QUICK REVIEWER

ON PRACTICAL EXERCISES
By: Atty. Edwin M. Carillo1

Based on the official syllabus, this year’s Bar Examinations shall have a
portion on Practical Exercises as part of the exams on LEGAL ETHICS. While
this has always been a part of previous Bar Examinations, this portion was
removed in the 2012 Bar examinations after it gained prominence in the 2011
Bar Examinations when the Bar Chairman opted to insert a skills examination
on a predominantly MCQ-type exam that year, asking the candidates to draft
both a legal opinion and a trial memorandum.

This year’s Bar Exam syllabus on Legal Ethics lists the following for
Practical Exercises:

A. Quitclaim in Labor Cases;

B. Simple Contracts - - Lease, Sale of Realty or personal property;
C. Promissory Note;
D. Verification and Certificate against Forum Shopping;
E. Notice of Hearing and Explanation (All levels);
F. Affidavits – Loss, Change of Name.

Although admittedly this could determine the success of a candidate, its

importance, unfortunately, is often brushed aside mainly because of the
examinee’s fatigue or his eagerness perhaps to go home and join the
merriment happening outside the exam site. Since about an hour shall be
devoted in the preparation of three to four documents listed above, one must
be reminded to:

a. WATCH THE TIME. Time is of the essence. Consequently, only the

minimum requirements of the law must be reflected in drafting the required
form;

b. AVOID FANCY, LONG, AND NEEDLESS WORDS. Simple, concise

and grammatically correct statements are hallmarks of effective legal writing.
More importantly, they save you precious time;

c. AVOID ERASURES as much as possible because they reduce the

impressiveness of your work. To avoid erasures, do your pre-work (answer
outline) using the questionnaire you received. Remember that nothing comes
between YOU and the EXAMINER other than your written work. Thus, your
work should mirror not only legal aptitude but also neatness; and,

d. PUT A DATE in all the legal documents that you will draft as
required.
1
Atty. Carillo served as member of the College of Examiners in the 2011 Bar Examinations that
handled Legal Ethics and the Skills Examinations for Trial Memorandum. He is a professor of law
and bar reviewer teaching courses like, Political and Constitutional Law, Land Registration Law,
Administrative Law, Legal and Judicial Ethics, Trial Technique, and Legal Forms and Writing for
over two decades now. He currently serves the government as an Assistant Government Corporate
Counsel of the Office of the Government Corporate Counsel, an agency attached to the Department
of Justice.
 -2-

The patterns of legal forms, i.e., Business Legal Forms or Judicial Legal
Forms would be useful here. Familiarize yourselves with their respective
patterns to save you time when drafting any of them during the examinations.

A. BASIC CONTRACTS

I. AFFIDAVITS
An affidavit is a sworn declaration of facts known to a declarant or affiant. It consists
of the following parts: the Venue of Execution, Title, Person’s Bona Fides, the Oath,
Statement, the Signature and the Jurat. (Code: VeTiPe-OSta-SiJu) Of all these parts, the
jurat is most important as this is the certification of an officer that the statement was sworn
before him. Section 6, Rule II of the 2004 Rules on Notarial Practice (RNP) defines a jurat
as an act in which an individual on a single occasion:

(a) appears in person before the notary public and presents an instrument or document;
(b) is personally known to the notary public or identified by the notary public through
competent evidence of identity as defined by these Rules;
(c) signs the instrument or document in the presence of the notary; and
(d) takes an oath or affirmation before the notary public as to such instrument or
document. (This means that the declarant vows under penalty of law to the whole truth
of the contents of his statement. Note also that the elements of a jurat are connected by
a conjunctive “and”. As such, each one act should be reflected in the jurat.)

Check out the following sample of an Affidavit of Loss that can be asked in this year’s Bar
examinations:

Republic of the Philippines)

City of Manila ) S.S.

AFFIDAVIT

I, FERNANDO K. ROCO, of legal age, married, residing at 505 V.G.

Cruz, Sampaloc, Manila, state under oath that:

1. I own a car described as follows:

Make: Toyota Corolla 1987; Motor: EMC14356C

Serial/Chassis: CDC042094, File: 2345567E
Reg. Cert.: 4567EC, Plate: PPA 863

2.  This car is registered in my name before the Land Transportation

Office in 2014 for which I was issued a registration certificate.

