Harbour View Q2 2015

HARBOUR VIEW N e w s a n d O p i n i o n s f r o m T h e H a r b o u r Te a m

2015

Q2 Issue focus‌ costs management

In this edition of HARBOURVIEW we focus on costs management which was addressed by Lord Justice Jackson and Lord Dyson at the 3rd Annual Harbour Lecture, and discussed by practitioners and clients at the Harbour/Legal Business round table.

We also explain what constitutes a good claim for funding and how to make a funding application.

CONTENTS 3rd Harbour Annual Lecture p3 The Confronting Costs Management The Veil p5 Lifting A Harbour/Legal Business Round Table

Funding p7 Litigation Maximising Your Potential HARBOURNEWS‌ in brief p13

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The 3rd Harbour Annual Lecture Confronting Costs Management On 13 May, Lord Justice Jackson and Lord Dyson MR delivered the 3rd Harbour Annual Lecture, the former giving his first in-depth public commentary on the costs management aspects of the 2013 civil justice reforms.

The speeches provided a rare insight into the views of the senior judiciary about the present and future state of costs management. The Master of the Rolls was broadly supportive of Lord Justice Jackson’s recommendations for further reform, in particular the need for further training in costs management by the Judicial College.

The benefits of costs management Regardless of how you feel about the new regime, it appears to be here to stay. Lord Justice Jackson hit back at the critics of his costs management reforms, reminding the audience that the civil justice system exists to deliver civil justice to the public at proportionate costs, not to promote the contentment and convenience of lawyers.

Although the new regime requires further refinement, and both lawyers and judges need to develop skills that have not necessarily been core to their practices in the past, he saw an increasing recognition within the profession of the benefits of costs management.

Indeed, he predicted that in 10 years it will be accepted as an entirely normal practice and people will wonder what all the fuss was about.

The key benefits that Lord Justice Jackson outlined were: 1. B oth sides know where they stand financially.

They have clarity as to what they will recover if they win, and what they will pay if they lose. This information is of obvious benefit to those taking decisions about the future conduct of litigation, and in the context of settlement discussions.

2. Early settlement is encouraged.

Once parties are able to see the total costs of the litigation and the extent of their own exposure they are more inclined to ‘see sense’, and settle early. In a majority of cases, costs are a major factor. Failure by the victor to recover sufficient

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Nick Williams and Matthew Knowles costs may make the whole litigation futile, and the costs burden on the loser may be crushing regardless of its exposure to damages.

3. Costs are controlled from an early stage.

In some cases, the very act of preparing a budget may temper behaviour, and effective costs management also reduces costs payable by both parties, despite the additional costs involved in the costs management process, which should, over time, diminish as practitioners become more adept.

4. CMCs are more effective.

Rather than being formulaic, CMCs are now effective opportunities for the judge to take a grip on the case, identify the issues, and give directions that are focused on early resolution of those issues.

5. Fairness is promoted, as each party will know what is being claimed.

Costs that you intend to claim should be set out in exactly the same way as damages.

He went on to detail the common objections levelled at costs management, which include: • increased arguments over costs leading, in themselves, to higher costs; • it being unnecessary in cases that settle, i.e. the considerable majority; • disproportionate front loading of costs; and, • the difficulties of accurately budgeting for unforeseeable events.

He felt that none of these apparent disbenefits present a good argument for not managing costs effectively; managing costs promotes access to justice, and increasingly other jurisdictions, such as Singapore, are recognising the benefits of introducing costs management into their procedure rules.

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Recommendations for further reform Both speakers felt that although the reforms had been a success, there remains further work to be done in improving the costs management regime. Having canvassed the views of numerous practitioners and key judges, Lord Justice Jackson had the following further recommendations: 1. Better judicial training, including mandatory costs management training, and development of a standard form of costs management order. He also suggested that the Rules Committee might consider further simplification of the costs management rules. He felt these reforms would help combat judicial inconsistency, unduly long hearings and micro management.

2. Combining case and costs management into a single hearing. He proposed this as an iterative process: first giving case management directions; then budget the costs; then revise the case management directions if the costs are still disproportionate.

3. Amendment of the rules so that costs budgets must be filed 14 days before the case and costs management conference (CCMC). It is envisaged this would overcome the problem of budgets being overtaken by events, whilst avoiding budgets being prepared at the last minute.

