Some thoughts before you speak

Posted on August 14, 2013 by Paul Duggan

If you haven’t sat through a thousand awful lectures, submissions and presentations you probably aren’t a real lawyer.

And if you have applied the unintended lessons of all that professional experience and training you are probably a dreadful public speaker as a consequence.

I was reminded of this when I attended a presentation this week on presentation skills. It was delivered to a room full of barristers by a non-lawyer, ex-teacher and freelance speechwriter, Ben Richards of Aticus.

Lecturing barristers on public speaking should be a tough gig. Richards made it look very easy – and he did so for a compelling 90 minutes without as much as a single note or Powerpoint slide.

I took copious notes. Here is a distillation.

Delivering professional presentations and writing the seminar papers which are typically meant to accompany them are very different beasts. Treat them as such. Plan your paper’s content and its delivery as separate exercises.
Australians often expect oral presentations to be bland at best. It is actually not that difficult to surprise on the upside.
Why should any speaker see and hear his or her very own presentation for the first time simultaneously with the audience? Do at least some practice aloud beforehand. Also, warm up the vocal cords before you actually take the microphone.
The first draft is never good enough. It will always need at least some rewriting and editing.
Speak to the back of the room. There will never be anybody sitting in the front row anyway. Modulate tone and speed. Use vocal variation.
The law is always prosaic. Be generous with the real-world stories and problems which make the legal issues you are discussing interesting.
Also, start with your conclusions – if you keep your audience waiting its concentration might well be spent by the time you get to the end (where you were probably planning to put your conclusions).
The presentation and the paper should not coincide. They are separate forms of communication which should not be fused.
Don’t turn up late, flustered and then open with an apology and/or a plea to the floor for assistance with the operation of the PowerPoint projector.
PowerPoint can only ever be a background visual aid. It is quite useless as a handout. It can be useful for diagrammatic explanations and/or key (and short!) pieces of text. [For a quick PowerPoint refresher see my post Slide into PowerPoint – a novice’s guide]
The traditional 50 or 60-minute presentation format is problematic. It is usually a much better use of everybody’s time to divide the allotted hour evenly between two speakers and a Q & A session at the end.
For the Q & A session be sure to plant some Dorothy Dixer questions – commonly at these events nobody wants to ask the first question but everybody wants to ask the second question.
Doing a one-off presentation is terribly inefficient – wherever possible commoditise your talk. Its (complete or modified) reuse at subsequent events will improve both its efficiency for you as the speaker (through its delivery to more than a single audience) and also its quality as you are able to polish its content and delivery with practice.
Preparation is key. Many brief preparation sessions over the course of weeks will usually be much more productive than a preparation marathon on the eve of your presentation.
Preparation should start with three questions:
1. Who is your audience?
2. What is your objective?
3. What are your key messages?
You can rarely ask your actual audience in advance what they want to hear but you can usually speak to individuals who are potential audience members and/or have attended similar presentations. What do they know? What don’t they know? What more do they want to know? Ask them!
Be realistic. Large books might well have been written on your topic. You (and your audience) have limited time. Don’t pretend that you can or should attempt to cover everything.
Getting the structure right means putting the right ideas in the right sequence. Maybe start by putting the ideas on post-it notes, sticking them on a window and then rearranging them into an order that makes sense to you.
Test the structure of your presentation by looking at its transitions. If the transitions don’t work it’s probably because the structure doesn’t.
Never give a presentation without some ‘real-world’ connections. War stories are good. In their absence hypotheticals will suffice. Humour is good. So is fear-mongering with worst-case scenarios.
Your opening should persuade the ambivalent audience that it should be interested. You can’t do this unless you sound interested yourself.
Planning your opening is obvious (and important). Planning your closing is less obvious but just as important. The presentation that peters out with an apologetic murmur about the lateness of the hour or an abrupt full stop followed by an unexpected “Thank you” as you sit down is finishing on a bum note indeed.
Speaking notes are a parachute – not a script. If you must have notes use keywords and phrases in large (say 30 point) type. Speaking notes which comprise full written sentences are inherently unsuitable to oral presentations. Using your 20-page seminar paper as your own speaking notes is an own goal accordingly..
Audiences typically take away between 2% and 9% of a presentation’s content. Overcooking your content will compound the problem. Highlight the particular gems you want your listeners to retain.
The average adult’s attention span is approximately 6 to 7 minutes. Harness this rather than being defeated by it. A 60-minute presentation on a monolithic topic is frequently doomed to failure from the outset. And yet it might fly if it is effectively broken up into, say, 8 to 10 chunks of approximately 6 minutes each about particular components of that very same substantive topic.
Consider contriving your own interruptions as breaks to punctuate your presentation. Ideally each resulting segment will prompt a renewed attention span from the audience. These breaks in the presentation can be disguised as, for example, brief group discussion exercises or questions from the floor on a segment-by-segment basis.
Each segment of your presentation should :
1. Contain a statement of the “learning outcome” desired (eg why should we talk about X at all?);
2. Highlight the substance of X which needs to be conveyed; and
3. Conclude with a reflection on X by which the point of the exercise is very briefly recapped.
In the Google age presenters who simply deliver publicly available information are wasting their own and their audiences’ time. Unless you are adding your own personal analysis, experiences, war stories, criticism, humour and/or editorials you are giving your audience nothing positive to remember you by. (Indeed, you might be giving them positive reasons to forget you.)
Don’t run over time. It antagonizes audiences, subsequent speakers and the catering staff. Most of all it looks chaotic.

