The team have been shortlisted for the Family team of the year award at the Solicitor’s Journal annual awards.

The awards recognise excellence in the Legal community and we are thrilled to have made the shortlist. Our award submission is around the fixed fee scheme which we have set up to focus the client at the centre of everything that we do.

The awards ceremony will be on 17 May in London when we will find out who the winner is.

* Disclaimer: The information on the Anthony Gold website is for general information only and reflects the position at the date of publication. It does not constitute legal advice and should not be treated as such. It is provided without any representations or warranties, express or implied.*

 

On Friday the 24 March 2017, the Court of Appeal, which included the President of the family court, refused the appeal of Mrs Tini Owens against the refusal of His Honour Judge Tolson, to grant the wife a divorce.  The decision of the trial Judge was that even though he found that the marriage had broken down and the prospects of reconciliation hopeless, he nonetheless did not find that the wife had proved the allegations in her unreasonable behaviour petition.

The task for the Court of Appeal was to consider whether or not the Judge was “wrong” in coming to this conclusion on the facts and therefore, the Court of Appeal entitled to interfere with the trial Judge’s decision pursuant to CPR 52.11(3)(a).

The facts of the case are, in many ways, unremarkable.  It was a long marriage with grown up children.  They were not getting on. The wife sought a divorce on the basis of unreasonable behaviour and the allegations included that :-

• The husband prioritised work over family life, often missing family holidays and family events;
• The husband had not provided the wife with love, attention or affection and she felt unsupported;
• The husband suffered from mood swings which caused frequent arguments which were distressing and hurtful;
• The husband had been unpleasant and disparaging about the wife, her family and friends;

A very typical divorce set of particulars designed not to paint the husband as a despicable rogue but still setting out the unhappiness and sadness that the wife was experiencing.

In many cases, respondents receiving such a petition would simply shrug their shoulders, return the acknowledgement of service form indication they are not defending the divorce but write a side letter to the Judge saying the petitioner was just as unreasonable.  However, Mr Owens decided to defend the case.  The wife amended her petition to beef up the particulars.  In statements and oral evidence at trial, there were various incidences cited at airports,  restaurants and pubs.

In law a petitioner can obtain a divorce if they can show that their marriage has “broken down irretrievably”.  Section 1 of the Matrimonial Causes Act 1973 allows a petitioner to prove this in one of only five ways – known as “the five facts” – one of which under Section 1(2)(b) “that the respondent’s has behaved in such a way that the petitioner cannot reasonably be expected to live with the respondent”.  Sub-section (3) imposes a duty on the Court “to enquire, so far as it reasonably can, into the facts alleged by the petitioner”.  It rarely does. There is no need as 99% of divorces are uncontested.

The Court must make findings of fact as to whether the instances of unreasonable behaviour occurred but also what impact that conduct had on the petitioner.  The test of what is unreasonable behaviour is set out in Rayden, the divorce bible text, which the Court of Appeal approved is  “it has been said that the correct test to be applied is whether a right thinking person, looking at that particular husband and wife or civil partners, would ask whether the one could reasonably be expected to live with the other taking into account all circumstances of the case and the respective characters and personalities of the two parties concerned”.  As Hallett LJ apparently said during the course of arguments at the appeal hearing, “what may be regarded as trivial disagreements in a happy marriage could be salt in the wound in an unhappy marriage”. As relationships go on, people’s behaviour does not necessarily change but the perception of it can.  A husband can at the beginning of a relationship “love her infectious giggling” but in a deteriorating relationship, this becomes “an irritating laugh”.  What starts as “Oh darling you are so funny when you are a little tipsy” becomes “an irritating drunk”.

A good working example of how the test has a subjective element is the case that I conducted many years ago.  I acted for a husband who received an unreasonable behaviour petition which was based exclusively on golf:-

1. He played too much golf;
2. He talked about golf too much;
3. He socialised with people who played golf a lot;
4. He spent too much money on golf.

It was abundantly clear, and the husband accepted that his wife had no interest in golf and found his obsession with it unsatisfying.  On the other hand, my client was absolutely delighted that his life had been encapsulated in this way.  He had shown the petition to various of his golf friends who all roundly agreed that he was “THE IDEAL HUSBAND”.  What is unreasonable behaviour to one may not be to another.  That divorce, however, concluded smartly and for all I know, the husband is still hacking his way round golf courses in Essex and the wife has never heard talk of the little white ball since.

