Success Lane Development Ltd v. Fergurson Hong Kong Ltd t/a New World Millennium Hong Kong Hotel

Read the full judgment text of DCCJ 2191/2023 on BabelCite. This District Court judgment was delivered on 27 March 2024.

2. I shall not repeat the background and the parties’ respective cases already detailed by Deputy District Judge M Lam in §§2-28 of her Decision handed down on 25 September 2023 ( [2023] HKDC 1325 ) for discharging the ex parte injunction order (the “Ex Parte Order”) obtained by the plaintiff upon its second ex parte application made on 12 July 2023 (the “2 nd Ex Parte Application”). I do, however, think it necessary to set out certain procedural steps taken by the parties here insofar as they a

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Case No.DCCJ 2191/2023[2024] HKDC 509
Court
District Court
Date27 Mar 2024
Judge
Case Document
100%Judiciary

DCCJ 2191/2023

[2024] HKDC 509

IN THE DISTRICT COURT OF THE

HONG KONG SPECIAL ADMINISTRATIVE REGION

CIVIL ACTION NO. 2191 OF 2023

________________

BETWEEN

SUCCESS LANE DEVELOPMENT LIMITED Plaintiff
and
FERGURSON HONG KONG LIMITED trading as NEW WORLD MILLENNIUM HONG KONG HOTEL Defendant

————————

Before: Deputy District Judge Gary C C Lam in Chambers (Open to Public)
Date of Hearing: 27 March 2024
Date of Decision: 27 March 2024

___________________

DECISION

___________________

INTRODUCTION

1.Before me are:-

(1) The plaintiff’s summons filed on 16 November 2023 to re-amend the amended statement of claim per the draft re-amended statement of claim attached thereto (“P’s Amendment Summons”); and

(2) The defendant’s summons filed on 20 December 2023 for specific discovery and expert directions (“D’s Discovery and Expert Summons”).

BACKGROUND

2.I shall not repeat the background and the parties’ respective cases already detailed by Deputy District Judge M Lam in §§2-28 of her Decision handed down on 25 September 2023 ([2023] HKDC 1325) for discharging the ex parte injunction order (the “Ex Parte Order”) obtained by the plaintiff upon its second ex parte application made on 12 July 2023 (the “2nd Ex Parte Application”). I do, however, think it necessary to set out certain procedural steps taken by the parties here insofar as they are relevant to determination of the Summonses.

3.The Ex Parte Order was not a mere injunction order. It consisted of, among others, an order that the defendant be compelled to allow the plaintiff and its loss adjuster access to the Room for inspection and assessing damage of the Belongings for a period of 7 days, within 7 days from the issuance of the order: see §30(5) of the said Decision. Deputy District Judge M Lam discharged the whole Ex Parte Order “on the mere ground of there being material non-disclosure on the part of P”: see §33 of the said Decision, namely, the plaintiff failed to disclose in the 2nd Ex Parte Application that on 2 June 2023, the plaintiff had made a first ex parte application to obtain essentially an identical injunction order but failed: see §36 of the said Decision. The learned judge, for the sake of completeness, also examined other grounds for discharging the Ex Parte Order. The plaintiff’s application for leave to appeal against her Decision was refused by the learned judge on 1 March 2024, and I am given to understand that on 15 March 2024, the plaintiff lodged with the Court of Appeal an application for leave to appeal.

