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Aaron is a commercial and insolvency barrister based in 3PB's Birmingham office but also working across all 3PB locations. After being called to the bar in 2015, Aaron worked as a paralegal at law firm Shoosmiths LLP, before subsequently being offered a training contract with the firm. He gained experience in a number of practice areas including real estate, commercial litigation, corporate and restructuring and insolvency. During his commercial litigation seat, Aaron was involved on a range of commercial disputes including phone hacking, employment disputes, contract claims and an international arbitration. Aaron qualified as a solicitor in 2020 into a busy, Tier 1 insolvency team (Legal 500). Aaron brings with him extensive contentious restructuring and insolvency experience, including administration appointments and extensions, disclaimers of leasehold estates, security and retention of title claims and directors’ duties. As a solicitor, Aaron also assisted with and prepared many Court applications. After gaining his Higher Rights of Audience (Civil Proceedings), Aaron joined the Birmingham office of international law firm DWF LLP as a solicitor-advocate and later as an employed barrister. As an advocate, Aaron has already appeared in over 300 hearings including a wide range of applications and fast track trials. Aaron is regularly instructed to appear in the High Court and County Court at all stages of proceedings, from pre-action advice, interlocutory hearings and through to trial. Aaron is a passionate and determined barrister who understands, first-hand, the challenges and demands faced by solicitors, and who uses his own personal experience to prioritise providing excellent client care. Outside of work, Aaron enjoys cycling and following his beloved West Bromwich Albion football team across the country, albeit seldom with success! Aaron is also a school governor where he chairs the health and safety committee. Commercial Aaron Luxton is a busy member of the 3PB commercial team and advises both claimants and defendants on a range of finance litigation, contractual and commercial matters. Recent examples include Advising a consumer on prospects of a claim under the Consumer Rights Act 2015 in relation to a defective vehicle. Aaron was also later instructed to settle pleadings for the same matter. Acting for a landlord in recovering unpaid rent. Aaron secured a judgment for the client which included unpaid rent, interest and contractual costs on the small claims track. Appearing for a vehicle manufacturer in securing a strike out of a matter which had been brought against the incorrect entity. Advising on settlement in section 75 connected lender liability matter. Advising on limitation at a pre-action stage in relation to a series of contractual breaches. Appearing at trial on various motor finance ‘secret commission’ matters. Acting for a trade wholesaler in recovering outstanding monies due under a personal guarantee. Aaron secured a judgment for the client which included the outstanding balance, interest and contractual costs on the small claims track. Appearing for a bank in its application to set aside judgment obtained by default. Successfully securing the dismissal of a claim whilst acting for an insurer at trial in relation to an allegedly mis-sold investment product. Advising a University in relation to a claim brought by a former student for loss of opportunity and career set back. Insolvency and Bankruptcy Aaron Luxton brings with him extensive contentious restructuring and insolvency experience, including administration appointments and extensions, disclaimers of leasehold estates, security and retention of title claims and directors’ duties from his time as a solicitor. Aaron regularly appears in the High Court in relation to winding up petitions, acting for both creditors and debtors. Aaron also represents creditors and debtors in relation to statutory demands, restraining the advertisement of petitions, setting aside statutory demands and bankruptcy proceedings. Recent examples of work include: Securing the set aside of statutory demands for individuals being pursued under a personal guarantee. Advising in relation to the strike off and dissolution of a company. Acting for a creditor in securing a final charging order after the debtor opposed the interim order. Securing a bankruptcy order for a creditor in relation to unpaid rent arrears.

Adeo Fraser

Adeo Fraser is a busy junior family law barrister who advises and represents in court on the full range of financial remedies, TOLATA, public and private children law disputes, injunctions and domestic abuse cases. He is known for his pragmatic, robust approach and keen attention to detail, whilst remaining sensitive to client care. He is frequently trusted with and instructed in lengthy and complex hearings and has represented several clients on both UK and international abduction and relocation cases, particularly involving Somaliland, Poland and the Dominican Republic. Prior to coming to the Bar, Adeo spent almost 18-months as a family law legal assistant in a medium-sized law firm in Birmingham. He worked alongside the Head of the Family department, assisting with the day-to-day management of complex care, adoption, contact and divorce proceedings. Outside of a busy work diary, Adeo is passionate about social action and also a keen sportsman. Adeo is a member of the RuJohn Foundation, which seeks to provide the necessary educational tools for rural schools throughout Jamaica and select U.S. cities. Adeo has played National League Basketball and continues to play at a high level in the Midlands. Publications: “From the Kalashnikov to the Keyboard: International law’s failure to define a ‘cyber use of force’ is dangerous and may well lead to a military response to a ‘cyber use of force’” Hibernian Law Journal 15 (2016) 86-113 Fraser, A. and Omotosho, Y. “Driverless cars: the ethical and legal dilemmas” in From the Frontline, Lyons Davidson Solicitors LLP (March 2017) 2 Family Adeo Fraser practices exclusively in Family Law and his practice encompasses Public Law, Private Law, Family Finance, Injunctions and Domestic Abuse cases. Financial Remedies Adeo has experience in a wide variety of financial remedies matters. He is able to run a case through from First Directions Appointments through to Final Hearings. He also has significant experience of disputes between unmarried couples, in particular applications under the Trusts of Land and Appointment of Trustees Act 1996 and Schedule 1 applications and undertakes written advisory work as well as advocacy. Private Remote FDR Hearings Adeo is available for private remote FDR hearings. For more information on private remote FDR hearings please click here. Care and Adoption Adeo has experience of representing all parties in care proceedings, representing parents, prospective special guardians, children and local authorities in complex care proceedings. He has experience of representing clients with mental health issues and learning difficulties. Adeo is regularly instructed in multi-day final hearings and his cases routinely involve the cross examination of experts from multiple disciplines. His experience includes cases involving vulnerable clients, non-accidental injuries, domestic violence, applications for adoptive orders and cases proceeding in the FDAC courts. Adeo also has experience in applications for the revocation of placement orders. Recent case includes: Re:S&J, successfully represented paternal grandparents in a 13-day care case, where he challenged the local authority’s adoption plan and obtained an adjournment for medical assessment and psychiatric assessment of the grandparents, where the child was then placed. Private law children Adeo regularly accepts instructions to appear on behalf of both applicant and respondent parents in private children matters. He has gained experience in a range of child arrangement disputes, including allegations of domestic abuse, international abduction and parental alienation cases. He is frequently trusted with and instructed in lengthy and complex hearings and has represented several clients on both UK and international abduction and relocation cases, particularly involving Somaliland, Poland and the Dominican Republic. Recent cases include: Re:S, represented the first male victim of controlling and coercive behaviour, in English history, in private law proceedings. He managed to obtain a no contact order against the children’s mother. Re:W, successfully represented a grandmother on her opposed application to relocate to Somaliland with her grandchildren. Re:D, successfully represented a diplomat from the Dominican Republic on an international abduction case. Adeo also has extensive experience in applications for prohibited steps and specific issue orders, ranging from matters concerning changes of names to removal from the jurisdiction to non-Hague convention countries. Injunctions Adeo has considerable experience in representing both applicants and defendants in applications for declarations of parentage, non-molestation orders and occupation orders.

Aimee Fox

Aimee Fox was nominated for Barrister of the Year at the Birmingham Law Society Legal Awards 2023. She is ranked as a leading lawyer by the Legal 500 in all of her areas of practice and takes instructions for cases across the UK; as well as in Chambers & Partners. Prior to completing pupillage and joining the Bar, Aimee was an associate at magic circle law firm, Clifford Chance LLP in Brussels. Aimee specialises exclusively in Family Law and Education Law. She handles an established practice specialising in financial remedies and private law proceedings. She is often instructed for her expertise in education law (SEN) to assist on related Children Act and financial matters where children have additional needs. Aimee’s financial remedy work has included a variety of high value disputes. Aimee has also been instructed on a schedule 1 application with significant international elements and an unusual case involving the enforcement of a German child maintenance order. She continues to be in constant demand for her expertise in complex and highly sensitive cases. Aimee has extensive experience in tribunals relating to EHC Plans. She has also been successful in a number of judicial reviews and appeals to the Upper Tribunal. Aimee’s expertise is such that she is often invited to train other practitioners and was invited to speak on Education Law at the Annual Conference of Chartered Paediatric Physiotherapists at the Emirates Stadium. Education Aimee has a busy education law practice and regularly appears in the First-tier Tribunal. She acts for and advises all parties including, local authorities, schools, parents and young people. Aimee was recently invited to speak on education law at the National Conference of Chartered Paediatric Therapists. Aimee has also been instructed on a number of judicial review matters. She was successful in defending a local authority in a claim for judicial review brought pursuant to section 19(1) Education Act 1996. Other examples of matters Aimee has been involved with include: Discrimination claims Special educational needs Prosecutions for non-attendance at school (including in the Crown Court and High Court) Clerking Permanent Exclusion Review Panels Appeals concerning permanent exclusion School inspection Appeals against decisions of the First-Tier Tribunal Disputes concerning Local Offers Advice and representation in judicial review Notable Cases DH and GH v Staffordshire County Council [2018] UKUT 49 (AAC) This case concerned an appeal from the First Tier Tribunal. The Appellants argued that the Tribunal had misdirected itself on the law in respect of issuing an Education, Health and Care Plan and the ability of a mainstream school to make relevant provision. This case involved issues which Aimee’s opponent, David Wolfe QC, described to Upper Tribunal Judge Jacobs at the oral hearing as “complex and novel”. For more information click here. DS, R (on the application of) v Wolverhampton City Council [2017] EWHC 1660 (Admin) Aimee Fox successfully represented the local authority against an allegation that there had been a failure by it to provide suitable education for DS in breach of its duty under section 19(1) of the Education Act 1996. DS had not returned to school after a contested incident during which he had returned home in a state of undress. Mr Justice Garnham went on to consider whether, if a breach had been found, the local authority’s alternative provision would have been suitable. Family Finance Before joining the bar, Aimee worked on mergers and acquisitions in a variety of sectors including pharmaceuticals and telecommunications. Her experience in M&A means she is more than comfortable navigating parties’ financial arrangements on divorce. Aimee is often instructed to represent high-net-worth parties where there are arguments involving inherited wealth or pre- or post-relationship acquired assets. Aimee has been instructed on cases where there are disputes concerning companies, trusts, partnerships, third party interests, cryptocurrency, non-disclosure, inheritance and pre-acquired wealth. Aimee has been involved with a number of more complex matters including cases involving the Proceeds of Crime Act 2002 and personal injury awards. She has also been able to call upon her expertise in the law of special educational needs (SEN) to assist in advising separating spouses whose children require bespoke accommodation or additional care. Aimee is also happy to provide representation in private FDRs and Early Neutral Evaluations. Cases: Recent cases Aimee has been instructed on include: C v C: Represented applicant at first instance and on appeal against leading financial remedy QC in respect of occupation of the FMH. H v H: Represented applicant in proceedings involving enforcement of child maintenance order from another jurisdiction in the EU. At one stage of the proceedings, the case had been referred to European Court of Justice for guidance on domestic law. R v S: Schedule 1 application in which the respondent was not domiciled in the UK and had business interests and income streams in Mexico, Belize and other jurisdictions. H v B v S: Represented the applicant in proceedings involving a divorce obtained allegedly as a result of fraud and forgery of divorce documents. Queen’s Proctor invited to intervene. T v T: Represented the respondent in an application to vary a ‘Christmas Order’ for child periodical payments. W v W: A civil partnership dispute in which the assets were worth several million pounds and included a large property portfolio and a very high value share portfolio. Arguments also involved financial liabilities abroad. B v S: Financial remedy proceedings with concurrent proceedings in the Crown Court with the matrimonial assets at risk because of a Proceeds of Crime Act application by the Crown Prosecution Service. D v D: Financial remedy proceedings made complicated as a result of the application having been made some 15 years after the end of the marriage. F v F: Final hearing of committal application for failure to comply with orders and provide disclosure in financial remedy proceedings. K v K: Represented the Wife in a case where the court awarded her 100% of the identifiable assets as a result of the Husband’s poor litigation conduct. Private Law Children, Injunction and Domestic Abuse Aimee is well known for her expertise in private law matters. Aimee is regularly instructed in complex proceedings involving children which include allegations of physical and emotional abuse, sexual abuse, domestic violence and parental alienation. Aimee is well equipped to handle applications where there has been social work involvement after spending a number of years representing parties in public law care proceedings. Aimee’s expertise in education law allows her to excel in applications before the family court involving children with special educational needs (SEN), mental health diagnoses or disabilities including Autism. This also allows her to provide advice on applications involving schooling. Aimee is experienced in representing parties involved in disputes where there is expert evidence. In her areas of practice, she has cross-examined psychologists including educational psychologists, psychiatrists, occupational therapists, speech and language therapists, physiotherapists as well as teachers. She has experience of internal and international relocation cases and has provided training to solicitors on pursuing and defending relocation applications. Aimee has an LLM in European Law which makes her particularly adept in this area. She also completed prestigious internships at the British Institute of International & Comparative Law and the International Bar Association. Aimee has been commended for her personable manner and client focused approach. She always seeks to find pragmatic and cost-effective solutions for her clients. Cases: Recent cases Aimee has been instructed on include: G v R: Represented a parent in protracted proceedings against a leading QC in which the subject child was recognised as academically gifted. The child’s stellar talent and achievements factored heavily in the arguments raise by the parties. Alienation was also alleged. D v D: Represented the applicant in private law proceedings against a leading QC. Allegations of domestic abuse and punishment of the children featured in the case. The matter procedurally complex and involved the consolidation of concurrent proceedings in respect of other siblings. R v J: Represented a high-profile public figure in private law proceedings. A v D: 7 day fact-find to determine allegations of domestic violence. One party represented by a leading QC. H v H: International relocation to Romania. P v B v P: Private law proceedings in which the child had been subject to lengthy litigation and numerous appeals in Poland. Jurisdictional issues arose as well as consideration of the legal effect of orders made in Poland. D v H v I: Lengthy private law proceedings with arguments on parental alienation and residence as well as special guardianship and the applicability of a section 91(14) barring order. There was involvement from NYAS. A v C: Appeal in private law proceedings arising from the court’s decision to transfer residence. D v D: Private law proceedings requiring the court’s determination in respect of the child’s medical treatment and schooling. B v R: Private law proceedings involving multiple experts from various fields. Y v F: Advising special guardians on international relocation. B v B: International relocation in which respondent parent was living outside the jurisdiction. T v T: Private law proceedings involving at 16.4 guardian and a child with Autism. FDR Hearing Service Aimee is available for private remote FDR hearings. Public and Regulatory Aimee Fox's public and administrative law practice is focused on her expertise in all aspects of education law and she regularly appears in the First-tier Tribunal. She acts for and advises all parties including local authorities, schools, parents and young people. Aimee was recently invited to speak on education law at the National Conference of Chartered Paediatric Therapist. She has given a number of seminars across the country on issues relating to Education, Health & Care Plans, exclusions and admissions. Aimee has been instructed on a number of judicial review matters in the education sector. She was successful in defending a local authority in a claim for judicial review brought pursuant to section 19(1) Education Act 1996. More recently she has been instructed on judicial review matters relating to the impact of Covid-19 on educational provision.

Andrew Neaves

Andrew Neaves is a highly-experienced family barrister who has exclusively specialised in the law relating to children with a focus on more complex public law cases in the County Court, High Court and Court of Appeal. Andrew also undertakes judicial review work in which the issues are related to his family practice and to his work in the Court of Protection. He is a co-author of “Family Law and the Human Rights Act 1998’ published by Jordans, has lectured extensively on issues of human rights and family law for Jordans and was appointed a trainer by the Judicial Studies Board in relation to the Human Rights Act 1998. Andrew was the Head of the Health and Welfare Court of Protection practice group in his former chambers and regularly undertakes work in the Court of Protection and related cases under the inherent jurisdiction of the High Court. Family Children Andrew is experienced in complex public law cases involving children. He has a particular interest in those cases which involve complex medical evidence. These Care cases are frequently of the most challenging kind, including induced/factitious illness cases, cases involving the death of a child, serious brain injury and sexual abuse. He has a particular interest in cases involving disputed expert evidence and enjoys the cross examination of professional witnesses. Andrew regularly represents all parties in such cases, having wide experience of conducting such cases for local authorities and the entire range of respondents, from parents to grandparents and children, both by their Children's Guardians and separately. Andrew has also frequently represented clients with mental health difficulties and a wide range of disabilities, both directly and through the Official Solicitor. Court of Protection Andrew was the Head of the Health and Welfare Court of Protection practice group in his former chambers and regularly undertakes work in the Court of Protection and related cases under the inherent jurisdiction of the High Court. He has extensive experience of work in the health and welfare field in which he represents all parties. He is a co-author of “Family Law and the Human Rights Act 1998’ published by Jordans, has lectured extensively on issues of human rights and family law for Jordans and was appointed a trainer by the Judicial Studies Board in relation to the Human Rights Act 1998. Andrew specializes exclusively in the law relating to children with a focus on more complex public law cases in the County Court, High Court and Court of Appeal. Andrew also undertakes judicial review work in which the issues are related to his family practice and to his work in the Court of Protection.

Andrew Duncan

Family law barrister Andrew Duncan has developed a strong reputation in all areas of family disputes. Regularly instructed in complex private and public law cases, Andrew has developed a reputation as a fearless advocate who dispenses advice in a frank and down-to-earth manner. He joined 3PB in September 2023 from a specialist family law chambers. Professional clients can expect Andrew to be a team player, who goes the extra mile and values the importance of working together. Andrew is instructed across all levels of court allocation. He regularly deals with complex physical and sexual abuse allegations, and within the private law sphere has developed a trusted reputation for cases involving complex parental alienation. Andrew represents parents, local authorities, children (directly or through their guardian), intervenors, grandparents and divorcees. Andrew without doubt has an ability to get straight to the point, he is a strong negotiator, and a resolute cross examiner. Andrew is regularly instructed in cases involving complex issues such as: non-accidental injury, sexual abuse, international relocation, parental alienation, significant substance misuse, mental health issues and domestic violence. Andrew has participated as both Appellant and Respondent in many appeal hearings. A number of those appeals have resulted in re-hearings being directed. Andrew also assists Not Beyond Redemption, which provides free family law advice and representation to mothers in prison, or who have left prison, to assist in re-establishing and regenerating the fundamental relationship between mother and child. Outside of a very busy work schedule, Andrew's interests include spending time with friends and his family and all country pursuits from fly fishing for salmon to skiing in the Alps. Family Family law barrister Andrew Duncan is regularly instructed in complex private and public law cases, often where dispute involving child protection, domestic violence, abuse or parental alienation issues are involved. Notable cases include: Re R [2024]: Andrew represented a father accused of three separate counts of attempted rape of his daughter. This was a complex case involving third party phone data, applications for adverse inferences arising from factory re-setting phones and cognitive difficulties. After Andrew’s representation following an 8 day trial, no findings were made against his client and the Local Authority’s factual case found not proven. Re C & M [2024]: Andrew represented an intervenor in a Non-Accidental Injury case concerning significant facial bruising to a 20-month-old child. There had been four intervenors however by the time the trial concluded, only Andrew’s client and the mother remained in the pool of perpetrators. The case against Andrew’s client was found not proven. Re B [2023]: Andrew represented a Local Authority in a legally complex case where there was a positively assessed special guardian, and a known prospective adopter, neither of which the child lived with at the time of the final hearing. Andrew successfully obtained care and placement orders on behalf of the Local Authority following legal argument. Re DS [2022]: Andrew represented a father where allegations were made of the most serious form of sexual abuse against both him and his brother in law. After a 10 day fact find where two sets of care proceedings were consolidated, no findings were made against Andrew’s client, who was exonerated, immediately allowed to return to the family home and the care proceedings were dismissed. Re LM [2022]: Andrew, led by Kings Counsel, gave difficult advice to compromise an appeal brought against his client in the Court of Appeal, recognising the decision of the first instance Judge and the actions of his client was not sustainable in law. Re RM [2022]: Andrew represented a father where significant historic findings had been made against him at an earlier fact find hearing and an application for further assessment of him had been refused. Following Andrew’s cross examination at the welfare hearing where care and placement orders were sought, the Judge acceded to Andrew’s application for expert risk assessment and an adjournment of the final hearing for that assessment to be completed. Re D [2022]: Andrew represented maternal family members during a lengthy welfare hearing at the High Court to determine where a child would live following the killing of her mother by the father. The father was held on remand for murder throughout the duration of the trial. Re C [2022]: Andrew sought an order for adoption on behalf of foster carers in a very complex case where the foster carers had cared for a child for almost 3 years at the time of the hearing, but where there was a positively assessed family member and the added complexity of linked care proceedings in relation to a sibling child being heard at the same time. Re E [2021]: Andrew represented a mother, led by Kings Counsel, where the parents were in the pool of possible perpetrators following discovery of two rib fracture during a routine X-Ray. Andrew’s team brought about the withdrawal of the case by the Local Authority and the parents were exonerated. Re T [2021]: Andrew successfully sought the transfer of living arrangements for two sibling children from the mother to the father where there had been earlier findings of parental alienation and a failed therapeutic process. Re RN [2021]: Andrew successfully sought findings on behalf of his client of the falsification of various allegations of domestic abuse including that the mother had falsified an allegation of attempted murder. Re L [2021]: Andrew dealt with a complex conjoined cases where the birth parents sought contact with a previously adopted sibling group in private proceedings at the same time as adoptive family were involved in public law proceedings following the breakdown of the adoptive placement. Re CE [2020]: Andrew appeared for a mother, accused of parental alienation as assessed by a psychologist. Andrew was instructed late in the proceedings when a fact find, and welfare hearing were listed. His advice, and representation brought about agreement to the proceedings and resulted in the vacating of the fact find hearing and the child remaining in the care of his client. Re B [2020]: On behalf of the children, Andrew successfully opposed an appeal brought by the parents and the children were removed into foster care and the conclusion of the appellate process. Re TE [2020]: Andrew represented a father who faced a number of allegations of domestic violence over a decade. Following the fact find hearing the court found those allegations not proven and went on to find the mother was the aggressor in the relationship. Re J [2020]: Andrew appeared as junior for a father to the sibling of a murdered child in the High Court. The case involved complex issues of non-disclosure, significant police disclosure, and a forensic enquiry into the conduct of foster carers at the welfare stage. Re P [2019]: Andrew acted for the children where he sought the transfer of living arrangements of two children who were living with the mother to their father’s care. This was a complex parental alienation case where the mother had previously made serious allegations of abuse against the father. The children were successfully transitioned at the conclusion of the case. Re H [2019]: Andrew appeared for a mother who made allegations of significant domestic violence and coercive control, including gaslighting and influence of the child. The proceedings had jurisdictional issues and the court ultimately found all the allegations made by the mother proven. Re RJ [2018]: Andrew represented a father in a parental alienation case who faced twelve allegations of physical abuse against his child made by the mother. The court found none of these allegations proven and went on to find that the mother had alienated the children from the father and that the child was at risk of significant harm in the care of the mother. Re PD [2018]: Andrew appeared on behalf of the mother and successfully sought an order for no direct contact between a child and her father. The court made the order sought by Andrew following his cross examination of a consultant psychiatrist, community psychiatric nurse, and CAFCASS officer who had all recommended that there be direct contact between the father and the child.

Angel Matoke-Njagi

Dr Angel Matoke-Njagi joined 3PB’s Birmingham office after successfully completing a 12-month pupillage with 3PB. Angel is a member of 3PB’s Family Law Group and accepts instructions in all areas of family law. She has a keen interest in financial remedies and private and public children law. Angel has experience with financial remedies proceedings under the Matrimonial Causes Act 1973 and the Matrimonial and Family Proceedings Act 1984, private children law disputes concerning children from first hearing dispute resolution appointments to final hearings, and family law injunctions from directions appointments to final hearings. Angel has been commended for her client care skills, including her positive, pragmatic, reassuring manner and ability to build a rapport with clients quickly. She has experience supporting clients with a full range of cognitive abilities through difficult and upsetting cases and providing them with realistic, practical, and sensitive advice. Angel’s interpersonal skills have enabled her to efficiently negotiate with opponents and litigants in person to ensure excellent outcomes for clients. Her experience of criminal law in pupillage, in which she secured acquittals, has enabled Angel to develop thorough and robust cross-examination skills that are an asset in contested final hearings. In academia, Angel taught law undergraduates at the University of Warwick about the English Legal System and Constitutional and Administrative Law. Angel left academia to become a barrister after being awarded the Cassel Scholarship and BPP Pro Bono Award. The latter was awarded in recognition of her strides in volunteering and teaching. Angel volunteered for the Office of the State Public Defender in Mississippi, the Personal Support Unit, and the University of Kent's Law Clinic, among others. Angel has drafted threshold documents, schedules of allegations, grounds of appeal, skeleton arguments on family matters, such as ToLATA, and advice on various issues, including parental alienation. Outside work, Angel uses movement (yoga, walking, and weightlifting) to find moments of peace in a busy world. Family Angel is a busy member of 3PB’s Family Law Group. She has a keen interest in all areas of family law. Angel’s recent successes include: A three-year non-molestation order and findings made against a respondent following Angel’s cross-examination of him. Settlement at a financial dispute resolution appointment with a 78/22 division of the net proceeds of the sale of the former matrimonial home (the only property in the marriage) in favour of her client. Obtaining freezing orders and third-party disclosure orders in financial remedies proceedings. Obtaining no orders for contact (save through letterbox) at Dispute Resolution Appointments and Final Hearings. Persuading the tribunal that a fact-finding hearing was necessary and proportionate against CAFCASS’s recommendation due to allegations of domestic abuse. Obtaining live with orders and spend time with orders in line with what was sought by the applicant. Obtaining prohibited steps orders to prevent respondents from removing the children from the care of the applicant or an institution entrusted with the care of the children. Resisting an application for more contact than the parties had agreed in mediation. Negotiating non-molestation orders by consent for applicants, despite previous reluctance to consent from respondents. Acquiring an order specifying that the applicant would remain with the child’s passport and that the respondent had to inform the applicant before applying for a foreign passport.

