Following is the full text of the letter sent to Karl Hudson-Phillips QC by Seenath Jairam SC in response to Hudson-Phillips' earlier correspondence to Jairam calling on him to resign after accepting a brief to be the lead counsel in the CLICO/HCU Commission of Enquiry:

I was tempted to address you as "Dear Mamoo" (Uncle) as I have done for more than two decades at your insistence. However you are not deserving of such accolade or reverence as I cannot imagine my mother's brother would want to destroy his nephew as you are attempting to do to me.

It is clear to all that your letter dated October 8, 2012, although addressed to me, was really meant for the Press so as to enable you to obtain the fullest publicity of your vilification of my character and reputation by these unfounded and vile accusations against me; this was obviously your intention.

I was before the High Court up to very late on the afternoon of October 18, 2 012 and only read your letter (which was delivered to my Chambers

After I returned from Court. Lo and behold on the morning of October 19, 2012 there appeared flashed on the front pages all of the Daily Newspapers the following banner headlines," After Jairam returns brief,

Karl says: STEP DOWN NOW...as Law Association head" (Guardian) "Blame Game. LAWYERS RETURN CLICO BRIEF" (Express) "SEENATH RETURNS CLICO BRIEF...BUT KARL SLAMS CONDUCT (Newsday) with stories carrying the vicious and unfounded allegations you made against me in your letter. Did you send copies of this letter to the Press? Did you not think that as a courtesy to a fellow attorney, you ought to have contacted me for a response before going to the press?

Before I deal with what you haves so unfairly alleged against me, and the unscrupulous and unprofessional person, and the "scab" you have sought to make me out to be, I should like to remind you of our relationship, professional and personal which goes back some two decades. I have to do this to find out from you when did I metamorphose in your eyes into this unworthy attorney.

Preliminaries

Am I not the same person to whom you referred at your 60th birthday celebration at the La Ronde in the presence of prime ministers, senior judges, senior counsel, commissioners of police and others of as one of five persons who have touched you in your life? Over the years, did you not express confidence in my honesty and integrity, both as a person and as an attorney, so much so that at your request I successfully as a Junior represented you personally in several cases before the High Court, including one in which senior counsel had returned your brief, an action which made you very upset? Do you not recall latter that in the case you wanted to know whether I desired to be led by two (2) senior counsel from the region, a request to which I responded in the negative; and I proceeded to obtain judgment in your favour? When did I become this person whose behaviour is unbecoming as an attorney? Am I not the same person who in our earlier years at the bar of whom you said on many occasions that you were sorry that you had not met earlier?

I will now proceed to deal with each of the accusations raised in your letter:

1. Soliciting your support for my candidacy as president of the Law Association.

2. Alleged breach of rules of etiquette in accepting the brief.

3. The Farrell Case.

Soliciting your support for my

candidacy as President of the Law Association:

I never solicited your support for my candidacy as president of the Law Association. Your memory of the telephone conversation I had with you in June of this year is either flawed or you have deliberately distorted what transpired between us on that occasion; In view of the vicious charges and the hostility you have displayed towards me, the latter is more probable.

It was well known in the profession that at one time you were interested in the presidency of the Law Association with Mr Ramesh Lawrence-Maharaj, SC as vice-president; you wished to be unopposed. Sometime later you supported the candidacy of Mr Israel Khan, SC for president when he threw his hat into the ring. You well know as it was widely publicised that Mr Israel Khan, SC made it clear that if you had decided to run for the presidency he was prepared to step down and support you. These matters were common knowledge in the profession.

Against this background and despite our excellent relationship over the years, when I agreed to contest the Presidency, I had no intention of calling you for support. How could I have asked for your support when I knew that Mr Khan ,SC who was also contesting had previously indicated that he was prepared to stand down if you decided to run?

I reluctantly called you in June and sought your views on my candidacy because a colleague, Mr Larry Lalla, who was at my chambers at the time and who knew of our close relationship felt that I should give you a call, and so I did. During our conversation, to which you have referred at the second paragraph of your letter, I want to emphatically state that you never told me:

• That another senior colleague was present.

• That you could not support me because you did not have confidence that my motivation was purely to advance the standing of the profession in Trinidad and Tobago.

• That I was putting myself forward only to ingratiate myself with the executive to get briefs.

Those statements are totally false and untrue.

The true contents of our conversation:

You told me that as silk, I am expected to be a leader of the bar and that I was silent on the two recent issues, i.e. the misappropriation of funds from the Law Association and the recent award of silk. In response, I reminded you that after you had published your letters to the press, you had called me to seek my views and we had a lengthy conversation about the silk issue. I also reminded you (as l had told you previously) that I was going to write letter to the press about the award of silk, but that I had had a very long conversation with one of our senior colleagues (whose name I disclosed to you) and who had persuaded me not to do so. I also told you that I could not comment on the misappropriation of funds from the Law Association as I was advising a member of the council on that issue (whose name I also disclosed to you).

