Davern v QBE Insurance (Australia) Limited
[2023] NZHC 182
•13 February 2023
IN THE HIGH COURT OF NEW ZEALAND CHRISTCHURCH REGISTRY
I TE KŌTI MATUA O AOTEAROA ŌTAUTAHI ROHE
CIV-2020-409-390
[2023] NZHC 182
BETWEEN JOHN TIMOTHY DAVERN AND MARITA DAVERN
First Plaintiffs
AND
IAG NEW ZEALAND LIMITED
Second Plaintiff
AND
QBE INSURANCE (AUSTRALIA) LIMITED
Defendant
Hearing: 7 February 2023 (by VMR) Counsel:
D J Cooper KC and V A Ma for Plaintiffs
D H McLellan KC and A J Peat for Defendant
Judgment:
13 February 2023
JUDGMENT OF OSBORNE J
(admissibility of evidence — reasons)
This judgment was delivered by me on 13 February 2023 at 4.00 pm pursuant to Rule 11.5 of the High Court Rules
Registrar/Deputy Registrar Date:
DAVERN v QBE INSURANCE (AUSTRALIA) LTD [2023] NZHC 182 [13 February 2023]
[1]The trial of this proceeding is scheduled to commence on 13 February 2023.
[2] Briefs of evidence have been exchanged. The defendant, QBE Insurance (Australia) Ltd (QBE), has given notice under r 9.11(2) High Court Rules 2016 that there is an admissibility issue relating to the entire brief of evidence of Murray James, the Corporate Manager of the second plaintiff, IAG New Zealand Ltd (IAG).
[3] By a results judgment (the Results Judgment), I directed the removal of aspects of Mr James’s brief.1 These are my reasons.
A procedural matter
[4] I deal first with a procedural issue initially raised by the second plaintiff’s solicitors but responsibly not pursued in counsel’s submissions.
[5] In terms of r 9.11 High Court Rules, any challenge to the admissibility of a brief, in whole or in part, must be notified to the party or parties concerned within 20 working days after receipt of the brief by the challenging party. Under r 9.11(2), there is then a requirement for notice to be given to the Court if the issue is not resolved between counsel within a further 10 working days.
[6] In this case, Mr James’s brief was served on 13 October 2022. Consequently, r 9.11(1) required that notice of objection be given by 11 November 2022 (that is within 20 working days). The defendants’ solicitors gave notice on 25 November 2022, 10 working days late.
[7] There is commentary in McGechan on Procedure that the consequence of a breach of the timing requirements under r 9.11(1) may be that any subsequent objection is not entertained by the Court.2 The commentary then contains the admonition: “Parties should therefore be vigilant in complying with the notice requirement.”
1 Davern v QBE Insurance (Australia) Ltd [2023] NZHC 137.
2 Robert Osborne (ed) McGechan on Procedure (online ed, Thomson Reuters) at [HR9.11.02].
[8] The latter part of the commentary is clearly correct — vigilant compliance with r 9.11(1) is to be expected. That said, the Court will retain a power to consider the issue of admissibility whether or not the affected party raises the objection within the specified period. Such flows inevitably from the power of the Court to control its own processes, including at trial, a power the trial Judge is required to exercise under ss 7, and 9 Evidence Act 2006 in relation to evidence which is irrelevant or will have an unfairly prejudicial effect on or needlessly prolong a proceeding. This obligation is not limited to the situation in which a party raises the non-compliance of evidence with ss 7 and 8. Furthermore, within the High Court Rules, r 1.5(1) expressly provides that a failure to comply with the requirements of the Rules must be treated as an irregularity and does not nullify any step taken in the proceeding. By r 1.5(2)(b) the Court (in relation to such irregularities) may make any order dealing with the proceeding generally as it thinks just.
[9] Also relevant in this case are the provisions of the Evidence Act in relation to expert evidence (especially ss 23 and 25). I refer particularly to s 25(1) which provides:
Admissibility of expert opinion evidence
(1)An opinion by an expert that is part of expert evidence offered in a proceeding is admissible if the fact-finder is likely to obtain substantial help from the opinion in understanding other evidence in the proceeding or in ascertaining any fact that is of consequence to the determination of the proceeding.
