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Lawyer Complaints Procedure

eSolicitors

COMPLAINTS PROCEDURE: HOW TO COMPLAIN ABOUT A CLIENT

For Solicitors, Attorneys, and Qualified Legal Professionals in the United Kingdom, the United States, and International Jurisdictions

This Complaints Procedure forms part of the standard operating procedures of the eSolicitors platform and should be read together with the applicable Lawyer Terms and Conditions (the UK Solicitors Terms, the US Attorney Terms, or the International Lawyer Terms, as applicable). Capitalised terms not defined in this procedure have the meanings given in the applicable Lawyer Terms.

eSolicitors is a technology platform. It is not a law firm. It is not regulated by the SRA, any US state bar, or any other legal regulatory authority in any jurisdiction. It does not adjudicate legal disputes, assess the quality of legal work, or exercise any regulatory function. The complaints process is an operational procedure only - it does not replace the SRA, the BSB, any US state bar disciplinary authority, any international Regulatory Authority, the Legal Ombudsman, the police, the FBI, or the courts.

CONTENTS

Part A Scope and Eligibility (Clauses 1-5)

Part B Complaints About a Client's Conduct (Clauses 6-12)

Part C Complaints About the eSolicitors Platform (Clauses 13-18)

Part D Important: Suspected Money Laundering or Financial Crime (Clauses 19-23)

Part E How to Make a Complaint About a Client (Clauses 24-30)

Part F Your Other Remedies (Clauses 31-35)

Part G Your Regulatory Obligations When Making a Complaint (Clauses 36-42)

Part H Ceasing to Act, Record Keeping, and General Provisions (Clauses 43-52)

Part I Quick Reference Table

PART A - SCOPE AND ELIGIBILITY

1. Scope

1.1 This Complaints Procedure applies to all solicitors, attorneys, and qualified legal professionals ("You" or "Your") registered on the eSolicitors platform ("the Platform"), regardless of jurisdiction or practice model.

1.2 This procedure distinguishes between two categories of complaint: (a) complaints about a Client's conduct in connection with the Platform (Part B); and (b) complaints about the Platform's own technology and marketplace services (Part C). The complaint routes, timescales, and escalation options differ for each category.

2. United Kingdom Practitioners

2.1 This procedure applies to the following UK practitioners: (a) solicitors employed by an SRA-authorised law firm; (b) sole practitioners (recognised sole practice); (c) freelance solicitors authorised by the SRA to provide services directly to the public; (d) fractional or consultant solicitors providing part-time or portfolio general counsel services; (e) barristers registered with the BSB accepting instructions through the Platform.

2.2 If You are employed by a law firm, You should discuss any complaint with Your firm's COLP or complaints partner before submitting it through the Platform, as the complaint may need to be submitted in the firm's name.

3. United States Practitioners

3.1 This procedure applies to the following US practitioners: (a) licensed attorneys admitted to the bar in one or more US states; (b) solo practitioners operating their own law practice; (c) of counsel attorneys; (d) contract attorneys providing services on a project or temporary basis; (e) foreign legal consultants authorised under a US state's foreign legal consultant rules.

3.2 If You are employed by a law firm, You should discuss any complaint with Your firm's managing partner or general counsel before submitting it through the Platform.

4. International Practitioners

4.1 This procedure applies to all qualified legal professionals duly admitted, licensed, registered, or otherwise authorised to practise law in one or more jurisdictions outside the United Kingdom and the United States, including (without limitation) solicitors, barristers, advocates, avocats, Rechtsanwälte, abogados, advogados, attorneys, notaries, and all other legal professionals howsoever designated, as well as dual qualified lawyers.

4.2 You must comply with the Applicable Regulatory Requirements of every jurisdiction in which You are qualified and in which You deliver legal services. Your obligations under Your local rules of professional conduct continue to apply in full throughout the complaints process.

4.3 If You practise through a law firm, You should discuss any complaint with the appropriate person within Your firm before submitting it through the Platform.

5. Reserved

PART B - COMPLAINTS ABOUT A CLIENT'S CONDUCT

6. What You Can Complain About: Client Conduct

6.1 Part B applies where Your complaint is about a Client's conduct in connection with the Platform. The Client may be an individual, sole trader, limited company, LLC, LLP, partnership, law firm instructing You on behalf of their own client, professional body, government entity, or any other entity registered on the Platform.

