Brain and Spine Injuries- The Fight for Justice
Published August 2001
"This is a humane book, which never reduces
tragedy to equations, and it is a valuable check to the hard-nosed reductionism
of modern case management. It needs to be bought by clients for their lawyers
and by lawyers for their clients."
"This is a quirky, fascinating, caring
book from a great personal injury litigator. It plugs a yawning gap in the market
and deserves to do very well."
Solicitors Journal 30th November
2001
I have set out below the index of my new book, the introduction, and the first
page of each chapter, in order to give the reader an impression of the contents.
TO ORDER:
Send a cheque for £27.50 (£25 for the book, and £2.50 post and packing)
payable to "The Book Account" to Chantal Campbell at Exchange Chambers, Pearl
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or E-mail Chantal Campbell on campbell@exchangechambers.co.uk
INDEX
DEDICATION
INTRODUCTION
CHAPTER 1 FUNDAMENTAL PRINCIPLES
CHAPTER 2 THE CONDUCT OF LITIGATION
CHAPTER 3 GLOSSARY OF LEGAL TERMS
CHAPTER 4 BRAIN INJURY
CHAPTER 5 SPINAL INJURY
CHAPTER 6 GLOSSARY OF BRAIN & SPINE TERMINOLOGY
CHAPTER 7 PLAN FOR LIFE
CHAPTER 8 MULTIPLIERS - THE CALCULATION OF FUTURE LOSS
CHAPTER 9 REHABILITATION
CHAPTER 10 INTERIM PAYMENTS
CHAPTER 11 THE ASSESSMENT OF MENTAL CAPACITY
CHAPTER 12 MANAGEMENT OF THE EXPERT IN LITIGATION
CHAPTER 13 PRESENTATION OF THE FINANCIAL CLAIM
CONCLUSION
MY PROFILE
INTRODUCTION
"Under the present law I am compelled to award damages on a once for all basis,
and there is no scope for a continuous assessment either of need or of loss of
earnings, to be decided from time to time as Samir's future unfolds. This
case therefore only serves to highlight once again the crying need for a review
of this branch of the law, which Judges have so frequently urged, but which only
Parliament can undertake.":
Mr Justice Hirst in 1987 in Aboul-Hosn v. Trustees of the Italian Hospital and Others: Kemp &
Kemp A4 101.
This book is aimed at all those involved in the process of litigation
following a severe injury to the brain or spine: the person injured, the family,
loved ones and friends, the various caring professionals, and the lawyers. It
is written in non-legal language, although legal jargon is used sometimes, because
otherwise the non-lawyer reader might be put off by people (not only the lawyers)
talking about legal principles in terms which are not familiar, and so are confusing.
The object of the book is to guide the reader through what I see as the important stages
of litigation, so that everyone knows what is going on at any particular time: my experience is
that the failure to communicate can be an enormous obstacle to the successful conclusion of a
case, and I would hope that communication is made easier if all concerned understand the basic
principles involved.
I have spent all my working life conducting personal injury litigation, and since
I "took silk" (became a Q.C., or Queen's Counsel) in 1992 I have spent all my
time dealing with this type of claim. A full description of me and my work is
at the end of this book, but at this stage I just want to emphasise that, having
seen over a thousand severely injured people in all parts of this country, and
abroad, I have formed clear views on how these cases can and should be conducted,
with the overriding objective of making the process more satisfactory to claimants.
I must make it clear at the outset that I only work for claimants, not for insurance
companies or other organisations responsible for the injury in question.
I have tried not to create yet another textbook on litigation generally, but instead
to concentrate on the specific areas of this type of litigation which I think
deserve attention. This is not intended to be a book in which you can look up
abstruse points of law, or consult rules about court procedures.
I have become convinced that efficient management is likely to
be the key to the successful outcome of a claim, because almost all relevant aspects
of a personal injury "action" (a court case) are governed by simple rules of efficiency,
not by complex legal principles. Efficient management is more likely to be achieved
by specialist lawyers, or by those who have a clear interest
in this type of injury.
As part of that system of management, I am very keen on the notion of teamwork;
I really do think that claims go better when the participants have got to know
each other, and all understand how the claim is being presented.
Possibly the final general ingredient for a successful outcome is communication.
I regard this as the lawyers' duty, because it is up to us to make sure that all
those involved have the opportunity to spend enough time talking to avoid misunderstanding.
