<p>Ground 1: Payment of $94,200 to the barrister without being provided with a costs agreement, invoices or receipts</p><p>Ground 2<u>:</u> Preparation of the complainant’s criminal defence for trial, specifically:</p><p>(i) selection of the location of the trial;</p><p>(ii) selection of expert witnesses and lay witnesses;</p><p>(iii) the barrister himself writing the report for an expert witness;</p><p>(iv) the barrister’s failure to develop a strategy for the case based on an issue that the complainant considered to be critical (the authenticity of documents relied upon by the Crown); and</p><p>(v) the barrister’s failure to subpoena relevant documents.</p>