Salah Documents

2.1 Pursuant to RDC 16.16 – 16.17 the Claimants file this Reply to the Defences served by the  Defendants on 1 June 2026.  

2.2 This Reply is confined to new matters, contradictions, factual mischaracterisations, admissions, and  allegations requiring clarification failing to meet requirement of RDC 17.27  

2.3 unless expressly admitted, all allegations, denials, assertions and implications contained in the  Defences are denied with reasons given herein.  

2.4 The Claimants rely upon the Particulars of Claim dated 13 May 2026, the documents exhibited  thereto, and the documents referred to in this Reply.  

2.5 To the extent that this Reply does not deal with every matter raised in the Defences, the Claimants  do not admit such matters and require the Defendants to prove the same pursuant to RDC 17.35  

2.6 This Reply is not intended to plead new causes of action. It is intended to answer the matters raised  in the Defences and to clarify the existing pleaded case further.  

2.7 Legal framework relied upon is detailed in section 13 of this Reply.

3.1 The Claimants reject the reliance upon the following contrived pretexts:  (a) – payments of professional fees were staggered.  (b) – segmenting timeline of legal representation.  (c) – previous pleadings while litigant in person.  

3.1 Those matters do not provide a complete answer to the central causation pleaded in the Particulars of Claim. A defense predicated on the assertion that no professional duties were owed prior to the receipt  of full payment is legally untenable, the Claimants relay the duty of “good faith and fair dealing” Article 57 of the DIFC Contract Law (Law No. 6 of 2004)

3.2 The execution of the Retainer Agreement on 13 March 2025, predating the relevant Court Order,  coupled with the initial fee remittances, imposed a positive duty upon CFI Counsel to place the CFI  Defendants on clear and timely notice if they intended to withhold legal services, advice, review or  procedural guidance pending full payment, particularly concerning the 18 April Disclosure Order. No such notice was ever served.  

3.3 This early non-preference in the absence of reasonable notice is precisely a breach of terms (1.  Review of case files) and (8. Provide timely updates) of the agreement, The subsequent written  assurances provided on 5 and 30 June 2025 further evidence the Second Defendant’s actionable  negligence regarding the 18 April Order.  

3.4 The Claimants do not allege that mere inaction, by itself, is a standalone cause of action, the  pleaded complaint is that, having accepted the retainer, having received payments, and having  communicated with the Claimants regarding the matter, CFI Counsel failed to provide basic procedural  advice, warning, or timely clarification in relation to the 18 April 2025 Disclosure Order.

3.5 the CFI Counsel’ minimum professional duty was to promptly advise the CFI Defendants to  independently comply with the 18 April Order prior to the deadline, even if their allegations are true.  

3.6 The Defendants’ reliance on late payment is inconsistent with their own communications. The  Claimants rely upon correspondence and WhatsApp communications with Ms Manaf, in which Second  Defendant acknowledged receipt of partial payments on 18 April 2025, stating that the matter was being worked on, and indicating that procedural steps would be taken. These communications are inconsistent  with any allegation that no duty of advice existed until full payment had been received.

3.7 The principal adverse costs liability relied upon is the amount assessed by the Court by Order dated  24 March 2026 in the sum of AED 343,953.75, arising from the costs ordered by reference to the Orders  dated 7 August 2025 and 4 September 2025. representing the net wasted costs incurred by the CFI  Claimants between 9 July and 4 September 2025, the  formally acted on the Court record.  precise  period during which the CFI Counsel  

3.8 Furthermore, the 24 March 2026 Order encompasses no costs originating from the 18 April Order,  and no such costs are claimed herein. Consequently, the Defendants’ attempt to limit their liability to the  date of their formal appearance on the Court record is logically immaterial.  

3.9 The total quantum of damages pleaded in the Particulars of Claim consists of (a) the amount  mandated by the 24 March 2026 Order, and (b) restitution of fees paid for legal representation, wasted  court fees, related disbursements (including costs incurred with the struck-out Counterclaim), and the  additional corrective costs incurred within the CFI-066-2024 Proceedings.

4.1 The Defendants failed to specify any legal or factual nexus demonstrating how the Claimants’ prior  litigant-in-person status caused the later insertion of incorrect or non-existent legal authorities into amended defences drafted and filed by CFI Counsel.  This is central to causation.  

