Re Oakwood Partners
[2022] VSC 338
•20 May 2022
| IN THE SUPREME COURT OF VICTORIA | Not Restricted |
AT MELBOURNE
COMMERCIAL COURT
CORPORATIONS LIST
S ECI 2022 01026
IN THE MATTER OF ACN 602 353 391 PTY LTD (IN LIQUIDATION) (formerly trading as OAKWOOD PARTNERS)
| NICHOLAS GIASOUMI and SHANE LESLIE DEANE in their capacity as joint and several liquidators of A.C.N. 602 353 391 PTY LTD (IN LIQUIDATION) (ACN 602 353 391) formerly trading as ‘OAKWOOD PARTNERS’ | Plaintiffs |
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JUDGE: | ATTIWILL J |
WHERE HELD: | Melbourne |
DATES OF HEARING: | 6 and 16 May 2022 |
DATE OF RULING: | 20 May 2022 |
CASE MAY BE CITED AS: | Re Oakwood Partners |
MEDIUM NEUTRAL CITATION: | [2022] VSC 338 |
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WARRANT – Ex parte application by liquidators for a warrant under s 530C of the Corporations Act 2001 (Cth) – Whether Court is satisfied of matters under s 530C – Conditions of the warrant – Undertaking required – Application Granted – Warrant issued.
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APPEARANCES: | Counsel | Solicitors |
| For the Plaintiffs | Mr Purton | Madgwicks Lawyers |
HIS HONOUR:
INTRODUCTION
The plaintiffs (the Liquidators) are joint and several liquidators of ACN 602 353 391 Pty Ltd (in liquidation) (the Company). They were appointed on 10 January 2022.
The Liquidators applied ex parte by originating process for a warrant under s 530C of the Corporations Act 2001 (Cth) (the Corporations Act).
The Liquidators relied upon affidavits of Nicholas Giasoumi (one of the Liquidators) sworn 28 March 2022 (initially affirmed and then sworn on 5 May 2022), 5 May 2022 and 12 May 2022 (the Giasoumi affidavits).
The Liquidators also filed submissions on 5 May 2022 and 12 May 2022 and a book of authorities.
Mr Adam Purton, of counsel, made submissions at the hearings of the originating process on 6 May 2022 and 16 May 2022.
BACKGROUND
The Company operated an accounting practice under the trading name ‘Oakwood Partners’ and was a registered tax agent.
The Company’s registered office and principal place of business was at Suite 34, Level 1, 1 Ricketts Road, Mount Waverley (the Premises). Pinia Investment Holdings Pty Ltd (Pinia) owns the Premises. Pinia leased the Premises to the Company. Pinia’s registered office and principal place of business are the Premises. Mr Delis is the sole director and secretary of Pinia.
The sole director and shareholder of the Company is Oona Yang (Ms Yang). The secretary of the Company is Peter Delis. He is also a former director and member.
An accounting practice trading under the name ‘Oakwood Partners’ continues to trade from the Premises.
On or about 11 February 2020, the Company purchased a server described as a ‘Asustor 4-Bay NAS with 4 x 2T Samsung SSD’ (the Server). In February 2020, the Company paid for the Server and certain associated services, including ‘Onsite Tech Service’. Since that time and until the appointment of the Liquidators, the Server was used in the Company’s business and was the Company’s primary memory and back-up system.
In about early December 2021, Mr Delis denied Ms Yang remote access to the Server.
On 10 January 2022, Mr Giasoumi had a discussion with Ms Yang and she told him that:
(a)the books of the Company are all held at the Premises and that, she has been denied access to the Premises by the landlord, Pinia, since around 7 December 2021; and
(b)company assets, specifically a computer server and office furniture, were left at the Premises.
On 10 January 2022, Mr Giasoumi spoke with Mr Delis and informed him of the liquidation. During this conversation, Mr Giasoumi said that he required access to the Premises in order to obtain Company property, client files and server access. Mr Delis agreed to cooperate and said that he had ‘debtor/WIP records’.
On 10 January 2022, Mr Giasoumi sent a letter to Mr Delis enclosing a notice under s 530B of the Corporations Act. The notice required Mr Delis to deliver books of the Company in his possession to the Liquidators by 13 January 2022.
On 10 January 2022, Mr Giasoumi sent a letter to Pinia, inter alia, requesting it to ‘promptly enable access’ to the Premises so that he could take possession of the Company property. The Company property which was identified, at that time, did not include the Server.