Good communication in this context means that the people in a court case have
sufficient opportunity to discuss all relevant matters with those who are interested.
In particular, that implies that the injured person and his or her family should
have every opportunity to deal with issues which seem important to them, and lawyers,
doctors and other health professionals should take time to listen.
A feature which seems to me to run through personal injury litigation over the
ages is the constant insistence by the establishment that we must not let these
claims become too large, or something terrible will happen. A classic example
is the case of Lim Poh Choo v Camden and Islington Area Health Authority [1980]
A.C. 174 (an explanation of the legal method of referring to cases might
help; Lim Poh Choo was the name of the claimant: "v" is short for "versus", Latin
for "against": the Camden etc Health Authority was the organisation responsible
for running the hospital which caused the injury - the Defendant: 1980 is the
year in which the case was reported in that particular set of Law Reports: the
square brackets indicate a specific set of Law Reports: A.C. is short for Appeal
Cases - one of the set of Law Reports, dealing with cases which are tried in lower
courts, but then are appealed to the higher (appellate) courts: 174 is the page
at which the report starts). The claimant was a doctor with a bright future ahead
of her, who suffered very severe brain damage resulting in the need for total
care. She was awarded nearly £250,000 in 1977, which Lord Denning said was a "staggering
figure", adding that "if these sums get too large, we are in danger of injuring
the body politic, just as medical malpractice cases have done in the United States
of America.". Lord Scarman said: "A further disturbing feature in this branch
of law is that Dr Lim's case is not a rare exception.". In the next breath, though,
he said that the principle of the law is that compensation "should as nearly as
possible put the party who has suffered in the same position as he would have
been if he had not sustained the wrong.". Nowadays, we would expect a claim like
Dr Lim's to attract compensation measured in millions of pounds, depending on
the claimant's age, need for care, and earnings potential. As I write, the current
largest award in this country (ie England and Wales, because the system in Scotland
and Ireland is different) is about £9.3 million, although the defendant in that
case appealed against the award. Oddly enough, the sky has not fallen in since
the decision in Lim Poh Choo; the insurance industry will doubtless cope with
this comparatively minor problem (in the scale of things, I cannot imagine that
a few large personal injury claims are going to put them out of business, if tornados,
hurricanes and earthquakes do not).
I feel that claimants should fight for a fair and just result.
I understand the bitterness which they and their families may be feeling, against
the person who caused the injury, and against life in general for dealing them
such a harsh blow, but I still feel that we should seek only a fair and just result.
My job is to make sure that we achieve that for the claimant, but as a matter
of fact I think that the defendant (the insurance company or the organisation
responsible for the injury) is also entitled to a fair and just result. The difference
is that it is crucial that a claimant achieves it, whereas defendants are almost
always large organisations, to which the result is less important.
I have devoted separate chapters to glossaries of legal terms
and of words and phrases used in brain and spine injury.
I have usually referred to "he or she" and "him or her" to reflect the fact that
claimants, lawyers, judges and experts may be male or female. Occasionally, I
have used the masculine only; there is no significance, merely convenience.
The standard book used in the assessment of compensation for personal injury is
Kemp & Kemp "The Quantum of Damages", of which I am the Consultant
Editor. I mention this now, because this book has frequent references to Kemp
& Kemp.
In early 1999 new procedural rules were introduced by the courts, called the CIVIL
PROCEDURE RULES. They were and are intended to improve the conduct of personal
injury litigation (and other types). They were thought to be revolutionary, particularly
because they gave judges more power, and encouragement, to intervene in the conduct
of cases, and not to leave procedure to the lawyers. That had an attractive sound,
but the problem may be that few judges have as much in-depth experience of these
cases as specialist lawyers. I refer to these new rules throughout this book,
but my overall impression is that they have not made much impression in substantive
matters in this type of litigation.
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CHAPTER 1
FUNDAMENTAL PRINCIPLES
Claimants' and families' rights
Families
Quality of life
All claimants are different
Sensible and reasonable
Specialisation
Efficiency
Teamwork
Before I deal with specific parts of the litigation process, I have found, in writing this
book, that certain aspects have loomed large as being particularly important to me, and I wanted
to highlight them before I concentrate on individual aspects in separate chapters.
