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Can my ex access my psychological records?

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In family law parenting matters, it is well-established that the paramount consideration to the Court is the best interests of the child. This takes priority over everything, even your right to confidentiality.

In considering what is in the best interests of the child, the Court will consider many factors, including:

  • the benefit the child may have from a meaningful relationship with both parents;
  • any views that the child expresses;
  • the nature of the relationship between the child and each of the child’s parents; and
  • the capacity of each of the parents to provide for the needs of the child, including emotional and intellectual needs.

If one parent attends counselling, it is likely that their counsellor’s notes would shed some light on these factors. In particular, the psychological records would be relevant to the question of whether the parent has the capacity to:

  • take care of the child’s best interests;
  • take care of the child physically;
  • provide emotional support to the child;
  • maintain or build a meaningful relationship with the child; and
  • Take care of the child long-term.

Psychological records may also evidence a risk of future family violence, psychological abuse or neglect. Therefore, psychological assessments can be highly relevant when determining orders that are in the child’s best interests.

 

How can my records be obtained?

Psychological records can be obtained pursuant to a subpoena. A subpoena is an order by the Court to an institution, such as your counsellor, to provide documents they have on record pertaining to you. Failing to comply with a subpoena is a breach of a Court order, which is punishable by a fine or imprisonment.

 

What about confidentiality?

Health practitioners have a duty of confidentiality, pursuant to which they cannot disclose medication information about the patient without the patient’s consent. However, this duty is subject to the medical practitioner’s obligations under a subpoena. If a counsellor receives a subpoena requesting them to provide documents to the Court about a patient, they must do this; practitioner-patient confidentiality is subject to the Court’s orders.

 

Please note that the above is general information and should not be relied upon as legal advice. All situations are different and legal advice must always be tailored to the specific situation.

Co-Parenting after Separation? Welcome to the Apps of the 21st Century!

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Relationships break down for many reasons and unfortunately, it is not always on good terms. However, being able to amicably co-parent with your ex-partner is very important for children and family dynamic. Having potentially lost the stability of having a close family unit, it is important that children see their parents communicating and working towards advancing the children’s best interests.

Traditionally, co-parenting has been difficult and communication breakdowns are common. However, with the development of smartphones and new apps there are now several options to assist those endeavouring to co-parent in the 21st century.

 

What are co-parenting apps?

A co-parenting app is an application that you are able to download onto your phone or tablet which aims to provide easy communication regarding the well-being and needs of your children. They have in-built features such as calendars and schedules, as well as access to important medical information about the child/children. They may also have features that track shared expenses and payments, or reminders and alarms to help both parents keep up with the designated schedule.

 

What are the benefits of co-parenting apps?

Co-parenting apps seek to bring a sense of organisation and peace to what can be a very overwhelming and difficult process. Co-parenting involves a large number of considerations including schedules, appointments, expenses, exchange places/times, health concerns of the children, special occasions such as birthdays and holidays, and so much more.

Both parents being able to access all of this information in one place will bring more organisation and clarity to the co-parenting situation. Being able to coordinate both the big things, such as birthdays and sleeping arrangements, as well as the smaller things, such as school events and excursions, in one application may help to soften some of the difficulties of co-parenting.

Co-parenting apps may also be successful in minimising conflict that may arise if the parents were to privately text one another or speak through a third-party. By encouraging parents to resolve smaller issues regarding the children between themselves and through an app, there may be less disagreement and less interactions with the court. This is also likely to have a flow-on effect and positively impact the psychological well-being of the child.

 

Examples of co-parenting apps

SharedCare

This app contains features such as a shared calendar, care arrangements (including requests to swap days), an expenses recorder (including reimbursement requests), and a group news feed where other carers including grandparents, nannies and aunts and uncles can keep updated on important milestones and news.

 

Parentship

Parentship utilises features including custom calendaring, digital documents, reminders, and a smart profile that contains everything about the child in one place.

 

Cozi

Cozi is a free app with a hassle-free family calendar and other features such as being able to create to-do lists and even share recipes where children may have allergies or dietary requirements.

 

Our Family Wizard
A popular app used globally with a great deal of options and functions, designed from the ground up for difficult situations in which the Family Court is involved. This app can also give children a controlled level of access to information, as well as third parties and legal practitioners, where relevant.

 

We note that this is just a small sample of the various applications on offer.