On 11 January 2022, Mr Giasoumi spoke to Mr Delis’ wife and told her that he would like to attend the Premises to collect the records of the Company. He also left a message with Mr Delis to the same effect.
On 11 January 2022, Mr Giasoumi spoke with Nick Theofilakos of Frenkel Partners. Mr Delis had previously told Mr Giasoumi that Mr Theofilakos acted for him. Amongst other things, Mr Theofilakos told him that ‘I do not dispute that the liquidator is entitled to debtors/WIP. Mr Delis would take photos of Company property and that he will speak with the tenant in relation to see if an offer would be made in respect of them’. Mr Giasoumi also said that he has invoices that show that the Company purchased a new server in 2020 and that the liquidators have an obligation to secure the server and image it. Mr Giasoumi said further that, ‘I have arranged for staff and IT experts to be available tomorrow to image the server, notebooks and to obtain bank statements, etc’.
On 12 January 2022, Mr Giasoumi made ‘a number of attempts’ to telephone Mr Delis and Mr Theofilakos.
At 9:30am on 12 January 2022, two of Mr Giasoumi’s staff attended the Premises and did not obtain access to the Premises. I give no weight to the matters deposed to by Mr Giasoumi in paragraph 6 of his affidavit sworn 12 May 2022 as the evidence is vague and lacking detail. The ‘friend’ referred to is not identified.
At 1:15pm on 12 January 2022, Mr Delis informed Mr Giasoumi that he had spoken with his solicitor, that he was compiling the information and that the information would be provided on Monday. Mr Giasoumi told Mr Delis that he required the image of the Server. Mr Delis responded by saying that ‘I won’t provide the server because it has information that is not related to the Company’. Mr Delis also said that Ms Yang resigned and he ‘locked her out of the server and remote access’. Mr Giasoumi said that ‘protocols can be set to ensure that access is only provided to Company records’. Mr Delis said that he would get Mr Theofilakos to discuss this with Mr Giasoumi but advised that, in the interim, he would provide debtor invoices, WIP reports, client lists, financial statements, cheque books, bank statements, cash book and general ledger and a backup.
On 17 January 2022, Mr Delis informed Cecilia Korn, a staff member of Mr Giasoumi, that he had a medical emergency and was unable to obtain the requested information.
On 18 January 2022, Mr Giasoumi rang and left messages for Mr Delis a number of times. Mr Delis did not return any of those calls.
On 18 January 2022, Mr Giasoumi sent a letter to Mr Delis detailing the attempts made to obtain access to the Premises and recent discussions with Mr Delis. He made a further demand for the property and books of the Company to be delivered by 5:00pm that day. He also stated that he is ‘still required to image Company records contained on the server’.
On 18 January 2022, James Delis, Mr Delis’ son, attended Mr Giasoumi’s office and provided about 400 pages of documents including the following documents:
(a)company register;
(b)copies of financial statements for the years ending 30 June 2017 to 30 June 2020, including general ledger reports for these periods;
(c)copies of the Company’s tax returns for the years ending 30 June 2017 to 30 June 2020;
(d)copies of business activity statements for the quarters ending 30 June 2016 to 30 September 2021, inclusive; and
(e)documents purporting to be debtor and WIP reports as at 10 January 2022.
On 19 January 2022, Mr Giasoumi sent a letter to Mr Delis informing him of his preliminary review of the documents provided, demanding PDF copies of certain documents and also demanding access to the Server to enable him to ‘secure all Company records’. Mr Giasoumi’s preliminary review was informed by an email from Ms Yang to Megan Kellett, of Mr Giasoumi’s office, cc’d to Mr Giasoumi, in which she made observations of the documents provided on 18 January 2022.
On 24 January 2022, Mr Delis emailed Mr Giasoumi advising, amongst other things, that Mr Giasoumi had not been denied the books and records as they were hand delivered to Mr Giasoumi’s offices on 18 January 2022 and that ‘such records are the responsibility of the previous sole director Mrs Oona Yang…’.
On 24 January 2022, Mr Giasoumi sent a letter to Mr Delis in which he stated, inter alia, that Mr Delis had failed to comply with ‘my notices issued pursuant to section 530B of the Act.’.
