Funding In Focus - Content Series - Report Three - July 2016

FUNDING IN FOCUS CONTENT SERIES REPORT T HREE JULY 2016 2 | VANNIN CAPITAL Funding in Focus Content Series Welcome Welcome to the third edition of Funding in Focus. Since the inception of Funding in Focus, the funding market has grown and developed. This development is reflected in the number, type and complexity of the cases we are being asked to fund across the globe. We have seen an exponential rise in requests for funding in a range of sectors, including in arbitration and insolvency, and in a range of jurisdictions. This edition of Funding in Focus includes articles from leading practitioners in these areas providing valuable insights about funding in these markets and predictions for future trends and developments in them. Rosemary Ioannou, Editor and Senior Counsel, Vannin Capital 01 Emergency Arbitration: a lasting trend? Written by: Prof. Dr. Kaj Hobér page 3 02 Legal developments and funding in the UAE Written by: Keith Hutchison, Partner, Clyde & Co pages 4 - 7 03 The duration and costs of ICSID and UNCITRAL investment treaty arbitrations Written by: Jeffery Commission, Senior Counsel, Vannin Capital pages 8 - 11 04 Litigation Funding: An Insolvency Practitioner’s perspective Written by: Michael Leeds, Director, and Nick Wood, Partner of the Fraud Insolvency Division (FInD), Grant Thornton UK LLP pages 12 - 14 05 London – arbitration and litigation: who wins, where & why? Written by: Iain McKenny, General Counsel of Disputes, Vannin Capital pages 15 - 21 06 The court steps in: recent developments in the pages 22 - 23 regulation of litigation funding in Australia Written by: Tom McDonald, Counsel, Vannin Capital Contents Funding in Focus Content Series VANNIN CAPITAL | 3 The interim measures addressed in Article 17 are based on the premise that they are granted by an arbitral tribunal established as a result of the arbitration agreement entered into by the parties. In practice however, parties are oftentimes in need of interim measures, both in commercial arbitration and in investment treaty arbitration, before an arbitral tribunal has been established. Typically in the past, in such a situation, parties would have had to go to court to obtain interim measures. Depending on the jurisdiction in question, courts may not however, have been available, or even if available, may not have been perceived as reliable by the party seeking such measures. Starting with the American Arbitration Association’s International Centre for Dispute Resolution (ICDR), emergency arbitration regimes have proliferated. Today most leading arbitration institutions have rules for emergency arbitrations. Such rules were adopted by the SCC in 2010, SIAC in 2010, ICC in 2012, Swiss Rules in 2012, HKIAC in 2013 and the LCIA in 2014. When the 1985 UNCITRAL Model Law on International Commercial Arbitration was amended in 2006, one of the significant amendments was the introduction of Article 17, dealing with various aspects of interim measures, including the recognition and enforcement of such measures. It had been suggested that one critical aspect of the international arbitration regime was lacking, i.e. rules and provisions dealing with interim measures. Article 17 of the amended Model Law was intended to fill that void. The amended Article 17 confirmed, inter alia, that arbitral tribunals do have the power to grant interim measures. London – arbitration and litigation: who wins, where & why? Written by: Iain McKenny, General Counsel of Disputes, Vannin Capital 01 Emergency Arbitration: a lasting trend? The underlying idea is simple: a party may obtain interim relief before an arbitral tribunal has been established. The party seeking emergency relief files a written request with the arbitral institution in question. The institution, having ascertained that it has prima facie jurisdiction, will appoint a sole arbitrator. This arbitrator will render a decision dealing with the application within a very short period of time. There is a steadily growing body of case law in the area. Since 2006 the ICDR is believed to have handled approximately 50 applications for emergency relief, SIAC around 40, the ICC 30 and the SCC approximately 25 (8 of which during the first five months of 2016). The number of applications for emergency relief seems to be growing. A fair number of the applications are being granted. The relief requested varies, but typically concern measures aimed at preserving the status quo; measures aimed at securing the enforcement of the future award; anti-suit injunctions and orders for interim payments. It is still early days concerning requests for emergency relief. Accordingly, no uniform standards for granting such relief are yet discernible. It would seem, however, that emergency arbitrators are increasingly looking at the commercial and factual realities of a given situation, rather than at strict legal criteria, probably more so than a court of law would do. It seems reasonable to assume that this trend will continue. It is worthy of note that the increase in the number of applications for emergency relief is taking place despite the fact that decisions on interim measures are still unenforceable in many jurisdictions. The degree of voluntary compliance with such decisions seems to be relatively high, perhaps because parties will typically not wish to defy instructions given to them by duly appointed arbitrators. ‘It is worthy of note that the increase in the number of applications for emergency relief is taking place despite the fact that decisions on interim measure are still unenforceable in many jurisdictions.’ By Prof. Dr. Kaj Hobér 4 | VANNIN CAPITAL Funding in Focus Content Series Legal developments and funding in theUAE From a local legal practitioner’s view, the Middle East has not been an area of mainstream activity in dispute resolution funding. While there are a few examples of funded disputes here, it is only recently that funding has started to gain more tangible traction with potential litigants and the market has shifted gear. This is in part due to increased knowledge and awareness of funding amongst litigants and lawyers in the region, while developments in local legal systems have helped to shape the landscape into one where funders are more ready to invest. This article outlines some of the reasons why funding is starting to take off in the United Arab Emirates (UAE). Funding in Focus Content Series VANNIN CAPITAL | 5 02 UAE not a traditional market for funding The past 12 months have seen a notable increase in awareness of third party funding in the UAE market, both amongst corporates and legal practitioners. Funding has been, and continues to be, a topic of discussion in legal and financial industry forums. But there is not yet a significant uptake of funding for disputes. What are the reasons for this? Third party funding of litigation or arbitration is not prohibited under UAE law. It is also not a case of an absence of the right kind of disputes – quite the opposite in fact in the UAE since the mid-2000s, particularly with the growth of financial, investment and construction-related disputes. It is fair to say that funders have long seen the UAE’s potential as a market for funding, but until recently have treated it extremely cautiously as an investment opportunity. This is borne out by the very few known examples of funded court litigation (in a relatively small market by size) and no real visibility of the use of funding in local arbitration. This perhaps owes something to the view that Middle Eastern jurisdictions have not traditionally provided the level of certainty and predictability of legal processes and outcomes that a funder may look for. Undoubtedly there are claimants who have been discouraged from pursuing meritorious claims by jurisdictional risks of litigating in the local court systems. Arbitration has also faced challenges over the years in regional jurisdictions, particularly when it comes to upholding the arbitral process and the enforcement of awards. It is therefore unsurprising that funders have until recently found little encouragement to actively fund claims. So, what has changed? Developments From a legal perspective, two significant developments have signalled a change in the outlook for funding: (1) the rise of arbitration as a dispute resolution mechanism with a corresponding improvement in treatment of arbitration by the local courts; and (2) the establishment of financial free zones in Dubai and, much more recently, in Abu Dhabi, with specialist financial courts to support the increase in complex and highvalue commercial transactions and related litigation. The result is a sophisticated legal landscape with international familiarity and increased certainty of process and outcomes. As such, the UAE has become a more attractive jurisdiction to litigants and funders alike. Developing this theme, the remainder of this article considers the Dubai International Financial Centre (DIFC) Courts and the establishment of the Abu Dhabi Global Market (ADGM) to illustrate the current direction of litigation in the UAE. DIFC Courts The DIFC Courts were established nearly 12 years ago. Over the last five years in particular, a steady increase in case load has been accompanied by significant year-on-year growth in aggregate values in dispute. This suggests that more complex cases and higher value cases are being brought before the Courts. The following is a summary of how the DIFC Courts are being used and gives an indication of where funding opportunities may arise: – Sector coverage in DIFC Courts disputes is gradually broadening. Banking and finance related disputes continue to make up a significant ‘funding has started to gain more tangible traction with potential litigants and the market has shifted gear.’ By Keith Hutchison, Partner, Clyde & Co [Continued overleaf] 6 | VANNIN CAPITAL Funding in Focus Content Series ‘what does the UAE offer for claimants and funders? The short answer is: more now than ever before. The UAE is entering a new phase in the way corporates think about litigation and how funding can help achieve a variety of commercial and financial objectives. The next 12-18 months will see a rise of funded cases in the financial courts and in regional arbitration, with the UAE as the focal point. body of the case load, in addition to more commonplace shareholder, property and other commercial contract disputes. Employment disputes are a mainstay of the Small Claims Tribunal, with some larger and more complex employment claims being heard in the Court of First Instance. – In terms of subject matter, the past few years have also seen ‘firsts’ in terms of cases in the DIFC Courts involving, amongst other things, insurance and reinsurance; a derivative shareholder action; professional negligence; litigation funding; construction and education. That is not to say there has been a proliferation of cases from these sectors, but it does indicate a broadening spectrum in the DIFC courts’ case load since the expansion of its jurisdiction in 2011. – As a result of the increasing popularity of the referral of contractual disputes to DIFC-LCIA arbitration, there is also a growing role for the DIFC Courts to play as the supervisory courts for DIFC-seated arbitrations. – A robust and sophisticated DIFC insolvency regime is also likely to be a driver for increased volume of claims in the DIFC Courts going forward. There is a generally heightened awareness of funding amongst DIFC legal practitioners and potential claimants. I have direct recent experience of potential claimants who are actively exploring third party funding for litigation in the DIFC Courts. The DIFC Courts are currently in a period of consultation over a draft Practice Direction in relation to third party funding; a clear recognition of the rise of funding in international litigation and a desire to encourage the use of funding while ensuring minimum standards and protections for parties. An increase in funded cases before the DIFC Courts is therefore anticipated. Developments in DIFC law may also create opportunities for more funded claims. Two particularly noteworthy developments in the past 18 months involve the recognition and enforcement of arbitral awards and foreign judgments through the DIFC Courts as a conduit jurisdiction for enforcement into the wider UAE. This has particular significance where enforcement of arbitration awards and foreign judgments directly through the local courts (i.e. outside the financial free zones) remains a challenging area, although it should be recognised that there have been successes with some local court enforcements of foreign arbitration awards in recent years. The seminal arbitration award enforcement case in the DIFC Courts is Banyan Tree Corporate Pte Ltd v Meydan Group LLC1 (a Clyde & Co case) in which the Courts for the first time ordered the recognition and enforcement of a Dubai-seated DIAC award against a defendant domiciled in Dubai outside the DIFC, in circumstances where neither the parties nor the award had any connection with the DIFC. Many similar award enforcement claims have followed in the wake of Banyan Tree as arbitration award creditors take advantage of the DIFC Courts enforcement regime as a route to enforcement ‘onshore’ and, possibly, beyond through the application of regional treaties. This is a trend I expect will continue. The use of the DIFC Courts as a conduit jurisdiction for enforcement of foreign judgments is a much more recent but equally significant development. In DNB Bank v ASA Gulf Navigation Holding PJSC2 the DIFC Court of Appeal held that the Courts have jurisdiction to recognise Funding in Focus Content Series VANNIN CAPITAL | 7 1 ARB-003-2013 and CA-005-2014. 2 CA-007-2015. 3The DIFC has its own bespoke laws drafted with influence from a number of international jurisdictions. English common law authorities are frequently relied on in legal argument before the DIFC Courts. English common law also provides a default position for DIFC law where the there is no specific DIFC law on a particular issue and no other law otherwise applies according to the application of civil and commercial laws in the DIFC. 4 A period of consultation of the draft Rules is due to close in May 2016. 