Submissions on behalf of Janet Loughman

SUBM.1019.005.0014
ROYAL COMMISSION INTO INSTITUTIONAL RESPONSES TO CHILD SEXUAL ABUSE
At Sydney
PUBLIC INQUIRY INTO
THE RESPONSE OF THE STATE TO COMPLAINTS MADE AND LITIGATION INSTITUTED BY
FORMER RESIDENTS OF BETHCAR CHILD'S HOME, BREWARRINA, NEW SOUTH WALES
SUBMISSION ON BEHALF OF JANET LOUGHMAN
PRINCIPAL SOLICITOR, WOMEN'S LEGAL SERVICES NSW
Introduction
1. The following submissions are made on the evidence heard during the Case Study
and findings are proposed in relation to:
2.
a.
the Department of Family and Community Services (and its predecessors)
b.
the Crown Solicitor's Office
c.
Mr Michael Cashion SC
d.
Mr Patrick Saidi
In addition, we propose that the evidence supports additional findings on several
systemic issues in civil litigation as they affect persons claiming aga inst the State of
NSW for damages for child sexual abuse. These include :
a.
the operation of the Model Litigant Policy;
b. the operation of the NSW Guiding Principles for Government Agencies
Responding to Civil Claims for Child Sexual Abuse; and
c.
the lack of clarity as to scope of the law.
The Department of Family and Community Services (and its predecessors)
3.
The plaintiffs in the Bethcar litigation had all been very disadvantaged chi ldren,
living in a remote community, where there were high levels of poverty and the
complex impacts of dispossession of Aboriginal people. They were chi ldren
considered to be some of the most economically and socially disadvantaged wit hin
the Australian community.
4.
In some instances the State had formed a view that their parents could not care for
them. In other instances, their own parents had in effect, given them up, as they
could not care for the children .
1
SUBM.1019.005.0015
5.
We refer to paragraphs 17 - 48 of Counsel Assisting's submission, which outlines
uncontested facts relating to the experience of the former residents of Bethcar and
of the Department and the Police after becoming aware of problems at Bethca r. The
uncontested evidence includes that:
a.
Jodie Moore, a former Bethcar resident gave evidence at the public hearing
that she felt let down by the system because YaCS officers that visited
Bethcar interviewed the resident children in the presence of the Gordons.
As a result Ms Moore felt that she and the other child ren we re unable t o tell
YaCS officers how they truly felt, what was going on at Bethcar, or that t he
Gordons were abusing them.
b.
1
Ms Jodie Moore gave evidence that a welfare officer from DoCS took her
and some other children from Bethcar to the police station where verba l
statements were taken by police, but that the children were returned to
Bethcar by the Docs officers, only to be beaten by Mr and Mrs Gordon. 2
c.
AIH gave evidence that no one came to check on her whilst she was at
Bethcar.
d.
3
Mr Terry Madden, the RDO of the Department at Brewarrina in 1980,
decided not to place any further children into the Bethcar Home "at this
stage". 4
e.
Ms Fishburn relieving RDO employed by the Department at Brewarrina also
said that she was "very concerned that the allegation of sexual abuse [in
respect of AIA) has not been followed up and more information gathered.5
f.
There was no evidence that the Department took any further action other
than putting the available evidence in the hands of the Police.
6.
6
The evidence also suggested that that had it not been for the Gordons, there wou ld
have been nowhere else for the children to go. Brewarrina is a small town in far
north western NSW. Evidence before the Commission was that Brewarrina is 'pretty
remote' and that Bethcar was nine miles out of town, and 'because of poor roads
1
Statement of Jodie Moore at paragraph 18; Transcript of J B Moore, T10075:42-47 (Day 96).
2
Statement of Jodie Moore at paragraph 17; Transcript of J B Moore, T10075:27-31(Day96).
3
Statement of AIH at paragraph 10; Transcript of AIH, T10090:25-27 (Day 96).
4
Exhibit 19-0012, Statement of Michael Coutts-Trotter, STAT.0369.002.0032 at page 2.
5
Exhibit 19-0001, NSW.0033.008.0437 _R.
6
Submissions of Counsel Assisting the Royal Commission at paragraphs 42 and 43.
2
SUBM.1019.005.0016
and flooding the place could be physically isolated for long periods of time'. 7 It was
considered significant that the children were able to be placed with Aborigina l
8
carers.