4.2 The Defendants conflate the Claimants’ general knowledge of the factual defense with informed knowledge of, or consent to, the inclusion of fabricated legal citations.  

4.3 The Defendants’ position regarding the non-compliance of the 18 April Order in the CFI-066-2024  Proceedings was originally attributed to a “lack of understanding” by the CFI Defendants while in these proceedings, it has morphed into a “late payment” assertion.  integrity of the pleaded defences.

4.4 The Defendants have not answered the Claimants’ pleaded distinction between ordinary amendment costs and the consequences arising from the strike-out of the amended defences and counterclaims following the Court’s concerns regarding AI-assisted materials, false references and misleading content.

• Drafts were not formally provided before filing, Paragraph (14.3) First Defendant’s Defence.  

• Legal citations were not verified before filing, Paragraph (37.3.) First Defendant’s Defence.  

• The Second Defendant admits that the First Defendant is an employee and a registered practitioner  authorized to represent the firm before the DIFC Courts, Paragraph (5.)

6.1 The Defendants rely on the timeline of fee payments to disclaim early obligations, yet simultaneously admit to filing formal notices with the Court on the Claimants’ behalf prior to the receipt of full payment.  

6.2 The Defendants contradictory positions regarding the assumption of liability is noticeable. As the  registered legal representative on record and the contracted Firm respectively, the Defendants are jointly  and severally liable for all submissions executed through their portal, irrespective of any internal  delegation to assistants.  

6.3 The Defences present inconsistent positions regarding the fabricated citations, the First Defendant  admits the presence of erroneous citations, whereas the Second Defendant evades the admission and  improperly attempts to shift liability to the First Claimant.  

6.4 The Defendants’ case also seeks to treat the Claimants’ prior litigant-in-person conduct as the cause  of the loss, while the pleaded loss arose from later amended defences and counterclaims prepared,  verified, filed and/or advanced after CFI Counsel had assumed conduct of the relevant amendment  process. 

7.1 The First Defendant contends that she acted solely as an employee, was not a party to the Retainer  Agreement, and assumed no personal responsibility for the conduct of the case. That contention is  denied as a defence to the pleaded duty of care, assumption of responsibility, professional responsibility,  and/or responsibility for documents signed, filed or issued under her name, signature or authority.  

7.2 in the Lutfi & Co Advocate’s formal letters dated 25 July 2025 executed by Harikrishnan Ravindran  to represent the CFI Defendants at the 31 July hearing explicitly contravene this assertion. These  documents unequivocally state that:  I. ) “All documents that have been filed or are required to be filed will be prepared and filed by Ms.  Harjeet Kaur. I bear no responsibility towards preparation and filing of these documents.”  II. ) “The entire responsibility and liability for conduct of these proceedings on behalf of Lutfi & Co  Advocate and Legal Consultants rests with Ms. Harjeet Kaur…”  

7.3 Mr Harikrishnan of Lutfi & Co mistakenly signed off a Skeleton Argument of CFI Claimants instead of  CFI Defendants and appeared at the 31 July 2025 CMC, further evidencing a systemic failure to review  documents prior to Court submission  7.4 Accordingly, the Defendant’s attempt to deny any responsibility is  inconsistent with the documents  issued by or on behalf of the Second Defendant and with the practical conduct of the CFI-066-2024  Proceedings.

7.5 The Claimants rely upon those formal letters as irrefutable documentary evidence establishing joint and several liability between the Defendants. Annexure 14 – Annexure 1 – filed on 12 May

8.1 The attempt to exclude the Second Claimant is denied.  Annexure 1 – filed on 12 May

8.2 The claim is not advanced solely on a narrow contractual basis. The Defendants acted in the  CFI-066-2024 Proceedings for the benefit of both CFI Defendants, filed a Notice of Change of Legal  Representative for the Second Claimant, drafted and filed documents on her behalf.  

8.3 The 25 July 2025 engagement documents also referred to representation of 3 named defendants in  CFI-066-2024, including the Second Claimant.  

8.4 The Second Claimant’s claim is therefore maintained in representation letters, and in professional  negligence, assumption of responsibility, reliance, and foreseeable economic loss.  

8.5 Further, the adverse costs order assessed on 24 March 2026 was made against, among others, Ms  Iuliia Valiullina. The Second Claimant therefore has a direct interest in the pleaded loss and in the  causation issues arising from the Defendants’ conduct.