5 ADGM press release, 19 April 2016. and enforce foreign judgments in circumstances where neither the parties nor the judgment for which enforcement is sought have any connection with the DIFC, and without delimiting the scope of the enforcement to the territory of the DIFC. A track record of successful onward enforcement of such DIFC judgments through local court execution procedures will hopefully follow in time. In conclusion, while there is not a clear pattern of cases coming before the DIFC Courts, save perhaps for the current trend of arbitration award enforcement claims, which is now likely to be followed by an increase in foreign judgment enforcement claims, the DIFC Courts are gradually being used for a growing variety of disputes involving a range of different sectors. As such, the DIFC is likely to be the focus of funding activity in the UAE. Abu Dhabi Global Market The ADGM is a nascent legal jurisdiction established as a financial free zone in Abu Dhabi in 2013. Like the DIFC, the ADGM is a common law jurisdiction with its own judicial authority and court system that is independent of the UAE Federal Ministry of Justice, while being complementary to it. Unlike the DIFC, the ADGM has adopted as its legislative foundation a wholesale importation of English common law together with select English statutes and specifically enacted ADGM laws . There are some carve-outs of provisions of the English statutes which are not relevant or applicable to the ADGM and/or the UAE, or which have been modified or amended under the enacting ADGM legislation to apply in context. This adoption of the laws of another jurisdiction is a particularly novel and intriguing feature of the ADGM that differentiates it from the DIFC. At the time of writing the issuance of procedural rules of the ADGM Courts is imminently anticipated, with the courts themselves expected to be open for business soon thereafter. Lord David Hope (a former judge of the English courts) is appointed as the inaugural Chief Justice, with four other international judges appointed to the bench from England, Australia, New Zealand and Hong Kong. The potential for interaction between the DIFC Courts and the ADGM Courts promises interesting opportunities for inter-Emirate judgment enforcement. This is essential if the ADGM Courts are to enjoy the success of the DIFC Courts. In a promising start, in April 2016 the ADGM Courts and the Abu Dhabi Judicial Department signed a Memorandum of Understanding (MOU) for judicial cooperation in legal and judicial matters. The MOU is to establish a framework for judicial cooperation between the ADGM Courts and the Abu Dhabi courts, specifically with respect of the reciprocal recognition and enforcement of judgments, orders and arbitration awards. The MOU does not have legislative force and is framed as a “sound basis for cooperation and coordination” between the courts . A point of interest to claimants and funders is likely to be whether the ADGM Courts will follow the DIFC in providing a conduit jurisdiction for enforcement of arbitration awards and judgments. Much will depend on the interpretation and application of ADGM’s laws, and it will probably be some time before there is a firm position on the point. Like the DIFC before it, the early years of the ADGM are likely to see jurisdictional issues featuring heavily in the Courts’ caseload, which will in time define more clearly the role the Courts will play in the UAE legal system. The future for funding in the UAE Drawing these themes together, what does the UAE offer for claimants and funders? The short answer is: more now than ever before. The UAE is entering a new phase in the way corporates think about litigation and how funding can help achieve a variety of commercial and financial objectives. The next 12-18 months will see a rise of funded cases in the financial courts and in regional arbitration, with the UAE as the focal point. 8 | VANNIN CAPITAL Funding in Focus Content Series Before making a decision whether or not to invest in any particular investment treaty claim, a third party funder will typically assess six key variables: jurisdiction, liability, quantum, enforcement/recovery, duration, and cost. The last two of these variables – time and costs – are, of course, not only of interest to third party funders, but have come under increased scrutiny by arbitration users more generally. Indeed, in October 2015, the Queen Mary University of London and White & Case International Arbitration Survey reported that cost and lack of speed were both ranked as amongst the worst characteristics of international arbitration. That said, comprehensive and complete details about time and costs in investment treaty arbitrations – namely, how much arbitrations cost and how long they take – have not been made readily available by arbitral institutions until quite recently, and even then, only in part. ‘time and costs – are, of course, not only of interest to third-party funders, but have come under increased scrutiny by arbitration users more generally.’ By Jeffery Commission, Senior Counsel, Vannin Capital 03 duration costs of ICSID and UNCITRAL investment treaty arbitrations The and As for ICSID, although it has provided an increasing level of detail and transparency regarding the duration of ICSID Convention and ICSID Additional Facility arbitrations in the last five years, it has not adopted the same approach with respect to costs. For instance, since 2010 ICSID has published details of the average duration of arbitrations in its annual reports, a period typically “between three to four years”. Costs incurred by claimants and respondents in ICSID arbitrations, however, are amounts not made readily available by the institution in published reports, but which ICSID acknowledges “could be substantial”. In terms of UNCITRAL treaty arbitrations, as there is no equivalent institution to report on all investment arbitrations conducted under the UNCITRAL Arbitration Rules – to the extent an institution is even involved – there is a paucity of data on duration and costs available. In the absence of transparency from institutions, observers and users of the system have compiled details about the duration and costs of ICSID and UNCITRAL arbitrations on their own. For instance, in October 2009, prior to the publication of ICSID’s first statistical report, an oft-cited article published in Global Arbitration Review (“ICSID arbitration: how long does it take?” by Anthony Sinclair) featured the first detailed accounting of how long each phase of an ICSID arbitration takes. There it was reported that the average time between a hearing on the merits and an award is 425 days. That finding was based on a review of the 115 ICSID cases resulting in an award from ICSID’s creation until 1 July 2009. No such study has been taken of the duration of UNCITRAL arbitrations. On the subject of costs, in 2012, the OECD concluded that legal and arbitration costs for claimants and respondents in recent Investor-state Dispute Settlement cases averaged in excess of US$8,000,000, having surveyed 143 ISDS awards (available as of August 2011). In 2013, UNCTAD reported that legal fees and tribunal expenses, on average, “exceeded $8 million per party per case”. In 2014, an Allen & Overy study concluded that average party Funding in Focus Content Series VANNIN CAPITAL | 9 The duration of ICSID and UNCITRAL arbitration proceedings ICSID arbitration proceedings Writing in the winter 1986 edition of News from ICSID about the duration of arbitration proceedings, the centre’s then secretary general Ibrahim Shihata observed that “statistics regarding the average duration of such proceedings have little value because of the many factors that may differentiate one proceeding from another”. To recall, at that time, only five arbitration proceedings were pending at ICSID and no new case had been registered all year, as explained by Shihata in ICSID’s 1986 Annual Report. Fast forward 30 years, and, in January 2016, ICSID reported that it had registered 549 cases under the ICSID Convention and Additional Facility Rules as of 31 December 2015. This was reported not in News from ICSID (discontinued since 2009), but in The ICSID Caseload-Statistics, a bi-annual publication started in 2010 that is dedicated to featuring empirical details about aspects of international investment cases administered by ICSID. At the same time, ICSID began publishing details of the average duration of arbitrations in its annual reports. In so doing, it calculated the duration of arbitrations from the date of a tribunal’s constitution to conclusion, reporting for the last six fiscal years (lasting from 1 July to 30 June). For instance, for FY2015, the average duration was reported to be “on average, 39 months” As explained in Global Arbitration Review earlier this year, Vannin Capital has released data on the average duration of ICSID Convention and Additional Facility proceedings. There, it was explained that the average duration of such proceedings – from registration to award – was 3.75 years, or 1,370 days. Anthony Sinclair arrived at a similar figure in his Global Arbitration Review study concluding then that the average duration of ICSID arbitrations was 3.63 years (1,325 days), on average, from filing of the request for arbitration to the date of the final award. Proceedings resulting in a final award Days between registration and award ICSID arbitration (mean) 1,370 ICSID arbitration (median) 1,266 To that figure must be added the duration of the most prevalent of the post-award remedies in ICSID Convention arbitrations, annulment. As of 31 December 2015, 45 decisions on annulment have been rendered since ICSID’s inception. The average amount of time between registration of a request for annulment and the issuance of a decision on annulment was 2 years (730 days). Proceedings resulting in a decision on annulment Days between registration and award ICSID annulment (mean) 730 ICSID annulment (median) 720 UNCITRAL arbitration proceedings There is, of course, no equivalent institution to report on all investment arbitrations conducted under the UNCITRAL Arbitration Rules. A review of the 60 publicly available investment arbitrations conducted under the UNCITRAL Arbitration Rules resulting in an award between 1990 and 2015 reveals that the average duration of an UNCITRAL arbitration from notice of arbitration to award is 3.96 years, or 1,446 days. Proceedings resulting in a final award Days between registration and award UNCITRAL arbitration (mean) 1,446 ICSID arbitration (median) 1,246 As post-award proceedings in UNCITRAL arbitrations vary depending on the seat of the arbitration, a review of the duration of such proceedings is beyond the scope of this article. ‘the average duration of an UNCITRAL arbitration from notice of arbitration to award is 3.96 years, or 1,446 days.‘ costs were US$4,437,000 for claimants and US$4,559,000 for respondents based on a review of 176 ISDS awards (available as of December 2012). Last year, in 2015, the European Commission suggested in a paper entitled “ISDS: some facts and figures” that “the average legal and arbitration costs for a claimant are around US$8 million”. (In fact, the OECD research to which UNCTAD and the European Commission referred indicated that costs for both parties combined was in excess of US$8 million, not costs incurred by only one party). Here, in an effort to supplement these previous studies with more up-to-date duration and costs data in ICSID and UNCITRAL arbitrations – current as of 31 December 2015 – Vannin Capital presents the most recent information publicly available on these two key variables. [Continued overleaf] 10 | VANNIN CAPITAL Funding in Focus Content Series The costs of ICSID and UNCITRAL arbitration proceedings In the last five years (FY2011 – FY2015), a review of ICSID arbitrations concluded reveals that the average amounts spent were US$5,619,261.74 by claimants and US$4,954,461.27 by respondents, as explained in more detail below. A similar review of UNCITRAL treaty arbitrations concluded in the last five calendar years (2010 – 2015) shows an average claimant spend of US$7,300,344.91 and respondent spend of US$4,709,504.30. ICSID arbitration proceedings In the last five years, a total of 138 ICSID arbitration proceedings were concluded between FY2011 and FY2015. Data on costs in ICSID arbitrations concluded between FY2011 and FY2015 is available for claimants in 55 arbitrations and respondents in 56 arbitrations. Costs data in many of the 93 decisions and awards is not available for one of three reasons: (a) the award is not yet publicly available; (b) the award is publicly available but costs data was not included; or (c) some but not all costs data is included in the award. Details on tribunal costs are available in 40 awards. Any cost amounts not denominated in USD were converted to USD as of the date of award. The average claimant costs in the 55 ICSID arbitrations concluded between FY2011 and FY2015, where such information was available, was US$5,619,261.74. In 64% of the arbitrations claimant costs were below US$5 million, and above US$5 million in 36%: Claimant Costs in Concluded ICSID Arbitrations FY2011-FY2015 Number of arbitrations US$1 million and less 9 US$1-2 million 10 US$2-3 million 9 US$3-4 million 4 US$4-5 million 3 US$5 million and above 20 TOTAL 55 In the 56 ICSID arbitrations concluded between FY2011-FY2015 where respondent costs data was available, average costs were US$4,954,461.27. In 68% of the arbitrations, respondent costs were below US$5 million, and above US$5 million in 32%: Respondent Costs in Concluded ICSID Arbitrations FY2011-FY2015 Number of arbitrations US$1 million and less 13 US$1-2 million 9 US$2-3 million 2 US$3-4 million 6 US$4-5 million 8 US$5 million and above 18 TOTAL 56 As with previous studies, the median figures for both claimant and respondent costs are significantly lower than the averages: US$2,913,786.50 in the case of claimant costs, US$3,650,252.62 in respondent costs. In 40 of the 93 arbitrations, awards included data about tribunal costs incurred. The average tribunal costs were US$882,668.19, with a median of US$875,907.97. In the majority of the ICSID arbitrations concluded in FY2011-FY2015 where tribunal costs data was available, such costs were US$1 million or less: ICSID/Tribunal Costs in Concluded ICSID Arbitrations FY2011-FY2015 Number of arbitrations US$1 million and less 27 US$1-2 million 12 US$2-3 million 0 US$3-4 million 1 TOTAL 40 Claimant Costs in Concluded UNCITRAL Arbitrations 2010 – 2015 Number of arbitrations US$1 million and less 2 US$1-2 million 5 US$2-3 million 7 US$3-4 million 2 US$4-5 million 0 US$5 million and above 4 TOTAL 20 In 26 UNCITRAL arbitrations concluded between 2010 and 2015 where respondent costs data was available, average costs were US$4,709,504.30. In 73% of the arbitrations, respondent costs were below US$5 million, and above US$5 million in 27%: Respondent Costs in Concluded UNCITRAL Arbitrations 2010 – 2015 Number of arbitrations US$1 million and less 7 US$1-2 million 5 US$2-3 million 4 US$3-4 million 0 US$4-5 million 3 US$5 million and above 7 TOTAL 26 In the majority of the UNCITRAL arbitrations concluded between 2010 and 2015, where institutional/tribunal costs data was available, such costs were US$1 million or less: Institutional/Tribunal Costs in Concluded UNCITRAL Arbitrations 2010 – 2015 Number of arbitrations US$1 million and less 22 US$1-2 million 4 US$2-3 million 1 US$3 million and above 1 TOTAL 28 The underlying data on duration and costs referenced in these studies will be available in appendices to the forthcoming monograph Procedural Issues in International Investment Arbitration (Oxford University Press, 2016) co-authored by Vannin Capital’s Senior Counsel Jeffery Commission. UNCITRAL arbitration proceedings Between 2010 and 2015, a total of 40 UNCITRAL arbitration proceedings were concluded, resulting in a final decision or award. Data on costs in those 40 arbitrations is available for claimants in 20 arbitrations and respondents in 26 arbitrations. Details on tribunal costs are available in 28 awards. The average claimant costs in the 20 UNCITRAL arbitrations concluded between 2010 – 2015, where such information was available was US$7,300,344.91. In 80% of the arbitrations claimant costs were below US$5 million, and above US$5 million in 20%: Funding in Focus Content Series VANNIN CAPITAL | 11 ‘In the last five years (FY2011 – FY2015), a review of ICSID arbitrations concluded reveals that the average amounts spent were US$5,619,261.74 by claimants and US$4,954,461.27 by respondents.’ 12 | VANNIN CAPITAL Funding in Focus Content Series ‘Indeed, without funding, it may not be possible to bring the claim at all.’ Funding in Focus Content Series VANNIN CAPITAL | 13 In many insolvency cases there are likely to be limited assets or, in especially desperate cases, no assets at all. So, how can the Insolvency Practitioner (IP) realise value for the creditors if there is a suspicion that assets have been dissipated and there is an angry creditor (or angry creditors) who want their money back? ‘The key to a successful asset tracing and recovery case is to have the right team in place.