4.Then, on 22 September 2023, the plaintiff made the third ex parte application for, again, essentially an identical injunction order. The application was adjourned for an inter partes hearing on 29 September 2023 before His Honour Judge Harold Leong, who dismissed the application on the same date, on the ground that there was no urgency and in any event, the application itself was unmeritorious. In his Chinese Reasons for Decision handed down on 9 January 2024, he recounted certain facts which are relevant to my task of determining D’s Discovery and Expert Summons below:-

“18. 原告人於2023年9月13日回覆被告人的信件中提及,被告人建議為免有任何爭議,需要一個公證行的人員觀察整個程序。

19. …

20. 但是原告人答覆被告人的信件中就加了很多自己的條件,例如「你有個公證行,我亦都要有個公證行」以及「我個公證行嘅人就係做檢查嘅啫,你個公證行嘅人凈係睇嘅啫,唔可以係一個聯合嘅視察」, 原告人還要說明這個條件是不可協商的。原告人亦都加多了其他條件,例如要求被告人交出一份2023年5月18日原告人移離酒店房間的物品清單。

21. 被告人於2023年9月14日回覆原告人,對原告人的要求有爭議,被告人指出原告人不應該禁止專家做任何合理的檢查。被告人亦提出如果原告人要被告人的清單,原告人都必須有自己的清單,因為原告人一早提出自己有一個物品清單,相片及錄影片段,雙方可作交換。被告人提出如果雙方就以上的問題不能達共識,被告人就會向法庭提出要求指示。

22. … 被告人於2023年9月12日第二封信再次向原告人說明:如果原告人不遵守被告人提及的要求,被告人就不可移離物品。

23. 於第5段中,被告人說 ﹕「Our client remains open to the relocation in terms of described by our letter dated 11th September 2023. Without prejudice to its stand and right on seeking joint inspection, our client proposes to carry out the relocation upon joint inspection of the belongings in situ at the storage area such that your loss adjustor can monitor the relocation」。”

5.The plaintiff’s application for leave to appeal against his Decision was refused by His Honour Judge on 5 March 2024, and I am given to understand that on 19 March 2024, the plaintiff lodged with the Court of Appeal an application for leave to appeal.

6.Besides relevance to the determination of D’s Discovery and Expert Summons below, in the plaintiff’s various failed applications for injunction order, the parties filed substantial evidence in relation to the dispute between them. Thus, while, though the pleadings having been closed, no automatic discovery has been carried out and no case-management summons has been taken out, the parties’ evidence filed so far has been rather comprehensive and the parties should be able by now to know what the essential disputes between them are. It is not like a usual case where the parties have yet to know the other parties’ essential documentary evidence and essential witnesses’ evidence, upon which it is not unusual for parties to amend the pleadings.

P’S AMENDMENT SUMMONS

7.In respect of P’s Amendment Summons, the defendant sensibly does not object to certain parts of the proposed amendments to the amended statement of claim, namely, §§14d, 24-26, 28-37 and 68-71 of the draft re-amended statement of claim. Those parts are related to the substantive dispute between the parties. In my view, the plaintiff is entitled to make those amendments.

8.The defendant opposes the rest of the proposed amendments, namely, §§19-23, 27 and 38-67 of the draft re-amended statement of claim. Those proposed amendments are all averments about the history of and submissions made in plaintiff’s previous applications for injunctions and the related costs orders as well as plaintiff’s some attempted communications with one of the judges seized of the matter. The representative of the plaintiff, Ms Yung Mei Chun Jessie, submits that these averments provide the background. In my view, background they may be, they are not relevant to the substantive disputes between the parties. They should be disallowed.

9.In the circumstances, I grant leave for the plaintiff to re-amend the amended statement of claim per §§14d, 24-26, 28-37 and 68-71 of the draft re-amended statement of claim, and dismissed the plaintiff’s application for the rest of the proposed amendments.

10.Lastly, I note that the statement of claim and the amended statement of claim were not properly verified by a statement of truth. By virtue of Order 41A rule 3(2) of the Rules of the District Court (Cap 336H), the statement of truth of the plaintiff shall be signed by a person holding a senior position in the plaintiff. However, the statements of truth were both signed by an unknown person on a company chop of the plaintiff, and I note that the signature there was not the same as the signature on the Affirmation of Yung Mei Chun Jessie, who has prepared various affirmations in relation to the applications now before me. I take this opportunity to remind the plaintiff that in the coming re-amended statement of claim, the statement of truth must be properly signed by an identified person holding a senior position in the plaintiff.

