Lavrentiadis v Wintrust New Zealand Limited
[2022] NZHC 326
•1 March 2022
IN THE HIGH COURT OF NEW ZEALAND AUCKLAND REGISTRY
I TE KŌTI MATUA O AOTEAROA TĀMAKI MAKAURAU ROHE
CIV-2018-404-925
[2022] NZHC 326
BETWEEN LAVRENTIOS LAVRENTIADIS
Plaintiff
AND
WINTRUST NEW ZEALAND LIMITED
First Defendant
WINTRUST ASIA PACIFIC PTE LIMITED
Second DefendantMILKY WAY LIMITED
Third DefendantDEXTRA PARTNERS PTE LIMITED
Fourth DefendantBERNHARD WILHELM RUDOLF WEBER
Fifth Defendant
TRACEY CASARI
Sixth Defendant
Hearing: On the papers Appearances:
LL Fraser and JC Adams for the Plaintiff
Judgment:
1 March 2022
JUDGMENT OF ASSOCIATE JUDGE SUSSOCK
This judgment was delivered by me on 1March 2022 at 11.30am pursuant to r 11.5 of the High Court Rules
Registrar/Deputy Registrar
LAVRENTIADIS v WINTRUST NEW ZEALAND LTD & ORS [2022] NZHC 326 [1 March 2022]
Introduction
[1]The plaintiff/applicant is seeking orders:
(a)setting aside the fourth and fifth defendants’ claims to privilege in relation to documents containing legal advice they received and shared with the first to third defendants (including by disclosing it to the sixth defendant);
(b)for the first to third defendants to make the above documents (and material summarising or referring to the content of such documents) available to the plaintiff for inspection, by way of provision of unredacted electronic copies; and
(c)that the fourth and fifth defendants be ordered to pay the costs of the application.
[2]The plaintiff says that the above orders are justified on the basis that:
(a)the fourth and fifth defendants have asserted privilege over documents but have since stopped participating in the proceedings and have failed to substantiate their claim to privilege;
(b)the first to third defendants have the documents and would make them available to the plaintiff were it not for the fourth and fifth defendants’ claim to privilege; and
(c)the evidence available suggests the claim by the fourth and fifth defendants cannot be substantiated, including on the basis of the recent decision of the Supreme Court in Lambie Trustee Limited v Addleman.1
[3] The application relates to 29 documents. Eight of the documents have been wholly withheld while the remaining 21 documents have been redacted to a greater or lesser degree. Several of the documents are either exact or close copies of each other.
1 Lambie Trustee Limited v Addleman [2021] NZSC 54.
[4] As a result of liquidation and bankruptcy proceedings in Singapore respectively, directions have been made that the fourth and fifth defendants are not required to take any steps in the proceedings until further order of the Court.2
Issues
[5]The issues are:
(a)Are the documents that have been withheld or had passages redacted relevant and discoverable?
(b)Is the fact that the fourth and fifth defendants have failed to substantiate their claim to privilege fatal to that claim in circumstances where the Court has directed they are not required to take further steps?
(c)Does the joint interest exception to privilege as discussed in Lambie Trustee Limited v Addleman extend to the plaintiff in respect of these documents?
(d)Have the fourth and fifth defendants waived privilege in the advice?
Background to the application
The parties and their roles
[6] The plaintiff is the settlor and primary beneficiary of a New Zealand trust, the Golden Galaxy Trust (“GGT”), established by declaration of trust dated 25 September 2008. The first defendant, Wintrust New Zealand Limited, was the trustee of the GGT until 2016.
[7] The plaintiff alleges the second defendant, Wintrust Asia Pacific Pte Ltd, was the GGT’s administrator until September 2016. The second defendant admits it is a licensed trust company providing trustee, corporate and fiduciary services but otherwise denies that allegation.
2 Lavrentiadis v Wintrust New Zealand Ltd HC Auckland CIV-2018-404-925, 16 July 2021. (Minute of Associate Judge Bell)
[8] The third defendant, Milky Way Limited, succeeded WTNZ in its role as trustee and remains the trustee of the GGT.
[9] The first to third defendants are referred to collectively as the “Wintrust Defendants”.
