Kehoe & Seden (No 4)
[2023] FedCFamC1F 753
FEDERAL CIRCUIT AND FAMILY COURT OF AUSTRALIA
(DIVISION 1)
Kehoe & Seden (No 4) [2023] FedCFamC1F 753
File number(s): SYC 7833 of 2018 Judgment of: HARPER J Date of judgment: 1 September 2023 Catchwords: FAMILY LAW – PROPERTY – INTERIM PROPERTY – Where wife seeks compliance with previous orders – Where wife seeks payment by husband of outstanding single expert fees – Where estimated single expert fees are substantial – Where consent orders were previously made requiring husband to meet the costs of the single experts in the first instance – Where wife to reimburse husband for her share of the single expert fees from final property adjustment – Where husband seeks to discharge consent orders – Where husband claimed he no longer had the financial resources to pay the single expert fees – Where husband did not satisfy the Court that consent orders made four months previously should be discharged – Where the wife seeks payment of interim costs in the amount of $500,000 or a dollar for dollar costs order – Where husband claimed he no longer had financial resources to pay interim costs to the wife – Where husband previous received significant financial assistance from the second respondent – Where husband and second respondent argued the second respondent would no longer provide husband with financial support – Husband and second respondent directors of trustee of testamentary trust – where testamentary trust has lent husband substantial funds since 2017 - Where Court satisfied husband has sufficient access to funds to pay single expert fees and a dollar for dollar order in favour of wife – Consent order not discharged – Dollar for dollar order made in favour of wife. Legislation: Family Law Act 1975 (Cth) Pt VIII
Federal Circuit and Family Court of Australia Act 2021 (Cth) ss 67(1), 67(2), 68
Cases cited: Bing and Bing (2007) FLC 93-318; [2007] FamCA 418
Hall v Hall (2016) 257 CLR 490; [2016] HCA 23
Kehoe & Seden (No 2) [2022] FedCFamC1F 346
Kennon v Spry (2008) 238 CLR 366; [2008] HCA 56
Poletti & Poletti (1990) 15 Fam LR 794; [1990] FamCA 79
Seden & Kehoe [2020] FamCAFC 294
Salvage and Fosse (2020) FLC 93-966; [2020] FamCAFC 144
Division: Division 1 First Instance Number of paragraphs: 46 Date of hearing: 26 July 2023 Place: Sydney Counsel for the Applicant: Mr Kearney SC Solicitor for the Applicant: Rubn Blight Hardy Family Lawyers & Mediators Counsel for the First Respondent: Mr Bennett Solicitor for the First Respondent: Coleman Greig Lawyers Counsel for the Second, Third, Fourth, Fifth, Sixth, Seventh, Eighth, Ninth and Tenth Respondents: Ms Jeliba Solicitor for the Second, Third, Fourth, Fifth, Sixth, Seventh, Eighth, Ninth and Tenth Respondents: Barkus Doolan Winning ORDERS
SYC 7833 of 2018 FEDERAL CIRCUIT AND FAMILY COURT OF AUSTRALIA (DIVISION 1)
BETWEEN: MS KEHOE
Applicant
AND: MR SEDEN
First Respondent
MS G SEDEN
Second Respondent
SEDEN GROUP HOLDINGS PTY LTD (and others named in the Schedule)
Third Respondent
ORDER MADE BY:
HARPER J
DATE OF ORDER:
1 SEPTEMBER 2023
THE COURT ORDERS THAT:
1.Within 21 days of the date of these orders the First Respondent Husband (“husband”):
(a)Sign the QQ Valuers Fee Proposal dated 26 May 2023 and pay the deposit invoice of QQ Valuers in the sum of $142,065.
(b)Pay RR Valuers outstanding Invoices identified below:
(i)$5,595.00 for SS Street, Suburb TT QLD;
(ii)$3,850 – UU Street, Suburb R;
(iii)$12,100 for VV Street, Suburb WW; and
(iv)$6,600 for XX Street, Suburb YY.
2.The husband pay or cause to be paid any further invoices from the appointed single experts RR Valuers, QQ Valuers and ZZ Accountants by the due date specified on any such invoice.
