LEITH & LEITH
[2014] FCCA 2394
•20 October 2014
FEDERAL CIRCUIT COURT OF AUSTRALIA
| LEITH & LEITH | [2014] FCCA 2394 |
| Catchwords: FAMILY LAW – Property settlement – ex parte orders sought to preserve the subject matter of property proceedings – where a party asserts that their application on a final basis would be rendered nugatory were notice to be given to the other party of the orders sought – orders made restraining the other party from dealing with bank accounts – orders made requiring a third party to suspend a party’s access to internet banking facilities associated with bank accounts. |
| Legislation: Family Law Act 1975, ss.75(2), 90AE, 90AF, 114, 114(1)(e) Federal Circuit Court Rules 2001, r.5.03 |
| Applicant: | MS LEITH |
| Respondent: | MR LEITH |
| File Number: | PAC 4108 of 2014 |
| Judgment of: | Judge Harman |
| Hearing date: | 29 August 2014 |
| Date of Last Submission: | 29 August 2014 |
| Delivered at: | Parramatta |
| Orders delivered on: | 29 August 2014 |
| Reasons delivered on: | 20 October 2014 |
REPRESENTATION
| Counsel for the Applicant: | Mr Rosic |
| Solicitors for the Applicant: | Rowlandson & Co |
| Solicitors for the Respondent: | Ex parte |
ORDERS
Pending further order and pursuant to section 90AE(2) of the Family Law Act 1975 the (omitted) Bank shall be and is hereby directed to:
(a)Do all things necessary to immediately suspend all and any access by the husband Mr Leith to internet banking facilities associated with all and any accounts in the names of Mr Leith, MR LEITH and/or Mr Leith including without limitation account number BSB (omitted) Account (omitted) and BSB (omitted) Account (omitted);
(b)Do all things necessary to ensure that no person can operate any of the above accounts or affect any transaction with respect to the above accounts being accounts in the names of Mr Leith, MR LEITH and/or Mr Leith and so as to ensure that the balance presently held in those accounts (subject only to withdrawal by the Bank of fees, charges and administrative costs relating to compliance with these orders) are not reduced from their present balances.
In the event that any administrative costs are incurred by the (omitted) Bank in complying with the above order then such costs are to be paid by the husband and from the above accounts at first instance and such costs shall be the subject of further determination by the court if required.
Pursuant to section 114(3) of the Family Law Act 1975 the husband Mr Leith shall be and is hereby restrained from dealing with disposing, affecting any transaction or reducing the balance held in any account in which he has an interest (whether in his sole name, jointly with any other person or held in trust with any other person) provided, however, that this restraint shall not preclude or interfere in Mr Leith operating, in the usual course of business, the account in the name of "(business omitted)” being account number (omitted).
Adjourn these proceedings for further mention and directions to 4 September 2014 at 2pm.
The wife shall forthwith cause the husband to be served with a copy of the following documents:
(a)The application Initiating Proceedings filed 29 August, 2014;
(b)The affidavit of MS LEITH filed 29 August, 2014;
(c)The financial statement of Ms N filed 29 August, 2014;
(d)A copy of these orders.
The wife shall forthwith cause the (omitted) Bank to be served with a copy of these orders such service to occur by email and/or facsimile in first instance.
Grant liberty to the (omitted) Bank to apply to restore the proceedings to the list on 24 hours’ notice.
The husband shall no later than close of business 3 September 2014 file and serve a Response, Affidavit sufficient to comply with Federal Circuit Court Rules and a Financial Statement.
Noted: The wife has filed a written undertaking as to damages.
Noted: The above relief, to the extent that it is sought against the (omitted) Bank, is granted having been satisfied that:
(a)The order is reasonably necessary and appropriate to enable preservation of matrimonial assets and to affect, in due course, an appropriate division of property between the husband and wife;
(b)(omitted) Bank has been afforded procedural as demonstrated by affidavit material filed;
(c)The order is just and equitable as between the parties and as regards the (omitted) Bank;
(d)The administrative costs of the (omitted) Bank are provided for and accommodated.
In the event that either party or the (omitted) Bank requires written reasons then a written request for same is to be made no later than close of business 4 September 2014 and written reasons will be delivered as soon as practicable thereafter.