[10] The correct approach in this case, therefore, is to treat the defendant’s late notification of its objection as an irregularity and to then deal with the issue before the Court as I think just. In relation to QBE’s particular objections to Mr James’s briefs, the just resolution will flow from the application of ss 7, 8 and 9 Evidence Act. Given the central requirement of admissibility that evidence be relevant,3 I will initially turn to the issues for trial, as identified through the pleadings.
3 Evidence Act 2006, s 7(2).
The plaintiffs’ claims and the issues
[11] The first plaintiffs, John and Marita Davern, own a Christchurch property (the property) damaged in the Canterbury Earthquake Sequence. The insurance policy in relation to the property was underwritten by IAG.
[12] IAG and Orange H Management Ltd (Hawkins Management) are parties to a Rebuild Solution Master Agreement dated 13 August 2012 (2012 RSMA). The 2012 RSMA is the same contract as applied to the repair works on the property of the plaintiffs in Sleight v Beckia Holdings Ltd.4
[13] Under the 2012 RSMA, Hawkins Management agreed to indemnify IAG in relation to claims incurred by IAG as a result of any breach of the 2012 RSMA5 and also provided a guarantee and indemnity to IAG in relation to liabilities arising from a failure to perform any obligation under the 2012 RSMA.6
[14] The plaintiffs allege that Hawkins Management made a sequencing error in relation to the construction of a required retaining wall which resulted in pleaded defects.
[15] From June 2012 to the present, Hawkins Management and Orange H Group Ltd (Hawkins Group) held liability policies of insurance with QBE. Both Hawkins Management and Hawkins Group have subsequently been placed in receivership and liquidation, resulting in the plaintiffs joining QBE as defendant under the Law Reform Act 1936.
[16]The plaintiffs plead two causes of action.
[17] Firstly, plaintiffs claim judgment in relation to the defendants on the basis that Hawkins Management, in carrying out the repair works, breached a duty of care owed
4Sleight v Beckia Holdings Ltd [2020] NZHC 2851 [Sleight High Court]. The decision was subsequently the subject of the Court of Appeal judgment in IAG New Zealand Ltd v QBE Insurance (Australia) Ltd [2022] NZCA 208 [Sleight Court of Appeal].
5 Clause 17.2 of the 2012 RSMA.
6 Schedule 5, cl 1.1 of the 2012 RSMA.
to the first plaintiffs through particularised breaches including failures of monitoring or supervision and failures to provide for correct sequencing. Additionally the first plaintiffs allege that Hawkins thereby breached guarantees under ss 28 and 29 Consumer Guarantee Act 1993 (the CGA) through the provision of unsatisfactory services.
[18] As a second cause of action, the second plaintiff (IAG) repeats the earlier allegations and alleges that Hawkins (in breach of contract) did not meet its obligations under the 2012 RSMA, causing IAG loss to its indemnification of the first plaintiffs for the repair costs and continuing expenses. IAG relies on both the indemnity and the guarantee (in the RSMA). Additionally, IAG asserts that Hawkins breached a duty of (tortious) care owed to IAG.
[19] By its pleadings, QBE admits that IAG and Hawkins are parties to the 2012 RSMA and admits the terms of the 2012 indemnity and the 2012 guarantee.
[20] QBE denies it owed a duty of care to the first plaintiffs or that it owed any duty to IAG other than in accordance with the 2012 RSMA. QBE denies that its conduct involved any breach of contract or was negligent.
[21] In his submissions for the plaintiffs, Mr McLellan KC has described IAG’s primary pleaded claim as being that Hawkins breached its obligations under the 2012 RSMA. Mr McLellan acknowledges that IAG also claims in tort, but notes that the particulars of that claim mirror those for breach of contract.
The purpose and content of Mr James’s brief
Purpose
[22] Mr James has had management roles at IAG since 2012, including in relation to earthquake claims. Since January 2016, he has been the Corporate Manager for IAG’s NZI sales team in the lower North Island and across the South Island. He was not involved in the drafting of the 2012 RSMA. From March 2013, he had roles first as General Manager for Loss Adjusting and Specialist Partners and then as General Manager for the Canterbury Rebuild Program Delivery where he worked with
Hawkins Management and had responsibility for the loss-adjusting team. He states that he dealt frequently with personnel from Hawkins. In his brief, he explains the purpose of his evidence:
11 I will describe IAG’s claims handling process before and after the Canterbury earthquakes and, in particular, how the handling process operated where both the house and the property’s retaining walls were earthquake damaged. I will address the Services that Hawkins Management agreed to provide under the 2012 Rebuild Solution Master Agreement and how those services related to retaining wall repairs.