4. Given that it is rare for cases which have been subject to costs management to proceed to detailed assessment, introduction of a summary bill of costs. That bill should be in a format matching Precedent H to aid costs judges and practitioners in marrying up approved budgets with final bills of costs.

5. A single revision of Precedent H to deal with various shortcomings from which it suffers, in particular the absence of a distinction between costs already incurred by the time of the CCMC and the estimated future costs.

6. Generally the court should only determine budgets for future costs but in order to address concerns where significant costs have already been incurred, it should be given the power to comment on or summarily assess incurred costs, or set a global budget figure for incurred and future costs, where significant costs have already been spent.

…if parties were able to avoid costs management, it would become the exception rather than the rule, and that instead at least one additional QBD master be appointed to help deal with the costs management of clinical negligence cases.

7. Repeal of rule 3.15 and PD 3E which provide that courts generally make a costs management order in every case, and their replacement with criteria to guide courts on whether to do so. In particular, that the court may deviate from the rules on costs management if it lacks the resources to do so without significant delay and disruption to that or other cases.

8. The fixed costs regime should be extended to lower value multi-track work, perhaps in claims worth up to £50,000. Presently it is only applicable in certain Personal Injury fast track cases and in the Intellectual Property Rights Court.

Lord Dyson praised the costs reforms stating that “in many respects, the cost management aspects of the reforms have been successful”. He also lent his endorsement to the above recommendations, with the sole exception of repealing rule 3.15 and PD 3E. He felt that if parties were able to avoid costs management, it would become the exception rather than the rule, and that instead at least one additional QBD master be appointed to help deal with the costs management of clinical negligence cases.

Comment Funders (who are no different to clients, who want a cost effective, proportionate and predictably run litigation experience) naturally have a vested interest in costs management being done properly. Accurate estimations of how much is going to be spent, and when, is a key concern when making investment decisions and managing the capacity in our Funds.

Long before the introduction of the civil justice reforms, costs management (or the lack thereof) was a hot topic for us.

On some occasions we have been surprised by how little concern certain lawyers had for when and how much of their clients’ money was going to be spent. Together with an increased focus on budgets by clients, the new costs management regime has been a significant step in ameliorating the position, and we support further reform. The recommendations will no doubt be considered carefully by the sub-committee of the Civil Procedure Rules Committee headed by Mr Justice Coulson.

A video recording and the full text of both speeches is available on the Harbour website at: http://bit.ly/1K830D8

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Lifting The Veil A Harbour/Legal Business Round Table We recently teamed up with Legal Business to host a round table discussion with a panel of leading disputes lawyers. We stimulated the discussion with two examples of cases Harbour has funded, one successful and one not, and looked behind some of the myths that pervade our market. The key topic of the debate, perhaps inevitably, was costs management.

Earlier this quarter an A-List panel, comprising lawyers from firms such as Herbert Smith Freehills, Norton Rose Fulbright, Allen & Overy, Stewarts Law, Quinn Emanuel and Mishcons, and chambers such as Essex Court and Brick Court, assembled in London with Harbour and Legal Business to debate a number of issues affecting the litigation funding market.

After the warm up – a debate concerning two cases Harbour has funded – we covered a number of topics such as the relationship between funder, lawyer and client, ATE insurance and the speed and efficiency of our case review process. Inevitably, however, the key topic of debate was costs management – is it truly possible to project manage a large, complex dispute as one would a non-contentious transaction?

Stephen O’Dowd We revealed to the panel that in Harbour’s first fund, cases we invested in ran, on average, 18% over budget.

In our second fund, we are running at 2% over budget and the goal with our current (third) fund is to close all investments within budget. However, that goal is not without its challenges.

…we covered a number of topics such as the relationship between funder, lawyer and client, ATE insurance and the speed and efficiency of our case review process.

Ted Greeno, from Quinn Emanuel Urquhart & Sullivan, expressed his view that the idea you can budget a large commercial case accurately is flawed. This view was challenged by a number of panellists, including Deirdre Walker from Norton Rose Fulbright. Although she acknowledged that disputes are non-consensual and therefore not like a typical legal transaction, she explained that her firm now deploys dedicated pricing executives on large disputes. This is because, in her view, the idea that a partner is the right person to manage the administrative day-to-day running of a case, which includes the budget, is “fanciful”.