CLAIMANTS' AND FAMILIES' RIGHTS
First, a thread running throughout is the rights of the injured person
and his or her family. I don't mean just their legal rights, but perhaps more
importantly their right to be treated decently at all stages of the litigation
process. As part of that, I feel that they should be given as much information
as they require, and encouraged to ask questions at all stages, to which they
should almost always be given full and frank answers.Their rights start with treatment
in hospital. I see it as crucial to a good eventual outcome, following severe
injury, that this treatment should be of the best. Although this may well be so
in the acute stages (ie shortly after the injury), it can be seen more commonly
nowadays that financial constraints limit the nature and extent of treatment and
rehabilitation in these cases. If the family seek legal help early (and I do mean
specialised legal advice), it is sometimes possible to augment National Health
Service funds with an early payment on account (interim payment), and so to permit
or arrange more suitable or extensive treatment and rehabilitation.
Whether that is feasible or not, it should be possible for all health professionals
to communicate with the family, and to involve them to a degree which is acceptable
to all
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CHAPTER 2
THE CONDUCT OF LITIGATION
Introduction
Taking instructions
Liability
Quantum
Pain, suffering and loss of amenity
Financial loss
Los of earnings
Care
Case management
Accommodation
Aids and equipment
Transport
Therapies
Financial management of the award
Court of Protection
Evidence
Settlement of claims
The trial
After trial
General
INTRODUCTION
This chapter is not intended to be a comprehensive guide to enable the reader
to conduct a personal injury claim from start to successful conclusion. As elsewhere
in this book, I have selected those parts of the process which seem to me to
be important.
TAKING INSTRUCTIONS
Of course the first step is that the injured person, or those who are
responsible for him or her, must decide to consult a solicitor so that they can
be advised whether they have, or might have, a claim against the person who they
think caused the accident or injury. I would encourage people to take this first
step: many people assume that there is no valid claim, and do nothing for
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CHAPTER 3
GLOSSARY OF LEGAL TERMS
ACTION
The proceedings in court
BARRISTER
A specialist in the preparation and presentation of claims in court: nowadays,
he should also be a specialist in the topic with which he is dealing, such as
injury to the brain and spine
CLAIMANT
The word used since April 1999 for the person who has been injured,
and who is bringing the action against the person responsible to recover damages
- the previous word was Plaintiff
COUNTER-SCHEDULE
The document served by the defendant in response to the claimant's Schedule
of Damage, challenging the parts in issue and explaining the arguments which
will be put forward at trial
DAMAGES
Financial compensation
DEFENCE
The court document which sets out the reasons why the Defendant says he is not
responsible for the injury or should not pay damages
DEFENDANT
The person said to be responsible for the injury
DISABILITY
Any restriction or lack of ability to perform an activity in the manner or within
the range considered normal for a human being
DISTRICT JUDGE or MASTER
The judge who decides the preliminary issues
GENERAL DAMAGES
All parts of the award of compensation which relate to the future (from trial)
as distinct from the past (before trial)
HANDICAP
A disadvantage for a given individual, resulting from an impairment or a disability,
that
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CHAPTER 4
BRAIN INJURY
General
Description of the brain
Different types of cause
Different types of injury
Post-traumatic amnesia
Oedema
Epilepsy
Behaviour
Cognitive deficits
Types of medical report
Other reports
GENERAL
About one million people attend hospital every year with head injuries, which
account for 150,000 admissions a year, the largest group of which are young
people. Contrary to popular belief, disorders of the brain and spine are tremendously
common, frequently affecting children and adults in the prime of life. They
are the single biggest cause of disability in the community, and spinal disorders
are the most common single cause of lost working days in the country, accounting
for 67 million days, which is thought to represent an annual cost in lost production
of £3 billion. In spite of this huge clinical problem, the whole of the British
Isles is served by only about 132 neurosurgeons and about 170 neurologists;
hence, 95% of head injury victims never see a specialist in the field.
So, most head-injured patients are young, and there is a peak in the rate of injury
among 15 to 30 year olds (and another peak after the age of about 55). The significance
of the statistic about the young is, of course, that there is, or was, a lifetime
of work ahead of them, as part of an independent life, and thus the elements of
care and loss of earnings are likely to be at their maximum. The fact that most
victims are male may gradually reduce in significance as more and more women work,
although industrial injury is not the main cause of these injuries; road traffic
accidents are the major culprit, accounting for between a third and a half of
all such injuries.