 

Are there any concerns?

Some co-parenting apps may require a small payment or a subscription fee. Also, co-parenting apps will only be successful if the parents are able to set aside their personal conflicts in order to put the children’s interests at their very highest concern.  Co-parenting apps may not be appropriate in all cases.

Unfortunately, these apps will not resolve all disputes that may arise in parenting matters; however, they allow for effective communication and synchronised scheduling which aims to benefit the children in the long term. Our lawyers can advise whether a co-parenting app is the right fit for your matter.

If you have concerns regarding a Parenting Matter, please contact Carter Dickens Lawyers on (08) 9408 5212 and we will endeavour to provide you with comprehensive legal advice to assist in your matter.

 

Please note that the above is general information and should not be relied upon as legal advice. All situations are different and legal advice must always be tailored to the specific situation.

 

Pressure to Settle in Parenting Matters & Without Prejudice Offers

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Parenting disputes affect people deeply. When accusations are being thrown around, and in particular when children are being withheld from a parent, tensions can run high. A person can feel a strong desire to agree to parenting arrangements they feel are unfair because they want it to be over, or want their children returned.

 During negotiations, you might receive a proposed “Minute of Consent Orders” for parenting arrangements that you don’t agree with, but you may feel tempted to sign them to see your kids again. In most cases, each parent will believe that what they are proposing is necessary for the best interests of the children, even though their beliefs differ. 

 In some circumstances however, a party might choose to withhold children as a strategy to get the other party to sign their preferred parenting orders – rather than because they believe they need to withhold the children to keep the children safe. This is rare, but does happen. 

 However, communications exchanging proposals to settle are typically ‘Without Prejudice’, which means that the proposed arrangements cannot be adduced in evidence should your dispute end up before a judge.  If you think someone is trying to pressure you to agree in a way that demonstrates their bad faith, you may want to show this to the Court, to have the Court to take this into account.

 However, the general rule for ‘Without Prejudice’ communications is that they cannot be shown to the Court.

 

Without Prejudice Communications

 The term ‘Without Prejudice’ invokes a particular kind of legal privilege, which is specifically permitted for negotiating settlements. The privilege is that that communication cannot be relied on by the other party in Court proceedings. For example, it cannot be introduced as evidence claiming, for example, to demonstrate the weakness of that party’s case.

 Providing the other party’s without prejudice offers and communication to the Court is typically disallowed, and if they are filed by the other party, they will be struck out by the Court in line with this privilege, and for good reason. This is because the ability to engage in ‘Without Prejudice’ communications is generally to the advantage of both parties, as it allows them to make offers to settle a matter without fear of having the offer brought up later.

 This applies in the Family Court, it can be found in the Family Law Rules at 10.2:

 FAMILY LAW RULES 2004 – RULE 10.02 OPEN AND “WITHOUT PREJUDICE” OFFER

 10.02(1) An offer to settle is made without prejudice (a without prejudice offer) unless the offer states that it is an open offer.

 10.02(2) A party must not mention the fact that a without prejudice offer has been made, or the terms of the offer:

 (a) in any document filed; or

 (b) at a hearing or trial.

 The rule against providing without prejudice communications to the Court is a part of a broader set of rules regarding evidence.

 

Family Court and the Rules of Evidence

 The Family Court has a number of notable exceptions to the normal rules of Evidence. The ability to quote children’s speech, when they are not giving evidence themselves, which would normally be a breach of the Rule of Evidence against Hearsay, is the most well-known example, located at 69ZV of the Family Law Act (“the Act”).

 Family Law however can involve a number of other exceptions to standard rules of evidence. More generally, 69ZT “Rules of evidence not to apply unless court decides,” specifies the parts of the Evidence Act (Cth), which codifies the principles of evidence, which the Court may decide whether or not to apply in child-related proceedings as per the considerations in that section, and what weight to give them. This includes documents and other evidence including demonstrations, experiments and inspections, and evidence that is hearsay, opinion, admissions, evidence of judgments and convictions, tendency and coincidence, credibility and character.

 The important principle to keep in mind is that in parenting matters, the primary consideration is the best interests of the children. What is in the best interests of the children is determined by consideration of primary and secondary factors at s60CC of the Family Law Act.