6.2 Complaints about a Client's conduct include (without limitation) complaints about: (a) abusive, threatening, or harassing behaviour towards You or Your staff, whether in calls, messages, emails, or through the Platform's communication tools; (b) fraud or misrepresentation - the Client has provided false identity documents, misrepresented their identity, given a false name, or misrepresented the nature of their matter; (c) non-payment - the Client has failed to pay fees properly due, has disputed payment without reasonable grounds, or has attempted to circumvent the Platform's payment process; (d) obstruction of Your regulatory obligations - the Client has refused to provide identification for CDD or KYC purposes, has refused to cooperate with Your AML checks, or has obstructed Your ability to comply with the applicable rules of professional conduct, anti-money laundering legislation, or sanctions requirements in Your jurisdiction; (e) suspected money laundering or sanctions evasion - You have concerns that the Client's instructions or the source of funds may involve criminal activity (see Part D before making this type of complaint); (f) vexatious or retaliatory complaints - the Client has made complaints against You that are without merit and appear designed to pressure You into reducing fees, avoiding payment, or as intimidation; (g) discriminatory behaviour - the Client has discriminated against You on the basis of a protected characteristic under the Equality Act 2010 (UK), applicable federal or state anti-discrimination laws (US), or applicable anti-discrimination legislation in Your jurisdiction (international); (h) breach of the Client's Platform terms - the Client has breached the Client Terms and Conditions in a way that affects You or Your ability to provide services.

7. What Is Not a Complaint About a Client

7.1 The following are not complaints about a Client and should be directed to the Platform under Part C: (a) dissatisfaction with the Platform's matching or recommendation algorithm; (b) issues with the Platform's website, mobile application, or technology infrastructure; (c) the accuracy of the AI Scope Script generated by the Platform's automated systems; (d) the Platform's own fees charged to You (Platform Usage Fee, Technology and AI Fee, Seller Protection Fee, Compliance and Audit Fee); (e) payment processing errors by Stripe or the Platform's payment systems (as distinct from Client non-payment); (f) Your Platform account, subscription tier, profile display, or login issues; (g) the availability, accuracy, or content of Platform templates, document workspace features, or scheduling tools; (h) data protection or privacy concerns relating to data held or processed by the Platform; (i) the conduct of the Platform's own staff.

8. Held Funds During a Client Conduct Complaint

8.1 Where You raise a complaint about a Client's conduct and Held Funds for a milestone have not yet been released, the Platform may, at its reasonable discretion, suspend the release of Held Funds pending investigation. Where the complaint relates to non-payment or the Client has raised a counter-dispute, the Platform will not release Held Funds until the matter is resolved by agreement, escalation, or expiry of the relevant period.

8.2 In exceptional circumstances, the Platform reserves the right to instruct Stripe to release Held Funds at its reasonable discretion. The Platform will notify both parties before taking such action.

9. Your Right to Object

9.1 If a Client raises a complaint about Your services through the Platform and the outcome is adverse to You, You have the right to object to the outcome within fourteen (14) days. Your objection must be submitted in writing through the Platform and must state the grounds on which You disagree with the outcome. The Platform will review the objection and communicate its decision in writing.

9.2 The Platform's complaint and dispute mechanism does not replace or override: (a) Your own internal complaints procedure; (b) the Client's right to file a regulatory complaint; (c) the Client's right to bring court proceedings; or (d) any applicable fee dispute mechanism.

10. Complaints About Client Conduct During the Confirmation Period

10.1 If a Client raises a dispute during the Confirmation Period that You believe is vexatious, retaliatory, or made in bad faith (for example, to delay payment or to pressure You into reducing fees), You may raise a counter-complaint through the Platform under this procedure. The Platform will consider both the Client's dispute and Your counter-complaint together.

11-12. Reserved

PART C - COMPLAINTS ABOUT THE eSolicitors PLATFORM

13. What You Can Complain About: The Platform

13.1 Part C applies where Your complaint is about the Platform's own technology and marketplace services, not about a Client's conduct.