[23] There is no suggestion that Mr James had any involvement in the claim in relation to the repair work carried out on the Daverns’ property.
[24] In response to QBE’s r 9.11(2) memorandum, Mr Cooper KC, by memorandum, recorded that the plaintiffs consider Mr James’s evidence relevant to the dispute as to the scope and nature of the obligations assumed by Hawkins Management under its contract with IAG.
[25]For the plaintiffs, it has further been asserted that:
It is important to have evidence as to what he, as someone who is familiar with the IAG and Hawkins processes and the contractual relationship between the parties would have expected to have occur on site to comparison with (sic) the evidence from other witnesses who set out to what (sic) did at 9 Crest Lane.
Content
[26]Mr James’s brief spans some 34 pages (154 paragraphs).
[27]After introductory passages, Mr James deals with a number of topics:
(a)[12]–[34]: description in general terms of how IAG processed claims before the earthquakes;
(b)[35]–[39]: how IAG responded to the September 2010 earthquake, including entry into a (2010) RSMA with a Hawkins company;
(c)[40]–[75]: how IAG responded to the February 2011 earthquake, including entry into the 2012 RSMA with Hawkins Management, and how the IAG dealt with claims (including the Daverns’) through a number of “silos”;
(d)[76]–[145]: how in 2012, IAG and Hawkins Management developed a non-EQC Silo Solution document for dealing with a range of non-EQC works to damaged properties and the roles of IAG and Hawkins Management in that process;
(e)[146]–[152]: how IAG dealt with problems with repair works;
(f)[153]–[154]: a brief conclusion as to what IAG was relying on Hawkins to do under the 2012 RSMA.
The admissibility objections
[28] QBE’s solicitors identified QBE’s admissibility objections in a Schedule to the notice given to the plaintiffs in November 2022. It is reproduced as the Schedule to this judgment.
[29] As Mr McLellan has elaborated, QBE’s primary objections to Mr James’s brief are:
(a)Mr James’s evidence is effectively a report on documents he did not author and includes abstract postulations about what he would have expected to have occurred generally, not in relation to the Daverns’ particular insurance claim;
(b)Mr James’s evidence includes his opinions on contractual responsibilities that Hawkins may have had under the 2012 RSMA, when he is not qualified as an expert and the nature of Hawkins’ responsibilities is a submission which is the domain of counsel; and
(c)Mr James’s evidence will needlessly prolong the hearing:
(i)despite the length of his brief, he refers to the Daverns’ property in only three places;
(ii)having regard to the length of Mr James’s evidence and likely cross-examination, his evidence is likely to take up to one day of the ten allocated days;
(iii)relative to the lack of directly probative evidence in the brief, it is disproportionately lengthy evidence and, in terms of s 8(1)
Evidence Act, would needlessly prolong the proceeding; and
(iv)QBE has had to prepare briefs in response to Mr James’s brief, a substantial part of which would not be called if Mr James’s evidence is not admissible.
[30] Mr McLellan characterises the first 50 paragraphs of the brief as [reporting] on documents and postulations about what Mr James would expect to have generally occurred”, and says that that material is objectionable because of content that is hearsay, irrelevant or such as to needlessly prolong the hearing.
[31] Mr McLellan invokes the observations of the Supreme Court in Bathurst Resources Ltd v L&M Coal Holdings Ltd.7 The Court described ss 7 and 8 Evidence Act as the “engine room of the Act”.8 Mr McLellan referred particularly to the Court’s explanation as to how ss 7 and 8 applied to contractual interpretation:9
[62] Applying s 7 in the context of contractual interpretation, evidence is prima facie admissible if it has a tendency to prove or disprove anything of consequence to determining the meaning the contractual document would convey to a reasonable person having all the background knowledge reasonably available to the parties in the situation in which they were at the time of the contract. We say prima facie as relevant evidence may still be inadmissible in terms of s 8, or in terms of one of the Act’s (or any other Act’s) exclusionary provisions.
