Iacovetta and Comcare
[2005] AATA 955
•27 September 2005
Administrative
Appeals
Tribunal
DECISION AND REASONS FOR DECISION [2005] AATA 955
ADMINISTRATIVE APPEALS TRIBUNAL )
) No A2005/231
GENERAL ADMINISTRATIVE DIVISION ) Re ANTONIO IACOVETTA Applicant
And
COMCARE
Respondent
DECISION
Tribunal Mr S Webb, Member Date27 September 2005
PlaceCanberra
Decision The Tribunal decides not to extend the time in which an application can be lodged. Mr S. Webb, Member
CATCHWORDS
COMPENSATION – practice and procedure - extension of time in which to lodge an application – exercise of discretion – extension of time not granted
Safety, Rehabilitation and Compensation Act 1988 s 14, 16, 36, 37, 53, 54, 64, 65
Administrative Appeals Tribunal Act 1975 s 29, 33
Australian Postal Corporation v Oudyn (2003) 73 ALD 659
Brisbane South Regional Health Authority v Taylor (1996) 186 CLR 541
Castellano v Inspector-General in Bankruptcy (1998) 51 ALD 254
Comcare v A’Hearn (1993) 45 FCR 441
Duong v Australian Postal Corporation [2005] FCA 991
Re Geary and Australian Postal Corporation [2001] AATA 457
Jess v Scott (1986) 70 ALR 185
Hunter Valley Developments Pty Ltd v Cohen (1984) 3 FCR 344
Maric v Comcare (1993) 17 AAR 259
Re Mulheron and Australian Telecommunications Corporation (1991) 23 ALD 309
Re Petrou and Australian Postal Corporation (1992) 25 ALD 407
Riverside Nursing Care Pty Ltd v Secretary, Department of Health and Aged Care [2003] FCA 1065
REASONS FOR DECISION
27 September 2003 Mr S Webb, Member 1. On 27 July 2005, Antonio Iacovetta (“the Applicant”) applied for review of a decision of Comcare, dated 27 March 2003, to reject his claim for compensation inrelation to an alleged back injury on 17 August 1999. He also applied for an extension of time in which to lodge that application. On 9 August 2005 the Respondent opposed the making of orders to grant the extension of time.
2. The extension of time issue came on for hearing before me on 22 September 2005, Mr D. Richards represented the Applicant. Mr P. Woulfe appeared on behalf of the Respondent. The Applicant gave oral evidence. Documents were tendered and labelled as exhibits.
facts
3. The following information is drawn from the documents and the oral evidence of the Applicant.
4. The Applicant is 34 years old (date of birth: 9 August 1971).
5. On or about April 1998 he commenced employment by the Canberra Institute of Technology (“CIT”) as a Level 1 Courier. He terminated that employment on 28 November 2000.
6. Comcare conceded that the Applicant completed an Accident Report form in respect of an incident on 17 August 1999 in which he alleged he hurt his back while loading a station wagon, reportedly describing “sore and tenderness of lower back and hip right side” (Comcare Objection, Attachment A, p1).
7. On 2 February 2002 Dr M. Hislop stated in a Centrelink Medical Certificate that the Applicant was suffering from “L5/S1 spondylolithesis of lower back” and was not able to work for more than 8 hours per week (Exhibit A, Item 4).
8. On 19 February 2002 the Applicant instructed Romano & Verducci Solicitors to act on his behalf (Exhibit A, Item 1).
9. On 9 April 2002 the Applicant signed a Claim for Rehabilitation and Compensation form (Exhibit A, Item 3) in relation to “pain in lower back” said to have occurred in July 1999 at the “Reid Cit Records management dock” (Comcare Objection, Attachment A, p1). The Applicant claimed that on the date of claim the injury affected him: “Unable to stand for long/short periods or sit for long/short periods, constant pain”. The sequence of events is described thus:
“24 …Loading back of station wagon to put mail in, moved a trolley, by pushing it to the side of the rear of the station wagon. (Trolley lying down in wagon) & felt pain in lower back.”
The Applicant acknowledged that his solicitors completed the form, which he signed.
10. In support of the claim the Applicant provided a letter by Dr B. Allan dated 14 February 2002 (Exhibit D):
“Antonio developed back pain 3 years ago. It has become progressively worse since then and he is now only able to work 3 days/wk. CT back then revealed L5-S1 spondylolithesis. His pain radiates to both legs and he experiences pins and needles…
I believe he has quite an unstable spondylolithesis, and may benefit from surgery to stabilise his lumbosacral spine.”