3.  This certificate was among those destroyed on 14 June 2015 when
my entire house was razed by fire.

Manila, 6 June 2017.

(SGD.) FERNANDO K. ROCO

Affiant
┐
│
SIGNED AND SWORN before me this 6 June 2017 at Manila, affiant │
exhibited to me his Passport JJ2003*, issued on 9 January 2016 at Manila. │
 -3-

│
│
(SGD) JUAN C. MENDOZA │
Notary Public for Manila │
Suite 212 Burke Building, Escolta, Manila │ Jurat
Commission Serial 54342 │
Until Dec. 31, 2018 │
Roll of Attorney 38718 │
PTR 56789; 1-12-17; Manila │
IBP 24680 1-12-17 Manila │
Doc. 12; │
Page 8; │
Book II; │
Series of 2017. ┘

*The passport number is indicated here as a competent evidence of identity defined

under Section 12, Rule 2 of the 2004 RNP, which provides:

SEC 12. Competent evidence of Identity – The phrase “competent

evidence of identity” refers to the identification of an individual based on:

(a) at least one current identification document issued by an official

agency bearing the photograph and signature of the individual; or

(b) the oath or affirmation of one credible witness not privy to the
instrument, document or transaction who is personally known to the notary
public and who personally knows the individual, or of two credible witnesses
neither of whom is privy to the instrument, document or transaction who each
personally knows the individual and shows to the notary public documentary
identification.

TAKE NOTE:
A notary public may attest in his jurat that he personally knows the affiant and that
would have been valid. In fact, if this is the case, the presentation of a competent evidence
of identity may be dispensed with. Therefore, if there is no requirement from the examiner to
this effect, the jurat would have been complete if it is stated in this manner:

“SIGNED AND SWORN before me this 6 June 2017 by affiant whom I personally know.”

SAMPLE PROBLEM / ANSWER

Given the items in the Legal Ethics syllabus, a possible problem can be asked in this
manner:

18. Technology manager Bernardo B. Sales filed a complaint against

Seize Tomorrow Corporation (STC) and a number of its officers before the
arbitration branch of the National Labor Relations Commission, Regional Office
IV located in Calamba City, Laguna, docketed as NLRC Case RAIV 82345-07 for
a number of issues arising from the last company action against him. During the
mandatory conference between the parties, they amicably settled their
differences such that Bernardo shall receive PhP500,000.00 by way of financial
assistance from STC in exchange for his commitment not to do any act
prejudicial to the interest of the company, its branches, or its projects arising
from or with respect to his previous employment and his outright execution of a
quitclaim against the same company and officers. Draft the needed document.

And the answer to this would be:

18.
Republic of the Philippines)
 -4-

Calamba City, Laguna) S.S. 

QUITCLAIM AND RELEASE

I, BERNARDO B. SALES, of legal age, married, and residing at 801

Naujan St., Calamba City, Laguna, hereby state under oath:

1.  I acknowledge to my full and complete satisfaction that I have

received PhP50,000.00, by way of financial assistance from Seize Tomorrow
Corporation (STC).

2. I now admit that I have no further claim or cause of action against

STC, its officers or employees with respect to any matter incident to or arising
out of my previous employment. Consequently, I will institute no action with
respect to it even as I now release and forever discharge STC, its officers and
employees from any claim, cause of action, or any further obligation in
connection with it.  I fully acknowledge that the consideration I received is and
shall be the full and final settlement of any and all such claims.  

3. Finally, I declare that I have read this document and I willingly and
voluntarily give this quitclaim fully knowing my rights under the law.

SIGNED this 6 June 2017 in Calamba City, Laguna.

                                                                            (SGD.) BERNARDO B.
SALES
                                                                                        Affiant

SIGNED AND SWORN before me this 6 June 2017 by affiant whom I

personally know.

(SGD) JUAN C. MENDOZA

Notary Public for Calamba City, Laguna
Suite 212 Burke Building, Calamba City, Laguna
Commission Serial 54342
Until Dec. 31, 2018
Roll of Attorney 38718
PTR 56789 1-12-18; Calamba City
IBP 24680 1-12-18 Calamba City

Doc. 6;
Page 4;
Book I;
Series of 2017.