9.1 The assertion that the CFI Counsel’s obligations under the Retainer Agreement were contingent  solely upon the receipt of full payment now relied on as a defense is denied.  

9.2 Documentary evidence establishes that the Second Defendant promised, via correspondence on;  (a) On 12 March 2025, to commence work immediately upon the execution of the Agreement and  stated that an invoice would follow. The Retainer Agreement was executed the following day.  (b) On 20 March 2025, case documents are being reviewed directly from the Court Portal as the log in  permitted by the First Claimant to his account by the Second Defendant was successful, in that  correspondence Ms. Manaf on behalf of the Second Defendant requested some time to complete  the review, and to get back to the First Claimant accordingly.  (c) This was followed with promises during April via WatsApp that the Firm is working on the case.  

9.3 AED 17,000 of the initial AED 50,000 fee was remitted prior to the 18 April Disclosure Order;  however, the corresponding invoice was not issued before late July 2025.  Page of  6 14 Drafted by the First Claimant, 8 Jun 26

9.4 At that material time, the Claimants did not demand the immediate filing of a Defence, but  reasonably expected competent guidance regarding the opposing party’s Request to Produce, or  minimally, a timely instruction to respond in person because no legal advice would be provided until a  payment condition had been satisfied. Annexure 12 – Annexure P – filed on 12 May

9.5 Notwithstanding the executed Agreement and partial payment, the CFI Counsel’s negligent omission  regarding the April Disclosure Order proximately caused the CFI Defendants to breach a mandatory  Court directive. This initial professional failure irreparably damaged the attorney-client trust and  constituted the basis for the refund request.  

9.6 with that in consideration, the Defendants explicitly assumed a duty of care long before the receipt of full payment. “a duty of care arises where there is an assumption of responsibility” Article 18 of the DIFC Law of Obligations (Law No. 5 of 2005)

The Claimants refer the Court to the direct WhatsApp correspondence with the Second Defendant’s  representative, Ms. Karina Manaf:  

(a) On 26 April 2025, following a partial payment remittance, Ms. Manaf explicitly stated: “I saw your  email, please note that we’re working on your case and will update you on the same by latest by  Wednesday”.  

(b) On 2 May 2025, Ms. Manaf further solidified this assumption of responsibility, stating: “Please rest  assured that we are actively working on your case and remain fully committed to protecting your  interests. We have reviewed the recent correspondence from the Court… Our immediate course of  action is to file a Notice of Change of Legal Representative… Following this, we will proceed to submit  the application to refile the Defense and Counterclaim…”. Annexure 15

9.7 The Defendants cannot reassure a client in April and May that they are “actively working on your  case” and ” fully  committed  to  protecting  your  no professional duties were owed until July.  interests,” only to subsequently argue before this Court that  

9.8 Accordingly, any defense relying upon the staggered payment schedule or the Claimants’ prior litigant-in-person status as an exculpatory mechanism must be dismissed as legally deficient.

10.1 The Claimants acknowledge the general rule under RDC Part 18.27 that the amending party bears  the costs of the amendment. The Claimants have never sought damages for standard amendment  costs; rather, damages are sought strictly in relation to the penal costs incurred when the Amended  Defences were struck out in their entirety.

As detailed in the Schedule of Reasons issued by H.E. Justice Thomas Bathurst:  

Paragraph 3. ” Following the filing of those defences the Claimants discovered that the defences had  been prepared substantially with the assistance of artificial intelligence which contained a number of  false references and other misleading material. As a consequence, the Claimants sought to strike out  the amended defences and counterclaims of each of the Defendants.”  

Paragraph 4. “At a CMC on 28 August 2025, and by way of the Order dated 4 September 2025, I  ordered those defences be struck out.”  

10.2 The judicial findings of the honourable judge conclusively preclude the Second Defendant’s  assertion that the Claimants’ 2 September Urgent Application merely ‘adopted’ the opposing party’s  position, and render the Second Defendant’s demand for ‘strict proof’ as satisfied.  

10.3 The ultimate determination of liability regarding the defective amendments, in light of the Court’s  explicit Schedule of Reasons, remains the exclusive purview of this Honourable Court.