IT IS NOTED that publication of this judgment under the pseudonym Leith & Leith is approved pursuant to s.121(9)(g) of the Family Law Act 1975 (Cth).
| FEDERAL CIRCUIT COURT OF AUSTRALIA AT PARRAMATTA |
PAC 4108 of 2014
| MS LEITH |
Applicant
And
| MR LEITH |
Respondent
REASONS FOR JUDGMENT
The proceedings
These are proceedings with respect to property adjustment.
The proceedings were commenced by an Initiating Application filed this morning 29 August 2014. The wife’s attorney attended upon a Registrar in Chambers and sought leave to have the proceedings listed before me on an urgent, ex parte basis. The Registrar acceded to that application and the proceedings thus now come before me.
The parties to the proceedings are MS LEITH who is the applicant and the wife in a marriage between the parties and Mr Leith who is the respondent and husband.
The parties were married on (omitted) 1999 and alleged by the applicant to have separated on a final basis on 6 June 2014.
Material considered
In dealing with the proceedings today I have read and considered each of the following documents, namely:
a)Initiating Application filed 29 August 2014;
b)Affidavit of the wife sworn or affirmed 29 August 2014 and filed the same day;
c)Financial Statement sworn by the wife 29 August 2014 and filed the same day;
d)Written undertaking as to damages signed by the wife and filed 29 August 2014; and
e)Affidavit of Victoria Rowlandson sworn or affirmed 29 August 2014 and filed in Court today.
Factual background as alleged by the wife
I am conscious that these proceedings come before the Court on an ex parte basis. Accordingly, the purpose of setting out the factual background alleged is to establish that before me today. I make clear that:
a)No findings of fact are made;
b)An assessment of the wife’s evidence occurs on the basis of its internal consistency and plausibility only; and
c)To the extent that any material is afforded any weight and relied upon as a basis for exercising jurisdiction and granting relief, I am loathe to do so, save to the extent that there is corroborative evidence available.
The wife has annexed to her affidavit material a number of documents which, on their face, corroborate allegations made by her and sworn on her oath. However, again, findings of fact are not made in accordance with the wife’s evidence at this point and will not be made until such time as they are demonstrated to be appropriate and following the husband being afforded an opportunity to participate in the proceedings, lead evidence and test evidence.
The wife alleges that a number of transactions have been undertaken by the husband with respect to assets which are, on their face, assets of the marriage and which would and could be taken into account in proceedings under part VIII of the Family Law Act 1975.
It is clear that the parties own a parcel of real estate comprising a home at Property K. The wife and child of the relationship reside within that property. The value of the property as alleged by the wife to be $600,000.
The husband is presently engaged as a sole trader operating a business under the name “(business omitted)” being a (omitted) business.
The business has been operated by the husband since 2005.
There is one child of the relationship X born (omitted) 2008. X is five years of age and will shortly turn six.
During the relationship the parties purchased a number of investment properties. The properties have all been sold, the last having been sold in March. The proceeds of sale were deposited to one or other of the accounts operated by the parties.
The wife alleges that there are four banking accounts presently relevant and operated by the parties or one or other of them. They are enumerated in paragraph 40 of the wife’s affidavit.
The wife deposes as to a number of transactions operated by the husband upon the various banking accounts of the parties and which transactions have been without the knowledge of or recourse to the wife. The wife sets out those transactions in some detail commencing at paragraph 40 of her affidavit.
Of particular concern to the wife is an allegation (or perhaps more correctly a series of allegations) that monies are transferred by the husband between various accounts and by internet banking. The net effect of these transactions is that funds are moved from accounts to which the wife has recourse or can access, to accounts with respect to which she has no access.
On the basis of the wife’s evidence, if ultimately accepted, the balance of funds held by the parties in banking accounts are of far greater quantum than the equity available to the parties from the former matrimonial home in which the wife is living and which represents the only significant, tangible asset otherwise available for division.
Orders proposed
The wife proposes, on an interim basis, that injunctions be made directed to each of the husband and the (omitted) Bank restraining:
a)The husband from dealing with or disposing of the funds held in any of the nominated accounts; and
b)As regards the (omitted) Bank a restraint from allowing the husband to access or obtain access to those accounts, particularly, by way of internet banking.