Ashley Blood-Halvorsen

Ashley Blood-Halvorsen (TEP) specialises in property and chancery disputes with particular emphasis in contentious probate, TOLATA and insolvency. She is down to earth, approachable and connects well with lay clients who are often appearing in court for the first time. Part of her customer service offering is being responsive and providing advice that is straight to the point. Ashley is a prize winning barrister, having been awarded both the Nicholas Pumfrey Memorial Scholarship and the Blackstone Entrance Scholarship by Middle Temple, and the Dean’s Bar Professional Training Course (BPTC) Scholarship. In addition, she won the Baron Dr Ver Heyden de Lancey Prize as the best Middle Temple student on the BPTC at her centre. Publications Clawing Back the Cash — The Test for Permission to Challenge a Trustee in Bankruptcy's Remuneration — A Look at Singh v Hicken Article published on Feb 11, 2019 in the Corporate Rescue and Insolvency Journal - Citation: (2019) 1 CRI 8. Authors: James Davies and Ashley Blood-Halvorsen Cannabis: A look at sweeping global change Published in June 2019 as a paper for the working party of the Society of Conservative Lawyers. Forward written by Victoria Prentis MP. Ashley is a guest editor of the Surveyors chapter of the Encyclopaedia of Professional Partnerships by Sweet & Maxwell. Academia Ashley read history at the University of Toronto, where she specialised in the history of religion. She relocated to England in 2011 to study law and graduated top of her class, winning the Sweet & Maxwell Law Prize as the top performing final year student. During her law degree she spent a summer studying civil law in France at Paris II-Panthéon Assas University (Sorbonne). She was awarded a scholarship from the Fondation pour le Droit Continental to attend. Interests Outside work, Ashley’s varied interests include Jewish apocalyptic literature, Freddie Mercury and day trading stocks on listed exchanges. Property and Estates Ashley Blood-Halvorsen specialises in business and property disputes with particular emphasis in property & estates and contentious probate. Read more about Ashley's expertise in her specialist profiles below. Ashley Blood-Halvorsen (TEP) has a strong understanding of - and caseload in - all aspects of contentious probate and estates work, advising and representing individuals. Before qualifying as a barrister, she spent some time working for a firm tracing beneficiaries to estates. She acts for clients in respect of a range of estates, from those of a modest value through to those involving substantial sums and including estates with an international aspect. Her practice covers all areas regarding the validity of wills and testamentary dispositions, both as regards the necessary formalities and in respect of the substantive validity, and she also advises on the interpretation and construction of wills and other instruments. Ashley has undertaken many Inheritance Act cases and has a firm understanding and extensive experience of TOLATA claims. She is a full member of STEP, and earlier earned a merit in her Taxation of Trusts and Estates exam. Cases include: Obtaining a freezing injunction in relation to monies arising out of a sale of a trust property. Drafting a particulars of claim regarding breach of trust in the sale of a property from an estate. Advising on and appearing in hearings for the removal of trustees and executors. Providing advice regarding a beneficiaries entitlement to commence possession proceedings regarding a residential property. Advising executors regarding potential inheritance act claims and claims of historic devastavit with limitation elements. Advising claimants regarding inheritance act claims by: Adult children and those who were maintained by the deceased; Cohabitees of the deceased; Spouses of a polygamous marriage entered into outside of England and Wales. She has given talks regarding: ‘DIY Will Drafting and Digital Assets – what can go wrong?’ in connection with STEP East Midlands ‘The cost of dying - litigation costs in Probate and Inheritance Act claims’ She can provide quantum advices for infant settlement hearings when a compromise has been made on behalf of minor children in Inheritance (Provision for Family and Dependants) Act 1975 claims. Cases include: Re Estate of GB Advised, and drafted particulars of claim regarding a breach of trust, fiduciary duty, devastavit and fraud of an executor. Ashley subsequently successfully represented the Claimants in a summary judgment application in the High Court. Re Estate of JC Part 8 proceedings regarding the construction of a clause in a will and whether or not a trust is properly constituted. Re Estate of EJ Advising an executor regarding potential claims on the estate from a beneficiary in Australia. Re Estate of MS Advising an executor regarding a 1975 claim from a polygamous wife with a severely disabled child. Re Estate of KS Representing the adult child who was maintained by the deceased in 1975 proceedings. Successfully resisted a strike out application in the High Court. Re Estate of PB Advised in a 1975 claim involving a cohabitee and a separated spouse. Questions over what formed part of the net estate. Re Estate of PS Advising in a 1975 claim involving a cohabitee who has a legal interest in the joint property. Dispute about whether the applicant is entitled to a life interest. She is willing to consider matters on a Conditional Fee Arrangement in appropriate cases. Ashley also routinely appears in mediations for her clients. Coownership and Trusts of Land Ashley regularly advises on and appears in Trusts of Land and Appointment of Trustees Act 1996 (TOLATA) claims. She has experience of occupation rent claims and where there has been a failure to pay the mortgage by one party. She also has experience of where on party alleges that they were engaged so to rely on the Matrimonial Proceedings and Property Act 1970 this can involve issues around non-qualifying ceremonies. She acts for parties in mediation and alternative dispute resolution. Cases include: M v M Dispute between a father and son regarding various properties, promissory estoppel, and constructive trusts with an international element. The matter started as a small claim and was transferred to the multi-track. Proceedings were settled after Ashley drafted a Reply to the Amended Defence. DH v PP Dispute between former cohabiting couple and whether or not there was a common intention constructive trust. SH v ZM Dispute between a former couple which included significant analysis of financial statements, taking of an account and occupation rent. DY v MH Dispute between former cohabitating couple where it was alleged that there was an engagement which was denied. There was an argument about whether a ‘garden office’ constituted a substantial improvement to the property. The matter was settled in a mediation in which Ashley appeared. JF v MR and KR A matter which concerned express declaration of trust between a mother and son with the former girlfriend. Arguments surrounding running an equitable account before the relationship breakdown to take into account significant unmet contributions made by one party. RM v PB A dispute about jointly held property and whether an unsigned declaration of trust constituted a ‘settled agreement’ between the parties. Satellite arguments over estoppel and whether there has been detriment. The property was in negative equity the majority of time since purchase. Land and Boundaries Ashley acts for businesses and individuals in respects of, right of access, rights of way, and boundary disputes. Recent work includes: Interference with a right of way involving cross-examination of a claimant who accepted that the alleged interference was not substantial. Advising a charity regarding interference with an easement and derogation from grant. Drafting statement of cases for boundary disputes and advising on Part 36 offers. Interpreting rights of way within title deeds and TR1s. Advising regarding an easement for the supply of where the servient tenement freeholder threatened to interrupt the supply for which an injunction was obtained. Advising regarding a ‘property hijack’ fraud and the right to an indemnity under the Land Registration indemnity scheme. She also acts in matters regarding conveyancing disputes including third party claims of overreaching rights. She has a particular interest in easements including the construction thereof. Commercial Landlord and Tenant Ashley Blood-Halvorsen accepts instructions on behalf of both landlords and tenants and has experience in dealing with possession and forfeiture claims, and injunctive relief. Recent work includes: Advising on lease extensions pursuant to the Landlord and Tenant Act 1954 including what is meant by in occupation for the purpose of its business. Relief from forfeiture hearings. Proceedings where there has been unauthorised Airbnb use. Obtaining an emergency injunction in a commercial landlord and tenant dispute involving the CRAR procedure. Advising on lease extensions pursuant to the Landlord and Tenant Act 1954. Advising whether leases have been forfeited or surrendered and the enforceability of a deed of guarantee where it is irregular. Successfully resisted a claim for loss of bargain related to guaranteed rental income and the repudiation of a lease. Interpreting leases and classifying whether business, residential or common law in relation to holiday lets. Residential Landlord and Tenant Housing Ashley acts on behalf of landlords and tenants in respect of the following areas: Possessions by personal representatives in the context of a death estate. Defending counterclaims arising out of disrepair claims. Appearing in injunction hearings to permit a gas safety inspection. Defending deposit protection claims pursuant to the Housing Act 2004 including where there are multiple tenants and successive tenancies. Matters which involve subletting of properties and which engage section 18 of the Housing Act 1988. Advising landlords in respect of HMOs and the mandatory licensing regime including Rent Repayment Orders. Ashley also regularly appears in mortgage possession hearings on behalf of the lender. She has experience in the First-tier Tribunal (Property Chamber) for breach of covenant proceedings and service charge disputes including the interpretation of long leases. Cases include: GB v AP, NS and EH Currently advising pre-issue a long leaseholder in relation to repairing covenants and enforcement covenants with the freeholder. Interesting point of law in relation to direct enforcement of the repairing covenants against another long leaseholder within the same building who recently died. LS v MC Advising on the interpretation of a lease and supplemental lease for an application to the FTT. Dispute over the reasonableness of service charges and whether the property constitutes a ‘dwelling’ for the purposes of the 1985 Act. Insolvency and bankruptcy Ashley Blood-Halvorsen regularly appears in insolvency hearings such as the winders, bankruptcy hearings, costs arising out of those hearing and application to set aside statutory demands. Her insolvency experience includes applications to annul bankruptcy orders in the context of matrimonial financial remedies. She worked on the reported case of Singh v Hicken [2018] EWHC 3277 (Ch) who represented Mr Hicken. Singh v Hicken concerned a challenge to trustee’s remuneration. Mr Justice Nugee (as he was then) considered the approach to be adopted to such applications, including the applicability of the provisions in the Insolvency Practice Direction dealing with remuneration applications. Family Much of Ashley’s practice overlaps family matters and probate disputes. She regularly advises on TOLATA matters and has appeared in applications to annul bankruptcy order in the context of marital breakdowns. Co-ownership and Trusts of Land Ashley appears in Trusts of Land and Appointment of Trustees Act 1996 (TOLATA) claims. She has experience of occupation rent claims and where there has been a failure to pay the mortgage by one party. She also has experience of where on party alleges that they were engaged so to rely on the Matrimonial Proceedings and Property Act 1970 this can involve issues around non-qualifying ceremonies. She acts for parties in mediation and alternative dispute resolution. Cases include: M v M Dispute between a father and son regarding various properties, promissory estoppel, and constructive trusts with an international element. The matter started as a small claim and was transferred to the multi-track. Proceedings were settled after Ashley drafted a Reply to the Amended Defence. DH v PP Dispute between former cohabiting couple and whether or not there was a common intention constructive trust. SH v ZM Dispute between a former couple which included significant analysis of financial statements, taking of an account and occupation rent. DY v MH Dispute between former cohabitating couple where it was alleged that there was an engagement which was denied. There was an argument about whether a ‘garden office’ constituted a substantial improvement to the property. JF v MR and KR An ongoing case involving an express declaration of trust between a mother and son with the former girlfriend. Arguments surrounding running an equitable account before the relationship breakdown to take into account significant unmet contributions made by one party. Matrimonial Finance Ashley accepts instructions for FDAs and FDRs. She has a particular interest in proceedings involving inherited wealth upon divorce. Her insolvency experience includes applications to annul bankruptcy orders in the context of financial remedies. She is particularly instructed by Intervenors when there is a dispute about the beneficial interest in real property and or trusts. Cases include: ML v CL and The Official Receiver Represented the Husband in an application made by Wife to annul Husband’s bankruptcy. The Wife alleged the Husband made himself bankrupt to frustrate matrimonial finance proceedings. Arguments over whether the Husband was cash flow insolvent and the significance of a Capital Gains Tax liability. RV v KV Represented the Husband at interim hearings regarding an application by a third party to intervene in the matrimonial finance proceedings who was resident in Zimbabwe. Successfully represented Husband at the final hearing. Issues concerning the authenticity of a purported deed of trust, beneficial interest in the former matrimonial home and sharing of the other matrimonial property. Matter was settled on the first day of the final hearing. SD v KD and SN Represented the proposed intervener at a Financial Dispute Resolution hearing. Husband claims he has a beneficial interest in the Intervenor’s property based on claiming monies used for the purchase were not a gift. Ashley continues to represent the Intervenor. SN v PN and SK Represented the Husband at a First Directions Appointment. Identified that there was an arguable case for the Husband’s mother to intervene in the matrimonial finance proceedings on the basis she has a beneficial interest in real property obtained by the couple before they were married. Ashley continues to represent the Husband. Direct Access Ashley Blood-Halvorsen is qualified to accept instructions directly from members of the public and professional clients under the Direct Access (or Public Access) scheme.

Ayesha Bell-Paris

Overview Family barrister Ayesha Bell-Paris is regularly instructed in cases following the breakdown of a relationship and offers a holistic wrap-around service; whether that be resolving the arrangements for children, or the parties’ financial affairs. Ayesha also has significant experience in care/public law proceedings and applications arising from the Family Law Act 1996. Ayesha has a balanced practice and has represented Local Authorities, parents, extended family members, intervenors, cohabitees, divorcees, same sex couples, and children (both directly and via a Guardian). She has been instructed in cases at all levels of allocation, including in the High Court and the Court of Appeal. Ayesha has also assisted clients at mediation, resulting in the resolution of matters without the need for proceedings to be issued. Ayesha is regularly instructed in cases involving complex family dispute issues such as international relocation, parental alienation, substance misuse, mental health issues, domestic violence and non-accidental injury. Ayesha also accepts instructions directly from members of the public under the Direct Access scheme. Outside of chambers, when not kept busy by her two young children, Ayesha enjoys country pursuits, skiing and travelling. She supports and has been a volunteer with the charity, Independent Parental Special Education Advice (IPSEA), which helps children and young people with special educational needs and/or disabilities in England to get the right education. Family Family barrister Ayesha Bell-Paris specialises in disputes over children in both public care or adoption/fostering cases and in privately-funded disputes over parents' financial affairs and suitable arrangements for their children. She focuses on private law children (including cases involving international elements and removal from the UK), matrimonial finance and TOLATA cases. Ayesha has a developed a busy and varied practice advising local authorities, parents, wider family members, children, divorcees and cohabitees. Recent cases include: Reported cases: W-C-T (Children) [2019] EWCA Civ 845 Ayesha acted for a respondent to an appeal following a fact-finding hearing in Care Proceedings whereby findings of sexual abuse had been made against the appellant by a Circuit Judge. The appeal was successfully defended and dismissed by the Court of Appeal. Recent cases: P v F [2022] Ayesha successfully defended an application for an Occupation Order brought by her client’s ex-partner. The court ultimately agreed that Ayesha’s client should remain living in the property and an order was made against the Applicant to vacate the property. Re L [2021] Ayesha acted for a parent in final hearing in Care Proceedings in which the Local Authority sought Care and Placement Orders in respect of the child (supported by the Children’s Guardian) due to concerns in respect of previous longstanding alcohol misuse. The court refused the Local Authority’s application and allowed time for further assessment of the parents. The proceedings concluded with the child being rehabilitated into the parents’ care. Re M [2019] This was a private law dispute involving an application for permanent removal from the Jurisdiction. Ayesha successfully achieved an order permitting her client to relocate to Germany with the subject children and discharge of previous prohibited steps orders. Re B [2019] Ayesha represented a father at a multi-day final hearing in care proceedings in which all other parties supported Care and Placement orders being made in relation to two children. Ayesha successfully persuaded the court to resist making final orders and to direct an independent social work assessment of her client. B v P [2015 & 2018] TOLATA proceedings culminating in a final hearing at which Ayesha obtained an order for sale of a jointly owned property and a favourable division of the equity for her client. Ayesha was instructed in the subsequent enforcement proceedings in which a possession order was obtained and costs awarded. Re R-T [2017] Ayesha represented a mother in care proceedings who was accused of inflicting significant bruising upon her young child. No findings of inflicted injury were made during the fact finding hearing and the proceedings concluded with both subject children being rehabilitated home to her care pursuant to a Supervision Order.

Carol Clelland

Overview A former Director and Head of the Care Department at the law firm Cartwright King, Carol Clelland qualified as a solicitor in 1994 and has over 25 years of experience in family law. She joined 3PB's 70-strong Family Group in February 2020. For the last 20 years Carol has specialised in care and associated proceedings, representing a wide and varied client base consisting of both lay and professional clients. She has represented parents, grandparents and other family members, Guardians, Gillick competent children, intervenors, vulnerable persons via the Official Solicitor and directly as well as Local Authorities. Carol regularly represent clients addressing issues of sexual and physical abuse, non-accidental injuries, chronic neglect, substance misuse, force marriage and honour based violence and cases with international and jurisdictional issues. Carol is a strong advocate who is known for her sound and sensible advice and representation. Cases of Note: Re: Z (Independent Social Work Assessment) [2014] EWCH 729 (Fam) - Representing the father who was an over stayer from India, in a case where a non-mobile child suffered serious multiple injuries that had left her with life changing disabilities. Following an extensive fact findings hearing where a substantial amount of expert evidence was presented to the court the father was exonerated of all wrong doing. He thereafter sought to be assessed to care for his daughter. Such assessment was undertaken by the local authority however we sought to challenge this assessment on behalf of the father as fundamentally flaw and unsafe to be relied upon. At this time the case was in week 72. The court granted the assessment stating as follows:- In any case in which a local authority applies to the court for a care order, the assessment of a parent is of critical importance. That assessment will be a key piece of the evidential jigsaw which informs the local authority’s decision-making, in particular with respect to the formulation of it final care plan. If the assessment is deficient then it is likely to undermine the reliability of the decision-making process. It follows, therefore, that any assessment of a parent must be, and must be seen to been fair, robust and thorough. Was RD’s assessment of the father fair, robust and thorough? In my judgment it was not…… Re: Solihull MBC v S-B [wasted costs] 2016 - Representing a father who was facing serious allegations of sexual abuse of his daughter (S) and son (B) solely on the basis of the daughter demonstrating extreme sexualised behaviour. The son was not demonstrating any such behaviour and the daughter who had specific needs has been exposed to numerous professionals and periods in residential home. The father consistently denied the allegations and argued as follows: i) there was no evidence of sexual abuse; and ii) if S had been sexual abuse there was a significant number of individuals who could be perpetrator of such abuse. Upon adducing the evidence to support his case the father invited the local authority to revise the basis of it’s case to one of S being beyond parental control and discharging the proceedings in respect of B. The Court themselves challenged the Local Authority on more than one occasion as to how it was going to make it’s case out however notwithstanding this the Local Authority continued with the case as originally pleaded and sought findings against the father. Following a full fact hearing the father was fully exonerated, B was returned to his care and the father agreed to S being placed in a specialist residential unit. The father sought costs from the local authority from the date when all the evidence was adduced and he invited the local authority to revise the basis of case to the conclusion of the proceedings. A wasted cost order was made against Solihull MBC with the judge stating as follows:- “In the circumstances I am compelled to the view that an adverse order for cost against SMBC is not only justified but necessary” Care and Adoption Carol Clelland often represents local authorities and parents in complex cases involving expert evidence, serious non-accidental injury to children, cases involving attempted murder, rape, incest, physical violence, FGM, fabricated and induced illness (FII), parents with serious learning disability, sexual abuse, vulnerable parents, and cases with multiple international elements. Carol’s work for such a varied client base has provided her with a depth of knowledge of procedure and practice as well as extensive advocacy skills. She regularly represents parties in care cases involving the following: - Non-accidental injuries and death Sexual abuse Child exploitation and trafficking Force Marriage/Honour violence FMG Chronic neglect, drug and alcohol addiction Mental health issues and personality disorders Domestic Abuse Cross-boarder case/ international element Special Guardianship Adoption Secure accommodation Discharge of care orders/revocation of placement orders Interlocutory applications such as S38 applications/ s34 applications Inherent jurisdiction and Wardship Private Law Carol Clelland is regularly instructed in complex proceedings involving children which include allegations of physical and emotional abuse, sexual abuse, domestic violence and parental alienation. She is used to handling applications where there has been social work involvement after and regularly represents parties in cases involving: R16.4 Guardian - parental alienation/implacable hostility Special Guardianship Removal from the jurisdiction Cross-boarder applications/Hague convention Recovery orders Specific issue orders / Prohibited Steps Order Surrogacy

Charles Hogan

Overview Charles Hogan joined 3PB in November 2021 as an established family law specialist, having built a busy practice at a small chambers in Northampton. He brings experience of complex matters beyond his year of call. Charles combines outstanding academic ability with a pragmatic approach. He has an easy rapport with both lay and professional clients and works hard to achieve the desired outcome. He welcomes instructions in all areas of family law and TOLATA, with a particular focus on family finance and private Children Act applications. Charles has a background in business, having worked in an account management role at a communications company for four years before reading law at the University of Buckingham. He is also frequently involved in the award-winning family business, Hogan's Cider in Alcester, Warwickshire. He is the author of "Trust and Confidence: do we need it? Commonwealth Bank of Australia v Barker [2014] HCA 32" which was published in the Buckingham Student Law Review 2015 Vol 1 pp 19-28. Outside of work, Charles plays guitar and writes songs in a rock band. He follows football and cricket, reluctantly keeps fit and enjoys anything powered by internal combustion. Family Charles Hogan is an established family law specialist, and brings experience of complex matters beyond his year of call. Financial remedies and TOLATA Charles has substantial experience in financial remedies, including the dealing with the following issues: international assets freezing injunctions interveners applications under Part III of the Matrimonial and Family Proceedings Act 1984 separation agreements applications to vary an order for periodical payments disputes as to whether sums advanced by a third party was a loan or a gift pension sharing, including cases involving the instruction of a PODE personal injury damages. He is alive to issues at the early stages of First Appointment, focuses on presenting the client’s case succinctly and powerfully at FDR in order to obtain the best indication and settlement, and provides effective representation at final hearing where a settlement is impossible. Charles can assist with drafting questionnaires and practice direction documents. Charles also advises and represents clients on TOLATA disputes, from the pre-issue stage to final hearing. Significant cases: N v N – Charles represented the wife in a long-running dispute between two Iranian nationals, with competing divorce petitions in Iran and England. There were substantial assets both in the UK and Iran, a freezing injunction in the UK, and an application under Part III of the Matrimonial and Family Proceedings Act 1984 for financial remedy in the UK after a divorce settlement in Iran. F v F – Charles represented the husband in a case where the wife did not engage with financial proceedings. He secured an order for her committal, an order for sale of the family home, and costs at all stages of proceedings, as well as providing advice as to how to obtain a warrant for possession of the family home under CPR 83. C v C – Charles represented the wife in a case where the husband claimed that the mortgage had been paid off by a loan from his father. At final hearing, the court heard the evidence of the father and the parties, and Charles persuaded the court that the sum advanced was in fact a gift. Private child Charles has extensive experience in private Children Act applications, including: Relocation, both internally and internationally Allegations of serious physical and sexual abuse Parental alienation Section 91(14) orders Parentage disputes between same-sex couples Drug and alcohol issues Enforcement applications Charles is very experienced at all stages of proceedings, and has a record of successfully challenging professional recommendations at final hearing. Significant cases: M vs RB and R – Charles represented the second respondent civil partner of the birth mother in an application by the birth mother’s former partner for contact and parental responsibility. A vs T - Charles represented the father accused of historic sexual offences against children in his application for contact, and was successful at the fact-finding hearing in achieving no findings against the father, and ultimately an order for unsupervised contact. K vs M – Charles represented the mother in an application by the father for contact, where the father had made threats to kill the mother, and numerous applications to enforce child arrangements orders. Charles secured an order for the father to have supervised contact only. Injunctions Charles has considerable experience in representing both applicants and respondents in applications for non-molestation orders and occupation orders, and is aware and provides advice at all times as to how these matters interact with other parts of a wider dispute. Charles has also represented a defendant in an application for a gang injunction. Significant cases: B v B – Charles successfully represented the respondent husband, allowing him to return to the family home after an occupation order was granted at an interim stage; K v K – Charles successfully represented the wife at the final hearing of her application for an occupation order, securing her occupation of the family home; West Midlands Police v M – Charles represented a defendant in an application for a gang injunction brought by a Chief Constable under The Policing and Crime Act 2009, settling the matter with undertakings given by the client on favourable terms. Care and adoption Charles has significant experience representing parents at all stages of care proceedings, including multi-day final hearings involving complex issues, including: Drug and alcohol issues, including those heard in the Family Drug and Alcohol Court Mental health issues, including representing clients assisted by intermediaries and advocates Allegations and findings of serious sexual abuse Allegations and findings of serious physical abuse Non-accidental injuries Interim removal Applications for independent assessment Expert psychological and psychiatric evidence Cases where placement abroad is a realistic option Significant cases: Re V – Charles represented the mother as junior counsel in a fact-finding hearing to determine allegations that she committed serious sexual abuse against her children, and had large amounts of indecent images of children on her devices. The evidence included evidence provided by the FBI. Re T – Charles represented the father in the final hearing of his application to discharge a care order, and was instructed on day two of the four-day hearing after the father had ceased instructing his previous solicitor and barrister. The application was unsuccessful, but Charles succeeded in preserving the father’s current favourable contact arrangements. Re A – Charles secured an culturally appropriate independent social work assessment of a Ghanian father in care proceedings after the parenting assessment prepared by the Local Authority did not take sufficient account of the father’s cultural identity and beliefs.

Charlotte Steer

Overview Charlotte Steer is a family law barrister at 3PB based in Oxford. Charlotte completed 11 months of her pupillage at a specialist family law chambers and successfully completed the last month of pupillage in September 2023 at 3PB. Charlotte has developed a busy family law practice in both private and public law proceedings in addition to proceedings under the Family Law Act 1996. Charlotte represents parents, local authority’s and children through their Children’s Guardians at all hearings from first hearing through to contested final hearings. Charlotte regularly deals with cases involving allegations of neglect, physical and emotional abuse, domestic violence, substance misuse and mental health issues. Charlotte also has experience in private law cases involving allegations of parental alienation, in addition to cases involving issues with capacity. Charlotte has been commended for her incredibly thorough preparation and her ability to assimilate complex information and to distil salient facts and arguments into detailed position statements, that have both gravitas and authority, which is far beyond her year of call. Charlotte puts her client's case fearlessly, with both authority and compassion. During pupillage, Charlotte had exposure to the full spectrum of family law proceedings, including both fact find and welfare hearings involving complex non-accidental injury and sexual abuse. Charlotte assisted her pupil supervisor with the preparation of lengthy schedules of inconsistencies, complex position statements, advice on appeal and skeleton arguments. During the first month of her second six, Charlotte successfully appealed a magistrates’ decision to a Circuit Judge. Prior to joining chambers, Charlotte worked as a paralegal in the childcare department of a well-respected Family team at a Northampton law firm. Charlotte worked predominantly on care proceedings, both before and after issue, in addition to rule 16.4 cases and applications for Special Guardianship Orders. After completion of the BPTC, Charlotte worked at a law firm in London and assisted with private family law cases, such as applications under Section 8 of the Children Act 1989 and Divorce and Ancillary relief proceedings, in addition to civil litigation disputes. Outside of work, Charlotte enjoys playing badminton having previously played for her county, going to the gym and spending time with friends. Charlotte enjoys travelling, having undertaken an around the world trip during her gap year and is always keen to explore new places and experience different cultures.