 One interesting example of a departure from normal legal principles regards ‘Without Prejudice’ communication. Typically, if a party tries to put ‘Without Prejudice’ communication before the Court as evidence, it will be struck out and not considered by the Court.

 

Can Without Prejudice Communications ever be Submitted to the Court?

 However, there are exceptions, generally and in the Family Law specific to the normal ‘Without Prejudice’ principles.

 Sometimes, without prejudice communications will include content which go towards demonstrating a fact of sufficient significance that the Court may choose to allow their entry into evidence.

In Parenting matters, the best interests of the children are the primary consideration, as per s60B and s60CA. As such, if the other party provides ‘Without Prejudice’ communications, such as an offer that provides for orders which implicitly contradicts other assertions that have been made in Court documents, the court may be willing to enter the ‘Without Prejudice’ communications into evidence.

 This has been discussed in the WA case S and K [2007] FCWA 17, where Her Honour Justice Crisford identifies, at 28-32:

 28 It goes without saying that it is important to preserve confidentiality in relation to offers. Full and frank negotiation needs to take place between parties so that matters may be resolved without the need for further court action. Often in children’s matters, the very avoidance of litigation can itself be in the best interests of the children. Whilst children are not parties to the proceedings, they are well and truly the subject of the proceedings. The principles governing these sorts of proceedings are very different to those relating to property matters.

 29 However, whilst it is important for negotiation that confidentially be preserved, especially in light of the rules of the Court, I am of the view that the preservation of confidentiality is not absolute. One of the main purposes of the Rules is that cases are resolved in a just manner. The Rules do not provide a complete code of the Court’s powers. Other powers are found in the provisions of various Acts, the Court’s inherent jurisdiction and the common law.

 30 Hutchings v Clarke may well stand for the proposition that the issue of legal professional privilege does not operate to exclude evidence if in the discretion of the trial Judge such evidence is required to be put before the Court in order to preserve the best interests of the child.

 31 There is no doubt that it is important to preserve confidentiality and to foster an environment that allows parties to negotiate without fear they will be compromised in an endeavour to settle matters. However, offers can be made for a number of reasons and the overarching principle is always the best interests of the child. It is not the sole consideration but it is the paramount one.

 32 The Court should not be precluded from obtaining information to ensure that the principle is met, especially in cases of such naked acrimony as this.

 

As such, if you have been sent ‘Without Prejudice’ communications in a Family Law matter, where untrue claims are made or strict orders are being sought when the other party does not actually require those Orders, the Court may be willing to accept that correspondence of an offer to settle into evidence. 

Such a circumstance might be withholding children except when supervised by a professional supervision agency; while simultaneously making an offer that involves children spending time without any external supervision. 

However, other avenues for adducing the same evidence ought to be pursued first. The Court will be very hesitant to override the general rule regarding ‘Without Prejudice’ offers, as ‘Without Prejudice’ offers are a very significant element which benefit the ability to conduct settlement negotiations, and this privilege will not be dismissed lightly.

Indeed, settling a parenting matter by agreement may, in many cases, be very much in the best interests of the child, as ongoing proceedings may very well put children under stress, increase hostility between parents, and potentially require the children to be involved in proceedings to some degree.

As such; the possibility of successful negotiations, and thus ability to engage in these negotiations ‘Without Prejudice’, towards reaching parenting orders both parties may not like but are prepared to accept may well be a better outcome than the outcome of ongoing proceedings even should the party’s preferred orders be made and their concerns legitimate, given the impact on the children of ongoing proceedings. 

If you need advice about your family court negotiations, please contact us on (08) 9408 5212 for a free telephone consultation. 

Please note that the above is general information and should not be relied upon as legal advice. All situations are different and legal advice must always be tailored to the specific case in question.

The Pitfalls of Homemade Wills

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Homemade Wills are a tempting proposition for those interested in reducing the costs associated with obtaining legal services. Whilst on the surface these Homemade Wills kits appear be straightforward and binding, this is not always the case. It is important to ensure that your Will is prepared in the proper legal manner so that your wishes are unambiguous, and your estate may be correctly dealt with at the time of your passing.

The common issues surrounding Homemade Wills have been exemplified in the Supreme Court of Western Australia’s recent case James Edward Donnelly as executor of the estate of Sarah Shulman v Donnelly 2020 WASC 254. In this decision, Master Sanderson at [13] heavily criticised the ambiguity of the Homemade Will in question, stating:

“Although it is a valid will because it complies with the provisions of the Wills Act apart from appointing the plaintiff as executor, it has no content. It makes no disposition. It is meaningless.”