II. DEED FORMS

A Deed indicates the unilateral act of a person in disposing his property or right in
favor of another after his receipt of a consideration. The transaction is terminated by the
conveyance of the thing or right. A typical deed has the following parts: Title,
Announcement, First Party, Consideration, Act or Conveyance, Second Party, Signature
and Acknowledgment. (Code:TAF-CAS-SA) Observe these parts in the deed below.

(T) DEED OF SALE

(A) THE PUBLIC IS INFORMED:

(F) I, PROCOPIO C. CRUZ, of legal age, married, and residing at 12 Apo

St., Quezon City, (C) for and in consideration of the sum of PHP100,000.00, (A)
hereby sell on an “as is where is” basis my motor vehicle, more particularly
described as follows:
 -5-

Make: Toyota Corolla 1987; Motor: EMC14356C

Serial /Chassis: CDC042094, File: 2345567E
Reg. Cert.: 4567EC, Plate: PPA 863

(S) to RICARDO LIM, of legal age, married, and residing at 2 Bangkal St.,
Manila.

(S) SIGNED this 8 July 2014 in Quezon City.

(SGD.) PROCOPIO C. CRUZ

Seller
With my consent:

(SGD.) Helen Y. Cruz

Spouse

(A) (ACKNOWLEDGMENT)

If we change the subject matter to a real property, the act or conveyance part above
would read like this:

“hereby sell a 150 square meter parcel of land located in Tondo, Manila, covered
by Transfer Certificate of Title 42349-B, particularly described as follows: (insert
technical description)”

III. CONTRACT FORMS

In drafting an agreement using a contract form, you must remember that it should
contain the essential requirements of object, consideration, and consent. The peculiarities of
a specific contract should also be taken into consideration. Using a contract form means that
you must show the parties’ respective undertakings. A contract usually has the following
parts: Title, Announcement, Actors, Recitals, Agreement, Conditions, Signatories and
Acknowledgment. (Code: TAA-RAC-SA) Observe these parts in the contract of lease below,
a possible contract that the examiner may ask:

(T) LEASE CONTRACT

(A) The Public Is Informed:

(A) This contract is executed between:

FELIPE D. GUZMAN, Filipino, of legal age, single, residing at 28 Aurora

Blvd., Quezon City;
- and -

ARTHUR E. MIRANDA, Filipino, of legal age, married to Agnes Torres,

residing at 30 Aurora Blvd., Quezon City.

(R) Felipe wants to lease the residential apartment he owns located at 30

Aurora Blvd., Quezon City and Arthur expressed his desire to lease it from Felipe.

(A) Consequently, the parties agree on the following conditions:

(C) 1. Felipe leases to Arthur the apartment unit for one year from the signing
date of this agreement.
2. Arthur shall pay Felipe Php5,000.00 monthly rental, payable in advance
within the first five days of each month.
3. Arthur warrants that he received the apartment in good and habitable
 -6-

condition.
4. Arthur shall not sublet the apartment to any one without Felipe’s written
consent.

(S) 10 April 2017, Quezon City

(Sgd.) FELIPE D. GUZMAN (Sgd.) ARTHUR E. MIRANDA

Witnessed by: (Sgd.) Rene A. Miranda (Sgd.) Cito C. Jose

(A) (Acknowledgment)

Note well that deeds and contracts forms both speak of agreements and, therefore,
covered by the civil law concept of contracts. They vary in templates or forms used as
shown above. Deed forms are unilateral and, therefore, a first person’s point of view is
utilized. Contract forms demonstrate bilateral or multilateral acts or undertakings. As such,
the third person’s viewpoint is recommended to draft this. Notice too that the lease contract
your saw above can be drafted using the deed form. Thus, if the examiner does not qualify, I
suggest that you use the deed form, as it is simpler and, therefore, quicker to draft, saving
you so much precious time.

ACKNOWLEDGMENTS (COMMON TO ALL DEEDS & CONTRACTS)

Read: Section 1, Rule II of the 2004 RNP

The notary public speaks in this part of the deed or contract. Take a look at the
sample below.

ACKNOWLEDGMENT

The following personally appeared before me:

Name Passport No. Date/ Place Issued

1. Tomas S. Balatan CC123330 1-05-2002/ Baguio City
2. Juan N. Buelta JJ200345 1-17-2004/ Manila

They are known to me to be the same persons who executed the foregoing
contract and they acknowledged that their signatures prove their voluntary acts
for the purposes stated in the document.