Dorian Day

Overview Dorian specialises in all aspects of work involving familial and relationship breakdown. In particular he is renowned for his representation of parties in cases of complexity with serious allegations of homicide, physical and sexual abuses, in High Court care proceedings. Dorian is also well reputed for complex and high value financial remedy cases. Until 2011 Dorian practiced out of chambers in London where he continues to conduct significant amounts of work. Dorian has 20 years’ experience having practiced in criminal, civil and family law at the highest levels and in the most complex and demanding cases. Dorian’s extensive background and particular expertise is that of a forensic trial lawyer with a methodical approach to preparation, detail, and effective presentation of the key issues in any particular dispute. Dorian combines the ability to offer sensitive sound practical advice backed up by detailed preparation and robust Court presentation in any dispute and is highly respected by both his opponents and the judiciary. Family Public Law Care and Adoption Dorian is highly experienced in complex public law cases under the children and adoption legislation. Dorian thrives and excels were there are allegations of the death of a child (parent or carer), very serious non-accidental physical injury, sexual abuse and trafficking of children. Dorian has particularly concentrated his work in cases involving complex medical issues including FII. Dorian is also very well renowned for cases where there are jurisdictional orders involving the inherent jurisdiction and wardship and where there are international cross-border jurisdictional issues. Private Law Children and Domestic Abuse Dorian has broad and extensive expertise in all aspects of private law children disputes. In particular he is reputed for his representation of children in such disputes. Dorian is particularly sought after for his advice and representation in cases involving international relocation and abduction of children. Dorian offers the ability and duality to advise and represent parties on both the welfare and financial aspects of children cases. Family Finance Team Dorian is a specialist in Financial Remedy matters - his skills encompass driven and guided practical advice to problem solving and detailed preparation and cross-examination in all aspects of financial work. Dorian has experience in conducting claims where there are assets of substance [up to £40 million], trust assets, business interests, intervening parties, cryptocurrency, a foreign or jurisdictional element, estates and also where there are aspects of conduct or asset dissipation raised before or within the proceedings. Dorian also conducts cases involving inheritance provision, TOLATA and Schedule 1 Children Act Claims. Judicial Review Dorian undertakes all aspects of judicial review work particularly in the field of children, families, and decisions by Local Authorities particularly regarding funding and involving policy considerations. In particular Dorian has regularly challenged and advised Local Authorities in relation to decisions pertaining to special guardianship/residence allowances and funding decisions. Dorian's experience and expertise extends to all forms of tribunal challenge including disciplinary decisions made by the police and other professional bodies. Abuse Claims Dorian has long acted for abuse complainants across the country. He covers all strategies of sexual abuse, neglect and death in cases including religious orders, in children’s homes and schools, in foster care, teachers, families, in sporting and voluntary and media organisations. He has acted for vulnerable adults and children abused in long term care and for learning disabled children and young people, as well as in claims against local authorities for failing to remove children at risk. Cases of Note and Interest: The Mother & Anor v Shropshire Council & Anor [2024] EWHC 344 (Fam) P (A Child: Fair Hearing) [2023] EWCA Civ 215 BSA v NVT [2021] EWHC 2202 (Fam) J&H&Ors [2022] EWHC 862 (Fam) Z (A Child) (Surrogacy) [2022] EWFC 18 Re CD [2021] EWFC 112 J v J [MFPA - Interim Provision] [2021] EWFC 78 Re G (Abduction: Consent/Discretion) [2021] EWCA Civ 139 Z (INTERIM CARE ORDER) - [2020] EWCA Civ 1755 A London Borough -v- N [2020] EWHC 2857 (Fam) BSA -and- NVT [2020] EWHC 2906 (Fam) The Local Authority -V- Mother (1) Father (2) Lucy (By Her Children’s Guardian) And Belinda - [2020] EWHC 2801 (Fam) Re Y (Children in Care: Change of Nationality) [2020] EWCA Civ 1038 C.E. AND N.E. - AND - Hampshire County Council [2020] IECA 201 GC v A County Council & Ors [2020] EWCA Civ 848 Hampshire County Council v CE and NE [2020] IECA 100. Irish Court Of Appeal 9.4.20 KT v JB and WB (A Child) [2020] EWFC 14 Cases A, B and C (Adoption: Notification of Fathers and relatives) [2020] EWCA Civ 41 A Local Authority -and- M, F, P and T [2019] EWFC 33 Re S (No. 3) (Care Proceedings) (Article 56: Placement in the Republic of Ireland) [2019] EWFC 36 Hampshire County council v C.E. & anor [2019] IEHC 340 In re S (A Child) (No. 2) [2019] 1 WLR 5045 Hampshire County Council v CE and Others [2019] 1 FLR 636 Re S (Care proceedings: Article 15 Second transfer) [2018] EWHC 3054 (Fam) (29 October 2018) H (Children) [2018] EWFC 61 (18 October 2018) ([2018] EWFC 61 Hampshire County Council v C.E. & Ors [2018] IECA 365 Hampshire County Council v C.E. and N.E. (Urgent preliminary ruling procedure - Jurisdiction, recognition and enforcement of judgments in matters of parental responsibility - International child abduction - Judgment) [2018] EUECJ C-325/18PPU & UK =[2018] WLR(D) 584CFA (Ireland) v F [2018] EWHC 939 (Fam) (12 April 2018) ([2018] EWHC 939 (Fam) AK, Re Human Fertilisation and Embryology Act 2008 [2017] EWHC 1154 (Fam) (28 July 2017) ([2017] 4 WLR 169, [2017] EWHC 1154 (Fam), [2017] WLR(D) 617; From England and Wales High Court (Family Division) N (Children: Welfare Decision), Re [2016] EWFC 44 (23 September 2016) ([2016] EWFC 44; From England and Wales Family Court Local Authority X v HI & Ors [2016] EWHC 1123 (Fam) (12 May 2016) ([2016] EWHC 1123 (Fam), [2016] Fam Law 802, [2017] 1 FLR 1362; From England and Wales High Court (Family Division) Re N (Children) SC [2016] UKSC 15F and J (Children) [2015] EWFC B231 (11 December 2015) ([2015] EWFC B231; From England and Wales Family Court Decisions (other Judges) N (Children : Adoption: Jurisdiction) [2015] EWCA Civ 1112 (02 November 2015) ([2015] EWCA Civ 1112, [2015] Fam Law 1444, [2015] WLR(D) 436, [2016] 1 All ER 1086, [2016] 1 FCR 217, [2016] 1 FLR 621, [2016] 2 WLR 713; From England and Wales Court of Appeal (Civil Division) Decisions F and J (Children) [2015] EWFC B231 E, A And L (Children) [2014] EWHC B22 (Fam) (13 June 2014) ([2014] EWHC B22 (Fam); From England and Wales High Court (Family Division) Decisions E, A And L (Children) [2014] EWHC B21 (Fam) (24 May 2013) ([2014] EWHC B21 (Fam); From England and Wales High Court (Family Division) Decisions London Borough of Lewisham v D & Ors [2010] EWHC 1239 (Fam) (29 March 2010) ([2010] EWHC 1239 (Fam), [2010] Fam Law 795, [2011] 1 FLR 908; From England and Wales High Court (Family Division) Decisions London Borough of Lewisham v D & Ors [2010] EWHC 1238 (Fam) (17 February 2010) ([2010] EWHC 1238 (Fam), [2010] Fam Law 794, [2011] 1 FLR 895; From England and Wales High Court (Family Division) Decisions H (Child), Re [2003] EWCA Civ 1629 (18 November 2003) ([2003] EWCA Civ 1629, [2004] 2 WLR 419, [2004] Fam 89; From England and Wales Court of Appeal (Civil Division) Decisions H (A Child), Re [2002] EWCA Civ 469 (8 March 2002) ([2002] EWCA Civ 469; From England and Wales Court of Appeal (Civil Division) Decisions Articles and Publications “Pay day for the silent army of Special Guardians” - The Ramifications of the Decision in B v LB Lewisham - Family Law 2010 FDR Hearing Service Dorian is available for private remote FDR hearings. For more information on private remote FDR hearings please click here. Property Described as "A very well prepared and skilful advocate." Dorian has a varied property and chancery practice. He thrives and excels where there are challenging & technical issues and is highly experienced in complex cases. His open approach gains favour from solicitors who appreciate easy access to him throughout the course of a case. With over 35 years at the Bar, Dorian has built up extensive experience in many areas of property & chancery work including the following: Landlord & Tenant TOLATA Wills, Probate & Estates Land & Boundary disputes Housing Mortgages Court of Protection Dorian also specialises in professional negligence cases. Dorian undertakes all aspects of judicial review work as well as having considerable expertise in cases involving the Court of Protection. Clinical Negligence Described as "A very well prepared and skilful advocate." Dorian represents clients from inquest stage through to trial taking an active role throughout. Dorian is highly experienced in complex cases. He thrives and excels where there are challenging & technical medical issues. Dorian has an extremely approachable manner ensuring clients are quickly put at ease. His open approach gains favour from solicitors who appreciate easy access to him throughout the course of a case. With over 35 years at the Bar, Dorian has built up extensive experience in many areas of clinical Negligence including the following: Obstetrics and gynaecology Oncology, delayed diagnosis Accident and Emergency ENT General Surgery Orthopaedic surgery Anaesthetics Cardiology General practice Nursing Care Dental Care of psychiatric patients Dorian undertakes all aspects of judicial review work as well as having considerable expertise in cases involving the Court of Protection. Personal Injury Described as "A very well prepared and skilful advocate." Dorian represents clients from inquest stage through to trial taking an active role throughout. Dorian is highly experienced in complex cases. He thrives and excels where there are challenging & technical medical issues. Dorian has an extremely approachable manner ensuring clients are quickly put at ease. His open approach gains favour from solicitors who appreciate easy access to him throughout the course of a case. With over 35 years at the Bar, Dorian has built up extensive experience in many areas of Personal Injury: Abuse Claims Dorian has long acted for abuse complainants across the UK. He advises claimants who are bringing claims of sexual abuse, neglect and death in cases including religious orders, and abuse perpetrated in children’s homes and schools, in foster care, by teachers, within families, or in sporting and voluntary and media organisations. He has acted for vulnerable adults and children abused in long term care and for learning disabled children and young people, as well as in claims against local authorities for failing to remove children at risk. Dorian undertakes all aspects of judicial review work as well as having considerable expertise in cases involving the Court of Protection. Court of Protection Dorian has considerable expertise in cases involving the Court of Protection. Dorian has acted in both welfare matters as well as all aspects of a patient’s property and affairs. Dorian recently lectured on aspects of “Forced Marriage” to the Court of Protection users group. Dorian's combined experience, knowledge and insight in welfare and finance matters in other fields makes him a considerable asset when it comes to issues surrounding vulnerable patients.

Eleanor Marsh

Overview Eleanor Marsh is a busy private law children and financial remedies (including TOLATA) barrister who joined 3PB in November 2022 from another well-known chambers in Birmingham, where she had completed her pupillage. Eleanor is able to develop a strong rapport with clients by being empathetic and approachable; and is routinely described as "diligent", "professional", and "effective" counsel. Eleanor is renowned as a formidable advocate in court; a skill she has developed since she completed a Stage at the European Court of Justice in the cabinet of Advocate General Eleanor Sharpston, conducting legal research in French. A multiple scholarship and awards-winner, Eleanor represented Lincoln’s Inn at the Imperial Open Debating Competition and was a finalist of the Sir Louis Gluckstein Advocacy Competition, Lincoln’s Inn. During her university studies, Eleanor was a human rights volunteer with Projects Abroad leading numerous human rights sessions for marginalised communities and schoolchildren, often working with victims of domestic abuse and leading presentations on police corruption and child labour. Eleanor is appointed as the Lincoln's Inn Circuit Representative for the Midland Circuit, as well as being a Co-opted Bar Representation committee member, representing the Hall on the Post-Call Education Committee. When Eleanor isn't busy working, she enjoys playing the cello, piano or euphonium alongside her husband and two-year-old, who enjoys playing the tambourine beside them! Family Eleanor Marsh is an expert private law children and family finance barrister. Private Law Children Eleanor is regularly instructed on behalf of both parents and children (through their rule 16.4 Guardian) within private law proceedings on the full spectrum of hearings; from first hearings to fact-finding hearings, final contested hearings and appeals. She prides herself on working closely with instructing solicitors for the lay client’s benefit, and always strive to achieve continuity of counsel throughout proceedings. Eleanor regularly deals with matters involving serious allegations of domestic abuse, emotional and physical abuse of a child, and parental alienation; often requiring lengthy and complex fact-finds. For instance, she appeared in the High Court on behalf of a parent, where a party was appealing a Female Genital Mutilation Protection Order made by a Circuit Judge, following a 5-day fact-finding hearing. In summary, Eleanor has been instructed to act in connection with, but not limited to, the following applications: Contact disputes Transfer of living arrangements Applications to vary a Child Arrangements Order Enforcement of contact orders Female Genital Mutilation Protection Orders Specific Issue Orders, including schooling Declarations of Parentage Special Guardianship Appeals Eleanor regularly represents clients seeking non-molestation orders and/or occupation orders, or opposing the same. Recent cases include: Griffiths v Griffiths – represented the child via their 16.4 Guardian at the permission to appeal hearing in relation to the mother’s appeal against an order for her to pay an equal share of the cost of the father’s contact centre contact despite significant findings of domestic abuse. B v B – represented a parent in protracted proceedings involving allegations of sexual abuse against a child. B v A – lengthy private law proceedings where the court changed the child’s residence as result of clear findings of parental alienation. There was extensive involvement from NYAS, and the child had Autism and significant health needs. X v H – protracted private law proceedings involving a 16.4 Guardian including a lengthy fact-find hearing and the making of a Female Genital Mutilation Protection Order. M v G – private law proceedings involving allegations of abuse against the children and their primary carer. Final orders made for indirect contact only. S v W – private law proceedings in which the child had been retained following contact due to safeguarding concerns surrounding alcohol misuse of the other parent. F v L – private law proceedings involving a 16.4 Guardian where delays in listing the final hearing had created a new status quo for the child. Family Finance Eleanor has a busy family finance practice, again appearing in the full spectrum of hearings, appearing on behalf of husbands, wives, and interveners in matrimonial finance cases. She has been instructed on cases involving valuable business assets and overseas properties as well as matters which have involved “add back” arguments and conduct allegations. She is regularly representing clients at the full spectrum of hearings, these have included (but are not limited to): First hearings Interim hearings Section 37 applications FDR appointments Contested final hearings Appeals She has been praised by solicitors for facilitating settlement at FDR when the client has been seemingly intractable; and regularly provides written advice on settlement. She is also known for her empathetic but clear advice; and regularly negotiates fair settlements for her clients, even where there are limited matrimonial assets to be divided. Eleanor also enjoys advising on and appearing in TOLATA matters, both in Court and via written opinion. This has included appearing on behalf of a party on appeal following contested proceedings to determine the beneficial ownership of the former family home. Recent cases include: S v S – represented the respondent in proceedings involving a number of significant factual issues, including: the beneficial ownership of three separate properties, the length of the parties’ cohabitation, contributions arguments in relation to the purchase and running of the FMH, the veracity of significant liabilities, disputed business interests, and allegations of material non-disclosure. B v S - represented the applicant in proceedings where an intervener asserted that they were the sole beneficial owner of the former family home. B v B – represented the applicant in proceedings involving a family home within the jurisdiction and six other properties situated in India where family members had declined to intervene but brought separate court proceedings within India. As well as jurisdictional issues, there were also issues with disclosure and compliance with court orders, resulting in a significant “add back” argument being raised and litigation conduct. D v D – represented the respondent in proceedings involving significant matrimonial assets, including a very successful and valuable business where the wife was seeking the transfer of one of the commercial premises to her sole name. H v H – represented the respondent husband in proceedings where reckless / wanton expenditure had been accepted, but not to the extend sought by the applicant wife. K v N – represented the wife on appeal in relation to the beneficial ownership of the FMH following a trial of preliminary issue hearing.

Elizabeth McGrath KC

Overview Elizabeth McGrath KC (Liz) was called to the bar in 1987 and for over 20 years has practiced exclusively in the field of family law. Liz was appointed Queen's Counsel in 2014. Liz appears regularly in complex high net worth financial remedy cases and has particular expertise in dealing with cases involving private limited companies, partnerships and extensive property and pension portfolios. Liz is often instructed in cases in which there are parallel private law children issues with particular emphasis on ‘residence’, ‘contact’, relocation, LGBT parenting and surrogacy. Liz has extensive expertise in public law, acting for Local Authorities, parents and children in the High Court and the Court of Appeal. She has been instructed in a number of complex fact finding hearings involving allegations of sexual abuse and non-accidental injuries, and has appeared in a number of reported cases. Liz’s vast experience across the field of private and public family law, and her down to earth, approachable manner, is known to inspire confidence in her instructing solicitors and enables her to establish a productive and easy rapport with lay clients. Her thorough approach to preparation means that she is quick to identify the crucial issues in complex cases. Whilst Liz gives firm and fair advice with an eye to early resolution where possible, if proceedings require a judicial decision she has a reputation for concise, robust and effective advocacy. Liz has extensive expertise in public law, acting for Local Authorities, parents and children in the High Court and the Court of Appeal. She has been instructed in a number of complex fact finding hearings involving allegations of sexual abuse and non-accidental injuries, and has appeared in a number of reported cases. Liz’s vast experience across the field of private and public family law, and her down to earth, approachable manner, is known to inspire confidence in her instructing solicitors and enables her to establish a productive and easy rapport with lay clients. Her thorough approach to preparation means that she is quick to identify the crucial issues in complex cases. Whilst Liz gives firm and fair advice with an eye to early resolution where possible, if proceedings require a judicial decision she has a reputation for concise, robust and effective advocacy. Family Liz was called to the bar in 1987 and for over 20 years has practiced exclusively in the field of family law. She appears frequently in complex and sensitive cases involving children (public and private) as well as cases within the financial remedies remit, dealing with issues involving substantial assets and often where the Court is faced with complex factual and expert evidence. Liz has a proven ability to deal with high conflict issues in a calm and professional manner whilst devoting significant energy to her client’s case. Liz is available for work internationally on all family law matters. Reported Cases A Local Authority -v- MM, NM, MC, CM and W, X , Y and Z (Children acting through their Guardian) [2020] EWFC 65 Re ABC (Children: Overlaying Child) [2020] EWFC [57] B-T (A Child: Threshold Conditions) [2020] EWCA Civ 697 RE AA (Children) & 25 Ors [2019] EWFC 64 E (A Child) (Family Proceedings: Evidence), Re [2016] EWCA Civ 473; [2016] 4 W.L.R. 105 Stockport MBC v AM [2016] EWFC 12 A CC v AB [2015] EWFC 82 W (Children) (Adoption: Procedure: Conditions), Re [2015] EWCA Civ 403; [2016] 1 F.L.R. 454; [2015] 3 F.C.R. 99; [2015] Fam. Law 765 Coventry City Council v B [2012] EWHC 4014 (Fam); [2015] 1 F.L.R. 411; [2014] Fam. Law 954 E (A Child) (Wardship Order: Child in Voluntary Accommodation), Re [2012] EWCA Civ 1773; [2013] 2 F.L.R. 63; [2013] Fam. Law 399 K (A Child) (Post Adoption Placement Breakdown), Re [2012] EWHC 4148 (Fam); [2013] 1 F.L.R. 1; [2012] Fam. Law 1450 Coventry City Council v O [2011] EWCA Civ 729; [2012] Fam. 210; [2012] 3 W.L.R. 208; [2012] P.T.S.R. 835; [2011] 2 F.L.R. 936; [2011] 3 F.C.R. 38; [2012] B.L.G.R. 279; [2011] Fam. Law 921; (2011) 108(27) L.S.G. 23; (2011) 161 N.L.J. 952; Times, July 1, 2011; Official Transcript J (A Child) (Care Proceedings: Injuries), Re [2009] EWHC 1383 (Fam); [2009] 2 F.L.R. 99; [2009] Fam. Law 479 Private Law Private Law Children and Domestic Abuse Liz acts for parents and guardians (where appointed) in residence and contact cases of great sensitivity and often where the evidence of expert psychologists or psychiatrists aids the courts determination on welfare issues. She is a fierce advocate in cases involving allegations of sexual abuse and parental alienation. Her vast experience in this field extends to cases involving an international element where clients need to be given comprehensive advice on an urgent basis. Liz has represented clients from a range of backgrounds, including those with learning difficulties, and her experience and maturity enable her to establish a rapport with the client to achieve the best outcome possible. Care and Adoption Public Law Care and Adoption Liz acts for Local Authorities, parents, guardians and grandparents/other interested parties, in cases involving serious non accidental injury, sexual abuse, chronic neglect, death of the child and fabricated and induced illness (FII). Liz is experienced in complex public law cases under the children and adoption legislation, in particular those involving complex medical issues; cases where placement of children outside the jurisdiction is proposed; cases where confidentiality and disclosure are an issue, including restraint of publication by the media and cases involving the use of the inherent jurisdiction of the High Court. Finance Liz acts for wives, husbands and intervenors in cases involving substantial assets and often where the Court is faced with complex factual and expert evidence. In recent years she has specialised in cases involving businesses where the Court has been required to consider forensic accounting evidence in order to value shareholdings and to assess liquidity. She has acted in a number of cases involving minority shareholdings where the issue of quasi partnership has arisen and where contribution arguments have featured. Liz has extensive experience of cases involving significant pension assets where the issue of pension sharing /offset has been the subject of expert actuarial evidence. Her breadth of experience in the field of family finance enables her to give forthright views as to likely outcomes at an early stage in proceedings and in that way to ensure that financial dispute resolutions are as effective as they can be. Liz believes that her expertise in private law children cases can be of significant benefit to those clients facing marital breakdown who need swift advice and able representation on both money and the arrangements for their children, who would prefer to obtain it from one source. FDR Hearing Service Liz is available for private remote FDR hearings. Family Liz was called to the bar in 1987 and for over 20 years has practiced exclusively in the field of family law. She appears frequently in complex and sensitive cases involving children (public and private) as well as cases within the financial remedies remit, dealing with issues involving substantial assets and often where the Court is faced with complex factual and expert evidence. Liz has a proven ability to deal with high conflict issues in a calm and professional manner whilst devoting significant energy to her client’s case. Liz is available for work internationally on all family law matters. Reported Cases P and E (Care Proceedings: Whether to Hold Fact-Finding Hearing), Re [2024] EWCA Civ 403 The Mother & Anor v Shropshire Council & Anor [2024] EWHC 344 (Fam) A Local Authority -v- MM, NM, MC, CM and W, X , Y and Z (Children acting through their Guardian) [2020] EWFC 65 Re ABC (Children: Overlaying Child) [2020] EWFC [57] B-T (A Child: Threshold Conditions) [2020] EWCA Civ 697 RE AA (Children) & 25 Ors [2019] EWFC 64 E (A Child) (Family Proceedings: Evidence), Re [2016] EWCA Civ 473; [2016] 4 W.L.R. 105 Stockport MBC v AM [2016] EWFC 12 A CC v AB [2015] EWFC 82 W (Children) (Adoption: Procedure: Conditions), Re [2015] EWCA Civ 403; [2016] 1 F.L.R. 454; [2015] 3 F.C.R. 99; [2015] Fam. Law 765 Coventry City Council v B [2012] EWHC 4014 (Fam); [2015] 1 F.L.R. 411; [2014] Fam. Law 954 E (A Child) (Wardship Order: Child in Voluntary Accommodation), Re [2012] EWCA Civ 1773; [2013] 2 F.L.R. 63; [2013] Fam. Law 399 K (A Child) (Post Adoption Placement Breakdown), Re [2012] EWHC 4148 (Fam); [2013] 1 F.L.R. 1; [2012] Fam. Law 1450 Coventry City Council v O [2011] EWCA Civ 729; [2012] Fam. 210; [2012] 3 W.L.R. 208; [2012] P.T.S.R. 835; [2011] 2 F.L.R. 936; [2011] 3 F.C.R. 38; [2012] B.L.G.R. 279; [2011] Fam. Law 921; (2011) 108(27) L.S.G. 23; (2011) 161 N.L.J. 952; Times, July 1, 2011; Official Transcript J (A Child) (Care Proceedings: Injuries), Re [2009] EWHC 1383 (Fam); [2009] 2 F.L.R. 99; [2009] Fam. Law 479 Private Law Private Law Children and Domestic Abuse Liz acts for parents and guardians (where appointed) in residence and contact cases of great sensitivity and often where the evidence of expert psychologists or psychiatrists aids the courts determination on welfare issues. She is a fierce advocate in cases involving allegations of sexual abuse and parental alienation. Her vast experience in this field extends to cases involving an international element where clients need to be given comprehensive advice on an urgent basis. Liz has represented clients from a range of backgrounds, including those with learning difficulties, and her experience and maturity enable her to establish a rapport with the client to achieve the best outcome possible. Care and Adoption Public Law Care and Adoption Liz acts for Local Authorities, parents, guardians and grandparents/other interested parties, in cases involving serious non accidental injury, sexual abuse, chronic neglect, death of the child and fabricated and induced illness (FII). Liz is experienced in complex public law cases under the children and adoption legislation, in particular those involving complex medical issues; cases where placement of children outside the jurisdiction is proposed; cases where confidentiality and disclosure are an issue, including restraint of publication by the media and cases involving the use of the inherent jurisdiction of the High Court. Finance Liz acts for wives, husbands and intervenors in cases involving substantial assets and often where the Court is faced with complex factual and expert evidence. In recent years she has specialised in cases involving businesses where the Court has been required to consider forensic accounting evidence in order to value shareholdings and to assess liquidity. She has acted in a number of cases involving minority shareholdings where the issue of quasi partnership has arisen and where contribution arguments have featured. Liz has extensive experience of cases involving significant pension assets where the issue of pension sharing /offset has been the subject of expert actuarial evidence. Her breadth of experience in the field of family finance enables her to give forthright views as to likely outcomes at an early stage in proceedings and in that way to ensure that financial dispute resolutions are as effective as they can be. Liz believes that her expertise in private law children cases can be of significant benefit to those clients facing marital breakdown who need swift advice and able representation on both money and the arrangements for their children, who would prefer to obtain it from one source. FDR Hearing Service Liz is available for private remote FDR hearings. For more information on private remote FDR hearings please click here.

Elizabeth Porteous

Overview Elizabeth Porteous is a barrister in 3PB's family team and is based in the Birmingham office. She joined 3PB in November 2022 from a rival Midlands set where she successfully completed her 12-month family pupillage. Prior to pupillage, Elizabeth worked as a senior legal assistant at Herefordshire Council. Elizabeth worked on a large number of children public law cases at the local authority and already has built a good practice in care and adoption and private law children cases. A mooting competition finalist at University of the West of England (UWE) in Bristol, Elizabeth was appointed head of mooting. At the University of Bristol, she was part of the Human Rights Law Clinic where she undertook in-depth research into a variety of human rights issues, helping to influence ongoing litigation and policymaking. Whilst completing the BPTC at the University of Law in Birmingham, Elizabeth was Head of the Advocacy Committee where she had the responsibility of organising and running mooting competitions and workshops. Elizabeth has volunteered for the charity "Support Through Court", helping litigants in person to issue or defend claims. This involved frequent representation for clients in remote hearings throughout the pandemic. Outside work, Elizabeth enjoys going on long walks and paddle-boarding. She also loves to travel and to attend festivals. Family Elizabeth Porteous completed her family law pupillage at another chambers in the Midlands and joined 3PB in November 2022 to further develop her skills and experience in public and private law children disputes. She has a busy public children and private law children caseload. She plans to conduct cases that include complex allegations requiring robust cross-examination and in-depth analysis. Elizabeth is frequently commended by solicitors for her client care and her ability to rapidly build rapport in often very difficult and upsetting circumstances. She receives excellent feedback from clients for her approachability and ability to provide realistic but sensitive advice. Her approach to clients quickly puts them at ease and enables her to build relationships with opponents and colleagues efficiently. After completing the BPTC, she worked as a paralegal in Herefordshire Council's Legal Department dealing exclusively with public law proceedings, giving her an insight into the complexities of local authority and social work processes. Elizabeth also volunteered with "Support Through Court" at Birmingham Family and County Court, assisting members of the public to fill in legal documents and prepare for court hearings. This experience taught her to communicate and adapt in circumstances when working with people who are often highly emotional and unsure of the family law litigation process.

Emma Shiels

Emma Shiels joined 3PB in September 2024 as a probationary tenant barrister from another well-known chambers on the Midlands Circuit. Emma's practice is primarily focused on property disputes, probate & estates and general commercial. She is frequently instructed in possession actions, housing disrepair matters and injunctions. Emma has an interest in Trusts of Land and Appointment of Trustees Act cases and offers experience of working on matters where equitable accounting arises within ToLATA proceedings. Recently, Emma has successfully negotiated favourable outcomes for clients in a range of civil matters including; matters involving arguments on technical defects (leading to a successful outcome for her clients), mortgage possession claims and matters where there is a dispute surrounding a leasehold agreement. Emma has also represented landlords in the First Tier Tribunal, notably in an appeal against a civil penalty imposed under Section 249a of the Housing Act 1984. As well as general property matters, Emma has also experience in contentious probate matters, recently being involved in a matter listed in the High Court. Emma coaches football at an elite level at Leicester City Football Club’s Academy and is a England Women’s Technical and Future Lionesses Coach. She is fast-developing a niche sports law practice. Using her experience as a player and coach and in dealing with the FA’s disciplinary panels, she is particularly focused in regulatory and disciplinary proceedings frameworks within football as well as other sports. Previously, Emma worked as a secondary school teacher specialising in both mathematics and law. She also has volunteered as an adviser at the Citizens Advice Bureau and the University of Law’s Legal Advice Centre, across a wide range of legal issues including housing matters, debt and family law. Emma has also volunteered as a tribunal advocate, appearing on behalf of clients in appeal hearings. Emma is routinely praised for her advocacy skills and clear concise written work from lay and professional clients alike. Outside of work and in-between practice and coaching football, Emma is learning Spanish and has recently taken up playing the piano - which she mostly enjoys !!

