Will a Client's TEP Breach Trigger a GED Prosecution Against Your Consulting Firm? A Property Development Lawyer's Guide
KEY TAKEAWAYS
The 2024 amendments to the Environmental Protection Act 1994 (Qld) introduce a direct criminal offence under section 319(2) for breaching the general environmental duty where the breach causes, or is likely to cause, serious or material environmental harm. That changes the risk profile for environmental consultants.
The notification duties applied by section 320A of the Environmental Protection Act 1994 (Qld) are now triggered where a person carrying out an activity "ought reasonably to have become aware" of an event causing or threatening serious or material environmental harm. Where the duty applies to a consultant, it overrides contractual confidentiality clauses, including during preliminary site investigations.
Consolidated Environmental Enforcement Orders (EEOs) are likely to accelerate pass-through professional negligence claims as clients attempt to shift compliance costs back onto their advisers.
Environmental consultants drafting Transitional Environmental Programs (TEPs) should deliberately demarcate their compliance advice from the client’s operational execution to mitigate direct regulatory targeting.
You check your phone on a Tuesday morning to find a frantic message from a facility manager: a primary storage bund has failed, releasing contaminants into a nearby waterway and directly breaching the Transitional Environmental Program (TEP) your firm finalised last month. The client is facing significant clean-up costs, but your immediate problem is the methodology section of the TEP that bears your signature. Since the Environmental Protection (Powers and Penalties) and Other Legislation Amendment Act 2024 (Qld) amended the Environmental Protection Act 1994 (Qld) (EP Act), a client's physical site failure can quickly trigger a regulatory investigation into whether the consultant's underlying advice fell short of the general environmental duty (GED). Breach of that duty is now an offence in its own right. This article explains how the amended duties apply to environmental consultants, and the drafting and documentation steps that help separate your advice from a client's operational failures.
Mapping the Immediate DETSI Exposure: TEP Drafting vs. Client Operational Failures
You've just been told about the containment failure, and the client already wants answers. Your first question is whether the regulator will look only at the client’s operational failures, or also at your firm’s advice, and specifically whether the transitional environmental program your firm designed contributed to the breach. A TEP is typically the operator's route back into compliance, often with its environmental authority conditions, so the regulator will want to know whether the program failed or the client failed to follow it. This section sets out the regulatory and civil pathways you face in the first days after a TEP breach, and how to keep your exposure separate from the client's.
The New Section 319(2) General Environmental Duty Offence vs Professional Negligence Claims
When a TEP fails, consultants face two distinct legal pathways: statutory regulatory enforcement and civil liability claims from the client. Historically, the general environmental duty under the Environmental Protection Act 1994 (Qld) functioned largely as a defensive standard. The 2024 amendments changed that. Section 319(2) of the EP Act establishes that a person commits an offence if the person contravenes the general environmental duty and the contravention causes, or is likely to cause, serious or material environmental harm.
While a client may separately pursue a professional negligence claim against your firm for allegedly deficient advice, the immediate threat is direct statutory prosecution by the regulator. The stakes are significant. Section 319(2) of the EP Act carries a maximum penalty of 4,500 penalty units or two years' imprisonment where the offence is committed wilfully, and 1,655 penalty units otherwise. At the Queensland penalty unit value of $172.70 that applies from 1 July 2026, that is $777,150 and about $285,800 respectively. For a body corporate, section 181B(3) of the Penalties and Sentences Act 1992 (Qld) generally allows a court to impose a maximum fine of up to five times the individual maximum. ^pFirm principals should also note section 493 of the EP Act. If a corporation commits an offence against the Act, each of its executive officers also commits an offence of failing to ensure the corporation complied, carrying the maximum penalty that applies to an individual. It is a defence for an officer to prove that they took all reasonable steps to ensure compliance or were not in a position to influence the corporation's conduct in relation to the offence.
The 2024 amendments turn the general environmental duty in Queensland from a guiding principle into a direct statutory offence where a breach causes, or is likely to cause, serious or material environmental harm.
This gives the Queensland Department of the Environment, Tourism, Science and Innovation (DETSI) a direct prosecution pathway against any person whose activity causes, or is likely to cause, serious or material environmental harm without all reasonably practicable measures being taken. Whether preparing compliance advice is itself "carrying out an activity" for this purpose has not been tested, but the risk that a regulator will argue it is explains why you need to separate your advisory role clearly from the client's physical site operations.