‘ By Michael Leeds, Director, and Nick Wood, Partner of the Fraud Insolvency Division(FInD), Grant Thornton UK LLP 04 A number of cases within our FInD portfolio have no assets and yet either fraud is suspected or there may be potential claims against third parties. We are engaged on the following scenarios: 1. Assisting with the enforcement of an unsatisfied arbitration award. 2. Pursuing a former employee who has had their hand in the till. 3. Acting as a Receiver over specific assets. 4. Assisting a judgment creditor with enforcing the debt. 5. Pursuing delinquent directors. Usually there are pro-active creditors looking for a route to money where they have been unable to recover anything. They have taken steps to put the company into an insolvency process to enable an investigation to be undertaken and assets recovered using the powers given to the IP under the Insolvency Act 1986. As set out above it is often the case that an insolvent company will have no assets on its balance sheet and no cash at bank. What the IP focusses on is recovering assets which are off the balance sheet. Is there a misfeasance claim against the directors who caused the collapse of the company or is there a claim for wrongful trading against them? Or have assets been intentionally stripped out of the company and transferred to third parties which can be recovered by the IP? The key to a successful asset tracing and recovery case is to have the right team in place, with the right expertise in the right jurisdictions who work collaboratively as a genuine team. This includes onshore solicitors, counsel, offshore solicitors, digital forensic experts and investigators. This is pricey….so access to funding can be critical. Much is made of identifying and then recovering ‘low-hanging fruit’ on insolvency cases, but in practice it is rarely there to pick. There may be some debtors or a VAT refund available but the reality is that, even if such assets can be brought into an Estate, there will be insufficient cash to fund a meaty £multi-million claim against a party that has taken your money…the stakes are high, so how can you get a case up and running? There are a number of things an IP can do: 1. Go all in and enter into a Conditional Fee Arrangement, bringing all your external team into the same arrangement. This sounds good in principle, but what if your lawyer loses interest in the case because there is a case with cash in it elsewhere? The case can soon de-rail. Will your other partners support you incurring significant work in progress, with the attendant risk? 2. Fund the Disbursements yourself. This depends on how much cash you have available. Can you afford to spend £1 million? 3. Secure Disbursements funding. This enables the case to get going – bringing in investigators, offshore lawyers to recover information etc. 4. Obtain funding from a creditor. Having already lost potentially £millions, creditors are often reluctant to contribute more. 5. Bring in a litigation funder to fund claims. The IP’s dilemma The role of the IP is to distribute the company’s assets to creditors by maximising realisations and minimising costs. This is an important consideration in the decision about how to fund a case. The decision to self-fund or seek external funding comes down to price and the appetite of your other partners. This scenario creates tension in insolvency cases where funding is required given the costs associated with taking such an approach. Here is an example of how this dilemma works in practice. The IP has identified a property where a bankrupt individual resides, however, it is held by a third party. The property is worth £10 million and is unencumbered. Following an investigation, the IP believes that there is a claim that can be brought that will bring the property into the bankruptcy estate. Let’s assume that this Litigation Funding: An Insolvency Practitioner’s perspective [Continued overleaf] 14 | VANNIN CAPITAL Funding in Focus Content Series claim will be hotly contested, therefore how does the IP maximise the recoveries? If they go down the route of bringing the claim then it could be difficult to do so on an unfunded basis so funding is required. Different litigation funders offer different funding options and investment terms. As an IP it is important to ensure that you are acting in the best interests of the creditors. This means ensuring that the funding terms offered are reasonable in all of the circumstances. What this means in practice varies on a case by case basis and is normally dependent upon a balance between the value of the claim and the level of funding required. Funding is not always the cheapest solution but, as noted above, it may be the most commercial. Indeed, without funding, it may not be possible to bring the claim at all. If the IP and legal team acted on a CFA, the creditors are unlikely to be better offer and, in practice, that commitment can be difficult so funding on a non-recourse basis is more attractive. And, if a creditor is unwilling to invest further sums, then there should be some uplift for a party that is willing to take the risk of funding the case on. However, it is often a difficult judgement call for the IP to make when assessing the funding route and requires scenario planning. Factors for the IP and Funders to consider There are a number of factors that the IP and the Funder will take into account when deciding whether to fund a case or not, as follows: • Working with an IP. We tend to find that funders can be more comfortable going into battle with an IP, given that they are a professional, have some skin in the game and are therefore less likely to seek funding on hopeless or speculative cases. There is unlikely to be any emotion in the decision to litigate against a party on the part of the IP, unlike with an aggrieved litigant. • Legal merits. Funders will undertake their own due-diligence to assess the legal merits of any case. This means engaging with a lawyer or barrister to provide an opinion on the case. Claimants must have a strong case before issuing a decision to fund. Looking at a case ‘cold’ has both upsides and downsides as far as the IP is concerned. • Number of cases and level of funding sought. Size does matter when it comes to litigation funding because potential funders will evaluate the time and resources required to pursue a claim. Bringing multiple cases to the same funder can also help reduce the cost of funding so an IP with a portfolio of cases may seek to enter into an exclusive arrangement with a funder. • Recoverability of assets and perception of risk. Funders seek assurances that, even in the strongest of legal cases, a defendant has the requisite assets to pay a claimant and that these assets can be recovered easily following a judgment. It is important to identify assets to enforce against and often there can be difficulties if assets are hidden in offshore structures. There is no point going after a pyrrhic victory. Funders will look at the recoverability of assets and in practice an IP should have undertaken that exercise themselves before seeking funding. If they have obtained freezing orders or restrictions, even better! • External or commercial factors. Litigation funders are likely to look at cases holistically, spending time evaluating the external or commercial factors that might have a positive or negative influence on the outcome of a case. These factors are likely to put pressure on a defendant to reach a settlement. • Claims record and relationship with IP. A strong track record in similar types of disputes gives litigation funders greater confidence about the chances of success in subsequent matters. Similarly, a close working relationship with individual IPs or legal teams can eliminate levels of uncertainty for potential funders; they are more likely to provide funding to firms they find easy to work with. • Funders will require an ATE insurance product. This will protect the IP against adverse costs but also protects the funder against a court order that says the third party pays the other side’s costs. So, overall, there are a number of factors to consider when considering funding for both the IP and the funder. Cost will always be a key concern for the IP and merits of the case and recoverability of assets will be on the agenda for the Funder. Saying that, the insolvency funding market is developing and we expect to see an on-going evolution of the products offered, which is good for IPs and claimants more generally. Going forward, we expect to see: (1) funders taking on more risk when assessing their cases with IPs; (2) new innovation such as partial funding or disbursement funding becoming more widely available and different funding models; (3) better recovery rates for the insolvent estate, given that the funds are to be distributed to the creditors; (4) a quicker turnaround on funding requests; and (5) more participants in the funding market. ‘As an IP it is important to ensure that you are acting in the best interests of the creditors. This means ensuring that the funding terms offered are reasonable in all of the circumstances.’ Funding in Focus Content Series VANNIN CAPITAL | 15 The disputes market in London Before delving into the analysis, we need to consider briefly the dispute climate that we are in and ask; what is generating the disputes work in the City? Well, the financial crisis of 2008 including the collapse of Lehman Brothers and the Icelandic banking system still generate a great many disputes. Third party funders continue to be approached by claimants who claim damage and loss caused by the actions of financial institutions which have included allegations of dishonesty, mis-selling and various breach of duty obligations. We have also seen the rouble decline and a plummet in oil prices which have loosened restraints on many more disputes. Finally, the City continues to pick up a tremendous amount of cross border dispute work in the field of international arbitration – both commercial and treaty disputes as claimants continue to use English law to govern contracts and London remains a popular choice for arbitral seats. At a time where financial markets are eking out meagre returns, the legal market in London continues to move from strength to strength. Good news for professional third party funders who continue to responsibly trail blaze investment into this de-correlated asset class. The types of claimants We must also consider the different types of claimants that we see and what criteria they use in choosing a legal team. From a funding perspective we see three general types of claimant: - Claimants seeking access to justice which they could not otherwise afford; - Small and medium size companies for whom cash flow is key; and - Larger corporations seeking partnership to augment their legal budgets. The access to justice claimants are typically new to the world of legal disputes; stricken hard by the harm they have suffered and often need immediate legal assistance. For these claimants, time is usually the decisive factor and we typically identify the legal team who we know are experienced with the type of dispute and effectively bring the dispute to them. The SME’s are more familiar with the legal wrangling of the dispute but are focussed on growing their business and the prospect of a lengthy dispute has a severe impact 05 who wins, where & why? London–arbitration and litigation: The sector view In this edition of “Who wins, where and why?” we narrow our gaze to the big smoke and ask which legal teams in the city are winning for their claimant clients and why? What drove this piece is a growing trend where claimants have approached Vannin not only for the benefits of transferring the financial risk to a third party but either to know which legal team to appoint or in some instances to run a tender process among the top legal teams in the City. As one of the most active funders in the world, we meet and work with a lot of legal teams and we make it our business to get to know the teams that are making the difference. Our motto is simple: meritorious claims, run by the best. It is a sincere sentiment and strategy that has greatly benefited us, the legal teams that we work with and most of all the claimants whom we support. ‘The sophistication of financial legal risk transfer has grown significantly over the last 5 years.’ By Iain McKenny, General Counsel of Disputes, Vannin Capital [Continued overleaf] 16 | VANNIN CAPITAL Funding in Focus Content Series on their cash flow. For these claimants, subject to urgency, they want more of a choice. They want to know not only the team best equipped but also the team with whom they can envision themselves working over the next few years and often longer. It is usually a very personal choice, where the claimant seeks a connection with the legal team whom they can trust to look after their best interests while the claimant continues to grow the business. The larger corporations however typically have in-house counsel that have been nurturing the dispute to the point where they need external legal support. This is a much slower, careful process where we work closely with the in-house counsel to identify the strengths and weaknesses of a dispute or multiple disputes. This type of claimant often balances a fixed legal budget against the knowledge that paying for a legal team to go the extra mile can make all the difference. It is in these situations where a third party legal budget facility can be used to maximum effect to ensure that the claim remains at the top of the successful legal team’s list of priorities. Essentially, the claimant here caps its legal spend exposure while using the third party funder’s facility to pay for the budget in excess of their capped budget. Managing litigation or arbitration risk Despite the differences between these three general types of claimant, they are all trying to do the same thing. They are trying to manage dispute risk. This is an essential component of every discussion we have with claimants. What is risk and how can it be managed? Put simply, risk is the relationship between impact and probability. For disputes; what is the likelihood of success versus the impact of a loss? In this assessment a claimant must consider the four Ts of risk management. - Terminate - Tolerate - Transfer - Treat This is not a new concept and often our claimant clients know more about this than either we do or, indeed, the legal teams with whom we work. It is an essential risk matrix methodology and management tool taught in business schools all around the world. It is often how our claimant clients not only decide whether they will commence a dispute but also, how to manage it. The first question; what is the likelihood of success versus the impact of a loss? This is essentially the domain of terminate and tolerate. Is there a way to avoid a formal dispute process? Is it worth tolerating for the good of a fruitful relationship? Is there a pre-dispute settlement scenario that is tolerable? Are the facts too thin or the law too uncertain to proceed? These are the questions that any claimant, regardless of size or sophistication must consider before bringing a formal legal action against another company or a State. The domains of transfer and treat in the context of a dispute are essential considerations for when the impact of losing is outweighed by the prospects of success. How do you treat dispute risk and how do you transfer dispute risk? The latter is third party funders, adverse cost insurance and more recently, award default insurance. It is now possible for a claimant to transfer the financial