And on that last point Richards concluded – precisely an hour and a half after he told us he was going to speak for 90 minutes.

If only it was simple as people in Richards’ league make it look.

WA court bins stat demands, orders indemnity costs and calls the cops

Posted on June 13, 2013 by Paul Duggan

Some obscure judgments deserve a wider audience.

Master Sanderson of the Western Australia Supreme Court delivered one such gem in April in Rohanna Pty Ltd v Nu-Steel Homes Adelaide Pty Ltd [2013] WASC 109.

Some scene-setting first.

In Christmas week 2012 the plaintiff received two statutory demands from the defendant. The parties had never had any prior contact with each other and yet the demands totalled almost $220,000. Both stat demands were ultimately set aside by Master Sanderson. In the interim the defendant was represented in correspondence by a South Australian solicitor who did not file a formal appearance (Mr Nicholls) and in Court by a non-lawyer (Mr Pearse). Mr Nicholls had offered to settle the matter on the basis that the plaintiff pay the defendant’s costs of $25,000. He also remarked upon the need to advertise any winding up application which might follow if the plaintiff didn’t stump up that loot.

Master Sanderson was scathing. Here are some highlights from a stinging judgment.

11. In further support of its application the plaintiff filed a second affidavit …. The purpose of this affidavit was to demonstrate the solvency of the plaintiff. A mere glance at this affidavit would be enough to convince even the economically illiterate the plaintiff was solvent. Indeed it shows the plaintiff as a massively successful commercial enterprise. But that was not enough for Mr McNamara.

….

17. All of these matters can then be aggregated. First, the defendant served the statutory demands without any prior consultation with the plaintiff. If it had a genuine belief there was a debt owed it would have been reasonable to write to the plaintiff, make a claim and explain the basis of that claim. That was not done. Instead the demands were sent by post and arrived on the Thursday before Christmas. If ever there was a time when it was difficult to deal expeditiously with a demand which required action within 21 days, that was it.

….

20. Fourthly, faced with clear evidence of the solvency of the plaintiff the defendant determined to press on. No reasonable party properly advised would have done so.

21. Fifthly, the correspondence suggests an attempt to embarrass the plaintiff by advertising the fact of a winding up application. There was no need to refer to the advertising of a winding up application in the way Mr McNamara did. The letter strongly suggests the defendant was looking to force the plaintiff into a compromise to serve its own purposes.

