Effective regulation requires some risk taking and a willingness to push boundaries and test principles and practices.
John Briton was the first Legal Services Commissioner for Queensland. He is the author of the paper “Between the Idea and the Reality Falls the Shadow.” 
I am not a lawyer. Before my appointment as the first Legal Services Commissioner for Queensland, I served as Queensland’s Anti-Discrimination Commissioner and the State Director of the Human Rights and Equal Opportunity Commission. Prior to that I served in Victoria as the Deputy Public Advocate and Senior Advocate in the Office of the Public Advocate, where I investigated and reconciled alleged abuse, exploitation and neglect of older people and people with disabilities.
In those roles, I acquired significant experience with regulatory matters, complaints and investigations of conduct, and notably experience with respect to human rights. And that’s the experience I took into my role of Legal Services Commissioner. To my knowledge, I was the first and, to date, the only, non-lawyer appointed in Australia to a Legal Services Commissioner position.
I was appointed on the heels of a scandal, which I think explains my appointment. The Law Society had been pilloried in the media over a period of several years for the way that it handled complaints. A common headline was “Caesar Judging Caesar,” in reference to the fact that the Law Society, the membership body which represents lawyers and is essentially their trade union, had the responsibility for handling complaints against lawyers.
When I assumed my position, I knew that the Commission would comprise lawyers in the main so I knew I would get the legal advice I would need. That being said, many lawyers are incredibly risk adverse, and they see lawyering as a way not to manage risk but to avoid it altogether. In my opinion, effective regulation requires some risk taking and a willingness to push boundaries and test principles and practices. For that reason, I think it was helpful — an advantage — that I was not a lawyer. It made it easier for me to push boundaries. I could challenge assumptions by playing dumb and asking naïve questions. I think it was particularly helpful to not be a lawyer in the context of setting up an organization from the beginning, which enabled me to establish a certain culture.
It was by pushing boundaries that I got interested in the topic of billing practices. As I discuss in my paper, most lawyers don’t think much about their billing practices – it’s just what they do — it’s just standard operating procedure and they don’t see anything problematic or dubious about them. But I looked at some of those practices and thought that they were outrageous, especially from the perspective of fair treatment and consumer protection. Some examples of the practices are: (i) billing undisclosed mark ups or “secret profits” on outlays, (ii) billing in 6- or 10-minute increments of time, and invoicing clients for a full 6 or 10 minutes even if the work took considerably less time (perhaps just one minute, for example), with the result of significantly inflating the stated hourly rate and (iii) “double dipping” with the same time by charging a client a “cancellation fee” for time that was set aside to work on a matter but which turned out not to be needed, and using that time to do paid work for other clients. And these practices often occur in a cultural context in which firms place unreasonable pressure on their lawyers to meet unrealistic hourly billing requirements and in which meeting billing targets is an “all purpose” performance measure for promotion and career advancement purposes.
One of the first challenges of my job was the legislation that established our office. It said that the job of the Legal Services Commissioner is to make sure the consumers have a means of redress for their complaints. That was fine, except that we had no powers to provide an effective a means of redress, other than to involve disciplinary bodies, who could order compensation. All we could do was see if we could mediate a solution. This was frustrating for us because not all matters needed to be treated as disciplinary matters — many were simply careless and honest mistakes that just needed to be made right. One example is a lawyer whose secretary deposited the proceeds from the sale of a house into the client’s Australian bank account when the client had specifically instructed that it be deposited into his UK bank account, with the result that the client lost hundreds of pounds due to fluctuations in the exchange rate.
We thought for a long time about how to handle this. We finally decided that the way the legislation was set up, every matter which warranted compensation must be a disciplinary matter. Otherwise the legislation did not make sense. So, our solution was to treat every matter, even just plain muck-ups, as a disciplinary matter.
Yes, that was really harsh. But at the same time, we were not obliged to prosecute every matter. For any given matter, we could ask if there was a public interest in prosecuting, and if we decided there was not one, we wouldn’t — and where is the public interest in prosecuting a lawyer for an honest and minor mistake that they have voluntarily put right? We had to do it subtly, to not encourage bargaining. At the time we made this decision, it seemed to others to be quite brave if not crazy, but, in hindsight, it was seen as simply being sensible. And the fact is that it turns out that most complaints concern simple mistakes or errors of judgement and just need to be fixed — by doing the work again, apologizing, compensating for financial loss.