On 24 January 2022, Mr Delis sent an email to Mr Giasoumi in which he stated:
Further to your letter dated the 19th of January 2022 and in particular the letter sent today ( 24th January 2022 ) by Megan Kellet from your office and confirm as follows.
That I have been compliant with this request and confirm that I have delivered what you have requested.
On the 18th of January 2022 I hand delivered all the available books and records that were in my possession.
As for any further details requested , please refer them to the previous director, Mrs Oona Yang.
Prior to your appointment and the previous Handisoft ceasing to operate we compiled the copies of debtors and WIP reports provided.
We also note that Mrs Oona Yang always controlled and had access to the company accounting records including the internal MYOB reporting on site and remotely and had always had access to the company bank accounts and statements remotely and from her PC.
It appears that these back- up tapes / discs have been removed from the office at some point during the period of my absence due to my stay in hospital for contracting COVID during the first 3 weeks in December 2021.
No doubt I will also be formally communicating about your conduct with the Australian Securities and Investments Commission and your professional bodies that you are associated with as well.
On 25 January 2022, Mr Giasoumi sent a further letter to Mr Delis in which he stated:
I refer to previous communication in this matter and in particular to your emails dated 24 January 2022.
In the course of this administration to date you have been hindering, misleading and contradictory in your communications. Access to the Company server has not been provided to enable the books and records of the Company to be secured, despite repeated requests and notices issued pursuant to section 530B of the Corporations Act 2001.
Your assertion that you have complied with my requests for delivery of Company records is refuted.
I refer to the documents you refer to that were hand delivered to my office by James Delis on 18 January 2022 and I state the following;
• These were selective documents, which do not include a client list, complete debtor records, WIP and all tax invoices;
• The records that were produced appear to be altered and no not include key clients.
Your non-compliance continues to hinder the orderly winding up of the Company.
There has not been a transmission or sale of the Company’s business, yet you retain unfettered access to the Company records.
Should you wish to acquire the business, payment of its market value is required.
Further you are to account to the Company in relation to un accounted debtors and WIP and any other receipts of the Company.
I welcome your communication with the Australian Securities and Investments Commission in this matter.
Should you have any queries in respect of this matter do not hesitate to contact Megan Kellett or me at this office.
Mr Delis has not responded to this letter.
On 5 April 2022, Mr Giasoumi addressed, in his circular to creditors, as follows:
In the absence of books and records, I have not been able to conduct complete investigations in to [sic] the affairs of the Company, including those related to asset recovery or liquidators’ recovery actions under Part 5.7B of the Corporations Act 2001 (such unfair preferences, uncommercial transactions, unreasonable director-related transactions, unfair loans, or insolvent trading by the sole director) that could be commercially recovered for the benefit of the creditors of the Company.
Mr Giasoumi gave evidence that:
Based on my discussions with Ms Yang and on my 30 years’ experience as an insolvency practitioner and accountant, I believe that the books and records produced by Mr Delis are deficient. They are incomplete and also appear to be both selective and altered. Noticeable deficiencies include, but are not limited to, the following:
(a)cheque books and bank account statements;
(b)all electronic records, including email accounts;
(c)client engagement letters;
(d)the aged debtors report provided dated of 6 January 2022 and WIP report provided dated of 18 January 2022 is inconsistent, thus not providing receipts and invoices for respective periods and to the period Company access was hindered/lost around 7 December 2021;
(e)the selective debtor invoices provided relate to doubtful debtors, which are significantly aged;
(f)reports of debtors for the period from about 7 December 2021 to the date of debtor/WIP records generated;
(g)client list and reports omit key clients, for example skips J and K codes (missing those of JOY amongst others, in addition to PLA, PAB, TSA and VIE) and client contact details;
(h)date of client statements appear altered; and
(i)documents appear to be photocopies of print outs and not original.
APPLICABLE LAW
Section 530C of the Corporations Act provides:
Warrant to search for, and seize, company’s property or books
(1)The Court may issue a warrant under subsection (2) if:
(a)a company is being wound up or a provisional liquidator of a company is acting; and
(b)on application by the liquidator or provisional liquidator, as the case may be, or by ASIC, the Court is satisfied that a person:
(i)has concealed or removed property of the company with the result that the taking of the property into the custody or control of the liquidator or provisional liquidator will be prevented or delayed; or
(ii)has concealed, destroyed or removed books of the company or is about to do so.