[10] The fourth defendant, Dextra Partners Pte Ltd, was the protector of the Trust from April 2012. Dextra is now in liquidation in Singapore.
[11] The fifth defendant, Mr Bernhard Wilhelm Rudolf Weber, is a shareholder and director of Dextra. Mr Weber has now been adjudicated bankrupt in Singapore.
[12] The fourth and fifth defendants are referred to collectively as the “Dextra Defendants”.
[13] The sixth defendant, Ms Tracey Casari, was a director of the first defendant from 18 November 2004 to 23 June 2016 and a director of the second defendant from 7 July 2006 to 30 September 2016.
[14] The plaintiff’s claim in these proceedings centres around the Wintrust Defendants permitting a transfer in May 2012 of €11 million of the GGT’s assets to the Dextra Defendants and the ongoing failure to recover or return those funds to the GGT. The plaintiff alleges that what took place amounts variously to breaches of fiduciary duties owed by the Wintrust and Dextra Defendants and Ms Casari or knowing assistance or conspiracy to defraud.
[15] The insolvencies of the Dextra Defendants were precipitated by successful civil proceedings brought by the plaintiff against the Dextra Defendants in Singapore in relation to a separate trust structure. In the Singapore proceedings Dextra was held to have breached its fiduciary duties to the plaintiff. Mr Weber was found to have knowingly assisted in those breaches of duties. The plaintiffs submit that the Singapore High Court awarded the plaintiff in excess of €18m.3
3 Lavrentiadis v Dextra Partners Pte Limited & Weber [2020] SGHC 146.
[16] The Dextra Defendants’ lawyers have advised that they are no longer receiving instructions from their clients. Associate Judge Bell made a direction on 16 July 2021, prior to the fourth and fifth defendants entering into insolvency, that the fourth and fifth defendants were not required to take any steps in this proceeding pending further order of the Court. Associate Judge Bell’s Minute records that it may be necessary to consider whether to stay this proceeding against them if they do enter insolvency as any claims would be dealt with through the insolvency administration process. An order for stay was not made at that time.
[17] Before they went into liquidation and bankruptcy, the fourth and fifth defendants claimed privilege in the documents identified by the first, second and third defendants.
[18] In preparation for what was originally to be a hearing of this application on 11 October 2021, the plaintiff’s lawyers sent the liquidators and trustee in bankruptcy for the fourth and fifth defendants the application for discovery. The liquidators and trustee replied saying the proceedings against the fourth and fifth defendants are now stayed under Singapore law, but did not engage with the discovery issue.
[19]No notice of opposition has been filed in response to the application.
[20] A case management conference was convened on 6 October 2021 to consider how to proceed. In his minute of the same date, Associate Judge Bell recorded that Ms Scott (who was appearing for the former solicitors for the fourth and fifth defendants) submitted that as Associate Judge Bell had directed that the parties were not required to take any steps in the proceeding and as the fourth and fifth defendants have asserted privilege in the documents, it would be wrong to decide the discovery application without giving the fourth and fifth defendants the opportunity to be heard. Associate Judge Bell accepted the point made by Ms Scott but declined to vacate the fixture on 11 October 2021 to wait for the liquidators and trustee in bankruptcy to take any steps. His Honour considered that it was more efficient to decide the discovery application even if the liquidators and trustee in bankruptcy did not take any part, whilst expressly reserving to the liquidators and trustee in bankruptcy the right to seek a review under r 7.49 of the High Court Rules 2016 if they consider that the decision
is wrong. As the liquidators and trustee in bankruptcy are in Singapore, the time for seeking a review is to be extended under r 1.19 of the High Court Rules beyond the standard five working days to 15 working days after receiving the decision. Associate Judge Bell further directed that any review application need not be heard by the Judge deciding the plaintiff’s discovery application.
[21] On that basis, Associate Judge Bell directed that the plaintiff’s application could proceed on the papers.
The documents withheld or redacted
[22] The documents that are the subject of this application are held by the Wintrust Defendants and include:
(a)legal advice provided to the Dextra Defendants by their Singapore lawyers, Harry Elias Partnership, that was then shared with the Wintrust Defendants including by providing it to Ms Casari; and
(b)documents summarising the contents of that legal advice. (together, the Withheld Documents).