Proceeding on an ex parte basis
As the proceedings come before the Court today on an ex parte basis I must address the matters set out in rule 5.03 of the Federal Circuit Court Rules 2001. That rule is in the following terms:
Evidence
(1) Unless the Court otherwise orders, the applicant must establish by affidavit or, with the leave of the Court, orally:
(a) whether there are previous proceedings between the parties and, if so, the nature of the proceedings; and
(b) whether there are any current proceedings in any court in which the applicant or the respondent are parties; and
(c) the particulars of any orders currently in force between the parties, including the courts in which they were made; and
(d) the steps that have been taken to tell the respondent or the respondent's legal representative of the applicant's intention to make the application or the reasons why no steps were taken; and
(e) the nature and immediacy of the damage or harm which may result if the order is not made; and
(f) why the making of the order is a matter of urgency and why an abridgement of the time for service of the application and the fixing of an early hearing date would not be more appropriate; and
(g) if the application relates to a financial matter, the capacity of the applicant to give an undertaking as to damages; and
(h) the other facts, matters and circumstances relied on by the applicant in support of the application.
The application as filed also seeks ex parte relief as against the (omitted) Bank. The application does not name nor seek to join the (omitted) Bank as a party to the proceedings. As a consequence of the relief sought against the bank (being an order under part VIIIAA of the Act), I must also consider and be satisfied as to compliance with the obligations imposed by sections 90AE and 90AF which sections are in the following terms:
Section 90AF
Court may make an order or injunction under section 114 binding a third party
(1) In proceedings under section 114, the court may:
(a) make an order restraining a person from repossessing property of a party to a marriage; or
(b) grant an injunction restraining a person from commencing legal proceedings against a party to a marriage.
(2) In proceedings under section 114, the court may make any other order, or grant any other injunction that:
(a) directs a third party to do a thing in relation to the property of a party to the marriage; or
(b) alters the rights, liabilities or property interests of a third party in relation to the marriage.
(3) The court may only make an order or grant an injunction under subsection (1) or (2) if:
(a) the making of the order, or the granting of the injunction, is reasonably necessary, or reasonably appropriate and adapted, to effect a division of property between the parties to the marriage; and
(b) if the order or injunction concerns a debt of a party to the marriage--it is not foreseeable at the time that the order is made, or the injunction granted, that to make the order or grant the injunction would result in the debt not being paid in full; and
(c) the third party has been accorded procedural fairness in relation to the making of the order or injunction; and
(d) for an injunction or order under subsection 114(1)--the court is satisfied that, in all the circumstances, it is proper to make the order or grant the injunction; and
(e) for an injunction under subsection 114(3)--the court is satisfied that, in all the circumstances, it is just or convenient to grant the injunction; and
(f) the court is satisfied that the order or injunction takes into account the matters mentioned in subsection (4).
(4) The matters are as follows:
(a) the taxation effect (if any) of the order or injunction on the parties to the marriage;
(b) the taxation effect (if any) of the order or injunction on the third party;
(c) the social security effect (if any) of the order or injunction on the parties to the marriage;
(d) the third party's administrative costs in relation to the order or injunction;
(e) if the order or injunction concerns a debt of a party to the marriage--the capacity of a party to the marriage to repay the debt after the order is made or the injunction is granted
Section 90 AE
Court may make an order under section 79 binding a third party
(1) In proceedings under section 79, the court may make any of the following orders:
(a) an order directed to a creditor of the parties to the marriage to substitute one party for both parties in relation to the debt owed to the creditor;
(b) an order directed to a creditor of one party to a marriage to substitute the other party, or both parties, to the marriage for that party in relation to the debt owed to the creditor;
(c) an order directed to a creditor of the parties to the marriage that the parties be liable for a different proportion of the debt owed to the creditor than the proportion the parties are liable to before the order is made;
(d) an order directed to a director of a company or to a company to register a transfer of shares from one party to the marriage to the other party.
(2) In proceedings under section 79, the court may make any other order that:
(a) directs a third party to do a thing in relation to the property of a party to the marriage; or
(b) alters the rights, liabilities or property interests of a third party in relation to the marriage.
(3) The court may only make an order under subsection (1) or (2) if:
(a) the making of the order is reasonably necessary, or reasonably appropriate and adapted, to effect a division of property between the parties to the marriage; and
(b) if the order concerns a debt of a party to the marriage--it is not foreseeable at the time that the order is made that to make the order would result in the debt not being paid in full; and
(c) the third party has been accorded procedural fairness in relation to the making of the order; and
(d) the court is satisfied that, in all the circumstances, it is just and equitable to make the order; and
(e) the court is satisfied that the order takes into account the matters mentioned in subsection (4).