Note: it is important to distinguish between the head and the brain. It is possible
to have
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CHAPTER 5
SPINAL INJURY
Description
Different types of cause of injury
Different types of injury
Respiratory complications
Urinary tract infections
Pain
Spasticity
Types of medical report
Other reports
DESCRIPTION
The vertebral column is built up from alternating vertebrae
(there are 33) and discs, which are made of cartilage and act
as shock absorbers. The disc is composed mainly of fibres (the annulus) surrounding
a central pulpy substance (nucleus pulposus) which attracts water into the centre
of the disc, making it resilient (in a young adult, 90% of the disc content is
water, reducing to 70% later on). The vertebrae, which are made of bone, are joined
by ligaments which are intended to protect the spine from extremes
of movement. Of the 33 vertebrae, only 24 are independent, namely those above
the sacrum. Each vertebra consists of a body at the front, and
the vertebral arch at the back, which contains the all-important
spinal cord, the object being to provide a mechanically strong
structure capable of protecting the cord from all but the most severe trauma.
The vertebrae are divided into levels: 7 cervical, 12 thoracic
(or dorsal), 5 lumbar, 5 sacral
and 4 coccygeal. They are abbreviated by the initial of their
area and their numbering from the top, for example C6 or T3. The cord is the line
of communication between the brain and the rest of the body, and it ends near
the base of the back, where it becomes the "Cauda Equina" (literally,
horse's tail, due to its shape). Each vertebra has two facet
(apophyseal) joints linking one vertebra to the next by articular processes. The
sacro-iliac joints link the sacrum to the back of the pelvis.
At each segmental level of the spinal cord, a nerve root leaves the cord on either
side, passing through spaces between adjacent vertebrae (the intervertebral foramen
- foramina in the plural).
DIFFERENT TYPES OF CAUSE OF INJURY
Generally spinal cord injury (S.C.I.) is caused as follows
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CHAPTER 6
GLOSSARY OF BRAIN AND SPINE TERMINOLOGY
AGNOSIA- Inability or impaired ability to
recognise objects or other events via the senses
AFFECT- Emotional disposition
AKINESIA- Inability to start movement or slowness in movement
AMNESIA- Loss of memory
ANARTHRIA- Inability to pronounce words
ANNULUS- The outer part of the vertebral disc
ANOSMIA- Loss of smell
ANOXIA- Failure of oxygen supply
ANTERIOR- Front
APHASIA- Inability to use or understand language
APHONIA- Inability to make vocal sounds
APRAXIA- Inability to carry out actions
ATAXIA- Unsteadiness of gait
AURA- The warning that an epileptic seizure is imminent
BROCA'S AREA- The part of the brain responsible for the production
of speech
BURR HOLE
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CHAPTER 7
PLAN FOR LIFE
Introduction
Life expectancy
Rehabilitation
Treatment and therapies
Accommodation
Care
Transport
Equipment
Leisure
Conclusion
INTRODUCTION
I think it is essential to consider a plan for the life of a seriously
injured person. Statistically, most of those who suffer serious brain or spine
injury are young, and the probability is that, following their accident, they
will be looked after by family, usually parents or spouses. The burden on family
carers is high, and there is a real risk that they will not be able to continue
to cope with all the stresses and strains of looking after their loved ones. In
the case of parents, or any family carer who is significantly older than the injured
person, it is likely that they will pre-decease the patient, thus depriving him
of what may well have been a long-established pattern of care to which he has
become accustomed. Many other changes are likely over the years, and they should
all be considered and foreseen, wherever possible, by the legal and medical team,
and discussed in detail with the injured person and his family. The one thing
which is certain is that both the patient (assuming that he has a significant
life expectancy) and his family will get older, and that this will have an impact
on the way in which they all manage to cope. In order to create a plan which will
cover all foreseeable eventualities, one has to consider every aspect of life;
treatment and rehabilitation, accommodation, care, transport, equipment, leisure
and therapies.
I have seen over a thousand severely injured people, and this question of making
arrangements for the future is one which looms large: I remember one mother saying
to me, after our consultation: "I feel much better: now I can die happy.".