7 Bathurst Resources Ltd v L&M Coal Holdings Ltd [2021] NZSC 85, [2021] 1 NZLR 696.
8 At [61].
9 At [62].
[32] Mr McLellan notes that Mr James is not qualified as an expert and is therefore not qualified to give opinion evidence. Were he so qualified, in Mr McLellan’s submission, s 25(1) Evidence Act would apply to render the evidence inadmissible because the Court is unlikely to obtain substantial help from Mr James’s opinion evidence.
[33] Mr McLellan observed that IAG’s pleadings rely on the express terms of the 2012 RSMA, and not on any implied term. The text of the 2012 RSMA is therefore what will be of central importance, as reflected in the approach this Court took in the Sleight case, adopting the interpretation approach required by the Supreme Court in Firm Pl 1 Ltd v Zurich Australian Insurance Ltd.10
[34] Mr McLellan submitted that Mr James’s evidence is in large part an attempt to add a gloss to the text of the 2012 RSMA, an approach rejected by this Court in Sleight:11
Although IAG does not plead or allege that an implied term as to quality should be included in the 2012 RSMA and its case is based on the express words of the contract, in evidence and submissions IAG has attempted to project a meaning into the 2012 RSMA that I am satisfied the words do not bear. In evidence of certain experts advanced by IAG, opinions were expressed that Hawkins had both an expectation and a responsibility through accepted practice to monitor quality and compliance of the builder’s work, both through the currency and at the completion of each building contract. In my view, that is not, however, what the bespoke 2012 RSMA clearly provided. It would not be appropriate here for the Court to imply a term in the 2012 RSMA relying simply on what in some of the evidence before me was referred to as “common practice”.
[35] In short, Mr McLellan invited the Court to apply to Mr James’s brief the requirements of r 9.7(4) High Court Rules, which relevantly states:
Every brief—
(a)…
(b)must be in the words of the witness and not in the words of the lawyer involved in drafting the brief:
10 Sleight High Court, above n 4 at [437], citing Firm Pl 1 Ltd v Zurich Australian Insurance Ltd
[2014] NZSC 147, [2015] 1 NZLR 432.
11 Sleight High Court, above n 4, at [467].
(c)must not contain evidence that is inadmissible in the proceeding:
(d)must not contain any material in the nature of a submission:
(e)must avoid repetition:
(f)must avoid the recital of the contents or a summary of documents that are to be produced in any event:
(g)must be confined to the matters in issue.
[36] The importance of requiring good practice in relation to the content of briefs is reinforced by the provisions of r 9.7(5), which provides not only that the Court may direct that a brief may not be read in whole or in part, but the Court may, in relation to a non-complying brief, make such order as to costs as the Court sees fit.
[37] The need for enforcement of the requirements for briefs under r 9.7(4) has very recently been identified by the Rules Committee as a significant issue in restricting access to civil justice. That follows a three year process of review and consultation, culminating in the Committee’s report entitled “Improving Access to Civil Justice”.12
[38] The Committee there identified that many judges consider that briefs and affidavits often contain much inadmissible material, submissions disguised as evidence and unnecessary recitation of the documentary record.13 The Committee referred to the prohibition of inadmissible material under r 9.7(4), discussed the difficulties facing trial Judges when objections arise at or shortly before trial, and agreed that the current processes and practices for briefs of evidence remain a key cause of the unnecessary expansion of litigation.14
Submissions for the plaintiffs
[39] For the plaintiffs, Mr Cooper emphasised that Mr James (as explained in his brief) was responsible for managing IAG’s response to Canterbury earthquake claims, including IAG’s relationship with Hawkins. His involvement was direct and extensive.
12 Rules Committee “Improving Access to Civil Justice” (November 2022) Courts of New Zealand
At [177].
14 At [178]–[181].
[40] In relation to Mr James providing evidence of context, Mr Cooper referred to passages in the judgments of the Court of Appeal and this Court in the Sleight case which referred to context evidence, including that given by Mr James (for IAG) “from the insurance industry’s perspective” and from a Mr Wood (for QBE) setting out Hawkins’ perspective.15
[41] Mr Cooper submits that IAG’s objection proceeds on an incorrect assumption that the case involves only a claim for breach of contract under the 2012 RSMA. Mr Cooper refers (correctly) to four additional sets of issues being:
(a)the Daverns’ claim under the CGA;
(b)the Daverns’ claim in the tort of negligence;
(c)IAG’s claim in the tort of negligence; and
(d)QBE’s affirmative defences alleging failure to mitigate loss and contributory negligence.
