Voukidis v Anastasopoulos and Anor (No.2)
[2020] FCCA 3501
•23 December 2020
FEDERAL CIRCUIT COURT OF AUSTRALIA
| VOUKIDIS v ANASTASOPOULOS & ANOR (No.2) | [2020] FCCA 3501 |
| Catchwords: COSTS – Calderbank offer – relevant considerations. |
| Legislation: Bankruptcy Act 1966, ss.73, 222 Federal Circuit Court of Australia Act 1999, s.79 Federal Circuit Court (Bankruptcy) Rules 2016, r.13.01 |
| Cases cited: Voukidis v Anastasopoulos & Anor [2019] FCCA 3397 Calderbank v Calderbank [1975] 3 All ER 333 |
| Applicant: | OLGA VOUKIDIS |
| First Respondent: | GEORGINA ANASTASOPOULOS |
| Second Respondent: | LOUISE THOMSON IN HER CAPACITY AS TRUSTEE FOR THE BANKRUPT ESTATE OF GEORGINA ANASTASOPOULOS |
| File Number: | SYG 2634 of 2017 |
| Judgment of: | Judge Cameron |
| Hearing date: | On the papers |
| Date of Last Submission: | On the papers |
| Delivered at: | Sydney |
| Delivered on: | 23 December 2020 |
REPRESENTATION
| Counsel for the Applicant: | Mr A. Hopkins of counsel |
| Solicitors for the Applicant: | CLIC Law Group Pty Ltd |
| Counsel for the FirstRespondent: | Mr J. Rose of counsel |
| Solicitors for the First Respondent: | Diamond Conway Lawyers |
| The Second Respondent filed a submitting appearance. |
ORDERS
The applicant pay the first respondent’s costs of the proceeding on the party and party basis as agreed or taxed pursuant Part 40 of the Federal Court Rules 2011.
The applicant and the first respondent pay their own costs of the argument on costs.
| FEDERAL CIRCUIT COURT OF AUSTRALIA AT SYDNEY |
SYG 2634 of 2017
| OLGA VOUKIDIS |
Applicant
And
| GEORGINA ANASTASOPOULOS |
First Respondent
| LOUISE THOMSON IN HER CAPACITY AS TRUSTEE FOR THE BANKRUPT ESTATE OF GEORGINA ANASTASOPOULOS |
Second Respondent
REASONS FOR JUDGMENT
(As Corrected)
INTRODUCTION
On 25 November 2019 this Court dismissed the applicant’s (“Olga’s”) application under s.222 of the Bankruptcy Act 1966 (“Act”), for orders:
a)setting aside a composition under s.73 of the Act (“Composition”) into which the first respondent (“Georgina”) and her creditors had entered on 6 April 2017; and
b)restoring the creditors to the position they had been in before the Composition was proposed: Voukidis v Anastasopoulos & Anor [2019] FCCA 3397 at [1] (“First Judgment”).
The parties filed submissions regarding the costs of the proceeding and agreed that the Court should make a determination on the papers.
Georgina sought orders:
(a)…that…[Olga] pay [Georgina’s] costs (including reserved costs and amounts paid or payable by the First Respondent to Christos Voukidis and SydLegal Pty Limited under rule 15A.11 of the Federal Circuit Court Rules 2001 (Cth)
(i)on the party and party basis up to and including 29 August 2019; and
(ii)on the indemnity basis from 30 August 2019 onwards.
(b)…that costs payable [by] [Olga] in these proceedings (whether under these orders or under previous costs orders) be determined as agreed between the parties or otherwise than by taxation namely, as assessed under the costs assessment scheme operating under the law of the State of New South Wales.
Olga opposed the orders sought by Georgina and submitted that the Court should instead make orders that:
1.[Olga] … pay, on the ordinary basis, 70% of [Georgina’s] costs, up to and including 25 November 2019.
2.[Georgina] to pay [Olga’s] costs of the argument regarding costs being the costs from 26 November 2019 up to and including today’s date [being the costs of the unsuccessful application for indemnity costs].
For the reasons which follow, Olga is to pay Georgina’s costs of the proceeding on the party and party basis as agreed or taxed pursuant pt.40 of the Federal Court Rules 2011 (“FCA Rules”).