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Damian Grave, from Herbert Smith Freehills, echoed Deirdre’s comment, stating that on many disputes run by the firm they work with costs management specialists in order to present costs-related information to clients in a meaningful way. Catherine Wolfenden, from Osborne Clarke, added that it is essential when working with a funder that costs can be tracked accurately on a week-by-week basis.

The client’s perspective came from Jamie Drinnan at Consensus Business Group. He expressed amazement at how many law firms think of regular cost reporting as being the submission of monthly bills.

He also pointed out that: “ …there tends to be a big difference between the initial budget and the time estimate you are given when you are pitched to and then what it turns out to be. That is where funding can have a real value for us, as a client.

You get that secondary review. You get a more honest appraisal of how much this is really going to cost, because somebody else is having to fund it”.

Our favourite quote on costs management, however, came from Toby Landau QC at Essex Court Chambers: “ Can I just give a Bar perspective on this, as a profession which historically, and notoriously, has never really understood much about budgets or, indeed, money?

I have an experience that happens all too frequently.

I arrive at a hearing as lead counsel. I sit at counsel’s table, facing the tribunal. I have my notes in front of me, and all of the materials that I will need to communicate my case. And when I turn to my side, I see a long line of people stretching down the length of the table, and sitting behind, who are part of my team. And as I look further down the line, there are banks of people who I have never seen before.

They have apparently been working hard, and billing hard, on the case, but I have no idea what exactly they have done, or what has been produced by their labours.

And certainly nothing they have done or produced has made it into my notes, or the materials in front of me, and so will be communicated to the tribunal.

This scenario is a consequence of a lack of co-ordination. There is a lot of waste. There is nobody taking an overview and saying, ‘What do we really need to do to actually present and argue the case?”

Comment Our contribution to the debate over costs management included a discussion of lessons we have learned from previous cases, such as the need for a sizeable claim value to costs ratio, and the need to build healthy contingency into budgets.

We are not saying that costs management is simple – it isn’t meant to be – but we are saying that effective costs management is possible. We are achieving it on a number of the cases we are funding.

To leave Deirdre Walker with the last word: “ Ultimately… clients want more certainty and we have to find a way to deliver it”.

The full text of the round table is available at: http://bit.ly/1KcbA42

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Litigation Funding Maximising Your Potential The following article was published in the June issue of Insolvency Intelligence. Whilst the article was written with insolvency disputes in mind, it gives useful guidance on how to determine whether any claim may be suitable for litigation funding and, if so, those matters that should be borne in mind when approaching the market for funding.

Introduction The hard work in identification of claims is well known.

But once a potential claim is identified, what then?

An insolvency practitioner and his legal team will need to consider with creditors the funding options available to pursue the claim. The recent extension by the government of the insolvency carve out from the Legal Aid, Sentencing and Punishment of Offenders Act 2012 means that conditional fee agreements (CFA) and after the event (ATE) insurance remain important funding options for many insolvency claims.

As funders are looking at the recovery of their investment and an appropriate reward for their investment, they are

Rocco Pirozzolo

1. Guidance on applying for litigation funding Type of claim As a general rule, funders will consider any claim that has a damages outcome. However, there are cases where the claim is not monetary but the remedy can be ‘converted’ into cash, such as intellectual property rights.

An opponent who can pay Funders are looking to the recoveries – of compensation, interest and costs – to recover their investment in the case as well as their reward for investing in pursuing the case.

There may be claims, such as professional negligence claims, where the existence of an insurance policy can usually be assumed. Of course, this may still leave coverage issues and the extent of the cover is an important consideration.

interested in understanding the value of the claim…

The options do not, of course, end there.

The relevance and viability of litigation funding (or third party funding, as it is also known and which is available for both arbitrations and litigation) should not be overlooked.

The purpose of this article is twofold. Firstly, to provide some guidance on how to determine whether a claim may be suitable for litigation funding and, if so, those matters that should be addressed in making an application. Secondly, to highlight some issues of which litigants should be mindful when seeking funding.

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This differs from a claim where there may be no insurance available and where the assets of the opponent(s) need to be considered. Put simply, are the opponents able to satisfy any judgment and costs?