Almost hilariously and certainly ironically, the Court of Appeal heard the wife’s appeal on St Valentine’s day, 14 February 2017.  The President, in a wonderful section of the judgment discusses the extent to which the Court has the ability to bring law up to date.  He says “so in my judgment … the words “cannot be reasonably expected” that objective test has to be addressed by reference to the standards of the reasonable man or woman on the Clapham omnibus; not the man on the horse drawn omnibus in Victorian times which Lord Bowden would have had in mind … not the man or woman on the route master clutching their paper bus ticket on the day in October 1969 when the 1969 Act received the royal assent but the man or woman on the Boris bus with their Oyster card in 2017”.  The Court went on to consider the judgment of Judge Tolson in which he described the wife’s petition as “hopeless” “anodyne” “scraping the barrel” and “lacked beef”.

The Appeal grounds and decision

Mrs Owens’ grounds for appeal were in broad summary the trial Judge:-

1. failed to make essential findings in respect of the pleaded allegations
2. failed to undertake a proper assessment of the wife’s subjected characteristics
3. failed to take an assessment of the cumulative impact her husband’s behaviour had on the wife
4. failed to apply the law properly to the facts
5. failed to take into account the wife’s Article 8 and Article 12 rights under the European Convention.

The President outlined what the function of the Court of Appeal was in assessing the trial Judge’s judgment.  He confirmed that the trial judge is in the best position to consider the case, having read the file, the court bundle and the evidence of the parties under cross-examination.  The Appeal Court rejected the idea that the Judge was “plainly wrong”.  The Appeal Court rejected the proposition that the trial Judge was right to direct that the case focus on a selection of the allegations after having asked Mr Philip Marshall QC, who led for the wife, to kick his best/worst allegations to be examined in detail.  The Judge could not be criticised for finding the facts as he did, both in terms the extent to which the incidents of unreasonable behaviour were proven, but also the effect that it had upon the wife nor indeed, the cumulative impact upon the wife.  The Human Rights’ point was also rejected on the basis that there was no convention right to be divorced. The appeal fails and Mrs Owens has the sympathy of the Court of Appeal but not the divorce she desires.

The paragraphs dealing with the reason reasons for rejecting the appeal are short and perhaps underline that this appeal never really had any prospects of success once the Judge had made the findings that he had.  The judgment gives more space to the prospect of the law changing.  The President goes through the history of divorce law since the Divorce Reform Act 1969 which was then re-enacted in the Matrimonial Causes Act 1973.  This remains the legislation that governs divorce and is out of date.

The President reflects on the unsatisfactory position regarding allegations of unreasonable behaviour and quotes Resolution’s 2016 Guide to Good Practice on Correspondence in which a petitioner solicitor writes to a prospective respondent and invites the prospective respondent to, in effect, co-operate in the drafting of allegations of unreasonable behaviour.  Indeed, Resolution’s new code of practice emphasises that members are to “reduce or manage any conflict and confrontation; for example, by not using inflammatory language”.

It is unfortunate that the trial Judge is so critical of the wife in her approach.  There is a risk that following the Owens case, that lawyers will feel obliged to advise their clients to make stronger and more challenging allegations in the petition.  Resolution lawyers frequently, at present, encourage petitioners not to put in every allegation and not to put in the most serious allegations because experience shows that doing so, adversely affects the way the case is conducted in the future.  This is especially relevant in cases where there are children issues.  If the allegations in the divorce petition raise the temperature of the arguments between a separating couple, then that adversely affects the parties and particularly the children.  It is an unsatisfactory state of affairs.  But before family lawyers start drafting particulars in a more forthright way they should remember that the petition failed not because the words used in the petition were not enough, it was because the judge decided that Mrs Owens did not have any evidence of substance to support the allegations.

What is the way forward for Mrs Owens?

Her petition for unreasonable behaviour was filed on the 6 May 2015 and the judge dismissed the wife’s unreasonable behaviour petition. One might hope that the husband might agree to a divorce based on 2 year’s separation with consent.  The wife contends that the parties have been living separate lives for some years now.  If Mr Owens refuses to give his consent then unless parliament changes the law, Mrs Owens will have to present a fresh petition but not until they have been separated for a full 5 years.  One cannot begin to imagine the disappointment and sadness that she must feel, not least with the expense the case must have taken but also what an earth the point is in this marriage continuing.