PLEADINGS RELEVANT TO D’S DISCOVERY AND EXPERT SUMMONS

11.For the present purposes of determining D’s Discovery and Expert Summons, I shall set out the following parts of the parties’ pleadings. As I have granted leave for the plaintiff to re-amend its amended statement of claim, I shall refer to the re-amended statement of claim here.

12.The re-amended statement of claim contains the followings:-

“4. While the Plaintiff and the Defendant were still in negotiations over the outstanding rental rate/daily rental rate of the Room for the period from 14th August 2022 to 4th September 2022, which is disputed by the Plaintiff, the Defendant insisted on retaining the Plaintiff’s belongings (about 200 packs/boxes of valuable items), which include but are not limited to business documents, personal belongings of the Plaintiff’s directors, and valuable items, which are of a sensitive and private nature, all stored inside the Room (“the Belongings”)…

6. On 18th May 2023, the Plaintiff sent an email to the Defendant expressing disapproval and frustration towards the intended removal of the Belongings, which contained numerous valuable items, as previously and repeatedly highlighted to the Defendant since 16th July 2022. The Plaintiff also warned the Defendant that it should be held accountable for all loss and damage to the Belongings caused by and incidental to their removal…

a. … Despite these numerous warnings, the Defendant unilaterally proceeded with the removal on 18th May 2023. The Defendant did this without allowing the Plaintiff the opportunity to inspect, inventory, or otherwise verify the condition and quantity of the Belongings, thus infringing upon the Plaintiff’s rights…

AND The Plaintiff’s claims against the Defendant are as follows:

1. An Order requiring the Defendant to provide the list, compiled by the Defendant, of items that were moved out of the Room on 18th May 2023.

2. The return of all the Plaintiff’s Belongings as originally stored in the Room 442, no matter whether it is damaged or not.

3. The Defendant is required to pay the assessed damage sum of HK$3 million.

4. …”

13.The amended defence and counterclaim contains the following:-

“11. Regarding Paragraph 4 (and its sub-paragraphs):

(b) The rest of Paragraph 4 (and its sub-paragraphs) are denied and the Plaintiff is put to strict proof thereof. In particular, the Plaintiff is put to strict proof as to:-

(i) the number of packs and/or boxes and/or items constituting the Belongings (which is denied);

(ii) the content of the Belongings (which is denied);

(iii) the value of the Belongings (which is denied);

(iv) the Plaintiff’s ownership of the Belongings (which is denied)… It is averred that, by emails dated 4th September 2022, 18th May 2023, 27th May 2023 and 28th May 2023, the Plaintiff and/or the Couple [directors of the Plaintiff] repeatedly asserted that the Belongings were ‘personal’ belongings; and

(v) the original conditions of the Belongings as being moved into the Room (which is denied).

13. Regarding Paragraphs 5 to 14 (and their sub-paragraphs, if any):

(a) It is averred that the Plaintiff’s pleaded case formulated by these paragraphs, which appears to be one accusing the Defendant having caused damage to the Belongings (“the Plaintiff’s Property Damage Claim”), is wholly embarrassing for lacking the necessary particulars… The Defendant hereby reserves its rights to request for further and better particulars and/or to amend its Amended Defence and Counterclaim with proper costs sanction;

(b) …

(ii) The Defendant further avers that the removal of the Belongings from the Room to the Storage Area had been arranged and done meticulously without causing any damage to the Belongings;

(iii) Paragraph 6 (and its sub-paragraphs) and 7 are denied save and except that the Plaintiff and/or the Couple did send an email to the Defendant on the date as pleaded and the police did visit the Hotel on the dates as pleaded… The Defendant specifically denies any and all allegations as to the particulars, properties, value and/or vulnerability of the Belongings as alleged, contained, and/or implied in Paragraph 6 (or the aforesaid email)…

14.The plaintiff has not filed any reply and defence to counterclaim.