13.2 Complaints about the Platform include (without limitation) complaints about: (a) the matching or recommendation algorithm (how Clients are matched to You, the accuracy of match criteria, the volume or quality of introductions); (b) the Platform's website, mobile application, or technology infrastructure (downtime, bugs, errors, accessibility); (c) the AI Scope Script (accuracy of the automated summary generated from the Scoping Call recording); (d) the Scoping Call technology (video or audio quality, recording failures, scheduling errors); (e) the Platform's own fees charged to You (Platform Usage Fee, Technology and AI Fee, Seller Protection Fee, Compliance and Audit Fee); (f) payment processing by the Platform or Stripe (delays in releasing Held Funds, incorrect charges, errors in fee deductions); (g) Your Platform account (registration, login, profile display, subscription tier, account suspension or termination, Credibility Badge accuracy); (h) the Confirmation Period mechanics (duration, notifications, the payment holding and release process); (i) Platform templates, the document workspace, file-sharing features, or the scheduling system; (j) the Platform's handling of a complaint or dispute between You and a Client (timeliness, fairness, communication); (k) the compliance audit process (timing, scope, the Platform's conduct of audits under Part R of the Lawyer Terms); (l) data protection or privacy concerns relating to Your Solicitor Personal Data held or processed by the Platform; (m) marketing communications, cookie preferences, or consent management; (n) the conduct, behaviour, or communication of the Platform's own staff or representatives.

14. How to Complain About the Platform

14.1 Contact the Platform directly. You may complain in writing, by email, or through the Platform's Help section. Contact: eSolicitors (Esol Corporation Limited), 34-35 Hatton Garden, Unit 3a, Suite 6973, London, EC1N 8DX. Company number: 16927988. Website: www.esolicitors.com.

14.2 The Platform will acknowledge Your complaint within five (5) Business Days and aim to resolve it within twenty (20) Business Days.

15. Possible Outcomes of a Platform Complaint

15.1 If Your complaint about the Platform is upheld or partially upheld, the Platform may: (a) apologise and explain what went wrong; (b) take corrective action (fix a technical issue, correct an account error, update information); (c) refund Platform Fees where appropriate; (d) escalate the matter internally to the Platform Chief Legal Officer (graham.clo@esolicitors.com); (e) change a process, policy, or system to prevent recurrence.

16. If You Are Not Satisfied with the Platform's Response

16.1 If You are not satisfied with the Platform's response, You may: (a) request escalation to the Platform Chief Legal Officer (graham.clo@esolicitors.com); (b) bring a claim in the county court (UK), state court (US), or the courts of the relevant jurisdiction (international); (c) report the Platform to the applicable consumer protection authority or data protection supervisory authority where relevant.

17-18. Reserved

PART D - IMPORTANT: SUSPECTED MONEY LAUNDERING OR FINANCIAL CRIME

19. United Kingdom

19.1 If Your complaint relates to suspected money laundering, terrorist financing, or sanctions evasion, You must: (a) file a Suspicious Activity Report (SAR) with the National Crime Agency (NCA) before or at the same time as complaining to the Platform - this is Your personal legal obligation under the Proceeds of Crime Act 2002 (POCA); (b) not tip off the Client (or anyone who might tell the Client) that You have filed a SAR or that an investigation is or may be conducted - tipping off is a criminal offence under section 333A of POCA 2002; and (c) not include SAR details in Your Platform complaint.

19.2 If in doubt, contact the SRA's ethics helpline (0370 606 2577) or seek independent legal advice. Do not delay filing a SAR while You seek guidance.

20. United States

20.1 US attorneys are not currently subject to mandatory SAR filing requirements under the Bank Secrecy Act. However, if You become aware that a client is using Your services to further criminal activity, You have obligations under Rule 1.6 and Rule 1.16 to withdraw. If suspicious transactions involve Your IOLTA or client trust account, cooperate with Your bank's compliance team. OFAC sanctions: You are prohibited from providing services to individuals or entities on the OFAC SDN list.

21. International

21.1 Your AML and reporting obligations are governed by the legislation and professional conduct rules of Your Home Jurisdiction and the Delivery Jurisdiction. You must comply with all applicable suspicious transaction reporting obligations and tipping off prohibitions. Do not include details of any regulatory report or filing in Your Platform complaint.

22. Platform's Position

22.1 The Platform will not tip off either party. If the Platform identifies that a complaint may involve money laundering or financial crime, it will preserve records, may refer the matter to the relevant authorities (NCA, FinCEN, FBI, or equivalent), and will not disclose any information where doing so could constitute tipping off or obstruct an investigation.