About ten years ago, judges and others were writing articles and giving speeches on the question of whether law is a business or a profession. My reaction to that was “what a bizarre question.” Obviously it’s a profession and obviously it’s a business. Can you really argue that law firms with acres of marble in high rise buildings and paying million-dollar salaries are not turning a profit? That’s crazy. Lawyers sell legal services for profit. That’s what private legal practice is — it’s a business. So, let’s have a sensible discussion about what sort of business it is and what are the requirements of this business as opposed to some other business, and what are the professional obligations. But the idea that lawyers somehow aren’t in it to make money — it’s simply nonsense.
So, the question is: how can it be regulated in a way that while people make money, at the same time they have professional standards, they meet their obligations to the court, and they treat consumers appropriately? That is the question.
The competency and character requirements that are placed upon lawyers as individuals — that is fine. There is not much to say about that. But that does not mean the discussion is finished. Because anyone who has read any organizational studies literature knows – and it is pretty obvious, anyway — that organizational cultures influence behavior.
When I first saw the regulatory framework for ILPs, I thought it was fantastic. I saw a regulatory framework that looks at management systems and what legal ethicists call “ethical infrastructures,” and I saw that it really gives you a way to get to the cultural influences that have an impact on the behavior of lawyers in law firms. The regulation of lawyers that only looks at the conduct of individual lawyers is, in my view, a hangover from when everyone was a sole practitioner or operating in very small firms. Today most lawyers work in large and medium-size firms, and the cultural influences of those firms are just as much if not more important in determining how an individual performs than that individual’s knowledge and character.
The most obvious example relates to money. It is not uncommon for law firms to put their lawyers under unreasonable pressure to meet unreasonable billing targets. It is obvious that will influence someone’s behavior, and create ethical challenges for the people that have to operate in that environment. It’s common sense.
At work people are motivated by many things, such as the desire to please their boss, the desire to get a pay increase, as well as the desire to do the right thing. Regulators of legal services need to be able to address all of these motivations, and not just some of them.
Lawyers can be influenced by a number of different people, and, yes, that includes shareholders. That is not a reason to exclude shareholders. It is a reason to manage the risk.
Australia’s response to this has made sense — yes, allow non-lawyers to own shares of a law firm, but require the firm to appoint at least one Legal Practitioner Director. There needs to be a lawyer who is ultimately responsible for the legal services provided by that firm and that person needs to have specific obligations over and above their obligations as a lawyer. Those obligations need to be that the firm is run in accordance with lawyers’ professional obligations and making sure that the firm has an ethical infrastructure (governance arrangements, supervisory systems, training…) in place. And that lawyer needs to be personally responsible to the disciplinary regime for that. It’s a really good framework, and it works.
Christine Parker’s research regarding the effect of self-assessment audits is significant. If you recall, this is the requirement that an ILP review its systems and structures on the basis of a self-assessment questionnaire. It’s a pretty modest thing. The 39-page questionnaire addresses a certain number of objectives, such as the timely identification and resolution of conflicts, the establishment and disclosure of appropriate billing practices, and effective, timely, and courteous communication. What the self-assessment does is say to firms “here’s the framework — you review it and then tell us if you have in place systems for dealing with conflicts, for dealing with liens, etc. — just review your systems, and come back to us with some evidence that you’ve actually thought about this stuff and you have some systems in place.” Christine Parker’s research shows that simply performing a self-assessment reduces complaints by two-thirds.
Susan Fortney’s follow-up research is also significant. She interviewed a large sample of legal practitioner directors to understand their attitudes towards the self-assessment audits. The clear majority of them told her that they “thought at first it would be a real pain — that it would be just more red tape — but that actually it really got us thinking, and we think we’ve improved our client service as a result.”
During my time as Commissioner, we did not stop with the self-assessments. We had a variety of other programs in place. One example is what we called “ethics checks.”  Done on an anonymous basis, these provided a framework for a firm to involve everyone (or nearly everyone) in their offices to engage with respect to ethical issues. The purpose of the checks was to foster reflection together with spontaneous and organized discussions. We approached this by explaining to firms that it would only take 30 minutes to respond to an online survey intended to get people thinking on topics like complaints management, billing systems, supervision arrangements, etc. We explained that the surveys enabled a firm to test whether perceptions across that firm were consistent, such as if the partners’ perceptions were the same as the other lawyers’ perceptions and whether the perceptions in one office were the same as the perceptions in another office. It provided a wealth of information that permitted the partners to understand what was happening and to change things if needed.