15.It is clear from the above that:-

(1) The Plaintiff sent an email to the Defendant on 18 May 2023 (the “Plaintiff’s 18 May 2023 Email”).

(2) The Defendant did remove the Belongings on 18 May 2023 from the Room to the Storage Area.

(3) The Plaintiff has not given any or any sufficient particulars of the Belongings.

16.The issues as crystalised by the pleadings set out above are, broadly:-

(1) What were the items in the Belongings (including the number of packs, boxes and other items, their contents, their values, their ownerships, their original conditions)?

(2) What items were removed from the Room?

(3) What are the items now left in the possession of the defendant?

(4) Are there any items lost?

(5) What are the current conditions of the items (for example, whether they are damaged and if so, what is the extent of the damage)?

(6) What is the quantum of damages for the lost items and damaged items?

(7) Did the defendant cause the loss and damage, if any?

PLAINTIFF’S 18 MAY 2023 EMAIL

17.In the Ex Parte Application, the plaintiff, in its supporting affirmation, exhibited a bundle of correspondence between the parties, among which was the Plaintiff’s 18 May 2023 Email. I set out the relevant paragraph of that email below:-

“…

During our visit to Room 442 in the company of the police, we noted that the air conditioning had been turned off and the lighting was insufficient, despite out repeated warnings that these conditions could cause damage to our belongings. If any damage occurs, your hotel will be held accountable for all losses and damages. We have compiled a detailed inventory, completed with photos and videos, of the items in Room 442 and their respective values. Should you choose to move our belongings due to your unwarranted demands for payment, we are prepared to take legal action for any resulting losses or damages.

…”

(emphasis added)

APPLICATION FOR DISCOVERY IN D’S DISCOVERY AND EXPERT SUMMONS

18.The document sought by the defendant against the plaintiff in D’s Discovery and Expert Summons is this very document mentioned in Plaintiff’s 18 May 2023 Email, described in the said summons as “[t]he detailed inventory, complete with photos and videos, of the items in the hotel guest room 442 (“Room”) and their respective values, as compiled by the Plaintiff and referred to by the Plaintiff in its email to [the Defendant] dated 18 May 2023”. Thus, there is prima facie evidence of the existence of this document. At the hearing, without evidence, Ms Yung said that the Plaintiff’s 18 May 2023 Email was written by her husband, Cheung Moon Hoi Jeff, the other director of the plaintiff and her husband told her that he had many inventory lists at the time of writing that email and he had no idea which inventory lists the defendant is seeking discovery of. What Ms Yung said is not in evidence, not even hearsay evidence in Ms Yung’s affirmation filed in opposition. Further, her husband did not make any affirmation and Ms Yung told me that she does not see any reason why her husband had to. In any event, Ms Yung’s such saying from the bar table would only point to the existence of the inventory; it is just that there are more than one inventory list as at the date of 18 May 2023 when that email was issued. If that is the case, then all the lists exist, and apparently, the reference to the “inventory” in the Plaintiff’s 18 May 2023 Email is a reference to all the lists. I disagree with Ms Yung that such discovery of the lists would be fishing – the lists would tell what the Belongings were, and if, as Ms Yung seemed to suggest, the lists are incomprehensive and/or inaccurate, the plaintiff may adduce evidence in support of her such suggestion, the credibility of which would be a matter for trial.

19.As regards relevance, the inventory is centrally relevant to the subject dispute, and the plaintiff’s opposition raised in its affirmation that the discovery would infringe upon the plaintiff’s and its directors’ privacy is stated to be rejected – the relevance clearly outweighs any alleged privacy here: see Chan Yim Wah Wallace v New World First Ferry Services Ltd [2015] 3 HKC 382 at §§44-47 per Bharwaney J. If in due course, the plaintiff thought it not worth claiming for damages in relation to certain items that are very private to the plaintiff or its directors, the plaintiff would be at liberty to waive claim in relation to those. Further and in any event, the defendant has an implied undertaking not to use any documents disclosed in these proceedings for ulterior purposes: see Order 24 rule 14A, and in response to the plaintiff’s such privacy concern, the defendant expressed this undertaking to the Court at the hearing as well.

