⚖️ Boss Lawyers — Litigation Dashboard

Boutique Commercial Litigation & Insolvency
Tue 28 Apr 2026, 6:28 PM
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63
Days to AML/CTF
Active Matters
McKenzie & Anor ats JPS Medical Recruitment Pty Ltd
District Court QLD — No. 598/26
Phase 3 — Defending
MH:McKenzie
1. Intake
2. Pre-Lit
3. Defence
4. Interloc
5. ADR
6. Trial Prep
7. Trial
Merits: 7.5/10 Claim: ~$300k | Counterclaim: $88k Restraint expires: 2 Jul 2026 (65 days)

⚡ Next Actions

→
Client to review Defence ver 22
Client to confirm 3 VERIFY items
Client to send commission calculation files
Receive $2,015 filing fee from client
Arrange verification (oath)
File and serve Defence and Counterclaim
Send Calderbank letter (4-6 weeks post-filing)

📅 Key Dates

Defence due [X] days
Restraint expires 65 days — 2 Jul 2026
Calderbank letter target ~6 weeks post-filing
AML/CTF deadline 63 days — 1 Jul 2026

⚠️ Risk Register

Overall Risk
6.5 / 10 — Moderate-Good
✓ Restraint: 8.5/10
✓ Damages/remoteness: 8/10
✓ Fiduciary: 8/10
✓ Counterclaim: 7/10
⚠ Confidence: 6/10
⚠ s 183 Corps Act: 6/10
✗ Exelare export (33k records): HIGH RISK

📄 Document Tracker

✓
Statement of Claim
Filed 2 Mar 2026
✓
Notice of Intention to Defend
Filed [date]
⟳
Defence & Counterclaim (ver 22)
Client reviewing
⟳
Calderbank Letter (v4)
Ready — hold for post-filing
⟳
Client advice email
Ready to send
○
Reply (from Plaintiff)
Awaiting filing
○
Answer to Counterclaim
Awaiting filing

📋 Recent Activity

Defence & Counterclaim ver 22 finalised
28 Apr 2026 — Form 18 compliant, repudiation redraft
VLL research completed — 5 topics, 100k chars
28 Apr 2026 — CCH iKnowConnect
Repudiation analysis — recommendation: KEEP and MODIFY
28 Apr 2026 — CHA v Loone confirmed
Client instructions received — payslip, resignation, ATO statement
28 Apr 2026 — 9 topics confirmed
Instructions request sent to client — 9 outstanding items
27 Apr 2026
Deep pleading study — 6 new reference files created
28 Apr 2026 — 5:30 AM cron task

🎯 Opponent Intelligence

Thomson Geer
National firm — Brisbane office
David Quinn
Special Counsel — on the record
Employee-side background. Unusual for plaintiff employer.
Gavin Rebetzke
Junior counsel
Generalist. Not a restraint of trade specialist.
Tony Tallant
Director — JPS Medical Recruitment
Key witness. Made commission representations.

💰 Costs Tracker

WIP — 28 Apr 2026
$5,147
76 units (6 hrs 20 min)
Defence drafting (ver 10-22)$2,800
Legal research (VLL + authorities)$1,067
Client correspondence$533
Calderbank letter$800
Estimated total to trial
Pre
Plead
Interloc
ADR
Trial prep
Trial
$0 Estimate: $415k - $585k

🤖 AI Recommendations

STRATEGY
File Defence and Counterclaim, wait 4-6 weeks, then send Calderbank offer. Time is on your side — restraint expires 2 Jul 2026.
EVIDENCE GAP
Client's commission calculation files not yet received. These are critical for particularising the counterclaim quantum. Chase immediately.
RISK MITIGATION
Exelare export (33k records) is the primary vulnerability. Get precise instructions on what was exported, when, and current status of the data.
AUTHORITY ALERT
Wollermann v Fortrend [2025] FCA 103 — new authority on s 323 FW Act. Commission forfeiture on termination held unlawful. Directly supports para 40.

✅ Phase 3 Workflow — Defending

Pleading
✓
Obtain full instructions on SOC
✓
Draft Defence (22 versions)
✓
Draft Counterclaim
✓
Quality gate — UCPR compliance
✓
Form 18 compliance check
✓
Solicitor's certificate (r 246)
→
Client review and approval
Verification (oath)
File and serve
Research
✓
VLL — CCH iKnowConnect (5 searches)
✓
Restraint of trade authorities
✓
Commission / s 323 FW Act
✓
Confidential information / Faccenda
✓
Repudiation analysis
✓
Clayton Utz article review
✓
Calderbank requirements research
Correspondence
✓
Instructions request to client
✓
Client advice email (with Defence)
✓
Calderbank letter drafted (v4)
Send advice email to client
Send Calderbank (post-filing)

📚 Key Authorities

CHA v Loone [2017] VSCA 181 at [88]–[102]
Repudiation kills 12-month restraint. Directly on point.
Wollermann v Fortrend [2025] FCA 103 at [78]–[95]
s 323 FW Act — forfeiture of commission unlawful.
AECI v Convey [2020] QSC 207 at [43]–[55]
QLD — Australia-wide restraint too broad.
Adams v Westfield (2000) 48 AILR ¶5-280
Absolute discretion read down where capricious.
Artedomus v Del Casale [2006] NSWSC 146
Skill & knowledge vs confidential information.
Faccenda Chicken v Fowler [1987] Ch 117 at 137–138
Three categories: trade secret / know-how / trivial.
General Billposting v Atkinson [1909] AC 118 at 123
Foundation: repudiation releases restraint.
MGICA v Kenny & Good (No 2) [1996] 1 Qd R 583 at 587
QLD — unreasonable rejection of Calderbank offer.
[Future Matter]
—
Phase 1 — Intake
1. Intake
2. Pre-Lit
3. Defence
4. Interloc
5. ADR
6. Trial Prep
7. Trial