[23] The Wintrust Defendants’ position in response to this application is that they would produce the Withheld Documents were it not for the Dextra Defendants’ assertion of privilege, but that in light of that claim they do not have authority to disclose the documents as they cannot themselves waive privilege.
[24] The Wintrust Defendants have provided copies of the documents to the Court in redacted and unredacted forms but otherwise abide the decision of the Court (except in relation to costs).
Relevant legal principles
[25] Rule 8.25(1) of the High Court Rules 2016 provides that if a party challenges a claim of privilege in an affidavit of documents, another party may apply to the Court for an order setting aside or modifying the claim. Pursuant to r 8.25(3), the Court may then set aside the claim to privilege, modify the claim to privilege, dismiss the
application, or make any other order with respect to the document under review that the Judge thinks just.
[26] Section 54 of the Evidence Act 2006 provides for the privilege for communications with legal advisers. It is predicated on an intention that the communication between the person and the legal adviser is intended to be confidential (s 54(1)(a)). In addition, s 56 provides a privilege for preparatory materials for proceedings. The documents at issue are dated between 26 June 2012 and 8 January 2015: significantly in advance of the filing of these proceedings in May 2018. With that context, I proceed on the basis that the privilege claim in this instance is a claim to privilege under s 54.
Are the documents relevant to the matters in issue?
[27] The plaintiff submits that the fact that the Wintrust Defendants’ position is that they would produce the Withheld Documents were it not for the Dextra Defendants’ assertion of privilege clearly infers that the Withheld Documents are relevant to the claim and discoverable.
[28] The Wintrust Defendants’ willingness to produce the documents, however, needs to be considered against the documents themselves.
[29] Having reviewed the documents, the advice for which privilege is claimed can be divided into two categories:
(a)the Dextra Defendants’ obligations as “trustee” in administering the trust; and
(b)the reporting requirements of the regulators.
[30] The Minute of Associate Judge Andrew following the case management conference dated 23 April 2021 attaches at Schedule A a list of indicative issues. These are to be updated following amended pleadings but are sufficient for considering this application. The schedule includes issues relating to both Wintrust’s and Dextra’s obligations to the plaintiff, whether fiduciary or otherwise. The first category is clearly relevant to this.
[31] In the second category there is advice in relation to reporting requirements as a trustee generally for supervision of trusts and advice relating to the filing of suspicious transaction reports in respect of money laundering legislation. The latter advice refers to the no tipping off rule in respect of suspicious transaction reports pursuant to Singapore’s anti-money laundering legislation. In New Zealand the equivalent provision makes it an offence to let a client know whether a suspicious transaction report has been filed.4
[32] Some of the documents which have been provided in redacted form make it clear that a suspicious transaction report is being considered with just the legal advice in relation to such a report redacted.
[33] It appears from the documents that the legal advisers consider that the filing of a suspicious transaction report may be relevant to a trustee’s duties in respect of trust funds held. Furthermore, the advice in relation to whether to file a suspicious transaction report in these circumstances is often intertwined with other advice. I proceed on the basis therefore that all of the advice withheld or redacted can be considered relevant. At the end of the judgment I reserve leave to the fourth and fifth defendants, and their liquidators and trustee in bankruptcy respectively, to seek review of this decision as discussed above. If any issues arise with disclosure of details in relation to any suspicious transaction report, the affected party may make an application.
Have the Dextra Defendants failed to substantiate their privilege claim?
[34] The plaintiff submits that in this case the Dextra Defendants are no longer participating in the proceedings and have made no effort to establish their claim to privilege beyond asserting it. In the plaintiff’s submissions they should, therefore, not be afforded the benefit of the privilege. In making this submission, the plaintiff relies on Kupe Group Ltd v Ariadne Australia Ltd where Wylie J held: 5
The onus is on the party setting up the claim [to privilege]. It must be remembered that privilege is just what it says – it is an exception to the general rule for discovery and right of inspection. The party setting up the claim has
4 Anti-Money Laundering and Countering Financing of Terrorism Act 2009, s 46.
5 Kupe Group Ltd v Ariadne Australia Ltd (1991) 4 PRNZ 135 (HC) at 138.
an onus to establish its entitlement to the benefit of the privilege … and in my opinion that entitlement must be established and unequivocally.