Establishing the Boundary Between Consultant Advice and Site Execution
Expert insight: Section 319(1) of the EP Act puts the general environmental duty on every person carrying out an activity that causes, or is likely to cause, environmental harm. In practice, though, investigators rarely start with the statute. They start with the documents. After a TEP breach, the first request usually covers the whole project file (draft versions, email chains, meeting notes), not just the approved TEP. What investigators are looking for is the gap between what the TEP said would happen and what actually happened on site. Say the TEP committed to weekly bund inspections and the site logs show three inspections in two months: the failure tends to sit with the operator. But if the TEP specified a bund capacity that was never adequate for the site's catchment, the focus can shift to whoever designed that measure.
Wording matters more than most consultants expect. A TEP written in the passive voice ("the bund will be upgraded", "monitoring will be undertaken") leaves open who was responsible. Investigators may read that ambiguity against the party with the technical expertise. When each action names the operator as the responsible party, it is much harder to recast after the event. Often the most damaging documents are the consultant's own emails. A message to the client saying "we'd normally recommend a larger buffer, but this should get through approval" can do more to show that a reasonably practicable measure was identified and not adopted than any expert report. If a client rejects a recommendation on cost grounds, put in writing at the time both that you made the recommendation and that the client declined it. Cost is a legitimate consideration: section 319(4)(e) of the EP Act requires regard to be had to the financial implications of different measures, so a client's decision to decline a measure on cost grounds is not automatically a breach.
The regulator will, however, expect to see that the decision was made knowingly, and your written record is what shows it. Finally, if your firm’s methodology was sound but the client departed from it, you need to be able to prove that departure. Site variation notices, change requests and operator instructions to scale back works are what separate advice from execution. Without them, your firm is more exposed to being drawn into an environmental prosecution in Queensland, even where the advice itself was defensible.
The First Seven Days After a TEP Breach: A Response Timeline
Consider a scenario where a primary containment bund fails at 2 am on a Sunday. Later that day, well inside the 24-hour window for written notice, the operator notifies DETSI. In a scenario like this, authorised officers may attend the site within days and ask for copies of the TEP and associated engineering reports. At the same stage, the client's legal advisers are likely to be reviewing the consulting agreement for time bar clauses or indemnity provisions, preparing to deflect liability. Because DETSI will assess whether all reasonably practicable measures were taken (see the Information Sheet – General Environmental Duty (ESR/2024/6837)), the consultant should secure its project files straight away and be ready for a formal written requirement to provide documents or information within the first week.
The "Ought Reasonably to Have Become Aware" Trap During Site Investigations
The same exposure can arise earlier, before a TEP is drafted. Suppose your field team is carrying out a limited-scope contaminated land assessment and notices signs of an active problem, such as fresh staining below an operating tank or a leaking drainage line, in an area your scope of services expressly excluded. The client asks you to leave it alone and keep the findings confidential. You may now be caught between the client's demand for discretion and an objective statutory reporting duty. Here's how that duty works, when it is likely to reach your firm, and why a confidentiality clause won't protect your firm if it does.
Section 320A's Objective Standard for Triggering the Duty to Notify
Section 320A of the EP Act sets out when the notification duties in Chapter 7, Part 1, Division 2 apply. The operative duties are in the provisions that follow it, and they are triggered by what a person actually knew or ought reasonably to have become aware of. Actual knowledge is not required.
The 2024 amendments expanded the duty to notify environmental harm in Queensland. Under section 320A(1)(a) of the EP Act, the notification duties apply if a person, while carrying out an activity, "becomes aware, or ought reasonably to have become aware, that an event has happened that causes or threatens serious or material environmental harm because of the person's or someone else's act or omission in carrying out the primary activity or another activity being carried out in association with the primary activity". This shift adds an objective standard to the existing actual knowledge test.
The words after the awareness test matter. The duty is clearly engaged where the event arises from your own site work, for example where drilling breaches a contaminated layer or damages a tank. It is arguably engaged where the event arises from the client's ongoing operations on the site and those operations can be said to be carried out in association with your investigation. It is much less likely to capture historical contamination caused by past activities unconnected with your engagement. ^where the duty applies, who must notify whom depends on how the work is engaged. A person carrying out the primary activity "during the person's employment or engagement by, or as the agent of, someone else" must notify that other person (the "employer") within 24 hours or give the administering authority written notice if the employer cannot be contacted (section 320B).