SIGNED AND SEALED in Manila, 15 August 2016.

(SGD.) Juan C. Mendoza

Notary Public for Manila
Suite 212 Burke Building, Escolta, Manila
Commission Serial 54342
Until Dec. 31, 2017
Roll of Attorney 38718
PTR 56789; 12 Jan. 16; Manila
IBP 24680; 12 Jan. 16; Manila
Doc. 12;
Page 8;
Book II;
Series of 2016.

(Special Requirement in Conveyance of Real Property pursuant to Act

496, as amended)

This paragraph should be added before the notary public’s signature:

 -7-

This deed/contract relates to the sale of a parcel of land situated in

Quezon City consisting of two pages, including this where the acknowledgment
is stated and was signed by the parties and their witnesses in the left margin of
every page.

(Special form of acknowledgment if deed/contract is executed by a

corporation)

ACKNOWLEDGEMENT

BEFORE ME, personally appeared:

Name Competent Evidence Date/ Place Issued

of Identification

1. Tomas S. Balatan, Passport CC123330 1-05-2002 / Baguio City

President of True All-
Star, Inc.

2. Juan N. Buelta, Passport JJ200345 1-17-2004 / Manila

President of Right Pak,
Inc.

They are known to me to be the same persons who executed the foregoing
contract on behalf of the corporations they represent and acknowledged to me
that the same is their voluntary acts and that of the corporation being
represented.

City of Manila, 17 August 2004.

(Notarial Signature and Certificate)

*Based on Section 1, Rule II of the 2004 Notarial Rules, only individuals can be
parties in the acknowledgment process. Corporations cannot take part in the process even if
they are the real party to the contract or deed. If a corporation is a party to the contract, its
representative must act for it and must so indicate in the acknowledgment that he acts in
such representative capacity. Unless required, It is advisable to simply refer in the drafted
deed or contract the specific authority of the corporation’s representative.

*The absence of an acknowledgment will not render the contract or deed void except
when the law requires that a contract be in some form in order that it may be valid or
enforceable like acts and contracts which have for their object the creation, transmission,
modification or extinguishment of real rights over immovable property; sales of real property
or of an interest in it which under the law must appear in a public instrument. An
acknowledgment, therefore, in these special cases is a must.

SAMPLE PROBLEM / ANSWER

Again, given the released syllabus, a possible problem that can be asked is - -

22. Ricardo Gonzales, who resides at 1340 Amihan Road, Paseo de

Encantadia, Cainta, Rizal, asked his friend Ernesto Roman for a PhP1.5 million
loan and promising to pay him in full, without further amortizations, on year
two from the date he executes the note with 12% interest per annum. Ernesto
agreed but imposes the condition that if the amount will not be paid in full on
the second year as promised, forcing him to litigate to collect the loan he gave,
he would sue only in Manila where he resides. Draft the parties’ document
without the notarial certificate.

The Answer:
 -8-

22.
Promissory Note

For value received of PhP1,500,000.00, I RICARDO C. GONZALES, of

legal age, married, and residing at 1340 Amihan Road, Paseo de Encantadia,
Cainta, Rizal, do hereby promise to pay Ernesto G. Roman, of legal age, single
and residing in 2345 Zafiro Street, San Andres Bukid, Manila, the full amount
that I received above plus interest of 12% per annum exactly on the second year
from the date of this note.

In case of litigation arising from or in connection with this note, the

venue for trial shall be competent court of the City of Manila to the exclusion of
all others.

SIGNED this 9 June 2017, in Manila.

(SGD.) RICARDO C. GONZALES

Promissor/Borrower
With my consent:

(SGD.) ROSELLE G. GONZALES

Spouse

Acknowledgment

Ricardo C. Gonzales, whom I personally know, appeared before me this

9 June 2017. He executed the foregoing promissory note and acknowledged to
me that his signature on it proves his voluntary act for the purposes stated in it.