11.1 to Paragraph 4.7 The matters pleaded therein amount to an admission that the First Defendant had  knowledge of the procedural advancements in the CFI-066-2024 Proceedings. Yet, the First Defendant failed to notify the CFI Defendants to comply with the 18 April Order in person. This contrasts with the  email dated 20 March 2025, wherein the Second Defendant (with the First Defendant copied) requested  a short time to review the case documents, but failed to provide any subsequent update.  

11.2 to Paragraphs 7.1 to 7.6 The First Defendant denies owing any contractual, fiduciary, any duties of  care but fails to reconcile this denial with her personal signature, verified by a Statement of Truth, upon  multiple iterations of the filed Defences. the Claimants maintain their pleaded case in professional  negligence and assumption of responsibility.  

11.3 to Paragraphs 9.3 (1) (2), These paragraphs fundamentally mischaracterize the material evidence.  The correspondence dated 18 March 2025 concerned documents relating to the Statement of Defence,  It did not concern the separate documents later identified in the CFI Claimants’ Request to Produce and/ or ordered by the Court on 18 April 2025, which the CFI Counsel totally ignored.

11.4 Further to Annexure 2, The 20 attached documents represented only a portion of the materials in  the CFI First Defendant’s possession. Crucially, the eRegistry login credentials were provided, obligating  the Second Defendant to revert with precise document requests to avoid duplicative filings, an obligation  they failed to meet. Annexure 12

11.5 to Paragraphs 15 to 15.3 These paragraphs impermissibly conflate “documents ordered for  disclosure” with “documents the CFI Defendants “wished to rely upon” Furthermore, the present claim  does not seek damages merely in respect of supporting documents.  

11.6 to Paragraphs 16.2 (1,2,3 and 4) These allegations concern pleadings that predate the 7 January  2025 Particulars of Claim in the CFI-066-2024 proceedings. These materials were not included in the  Strike Out Order and are therefore irrelevant to the proximate cause of damages in the present claim.  

11.7 to Paragraph 17.2 The assertion that ” the  time  for  document  production  had  passed” directly  contradicts Paragraph 4.7, wherein the First Defendant admits possessing knowledge from 13 March  regarding the impending 21 April disclosure deadline, The issue is that CFI Counsel, having accepted  the retainer, received payments, failed to provide timely advice, warning, or notice concerning  compliance with the 18 April 2025 Disclosure Order.  

11.8 to Paragraph 19. (3) The Claimants reiterate the rebuttals set forth in Paragraphs 10.3 and 10.4  herein, The Court is invited to compare the relevant Annexures 12 with 13.

11.9 to Paragraph 20.3 The First Defendant improperly conflates the wider CFI-066-2024 case  documents with the specific defective amended pleadings drafted exclusively by the CFI Counsel. Such  intentional obfuscation serves only to prolong proceedings and increase costs.  

11.10 to Paragraph 21.1 The cited correspondence was expressly intended to prevent any further filings  while the CFI Defendants investigated matters arising from the CFI Claimants’ Skeleton Argument  regarding the insertion of fabricated or AI-generated legal authorities by the CFI Counsel.  

11.11 to Paragraph 23.2 The cited rule explains precisely why the CFI Defendants did not issue a formal  complaint prior to the issuance of the penal Strike Out Order.  

11.12 to Paragraph 39 The defense raised evidences further negligence. The First Defendant was  copied on correspondence wherein Ms. Manaf provided factually incorrect assurances to the CFI  Defendants, despite having unrestricted access to the CFI First Defendant’s eRegistry profile since 20  March 2025, where the CFI-066-2024 pleadings were listed.

11.13 to Paragraph 42.1 The Claimants’ awareness of the general factual matters to be pleaded is not  legally equivalent to possessing knowledge of, or granting consent to, the inclusion of fabricated legal  references.  

11.14 to Paragraph 43.2 The assertion that the “CFI Counsel were not under any obligation”  demonstrates a fundamental misapprehension of the Claimants’ pleaded case. CFI Counsel were  obliged either to provide timely procedural guidance or to place the CFI Defendants on clear notice that  no service would be provided before full payment rather than remain silent and later rely on non payment as an answer to their omissions.

12.1 to Paragraph 6., The Particulars of Claim do not sue Mr. Lutfi in his personal capacity, nor  dependent upon proving that he personally drafted the defective documents. The Claimants’ cause of  action is predicated on the fact that Lutfi & Co. in its corporate capacity, was the contracting legal service  provider, acting through its authorized personnel, including the First Defendant and Ms. Karina Manaf.  