An employer that has been notified must then give the administering authority written notice within 24 hours and notify affected owners and occupiers (section 320D). For a consulting firm, this can be read two ways. If the firm's own field employee reports the event, the firm is arguably the notified employer and must itself notify DETSI under section 320D. But because the firm is itself "engaged by" the client, it may instead be treated as a person whose duty is only to notify the client, leaving the section 320D obligation to notify DETSI with the client. The Act does not say which reading applies, and we have not identified a decision on the point.
The prudent course is to assume the firm may have to notify DETSI directly within 24 hours and, at a minimum, to notify the client in writing within that time. Each duty is subject to a "reasonable excuse" exception, but a client's instruction to stay silent should not be assumed to qualify. The duties do not apply to an event that is authorised under, among other things, a transitional environmental program, an environmental enforcement order or an environmental authority (section 320A(4)). A containment failure that breaches a TEP will not be authorised by it, but the exclusion is another reason for a TEP to define precisely what it does and does not permit.
Because the test is objective, a person cannot rely on ignorance where a competent person in their position ought reasonably to have identified the threat. DETSI's Guideline – The duty to notify of environmental harm (ESR/2016/2271) explains how the department applies the duty. There is also a civil side. If your team walks past obvious indicators and says nothing, the client or a later purchaser may frame the omission as a failure to identify contamination, a common basis for contaminated land assessment negligence claims.
Separately, historical contamination is dealt with mainly by section 320A(2). That subsection applies to the owner or occupier of land, an auditor performing a function mentioned in section 568(b), and a rehabilitation auditor, where they become aware, or ought reasonably to have become aware, of a hazardous contaminant on the land that is causing, or is reasonably likely to cause, serious or material environmental harm, or of a notifiable activity carried out on the land. Unless your firm is acting as an auditor, the person most likely to hold that duty is the client, as owner or occupier, and notification can lead to the site being recorded on the Environmental Management Register.
How the Expanded Duty Overrides Contractual Client Confidentiality
Warning: A confidentiality clause cannot require your firm to break the law. Where the notification duty applies to your firm, it overrides private contractual confidentiality provisions, so a consulting firm cannot legally agree to conceal a reportable event. If a client relies on the engagement letter to demand silence and your firm goes along with it, the firm may face its own, independent liability under the EP Act. Where the duty sits with the client instead (for example, as owner or occupier under section 320A(2) of the EP Act), record in writing that you have drawn the client's attention to it. If a client is pressing you to bury adverse findings, promptly seek independent commercial law advice so you can meet your reporting obligations while managing any good faith obligations you owe the client.
Documenting Knowledge Boundaries During TEP Preparation
Expert insight: When DETSI alleges that a consultant ought reasonably to have become aware of contamination, the argument usually turns on what the field team saw, not what the scope said. The scope of services limits what you were paid to investigate. It does not limit what a competent professional standing on the site would be expected to notice.
A common mistake is leaning on generic report limitations, such as "subsurface conditions may vary between sampling locations", to cover specific access problems. That kind of boilerplate may carry little weight against a photograph of stained soil or a stockpile nobody tested. Limitations need to be specific to the site and traceable back to the field record.
These documentation steps tend to hold up under scrutiny:
Mark restricted areas on the site plan on the day. Record who restricted access, the reason they gave, and the time.
Photograph the edge of what you could access, not just the sampling points. Save the images to the project file straight away, not a staff member's personal phone.
Confirm the restriction by email to the client the same day. That way the constraint sits in a document the client received and did not dispute.
Carry each restriction into the report's limitations section by location. Don't fold it into a general caveat.
Field notes cut both ways. A note reading "strong hydrocarbon odour near former tank pit — outside scope" shows awareness. If nothing follows it, that note may become the centrepiece of a failure-to-notify allegation. Every out-of-scope observation should go to a senior practitioner the same day. That person makes and records a decision on whether the notification threshold is met, bearing in mind the 24-hour timeframes in sections 320B and 320D of the EP Act.
Don't amend field notes after the event. Late additions can usually be detected through file metadata, and one altered record can damage the credibility of every other document on the file.