(Notarial certificate deleted)

B. BASIC PLEADING ISSUES

I. VERIFICATION/CERTIFICATION.

Verifications are additions to complaints and petitions required only in cases

provided for by the Rules of Court and other circulars. (Cf. Section 4, Rule 7, 1997 Rules on
Civil Procedure). The revised rules on summary procedure for instance require that all
pleadings be verified. (Cf. Section 3 (B) (II), Revised Rules on Summary Procedure)

Certifications against forum shopping are necessary in complaints or other initiatory

pleadings (Cf. Section 5, Rule 7, 1997 Rules on Civil Procedure). A counsel cannot certify
against forum shopping; it should be the plaintiff. A certification against forum shopping by
counsel is a defective certification. It is clearly equivalent to non-compliance with the
requirement under the rules and constitutes a valid cause for dismissal of the complaint or
petition. (Cf. Far Eastern Shipping Company vs. Court of Appeals, et al., G.R. 130068, 1
October 1998) If the plaintiff is a corporation, it should be signed by its authorized officers.
Failure to comply with this requirement could be a cause for dismissal of the action but only
upon motion and hearing. The defect is not curable by amendment. (Cf. Barroso v. Ampig,
Jr., 328 SCRA 530) Since verifications and certifications against forum-shopping are
required to be under oath, they are usually combined to avoid a repetitive process. See the
sample below:
___________________________________________________________________

Verification/Certification

I, Pedro Labo, plaintiff in the above-entitled case, state under oath that: (1) I
have read the above complaint and the facts stated in it are true and correct to the
best of my knowledge and/or based on authentic documents available to me; (2) I
have not commenced any action or filed any claim involving the same issues in any
 -9-

court, tribunal or quasi-judicial agency and, to the best of my knowledge, no such

other action or claim is pending in them; and (3) if I should learn that the same or
similar action or claim has been filed or is pending after its filing, I shall report
such fact within five days from notice.

Manila, 7 August 2017.

(SGD.) PEDRO C. LABO

(JURAT)

II. NOTICES OF HEARING.

The Rules of Court requires that the notice should be directed to the parties (counsel
included) NOT TO THE CLERK OF COURT. Otherwise, the motion shall be considered a
sham or a mere scrap of paper (Cf. Mesina, et al. vs. Court of Appeals, G.R.110946, 24
October 1994). Moreover, the rules provide that the motion day and time be on Friday at
2:00 o’clock in the afternoon. While in actual practice this rule is usually observed in the
breach, you are expected to conform strictly to this requirement as a Bar examinee. Motions
are either litigated or not. Non-litigious motions are those that may be acted upon by the
Court without further argument like a motion to reset or a motion for postponement. All other
motions are litigated and should be acted upon after due hearing. Check the sample notice
below.

(ASSUME THAT A MOTION HAS BEEN DRAFTED)

Notice and Copy furnished:

Atty. PEDRO PENDUKO

Counsel for the Defendant
(Address)

Due to the non-litigious character of the foregoing motion, please submit

the same to the Court for its immediate consideration and approval.

(or if litigated motion)

Please note that the undersigned counsel shall submit the foregoing
motion for the Court’s resolution on 9 June 2017, Friday, at 2:00 o’clock in the
afternoon.

(SGD.) CRISANTO Y. MENDEZ

_________________________________________________________________________

III. SERVICE EXPLANATIONS

Section 11, Rule 13, Rules of Court, as amended, requires an explanation if service
cannot be done personally. A violation of this requirement “may be cause to consider
the paper as not filed.” See: Solar Team Entertainment, Inc. v. Hon. Helen Bautista
Ricafort, et al. (G.R. 132007, 5 August 1998). Consider a sample explanation below.

Explanation: Due to time constraints, a copy of this comment shall be served by

registered mail.

____________________________________________________________________________
IV. CHANGE OF NAME PETITION (AFFIDAVIT FORM)
 - 10 -

An affidavit form can also be used to house pleadings when authorized by law. To
draft a petition for change of name in an affidavit form, it is important for you to read
Republic Act 9048. After doing so, read the following - -

SAMPLE PROBLEM / ANSWER

5. Spouses Benjamin and Leonor Relova approached you seeking help for
their son, Batman Bruce. They disclosed that they wanted to have their son’s
name changed by dropping the first of his two first names, as this current name
has caused him to be the butt of jokes from both friends and relatives. They want
that this issue be addressed soonest hopefully before their son finishes law in San
Sebastian College. Draft the needed document to carry out what they want
without any notarial act.

The Answer:

5.

Republic of the Philippines)

City of Manila ) S.S.