In this case, despite there being every reason to believe that the deceased intended to leave her entire estate to the first defendant, even the most benign interpretation of the Homemade Will offered no benefit to the first defendant. Apart from being mentioned as executor of the Will, the first defendant was not mentioned at all – in fact, no-one was.

Master Sanderson suggests in this judgement that there is no question of the Will being ambiguous, as it simply remained silent on who was to receive the benefit (the beneficiaries of the Will). Through proper exercise of the construction of the Will, it was determined by Master Sanderson that, on the facts, he was satisfied that the deceased intended to leave her estate to the first defendant.

Although in this case the exercise of discretion fell in the favour of the defendant, this acts as a reminder as to the pitfalls of drafting Homemade Wills.

 

How do the Courts Construct an Ambiguous Wills?

You may be wondering what process is undertaken to properly “construct” or “read” an ambiguous will by the Courts? Construction of a Will is a two-step process:

  1. Firstly, the Will is to be read on its own without regard to any evidence. If this does not lead to an interpretation of the Will then an attempt must be made to deduce the intentions of the testator.
  2. If the intentions of the testator cannot be readily discerned for any reason, then the court should proceed to construe the Will with the assistance of cannons of construction. These cannons often allow a judicial officer to review extrinsic materials, as per section 28A of the Wills Act 1970 (WA), to better consider the intentions of the testator at the time of drafting the Will.

 

Common issues with Homemade Wills

Although use of these Homemade Wills kits may provide you a legally binding Will, it may not be drafted in such a way as to achieve what you truly intended. Common issues with Homemade Wills include the following:

  1. Failure to properly date the Will;
  2. Leaving the wrong assets or assets you are not entitled to distribute;
  3. Misunderstanding legal definitions;
  4. Losing the Will;
  5. Incorrectly witnessing documents;
  6. Unintended Tax Consequences;
  7. Appointing the wrong Executor;
  8. Ignoring potential and eligible beneficiaries; and
  9. Failing to provide for the guardianship of children.

 

Recent Judicial Commentary regarding Homemade Wills

Despite gaining popularity in recent years, Homemade Wills have been an enduring cause of concern within the Judicial system. Recent Western Australian examples which demonstrate this concern include the following:

Kossert v Ruggi as Executor of Will of Korps (No 2) [2012] WASC 191

Kenneth Martin J at [8] stated:

‘Sadly, as so many home-made wills seem to do because of a failure to receive proper legal advice, it throws up the question of [the deceased’s] failure to deal fully by his will with the one substantial asset he left, namely the house and land’

 

O’Brien, as Executor of Will of Hogan v Warburton [2012] WASC 82

EM Heenan J at [3] stated:

“ [the deceased’s] last will was prepared by him or at his direction apparently without any legal advice or assistance. Major difficulties have arisen in determining the proper construction of the testament and, in particular, whether or not it fails fully to dispose of the testator’s estate, so leaving a partial intestacy”

EM Heenan J at [58]:

“Obvious difficulties arise when parts of a will are ambiguous or, worse still, inconsistent. Such problems are often experienced in home-made wills such as this..”

 

Thomas v Pearman [2017] WASC 209

Master Sanderson at [1] criticised Homemade Wills, stating:

“The will and the codicil were home-made. They comprise 14 pages in all. They are a particularly egregious example of the folly of home-made wills.”

 

How can Carter Dickens Lawyers help?

Our expert lawyers are able to properly draft a will in the accepted legal manner, ensuring all of your wishes are to be fulfilled upon your passing. This will circumvent the ambiguous situations that often arise from Homemade Wills kits, and ensures that you can confidently have your Will executed as per your intentions.

At Carter Dickens Lawyers, we have the experience and knowledge to help you navigate this potentially complicated area of law. We understand the difficulties faced by families upon the death of a loved one, and we hope to ease this process by ensuring your final wishes are understood and binding.

Our Wills and Estates matters are provided on a fixed fee basis. Wills and Estates matters we may assist you with include the following:

  • Single Wills
  • Couples Wills
  • Enduring Power of Attorney (EPA)
  • Enduring Power of Guardianship (EPG)
  • Advanced Medical Directive
  • Probate Application
  • Letters of Administration (Deceased had no Will)

If you would like to discuss your Wills and Estates related matter, please contact Carter Dickens Lawyers on (08) 9408 5212.