(2)The warrant may authorise a specified person, with such help as is reasonably necessary:
(a)to search for and seize property or books of the company in the possession of the person referred to in subsection (1); and
(b)to deliver, as specified in the warrant, property or books seized under it.
(3)In order to seize property or books under the warrant, the specified person may break open a building, room or receptacle where the property is or the books are, or where the person reasonably believes the property or books to be.
(4)A person who has custody of property or a book because of the execution of the warrant must retain it until the Court makes an order for its disposal.
Such applications are a last resort to be made only after all other reasonable steps have been taken: Pattison v May.[1]
[1] [2005] VSC 454, [2] (Whelan J).
In Re Carrello[2] Banks-Smith J said:[3]
[2] [2019] FCA 1563.
[3] Ibid, at [7]-[8] (citations omitted).
7.A warrant should be granted if the Court finds that there has been a ‘persistent pattern of non-cooperation and evasion’…This does not appear to be a requirement of granting a warrant, but provides useful guidance.
8.Factors that have been relied upon in deciding that a person has concealed or removed property of the company include:
(a)refusals to comply with liquidators’ requests to deliver up the books and records of the company;
(b)transfer of assets to, and continued use of the assets by, related companies or entities without proper accounting; and
(c)moving of assets, books or records from one place to another.
In Re Ezyclad Pty Ltd (in liquidation),[4] Robson J said:[5]
67.Furthermore, the court’s power under s 530C is discretionary and, therefore, in my opinion the section does not require that the court either issue a warrant in an unconditional form or not at all. In my view, the discretion means that conditions which limit the full ambit of what the Act permits may be imposed.
[4] [2014] VSC 66.
[5] Ibid, at [67].
Robson J also said:[6]
76.In my view, “books” of the company include electronic information, which is non–rivalrous. Accordingly, it is possible for a person – authorised by the warrant - to search for and to seize books (within the definition of the Act) in an electronic form without the person - the subject of the warrant - in possession of such electronic information, from losing seizure or possession of the electronic information itself. In my opinion, electronic information is of a nature that can be seized (within the meaning of the Act) by copying it. The nature of electronic information is such that one cannot distinguish between what is said to be a copy and what is said to be the original. The information contained in both forms is exactly the same. This is the nature of a non-rivalrous entity or thing.
77.Therefore, I consider it appropriate for the warrant to make clear that seizure includes taking copies of electronic records. Such a clarification would also have the effect of satisfying what Young J said in Cvitanovic, where his Honour said:
A problem with warrants is that they are construed very restrictively by courts because of a concern for the liberty o the subject and the subject’s freedom from compulsory process, so that a person who acts outside the terms of the warrant, even if that person acts honestly, can often find themselves liable in conversion or trespass. It is appropriate that the warrant be worded in specific language to protect the persons to whom it is issued as much as possible against such claims.
[6] Ibid, at [76]-[77] (citations omitted).
ANALYSIS
On the basis of the Giasoumi affidavits, I am satisfied that Mr Delis and Pinia have concealed and removed the Server of the Company in their possession. I am also satisfied that, as a result, the taking of the Server into the custody or control of the Liquidators will be prevented or delayed.
On the basis of the Giasoumi affidavits, I am also satisfied that Mr Delis has concealed and removed books of the Company in his possession.
I am mindful that this application is made ex parte.
The Premises are the principal place of business and registered office of the Company. Mr Delis is the secretary of the Company. Mr Delis is the sole director and secretary of Pinia. The Premises are the principal place of business and registered office of Pinia. Pinia also owns the Premises. Mr Delis works from the Premises. A business named ‘Oakwood Partners’ continues to be conducted from the Premises.
Upon the material presently before the Court:
(a) On or about 11 February 2020, the Company purchased, with its own funds, the Server from GLF Group Pty Ltd for delivery to its Premises.
(b) The Server was used in the Company’s business and has been the Company’s primary memory and back-up system since February 2020 until the appointment of the Liquidators.
(c) The Server is at the Premises.
(d) Mr Delis locked out Ms Yang from remote access to the Server in about December 2021.
(e) The Server also has data on it which does not relate to the Company.
(f) The Liquidators have requested that Mr Delis and Pinia deliver the Server to them. The Liquidators told Mr Delis that protocols may be set with Forensic IT to ensure access is only provided to information concerning the Company.
(g) Mr Delis and Pinia have refused to provide the Server to the Liquidators or provide the Liquidators access to it.