12.1 (a). The Contracting Party is the Firm, Not the Individual Owner  

• The Second Defendant attempts to evade liability by asserting that its owner, Mr. Lutfi, neither met the  Claimants nor worked on the matter. This assertion is legally immaterial. The Claimants executed a  formal Retainer Agreement (titled “Engagement Letter”) with the Second Defendant, Lutfi & Co. This  Agreement was issued on official letterhead, explicitly stated “The firm has been engaged…”, and  concluded with the official signature and stamp of the Firm.  

12.1 (b) Direct Assumption of Liability for Assigned Personnel  

• The Second Defendant cannot disclaim responsibility for the First Defendant’s conduct. The Retainer  Agreement expressly dictates that “The members of the firm who will be working on your matter are  Ms. Harjeet Bhatia… and Karina Manaf.”  

• By designating these individuals to perform the firm’s contractual obligations, the Second Defendant  assumed contractual liability for their professional conduct. Furthermore, the subsequent Engagement  Letters dated 25 July 2025 explicitly state that responsibility rests with the First Defendant “on behalf of  Lutfi & Co Advocate and Legal Consultants. Annexure 1 – filed on 12 May

12.2 The Second Defendant admits it is a sole proprietary firm and that the First Defendant is an employee/registered practitioner authorized to represent it before the DIFC Courts. Consequently, any professional negligence or breach executed by the First Defendant under the banner of Lutfi & Co. constitutes a direct breach by the Second Defendant. The demand for “strict proof” of Mr. Lutfi’s personal involvement is a misdirection.

12.3 to Paragraph 8., The Particulars of Claim reference the date of the Retainer Agreement, not the  date of execution. The damages sought arise from documented professional misconduct, not from oral  warranties.  

12.4 to Paragraph 10., the first cause led to damage resulted from the Second Defendant’s non performance and failure to provide formal notice of its intent to withhold services, while the second  cause led to sever damage materialized strictly while the Second Defendant was formally on record.  

12.5 to Paragraph 11., There are no allegations in the Particular of Claim that the amendment of  Defense was not needed. In fact It was needed, and the Claimants by the relevant time never issued  any complaints about the cost of the amendment, until these amended defences were struck out in their  entirety with cost.

12.6 to Paragraph 12., The Second Defendant’s denial of correspondence executed by its own  employees is rejected. The Second Defendant possesses direct access to these communications via the  official email and WhatsApp accounts assigned to Ms. Manaf.  12.7 to Paragraph 16., The Claimants have never averred that the 7 August Order contained explicit  findings of dishonesty, professional negligence, or AI-related misconduct.  

12.8 to Paragraph 17., The Claimants’ Urgent Application dated 2 Sep 2025 is subsequent to the oral  Strike Out ruling issued by H.E. Justice Thomas Bathurst during the 28 August 2025 CMC. The  Application did not cause the Strike Out; rather, it was a necessary mitigatory response to the CFI  Counsel’s failure to furnish contrary factual evidence to the Court.  12.9 to Paragraph 18., The Claimants note that the term “other things” used by the Second Defendant is  inconsistent with closing sentence of Paragraph 14. thereon.  

12.10 to Paragraph 20., the Second Defendant’s denial amount to a challenge to the judicial findings  codified in the Schedule of Reasons accompanying the 24 March Order. The present claim is firmly  based on established judicial determinations. Not personal opinions.  

12.10 to Paragraph 22., The pleaded breach is the filing of amended defences containing false, incorrect  or unverified authorities in the first place, without prior client review or proper verification. The later  attempt to correct those references is relevant, at most, to mitigation and causation. It does not  retrospectively authorises the original filing, nor does it remove liability for loss already caused or not  prevented.  

12.11 to Paragraph 30., The factual assertions within the witness statements relied upon by the Second  Defendant do not provide a defence to the insertion of misleading legal references. Those witness  statements did not contain any warning to the CFI Defendants that artificial intelligence had been used,  that legal authorities were unverified, or that false citations had been inserted.

12.12 to Paragraphs 39. to 43. the Claimants deny the need to prove enforceable liability and rely upon  the Court’s Order dated 24 March 2026 as creating an enforceable liability, irrespective of whether all  sums have yet been discharged. The Second Defendants is invited to review Annexure P where  payments, invoices filed in support to the claim at this pleading stage.  