20.As regards possession, custody and/or power, this inventory obviously is or has been in the plaintiff’s possession, custody and/or power because the plaintiff itself wrote in the email that “we have [the] detailed inventory…”, and the plaintiff does not say anything to contradict what it wrote in the email. At one point, Ms Yung seemed to suggest that the inventory lists are no longer with the plaintiff. But even documents that have been in possession, custody and/or power should still be disclosed in the list of documents, and if the documents are no longer with the plaintiff such that the plaintiff cannot provide the same for inspection, the plaintiff would say so properly.

21.The plaintiff also submits that the application for the discovery is oppressive because it would be unable for the plaintiff to compile the inventory lists to the satisfaction of the defendant. Such submissions are unmeritorious at all because what the defendant is seeking is the inventory lists referred to in the Plaintiff’s 18 May 2023 Email. The plaintiff would not be asked to compile some new lists now.

22.Another ground of opposition is that the discovery is not necessary for the fair disposal of the matter and/or saving costs at this stage. In this regard, the Court has a wide discretion when to order discovery in the interest of justice, although in general, discovery is refused before the close of pleadings because issues would usually not have been defined: see Hong Kong Civil Procedure 2024 Vol 1, §24/3/5.

23.In my view, in response to such lack of particulars of the Belongings provided by the plaintiff, the defendant may choose to apply for further and better particulars first rather than specific discovery at this early stage. Nevertheless, given (1) the procedural history where the plaintiff referred to the Plaintiff’s 18 May 2023 Email itself in its own affirmation; (2) the inventory itself would provide the particulars; and (3) the likelihood that upon provision of the further and better particulars (if so applied), the defendant would then seek specific discovery of the documents in support of the particulars in the light of the Plaintiff’s 18 May 2023 Email, I am satisfied that the discovery is in the interest of justice and necessary for the fair disposal of the matter and also for saving costs even at this stage. Thus, I shall make an order of discovery of the inventory.

24.Another discovery being sought under D’s Discovery and Expert Summons is, rather unusual, a discovery against itself, for “the list of items moved out of the Room on 18 May 2023 as recorded and prepared by the Defendant”. This is obviously relevant. The defendant’s unusual application for a discovery order against itself is because of its concern about the timing of the discovery – it seeks a mutual exchange of the plaintiff’s inventory and its own list. I can see the reason for a mutual exchange – this is to be fair to both parties by avoiding any unnecessary argument that the document discovered later by one party is somehow doctored based on the document discovered earlier by the other party. Given the prime relevance and importance of the inventory and the list to the dispute between the parties, I am satisfied that in exercising my discretion to order the discovery, for a fair disposal of the matter, it should be done by way of mutual exchange. The inventory and the defendant’s list are ready. The exchange shall take place within 28 days as proposed by the defendant.

25.For convenience, I shall refer to this discovery order as the “Discovery Order”.

APPLICATION FOR EXPERT DIRECTIONS IN D’S DISCOVERY AND EXPERT SUMMONS

26.In respect of the defendant’s application for expert directions, I note that the margin of D’s Discovery and Expert Summons states “O. 40”, which is a provision for court expert. At the hearing, the defendant clarified that it intended to make the application under Order 38 rule 36. It must be, because in the proposed order in the said summons, each party would be able to engage its own expert.