7.
Detective Inspector Peter Yeoman's gave evidence that 'It's very easy in 2014 to say
what they should have done, however something should have been done on the day
not to return those children. Out of all the things that could have been done,
including interviews, going back and getting some corroborative evidence, all of
those things, the children should not have been returned.' 9
8.
Mr Menzies SC, counsel for the State of NSW, in questioning Peter Yeomans put to
him: 'But not the least of the problems in that physical environment is what you do
with 30 children in this remote area that you're concerned about.' Also suggesting
that it could have been 'any of those physical limitations' affecting the State's
10
response .
9.
It is submitted that remoteness and isolation should be factors to be overcome in
providing an effective response to children at risk, not an excuse by the State for not
being able to.
10. Available finding: that the Department failed to take action to properly supervise
and monitor the placement of the children at Bethcar.
11. Available finding: that the State of NSW (Police and the Department) failed to take
action in response to reports of child sexual abuse at Bethcar in March 1980, and
again in 1983 and 1984 by not properly investigating the allegations, by returning
the children to Beth car and by failing to provide a safe alternative placement.
The Department's Approach to the Civil litigation
12. The evidence a pattern of abuse by the Gordons and Colin Gibson that was extensive
and spanned many years. So much would have been apparent from the Statements
of Claim, material and information that was in the knowledge of the Depart ment
and
I
or obtained by the Crown Solicitors Office (including evidence of the Po lice
complaints, from the trial of Colin Gibson) and from the particu lars provided in the
litigation .
7
Transcript of P Yeomans, T10540: 1-6 (Day 100)
8
Exhibit 19-0001, NPF.051.001.0038_R.
9
Transcript of P Yeomans, T10541: 18-23 (Day 100)
10
Transcript of P Yeomans, T10540: 25-35 (Day 100)
3
SUBM.1019.005.0017
13. The evidence showed that for many years the State did not acknowledge and accept
that the pattern of abuse suggested the possibility of a serious and extensive fai lure
by the State.
14. If the possibility of a serious and extensive failure by the State had been considered
at the outset, it may have influenced the State and its advisors to adopt a less
oppositional approach in the litigation. What the evidence shows, is that both the
Department and the CSO failed for a very long time to realise the magnitude of the
abuse that had occurred at Bethcar.11 It is submitted that this was a key failure that
in turn led to the adoption of an approach to the lit igation that was insensitive and
further injurious to the plaintiffs.12 It is difficult, otherwise, to comprehend how the
State and the CSO were able to approach the civil litigation with the degree of
antipathy adopted, particularly when the State through the Department was then
and remains responsible for acting to protect children at risk.
15. Available finding: in its conduct of the defence of the Bethcar litigation, the
Department failed to act properly, fairly and in accordance with the highest
professional standards, in breach of clause 3.1 of the Model Litigant Policy.
Crown Solicitor's Office
Raising of the Batistatos issue
16. We supplement paragraphs 173 to 195 of Counsel Assisting' s submissions with the
following submissions.
17. Paragraph 174 of Counsel Assisting's submissions note that Ms Jodie Vella raised the
Batistatos issue with Mr Paul Arblaster in September 2011.13 However, evidence
before the Commission demonstrates that as early as June 2009 the CSO already
14
had within its knowledge the Batistatos issue.
18. Despite the Batistatos issue being within the CSO's contemplation over the course of
three and a half years before the hearing of Ms Kath leen Biles' limitation motion on
20 February 2012, the CSO only filed the Department's appl ication based on t he
Batistatos issue ('the strike out application') two and a half weeks before the
11
Transcript of M P Coutts-Trotter, T10300:23-38 (Day 98).
12
Transcript of M P Coutts-Trotter, T10300:46-T10301:2 (Day 98).
13
Exhibit 19-0011, Annexure to HA-1, STAT.0370.003.0167_ R.
14
Exhibit 19-0001, NSW.COMS.544.001.1520.
4
SUBM.1019.005.0018
hearing of the limitation motion, and despite opposition from the plaintiff.
15
The
plaintiffs' opposition was dismissed by the CSO as being 'frivolous', 1 6 and it pressed
the District Court to make orders that the strike out application be heard as a
preliminary matter to the limitations motion on 20 February 2012.