Funders will expect some due diligence to have been covered within the application, even though they will also carry out their own enquiries.

Good merits on both liability and value It is a common observation of funders that too little emphasis is placed in applications for funding upon the value of the claim, with the focus being on establishing liability.

As funders are looking at the recovery of their investment and an appropriate reward for their investment, they are interested in understanding the value of the claim, whether this is achieved by way of a settlement or awarded by a court. Accordingly, they will consider the range of what may be a ‘realistic minimum’ offer or award, rather than the sum claimed or pleaded.

Some funders will consider paying for an opinion or a valuation report, if this is necessary.

Type of retainer Some, but not all funders are insistent on solicitors – though not necessarily barristers – acting under some form of CFA. Exposing a significant part of their hourly rate to risk by way of a discounted CFA is taken to demonstrate that the advisers have confidence in their assessment of the case.

Some funders readily accept lawyers being paid on an hourly rate basis. This may be for practical reasons: namely, in order to ‘level the playing field’ when bringing a case against a well-resourced opponent, it is accepted that the claimant’s legal team simply need to be fully paid. Equally, it may also avoid too many stakeholders having to be paid from the recoveries in the litigation.

Costs budgeting A funder will expect to see a costs budget for running the dispute to trial even if it is not required by the rules of court. While cases do settle, funders (and creditors) need to know that there is sufficient funding to take the case to trial.

Any costs budget will be scrutinised and ‘stress tested’ as it is, clearly, better to have a robust rather than an optimistic budget. Although over-runs can be catered for, funders aim for certainty about the amount that they need to invest in a case. Indeed, the budget which is agreed will become one of the schedules to the funding agreement and progress will be monitored against that budget. Budgets should include all necessary costs to conduct the case properly, namely solicitors, counsel, and experts.

The funder will also consider whether they will bear the adverse costs exposure or whether an ATE insurance policy may be desirable. ATE insurers may well seek payment of the premium and the insurance premium tax, either wholly or partly, before the policy is incepted. This cost would then be added to the sums sought from the funder to invest in the client’s case.

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A further item of cost that needs to be considered may relate to security for costs. If a bond (or deed of indemnity) or bank guarantee is needed then an additional cost will need to be budgeted for.

Expertise of the team While a claim may have merit, it is important to have a team that can convince the court of that merit.

Accordingly, consideration will, inevitably, be given to the experience and expertise of the legal team.

Over and above the fee earner with day-to-day conduct of the case, this will extend to considering counsel and any expert as well as the resource of the opponent’s legal team.

There may be a concern that funders will replace the legal team with their own preferred ‘panel’.

Yet the reality is, however, more simple: if funders do not believe in the suitability of the team, they will not invest in the claim.

Gearing of the investment to the damages and the funder’s reward The financial reward of the funder for their investment in pursuing a case can take a variety of forms. It typically consists of either a percentage of the damages recovered, or a multiple of the amount advanced by the funder, or a combination of these two. There may also be some staging of the reward, depending on when a case concludes.

While each funding agreement is freely negotiated between the funder and the litigant, there have been some trends over the years. As a rule of thumb, funders have sought between 25 per cent and 40 per cent of the damages recovered, or a minimum of three times the amount advanced. Thus, by way of an example, if the legal fees which have been paid amount to £500,000, the funder would expect to receive its investment returned in full as well as £1.5 million to represent its reward. Accordingly, the damages available in any case have to be substantial enough to enable this rate of return to be made. This is because when a funded case is lost, that results in a total write off of the funder’s investment.

The litigation funding market is evolving. There has developed over the last 2 years a segment in the market that invests in small to medium sized claims, ranging from £100,000 to £2.5 million in value. The definition of “small” or “medium” sized claims will develop over time but, certainly, one of these funders has gone to press to say that it will invest sums of between £10,000 and £600,000 in such claims.

The ratio of the investment compared to the damages represents the “gearing.” Funders operate different ratios, but a ratio of 1:10 (investment: damages) may be regarded as standard. Nonetheless, ‘gearing’ has the effect of imposing a minimum value of a claim, being a ‘realistic’ value assessed by the funder rather than the ‘face value’ of the claim. Funders operate a minimum value of the claim below which they would not, typically, be interested in offering funding. This threshold may be evident from a funder’s website or by telephoning them.