3.Pursuant to s 117 of the Family Law Act 1975 (Cth):
(a)Within seven days of any and all future payment(s) by or on behalf of the husband in payment of:
(i)Accounts rendered by the husband’s solicitors; and/or
(ii)Accounts rendered by the husband’s barrister(s); and/or
(iii)A request made by the husband’s solicitors to hold funds in trust on behalf of the husband, including costs on account of anticipated counsel’s fees (excluding for the payment of any single expert fees for which the husband is liable pursuant to orders);
the husband shall pay or cause to be paid, the same sum of money to the trust account of the solicitors for the Applicant Wife (“wife”), for the wife’s legal costs and disbursements in these proceedings.
THE COURT NOTES THAT:
A.Any outstanding interlocutory applications will be subject to further directions upon the Court hearing from the parties.
Note: The form of the order is subject to the entry in the Court’s records.
Note: This copy of the Court’s Reasons for judgment may be subject to review to remedy minor typographical or grammatical errors (r 10.14(b) Federal Circuit and Family Court of Australia (Family Law) Rules 2021 (Cth)), or to record a variation to the order pursuant to r 10.13 Federal Circuit and Family Court of Australia (Family Law) Rules 2021 (Cth).
Section 121 of the Family Law Act 1975 (Cth) makes it an offence, except in very limited circumstances, to publish proceedings that identify persons, associated persons, or witnesses involved in family law proceedings.
IT IS NOTED that publication of this judgment by this Court under the pseudonym Kehoe & Seden has been approved pursuant to s 121(9)(g) of the Family Law Act 1975 (Cth).
REASONS FOR JUDGMENT
HARPER J:
INTRODUCTION
These are complex property proceedings under Pt VIII of the Family Law Act 1975 (Cth) (“the Act’) between the applicant wife, Ms Kehoe (“the wife”) and first respondent husband Mr Seden (“the husband”). The proceedings were commenced by the wife in December 2018 seeking an alteration of property interests and spousal maintenance pursuant to the Act.
Issues in these proceedings have been the subject of a number of earlier judgments (Seden & Kehoe [2020] FamCAFC 294 (“Seden & Kehoe”) and Kehoe & Seden (No 2) [2022] FedCFamC1F 346 (“Kehoe & Seden (No 2))). I refer to these earlier judgments and note they relieve me of the necessity of setting out, except to the extent necessary, the relevant background.
However, I note here that the second respondent is the mother of the husband. The third to seventh respondents are members of the husband’s family, and the eighth to tenth respondents are companies relevant to the relief sought by the wife. The eleventh to eighteenth respondents were joined by consent on 26 July 2023.
The proceedings are listed for final hearing commencing on 27 November 2023 with an estimate of 10 days.
BACKGOUND
By an Amended Application in a Proceeding filed on 7 July 2023, the wife sought a range of orders including compliance with orders made on 2 March 2021 and 2 March 2023 for the payment by the husband of outstanding single expert fees, and payment of interim costs to the wife in the sum of $500,000, or alternatively a dollar for dollar costs order. The wife sought other orders including orders for further disclosure, the joinder of additional parties and leave to further amend her Initiating Application.
The wife’s case outline filed 24 July 2023 introduced a proposed order for the sale of the property known as W Street, Suburb E (“Suburb E property”) in the event the husband defaulted in making payments ordered by the Court. The property is owned by the husband. He currently resides there with his second wife and their infant child. However, this part of the relief was not pressed by the wife at the hearing before me on 26 July 2023. Senior counsel accepted that in the event the wife succeeds in obtaining orders for payment of experts’ fees and interim costs, it is open to her to make a further application for the sale of the Suburb E property in the event of the husband’s default.
Procedural orders made on 7 July 2023 required the husband’s response to the wife’s interlocutory application to be filed by 18 July 2023. By his Response to an Application in a Proceeding filed on 20 July 2023, the husband resisted the orders sought by the wife regarding litigation funding and payment of the single expert’s fees. He also sought an order bifurcating the proceedings and for the wife to serve updated points of claim. His response also sought a discharge of an order made on 13 December 2019 requiring him to pay the wife $1,000 per week by way of interim spouse maintenance.
The interlocutory applications and responses were listed for hearing before me on 26 July 2023. On that occasion, a number of issues were dealt with by consent including joinder of additional parties, dismissal of the husband’s application for bifurcation, issues of disclosure and the provision of further amendment by the wife. By reason of the late filing of his Response to an Application in a Proceeding, the wife was unable to meet, on 26 July 2023, the husband’s application for discharge of the spouse maintenance order. This remains to be determined if the husband presses it.