Perhaps because of your insatiable craving for the limelight despite our close relationship and your high regard for me over the years you saw this as an opportunity to get back to centre stage once again. Karl, you denigrated me and used me as your scapegoat to seize media coverage despite our long and close relationship over the years.

Traditions of the Bar

You claim to be the epitome of moral rectitude but it is clear to those of our colleagues who know you well and have seen behind your facade that you are using me as a pawn in you quest for self-aggrandisement. For one who sets himself up on a pedestal and purports to be concerned with upholding the rules of the profession, you have demonstrated s pathetic lack of knowledge of the Legal Profession Act Chap. 90:03 which governs the relationship between attorneys. In that regard you ought to be aware of Part A of the Third Schedule to that Act and in particular Rules 1 and 41 which state as follows:

1. An attorney-at-law shall observe the rules of this code, maintain his integrity and the honour and dignity of the legal profession and encourage other attorneys-at-law to act similarly both in the practice of his profession and in his private life, shall refrain from conduct which is detrimental to the profession or which may tend to discredit it.

41. The conduct of an attorney-at-law towards his fellow attorneys shall be characterised by courtesy, fairness and good faith and he shall not permit ill-feeling between clients to affect his relationship with his colleagues.

It is clear from your letter and your haste to go to the press before calling me that you were not acting in good faith and demonstrated a patent lack of courtesy and fairness. Such conduct is clearly detrimental to the profession, specially from one who purports to hold himself out as the embodiment of ethical correctness and rectitude.

Your conduct was obviously egregious. The text of the letters set out hereunder demonstrate that l fulfilled my obligations in every respect to Mr Fyard Hosein, SC when I accepted the brief from the Ministry of Finance. I now turn to consider this issue.

My contact with previous attorneys:

You have said that Mr Fyard Hosein, SC claims that the only letter he received from me was the letter dated October 8, 2012. Perhaps you should have a word again with Mr Hosein, SC who will tell you that he also received a letter from me dated October 15, 2012; this was in response to his letter to me also dated October 15, 2012. The texts of these letters are important, as also the one I wrote to the permanent secretary of the Ministry of Finance and the Economy concerning fees to Mr Hosein, SC and Mr Quamina as these letters would clearly, demonstrate the falsity of your accusations against me that I have violated the rules of professional conduct and the duties of one attorney to another and Paragraph 48 of the Code of Ethics. The text of these letters are as follows:

In relation to the letter of October 8, 2012 which I sent to Hosein, SC:

"Dear Fyard,

I have been retained by the Ministry of Finance to represent it in the captioned matter. Our colleague Ms Radha Carrie Maharaj spoke with me late on Friday, October 5, 2012 and thereafter issued a letter which was delivered to me on Saturday, October 6 , 2012. Our colleagues Mr Joseph Toney and Mr Jagdeo Singh are my juniors.

As you can imagine, the reading of the material is a very huge task and I have just only begun. However, in keeping with the highest traditions of our profession, I write to you immediately to inform you of our retainer and to say that I trust that satisfactory arrangements are in place or have been made for payment of any or all outstanding legal fees due to both your goodself and your junior(s).

With very best regards,

SEENATH JAIRAM, SC

Hosein, SC's reply on October 15, 2012

"Dear Seenath,

I wish to thank you for your letter of October 8, 2012 which I received on 10th. I was notified of the termination of my retainer late in the evening of the 5th. Accordingly my junior and I have since submitted a bill to the Ministry of Finance. I would be grateful if you could in the tradition of the bar and in accordance paragraph with 48 of the Third Schedule of the Legal Profession Act ensure that our outstanding fees are paid well in advance of the next hearing of the commission.

My best wishes to you and your team.

Regards

Fyard Hosein,S C

Attorney-at-Law

My letter to the permanent secretary Ministry of Finance and the Economy dated October 15, 2012:

"Dear Permanent Secretary,

I refer to correspondence passing between us and respectfully wish to inform you that I have just received a letter dated October 15, 20I2 from my colleague, Mr Fyard Hosein, SC regarding the prompt payment of outstanding fees due to him and his junior Mr Michael Quamina.

As attorney who is replacing Mr Hosein, SC I have a professional obligation to ensure that all outstanding fees have been satisfied in accordance with Paragraph 48 of the Third Schedule of the Legal Profession Act Chap.90:03. For the sake of completeness, I set out here-under the provisions of Paragraph 48:

"48. An attorney-at-law shall not accept instructions to act in court proceedings in which to his knowledge the client has previously been represented by another attorney-at-law, unless he first notifies the other attorney-at-law of the change, and makes reasonable efforts to ensure that attorney has been paid for his services, but shall be deemed to have notified the other attorney-at-law if he has made reasonable efforts to notify him."