Proceeding ex parte as against the respondent husband
By reference to rule 5.03 of the Federal Circuit Court Rules 2001, the applicant must establish various matters. I propose to deal with each individually.
Previous proceedings
There have not been any prior proceedings between the parties.
Current proceedings
There are no current proceedings between the parties.
Particulars of orders in force between the parties
There are none.
Steps taken to tell the respondent of the application
The wife is clear, candid and frank in her material that she has not taken any steps to alert the husband to these proceedings nor of her intention to commence them. This is on the basis that the wife deposes to conversations between she and the husband in which the husband has alluded to his knowledge of, if not his intention to secrete funds, or otherwise move them to accounts unknown to the wife and so as to ensure she is unable to utilise those funds or locate them.
The wife annexes to her material (annexure L), material which she relies upon to form and express to the Court a concern that the husband has opened one or more accounts in his sole name of which she has no knowledge. Transactions are shown upon the statement produced evidencing a transfer of $400,000 to one or more of such accounts.
The wife asserts that her position would be damaged, if not her application to the Court on a final basis rendered nugatory, were notice to be given to the husband of the application now made by her.
The nature and immediacy of damage or harm
The wife’s financial statement would suggest that other than the matrimonial home (in which equity of the parties is unclear), there are a number of banking accounts with balances in the region of $620,000 in total and which funds are presently available for division between the parties (largely representing the proceeds of sale of previous investments).
The wife asserts that the husband has demonstrated, through his recent actions, his willingness and ability to transfer funds from accounts of which the wife has knowledge and access into accounts of which the wife has no knowledge and no ability to access. Further, the wife asserts that in the event that the funds which have been removed (whether temporarily or permanently) are not able to be located and taken into account in any property adjustment proceedings between the parties, that she would be significantly disadvantaged. Indeed, the wife goes so far as to allege that her application would be frustrated wholly or substantially.
The matrimonial home in which the wife is presently residing is alleged to be owned jointly by the parties and others being, at least as regards registered proprietorship, relatives of the husband. On this basis the wife does not seek an order to retain the property. She seeks, instead, an order that she be paid a lump sum by the husband and that she then transfer to the husband her interest in the real property.
On its face the orders that are sought by the wife, based upon the evidence led by her at this time (noting that the evidence is not complete nor has the husband had any opportunity to respond to it or test it) could not be described as fanciful. That is not to suggest that the orders that the wife proposes are accepted as appropriate. It is simply a reflection that the relief sought would appear to have an arguable basis in the material filed.
In light of the above and in the event that the wife’s fears were ultimately realised (i.e. significant cash funds were disposed of by the husband or made unavailable to the wife), then the wife would suffer serious and significant financial harm and the application made by her would be rendered nugatory.
Why the making of the order is a matter of urgency and why an abridgement of time is not adequate
The wife’s evidence would suggest that over the space of some weeks the husband has moved significant sums of money between accounts. Many of the transactions undertaken by the husband have ultimately been reversed by him and funds returned to accounts of which the wife is aware. However, the wife asserts that there is a real likelihood that the husband might, if given notice of the proceedings, affect transactions by withdrawal which will not be reversed and which cannot be adequately remedied by the wife.
I accept the wife’s concerns are genuinely held, being that if notice were given to the husband of this application that he might (although no finding is made that he would) affect further transactions and thus render the wife’s position more difficult, if not untenable.
In the event that significant funds were removed (and as addressed above) I am satisfied that the wife would suffer significant harm.
Whether an undertaking as to damages is given
The wife offers an undertaking as to damages and it is filed with the Court and will be remain upon the Court file. Any orders made by the Court will be subject to the undertaking as to damages and it will be open to the husband to seek orders to appropriately compensate him in the event that it is suggested that he has suffered damage and that the wife should be found liable to compensate him therefore.