Please note that the above is general information and should not be relied upon as legal advice. All situations are different and legal advice must always be tailored to the specific situation.

 

Challenging a Child Support Assessment

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The initial stage of separating from your partner is often the most difficult phase, especially when there are children involved. The transition from sharing care to being the primary carer often leaves single parents struggling to make ends meet. Child support is designed to alleviate this stress.

A child support assessment is made using one of various formulas, with the appropriate formula being determined by your individual circumstances. However, no two families are the same. We each have different lives, different needs and different circumstances. For this reason, it is sometimes arguable that your unique circumstances justify departing from the usual formula.

The Court will consider making a departure from the ordinary formula when:

  • a ground for departure in section 117(2)(a) of the Child Support (Assessment) Act 1989 (‘the Act’) applies; and
  • it would be just and equitable or otherwise proper to make the order.

 

Step 1: Grounds for Departure

There are a number of grounds for departure outlined in section 117(2) of the Act. In summary, these grounds are as follows:

  • In the special circumstances of the case, the non-carer parent’s capacity to provide financial support is significantly reduced because of their duty to maintain themselves, another child or any other dependant person.
  • In the special circumstances of the case, the costs of maintaining the child are significantly affected:
    • because of high costs involved in enabling a parent to spend time with, or communicate with, the child;
    • because of special needs of the child;
    • because of high child care costs in relation to the child; or
    • because the child is being cared for, educated or trained in the manner that was expected by his or her parents.
  • In the special circumstances of the case, application of the formula would be unjust and inequitable because of the income, earning capacity, property and financial resources of either of the children or the parents.

The common denominator in all of the grounds is the phrase ‘in the special circumstances of the case’. So, what does this mean?

When discussing the meaning of this phrase, the Family Court in Gyselman & Gyselman (1992) 15 Fam LR 219 stated, “Whilst it is not possible to define with precision the meaning of that term, as a generality it is intended to emphasize that the facts of the case must establish something which is special or out of the ordinary. That is, the intention of the Legislature is that the Court will not interfere with the administrative formula result in the ordinary run of cases.”

There is no one definition of what exactly a ‘special circumstance’ is, and this is intentional. The term is broad and flexible enough to cover a wide variety of circumstances. That being said, the following are examples of circumstances which have been held by the Court to be ‘special’:

  • In L and L [2003] FMCAfam 223, the liable parent was ordered to contribute to private school fees for a child with special needs. The Court held that the ‘special circumstances’ in this case were the child’s need for medical care, which was not covered by medical insurance, and her need to be encouraged to attend school. As the child was already enrolled in a private school, the non-liable parent was ordered to contribute to the fees.
  • In Bassingthwaighte and Leane (1993) 16 Fam LR 918, the father was an airline pilot who owned a farm, which operated at a loss. While the father’s taxable income was significantly reduced, the actual income he received was not. The Court allowed a departure from the usual assessment, in that his income without the reductions for tax losses was considered for the purpose of the assessment.
  •  In Dwyer and McGuire (1993) 17 Fam LR 42, the father owned a number of farming properties with his family, several of which were in the father’s sole name. The properties were unencumbered and the farming business had little debt. The father’s substantial assets established a ground for departure, and the Court ordered that the assessment would take these assets into account.

Step 2: Just and Equitable

The Court may only make a particular departure order if it is satisfied that doing so would be just and equitable to the child and both parents. Here, the Court looks at the overarching circumstances, having regard to:

  • the nature and duty of a parent to maintain a child;
  • the proper needs of the children;
  • the income, earning capacity, property and financial resources of the child and each of the parents;
  • the commitments of each parent that are necessary to enable the parent to support themselves or any other child or dependant;
  • the direct and indirect costs incurred by the carer entitled to child support in providing that care; and
  • any hardship that would be caused to the child and the parents if the order was either made or refused.

 

How can a lawyer help?

A lawyer with experience will be able to provide you with the knowledge and assistance you need to determine the grounds of departure which likely apply, whether your circumstances are special, and what kinds of departure order(s) would be just and equitable in your circumstances.