When we asked partners in law firms that participated in these programs what they thought of them, they thought they were fantastic. They almost invariably said that the surveys forced them to think, and more than a few of them that because of the surveys they realized there were problems that needed to be fixed, and they fixed them.
There are some questions you can ask of an organization that are key indicators of the ethical health of that organization. An example is “are you willing to share bad news with management?” If the response to that question is “no,” that is likely to be a poor performing organization from an ethical perspective.
We used an off-the-shelf program like Survey Monkey to conduct the surveys. The responses were anonymous. We did not ask for any identifying information. We did not even ask the firms to identify themselves. They could use a secret code to link the responses from the same firm.
We did ask for demographic information, such as are you a partner, associate, or paralegal, how long have you been practicing, are you a man or a woman, and the like. In addition to questions about reporting bad news to management (questions like would you report it, what do you think would happen if you did, would your career be advanced…), the survey also asked questions like:
- Does your firm have a policy for dealing with complaints? Do you think it works?
- Do you have a billable hour policy? Do you think it works?
- Do you have supervisory responsibilities? If so, are your billable hour expectations reduced?
- Here is scenario X — what would you do in this scenario?
The responses we obtained from these surveys were incredibly interesting and useful. For example, it was common for the partners to think it was safe to report bad news to management but for the junior lawyers to disagree, especially the junior women in the firm. That was very good information for the firm’s management, and it gave them a lot to think about. This was proactive ethical reflection, and it worked.
With ILPs, we used these surveys as mandatory when we could. We presented them to ILPs by explaining that we expected everyone in their firm to respond. We said that it would not take long, and that we expected to get useful information that we would share with the firm’s management. Christine Parker has published several papers based upon the results of these checks.
What we did needed a lot of selling. Some people saw it as an unjustified intrusion into their affairs, or believed we would share confidential information about a firm with the firm’s competitors. But for me, if these checks were conducted properly, they could be sold, because when you asked people who had done them what they thought, they almost invariably responded that they thought it was going to be a waste of time, but that in fact it was incredibly helpful — just like the self-assessment audits of ILPs.
Because of our very general right to perform audits with ILPs, we could oblige ILPs to participate in the ethics checks. That being said, we sought to present them as something helpful and useful rather than an unreasonable burden. With respect to firms that were not ILPs — we could not oblige them. So, instead, I sought out friendly and progressive partners. I would have a cup of coffee with them and encourage them to participate. Quite a few did participate as a result.
Some firms, and notably small firms, have become ILPs for the principal reason that it presents certain tax advantages. Other firms, especially mid-size firms, have become ILPs because it gives them a more sensible management structure. It gives them more interesting options for remunerating their people. It allows people to be shareholders without the burdens of being a partner, and notably without the management or supervisory responsibilities. From my perspective, these firms tend to be better run. Their management understands that they are running a business, and that they need to think like business people. This means thinking about things like customer service and loyalty and providing effective and efficient services — all the things that smart businesses do. This is not inconsistent with being a lawyer. It’s just smart business.
Let’s take Slater and Gordon as an example. It’s often derided as a personal injury factory. In reality, Slater and Gordon is a slick operation, as are many of the other large personal injury firms in Australia. We used to get complaint after complaint about personal injury firms, but once they started to think through the issues of how to construct an effective customer service and how to design and implement in-house complaints management systems and the like, the complaints to the Commissioner’s office went right down. Generally speaking, they, together with other ILPs, are well-managed firms.
When Slater first decided to go public, the Legal Commissioners for New South Wales, Queensland and Victoria, met on a number of occasions with Andrew Grech, Slater’s Managing Director. The net effect of these meetings was that the company’s prospectus states very prominently that the company’s first and overriding obligation is to the court, and that its second obligation is to clients. The company’s obligations to its shareholders only come in third. Shine’s prospectus states the same thing.