RELEVANT LEGISLATION
Section 79 of the Federal Circuit Court of Australia Act 1999 (“FCC Act”) empowers this Court to award costs in proceedings under, relevantly, the Bankruptcy Act. That section relevantly provides that:
…
(2)The Federal Circuit Court of Australia or a Judge has jurisdiction to award costs in all proceedings before the Federal Circuit Court of Australia (including proceedings dismissed for want of jurisdiction) other than proceedings in respect of which any other Act provides that costs must not be awarded.
(3)Except as provided by the Rules of Court or any other Act, the award of costs is in the discretion of the Federal Circuit Court of Australia or Judge.
Rule 13.01 of the Federal Circuit Court (Bankruptcy) Rules 2016 (“Bankruptcy Rules”) relevantly provides:
13.01 Basis for costs
(1)Subject to Division 13.2, a person who is entitled to costs in a proceeding to which the Bankruptcy Act applies is entitled to costs in accordance with Part 40 of the Federal Court Rules 2011 unless the Court otherwise orders.
(2)In making an order for costs, the Court may fix the amount of the costs.
(3)If the Court fixes the amount of the costs, Part 40 of the Federal Court Rules 2011 does not apply to a bill of costs submitted for the costs, except for the issue of a certificate of taxation.
Rule 40.02 of the FCA Rules relevantly provides that:
40.02 Other order for costs
A party or a person who is entitled to costs may apply to the Court for an order that costs:
(a)awarded in their favour be paid other than as between party and party; or
(b)be awarded in a lump sum, instead of, or in addition to, any taxed costs; or
(c)be determined otherwise than by taxation.
Note 1:The Court may order that costs be paid on an indemnity basis.
Note 2:The Court may order that the costs be determined by reference to a cost assessment scheme operating under the law of a State or Territory.
EVIDENCE
Olga did not file any evidence on the question of costs.
Georgina relied upon an affidavit of her solicitor, Matthew Hudspeth, sworn 2 December 2019 in which he deposed to matters and events in the proceeding occurring prior to the hearing including, relevantly:
a)an application made by Georgina in January 2018 to set aside subpoenas issued by Olga (“First Subpoena Dispute”) in respect of which on 7 March 2018 District Registrar Wall amended the subpoena’s schedule but otherwise dismissed the application with costs in Olga’s favour;
b)although on 9 March 2018 Olga had been ordered to file and serve her affidavits in chief by 20 April 2018 she did not file and serve the last of them until 20 July 2018, there having been three directions hearings in the meantime, the costs of one of which were fixed at $299 and ordered against Olga;
c)an application made by Olga in September 2018 to set aside subpoenas issued by Georgina (“Second Subpoena Dispute”) which was dismissed with costs in Georgina’s favour by Registrar Wall on 21 February 2019;
d)that on 30 July 2019 Olga filed the evidence of Christos Voukidis notwithstanding orders made on 18 July 2019 that:
…
2.Without leave of the Court the applicant is not entitled to rely on:
a. any evidence from Christos Voukidis that is not served by 5:00pm on or before 24 July 2019. …
On 2 September 2019, Olga was granted leave to rely on this evidence.
e)A Calderbank offer was sent by Georgina’s solicitors to Olga’s solicitors on 29 August 2019. The offer’s terms were:
a)the proceeding is to be dismissed against all respondents;
b)all extant cost orders made in the proceeding to date are to be vacated; and
c)the Applicant and the First Respondent are to each pay their own costs of the proceeding.
f)on 30 August 2019 Olga made a counter Calderbank offer, which was in the following terms:
a.That your client consent to orders that the composition be set aside pursuant to s 222(1).
b.That your client consent to the appointment of a new trustee to administer the estate of the first respondent.
c.That each party pay their own costs of the proceedings (including the vacation of all previous costs orders).
Mr Hudspeth deposed that as at 29 August 2019 Georgina had incurred legal fees of at least $175,998.60 (including GST, but excluding disbursements), and presumably on a solicitor and client basis, being:
a)$103,950 (including GST) in professional costs; and
b)$72,048.60 (including GST) in counsels’ fees.