19. We argue that the CSO's delay in raising the Batistatos issue and its advice to the
Department to force the Plaintiff to respond to the strike out application with two
and a half weeks notice was a breach of clauses 3.1 and 3.2(a) of the Model Litigant
Policy.
20. Available finding: that the CSO's delay in raising the Batistatos issue and its advice to
the Department to force the Plaintiff to respond to the strike out application with
two and a half weeks notice was a breach of clauses 3.1 and 3.2(a) of the Model
Litigant Policy.
CSO Approach to the Civil Litigation
21. Taking into account the evidence before the Commission of the CSO's conduct in
representing the Department and its conduct of the litigation, we submit that a
review of all the evidence establishes that the CSO failed to act 'properly, fairly and
in accordance with the highest professional standards'.
17
Mr IV Knight gave evidence
that the CSO staff did not have experience in or know about particu lar features one
would expect to encounter in child sex abuse litigation. 18
22. However, the CSO advised and represented the Department both in its exercise of
its statutory child protection responsibilities to protect children at risk as well as in
litigation against the Department. 19' The CSO had at its disposal resou rces that
would have allowed it to train staff about child sexual abuse, its effects and risks for
the victims in litigation:for e.g. the longstanding sequelae of child sexua l abuse, that
a delayed failure to report was common, of the risks of further trauma through retelling abuse and the concern about not being believed.
23. We reiterate the issues in paragraph 12-14 of these Submissions and submit t hat the
matters raised also apply to the staff of the CSO.
15
Exhi bit 19-0001, NSW.2001.004.5113_R.
16
Exhi bit 19-0011, Annexure to HA-1, STAT.0370.003.0185_R.
17
Model Litigant Policy, clause 3.1
18
Transcript of I V Knight, T10622:24 ff {Day 101)
19
Transcript of H Allison, T10201:36-T10202:16 {Day 97).
5
SUBM.1019.005.0019
24. Available finding: In its conduct of the defence of the Bethcar litigation, the CSO
failed to act properly, fairly and in accordance with the highest professional
standards, in breach of clause 3.1 of the Mode l Litigant Pol icy.
Mr Michael Cashion SC
25 . We comment on Counsel Assisting's Submissions in relation to Mr Michael Cashion
SC at pa ragraphs 335 to 338.
26 . With reference to paragraph 336 of Counsel Assisting's submissions, we submit that
Mr Cashion SC's conduct in not making further enquiries between 10 and 14
February 2012 as to the content of the 'other relevant information which was not
disclosed in the affidavits' 20 amounted to a fa il ure of his professional responsibility,
particularly in the context of preparing to lead the running of the Batistatos strike
out application where the Defendant proposed to say that the effluxion of time and
the deterioration of evidence because of a lack of available witnesses meant that
the Defendant was irremediably prejudiced.
27. In his evidence, Mr Cashion SC did not accept that in a legal team made up of
instructing solicitors, junior and senior counsel, responsibility ultimately fell on
senior counsel.
21
28 . Whilst Mr Cashion SC accepted that he should be responsible for what he himself
put to the court,
22
he denied acting in an improper or inappropriate manner by
failing to inform the court of the existence of relevant information because he did
not do so knowingly or deliberately.
23
29. Mr Cashion's evidence was that when he prepared the advice in relation to running
an application based on the Batistatos issue ('the advice' ) he had not yet done a
24
detailed analysis of the evidence put forward by the State.
His recollection was
that the advice was in relation to 'the prudence or the wisdom of running the
Batistatos application at the same time as the Limitation Act application' 25 rather
than an advice on prospects of success because he otherwise conceded, the advice
20
Submissions of Counsel Assisting the Royal Commission at paragraph 336.
21
Transcript of M Cashion, T10799:19-21(Day103).
22
Transcript of M Cashion, T10799:23-29 (Day 103).
23
Transcript of M Cashion, T10799:37-40 and T10800:12-13 (Day 103).
24
Transcript of M Cashion, T10788:17-26 (Day 103).
25
Transcript of M Cashion, T10788 :37-38 (Day 103).
