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Interest on costs

In Victoria, you can enforce a judgment for up to 15 years: s. 5(4) Limitation of Actions Act, 1958 (Vic.).  During that time, the judgment debt earns interest at a nice little rate, the penalty interest rate: s. 101 Supreme Court Act, 1986.  As of yesterday, the penalty interest rate is 10.5%, while the cash target rate you hear about in the news and on bank statements for your mortgage is, as of today — surprise! — still 3.75%.  And there is no discretion involved, unlike the interest which accrues at the same rate between commencement of proceedings and judgment: Hartley Poynton Ltd v Ali [2005] VSCA 53.  Typically, in superior courts, judgment is given on the claim, and an order made for the winner to pay the loser’s costs.  Working out how much the loser has to pay, however, takes time. The process is known as ‘taxation’.  First a costs consultant usually draws up a bill of costs in taxable form.  Then there are negotiations, and if they do not succeed there is a trial of the question of how much costs the winner pays the loser, generally after a long wait for a court date.  At the end of that, the court gives another judgment of sorts.

From when does s. 101 interest run on that part of the judgment requiring the loser to pay the winner’s costs? Continue reading “Interest on costs”

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Supreme Courts’ inherent jurisdiction to discipline lawyers to be invoked sparingly

Update, 5 March 2012: See also, to similar effect, Bott v Carter [2009] NSWSC 236 at [28] – [34].

Original post:  In AM v Legal Practitioners Disciplinary Tribunal [2010] NTSC 02, a Full Court of the Supreme Court of the Northern Territory heard an appeal by way of rehearing into a decision of the Disciplinary Tribunal (see my earlier post on the case).  One of the grounds of appeal was that the Tribunal had not had jurisdiction. The Law Society of the Northern Territory argued that whether or not the Legal Practitioners Disciplinary Tribunal had had jurisdiction, the matter was now before the Court on a rehearing and it could exercise its inherent jurisdiction, rendering the fascinating jurisdictional questions irrelevant.  ‘I don’t think so!’, said the Chief Justice, with whom Justice Riley agreed.  ‘Wrong way, go back!’ they said with emphasis, noting that the Northern Territory was not the wild West:

‘[159] The Law Society submitted that if this Court was of the view that the Tribunal lacked jurisdiction, as the evidence and the matter of the practitioner’s conduct is now before the Court, it should exercise its inherent jurisdiction over the profession by dealing with the practitioner in respect of her conduct. This approach would require this Court to rely on evidence placed before the Tribunal in the course of invalid proceedings. Counsel for the practitioner submitted that as the Law Society chose the Tribunal route, it would be inappropriate for this Court to exercise other than the appellate jurisdiction. As counsel put it it is “counter-intuitive” to make use of material put before the Tribunal and, if the Tribunal lacked jurisdiction, justice demands a fresh proceeding. To exercise the inherent jurisdiction de novo would involve formulating a charge and carrying the baggage of the old proceedings. Overall, suggested counsel, exercising the inherent jurisdiction would carry with it a flavour of the “wild west”.

[160] In my view, there is considerable force in the submissions of counsel for the practitioner. If I am wrong in my view that the Tribunal possessed jurisdiction, in my opinion this Court should not endeavour to exercise its inherent jurisdiction.’

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David Ross, QC, RIP

In the many panics during the Bar Readers’ Course when I was expected to adventure incompetently into the criminal law, the criminal lawyers whom I made sure to be nice to referred me to ‘the Bible’, Ross on Crime. Leafing through it disconsolately one day, I noticed the chapter entitled ‘Jazz’.  What a revelation.  After that, I knew he was a character, but not until I read his obituary in The Age did I realise how much of a character the Bar has lost.  I wonder whether the very English form of academic eccentricity which has always been a halmark of the Bar, and the qualities of true professionalism which it sounds like Ross personified, are on the wane, whether any of my contemparies will be David Rosses of the future.

I never met the man who passed away recently having succumbed to motor neurone disease.  I did read his book on advocacy, Advocacy.  It is beautifully written, short.

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The obligation not to allege ‘fraud’ without an appropriate evidentiary foundation: what is ‘fraud’?