I understand that outside Australia strong fears of ILP-type structures have been expressed, in part with the argument that they will lead to a consolidated market, as evidenced in the personal injury market in Australia. I am suspicious of this argument. In Australia, many small firms are struggling. They have been taken over by other firms, but typically for reasons that have nothing to do with incorporation. It is because being a small generalist law firm in an increasingly specialized world of legal services is just too hard. This has resulted in all sorts of problems among the partners of small firms, and notably problems of depression, breakdowns, and alcoholism. Many of those partners just want to be lawyers. You used to be able to run a law firm where you could be a generalist — family law, wills and estate planning, personal injury,… But now these areas are so complicated, you have to be an expert to do it effectively. As a result, many firms are really struggling. Firms like Slater and Gordon and Shine are probably better positioned to buy up firms than others are, because they have access to capital. But I do not see the consolidation of the market as detrimental — it is merely a reflection of what is happening in the market — and from a consumer perspective it has advantages. The consolidated firms tend to be better managed. And most complaints come about not because lawyers are poor at doing law, but poor at doing the business of law.
In Australia, the form of ILP is the preferred business model for start-up law firms. Law firms were first allowed to incorporate in Queensland in 2007, and only five years later one-third of all Queensland law firms were ILPS. It is just a sensible way of structuring a business. The regulatory framework has not stopped people from using the ILP structure. The objections to the regulatory framework that are expressed are based upon ideology (in favor of deregulation notably) and not on evidence.
I’ve also heard the argument that in Australia ILPs have not brought a change to the legal services market — that they have not fostered any significant creation of new or different kinds of legal services to better serve consumers. This argument is a double-edged sword. How can you on the one hand argue that allowing ILPs will result in the end of the world as we know it, but on the other hand argue that they’ve not changed anything?
In any event Christine Parker’s research is evidence that the ILP structure has made a difference for consumers in that it has led to better quality customer service with far fewer complaints. The evidence is that our regulatory regime for ILPs results in better quality customer service. It may or may not have resulted in better quality legal advice — there is no research on that question — but there is evidence that customers have better experiences and are happier.
And if you really believe that nothing has changed, then what legitimate justification is there for being opposed to ILPs?
I have often argued that all law firms should be subject to the same regulatory regime as ILPs. More specifically, I have argued that the single most effective reform we could make to better promote, monitor and enforce high standards of service in the delivery of legal services and to better protect consumers would be to make all law firms subject to the same regulatory arrangements as ILPs. I argue this because the regime offers the best means to engage with law firms about their ethical infrastructures — their management systems, their governance arrangements, their workplace cultures… We do this with the knowledge that a firm’s ethical infrastructure is just as if not more important than a lawyer’s character in shaping their conduct. All of a lawyer’s obligations are affected by culture. Putting lawyers under unreasonable pressure to meet an unreasonable billing target is hardly ethically neutral, for example.
The ILP regulatory structure gives regulators the capacity to engage with law firms about a whole range of influences that shape their performance as a law firm that you can’t do under a regulatory framework that is based solely on reacting to complaints. It permits regulators to be helpful and to be seen as being helpful, rather than be seen as an “enemy” to be feared because they are out to get you.
There is a common law tradition in Australia which is at odds with the vicarious responsibility placed upon the Legal Practitioner Director. It holds that a lawyer should not be held to account for something unless that person was personally responsible for it. In my opinion this is regressive and myopic thinking. It creates room for smart operators to look the other way in order to avoid responsibility. And there can be an inherent contradiction in this argument. Does a law firm partner really want to argue that they could not have influenced a particular action or behavior? That might be true sometimes but equally it will sometimes be akin to an argument that “I’m not guilty because I’m an incompetent supervisor.”
Directors cannot get away with that argument in other areas of law. Take our rules as regards sexual harassment, for example. Employers are vicariously responsible for sexual harassment by their employees unless they can demonstrate that they took all reasonable steps to prevent it from happening. In my opinion, this is the kind of obligation that principals of law firms should have with respect to the ethical conduct of everyone in the firm. That is, principals should be vicariously liable unless they can show — under a reversed burden of proof — that it was so far out of their sphere of influence that it is unreasonable to hold them accountable. Without this reversed burden of proof, then no one ends up being responsible for the workplace culture, and that makes no sense.
It is with a heavy heart that I think Queensland should sign up to the Legal Profession Uniform Law (LPUL). In some ways the LPUL is a great advance, but in other ways it is a big step backwards and already out of date. It is a great disappointment.