Resolution for change

All the time that Mrs Owens is battling for a divorce in the Family Court, Resolution, throughout the same timeline, has been campaigning for “no fault” divorce.  It is a fundamental plank of their current objectives.  Resolution has arranged all party events at Parliament setting out the considerable disadvantages of “fault” divorce, unreasonable behaviour and adultery. Further, the advantages to separating couples, the Courts and the Government’s budget of a “no fault” divorce.  Resolution has compared and contrasted how other countries deal with divorce and have shown that in countries that have “no fault” divorce, their divorce rate is no higher than that in the UK. Moreover, the process more civilised and straightforward.  Introducing “no fault” divorce will not mean that the parties do not continue t0 have differences over finances and the arrangements for the children, but what will happen is that unnecessary flammable liquid will not be poured onto already smoking fires.  The issue will be debated no doubt at Resolution’s forthcoming annual conference in Birmingham on the 31^st of March and 1^st of April.

What, might one think in this case is that there has been an awful lot of investigation spent in relation to instances of both the wife’s and the husband’s behaviour and incidents that have taken place in their marriage.  Nonetheless, the wife is absolutely clear she wants to end the marriage and live separately.  She has pursued this case for a number of years in order to achieve a divorce.  What useful purpose for the Courts and, indeed, for the State, that couples should remain together when one does not want to after a reasonable period of reflection.  If, after a period of months, it is clear to one party that they want to end the marriage, how does it serve that couple or society as a whole to keep them married?

The momentum for reform is in fact bolstered by the Court of Appeal’s rejection of Mrs Owens’s petition for divorce.  The case highlights the difficulties that parties can face when a divorce is contested.  There is now cross-party support for “no fault” divorce.  What remains is for the Government to find both the will and the time to submit to pass what would be fairly simple and straightforward legislation.

* Disclaimer: The information on the Anthony Gold website is for general information only and reflects the position at the date of publication. It does not constitute legal advice and should not be treated as such. It is provided without any representations or warranties, express or implied.*

I must confess that one of my guilty pleasures is Coronation Street and the ongoing Leanne/Steve/Nick/Michelle baby storyline has well and truly erupted over the last week.

To briefly summarise the background (which, unsurprisingly for a soap, is messy and complicated), Steve is married to Michelle. Steve and Michelle temporarily split last year and during this time Steve spent the night with Leanne. Steve subsequently reconciled with Michelle and Leanne reconciled with and became engaged to her childhood sweetheart, Nick. Leanne and Steve kept what had happened between them a secret. However, Leanne unexpectedly became pregnant and so she told Nick the truth. Leanne and Nick had always wanted a child and so suggested to Steve that they bring up the baby, with Steve having no involvement. Steve agreed, as by this time Michelle had also become pregnant and he believed that his marriage would be over if she discovered the truth. Tragically, Michelle’s baby son was stillborn a few weeks before Leanne gave birth to a healthy baby, Oliver. On meeting baby Oliver Steve could not keep the secret any longer and in true Coronation Street style announced in a restaurant full of people that he is the father.

This has brought to the surface a number of practical and legal problems. Michelle is understandably furious with Steve. She wants to divorce him and retain control of The Rovers Return, the pub they run together. Nick wants Leanne to agree to formalise his role in Oliver’s life on the basis that he sees him as his own son and this was what they all agreed. Steve wants access to Oliver and for his own parental rights to be recognised. Amidst the drama, this week’s episodes contained some serious yet common legal misconceptions and myths that I think need to be cleared up.

1.  Leanne – “when I marry Nick he will have Parental Responsibility for Oliver”.

This is not true. Nick will not automatically obtain Parental Responsibility for Oliver by marrying Leanne. He can only obtain it with Leanne’s explicit consent by Leanne entering into a Parental Responsibility Agreement with Nick.

(NB if Leanne were to register Steve on Oliver’s birth certificate, Steve would have Parental Responsibility and Nick would need the consent of Steve as well as Leanne to obtain Parental Responsibility for himself. It is possible for more than two people to have Parental Responsibility for a child and granting Parental Responsibility to a third person would not remove Parental Responsibility from anyone else who already has it.)

Once Nick and Leanne are married Nick could apply to court for a Parental Responsibility Order in his capacity as Oliver’s step parent.