11. On 10 May 2002 Comcare determined to reject the Applicant’s claim for compensation, purportedly stating (Comcare Objection, Attachment A, p2):
“… based on the Accident Report signed don [sic] 18 August 21999 [sic], it is acknowledged that you suffered an injury on 17 August 1999 while loading the courier car. You did not require any medical treatment or time off work as a result of the injury. The available evidence on file is not sufficient enough to establish the relationship of your current condition to the injury sustained on 17 August 1999.”
12. On 21 June 2002 the Applicant’s solicitors requested a reconsideration of the 10 May 2002 determination.
13. On 3 September 2002 Dr R Newcombe, Neurosurgeon and Spinal Surgeon, provided a report to the Applicant’s solicitors (Exhibit C, Item 1).
14. On 27 March 2003 Comcare issued a reviewable decision affirming the primary determination to reject the Applicant’s claim for compensation. That decision was sent to the Applicant’s solicitors in a document setting out information about the Applicant’s entitlement to apply to the Administrative Appeals Tribunal for review of the decision within a period of 60 days.
15. On 24 June 2003 the Applicant’s solicitors wrote to Comcare (Exhibit B), stating:
“Our client did not receive Notice of your Decision and Reasons until 20 June 2003. This was on account of us being unable to contact our client until last week. We are instructed to apply for an extension of time to have your decision reviewed by the AAT. Our application shall follow shortly. Please advise us in the interim if you will object to our application for an extension of time to review your decision.”
16. On 1 July 2003 the Applicant’s solicitors wrote to Comcare (Exhibit A, Item 6):
“We confirm that we are instructed to apply for a review of your decision by our client.
Please be advised that we are presently obtaining medical reports arising from information which has just recently come to hand from our client, namely that he attended the surgery of Dr Hyslop (sic) of Chapman and Mr Konrad Bussman of Woden Physiotherapy following the incident at his work place on 17 August 1999. We shall provide you with copies of these medical reports upon receipt evidencing our client’s attendance at his treating practitioners following the incident at work. We trust that this may change your position. In the alternative, we shall press for a review of your decision by the AAT based on the new material, which is received.”
17. On 9 July 2003 Comcare wrote to the Applicant’s solicitors (Exhibit A, Item 7), stating:
“The determination of 27 March 2003 was a reconsideration of the determination dated 10 May 2002 under section 62(5) of the Safety, Rehabilitation and Compensation Act 1988 (the Act). Please be advised that the reconsideration decision of 27 March 2003 stands and will not be reviewed any further.
As explained in the decision under the heading “Notice of Rights” if you are dissatisfied with the decision your avenue of appeal now lies with the Administrative Appeals Tribunal. The necessary steps you need to undertake in order to pursue your client’s claim to the Administrative Appeals Tribunal is explained in the decision. Any further evidence you obtain in relation to your client’s claim will need to be submitted with your application to the Administrative Appeals Tribunal.”
18. On 18 April 2005 the Applicant’s solicitors wrote to Comcare (Exhibit A, Item 8), stating:
“We advise that we have received the following reports from our client’s treating specialists:
1. Report of Conrad Busman [sic], Physiotherapist at Woden Physiotherapy dated 11 August 2003.
2. Report of Dr Mark Hislop, Medical Practitioner dated 12 August 2003.
Kindly advise us whether you will now reconsider our client’s claim, having regard to the above reports.
In the event that you will not reconsider our client’s claim, we would be pleased if you would advise us within fourteen days of the date of this letter. We will then either file a new claim on behalf of our client or in the alternative lodge an appeal to the Administrative Appealers [sic] Tribunal.”
19. On 26 April 2005 Comcare wrote to the Applicant’s solicitors (Exhibit A, Item 9), effectively reiterating the contents of the previous letter dated 9 July 2003.
20. On 27 July 2005 the Applicant lodged an application for review of the decision dated 27 March 2003 and an application for an extension of time in which to lodge that application with the Administrative Appeals Tribunal.
legislation
21. The relevant legislation is section 65 of the Safety, Rehabilitation and Compensation Act 1988 (“the SRC Act”) and section 29 of the Administrative Appeals Tribunal Act 1975 (“the AAT Act”).