Such other matters as are considered relevant
I am satisfied as above that:
a)The nature of risk of damage to the wife’s financial position is such that notice to the husband should be dispensed with.
b)The magnitude of the risk as alleged by the wife (and subject to her sustaining her position once the husband has had an opportunity, on short notice, to participate in the proceedings) is such as to support the making of orders on an urgent, ex parte basis.
c)The risk to the husband of orders as sought would appear minimal. The relief sought by the wife does not seek to interfere in the day-to-day affairs of the business operated by the husband (one of the four accounts the subject of the proceedings is an account of the business) and from the evidence led by the wife that account is sufficiently in credit to allow the husband, during the brief period of any adjournment, to conduct the affairs of that business without interference.
d)Notice to the husband of the wife’s application would potentially and in all probability render both the wife’s claim for substantive and interim/interlocutory relief nugatory.
Relief sought as against the (omitted) Bank
I am satisfied that jurisdiction exists pursuant to sections 90AE and/or section 90AF to entertain an application for property adjustment orders or injunctive relief (particularly by reference to section 114 of the Act) as against a third party of which the (omitted) Bank is clearly an example.
In dealing with that which must be addressed by reference to section 90AF, I was not initially satisfied, when this matter was first called before lunch, that jurisdiction was established or, if established, could appropriately be exercised.
It is to be noted that section 90AF(3) sets out a mandatory list of considerations to be addressed by the court prior to any order being made which binds or purports to bind (or affect) a third party.
Principle amongst these is the obligation to ensure that due process is afforded to any third party against whom an order is sought. To this end an order was made, whilst the matter was stood down, requiring that notice be given to the (omitted) Bank and that they be afforded an opportunity to be heard. It is with respect to compliance with this order that the affidavit of Ms Rowlandson is filed.
Section 90AF(3)(c) requires that a third party (in this case the (omitted) Bank) be “accorded procedural fairness in relation to the making of the order or injunction”. There is nothing within the section or the rules of Court which prescribe that which is required to be taken to have “accorded procedural fairness”. Thus that which is required must be determined on a case-by-case basis and by reference to the facts and circumstances of each case.
I am satisfied that the (omitted) Bank must, as a third party, not only receive notice of that which is sought against them but receive adequate notice to allow them to appear and be heard in opposition to such orders if they are, in fact, opposed.
In light of the apparent urgency raised on the wife’s evidence, I was satisfied that short notice could be given to the (omitted) Bank and subject to evidence on oath being given as to compliance therewith. To that end an order was made by me, prior to the matter being stood in the list for some hours, in the following terms:
1. Forthwith the wife’s attorneys shall cause notice to be given to the (omitted) Bank that an order will be sought today to immediately suspend the husband’s internet banking access to the accounts nominated in the Application filed 29 August 2014 as well as requiring the bank to do all things necessary to ensure that the husband cannot operate those accounts.
2. (omitted) Bank is requested to ensure that any communication between the wife or her legal representatives and the bank is not communicated to the husband pending further order.
The affidavit of Ms Rowlandson deposes to compliance with the above orders. A conversation between Ms Rowlandson and a bank employee Ms A is deposed to and in which it is alleged that the following conversation occurred:
Ms Rowlandson: Hello Ms A, my name is Victoria Rowlandson. I am a solicitor… who acts for an applicant wife in relation to certain family law proceedings currently being conducted in the Federal Circuit Court of Australia, Parramatta Registry. My client seeks on an interim ex parte basis injunctive orders restraining her estranged husband from accessing certain bank accounts with your bank and I have been directed to write to you affording your bank procedural fairness concerning the orders sought by my client prior to 2:15pm when the matter is again listed before [the Court].
A letter was then forwarded to the bank via a fax number provided by the bank employee and email.
A response thereto, by email, is then annexed to Ms Rowlandson’s affidavit acknowledging receipt of the material sent (which included a copy of the Application filed in the wife’s case) and raising no objection to the relief sought.
On the basis that the bank has been afforded procedural fairness and an opportunity (albeit slight and on an urgent basis) to be heard I am satisfied that the portion of the application that seeks to impose an obligation on the bank (by way of injunction pursuant to section 114 of the Act) can proceed safely.
Relief sought
On an interim basis orders are sought pursuant to section 114(3) of the Family Law Act 1975 which would restrain both the husband and the (omitted) Bank from operating or permitting operation of certain nominated accounts.
The orders that are sought specifically exclude the account in the name of the husband’s business and such as to ensure that the business can be operated by the husband without undue interference.
As regards the third party bank, I must be satisfied of each of the matters set out in section 90AF(3). I propose to deal with each of those factors separately.
The making of the order or granting of the injunction is reasonably necessary or appropriate to effect a division of property between the parties
The injunctive relief that is sought will not effect a division of property but will, rather, preserve the subject matter of property proceedings.