Solicitors and barristers are obliged not to make allegations of criminality, fraud or other serious wrongdoing in ‘court documents’ without an adequate factual foundation. The rule for Victorian barristers is rule 34. This post explores what ‘court documents’ are, what ‘fraud’ means in this context, and what an adequate factual foundation is, in part by looking again at AM v Legal Practitioners Disciplinary Authority [2010] NTSC 02, treated in the previous post, a decision of the Full Court of the Supreme Court of the Northern Territory.  It also notes a bizarre anomaly between the rules which govern Victorian and other states’ solicitors and between the rules which govern Victorian solicitors and Victorian barristers in this regard. Continue reading “The obligation not to allege ‘fraud’ without an appropriate evidentiary foundation: what is ‘fraud’?”

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$19,500 fine for making complaint against lawyer without adequate evidentiary foundation

A Full Court of the Supreme Court of the Northern Territory delivered judgment in AM v Legal Practitioners Disciplinary Authority [2010] NTSC 02 a week ago. The Darwin lawyer, AM, lodged a complaint with the NT Law Society alleging that a competitor firm, Cridlands, which used to act for her client, had acted in the face of a conflict of duties.  That complaint was dismissed.  The Law Society then turned the lens on the author of the complaint and investigated her for making allegations of serious impropriety without a proper evidentiary foundation.  She was successfully prosecuted and her appeal failed. The Supreme Court confirmed the decision of the Legal Practitioners Disciplinary Tribunal (here and, in relation to penalty, here), finding the lawyer guilty of professional misconduct.  According to the NT News, the lawyer was ordered publicly to apologise to the lawyers about whom the complaint was made, complete professional conduct and ethics courses, and ordered to pay a fine of $19,500.  The costs bill is presumably very high.

The duty which was breached was formulated at [141] as follows:

‘the obligation carried by a legal practitioner is to take care when making serious allegations of impropriety against another on behalf of a client. The obligation arises not only when making allegations or preparing pleadings in a court proceeding but in other situations where the practitioner is protected by privilege and, indeed, in all circumstances, to maintain standards of decency and fairness. The appropriate standard of care is exercised by ensuring that there is evidence upon which allegations might be made and in the light of that evidence by seeking specific instructions in relation to the allegations.’

Continue reading “$19,500 fine for making complaint against lawyer without adequate evidentiary foundation”

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Yet another implied waiver case: Paragon Finance Plc v Freshfields (a firm)

Several recent posts have been about the implied waiver which is said to be an incident of clients suing their former solicitors for negligence.  They are simply case notes.  Some of the cases are English.  All were decided under a law different from that which from 1 January 2010 applies in Victorian court proceedings, a law which has existed in fellow uniform evidence jurisdictions NSW and the Commonwealth only since the beginning of 2009, when amendments to the client legal privilege provisions came into operation.  The purpose of this preamble is to warn against assuming that the law stated in these cases, which represent the common law at the time and in the place of their decision, is the law today. I’m not saying it’s not, right; I just can’t be bothered for the moment to work it out.

Paragon Finance Plc v Freshfields (a firm) (1999) 1 WLR 1183; [1999] EWCA 955 is a unanimous decision of the English Court of Appeal’s Chief Justice, Lord Bingham, and Lord Justices Brooke and Chadwick.  The question the Court identified for decision was:

‘if a client sues his former solicitors claiming damages for alleged negligence in the handling of a commercial transaction between the client and a third party, does the client’s waiver of legal professional privilege (implied from the bringing of the proceedings against the former solicitors) apply not only to confidential communications between the client and those former solicitors relating to that transaction but also to confidential communications between the client and different solicitors whom he later instructed to pursue and settle his claim against the third party?’ Continue reading “Yet another implied waiver case: Paragon Finance Plc v Freshfields (a firm)”

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No problem with solicitors asserting liens over passports

Passports remain property of the government even after they have been issued, and it is a crime to have in your possession or control the passport of another without a reasonable excuse: ss. 6A and 9A Passports Act, 1938.  A solicitor may exercise a lien over property of the client received by her in the course of a retainer.  Is a client’s passport a document over which she may assert such a lien? The answer is yes, because the client’s status as bailee of the passport is a sufficient proprietary interest for the purposes of lien law to bring it within the class of things, as against the client, over which a lien may be exercised: CYX v Council of the Law Society of NSW [2009] NSWCA 430.  Another aspect of this decision is the subject of this post.