When making any decisions the court would consider the best interests of Oliver to be the priority, rather than the “rights” of any of the adults involved

For more about Parental Responsibility, click here.

2.  Michelle’s solicitor to Steve – “you have committed adultery with Leanne. You cannot contest the divorce.”

This is also not true. If a divorce petition is based on adultery the respondent (Steve) would need to sign a formal confession statement within the divorce proceedings in order for the proceedings to go ahead undefended. If Steve refuses to sign the confession statement the divorce would become defended and the court would list an oral hearing to deal with the matter. This would come at huge cost for Michelle and Steve, both emotionally and financially.

An alternative would be for Michelle to petition Steve for divorce on the basis of his unreasonable behaviour. Although Steve would still need to confirm his agreement to the divorce going ahead undefended, there would be no requirement for him to formally admit and confess to the allegations of behaviour in the same way that he would be required to formally admit and confess to his adultery. For that reason many people choose to petition on the basis of behaviour rather than adultery, even where adultery is the main reason for the marriage breaking down.

For more about unreasonable behaviour and divorce, click here.

3.  Michelle’s solicitor to Michelle – “Steve is the sole legal owner of The Rovers Return. You don’t have a financial stake in the business.”

No. All assets and liabilities, whether jointly owned or held in sole names, are taken into consideration on divorce so as to try and achieve a fair financial outcome. It often does not matter whose name an asset is held in, particularly if the marriage is a lengthy one. It may be that Steve could keep the pub, but if he does it is likely that he would need to make significant provision for Michelle from his other assets.

4.  Michelle’s solicitor visited Steve and made proposals for a financial settlement on divorce without considering disclosure and without giving Steve the opportunity to seek independent legal advice.

This would be very bad practice on the solicitor’s part and, should an agreement be reached, could give rise to a subsequent application by Steve to “set aside” the agreement on the basis that he was put under pressure to enter into it. Both parties in a divorce should be given reasonable opportunity to seek independent legal advice.

Further, an agreement should not be entered into without mutual exchange of full and frank financial disclosure. This is a statement completed by each party setting out their assets, liabilities and any other relevant matters, together with supporting evidence. Exchange of disclosure is crucial as it enables the parties and their legal representatives to have a clear, accurate and comprehensive picture of the financial circumstances before deciding on an appropriate way for the finances to be split.

Our specialist Family Law team at Anthony Gold have expertise in all matters arising from divorce and separation, including resolving financial issues and arrangements for children. If you are experiencing difficulties and wish to discuss your options please contact us on 0207 940 4000

* Disclaimer: The information on the Anthony Gold website is for general information only and reflects the position at the date of publication. It does not constitute legal advice and should not be treated as such. It is provided without any representations or warranties, express or implied.*

Kim Beatson and the Family team offer advice on what to do if your relationship breaks down. DIVA magazine is Europe’s only lesbian magazine which offers gay women monthly information and inspiration. Click the PDF link on the right hand side to read the article.

* Disclaimer: The information on the Anthony Gold website is for general information only and reflects the position at the date of publication. It does not constitute legal advice and should not be treated as such. It is provided without any representations or warranties, express or implied.*

Relationship Breakdown and Divorce

This is an emotional experience and it is particularly important to choose a legal framework which makes the experience less painful and costly.

It is therefore worth exploring the different process options that may pave the way for a speedy and more amicable outcome and one that keeps the family out of the court arena.

These can be framed as follows:-

1. Mediation
   Family mediators are specially trained.  They usually meet with the couple together and assist them in making arrangements around parenting and finance.
2. Collaborative Practice
   Each party instructs a trained collaborative lawyer who works with other professionals (financial and family support professionals) to support the couple through the separation process.  Two lawyers are involved but the lawyers work side by side.  All parties agree to work together outside the court process.
3. Arbitration
   The couple appoint a family arbitrator (possibly a retired judge or a very experienced member of the legal profession) who makes a binding decision on parenting or financial issues.  The arbitrator is chosen with assistance from legal advisors. The experience is bespoke and it is much quicker than using the court process.
4. Negotiating Through Lawyers
   Here your own family lawyer focusses on your interest and negotiates with your partner’s lawyer.  In the absence of a negotiated outcome, the lawyer may suggest making an application to court, hiring a private judge or family arbitration.