risk of running a dispute to a third party funder, transfer the risk of an adverse costs award to an ATE provider and have an insurer guarantee payment of an award or part of an award against a respondent in the event that the respondent doesn’t pay (typically in the field of investment treaty arbitration and within 120 days of the award being rendered). The sophistication of financial legal risk transfer has grown significantly over the last 5 years. Treatment of dispute risk is all about ensuring that the claimant’s witnesses are able and willing, that the claimant’s claims are backed up by strong independent expert evidence and essentially that the legal team has the experience, talent and time to manage the dispute as its first priority. Transfer of legal risk may get the claimant comfortable with the decision of whether to launch a dispute or not but it is treatment of legal risk and specifically the legal team chosen, that can make all the difference between a case that wins and a case that does not. It is to legal teams, specifically in London, that we must now focus on. Parameters: Let’s be clear, this is no easy task. The City of London houses some of the best legal teams in the world. Claimants flock from around the world to this hub of legal excellence not only for a superb legal system, light years ahead of many others, but for the highest quality of legal counsel from whom to choose. In this analysis we must pit the full service law firm against the specialist boutique. We must peel back the brand and focus on the legal teams winning the cases and then we must focus on what is it that these teams are doing that bring success to them and their clients. First, some hard decisions need to be made in order to prevent unwieldy article sprawl. Restrictions must be imposed for fear of reducing all analysis to mere correlations. Evidently we are focussed on claims. For this purpose, we have restricted the dispute sector to International Arbitration (commercial and treaty) and Commercial Litigation. We have restricted the legal market to those legal teams in London (we look forward to a future article where we do the same in Paris, and across the decentralised German legal market for example). Ultimately, ambitiously, we want to try to understand what makes for a great legal team. We therefore collate, refine and distil our analysis on London’s legal teams as follows: • Collation: We identified the top 10 firms as widely reported as dominating the disputes sector from popular legal rankings including The Legal 500 and Table 2: Global Arbitration Review, The Lawyer and Legal Week Synthesis - Top 10 firms in arbitration and commercial litigation in London (alphabetical): Allen & Overy Clifford Chance Debevoise & Plimpton Freshfields Bruckhaus Deringer Herbert Smith Freehills Hogan Lovells International King & Spalding Sherman & Sterling White & Case WilmerHale Pickering Hale and Dorr Table 1: The Legal 500 and Chambers & Partners synthesis: Top 10 in arbitration and commercial litigation firms in London (alphabetical) Allen & Overy Clifford Chance Debevoise & Plimpton Freshfields Bruckhaus Deringer Herbert Smith Freehills Hogan Lovells International Slaughter and May Skadden, Arps, Slate, Meagher & Flom White & Case WilmerHale ‘the claimant seeks a connection with the legal team whom they can trust to look after their best interests while the claimant continues to grow the business.’ Funding in Focus Content Series VANNIN CAPITAL | 17 LITIGATION: Partner Associate ARBITRATION: Partner Associate Allen & Overy Clifford Chance Debevoise & Plimpton Freshfields Bruckhaus Deringer Herbert Smith Freehills Hogan Lovells International Skadden, Arps, Slate, Meagher & Flom White & Case WilmerHale 100 30 23 9 11 26 3 12 40 21 9 12 60 21 20 4 178 21 39 5 196 22 54 9 40 27 6 6 276 16 54 6 100 200 300 0 Chambers and Partners (see table 1). • Refinement: We went to the legal journals including Global Arbitration Review, The Lawyer, Legal Week and International Arbitration Reporter and collected relevant assessments and reports over the last 2 years (see table 2). • Distillation: We used publically available information from services such as the Investor State Law Review and various pitch documents and presentations from the firms with whom we have worked. Collation, refinement, distillation – all good systems that helped us identify how others have seen and reported on legal teams. Useful information undoubtedly but somehow incomplete. To tie this analysis together, to peel back the brand we need empirical evidence. Empirical evidence We asked 9 recent commercial litigation claimants and 9 recent arbitration claimants of varying sizes who have sought funding from us who are the firms that they thought of when considering a legal team for their dispute. We have taken these results and identified these legal teams on our map of London. The results from this empirical assessment are not too dissimilar from the collation, refinement and distillation exercise, but with a few surprises. These are clearly not the only legal teams that come to mind and with whom we are proud to work, but in this recent survey they topped the charts among a diverse array of claimants and added a strong empirical comparison to the wider lens analysis that we have undertaken. These are the legal teams who continue to impress us and their claimant clients with their skill, dedication and commitment to excellence. Plunging further into this empirical evidence, we asked each of the legal teams identified by these claimant clients what are the top five issues that make the difference between winning a case and not winning. Their answers, reproduced on the map, reveal a 7 step recipe for success, summarised as follows: • Own the facts • Understand the claimant • Research your opponent and its legal team • Understand the judge/arbitrator(s) • Be reasonable • Never overinflate the claim • Good, clear, concise pleadings and advocacy These are undoubtedly points which most arbitration and litigation teams in the City will agree with but there is a significant difference between knowing them and experiencing them. The key is not in understanding that these issues are important – this we expect from every law firm we work with and to explain to every claimant we work with. The key is in understanding from experience how to achieve them. Arbitration practice vs litigation practice by firm showing partner to associate ratio in London [Continued overleaf] 28 5 48 7 18 | VANNIN CAPITAL Funding in Focus Content Series BOROUGH OF GREENWIC H BOROUGH OF LEWISHAM BOROUGH OF W A NDSWOR T H BOROUGH OF RICHMON D BOROUGH OF L AMBET H BOROUGH OF SOUTHW A R K BOROUGH OF NEWHAM BOROUGH OF C AMDEN BOROUGH OF BREN T BOROUGH OF ISLING T O N BOROUGH OF HACKNE Y BOROUGH OF H AMMERSMITH & FULHAM BOROUGH OF KENSING T O N & CHELSEA CITY OF W ESTMINSTE R C ITY OF LONDO N BOROUGH OF T OWER HAMLETS CLERKENWELL SHOREDITCH SPI TA LFIELDS W A PPIN G SHADWELL STEPNE Y LIMEHOUS E MILE EN D B O W GLOB E T O W N BROMLE Y STRATFORD P LAIST O W S I LV E R T O W N WOOLWIC H KIDBROOK E LEWISHAM NEW CROSS PECKHAM EAS T DULWICH DULWIC H NUNHEAD HONOR OA K BROCKLEY FOREST HILL CHARLT O N BECKT O N U P T O N PA R K U P T O N POPLAR DOCKLAND S MILLW A L L GREENWIC H PENINSULA GREENWIC H DEPTFOR D SURREY QU AY S ROTHERHITH E BLACKHEAT H E LTHAM ISLE OF DOGS HOXT O N DALS T O N HACKNE Y HACKNE Y WIC K BETHNA L GREE N HOLBOR N COVEN T GARDEN SOHO S T JAMES’ S PIMLIC O CHELSEA KNIGHTSBRIDGE BELGR AV I A L AMBET H B ATTERSEA W A NDSWOR TH T O W N SOUTHFIELD S EARLSFIEL D W EST HILL PUTNEY BARNE S FULHAM EAR L ’ S COUR T H AMMERSMITH W EST KENSING T O N SHEPHERD’S BUSH CHELSEA HARBOU R ROEHAMPT O N CLAPHAM S T OCKWEL L KENNING T O N BRIX T O N HERNE HILL TULSE HILL STRE AT HAM HILL CLAPHAM PA R K SOUTHW A R K BOROUG H W A LWOR T H CAMBER WELL BERMONDSEY SOUTH BAN K W ESTMINSTE R PA DDINGT O N B AYSW AT E R NOTTING HILL N O R T H KENSING T O N KENSAL T O W N KENSAL GREEN KILBURN BRONDESBU R Y WILLESDEN GREEN MAR YLEBONE MAIDA VA L E S T JOHN’S WOOD PRIMROSE HILL C AMDEN T O W N KENTISH T OWN KINGS CROS S ISLING T O N BARNSBU R Y CANONBUR Y DE BEAUVOIR T O W N HIGHBU R Y SOUTH HAMPSTEAD W EST HAMPSTEAD M AY FA I R KENSING T O N BLOOMSBU R Y Canary Wharf West India Quay Westferry Stepney Green Whitechapel Shadwell Limehouse Wapping Rotherhithe Bermondsey Canada Water Surrey Quays Poplar Blackwall East India All Saints Langdon Park Devons Road Bow Church Bow Road Bromley-by-Bow West Ham Abbey Road Star Lane Canning Town Royal Victoria West Silvertown Pontoon Dock Custom House Prince Regent Royal Albert London City Airport Plaistow Pudding Mill Lane Stratford High Street Stratford Maryland Wanstead Park Forest Gate Manor Park Woodgrange Park Upton Park Stratford International Hackney Wick London Fields Homerton Hackney Central Hackney Downs Dalston Kingsland Dalston Junction Haggerston Mile End Bethnal Green Bethnal Green Cambridge Heath Hoxton Heron Quays Canary Wharf North Greenwich South Quay Crossharbour Mudchute Island Gardens Cutty Sark Greenwich Deptford Bridge Elverson Road Deptford New Cross New Cross Gate ELL Queens Road Peckham South Bermondsey Maze Hill Charlton Westcombe Park Edgware Road Baker Street Marylebone Goodge Street Regent’s Park Great Portland Street Warren Street Euston Square Mornington Crescent Camden Town Camden Road Chalk Farm Kentish Town West Kentish Town Gospel Oak Hampstead Heath Finchley Road & Frognal Belsize Park Finchley Road West Hampstead Thameslink West Hampstead Kilburn Willesden Green Dollis Hill Brondesbury Park Queens Park Kilburn Park Kensal Rise Willesden Junction Kensal Green Brondesbury Swiss Cottage South Hampstead Kilburn High Road St John’s Wood Russell Square Euston King’s Cross Angel Essex Road Highbury & Islington Canonbury Caledonian Road Caledonian Road & Barnsbury Holloway Road Drayton Park St Pancras Maida Vale Paddington Marble Arch Bond Street Tottenham Court Road Oxford Circus Lancaster Gate Old Street Moorgate Blackfriars Temple Holborn Farringdon Barbican Chancery Lane Covent Garden Embankment Westminster Pimlico Vauxhall Oval Stockwell Battersea Park Queenstown Road Imperial Wharf Fulham Broadway West Brompton West Kensington Earl’s Court Barons Court Hammersmith Kensington Olympia Shepherd’s Bush Shepherd’s Bush Market Goldhawk Road Wood Lane White City Latimer Road Ladbroke Grove Westbourne Park Holland Park Notting Hill Gate Queensway Bayswater Royal Oak Warwick Avenue East Acton Ravenscourt Park Stamford Brook Parsons Green Putney Bridge Barnes Wandsworth Road Clapham North Brixton Loughborough Junction Denmark Hill Peckham Rye East Dulwich Honor Oak Park Forest Hill Catford Catford Bridge Hither Green Lee Kidbrooke Blackheath Crofton Park Brockley St Johns Lewisham Ladywell Nunhead North Dulwich Herne Hill Clapham Common Clapham South Wandsworth Common Earlsfield Southfields East Putney Putney Balham Streatham Hill Clapham Junction Wandsworth Town Clapham High Street Kennington Elephant & Castle Lambeth North Southwark Borough London Bridge Waterloo Waterloo East Piccadilly Circus Green Park Knightsbridge South Kensington Gloucester Road High Street Kensington Sloane Square Victoria St James’s Park Hyde Park Corner Leicester Square Charing Cross Cannon Street Mansion House Liverpool Street Aldgate Tower Hill Tower Gateway Monument Aldgate East Fenchurch Street Shoreditch High Street Central Street Moreland Street Spencer Street Myddelton St Exmouth Market Margery Street Great Percy St Amwell Street Blundell Street Sheringham Road Halton Street Rippleford Grove Thornhill Road Huntingdon Street Tolpuddle Street Rodney Str eet Cloudesley Road Carnegie St Donegal Street Colebrooke Row Elizabeth Ave Ecclesbourne Rd Britannia Row Alwyne Road Canonbury Cr Ockendon Road Oakley Road Elmore Street Shepperton Street Popham Street Basire Street StPeter’s Street Noel Road St Paul Street Linton Street Arlington Avenue Wenlock St Wenlock Road Murray Grove Nile Street Chart St Hoxton Street Mintern Street Hyde Rd Bridport Place Phillipp Street Crondall St Falkirk St Nuttall St Pitfield Street Hoxton Street Orsman Road Downham Road Hertford Road Road Hertford Ardleigh Rd Culford Road Englefield Rd De Beauvoir Road Buckingham Rd Tottenham Road Stamford Road Albion Drive Forest Road Richmond Road Middleton Road Hol yl Street Whiston Road Brownlow Road Haggerston Road Laburnum Street How’s Street Appleby Street Queensbridge Road Dunloe Street Quaker Street Buxton Street Bacon Street Virginia Road Swanfield Street Calvert Ave Club Row Derbyshire Street Vallance Road St Matthew’s Row Wellington Row Columbia Road Columbia Road Gosset Street Corfield Street Wilmot Street W estfield Way Cleveland Way Sceptre Road Braintree Street Cephas Avenue Colebert Avenue Cephas Street Alderney Road Grantley Street Bancroft Road Morpeth Street Palmers Road Road Bonner Approach Road Pritchard’s Road Goldsmith’s Ro Whiston Road w Tudor Road Sheep Lane Broadway Market Andrews Road Regent’s Row Brougham Road Pownall Road Marlborough AVenue Shrubland Road Albion Drive Middleton Road Lavender Grove Mapledene Road Greenwood Roa F d orest Road Gayhurst Road Martello Street Lansdowne Drive Wilton Way Richmond Road Chatham Place Valentine Road Oriel Road Mabley Street Churchill Walk Rushmore Road Rushmore Road Townmead Road Peterborough Road Carnwath Road Broomhouse Lane Hurlingham Road Clancarty Road Studdridge Street Imperial Road Woodlawn Road Stevenage Road Greyhound Road Seagrave Road Sydney Street Onslow Gardens Addison Gardens Blythe Road Glenthorne Road Hammersmith Grove Paddenswick Road Bloemfontein Road Sawley Road South Africa Road Du Cane Road Portobello R oad Ladbroke Road Chepstow Villas Abootsbury Road Addison Road Holland Villas Road Campden Hill Road Phillimore Gardens Kensington Palace Gardens Earls’s Court Road Marloes Road Vic ot ria Road Queen’s Gate Exhibition Road Prince Consort Road Thurloe Place South Carriage Drive Sloane Avenue Cale Street Manresa Road Old Church Street Beaufort Street The Boltons Tregunter Road Oakley Street BelgraveSquare Belgrave Place Eccleston Street Grosvenor Cres Ebury Street Elizabeth St Warwick Way Rochester Row Lupus Street John Islip Street Marsham Street Great Smith Street Great Peter Street Buckingham Gate Birdcage Walk Constitution Hill The Mall Horse Guard s’ Road Abingdon Street Northumberland Ave Chraing Cross Road St Martin’s Lane St James’s Street Curzon Street New Bond Street Conduit Street Great Marlborough Street Craven Road Connaught Street Seymour Place Portman Sq Upper Berkeley Street George Street York Paddington Street St Gloucester Place Devonshire Street Weymouth Street New Cavendish Street Dean Street Brewer Street Newman Street Wells Street New Oxford Street Great Russell Street Montague Street Bedford Square Torrington Place Malet Street Tavistock Place C althorpe Street Swinton Street Acton Street Sidmouth Street Ski nner Street Percival Street Lloyd Baker Street Aldersgate Street Newgate St Holborn Viaduct Beech Street Farringdon Road Gray’s Inn Road Chancery Lane Fetter Lane Fleet Street Ludgate Hill High Holborn Cheapside Poultry Cannon Street Queen Victoria Street Upper Thames Street Lower Thames Street Gracechurch Street Moorgate Worship Street Curtain Road Shepherdess Walk Eagle Wharf Road Cropley Street Wharf Road Graham Street Baring Street Barnsbury Road Penton Street Copenhagen Street Hemingford Road Richmond Avenue Bewdley Street Barnsbury St Theberton Street Laycock Street Offord Road Lofting Road Bingfield Street Copenhagen Street Brewery Road Market Road Roman Way Bride Street Mackenzie Road Highbury Place H gi hbury Crescent High bury New Park Aberdeen Road Petherton Road Mildmay Road Northchurch Road Do Englefield Road uglas Road