22. Section 65(4) of the SRC Act modifies s 29(2) of the AAT Act to prescribe a sixty day period in which applications for review by the Tribunal under the SRC Act may be lodged.
23. The AAT Act does not set out criteria for the exercise of the Tribunal’s discretion to extend the time in which an application for review may be lodged. However, the discretion must be exercised judicially with regard to the particular facts (Maric v Comcare (1993) 17 AAR 259).
24. Wilcox J set out guiding principles concerning applications to extend time limits imposed under the Administrative Decisions (Judicial Review) Act 1977 in the often quoted case of Hunter Valley Developments v Cohen (1984) 3 FCR 344 at 348 to 350. Those guiding principles were considered in relation to the SRC Act by the Tribunal (O’Connor J) in Re Mulheron and Australian Telecommunications Corporation (1991) 23 ALD 309, and more recently by Edmonds J in Duong v Australian Postal Corporation [2005] FCA 991 at [17]:
“[17] …Those principles may be summarised as follows:
(1) Prima facie, proceedings should be commenced within the prescribed period and an applicant for extension must show ‘an acceptable explanation of the delay’ and that it is ‘fair and equitable in the circumstances’ to extend time;
(2) Any action taken by the applicant, other than by making an application for review, is relevant to the consideration of the question whether an acceptable explanation for the delay has been furnished. A distinction is to be made between the case of a person who, by non-curial means, has continued to make the decision-maker aware that he contests the finality of the decision (who has not ‘rested on his rights’) and a case where the decision-maker was allowed to believe that the matter was finally concluded.
(3) Any prejudice to the respondent including any prejudice in defending the proceedings occasioned by the delay is a material factor militating against the grant of an extension.
(4) However, the mere absence of prejudice is not enough to justify the grant of an extension. In this context, public considerations often intrude. A delay which may result, if the application is successful, in the unsettling of other people or of established practices is likely to prove fatal to the application.
(5) The merits of the substantial application are properly to be taken into account in considering whether an extension of time should be granted.
(6) Considerations of fairness as between the applicants and other persons otherwise in a like position are relevant to the manner of exercise of the court’s discretion.”
25. As has been observed in the authorities, these guiding principles are not exhaustive in relation to the Tribunal’s discretion. I note that the absence of a reasonable explanation for the delay in bringing an application is not necessarily determinative of the question whether to grant an extension of time (Comcare v A’Hearn (1993) 45 FCR 441). What is required is the careful consideration of all relevant factors, weighing the related evidence, to determine whether it is fair and equitable in the particular circumstances to grant an extension of time. In that consideration prescribed limitation periods must be regarded as the general rule and any extension of time is the exception to the general rule (Brisbane South Regional Health Authority v Taylor (1996) 186 CLR 541).
consideration and findings
26. In making this decision I have carefully considered all of the evidence, the submissions of the parties, the relevant case law and legislation.
27. Section 29(7) of the AAT Act permits the grant of an extension of time where the person seeking the extension has applied in writing. The Applicant made written application on 27 July 2005.
28. The application is for review of a reconsideration decision made by Comcare on 27 March 2003. The time limit prescribed by the combined effect of subs 65(4) of the SRC Act and subs 29(2) of the AAT Act is 60 days from the date of that decision, that is by 27 May 2003.
29. It follows that the application is 2 years and 2 months out of time.
explanation for delay
30. The Applicant’s counsel submitted that the reason for delay in making the application to the Tribunal was that the Applicant’s solicitors were obtaining further medical evidence from Dr Hislop and Mr Bussman to submit to Comcare, with the purpose of asking Comcare to revisit its reconsideration decision (Exhibit A, Item 6). That submission is in the face of evidence that Comcare wrote to the Applicant’s solicitors on 9 July 2003 and plainly stated that any ‘appeal’ and related evidence was to the Tribunal. There is no evidence before me of any delay encountered by the Applicant’s solicitors in obtaining medical reports from Dr Hislop or Mr Bussman. I note that those reports are dated 12 August 2003 and 11 August 2003 respectively (Exhibit A, Item 4; Exhibit C) and a further report by Dr Newcombe tendered by the Applicant in these proceedings is dated 3 September 2002 (Exhibit C).