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2. Some issues to keep in mind Care should be taken when approaching the funding market to understand who is a funder (who has immediate access to funds, as opposed to a broker) and also whether any funder has subjected themselves to voluntary regulation by the Association of Litigation Funders (ALF). ALF is the regulator of its funder members and requires their adherence to its Code of Conduct (Code). This Code applies to resolving disputes within England and Wales. As at April 2015, there are seven funder members. Any member will need to renew its membership each year and the ALF website, at www.associationoflitigationfunders.com, should be consulted for details of their members and any changes to the Code.

Some of the matters raised below may well be addressed by virtue of the funder being an ALF member. The Code is a quality mark of the practice and standards for funders and it is in this context that the Code is referred to below.

Capital adequacy of the funder While it may seem like an obvious point, it is clearly important to ensure that funders have the capital needed to fulfil their commitments to litigants who enter into a funding agreement with them. For funder members of the ALF, there is a ‘general obligation’ that funders will at all times maintain adequate financial resources to meet its obligations to fund all of the disputes that it has agreed to fund, and in particular will maintain the capacity: (i) to pay all

debts when they become due and payable; and (ii) to cover aggregate funding liabilities under all of its funding agreements for a minimum period of 36 months (which is regarded as longer than the average life cycle from entering the funding agreement to the conclusion of the litigation).

The Code extends this general obligation beyond the funder to its funder subsidiaries and associated entities as well as adding four additional requirements to: (a) Ensure that it maintains access to a minimum of £2 million of capital or such other amount as stipulated by the ALF; (b) Be subject to a continuous disclosure obligation in respect of its capital adequacy and will notify the ALF and the litigant if its capital adequacy is no longer sufficient; (c) Undergo annual auditing and provide the ALF with an audit opinion about their most recent annual financial statements; (d) Provide the ALF reasonable evidence from a qualified third party (preferably from an auditor, but alternatively from a third party administrator or bank) that the funder satisfies the capital adequacy requirements which apply at the time that its annual subscription is paid to the ALF. Funder members of ALF must test their exposures whenever they enter into a new funding agreement, and thereafter at least monthly with respect to ongoing commitments.

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Where a funder is not a member of the ALF, then it will be for the insolvency practitioner and their legal advisers to satisfy themselves on the capital adequacy of the funder approached – this is a critically important piece of due diligence.

The basis upon which the funder is to be paid The essence of litigation funding is that money is invested in a case on a non-recourse basis. This means that if the case that the funder has invested in has been unsuccessful, the funder loses its investment with no ability to pursue the litigant (as it is not a loan), unless there has been a material breach of the funding agreement. It also means that the funder does not seek any payment in excess of the proceeds recovered in the dispute funded.

Accordingly, if a case succeeds at first instance but loses on appeal, then the funder should not be entitled to any monies. Any attempt by a funder to seek the return of their investment and earn their reward from the first instance judgment when the litigant has ultimately lost on appeal would not reflect that the funding is following the outcome of the litigation.

Another issue to be mindful of is where there is a partial success in the litigation, such as where the case has been successful against one opponent but not against other opponents. The funder is following the fortune of the litigant in the case and so any return of investment and reward should take into account the combined (aggregated) financial outcome for the litigant.

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An issue also worth being mindful of is whether the funder’s reward is based on the sums paid or incurred, or on the budget agreed for funding the case to trial.

If it is the latter, then a litigant may feel aggrieved if a dispute is settled early but the funder’s reward is based on a multiple of the total budget for the case being determined at trial.

…there is a ‘general obligation’ that funders will at all times maintain adequate financial resources…

Ability to obtain an increase in funding At the time of entering into the funding agreement, the budget should have been agreed at a level which is realistic for the dispute to be decided at trial.

However, experience shows that budgets can be exceeded due to unforeseen developments in the case, such as an application made by an opponent. Some funders are not able or willing to increase the amount that they have committed to a case once the agreed budget has been exceeded. Such a stance may well influence who a litigant may want to work with as their funder and enquiries can be made to determine their flexibility should a budget increase be necessary.