Canonbury Park North Halliford Street Rotherfield Street Anson Road Melrose Avenue Ellesmere Road Chapter Road Park Avenue North Exeter Road Teignmouth Road Fordwych Road Mill Lane Chatsworth Road Westbere Road Denzil Road Longst one Avenue Pound Lane Robson Avenue Roundwood Road Doyle Gardens Doyle Gardens Bathurst Gardens Aylestone Avenue The Avenue Chevening Road Purves Road Furness Road St Mark’s Road Oxford Gardens Kensal Road Golborne Road Ashmore Road Fernhead Road Ilbert Street Droop Street Shirland Road Shirland Road Sutherland Avenue Lauderdale Road Abercorn Place Carlton Hill Canfield Gardens Greencroft Gardens Priory Road Abbey Road Victoria Road Compayn e Gardens Broadhurst Gardens Arkwright Road Frognal Lane Blackburn Road Maresfield Gardens Lyndhurst Road Wedderburn Road Belsize Avenue Belsize Park Gardens Eton Avenue Fellows Avenue Lanaster Grove Steele’s Road Eton Road Belsize Lane Sheriff Road King Henry’s Road Elsworthy Road Ave nue Road Primrose Hill Road Regent’s Park Road Chalcot Road Grafton Road Queen’s Crescent Prince of Wales Road Regis Road Leighton Road Bartholomew Road Islip Street Caversham Road Gaisford Street Patshull Road Bartholomew Road Leighton Grove Rochester Place Torriano Avenue Camden Mews Murray Street Cantelowes Road Agar Grove Castle Road Delancey Street Parkway Oval Road Jamestown Road Park Village East S at nhope Street Robert Street Drummond Street Cardington Street Chalton Street Midland Road Ossulston Street Camley Stre et Handyside Street North Road Hungerford Road Dalmeny Avenue Carleton Road Hilldrop Lane Penn Road Hornsey Street Camden Road Eden Grove Benwell Road George’s Road Lough Road Westbourne Road Biddestone Road Hartham Road Drayton Park Horsell Road Mildmay Grove North Mildmay Grove South Aberdeen Park Matthias Road Howard Road Palatine Road Boleyn Road Princess May Road King Henry’s Walk Farleigh Road Sh acklewellLane Cecilia Road Downs Park Road Sandringham Road Queens Down Road Amhurst Road Brooksby’s Walk Glyn Road Waterden Road White Post Lane Westfield Avenue Montfitchet Road International Way Carpenters Road Loop Road Honour Lea Avenue Celebratoi n Avenue Chobham Road Downsell Road Millais Road Hall Road Henniker Road Liberty Bridge Road Temple Mills Lane Colegrave Road Chandos Road Maryland Road Maryland Street Waddington Road Gurney Road Buxton Road Cemetery Road Janson Road Towr Hamlets Road Field Road Odessa Road Vansittart Road Station Road St James’ Road Idmiston Road Ash Road Sebert Road Godwin Road Capel Ro ad Ridley Road Centre Road Tylney Road Cranmer Road Durham Road Hampton Road Osborne Road Claremont Road Windsor Road Tuylney Road Earlham Grove Clova Road Atherton Road Carnarvon Road Keogh Road Margery Park Road Knox Road Ham Park Road Sherrard Road Sherrard Road Halley Road Monega Road Strone Road South Esk Road Bristol Road Stafford Road Derby Road Rutland Road Chester Road Dorset Road St Stephen’s Road Whyteville Road Grosvenor Road St George’s Road Upton Park Road Boleyn Road Neville Road Harold Road Terrace Road Stratford Road Milton Avenue Heigham Road Wakefield Street Grangewood Street Queen’s Road West Southern Road Selsdon Road Corporation Stre et Upper Road Grange Road Hermit Road Western Road Queen’s Road St Mary’s Road Aragon Road New City Road Cotswold Gardens Henniker Gardens Haldane Road Masterman Road HatherleyGardens Montpelier Gardens Jedburgh Road Cumberland Road Wanlip Road Jenkins Road Holborn Road Chadwin Road Glen Road Roman Road Kildare Road Croydon Road Chargeable Lane Star Lane Ma lmesbury Road Bider Street Gainsborough Road Cody Road North Crescent South Cres Twelvetrees Crescent Stephenson Street Tarling Road Redland Road Fords Park Road Vincent Street Ruscoe Road Butchers Road App leby Road Boreham Avenue Varley Road Garvary Road Alnwick Road Churchill Road Baxter Road Dove Approach Eisenhower Rd Seagull Lane Sandstone Lane Tidal Basin R d Wesley Avenue Evelyn Road Mill Road Knights Road Bradfield Road Thames Road Caistor Park Road East Road Crescent Rd Dacre Road Gwendoline Avenue Church Street Meath Road Holbrook Road Abbey Road Rokeby Street Paul Street Abb ey Lane Abbey Lane Carpenters Road Sugar House Lane Tredegar Road St Stephen’s Road Driffield Road Armagh Road Wick Lane Malmesbury Road Lichfield Road Medway Road Anthill Road Coborn Road Morgan Street Alfred Street Bruce Road Bow Common Lane Thomas Road Ackroyd Drive Lindfield Street Cordelia Street Brabazon Street St Leonards Road Uamvar St er et Teviot Street Leven Road Abbott Road Dee Street Blair Street Co tton Street Canton Street Grundy Street Marsh Wall Marsh Wall Byng Street Alpha Grove Mastmaker Road Millharbour Road East Ferry Road Spindrift Avenue Stebondale Street Saunders Nes s Road Chapel House Street Tiller Road Gascoyn e Road Ballance Road Lee Conservancy Road Ashenden Road Roding Road Homerton Grove Darnley Road Retreat Place Cadogan Terrace Morpeth Road King Edward’s Road Loddiges Road Brenthouse Road Southborough Road Daubeney Road St John Street Compton Street Seward Street Bastwick St Gee Street Banner Street Whitecross Street Radnor St Golden Lane Goswell Road City Road Leonard Road Tabernacle Srt eet Appold Street Folgate Street Brushfield Street Hanbury Street Princelet Street Old Montague Street Chicksand Street Fieldgate Street Varden Street Nelson Street Stepney Way Redmans Road Stepney Way Jamaica Street Jubilee Street Bromley Street Aylward Street Clark Street Ernest Street Shandy Street Harford Street Duckett Street Ben Jonson Road Copperfield Road Salmon Lane Aston Street Sutton Stree C t hristian Stree B t ack Church Lane Pennington Street Vaughan Way Kennet Street Wapping High Street Prusom Street Wapping Wall Garnet Street Wapping L ane Leman Street Alie Street Prescot Street Mansell Street Middlesex Street Minories Houndsditch London Wall Leadenhall Street Fenchurch Street Great Tower Street Gresham Street West Smithfield Giltspur St Old Bailey Carter Lane Tudor Street S hoe Lane Carey Street Drury Lane Rosebery Avenue Leather Lane Phoenix Place Roger Street Northington St Old Gloucester Street Gough Street Whitehall Place Regency Street Page Street Erasmus Street Vincent Square St George’s Square Moreton St er et Churchill Gardens Road Sutherland Street St George’s Drive Palace Street Carlisle Place Francis Street Petty France Bressenden Place Wilton Road Lower Belgrav e Street Easton Place Eaton Terrace Bourne Street Holbein Place Lower Sloane Street St Leonard’s Ter Tite Street Smith St Markham St Elystan Street Ixworth Place Cranley Gardens Roland Gdns Gilston Road Drayton Gardens Beaufort Street The Vale Cathcart Road Redcliffe Road The Little Boltons Draycott Avenue Draycott Place Walton Street Hans Road Kinnerton Street Cadogan Place Cadogan Lane Pavilion Road Pavilion Road Motcomb St Eaton Place Chapel Street Princes Gardens Ennismore Gdns Harrington Gardens Wetherby Gdns Collingham Road Gloucester Road Laverton Place Elvaston Place Cornwall Gardens Wrights Lane Lexham Gardens Hornton Street Palace Avenue Palace Gardens Terrace Brunswick Gdns Bedford Gardens Kensington Place Uxbridge Street Peel Street Duchess of Bedford’s Walk Phillimore Walk Pembroke Villas Melbury Road Holland Park Road Edwardes Sq Holland Park Holland Park Mews Holland Park Lansdowne Road Ladbroke Square Portland Road Pottery Lane Princedale Road Queensdale Road St James’s Gardens Wilsham Street Sirdar Road Walmar Road Elgin Crescent Blenheim Crescent Cornwall Crescent Dawson Place Chepstow Place Garway Road Moscow Road Pembridge Cr es Westbourne Grove Talbot Road Westbourne Park Villas P orchester Road Tavistock Road Lancaster Road Colville Terrace Lonsdale Road Lancaster Road St Ann’s Road Freston Road Cambridge Gardens Bassett Road Pangbourne Ave St Charles Square Chesterton Road Dalgarno Gardens Sutton Way Australia Road Commonwealth Ave Australia Road Dorando Close Ellerslie Road Adelaide Grove Ormiston Grove Galloway Road Wormholt Road Bryony Road Lime Grove Pennard Road Scotts Road Coningham Road Godolphin Road Loftus Road Stan ak l e Road Frithville Gardens Greenside Road Cathnor Road Stowe Road Goodwin Road Findon Road Davisville Road Becklow Road Cobbold Road Rylett Road Bassein Park Road Ravensco urt Gardens Dalling Roa d Benbow Road Brackenbury Road Agate Road Iff ey l Road Richford Street Sulgrave Road Cardross Street Nasmyth Street Adie Road Banim Street Ravenscourt Road Ravenscourt Park Stamford Brook Ave R|avenscourt Square Prebend Gardens Netheravon Road Airedale Avenue Chiswick Mall British Grove St Peter’s Square Black Lion Lane Beavor Lane Standish Road Upper Mall Welt ej Rd Rivercourt Rd Rutland Grove Queen Caroline Street Black’ s Road Studland St Ca mbridge Gr Chancellor’s Road Yeldham Road Biscay Road Beryl Road Crisp Road St Dunstan’s Rd Margr avine Road Margravine Gardens WinslowR oad Parfrey Street Rannoch Road Rainville Road Crabtree Lane Niton Street Lysia Street Queensmill Road Langthorne Street Kenyon Street Inglethorpe Street Harbord St Finlay St Ellerby Street Doneraile Street Cloncurry Street Bishop’s Park Road Bishop’s Avenue Greyhound Road Field Road EveringtonSt Tasso Road Kinnoul Rd Musard Road Brecon Road Comeragh Road Vereker Road Star Road Bramber Road Normand Road Chaldon Road Prothero Road Mendora Road Delaford Street Rylston Road Estcourt Road Haldane Road Hartismere Road Fabian Rd Mirabel Rd North End Road Shorrolds Rd Sedlescombe Road Ongar Road Halford Road Racton Road Anselm Road Farm Lane Walham Grove Farm Lane Barclay Road Moore Park Road Harwood Road Wat erford Road Musgrave Crescent Britannia Rd Rockley Road Netherwood Road Lakeside Road Bolingbroke Road Richmond Way Sinclair Ro M ad ilson Ro M ad asbro Road Augustine Roa Du d nsany Road Blythe Road Brook Green Brook Green Rowan Road Caithness Rd Aynhoe Rd Girdlers Road Blythe Rd Gunterstone Road Edith Road Batoum Gdns Hemlock Road Steventon Road Sundew Avenue Daffodil St Yew Tree Rd Aycliffe Rd Dunraven Road Russell Road Avonmore Road Glidon Rd Colet Gardens Shortlands Butterwick Kingwood Road Munster Road Wardo Avenue Gowan Avenue Colehill Lane Waldemar Avenue Munster Road Sherbrooke Road St Maur Road St Dionis Road Novello Street Crondace Road Munster Road Fulham Park Gard ens Napier AVenue Perrymead St Haz eb l u yr Road Broughton Road Hugon Road Stephendale Road Bagleys Lane Hortensia Road Lots Road Lots Road Tadema Road Limerston Street Milman’s St Park Walk Paulton’s Square Elm Park Road Pelham Street Chelsea Manor St Flood Street Radnor Walk Glentham Road Tri nity Chur ch Road Boileau Road Nowell Road Barnes Avenue Verdun Road Washington Road Madrid Road Suffolk Road Westmoreland Road Nassau Road Church Road Queen Elizabeth Walk Elm Grove Road Ranelagh Avenue Glebe Road Gerard Road Comm on Road Vine Road Embankment Festing Road Felsham Road Hotham Road Clarendon Drive Putney High Street Deodar Road Montserrat Road Werter Road Disraeli Road Fawe Park Road Norroy Road Chelverton Road Erpingham Road Dryburgh Road Sefton Street Dover House Road Huntingfield Road Putney Park Lan Parkstead R e oad Crestway Dover Park Drive Dover House Drive Roehampton High St Medfield Street Westmead Holford Way Clarence Lane Danebury Avenue Laverstoke Gardens Ibsley Garde ns Alton Road Bessborough Road Telegraph Road Portsmouth Road Wildcroft Road Howards Lane Hazlewell Road Malbrook Road Colinette Road Larpent Avenue Luttrell Avenue Chartfield Avenue Gwendolen Avenue St John’s Avenue Cambalt Road Westleigh Avenue Genoa Ave Cortis Road St John’s Avenue Carlto n Drive Keswick Road Porti nscale Road Lytton Grove Rusholme Road Kersfield Road Eastfields Ave O akhill Road Schubert Road Galveston Road Mexfield Road Cromford Road Santos Road Wandsworth High Street East Hill Swandon Way Trinity Road Wandsworth Common North Side Trinity Road Plough Road Nantes Close Harbut Road Alma Road Elsynge Road Spencer Rd Wandsworth Common West Sdi e Spencer Park Windmill Rd Spencer Park Geraldine Road Melody Rd Heathfield Road Westover Road Allfarthing Lane St Ann’s Hil V l ermont Rd Iron Mill Rd Swaffield Road St Ann’s Hill Kimber Road Aslett Street Bassingham Rd Wilna Rd Lydden Rd Winfrith R d Brathway Road Merton Road Ringford Road Haldon Road West Hill Road West Hill Road Melrose Road Granville Road Wimbledon Park Road Seymour Road Pulborough Rd Sutherland Grove Gi rdwood Road Skeen a Hill Combemartin Roa d Beaumont Road Princes Way Augustus Road Augustus Road Victoria Drive Albert Drive Inner Park Road Victoria Drive Princes Way Gartmoor Gardens PirbrightRo ad Merton Road Merton Road Durnsford Rd Replingham Road Balvernie Grove Standen Road Longfield St Brookwood Road Lavenham Road Revelstoke Road Elsenham Street Heythorp Street Clonmore street Engadine Street Elborough Street Trentham Street Astonville Street Ravensbury Road Mount Rd Penwith Road Strathville Rd Haslemere Ave Garratt Lane Wandle Way Vanderbilt Rd Brocklebank Rd Tranmere Road Swaby Road Openview Fieldview Godley Road Tilehurst Road Ellerton Road Loxley Road Frewin Road Herondale Avenue Lydford Road Beechcroft Road Brodrick Road Wandle Road Hendham Road Dalebury Road St James’s Drive Balham Park Road Sarsfeld Road Boundaries Road Row fant Road UpperTooting Park Marius Rd Oakme ad Road Elmfield Road Cloudesdale Rd Byrne Road Bedford Hill Dornton Road Fernlea Road Rossiter Road Sistova Road Laitw ood Road Ormeley Ro ad Old Devonshire Rd Balham New Rd Ravenslea Road Mayford Road Chestnut Grove Endlesham Road Ramsden Road Balham Grove Oldridge Road Alderbrook Road Badminton Road Dinsmore Rd Yukon Rd Dagnan Road Cathles Road Gaskarth Road Hazelbourne Rd Englewood Road Sudbrooke Road Thurleigh Road Montholme Road Gayville Road Devereux Road Hillier Road Wroughton Road Kyrle Road Broxash Road Manchuria Road Roseneath Road Honeywell Road W Chatto Road ebb’s Rd S Wakehurst Road alcot Road Leathwaite Road Bennerley Rd Mallinson Rd Shelgate Road Grandison Road Alfriston Road Muncaster Road Canford Road CulmstockRd Winsham Grove Clapham Common West Side Salcott Rd Wakehurst Rd Belleville Rd Kelmscott Rd Bramfield Rd Old Par k Ave Baskerville Road Bolingbroke Grove Lavender Sweep Lavender Walk Lavender Gardens Grant Road Ingrave Street Este Road Cabul Road Lombard Road Gwynne Road Vicarage Crescent Battersea High Street Shuttleworth Road Orbel Street Bridge Lane Surrey Lane West bridge Road BatterseaChurch Road Parkgate Road Cambridge Rd Rosenau Rd Albert Bridge Road Prince of Wales Drive Brynmaer Rd Warriner Gardens Lurline Gardens Queenstown Road Dagnall Street Burns Road Sheepcote Lane Culvert Road Eversleigh Road Eversleigh Road Tyneham Road Ashbury Road Sabine Road Elsley Road Eland Road Stanley Grove Ingelow Road St Philip Street Tennyson Street Sugden Ro ad Mysore Road Sto mr ont Road Taybridge Road Gowrie Road Dorothy Road Thessaly Road Stewart’s Road Robertson Street Wandsworth Road Victoria Rise The Chase Macaulay Road Lillieshall Rd North Street Larkhall Rise Clapham Manor St Gauden Road Edgeley Road Union Road Chelsham Road Timber Mill Way Larkhall Lane Jeffreys Road Studley Road Lansdowne Way Priory Grove Wandsworth Road Hartington Road Thorne Road Guildford Road Dorset Road Fentiman Road Fentiman Road Palfrey Place Harleyford Road Meadow Road Vauxhall Street Black Prince Road Sancroft Street Courtenay Street Vauxhall Walk Lambeth Walk Fitzalan Street Wincott St Renfrew Road Lambeth Palace Road Westminster Bridge Road Hercules Road Hayles Street Brook Drive York Road Belvedere Road Upper Ground Stamford Street The Cut Hatfields Southwark Street Union Street Borough High Street Southwark Bridge Road Trinity Street Newington Causeway Tabard Street Manciple Street Falmouth Road Deverell Street Snowsfields WestonStreet Newcomen St St Thomas Street Tooley Street Shad Th ames Tooley Street Druid Street Tower Bridge Road Spa