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CHAPTER 8
MULTIPLIERS - THE CALCULATION OF FUTURE LOSS
The basics
Types of multiplier
Selection of the multiplier
The Discount rate
What level of risk should a claimant have to face
Discounting for contingencies
General
Conclusion
THE BASICS
When calculating future financial loss and expense, courts often use
the multiplier/multiplicand system. The object is to assess "the
present value of prospective loss", as Lord Reid said in British Transport
Commission v Gourley [1956] A.C. 185.
The first step is to establish the annual sum (the multiplicand) which has to
be provided to cover the future yearly loss (for example, loss of earnings) or
expense (such as the cost of care). When that has been done, it is then necessary
to multiply it by a multiplier, which represents, but is not the same as, the
number of years over which the loss will last or the expense will be incurred.
It is not sufficient simply to calculate the number of years in the future over
which the loss will be sustained, because the money awarded by the court is paid
in a lump sum at trial(for the purpose of this approach). That is in fact more
advantageous than receiving the money every week or month over the years to come
(it is called "accelerated receipt").
The multiplicand is established in various different ways, depending
on the nature and complexity of the facts in the case: the most obvious example
is the person in a stable job who is injured so badly that he will never work
again. If his annual earnings are clear, all that is needed is to make sure that
he is given a lump sum which will, when "prudently invested" (Mallett v McMonagle
1970 A.C.166), provide him with the same net income as he would have earned
had he not been injured. It is the calculation of this lump sum which requires
the use of a multiplier. In order to decide the multiplier, we
need to decide how many years of work have been lost, and this will depend on
a factual finding by the judge: if (and I emphasise if) the
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CHAPTER 9
REHABILITATION
Introduction
Does it work?
Suitability of different types of rehabilitation
Rehabilitation into work
Rehabilitation and leisure
Cost effectiveness
Goals and targets
Conclusion
INTRODUCTION
Rehabilitation can be one of the most rewarding areas of the work I do.
I travel the country seeing people who have been injured severely, all of whom
want as good an outcome as is possible. Very often the National Health Service
has not been able to provide any or sufficient rehabilitation, and one of the
first areas I like to discuss when I see clients in consultation is whether there
are avenues of treatment or rehabilitation which have not yet been explored, or
which they would like to pursue further. It is quite common to find that there
are suggestions which can be made in order to give the injured person the best
possible chance of a good outcome. If there are sensible avenues to be explored,
then it is a matter of pride for the lawyers to be able to obtain money to fund
whatever is reasonably necessary. This is done by an application for an "interim
payment" (payment in advance of the final award of compensation), the principles
of which are set out in a separate chapter.
DOES IT WORK?
Two questions arise frequently:-
1 Does rehabilitation work?
2 How do we know rehabilitation works?
These questions raise an issue of great importance in litigation involving brain
(and spine) injury, namely whether in any particular case the claimant's lawyers
are justified in advising or arranging specialist rehabilitation, which can be
very costly and which sometimes lasts for many months or even over a year.
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CHAPTER 10
INTERIM PAYMENTS
Introduction
History
Contributory negligence
Purpose of interim payment
Procedure
Statutory benefits and Social Security benefits
Summary
Conclusion
INTRODUCTION
One area of the law in which there is disappointment for many litigants
is in relation to interim payments. If an action is commenced for damages for
personal injury and loss arising out of an accident, the claimant is entitled
to ask the court to order the defendant to pay some of the compensation in advance
of the final award. The court's power is hedged about with limitations designed
to make sure that a defendant is not prejudiced, but the power seems to have become
even more limited in practice. The purpose of this chapter is to tell people of
the general power, and then to encourage those to whom it may be relevant to use
the power to its maximum, in order to relieve some of the worst effects of what
is likely to have been a catastrophic accident. In addition, defendants and their
insurance companies may wish to consider the possibility that the sensible, early
use of an interim payment might be a constructive and cost-effective approach
to a claim.
I deal in this chapter with the procedure in more detail than elsewhere, because
interim payments are so important, and claimants are often discouraged by the
technicalities.