DISCUSSION
Calderbank offer
Georgina’s submissions
Georgina submitted that costs should follow the event and that she should be awarded costs on an indemnity basis from 30 August 2019, being the date that Olga had refused her 29 August 2019 offer. In support of that argument Georgina submitted that her offer had been a “genuine and reasonable compromise” because it:
a)was reasonable given the nature of the proceeding;
b)was aimed at avoiding the costs of a five day hearing;
c)reflected the Court’s decision; and
d)was more favourable to Olga than the Court’s order, amongst other things because it would have relieved her of the 27 April 2018 and 21 February 2019 costs orders already made against her.
Georgina submitted that, on the other hand, Olga’s refusal of the offer had been unreasonable because:
a)the offer had been made in accordance with the principle in Calderbank v Calderbank [1975] 3 All ER 333;
b)the offer was made at a reasonable point in the proceeding in that all pleadings, evidence and arguments had been served such that Olga had the information necessary to evaluate it;
c)the offer provided an opportunity to avoid the substantial costs that the parties would incur if the matter proceeded to the imminent five day trial;
d)the offer had been “unambiguously clear”;
e)the offer had been open until the first day of the hearing with the option of an extension of time and so had been open for a reasonable period. Georgina further argued that Olga had rejected the offer the day after receiving it, indicating that she had not needed more time to consider it;
f)the offer would resolve the proceedings completely;
g)Olga had been legally represented; and
h)Olga’s prospects of success were “less than clear”.
Georgina also submitted that Olga’s evidence indicated that for her and for her former husband, Christos, the matter had been personal.
Olga’s submissions
Olga agreed that costs should follow the event but noted in connection with Georgina’s claim for indemnity costs that no automatic presumption of indemnity costs arose from her rejection of Georgina’s Calderbank offer and so the question was whether her rejection of it justified a departure from the usual costs order. She submitted that an indemnity cost order was not appropriate and that she should pay costs on the party and party basis from 29 August 2019 because:
a)the offer had been an invitation to yield rather than a “meaningful compromise” in that:
i)the offer proposed no real compromise and offered nothing of material value that she could take away from the proceeding, such as by “buying [her] out” or offering a resolution that was not available by judgment. It was an invitation to “walk away” and, had it been accepted, Georgina would have been wholly successful save for costs already incurred;
ii)it was not unreasonable to refuse an offer to walk away at a point when the costs of preparation had been fully incurred and the only benefit being offered was to avoid the risk of paying the other party’s costs;
iii)Georgina’s offer failed to specify the quantum of the costs she was willing to sacrifice, stating only that she had incurred “significant costs”. It was not unreasonable to be unimpressed by an offer to compromise “unknown and Delphic costs”;
b)the proceedings were neither “hopeless” nor “without merit”, as demonstrated by the findings made in the First Judgment, and it was not unreasonable to have refused the offer; and
c)Georgina’s offer had, in effect, been open only for one clear business day, because it was served just before the final hearing, and was just “an attempt to engage the costs consequence of rejection”.
Consideration
The recognition given to Calderbank offers reflects the public interest in the consensual resolution of litigation and represents one mechanism by which that may be encouraged, namely the making of an order for costs other than on a party and party basis.
The principles applicable to the situation where a party does not accept an offer made in a Calderbank letter but fails to achieve an outcome better than that offer are settled. They are that the offering party is not presumptively entitled to indemnity costs from the date of the offer or its expiry, as would be the case of a notice of offer to compromise served under rules of court, but must demonstrate that the rejection of the offer was unreasonable: Commonwealth of Australia v Gretton [2008] NSWCA 117 at [1], [44] and [117]; CGU Insurance Ltd v Corrections Corporation of Australia Staff Superannuation Pty Ltd [2008] FCAFC 173 at [75]; Taleb v GM Holden Ltd (2011) 286 ALR 309 at 318 - 319 [49]. Whether it was unreasonable of a party to not accept a Calderbank offer is to be determined prospectively, that is to say without the benefit of hindsight, by reference to the circumstances of the case at the time the offer was made or was rejected, those circumstances including whether the offer itself was reasonable: Australian Medic-Care Company Ltd v Hamilton Pharmaceutical Pty Ltd (No.2) [2009] FCA 1494 at [14]; Seven Network Ltd v News Ltd (2007) 244 ALR 374 at 389 [65]; Commonwealth vGretton at [1] and [78]; Taleb v GM Holden Ltd at 318 - 319 [49]; Facton Ltd v Seo (2011) 91 IPR 135 at 146 - 147 [55].