Road GrangeWalk Willow Walk Mandela Way Bath Terrace Rodney Road Heygate Street East Street Brandon Street Thurlow Street Chatham Street Congreve Street East Street Portland Street Merrow Street Inville Road Dawes Street Surrey Square Kinglake Street Mina Road Penton Place Braganza Street De Laune Street Kennington Park Place Cook’s Road Royal Road John Ruskin Street Grosvenor Terrace Bethwin Road Wyndham Road Medlar Street C omber Grove Fielding Street Penrose Street Manor Place Lorrimore Road Edmund Street Benhill Road Elmington Road St Giles Road Havil Street Dalwood Street St George’s Way Chandler Way Sumner Road Sumner Road Cobourg Road Glengall Road Haymerle Road Green Hundred Road Friary Road Naylor Road Meeting House Lane Asylum Road Asylum Road Fenham Road Carlton Grove Montpelier Road Goldsmith Road Clifton Way Caldwell Street Vassall Road Foxley Road Cranmer Road Hackford Road Hillyard Street Stockwell Park Road Groveway Lorn Road Robsart St Sidney Road S ot ckwellParkC er s Aytoun Road Liberty Street Lingham Street Combermere Road Dalyell Road Mordaunt St Hargwyne Street Ferndale Road Hubert Grove Sandmere Road Solon Road Corrance Road Ballater Road Cowley Road Mosty n Road AkermanRoad Co mr ont Road Knatchbull Road Paulet Road Lilford Road Minet Road Loughborough Road Barrni gton Road Wiltshire Ro ad Flaxman Road Denmark Road Flodden Road Calais Stre et Camberwell Station Road Warner Road Crawford Road Coldharbour Lane Atlantic Road Nelsons Row St Alphonsus Road Crescent Lane Elms Road Park Hill Crescent Lane Lepoc Road Elms Crescent Rodenhurst Road Narbonne Avenue Ha mbalt Road Klea Ave Clarence Cresce nt Lyham Road Kingswood Road New Park Road Dumbarton Rd Jebb Avenue Lambert Road Branksome Road Strathleven Road Sudbourne Road Hayter Road Baytree Road Atkins Road Weir Road Hydethorpe Road Cambray Road Midmoor Road Radbou rne Road Burnbury Road Haverhill Road Emmanuel Road Kings Avenue New Park Road Drewstead Road Sternhold Avenue Criffel Ave Telford Avenue Tierney Road Kirkstall Road Palace Road Wavertree Road Downton Avenue Cricklade Avenue Barcombe Avenue Hillside Road Lanercost Road Palace Road Daysbrook Road Abbots Park Gaywood Close AthloneR oa C d laverdale Road Elm Park Leander Road Helix Road Arodene Road Fairview Place Brixton Water Lane St Matthew’s Road Dalberg Road Rattray Road Saltoun Road Somerleyton Road Loughborough Park Shakespeare Road Moorland Road Mayall Road Kellett Road Me rvan Road Talma Road Barnwell Road Effra Parade Chaucer Road Spenser Road Shakespeare Road Milton Road Herne Hill Road Lowden Road Fawnbrake Avenue Poplar Road Finsen Road Ferndene Road Poplar Walk Brantwood Road Dorchester Drive Kestrel Avenue Red Post Hill Sunray Avenue Dylways Woodfarrs Red Post Hill Beckwith Road E ml woodRoad Danecroft Road Frankfurt Road Elfindale Road Homdene Avenue Hollingbourne Road Ruskin Walk Champion Hill Champion Hill Denmark Hill Lowth Road De Crespigny Park Grove Lane Camberwell Grove McNeil Road Grove Park Grove Park Chadwick Road Choumert Road Copleston Road Danby Street Avondale Rise Bellenden Road Oglander Road Ondine Road Adys Road Choumert Rd Rye Lane McDermott Road Fenwick Road Vestry Road Grace’s Road Shenley Road Crofton Road Bushey Hill Road Talfourd Road Lyndhurst Grove Denman Road Lyndhurst Way Bellenden Road Hanover Park Clayton Road Cope al nd Road Consort Road Heaton Road Peckham Rye Nutbrook Street Amott Road Gowlett Rd Peckham Rye Gordon Road Kirkwood Road Lugard Road Cossall Walk Brayards Road Hollydale Road Ansdell Road St Mary’s Road Lausanne Road Deronda Rd Lovelace Road Rosendale Road Rosendale Road Rosendale Road Carson Road Thulow Hill Croxted Road Turney Road Park Hall Road Gallery Road College Road College Road Burbage Road Burbage Road Turney Road DulwichVil al ge Frank Dixon Way Court Lane Woodwarde Road Calton Avenue Dovercourt Road Beauval Road Townley Road Me bl ourne Grove Ashbourne Grove Pytchley Road Crystal Palace Rd Upland Rd Crystal Palace Road Whateley Road Landcroft Road Fellbrigg Road Silvester Roa Pellatt Roa d d Ulversfcroft Rd Darrell Road Hindmans Road Goodrich Road Friern Road Friern Road Henslowe Road Friern Road Upland Road Upland Road Du nstans Road Overhill Road Underhill Road Wood Vale Langton Rise Wood Vale Hillcourt Road Landells Road Dunstans Road St Aidan’s Road Ryedale Colyton Road Oakhurst Grove Westwood Park Westwood Park Tewkesbury Avenue Canonbie Road Netherby Road Manor Mount Devonshire Road D evonshire Road DunoonRoa d Mundania Road Therapia Road Marmora Road Scutari Rd Shelbury Rd Dovedale Rd Brenchley Gardens Kelvington Road Waldram Park Roa d Church Rise Sunderland Road Kemble Road Crans ot n Road Beadnell Road Malham Road Garthorne Road Bovill Road Colfe Road Kilmorie Road Elsinore Road Hurstbourne Road Vancouver Road Marler Road Blythe Vale Elm Lane Faversham Road Blythe Hill Lane St German’s Road Brockley Park Lowther Hill Brockley View Duncombe Hill Codrington Hill Montem Road Bankhurst Road Ravensbourne Park Cres Ravensbourne Park Stillness Road Brockley Rise Crofton Park Road Salehurst Road Bexhill Road Manwood Road Ewhurst Road Marnock Road Sevenoaks Road Grierson Road Buckthorne Road Manwood Road Brenchley Gardens Athenlay Road Inverton Road Brockley Way Turnham Road St Norbert Road Limesford Road Water Mew s Linden Grove Nunhead Lane Kimberley Avenue Lynton Road St James s’ Road Galleywall Road Blue Anchor Lane Marlborough Grove Chambers Street George Row Bevington Street Drummond Road Southwark Park Road Raymouth Road Camilla Road Lynton Road Catlin St Verney Road Credon Road Ilderton Road Surrey Canal Road Mercury Way Avonley Road Surrey Quays Road QuebecWay Rotherhithe Street Rotherhithe Tunnel Needleman Street Rotherhithe Street Rotherhithe Street Finland Street Rope Street Timber Pond Road Hawkstone Road Rotherhithe New Road Bush R oad Trundley’s Road Oldfield Grove Silwood Street Plough Way Grove Street Oxestalls Road Grinstead Road Ca nal Approach Scawen Road Landmann Way Bacl khorse Road Gosterwood Street Juno Way Rolt Stre et Childers Street Abinger Grove Arklow Rd Edward Street Amersham Vale Brocklehurst Street Camplin Street Kender Street Pag nell Street Achilles St Watergate Street Prince St Deptford Green Creekside Deptford High Street Watson’s Street Milton Court Road New Cross Road Am ersham Road Florence Road Heald St Albyn Rd Vanguard St Friendly Stree Ta t nner’s Hill Lucas Street Albyn Rd Cranbrook Rd Ashmead Road Brookmill Road Thur ston Ro ad Shardeloes Road St Donatts Road Barr ei da el Rokeby Road Upper Brockley Road Ashby Road Lewisham Way Upper Brockley Road Manor Avenue Wickham Road Breakspears Mews Breakspears Road Wickham Mews Ashby Mews Geoffrey Rd Cranfield Road Harefield Rd Wickham Road Tressillian Road Harefield Road Tyrwhit Road Hilly Fei lds Cres cent Jerningham Road Jerningham Road Musgrove Road Pepys Road Erlanger Road Arbuthnot Road Waller Road Kitto Road Vesta Road Endwell Road Shardeol es Road Sprules Road Wallbutton Rd Pepys Road Gellatly Road Dennett’s Road Bousfield Road Avignon Road St Asaph Road St Norbert Road Revelon Road Pincott Place Aspinall Rd Harlescott Road Howson Rd Braxfield Road Comerford Road Brockley Road Harcourt Road Dalrymple Road Ivy Road Brockley Grove Montague Avenu e Ladywell Rd Chudleigh Road Arthurdon Road Amyruth Road Elsiemaud Road Malyons Road Vicars Hill Brookbank Road Ellerdale Street Marsa al Road Algernon Road Embleton Road Shell Road Cliffview Road Sandrock Road Slagrove Pl ace AlbacoreCrescent Doggett Road Hawstead Road Bradgate Road Canad ai n Avenue Holbeach Road Fordmill Road Sangley Road Culverley Road Bargery Road St Fillans Road Thornsbeach Road Sandhurst Road Dowanhill Road Torridon Road Wellmeadow Road Muirkirk Road Hither Green Lane Springbank Road Stainton Road Davenport Road La el ham Road Minard Road Hither Green Lane Fur he t r Gree n Road St Mildreds Road Burnt Ash Hill Alnwick Road Sibthorpe Road Winn Road Mottingham Lane Guibal Road Horncastle Road Middle Park Avenue The Vista Eltham Palace Road Middle Park Avenue Kingsground Churchbury Road Upwood Road Horn Park Lane Crathie Road Cambridge Drive Leyland Road Woodyates Road Manor Lane Holme Lacey Road Southbrook Road Wantage Road Manor Park GilmoreRoad Brandram Road Dacre Park Lee Park Manor Way Weigall Road Moorhead Way Tudway Road Edgeworth Road Meadowside Elt ham Green Road Shawbrooke Road Briset Road Purneys Road Phineas Pett Road Langbrook Road Bournbrook Road Broad Walk Blackheath Park Foxes Dale Dursley Road Woolacombe Road Wricklemarsh Road Holburne Road Kidbrooke Park Road Eastbrook Road Merriman Road Kidbrooke Grove Kidbrooke Park Road Kidbrooke Gdns Morden Road Pond Roa d St Joseph’s Vale Marischal Road Lewisham Park Moun t Pleasant Road George Lane Campshill Road Ringstead Road Fe rnbrook Road Longhurst Road Mounts Pond Road Granville Park Hare and Billet Road Golfers Road Lewisham Hill Wat Tyler Road Lewisham Road Lewisham High M Street olesworth Street Greenwich South Street Point Hill Royal Hill Hyde Vale Crooms Hill King George Street Devonshire Drive The Avenue Blackheath Avenue Charlton Way Maze Hill Vanbrugh Park Prince Charles Road Dartmouth Hill Greenwich High Road Westcombe Park Road Foyle Road Coleraine Road HardyRoad Humber Road Beaconsfield Road Mycenae Road Westcombe Hill Langton Way Vanbrugh Hill Pelton Road Tunnel Avenue Tunnel Avenue West Parkside East Parkside Riverside Anchor and Hope Lane Bugsby’s Way Westmoor Street Woodland Terrace Heathwood Gardens Kinveachy Gardens Charlton Lane Maryon Road Thorntree Road EastcombeAvenue Wyndcliff Road Victoria Way Elliscombe Road Charlton Park Lane Canberra Road Hornfair Road Prince Henry Road Charlton Dene Sutlej Road Indus Road Marlborough Lane Old Dover Road Brooklands Park Parkgate St John’s Park Corelli Road Teilson Avenue Lodge Road Penfold Street Broadley Street Harewood Avenue Outer Circle Outer Circle Ches In ter Road ner Circle St John’s Wood High Street BROMPTON RD EDGWARE ROAD MAIDA VALE HOLLOWAY ROAD A1 UPPER STREET A1 KINGSLAND ROAD BLACKWALL TUNNEL NORTHERN APPROACH BOW ROAD EAST CROSS ROUTE EAST INDIA DOCK ROAD LEWISHAM WAY BRIXTON ROAD KENNINGTON PARK ROAD CLAPHAM ROAD CLAPHAM HIGH STREET STOCKWELL ROAD VAUXHALL BRIDGE ROAD NEW KENT ROAD WEST CROSS ROUTE HOLLAND ROAD WESTWAY A40 WESTWAY MARYLEBONE ROAD HAMPSTEAD ROAD EUSTON ROAD BATTERSEA PARK ROAD NINE ELMS LANE GROSVENOR ROAD CHELSEA EMBANKMENT LATCHMERE ROAD TRINITY ROAD ROEHAMPTON LANE UPPER RICHMOND ROAD SHOOTERS HILL ROAD BLACKHEATH HILL FINBOROUGH RD REDCLIFFE GDNS BATTERSEA BRIDGE ROAD BRIXTON HILL POYNDERS RD BROWNHILL ROAD SOUTH CIRCULAR A205 LORDSHIP LANE SOUTH CIRCULAR A205 GREAT WEST ROAD TALGARTH RD HAMMERSMITH FLYOVER CROMWELL RD HIGH ROAD A407 A4088 WALM LANE HIGH ROAD CRICKLEWOOD BROADWAY A5 KILBURN HIGH ROAD A5 MAIDA VALE A5 WILLESDEN LANE BRONDESBURY PAR SI K DMOUT H ROAD ALL SOULS AVENUE CHAMBERLAYNE ROAD A404 HIGH STREET HARLESDEN WROTTESLEY ROAD HARROW ROAD A404 HARROW ROAD A404 HARROW ROAD A404 ELGIN AVENUE KILBURN LANE HARVIST ROAD CARLTON VALE SALUSBURY ROAD BRONDESBURY ROAD WEST END LANE FORTUNE GREEN ROAD FINCHLEY ROAD A41 FINCHLEY ROAD FIN CHLEY ROAD A41 BELSIZE ROAD ABBEY ROAD WEST END LANE GROVE END ROAD LISSON GROVE FITZJOHN’S AVENUE ROSSLYN HILL HAVERSTOCK HILL A502 ADELAIDE ROAD MALDEN ROAD MANSFIELD ROAD HIGHGATE ROAD FORTESS ROAD KENT SI H TOWN ROAD BRECKNOCK ROAD CAMDEN ROAD HILLMARTIN ROAD YORK WA CA Y MDEN PK RD YORK WAY CALEDON AI N ROAD CALEDONIAN ROAD LIVERPOOL ROAD CANONBU RY ROAD HIGHBURY GROVE ST PAUL’S ROAD NEW NI GTON GN RD GREEN LANE A105 ALBION LAN H E GI HBURY PARK ESSEX ROAD BALLS POND ROAD SOUTHGATE ROAD STOKE NEWINGTON ROAD DALSTON LANE GRAHAM ROAD DALSTON LANE AMHURST ROAD DALSTON LANE PEMBURY ROAD LOWER CLAPTON ROAD HOMERTON HIGH STREET HOMERTON ROAD EASTWAY A12 HIGH ROAD LEYTON CROWNFIELD ROAD LEYTONSTONE ROAD A11 CANN HALL ROAD FOREST LANE LEYTON ROAD WATER LANE ROMFORD ROAD A118 DAMES ROAD ROMFORD ROAD A118 HIGH STREET NORTH A117 KATHERINE ROAD SHREWSBURY ROAD GREEN STREET UPTON LANE A114 PLASHET GROVE PLASHET ROAD PORTWAY ROAD VICARAGE LANE WEST HAM LANE GREAT EASTERN ROAD STRATFORD HIGH STREET A118 PLAISTOW ROAD MANOR ROAD UPTON LANE STOPFORD ROAD KATHERINE ROAD GREEN STREET BARKING ROAD A124 BARKING ROAD A124 GREENGATE STREET THE BROADWAY CENTRAL PARK ROAD BOUNDARY ROAD LONSDALE AVENUE NEWHAM WAY A13 PRINCE REGENT LANE BALAAM STREET BARKING ROAD A124 NEWHAM WAY A13 NEW BARN STREET MANOR ROAD PR NI CE REGENT LANE TOLLGATE ROAD STANSFELD ROAD ROYAL ALBERT WAY CONNAUGHT BRIDGE ALBERT ROAD A112 NORTH WOOLWICH ROAD FREEMASONS ROAD SILVERTOWN WAY LOWER LEA CROSSING MORNING LANE WICK ROAD CASSLAND ROAD WELL STREET KENWORTHY ROAD VICTORIA PARK ROAD VICTORIA PARK ROAD GROVE ROAD MARE STREET MARE STREET OLD FORD ROAD OLD FORD ROAD ROMA N ROAD ROMAN ROAD PARNELL ROAD FAIRFIELD ROAD GROVE ROAD GLOBE ROAD BETHNAL GREEN ROAD WARNER PLACE CHESHIRE STREET SEWARDSTONE RD BISHOP’S WAY HACKNEY ROAD QUEENSBRIDGE ROAD HACKNEY ROAD NEW NORTH ROAD CITY ROAD GREAT EASTERN STREET OLD STREET P TI F EI LD STREET OLD STREET GOSWELL ROAD A1 ESSEX ROAD CLERKENWELL ROAD LEVER STREET ST JOHN STREET ROSEBERY AVENUE PENTONVILLE ROAD CHISWELL ST LONDON WALL BUNHILL ROW BATH STREET BISHOPSGATE COMMERCIAL STREET COMMERCIAL ROAD A13 WHITECHAPEL ROAD BRICK LANE CAMBR DI GE HEATH ROAD MILE END ROAD STEPNE Y GREEN VALLANCE ROAD NEW ROAD CANNON ST ROAD CABLE STREET THE HIGHWAY CABLE STREET LIMEHOUSE LINK COMMERCIAL ROAD A13 EAST INDIA DOCK ROAD BURDETT ROAD ST PAUL’S WAY VIOLET ROAD CHRISP STREET WESTFERRY ROAD MANCHESTER ROAD WESTFERRY ROAD KING’S CROSS ROAD GRAY’S INN ROAD GUILFORD STREET THEOBALD’S ROAD HIGH HOLBORN JUDD STREET SOUTHAMPTON ROW UPPER WOBURN GOWER STREET TOTTENHAM COURT RD GOODGE STREET GREAT PORTLAND STREET PORTLAND PLACE EVERSHOLT STREET OUTER CIRCLE PRINCE ALBERT ROAD PARK ROAD PANCRAS ROAD PANCRAS WAY CAMDEN STREET ROYAL COLLEGE STREET WIGMORE STREET OXFORD STREET MARYLEBONE HIGH STREET BAKER STREET GLOUCESTER PLACE OXFORD STREET REGENT STREET SHAFTESBURY AVENUE PICCADILLY PALL MALL PARK LANE PRAED STREET SUSSEX GARDENS BAYSWATER ROAD BAYSWATER ROAD BISHOP’S BRIDGE ROAD WESTBOURNE TERRACE PEMBROKE VILLAS WESTBOURNE GROVE CHEPSTOW ROAD WESTBOURNE PARK ROAD LADBROKE GROVE KENSINGTON PARK GROVE CLARENDON ROAD HOLLAND PARK AVENUE LADBROKE GROVE BARLBY ROAD WESTWAY A40 WESTWAY A40 SCRUBS LANE WOOD LANE UXBRIDGE ROAD GOLDHAWK ROAD ASKEW ROAD OLD OAK ROAD SHEPHERD S’ BUSH ROAD GOLDHAWK ROAD KING STREET H AMMERSMITH ROAD WARWICK ROAD KENSINGTON HIGH STREET KENSINGTON C HURCHSTREET KENSINGTON ROAD KENSINGTON GORE KNIGHTSBRIDGE GLOUCESTER ROAD WEST CROMWELL ROAD WARWICK GARDEN S BROMPTON ROAD FULHAM ROAD PONT STREET SLOANE STREET GROSVENOR PLACE EATON GATE KING’S ROAD KING’S ROAD NEW KING’S ROAD GUNTER GROVE EDITH GROVE CHELSEA BRIDGE ROAD ROYAL HOSPITAL ROAD PIMLICO ROAD BUCKINGHAM PALACE ROAD BELGRAVE ROAD VICTORIA STREET HORSEFERRY ROAD MILLBANK VICTORIA EMBANKMENT WHITEHALL STRAND VICTORIA EMBANKMENT ALDWYCH KINGSWAY FARRINGDON HATTON GARDEN TOWER BRIDGE LONDON BRIDGE SOUTHWARK BRIDGE MILLENNIUM BR BLACKFRIARS BR WATERLOO BRIDGE WESTMINSTER BR LAMBETH BR VAUXHALL BR CHELSEA BR ALBERT BRIDGE BATTERSEA BR WANDSWORTH BR PUTNEY BR HAMMERSMITH BR WANDSWORTH BRIDGE ROAD FULHAM ROAD FULHAM PALACE ROAD DAWES ROAD LILLIE ROAD NORTH END ROAD FULHAM PALACE ROAD LONSDALE ROAD CASTELNAU ROCKS LANE STATIO N ROAD MILL HILL ROAD QUEEN’S RIDE LOWER RICHMOND ROAD PUTNEY BRIDGE ROAD ARMOURY WAY MERTON ROAD GARRATTLANE ST JOHN’S HILL LAVENDER HILL QUEENSTOWN ROAD SILVERTHORNE ROAD ELSPETH ROAD CEDARS ROAD CLAPHAM COMMO N NORTH SIDE LONG ROAD CLAPHAM COMMON SOUTH SIDE NORTHCOTE ROAD BROOMWOOD ROAD BOLINGBROKE GROVE NIGHTINGALE LANE BELLEVUE ROAD BALHAM HIGH ROAD BALHAM HILL ABBEVILLE ROAD CLAPHAM PARK ROAD ACRE LANE BEDFORD ROAD KINGS AVENUE