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Benecke v National Australia Bank: imputed waiver by criticising lawyers in proceedings to which they are strangers

Benecke v National Australia Bank (1993) 35 NSWLR 110 is one of the best known Australian cases about imputed waiver in relation to making allegations about the course of the retainer of former lawyers.  It is not, however, a case about imputed waiver in professional negligence suits against former solicitors, since this was not such a suit.  Rather, in the course of a proceeding to set aside the settlement of a previous proceeding, Ms Benecke claimed that her solicitor and the other side’s solicitor had settled her case without Ms Benecke’s authority, and gave a detailed account of her conversations with her QC.  The defendant, seeking to uphold the settlement called Ms Benecke’s former QC as its witness.  Ms Benecke’s complaint upon appeal that such evidence was privileged and should not have been admitted was rejected on the basis that Ms Benecke had waived privilege over the conversations by setting out her version of them. Continue reading “Benecke v National Australia Bank: imputed waiver by criticising lawyers in proceedings to which they are strangers”

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The concurrent operation of the new Evidence Act, 2008 and of the Legal Profession Act, 2004

Section 8 of the Evidence Act, 2008 says it does not affect the operation of the provisions of other Acts.  So, although the compellability and competence provisions and the admissibility provisions of the new Act are often spoken of as a code, those who say so are thinking about the continuing operation of the common law, rather than statute law on the subject which survives the legislative change consequent upon the enactment of the new Act.  That caused me to look through the Legal Profession Act, 2004 with a view to finding out how the law of evidence in cases involving lawyers might differ from that to be found in the new Act.  I found that it:

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Basic facts and useful resources about the uniform evidence legislation

Now I have too many words in my Advanced Evidence paper, so you can have the first off-cut.

The uniform evidence legislation is comprised of:

  1. The Evidence Act, 1995 (Cth.), which commenced almost 15 years ago on 18 April 1995;
  2. The Evidence Act, 1995 (NSW), which commenced on 1 September 1995;
  3. The Evidence Act, 2001 (Tas.), which commenced on 17 December 2001;
  4. The Evidence Act, 2004 (Norfolk Island), which commenced on 1 December 2004;
  5. The Evidence Act, 2008 (Vic.), which commenced on 1 January 2010.

The Victorian Act was amended before it commenced (including a Victoria-specific widening of the hearsay exceptions), by the Statute Law Amendment (Evidence Consequential Provisions) Act, 2009 and the Criminal Procedure Amendment (Consequential and Transitional Provisions) Act, 2009, so buy the forthcoming (green) reprint rather than the (grey) numbered Act, and be careful for the time being to check whether Austlii’s consolidation is up to date. Continue reading “Basic facts and useful resources about the uniform evidence legislation”

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Admissibility rulings may be revisited

Res judicata does not attach to interlocutory orders.  It is open to the trial judge, for example, to vary them.  So much I knew.  Until I read In the Marriage of Bowron (1982) 8 Fam LR 651 (this adventure into the law of evidence is taking me to strange places), I had never thought about whether a ruling as to the admissibility of evidence is final.  The answer is, if this case remains good law, that it is not final, even if the result of a voir dire.  Justice Baker said: Continue reading “Admissibility rulings may be revisited”

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Imputed waiver of privilege upon clients suing former lawyers: Lillicrap v Nalder & Son

Back from Vanuatu, a pleasant place, I am slaving away at a 10,000 word paper on the application of the Evidence Act, 2008 to civil cases involving lawyers.  In due course, no doubt, I will subject you to a serialised version of it.  One of the things I am considering is that species of implied waiver of legal professional privilege which is an incident of suing your lawyer, so expect more case notes on that topic than you could reasonably want to read.  First up: Lillicrap v Nalder & Son [1993] 1 WLR 94, which seems to be the English decision most often cited for the proposition that upon a client suing their lawyer, the client’s client legal privilege over the solicitor’s file, and over communications between them more generally, is waived to the extent necessary to allow the lawyer to respond to the suit.  It was recently affirmed in Esso Australia Resources Pty Ltd v BHP Billiton Petroleum (Bass Strait) Pty Ltd [2007] VSCA 224, a decision of Acting Chief Justice Maxwell and Justice of Appeal Chernov.  And in Mann v Carnell (1999) 201 CLR 1, the majority said: Continue reading “Imputed waiver of privilege upon clients suing former lawyers: Lillicrap v Nalder & Son”

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Transitional provisions for introduction of Evidence Act, 2008 (Vic.)