The system for dealing with complaints under the LPUL is much better than the one in Queensland and elsewhere in Australia but the limitations that the LPUL places on the Commissioner’s right to conduct compliance audits is a big step backwards. Before the LPUL, the Commissioner could conduct a compliance audit of an ILP at any time and for any reason, and even for no reason at all. Under the LPUL, the Commissioner’s ability to audit not just an ILP but any firm is curtailed: a compliance audit may be conducted only in the event of a complaint or some other conduct that causes the regulator concern. In my opinion, this destroys one of the very best parts of the prior regime. In particular, under the prior regime, the regulator could focus its resources where it perceived there to be the greatest risks. In doing so, the regulator did not need to wait for something to go wrong to go and talk to a firm, and did not need to wait for something to go wrong to require a firm to conduct a self-assessment. That is, under the prior regime, the regulator could be proactive.
Reactive regulation is waiting for things to go wrong, and then using the regulator’s powers to figure out why they went wrong. Proactive regulation is engaging with firms in order to prevent bad things from happening.
Sometimes clients understand that something has gone wrong — they understand that they have grounds for complaint and they do, in fact, make a complaint. But I think that is the exception rather than the rule. More often than not clients simply do not know that something has gone wrong. There are many more consumers, and I say many tens if not hundreds of times more consumers who have cause to complain as compared to the number that actually make complaints.
That is why the ability for the regulator to act proactively is so important. Very unfortunately, under the LPUL, that power is gone.
The explanation for this big step backwards is politics. The professional bodies and the large law firms ran what I believe was an entirely misconceived and over the top campaign which assured that the regulatory regime which applied to ILPs would not be expanded to all firms — which assured that in harmonizing the regimes for ILPs and non-ILPs, the regime for ILPs was scaled back to be principally reactive rather than proactive. What I found very ironic in this is that the people responsible for this political campaign had never themselves experienced the ILP regime, and did not understand what it was.
The argument played out for example in the Consultative Group to the National Legal Profession Reform Taskforce (the group responsible for designing the Legal Profession Uniform Law). I was a member of that Group and argued that the regulatory framework for ILPs should apply to all law firms, ILP or otherwise. The only person in the room who agreed with me was a legal practitioner director of a prominent ILP which had been through the process. He was only lawyer in the room whose firm actually had the experience of the regulatory framework for ILPs and he supported it. None of the others or their firms had been through the self-assessment process, and when I asked them to describe it, they couldn’t. Their lack of knowledge of the ILP regime did not stop them from arguing against it, however, and its expansion to all firms.
They argued for example that regulators could not be trusted not to abuse their powers, and that empowering regulators to conduct compliance audits of all law firms would be “unnecessarily intrusive” and impose an “unjustified regulatory burden” on law firms — so much so it would put small law firms in rural areas out of business, for example, with the result that ordinary people would not be able to access a lawyer. Their arguments were way over the top and frankly nonsense. They favored a deregulatory ideology over evidence and were not going to the facts to get in the way of their story — and the fact is that the so-called regulatory “burden” on ILPs hasn’t stopped law firms queueing up to become ILPs, so much so as I have said already that ILPs made up one-third of all Queensland law firms only 5 years after incorporation was permitted.
So the LPUL takes a step backwards in this respect. I mentioned earlier that is it is already out of date in another. It makes costs disclosure the centerpiece of its consumer protection framework in relation to costs. It assumes that costs agreements that consumers enter into with lawyers are fair — and can be enforced like any other contract — provided only that their lawyers have disclosed their costs or the basis on which their costs will be calculated. It seeks to protect consumers from being treated unfairly in relation to their costs by requiring lawyers to ensure that the process by which they enter into a costs agreement is fair.
But contemporary consumer protection best practice has moved on. The Australian Consumer Law (the ACL) for example recognizes that disclosure by itself doesn’t and can’t protect consumers from signing up to unfair contracts. It recognizes that ordinary consumers all too often lack the legal or technical expertise to fully understand contracts they are given to sign or to negotiate the terms of the contract and can only too easily be sold short. So the ACL tests the fairness of a costs agreement not by reference not to the process by which it was entered into but to its substance. It prohibits unfair terms. This is a more stringent test and more sympathetic to consumers.