CLARENCEAVENUE LANDOR ROAD EFFRA ROAD TULSE H LI L DULWICH ROAD RAILTON ROAD UPPER TULSE HILL ATKINS RO AD SOUTH CIRCULAR A205 CHRISTCHURCH ROAD SOUTH CIRCULAR A205 SOUTH CIRCULAR A205 CAVENDISH ROAD THURLOW PARK ROAD SOUTH CIRCULAR A205 DULWICH COMMON SOUTH CIRCULAR A205 ROEHAMPTON LANE PUTNEY HEATH PUTNEY HILL TIBBET’S RIDE WIMBLEDON PARK SIDE WIMBLEDON PARK ROAD EARLSFIELD ROAD BURNTWOOD LANE MAGDALEN ROAD THORNTON ROAD CAVENDISH ROAD NORWOOD ROAD TRINITY RISE CROXTED ROAD HALF MOON LANE MILKWOOD ROAD HERNE HILL DENMARK HILL COLDHARBOUR LANE CAMBERWELL NEW ROAD PECKHAM ROAD WALWORTH ROAD KENNINGTON LANE CAMBERWELL ROAD ALBANY ROAD SOUTHAMPTON WAY KENNINGTON ROAD KENNINGTON LANE LAMBETH ROAD ALBERT EMBANKMENT ST GEORGE’S ROAD LONDON ROAD BLACKFRIARS ROAD WATERLOO ROAD BOROUGH ROAD UNION STREET BERMONDSEY STREET LONG LANE GREAT DOVER STREET HARPER ROAD JAMAICA ROAD ABBEY STREET GRANGE ROAD SOUTHWARK PARK ROAD ROLLSROAD DUNTON ROA O D LD KENT ROAD A2 OLD KENT ROAD A2 ROTHERHITHE NEW ROAD TRAFALGAR AVENUE COMMERCIAL WAY PECKHAM HILL STREET PECKHAM PARK ROAD GROVE LANE VILLAGE WAY EAST DULWICH GROVE LORDSHIP LANE LORDSHIP LANE BARRY ROAD UNDERHILL PECKHAM RYE EAST DULWICH ROAD EVELINA ROAD DRAKEFELL ROAD PECKHAM RYE IVYDALE ROAD HONOR OAK ROAD FOREST HILL ROAD HONOR OAKPARK BROCKLEY R SI E BROCKLEY ROAD STONTON PARK ADELAIDE AVENUE CATFORD HILL STANSTEAD ROAD SOUTH CIRC ULAR A205 BROMLEY ROAD A21 LEWISHAM HIGH STREET VERDANT LANE BARING ROAD WESTHORNE AVENUE SOUTH CIRCULAR A205 SIDCUP ROAD A20 BURNT ASH ROAD ELTHAM ROAD KIDBROOKE PARK ROAD LOAM PIT VALE LEE HIGH ROAD BELMONT HILL LEE ROAD LEE TERRACE PRINCE OF WALES ROAD ELTHAM HILL ROCHESTER WAY A2 ROCHESTER WAY A2 ROCHESTER WAY A2 SHOOTERS HILL ROAD A207 ROCHESTER WAY CHARLTON ROAD A102 CHARLTON PARK ROAD CHARLTON CHURCH LANE A102 BLACKWALL LANE WOOLWICH ROAD WOOLWICH ROAD BUGSBY’S WAY TRAFALGAR ROAD WOOLWICH CHURCH STREET MILLENNIUM WAY ROMNEY ROAD CREEK ROAD DEPTFORD CHURCH STREET EVELYN STREET LOWER ROAD SALTER ROAD REDRIFF R OA LO D WER ROAD SANFORD STR EET NEW CROSS ROAD MALPAS ROAD SOUTH LAMBETH ROAD WANDSWORTH ROAD RANDOLPH AVENUE LANARK ROAD SUTHERLAND AVENUE WARRINGTON CRES WARWICK AVENUE CASTELLAIN RD BOURNE TERRACE WARWICK AVE BLOMFIELD ROAD MAIDA AVENUE WALTERTON ROAD CHIPPENHAM ROAD KILBURN PARK ROA M D ALVERN ROAD SALTRAM CRESCENT RANDOLPH AVENUE LANARK ROAD PRINCESS ROAD CA RLTON VALE GREVILLE PLACE BOUNDARY ROAD SPRINGFIELD ROAD CLIFTON HILL LOUDOUN ROAD QUEEN’S GROVE HAMILTON TERRACE MARLBOROUGH PLACE ST JOHN’S WOOD TERRACE ALLITSEN ROAD TOWNSHEND ROAD CIRCUS ROAD ORCHARDSON STREET FRAMPTON ST MARY’S TERRACE LEINSTER GARDENS GRANTULLY ROAD GREAT WESTERN RD PORTNALL ROAD BRAV NI GTON ROAD MARBAN RD FIFTH AVENUE SIXTH AVENUE THIRD AVENUE KINGSWOOD AVENUE MILMAN ROAD KEMPE ROAD KESLAKE ROAD HYTHE ROAD WHITMORE GARDENS BUCHANAN GARDENS PALERMO ROAD RUCKLIDGE AVENUE LEGHORN ROAD CROWNHILL ROAD HARLESDEN ROAD LEIGHTON GARDENS HARDINGE ROAD COLLEGE ROAD WRENTHAM AVENUE MOUNT PLEASANT HANOVER ROAD TIVERTON ROAD HARVIST ROAD GLENGALL RD PRIORY PARK ROAD DYNE ROAD CAVENDISH ROAD TORBAY ROAD CHRISTCHURCH WILLESDEN LANE ABERDA RE GARDENS GOLDHURST TERRACE GOLDHURST KINGSGATE ROAD MAYGROVEROAD FAIRFAX ROAD KING HEN RY’SROAD PARKH LI L ROAD TH URLOW RD FLEET ROAD AGINCOURT ROAD FROGNAL LYMIN GTON ROAD BRAC KNELL GDNS SUMATRA RD HILLFIELD RD LOVERIDGE ROAD IVERSON RD DARTMOUTH ROAD LYDFORD ROAD WALM LANE ANSON ROAD KENDALL ROAD GEARY ROAD FLEETWOOD ROAD SHERRICK GREEN ROAD DEWSBURY ROAD VILLIERS ROAD DEACON ROAD CHAPLIN ROAD SANDRINGHAM ROAD CHURCHILL ROAD PARK AVENUE BRONDESBURY PARK CRANHURST ROAD DONNINGTON ROAD CHAMBERS LANE DOBREE AVENUE UFFINGTON ROAD HERBERT GDNS HOLLAND ROAD CAMDEN HIGH STREET BLACKWALL TUNNEL SOUTHERN APPROACH KNIGHTSBRIDGE ROEHAMPTON VALE A3 KINGSTON ROAD A3 WEST HILL A3 YORK ROAD YORK ROAD BATTERSEA RISE ASPEN WAY Middle Dock North Dock Blackwall Basin Poplar Dock East India Dock Basin WEST INDIA DOCKS South Dock Millwall Outer Dock Royal Albert Dock Royal Victoria Dock North Greenwich Pier Greenwich Pier Masthouse Terrace Pier Greenland Pier Hilton Docklands Nelson Dock Pier Canary Wharf Pier Tower Millennium Pier Bankside Pier Blackfriars Pier Embankment Pier London Eye Pier Millbank Pier St George Wharf Pier Cadogan Pier Chelsea Harbour Pier Wandsworth Riverside Quarter Pier Putney Pier London Bridge City Pier River Lea or Lee Greenland Dock South Dock Marina Grand Union Canal –Paddington Ar m Little Venice Paddington Basin Regent’s Canal Boating Lake Regent’s Canal Battlebridge Basin City Road Basin Wenlock Basin Regent’s Canal K ni gs al nd Regent’s Canal Hertford Union Canal West Lake East Lake Lee Nav gi at oi n Lee Navigation River Lea or Lee City Mill River Waterworks River Three Mills Wall River Prescott Channel Abbey Creek Channelsea River Bow Back Rivers River Lea or Lee Limehouse Cut Bow Creek Regent’s Canal Limehouse Basin Millwall Inner Dock River Thames River Thames River Thames Rive r T h a m e s The Serpentine Round Pond St Katharine Docks Shadwell Basin Boating Lake River Wandle King’s Mere River Ravensbounr e River Quaggy Deptford Creek River Ravensbourne Battersea Park Clapham Common Wandsworth Common Wandsworth Park Hurlingham Park Bishops Park South Park Barn Elms Playing Fields Barnes Common Putney Lower Common Roehampton Golf Club Roehampton Playing Fields Barnes Green Eel Brook Common Parsons Green Imperial Park York Gardens Falcon Park Heathbrook Park Larkhall Park William Parnell Park Brompton Cemetery Ranelagh Gardens Burton Court Green Park St James’s Park Kennington Park Myatt’s Fields Slade Gardens Max Roach Park Wyck Gardens Windmill Gardens Burgess Park Ruskin Park Greendale Playing Fields Sunray Gardens Brockwell Park Dulwich Park Peckham Rye Nunhead Cemetery Brockley and Ladywell Cemetery Hilly Fields Park Deptford Park Folkestone Gardens Bridgehouse Meadows Southwark Park Stave Hill Ecological Park Greenwich Park Blackheath Mountsfield Park Blackheath Park Old Colfeians Sports Ground Lewisham Park Charlton Park Hornfair Park Maryon Wilson Park Maryon Park Greenwich Peninsula Ecology Park Mudchute Park West Ham Park East London Crematorium Hermit Road Recreation Ground Plaistow Park Queen Elizabeth Olympic Park Victoria Park Well Street Common London Fields Haggerston Park Shoreditch Park Weavers Fields Bethnal Green Gardens Millennium Park King Edward VII Park Meath Gardens Mile End Park Stepney Green Park Tower Hamlets Cemetery Park Hackney Downs Hackney Marsh Wanstead Flats Manor Park Cemetery Woodgrange Park Cemetery Plashet Cemetery Plashet Park Beckton District Park North Thames Barrier Park Brampton Park Wick Woodland Drapers Field Mabley Green Highbury Fields Millwall Park Sutcliffe Park Horn Park Northbrook Park Sports Ground Sports Ground Sports Ground Sports Ground London Marathon Playing Field Althletic Ground Middle Park Field Queenscroft Recreation Ground Eltham Green Greenwich Cemetery Kidbrooke Playing Fields Honor Oak Park One Tree Hill Golf Course Blythe Hill Fields Brockley Hill Park Manor House Gardens Guy’s Hospital Athletic Grounds Ladywell Fields Horniman Gardens Camberwell Old Cemetery Camberwell New Cemetery Belair Park Edward Alleyn Club Ravenscourt Park Margravine/Hammersmith Cemetery Lillie Road Park Bayonne Park Normand Park Fulham Palace Rd Cemetery Holland Park Hyde Park Regent’s Park Primrose Hill Queens Park Lord’s Cricket Ground Saint Mary’s Catholic Cemetery Kensal Green Cemetery Paddington Old Cemetery Kilburn Grange Park Hampstead Cemetery Roundwood Park Willesden New Cemetery Willesden Sports Ground Tiverton Green Wormwood Scrubs Park Little Wormwood Scrubs Paddington Recreation Ground Barnes Wetland King George’s Park Wandsworth Cemetery Tooting Bec Common Putney Heath Richmond Park Wimbledon Common Wimbledon Park Russell Square Lincoln’s Inn Fields Gray’s Inn Brunswick Square / Coram’s Fields Barnard Park Paradise Park Caledonian Park St Mary Magdalene Garden Inner Temple Gardens Bunhill Gardens Victoria Embankment Gardens Kensington Gardens Vauxhall Park Pasley Park Lambeth Palace Gardens Archbishop’s Park Vauxhall Pleasure Gardens The Oval Jubilee Gardens Victoria Tower Gardens Buckingham Palace Gardens The O2 Buckingham Palace Houses of Parliament St Thomas’s Hospital National Gallery London Eye Southbank Centre Oxo Tower Courtauld Gallery King’s College LSE Tate Modern Tower of London St Paul’s Cathedral Barbican St Bartholomew’s Hospital Tate Britain Westminster Abbey V & A Science Museum Kensington Palace Natural History Museum The Shard Shakespeare’s Globe Guy’s Hospital Imperial War Museum British Museum Homerton Hospital Great Ormond Street Children’s Hospital Hospital of St John and St Elizabeth Royal Free Hospital UCH SOAS Birkbeck Moorfields Eye Hospital City University London Newham University Hospital The Royal London Hospital Queen Charlotte’s & Chelsea, and Hammersmith Hospitals St Mary’s Hospital King’s College Hospital Charing Cross Hospital Chelsea & Westminster Hospital Royal Marsden Hospital Royal Brompton Hospital Design Museum Royal Opera House London Transport Museum Museum of London National Maritime Museum Queen’s House Royal Observatory Geffrye Museum V&A Museum of Childhood Mile End Hospital Queen Mary University of London HMS Belfast Horniman Museum Royal Academy of Arts Saatchi Gallery Serpentine Gallery Whitechapel Gallery Camden Arts Centre Dulwich Picture Gallery Estorick Collection Wallace Collection White Cube Gallery The Gherkin Westfield London Shopping Centre Harrods Harvey Nichols Selfridges John Lewis Fortnum & Mason Peter Jones Bank of England Leadenhall Market Camden Market Southwark Cathedral Borough Market Columbia Road Flower Market Portobello Market Spitalfields Market Covent Garden Market Madame Tussauds British Library ExCeL London Chelsea FC Earl’s Court Exhibition Centre Westfield Stratford Shopping Centre West Ham United FC New Covent Garden Market Flower Market Imperial College Royal Albert Hall UCL 0 1 km 0 1 mile National Rail Station DLR Station London Overground Station Tube Station Map base © maproom.net 5 things that the City’s top legal teams do that help their claimants win “mastering the facts: sound arguments must be rooted in facts and supported by appropriate evidence.“ Richard Lewis and Markus Burgstaller, Hogan Lovells “understand the interests and goals of the client– whether an individual, company, or a State.” Mark McNeill and Jeremy Sharpe, Shearman and Sterling “choose your witnesses with care. You may not have much choice over the fact witnesses, but your choice of experts can make or break the case.“ James Kennedy Reza Mohtashami, Freshfields Bruckhaus Deringer “See everything through the eyes of the tribunal.“ Peter Goldsmith and Patrick Taylor, Debevoise & Plimpton “a good team will master the key facts early and identify (as far as possible) the strongest claims from the outset.“ Adrian Lifely and Greg Fullelove, Osborne Clarke “risk is the relationship between impact and probability. For disputes; what is the likelihood of success versus the impact of a loss?” Iain McKenny, Vannin Capital “Pick your strong points and focus on them; do not run bad points too, they distract from the good ones.” Ali Malek and Christopher Harris, 3 Verulam Buildings Funding in Focus Content Series VANNIN CAPITAL | 19 BOROUGH OF GREENWIC H BOROUGH OF LEWISHAM BOROUGH OF W A NDSWOR T H BOROUGH OF RICHMON D BOROUGH OF L AMBET H BOROUGH OF SOUTHW A R K BOROUGH OF NEWHAM BOROUGH OF C AMDEN BOROUGH OF BREN T BOROUGH OF ISLING T O N BOROUGH OF HACKNE Y BOROUGH OF H AMMERSMITH & FULHAM BOROUGH OF KENSING T O N & CHELSEA CITY OF W ESTMINSTE R C ITY OF LONDO N BOROUGH OF T OWER HAMLETS CLERKENWELL SHOREDITCH SPI TA LFIELDS W A PPIN G SHADWELL STEPNE Y LIMEHOUS E MILE EN D B O W GLOB E T O W N BROMLE Y STRATFORD P LAIST O W S I LV E R T O W N WOOLWIC H KIDBROOK E LEWISHAM NEW CROSS PECKHAM EAS T DULWICH DULWIC H NUNHEAD HONOR OA K BROCKLEY FOREST HILL CHARLT O N BECKT O N U P T O N PA R K U P T O N POPLAR DOCKLAND S MILLW A L L GREENWIC H PENINSULA GREENWIC H DEPTFOR D SURREY QU AY S ROTHERHITH E BLACKHEAT H E LTHAM ISLE OF DOGS HOXT O N DALS T O N HACKNE Y HACKNE Y WIC K BETHNA L GREE N HOLBOR N COVEN T GARDEN SOHO S T JAMES’ S PIMLIC O CHELSEA KNIGHTSBRIDGE BELGR AV I A L AMBET H B ATTERSEA W A NDSWOR TH T O W N SOUTHFIELD S EARLSFIEL D W EST HILL PUTNEY BARNE S FULHAM EAR L ’ S COUR T H AMMERSMITH W EST KENSING T O N SHEPHERD’S BUSH CHELSEA HARBOU R ROEHAMPT O N CLAPHAM S T OCKWEL L KENNING T O N BRIX T O N HERNE HILL TULSE HILL STRE AT HAM HILL CLAPHAM PA R K SOUTHW A R K BOROUG H W A LWOR T H CAMBER WELL BERMONDSEY SOUTH BAN K W ESTMINSTE R PA DDINGT O N B AYSW AT E R NOTTING HILL N O R T H KENSING T O N KENSAL T O W N KENSAL GREEN KILBURN BRONDESBU R Y WILLESDEN GREEN MAR YLEBONE MAIDA VA L E S T JOHN’S WOOD PRIMROSE HILL C AMDEN T O W N KENTISH T OWN KINGS CROS S ISLING T O N BARNSBU R Y CANONBUR Y DE BEAUVOIR T O W N HIGHBU R Y SOUTH HAMPSTEAD W EST HAMPSTEAD M AY FA I R KENSING T O N BLOOMSBU R Y Canary Wharf West India Quay Westferry Stepney Green Whitechapel Shadwell Limehouse Wapping Rotherhithe Bermondsey Canada Water Surrey Quays Poplar Blackwall East India All Saints Langdon Park Devons Road Bow Church Bow Road Bromley-by-Bow West Ham Abbey Road Star Lane Canning Town Royal Victoria West Silvertown Pontoon Dock Custom House Prince Regent Royal Albert London City Airport Plaistow Pudding Mill Lane Stratford High Street Stratford Maryland Wanstead Park Forest Gate Manor Park Woodgrange Park Upton Park Stratford International Hackney Wick London Fields Homerton Hackney Central Hackney Downs Dalston Kingsland Dalston Junction Haggerston Mile End Bethnal Green Bethnal Green Cambridge Heath Hoxton Heron Quays Canary Wharf North Greenwich South Quay Crossharbour Mudchute Island Gardens Cutty Sark Greenwich Deptford Bridge Elverson Road Deptford New Cross New Cross Gate ELL Queens Road Peckham South Bermondsey Maze Hill Charlton Westcombe Park Edgware Road Baker Street Marylebone Goodge Street Regent’s Park Great Portland Street Warren Street Euston Square Mornington Crescent Camden Town Camden Road Chalk Farm Kentish Town West Kentish Town Gospel Oak Hampstead Heath Finchley Road & Frognal Belsize Park Finchley Road West Hampstead Thameslink West Hampstead Kilburn Willesden Green Dollis Hill Brondesbury Park Queens Park Kilburn Park Kensal Rise Willesden Junction Kensal Green Brondesbury Swiss Cottage South Hampstead Kilburn High Road St John’s Wood Russell Square Euston King’s Cross Angel Essex Road Highbury & Islington Canonbury Caledonian Road Caledonian Road & Barnsbury Holloway Road Drayton Park St Pancras Maida Vale Paddington Marble Arch Bond Street Tottenham Court Road Oxford Circus Lancaster Gate Old Street Moorgate Blackfriars Temple Holborn Farringdon Barbican Chancery Lane Covent Garden Embankment Westminster Pimlico Vauxhall Oval Stockwell Battersea Park Queenstown Road Imperial Wharf Fulham Broadway West Brompton West Kensington Earl’s Court Barons Court Hammersmith Kensington Olympia Shepherd’s Bush Shepherd’s Bush Market Goldhawk Road Wood Lane White City Latimer Road Ladbroke Grove Westbourne Park Holland Park Notting Hill Gate Queensway Bayswater Royal Oak Warwick Avenue East Acton Ravenscourt Park Stamford Brook Parsons Green Putney Bridge Barnes Wandsworth Road Clapham North Brixton Loughborough Junction Denmark Hill Peckham Rye East Dulwich Honor Oak Park Forest Hill Catford Catford Bridge Hither Green Lee Kidbrooke Blackheath Crofton Park Brockley St Johns Lewisham Ladywell Nunhead North Dulwich Herne Hill Clapham Common Clapham South Wandsworth Common Earlsfield Southfields East Putney Putney Balham Streatham Hill Clapham Junction Wandsworth Town Clapham High Street Kennington Elephant & Castle Lambeth North