Other matters relevant to be kept in mind when considering whether failure to accept an offer made in a Calderbank letter was unreasonable include but are not limited to: when in the proceeding the offer was received; how long the offer was open; the clarity of the offer; whether an application for indemnity costs was foreshadowed; and, as at the date of the offer, what the offeree’s prospects of success were: Hazeldene's Chicken Farm Pty Ltd v Victorian Workcover Authority (No 2) (2005) 13 VR 435 at 442 [25]. It is not suggested that Olga, who was represented at the time, did not know what Georgina was offering or what the potential consequences of refusing the offer were. Nor, in the circumstances am I persuaded that the relatively short time during which the offer was open for acceptance is a matter of any moment given that Olga responded the day after receiving it, making a counter-offer. Olga has not argued that she had needed more time to shoot back an answer. Nor do I consider that the point in the proceeding when the offer was made has any particular significance except to the extent that by then the parties should have had a clear-eyed view of their prospects, subject to the uncertainties attendant on any litigation.
The parties were agreed that this was an “all or nothing” case but disagreed on what relevance that characterisation of this matter had to the rejection of Georgina’s offer. Georgina said that the best she could offer was to bear her own costs and Olga essentially said that something like damages would have been more appropriate.
It should not be forgotten that the genesis of this proceeding was Olga’s bankrupting of Georgina because Georgina did not pay her debt to Olga and that the effect of the First Judgment is that that debt will now never be paid in any substantive way. In circumstances where Olga was pursing the payment of a judgment debt, it would be naïve to think that she would not have welcomed an offer which acknowledged that in a material fashion.
On the other hand, Georgina submitted that due to the “binary” nature of this case, in that the Court could either decide to set the composition aside or decide not to, she was precluded from “buying off” Olga’s claim. She further argued that, apart from capitulating herself, to do anything other than what she did in connection with a proceeding in which financial compensation was not the relief sought, would have been “tantamount to bribery”. That expression was hyperbolic but in Leichhardt Municipal Council v Green [2004] NSWCA 341 at [25] and [26] Santow JA said, Stein JA agreeing at [61]:
… a defendant by definition is not the claiming party, and thus is not before the Court voluntarily. If it reasonably disputes liability and has a firm belief in the strength of its case, the best solution it can hope for – that the claim is dismissed – is not a monetary one. It will in economic terms be no better or worse off for its victory by way of successful defence, costs aside. Thus, unlike a plaintiff, it cannot discount its optimum return by way of compromise.
… the only option for a defendant is not an attractive one; to ‘buy off’ the claim by offering to pay unmeritorious claimants a sum of money to discontinue the litigation. This practice, though it no doubt occurs, is not one which the law should encourage. The policy of the law is certainly to encourage genuine compromise, but it is no genuine compromise for a defendant to pay off a plaintiff or series of plaintiffs.
His Honour went on to conclude at [30] and [36] that a defendant’s offer to be let out of proceedings with each party to pay their own costs was not necessarily an invitation to capitulate and could be a valid and genuine offer of compromise.
Whether or not Georgina could have offered something more than she did, as Olga argued, is not to the point. The question here is whether Georgina’s costs proposal offered a meaningful compromise and Georgina submitted that it did because it would have required her to bear substantial costs and would have saved Olga from the risk of doing so. Given the tenacious nature of the parties’ dispute in this Court, I accept that Georgina’s costs would have been substantial and would have been appreciated by Olga to be so, even if Georgina did not vouchsafe her a quantification. Those circumstances distinguish this matter from Regency Media Pty Ltd v AAV Australia Pty Ltd [2009] NSWCA 368, to which Olga referred in submissions.
I conclude that Georgina’s offer proposed a real compromise.
Nonetheless, I am not of the view that Olga’s refusal of the offer was unreasonable. In Facton Ltd v Seo (2011) 91 IPR 135, Gordon J summarised the issue in the following terms:
7.in determining whether an offer should have been rejected, a court looks at the “reasonableness of the conduct of the offeree, [when] viewed in the light of the circumstances which existed when the offer was rejected” … It has also been described as whether the rejection of the offer was “imprudent” or “unreasonable” … or “imprudent, reckless or unreasonable” … (at 147 [55]) (reference omitted)
In an all or nothing case, as this one was, particularly one which involves the exercise of discretion, it is difficult to conclude that a party with a case which would not be said to lack reasonable prospects of success, as that expression is understood in light of the authorities on summary disposal, acts unreasonably in not accepting an offer which offers nothing more than a “walk away”. This matter was complex factually and legally. Olga’s case, although unsuccessful, would not have been described at the time of the offer as one lacking reasonable prospects of success or one which she would be wrong not to abandon. For those reasons, I am not persuaded that Olga acted unreasonably in refusing Georgina’s offer.