23. Reserved

PART E - HOW TO MAKE A COMPLAINT ABOUT A CLIENT

24. Step 1: Try to Resolve It Directly First (Where Safe)

24.1 If the issue is one that can safely be raised with the Client (for example, non-payment, late cooperation with identity checks, or a misunderstanding about scope), consider raising it directly through the Platform's messaging system. Do not attempt direct resolution if You suspect fraud, money laundering, or if the Client is threatening or abusive.

25. Step 2: Submit a Formal Complaint Through the Platform

25.1 If the issue cannot be resolved directly, or if it involves conduct that is serious enough to require Platform intervention, submit a formal complaint through the Platform. You can do this by logging into Your Platform dashboard and selecting the complaints channel for the relevant matter.

25.2 Your complaint must include: (a) Your name, regulatory registration number (SRA number, state bar number, or equivalent), and Platform account reference; (b) the Client's name and Platform reference; (c) a clear description of the conduct You are complaining about; (d) the dates and circumstances; (e) any supporting evidence (screenshots, emails, documents - but do not include privileged or confidential client information unless disclosure is required or permitted by law); (f) the outcome You are seeking.

26. Step 3: The Platform Investigates

26.1 The Platform will acknowledge Your complaint within three (3) working days. An investigator with no prior involvement in the matter will be assigned. The Client will be notified and given a fair opportunity to respond (except where notification could prejudice an investigation or constitute tipping off). The Platform investigates on the balance of probabilities and will communicate the outcome in writing with reasons.

26.2 Target timescales: urgent matters (safety, fraud) seven (7) working days; non-payment fifteen (15) working days; other matters twenty (20) working days.

27. Step 4: Possible Outcomes

27.1 If Your complaint is upheld or partially upheld, the Platform may: (a) issue a written warning to the Client; (b) temporarily suspend the Client's Platform account; (c) permanently remove the Client from the Platform; (d) refer the matter to the police or relevant law enforcement authority; (e) refer the matter to the NCA (UK), FinCEN/FBI (US), or the relevant authority in the applicable jurisdiction (international) where financial crime is suspected; (f) refer the matter to OFSI (UK), OFAC (US), or the relevant sanctions authority where sanctions breaches are suspected.

27.2 Both You and the Client have the right to appeal the outcome within fourteen (14) days.

28. Step 5: If the Platform Cannot Resolve It

28.1 The Platform cannot: award compensation; determine whether a Client owes You money (that is a matter for the courts); investigate the merits of a legal dispute between You and the Client; or exercise any regulatory function.

29. Complaints About a Client That Is a Law Firm

29.1 UK: The law firm Client is itself regulated by the SRA (or BSB). You may report to the SRA in addition to complaining to the Platform. Under paragraph 7.7 of the SRA Code, this may be a duty.

29.2 US: The law firm Client's attorneys are subject to the Rules of Professional Conduct of their licensing state(s). Under Model Rule 8.3, reporting may be mandatory.

29.3 International: If the law firm Client is regulated by a Regulatory Authority, You may report to that authority.

29.4 All jurisdictions: Distinguish between the Client and the underlying client. If Your concern is about the underlying client (e.g. money laundering), Your obligations run to the relevant reporting authority (NCA, FinCEN/FBI, or equivalent), not to the Platform.

30. Reserved

PART F - YOUR OTHER REMEDIES

31.1 Complaining to the Platform does not prevent You from pursuing any other remedy.

32. United Kingdom

32.1 Your other remedies include: (a) report to the police if the Client's conduct is criminal (fraud, threats, harassment, identity theft) or to Report Fraud (0300 123 2040, www.reportfraud.police.uk); (b) pursue a civil claim (county court for claims up to £100,000, High Court for larger claims, small claims track for claims up to £10,000); (c) file a SAR with the NCA if You suspect money laundering, terrorist financing, or sanctions evasion; (d) report to OFSI if You suspect a breach of UK financial sanctions; (e) notify Your PII insurer if the Client's conduct has given rise to a potential claim against You; (f) report to Your COLP if You work for a law firm.