[35] The complicating factor here is that there is a direction that the fourth and fifth are not required to take any steps in the litigation until further order of the Court.
[36] Without reaching a view on this aspect, I consider the further grounds for disclosure below as they may resolve matters without needing to rely on this factor.
Does the plaintiff have a joint interest in the legal advice obtained by the Dextra Defendants and provided to the Wintrust Defendants?
[37] The plaintiff submits that aside from the failure to substantiate their claim, the documents should be treated as documents in which the plaintiff as a beneficiary of the GGT has a joint interest in light of the Supreme Court decision Lambie Trustee Limited v Addleman,6 such that the fourth and fifth defendants are not entitled to claim privilege against the plaintiff.
Position of Dextra
[38] In Lambie the advice in issue was given directly to the trustee. Here, however, the advice was given to one or both of the Dextra Defendants, who then shared it with the trustee of the GGT. Dextra was the protector of GGT rather than named as a trustee.
[39] In their statement of defence dated 5 July 2011, the Dextra Defendants admit that €11 million, the trust property in this case, was transferred to Dextra’s client account with DBS Bank Limited on or around 16 May 2012 (“Transfer”). Importantly, the Dextra Defendants say further that Dextra held the funds on behalf of the first defendant, the trustee of GGT.
[40] For the purposes of this application, Dextra can therefore be considered to be in the position of trustee in respect of the Transfer.
6 Lambie Trustee Limited v Addleman, above n 1.
Joint interest privilege exception
[41] In Lambie the Supreme Court relied on a passage from Lewin on Trusts to explain the joint interest exception to legal professional privilege shared between beneficiaries and trustees:7
Normally disclosure will be ordered of cases submitted to, and opinions of, counsel taken by the trustees, and other instructions to and legal advice obtained from the trustees’ lawyers, for the guidance of the trustees in the discharge of their functions as trustees, and paid for from the trust fund. Even though such advice is privileged, the privilege is held for the benefit of the beneficiaries, not for the personal benefit of the trustees, and so privilege is no answer to the beneficiary’s demand for disclosure. A beneficiary should, of course, seek disclosure from the trustee, or if necessary in proceedings to which the trustee is a party, and not directly from the lawyer who gave the advice since the lawyer is bound by privilege and is in no position to waive it at the instance of a beneficiary.
[42] The Supreme Court held that it was clear that the joint interest exception applied to legal advice given to trustees relating to the general administration of the Lambie Trust and that this included advice in relation to a distribution to Mrs Addleman in 2002.
[43] Some of the legal advice at issue in Lambie, however, was legal advice given to Lambie Trustee Ltd in connection with litigation with Mrs Addleman.
[44] In considering whether the joint interest exception applied to advice in respect of the litigation with Mrs Addleman, the Supreme Court held that the issue was “whether the dispute between Lambie Trustee Limited and Mrs Addleman resulted in their joint interest coming to an end, and, if so, when”.8 The Supreme Court explained:9
The joint interest exception is founded on the assumption that advice to which it applies is obtained for the benefit of beneficiaries. It follows that there may be circumstances in which that assumption no longer applies. Where this happens, the joint interest on which the exception is based has come to an end.
7 At [73], citing Lynton Tucker, Nicholas Poridevin and James Brightwell Lewin on Trusts (19th ed, Sweet & Maxwell, London, 2015) at [23-048] (footnotes omitted).
8 At [74].
9 At [74].
[45] In this case, the advice at issue is all dated between 2012 and 2015, well before this litigation was brought in 2018. The question remains however whether the assumption that the advice was obtained for the benefit of the beneficiary applies to all of the advice for which privilege is claimed or whether in this case the advice could be said to have been obtained for the benefit of the trustee or trustees personally.