Update, 4 March 2010: The changes to legal professional privilege apply retrospectively to communications which pre-date the commencement at the beginning of this year of the Evidence Act, 2008.  See this post.
Update, 15 February 2010: ‘Quis Custodiet Ipsos Custodes’ has published a useful (but not exhaustive) summary of the provisions here.

Original post: Before you start worrying about my sanity, note that I did not write this on New Year’s Day; I just set it to publish on that day. No doubt you’re wondering about the transitional provisions for the Evidence Act, 2008 (Vic.) which came into operation on 1 January 2010, being the ‘commencement day’.  They were inserted into the Act (no. 47 of 2008) by an amending Act which came into operation before or at the same time as the principal Act, namely the Statute Law Amendment (Evidence Consequential Provisions) Act, 2009 (Vic.) (no. 69 of 2009).  The thrust of them is that the new Act applies to hearings which commence in 2010, but there is lots of detail.  They follow below, but you should also be aware that the Evidence Act, 2008 was amended before it came into operation, but the consolidated version is still not yet available on Austlii: Continue reading “Transitional provisions for introduction of Evidence Act, 2008 (Vic.)”
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Privy Council on privilege as an answer to legal regulators’ powers of compulsion

Update, 24 September 2018: See now Financial Reporting Council Limited v Sports Direct International Plc [2018] EWHC 2284.

Update, 13 May 2012: See now Finlayson v Legal Practitioners Conduct Board [2012] SASC 77.

Original post: Rosemary Pattenden’s The Law of Professional-Client Confidentiality is one of those books which, until now, I would like to have but could not bring myself to shell out for.  Just now, I spent $134 on a second-hand copy, and here’s why. In a web-based update for the book is a reference to B v Auckland District Law Society [2003] UKPC 38 which I wish I had known about earlier, like when I was arguing whether the Legal Profession Act, 2004 abrogates by necessary intendment legal professional privilege over client documents which the Legal Services Commissioner purported to compel the client’s solicitor to produce as part of a disciplinary investigation of a complaint by a non-client, namely the client’s opponent in litigation.  All this time I have been languishing in the darkness of ignorance of the Privy Council’s view that a New Zealand statute not dissimilar to the Legal Profession Act, 2004 did not impliedly abrogate privilege in the way the last Legal Services Commissioner believed the 2004 Act did.  Of course, every statute is different, and the question is always one of statutory construction.  But the New Zealand provision was pretty bog ordinary, and the resolute interpretation of the Commonwealth’s highest court is a promising place for the analysis to start from the point of view of clients. Continue reading “Privy Council on privilege as an answer to legal regulators’ powers of compulsion”

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Experienced private practitioner appointed Legal Services Commissioner

The Acting Legal Services Commissioner, Michael McGarvie, has been appointed Legal Services Commissioner. A photo published in 2004 may be found here. The government’s press-release is mirrored here. Mr McGarvie is very much from the profession’s private practice sector, and used to the realities of dealing with punters; he was for a long time a partner in the plaintiffs’ personal injury practice at Holding Redlich until he went to the Supreme Court as its CEO in 2006, where he oversaw a period of considerable change.  His wife is a lawyer with a plaintiff’s firm, and he is the brother of Richard McGarvie QC and the sister of Ann McGarvie who is, amongst other things, a sessional member of VCAT, the tribunal in which Mr McGarvie will continue to bring disciplinary prosecutions of lawyers.  His father, the late Richard McGarvie was a Supreme Court judge and Governor of Victoria.

Although it might be said that partners of plaintiffs’ lawyers firms are taking over the law (the Law Institute’s CEO, Michael Brett Young, was formerly Managing Partner of Maurice Blackburn, and the Victorian Government Solicitor, John Cain also hailed from there), I suspect that the appointment will be regarded by the predominantly conservative profession more favourably than the appointments of Kate Hamond or Victoria Marles before him.

When the Commissioner’s website is updated with Monday’s news, Mr McGarvie’s official profile will presumably be posted here.  Mr McGarvie takes the post at a time when widespread dissatisfaction with the Commissioner’s office has found a focal point in one of the scathing reports of Victorian regulators the Ombudsman is not backwards in coming forwards with.  A key problem to be addressed will undoubtedly be the glacial pace at which investigations proceed.