33. United States

33.1 Your other remedies include: (a) report to law enforcement (local police, FBI, or IC3 at www.ic3.gov); (b) pursue a civil claim (state court or federal court); (c) report to the state bar if the Client is also a licensed attorney; (d) report to OFAC if You suspect sanctions violations; (e) report to FinCEN if suspicious activity involves Your client trust account; (f) notify Your malpractice insurer; (g) report to Your firm's managing partner or general counsel.

34. International

34.1 Your other remedies include: (a) report to the relevant law enforcement authority; (b) pursue a civil claim in the courts of the relevant jurisdiction; (c) report to the Regulatory Authority if the Client is also a qualified legal professional; (d) file a suspicious transaction report in accordance with the AML legislation of Your jurisdiction; (e) report sanctions breaches to the relevant sanctions authority; (f) notify Your PII insurer; (g) report to Your firm's managing partner, compliance officer, or equivalent.

35. Reserved

PART G - YOUR REGULATORY OBLIGATIONS WHEN MAKING A COMPLAINT

36. General

36.1 Making a complaint to the Platform does not suspend or reduce Your professional obligations. Your applicable rules of conduct continue to apply in full throughout the complaints process.

37. United Kingdom - SRA Code of Conduct

37.1 Even while You are complaining about a Client's conduct, that Client remains Your client (unless and until the retainer is properly terminated). You continue to owe duties of competence, diligence, and confidentiality under the SRA Code of Conduct.

37.2 Limitation periods and court deadlines do not stop. You must continue to act competently (paragraph 3.2), keep the Client's affairs confidential (paragraph 6.3), and not mislead the Platform, the Client, or any third party (paragraph 1.4).

37.3 Self-reporting: under paragraph 7.11, You must promptly notify the SRA of facts that should be brought to their attention. Duty to report serious misconduct: under paragraph 7.7, You must report if You have reason to believe a regulated person has committed a serious breach.

38. United States - Rules of Professional Conduct

38.1 Your duties to the Client continue throughout the complaint process. You must continue to provide competent representation (Model Rule 1.1) with reasonable diligence (Rule 1.3). You must not reveal confidential information (Rule 1.6) except where permitted. Dishonesty in connection with the complaint is professional misconduct (Rule 8.4).

38.2 If the Client is a licensed attorney whose conduct raises a substantial question of honesty, trustworthiness, or fitness, You must report to the appropriate state bar (Rule 8.3). You must continue to safeguard client funds (Rule 1.15).

39. International - Applicable Regulatory Requirements

39.1 Your duties to the Client continue under the rules of professional conduct of Your Home Jurisdiction and any Delivery Jurisdiction. You must continue to act competently, diligently, and in accordance with all applicable regulatory requirements. Limitation periods and court deadlines in the Client's matter are not affected.

39.2 You must comply with all confidentiality obligations, reporting duties, and ethical requirements. If Your jurisdiction imposes a duty to report serious misconduct by another legal professional, that duty applies regardless of Your Platform complaint.

40-42. Reserved

Scotland: Regulatory Obligations

Scottish solicitors must comply with the Law Society of Scotland Practice Rules and maintain registration with the Law Society of Scotland. Advocates must comply with the Faculty of Advocates Guide to Professional Conduct. All Scottish practitioners must cooperate with the SLCC complaints process. The Regulation of Legal Services (Scotland) Act 2025 may introduce further requirements.

Northern Ireland: Regulatory Obligations

Northern Ireland solicitors must comply with the Solicitors (Northern Ireland) Order 1976 and associated regulations, and maintain registration with the Law Society of Northern Ireland. Barristers must comply with the Code of Conduct of the Bar of Northern Ireland. All NI solicitors must have an in-house complaints procedure and cooperate with the Solicitor Complaints Committee and the Law Society of Northern Ireland.

PART H - CEASING TO ACT, RECORD KEEPING, AND GENERAL PROVISIONS

43. Ceasing to Act / Withdrawal from Representation

43.1 UK: Give reasonable notice, warn the Client of imminent deadlines, allow time to instruct another solicitor, return papers (subject to any lien), apply to come off the record if in court proceedings, notify the Platform, and keep a contemporaneous file note.

43.2 US: Under Model Rule 1.16, withdrawal is mandatory where continued representation would violate the Rules or other law. Give reasonable notice, allow time to obtain new counsel, surrender papers and property, refund unearned fees, and seek leave of court if in litigation. Notify the Platform.