If a client deliberately blocks access to avoid a finding, whether that conduct amounts to a repudiation of a contract is a separate commercial question. The more pressing point is to document both the obstruction and your response to it. Both may bear directly on what your firm ought reasonably to have become aware of.
The Interaction Between Environmental Enforcement Orders and Pass-Through Claims
Pass-through claims are the second front. When DETSI issues an Environmental Enforcement Order (EEO), your client must comply with it, often at significant and unbudgeted cost. Non-compliance is a separate offence: wilfully contravening an order issued on a prescribed ground, which includes grounds involving serious or material environmental harm, carries a maximum penalty of 6,250 penalty units or five years' imprisonment (section 369A(1) of the EP Act). The client's natural next step is to ask who else should pay, and the firm that wrote the compliance advice is an obvious candidate. The new polluter-pays duties make this more likely, because they increase the costs a client may try to recover from you, and ultimately from your professional indemnity insurance.
Why Consolidated EEOs Are Likely to Accelerate Professional Negligence Allegations
When a client faces severe financial liability under an Environmental Enforcement Order, they may attempt to offset remediation costs by pursuing a professional negligence claim against the environmental consultant whose advice they relied upon.
The 2024 amendments streamlined the regulatory toolkit by replacing environmental protection orders, direction notices and clean-up notices with a single Environmental Enforcement Order (EEO). Because an EEO can require prompt and costly compliance action, clients facing large, unbudgeted costs often look to recover them through a different route: civil litigation. If the client can establish that the consultant’s original site suitability statement or compliance strategy was defective, it is likely to bring a professional negligence claim against the environmental consultant, alleging that it would not have incurred the EEO costs but for the consultant's deficient advice. That claim has to be framed in contract or negligence. Section 24(3) of the EP Act provides that a breach of the general environmental duty or the duty to restore the environment "does not, of itself, give rise to a civil right or remedy", so a client cannot sue simply because a statutory duty was breached. Instead, the EEO and restoration costs are claimed as loss flowing from the consultant's alleged breach of its contractual or common law duty of care.
The Section 319C(2) Statutory Duty to Restore the Environment
The 2024 amendments also introduce a positive duty that can increase what is at stake in a claim against an environmental consultant, indirectly, through the costs the client must bear. Section 319C(2) of the EP Act establishes the duty to restore the environment: "The person must, as soon as reasonably practicable after the incident happens, take measures, as far as reasonably practicable, to rehabilitate or restore the environment to its condition before the harm".
This provision, inserted by the Environmental Protection (Powers and Penalties) and Other Legislation Amendment Act 2024 (Qld), gives statutory effect to the "polluter pays" principle, which the same Act wrote into the EP Act's administering principles in section 6A(1)(a)(iv). Under section 319C(1) of the EP Act, the duty applies to a person who causes or permits an incident involving contamination of the environment that results in unlawful environmental harm.
The duty is qualified: restoration measures must be taken as soon as reasonably practicable, and only as far as reasonably practicable. In deciding what measures are required, regard must be had to matters such as the nature and extent of the harm, the current state of technical knowledge for remedial measures and the financial implications of different measures (section 319C(4)). Contravening the duty is itself an offence where the contravention relates to serious or material environmental harm, with the same maximum penalties as the section 319(2) offence (section 319C(3)). The cost of meeting the duty falls on the person who owes it, and it may be substantial (see the Information sheet – Duty to Restore the Environment – Overview (ESR/2024/6836)). For the consulting firm, this means a pass-through claim from the client is likely to seek to recover those restoration costs as well, significantly increasing the financial stakes of a negligence dispute.
The Limitations of Indemnity Clauses Against Statutory Environmental Liability
Warning: An indemnity or limitation of liability clause in an environmental consultant's engagement terms is intended to cap the firm's financial exposure to the client. It cannot, however, displace the section 319(2) offence, because a contract cannot exclude or transfer criminal liability under a statute. If DETSI considers that a consultant's deficient advice or systems contributed to serious or material environmental harm, the firm may face prosecution regardless of any civil indemnities provided by the client. Relying on a commercial indemnity to deflect regulatory attention is often a fatal miscalculation, and firms facing joint civil and regulatory action should engage a Queensland litigation lawyer early to manage these concurrent risks.