Importantly, a lawyer can also help you gather the evidence you need to support your case through different processes, such as disclosure. This is where both sides to the proceedings have an obligation to provide to the other party all relevant documents and material in their possession.

At Carter Dickens Lawyer, we have the experience and knowledge to help you navigate this complicated area of law to ensure that you put the best case forward, so please do not hesitate to contact our office for more information.

Please note that the above is general information and should not be relied upon as legal advice. All situations are different and legal advice must always be tailored to the specific situation.

 

What are my Legal Rights to a Parentage Test?

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We are occasionally asked by our family law clients whether it is possible to obtain a parentage test where the paternity of a child is “in issue” or “in doubt”. Despite potentially valid reasoning by a party to seek such a test, the Courts are often reluctant to make orders that a test be conducted.

 At Carter Dickens Lawyers we will aim to assist you in providing to the Court the clear evidence which meet the requirements to be granted a DNA parentage order. This may in turn impact past, ongoing and future Child Support payments, as well as a range of other factors related to parenting a child.

Presumptions of Parentage

Given the inability to DNA test all alleged parents of children, the Court, through the relevant provisions of the Family Law Act 1975 (CTH) make certain presumptions. For example, a person is presumed to be the child’s biological parent if:

  • they are named as the parent on the birth certificate or adoption certificate
  • they sign a statutory declaration (a legal document) saying they are the father/parent
  • the child was born during the marriage
  • the child was born within 20 to 44 weeks of when the mother and father lived together
  • the court makes a declaration (finding) that a person is a child’s father and/or that a person is liable to pay child support for a child.

 

Rebutting the Presumptions

Presumptions of parentage used to play an important role prior to DNA testing being used as evidence. Now, with DNA testing, the role of the presumptions is simply to put onus on the person who wants to rebut the presumption to gather such evidence.

It is possible for the Court to require a parentage testing procedure to be carried out for the purpose of obtaining information to assist in determining the parentage of the child, and to seek to vary the presumption of parentage. The Court, however, requires there must be enough evidence which places the paternity of the child in doubt, before it can embark upon the process of subjecting the child to procedures for paternity testing.

The Court will only make such an order if you are able to demonstrate via evidence before the Court that you have an honest, bona fide and reasonable doubt that the child is your own (In the Marriage of Lee and Tse (2005) 33 Fam LR 167 at [29]-[34], [40]-[49).

 

What Happens if a Parent refuses the Parentage Test?

A court may draw such inferences as appear just in the circumstances if an adult person contravenes a parentage testing order or an associated order, or if a guardian of a child the subject of the application refuses to consent to the procedure.

In G v H (1994) 181 CLR 387, Brennan and McHugh JJ accepted the following definition of the word “inference”:

‘An inference is a tentative or final assent to the existence of a fact which the drawer of the inference bases on the existence of some other fact or facts. The drawing of an inference is an exercise of the ordinary powers of human reason in the light of human experience; it is not affected directly by any rule of law. Legal principle may confine the basic facts in order to exclude irrelevancies.’

In G v H, G (the man alleged to be the father of the child) refused to undergo parentage testing. The High Court considered the inference that could be drawn from this refusal. Their Honours, Justices Deane, Dawson and Gaudron held the following:

“So far as G’s state of mind is concerned, it may be inferred that he has chosen to take the risk of being held to be the father of H’s child and liable for his maintenance and support rather than submit to a test which will effectively disclose whether or not he is in fact the father … And if, as here, the evidence establishes that a particular person is the most likely person to be the father and that person has chosen to risk a finding that he is the father rather than submit to a parentage test, there is no injustice involved if such a finding is ultimately made.”

Essentially, it was concluded that an “inference may be drawn contrary to the interests of a party who, although having it within his or her power to provide or give evidence on some issue, declines to do so.”

Parentage is important because only parents have to pay Child Support. Parentage may also be an issue in Family Court matters when there is a dispute about who a child lives or spends time with. We therefore recommend you seek legal advice if you have any issues related to a topic raised in this article.

We understand the stress and time constraints that are often associated with these sensitive family issues. With this in mind, Carter Dickens Lawyers aims to both advise and make you fully aware of your rights, obligations and risks pursuant to Parentage Testing.

Please note that the above is general information and should not be relied upon as legal advice. All situations are different and legal advice must always be tailored to the specific case in question.

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