6
SUBM.1019.005.0020
would have 'involved a far greater analysis of the relevant evidence and the relevant
law'.26
30 . His evidence is not readily reconciled w ith the advice signed by him on 1 February
2012. It is submitted that it is plain that he did provide an advice on prospects of
success. Mr Cashion SC said that although he was not the author of the advice, he
signed it anyway; he also conceded responsibi lity for the contents therein . 27
31. Mr Cashion conceded that at the time of drafting the advice he had turned his mind
to 'the relevant principles in Batistatos, what it was about, that [the State] needed
evidence of prejudice and that the evidence of prejudice would be the same as the
evidence of prejudice in response to the application by the plaintiff for an extension
of the /imitation period' 28 • His evidence was also that at the time of drafting the
advice he did not know 'whether [he] understood there to be information which Mr
Maxwell had obtained and which was not disclosed' 29•
32 . The CSO and the Department were seeking his advice as to appropriateness of the
application and its likelihood of success and Mr Cashion SC was the most senior legal
practitioner advising the State on its conduct in opposing to the extension of time
application .
33. Available finding: that Mr Cashion ought not to have advised the Department to
bring the Batistatos application or advised on the prospects of success of any such
application until he had taken steps to enquire about the nature of the other
information that Mr Maxwell had obtained but not referred to in his fi rst two
affidavits.
Mr Patrick Saidi
34. We refer to paragraphs 90 to 92 and 235 to 247 of Counsel Assisting's submissions
in relation to a lengthy request for particulars issued by the CSO to Bell & Johnson
(and later WLS NSW}. The request is described as intrusive and oppressive; seeking
information that was within the knowledge of the Department.30
26
Transcript of M Cashion, T10788:32-35 (Day 103).
27
Transcript of M Cashion, T10790:30-32 (Day 103).
28
Transcript of M Cashion, T10793 :14-19 (Day 103).
29
Transcript of M Cashion, T10793 :37-39 (Day 103).
30
Submissions of Counsel Assisting the Royal Commission at paragraph 92.
7
SUBM.1019.005.0021
35. Mr Saidi gave evidence that he settled the request for particulars. 31
36. Mr Michael Coutts-Trotter, Secretary of the Department, and Mr Ian Knight, Crown
Solicitor gave evidence that these requests for particulars breached clause 3.2(a) of
the Model litigant Policy. In submissions, Counsel Assisting recommended that a
finding that the CSO and the Department breached clause 3.2(a) of the Model
Litigant Policy be accepted. 32
37. It is submitted that in participating in the drafting and settling of the requests for
particulars,33 Mr Saidi breached clause 3.2(a) of the Model Litigant Policy.
38. Available finding: that by drafting and settling the requests for particu lars Mr Saidi
breached clause 3.2(a) of the Model Litigant Policy.
Operation of the Model Litigant Policy
39. Whether the Department and the CSO conducted the litigation in accordance with
the NSW government Model Litigant Policy was the subject of inquiry during the
hearing. We refer to the summary of evidence and available findings submitted by
Counsel Assisting and make further submissions in relation to the operation of the
Model Litigant Policy.
40. The Model Litigant Policy was approved for adoption by all government agencies on
8 July 2008. The CEO of government agencies has primary responsibility for
compliance with the policy. There is a requirement for lawyers, including private
counsel, to be made aware of the policy. It is submitted that this infers a
responsibility on counsel briefed by the State to comply with the policy in the
formulation of advice and strategy in litigation.
41. Under the Model Litigant Policy, government agencies are required to:
•
•
•
•
•
•
34
Deal with claims promptly
Not take advantage of a claimant who lacks the resources to litigate a
legitimate claim
Pay legitimate claims
Avoid litigation
Keep costs to a minimum, and
Apologise where the State has acted inappropriately.
31
Transcript of P J Saidi, T10572:12-23 (Day 101).
32
Submissions of Counsel Assisting the Royal Commission at paragraphs 245 and 247.
33
Submissions of Counsel Assisting the Royal Commission at paragraph 92.
34
Exhibit 19-0012, Statement of Michael Coutts-Trotter, STAT.0369.002.0128.
8
SUBM.1019.005.0022
42. It is submitted that the Department, the CSO, and the counsel briefed failed to
comply with the spirit of the Model litigant Policy as well as particu lar breaches as
submitted by Counsel Assisting and at paragraphs 15, 24 and 38 herein. Furt her
submissions are made below in relation to strengthening the effectiveness of t he
policy.
43. We refer to Mr Knight's evidence of the CSO's understanding of the operation of the
Model litigant Policy; notably Mr Knight's evidence of what is the meaning of 'fair'.