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Pagone J hesitates before making consent order striking QC off Victorian roll

A Victorian QC was jailed this year by a County Court judge for 2 with a minimum of 6 months for possessing child pornography.  Recently, the Legal Services Board applied to the Supreme Court for an order striking him off.  The QC did not appear but communicated his willingess to be struck off by signing consent orders to that effect.  Concisely, Justice Pagone said:

1 This application is brought under s 2.4.42(5) of the Legal Profession Act 2004 (Vic) for the removal from the local roll of [the] QC who has been a member of the legal profession in this State for many years.

2 The basis upon which the application is made is the satisfaction of the Legal Services Board of the matters that it is required to be satisfied about in s 2.4.42. The matter for my consideration is whether [the QC] is, as events and facts are now known, not a fit and proper person to be on the roll.

3 The test can be seen from the three cases to which I have been referred: the Law Society of South Australia v Rodda;[1] the decision of Hansen J in Law Institute of Victoria v Gough;[2] and the more recent decision of Forrest J in Legal Services Board v Bourozikas.[3]

…

6 The conduct of [the QC] for which he has been found guilty was not conduct committed in the performance of his practice as a lawyer. Many lawyers engage in conduct which is wrongful but does not justify them being struck off the roll. The circumstances in which a lawyer, having committed an offence and has been found guilty of having committed an offence, other than in their conduct in legal practice, which justifies being struck off, is in part a reflection of community standards. However, it is not enough that an offence has been committed. Otherwise, the mere incurring of traffic fines would probably find few lawyers practicing anywhere. Continue reading “Pagone J hesitates before making consent order striking QC off Victorian roll”

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Richard Ackland’s 2009 wrap-up

Richard Ackland has reminisced about the 2009 indicia of the law’s assiness, and it’s worth a read.  Rich pickings: the artist formerly known as Justice Einfeld, Carmen Randazzo QC2B?, Anal Sheik etc. etc. none of which have been covered on these pages.  It almost tempts me to reintroduce ‘200#; law and war’, last seen in 2007, but don’t hold your breath; I have a date with Vanuatu, a tax haven which, if Kevin 07 does not convince the world to do a real deal in Copenhagen, may give a new meaning to bottom of the harbour.

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‘Snapping on’ judgment in default

Update, 1 February 2012: Glen Wright of Tas Legal brought to my attention the case of Gavin Boyle Constructions Pty Ltd v Fabrok Pty Ltd [2011] QDC 214 in which the judge set aside a regularly entered default judgment, but declined to award costs in favour of the plaintiff because it knew, pre-commencement of the proceeding, that the defendant denied liability and failed to enquire of the defendant’s solicitor whether it intended to defend before signing judgment.  His Honour relied on Coburn v Brotchie and s. 5 of Queensland’s Uniform Civil Procedure Rules, which echo the overarching obligations in Victoria’s Civil Procedure Act, 2010.

Original post: I must say I was brought up believing that there was nothing at all wrong with rushing down to the court’s registry and entering default judgment if an appearance, or defence, was not filed by the due date.  Apart from anything else, you force the other side to set out enough on oath about their case to prove an arguable defence, plus you get the psychological advantage of an early interlocutory costs order, even if the judgment is set aside, as it usually is.  But where there is reason to believe that the defendant desires to defend, the practice is frowned upon, especially where the plaintiff is represented by a solicitor who knows who represents the defendant. The duty of professional courtesy comes into play.  The procedure is really there to provide a vehicle for the production of judgments in those many cases which pass quietly through the courts, particularly the Magistrates’ Court, without the defendant participating.  In fact ‘snapping on’ default judgment in bad faith, to use the strangely quaint language of some of the older cases,  is an irregularity entitling the defendant to have the judgment set aside ex debito justitiae as they say in the classics (as of right).  And it generally carries with it a costs sanction.  I was vaguely aware of these authorities, but thought they were less unanimous and less modern than in fact they turn out to be.  I have extracted the relevant bits below. Continue reading “‘Snapping on’ judgment in default”

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Commissioner’s obligation to charge dishonesty if he intends to allege it