You can, of course, represent yourself and many people do.  There is lots of information online and if you would like to talk through your options we offer a fixed fee scheme which can help you understand what your next steps are, please click here.

Kim Beatson is a specialist family lawyer, a mediator and a collaborative lawyer.  Her email address is Kim.beatson@anthonygold.co.uk.  Telephone:  020 7940 4000.

* Disclaimer: The information on the Anthony Gold website is for general information only and reflects the position at the date of publication. It does not constitute legal advice and should not be treated as such. It is provided without any representations or warranties, express or implied.*

Consideration of what will happen in case of death or loss of capacity by a director should be part of a standard process when setting up a company.

A director is a company officer,  but also normally an employee of the company.   As directorship is a personal office, it cannot be delegated to an attorney.  Hence, even a validly executed and registered LPA does not give the attorney the power to step into the shoes of the director, either as an officer or as an employee.

What happens therefore in case a director loses capacity?

One needs to consider the Articles of Association of the particular company.  In this article I will focus on companies using the model articles for modern companies, prescribed by the Companies Act 2006.  If a company is using bespoke Articles or model articles under earlier legislation, the situation needs to be considered by reference to the appropriate version of the Articles.

Art 18 of the model articles states:

“A person ceases to be a director as soon as—

(d) a registered medical practitioner who is treating that person gives a written opinion to the company stating that that person has become physically or mentally incapable of acting as a director and may remain so for more than three months;”

Where there is a written opinion by a treating doctor that the director is physically or mentally incapable to continue in the role for more than three months, directorship automatically terminates.  No agreement of the other directors (as to the termination or as to whether the person in question in fact lacks mental capacity) is needed.  The company should prepare a board minute recording the termination and the company secretary should file the requisite form with Companies House to remove the director’s name from the record.

What happens however when the incapacity of the one director prevents any board meeting being quorate (so that a record of the termination of the office cannot be made internally and external records accordingly cannot be updated)?  How can a company continue to operate without the director?

Under Art. 11 a board meeting that is not quorate can still appoint a new director or can call a general meeting so that shareholders can appoint a director.  The meeting must be at the instigation of the board of directors.  Accordingly, if there are no directors to call a general meeting, shareholders will need to apply under section 306 Companies Act 2006 for an order that a meeting be held at which resolutions are proposed to appoint directors or change the Articles.  If the incapacitated sole director was the sole shareholder of the company, the power to make section 306 application will vest with the director’s attorney or deputy if one has been appointed.  If none has been appointed, an application to the Court of Protection will be necessary to appoint a deputy.

What if the format or type of the opinion about the director’s capacity is not one as specified above (e.g. it is issued by not a treating doctor or it does not confirm the lack of capacity for a sufficient duration of time)?  In that case the office of the director will not be automatically vacated. As such, how can a director be removed?

The directors, if quorate, can normally terminate the incapacitated director’s contract of employment.  This need not vacate the office of director, however withdrawing the reward for director’s efforts may lead to the desired outcome.   What happens when directors are not able to act (e.g. they are not quorate)? Art. 7 allows the company to appoint additional directors by ordinary resolution.  The company may therefore gather the necessary quorum to terminate the incapacitated director’s contract of employment.  If the board is completely unable or unwilling to act, Art. 4 allows shareholders to direct the board by a special resolution to take a specific action (e.g. terminate the incapacitated director’s contract of employment).

Shareholders always have the option of removing a director from office by ordinary resolution at a shareholders meeting under section 168 Companies Act 2006. Meeting must be called following special notice procedures and the director in question may speak at the meeting in his defence.

The termination of the director’s employment contract will not automatically lead to removal of the director from his position as an officer of the company.  However, removal of the director from the position of an officer of the company will automatically terminate his/her employment contract.  The automatic termination of employment does not strip the director of his or her right to claim compensation for breaches of employment rights or his/her entitlement to contractual payments arising out of his termination of employment.  The contract of employment should therefore always be consulted prior to any action.

* Disclaimer: The information on the Anthony Gold website is for general information only and reflects the position at the date of publication. It does not constitute legal advice and should not be treated as such. It is provided without any representations or warranties, express or implied.*

Claims made by adult children for provision out of the estate of a deceased parent are not novel at all.  Children of the deceased (even though independent adults) are entitled to bring claims for a reasonable financial provision to be made for them out of their parent’s estate pursuant to the terms of the Inheritance (Provision for Family and Dependants) Act 1975.  Successful claims have been made by many adult children for approximately 40 years.   Re Hancock and Espinosa v Bourke, both dating back to late 1990s, show that whilst claims from able bodied children are not looked at enthusiastically, they will receive some damages if they can prove they have needs which require provision.   Why has therefore the recent and still ongoing case of Ilott v Mitson sparked so much interest?

