-born, Western Australian barrister Lloyd Rayney.

Hughes, among other things, allegedly described Rayney as a “curry muncher.”

Rayney then sued Hughes for defamation (which ultimately settled privately).

Coincidentally Rayney is now back in court again in a personal capacity. He is currently standing trial in Perth charged with the murder of his wife, Supreme Court Registrar Corryn Rayney. (See the WA News account here).

Rayney will be hoping for a better run in his murder trial from WA’s Director of Public Prosecutions than that accorded in another Perth murder trial to Paul Mallard.

Mallard was convicted of murder in 1995. The High Court subsequently overturned the conviction finding the prosecution had overcooked its case by failing to disclose important exculpatory evidence to the defence. (See an account of the High Court decision at Kyle McDonald’s summary crime blog).

Just how overcooked was the prosecution case against Mallard?

Pretty. Just last month (17 years after the event!) the prosecuting counsel copped a plea before WA’s Legal Profession Complaints Committee to unsatisfactory professional conduct and agreed that the maximum applicable fine was appropriate. (The Committee’s decision here was pointed out to me by the doyen of Melbourne’s legal bloggers Stephen Warne).

What would Robert Hughes have made of this?

Maybe we already know.

He once said “Western Australian justice is to ‘justice’ what Western Australian culture is to ‘culture’.”

Farewell Robert Hughes. At least outside WA you will be missed.

Charge and countercharge of overcharging in Sydney

Posted on by
Reply

Is the expression “excessive legal costs” tautological?

Cynics might say so but not our regulators.

Section 4.4.4(b) of the Legal Profession Act (Vic) makes the “charging of excessive legal costs in connection with the practice of law” (surely a further tautology) conduct capable of constituting either ‘unsatisfactory professional conduct’ or ‘professional misconduct’.

New South Wales’ equivalent legislation saw former high-flying personal injuries soli Russell Keddie struck off last month for just such professional misconduct.

According to the Sydney Morning Herald account here Keddie’s bill of $819,000 to his paraplegic client was $215,00 too high.

Keddie is unlikely to miss his ticket – he retired before he was rubbed out.

Perhaps with a view to the many similar claims against him and his former firm, he also declared himself bankrupt last month.

Keddie’s sagging public reputation is unlikely to be assisted by reports (like further SMH yarns here and here) that before his bankruptcy he transferred his half share in two properties worth a combined $6 million to his wife for – you guessed it – a single dollar each.

The SMH has given the Keddies story a lot of air since 2008 but in Victoria only readers of the Oz are likely to have heard of it.

Keddie’s eponymous firm was once NSW’s leading personal injury plaintiffs’firm. Slater & Gordon took it over for a reported $32 million in 2010. By then Keddies had been been already in strife with NSW’s Legal Services Commissioner for at least 4 years.

Radio National revisited the Keddies saga in Background Briefing last Sunday, 22 July 2012 – audio here and transcript here.

Some highlights from the ABC’s retelling:

  • Aggrieved Keddies clients have already racked up approximately $4 million in judgments against the firm’s three former partners;
  • The ABC speculates that the total overcharging judgments might eventually top $11 million;
  • Enforcement of those judgments is likely to be problematic. Of the three ex-Keddies partners sued, one is already bankrupt and the other two have reportedly had their assets frozen;
  • The overcharging claims against Keddies have been spear-headed by solicitor Stephen Firth with the apparent assistance of some ex-Keddies Deep Throat(s);
  • Coincidentally, Stephen Firth is himself defending several overcharging claims. The plaintiffs’ solicitor in those cases? None other than ex-Keddies partner (and defendant to many Firth-issued overcharging writs) Tony Barakat.

Firth has been forthright in his pursuit of Keddies – see his website here where he boasts of 11 wins totalling $1.5 million in Keddies cases for the month of April alone.

And Barakat is not bashful either. See his comments to The Australian here about the claims against Firth.

Only in Sin City?

 

 

Safeguard your Mareva injunction with a PPSA registration

Posted on by
Reply

I have just put the finishing touches to a seminar paper I am delivering this week on the Personal Property Securities Act 2009.

My paper is not as unwieldy and dry as the PPS Act itself (is anything?) but I wouldn’t call it sexy either. I will post it on its own discrete (ie separately tabbed) page in this blog after the seminar.

For an extremely short synopsis of the PPS Act generally see my post of 10 February 2012 (which you can access by simply following the date prompts below the mugshot in the right-hand margin of this page.)

But let me take you straight to what might be the highlight for general commercial litigators with Mareva-type injunctions in their armoury (and they should be in every armoury).

Once Mareva orders (aka ‘asset preservation orders’ and ‘freezing orders’) and some analogous orders are obtained from any Australian court or tribunal it seems they can be ‘perfected’ by registration on the PPS Register.