Grant Keyes

Overview Grant is an experienced specialist family law practitioner in public and private children law who joined 3PB in May 2023 from a specialist family law chambers in the Midlands. He represents clients in the Family Court, County Court, High Court and Court of Appeal, having the ability to disseminate the most complex cases into key facts in a calm manner whilst providing clear and realistic advice to the most demanding clients. Before joining the Bar, Grant gained extensive experience in corporate organisations such as American Express, Channel 4 and Accenture where he held Director and senior management roles. Grant always fights for the rights of his clients and uses his forensic approach to complex cases and skilled advocacy whilst maintaining a calm and warm manner with his clients. Grant has the experience of working with the most vulnerable individuals who have suffered significant trauma in their lives, and regularly works with intermediaries on particularly emotionally charged and complex cases. Grant acts on behalf of parents, children’s guardians, children and intervenors in a wide range of cases: • Serious non-accidental injury • Fabricated and/or induced illness • Sexual Abuse • Domestic Violence • Chronic Neglect • Drug and Alcohol Abuse (including FDAC proceedings) • Adoption including Revocation of Adoption • Special Guardianship • Secure Accommodation/Deprivation of Liberty • Child arrangements disputes, including intractable contact disputes Family Grant Keyes is a private and public law children barrister and expert. In public law proceedings, Grant has extensive experience of acting for parents, children’s guardians and interveners in cases that involve complex issues of NAI, physical, sexual and emotional abuse (including parental alienation). Grant is regularly instructed in complex fact-finding cases involving non-accidental injuries both in the County Court and the High Court. He regularly acts for clients with learning or mental health difficulties, including those represented through the Official Solicitor. In private law proceedings, Grant is highly skilled in dealing with Section 8 Children Act 1989 applications, including complex cases involving allegations of sexual abuse and domestic violence and has particular expertise in complex and entrenched cases between parents. Grant has a reputation for his high level of advocacy, demonstrating his forensic ability to find the ‘needle in the haystack’ and to always fight for his client. He is truly client focused and robust in his approach, whilst remaining calm in the ‘eye of the storm’. He cares deeply about his clients and will do what is right whilst always being professional providing advice in a straightforward and direct style. Recent reported cases A Local Authority and MF and F and the child (via their guardian) [2024] EWFC 238 (B) Re "Tim" (Fact-finding Care Proceedings) [2024] EWFC 194 (B) H-W [2023] EWCA Civ 149: ongoing involvement in the case which was voted Family Law Awards' Case of the Year in 2022. Re X, T, A, E &S [2020] EWCA Civ 1680 (Court of Appeal): NAI Fact Finding where judge had erred in his approach. Held that it was not open to the judge to find that T self-harmed as a result of the conduct of the parents. Re S [2020] EWCA Civ 1382 (Court of Appeal): Judge found to had erred in his approach to, and analysis of, the medical evidence and findings of fact relating to a serious head injury suffered by the child. Re H-B-S [2020] EWCA Civ 1027 (Court of Appeal): Judge had been wrong to discharge interim care orders in the middle of a fact finding. Re AB, CD, XB & YD [2020] EWFC 15 (High Court): Fabricated illness and sexual abuse case with a Finding of Fact and client exonerated. Re T (A Child) sub nom OCC v (1) A (Mother) (2) B (Father) (3) T (BY Guardian) (4 & 5) C & D (Paternal Aunt & Uncle) (2017): Successful challenge to foster carers to adopt with child returned to the family. Re P (a child) NCC v (1) LC (2) GA (3) P (a child) (2015): A placement order was made where a two-year old boy’s needs could not be met by either of his parents, who had abused drugs and exposed him to a chaotic lifestyle. Long-term fostering did not have the same level of security. Notable cases (unreported) Re L & T-L 2022: Complex Fact-Finding case including allegations of rape and sexual abuse. Represented challenging client (Father) who did not trust professionals. No findings found in relation to rape and sexual abuse and returned to the family home, despite opposition from the local authority Re S 2019: Complex Fact-Finding case where allegations of sexually abused the children. The very experienced Circuit Judge stated that this is the most difficult case she has ever had to make a judgment on as it involved the future risk of harm of a child that had been in Mother care throughout the proceedings with no issues but sanctioned removal Re S [2015]: Non-accidental injury (fracture) to a 6 month old baby, representing Father and after a 6 day fact-finding and final hearing the family was reunited as a family unit, with the baby returning home. Re A [2015]: Non-accidental injury to a young child (baby shaking) where the client was exonerated from the pool of perpetrators, and two of the children moved to her full time care. Re C [2015]: Rape and sexual assault of teenager, representing Father in a complex case where there were 8 advocates, including 2 Guardians and involving a 13 day fact finding and final hearing where the children were returned to family members.

Hannah Bush

Overview Hannah Bush was called to the Bar in 2007 and began practice in the Midlands in 2008. Hannah accepts instructions in all areas of family law. She has particular experience in dealing with vulnerable clients and cases involving domestic abuse. In 2013, Hannah was awarded a Pegasus Scholarship and spent six months working in New Orleans with lawyers who represent clients on death row. This work developed Hannah’s skills set. In 2014 Hannah took a teaching position on the Bar Professional Training Course. Hannah now combines teaching with practice at the bar. Hannah has much experience in teaching advocacy. She has also delivered advocacy training to junior practitioners in South Africa. In May 2020, Hannah was appointed a Deputy District Judge and a part-time First Tier Tribunal judge after separate competitions. Hannah has an approachable manner, giving practical advice to clients. Family Public Law Care and Adoption Hannah has experience at all stages of proceedings, from emergency applications, fact finding hearings through to final hearings. She has been instructed on behalf of local authorities, parents, children, interveners and other parties in public law matters. Hannah has been instructed on behalf of clients with cognitive impairment or capacity issues. In particular, Hannah has experience in cases involving: Domestic violence Substance abuse Neglect and emotional harm Non accidental injury Sexual abuse Discharge of contact/placement orders Applications for contact post care order/placement order. Issues over the designated local authority. Hannah has experience dealing with applications regarding disclosure. She also has experience of applications under s17 Children Act 1989. Private Law Hannah has much experience dealing with child arrangement matters. She has acted for parents, grandparents, children and other family members. Hannah represents clients from first appointment to final hearing as well as fact finding hearings. Hannah has undertaken cases involving: Intractable disputes between parents regarding where a child should live Allegations of abuse (emotional / physical and sexual) Cases with significant local authority involvement Cases involving relocation (national and international) Hannah has much experience in applications for non-molestation and occupation orders.

Jamie Johnston

Overview Property and commercial barrister Jamie Johnston joined 3PB in April 2022, from a chambers in Newcastle. He is based in their Birmingham office but works across all 3PB locations. He practises in all aspects of property law and commercial disputes, as well as having a strong practice at sports disciplinary hearings. He has a busy practice in the High Court, County Court and tribunals. A recent reported case of Jamie’s was Elias v Blemain Finance [2021] EW Misc 15 (CC). Before coming to the Bar, Jamie spent ten years' building up and then selling a national franchising company. This gives him a first-hand understanding of commercial realities and helped develop the robust negotiation skills which he brings to his legal practice. When not working as a barrister, Jamie maintains his love of sport and continues to train and compete in duathlon events at a national and international level and running competitions in the UK for his age-group, and competed in both the World and European Championships in 2022. Property and Estates Jamie Johnston is a property barrister who combines real-world experience with deep legal knowledge and a forensic attention to detail. He appears frequently in the Business and Property Court, County Court and in the First Tier Tribunal (Property Chamber). Jamie has a strong reputation for acting in cases concerning boundary disputes, restrictive covenant and proprietary estoppel. Jamie has a strong personal interest in landlord and tenant work as he has managed a portfolio of residential property for several years. This experience informs his property practice in all aspects of commercial and residential landlord and tenant work. He recently delivered LexisNexis’ 2023 webinar on commercial rent arrear recoveries. In the past few months, Jamie has: Represented and advised both commercial and residential clients in several trespass and boundary disputes. Advised in a variety of commercial lease issues including breaches of tenancy, forfeiture and service charge liabilities. Contested a possession claim defended on grounds of proprietary estoppel. Represented and advised in a number of cases concerning rights of way and breaches of restrictive covenants. Advised on prospects of appeal to the Lands Tribunal. Drafted pleadings in multiple commercial and residential landlords in possession claims. Acted for several local authorities in the West Midlands and South West England in a range of property disputes. Commerical Jamie has an extensive commercial practice, his experience being forged as a managing director who grew, franchised, and then sold his company before coming to the Bar. Business clients appreciate his instinctive understanding of commercial pressures and realities when providing legal advice. He is frequently instructed in wide range of contractual disputes across multiple sectors, from shareholders and directors’ duties to unpaid invoices and fees. Jamie works as an extension of the clients business to ensure the best outcome within the confines of the case. Regularly instructed to secure a wide range of injunctions, Jamie works to ensure the clients case is in the strongest position to succeed either through negotiations or the Court process. Jamie also has a niche specialism in equine matters, specifically misrepresentation including where there are allegations of withholding information on temperament and declarable vices, and where there has been health information potentially missed in pre-sale veterinary inspections. Recent work includes: A five-day trial concerning the mis-selling of a dressage horse, which included allegations of sedation prior to purchase. Resolving a claim for unpaid invoices through mediation. Drafted pleadings, advised upon and ultimately recovered unpaid fees due to a consultant in a long-running dispute. Advised in a case concerning negligent workmanship and unpaid invoices. Professional Negligence Jamie has experience of advising in a range of professional negligence claims, especially related to property. He has recently advised in: A failure of a conveyancer to investigate the potential presence of a mineshaft in a property purchase. Prospects of a claim against solicitors for failing to draft possession pleadings correctly. A range of negligence claims concerning conveyancing errors and poor drafting of wills. Acting where solicitors have acted in spite of a conflict of interest Sports Jamie Johnston brings extensive experience in elite sport to his sports law practice. He is a Disciplinary Chair for British Cycling and sits on the disciplinary panels for both UK Athletics and British Canoeing. He was also a legal adviser to the British Road Cycling Championships in 2018. As an advocate and disciplinary panelist, Jamie has experience of a wide range of disciplinary matters in sports as diverse as golf, athletics, swimming and cycling. He has worked in cases involving allegations of discrimination & racism, accusations of/purported cheating, violent misconduct and technical code violations. A former professional coach, Jamie has over 20 years’ experience working with athletes at every level, from grassroots to international and junior international competition. He has trained both able-bodied and para-sport athletes. Jamie played national league hockey and now competes in duathlon competitions internationally as well as running races throughout the UK for his age-group. His most sports regulatory work includes: Successfully defending a golfer facing a suspension for alleged cheating. Acting for a swimming club and its executive in disciplinary hearings alleging breaches of NGB regulations. Chairing a disciplinary hearing for a major UK sports body considering alleged discrimination by a member. A lengthy local government misconduct matter with consideration of the Localism Act 2011 and Nolan Principles Adjudicating breaches of sporting regulations by elite athletes Professional discipline and regulatory law Barrister Jamie Johnston represents local councillors in disciplinary procedures concerning serious allegations such as malfeasance, financial mismanagement or discrimination. He is familiar with the interplay and interpretation of the Localism Act 2011, Nolan Principles and principles of natural justice in investigations and hearings. Jamie provides pragmatic guidance with robust representation at all stages of disciplinary proceedings. He is adept at identifying failings in the investigative process and advises clients how to challenge them. He is a forceful advocate throughout any disciplinary procedure, most notably in any final hearings.

Jane Withington

Family barrister Jane Withington (formerly Jane Hayward) joined 3PB in October 2023 and is based in the Birmingham office. Jane brings a wealth of experience to our team, having qualified as a solicitor in October 2006 and practised in family law ever since. Jane was a solicitor for 17 years and was accredited as a member of the Law Society’s Children Panel in January 2014 representing a varied client base including parents, grandparents and other family members, Children’s Guardians, Gillick competent children, vulnerable persons including through the Official Solicitor as well as Local Authorities. Jane's busy practice now focuses on Private Law Children and Public Law Care work, where she will represent both professional and lay clients. She has considerable experience in all matters involving disputes about children, including Care Proceedings involving the local authority and disputes around contact and where a child should live. Jane is a very able advocate and attends court to undertake a variety of court hearings including more complex multi-day hearings and interim and final contested hearings as well as emergency hearings. Jane is highly motivated and strives to provide straightforward, honest and clear advice to clients and to ensure that they fully understand the legal process that they are involved in. Family Former family law solicitor-turned barrister Jane Withington (formerly Jane Hayward), who qualified as a solicitor in 2006, caseload focuses on Private Law Children and Public Law Care work, where she will represent all parties, including local authorities, parents, grandparents and children, among others. Care and Adoption Jane Withington has represented parents, children and local authorities in complex cases including non-accidental injury to children, physical violence, FGM, sexual abuse, and fabricated and induced illness. Jane has represented parties in care proceedings involving: Non-accidental injury and death of a child Child Sexual Exploitation (CSE) Child Criminal Exploitation Parental drug and alcohol addiction FGM Honour based violence Secure accommodation Deprivation of Liberty Adoption Recovery Orders Special Guardianship Discharge of care orders and revocation of placement orders Private Law Children Jane Withington has represented children and parents in cases involving: Domestic abuse Physical harm Rule 16.4 Guardian Parental alienation Special Guardianship Specific Issue Orders Prohibited Steps Orders Child Arrangements Orders

Kate Yeomans

Overview Family barrister Kate Yeomans is an experienced and tenacious advocate with a track record over fifteen years regularly representing  applicants and respondents at all stages of family law proceedings, including multi-day fact-find and final hearings. She joined 3PB in September 2022 and is now developing a family finance practice as well. Kate acts on behalf of local authorities, parents, children’s guardians, competent children and intervenors in a wide range of cases: Chronic neglect Drafting advices and threshold documents Drug and alcohol abuse (including FDAC proceedings) Adoption Special Guardianship Inflicted injuries Domestic Violence Child arrangements disputes, including intractable contact disputes National and International Relocation Parental Alienation Kate is adept at building a rapport with clients swiftly, to ensure that they feel at ease and have confidence in her representation. Whilst maintaining an ability to empathise with her clients over issues that are important to them, she never shies away from delivering robust advice. Whilst recognising the benefits of negotiation and compromise, Kate is a determined and forthright advocate who is always willing and prepared to fight for her clients. Outside of her busy career at the Bar, Kate enjoys a young family and her main sporting interest of horse-riding; and has competed with two of her horses. She also enjoys running and is a die-hard Harry Potter fan. Family Family barrister Kate Yeomans has fifteen years advocacy experience representing applicants and respondents at all stages of family law proceedings, including multi-day fact-find and final hearings. In addition to children and care cases, she is now developing a family finance practice as well. Reported cases: Re C (Interim threshold not crossed) [2019] EWFC B5 (15 February 2019): on behalf of a grandfather, Kate successfully opposed the local authority’s application for an interim care order, where the plan was to remove the subject child from the care of her client for the duration of proceedings. Kate successfully persuaded the Court that interim threshold had not been crossed, thus avoiding the need for public law orders and ensuring that the subject child remained in his grandfather’s care. Northamptonshire County Council v M, L, H, L, & N and E ((originally Re H-L (Summary Dismissal of Care Proceedings) [2019] EWCA Civ 704): following the conclusion of an 8-day Fact-Finding Hearing (which followed the Court of Appeal decision cited above), Kate’s client (the mother) was exonerated from having caused any of the inflicted injuries to her daughter and serious findings were made against the intervenor. As a result, Kate invited the local authority to withdraw their application for public law orders altogether and the case against her client was dismissed in its entirety.

Kevin Pettican

Kevin is a senior commercial barrister with a strong practice focused on commercial litigation and arbitration, personal and corporate insolvency, banking and finance, and property litigation. He is a seasoned trial lawyer with experience of appearing in courts at all levels, up to and including the UK Supreme Court and the Judicial Committee of the Privy Council, as well as arbitral tribunals both in London and internationally. Kevin joined 3PB from a London commercial chambers in September 2024. He has relocated to work from 3PB's Birmingham office, whilst continuing to develop his London-based practice. Before practicing at the independent Bar, Kevin spent two years as an employed barrister in the commercial litigation team of a boutique City of London law firm, followed by five years working within the international arbitration team of US-based law firm WilmerHale. This background means that Kevin understands the expectations of commercial clients in the litigation process and the need for counsel to work as part of an effective team with instructing solicitors to ensure that those expectations are met or exceeded. Kevin prides himself on his ability to devise creative and sometimes novel strategies for overcoming apparently insurmountable difficulties in a case. This is reflected in the fact that clients often come to Kevin at a late stage in the litigation process having become dissatisfied with their previous representatives. In such cases Kevin has often been able to turn things around at trial or on appeal or, where this is not possible, at least get the client to a position where a favourable settlement can be negotiated. Business Financing Kevin is frequently instructed in litigation with banks and financial institutions, especially disputes arising from secured lending and the provision of guarantees. In recent years, Kevin has been instructed in several cases involving disputes as to the terms and/or enforceability of interest rate swap transactions involving the ISDA Master Agreement. Most recently, in Deutsche Bank AG London v Comune di Busto Arsizio [2021] EWHC 2706 (Comm) Kevin was instructed (with Paul Downes KC) by an Italian local authority in Commercial Court litigation concerning the enforceability of two interest rate swaps. This was the first case in which the Commercial Court considered the effect of the decision of the Joint Divisions of the Italian Supreme Court in the Cattolica case (Case No. 8770/20220). Kevin acted (with Romie Tager KC) for the successful appellants in Szepietowski v The National Crime Agency [2013] UKSC 65; [2014] 1 AC 338, which is the leading case on the equitable doctrine of marshalling. Whilst the marshalling of charges is something that normally takes place in the context of secured lending, the case raised complex issues arising from a settlement agreement between Kevin’s clients and the National Crime Agency. Insolvency an Bankruptcy Insolvency & restructuring Kevin Pettican is regularly instructed in disputes arising in the personal and corporate insolvency context. His experience includes: Applications to set aside statutory demands Applications to restrain the presentation/advertisement of winding up petitions Contested bankruptcy and winding up petitions Matters arising during the insolvency process, including resisting applications by office holders to conduct private examinations under s236 and s366 of the Insolvency Act 1986, as well as representing individuals in such examinations Issues concerning the appointment of administrators and their powers Transaction avoidance claims by office holders Claims by trustees in bankruptcy Claims by office holders against former directors for fraudulent and/or wrongful trading and misfeasance Directors disqualification proceedings Reported cases Re: JD Group Ltd [2023]: Acting for a former director in a substantial claim by a liquidator alleging fraudulent trading and misfeasance in the context of an alleged MTIC fraud. Hira v Kanzai Securities Ltd [2017] EWHC 2213 (Ch): Successful defence of an appeal against an order refusing to set aside a statutory demand where the debtor was arguing that his liability under the personal guarantee did not give rise to a liquidated debt. The Law Society v Beller [2014] EWHC 3923 (Ch); [2014] BPIR 1480: Successful defence of a claim by the Law Society to recover a fund representing the work in progress of a solicitor’s former practice. The case raised complex issues concerning the relationship between an IVA entered by the former solicitor and the statutory trust that arose following the Law Society’s intervention in his practice. Re: Legal & Equitable Securities plc. (in Liquidation) [2012] EWHC 910 (Ch); (2012) 109 (24) L.S.G 22: A successful challenge to a liquidator’s refusal to admit the applicant as a contingent creditor based on a contractual indemnity. The case is significant in terms of the meaning of a contingent liability for the purposes of Rule 13.12 of the Insolvency Rules 1986. Re: RC Realisations (2011) Ltd: Acting for an Italian company in proceedings arising from the decision of the administrators of RC Realisations to refuse to admit a substantial claim. The case (which settled) concerned the impact of the EU sanctions regime against Iran on two international trade agreements. Beller v Valentine [2011] EWHC 2397; [2012] BPIR 15: Acting for a former solicitor in a claim for outstanding fees against a liquidator in the context of a third-party funding arrangement. The case is significant in terms of its consideration of the potential liability of an office holder who instructs solicitors in reliance on third party funding. Civil fraud & asset recovery Kevin is frequently instructed in commercial cases in which fraud is alleged or which involve the recovery of assets. Reported cases Re: JD Group Ltd [2023]: Acting for a former director in a substantial claim by a liquidator alleging fraudulent trading and misfeasance in the context of an alleged MTIC fraud. Winter v Hockley Mint Ltd [2019] 1 WLR 1617: The litigation involved claims of deceit and conspiracy in the context of office equipment leases. Kevin acted for the successful appellant and the decision of the Court of Appeal is a leading authority on the circumstances in which a principal is vicariously liable for the fraud of his agent. Szepietowski v The National Crime Agency [2014] 1 AC 338: A successful appeal to the Supreme Court (together with Romie Tager KC) in what is now the leading case on the equitable doctrine of marshalling. The case raised complex issues arising from a settlement of asset recovery proceedings that was originally brought against Kevin’s client by the National Crime Agency. Kinch v Rosling & Ors [2019] EWHC 286: Successful claim on behalf of Leicestershire businessman Gilbert Kinch who had been the victim of an advanced fee fraud in connection with a failed bid to acquire Leicester City Football Club. Al Baho & Ors v Meerza [2011] EWHC 2984: Acting for a Kuwaiti national, a member of the ruling family of Kuwait and a former English solicitor in litigation arising from the sale of a London property in which it was alleged that the purchaser had paid a bribe and a secret commission had been received. The dispute gave rise to proceedings in the Chancery Division, the Queen’s Bench Division (for defamation), as well as proceedings in Kuwait. Commercial Kevin Pettican is a commercial litigator with 30 years of experience in litigating and arbitrating business disputes before courts at all levels up to and including the Supreme Court, and before arbitral tribunals both in the UK and internationally. Whilst Kevin particularly enjoys preparing for and conducting trials, he is a versatile advocate who is equally at home in the applications court, or argument a novel point of law before the Court of Appeal. In all his cases, Kevin seeks to adopt a persuasive and direct approach to advocacy, based on intensive prior preparation. Reported cases Deutsche Bank AG London v Comune di Busto Arsizio [2021] EWHC 2706 (Comm): Kevin was instructed (together with Paul Downes KC) by an Italian local authority in Commercial Court litigation concerning the enforceability of two interest rate swaps. This was the first case in which the English Commercial Court considered the effect of the decision of the Joint Divisions of the Italian Supreme Court in the Cattolica case (Case No. 8770/20220). NaturaStudios Ltd v The New York Laser Clinic Ltd [2019] EWCA Civ 421: This was a dispute concerning the supply of laser equipment to the claimant. Kevin successfully appealed against a decision by the Deputy High Court Judge that permitted the claimant to substantially change its case shortly before trial. Kevin was able to secure from the Court of Appeal a substantial adjournment of the trial and, thereafter, appropriate case management directions. Winter v Hockley Mint Ltd [2019] 1 WLR 1617: Kevin acted for an office equipment supplier in a substantial trial in the Chancery Division involving allegations of deceit and conspiracy in the context of office equipment leasing agreements. The allegations of wrongdoing against Kevin’s client were dismissed at trial and a finding by the trial judge that Kevin’s client was vicariously liable for the actions of one of the other defendants was set aside by the Court of Appeal. The Court of Appeal’s decision in this case is a leading authority on the circumstances in which a principal will be liable for the fraud of his agent in a commercial context. Dondore Incorporated v Fetaimia [2018] EWHC 1832 (Ch): This was a dispute over whether an oral agreement had been made (and performed) for the sale and purchase of the shares in a BVI company that owned a £2.5 million flat in Knightsbridge. Following a 5-day trial in the Chancery Division, the court found that Kevin’s client had entered into an oral agreement with the claimant to purchase the shares in the BVI company that owned the flat, and that the purchase price had been paid to an African company controlled by the claimant. The Ritz Hotel Casino Ltd v Al-Geabury [2015] EWHC 2294: Acting for the defendant in litigation with the Ritz Club arising from multi-million-pound gambling losses. The case gave rise to complex issues concerning the duties owed by a casino to a self-excluded customer under the Gambling Act 2005. Szepietowski v The National Crime Agency [2014] 1 AC 338: A successful appeal to the Supreme Court (together with Romie Tager KC) in what is now the leading case on the equitable doctrine of marshalling. The case also raised complex issues of construction arising from a settlement agreement entered between Kevin’s client and the National Crime Agency. Trident Australasia Pty Ltd v Versabuild LLC [2013] EWHC 4838: Security for costs in circumstances where there were no publicly available financial statements relating to the claimant. The issue arose in the context of a dispute between the partners to an international joint venture. Street v Larkins [2013] EWHC 1408: A dispute between the members of an alleged family partnership arising from the sale and purchase of property in London over a number of years. Re Giambrone LLP: Acting for various claimants in proceedings for professional negligence against a firm of Registered European Lawyers arising from losses suffered in relation to the purchase of off-plan holiday homes in Calabria, including making one of the first successful applications for summary judgment. Company/ Partnership law and Disputes Kevin Pettican is often instructed in disputes that arise in a company law context or which arise between partners (or the members of LLPs). Most commonly, these claims involve disputes between shareholders in which relief is sought pursuant to s994 of the Companies 2006, or in which an order is sought for the winding up of the company on the just an equitable ground. However, Kevin has been involved in a number of claims where disputes have arisen between partners (including disputes as to whether a partnership exists at all) or between members of an LLP. For example, Street v Larkins [2013] EWHC 1408 concerned a dispute as to whether a partnership had come into being because of various property dealings undertaken by various family members, and Simmons Gainsford LLP v Shah [2008] EWHC 2554 concerned a dispute between a firm of accountants and a former member of the LLP concerning entitlement to the proceeds of a life insurance policy. Property and Estates Real property disputes form a significant part of Kevin’s practice. Kevin has experience in the following areas: Commercial leases, especially contested lease renewals, forfeiture, arrears of rent and dilapidations claims Residential leases, especially disputes concerning the enforcement of covenants in long leaseholds Claims for specific performance of agreements for the sale and purchase of land Title disputes, including claims based on adverse possession Disputes between co-owners Boundary/neighbour disputes Mortgages and charges Reported cases Malik v Malik: a long-running family dispute concerning the disputed ownership of a valuable leasehold flat in Knightsbridge giving rise to some complex issues concerning the application of the law of adverse possession to leasehold property. Dondore Incorporated v Fetaimia [2018] EWHC 1832 (Ch): Successful defence of a possession claim tried over 5 days in the Chancery Division concerning the ultimate beneficial ownership of a £2.5 million flat in Knightsbridge. The court found that Kevin’s client had entered into an oral agreement with the claimant to purchase the shares in a BVI company that owned the flat, and that the purchase price had been paid to an African company controlled by the claimant. Ashley Gardens Freeholds Ltd v Landor (2017) Central London County Court: Successful claim for forfeiture of a long residential lease on the grounds that, by using the flat to operate a B&B business, the leaseholder was in breach of a user covenant prohibiting the use of the flat “for any purpose whatsoever other than as a private residential flat in one occupation”. The leaseholder was granted relief on terms that she sold the flat within six months of the judgment to avoid the freeholder obtaining a windfall at her expense. The case received substantial press attention. King v Robertson [2014] UKPC 34: An appeal to the Privy Council from the courts of St Vincent and the Grenadines concerning adverse possession of land.