[46] In Lambie, the Supreme Court was considering an application for disclosure of trustee information rather than a privilege claim in the context of discovery. For those purposes, the Supreme Court distinguished between trustee information and personal information. Separating the advice in this case into advice that would be considered trustee information and advice that would be personal information of the trustees assists in determining whether advice received is for the benefit of beneficiaries or not and therefore whether the joint interest privilege exception applies.
[47] Trustee information is described by the Supreme Court as the type of information that trustees must hand over to their successors where there is a change of trustees.10 The Supreme Court held that as a rough rule of thumb advice paid for using trust money is most unlikely to be personal to the trustees.11 There is no evidence before me as to who has paid for the advice in issue in this application. By inference from the Supreme Court’s description of trustee information, however, personal information, will be information that is not required to be handed over to successor trustees.
[48] Most of the advice in this case relates to Dextra’s obligations as trustee in respect of the money held on trust except for two instances where the advice appears to relate to personal obligations or possible personal liability of Dextra and/or Mr Weber.
[49] The first is advice in relation to the filing of a suspicious transaction report in the particular circumstances. Advice in relation to the need to file suspicious transaction reports more generally may be considered trustee information but advice
10 At [47]–[49].
11 At [50]–[52].
in relation to the filing of a suspicious transaction report in these particular circumstances would be personal information.
[50] The second is in one of the emails from Mr Philip Fong of Harry Elias (the Singapore law firm acting) dated 15 November 2014 when he begins his email to Mr Weber by saying “[i]t appears to me that your major concern is whether you had acted properly or improperly when you placed the funds in ‘protected assets’.” The advice continues “[a]s to whether you can release the funds given that there is now information that the funds and the assets may be tainted, I have already addressed the point”. This latter advice relates to the administration of the trust as it relates to the obligation to distribute the assets. This is analogous to the advice referred to in Lambie in relation to the distribution to Ms Addleman in 2002 which the Supreme Court held clearly fell within the exception. In contrast, the advice relating to whether the Dextra Defendants had acted properly or improperly may be considered personal to the Dextra Defendants.
[51] There may, therefore, be a basis for holding that the joint interest exception does not apply in respect of the advice that appears to be personal to the Dextra Defendants rather than in relation to the administration of the trust.
[52] A distinguishing factor in this case as compared to Lambie, however, is that the legal advice provided to the Dextra Defendants was forwarded to the Wintrust Defendants and Ms Casari, and, in some cases, third parties. I consider below whether any privilege in the advice is therefore waived, whether personal to the Dextra Defendants or not.
Is privilege in the advice waived?
[53] The plaintiff submits the Dextra Defendants’ claim to privilege in the documents should be set aside because they have clearly waived privilege vis-à-vis the Wintrust Defendants and Ms Casari. The plaintiff submits that, in light of Lambie, any limited waiver should be held to extend to the plaintiff as GGT beneficiary.
[54] I accept that any limited waiver of privilege in advice that would be considered trust information would not provide a basis for asserting privilege against the plaintiff.
[55] For the advice that might be considered personal to the Dextra Defendants, however, a limited waiver to the Wintrust Defendants and Ms Casari might not extend to the plaintiff on a joint interest exception basis.
[56] Having reviewed the unredacted versions of the documents there is no attempt in the documents themselves to record that the advice is provided on a confidential basis, or to protect any privilege in the advice or to discuss any limit on their distribution.
[57] The question is therefore whether there has been a limited waiver or whether the circumstances of the disclosure mean that any privilege in the advice has been waived more generally and should not be able to be asserted against the plaintiff in any event.
[58]Section 65 of the Evidence Act provides for waiver of privilege and states:
65 Waiver
(1)A person who has a privilege conferred by any of sections 54 to 60 and 64 may waive that privilege either expressly or impliedly.
(2)A person who has a privilege waives the privilege if that person, or anyone with the authority of that person, voluntarily produces or discloses, or consents to the production or disclosure of, any significant part of the privileged communication, information, opinion, or document in circumstances that are inconsistent with a claim of confidentiality.