Such registration will effectively advertise the existence of your client’s Mareva injunction to the world at large. That ‘perfection’, among other things, should constructively warn off third parties who might otherwise purchase or lend against the property in breach of a court order restraining the use and/or disposal of that property.

This new tool lies buried in reg 5.3(c) of the PPS Regulations. I am not aware of it having been used since the PPSA regime started on 30 January 2012.

Is this history waiting to be made or has it been made already?

Anyone?

Is your enemy’s enemy your friend? Proportionate liability cases and the rule in Jones v Dunkel

Posted on by
2

The rule in Jones v Dunkel permits a court to draw an inference at trial from a party’s unexplained failure to call a witness logically within that party’s camp. The permissible inference is that the absent witness’s evidence, if led, would not have assisted that witness’s camp.

The rule is not new.  It actually predates the case from which it takes its name – Jones v Dunkel (1959) 101 CLR 298.

Particularly since the commencement in 2004 of Part IVAA of the Wrongs Act (Vic) and its federal equivalents, apportionable liability cases have become commonplace. This has complicated the application of the Jones v Dunkel rule.

Co-defendants in commerical litigation now typically pitch their case at two levels:

  • firstly, they will argue in unison that the plaintiff’s case should fail;
  • secondly, as a fallback, they will argue against each other that, if the plaintiff succeeds, the other co-defendant(s) should wear all, or most, of the resulting liability.

These issues arose (on the pleadings at least) in Goddard Elliott v Fritsch [2012] VSC 87 (see my post below of 29 March 2012 for a brief overview of the case’s facts and issues).

There a disgruntled client sued his solicitors, plus the silk and senior junior retained on his behalf.

He alleged, inter alia, negligence against each of them. Both barristers settled but the solicitors fought the case to verdict. The barristers remained as nominal parties in the trial for the purposes of the apportionment issues.

In defending the negligence claim the solicitors did not call evidence from the silk in support of their case. But neither did the client call evidence from that silk in support of his case.

The client then asked the court to draw an adverse inference against the solicitors in accordance with the rule in Jones v Dunkel.

‘But the silk is an independent party and not within our camp’, replied the solicitors.

Bell J disagreed. Here are some extracts taken from between para 32 and 49 of the 1136 paragraph judgment:

“In the negligence and other claims which have been made, and in the factual basis of what has been alleged, the nature of that case puts all of the defendants by counterclaim in the one camp….

“… It was within the power of [the solicitors] to call [the silk] as a witness in relation to important issues of fact in the case, particularly [the client's] mental capacity and what occurred when the proceeding in the Family Court was settled…

“As [the silk) was in [the solicitors' firm’s] camp, it was reasonably to be expected that it would call him to give evidence on its behalf. For reasons which were not explained, it failed to do so.

“The unexplained failure of [the solicitors] to call [the silk] gives rise to an inference that his evidence would not have assisted [the solicitors'] case.  That inference may be taken into account against [the solicitors] in evaluating the whole of the evidence of the case, including the evidence of [the client]. By reason of [the solicitors'] failure to call [the silk] I might more readily resolve any doubts I have about the reliability of [the client's] evidence.

Conclusion

This ruling illustrates a conundrum likely to arise in many (perhaps even most?) multi-party cases where an apportionment of liability as between defendants (and/or joined parties) is sought.

For each co-defendant, the plaintiff will typically be the primary adversary but not the only adversary. Typically, each of the co-defendants will also be trying to shunt maximum liability on to each other’s plates. In that sense, every other ‘camp’ in the litigation will be an enemy camp.

But, for the purposes of the rule in Jones v Dunkell, your opposition’s opposition might be considered (by the Court at least) to be your friend.  The co-defendant trying to minimise his liability at your expense might very well be considered to have been within your ‘camp’ in the event of your unexplained failure to call evidence from that person.

But dare you call a hostile co-defendant to give evidence on your behalf?

Therein lies a post for another day…

Courage at all costs? Lawyers reminded of personal exposure in Centro

Posted on by
Reply

Australia’s most famous English silk, Geoffrey Robertson, once rhetorically rolled his eyes at the concept of fearless lawyers in Anglo-Australian law.

He was all for the idea but his point was that a brave lawyer, here or in London, braves mainly the risk of occasional unkind words from the bench and the media.

For truly courageous lawyers, he said, look to places like Columbia.

There, some lawyers’ career alternatives boil down to either a safe and very comfortable life for themselves and their families, subsidised by the local drug lords, or a more principled career on a very modest government income which, among other things, is hopelessly inadequate to guard them and their families from the real possibility of kidnapping or assassination.

Columbia remains a long way off but Robertson QC’s disparagement of legal courage here might require some updating after Justice Michelle Gordon’s reported comments in the Centro case this week.

The case is in its seventh week in the Federal Court. There are hundreds of millions of dollars at stake. The auditors were always in the gun. Now their counsel and solicitors King & Wood Mallesons might be too.