Laura Scott

Overview Family barrister Laura Scott practises exclusively in children and domestic violence law and has extensive experience representing parents, grandparents, children, guardians, extended family members and local authorities in all aspects of the law relating to children. Formerly at two well-known London sets, Laura now lives in the Midlands and joined 3PB in August 2022. Laura has been consistently ranked as a top family law barrister by legal researchers at Legal 500, focusing on her public and private child care work and cases involving children where there are allegations or evidence of abuse. Outside of work, Laura is a yoga and meditation teacher; she plays the drums and orchestral percussion and enjoys the cinema. Family Private Law Children Laura Scott is experienced in dealing with all aspects of child arrangements (including residence and contact, now known as ‘lives with’ and ‘spends time with’ orders), domestic violence allegations, extended family care arrangements (including grandparents’ applications for contact and residence), special guardianship, private adoption and applications for permission to remove children temporarily and permanently from England. She has extensive experience of cases involving allegations of parental alienation, having been involved in one of the first cases in which alienation allegations were proved against a father and became care proceedings. In another of her cases, Laura successfully challenged allegations of alienation made against a mother previously found to have been a victim of domestic abuse. Laura is regularly instructed in complex matters involving allegations of emotional, physical and sexual abuse, as well as cases where the representation and joinder of children to proceedings is an issue and where a change of the child’s residence is contemplated. Laura’s work often involves an international element and her practice encompasses applications by parents for leave to remove children permanently or temporarily from the jurisdiction. Non-court dispute resolution Having trained as a mediator over a decade ago, Laura strongly believes in the importance of avoiding litigation wherever possible and will always strive to give clients realistic advice on how to achieve an outcome that will meet their children’s best interests in the short and long-term. Laura offers a range of collaborative services to support separating parents, including round table discussions, non-court negotiations and single lawyer instructions for both parents; she will make recommendations for the most appropriate mediators for a family’s particular issues as well as for therapeutic support where indicated. Laura supports the use of arbitration as a highly effective alternative where court proceedings are contemplated and can advise parties on who best to instruct. Direct Access Laura was one of the first barristers to undertake family cases via the Direct Public Access scheme and has a wealth of experience working directly with parents, collaborating with and referring to solicitors where necessary. Reported cases: X v Y & Others (Assisted Reproduction: Parent) [2015] EWFC 13 (Fam): High Court declarations of parentage made in respect of father whose child was conceived using donated sperm, in circumstances where he had signed a consent form, which the fertility clinic had lost. K v P [2008] EWCA Civ 600: Court of Appeal decision relating to the length of sentence imposed in respect of breaches of a non-molestation order to which a power of arrest was attached. Re C-J (Section 91(14) Order) [2006] EWHC 1491 (Fam); [2006] 2 FLR 1213: Contact – appropriateness of s91 (14) order – exercise of district judge’s discretion. Other cases include: Re P [2021]: Acted for the child through their guardian in a matter where the immediate transfer of residence had been ordered after findings of parental alienation; subsequent agreement for contact with alienating parent reached through extensive negotiations with litigants in person. Re M [2021]: Acted for a mother in a case of very serious parental alienation and unlawful retention where a local authority was compelled to take ICOs for 2 children at the court’s own motion and care proceedings then followed. Re J [2016]: Acted for the father in seeking and obtaining parental alienation and physical abuse findings against a mother. Public Law Children Laura acts in matters involving all aspects of care and adoption, especially complex cases where there are allegations of non-accidental injuries and physical, sexual and emotional abuse, including historic allegations. She is highly adept at working with parties that have experienced trauma, having studied extensively the effects and implications of adverse life and childhood experiences (ACE). Laura will go above and beyond to forge and develop compassionate and supportive working relationships with clients who are all too often dismissed as ‘difficult’ as a consequence of their own traumatic childhoods. Laura is frequently instructed for fact-finding hearings and is adept at handling expert witnesses and voluminous medical evidence. Laura has a particular interest and expertise in dealing with vulnerable parties and witnesses, including children and those requiring the assistance of an intermediary. Laura regularly undertakes Deprivation of Liberty Safeguards (DoLS) cases. Laura has decades of experience in case managing and advising local authorities in complex matters, including drafting threshold documents to a high standard. In addition to care proceedings, Laura also has experience in relation to education law and provides advice and representation in this area, including where there may be cross-issues with accommodation under section 20. Reported Cases: P and E (Care Proceedings: Whether to Hold Fact-Finding Hearing), Re [2024] EWCA Civ 403: leading case on the importance of the court needing to establish a clear factual basis for safeguarding measures to be implemented. A (Care and Placement Orders) [2014] EWFC B143: Care proceedings involving applications for Care and Placement Orders. Represented the paternal aunt pro bono throughout High Court appeal and subsequent proceedings. Other cases include: Re C [2021]: Last minute representation of intervenor in very serious NAI. Complex case involving another intervenor lacking capacity but being required to give evidence. Re J [2016]: Represented a mother accused of causing a number of fractures to a young baby. Mother exonerated of causing the injuries or failing to seek prompt medical attention. Re A [2015]: Acted for a local authority in the 2nd set of care proceedings less than 18 months after conclusion of the first proceedings in relation to 5 children. Mother had transitioned gender without medical supervision. Re B [2013]: Acted for a local authority in successfully obtaining historic findings of sexual abuse made against a stepfather of an adult daughter where younger siblings were at risk and were being groomed by the father during supervised contact.

Lawrence Messling

Overview Lawrence is an experienced family law barrister advising in serious public law children cases, often appearing in High and County Courts. He has more than twenty five years experience as an advocate in public law children’s cases. He has also undertaken cases involving vulnerable adults and children for over 25 years in a variety of jurisdictions, including involving mental health and social care legislation, and undertakes Court of Protection cases. He represents local authorities, relatives and patients in health and welfare issues. Lawrence has chaired the British Agencies for Adoption and Fostering (BAAF) Midlands Region Legal Group for some ten years and is a trainer on the paediatrician expert witness programme. He also lectures on aspects of public children law and often chairs related conferences and seminars, usually of a multidisciplinary nature. Lawrence is an Accredited Mediation Advocate. Family Lawrence is an experienced family law barrister advising in public law children cases, often appearing in High and County Courts. He has more than twenty five years experience as an advocate in public law children’s cases. Public Law Care and Adoption Lawrence specialises in serious public law children’s cases, regularly appearing in the Family Division of the High Court. He is instructed by local authorities, parents and guardians. He undertakes serious fact finding cases including cases where a child has died, NAHI, other serious non-accidental injury, fabricated or induced illness, as well as complex outcome hearings including those with an international element. As well as conventional public law children cases, Lawrence also advises and appears in those with sensitive medical and ethical aspects for example, cases where the lawfulness of whether to resuscitate a child is at issue or where one parent has killed the other. He advises and appears in cases where there are serious issues of confidentiality and disclosure including those requiring the exercise of the High Court’s inherent jurisdiction and the making of reporting restriction orders to restrain media publication. He is regularly instructed by local authorities, parents and guardians to advise where there are issues of particular procedural, jurisdictional or evidential complexity. As a senior junior he regularly appears against silks and occasionally leads junior counsel. Court of Protection  Lawrence is an experienced family law barrister advising in public law children cases, often appearing in High and County Courts. He has more than twenty five years experience as an advocate in public law children’s cases. Health & Welfare Lawrence has undertaken cases involving vulnerable adults and children for over 25 years. These cases have involved a variety of jurisdictions, including Mental Health and Social Care legislation, the inherent jurisdiction of the High Court and more recently the Court of Protection. He has represented local authorities, relatives and patients. He has a number of qualities which have proved particularly relevant to these important and often complex cases. Lawrence has chaired the British Agencies for Adoption and Fostering (BAAF) Midlands Region Legal Group for some ten years and is a trainer on the pediatrician expert witness programme. He also lectures on aspects of public children law and often chairs related conferences and seminars, usually of a multidisciplinary nature. Reported Cases Re ABC (Children: Overlaying Child) [2020] EWFC [57] Lawrence advised Nottinghamshire County Council in the High Court case exercising its powers, under the inherent jurisdiction, in relation to a treatment plan for a young child involving the withdrawal of life-supporting treatment and the institution of palliative care measures. Please click here for more information. RE AA (Children) & 25 Ors [2019] EWFC 64 RE: R – A – Child [2019] EWCA 482 Civ Re T (A Child) [2018] EWCA Civ 650 Re F (A child) 11 Dec 2015 (HHJ Rundell) Birmingham City Council v CH [2015] EWFC 66 Re EK (Child: therapy) [2013] EWHC 3747 (Fam) A City Council v M [2013] 1 FLR 517 Re L (A child) [2011] EWHC 1285 (Fam) (Judge Bellamy) Actual errors and omissions in articles written by a journalist about care proceedings demonstrated the dangers in relying on  partisan reporting by family members and supporters rather than attending court hearings to hear the evidence the court itself heard. Re A and B (one parent killed by the other - guidance) [2010] EWHC B25 (Fam)(Hogg J) (7 September 2010) Hogg J considered the issues in a case where one parent had been killed by the other and gave extensive guidance about such cases. W-P (Children) [2009] EWCA CIV 216 (Sir Mark Potter (President), Smith LJ, Wilson LJ) [2009] 2 FLR 200 The Court of Appeal considered an appeal by a local authority against findings of fact made in respect of non-accidental injuries sustained by a seven week old baby. X and Y v a Local Authority (Adoption: Procedure) [2009] EWHC 47 (Fam) McFarlane J [2009] 2 FLR 984 McFarlane J considered a failure by the Family Proceedings Court to meet the requirements of the Adoption and Children Act 2002 s.46(6). An agreement which had been reached between local authority and birth parent on a regime for postadoption contact about which the adopters were not informed and to which the adopters would not agree was set aside. Re B (Minor) 2008 EWHC 1996 Coleridge J 10/6/08 (Lawfulness of not resuscitating disabled child) The court considered whether it would be lawful and in the best interests of a profoundly mentally and physically disabled child for her not to receive intensive resuscitation, if she developed a deteriorating illness or became severely unwell A County Council v a Mother, a Father and X, Y and Z (by their guardian) [2005] EWHC 31 (Fam) Ryder J[2005] 2 FLR 129 Ryder J considered the proper approach to deducing the welfare of the child. It was a multi-faceted concept which could not be deduced from any one professional perspective. He also considered the relevance of the terms ‘Munchausen’s syndrome by proxy’ and ‘Factitious/fabricated (and induced) illness (by proxy)’ concluding that they were not descriptions of a disease, but merely descriptions of a range of behaviours whose context and assessments could provide insight into the degree of risk a child might face.

Liz Adams

Elizabeth Adams (Liz) is a family barrister, who is focused on family disputes (including public/private children law and finance) and education law. She completed her 12-month pupillage with 3|PB and became a member of chambers in October 2023. Liz graduated with a first-class law degree before obtaining a distinction in her LLM, studied alongside her BPTC. Prior to pupillage, Liz worked with policymakers and charities to write and promote policies addressing domestic violence. She also advised on non-molestation and occupation orders through her work with the University of Law’s pro bono clinic. Liz has a specialist interest in matters involving disability and/or special educational needs. She delivered pro bono legal advice with IPSEA, a charity that assists parents of children with additional needs with securing educational support. Prior to commencing pupillage, Liz worked for two years as the in-house counsel for a company specialising in water filtration and enhancement. She delivered practical advice that considered the commercial reality of the business. She dealt with commercial property leases, employment tribunal representation, and intellectual property matters, and drafted and negotiated a wide range of domestic and cross-border commercial agreements, including memorandum of understandings, non-disclosure agreements, distribution agreements, and affiliate-link commission agreements. As a previous Open Championship Irish dancer, in her spare time Liz now enjoys exercising by yoga, pilates, zumba and hiking.

Luke Nelson

Overview Luke is a financial remedies and TOLATA specialist. Luke is also comfortable undertaking other chancery work such as probate and Inheritance Act disputes. He has also recently built a strong practice in child maintenance appeals; advising from the inception of a case through to representation at the Social Entitlement Chamber. Luke is approachable, calm, confident and able to put his clients at ease: utilising the skills he acquired in his previous life in the entertainment industry. He offers a sensible, pragmatic and persuasive approach to the matters in which he is instructed. Luke offers a principled, interest-focused approach to negotiations, whether at FDR, mediation or through correspondence. Luke understands that the key to a successfully negotiated outcome is achieving an outcome that satisfies both parties’ interests. He pursues that goal with compassion, focus and issue-centric advocacy. Luke is an experienced trial advocate. He is regularly praised for his clear and effective cross-examination and his ability to consolidate his trial preparation with the evidence to create a compelling closing speech. Advocacy & Legal Experience Prior to commencing pupillage, Luke worked as a part-time lecturer in Family Law at the University of Gloucestershire. He taught private family law to the second year students at the University, setting and marking coursework, teaching lectures and seminars and delivering online lectures. Luke also undertook work as a solicitor’s agent: providing advocacy services on various property matters across the country. Biography Luke has an unusual biography for a barrister, having been the drummer and manager of a heavy metal band until 2014, playing numerous concerts across the UK and recording an album during a six-year career in the music industry; all while managing a successful pool bar. Interests Outside work, music still remains a great interest, as well as heath, fitness and cooking. Property and Estates Luke has a particular interest in matters arising out of the Trusts of Land and Appointment of Trustees Act 1996 and is comfortable advising and advocating in concurrent Schedule 1 Children Act matters. Luke provides advice in conference or on paper and has a sound knowledge of the principles of equitable accounting and occupation rent. Luke is a skilled mediation advocate. He utilises his knowledge of the law to achieve practical, client-led solutions which work (so far as possible) for both sides. Luke understands that the key to successful mediation is identifying and addressing each party’s competing interests and developing a solution that satisfies both. Luke has recent experience in the following: Drafting statements of case and advising on prospects and offers pre-issue Advising and appearing in all hearings from inception of the claim, to CCMC to final hearing Advising in relation to the establishment of a constructive trust based on an agreement which was never executed, where the defendant was refusing to make mortgage payments over the property and possession proceedings were impending Advising and representing a client in a case involving large contributions from both sides, a reconciliation and considerable sums spent on renovations Representing a client in a long-running case alongside Children Act sch 1 proceedings where the respondent had suppressed the profit-earning capacity of the business in order to remain in the FFH Advising on a matter involving an agreement to transfer the beneficial interest in a property where the buy-out sum was never paid Obtaining strike out and summary judgment against a company who wrongfully asserted the existence of a common intention constructive trust, proprietary estoppel and agreement to dispose of beneficial interest in domestic property Family Luke undertakes a primarily finance-based practice: specialising in financial remedies, co-ownership disputes and contested divorce. Luke is known for his down-to-earth, practical and pragmatic approach to financial cases as well as his deft client care skills. He approaches all matters knowing that his clients are experiencing one of the most difficult times of their lives and endeavours to ease their burden with an easy rapport and clear advice. Luke taught private family law and financial remedies at the University of Gloucester before joining chambers and uses this experience in the matters in which he is instructed. Finance Luke is a specialist financial remedies barrister. Luke is known for his down-to-earth, practical and pragmatic approach to financial cases as well as his deft client care skills. He approaches all matters knowing that his clients are experiencing one of the most difficult times of their lives and endeavours to ease their burden with an easy rapport and clear advice. Luke taught private family law and financial remedies at the University of Gloucester before joining chambers and uses this experience in the matters in which he is instructed. Financial Remedies Luke has experience in a wide variety of financial remedies matters. He is able to run a case through from FDA to Final Hearing. He is also comfortable advising on enforcement actions, setting aside consent orders and intervener actions. Luke is also happy to draft all documents required in financial remedies matters, including questionnaires, schedules of deficiency, offer letters & interim applications. Luke frequently acts in cases involving foreign property, contested business valuations and intervener actions. Luke has recent experience in the following: Representing the company of a wealthy husband which was asserting ownership over various matrimonial properties in the High Court alongside and against leading Queen’s Counsel Advising and representing in a matter involving an alleged fraudulent disposition of cross-border property Successfully establishing the validity of an ante-nuptial agreement alleged to have been entered into under duress Successfully arguing an add-back of c.£50k in a needs case Prosecuting an application for committal based on consistent failures to comply with the service of financial disclosure Resisting an application for a Legal Services Payment Order where both parties worked and lived in Australia and the UK Advising on and drafting an application to freeze assets pending the outcome of financial remedy proceedings Assisting Hamish Dunlop in a long-running farming case involving inherited wealth and equestrian assets; the latter issue forming the basis of concurrent intervener proceedings TOLATA Luke has a particular interest in matters arising out of the Trusts of Land and Appointment of Trustees Act 1996 and is comfortable advising and advocating in concurrent Schedule 1 Children Act matters. Luke provides advice in conference or on paper and has a sound knowledge of the principles of equitable accounting and occupation rent. Luke is a skilled mediation advocate. He utilises his knowledge of the law to achieve practical, client-led solutions which work (so far as possible) for both sides. Luke understands that the key to successful mediation is identifying and addressing each party’s competing interests and developing a solution that satisfies both. Luke has recent experience in the following: Drafting statements of case and advising on prospects and offers pre-issue Advising and appearing in all hearings from inception of the claim, to CCMC to final hearing Advising in relation to the establishment of a constructive trust based on an agreement which was never executed, where the defendant was refusing to make mortgage payments over the property and possession proceedings were impending Advising and representing a client in a case involving large contributions from both sides, a reconciliation and considerable sums spent on renovations Representing a client in a long-running case alongside Children Act sch 1 proceedings where the respondent had suppressed the profit-earning capacity of the business in order to remain in the FFH Advising on a matter involving an agreement to transfer the beneficial interest in a property where the buy-out sum was never paid Obtaining strike out and summary judgment against a company who wrongfully asserted the existence of a common intention constructive trust, proprietary estoppel and agreement to dispose of beneficial interest in domestic property Injunctions Luke accepts instructions relating to injunctions and ownership of property, including non-molestation orders, occupation orders and applications for transfer of tenancy – usually linked to concurrent or impending financial remedy proceedings. Luke is experienced in advising on applications for freezing injunctions and avoidance of disposition orders under the Matrimonial Causes Act, Senior Courts Act and the court’s inherent jurisdiction. Property Luke has a particular interest in matters arising out of the Trusts of Land and Appointment of Trustees Act 1996 and is comfortable advising and advocating in concurrent Schedule 1 Children Act matters. Luke provides advice in conference or on paper and has a sound knowledge of the principles of equitable accounting and occupation rent. Luke is a skilled mediation advocate. He utilises his knowledge of the law to achieve practical, client-led solutions which work (so far as possible) for both sides. Luke understands that the key to successful mediation is identifying and addressing each party’s competing interests and developing a solution that satisfies both. Luke has recent experience in the following: Drafting statements of case and advising on prospects and offers pre-issue Advising and appearing in all hearings from inception of the claim, to CCMC to final hearing Advising in relation to the establishment of a constructive trust based on an agreement which was never executed, where the defendant was refusing to make mortgage payments over the property and possession proceedings were impending Advising and representing a client in a case involving large contributions from both sides, a reconciliation and considerable sums spent on renovations Representing a client in a long-running case alongside Children Act sch 1 proceedings where the respondent had suppressed the profit-earning capacity of the business in order to remain in the FFH Advising on a matter involving an agreement to transfer the beneficial interest in a property where the buy-out sum was never paid Obtaining strike out and summary judgment against a company who wrongfully asserted the existence of a common intention constructive trust, proprietary estoppel and agreement to dispose of beneficial interest in domestic property Injunction Luke accepts instructions relating to injunctions and ownership of property, including non-molestation orders, occupation orders and applications for transfer of tenancy – usually linked to concurrent or impending financial remedy proceedings. Luke is experienced in advising on applications for freezing injunctions and avoidance of disposition orders under the Matrimonial Causes Act, Senior Courts Act and the court’s inherent jurisdiction.

Maisie Carter

Maisie Carter is a family law barrister at 3PB based in Birmingham. Maisie completed a 12-month pupillage at a specialist family law chambers in the North West of England prior to joining 3PB in November 2023. Maisie has developed a busy family practice, acting in public and private law children matters and proceedings under the Family Law Act 1996. Maisie regularly deals with cases involving allegations of neglect, domestic abuse, substance misuse and mental health issues. Maisie represents local authorities, parents and intervenors in the full range of family law proceedings, including in multi-day final hearings for care and placement order applications. Maisie is routinely commended for her client care skills and ability to provide realistic but sensitive advice. Her approachability enables her to quickly build a rapport with her clients and colleagues. Prior to commencing pupillage, Maisie attained a first-class degree in Law with Criminology and won several awards for her degree performance. Maisie attained a Very Competent on the Bar Practice Course and was a volunteer for the National Centre for Domestic Violence and the Litigation Programme at the University of Law. Outside of work, Maisie enjoys travelling, socialising with family and friends, going to the gym and going on long walks with her dog.

Makhsudul Islam

Overview Makhsudul Islam is a commercial litigation barrister. Makhsudul has built up a busy court practice of trials and interlocutory hearings. Away from court, he drafts opinions, pleadings, conducts conferences and acts as a mediation-advocate. He has a strong following and is regularly instructed by leading international (including law firms from the UAE) and regional commercial law firms. Makhsudul is regularly instructed in the following: Company and partnership disputes Insolvency (corporate and personal) Contractual disputes Supply of goods and services Debt recovery Enforcement of personal guarantees Insurance disputes Clients have praised Makhsudul's technical ability, attention to detail, his effectiveness in giving detailed and clear opinions early on in proceedings, and his ability to put solicitor and lay clients at ease with his personable approach. Makhsudul was a finalist for Barrister of the Year at the Worcestershire Law Society Awards 2023. Outside of work, Makhsudul is keen on keeping fit and mental well-being. He enjoys weight training, football, cycling, travelling and reading. He is also a self-confessed "horologist" and has a passion for collecting vintage timepieces. He speaks five additional languages – Bengali (fluent), Urdu (fluent), Hindi (fluent), Arabic (basic) and French (basic). Commercial Makhsudul accepts instructions on a wide range of commercial disputes including contractual breaches, breach of manufacturer warranty, loss of chance/opportunity claims, debt recovery, supply of goods and services and enforcement of personal guarantees. He regularly represents some of the leading insurers, technology giants, banks, energy providers, shopping complexes, private schools and builders’ merchants in the UK. Makhsudul’s recent experience includes defending a luxury German and Japanese vehicle manufacturer against professional negligence and breach of manufacturer warranty claim. Aside from attending hearings and trials, Makhsudul is very well-versed in drafting opinions and pleadings in commercial matters. He is well-known for turning around opinions and pleadings very quickly and well in advance of any set deadlines. Some of his recent work includes: Advising a private healthcare provider and its director (on their personal liability) on a high value dispute arising out of a condition precedent clause in a share purchase agreement. Advising one of the largest builders’ merchants in the UK on its transfer of assets and assignment of debts following its merger and acquisition with another large builders’ merchant. Advising a renowned Japanese vehicle manufacturer on the prospects of success of obtaining a strike out and summary judgment on a professional negligence and breach of warranty claim. Advising a consultancy of construction experts on its prospects of recovering outstanding fees from an international law firm and a project management company. Advising and attending a trial on behalf of structural engineers for payment of outstanding invoices concerning desktop designs for an excavation that had gone wrong. Advising and drafting the Particulars of Claim for a property developer in recovering outstanding commercial rent arrears. Advising a consumer and drafting the Particulars of Claim in a claim against a well-renowned German luxury car brand for breach of contract. Advising a leading hotel chain on its contractual liability to contractors in the event of an Act of God (i.e. the COVID-19 pandemic). Advising and drafting Defences on behalf of a company and one of its directors who were being pursued by a consultant. Advising one of the largest builders’ merchants in the UK on their prospects of enforcing a personal guarantee against a director. Advising and drafting a Reply to Defence and Counterclaim, for an estate agent on an alleged oral variation to the terms and conditions and its entitlement to commission on the sale of a portfolio of properties. Advising and drafting a skeleton argument in a dispute between an ex-husband and wife arising out of the breach of an oral agreement. Advising a private school on its prospect of recovering outstanding school fees. Advising and drafting the Particulars of Claim for a leading energy provider on its prospects of recovering outstanding payments from a well-renowned hotel chain. As an extension of Makhsudul’s commercial practice, he can also attend the following hearings if required: Returns of goods Possession (relating to section 8 and section 21 notices) Application to suspend warrant of eviction Trespass Forfeiture Appeals In addition to the above, Makhsudul has experience of drafting forfeiture proceedings both for non-payment of rent and “other” breaches. He regularly advises commercial landlords and legal expenses insurers on breaches of lease agreements, interpretation of clauses and the prospects of obtaining an order for forfeiture. Enforcement As a result of Makhsudul’s commercial practice and in particular his specialism of debt recovery, clients regularly instruct him to attend enforcement hearings. He is able to attend the following hearings: Charging order Orders for sale Third party debt order Attachments of earning order Determination Insolvency and Bankruptcy Makhsudul attends bankruptcy and winding-up hearings on a regular basis at the Royal Courts of Justice and regional Business & Property courts. Aside from attending hearings, Makhsudul has experience of drafting: Statutory demands Verification of petitions Insolvency Act applications Settling witness statements on behalf of creditors contesting the annulment of a bankruptcy order Opinions on the prospects of obtaining a bankruptcy or winding-up order.

Matiss Krumins

Overview Matiss Krumins was called to the Bar in 2008 and qualified as a solicitor in 2011, specialising in public law children proceedings and judicial review. He was senior solicitor at Birmingham City Council from 2011 to 2016 and a Principal Solicitor from 2016 to 2017, when he left to pursue his career at the Bar with 3PB. Matiss accepts instructions from parents, intervenors, children’s guardians, and local authorities. Family Care and Adoption Proceedings Matiss has significant experience in all types of proceedings relating to children: All areas of care proceedings, including complex/highlight technical concerns: Neglect/emotional harm; Drug and alcohol abuse; Domestic violence. Sexual abuse (inter-generational and inter-sibling) and child sexual exploitation. Non-accidental injuries; Fabricated or Induced Illness (FII) Cases with a foreign element (particularly transfer of proceedings pursuant to Brussels II and placement of children outside of the jurisdiction) Applications in respect of child witnesses (application of Re W), in all types of cases. Cases involving individuals with learning difficulties/learning disabilities. Cases involving children with significant or profound disabilities, including life limiting conditions. Cases where one parent has killed another. Cases where a parent/adult has killed a child. Cases involving terrorism. Discharge of care Human rights infringements Designated local authority Adoption Placement applications Applications for post adoption contact Applications to discharge placement orders Applications to oppose adoption orders Special Guardianship Placement of children Application of support regulations Inter-local authority disputes Specialist applications in respect of: Female Genital Mutilation Forced Marriage Press/Reporting injunctions Wardship Appeals of care orders (interim and full) and placement orders. Judicial Review/Human Rights Matiss has significant litigation experience advising and drafting documents in respect of judicial review challenges and is accustomed to dealing with these matters on short notice, including applications for declaration of infringement of human rights in the following areas: Application of section 17 and section 20 duties, including: Child in Need – including all forms of support, with emphasis on financial/accommodation support. Child Protection. Fostering (both external issues and administration of local authority fostering duties, including assessment and termination of foster carers, and family and friend carers). Post-18 support to children, including children subject to immigration restrictions. Children within the criminal justice system, including issues around detention in police stations. Assessment and support for disabled children, including personal payments. Duties to individuals who are deemed No Recourse to Public Funds and associated immigration matters. Duties to Unaccompanied Asylum Seeking Minors including assessment and support Injunctions to prevent removal of children Applications for human rights declarations and damages Negotiating settlements in all types of the above matters, including large financial settlements. Costs in relation to all the above matters. Local Government Matiss has experience of the regulatory functioning of local authorities and can assist in: Advising on policy/procedural implications of changes in statute or case law, having previous experience of advising and assisting on: Policies and procedures in respect of foster carers, including family and friends foster carers Policies and procedures in respect of disabled children’s services; Policies and procedures in respect of terrorism. Advising on the application of local government constitution. Advising on consultation requirements. Advising in respect of Serious Case Reviews, having had experience of assisting with nationally reported Serious Case Reviews. Reported cases P and E (Care Proceedings: Whether to Hold Fact-Finding Hearing), Re [2024] EWCA Civ 403 X City Council v M [2023] EWHC 1767 (Fam) : Represented local authority in a fact finding where the mother was alleged to have poisoned her child with salt on multiple occasions. E (A Child) (Care and Placement Orders) [2023] EWCA Civ 721: appeal by a mother against care and placement orders made in respect of her son, E, who is now just over a year old. The appeal was opposed by the local authority and by the children's guardian. Judgement can be found here. P (A Child: Fair Hearing) [2023] EWCA Civ 215 Re Y (Children in Care: Change of Nationality) [2020] EWCA Civ 1038 A City Council & M & F & C [2020] EWHC 947 (Fam) Local Authority X v HI and others [2016] EWHC 1123 (Fam): this is a case whereby information arose by way of a 15-year-old child’s disclosure to the social worker that they did not want communicated to their parents within care proceedings. The local authority considered itself subject to a duty to disclose and the guardian sought to maintain the confidentiality of the disclosure. The court weighed the issues of relevance of the information, gravity and magnitude of harm and the rights of the individuals protected by the Human Rights Act 1998 in the balance. Birmingham City Council v AB & others [2014] EWHC 3090 (Fam): this is a case where the father violently killed the mother. The children were initially placed with their grandmother, who sadly misappropriated £32,500 of their compensation monies. The local authority sought and were granted care and placement orders, in a case that had many complex elements. Public and Regulatory Local Government Matiss has experience of the regulatory functioning of local authorities and can assist in: Advising on policy/procedural implications of changes in statute or case law, having previous experience of advising and assisting on: Policies and procedures in respect of foster carers, including family and friends foster carers Policies and procedures in respect of disabled children’s services; Policies and procedures in respect of terrorism. Advising on the application of local government constitution. Advising on consultation requirements. Advising in respect of Serious Case Reviews, having had experience of assisting with nationally reported Serious Case Reviews. Court of protection Matiss has significant experience of the application of Deprivation of Liberty to children in local authority care, which is a rapidly changing area of law as well as experience of welfare applications on behalf of disabled children, and experience of advising on financial matters in respect of disabled children (including issues of trust).