Structuring Consultant Defences Against Regulatory Escalation
If DETSI's investigation does turn to your firm, two statutory protections matter most: a charging bar introduced by the 2024 amendments, and a long-standing defence based on compliance with the general environmental duty. Neither will help unless your file supports it.
Leveraging Section 319B(2) Protections Against Alternative Charging
Section 319B(2) of the EP Act prevents a person who is charged with an unlawful environmental harm (or related) offence, and who intends to rely on the section 493A(3) defence, from also being charged with the section 319(2) offence as an alternative for the same, or substantially the same, conduct.
For consultants facing an environmental prosecution in Queensland, section 319B(2) is an important but conditional safeguard. It applies only where the three conditions in section 319B(1) are met: the conduct is a "relevant act" under section 493A(1) (such as an act causing serious or material environmental harm), the person is charged with an offence for that conduct, and the person intends to rely on the section 493A(3) defence. In that situation, "the person may not be charged with an alternative offence against section 319(2) in relation to the same, or substantially the same, conduct as the relevant conduct".
The practical effect is that a defendant who answers an unlawful harm charge by proving compliance with the general environmental duty cannot then be met with a section 319(2) charge in the alternative for the same conduct. Section 319B(3) adds a related protection: information obtained from the person in relation to the section 493A(3) defence in that proceeding cannot be used against them in a section 319(2) prosecution for the same, or substantially the same, conduct. Neither subsection stops DETSI from charging the section 319(2) offence in the first place. Where they apply, however, the regulator needs to decide at the outset which offence best fits what happened, and a defendant can run the section 493A(3) defence without that evidence being turned against it in a later section 319(2) prosecution.
Using the Section 493A(3) Compliance Defence in Advisory Roles
While the 2024 amendments created new offences, the long-standing section 493A(3) defence under the EP Act remains important for environmental consultants. It is a defence to a charge of unlawfully doing a "relevant act" under section 493A(1), which includes an act causing serious or material environmental harm or an environmental nuisance. The defendant must prove both that the act was done while carrying out an activity that is lawful apart from the EP Act, and that the defendant complied with the general environmental duty.
The defence answers unlawful harm charges, not the section 319(2) offence itself. If DETSI instead charges under section 319(2), the prosecution must prove that the duty was contravened, and the firm's position rests on showing that its advisory work met the standard of "reasonably practicable measures" or that the section 319(3) exception applies. Either way, the evidence the firm needs is the same. Firms advising on activities involving a relevant industrial chemical should also check section 319A, which the note to section 493A(3) flags as relevant to the defence. A robust internal QA/QC process, peer-reviewed methodology, and clear documentation of regulatory engagement can demonstrate that the firm fulfilled its duty, shifting the focus back onto the client's failure to properly execute the approved advice.
Defensive Drafting Tactics for Transitional Environmental Programs
A carefully drafted TEP and environmental consulting agreement become key evidence separating your advice from the client's execution. The drafting also matters for a second reason. Under section 319(3) of the EP Act, a person does not commit the section 319(2) offence where the contravention arises only because of an act that is authorised by a transitional environmental program (one of the instruments listed in section 493A(2)), and the program provides for reasonably practicable measures to be taken in relation to that act. Compliance with an applicable code of practice has the same effect. A TEP that specifies those measures precisely, and names who must take them, gives conduct carried out in accordance with it the best chance of falling within that exception. The exception will not assist where the harm results from a departure from the program. To insulate the firm from operational failures, adopt these protective drafting measures:
Explicitly allocate operational control: The TEP must clearly state that the client retains sole authority and responsibility for implementing the infrastructure changes and daily site management required by the program.
Define strict scope limitations: Document exactly which physical areas and processes the firm assessed, and expressly exclude components outside that scope from any compliance certification.
Document client constraints: Record any instances where the client refused recommended sampling, restricted site access, or ignored initial compliance warnings prior to the TEP submission.
Establish communication protocols for non-compliance: Require the client to notify you in writing, immediately, if it departs from the TEP methodology. That lets the firm issue a written non-conformance notice, recommend corrective action or withdraw its support before harm occurs. If the client disputes the notice, the dispute resolution clause in your agreement governs what happens next, ideally a staged process that ends in alternative dispute resolution in Queensland.