In all the circumstances I am not satisfied that a special costs order should be made.
Quantification of costs
Georgina submitted that her costs should be assessed under the New South Wales assessment scheme found in pt.7 of the Legal Profession Uniform Law Application Act 2014 (NSW), arguing that such an approach would be beneficial for the Court because a registrar or taxing officer of the Court would not be required to tax the costs. Olga’s position was that there was no persuasive reason for the costs to be assessed or taxed in a different jurisdiction.
It would be an unorthodox step to quantify the costs of a Federal proceeding in a State process and it must be assumed that the adoption by the Bankruptcy Rules of the costs procedure under FCA Rules was a considered decision. Nothing other than a reference to the Court’s convenience was advanced in support of the idea and something more than that would be necessary for the Court to order quantification of costs by a process other than the one that has been prescribed. For instance, it was not demonstrated that the State assessment process would be more appropriate or fairer to the parties than taxation under the FCA Rules.
No proper basis for departing from the prescribed manner of assessing costs having been demonstrated, costs in this matter are to be taxed in accordance with the FCA Rules.
Subpoenas – special costs order
Georgina referred to r.15A.11 of the Federal Circuit Court Rules 2001 which provides:
15A.11 Cost of complying with subpoena if not a party
(1) This rule applies if:
(a)a subpoena is addressed to a person who is not a party in the proceeding; and
(b)before complying with the subpoena, the person subpoenaed has given the issuing party notice that substantial loss or expense would be incurred in properly complying with the subpoena, including an estimate of the loss or expense; and
(c)the Court is satisfied that substantial loss or expense is incurred in properly complying with the subpoena.
(2)Unless the Court or a Registrar otherwise directs, the amount of the loss or expense estimated under paragraph (1)(b) is payable by the issuing party.
…
(5)If a party who is to pay an amount under this rule obtains an order for the costs of the proceeding, the Court may:
(a)allow the amount to be included in the costs recoverable; or
(b)make any other order it thinks fit.
Georgina alleged that she had paid to Olga and Christos’s then-solicitors a combined total of $5,500 for their costs of complying with subpoenas served on them. She submitted that Olga should be ordered to pay those costs pursuant to r.15A.11(5) of this Court’s rules. The issue was not addressed in any substantive way in Mr Hudspeth’s affidavit. For her part, Olga submitted that no order should be made in relation to the costs of the subpoenas on the basis that this was a matter better dealt with as part of the agreement on or taxation of the costs more generally.
The relevant effect of r.13.01 of the Bankruptcy Rules is, in this proceeding, that Georgina is entitled to costs in accordance with pt.40 of the FCA Rules, rather than under this Court’s rules. Rule 15A.11(5) of this Court’s rules, and the special provision it makes for sums paid to cover third parties’ expenses incurred in producing documents on subpoena, is therefore not relevant and a special order under that sub-rule is not available or appropriate. Nor, in the circumstances, is an order particularly dealing with those subpoena expenses necessary. Rule 40.29 of the FCA Rules provides that a taxing officer is to allow costs in accordance with sch.3 to those rules and item 18.1 of that schedule provides that the taxing officer may allow all court fees and “other fees and payments in the amounts actually incurred”. That provision covers the subpoena expenses in question.
Apportionment
Olga’s submissions
Olga submitted that although costs should follow the event, where she had been successful on certain discrete issues the costs should be apportioned. Although her position was that she should pay costs on the party and party basis in respect of the period following the making of the Calderbank offer, she proposed that she pay only 70% of Georgina’s party and party costs of the period before the offer. Olga argued in that connection that she had enjoyed success on three jurisdictional issues raised by Georgina and that this should be considered when evaluating whether the party and party costs to be awarded in relation to the period before the offer was made should be apportioned. Olga submitted that she had been “wholly successful”:
a)at [69]-[75] of the First Judgment as to whether the Composition had been in force and whether relief under s.222 of the Act had been available to her;
b)at [76]-[83] of the First Judgment that at the relevant time not all obligations under the Composition had been completed and so the of s.222 was available to provide relief; and
c)at [84]-[86] of the First Judgment that she had had standing as a creditor to bring the proceeding.