Consumer Guarantees Act
[42] The Daverns invoke the implied guarantees under ss 28 and 29 CGA. QBE denies that Hawkins Management provided services to the Daverns on the ground that its only role was to provide contractual services to IAG under the 2012 RSMA. Mr Cooper notes that the same argument was rejected in Sleight where this Court considered the relationship between the Sleights and Hawkins, including “[f]rom the Sleights’ perspective”, despite the Sleights’ rights against Hawkins under the CGA not being limited by any terms contained in the 2012 RSMA.16
[43] Mr Cooper submits that the full range of services provided by Hawkins Management under the Managed Repair Programme therefore requires consideration of Hawkins Management’s overall role, including the manner in which it interacted
15Sleight Court of Appeal, above n 4, at [6]; Sleight High Court, above n 4, at [36]–[38] and [438]– [440].
16 Sleight High Court, above n 4, at [348]–[349].
with IAG and others in the provision of services. Just as with the Sleights, the Daverns were not parties to and had not seen the 2012 RSMA — in Mr Cooper’s submission the relevant evidence cannot be limited by a focus on the terms of the RSMA. Mr Cooper observes that QBE’s same argument (as to Hawkins Management not providing services to the Daverns/Sleights) was unsuccessful in the Sleight case.17
Negligence
[44] Mr Cooper observes there is a parallel in the Daverns’ claims under the CGA and in negligence, in that QBE responds to both by pleading that Hawkins Management’s involvement was for the exclusive benefit of IAG and that the nature and extent of Hawkins’ Management’s involvement was determined solely by the 2012 RSMA. Mr Cooper observes that any inquiry as to the existence and scope of a duty of care necessarily requires an assessment of the full context in which the defendant has provided the services in question — what the leading Supreme Court judgment in North Shore Council v Attorney-General described as “everything bearing upon the relationship between the parties”.18
Failure to mitigate loss and contributory negligence
[45]Section 3(1) Contributory Negligence Act 1947 provides:
Where any person suffers damage as the result partly of his own fault and partly of the fault of any other person or persons, a claim in respect of that damage shall not be defeated by reason of the fault of the person suffering the damage, but the damages recoverable in respect thereof shall be reduced to such extent as the court thinks just and equitable having regard to the claimant’s share in the responsibility for the damage:
Provided that—
(a)This subsection shall not operate to defeat any defence arising under a contract:
(b)Where any contract or enactment providing for the limitation of liability is applicable to the claim, the amount of damages recoverable by the claimant by virtue of this subsection shall not exceed the maximum limit so applicable.
17 Sleight High Court, above n 4, at [348]–[340].
18 North Shore Council v Attorney-General [2012] NZSC 49, [2012] 3 NZLR 341 at [156].
[46] Mr Cooper observes that flowing from that provision, the inquiry in relation to contributory negligence is similar to that when determining the existence, scope and breach of a tortious duty but also includes the “just and equitable” assessment. He submits that the full context of the dealings and relationship between IAG and Hawkins is therefore relevant.19
Breach of contract claim
[47] Mr Cooper submits there are disputed aspects of the breach of contract claim that call for evidence covered by Mr James’s brief. In particular, he refers to the express contemplation under the 2012 RSMA that the parties would agree protocols, processes and procedures for carrying out their obligations under the 2012 RSMA. QBE disputes that certain protocols were created under provisions of the 2012 RSMA. QBE also pleads that IAG is estopped from alleging that such documents had contractual status or can be read as part of the 2012 RSMA by virtue of the Court of Appeal judgment in Sleight. Mr Cooper observes evidence was led by both IAG and QBE in Sleight as to documents of this type, with no suggestion in the judgments that such evidence was inadmissible. Mr Cooper also submits that the Court of Appeal’s judgment in Sleight addressed a narrower issue and that the documents referred to in Mr James’s evidence are different from those referred to in the Sleight judgment. He also refers to matters of timing relating to the RSMAs that he submits render the documents in question a relevant part of the context in which the 2012 RSMA was reached.