Accordingly, this judgment deals only with the contested issues of payment of the expert’s fees and interim costs to be paid in favour of the wife, either by lump sum or a dollar for dollar costs order.
INTERIM COSTS
There was no contention that the size of the lump sum payment of interim costs sought by the wife was inappropriate. The proceedings involve complex issues. The husband's estimate of likely future fees in fact exceeded $500,000. Rather, it was the husband’s argument that he no longer had any capacity to pay for either of the expert’s fees or to pay interim costs to the wife.
In summary, he claimed that this was because the support he had been receiving from his mother, who is the second respondent, had been withdrawn, and the only asset available to him from which he might satisfy in any order for interim costs was the Suburb E property.
There was evidence from the second respondent that she is not prepared to continue providing any financial support to the husband to cover a range of expenses. The second respondent gave the following evidence:
15. Save for the expenses relating to my granddaughter in paragraph 16 below, I am no longer prepared to lend money to [the husband] (and I am not prepared to lend money to [the wife]), whether to meet the following expenses in relation to these proceedings or otherwise:
15.1The cost of valuations for the purpose of these proceedings;
15.2 The legal costs and disbursement of [the husband] in relation to these proceedings;
15.3 The legal costs and disbursements of [the wife] in relation to these proceedings, including but not limited to the proposal in [the wife’s] Application that [the husband] pay her $500,000 or dollar-for-dollar Orders; or
15.4 The cost of spouse maintenance Orders previously made against [the husband] in these proceedings.
(Second respondent’s affidavit filed 18 July 2023)
She went on to say:
16. I am however prepared to continue to lend money to [the husband] at my discretion so that he can make monthly payments of $3500 to [the wife] strictly for the purpose of meeting day-to-day living expenses of their child, who is my granddaughter.
(Second respondent’s affidavit filed 18 July 2023)
It was undisputed that the husband has entered into an unregistered mortgage in favour of his mother over the Suburb E property to secure monies already advanced by her to him. According to the second respondent, as at 18 July 2023, the husband owes her a total of $1,526,848.20 excluding interest.
I interpolate here that the value of the Suburb E property was disputed. The wife relied upon a market appraisal from AB Real Estate dated 15 June 2023 giving estimates of value between $2.3 and $2.5 million (Wife’s affidavit filed 22 June 2023, p.163). The husband tendered another appraisal (Exhibit D) dated the 26 July 2023 which estimated the value of the property to be between $1.7 and $1.85 million.
Accordingly, at the lower end of the values there would be very little equity in the property once the loan outstanding to the second respondent is taken into account. At the upper end of the range there would be equity in the property of close to $1,000,000. At this point in the proceedings I am unable to form any sensible view about which property appraisal is more likely to be accurate. I will assume that the property has a value of no less than between $1.85 and $2.3 million taking the upper end of the wife's proffered value and the lower end of the husband’s proffered value.
If the Suburb E property was the only asset available to satisfy the wife's claim for interim costs and payment of the expert's fees it would appear to be unlikely that the husband had capacity to pay either interim costs or experts’ fees. However, this is not the end of the matter.
Financial resources available to the husband
In Kehoe & Seden (No 2), I recorded the following matters:
3.According to the wife, relevantly, the material property interests comprise a unit at Suburb E, with net equity of $1.4 million held by the husband, the husband’s interest in a […] business said to be of negligible value, and the husband’s interest in a group of companies called the Seden Family Group (“the Seden Group”). It is the wife’s claims in respect of these latter interests in particular, which raise factual and legal issues of some complexity.
4.The wife has also filed and served Points of Claim on 3 May 2021. It is unnecessary to canvass these in great detail. They make clear that a central issue in the proceedings is the nature, extent, and value of the husband’s interests and entitlements in and to, and the benefits which have been previously received, or will be receivable in the future by the husband from the H Seden Family Testamentary Trust (“the Testamentary Trust”) and the Estate of the late Mr F Seden and the Seden Group, which includes the Testamentary Trust.
5.The Seden Group is comprised of a number of entities. The relationship and the relations between those entities are governed, in part at least, by the Seden Family Group Rules (“the Group Rules”) dated 20 January 2014.
I pointed out in Kehoe & Seden (No 2) (referring to Seden & Kehoe at [49]):
7.There have been judgments in this Court and the Full Court on appeal in which comment has been made that there are financial resources available to the husband within the Seden Group, and that there can be no doubt that the husband’s interest in the Testamentary Trust “involved something more than an expectation of benevolence on the part of his mother and brothers”.