See the Fairfax reports here and here.

A judge’s power to order costs against the lawyers is not in doubt (see for example my post here on Superior IP International Pty Ltd v Ahearn Fox Patent and Trade Mark Attorneys [2012] FCA 282 and the Allen Arthur Robinson post on a similar recent case here). But such costs orders typically involve after-the-event criticism of the lawyers from the bench.

Media reports of the Centro case suggest provisional criticism from the bench of the lawyers’ anticipated performance.

Assuming these reports are correct, what is a brace of silks and senior juniors and their über firm instructing solicitors to do?

While it would hardly look courageous, they could turn tail and run. Abandoning a line of argument in defiance of a client’s instructions is a real option in some cases. While obviously problematic (not least from the costs angle) it can be justified in the right circumstances by the lawyers’ overarching obligations under, among other things, the Federal Court Act, the Civil Dispute Resolution Act (Cth) and Victoria’s Civil Procedure Act.

Another option is persevering in the teeth of incoming judicial flak and attempting to win over an apparently very dubious judge. (although they have reportedly described their argument as “not without foundation” which sounds a mite trepidatious.)

But whichever course the auditors’ representatives now choose, they will probably require more guts than Robertson QC thought was usually required of Anglo and Australian lawyers.

This a nine-cornered stoush (yes, nine!) and costs will surely be running at several Portsea beach houses per week.

Stay tuned.

PPSA in 500 words

Posted on by
Reply

The Commonwealth Personal Property Securities Act 2009 came into operation on 30 January 2012. It comprises 300 + pages (never mind the regulations) and is not light reading.

Can it be summarized in just two A4 pages? Let’s try.

The PPSR Act establishes something that might be crudely likened to a Torrens title registration scheme for tangible and intangible personal property. It is modeled on existing legislation in New Zealand and Saskatchewan.

“Personal property” does not mean domestic or consumer property (although that is within its scope too). “Personal” means personal as opposed to real property.  Most businesses will be affected (For example who has title to the hire-purchased photocopier in a solicitor’s office if the soli goes broke? What if the soli stays solvent and the photocopier supplier goes bust?)

The registration system is national, internet-based, administered by the Insolvency & Trustee Service of Australia (ITSA) and accessible 24/7.

In insolvency situations the register will generally determine the title of the liquidator / trustee in bankruptcy to personal property in the possession of the insolvent company / individual that might otherwise be claimed by a financier, unpaid supplier etc.

Example:

Say ABC Company goes into liquidation while in possession of:

  • vehicles it has leased from X bank;
  • widgets from Y supplier which have not yet been paid for and are subject to retention of title clauses; and
  • an entire business ABC purchased from Z on vendor terms and on which there are still instalments outstanding.

In this example X, Y and Z would formerly probably have had good title as against the liquidator to their particular property in ABC Company’s possession. But no longer. Under the new regime the liquidator will likely be entitled to seize and sell each of these assets as part of ABC Company’s insolvent estate unless the rival claimants have registered a security interest in them.

Registration of a given security interest will cost $5 a time.

Failure to make that $5 investment might cost unlucky punters literally millions – see Waller v New Zealand Bloodstock Limited [2005] NZCA 254; [2006] 3 NZLR 629. In that case the owners of a $2 million racehorse leased it to a stud. The stud’s financier repossessed the stud (and with it, the horse). The horse’s owners had not registered their security interest in their  horse under New Zealand’s equivalent of the Australian legislation. They lost their $2 million chaff-burner to the liquidator as a result.

Now consider the lawyers –

  • Clients’ standard terms of trade agreements might require revision. Previously effective retention of title clauses in supply agreements might fail under the new regime unless supported by registration of the resulting security interest;
  • Clients who are not advised of the new regime by their lawyers are likely to be gravely miffed if they lose their assets to their customer’s liquidators as a consequence;
  • Professional negligence claims against lawyers will inevitably result – see for example K-Auto Trading NZ v McGurie [2008] NZHC 94

After a remarkably long gestation the Personal Property Security Act 2009 is now operational law. The new regime includes a two year introductory transition period (but why defer getting things right until 2014?)

Paul Duggan

Image

2

Paul Duggan is a commercial litigation barrister based in Melbourne, Australia.

Since 1996 he has advised and appeared in most types of business-to-business and business-to-customer disputes – commercial and domestic building matters, commercial and retail leasing disputes, insolvencies, franchises, partnerships, insurance, professional negligence, sales of land, Corporation Act matters and trade practices disputes to name a few. Although Paul has represented governments, major public companies, insurers, Lloyds syndicates and private individuals his clients are predominantly small and medium enterprises contemplating or engaged in litigation in the Victorian Supreme Court, County Court or VCAT.

Paul also practises in the federal jurisdictions and interstate.

Paul’s clerk is Gordon & Jackson.

Liability limited by a scheme approved under the Professional Standards Act 2003.