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Ability to interfere or control the litigation The funding agreement should make clear that the funder agrees that it will not take any steps which may interfere with the relationship between the litigant and his or her solicitor or barrister which may cause either adviser to breach their professional duties. This is part of the Code which applies to funder members of ALF. The emphasis is that the litigant remains in control of the litigation being funded, despite the funder’s investment in the litigation being progressed. However, this needs to be distinguished from any reporting and consultation requirements that the litigant, through their legal representative, is obliged to give under the funding agreement such as by way of monthly reports.

(c) Reasonably believes that there has been a material breach of the agreement by the litigant.

If the agreement is terminated, under the Code funder members remain liable for all funding obligations accrued to the date of termination, unless the termination is due to a material breach.

In addition, the Code provides that if there is a dispute between the funder and the litigant about termination, then this would be referred to expert determination by a Queen’s Counsel, whose decision would be binding.

The expert shall be jointly instructed or nominated by the Chairman of the Bar Council.

Furthermore, the agreement should state whether, and if so how, the funder may provide input to the litigant’s decisions in relation to settlements. Should a conflict arise and there is a dispute between the funder and the litigant about settlement, then there should be a quick way of resolving such a dispute. Under the Code, ALF funder members’ agreements would contain a provision whereby any dispute would be referred to expert determination by a Queen’s Counsel, whose decision would be binding.

The emphasis is that the

Ability to terminate

being progressed.

Any funding agreement should be clear about the grounds for termination and also make it clear that there is no discretionary right to terminate the agreement outside of these circumstances.

Under the Code, ALF funder members can only terminate if one or more of the following are fulfilled: (a) Reasonably ceases to be satisfied about the merits of the dispute. The agreement may define this. In the case of Harcus Sinclair v. Buttonwood Legal Capital Ltd [2013] EWHC 1193 (Ch), the agreement contained a provision enabling the funder (Buttonwood) to terminate if in the reasonable opinion of Buttonwood, the litigant’s prospects of success in the proceedings were 60 per cent or less. Having initially invested a significant sum in the case, Buttonwood subsequently formed the view that the prospects of success did not exceed 60 per cent and served a notice terminating the agreement. The court upheld that the termination had been reasonable and effective. (b) Reasonably believes that the dispute is no longer commercially viable. An example would be where an opponent ceases to be ‘good for the money’. Even though the case may continue to be meritorious, it would be pointless to proceed for a “paper judgment.”

litigant remains in control of the litigation being funded, despite the funder’s investment in the litigation

ATE insurance Some funders are able to provide a “risk free” solution to a litigant both in relation to own costs (which they fund) and adverse costs. These funders may give a contractual indemnity for adverse costs in the funding agreement or they may have an ATE insurance facility arranged for adverse costs. If neither of these are available to a litigant, then there will be the need to approach the ATE insurance market separately, perhaps through a broker. This not only increases costs but also inevitably leads to delays in completing the funding package as the applications may be “out of step” with each other.

Conclusion The litigation funding market has grown and evolved over the last few years. Whilst litigation funding has, historically, been underused for insolvency disputes, it is clear that it may well be more suitable now given the market’s appetite for small, medium and significant sized claims. Insolvency practitioners and their lawyers should consider whether litigation funding may be appropriate for the cases in which they become involved. It is hoped that this article will prove useful when undertaking this review, as well as assisting with how to select the funder with whom to partner.

Comment It is important that legal advisers are able to discern if their client’s claim may be suitable for funding. This may avoid wasting time and cost in pursuing an application which may not be either of interest to the funding market or be ready to be presented to the market.

Equally, once funding can be applied for then it is vital that the application contains the information on those issues that funders are interested in. This should enable an informed and quick decision to be arrived at by funders.

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HARBOURNEWS‌ in brief

Susan Dunn and Stephen O’Dowd travelled to Australia in June, attending and guest speaking at various events concerning the state of the litigation funding market in Australia. We are currently funding 9 Australian cases.

In addition to writing the article in Insolvency Intelligence which is reproduced in this issue, Rocco Pirozzolo is due to speak at a Pricing Conference on 30 June organised

by Validatum in London.

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For more information please go to www.harbourlitigationfunding.com or contact Susan Dunn or Stephen O’Dowd on 0207 220 2370

Harbour Litigation Funding Limited 5th Floor East, 180 Piccadilly, London W1J 9ER

www.harbourlitigationfunding.com