35
44. We argue that any Model litigant Policy needs to be clea rl y expressed and
understood. Where concepts such as fairness have the potential to be ambiguous,
we argue that it is all the more incumbent on government agency leaders to
facilitate open and frank discussion of what is fair. There needs to be clear
guidelines and understanding within and amongst government agencies as to the
everyday application of the Model litigant Policy in order to achieve its aim of
maintaining proper standards in litigation and the provision of lega l services in NSW.
45. Evidence was given during the hearing that CSO solicitors are not requ ired to advise
their clients on whether they consider actions taken in litigation comply w ith t he
Model litigant Policy because 'agencies are quite aware of the model litigant
policy'36 and that advice about the Model litigant Policy is only given when it
appears that '[we] are getting instructions that are non-compliant with the Model
Litigant Policy' or 'if we think and understand for example that Counsel is doing
something that is not in accordance with the Model Litigant Policy.'
37
'We do not
routinely sit down and provide advices on the model litigant policy. ' 38
46. The totality of the evidence given, including the evidence of Ms Allison and the
concessions made by Mr Knight and Mr Coutts Trotter as to breaches of t he Model
litigant Policy,
39
indicate that it is not sufficient to assume that mere knowledge of
the existence of the Model litigant Policy will lead to proper application of t he
Policy, ensuring that it is effective. It is our submission that those employed by t he
CSO and other government agencies should be required to document t heir
35
Transcript of IV Knight, T10643:37-10645:37 (Day 101).
36
Transcript of H Allison, T10293:40-10293 :45 (Day 98).
37
38
Transcript of H Allison, T10293:40-10294:37 (Day 98).
Transcript of H Allison, T10294:10-11(Day98).
39
Transcript of H Allison, T10279:29-10284:35 (Day 98); Transcript of M P Coutts-Trotter, T10322:4710326:33 (Day 98); and Transcript of IV Knight, T10647:18-10650:39 (Day 101).
9
SUBM.1019.005.0023
consideration of the requirements of the Model Litigant Policy when advising on
strategy or significant steps in the litigation.
47. Counsel briefed to advise a body bound by the Model Litigant Policy shou ld be
required to consider the terms of the Model Litigant Policy and document their
consideration of the requirements, in advising on strategy and significant steps to be
taken in the litigation, rather than assume that 'it was a given that the Crown
Solicitor's Office would act as a model litigant.Ao_
48. Available finding: There needs to be a positive duty on government agencies and
their legal advisors/representatives to turn their minds to whether action taken or
advice given is in accordance with the Model Litigant Policy. Consideration should be
given to requiring a declaration similar to that required by an expert witness
pursuant to r 31.23(3) of the UCPR, suitable for the provision of advice. This could
also apply in relevant circumstances to the Guiding Principles for Government
Agencies Responding to Civil Claims for Child Sexual Abuse (see further comment
below at paragraphs 54 to 59).
49. Evidence was given before the Commission that comments made by judicia l officers
about whether the Model Litigant Policy was being adhered to or not, were not
reported back to senior staff at the CS0.
41
50. Available finding: The Model Litigant Policy should be amended to explicitly require
that comments by judicial officers on whether the Model Litigant Policy was being
considered in an approach taken before the Court be reported to the Crown Solicitor
and client agency.
51. Plaintiff lawyers are bound by professional conduct rules, which prohibit direct
contact with a represented 'other party' in litigation, and are not able to raise their
concerns about compliance with the Model Litigant Policy directly with the relevant
CEO of a government agency party in litigation.
52. For a litigant with significant resources such as the State, it is not sufficient for cost
orders to be the consequence of breaching the Model Litigant Policy. Mechanisms
that put greater weight on preventing breaches rather than remedying noncompliance after the event will have a much stronger protective factor for
vulnerable and disadvantage plaintiffs.
40
Transcript of P J Saidi, T10547:10-10548:11(Day100).
41
Transcript of IV Knight, T10648:42-10650:11(Day101).
10
SUBM.1019.005.0024
53. Available finding: That consideration be given to a mechanism or mechanisms to
strengthen the status of the Model Litigant Policy. For example, this could be
through legislation, the Australian Solicitor Conduct Rules, or Barristers Rules.
Operation of the NSW Guiding Principles for Government Agencies
Responding to Civil Claims for Child Sexual Abuse
54. We refer to paragraph 371 of Counsel Assisting's submissions in relation to the NSW
Government Guiding Principles for Government Agencies Responding to Civil Claims
for Child Sexual Abuse ('Guiding Principles') tabled on the last day of the public
hearing.