AFFIDAVIT
(To Petition a Change of Name)

I, BATMAN BRUCE RELOVA y ROSALES, Filipino, single, of legal age and

residing at 8 Enders St. Filinvest Homes East, Cainta, Rizal, under oath, declare
that:

1. I was born on 13 May 1999 from the union of Benjamin P. Relova and
Leonor C. Rosales and was given the first name “BATMAN BRUCE” as shown by
my birth certificate, here enclosed, recorded on such date in the Manila Local Civil
Registrar’s Office (LCRO) under registry number 1234567.

2. The first name to be changed is from “BATMAN BRUCE” to plain

“BRUCE.”

3. I execute this affidavit to support a change of my first name because my

given first name is downright ridiculous and has caused me dishonor ever since.

4. To support this, I also enclose here the following documents:

a. A certified true copy of the registry book page containing the entry
sought to be changed;
b. My elementary and high school transcripts of record where the name
“BATMAN BRUCE R. RELOVA” appears and upon which the change
shall be based;
c. The affidavits of Mrs. Maria R. Buenaventura and Mr. Pedro C. Vitug,
my elementary school and high school classmates, both stating
separately that I have been known in school as “BATMAN BRUCE R.
RELOVA, and upon which the change shall be based;
d. A certification of posting;
e. A certification from Barangay Santo Domingo, Cainta, stating that I am
known in the community as BRUCE R. RELOVA;
f. Separate certifications from the Philippine National Police and the
National Bureau of Investigation that I have no pending
administrative, civil or criminal cases, or any criminal record;
g. An affidavit of publication from the Manila Bulletin confirming the
requisite publication under the law; and,
h. A copy of the newspaper clipping from Manila Bulletin.

5. I have not filed any affidavit-petition and that, to the best of my

 - 11 -

knowledge, no other similar affidavit-petition is pending with any LCRO, court,

or Philippine Consulate.

6. I will file my affidavit-petition at the Manila LCRO in accordance with

Republic Act 9048 and its implementing rules and regulations.

SIGNED this 10 September 2017, in Manila.

(SGD.) BATMAN BRUCE R. RELOVA

Affiant

(Jurat is Omitted)

C. FINAL CONSIDERATIONS
Completing a required document for practical exercises will not be enough if your
aim is to submit an excellent work. Excellent writing needs editing, just as excellent furniture
needs finishing touches. Here are some editing tips that you can apply before turning over
your booklets to the proctor:

1. Aside from avoiding needless words to save on time, use the active voice instead
of the passive voice. Passive voice is indirect, limp, and weak. On the other hand, the active
voice is direct, vigorous, and strong. Sense the difference.

Abel was killed by Cain. (Passive) Cain killed Abel. (Active)

2. Use the right connectives. You need the help of connectives or transitory devices
to link your ideas one after the other and present a unified thought. You cannot assume that
your reader can read unspoken tie-ups between ideas. Consider the following useful
connectives:

Connective
And
Besides, what is more, furthermore, in
addition, and again
First, next, then, finally; meanwhile
Nearby, above, below
But, still, however, on the other hand,
nevertheless, rather
In fact, as a matter of fact,
Therefore, consequently, accordingly
In short, to sum up, in brief
Function
Connects two ideas of the same
kind
Adds another thought to the first
Arranges ideas in order
Arranges ideas in space
Connects two contrasting ideas
Connects the first idea with the
second one that points it up; the
second one affirms of validates the
first idea
Connects an idea with another that
follows from it.
Summarize several ideas

3. Avoid legalese and old English. Legal clichés have become hackneyed and
weak. To non-lawyers, they may even sound pretentious, unnatural or artificial, if not
arrogant. Phrases and words like to wit, instant case, aforesaid complaint, herein method,
thereat and theretofore deserve to be abandoned in favor of simpler words. Use standard
English always.

4. Be simple. Some have the mistaken belief that they will sound more dignified and
lawyerly if they use polysyllabic words like “accompanied” or “informed” instead of “went
with” or “told”, respectively. Your written work will have the same tone of formality and
dignity as long as it is serious and thoughtful. As a rule, a simple familiar word that means
exactly the same thing is the better choice. Simplicity is power!
 - 12 -

5. Check your grammar. In presenting answers, ensure that the subject agrees with
the verb. Use proper tenses and punctuations, too.

oOo

Good Luck to all Barristers!