43.3 International: Comply with the withdrawal requirements of Your jurisdiction, including giving reasonable notice, protecting the client's interests, returning papers and property, and complying with any court requirements. Notify the Platform.

44. Record Keeping

44.1 When a complaint arises about a Client, maintain: (a) a contemporaneous file note recording the Client's conduct, dates, and witnesses; (b) copies of all communications (Platform messages, emails, letters, telephone notes); (c) Your complaint to the Platform and all correspondence about it; (d) CDD/KYC records if the complaint relates to identity obstruction; (e) a record of Your decision-making (why You ceased acting, why You self-reported or did not, why You filed or did not file a suspicious transaction report).

44.2 Retain all complaint-related records for at least six (6) years from the conclusion of the matter or the resolution of the complaint, whichever is later (UK). In the US, follow Your state's record retention rules (typically 5-7 years). International lawyers should follow the retention requirements of their jurisdiction's Regulatory Authority.

45. Confidentiality and Privilege

45.1 When making a complaint, do not include information subject to legal professional privilege (UK), attorney-client privilege (US), or equivalent professional secrecy protections (international) unless disclosure is required or permitted by law.

46. Vexatious Complaints by Clients

46.1 The Platform takes vexatious complaints seriously and may decline to investigate, issue a warning to the Client, and record the matter on the Client's account. Your right to payment is not affected.

47. The Platform Cannot Give You Legal Advice

47.1 eSolicitors is a technology platform. For advice on Your position, consult an independent solicitor (UK), attorney (US), or lawyer in the relevant jurisdiction, or contact the SRA ethics helpline (UK: 0370 606 2577), Your state bar's ethics hotline (US), or the ethics guidance service of the relevant Regulatory Authority (international).

48. Data Protection Complaints

48.1 If Your complaint relates to the handling of Your Solicitor Personal Data by the Platform, You may complain under Part C and, if not satisfied, lodge a complaint with the relevant data protection supervisory authority (e.g. the ICO in the UK, or the applicable authority in Your jurisdiction).

49-52. Reserved

55. Contact

55.1 eSolicitors (Esol Corporation Limited), 34-35 Hatton Garden, Unit 3a, Suite 6973, London, EC1N 8DX. Company number: 16927988. Website: www.esolicitors.com.

PART I - QUICK REFERENCE TABLE


Concern Action UK contact US contact Int'l contact Complaint type

Abusive or threatening Client Platform complaint; if unsafe, police Platform, then police (999/101) Platform, then police (911) or FBI Platform, then local law enforcement Part B (Client)

Suspected fraud Platform complaint with evidence; report to police Report Fraud (0300 123 2040, www.reportfraud.police.uk) FBI IC3 (www.ic3.gov) Local law enforcement Part B (Client)

Non-payment Raise with Client; Platform complaint; court Client, Platform, county court Client, Platform, state court Client, Platform, court Part B (Client)

Client refusing CDD/KYC Decline instruction; report to Platform Platform Platform Platform Part B (Client)

Suspected money laundering See Part D; file SAR / report as required NCA FinCEN, state bar Jurisdiction's reporting authority Part D

Vexatious Client complaint Raise with Platform Platform Platform Platform Part B (Client)

Law firm Client breaching rules Decline; Platform complaint; consider regulatory report Platform, SRA Platform, state bar Platform, Regulatory Authority Part B (Client)

Platform matching/ algorithm Contact Platform directly eSolicitors eSolicitors eSolicitors Part C (Platform)

Platform fees/ account Contact Platform directly eSolicitors eSolicitors eSolicitors Part C (Platform)

AI Scope Script error Contact Platform directly eSolicitors eSolicitors eSolicitors Part C (Platform)

Platform data/ privacy Contact Platform, then supervisory authority eSolicitors, ICO eSolicitors eSolicitors, applicable DPA Part C (Platform)


This Complaints Procedure is provided for information purposes only and forms part of the standard operating procedures of the eSolicitors platform. eSolicitors (Esol Corporation Limited) is a technology platform. It is not a law firm, is not regulated by the SRA, any US state bar, the Law Society, the BSB, the FCA, or any other legal regulatory authority in any jurisdiction, and does not provide legal advice or exercise any regulatory function. If You are unsure about Your rights or obligations, seek independent legal advice.