(3)A person who has a privilege waives the privilege if the person—
(a)acts so as to put the privileged communication, information, opinion, or document in issue in a proceeding; or
(b)institutes a civil proceeding against a person who is in possession of the privileged communication, information, opinion, or document the effect of which is to put the privileged matter in issue in the proceeding.
(4)A person who has a privilege in respect of a communication, information, opinion, or document that has been disclosed to another person does not waive the privilege if the disclosure occurred involuntarily or mistakenly or otherwise without the consent of the person who has the privilege.
…
[59] Counsel for the plaintiff refers to the heart of legal advice privilege being the relationship of confidence between solicitor and client and that it is because the relationship is intended to be confidential that privilege attaches to the advice.12
[60] The plaintiff submits that privilege may be waived only for limited purposes, but, if that is what is intended, the party is required to make it clear that the waiver is so limited.13
[61] The plaintiff further submits that there is no suggestion that the fourth and fifth defendants took steps to limit the waiver of privilege to the Wintrust Defendants and Ms Casari, to the exclusion of the plaintiff (even if they could).
[62]The plaintiff makes the above submissions without having seen the documents.
[63] One document, WTNZ.01119, is important as far as waiver is concerned. In this document, Ms Tracey Casari forwards to Mr David Willis at least the beginning of advice forwarded to her by Mr Weber in WTAP.01230. Having received this email, David Willis then forwarded it on to two further parties, Mr Mike Reynolds and Ms Samantha Fox.
[64] Mr David Willis’s email address is @anchortrustees.co.nz. The decision of the Singapore High Court, Lavrentiadis v Dextra Partners Pte Limited & Weber refers to New Anchor Limited. New Anchor is described as a service provider that the Dextra Defendants used whenever the plaintiff wanted to withdraw a sum of money in cash.14 The Dextra Defendants did not have any interest in New Anchor according to the judgment. There is no confirmation however that Mr Willis is associated with the company referred to as New Anchor.
[65] The key point, however, is that in the emails forwarding the legal advice from Mr Weber to Ms Casari and then from Ms Casari to others including Mr Willis, there is no attempt to retain confidentiality in that advice.
12 Citing Matthew Downs (ed) Cross on Evidence (online loose-leaf ed, Thomson Reuters) at [EVA 65.2].
13 At [EVA 65.6].
14 Lavrentiadis v Dextra Partners Pte Limited & Weber [2020] SGHC 146, above n 3, at [216].
[66] Considering the content of WTNZ.01119, it is one page long with only the first part of the email from Mr Philip Fong of Harry Elias on 17 November 2014 included. It is not clear from WTNZ.01119 whether the whole of the email chain between Mr Weber and Harry Elias was included or not. This email chain included the potentially personal advice from Mr Fong of Harry Elias on 15 November 2014 beginning “[i]t appears to me that your major concern is whether you had acted properly or improperly”.
[67] Pursuant to s 65(2), a person with privilege waives that privilege if that person voluntarily discloses the privileged communication in circumstances that are inconsistent with a claim of confidentiality. Section 65(4) does provide that a person who has a privilege does not waive the privilege if the disclosure occurred involuntarily or mistakenly or otherwise without the consent of the person who has the privilege. However, a mistake sufficient to prevent privilege being disclosed in such circumstances must be a mistake as to the act of disclosure itself, rather than a mistake as to the implications of disclosure.15
[68] In circumstances where no steps have been taken when forwarding the emails to the Wintrust Defendants to attempt to protect the confidentiality of the advice, I consider any privilege in any personal information included (rather than trustee information) has been waived. Privilege cannot therefore continue to be asserted by the fourth and fifth defendants against the plaintiff either because the plaintiff falls within the joint privilege exception or, where the advice may be considered personal to the Dextra Defendants, privilege in the advice has been waived.
Result
[69]For the reasons discussed above, I make the following orders:
(a)any privilege in the documents listed in the schedule to this judgment is set aside with this order to take effect 16 working days following delivery of this judgment or on further order of the Court if an
15 See Body Corporate 191,561 v Argent House Ltd (2008) 19 PRNZ 500, as cited in Downs, above n 11, [EVA65.7]
application for review of this decision is made in accordance with the directions below;
(b)leave is reserved to the fourth and fifth defendants (or their liquidators or trustee in bankruptcy) to seek a review of this decision pursuant to r 7.49 of the High Court Rules 2016;
(c)the time by which any such application is required to be made in r 7.49(3) is extended to 15 working days (rather than five working days) after receiving the decision; and
(d)any review application is not required to be heard by me.