In relation to the concept of “financial resources” as referred to in s 75(2) of the Act, in Kennon v Spry (2008) 238 CLR 366, Gummow and Hayne JJ said at [96] “[t]he term ‘financial resources’ is apt to include more than assets which answer the definition of ‘property’” in the Act. In Hall v Hall (2016) 257 CLR 490 the High Court said:
54....The requirement that the financial resource be that "of" a party no doubt implies that the source of financial support be one on which the party is capable of drawing. It must involve something more than an expectation of benevolence on the part of another. But it goes too far to suggest that the party must control the source of financial support. Thus, it has long correctly been recognised that a nominated beneficiary of a discretionary trust, who has no control over the trustee but who has a reasonable expectation that the trustee's discretion will be exercised in his or her favour, has a financial resource to the extent of that expectation
55.Whether a potential source of financial support amounts to a financial resource of a party turns in most cases on a factual inquiry as to whether or not support from that source could reasonably be expected to be forthcoming were the party to call on it.
The wife relied upon authorities such as Salvage & Fosse (2020) FLC 93-966, Poletti & Poletti (1990) 15 Fam LR 794 and Bing and Bing (2007) FLC 93-318 in support of her submission that it is unnecessary for the Court to take the husband's assertion of an absence of capacity at face value. Rather, the Court only needs to be satisfied of an interlocutory finding that the husband has sufficient financial resources to meet the orders.
I will continue to refer to the H Seden Family Testamentary Trust as the “Testamentary Trust” for the purposes of this judgment, noting the background discussed in my earlier judgments. It was the wife’s contention that I should be satisfied, at an interlocutory stage, that the resources of the Testamentary Trust are financial resources “of” the husband which could be used to meet the orders for payment which she seeks.
In support of this contention, the wife pointed out that at a meeting in June 2020 with the members of the Seden family, it was confirmed that the principle underlying the Q Seden Family Trust was that each child was to be treated “equally” and “own a comfortable home without stress of a mortgage” (Wife’s affidavit filed 22 June 2023, p.177). Pursuant to this intention, each child is the beneficiary under a testamentary trust. In respect of at least three of the five children, distributions have continued to be made in their favour from those trusts.
Equality of treatment appears to have meant that the husband and his siblings were each to receive an entitlement of $3,381,093. In the husband’s case, when the value of the Suburb E property was taken into account, this meant he required an additional payment of $2,000,468 (Wife’s affidavit filed 22 June 2023, p.178). This was described as a “True-Up Allocation”. The husband claimed this was not an accrued entitlement for which he could call on immediate payment. Such allocations were also made to the husband’s other siblings, but in differing amounts which took account of differences in their individual circumstances. There was evidence that three of the six children had received a payment of their “True-up” allocation. However, there was no evidence that all “True-up” allocations had been paid to all children, or that the husband had received his allocation.
Neither the husband nor the second respondent gave any evidence about the “True-up” allocation. Their evidence did not explain how this possible financial resource may or may not have resulted in a payment to the husband.
However, it was the husband’s evidence that he has received financial support from the Testamentary Trust by way of a loan account since at least 2017. The debit balance of this loan account as at 31 March 2023 was $922,245.06 (Husband’s affidavit filed 19 July 2023, paragraph 48). He has also been loaned monies from the Q Seden Family Trust in the past. On 14 February 2020 the total amount owing was $560,166.87 (Husband’s affidavit filed 19 July 2023, paragraph 53). The second respondent gave evidence that she was assigned this outstanding debt and it forms part of the $1,526,848.20 owed to her by the husband (Second respondent’s affidavit filed 18 July 2023, paragraph 7).
Correspondence from DD Pty Ltd, the accountants for the Seden Group, dated 21 July 2021 set out a table of “high-level” approximations of movements in beneficiary loan accounts in a number of the testamentary trusts comprising the Seden Group (Exhibit A). The letter was addressed to the solicitors for the second to tenth respondents, for the purpose of compliance with court orders for disclosure. However, there was no mention of the husband in this table.
The husband argued that any distributions to him from the Testamentary Trust were used to offset his loan account and therefore, he does not actually receive any distribution in cash. The wife argued that this was the result of an election by the husband, that is, he chose to use distributions from the trust to offset his liabilities to the same trust. However, the husband gave evidence that it was the term of any loans made to him by the trust that distributions will be used to discharge his loan account, and the loan transactions ledger showed this has been the manner of dealing with his distributions since 2017.