Relatively recently, I posted on the question of whether a Bureau de Spank desiring to rely on a practitioner’s dishonesty or other form of conscious wrongdoing must expressly allege it in the charge, and discussed Walter v Council of Queensland Law Society Incorporated (1988) 77 ALR 228 at 234; [1988] HCA 8.  Now, in Legal Services Commissioner v Madden (No 2) [2008] QCA 301 the Queensland Court of Appeal has had a go, and reversed a decision of the Court’s Chief Justice sitting on the Legal Practice Tribunal.  The solicitor had previously been disciplined in relation to his trust account.  He was charged with gross delay in litigation which resulted in applications by the other side to compel the achievement of various interlocutory steps.  He dealt with those applications without advising his client, agreed on his client’s behalf to pay costs, withdrew money to pay those costs from monies held in trust on account of fees and disbursements, and then charged the client fees for his work in fixing up his own mistake.  He also acted for both husband and wife in the preparation of a pre-nup, apparently stuffing it up, and then later acted in a matrimonial dispute for the husband alone, described as a particularly obvious conflict of duties.

The Chief Justice made findings of dishonesty in the absence of any allegation of dishonesty in the charge.  One might say, in fact, that he went out of his way to do so.  First he sought comment in relation to whether on the agreed facts, the Tribunal was free to draw inferences that dishonesty actuated the solicitor’s conduct, and invited the Commissioner to amend the charge so as to allow exploration of that issue.  His Honour adjourned the hearing to give the Commissioner time to think about that. On the return of the hearing, the Commissioner declined the invitation to amend.  So the Tribunal put out a document specifying, as a matter of procedural fairness, the inferences it was considering drawing, and invited argument.  The solicitor swore an affidavit responding to the Tribunal’s document.  The Commissioner’s counsel cross-examined the solicitor, but did not put it to him that he had acted dishonestly. The Tribunal then concluded that the solicitor had acted dishonestly, and decided to strike him off rather than go with the fine and reprimand recommended by the Commissioner.  Ooffa!

‘Wrong way. Go back!’ said the Court of Appeal.  It started with a general proposition:

’54 It is … a well recognised rule of practice in civil proceedings that, although the word “dishonesty” is not necessarily required, any charge of dishonesty must be made in clear terms.  In a well known passage in Belmont Finance Corporation Ltd v Williams Furniture Ltd & Ors [1979] Ch 250 at 268  Buckley LJ said: Continue reading “Commissioner’s obligation to charge dishonesty if he intends to allege it”

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ASIC sics solicitor

In ASIC v Somerville [2009] NSWSC 934; [2009] NSWSC 998, ASIC successfully sought to have a legal practitioner of an incorporated legal practice which employed 49 people banned from managing companies.  The solicitor is an accredited business law specialist, a member of the Committee which awards such specialisation, the founding director of what he describes as North Sydney’s leading firm, and the president of the Northern Metropolitan Law Society. He has for ten years advised companies in financial difficulties (often over tax liabilities) to transfer assets and employees but not liabilities to a new company.  It is of course the oldest trick in the thick book of insolvency practitioners’ tricks, known as a ‘Phoenix company’.

But this particular solicitor added a little flourish which he says he thought made all the difference.  He advised the directors (generally sole directors of small companies) to issue to the original company shares in the new company with rights to the first specified amount of dividends paid by the new company.  Only problem was, none of the new companies ever paid any dividends.  Acting Justice Windeyer said ‘What has really happened here is that a scheme has been devised to bring about asset stripping but to attempt to make this seem legitimate by providing for “V” class shares.’  In the Piddity Liddity transaction (I kid you not), the original company phoenixed itself twice under the same scheme, first in 2002 and then in 2006 (unlike the indescribably gorgeous bird of lore inhabiting the cool cypress forests of Lebanon who flew to Heliopolos to arise from its own ashes only once every 500 years).

Do not feel too sorry for this solicitor, for he had been warned by an accountant that one of the transactions was on the nose.  The solicitor dismissed the opinion, telling the accountant that ‘no one had challenged the transactions and “until the Court proves otherwise I will continue to promote them”.’  He gave the advice on dozens of occasions, and seems to have charged thousands of dollars in fees for each immolation and rebirthing ceremony.  He continued to do so after he was aware that ASIC was investigating the scheme.  And Acting Justice Windeyer rejected as untrue the solicitor’s statement on oath that ‘I honestly believed that the creditors would be better off if the company could continue to trade and pay off its creditors over time’. Continue reading “ASIC sics solicitor”