31. Counsel for the Applicant submitted that to the extent that the delay was caused by the Applicant’s solicitor, it would be unfair to deprive the Applicant of the right to pursue his claim (Re Petrou and Australian Postal Corporation (1992) 25 ALD 407). As Hill J said in Comcare v A’Hearn (1993) 45 FCR 441 citing Jess v Scott (1986) 70 ALR 185, it is not a principle of law to be applied that the sins of solicitors must be visited upon their clients. However, in different circumstances O’Loughlin J said in Maric v Comcare (supra at 264):
“If it be said that it is not fair that the applicant should suffer the transgressions of his legal advisers, then likewise it must also be said that it is not fair that the respondent should suffer from those same transgressions.”
32. It is plain that the Applicant’s solicitor’s, and therefore the Applicant, were alive to the sixty day time limit. That fact is confirmed by the contents of the letters the Applicant’s solicitors wrote to Comcare on 24 June 2003 and 1 July 2003.
33. I am satisfied that the Applicant decided not to pursue his right of review under the SRC Act at that time in full knowledge that he had sixty days in which to apply for such a review. I am also satisfied that the Applicant understood that delaying the exercise of his right to review under the SRC Act outside the prescribed time period may subsequently preclude him from commencing proceedings in the Tribunal to that end. The Applicant made a deliberate and strategic choice not to seek review of the decision in issue, at that time, deciding instead to obtain further medical reports with the intention, rightly or wrongly, of persuading Comcare to change its reconsideration decision without recourse to the Tribunal.
34. It is clear that the Applicant decided to lodge an application for review by the Tribunal in consequence of his failure to persuade Comcare in that regard. However, a significant period of time elapsed, without any reasonable explanation, from the date of the medical reports in question and the date of his subsequent application to the Tribunal. That being so, I am satisfied that the Applicant rested on his rights under the SRC Act, albeit for reasons that remain opaque in these proceedings. No cogent evidence was adduced to explain the delay. If it was the fault of the Applicant’s solicitor, as implied by Mr Richards, there would need to be a compelling reason to grant the extension after such a long period in order to mitigate the manifest unfairness to Comcare that would otherwise accrue.
35. I find that his application did not provide any reasonable explanation for the delay in lodging the application that is supported by evidence. However, following Comcare v A’Hearn (supra), this does not conclude the matter.
action taken
36. The Applicant submitted that his intentions to pursue his rights under the SRC Act were made clear in correspondence from his solicitors to Comcare dated 24 June and 1 July 2003.
37. I accept that that was the case at the time. However, there is no evidence before me that the Application took any action to inform Comcare that the matter remained on foot in the period from 1 July 2003 to 18 April 2005. It is reasonable for Comcare to presume, after the passage of a reasonable period without any communication from the Applicant to the contrary, that the Applicant was resting on his rights under the SRC Act and that the matter was concluded. The proposition that notice given by the Applicant that the matter was not final on 1 July 2003 would continue to have currency almost two years later has no merit.
38. Foster J observed in Castellano v Inspector-General in Bankruptcy (1998) 51 ALD 254 at p259:
“It is important, therefore, to bear in mind in an extension of time application that when regard is paid to activities by the applicant, which have been undertaken instead of making the appropriate application, those activities are of significance only if they are such as to have brought to the attention of the respondent to the application that the applicant has it in mind, even though he is becoming out of time, to take some steps to assert the rights which would be given effect by his making the relevant application. Conversely, he will have it count against him in the application if he has taken steps which might allow the respondent to think that the matter has come to an end.”
39. In this case, while notice was given of the Applicant’s intentions to contest the decision in question, and that notice is relevant for present purposes, I accept that the force of the notice diminished with the effluxion of time in the absence of further action by the Applicant.
40. In the circumstances, I find the Applicant failed to take action to inform Comcare of his intentions to progress his rights under the SRC Act for an unreasonable period of time after July 2003, to the extent that Comcare was justified in presuming the case to be closed.
prejudice
41. In the Applicant’s submission Mr Richards contended that Comcare had not raised any issue of prejudice and, as the Applicant “continued” to write to Comcare in relation to the aforementioned medical reports, there could be no prejudice. Mr Richards submitted that as the Applicant was examined by Dr Newcombe (Exhibit C) and Dr Cillo (Exhibit A, Item 10) prior to the reconsideration decision, and Comcare could now proceed to have the Applicant’s present status assessed by a medicolegal expert, no prejudice would flow from granting an extension of time. I do not accept those submissions.