I am satisfied that the relief sought and the granting of that relief for a limited period (to afford to the husband an opportunity to appear in the proceedings and be heard in opposition to the wife’s application), is appropriate and necessary for the reasons addressed above in a discussion of rule 5.03 of the Federal Circuit Court Rules 2001.
If the order concerns a debt of the parties
The release sought by the wife relates to accounts of the parties held with the third party bank and in which the parties’ funds are held. Accordingly no issue as regards debt is raised.
Whether the third party has been accorded procedural fairness
As set out above I satisfied that this is so.
Whether the court is satisfied that it is proper to make the order sought
For the reasons set out above I am satisfied that absent orders of the nature sought by the wife that there is a real possibility (albeit without the husband having been afforded an opportunity to be heard at this point) that the subject matter of the proceedings may be substantially and significantly affected. That is not to suggest that the husband would or has dealt with the assets of the parties in such fashion as would frustrate the wife’s application. However, the wife’s evidence is clear, cogent, plausible and internally consistent as to the transactions which have occurred without reference to her, without her knowledge and which have involved significant sums of money being moved from accounts of which the wife is aware and which she has access to and into accounts of which the wife is unaware and/or has no access to.
Further to the above I am conscious that the wife has annexed to her material various statements which corroborate the allegations made by her as regards recent transactions and business records in the nature of independent third party corroboration (to the extent that business records are available supporting the wife’s contentions and allegations) are also made available.
Whether it is just or convenient to make the order
Clearly if the wife’s contentions are ultimately made out then any removal of funds from those available for distribution between the parties will result in an injustice and inequity as regards the wife.
As regards the husband, I am satisfied that the operation of the restraint sought by the wife and for a limited period of time will not visit upon him such misery or difficulty (or any at all) as to constitute injustice and inequity.
The effect of the order sought by the wife will be to preserve or “freeze” the substantial funds available to the parties and arising from the sale of previously owned investment properties until such time as they can each engage in the court process, place material before the court and, one would hope, then turn to a negotiated resolution with or without the assistance of third parties.
Other matters
I must also be conscious of the taxation effects of the order sought, the impact upon social security entitlements and the administrative costs of the third party.
It would not appear that any taxation effect or impact upon social security entitlements would arise from the order sought by the wife.
As regards third party administrative costs I am conscious to ensure that any costs as are incurred by the (omitted) Bank in dealing with this matter are able to be met. According, I propose to make orders that will allow and permit the (omitted) Bank to deduct such administrative costs from the funds held by them on behalf of the parties in the accounts which will be effected by the injunctions the wife seeks.
In due course any cost which has been incurred by the (omitted) Bank can be adjusted as between the parties and by way of substantive exercise of property adjustment jurisdiction under part VIII of the Act.
I must also have regard to the economic, legal or other capacity of the third party to comply with the orders. It would appear from that led in Ms Rowlandson’s affidavit that the bank has not apprehended or advised any difficulties as regards compliance with the order if made and subject to it being forwarded to them by fax or email as they have requested.
The third party has not sought to raise any additional matters with the Court nor with the attorneys for the wife.
Section 114
I am satisfied that the orders that are sought by the wife fall within the ambit of orders which the Court is authorised to make for the protection and preservation of property of the parties by reference to section 114(1)(e) of the Act.
With respect to the application generally I am satisfied that the wife’s evidence, on its face and accepting it on face value (noting that the husband has not yet had the opportunity to respond to, comment upon or test that evidence) would suggest that the wife has made contributions to the property of the parties and would have an arguable case as regards a number of adjustments pursuant to section 75(2) of the Act.
In all the above circumstances I am satisfied that the orders sought by the wife are appropriate, just and equitable and are made:
a)Appropriately without notice to the husband and bearing in mind the short period for which the order will operate without notice to the husband of these proceedings and orders made; and
b)Appropriate as against the (omitted) Bank who has been afforded procedural fairness.
I certify that the preceding sixty-nine (69) paragraphs are a true copy of the reasons for judgment of Judge Harman
Associate:
Date: 20 October 2014
Key Legal Topics
Areas of Law
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Family Law
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Civil Procedure
Legal Concepts
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Injunction
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Procedural Fairness
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Remedies
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Jurisdiction
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Costs
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Standing
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