Michael George

Overview Michael George is a specialist family practitioner with over 30 years experience. He has a reputation for a good humoured and robust forensic approach with careful analysis. Reported and Notable Cases T v T: Medium to medium large asset case. Analysis demonstrated £1.2M of assets not accounted for in the SJE report. Successful submissions on trust issues at FDR. Negotiated settlement. X v X: Medium asset case where proper analysis of police pensions and retirement dates by counsel increased pension pot for distribution to client by £350,000. S v V: Jurisdiction and forum issues in context of internationally wealthy family with offshore tax structures. Contested issues of billionaire financial resources. Successful LSPO and MPS appeal leading to successful negotiated settlement covering multiple jurisdictions. Re T: High net worth member alleged billionaire family issues of offshore trusts, family bounty, jurisdiction, forum, and circumstances of the marriage. Successful MPS and LSPO appeal. Re T: Asset base circa £6M. Intervener claims whether constructive trusts or estoppel, inaccurate business accounts, liquidity issues. Opposing Leading Counsel. Re X and Re Y: Two unrelated cases involving topflight motorcycle racers. Issues earnings structure of professional service company. Tax efficient strategies for extracting monies. Re M: Asset base circa £6M multiple corporate entities in UK and republic of Ireland, dividend accounting irregularities breach of directors’ duties, Reduction of Capital / Liquidation Reconstruction Demerger issues. Opposing Leading Counsel. Re S: Children private law, international contact issues and historic domestic violence. Opposing Leading Counsel. Re H: Farming case and commercial operation asset base circa £8M. Multiple plots, synergistic values, easements, demerger of asset base for tax implications. Re B: Farming case asset base £6M with overlapping family farming partnerships, leases, differential ownership of ransom strips, easements affecting valuations and caravan businesses. Re H: asset base circa £13M interim property portfolio reallocation before end of tax year to defer £600K of CGT. Opposing Leading Counsel. Re C: Variation of maintenance application. Husband was major shareholder in 8 private companies that had merged into one under complex and opaque arrangements. In original financial relief Wife alleged Husband had undisclosed offshore funds. No forensic accountant instructed – Wife’s original Counsel had failed to penetrate the web of arrangements and advised there was no evidence to pursue matter. On a variation application under cross examination Husband eventually accepted he was a beneficiary of a hitherto undisclosed Lichtenstein trust and that he had concealed assets from Court in earlier proceedings. Further inquiries revealed the existence of a secret trust to which Husband was a beneficiary and a further trust holding cash and loan notes against Husband’s company and a holding company incorporated in further offshore tax haven in the British Virgin Islands. Given these disclosures Wife capitalised her maintenance claim and the case settled on advantageous terms. Re L: Family business was valued at about £5m. Negotiated settlement using a variety of tax efficient methods including dividend waiver and share buyback and cancellation. Opposing Leading Counsel – now Judge of Family Division. Post consent order Wife alleged Husband had concealed a £200,000 policy and threatened to reopen proceedings. Persuaded Wife’s advisers that it was not worth the litigation risk to reopen. Re O: Complex portfolio of vested and unvested share options and LTIP scheme with differential tax regimes depending upon when options exercised. Client relocated from Kazakhstan to India during negotiations. Complex schedules of assets and contingent tax liabilities and international taxation considerations. B v B: Departure from separation agreement based upon Husband’s false representation that his retirement was imminent. AK v RB and MB [2011] EWHC 3317: Relocation to Kyrgyz Republic, expert evidence on socio political situation in the absence of international social services or diplomatic relations. Askey v Woods [2005] EWCA 574: Contributory negligence and causation where there is no evidence that the Claimant’s negligence would have contributed to the accident that did happen. Finance Michael George has over 30 years’ experience in big money cases and cases with limited assets, where creative solutions are needed to meet needs be it Divorce, Dissolution, Separation, Schedule 1, Intervener and Inheritance Act Claims. Michael regularly acts for overseas or internationally based clients where habitual residence, jurisdiction and forum are in issue. He is familiar with the practical and technical challenges these present. His expertise ranges from acting in financial remedy cases, advising on commercial and farming assets, tax efficient settlements for splitting assets as well as negotiating the complexities of undisclosed assets, financial manipulation, offshore funds, international assets, trust and corporate assets. He has a keen forensic and tactical brain and is particularly adept in cases involving company or trust assets and a significant element of his day-to-day practice involves dealing with corporate and trust structures that need unravelling. Michael is well versed in both civil and family legal procedure. He regularly lectures on some of the more complex aspects of family finance, trusts and company valuations. FDR Hearing Service Michael is available for private remote FDR hearings. For more information on private remote FDR hearings please click here. Property Michael regularly undertakes cases relating to trusts of land both as intervener claims within financial remedy proceedings and as freestanding Civil Proceedings under trust of Land and Appointment of Trustees Act. He also undertakes significant volumes of professional negligence work arising from leaseholder issues. Michael also undertakes a considerable amount of traditional Chancery work including Inheritance Act Claims, contested Probate and trusts both on shore and offshore with particular emphasis on the interplay with Financial Remedy proceedings. His extensive financial remedy practice gives him a significant advantage when advising and negotiating on contentious probate matters where the divorce comparator and family dynamics play a significant role in outcome. Property and affairs Michael also undertakes a considerable amount of Court of Protection Property and Affairs work including Inheritance Act Claims, contested Probate and trusts both on shore and offshore with particular emphasis on the interplay with Financial Remedy proceedings. Such experience extends to; revocation of an enduring power of attorney, proper exercise of the powers of a deputy, capacity to create a lasting power of attorney and the contested approval of a statutory Will. Professional Negligence Michael is member of the Professional Negligence Bar Association and as a former Head of Chambers Michael has extensive experience of adjudicating on professional standards issues and is on the Chambers’ professional adjudication panel. He frequently advises and acts in professional negligence matters with a focus on leasehold advice and claims with a matrimonial finance and property focus.

Nathalie Bull

Overview Nathalie Bull joined 3PB in 2019, practicing exclusively in family law. Before joining 3PB Nathalie practiced as a barrister for 12 years at another Midlands based Chambers. Prior to that, she worked in a national law firm as an in-house Advocate. Nathalie is ranked as a leading junior by Legal 500 in both of her areas of practice, namely children law and financial remedy. Having qualified as an Arbitrator in the Children Scheme with the Institute of Family Law Arbitrators (IFLA), Nathalie is a member of the Chartered Institute of Arbitrators (CIArb) and she welcomes instructions to act as the Arbitrator in children cases or to represent clients at arbitrations. Nathalie is regularly instructed to attend the Family Court and the High Court concerning private children proceedings, matrimonial finance and contested divorce/annulment proceedings. She is instructed by solicitors across the UK and internationally to represent separated couples, parents, grandparents and children. Nathalie prides herself on the consistently positive feedback that she receives from both her lay clients and instructing solicitors. Regardless of whether the case is child or finance related, Nathalie steers each case in a progressive manner with a view to concluding the proceedings efficiently at the earliest stage. She prides herself on her high record of agreed settlements reached between the parties in her cases. As an accomplished negotiator and advocate, Nathalie communicates effectively with her opponents and the judiciary to achieve the desired result. Nathalie has an eye for detail, she thoroughly prepares her cases and she strives to achieve the best possible result for her clients. In her spare time Nathalie enjoys keeping fit by running and horse riding. She loves travelling and spending time with her family. Family Nathalie Bull practices exclusively in family law. Before joining 3PB Nathalie was part of another Midlands-based chambers for 12 years and prior to that worked in a national firm of solicitors as an Advocate. She has a busy practice and is regularly instructed to attend the Family Court and the High Court concerning private children proceedings and matrimonial finance. Nathalie acts for separated couples, parents, grandparents and children. Regardless of whether the case is child or finance related, Nathalie steers each case in a progressive manner with a view to concluding the proceedings efficiently at the earliest stage. She prides herself on her high record of agreed settlements reached between the parties in her cases. Private Law Children, Injunction and Domestic Abuse Nathalie is frequently instructed in cases involving child arrangement orders, parental responsibility, prohibited steps and specific issues, including relocation applications and change of schools. Many of Nathalie’s cases involve allegations of domestic abuse, emotional, physical, sexual and financial abuse. She has a particular interest in complex cases of parental alienation and intractable contact disputes where the child may have suffered psychological harm as a result of the high levels of conflict. Nathalie appears regularly in urgent hearings, FHDRAs, DRAs, review hearings, direction hearings, fact-finding hearings, final hearings, enforcement hearings and appeals. Nathalie has considerable experience of fact-finding hearings, she prepares extensively, utilises a forensic approach and leaves no stone unturned. Nathalie is instructed by both applicants and respondents in applications for non-molestation injunctions, occupation orders and committal proceedings. Nathalie is a regular speaker of the 3PB Family Brunch Seminars, having spoken on the following topics: Enforcement of Child Arrangement Orders, Fact-Finding Hearings, Relocation in Children Act Cases, and Arbitration. An article written by Nathalie entitled ‘Relocation – a practical guide for improving prospects of making or defending applications’ was published by the Family Law Journal. Arbitration As a qualified Arbitrator in the Children Scheme, Nathalie welcomes instructions in all aspects of children related disputes to act as the Arbitrator, or to represent clients at arbitrations. Each dispute is unique to the facts and background circumstances of each case. The issues may concern relocation, or how much time the children should live/spend time with each parent, or may involve a specific issue such as which school the children should attend, whether the children's names should be changed, or what the holiday arrangements should be. For more information on Arbitration at 3PB please click here. If you would like to discuss arbitration, please contact Robert Leonard or Ian Charlton who will be happy to help you with the process. Both parties will be required to consent to the arbitration by completing the ARB1CS form, which can be accessed by clicking here. The completed form should then be emailed to the Institute of Family Law Arbitrators (IFLA) to the following email address: [email protected] Cases: L v S: private law (represented the mother). The mother applied for permission to relocate out of the jurisdiction from the Midlands to Scotland. The father opposed the application on the basis that his time with the 7-year-old child would be significantly reduced and the practicalities involved in the lengthy travel would be difficult and costly. The mother’s application to relocate was successful. It was in the child’s welfare interests to relocate with her primary carer and her half siblings. P v F: private law (represented the father). The mother made an application for relocation of the children within the UK. At the two-day final hearing the father successfully opposed the mother’s application and an order was made that the children must remain at their current educational establishments and the children must continue to live within the locality. D v D: private law (represented the father). The mother, a practicing GP, alleged the father had sexually abused the child and abused the mother including: rape, physical abuse, emotional abuse, gaslighting and coercive control. The father denied the mother’s allegations and he pursued 63 allegations of physical and emotional abuse against mother. A five day fact-finding hearing took place and resulted in all of the father’s allegations being found against the mother and none of the mother’s allegations being found against the father. The direct contact between the father and child that had been suspended was then resumed. The mother underwent a psychiatric assessment and therapy. Thereafter, the proceedings concluded in 2023 by way of a shared care arrangement. B v B: private law (represented the father). The mother sits as a judge in family law. The mother alleged the father had injured their two-year old child. The five-day fact-finding hearing concluded that the father had not injured the child. An expert psychological assessment of the family concluded that the mother had negatively influenced the child about the father. An independent social worker was instructed to re-build the relationship between the father and child after 2.5 years of no contact. Direct contact was then ordered to recommence. Re CD [2021] EWFC 112: care proceedings (represented the father) – Junior counsel led by Queen’s Counsel, appearing at the Court of Appeal on an appeal concerning public interest immunity brought by Warwickshire Police. Junior counsel at the fact-finding hearing before a section 9 Judge. The local authority unsuccessfully sought findings that the father had deliberately inflicted three fractures to his 4 month old baby. A number of expert witnesses from different fields of expertise were cross examined. The Court found that the father had unintentionally caused the fractures through his careless handling. The child was returned to the care of her parents. This is a reported case which is available to view on Bailii. T v T: private law (represented the father). Following allegations raised by the parties 11-year-old daughter to the school staff and to the police, the Mother alleged that the Father had physically assaulted their daughter. At the fact-finding hearing the Judge concluded that the Father had not harmed his daughter in any way and the court found that the child had actually lied to a number of professionals about the untruthful allegation. Direct contact was ordered to resume forthwith. E-I v E-I: private law (represented the father). International case with the father residing in Bahrain, the mother and children living in England and the witnesses residing in America. At the fact-finding hearing the mother pursued findings against the father of coercive control and domestic abuse. The Court did not find any of the disputed allegations proven. The mother had stopped all contact between the father and children without any justification. K v K: private law (represented the mother). The father was a practicing GP. Both parties made a number of allegations against each other. At the fact finding hearing the Court made findings of domestic abuse and violence perpetrated by the father against the mother in the presence of the child. No findings were made against the mother. The father’s contact with the child was to remain supervised pending completion of a Domestic Abuse Perpetrators Programme. H v S: private law (represented the father). The father had obtained a ‘spend time with’ CAO in previous proceedings after the mother had made unfounded allegations against the father and his partner. One month after the final hearing, the mother raised further allegations and failed to comply with the CAO. Father issued an enforcement application, a guardian was appointed, the court made cost orders and penal notices. The father ultimately issued a committal application and a ‘live with’ application. At the final hearing the father was granted a ‘live with’ order and the court ordered very limited supervised time to be spent with the mother. The father’s solicitor described this case as one of the worst types of implacable hostility cases that she had encountered in her career. H v G: private law (represented the mother). A complex Children Act matter involving a number of issues. One interesting issue concerned the maternal family’s Jehovah Witness belief. The father felt the child was being indoctrinated by unhealthy religious views and as a result he sought a PSO to limit the time that the extended maternal family spent with the child on a supervised basis. On behalf of the mother it was argued that such an order would be religiously discriminative. The Court refused to limit the maternal family’s time with the child. K v B: private law, represented the father at a fact finding hearing. The father was accused of 7 allegations, which included rapes, baby shaking, domestic abuse and controlling behaviour. No findings were made against the father. K v L: parental alienation (represented the father) – the mother refused any form of contact despite a child arrangement order being in place. A Guardian was appointed to consider a change of residence. Enforcement proceedings were brought which the mother failed to engage in. A committal order was made against the mother, suspended on the condition that she engages in the proceedings and with all orders. The mother only then complied with the child arrangement order. A cost order was made against the mother. S v S: private law (represented the mother) - following her diagnosis of cancer and the breakdown of her marriage, the mother resorted to alcoholism, which led to her children being removed from her care and her contact being limited to supervised. After some time, the mother’s physical and mental health improved and she was able to evidence her sustained abstinence from alcohol through alcohol tests and the fitting of a SCRAM bracelet. The case resulted in an agreed order of shared care, in accordance with the wishes of the children and the mother. H v S, H: private law (represented the paternal grandmother) - the grandmother applied for a child arrangement order in order to spend time with her granddaughter. As a result of suffering from mental health difficulties, the father was unable to spend time with his daughter. The grandmother’s application was successful. P v C: parental alienation (represented the father) – the mother refused any form of contact and alleged serious sexual abuse perpetrated by the father against the toddler. At the fact finding hearing the mother was found to have concocted the allegations in an attempt to cut the father out of the child’s life. A Guardian was instructed to consider a change of residence. Contact recommenced, the mother engaged with and complied with the child arrangement order. C v N: private law (represented the mother). At a fact finding hearing the Court found that the father had deliberately started a fire in his bedroom with the intention of killing himself and his two children. The Court made a ‘barring order’ under s.91(14) Children Act 1989 to prevent the father from making applications under s.8 of the Children Act 1989 for a term of 7 years, together with a non-molestation injunction for a term of 7 years. S v S: parental alienation (represented the father) – the mother was incapable of positively promoting contact between the children and their father. A Guardian was instructed and recommended a change of residence. The children were ordered to live with their father. Finance Nathalie is frequently instructed in financial remedy proceedings, from interim applications, FDAs and FDRs through to final hearings and appeals. Many of Nathalie’s cases involve complexities such as international property portfolios, multi-million pound assets, non-disclosure of assets, dissipation of assets, the acquisition of pre-marital or post-separation assets, and health complexities impacting on earning capacities. Nathalie’s strong negotiation skills result in the vast majority of her cases settling with Consent Orders, which often results in her lay clients avoiding significant legal costs. When attending final hearings, Nathalie strives to achieve the best possible outcome for her lay clients by utilising a forensic and persuasive approach. Private Remote FDR Hearings Nathalie is available for private FDR hearings and Early Neutral Evaluations. For more information on private remote FDR hearings please click here. Cases: M v M: finance proceedings (represented the husband). Complex three-day final hearing. The sole asset was the unregistered family home which had been built on land registered in the wife’s name. The property was landlocked, with a ransom strip around the property and access to the highway was by way of a revocable licence. The evidence of the SJE property valuer was challenged. The Court found the wife and her family to be dishonest having pressured the husband into selling the previous marital home and applying the net equity into the new build, with the intention of preventing him from benefiting from the new property. The Court ordered the property to be sold in order for a lump sum to be paid to the husband. E v E: finance proceedings (represented the wife). One day hearing before a High Court Judge to determine complex disputed jurisdiction points of law and fact under Brussels II Regulations 2201/2003. The husband accepted the British divorce petition was lodged eight days before the German divorce petition, but the husband argued that the fivemonth delay in serving the petition meant the German Court was first seised. The wife successfully argued that the British Court was first seised, the wife had not failed to take the required steps, much of the delay was outside of the wife’s control, and the husband had failed to serve a translated petition on the wife in breach of the Regulations. At the final hearing H was ordered to pay W a lump sum of £98,000, together with a pension sharing order in W’s favour and W retained her own property. W received 73% of the non-pension assets. S v C: finance proceedings (represented the husband). Complex case involving allegations of hidden assets, dissipation of assets, stollen gold, transferring sums to relatives to hold, mental ill-health and ringfencing of non-matrimonial inheritance and liquidated business assets. The husband achieved a favourable outcome, retaining 62.71% of the liquid assets. B v B: finance proceedings (represented the wife). The husband had failed to engage in the financial proceedings and disregarded all court orders. The wife successfully argued that adverse inferences should be drawn against the husband. The wife was awarded 84.31% of the total disclosed assets. A costs order was made against the husband. I v I: finance proceedings (represented the wife at the final hearing and on appeal). Complex case involving properties abroad, hidden assets, hidden income and non-disclosure, resulted in the commissioning of a private detective’s report. The Husband was found to be dishonest and adverse inferences were drawn against him. As a result, the Court ordered the FMH to be transferred to the Wife and ordered the sale of the foreign properties, with the sale proceeds being applied to discharge the FMH mortgage. Any remaining sums from the sale proceeds were to be retained by the Husband. The Husband appealed but the Wife successfully defended the appeal. A v A: finance proceedings (represented the wife at the final hearing). Complex case due to the Husband living in Germany, the Wife living in the UK and the FMH being in an uninhabitable state, having been ‘gutted’ by the Husband many years prior to the final hearing. The Wife and children had lived in a small, converted garage annex for years. The FMH had not sold due to its state of disrepair. The Wife achieved a favourable outcome of 90% of the FMH net equity. H v H: financial proceedings (represented the wife at FDR). The wife was the primary carer of the children of the family. The parties both had good income levels, but they had significant debts of c.£126,000 between them, which the wife argued was due to the husband’s frivolous and reckless spending. Settlement was reached at FDR by way of sale of the FMH with 65/35 in the wife’s favour, plus a 46% share of the husband’s pension. H v I: financial proceedings (represented the wife at final hearing). A complex case involving properties abroad, hidden assets, hidden income and non-disclosure, resulting in the commissioning of a private detective’s report to uncover the truth. The husband was found to be dishonest and adverse inferences were drawn against him. As a result, the Court ordered the FMH to be transferred to the wife and ordered the sale of the foreign properties, with the sale proceeds being applied to discharge the FMH mortgage. Any remaining sums from the sale proceeds were to be retained by the husband. O v O: financial proceedings (represented the husband) – this complex final hearing involved multiple properties, allegations of fraud, disposal of assets and hidden assets abroad. R v T: divorce (represented the husband) - the parties had a civil ceremony with the intention of having a religious ceremony two months later. They had planned to consummate their marriage after their religious ceremony. Unfortunately the parties separated before the religious ceremony had taken place. As the marriage had not been consummated the husband applied to annul the marriage under s.12 Matrimonial Causes Act 1973 on the basis of ‘wilful refusal’. The factually similar case authority of A v J (Nullity Proceedings) [1989] 1 FLR 110 was referenced. The wife consented to the husband’s application, however the husband was unable to bring himself to apply for Decree Nisi in order to bring the marriage to an end. The husband applied for the dismissal of his nullity application, the wife opposed this application. The Court allowed the husband’s application on the basis that the husband could not be forced to apply for Decree Nisi. B v B: financial proceedings (represented the wife) - the complexities concerned calculating a teacher’s final salary pension, the instruction of a pension actuary was required before settlement could be reached. D v D: financial proceedings (represented the wife) - short marriage without properties or children, settled at FDA, the arguments concerned the possession of valuable wedding jewellery and other gifted items including a brand new Mercedes. P v P: financial proceedings (represented the husband) - this case involved successful multiple-site estate agency businesses and a large number of properties within and outside the UK. Settlement was agreed between the husband and wife over the ownership of the properties. L v L: financial proceedings (represented the husband) - long marriage, settled at FDR, larger lump sum agreed in lieu of a pension share. S v O: financial proceedings (represented the wife) - concerned multiple investment properties and parcels of land. The complexities included the husband’s failure to engage in the proceedings, impending possession proceedings and conduct arguments. Family Law Arbitration Nathalie is a qualified Arbitrator in the Children Scheme and she welcomes instructions to act as the Arbitrator, or to attend arbitrations in children related matters.

Nicola Martin

Overview Nicola (formerly Simpson) Martin, former Head of the Family Law Group, is one of a minority of experienced family lawyers who not only conducts high net worth ancillary relief proceedings but also complex care cases (involving death or serious injury to a child) and sensitive private law children matters, including abduction and relocation. With experience over 30 years spanning from appearances before magistrates to the Privy Council, Nicola brings a pragmatic and helpful approach to her cases and is renowned for skilful cross examination, retaining an empathy with clients from all walks of life. Family Nicola (formerly Simpson) Martin, former Head of the Family Law Group, is one of a minority of experienced family lawyers who not only conducts high net worth ancillary relief proceedings but also complex care cases (involving death or serious injury to a child) and sensitive private law children matters, including abduction and relocation. With experience over 30 years spanning from FPC to Privy Council Nicola brings a pragmatic and helpful approach to her cases and renowned for skillful cross examination, retaining an empathy with clients from all walks of life. Private Remote FDR Hearings Nicola is available for private remote FDR hearings. For more information on private remote FDR hearings please click here. Recent notable cases include Q v R (intractable contact) [2017] EWFC B35 (28 June 2017) Ancillary Relief high net worth involving assets worldwide and allegations of hidden assets and non disclosure [2014] Care proceedings involving serious injuries, including fractures and brain injuries to a baby. Consideration of whether the extended family were implicated and if not whether the children could be sufficiently safeguarded within the family [2014] Contested residence and internal relocation contact proceedings with background of serious assault, alleged assault on a child with social services and Police involvement [2014] High value ancillary relief involving pre martial assets and disputed dissipation [2014] Representing young mother in care proceedings. Difficult issues in relation to extended family, history of removal of previous children, parents abusive relationship [2014] Representing father in relation to high net worth Sch 1 Children’s Act claims, including overseas trusts. Application to strike out and variation of child arrangements. International elements [2014] Complex Ancillary Relief case with allegations of hidden assets. Previous intevener proceedings. Future ownership of joint business [2014] Representation of a young mother in care proceedings resulting in return to her of 3 year old child and retention of unborn baby. Allegations of drug taking and chaotic lifestyle [2014]

Nicola Brown

Overview Family barrister Nicola Brown, who joined 3PB in December 2020, specialises in care and placement proceedings and acts for local authorities, parents, guardians and grandparents/other interested parties, in cases involving serious non accidental injury, sexual abuse, chronic neglect, death of the child and fabricated and induced illness (FII). Nicola practiced from another chambers in Manchester until 2010, where she specialised in personal injury and clinical negligence. She therefore has considerable experience of analysing and simplifying complex medical evidence. She is experienced in the handling of expert witnesses, particularly medical experts and she readily gets to grips with questions involving the causation of injury. Prior to joining 3PB, Nicola worked as an in-house advocate for Staffordshire County Council for a number of years, a role in which she has undertaken many cases involving allegations of neglect, emotional, sexual and physical abuse, child death, FII and spousal killing. She has a particular interest in jurisdictional issues having studied international law including conflicts of jurisdiction and law as part of her LLM. She has also conducted cases involving arguments of designation between Local Authorities. Nicola has always considered client care to be of the highest importance. She has always been commended for the way in which she puts her clients at ease and ensures that they understand their case. She is approachable, hard working and empathetic. Nicola has lectured in law at LLB level and has also been employed as a trainer on both the LPC and the BPTC. She has used her experience of teaching and training in the creation and delivery of bespoke training courses for solicitors, barristers and social workers. Family Care and Placement Proceedings Family barrister Nicola Brown now practices exclusively in care and placement proceedings, in which she represents all parties. She has a particular interest and expertise in cases involving non accidental injuries and fabricated/induced illness, due in part to her background as a clinical negligence lawyer but also to her experience of representing the Local Authority in such cases. She undertakes fact finding hearings. She has been involved in cases in which children have given evidence and also where vulnerable adults are alleged to have caused significant harm. She has been involved in many cases where placement orders have been sought and cases beyond care proceedings, notably contested adoptions and adoption breakdowns. Private Law Nicola undertakes private law cases, particularly when these involve finding of fact hearings. Her role as a local authority advocate increasingly frequently crossed the threshold between public and private law and she has a particular interest in case where there are allegations of harm. Legal training Nicola created and delivered a two day training course for Social Workers, entitled Courtroom Skills, to assist with the process of giving evidence. She has created and delivered advocacy training and bespoke training on interim removal hearings. She has delivered a lecture on the use of expert witnesses at a CAFCASS conference. Nicola will create and deliver bespoke training courses for clients to provide training on specific areas of interest. Notable Cases P and R [2023] EWFC 276 (B): Finding of Fact Hearing in respect of fracture to newborn baby's leg. The local authority's plan was adoption. The case was complicated by a threshold document which alleged historical matters, including allowing the child to have contact with a sex offender. The judgment exonerated the mother from any wrongdoing and the children were ultimately rehabilitated to her care. A County Council v A Mother & Ors. [2021] EWFC 104 (reported): Represented a local authority in an unusual and difficult High Court case involving an allegation of spousal murder by poisoning. Ultimately the authority sought supervision orders in respect of the children, who had undoubtedly been harmed by the death of their father, the allegation, the family conflict and the criminal investigation but not any parenting deficiency on the part of their mother. Re Y [2020] (unreported) : Acted for a LA in case involving protracted discharge of care order proceedings brought swiftly after care proceedings. The case featured successful applications for non molestation orders and high court injunctions, the termination of PR agreements, declaration of parentage and a section 91(14) order preventing further applications being brought without the leave of the court for 2 years. Re S [2020] (unreported) : Finding of fact hearing in which a child gave live evidence about allegations of sexual abuse against a step parent. Re D + Ors (Children) 2017 EWFC B87 (reported) Re DS [2017] (unreported) : Acted for a LA in a case involving the death of a child by drowning. Finding of fact hearing to establish parental culpability for the death. Press interest in light of ensuing criminal proceedings. Re T [2016] (unreported) : Acted in care and placement proceedings involving a large sibling group; allegations of sexual abuse. Earlier proceedings resulted in findings that male children were not at risk of sexual harm in parents’ care. Subject proceedings necessitated the challenging of those findings. Re Z [2016] (unreported) : Acted in protracted care and placement proceedings involving allegations of physical harm, international jurisdiction (several applications to transfer proceedings pursuant to Article 15 Brussels 11) prohibition of contact orders, assessment of potential carers in other jurisdictions, how such assessments can proceed particularly when the host country asserts sovereignty to control any such assessments.