22. Sixthly, the defendant actually issued a winding up application. This was done prior to the application to set aside the demands being heard. It must have been clear there was a live issue as to whether the application to restrain the defendant would succeed. … Once again it looks as though the defendant was attempting to pressure the plaintiff.

23. Seventhly, no appearance to the application to set aside the demands was ever lodged. Mr McNamara in his correspondence said he had been retained by the defendant. As late as 28 February 2013 he wrote to the plaintiff’s solicitors on behalf of the defendant. At no time did Mr McNamara indicate his instructions had been terminated and at no time did he give any indication he would not appear at the hearing of the matter on 7 March 2013. Perhaps the defendant was concerned if it did enter an appearance a costs order might be made against it. Or perhaps there was some other reason no appearance was entered. But it does suggest the defendant never took seriously the prospect it could successfully resist the plaintiff’s application.

24. Finally, there is the offer to settle on payment of $25,000 for costs. It may be that Mr McNamara is one of South Australia’s leading corporate lawyers. If that is so, this case does not represent his finest hour. But even assuming high competence on the part of Mr McNamara there is no possible way the defendant’s costs could have amounted to $25,000. No appearance was filed, no affidavits in opposition to the application were lodged, it would appear submissions to be made on behalf of the defendant were drawn by Mr Pearse and the totality of Mr McNamara’s involvement was three or four letters. Really this demand for ‘costs’ is no such thing. It was tantamount to extortion.

25. … This is a case where indemnity costs should be awarded and the only question is who should pay those costs. Mr Pearse will have 14 days from the publication of these reasons to make submissions as to why he should not pay the costs personally.

26. I intend to refer these reasons to the Western Australian Police Service for such action as they deem necessary in relation to Mr Pearse. I will also refer a copy of these reasons to the authorities in South Australia who regulate the legal profession to take such action as they deem appropriate in relation to Mr McNamara.

Lessons from this case? Many.

But the very first that occurs to me is that the Wild West’s legal system might have been unfairly maligned by the late Robert Hughes (as recorded in my post here on his passing).

Clayton Utz and the lingering smell of smoke

Posted on April 22, 2013 by Paul Duggan

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.

Tripping up on the slip rule

Posted on February 12, 2013 by Paul Duggan

“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.

(Mainly) keeping a sugar daddy’s confidences

Quote

Posted on October 23, 2012 by Paul Duggan

Geoffrey Edelsten (Photo credit: Wikipedia)

Are confidentiality clauses worth the paper they are written on?
Between parties of good will they are unnecessary. Between parties of ill will their enforcement is usually fraught. The genie secret can escape the confidentiality bottle too easily and, once loose, can seldom be ordered by any court entirely back into that bottle.
Dr Geoffrey Edelsten was reminded of this last week when he scored a dubious victory in Norman South Pty Ltd and Geoffrey Edelsten v da Silva [2012] VSC 477.
Australia’s most famous struck off GP ‘met’ the young, female defendant, Ms da Silva, at www.sugardaddyforme.com . (Go on — have a peek at a very strange world which promotes itself as “a dating site that promises you the man – and the bank account – of your dreams!”) Our star-crossed litigants then met in person, in Florida, one weekend in March this year.
Money subsequently changed hands. On the Edelsten version, that money was a $5000 loan from his company (the first plaintiff) to the defendant. He said the loan was governed by a written agreement which included a wide-reaching confidentiality clause.
Ms da Silva admitted receiving the $5000 but initially told the court it was a gift. Later in the trial she characterised the payment as a loan without any confidentiality obligations attaching to it. She said certain emails in evidence that appeared to contradict her were forgeries.
In a contest between two extremely unimpressive witnesses Edelsten was preferred to Ms da Silva.
What else transpired between the pair? We will probably never know because Ms da Silva is now injuncted from, among other things, persisting with the disclosures she had started making to a Herald Sun reporter.
It was those disclosures which apparently prompted Edelsten to seek a cocktail of orders against da Silva including for repayment of the $5000 loan, damages, injunctions to prevent further disclosures and a non-publication order under s 18(1)(c) of the Supreme Court Act in respect of the entire proceeding.
Edelsten succeeded on the loan claim and the injunctions (because of the confidentiality clause rather than breach of confidence principles) he failed to get damages and he got only a partial non-publication order.
Most successful litigants enjoy public vindication but Edelsten would probably have appreciated private vindication more.
Instead Justice David Beach suppressed “information derived from the proceeding that would disclose or further disclose the substance of any dealings” between the two main players but expressly exempted his 14 page judgment from that order.
Hence the judge’s scathing assessment of the main witnesses’ testimony can be shared with the world. Here (minus the footnotes) are some highlights from a stinging judgment:

1 A little over 23 years ago, Brooking J commenced a judgment with the statement “Titus Oates was the greatest perjurer that ever lived”. Self-evidently, his Honour was not the trial judge in the present proceeding.
….
9 …. one of the problems with this proceeding was that in respect of a significant number of the emails, each side had different versions of the relevant email. Each side accused the other of fraud. Specifically, each party made accusations that various emails passing between them had been fraudulently altered.
….
15 ….most of the evidence given by the defendant was demonstrably false and could not be believed.
16 However, Dr Edelsten was no more an impressive witness than Ms da Silva. The evidence disclosed that in his dealings with Ms da Silva he lied to her on a number of occasions. Further, much of Dr Edelsten’s evidence was simply unbelievable when one had regard to the whole of the evidence. Specifically, Dr Edelsten’s evidence as to being largely (if not wholly) motivated by altruism or charity in his dealings with the … defendant must be rejected. Additionally, much of Dr Edelsten’s evidence (and particularly the evidence I have referred to in this paragraph) is inherently unlikely when one looks at the written record of the communications passing between him and the defendant.
17 While, in some circumstances, and depending upon the demeanour of the particular witness (or other relevant matters), inherently unlikely evidence might nevertheless be accepted, nothing about Dr Edelsten’s appearance in the witness box or any of the evidence in this case led me to conclude that I should accept the evidence given by him (and to which I have referred) in the face of the more likely true position as disclosed in the emails tendered on his behalf. Specifically, the way in which Dr Edelsten gave evidence was unsatisfactory. On a number of occasions, there were inappropriately long pauses before an answer was given to a straightforward question that should have been capable of a ready answer. From time to time, Dr Edelsten appeared to be contemplating which of a selection of answers might prove least embarrassing or least destructive to his case. Further, Dr Edelsten’s willingness to deny seeing the contents of some attachments to a particular email from the defendant did not assist his credibility. Finally, in respect of too many matters in cross-examination, Dr Edelsten was content, all too readily, to say that he could not recall the matter inquired of, before having to, somewhat grudgingly, acknowledge its existence when taken to a specific email.
18 In summary, I found both Dr Edelsten and Ms da Silva to be unsatisfactory witnesses. Both were prepared to mislead me in respect of any matter that they thought they could get away with. Each was prepared to be truthful only if it did not otherwise embarrass them or harm their case. The one piece of evidence that could confidently be accepted from each of them is when each of them said that, in respect of certain matters, the other was being untruthful. That said, there was the occasional vignette of truth. Further, in fairness to Dr Edelsten and in the context of this case, it might be said that it was at least to his credit that he did not falsify any of the relevant documents.
….
40 In my view, it is necessary, so as not to prejudice the administration of justice, to make a non-publication order prohibiting the publication of any part of this proceeding that would disclose or further disclose the substance of the dealings to date between the second plaintiff and the defendant, including any emails, text messages or any other form of communication passing between them. However, I should say for the sake of completeness that such a non-publication order does not prevent the publication of this judgment.

Robert Hughes – a lawyer’s farewell

Posted on August 9, 2012 by Paul Duggan

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.

Paul Duggan

commercial barrister & mediator

Category Archives: general legal interest