It is not a good look, is it, when the generic consumer protection legislation which applies in the marketplace more generally imposes higher standards on business people in entering into contracts with consumers than the LPUL imposes on lawyers. That really ought to embarrass and trouble a profession so given to celebrating its high ethical standards vis-a-vis other “mere run of the mill” commercial enterprises.
At this time the regulatory system for legal services in Australia is mixed, in that it is partially self-regulated and partially independently regulated. In my opinion, the legal profession in Australia would be much better off if its representative bodies were freed from their regulatory obligations. That would free them up to fully advocate in favor of their members instead to clinging to the assertion that they are motivated purely by the public interest. Nobody believes that, so why do the professional bodies continue to believe it? Why not fully embrace their status as membership and representative bodies, effectively trade unions? At the same time, a fully independent regulatory regime would remove the inherent conflict of interest. It would promote greater confidence in the regulatory regime — it would promote public confidence that legal services are regulated in the public interest rather than the interests of the profession and mitigate the negative image so many members of the public have about lawyers.
I also believe that the public needs to have a much greater voice in the regulation of legal services. Take the handling of complaints, for example. When you do not involve the public, regulators invariably reflect the profession’s view of the purposes of the regulatory regime — of the system for dealing with complaints, for example. It becomes heavily weighted to professional discipline — to “weeding out the bad apples.” It grants the regulator extensive powers with respect to discipline but few if any powers to order redress for ordinary mistakes that fall short of disciplinary violations. Those regulations were designed without anyone’s head in the consumer space. If you look at the other regulatory bodies in Australia, you’ll see that they all have consumer sub-committees, or structured arrangements where they consult with consumers or with consumer advocacy organizations, like the Australian Communications Consumer Action Network. You don’t see this with respect to legal services. I think this is an important reason why firms can get away with abusive billing practices. Unfortunately, during my time as Commissioner, I could not get the professional bodies to take these issues seriously.
A body that is essentially a membership body will always find it difficult if not impossible to take regulatory action which its members perceive to be a threat to their livelihoods, no matter how great the benefit to the public may be. This is why we need independent regulators, as they are able to regulate in the interest of the public without any conflict of interest with a duty to represent members. And with independent regulation, I am not saying that the perspective of the public or of the consumer must or even should prevail — I am simply saying that it needs to be in the mix. It’s essential for instilling public confidence in lawyers as well as in the regulation of legal services, and for that matter in our system of justice and the rule of law.
 John Briton, “Between the Idea and the Reality Falls the Shadow” (paper presented at the fifth bi-annual Australian and New Zealand Legal Ethics Colloquium, Melbourne, Australia, December 3-4, 2015), https://www.monash.edu/__data/assets/pdf_file/0004/374872/Briton-Between-the-Idea-and-the-Reality-Falls-the-Shadow-revised-April-2016.pdf.
 Christine Parker, Tahlia Ruth Gordon, and Steve A. Mark, “Regulating Law Firm Ethics Management: An Empirical Assessment of the Regulation of Incorporated Legal Practices in NSW,” Journal of Law and Society, 2010, http://dx.doi.org/10.2139/ssrn.1527315.
 Susan Fortney and Tahlia Gordon, “Adopting Law Firm Management System to Survive and Thrive: A Study of the Australian Approach to Management-Based Regulation,” University of St. Thomas Law Journal 10 (2013): 152-194, http://ir.stthomas.edu/cgi/viewcontent.cgi?article=1298&context=ustlj.
 For example: Christine Parker and David Ruschena, “The Pressures Of Billable Hours: Lessons From a
Survey of Billing Practices Inside Law Firms,” March 18, 2011, http://dx.doi.org/10.2139/ssrn.1790082; and Christine Parker and Lyn Aitken, “The Queensland ‘Workplace Culture Check’: Learning from Reflection on Ethics Inside Law Firms,” Georgetown Journal of Legal Ethics 24 (2011): 399-441.
 See footnote 6.
 To clarify, here I am referring to the regime under the Legal Profession Model Laws that is today still in place in Queensland. I am not referring to the modified regime for ILPs recently adopted in New South Wales and Victoria, under the Legal Profession Uniform Law.
 Again, here I refer to the regime under the Legal Profession Model Laws and not the regime under the Legal Profession Uniform Law.
 For more detail on this subject, see my paper, pages 6-10.
 For more detail on the topic of costs agreements, see my paper, pages 12-16.
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