Oliver Nunn

Overview Oliver Nunn is a specialist property law barrister who is known for his clear, concise and robust style of advocacy, combined with a personable and pragmatic approach. His successful practice covers the full spectrum of property- related disputes. He has particular expertise in Landlord and Tenant disputes in the private residential and social housing sectors, agricultural tenancies and commercial leases. He has significant experience representing institutional investors such as housing associations and local authorities in actions for possession and injunctions, including where there are public law and Equality Act arguments. Oliver has extensive experience of seeking injunctions, committals and closure orders under the Anti-Social Behaviour, Crime & Policing Act 2014. He is also instructed in cases of forfeiture, relief and Rent Act matters. Oliver is also experienced in disputes arising from both business to business and consumer contracts, in particular equine matters involving the purchase of animals where there are arguments of misrepresentation and breach of contract. He is instructed in cases concerning the sale of goods, machinery, services, and other contractual disputes which cross over into the Property sphere, such as specific performance. He offers clear, concise and comprehensive advice, sympathetic to the wider commercial interest of the client. Oliver is involved in a number of initiatives to improve equality, diversity and access at the Bar. He sits on the Midland Circuit Social Mobility Committee and regularly speaks on the Sutton Trust's Pathways to Law programme. Oliver mentors through Lincoln’s Inn and the Future Bar Programme at DeMontfort Law School. He also established the Jeffers-Nunn Award at Leicester Law School, which provides financial support and mentoring in the form of a scholarship to aspiring Barristers from backgrounds which are underrepresented in the profession. Appointed as a Deputy District Judge on the Midland Circuit in September 2021, Oliver was also made an Honorary Associate Professor at the University of Leicester in 2022, where he lectured both Public and Contract Law. Away from chambers, Oliver enjoys cooking, jazz, follows Formula 1 and the Leicester Tigers. Residential landlord and tenant housing Oliver Nunn is a specialist property law barrister who is known for his clear, concise and robust style of advocacy combined with a personable and pragmatic approach. His successful practice covers the full spectrum of Property related disputes, representing clients at all levels, including the County Court, Business and Property Courts, Specialist Tribunals and the High Court. Oliver has particular expertise and substantial experience acting and advising on matters such as: Private Landlord and Tenant Social Housing Unlawful Eviction Agricultural Tenancies Commercial Leases Forfeiture & Relief Trespass Adverse possession Oliver is well particularly regarded for his Landlord and Tenant practice, he is regularly instructed by Institutional Investors, Insurers and Local Authorities in matters such as: Possession Injunction & Committals Anti Social Behaviour remedies pursuant to the ASBCPA 2014 Public Law and Equality Act challenges Policy Advice Housing Disrepair Claims Having lectured in Public Law at the University of Leicester, Oliver offers significant experience in the Housing Law sector and is often brought in to advise and act in more complex possession proceedings which may include; novel grounds for possession, succession, injunctive relief, Public Law defences, arguments raised under the Equality Act. Oliver is regularly instructed by Local Authorities, Housing Associations and the Police in seeking remedies under the ASBCPA 2014 and the Crime & Security Act 2010, including Injunctions and Closure Orders. He has significant experience in the use of injunctions to regulate conduct, not just in relation to individuals and properties, but also wider areas such as town centres, including against ‘persons unknown’. Oliver is recommended for his technical approach and is sought after for his advice in claims for unlawful eviction and on tactics navigating the complex case law and statutory framework associated with those high value claims. Commercial Oliver is regularly instructed to settle pleadings, advise and represent clients in contentious commercial disputes arising from both business to business and consumer contracts. He has considerable experience in dealing with a range of commercial disputes; including claims founded upon contracts for the sale of goods and/or services, building disputes, sale and installation of defective machinery, negligent references and the purchase of vehicles which are said to have been stolen. Oliver has a particular academic interest in contract law, which he lectured at the University of Leicester. Oliver has considerable experience in contractual claims with significant personal importance, including major events such as weddings or holidays where enhanced damages may be sought for distress or loss of enjoyment. He offers clear, concise and comprehensive advice, sympathetic to the wider commercial interest of the client. Oliver is a equine law specialist and receives many instructions to advise, represent and settle pleadings on a wide range of equine and animal disputes. He also has experience of claims founded upon the Animals Act 1971. He is also very experienced in disputes over the purchase of animals. Oliver provides advice, representation and settles pleadings in claims for refunds, rescission, other losses and misrepresentation. For professionals and suppliers alike, Oliver also accepts instructions in relation to recovery and enforcement of debts and other commercial or contractual disputes.

Paul Joseph

Overview Costs barrister Paul Joseph began his career at Wragge and Co (now Gowling WLG) in Birmingham and then spent nine years in the commercial litigation department at Edge Ellison (now Squire Patton Boggs). After four years as an attorney at law in the Cayman Islands, he returned to the UK in 2005 and transferred to the Bar. He joined 3PB in January 2024 from another large chambers in Birmingham, where he had been practising for 18 years. Paul has built up a busy practice and is an established and recognised costs specialist, consistently rated by both Legal 500 and Chambers UK. He understands the costs issues facing solicitors and clients in the current post Jackson climate. Paul recently appeared in the Court of Appeal, acting for the Home Secretary, in the landmark case of Isah -v- The Secretary of State for the Home Department [2023] EWCA Civ 268 in March 2023 about costs and summary assessment. In August 2021, Paul was appointed a Deputy Costs Judge of the Senior Courts Costs Office in London. Paul has acted for HM Government since 2010. He was instructed to advise in relation to the costs issues arising out of the many claims against the Ministry of Defence (MoD) brought by Iraqi civilians following the invasion of Iraq in 2003. He has considerable experience of issues arising out of the pre-action Protocols and the fixed cost regime. He is often instructed to appear on appeals and is frequently instructed on costs and case management hearings and detailed assessments. He appears in courts throughout England and Wales and regularly appears in the Senior Courts Costs Office and in the Court of Appeal. Paul also accepts instructions on a Direct Access basis. Outside of a busy work schedule, Paul enjoys playing first violin in the Stratford-upon-Avon Symphony Orchestra (where he is also a trustee) and, as a former member of the CBSO Chorus, still sings in a local Warwickshire choir. Costs Paul Joseph is rated as the best costs specialist barrister in the Midlands and one of the UK's top counsel in this specialist field. He is recognised in Legal 500 and Chambers UK as a top costs specialist. In August 2021, he was appointed a Deputy Costs Judge of the Senior Courts Costs Office in London. Paul is one of the senior members of 3PB's dedicated Costs Team. He works extensively for HM Government and, currently listed on the Attorney General’s Regional B panel, is regularly instructed by the GLD’s costs team on a wide variety of costs matters. Paul dealt with, for example, all the costs work in connection with claims made by Iraqi civilians against the MoD arising out of the invasion of Iraq in 2003; and similarly in relation to the MoD's actions in Afghanistan and during the Kenyan Emergency. More recently, Paul acted in Robin Makin-v-Ministry of Justice in which Paul obtained an Extended Civil Restraint Order and the removal of a solicitor advocate's anonymity as well as over 20 individual costs orders (of which nearly half were indemnity orders) and 10 declarations of totally without merit. Paul undertakes all types of costs work - across all areas of law except criminal cases - such as: Case and Costs Management Conferences Allocation Hearings (and now assignment issues) Wasted Costs Applications Security for Costs Applications Oral reviews of Provisional Assessments Detailed Assessment hearings (whether in the SCCO or anywhere else) Drafting Points of Dispute and Replies Part 36 issues Appeals relating to costs matters, including appeals to the Court of Appeal Reported Cases R (on the application of Jerry Isah) -v- The Secretary of State for the Home Department [2023] EWCA Civ 268: the extent and scope of summary assessment of costs. Robin Makin-v-Ministry of Justice [2023] EWHC 72 (KB): defending 4 applications for permission to appeal within detailed assessment proceedings, all of which were dismissed and declared to be totally without merit. Robin Makin-v-Ministry of Justice [2023] EWHC 1920 (KB): application to remove the anonymity granted to a solicitor advocate whom the MOJ wished to report to the SRA for serious misconduct. R (Jawad Faqiri) -v- Upper Tribunal (Immigration and Asylum Chamber) and Secretary of State for the Home Department [2019] EWCA Civ 151 AL (Albania) -v- Secretary of State for the Home Department [2018] EWCA Civ 1183: whether or not the Secretary of State had delayed unreasonably. R (Gudanaviciene) -v- Immigration and Asylum First Tier Tribunal [2017] EWCA Civ 352: Circumstances in which the court will make an order for costs against a Tribunal or inferior court. Rohan Ghising –v- Secretary of State for the Home Department [2015] EWHC 3706 (QB): Appeal concerning the recoverability of a retrospective success fee. Assaubayevs –v- Michael Wilson and Partners Limited [2014] EWHC 821 (QB) and [2014] EWCA Civ 1491: Extent of the court’s supervisory jurisdiction over bodies which pretend to be recognised legal bodies. J E Jamaica –v- Secretary of State for the Home Department [2014] EWCA Civ 192: Operation of CPR Part 52.9A. G (a child by her mother and litigation friend, M) –v- Kingston upon Hull City Council (Lawtel 01/10/13): applicability of SCCO guidelines on summary assessment to detailed assessments. Rangos –v- Secretary of State for Innovation [2012] EWHC 3186 (Ch): dismissal of an appeal against Costs Master’s decision to award costs against a receiving party notwithstanding that it beat an offer under CPR Part 47.19. Tibbles –v- SIG PLC (T/A Asphaltic Roofing Supplies) [2012] EWCA Civ 518: extent of the discretion to vary or revoke an order pursuant to CPR Part 3.1(7). Mediation Paul Joseph is a CEDR accredited mediator and is happy to accept instructions to act as mediator in any costs or commercial dispute. He takes a pragmatic approach to mediations and recognizes that parties may not be able to settle a dispute on the day of the mediation itself.

Rachel Bloxwich

Overview Rachel Bloxwich joined 3PB in April 2021, having spent nearly 15 years practising as a family solicitor with law firms in the West Midlands. Most recently, Rachel worked for nearly four years with FBC Manby Bowdler as an Associate in their top-rated family team in Wolverhampton. Rachel has specialised since qualification in 2007 in all aspects of family law and has gained extensive knowledge from her focus on financial remedy, private law children cases and domestic violence disputes. This has seen her build up a strong practice in divorce and separation cases, financial matters and advising on the arrangements for children. Outside her busy work commitments, Rachel is a school governor and chairs their finance committee. Family Rachel Bloxwich is a former solictor-turned-barrister who specialises in handling divorce, separation, and financial matters and arrangements for children. Her busy caseload includes the following: Financial Remedy Rachel has extensive experience in representing parties in financial remedy disputes, including cohabitation disputes. Rachel is known for taking a pragmatic and focused approach, understanding the need for cost-effective solutions for clients. She has experience of dealing with applications where expert evidence is required including actuarial and accountancy reports and where there are disputes concerning pre- and post-acquired assets. Private Law Rachel has a wide range of experience in representing parties at all stages of private law disputes, including disputes involving grandparents. Rachel has extensive experience in complex private law matters involving: Parental alienation Implacable hostility Domestic abuse Physical abuse Sexual abuse Physical abuse Drug or alcohol misuse S 91 (14) Orders Mental health issues Rachel is adept at dealing with applications where there is an overlap between private law disputes and domestic violence injunctions. Rachel is experienced in dealing with applications for Special Guardianship Orders, including those which have arisen from care proceedings. Rachel has experience in representing parties where expert evidence is required from independent social workers, psychologists and teachers and where there is social services’ involvement. Rachel is equipped to deal with applications concerning specific issues such as school placements and internal relocation. Rachel has experience of representing vulnerable parties, including those where capacity assessments are necessary and intermediaries or other participation directions are required. Domestic Violence Rachel has a wealth of experience in representing applicants and respondents in applications for non-molestation and occupation orders. This includes representing parties where extensive police disclosure and other expert evidence is required. Rachel is known for her sensitive approach and understanding of the wider issues of the parties’ needs and circumstances.

Rebecca Franklin

Overview Rebecca is a family law barrister – called to the Bar in 2001 - who practises in all court arenas, advising and providing representation in private law children matters, public law, domestic violence and injunctions. Rebecca has a down-to-earth manner and assists clients achieve the very best outcome with a sympathetic, yet robust approach. She prioritises thorough preparation and client care, particularly assisting lay clients to achieve an understanding of the legal intricacies of their case and all avenues open to them both within and outside of the court process. She has a wealth of experience in representing the most vulnerable clients, including those with learning disabilities and mental health difficulties, having been instructed by the Official Solicitor on numerous occasions. Rebecca is also instructed by a number of different local authorities in public law cases, by Children’s Guardians, minors acting by way of a solicitor and parents and other family members. Rebecca has conducted lengthy and complex fact-finding hearings involving significant injuries (including those of a fatal nature) to children, neglect and sexual abuse. She has presented many legal arguments including subjects such as implacable hostility and jurisdiction and been involved in cases with significant domestic violence. She has expertise and experience in child abduction matters concerning both Hague Convention and non-Convention countries. Rebecca is able to accept Direct Access instructions and welcomes enquiries in that regard. Family Rebecca is a family law barrister �� called to the Bar in 2001 - who practises in all court arenas, advising and providing representation in private law children matters, public law, domestic violence and injunctions. Rebecca has a down-to-earth manner and assists clients achieve the very best outcome with a sympathetic, yet robust approach. She prioritises thorough preparation and client care, particularly assisting lay clients to achieve an understanding of the legal intricacies of their case and all avenues open to them both within and outside of the court process. She has a wealth of experience in representing the most vulnerable clients, including those with learning disabilities and mental health difficulties, having been instructed by the Official Solicitor on numerous occasions. Rebecca is also instructed by a number of different local authorities in public law cases, by Children’s Guardians, minors acting by way of a solicitor and parents and other family members. Rebecca has conducted lengthy and complex fact-finding hearings involving significant injuries (including those of a fatal nature) to children, neglect and sexual abuse. She has presented many legal arguments including subjects such as implacable hostility and jurisdiction and been involved in cases with significant domestic violence. She has expertise and experience in child abduction matters concerning both Hague Convention and non-Convention countries. Rebecca is able to accept Direct Access instructions and welcomes enquiries in that regard. Public Law Care and Adoption Rebecca is instructed by a number of Local Authorities in public law cases and also represents parents, children (by way of their Guardian or personally when age-appropriate) and other connected persons. She is experienced in complex, lengthy proceedings in the High Court of the most serious in nature, including sexual abuse and fatalities. Reported Cases: B (Children) [2010] EWCA Civ 324 Private Law Children and Domestic Abuse Rebecca has conducted lengthy and complex fact-finding hearings, legal arguments regarding implacable hostility and cases involving significant domestic violence. She has expertise in child abduction matters concerning both Hague Convention and non-Convention countries.

Roger Thomas

Roger Thomas is a busy specialist family finance barrister, representing litigants under the Matrimonial Causes Act 1973, the Civil Partnership Act 2004 and cohabiting couples under the Trusts of Land and Appointment of Trustees Act 1996. He joined 3PB from another large barristers' chambers in Birmingham in November 2023. Having spent more than 20 years in commerce and industry before coming to the Bar, Roger brings to his work a wealth of first-hand experience at the ‘coal face’ which enables him to quickly understand the relevant issues in cases and to advise both professional and lay clients alike in simple, easily-understood terms. Family Family barrister Roger Thomas enjoys a thriving family finance practice, representing litigants under the Matrimonial Causes Act 1973, the Civil Partnership Act 2004 and cohabiting couples under the Trusts of Land and Appointment of Trustees Act 1996. He is regularly instructed in cases of high net worth, particularly where the valuation of businesses and farms is concerned and in which his previous experience as a Chartered Management Accountant can provide useful insights. Roger is used to dealing with family assets and disputes over business ownerships/shareholdings, wills and trusts. Roger is a skilled advisor and negotiator and is adept at putting even the most nervous client at their ease and instilling confidence in them. In aiming to obtain the best possible outcome for his lay clients, Roger strives to find a negotiated solution thereby saving time, money and trouble for them. However, if a final hearing becomes inevitable, he is an incisive and tenacious advocate in his client’s cause. Prior to coming to the Bar in 2001, Roger qualified as a Chartered Management Accountant and enjoyed a 20-year career in the manufacturing and commercial sectors. Much of his career was at Board level and a significant proportion of his work was of an international nature. Notable Cases Elliott v Butler [2016] EWCA Civ 953; Acting for the wife. Portfolio of properties all in the wife’s sole name valued at c.£4m but underpinned by mortgages of c.£3.5m. District Judge made an order for sale of whole portfolio to relieve the wife of the burden of the mortgages. Husband took up occupation of the only property with significant equity – a farm in the Lake District – and barricaded himself in, using every legal device imaginable to resist his removal. Secured an order in the High Court for his committal to prison, which was upheld in the Court of Appeal, allowing the portfolio to be sold. K v K: Acting for the husband. Assets in Australia worth AS$52m and a flat in London’s Piccadilly worth £2m. The parties had entered into an financial settlement agreement in Australia to deal with their Australian assets and a ‘side agreement’ in relation to the husband’s flat in Piccadilly by which he had agreed the wife could reside their when in London. Wife took up full time occupation in the flat and claimed home rights. Issues were the status of the ‘side agreement’ both in Australian law and English Law; whether the flat was a ‘matrimonial home’ under s.30(7) FLA 1996; and whether the wife had acquired any rights in the property. Consent order achieved by which the wife agreed to vacate the property. R v M: Acting for the wife. The wife’s divorce petition was defended by the husband on the grounds of domicile, he asserting that he was domiciled in the UAE and that he had obtained an alimony order in the Dubai courts. Trial of the issue resulted in a finding that the husband never lost his domicile of origin in England & Wales. Husband ordered to instruct his bank in the Isle of Man to pay the wife’s costs order. C v C: Acting for the wife. Husband and wife built a property in the grounds of the husband’s mother’s house and lived there for a number of years. Husband claimed in the divorce that the property was his mother’s and he had no interest in it, and also that his other assets were mortgaged to his mother. Uncovered undisclosed assets, including property developments and a Lamborghini in the husband’s name. Settlement subsequently obtained. F v R: Acting for the claimant in TLATA proceedings. Persuaded the court at trial that the claimant was subjected to coercive control by the defendant, including serious sexual assault, which vitiated her consent to the joint purchase of the property in dispute. Persuaded the court that all of the financial contributions to the purchase of the property were made by the claimant. Obtained a declaration that the claimant held 100% of the beneficial interest in the property and an order for costs. S v R: Acting for the claimant in TLATA proceedings / the defendant in Sch. 1 CA proceedings. Persuaded the court at trial that the declaration of trust entered into by the parties upon purchase of the property by which they had declared themselves tenants in common in unequal shares had not been varied by a later purported notice of severance of a joint tenancy. Obtained the dismissal of the defendant’s Sch. 1 application and an order for the immediate sale of the property together with a substantial order for costs. E v G: Acting for claimant in TLATA proceedings. Not long after purchasing a property together, the defendant disappeared. The claimant subsequently discovered that he had forged her signature to obtain loans which he had secured against the property and then fled the jurisdiction. Using social media and other tools, tracked the defendant down to an address in Ankara, Turkey, and then used the Hague Convention to serve him with the TLATA application in Turkey. H v H: Acting for the wife. Business assets (including the family home) over £5m and husbands SIPP worth £1.2m. The husband owned 75% of the shares in the dynastic family business which had been begun in the 1800s, some of which were held in a trust. The central issue was whether the wife had a claim over the business assets and, if so, to what extent. Resolved at trial on a needs basis with an award of £550k for housing plus a pension share of a further £450k. K v K: Acting for the wife. Assets worth £1.6m, including the parties’ civil engineering business. The issue was liquidity and how the wife could extract her entitlement to one half of the assets. Persuaded the court that this was one of those cases where “the goose may well have to go to market for sale…” Settlement achieved without a sale of the business. V v V: Acting for the wife who was living in the Netherlands. Assets worth £1.3m, including the wife’s inherited property worth £325k. Preserved wife’s inheritance intact and achieved 80:20 split of the other assets in her favour. Opposing Queen’s Counsel. O v O: Acting for the husband. Family home attached to family business (farm partnership) collectively worth c.£1m. The issue was the wife’s drastically curtailed life expectancy and how, if at all, that should affect the outcome after a marriage of almost 40 years. Persuaded the court that the wife’s award should be based on needs rather than sharing notwithstanding her testamentary wishes. Settlement achieved.

Sam Pentony

Overview Sam Pentony takes instructions for court representation, advocacy and advisory work - in 3PB’s 70-strong team of family law barristers. Sam joined 3PB in October 2020, having completed his first six pupillage at a specialist family set in the Midlands and became a tenant at 3PB in April 2021. He accepts instructions across the full spectrum of family matters including private and public law children proceedings and domestic abuse injunctions. Sam is developing his practice in financial remedies and is interested in matters relating to property including co-ownership and cohabitation of the family home. He is happy to accept instructions from first appointment to final hearing. Prior to joining the bar, Sam held specialist policy roles for trade bodies in the manufacturing and resources sectors. His work focused on environmental regulation, including the development of the Environment Bill, chemicals regulation (REACH) and environmental permitting and licensing. Sam has led on discussions with the UK Government relating to the chemical supply chain after Brexit. He also spent time in Brussels working alongside European trade associations in the development of technical and regulatory recommendations to the EU. Having worked with individuals and UK businesses across a variety of sectors, Sam is well known for his approachable manner and commercial outlook. Sam also previously worked as a paralegal in the family team of a Cambridgeshire law firm and so understands some of the unique pressures faced by solicitors and lay clients in the field of family law. When not working, Sam is passionate about blues music and plays the guitar when time allows. He recently took up running and when possible takes part in his local Parkrun. Family Sam Pentony is developing a busy practice in children proceedings and accepts instructions in both private and public law matters. He also accepts instructions in financial remedies and other matters relating to relationship breakdown. Public Law Children During pupillage, Sam represented local authorities and parents in cases up to and including final hearing involving emotional and physical abuse, domestic violence and drug and alcohol dependency. Despite his recent call, Sam has represented parties in cases involving complex jurisdictional issues and is keen to develop his practice in this area. He is also happy to accept instructions to provide written advice on jurisdiction, habitual residence, and related areas such as inherent jurisdiction. Sam has experience in and is happy to accept instructions involving: Discharge of care orders and adoption orders Special Guardianship and kinship placements Chronic neglect Section 38 (6) assessment ECHP plans and special educational needs Children separated from their appointed Children’s Guardian Deprivation of Liberty Private Law Children Sam has experience representing Applicants and Respondents including 16.4 Children’s Guardians and grandparents in private law proceedings. He also has experience in cases involving international relocation and is keen to develop his practice in this specialist area including cases of relocation within the UK. He has represented parties in cases involving: Intractable disputes Domestic violence Sexual abuse Substance misuse and addiction Learning difference International relocation Removal from the jurisdiction Sam accepts instructions in domestic violence injunctions. Financial Remedies Sam is developing his practice in financial remedies and is happy to accept instructions from First Appointment to Final Hearing. He has an interest in matters involving co-ownership and cohabitation of the family home. Sam also has experience in other cases relating to relationship breakdown such as: Contested divorce Judicial separation Freezing injunctions Recent cases include Z and X (Visit to Ukraine), Re [2024] EWHC 314 (Fam). FDR Hearing Service Sam Pentony is available for private remote FDR hearings. For more information on private remote FDR hearings please click here.

Samantha Smith

Overview Samantha Smith is a specialist family barrister and former-solicitor who has moved across to private practice after ten years working in-house for local authorities, employed as a senior in-house public family law expert for both Birmingham City Council and Worcestershire County Council. This has seen her representing local authorities in multi-day final hearings in care and adoption proceedings and advised on all matters of local authority decision-making in respect of families, including judicial review cases. Called to the Bar in 2007 and qualifying as a solicitor in 2011, Samantha joined 3PB in July 2022 and now accepts instructions in respect of public and private family law. She has built an excellent reputation as a highly competent and diligent lawyer, conducting advocacy as a childcare solicitor in the Family Court including appearing regularly in interim and final hearings. Family Samantha Smith is a specialist family barrister and former-solicitor who has moved across to private practice after ten years working in-house for local authorities, employed as a senior in-house family and public law expert for both Birmingham City Council and Worcestershire County Council. At Birmingham City Council, one of her roles included a two-year secondment exclusively as an advocate in the Family Court undertaking multi-day final hearings as well as appeals. Samantha has good experience of undertaking hearings that are complex, dealing with difficult circumstances as well as expert and vulnerable witnesses. Samantha has signicant experience of providing legal advice to children's services on policy matters placing them at risk of judicial review, for example advice about their NRPF subsistence policy, payments to foster carers and special guardians and the provision of services to children leaving care. Accordingly, Samantha is well versed at analysing risk and providing legal advice in a way that is robust, clear and pragmatic. She had conduct of a number of cases in the High Court and Court of Appeal including D (A Child) [2017] EWCA Civ 1695, a deprivation of liberty test case which was later overturned by the Supreme Court. Samantha has advised upon and represented children’s services in many applications for the authorisation of deprivations of liberty in respect of teenagers. She has experience of inter-jurisdictional cases, including children without leave to remain, family members living abroad and the placement of children out of the jurisdiction. Public family law Sam specialises in family law, including but not limited to: Adoption proceedings Care proceedings Child arrangements orders Contact disputes Deprivation of liberty Designation of local authority Domestic violence disputes Forced marriage Human Rights Act applications Injunctions Jurisdictional disputes Revocations of care and placement orders Secure orders Special Guardianship Threshold disputes (NAI, allegations of FII, sexual abuse, physical abuse and neglect) Wardship. Notable cases include X City Council v M [2023] EWHC 1767 (Fam): Represented local authority in a fact finding where the mother was alleged to have poisoned her child with salt on multiple occasions.