Conclusion
The scenario of a client's facility failing and breaching a newly drafted TEP is no longer just a commercial crisis—under the 2024 amendments to the Environmental Protection Act 1994 (Qld), it is a potential criminal exposure. We have seen how section 319(2) turns the general environmental duty from a standard used mainly in defence into an offence DETSI can prosecute directly. We have also examined how the objective "ought reasonably to have become aware" standard applied by section 320A can require consultants to prioritise statutory notification over client demands for confidentiality, and how the "polluter pays" duty to restore can rapidly escalate the financial stakes of a pass-through professional negligence claim.
Standard indemnity clauses can't carry that weight on their own. When a client’s operational failure causes serious environmental harm, the operator will usually be the regulator's first focus. But if the harm can be traced to a measure your firm designed, the regulator may examine the compliance advice behind it just as closely.
You can't control how your client runs its site, but you can control what your file shows. This week, pull out your current TEP template and standard environmental consulting agreement and check four things: whether every action names a responsible party, whether operational control sits expressly with the client, whether confidentiality gives way to statutory reporting duties, and whether your statutory notification and PI notification processes could meet a 24-hour deadline on a Sunday.
Merlo Law advises Queensland environmental consultants on TEP drafting, consulting agreements, regulatory investigations and pass-through claims. If you'd like your TEP templates and engagement terms reviewed, or you've just learned that a site you advised on has had an incident, contact John Merlo to discuss your next steps.
FAQs
What is the new general environmental duty offence in Queensland?
Under section 319(2) of the Environmental Protection Act 1994 (Qld), it is now a direct criminal offence to contravene the general environmental duty if that breach causes, or is likely to cause, serious or material environmental harm. This 2024 amendment means the duty is no longer just a guiding principle: its breach can now be prosecuted as an offence carrying substantial maximum penalties. The duty is qualified by what is reasonably practicable, so it is not a strict liability offence. Whether a consultant's advice can itself amount to carrying out an activity that breaches the duty has not yet been tested, but consultants should expect regulators to examine advice that underpins a failed control measure.
When is an environmental consultant required to notify DETSI of contamination?
Section 320A of the EP Act applies the notification duties where a person carrying out an activity "becomes aware, or ought reasonably to have become aware" of an event causing or threatening serious or material environmental harm because of an act or omission in carrying out that activity or an associated activity. The standard is objective, so a consultant can be liable for failing to report an event it ought reasonably to have recognised, even in an area excluded from its scope. The duty is most clearly engaged by events arising from the consultant's own site work. Historical contamination is dealt with mainly by section 320A(2), which applies to owners, occupiers and auditors rather than to consultants generally.
Can a client confidentiality agreement prevent me from reporting environmental harm?
No. Once the duty is triggered, the statutory obligation to report environmental harm under Chapter 7, Part 1, Division 2 of the EP Act overrides private contractual confidentiality clauses. If a client attempts to enforce silence regarding a reportable event, capitulating may expose your firm to prosecution if the firm itself holds a duty to notify the regulator. In some engagements, the firm's duty may instead be to notify the client within 24 hours, and the client's own demand for silence does not relieve the client of its duty to notify DETSI.
How does an Environmental Enforcement Order impact a consulting firm?
An Environmental Enforcement Order (EEO) requires the recipient, often the operator, to take the action it states, which may include prompt and costly remediation. Contravening an EEO without a reasonable excuse is itself an offence (section 369A). Because these orders can create significant financial pressure, clients may attempt to pass those costs on to their environmental consultants via professional negligence claims, alleging the consultant's prior site advice or compliance strategy was defective.
What is the statutory duty to restore the environment?
Section 319C(2) imposes a positive duty on a person who causes or permits an incident involving contamination of the environment that results in unlawful environmental harm to take reasonably practicable measures to rehabilitate or restore the environment to its pre-incident condition. This embeds the "polluter pays" principle into law and can significantly increase the potential damages a client might seek to recover from a consultant in a civil dispute.
Can I rely on my limitation of liability clause if DETSI investigates my firm?
While a limitation of liability clause is designed to cap your financial exposure in a civil dispute with a client, it has no effect on a prosecution brought by the regulator. Contractual indemnities cannot extinguish statutory criminal liability under the EP Act. If DETSI determines your firm breached the general environmental duty, you may face prosecution regardless of any commercial protections in your engagement letter.
This guide is for informational purposes only and does not constitute legal advice. For advice tailored to your specific circumstances, please contact Merlo Law
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