27.The expert directions being sought are:-

“2. Expert evidence on causation and quantum be limited to one Loss Adjuster to each party…

3. The parties are to arrange for a joint inspection of the items moved out of the Room on 18 May 2023 (“Belongings”) within the premises of [the defendant] by the respective Loss Adjusters within 28 days of [the discovery of the documents pursuant to the Discovery Order]…

4. The respective Loss Adjusters are to compile a joint report (accompanied by statements of truth) within 56 days from the date of the joint inspection addressing the following issues:-

(a) Compile an inventory list of the Belongings, with sufficient particulars as to the nature, character, conditions, and value thereof, at/upon their removal from the Room on 18 May 2023 (“Removal Date”), by making reference to the Plaintiff’s Documents and/or the Defendant’s Documents as disclosed pursuant to [the Discovery Order];

(b) Compile an inventory list of the Belongings, with sufficient particulars as to the nature, character, conditions and value thereof, as at the time of the joint inspection;

(c) Whether any of the Belongings was/were found lost or missing between the Removal Date and the date of the joint inspection? If so, please:

(i) identify the lost or missing item by making reference to the Plaintiff’s Documents and/or the Defendant’s Documents as disclosed pursuant to [the Discovery Order]; and

(ii) comment on the resulting quantifiable loss in terms of value and/or replacement costs (where applicable);

(d) Whether any of the Belongings was/were found damaged between the Removal Date and the date of the joint inspection? If so, please comment on:

(i) the nature and extent of damage;

(ii) what was/were the probable cause(s) of such damage;

(iii) whether such damage is permanent/irreversible; and

(iv) the resulting quantifiable diminution/loss in terms of value and/or repair/replacement costs (where applicable);

(e) Any other issue(s) which you believe is/are relevant.”

28.There is no dispute, and I agree, that the expertise required is that of a loss adjuster.

29.Issues (a) and (b) are clearly relevant. By compiling and comparing the lists, the parties would then be able to know the particulars of the items and identify the items and any lost items.

30.Issue (c) is clearly relevant, as one of the disputes between the parties is whether certain items have been lost and if so, their values.

31.Issue (d) is clearly relevant, as one of the disputes between the parties is whether any items have been damaged, and if so, whether the defendant caused the damage, and if so, how much.

32.The plaintiff opposes the application for expert directions. One of the grounds of opposition is set out in §17 of the Affirmation of Yung Mei Chun Jessie filed for the plaintiff on 24 January 2024, namely, “[t]hroughout the period from July to December 2023, the Defendant has vigorously defended against and opposed all the Plaintiff’s applications for inspection of loss assessments in all the hearings, their affirmations and submissions…”

33.The plaintiff’s such opposition is, if not misleading, based on misapprehension of the facts, and thus I reject the same, for the following reasons.

(1) Put in proper context, the defendant opposed, and the Court discharged and dismissed, the Ex Parte Order and the subsequent ex parte applications on the ground of material non-disclosure and lack of proper basis for making the applications on an ex parte basis.

(2) In any event, as set out in §3 above, the inspection part of the Ex Parte Order was a unilateral inspection only, and as set out in §4 above, the inspection subsequently proposed by the plaintiff was also unilateral. Further, such inspection would be done without any discovery of the inventory and the lists beforehand and without proper directions for joint inspection and issues to be addressed. Such inspection, if carried out, would be unfair to the defendant, and in any event, its effectiveness would be dampened by the absence of the inventory and the list and proper expert directions setting out specific issues to be addressed. Thus, the inspection the defendant was opposed to is an entirely different animal from the joint inspection it is now seeking.

(3) If the defendant’s opposition in the past were relevant at all (though I find it not), it would be relevant to costs only. It is not right to dismiss an application for expert directions which are necessary for the just resolution of the parties’ dispute in accordance with their substantive rights (Order 1A rule 2(2)) simply on the ground that the applicant has in the past opposed expert directions, which is not the case here in any event.