The husband pointed out that he has already paid to the wife amounts totalling approximately $464,000. He further argued that the parties were in an equal position but the orders sought by the wife in truth were not to level the playing field but were to place an inappropriate burden upon the husband to pay her costs in advance.
I am unable to find for the purposes of the present application that the husband has a present entitlement to a substantial “True-up” payment, with a value of up to $2,000,000. I do not discount the possibility that he has such an entitlement but further evidence is needed before a finding could be made.
Having said that, the corporate trustee of the Testamentary Trust is J Pty Ltd. The husband and the second respondent are the only directors and shareholders of the trustee. They control its decisions as trustee. This evidence satisfies me that, even if the second respondent has decided to withdraw financial support by providing further loans funds, this does not exhaust the husband’s financial resources.
Rather, the evidence of the husband and second respondent shows a pattern dating from at least 2017 of the husband receiving ongoing substantial loan monies from the Testamentary Trust each year. Individual loan amounts have been significant on occasion, and the cumulative amounts advanced since 2017 have been considerable. It is true that distributions from the trust are used to reduce the debit balance of this loan account. But that account has operated as a running account, so that even after repayments have been made from trust distributions, further monies have been lent to the husband.
Bearing in mind that the husband and the second respondent control the trustee, it is noteworthy that neither states in their evidence that for some reason they would cause the trustee to decline a request from the husband for further support by way of loan. They do not claim that the Testamentary Trust would be unable to meet a call for further loan monies from the husband. There is no evidence that the trust intends to call for immediate repayment of the monies owed by the husband, and any such suggestion would be unconvincing, considering the husband is one of the directors controlling the trustee.
On the contrary, the wife tendered a resolution, dated 28 June 2023, passed by the husband and the second respondent as directors of J Pty Ltd to the effect that the husband would receive a distribution of 100 per cent of net income of the Testamentary Trust for the financial year ended June 2023 (Exhibit A). Neither the husband nor the second respondent made any mention of this resolution in their affidavits, both of which were affirmed and filed several weeks after the resolution was passed. They gave no evidence of the likely quantum of any distribution to the husband from the Testamentary Trust.
However, drawing a reasonable inference from the past pattern of the conduct of the husband’s loan account, once the 2023 distribution has been credited against the loan account, there is no basis put forward by the husband or second respondent to conclude that the husband could not be lent further funds. Consequently, I am able to find that further loan monies could reasonably be expected to be forthcoming if the husband were to call on them.
EXPERT FEES
The husband relied upon the same arguments about incapacity to seek a discharge of the existing orders that he meet the fees of the single experts. The second respondent gave evidence that she is no longer willing to lend money to the husband to pay the experts’ fees.
There was no dispute that the expert fees will be considerable, up to $315,000. There was also no dispute that the likelihood of fees in the order of this magnitude has been known to the parties for approximately two years.
It is the wife who presses for valuations of trusts and companies which make the expert evidence necessary. In those circumstances prima facie it would be appropriate for her to meet the costs in the first instance. However, orders concerning expert evidence have been made on five occasions in the proceedings since March 2019. Orders were made by consent on 2 March 2022, which noted the husband’s agreement to meet the costs of the necessary experts’ reports in the first instance, with the wife’s liability for half to be met through an adjustment to any final property orders in her favour. The wife claimed that she does not have the capacity herself to pay, although she has been receiving financial support from her own parents.
The wife pointed out that the second respondent had been joined to the proceedings well before the date of the orders pertaining to payment of expert fees, and gave her consent to those orders. The orders required all respondents to sign a letter of engagement from one single expert, ZZ Accountants and provide documents. Accordingly, it is clear that it is the husband who must meet the fees out of his own resources before the single expert evidence can be prepared. As pointed out by the wife, these orders were made in court on occasions where the second respondent was present and represented so it could not be argued that the quantum of the costs was a matter which caused surprise to any of the parties.
The purpose of single expert evidence is to assist the Court and the parties with necessary evidence, and by avoiding as far as possible the need to resolve competing expert evidence. If the evidence is not produced, it is difficult to see how the trial listed at the end of November 2023 will be able to proceed. Accordingly, it is imperative that the evidence be produced in good time before the trial. In the face of a consent order, which was made only some four months ago, in my view the husband has not put forward a sufficient basis for the order to be discharged. The withdrawal of financial support from his mother in not persuasive in this regard. Although the second respondent is not bound by the consent order for payment of experts’ fees, there can be no doubt that she knew this liability would fall on the husband, whom she was supporting financially when the consent order was made.