Whilst I appreciate that the expression "court proceedings as used in paragraph 48 may have a special meaning, the spirit and tradition of the bar is for the incoming attorney to ensure that all fees are paid to the outgoing attorney in matters of this kind as well as in court proceedings. Mr Hosein, SC has specifically asked me to ensure that their outstanding fees (his and his junior's) are paid well in advance of the next hearing of the commission which is scheduled to commence on October 22, 2012. l therefore respectfully request that this be done in a timely manner to avoid any undue and undesirable complications.

I look forward to your early confirmation that the abovementioned fees owed to Mr Hosein, SC and Mr Quamina have been paid or that satisfactory arrangements have been made with Mr Hosein, SC and his junior for immediate payment.

I thank you in anticipation for your very consideration and co-operation.

Yours faithfully,

SEENATH JAIRAM, SC

cc. Mr Joseph Toney

Mr Jagdeo Singh

Ms Radha Carrie Maharaj

My letter of October 15, 2012 to Hosein, SC:

"Dear Fyard,

I thank you for your letter dated October 15, 2012 and I hasten to respond immediately.

I regret that my letter dated October 8, 2012 only came to your attention on October 10, 2012 but I was assured by my PA, Wendy Alexander that she had in fact delivered it on October 8, 2012 and has so recorded it .

By letter of even date, I have written to the permanent secretary of the Ministry of Finance and Economy requesting that immediate payment be made to your goodself and your junior, Mr Michael Quamina or alternatively, satisfactory arrangements have been made with both of you for immediate payment.

Please therefore let me know as soon as possible of the outcome of my request to the permanent secretary.

With very best regards,

SEENATH JAIRAM, SC

It is clear from the foregoing correspondence that in your anxiety to vilify me you did not bother to ascertain the full facts.

From the facts which I have disclosed it is obvious and I have been advised by senior counsel both of your generation and subsequent that I have fully complied with Paragraph 48 of the Code of Ethics which you have relied upon to castigate me. The same cannot be said of the contents of your letter as complying with Rules 1 and 41 of Part A to the Third Schedule of the Code of Ethics

The Farrell Case

I am quite amazed at the extent to which you have gone to immerse yourself in the conduct of the Farrell case. Your intrusive behaviour, seems merely for the purpose of seeking to acquire ammunition to demean and denigrate me. You called Mr Farrell on the phone and questioned him about the conference to which you referred. That was highly unprofessional and unethical.

As regards your allegation of conflict of interest I have been advised by senior counsel, both of your generation and subsequent thereto, that no conflict arose by my accepting the brief from the Ministry of Finance. However, because of the controversy arising out of this I returned the brief although I was advised that there was no need to do so.

For the record and in order to satisfy your intrusive appetite in this matter as evidenced by your questioning of Mr Farrell, you should note the following:

i. That at a conference on September 27, 2012, it was decided that my limited involvement in the Farrell case had effectively ended.

ii. That a further conference (at which the full legal team was present) which you refer to incorrectly as having been held on October 12, 2012 (when indeed it was held on October 10, 2012) merely confirmed that my limited involvement was at an end.

Self-appointed Guardian of the Ethics of Legal profession

At Paragraph 31 of the decision of the Privy Council in the case of Mantoor Ramdhanie and others v. The state (No. 47 of 2004) [2005] UK PC 47 you are quoted as arrogantly stating in your closing address to the jury as follows:

"You have to fear me when you hear my voice because I speak with moral authority and that is what this country wants and needs sadly to return to its formal rectitude."

When the matter reached the Privy Council you were roundly condemned and criticised by their lordships for what they considered "unfortunate comments" and "pledging [your] own credit for the validity of the prosecution case". In addition your conduct was condemned for impermissible and unfair comments, inconsistent with the high standards required of prosecuting counsel as a minster of justice.

Because of your improper conduct of the case their lordships felt compelled to quash the convictions of the defendants for material irregularity and unfairness in the conduct of the prosecution case.

It is clear that you are the last person in a position to castigate me for failure to uphold the highest traditions of the Bar.

Conclusion

While you sought to berate, denigrate and belittle me by your letter, you demonstrated crass behaviour, not class which is most unfortunate. As we get older, we should become gentler and wiser. Those are the hallmarks of a gentleman and a statesman.

As you have done I am forwarding a copy of this letter to the press,

Yours faithfully,

SEENATH JAIRAM, SC