42. As was made plain during the Applicant’s oral evidence, the effluxion of time adversely affects the quality of available evidence. Long delay gives rise to a presumption of prejudice: where there is delay the whole quality of justice deteriorates (Brisbane South Regional Health Authority v Taylor (supra) at pages 551-552).
43. In Comcare’s submission prejudice would flow if the extension of time is granted as, over a six year period from the date of the claimed injury, Comcare had no opportunity to minimise its costs and exposure to risk pursuant to the medical treatment and rehabilitation provisions of the SRC Act (ss 16, 36 and 37) in relation to the Applicant. That submission presupposes a decision favourable to the Applicant in relation to the threshold question of Comcare’s liability under the SRC Act for the claimed injury prior to any change or deterioration in that injury or consequent effects that may be compensatable, such as incapacity for work or impairment. The primary and reconsideration decisions Comcare made were to reject that threshold of liability. I do not accept, therefore, that Comcare is entitled now to complain of prejudice prior to the end of the period of limitation after the reconsideration decision. In the words of Kirby J in Brisbane South Regional Health Authority v Taylor (supra) at page 573:
“In judging prejudice, for the purposes of considering the order extending time, the matter to be weighed is the increase of prejudice after the expiry of the ordinary period of limitation. Until that time the law, as expressed in the Act, envisages that the defendant must accept any prejudice or delay without complaint.”
44. This case must be distinguished from that of Re Geary and Australian Postal Corporation [2001] AATA 457. In Ms Geary’s case liability was accepted for an injury and the Respondent subsequently determined to cease liability, the delay in the Applicant requesting review of that decision was said to have founded prejudice against the Respondent. That is not the case in these proceedings in which Comcare has not accepted liability to pay compensation in relation to an injury, whether in the form of medical treatment expenses or otherwise.
45. More salient is Comcare’s assertion of prejudice flowing from purported deterioration in the Applicant’s spinal condition subsequent to the expiration of the limitation period, and the difficulty obtaining contemporaneous evidence to ascertain whether any of those exacerbations constitute a novus actus intervienens. On the Applicant’s oral evidence, he experienced exacerbations of the symptoms of his spinal condition on a number of occasions and consulted a number of medical practitioners over time about his back condition, but could not recall when or how often such consultations took place. His own evidence was that he encountered difficulties obtaining relevant evidence because he was unable to locate certain of his treating doctors, such as Dr Polland for example, and his memory was hazy.
46. On that basis I accept that Comcare may encounter greater difficulty obtaining relevant contemporaneous medical and employment records for the purpose of properly assessing the status of the Applicant’s spinal condition before and after the claimed injury as a result of the Applicant’s delay in progressing his rights of review under the SRC Act than otherwise would have been the case had the matter been progressed within the prescribed time. On that basis I find that there is prejudice to Comcare.
47. To the extent that the Applicant contended an absence of prejudice to Comcare as a result of delay on the basis that he could make another application following Re Liu and Comcare [2004] AATA 617 and Australian Postal Corporation v Oudyn (2003) 73 ALD 659 if an extension of time is not granted, I do not agree. As I comprehend that submission, it is posited that the cases of Re Liu and Oudyn are authority for the proposition that the Applicant is not precluded from making a claim in relation to his alleged injury at any time. However, those cases are concerned with continuing liability once liability has been accepted for an injury by determination pursuant to s14 of the SRC Act. That is not the case in these proceedings.
48. The Applicant did not submit that there was any prejudice to him if the extension of time is not granted, contending that he would proceed to make a fresh claim in that event.
other people and established practices
49. Counsel for the Applicant submitted that as no decision was binding into the future, following Re Liu and Oudyn, there would be no effect on other persons, especially other applicants, if an extension of time is granted. That submission misapprehends the cited cases. The general rule expressed by the High Court in Brisbane South Regional Health Authority v Taylor (supra) is not so easily dispensed with. The Respondent asserted that the public interest is against the disruption of established practices whereby matters involving public funds may be dealt with expeditiously. That is plainly the case but issues of fairness and equity may intrude. I am satisfied that the public interest and the interests of those claimants, and solicitors acting on their behalf, who comply with the prescribed time limits, may well be unsettled by perceptions of unfairness and uncertainty, and concern about a lack of expedition dealing with public monies under the SRC Act, that may arise if the prescribed time limits in this case are set aside without good reasons.