Facts of Ilott v Mitson

Ms Ilott’s mother passed away in 2004 leaving an estate valued at just under £500,000 and a Will in which she left her entire estate to 3 animal charities.  Ms Ilott herself is an adult and at the time of the trial was in her mid- 40s, married with 5 children and dependant on state benefits.  She was the only child of her mother, but having married against her mother’s wishes, was estranged from her since she was 17 years old.

Courts’ decisions in Ilott v Mitson  

The court of first instance found that the Will, disinheriting Ms Ilott altogether, has failed to make reasonable financial provision for Mr Ilott and awarded the daughter a lump sum of £50,000.

Ms Ilott appealed to the High Court’s Family Division against the first instance decision on the basis that a sum of £50,000 awarded does not make reasonable financial provision for her.  The defending charities cross-appealed alleging that in the circumstances of this case, the original Will (making no gift to Ms Ilott) was a reasonable financial provision for her.

The High Court considering the charities’ cross appeal agreed with them and concluded that the lack of provision was reasonable in the circumstances of the case.  With that decision made, the issue of Ms Ilott’s appeal on the issue of the amount awarded was not considered.

Unhappy with the result Ms Ilott took the matter to the Court of Appeal.  The Court of Appeal agreed with Ms Ilott and reinstated the decision of the first instance judge.  It found that the Will failed to make a reasonable financial provision for Ms Ilott.  The Court of Appeal sent the matter back to the High Court for a decision as to the amount to be awarded.

The High Court concluded that the decision of the first instance judge on the amount awarded was not wrong (i.e. £50,000 was a reasonable financial provision to be made).  Ms Ilott disagreed and appealed for the second time to the Court of Appeal.

The Court of Appeal concluded that the decision as to the amount awarded as made by the first instance judge was wrong as it did not take into account the impact the award would have on Ms Ilott’s benefit entitlement.  As Ms Ilott was reliant on means tested benefits.  Had she received the £50,000, she would lose them.  The award would therefore have no impact on improvement of her circumstances.  The appellate court awarded Ms Ilott a sum of £143,000 to buy a house and an option to draw £20,000. Award structured in this way would not result in loss of benefits.

The charities appealed the decision of the Court of Appeal and the matter is to be heard by the Supreme Court in a month’s time.  The decision of the Supreme Court is going to be awaited with great interest and trepidation not only by the parties to this claim, but also lawyers working in this area and all potential claimants.  Why?

Primarily, because it is expected that guidance on the following points will be provided:

1. What is meant by “maintenance”, not only as a general point, but specifically with reference to adult children.  In the case of Ms Ilott, she has had no accommodation related income needs as her accommodation was being paid for by housing benefit. Can therefore the award made specifically for the purpose of purchasing a house be considered maintenance?
2. Is it necessary for the court to make sure that benefits are maintained when it makes and structures an award?  If not then clearly a claimant on benefits would require higher awards than claimants with income from other sources, so as to compensate them for the benefit lost as a result of the award made.
3. What is the impact of estrangement and lack of expectation to inherit on awards that may be made?  In the case of Ms llott, should the fact that she was estranged from her mother, but also the reason for such estrangement, bear any relevance?
4. What is the impact of the fact that the claimant’s situation is a life-style choice rather than a result of their age or disability on the awards made?  She was unable to find full time employment to assist her financial predicaments.  However, Ms Ilott was living on limited means not as a result of disability or age. She lived in a remote place where it was difficult to find work and she had five children to look after.
5. How does the claimants expectations impact on the size of the award?  Ms Ilott did not expect a legacy to meet all her needs. Should she be awarded more than she first hoped for?

Whilst guidance of the Supreme Court on the above points is awaited, should you have any questions regarding a claim, please do not hesitate to contact me or a member of my team.

* Disclaimer: The information on the Anthony Gold website is for general information only and reflects the position at the date of publication. It does not constitute legal advice and should not be treated as such. It is provided without any representations or warranties, express or implied.*