HISTORY
The court was previously given the power to award an interim payment
by Order 29 rule 11 of the Rules of the Supreme Court. Some of the limitations
were contained in the rules themselves, the most important ones being that
(1) the defendant must be insured, or a public authority, or able to afford to make an
interim payment, and
(2) the defendant must have admitted that the accident was his fault, or judgement
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CHAPTER 11
THE ASSESSMENT OF MENTAL CAPACITY
FOLLOWING TRAUMATIC BRAIN INJURY
Introduction
The law
The decision-making process
The legal approach
The medical approach
The importance of getting it right
INTRODUCTION
Following a severe brain injury, it is important for the injured person's
legal advisers to consider whether the effect of the injury has been so serious
that the person is no longer capable of managing his own affairs. As a matter
of fact, that question has to be considered if the lawyers have any real reason
to suspect that the client may not be capable, whatever the cause of the problem;
in other words, it need not be the injury which is the cause. If, after proper
consideration, it is decided that the person is incapable, for whatever reason,
two quite distinct consequences follow: first, it is necessary to appoint someone
("a litigation friend") to manage the litigation, and to make all relevant decisions
related to the conduct of the case. For example, if the action has got to the
stage where the insurance company makes an offer to settle the claim, a decision
has to be made whether that offer should be accepted. If the client is not capable
of managing his affairs, it obviously would not be right to expect him or her
to make that decision. Accordingly, the litigation friend must do it. Secondly,
whenever any money is received during the course of the case, or whenever the
patient has money of his or her own, the Court of Protection has to be appointed
to manage that money. It is not uncommon for a person to receive money after an
accident (sometimes insurance, sometimes an interim payment) and, due to the damage
sustained, to spend it inappropriately. I have seen several cases where that has
happened, and sometimes tens of thousands of pounds have gone missing, either
with no adequate explanation or in a sadly wasteful way.
Dealing first with the litigation friend, the essential requirement
is to select a person who is thought to be suitable to make all relevant decisions
during the conduct of the case. Usually
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CHAPTER 12
MANAGEMENT OF THE EXPERT
IN LITIGATION
Introduction
Selection of the expert
The instructions
Formation of the team
The timescale
The consultation
The report
Time to trial
Exchange of reports
Discussions between experts
Joint instruction of experts
The listing system
The hearing
The adversarial system
An example
Conclusion
INTRODUCTION
I start this chapter with quotes from two cases, which emphasise the
importance of selecting good experts, and using them appropriately.
1 "Regrettably, I was not at all impressed with some of the answers which I
received from Mr *. I did not feel he was the wholly unbiased and independent
witness one would expect. Some of his answers were given more or less on the
hoof and were ill thought out.... (He) said he had performed about 2,000
terminations. However, .... in fact a very low number of terminations had been
performed - probably one of the lowest rates in the whole country .... Mr * did
admit that he must have been wrong about his figures. Asked how he felt about
that he said that he did not think it important.... (he) told me .... that the split was
80% claimant to 20% defendant. However, again after further questioning, some
of it by me, Mr * admitted he had never given evidence on behalf of any
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CHAPTER 13
THE PRESENTATION OF THE FINANCIAL CLAIM
Introduction
Schedules and Counter Schedules
Past and future loss and expense
Past losses
Future loss and expense
Sample Schedule
INTRODUCTION
Every aspect of the financial claim has to be supported by evidence.
What I have tried to do is to highlight the approach which I think is likely to
present a realistic picture of what a claimant has lost, and what he or she will
need in the future.
SCHEDULES and COUNTER SCHEDULES
Once the evidence is satisfactory, it is gathered together and put into
money terms in a "Schedule". This is supposed to be a document
setting out the entire financial claim in such a way that it can be read easily,
and understood by all concerned (claimant, family, experts, all lawyers, judge,
and insurance representatives). It should not be full of jargon, nor should it
be so full of complex calculations that it is difficult to see how the figures
are reached. In my opinion, it should be capable of standing on its own at a trial
on quantum, so that anyone who reads it appreciates precisely what is claimed,
and why, and possibly even what some of the real issues are. I think that the
drafting of schedules is an art; part of the expertise is to present a document
that the judge will be pleased to read, and which he will think makes his life
easier.
The whole point of this document is to compare the claimant's position before
the accident with his situation as he is following the injury. The questions we
always ask are: "What would you have done? What would it have cost?" compared
with "What will you do in the future? What will it cost?".
The schedule is commonly called a "Schedule of Special Damage". That is technically
incorrect, because in current legal terms "special damage" is all loss and expense
up to the date of trial, and it does not include future loss, whereas the schedule
must deal with the future as well....
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BILL BRAITHWAITE Q.C.
Exchange Chambers,
Liverpool and Manchester |
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