[48] Mr Cooper then responded to QBE’s specific grounds of objection on the following points:
Reference to documents which Mr James “did not author”
(a)Mr Cooper submits the authorship of the documents is not the point. Rather, Mr James is referring to documents to explain how they were utilised in the management of the relationship between IAG and Hawkins. Mr Cooper rejects QBE’s suggestion that such documents
19 Citing also Hooker v Stewart [1989] 3 NZLR 543 (CA) at 547.
can come in as evidence through the common bundle. He argues, by reference to a particular document (a “Master Sheet”), that Mr James discussing certain documents yields a clearer picture as to their provenance and function which would not result from simply producing them in the common bundle.
Non expert opinions/submissions
(b)Mr Cooper submits that some examples of passages objected to by QBE do not constitute opinion or submission but instead “describe the process that was followed”.
Lack of personal involvement at the property
(c)Mr Cooper submits that Mr James’s non-involvement with the property is irrelevant as his evidence is in relation to the relationship between IAG and Hawkins and the respective roles each played in the Managed Repair Programme.
Paragraphs [1]–[50]
(d)Mr Cooper submits that these paragraphs, which contain Mr James’s evidence in relation to IAG’s claims processes and how they changed, provides relevant context. He submits that the evidence is not hearsay as Mr James speaks with direct knowledge of the matters he addresses. He refers to similar evidence led by both IAG and QBE (without objection) in the Sleight case.
Discussion
[49] There are repeated examples in Mr James’s brief of assertions as to what Hawkins was responsible for or required to do (or similar wording) under the 2012 RSMA or the other documents entered into between the parties. It is one thing (permissible) to refer to documents in order to provide context for what one of the parties was doing, but it is another matter (impermissible) when the witness then seeks to state their view as to the meaning of a contract or similar document or what
obligations were created under that document. In the Results Judgment at [5](a), I accordingly ruled that assertions of that latter nature had to be removed from his brief.
[50] That said, I did not require the removal of context from the brief of evidence, including by reference to documents of which Mr James had knowledge and with which he was involved in dealings with Hawkins. The suggestion for IAG that matters, such as reference to documents, could appropriately be dealt with simply by inclusion in the bundle, followed by counsel’s submissions, is in the circumstances of this case incorrect, as the “Master Sheet” example relating to matters discussed by Mr James and Mr Lemmon demonstrated. Such evidence is relevant, as Mr Cooper submitted, in establishing the provenance and function of such documents.
[51] The remaining area of potential concern with Mr James’s brief relates to his assertions concerning the conduct or practice of IAG, particularly in its relations with Hawkins. The plaintiffs’ response to the QBE objections that the witness was not giving evidence from his own knowledge or is otherwise speculating is, by its nature, difficult to assess when the brief is simply discussing the occurrence of events. Whether a witness indeed has such personal knowledge of events as to entitle them to give evidence about those events is a matter that is capable of exploration in cross- examination. However, the challenge having been made by QBE, it is appropriate in the circumstances of this case (where Mr James has a lengthy brief) to require counsel and Mr James to review his brief in relation to a range of assertions made regarding IAG practices and conduct to ensure he will indeed be giving evidence based on his personal knowledge of those matters. The direction made in the Results Judgment at [5](b) required such a review to be conducted and to be followed by the excision of any assertions which do not represent Mr James’s personal knowledge.
[52] Beyond those rulings, I did not consider it practicable or appropriate to consider whether any further passages in the brief of Mr James should be excised. The ruling in my Results Judgment deals with the evidence to be excluded. All remaining aspects of Mr James’s evidence will be open to review at trial, as in the case of any other witness, should an issue arise as to the admissibility of particular passages as they are read from his amended brief.
Costs
[53] I reserve the costs and disbursements associated with the review under r 9.11 High Court Rules. My present view is that costs should appropriately be paid by the plaintiffs to the defendant on a 2B basis, the defendant having been successful to a significant degree. While the defendant has not been fully successful in that I did not rule against Mr James’s brief in its entirety, virtually all the material covered in submissions and the hearing were necessary to reach the conclusions (in favour of the defendant) contained in this judgment.
[54] In the event the parties do not agree on costs, they will be determined on the papers upon the basis of memoranda filed (four page limit) by the defendant within 10 working days after this judgment and by the plaintiffs within five working days thereafter.
Osborne J
Solicitors:
Duncan Cotterill, Auckland Hazelton Law, Wellington
SCHEDULE
HAZELT0N(ŁAW
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Partner
HAZELT0N)LAW
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