merit
50. It is for the Applicant to show merit in the substantive application.
51. There is some evidence to support the Applicant’s claim, on which basis it cannot be said that the application is so lacking in merit that permitting it to proceed would be an exercise in futility. However, it must be said that the Applicant’s case will turn on evidence that is not before me. The evidence that is before me does not suggest that the decision in question was improperly made or infected with legal error (Riverside Nursing Care Pty Ltd v Secretary, Dpartment of Health and Aged Care [2003] FCA 1065 at [20]).
fairness
52. The Tribunal is satisfied that granting an extension of time in this case may be unfair to other applicants for review under the SRC Act who have pursued their right of review within the prescribed period. The Parliament prescribed an appropriate period in which a person may apply for review of a decision. The certainty of closure on completion of that period, or at least within a reasonable time thereafter if the circumstances warrant such extension, is important to the operation of the Commonwealth worker’s compensation scheme as a whole. Disturbing the prescribed limit without good reason would be unfair to applicants and respondents alike.
53. Counsel for the Applicant urged me to consider the effect of not granting an extension of time in this case in relation to paragraph 33(1)(b) of the AAT Act, on the basis that the Applicant, in such circumstances, would merely make a fresh claim. The aforementioned paragraph provides :
“33(1) In a proceeding before the Tribunal:
…
(b) the proceeding shall be conducted with as little formality and technicality, and with as much expedition, as the requirements of this Act and of every other relevant enactment and a proper consideration of matters before the Tribunal permit;
…”
Plainly the administrative expedition contended for by the Applicant in this submission must be consistent with the requirements of the combined effect of the SRC Act and the AAT Act. The possibility that not granting an extension of time in which to make an application for review under the SRC Act may lead to a fresh claim for compensation, alone, is not a potent factor in this case. It raises the issue of administrative efficiency in addressing a claim for compensation under the SRC Act. It is a curious proposition for the Applicant to make in these proceedings: for reasons relating to the efficient processing of his claim that he should be granted an extension of over 2 years in which to bring his application for review to the Tribunal. If there was a reasonable explanation for his delay in progressing his rights under the SRC Act and a basis of unfairness or equity in the particular circumstances, that submission may add its measure of weight to the balance. In the absence of evidence to support any such conclusion, it does not.
54. In the circumstances no such basis exists and there is no merit in the proposition that administrative efficiency or the expedition of Tribunal proceedings should outweigh other salient considerations that are consistent with the cited authorities.
55. Plainly under the SRC Act the Applicant had a right to apply to the Tribunal for review of Comcare’s reconsideration decision. Counsel for the Applicant asserted that it would be unfair to deny him that right now. I do not agree, the Applicant’s rights under the SRC Act exist within prescribed limits. Extending those limits requires consideration of issues of fairness and equity. In that consideration the claimed unfairness to the Applicant if an extension of time is not granted must be weighed in relation to issues of fairness and equity to Comcare and more broadly.
conclusion
56. I am satisfied that it would not be fair and equitable to extend the time in which to lodge the substantive application in these proceedings. The Applicant’s explanation for the delay is not reasonable in the circumstances. He has benefited from legal representation at all material times and there is no sound reason why Comcare should suffer the transgressions of his legal advisers in the circumstances. He was aware of the time limit in which to lodge his application and he chose to ignore it. He did not take any action to inform the Respondent of his desire or intention to progress his claim for an unreasonable period of almost two years. The Respondent was entitled to assume that the matter was closed. By the Applicant’s own account there is difficulty now obtaining relevant contemporaneous medical evidence. It would be unfair to permit the matter to be resuscitated two years and two months after the expiration of the limitation period.
57. The Tribunal decides that an extension of time will not be granted.
I certify that the 57 preceding paragraphs are a true copy of the reasons for the decision herein of Mr S. Webb, Member
Signed:
AssociateDate of Hearing 22 September 2005
Date of Decision 27 September 2005
Counsel for the Applicant Mr D Richards
Solicitor for the Applicant Ms B Romano, Romano Satsia Kordis Legal
Solicitor for the Respondent Mr P Woulfe, Dibbs Abbott Stillman
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