(h) Mr Delis and Pinia have not provided the Server to the Liquidators.
(i) The Server is in the possession of Mr Delis and Pinia at the Premises.
(j) As a result, I am satisfied that Mr Delis and Pinia have not provided, despite requests, the Server in their possession at the Premises to the Liquidators. Further, the Server is being used by Mr Delis for other purposes unrelated to the Company. I am satisfied that, in all of the circumstances, this constitutes concealment and removal of the Property by Mr Delis and Pinia. The result is that the taking of the Server into the custody or control of the Liquidators will be prevented or delayed.
Upon the material presently before the Court:
(a) The Liquidators have requested that Mr Delis deliver all of the books of the Company in his possession to them.
(b) Mr Delis has provided some of the books of the Company to the Liquidators.
(c) Mr Delis does not say that he has provided all of the books of the Company to the Liquidators. He says that he has provided all of the books of the Company in his possession.
(d) Ms Yang is of the opinion that the documents provided by Mr Delis do not constitute all of the books of the Company.
(e) Mr Giasoumi is of the opinion that the documents provided by Mr Delis do not constitute all of the books of the Company.
(f) The following documents, for example, have not been provided to the Liquidators:
(i) cheque books and bank accounts statements. Mr Delis told Mr Giasoumi that he would provide these documents during their conversation on 12 January 2022;
(ii) electronic documents, including from any email accounts. These documents are likely to be on the Server which is in the possession of Mr Delis (and Pinia) at the Premises;
(iii) client engagement letters;
(iv) client lists and reports omit key clients.
(g) There is no evidence that Ms Yang has possession of these documents.
(h) Mr Delis locked out Ms Yang from remote access to the Server in about December 2021.
(i) There is no evidence that Ms Yang, the sole director, took the ‘back-up tapes/discs’ that Mr Delis referred to as being removed from the Premises. In any event, the Company ceased to use such tapes/discs in about mid-2020.
(j) As a result, I am satisfied that Mr Delis has not provided, despite requests, all of the books of the Company in his possession at the Premises to the Liquidators. I am satisfied that, in all of the circumstances, this constitutes concealment and removal of the books of the Company by Mr Delis.
WARRANT
Mr Purton submitted that it would not be appropriate for the Liquidators to give the ‘usual undertaking as to damages’ as Mr Delis is the secretary of the Company and the warrant does not concern a third party. I reject this submission as the warrant does concern a third party, namely Pinia. Mr Purton submitted that it would also not be appropriate for the Liquidators to give an undertaking given the limited scope of what is sought to be the subject of the warrant. I acknowledge that the warrant that is sought is of limited scope. However, I reject the submission that this is a factor that weighs against the need for an undertaking. As this application is made ex parte, it is appropriate for the Liquidators to give the usual undertaking as to damages as the price of obtaining the warrant.[7]
[7] Re Ezyclad Pty Ltd(in liquidation) [2014] VSC 66, [82].
Upon the plaintiffs giving the usual undertaking as to damages, I am satisfied that it is appropriate for the Court to issue a warrant substantially in the form attached to these reasons (the Warrant).
I make the following further observations on the Warrant:
(a) The Warrant contains a number of ‘safeguards’ with respect to its execution including the hours and days upon which it may be executed and the identity of the persons who must accompany Mr Giasoumi.
(b) The Warrant provides for searching electronic documents by first copying documents. Robson J included a similar provision in the warrant in Re Ezyclad Pty Ltd (in liquidation).[8] I consider it is appropriate in this case.
(c) It provides for a mechanism to determine disputes between the Liquidators, Mr Delis and Pinia concerning any material seized under the Warrant.
(d) It provides for Mr Delis and Pinia to obtain copies of documents seized under the Warrant. This enables them to access any of their own documents that may be stored on the Server but also other documents to enable them to assess whether to dispute that the document is a book of the Company.
[8] [2014] VSC 66.
I will hear the Liquidators on the precise form of order and of the Warrant, including the conditions.