Olga submitted that in light of the proceeding’s protracted history and the novel legal issues raised by Georgina, which were rejected, these jurisdictional successes were significant. She submitted that costs should be apportioned to reflect where she had successful on these “discrete and identifiable issues” and that for her to bear the entirety of the costs would be unfair. She also submitted that the First Judgment at [125], [158] and [171] acknowledged “strong factual reasons” for her initiation of the proceeding.
Georgina’s submissions
Georgina submitted that the Court should not apportion costs because:
a)Olga’s figure of 70% was arbitrary and failed to represent the time allocated to each issue at trial. She submitted that the trial mostly consisted of factual issues concerning the FSL Loan which Olga had raised, whereas issues concerning s.222 of the Act were mainly covered in submissions;
b)even though not all of them had been successful it was reasonable for Georgina to have raised the grounds she did;
c)furthermore the issues raised by Georgina were significant enough for Olga to change her case during the hearing; and
d)cost orders aim to indemnify the successful party against their outlays. No special circumstances existed which would warrant the Court punishing Georgina by preventing her from recovering the costs of unsuccessful “minor sub-issues” when overall she had been successful.
Consideration
A successful party is ordinarily entitled to their costs on a party and party basis. The apportionment of costs is a departure from that standard practice and needs to be justified by special circumstances. The fact that an unsuccessful party has enjoyed success on certain issues which did not turn the tide in their favour is not necessarily such a circumstance. In Bostik Australia Pty Ltd v Liddiard (No 2) [2009] NSWCA 304 it was said:
•Where there are multiple issues in a case the Court generally does not attempt to differentiate between the issues on which a party was successful and those on which it failed. Unless a particular issue or group of issues is clearly dominant or separable it will ordinarily be appropriate to award the costs of the proceedings to the successful party without attempting to differentiate between those particular issues on which it was successful and those on which it failed: …
•In relation to trials it has been said that it may be appropriate to deprive a successful party of costs or a portion of the costs if the matters upon which that party was unsuccessful took up a significant part of the trial, either by way of evidence or argument … A similar approach is adopted on appeal.
•If the appellant loses on a separate issue argued on the appeal which has increased the time taken in hearing the appeal, then a special order for costs may be appropriate which deprives the appellant of the costs of that issue ...
•Whether an order contrary to the general rule that costs follow the event should be made depends on the circumstances of the case viewed against the wide discretionary powers of the court, which powers should be liberally construed ...
•A separable issue can relate to “any disputed question of fact or law” before a court on which a party fails, notwithstanding that they are otherwise successful in terms of the ultimate outcome of the matter ...
•Where there is a mixed outcome in proceedings, the question of apportionment is very much a matter of discretion and mathematical precision is illusory. The exercise of the discretion depends upon matters of impression and evaluation … (at [38]) (references omitted)
I am not persuaded that the circumstances of this matter are reflected in those considerations. The matters on which Georgina was unsuccessful and Olga succeeded were not sufficiently distinct from the remainder of the case that they justify separate costs consideration. Moreover, it could not be said that they took up a significant part of the trial. In those circumstances it would not be appropriate to apportion costs as Olga has sought.
Costs of the costs dispute
Georgina submitted that Olga should bear the costs of the costs dispute but she was unsuccessful in her application for indemnity costs. Olga was similarly unsuccessful in her application for the apportionment of costs.
The parties are to bear their own costs of the costs dispute.
CONCLUSION
As the parties have not made out their respective claims for special costs orders:
a)Olga is to pay Georgina’s costs of the proceeding on the party and party basis as agreed or taxed pursuant pt.40 of the FCA Rules; and
b)the parties are to pay their own costs of the argument on costs.
I certify that the preceding thirty-nine (39) paragraphs are a true copy of the reasons for judgment of Judge Cameron
Associate:
Date: 25 January 2021
CORRECTIONS
REPRESENTATIONS – delete “Respondents” insert “Respondent”
REPRESENTATIONS – insert “First” before the word “Respondent”
REPRESENTATIONS – insert “The Second Respondent filed a submitting appearance.
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