55. We wish to acknowledge the speed with which the NSW Government responded to
the issues raised in the public hearing.
56. It is hopeful that the policy changes brought by the new Guiding Principles in
conjunction with the Model Litigant Policy will bring about meaningfu l change for
victims of child sexual abuse bringing civil claims against the State.
57. However, we note that both the Model Litigant Policy and the Guiding Principles are
not enforceable . This is problematic because, as evidenced at the public hearing,
plaintiffs have little recourse if the State or its agencies breach the Model Litigant
Policy. It was the experience of the plaintiffs in the Bethcar litigation that where it
was raised with the State that the Model Litigant Policy was not being adhered to,
no adequate response was forthcoming.
58. It is submitted that the comments and recommendations made above in relation t o
the Model Litigant Policy are also relevant to the application of the Guiding
Principles.
59. In addition, we provide further comment on the Limitation defence. We submit that
consideration should be given to legislative change to abolish a limitation period for
civil actions in child sexual abuse cases. We argue that there should be no
exceptions to pleading the limitation defence in child sexual abuse cases. There are
other defences open to defendants e.g. abuse of process which would balance t he
interests of both parties. We emphasise that this would not be about taking away a
defendant's right to mount a defence, but to act in such a way that is truly
consistent with the Model Litigant Policy and the Guiding Principles.
11
SUBM.1019.005.0025
Difficulties for Plaintiffs at Common Law in Articulating Duty of Care
60. The evidence shows that the State and its advisors held views that the ir potential
liability at law to the former residents of Bethcar depended on the means by which
42
the children came to reside at Bethcar;
their legal status as wards of the state or
otherwise; and the nature of funding and licensing.
43
This high lights the difficu lties
pla intiffs face in bringing common law claims fo r damages for historical sexual abuse
(and also likely for more recent abuse).
61. A significant barrier for the Plaintiffs in the Bethcar civil litigation was the difficulty
faced in establishing and articulating the duty of care owed by the Defendant -
44
i.e.
the duty of care owed by a government body to children of a children's home,
where the government body has supervisory/funding oversight.
45
Th is difficulty
arises because the precise duty of care owed by the State is often difficult to discern
from the authorities on the law of negligence as it applies to the State.
62. Whilst it is beyond the scope of these subm issions to explore the adequacy of the
law, in order for victims to be more readily able to access damages for injury arising
from child sexual abuse, there needs be some clearer articulation of the
circumstances in which such claims can be advanced. The problem is of course
circular:
it is expensive and difficult for the plaintiffs to advance claims, and
therefore few cases reach the Courts and accordingly the law on when such claims
can succeed is difficult to clearly discern and define; and because the law is unclear
and difficult to discern and define, it is in turn difficult and expensive for claims to be
advanced .
63. Plaintiffs who have suffered injury as a result of abuse after being taken into care by
the State are let down by the failure of the law, either the common law or by the
failure of Parliament to establish enforceable statutory duties.
64 . It is submitted that consideration be given to recommending that statutory duties
be enunciated to give clarity to the circumstances in which a 'breach of duty of care'
can arise for children taken into care by the State .
42
Transcript of H Allison, T10288:8-17 (Day 98); Transcript of M P Coutts-Trotter, T10316:9-37 (Day
98); and Transcript of M P Coutts-Trotter, T10327:41-10328:4 (Day 98).
43
Transcript of H Allison, T10257:37-10258:23 (Day 98); and Transcript of IV Knight, T10628:3-8 (Day
101).
44
45
Transcript of J Loughman, T10158 :38-10160:37, T10161 :38 (Day 97).
Transcript of H Allison, T10215:15-16 (Day 97).
12
SUBM.1019.005.0026
Redress scheme
65. Redress schemes can work alongside the civil litigation path.
66. Civil litigation has a role to play not just in providing an individual remedy but also in
identifying systemic failures and in keeping agencies accountable.
67 . It is our submission that one should not operate to the exclusion of the other and
that a redress option is particularly important because civil litigation is beyond the
financial reach of many plaintiffs.
Maria {jerace
Maria Gerace
Maurice Byers Chambers
T: (02) 8233 0300
F: (02) 8233 0333
E: [email protected]
16 December 2014
13