IN THE SUPREME COURT OF VICTORIA
AT MELBOURNE
COMMERCIAL COURT
CORPORATIONS LIST
S ECI 2022 01026
IN THE MATTER OF A.C.N. 602 353 391 PTY LTD (IN LIQUIDATION) (ACN 602 353 391) formerly trading as ‘OAKWOOD PARTNERS’
| NICHOLAS GIASOUMI and SHANE LESLIE DEANE in their capacity as joint and several liquidators of A.C.N. 602 353 391 PTY LTD (IN LIQUIDATION) (ACN 602 353 391) formerly trading as ‘OAKWOOD PARTNERS’ | Plaintiffs |
WARRANT TO SEARCH FOR AND SEIZE
A COMPANY’S PROPERTY OR BOOKS
TO NICHOLAS GIASOUMI of Dye & Co Pty Ltd, 165 Camberwell Road, Hawthorn East in the State of Victoria:
WHEREAS an ex parte application was made to the Court by Nicholas Giasoumi and Shane Leslie Deane in their capacity as joint and several liquidators of ACN 602 353 391 PTY LTD (IN LIQUIDATION) (ACN 602 353 391) formerly trading as ‘Oakwood Partners’ (the Company) (the Liquidators) by Originating Process filed 28 March 2022 in proceeding S ECI 2022 01026 (Liquidators’ Warrant Proceeding);
AND WHEREAS I am satisfied that:
a.Peter Delis and Pinia Investment Holdings Pty Ltd (ACN 091 706 928) (Warrant Parties) have concealed or removed property of the Company with the result that the taking of the property into the custody and control of the Liquidators will be prevented or delayed; and
b.Peter Delis has concealed or removed the books of the Company;
PURSUANT to section 530C of the Corporations Act 2001 (Cth) (the Act) I issue this warrant to authorise you ON THE CONDITIONS SET OUT IN THE ANNEXURE TO THIS WARRANT and in the company of at least one member of Victoria Police and Lisa McNicholas of Madgwicks Lawyers (the solicitors for the Liquidators) and with such help as is reasonably necessary from members of your office, Victoria Police, Scott Reid and Tim Clarke of Forensic IT and Lisa McNicholas of Madgwicks Lawyers TO:
(a)SEARCH FOR AND SEIZE during the hours of 9am to 5pm on a weekday, the item of property described as an ‘Asustor 4-Bay NAS with 4 x 2T Samsung SSD’ (Company Property) in the possession of the Warrant Parties, and the books of the Company (as defined in s 9 of the Act) (Company Books) in the possession of Peter Delis, at Suite 34 Level 1, 1 Ricketts Road, Mount Waverley (the Premises), including by taking copies of electronic records stored on any computer, server or any other storage medium at the Premises (Copy Documents) and then searching the Copy Documents to identify Company Books; and
(b) DELIVER the things seized under this warrant and any Copy Documents (Warrant Material) into the custody of Forensic IT, to be held by Forensic IT until further order, as soon as practicable and no later than 2 days after the last day of the execution of this warrant.
Dated
The Honourable Justice Attiwill
ANNEXURE: CONDITIONS OF WARRANT
List of Warrant Material
Mr Giasoumi must record the Warrant Material in a list (List of Warrant Material) and provide the List of Warrant Material to Mr Giasoumi’s solicitors, Forensic IT and the Warrant Parties as soon as practicable and no later than 2 days after the last day of the execution of this warrant.
Determination of disputes
Within 7 days of the provision of the List of Warrant Material, any or both Warrant Parties may give notice to Mr Giasoumi in writing that an item on the List of Warrant Material is not Company Property or Company Books (Disputed Material).
If no notice is given in relation to an item on the List of Warrant Material in accordance with condition 2 above, then that item on the List of Warrant Material is deemed to be treated as company material (Company Material).
If notice is given in relation to an item on the List of Warrant Material in accordance with condition 2 above, and Mr Giasoumi and the Warrant Parties do not then subsequently agree within 14 days of that notice that the item of Disputed Material is:
a. Company Material or
b.not Company Material;
then Mr Giasoumi or any or both Warrant Parties may apply to the Court in the Liquidators’ Warrant Proceeding for further directions.
Inspection and copying
The Warrant Parties may inspect the Warrant Material at Forensic IT, and obtain copies of any document that is part of the Warrant Material, including any document stored on the Company Property, on the provision of 48 hours’ written notice to Forensic IT and an undertaking to pay the reasonable costs of Forensic IT in facilitating and supervising such inspection or copying.
Mr Giasoumi may obtain copies of any Company Material on the provision of 48 hours’ written notice to Forensic IT and an undertaking to pay the reasonable costs of Forensic IT in facilitating such copying.
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