All parties are bound by s 68 of the Federal Circuit and Family Court of Australia Act 2021 (Cth) to conduct the proceedings “in a way that is consistent with the overarching purpose”. The “overarching purpose” is set forth in s 67(1). The purpose is to facilitate the just resolution of disputes according to law; and as quickly, inexpensively and efficiently as possible. Subsection 67(2) specifies, among the objectives of the overarching purpose, the efficient use of the judicial and administrative resources available for the purposes of the Court, the efficient disposal of the Court's overall caseload, the disposal of all proceedings in a timely manner and the resolution of disputes at a cost that is proportionate to the importance and complexity of the matters in dispute.
Orders have already been made by consent for the payments of experts’ fees, and the onus falls on the husband to put forward a persuasive basis to discharge those orders. The Court itself should be astute not to act inconsistently with the overarching purpose. The liability of the husband to meet expert fees was entered into consensually. The final hearing is listed to commence on 27 November 2023, with an allocation of 10 hearing days. If the expert fees are not met, it is unlikely any of the proposed expert evidence will be prepared. There is a real risk therefore that a material aspect of the wife’s claims will be unsupported by the necessary expert evidence. This could lead either to failure of that part of her claim or an application for adjournment of the final hearing. Either outcome would cause injustice, not only primarily to the wife, but all parties, in these proceedings, and also to other litigants in the Court because further hearing time would have to be allocated.
The amount of costs already expended by the parties in these proceedings is enormous. It is not self-evident that these costs are proportionate to the complexity of the issues in dispute, but this is a question which cannot yet be answered with any clarity. However, any delay in the finalisation of the proceedings is likely to increase costs, which itself is inconsistent with the objectives of the overarching purpose, especially when viewed against the maters mentioned in the previous paragraph.
CONCLUSION
The husband’s evidence satisfies me that the Testamentary Trust is more likely than not to lend him sufficient funds to continue to meet his spouse maintenance obligations. The more difficult question is whether the trust is in a position to lend him as substantial an amount as $500,000 for the wife’s interim costs and to meet the payment of expert’s fees, which together would total about $800,000.
I do not consider that the husband has demonstrated a sufficient basis to discharge the existing order for him to meet the expert fees. He must comply with that order.
In the circumstances and at this stage of the proceedings, the wife’s proposed dollar for dollar costs order is more appropriate than ordering a lump sum payment of $500,000 for her interim costs. I will make such an order.
I certify that the preceding forty-six (46) numbered paragraphs are a true copy of the Reasons for Judgment of the Honourable Justice Harper. Associate:
Dated: 1 September 2023
SCHEDULE OF PARTIES
SYC 7833 of 2018 Respondents
Fourth Respondent:
Z PTY LTD
Fifth Respondent:
P PTY LTD
Sixth Respondent:
MR K SEDEN
Seventh Respondent:
MS HALEY
Eighth Respondent:
MR L SEDEN
Ninth Respondent:
MS AC SEDEN
Tenth Respondent:
MR M SEDEN
Eleventh Respondent:
AD PTY LTD AS TRUSTEE FOR THE MR K SEDEN FAMILY TESTAMENTARY TRUST
Twelfth Respondent:
AE PTY LTD AS TRUSTEE FOR THE H SEDEN FAMILY TESTAMENTARY TRUST
Thirteenth Respondent:
J PTY LTD AS TRUSTEE FOR THE H SEDEN FAMILY TESTAMENTARY TRUST
Fourteenth Respondent:
AF PTY LIMITED AS TRUSTEE FOR THE MR M SEDEN FAMILY TESTAMENTARY TRUST
Fifteenth Respondent:
AG PTY LTD AS TRUSTEE FOR THE MS AC SEDEN FAMILY TESTAMENTARY TRUST
Sixteenth Respondent:
AH PTY LTD AS TRUSTEE FOR THE MS HALEY FAMILY TESTAMENTARY TRUST
Seventeenth Respondent:
SEDEN FAMILY RETIREMENT FUND PTY LTD AS TRUSTEE FOR THE SEDEN FAMILY SUPERANNUATION FUND
Eighteenth Respondent:
MR SEDEN FAMILY PTY LTD AS TRUSTEE FOR THE N FAMILY TRUST
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