Sarah Bowen

Overview Sarah Bowen is a specialist practitioner in Employment, Discrimination and Education law. She has been recognised as a specialist in her field in Legal 500 and Chambers & Partners legal directories for many years. Sarah is regularly instructed in actions involving complex legal issues and technical arguments and is well regarded for her client skills and ability to assimilate complex cases into practical advice. She is often instructed to act in cases that are commercially sensitive, attract media attention or involve vulnerable persons. Sarah has extensive experience acting for claimants and respondents across the spectrum of employment and discrimination litigation including cases involving allegations of discrimination, unfair dismissal, breach of contract, TUPE and whistleblowing. She advises a broad range of clients including NHS Trusts/Providers, local authorities, regulatory bodies, education institutions (such as Universities, Colleges and Schools), FTSE 500 Companies and household brands. Sarah is committed to protecting and respecting your privacy. Please contact her for a copy of her privacy notice which sets out the basis upon which any personal data she may receive will be protected. Employment and discrimination Sarah has a particular interest in discrimination cases, with specific experience of representing clients in matters involving allegations of; sex (including pregnancy-related), race, religion/belief, age and disability. Sarah has also been instructed in actions involving claims of discrimination made by those other than employees under the provisions of the Equality Act 2010. Prior to joining the independent Bar Sarah was employed as an in house employment advocate for a national law firm. This background gives her a unique understanding of the challenges that solicitors face and their requirements. TUPE Acting on behalf of a claimant in a 5 day PHR dealing with the issue of whether there was a ‘relevant transfer’ pursuant to TUPE. The matter concerned complex issues relating to assignment and fragmentation within group companies. Sarah led complex legal submissions on behalf of the claimants, including submissions relating to corporate veils, which were also adopted by the Secretary of State for Business and Enterprise. Managing to avert liability for her client under TUPE by persuading the Tribunal that the Claimant’s employment had actually transferred to another Respondent. Successfully advising on who to pursue in a complex claim under TUPE in circumstances where the Respondent had attempted to conceal the same. This involved advice on specific disclosure applications so as to ascertain the true position. A complex case involving allegations of age and disability discrimination upon the background of a complex TUPE issue. In 2016 Sarah succeeded in an application to bring new claims against a new Respondent some 4 years post-issue (and some 2 years following an alleged TUPE transfer). Successfully applying to add a new respondent 18 months out of time when a TUPE issue arose in disclosure. Discrimination Sarah is frequently instructed in complex discrimination cases acting on behalf of both Claimants and Respondents across all protected characteristics. Lamb v The Business Academy Bexley UKEAT/0226/15/JOJ: Sarah acted on behalf of the Respondent before Simler P. The EAT provided clear guidance within the judgment as to the duties of the Tribunal in assessing the pleading of PCPs in reasonable adjustment claims and their application to the facts of the case. Sarah secured a finding of direct age discrimination on behalf of the Claimant in relation to the employer’s enhanced redundancy scheme which provides for a reduction in financial entitlement the closer an employee is to pensionable age. Sarah successfully represented the Claimant against ASDA Stores Limited in his claims of constructive dismissal, disability discrimination (s15, harassment and reasonable adjustments) and victimisation. In addition, following robust cross-examination the Tribunal concluded that the Respondent had subjected the Claimant to heavy-handed and intimidatory disciplinary and capability proceedings. Acting on behalf of a large employer (with 70,000 employees) to defend disability discrimination claims (on all bases under the Equality Act) arising from a shift and overtime policy. Sarah was involved preparatory elements of the claim (including how best to operate the policy moving forward) and was instructed to represent the respondent at the final merits hearing [settled]. Successfully representing the claimant against the National Oceanography Centre, in claims of unfair dismissal and disability discrimination, when he had been dismissed for drawing what the Respondent considered to be ‘sexually explicit’ or ‘pornographic’ images in the workplace. Sarah was praised for her ability to adapt the litigation process so as to meet the needs of her client who suffered from a significant mental impairment and greatly struggled with the Tribunal process. Sarah acted on behalf of a large health care sector employer who faced complex claims of disability, age and sex discrimination and unlawful deduction of wages by a senior employee. Following cross-examination of the claimant (4 days), all claims were withdrawn. Following withdrawal Sarah persuaded the Tribunal to award costs in the case (and upon instructions limited this to £20,000) against the claimant. In awarding costs, Employment Judge Moore stated that following cross-examination by Sarah just 25 per cent of the claimant’s original case stood up. Acting on behalf of the claimant against HSBC, Sarah made an application to amend to add a s15 Equality Act 2010 claim on the first day of the hearing. The application was granted and the Claimant’s case subsequently succeeded on this allegation. Sarah was described by Employment Judge Russell as ‘valiant’ in her pursuance of the Claimant’s case in her judgment. Unfair dismissal Sarah successfully represented the Claimant in his claim of constructive dismissal, persuading the Tribunal to conclude that the Respondent had subjected the Claimant to heavy-handed and intimidatory disciplinary and capability proceedings, extreme delay in dealing with his grievances and unreasonably withholding discretionary sick pay. Sarah successfully defended a claim of automatically unfair dismissal brought on the grounds of a flexible working request. Sarah successfully defended a complex constructive dismissal claim which was made against a large financial services company by a former senior manager. Successfully defending a claim that a failure to consider the Claimant for roles within various group companies/subsidiaries in a redundancy situation gave rise to an unfair dismissal by relying on the corporate veil and contractual arguments. Whistleblowing Sarah was instructed on behalf of two Respondent’s in the aerospace industry who are defending complex allegations of automatically unfair dismissal and detriment under the whistleblowing regime. Sarah was instructed on behalf of the Claimant in a complex whistleblowing claim against an international leading pharmaceuticals company. Claims related to a systematic and repetitive campaign of detriments which included a demotion, bonus reduction and culminated in dismissal. Once instructed Sarah was able settle the case a significant sum and on favourable terms. Sarah was instructed on behalf of a Claimant who was unceremoniously removed from his employment, with immediate effect shortly after he had raised concerns about the lawfulness of his employer’s financial reporting and billing to clients [settled on very favourable terms]. Breach of Contract Sarah acts on behalf of employers and employees in injunctive proceedings including those relating to restrictive covenants and undertakings. Sarah regularly accepts instructions to draft such contractual clauses, injunction applications and breach of contract proceedings. Acting on behalf of an employer seeking to enforce restrictive covenants contained in both a contract of employment and share purchase agreement. Advice was provided on process, enforceability and alternatives to injunctive proceedings. In addition, the employer received advice on the prospect of pursuing the new employer in addition to the employee. Advising on the prospects of pursuing an employer for several alleged breaches of contract including notice pay, misrepresentation and other benefit entitlements. Acting on behalf of a Claimant pursuing a breach of contract claim for permanent health insurance. Advising on a proposed claim for breach of contract relating to death in service insurance. Procedural instructions Successfully applying to bring new claims against a new Respondent some 4 years post-issue (and some 2 years following an alleged TUPE transfer). Levers v 170 Community Project UKEAT/0255/14/RN: Sarah successfully acted on behalf of the Respondent before Langstaff P. in defending an appeal against the Tribunal’s assessment of time limits following strike out of the Claimant’s claims. Securing a costs order of £20,000 after successfully defending complex claims of race, age and disability discrimination and persuading the Tribunal that the Claimant was untruthful. Securing a wasted costs order against a Claimant’s solicitors of approximately £3,000. Successfully resisting the Claimant’s application for relief from sanction in respect of an unless order. Acting on behalf of a Respondent in a 3 day PHR and successfully striking out all claims on the basis that they had no reasonable prospect of success (which included discrimination). Direct Access Sarah accepts instructions on behalf of Claimants and Respondents on a direct access basis whether that be for representation within legal proceedings or otherwise. To that end, Sarah has sat as an independent investigatory, disciplinary and appeal officer on behalf of employers (dealing with cases up to director level) and also regularly works alongside HR specialists. Case example: Discrimination (finding of fabricated evidence): McCoy v Lyndon Property Maintenance Limited, London Central ET 2016 (Direct Access) – Working in an extremely tight time frame (days) Sarah successfully guided her Respondent client so as to draft statements, make applications to the Tribunal and obtain expert forensic evidence. Sarah then persuaded the Tribunal that justice required the admission of the expert evidence on day 1 of the final hearing (in the absence of prior express permission) and she went on to win the case. In the judgment, the Employment Judge concluded that the claimant’s text messages were in fact ‘created’ for the purposes of misleading the Tribunal and pursuing her case (thus creating ample grounds for a full costs application). Sarah is able to provide bespoke advice and assistance to Respondents outside of legal proceedings such as drafting, ad-hoc advice, and training (including mock tribunals). Sarah is able to structure redundancy and TUPE consultations/processes and guide employers so as to ensure that they comply with legal requirements. For further information about instructing Sarah on a direct access basis please contact 3PB Barristers who will be happy to direct you to either Sarah or the 3PB Clerking team. Training Sarah regularly provides training, seminars, mock tribunals and file surgeries including to national insurers, the NHS and ACAS. Education Sarah accepts instructions on behalf of parents, young persons, schools, academies, local authorities and Universities to advise in relation to: Discrimination complaints against education institutions. Breach of contract claims against fee-paying schools and Universities (including claims for misrepresentation). Employment law related complaints brought against education institutions. Sarah has a specialist discrimination practice and accepts instructions in all areas e.g. education, employment, service provision. As a result, Sarah has significant experience of claims brought under the Equality Act 2010 for disability, sex (including sexual harassment), age, sexual orientation and gender reassignment discrimination, harassment and victimisation. Sarah is also a specialist employment practitioner, regularly advising and representing education institutions and employees in litigation. Examples include: Acting for a specialist school defending claims of unfair dismissal and disability discrimination brought by a teacher who was dismissed for gross misconduct consisting of the unreasonable use of physical restraint on a pupil. Defending a claim of disability discrimination brought by an agency worker on behalf of a school. Advising a school in relation to a claim of pregnancy and maternity discrimination and unfair dismissal brought by a teaching assistant. Representing a multi-academy trust in a claim of race and disability discrimination. Complaints included alleged racist behaviour by pupils towards a tutor. Representing a school in a 10 day hearing in a case involving tens of claims including the spectrum of discrimination complaints, whistleblowing detriment and constructive dismissal. Sarah has accepted instructions on several complex disability discrimination claims involving universities. Further information about Sarah’s experience can be found on her “Employment” profile.

Sarah Tierney

Overview Sarah Tierney practises exclusively in children law and has considerable experience in public law proceedings. Please click on the link below to view her family law expertise. Family Sarah qualified as a solicitor in 1999 and has over 19 years of experience of representation in public and private children law. She became a member of the Children’s Panel in 2005 and throughout her career has undertaken significant advocacy on behalf of parents and children. She has been sought out to act for children, parents and other family members in particularly complex care, adoption and secure accommodation proceedings. Sarah has substantial trial advocacy experience which has included cases involving allegations of non-accidental injury, chronic neglect, domestic violence, emotional abuse, multi-jurisdictional aspects and human trafficking. She is able to deal sensitively with difficult and complex matters and has considerable experience in representing vulnerable adults and young people . Reported cases X County Council -and- BE(1) AD (2) CD (BY HER CHILDREN'S GUARDIAN) (3) [2021] EWFC 112 Re G (Abduction: Consent/Discretion) [2021] EWCA Civ 139 Z (INTERIM CARE ORDER) - [2020] EWCA Civ 1755 A CITY COUNCIL & M & F & C - [2020] EWHC 947 (Fam) K, T and U (Placement of Children with Kinship Carers Abroad) [2019] EWFC 59 Re M (Children) (Suspected Trafficking - Competent Authority) 2017 EWFC 56

Saunak Irani-Nayar

Overview Saunak Irani-Nayar is a commercial barrister who specialises in banking, securities and finance litigation, contractual and business-to-business disputes, property disputes and consumer credit litigation. He appears in both the High Court and the County Court at all stages of proceedings, from interim relief and pre-action advice through to trials and appeals. Saunak has acted in several multi-day trials, Fast Track and Multi Track matters. He is equally comfortable in working in larger counsel teams or as the sole instructed counsel on a case. Saunak’s significant experience of employment law means he is well placed to act and advise where there is a crossover between commercial and employment law. Recent instructions in this area include appearing as sole counsel in the High Court in a high-value claim involving the alleged misuse of confidential information in the recruitment consultancy industry. The claim included allegations of breach of the terms of the employment contract, breach of fiduciary duty, breach of confidentiality, unlawful means conspiracy, infringement of copyright and unlawful inducement of breach of contract. Saunak has a strong, active client base for a barrister of his level of call. In particular, he receives instructions from the litigation team of a major international law firm, and regularly acts for defendant banks and financial institutions at interim hearings and trials. He has experience of possession claims, assignments, hire-purchase agreements, return of goods, compliance and enforceability of statutory notices, s.75 connected lender liability, and s.140A unfair relationships under the Consumer Credit Act 1974. Saunak has a broad experience of other consumer matters, including equine cases, particularly involving title to horses, purchase and sale disputes (under the Consumer Rights Act 2015 and Sales of Good Act 1979), and veterinary negligence. Saunak graduated with a BA and MA degree in Economics from the University of Cambridge and has been awarded several scholarships and prizes for his academic results. Saunak ranked 1st in his year on the GDL, achieving one of the highest sets of marks ever recorded on the course. Following this, he completed the BPTC ranking 2nd in his year and was called to the Bar as the top-ranking student at Middle Temple.

Stephen Abberley

Overview Family barrister Stephen Abberley, who specialises in cases involving children, thrives on challenges and has over twenty years experience in cases involving familial homicide, sexual abuse, serious cranial and other injuries, international law and cross-cultural issues. Stephen’s practice encompasses both public law cases – care, placement and adoption proceedings - and private law cases, acting for parents and children. With a practice evenly split between representing parents, children and authorities, Stephen brings perspective on how to meet the challenges in the case likely to be presented by the opposing side. Reported Cases: P And E (Care Proceedings: Whether to Hold Fact-Finding Hearing), Re - Find case law - The National Archives P (A Child: Fair Hearing) [2023] EWCA Civ 215 Re D-S (Contact with Children in Care: Covid-19) [2020] EWCA Civ 1031 Re C (A Child) (Application by Dr X and Y) [2015] EWFC 79 - [2017] 1 FLR 82 Disclosure – Re C (A Child) (Application by Dr X and Dr Y) [2015] EWFC 79 – [2015] Fam Law 1457 In the Matter of C (A Child) (Application by Dr X and Y) [2015] EWFC 79 Re J (A Child) (Fact-finding) [2015] Re Y [2014] EWHC 3601 (Fam) - Lexis Citation 31 Family With over twenty years of experience at the family Bar, Stephen Abberley never forgets just how daunting, confusing, and threatening court proceedings can seem to be for parents, children and even professionals. His aim is to guide people through proceedings in a way that helps them manage their fears, understand what is involved and present their case to achieve the best outcome. PUBLIC LAW – CARE PROCEEDINGS, ADOPTION Cases concerned with: Serious non-accidental injuries, including brain injuries and fractures Alleged fabricated or induced illness in children, including suffocation and poisoning, false reporting of illness Sexual abuse, within families and beyond Represents: Parents accused of inflicting serious and life-threatening injuries Parents accused of involvement in the sexual abuse of their own or other children Parents of children with complex health needs, accused of inducing or fabricating illness Local authorities bringing proceedings in the most serious of cases, managing cases from issue to fact-finding and final hearing Children, either through children’s guardians or directly, who are the subject of care proceedings or who are implicated in causing harm to other children Appears before and against: Mainly Circuit and High Court judges in the Family Court District Judges in the Family Court The Court of Appeal Frequently acts against leading counsel Will act as leader with other juniors when case requires Skillsets Up-to-date knowledge of complex medical issues and sound research skills Ability to explain complex information to clients Advises with firmness and compassion No-nonsense oral and written advocacy PRIVATE LAW - CHILDREN Stephen Abberley has a strong private law children practice, including regularly acting in private adoption cases. His busy caseload sees him: Frequently instructed to represent children in complex cases Represent parents on a private client basis Experienced in private adoption cases – relatives and stepparents Appear before all levels of tribunal, from lay magistrates to the Court of Appeal Experienced in cases with international and cross-cultural elements Provide clear and realistic advice, as well as forthright advocacy

Susan Todd

Susan Todd is a highly experienced senior family law barrister who joined 3PB in September 2023 from another large chambers in Birmingham. Susan has more than 30 years experience at the family bar. She works in the Family Court and the Family Division for parents, grandparents, intervenors and children's guardians. She prides herself on providing a committed service to every client, in a non-judgmental fashion, whatever their background, while remaining objective. Susan’s experience in public law includes: Non accidental injury Fabricated/induced illness Cases where one parent has killed the other Sexual abuse Abduction and forced marriage Female Genital Mutilation and Ritualistic abuse Human trafficking of children and adults and Modern Slavery Cases involving jurisdictional issues, including Article 15 BIIR and inter-country adoptions Same sex relationships and transgender client Secure accommodation Deprivation of Liberty Vulnerable clients such as those with a learning difficulty or a disability, including profound deafness Cases involving substance misuse, domestic abuse and mental illness Cases involving county lines and drug gangs Complex fact findings In private law Susan’s experience includes: Implacable hostility and parental alienation Internal and external relocation Removal from the jurisdiction (Hague Convention and non Hague Convention) Fact finding, including domestic abuse Change of name and school Private law special guardianship and adoption Neurodevelopmental issues in adults and children Cross-jurisdictional residence cases Acting for children through their rule 16.4 Guardian Between 2015 and 2016 Susan worked part time for BPP, teaching family law, opinion writing and drafting, conference and negotiation and professional ethics on the Bar Practice Training Course. Outside of work, Susan has worked in the voluntary sector as a school governor and as a trustee and director of a mental health charity. Family Public Law Care and Adoption Susan does a large variety of care, adoption and special guardianship work for parents, other relatives and for children’s guardians. She has a great deal of experience in dealing with clients from diverse backgrounds. Reported and notable cases include: Re M [unreported, July 2023]: Acted for mother in her applications to remove father as party from care proceedings and to terminate his parental responsibility. Father serving sentence for attempted murder, kidnapping, rape of the mother, whom he kept imprisoned in her flat with the children. Mother’s applications granted. Re R [unreported, Jan 2023]: Acted for Sri Lankan mother in sexual abuse case. Court deciding that fact finding was not necessary as child did not want to return home. Re W [unreported, 2021, 2022]: Lengthy hearing at welfare stage after fact finding in long running West Midlands sexual abuse case. Re T [unreported, 2020- 2021]: Junior to leading counsel in fact finding and welfare hearings in Pakistani sexual abuse case for father, involving fraud and corruption. Re J (Care Proceedings: Placement in Bangladesh) [2020] EWHC 490 (Fam) [2021] Fam Law 190 [2020] 3WLUK 740: Acted for mother in Bangladeshi NAI case at fact finding and welfare stages. Child was relocated to Bangladesh; involving expert opinion on Bangladeshi law. Re K [unreported, 2020]: acted for father in case involving Slovakian family subject to human trafficking and modern slavery of adults and children in the family. Re V-Z (Children) [2016] EWCA Civ 475: The Court of Appeal gave guidance on assessing potential carers in other jurisdictions, particularly when the relevant country will not allow assessment by UK social workers. Acted for Slovakian father. Private Law Children and Domestic Abuse Susan has extensive experience of private law cases. She has represented clients in intractable contact cases, change of name, change of school, relocation and removal from the jurisdiction (Hague Convention and non Hague Convention), private law special guardianship and adoption, and in cases involving children with special needs such as autism. Susan represents children in Rule 16.4 cases where they have their own Guardian. Reported and notable cases include: Re S (unreported, 2023): acted for mother in case of alleged parental alienation; issues of neurodiversity in parents and child. Re P (unreported, 2020): acted for mother in private law residence matter where the child was resident in the UK, the father was Italian, mother was Polish and the Italian Court of Appeal had made previous

Theresa Lim

Overview Theresa Lim qualified as a solicitor in April 2005, and transferred to the Bar and joined 3PB in October 2019. She has considerable experience undertaking a wide range of advocacy in family matters with a strong in-depth knowledge and specialism in complex public and private law proceedings, Family Law Act proceedings and proceedings under the Inherent Jurisdiction of the High Court for protection from Child Sexual Exploitation (CSE) as well as health and welfare Court of Protection proceedings. She has been a member of the Law Society’s Children Panel and regularly represents both children and vulnerable adults. Theresa is highly motivated with exceptional interpersonal skills and a proven track record within the legal profession as an accomplished and articulate advocate. She delivers an excellent service to clients working calmly and efficiently under pressure. Family Theresa has a strong and in-depth knowledge and specialism in complex public and private law proceedings. Objectively and effectively representing both lay and professional clients from all social backgrounds, maintaining a professional presence and providing a high standard of representation and client care to each client she represents. Theresa regularly represents clients via the Official Solicitor; or in cases where clients and/or witnesses have additional educational needs, and/or participation directions have been given. She is an expert in care and adoption and private children law cases, injunctions and domestic violence disputes. Care and adoption Theresa Lim regularly acts for parents, guardians, extended family members, intervenors, and the Official Solicitor. She has a particular interest in NAI cases and has appeared in cases involving brain and skull injury, rib fractures, limb fractures, extensive bruising and sexual abuse. Theresa is experienced in representing parties in care cases involving: Non accidental injury/death of a child Sexual abuse (parent and or sibling)(acting for the alleged perpetrator/victim/non-perpetrating parent or carer) Expert/medico-legal issues (including Factitious disorder by proxy) Chronic neglect, drug and alcohol addiction (including cases in the FDAC) Domestic violence and sexual abuse/offending Serious mental illness/personality disorders S.38(6) assessments S.34 applications Adoption/Special Guardianship/Wardship Secure Accommodation/Deprivation of Liberty Parents or children with special needs/cognitive impairment and capacity issues Revocation of placement orders/discharge of Care Orders As a solicitor, Theresa was the first to give notice to Birmingham City Council under S. 14 Children Act 1989 leading to one of the first Special Guardianship Orders being made in Birmingham. Private law Theresa Lim has a wide range of experience in private law applications, and applications under the Family Law Act.Theresa regularly acts for parents, carers, and Rule 16.4 Guardians. Theresa is experienced in representing parties in private law cases involving: Physical abuse Sexual abuse (parent and or sibling)(acting for the alleged perpetrator/victim/non-perpetrating parent or carer) Domestic violence and sexual abuse/offending Parental Alienation Implacable hositility Serious mental illness/psychological disorders Drug and alcohol misuse Removal from the jurisdiction/relocation in England and Wales Prohibited Steps Orders Specific Issue Orders including a child’s end of life care S.91(14) Orders Recovery Orders Tipstaff S.37 reports/ICO/ISO Theresa has represented parties in non-molestation and occupation order proceedings and has combined the protective orders under the Children Act and Family Law Act to obtain protection for victims of domestic violence and so-called “honour” violence. Court of protection Theresa’s background in complex public law Children Act proceedings - including the application of Deprivation of Liberty to children in local authority care - in which she regularly represents clients via the Official Solicitor, has led to a natural progression of her practice into health and welfare Court of Protection proceedings. This is also the case where clients and/or witnesses have additional needs and vulnerabilities, an area in which Theresa is highly experienced. Theresa is also very experienced in cases where there is conflicting capacity evidence including fluctuating capacity, together with cases involving declarations in respect of both capacity and best interests.

Vanessa Meachin KC

Overview Vanessa Meachin KC is a family law specialist and has developed a practice in which she enjoys the considerable mix of care, adoption, matrimonial finance and private law children act applications. In recent years she has coupled her family law practice with a developing interest in court of protection work. She appears frequently in complex and sensitive cases involving children in private and public law areas in the Family Division and Family Court. She represents parents, children and local authorities. In Vanessa’s financial remedies practice, her cases routinely involve substantial assets, corporate assets and issues relating to land and foreign property. She also deals with cases involving financial provision for the family on death and financial provision for children. Family Vanessa was called in 1990. She is a family law specialist and has developed a practice in which she enjoys the considerable mix of care, adoption, family finance and private law children act applications. She has appeared in the Court of Appeal at regular intervals in her career. Since 2009 she has been a Recorder on the South Eastern Circuit (Family and Civil). She is a pupil supervisor and regular speaker at seminars. She is a member of ALC, CoramBaaf and FLBA. She is an affiliate member of Resolution. She accepts instructions under direct access. Recent cases: X County Council -and- BE(1) AD (2) CD (BY HER CHILDREN'S GUARDIAN) (3) [2021] EWFC 112 Lancashire County Council -v- M (1) F (2) and C (3 By his Children’s Guardian) [2020] EWFC 43 W (A Child) [2019] EWCA Civ 1966 RE B (A Child) (Post-Adoption Contact) [2019] EWCA Civ 29 Re M (Children) (Suspected Trafficking - Competent Authority) [2017] EWFC 56 Re D + Ors (Children) 2017 EWFC B87 Re C (a child) [2016] EWFC B110 Re D (Appeal: Procedure: Evidence) [2015] EWCA Civ 409/ [2016] 1 FLR 249 Re D [2015] All ER (D) 136 A local Authority V AB and others [2015] All ER (D) 14 Re K (Wardship: Publicity) [2014] 1 FLR 548 Re K (Wardship: Publicity) (No 2) [2013] EWHC 3748 (Fam)/[2014] 2 FLR 310 A Local Authority v X and a Child [2013] EWHC 3274 (Fam)/ [2014] 2 FLR 123 Re K (A child: Therapy) [2013] All ER (D) 367 Re W (a child) (removal at birth: contact) [2013] All ER (D) 254 Birmingham City Council v AG and A [2009] EWHC 3720 (Fam)/[2010] 2 FLR 580 Re R (Placement order) [2007] EWHC 3031 (Fam) [2008] 1 FLR 1259 Re B (Appeal: lack of reasons) [2003] EWCA Civ 881/ [2003] 2 FLR 1035 Re G (Leave to Appeal: Jurisdiction) [1999] 1 FLR 771 Care and adoption Vanessa is experienced in complex public law cases under the children and adoption legislation. She has 26 years of experience of appearing for parents, other relatives, local authorities and children. She routinely appears in the High court in relation to cases relating to the death of a child by various mechanisms (including shaking, suffocation, possible consumption of drugs or infection caused by starvation). In other cases, where the child has not died, she has considerable experience of allegations of serious physical abuse (burns, bruising, head injuries, multiple fractures and attempted suffocation) sexual abuse (parent and or sibling), emotional abuse (including allegations of demonic possession), neglect, domestic violence and factitious illness. These cases will routinely involve the cross examination of a number of medical experts from multi disciplines. She has acted in cases where the welfare of the children has required exploration and assessment of relatives abroad. This has included consideration of jurisdictional issues as between England and Wales and countries such as Iraq, Latvia and Lithuania. She has acted in such cases involving Human Trafficking and cases involving the use of the Inherent Jurisdiction to enable a child to be securely accommodated in another country. Her practice has included protective orders for young females encompassing forced marriage, female genital mutilation, declarations that a marriage was unlawful (coercion and rape) and reporting restriction orders. She has represented parents from differing economic, cultural, social background and ages. Some may have issues such as drug, alcohol dependency, mental health difficulties, language difficulties or a combination of these problems. Finance Over the last 28 years Vanessa has accumulated extensive experience in applications arising in financial remedies, Schedule 1 of the Children Act 1989, the Inheritance (Provision for Family and Dependants) Act 1975 and more recently disputes involving civil partners. Her financial remedy work has included applications to set aside consent orders and presenting or opposing appeals. She is required routinely to conduct cases involving parties of medium to high net worth, business accounts, forensic expert reports and pension issues. Some interesting points have included consideration of the implications for a Wife following a foreign divorce, the consequences following a spouse's bankruptcy, an application to enforce maintenance arrears once the Husband’s mortgage fraud was identified and the approach to a personal injury award as a resource for the Husband. Vanessa will often be instructed at an early stage when attempts are being made to resolve the financial aspect of separation, before court proceedings have been issued. Vanessa has also been instructed to deal with other matters within the parties’ dispute including successfully resisting applications to set aside entitlement to decree nisi in two separate cases. Her clients have been from a wide background including those with physical or mental disability. These have involved instructions being taken from a Deputy acting for the protected party (P) or from the Official Solicitor. FDR Hearing Service Vanessa is available for private remote FDR hearings. For more information on private remote FDR hearings please click here. Private Law Vanessa has wide experience in private law applications, including cases where serious allegations of sexual abuse, physical abuse (against either the partner and or the child) or emotional abuse (against either the partner and or the child) and parental alienation have featured. These cases have often included other issues such as the local authority becoming involved with the family, consideration of the child or children being separately represented and implacable hostility being shown by one parent to the other post separation. Vanessa has been involved in cases where the court has contemplated and changed the child’s living arrangements following a determination that the parent with care has been attempting to alienate the child from the other parent. Vanessa has also been involved in cases featuring permission for children to travel out of the jurisdiction whether permanently or temporarily. Her cases have involved such varied countries as Kenya, Thailand, Australia and Spain.

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