34.Another ground of opposition raised by the plaintiff is that it is premature to have evidence of quantum of loss and damage, and that liability should be established first before any order for evidence in relation to quantum is made. I am surprised by such ground of opposition, because usually, it is the plaintiff who would like to have both liability and quantum tried together to shorten the time before it would be able to obtain damages. In any event, the general rule is that all the issues in a case are to be tried at the same time, and a split trial is ordered only if it is just and convenient to do so: see Hong Kong Civil Procedure 2024 Vol 1 §33/4/9. In the present case, there is no order for a split trial. No application is made for a split trial. Nor can I see from the materials before me why it is just and convenient to order a split trial. Ms Yung also submits that the expert directions are premature also because there may be further damage to the items prior to the trial. In my view, an update (if necessary) to the expert reports would be made easier with the ground work already carried out pursuant to the expert directions being sought by the defendant.

35.Lastly, Ms Yung submits at the hearing that the lists disclosed would not be sufficiently detailed for carrying the expert directions being sought by the defendant. However, from the description of the inventory in the Plaintiff’s 18 May 2023 Email being “a detailed inventory, completed with photos and videos, of the items… and their respective values” (my emphasis), the plaintiff’s inventory would be sufficiently detailed enough for that purpose. As regards the defendant’s lists, it seems from the defendant’s solicitors’ submissions that the list would not be sufficiently “detailed”, but with the plaintiff’s inventory lists alone, it seems to me that the experts would still be able to carry out the proposed expert directions. In any event, in order to cater for any possibility unforeseeable from the evidence before me, I would make it clear that there shall be liberty to apply in respect of the expert directions.

36.I have not overlooked the usual practice that expert directions are only given at the case-management stage, where discovery would usually have been completed and witness statements have been ordered. However, as the procedural history I set out above shows, the parties have effectively produced substantial evidence in the present action. Although I have just granted leave for the plaintiff to re-amend its amended statement of claim, the re-amendments do not affect the pleadings relevant to the determination of the expert directions. In the circumstances, I think I should grant the expert directions being sought by the defendant, subject to tying two loose ends as explained below.

37.First, I do not think that the loss adjusters should, as proposed in paragraph 4 of D’s Discovery and Expert Summons, compile a joint report before they have their own respective, separate reports. In my view, it is more effective to have their own reports exchanged first, then followed by without-prejudice meetings for the purpose of preparing a joint expert report setting out agreements and disagreements. The reason is that given the potentially large amounts of items, it should be more effective and fairer for the parties and their legal teams to have a chance to consider the other side’s report first, rather than having the experts discuss the agreements and disagreements among themselves to prepare the single report in one go.

38.Second, I do not accede to paragraph 4(e) of D’s Discovery and Expert Summons, which is effectively a carte blanche and would provide an unnecessary door for the experts to ramble on issues which the other side might not expect. If any of the experts would take the view that the issues defined in paragraph 4(a) – (d) are insufficient, he would inform the party accordingly and the party would make any necessary application to the Court.

PLAINTIFF’S OTHER APPLICATIONS IN CONTEMPLATION

39.For the sake of the completeness, towards the end of the hearing, Ms Yung submits that the plaintiff would like to make applications to strike out certain parts of the defendant’s amended defence and counterclaim, and for determination of issues under Order 24 rule 4 in relation to the lien counterclaimed by the defendant. She submits that these applications would have significant or even conclusive impact on the outcomes of the summonses before me. I do not have these applications before me; nor do I understand the grounds for such applications in the plaintiff’s contemplation at this stage. Therefore, I do not pay any regard to the plaintiff’s such contemplations at all in determining the Summonses before me.

CONCLUSION

40.In the premises, I make the following order.

41.In respect of P’s Amendment Summons:-

(1) There shall be leave to the plaintiff to re-amend the amended statement of claim as per §§14d, 24-26, 28-37 and 68-71 of the draft re-amended statement of claim attached to P’s Amendment Summons.

(2) The plaintiff do file and serve the said re-amended statement of claim, verified by proper statement of truth, within 21 days from today.