Costs
[70] The plaintiff seeks costs from the fourth and fifth defendants but not as against the first to third defendants. With the direction that the fourth and fifth defendants were not required to take any steps, I consider it would be appropriate to hear further from the plaintiff and the fourth and fifth defendants before making costs orders in respect of this application. I ask the parties to confer but, if agreement is not able to be reached, the plaintiff may file a memorandum of no more than five pages within 20 working days of this judgment. The fourth and fifth defendants (or their liquidator or trustee in bankruptcy) are to file any memorandum in response within 15 working days following service of the plaintiff’s memorandum.
Associate Judge Sussock
Solicitors/Counsel: Chapman Tripp, Auckland Duncan Cotterill, Wellington Wotton Kearney, Auckland Jackson Russell, Auckland
SCHEDULE OF WITHHELD DOCUMENTS
| Doc ID | Date | Doc Type | Author | Recipient |
| WTNZ.01817 | 26 June 2012 | Memo | Sandy Tay | WinTrust |
| WTNZ.01818 | 26 June 2012 | Memo | Sandy Tay | WinTrust |
| WTAP.01676 | 26 June 2012 | Memo | Sandy Tay | WinTrust |
| WTAP.00881 | 26 July 2012 | Sandy Tay | Tracey Casari, Bee Teng | |
| WTAP.01677 | 11 Sep 2012 | Sandy Tay | Bee Teng | |
| WTAP.01678 | 11 Sept 2012 | Sandy Tay | Tracey Casari, Bernhard Weber | |
| WTNZ.01819 | 12 Sept 2012 | Memo | Sandy Tay | WinTrust |
| WTAP.01679 | 12 Sept 2012 | Memo | Sandy Tay | WinTrust |
| MWL.00407 | 12 Sept 2012 | Memo | Sandy Tay | WinTrust |
| WTAP.01698 | 14 Jan 2013 | Tracey Casari | Sandy Tay | |
| WTAP.01699 | 14 Jan 2013 | Tracey Casari | Sandy Tay | |
| WTAP.01700 | 14 Jan 2013 | Sandy Tay | Tracey Casari | |
| WTAP.01230 | 17 Nov 2014 | Tracey Casari | Sandy Tay, Bee Teng | |
| WTAP.01755 | July 2014 | Article | Mourant Ozannes | |
| WTAP.01756 | Legislation | |||
| WTNZ.01119 | 20 Nov 2014 | Email chain | David Willis | Mike Reynolds, Samantha Fox |
| WTAP.01757 | 19 Nov 2014 | Sandy Tay | Bee Teng | |
| WTAP.01758 | July 2014 | Article | Mourant Ozannes | |
| WTAP.01759 | Legislation | |||
| WTAP.01761 | 19 Nov 2014 | Tracey Casari | Sandy Tay, Bee Teng | |
| WTAP.01762 | 19 Nov 2014 | Sandy Tay | Tracey Casari, Bee Teng | |
| WTAP.01232 | 19 Nov 2014 | Tracey Casari | Sandy Tay, Bee Teng | |
| WTAP.01231 | 19 Nov 2014 | Bee Teng | Sandy Tay | |
| WTAP.01760 | 19 Nov 2014 | Sandy Tay | Tracey Casari, Bee Teng | |
| WTAP.01312 | 8 Jan 2015 | Tracey Casari | Sandy Tay, Bee Teng | |
| WTAP.01310 | 8 Jan 2015 | Bernhard Weber | Tracey Casari, Sandy Tay | |
| WTAP.01313 | 8 Jan 2015 | Tracey Casari | Sandy Tay, Bee Teng | |
| WTAP.01314 | 8 Jan 2015 | Tracey Casari | Bernhard Weber | |
| WTAP.01311 | 8 Jan 2015 | Sandy Tay | Tracey Casari, Bee Teng |
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