12.21 Further the Defendants were invited by the Legal Notice paragraph 5 to settle the amount ordered on the 24 March by direct deposit into the Court or CFI Claimants’ bank account on behalf of the  Claimants. no double recovery is ever intended. Any recoverable loss will be subject to proof, causation,  mitigation, and any appropriate apportionment determined by the Court.

13.1 The Claimants rely on the statutory and procedural provisions pleaded in the Particulars of Claim  and further rely on the following provisions as they answer the matters raised in the Defences.

13. 2  DIFC  Law  of  Obligations  No .  5  of  2005 

(a) Article 17 is relied upon for the elements of negligence, namely duty of care, breach, causation and loss.  

(b) Article 18 is relied upon in answer to the Defendants’ denial of duty, including the issues of  foreseeability, proximity, fairness, and assumption of responsibility.  

(c) Article 20 is relied upon as the claim includes pure economic loss arising from professional advice, assumption of responsibility, reliance and reasonable reliance.  

(d) Article 21 is relied upon for the standard of care expected from a professional person exercising and professing the relevant special skill.

13. 3  DIFC  Contract  Law  No .  6  of  2004

(a) Articles 56 to 58 are relied upon as contractual obligations may be express or implied, including  obligations arising from good faith, fair dealing, reasonableness, and co-operation.  

(b) Article 64 is relied upon as performance must be made at the fixed time, within the relevant period,  or otherwise within a reasonable time.  

(c) Article 77 is relied upon because non-performance includes failure to perform, defective performance  and late performance.  

(d) Article 80 is relied upon in answer to the Defendants’ alleged correction attempt. Any cure must be  notified and effected promptly, and does not remove liability for delay or harm caused or not prevented  by the cure.

(e) Articles 109 to 113 are relied upon for the right to damages, full compensation, measure of damages,  certainty and foreseeability.  

(f) Articles 116 to 119 are relied upon as the Defendants raise contributory harm, mitigation and interest.  

(g) Articles 136 and 145 are relied upon as agency principles are relevant to duties of care, skill, and  liability for loss caused by breach of duty.  

(h) Articles 160 to 163 are relied upon as the Second Defendant seeks to avoid responsibility by referring to Mr Lutfi’s personal non-involvement, while the firm acted through authorised or apparently authorised personnel.

13 . 4  DIFC  Law  of  Damages  and  Remedies  No .  7  of  2005  

(a) Articles 8 to 12 are relied upon as the claim concerns damages arising from breach of contract,  including full compensation, measure of damages, certainty and foreseeability.  

(b) Articles 23 to 32 are relied upon as the claim concerns damages for breach of obligations, including full compensation, measure of damages, foreseeability, contributory loss, mitigation, prohibition of double recovery and interest.

13.5 Rules of the DIFC Courts  

(a) RDC 16.16 – 16.17 are relied upon as the procedural basis for this Reply.  

(b) RDC 17.26 to 17.30 are relied upon as the Defences are required to state what is admitted, denied,  not admitted, and the reasons for any denial.  

(c) RDC 17.34 to 17.36 are relied upon as a claimant is not taken to admit matters raised in a defence..  

(d) RDC 18.26 and 18.27 are relied upon as amended statements of case must be verified by a  statement of truth and as the Defendants rely upon the usual amendment-cost rule.  

(e) RDC 22.21 to 22.24 are relied upon as legal representatives signed or verified statements of case  and thereby represented that the client authorised the signature and was informed of the consequences.

13.7 The Claimants do not contend that every breach of the RDC or the Code automatically creates a  freestanding private law cause of action. The Claimants rely on the RDC and the Code as part of the procedural and professional framework informing the standard of care, breach, causation, foreseeability, mitigation and the reasonableness of the Defendants’ conduct.

14.1 For the reasons set out above and in the Particulars of Claim, the Claimants maintain that the  Defences fail to provide a complete answer to the pleaded claims.  

14.2 The Claimants maintain that the pleaded losses were caused by the Defendants’ breach of contractual and/or professional duties, including failures to advise, failures to provide prior review,  failures to verify legal references, failures to supervise filings, and failures to take effective remedial  steps in time.  

14.3 The Claimants reserve the right to rely upon further documents, correspondence, court orders,  pleadings and transcripts from the CFI-066-2024 Proceedings as they are relevant to the issues raised by the Defences