(3) The defendant do file and serve re-amended defence and counterclaim only consequential upon the re-amendments in the re-amended statement of claim within 21 days thereafter.

(4) The plaintiff do have leave to file and serve reply and defence to counterclaim, if any, only consequential upon any re-amendment in the re-amended defence and counterclaim.

(5) 30% of the costs of and occasioned by P’s Amendment Summons shall be in the cause.

(6) The plaintiff do pay the defendant 70% of the defendant’s whole costs of P’s Amendment Summons forthwith.

(7) The defendant’s whole costs of P’s Amendment Summons is summarily assessed at HK$12,000.00.

42.In respect of D’s Discovery and Expert Summons:-

(1) The plaintiff and the defendant do mutually exchange and provide for photocopying and inspection at an agreed time within 28 days from today:-

(a) By the plaintiff: a list of documents in relation to, and (a) copy(ies) of, the detailed inventory, complete with photos and videos, of the items in Room 442 (the “Room”) and their respective values compiled by the plaintiff and referred to by the plaintiff in its Plaintiff’s 18 May 2023 Email.

(b) By the defendant: a list of documents in relation to, and (a) copy(ies) of, the list of the items moved out of the Room on 18 May 2023 as recorded and compiled by the defendant.

(2) There shall be leave to each party to engage one loss adjuster for the purpose of preparing the expert reports pursuant to paragraphs (4) and (5) below.

(3) For the purpose of preparing the expert reports pursuant to paragraphs (4) and (5) below, the parties are to arrange for a joint inspection of the items moved out of the Room on 18 May 2023 (the “Belongings”) within the premises of New World Millennium Hong Kong Hotel by the respective loss adjuster within 35 days of the mutual exchange pursuant to paragraph (1) above. For the avoidance of doubt, both the parties and their legal advisers are at liberty to attend the joint inspection.

(4) The plaintiff and the defendant do file and exchange their respective expert reports within 42 days from the end of the joint inspection to address the issues and perform the tasks set out in paragraph (6) below.

(5) The plaintiff’s expert and the defendant’s expert do conduct (a) without prejudice meeting(s) for the purposes of preparing a joint expert report. The joint expert report shall set out the agreements and disagreements (with brief explanation for the disagreements) and shall be filed within 42 days after the exchange of their respective reports pursuant to paragraph (4) above.

(6) The issues and tasks are:-

(a) To compile an inventory list of the Belongings, with sufficient particulars as to the nature, character, conditions, and value thereof, at/upon their removal from the Room on 18 May 2023 (“Removal Date”), by making reference to the Plaintiff’s Documents and/or the Defendant’s Documents as disclosed pursuant to paragraph (1) above.

(b) To compile an inventory list of the Belongings, with sufficient particulars as to the nature, character, conditions and value thereof, as at the time of the joint inspection.

(c) Whether any of the Belongings was/were found lost or missing between the Removal Date and the date of the joint inspection? If so:-

(i) identify the lost or missing item by making reference to the Plaintiff’s Documents and/or the Defendant’s Documents as disclosed pursuant to paragraph (1) above; and

(ii) comment on the resulting quantifiable loss in terms of value and/or replacement costs (where applicable).

(d) Whether any of the Belongings was/were found damaged between the Removal Date and the date of the joint inspection? If so, comment on:-

(i) the nature and extent of damage;

(ii) what was/were the probable cause(s) of such damage;

(iii) whether such damage is permanent/irreversible; and

(iv) the resulting quantifiable diminution/loss in terms of value and/or repair/replacement costs (where applicable).

(7) There shall be liberty to apply.

(8) The costs of D’s Discovery and Expert Summons shall be in the cause.

  ( Gary C C Lam )
  Deputy District Judge

Ms Yung Mei Chun Jessie, Director, represents the Plaintiff, acting in person

Mr H Y Leung of Messrs Y T Chan & Co, for the Defendant

Other Judgments in This Case

Further hearings and rulings under DCCJ 2191/2023

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