Southwark Borough London Bridge Waterloo Waterloo East Piccadilly Circus Green Park Knightsbridge South Kensington Gloucester Road High Street Kensington Sloane Square Victoria St James’s Park Hyde Park Corner Leicester Square Charing Cross Cannon Street Mansion House Liverpool Street Aldgate Tower Hill Tower Gateway Monument Aldgate East Fenchurch Street Shoreditch High Street Central Street Moreland Street Spencer Street Myddelton St Exmouth Market Margery Street Great Percy St Amwell Street Blundell Street Sheringham Road Halton Street Rippleford Grove Thornhill Road Huntingdon Street Tolpuddle Street Rodney Str eet Cloudesley Road Carnegie St Donegal Street Colebrooke Row Elizabeth Ave Ecclesbourne Rd Britannia Row Alwyne Road Canonbury Cr Ockendon Road Oakley Road Elmore Street Shepperton Street Popham Street Basire Street StPeter’s Street Noel Road St Paul Street Linton Street Arlington Avenue Wenlock St Wenlock Road Murray Grove Nile Street Chart St Hoxton Street Mintern Street Hyde Rd Bridport Place Phillipp Street Crondall St Falkirk St Nuttall St Pitfield Street Hox ot n Street Orsman Road Downham Road Hertford Road Road Hertford Ardleigh Rd Culford Road Englefield Rd De Beauvoir Road Buckingham Rd Tottenham Road Stamford Road Albion Drive Forest Road Richmond Road Middleton Road Hol yl Street Whiston Road Brownlow Road Haggerston Road Laburnum Street How’s Street Appleby Street Queensbridge Road Dunloe Street Quaker Street Buxton Street Bacon Street Virginia Road Swanfield Street Calvert Ave Club Row Derbyshire Street Vallance Road St Matthew’s Row Wellington Row Columbia Road Columbia Road Gosset Street Corfield Street Wilmot Street W estfield Way Cleveland Way Sceptre Road Braintree Street Cephas Avenue Colebert Avenue Cephas Street Alderney Road Grantley Street Bancroft Road Morpeth Street Palmers Road Road Bonner Approach Road Pritchard’s Road Goldsmith’s Ro Whiston Road w Tudor Road Sheep Lane Broadway Market Andrews Road Regent’s Row Brougham Road Pownall Road Marlborough AVenue Shrubland Road Albion Drive Middleton Road Lavender Grove Mapledene Road Greenwood Roa F d orest Road Gayhurst Road Martello Street Lansdowne Drive Wilton Way Richmond Road Chatham Place Valentine Road Oriel Road Mabley Street Churchill Walk Rushmore Road Rushmore Road Townmead Road Peterborough Road Carnwath Road Broomhouse Lane Hurlingham Road Clancarty Road Studdridge Street Imperial Road Woodlawn Road Stevenage Road Greyhound Road Seagrave Road Sydney Street Onslow Gardens Addison Gardens Blythe Road Glenthorne Road Hammersmith Grove Paddenswick Road Bloemfontein Road Sawley Road South Africa Road Du Cane Road Portobello R oad Ladbroke Road Chepstow Villas Abootsbury Road Addison Road Holland Villas Road Campden Hill Road Phillimore Gardens Kensington Palace Gardens Earls’s Court Road Marloes Road Vic ot ria Road Queen’s Gate Exhibition Road Prince Consort Road Thurloe Place South Carriage Drive Sloane Avenue Cale Street Manresa Road Old Church Street Beaufort Street The Boltons Tregunter Road Oakley Street BelgraveSquare Belgrave Place Eccleston Street Grosvenor Cres Ebury Street Elizabeth St Warwick Way Rochester Row Lupus Street John Islip Street Marsham Street Great Smith Street Great Peter Street Buckingham Gate Birdcage Walk Constitution Hill The Mall Horse Guard s’ Road Abingdon Street Northumberland Ave Chraing Cross Road St Martin’s Lane St James’s Street Curzon Street New Bond Street Conduit Street Great Marlborough Street Craven Road Connaught Street Seymour Place Portman Sq Upper Berkeley Street George Street York Paddington Street St Gloucester Place Devonshire Street Weymouth Street New Cavendish Street Dean Street Brewer Street Newman Street Wells Street New Oxford Street Great Russell Street Montague Street Bedford Square Torrington Place Malet Street Tavistock Place C althorpe Street Swinton Street Acton Street Sidmouth Street Ski nner Street Percival Street Lloyd Baker Street Aldersgate Street Newgate St Holborn Viaduct Beech Street Farringdon Road Gray’s Inn Road Chancery Lane Fetter Lane Fleet Street Ludgate Hill High Holborn Cheapside Poultry Cannon Street Queen Victoria Street Upper Thames Street Lower Thames Street Gracechurch Street Moorgate Worship Street Curtain Road Shepherdess Walk Eagle Wharf Road Cropley Street Wharf Road Graham Street Baring Street Barnsbury Road Penton Street Copenhagen Street Hemingford Road Richmond Avenue Bewdley Street Barnsbury St Theberton Street Laycock Street Offord Road Lofting Road Bingfield Street Copenhagen Street Brewery Road Market Road Roman Way Bride Street Mackenzie Road Highbury Place H gi hbury Crescent High bury New Park Aberdeen Road Petherton Road Mildmay Road Northchurch Road Do Englefield Road uglas Road Canonbury Park North Halliford Street Rotherfield Street Anson Road Melrose Avenue Ellesmere Road Chapter Road Park Avenue North Exeter Road Teignmouth Road Fordwych Road Mill Lane Chatsworth Road Westbere Road Denzil Road Longst one Avenue Pound Lane Robson Avenue Roundwood Road Doyle Gardens Doyle Gardens Bathurst Gardens Aylestone Avenue The Avenue Chevening Road Purves Road Furness Road St Mark’s Road Oxford Gardens Kensal Road Golborne Road Ashmore Road Fernhead Road Ilbert Street Droop Street Shirland Road Shirland Road Sutherland Avenue Lauderdale Road Abercorn Place Carlton Hill Canfield Gardens Greencroft Gardens Priory Road Abbey Road Victoria Road Compayn e Gardens Broadhurst Gardens Arkwright Road Frognal Lane Blackburn Road Maresfield Gardens Lyndhurst Road Wedderburn Road Belsize Avenue Belsize Park Gardens Eton Avenue Fellows Avenue Lanaster Grove Steele’s Road Eton Road Belsize Lane Sheriff Road King Henry’s Road Elsworthy Road Ave nue Road Primrose Hill Road Regent’s Park Road Chalcot Road Grafton Road Queen’s Crescent Prince of Wales Road Regis Road Leighton Road Bartholomew Road Islip Street Caversham Road Gaisford Street Patshull Road Bartholomew Road Leighton Grove Rochester Place Torriano Avenue Camden Mews Murray Street Cantelowes Road Agar Grove Castle Road Delancey Street Parkway Oval Road Jamestown Road Park Village East S at nhope Street Robert Street Drummond Street Cardington Street Chalton Street Midland Road Ossulston Street Camley Stre et Handyside Street North Road Hungerford Road Dalmeny Avenue Carleton Road Hilldrop Lane Penn Road Hornsey Street Camden Road Eden Grove Benwell Road George’s Road Lough Road Westbourne Road Biddestone Road Hartham Road Drayton Park Horsell Road Mildmay Grove North Mildmay Grove South Aberdeen Park Matthias Road Howard Road Palatine Road Boleyn Road Princess May Road King Henry’s Walk Farleigh Road Sh acklewellLane Cecilia Road Downs Park Road Sandringham Road Queens Down Road Amhurst Road Brooksby’s Walk Glyn Road Waterden Road White Post Lane Westfield Avenue Montfitchet Road International Way Carpenters Road Loop Road Honour Lea Avenue Celebratoi n Avenue Chobham Road Downsell Road Millais Road Hall Road Henniker Road Liberty Bridge Road Temple Mills Lane Colegrave Road Chandos Road Maryland Road Maryland Street Waddington Road Gurney Road Buxton Road Cemetery Road Janson Road Towr Hamlets Road Field Road Odessa Road Vansittart Road Station Road St James’ Road Idmiston Road Ash Road Sebert Road Godwin Road Capel Ro ad Ridley Road Centre Road Tylney Road Cranmer Road Durham Road Hampton Road Osborne Road Claremont Road Windsor Road Tuylney Road Earlham Grove Clova Road Atherton Road Carnarvon Road Keogh Road Margery Park Road Knox Road Ham Park Road Sherrard Road Sherrard Road Halley Road Monega Road Strone Road South Esk Road Bristol Road Stafford Road Derby Road Rutland Road Chester Road Dorset Road St Stephen’s Road Whyteville Road Grosvenor Road St George’s Road Upton Park Road Boleyn Road Neville Road Harold Road Terrace Road Stratford Road Milton Avenue Heigham Road Wakefield Street Grangewood Street Queen’s Road West Southern Road Selsdon Road Corporation Stre et Upper Road Grange Road Hermit Road Western Road Queen’s Road St Mary’s Road Aragon Road New City Road Cotswold Gardens Henniker Gardens Haldane Road Masterman Road HatherleyGardens Montpelier Gardens Jedburgh Road Cumberland Road Wanlip Road Jenkins Road Holborn Road Chadwin Road Glen Road Roman Road Kildare Road Croydon Road Chargeable Lane Star Lane Ma lmesbury Road Bider Street Gainsborough Road Cody Road North Crescent South Cres Twelvetrees Crescent Stephenson Street Tarling Road Redland Road Fords Park Road Vincent Street Ruscoe Road Butchers Road App leby Road Boreham Avenue Varley Road Garvary Road Alnwick Road Churchill Road Baxter Road Dove Approach Eisenhower Rd Seagull Lane Sandstone Lane Tidal Basin R d Wesley Avenue Evelyn Road Mill Road Knights Road Bradfield Road Thames Road Caistor Park Road East Road Crescent Rd Dacre Road Gwendoline Avenue Church Street Meath Road Holbrook Road Abbey Road Rokeby Street Paul Street Abb ey Lane Abbey Lane Carpenters Road Sugar House Lane Tredegar Road St Stephen’s Road Driffield Road Armagh Road Wick Lane Malmesbury Road Lichfield Road Medway Road Anthill Road Coborn Road Morgan Street Alfred Street Bruce Road Bow Common Lane Thomas Road Ackroyd Drive Lindfield Street Cordelia Street Brabazon Street St Leonards Road Uamvar St er et Teviot Street Leven Road Abbott Road Dee Street Blair Street Co tton Street Canton Street Grundy Street Marsh Wall Marsh Wall Byng Street Alpha Grove Mastmaker Road Millharbour Road East Ferry Road Spindrift Avenue Stebondale Street Saunders Nes s Road Chapel House Street Tiller Road Gascoyn e Road Ballance Road Lee Conservancy Road Ashenden Road Roding Road Homerton Grove Darnley Road Retreat Place Cadogan Terrace Morpeth Road King Edward’s Road Loddiges Road Brenthouse Road Southborough Road Daubeney Road St John Street Compton Street Seward Street Bastwick St Gee Street Banner Street Whitecross Street Radnor St Golden Lane Goswell Road City Road Leonard Road Tabernacle Srt eet Appold Street Folgate Street Brushfield Street Hanbury Street Princelet Street Old Montague Street Chicksand Street Fieldgate Street Varden Street Nelson Street Stepney Way Redmans Road Stepney Way Jamaica Street Jubilee Street Bromley Street Aylward Street Clark Street Ernest Street Shandy Street Harford Street Duckett Street Ben Jonson Road Copperfield Road Salmon Lane Aston Street Sutton Stree C t hristian Stree B t ack Church Lane Pennington Street Vaughan Way Kennet Street Wapping High Street Prusom Street Wapping Wall Garnet Street Wapping L ane Leman Street Alie Street Prescot Street Mansell Street Middlesex Street Minories Houndsditch London Wall Leadenhall Street Fenchurch Street Great Tower Street Gresham Street West Smithfield Giltspur St Old Bailey Carter Lane Tudor Street S hoe Lane Carey Street Drury Lane Rosebery Avenue Leather Lane Phoenix Place Roger Street Northington St Old Gloucester Street Gough Street Whitehall Place Regency Street Page Street Erasmus Street Vincent Square St George’s Square Moreton St er et Churchill Gardens Road Sutherland Street St George’s Drive Palace Street Carlisle Place Francis Street Petty France Bressenden Place Wilton Road Lower Belgrav e Street Easton Place Eaton Terrace Bourne Street Holbein Place Lower Sloane Street St Leonard’s Ter Tite Street Smith St Markham St Elystan Street Ixworth Place Cranley Gardens Roland Gdns Gilston Road Drayton Gardens Beaufort Street The Vale Cathcart Road Redcliffe Road The Little Boltons Draycott Avenue Draycott Place Walton Street Hans Road Kinnerton Street Cadogan Place Cadogan Lane Pavilion Road Pavilion Road Motcomb St Eaton Place Chapel Street Princes Gardens Ennismore Gdns Harrington Gardens Wetherby Gdns Collingham Road Gloucester Road Laverton Place Elvaston Place Cornwall Gardens Wrights Lane Lexham Gardens Hornton Street Palace Avenue Palace Gardens Terrace Brunswick Gdns Bedford Gardens Kensington Place Uxbridge Street Peel Street Duchess of Bedford’s Walk Phillimore Walk Pembroke Villas Melbury Road Holland Park Road Edwardes Sq Holland Park Holland Park Mews Holland Park Lansdowne Road Ladbroke Square Portland Road Pottery Lane Princedale Road Queensdale Road St James’s Gardens Wilsham Street Sirdar Road Walmar Road Elgin Crescent Blenheim Crescent Cornwall Crescent Dawson Place Chepstow Place Garway Road Moscow Road Pembridge Cr es Westbourne Grove Talbot Road Westbourne Park Villas P orchester Road Tavistock Road Lancaster Road Colville Terrace Lonsdale Road Lancaster Road St Ann’s Road Freston Road Cambridge Gardens Bassett Road Pangbourne Ave St Charles Square Chesterton Road Dalgarno Gardens Sutton Way Australia Road Commonwealth Ave Australia Road Dorando Close Ellerslie Road Adelaide Grove Ormiston Grove Galloway Road Wormholt Road Bryony Road Lime Grove Pennard Road Scotts Road Coningham Road Godolphin Road Loftus Road Stan ak l e Road Frithville Gardens Greenside Road Cathnor Road Stowe Road Goodwin Road Findon Road Davisville Road Becklow Road Cobbold Road Rylett Road Bassein Park Road Ravensco urt Gardens Dalling Roa d Benbow Road Brackenbury Road Agate Road Iff ey l Road Richford Street Sulgrave Road Cardross Street Nasmyth Street Adie Road Banim Street Ravenscourt Road Ravenscourt Park Stamford Brook Ave R|avenscourt Square Prebend Gardens Netheravon Road Airedale Avenue Chiswick Mall British Grove St Peter’s Square Black Lion Lane Beavor Lane Standish Road Upper Mall Welt ej Rd Rivercourt Rd Rutland Grove Queen Caroline Street Black’ s Road Studland St Cambridge Gr Chancellor’s Road Yeldham Road Biscay Road Beryl Road Crisp Road St Dunstan’s Rd Margr avine Road Margravine Gardens WinslowR oad Parfrey Street Rannoch Road Rainville Road Crabtree Lane Niton Street Lysia Street Queensmill Road Langthorne Street Kenyon Street Inglethorpe Street Harbord St Finlay St Ellerby Street Doneraile Street Cloncurry Street Bishop’s Park Road Bishop’s Avenue Greyhound Road Field Road EveringtonSt Tasso Road Kinnoul Rd Musard Road Brecon Road Comeragh Road Vereker Road Star Road Bramber Road Normand Road Chaldon Road Prothero Road Mendora Road Delaford Street Rylston Road Estcourt Road Haldane Road Hartismere Road Fabian Rd Mirabel Rd North End Road Shorrolds Rd Sedlescombe Road Ongar Road Halford Road Racton Road Anselm Road Farm Lane Walham Grove Farm Lane Barclay Road Moore Park Road Harwood Road Wat erford Road Musgrave Crescent Britannia Rd Rockley Road Netherwood Road Lakeside Road Bolingbroke Road Richmond Way Sinclair Ro M ad ilson Ro M ad asbro Road Augustine Roa Du d nsany Road Blythe Road Brook Green Brook Green Rowan Road Caithness Rd Aynhoe Rd Girdlers Road Blythe Rd Gunterstone Road Edith Road Batoum Gdns Hemlock Road Steventon Road Sundew Avenue Daffodil St Yew Tree Rd Aycliffe Rd Dunraven Road Russell Road Avonmore Road Glidon Rd Colet Gardens Shortlands Butterwick Kingwood Road Munster Road Wardo Avenue Gowan Avenue Colehill Lane Waldemar Avenue Munster Road Sherbrooke Road St Maur Road St Dionis Road Novello Street Crondace Road Munster Road Fulham Park Gard ens Napier AVenue Perrymead St Haz eb l u yr Road Broughton Road Hugon Road Stephendale Road Bagleys Lane Hortensia Road Lots Road Lots Road Tadema Road Limerston Street Milman’s St Park Walk Paulton’s Square Elm Park Road Pelham Street Chelsea Manor St Flood Street Radnor Walk Glentham Road Tri nity Chur ch Road Boileau Road Nowell Road Barnes Avenue Verdun Road Washington Road Madrid Road Suffolk Road Westmoreland Road Nassau Road Church Road Queen Elizabeth Walk Elm Grove Road Ranelagh Avenue Glebe Road Gerard Road Comm on Road Vine Road Embankment Festing Road Felsham Road Hotham Road Clarendon Drive Putney High Street Deodar Road Montserrat Road Werter Road Disraeli Road Fawe Park Road Norroy Road Chelverton Road Erpingham Road Dryburgh Road Sefton Street Dover House Road Huntingfield Road Putney Park Lan Parkstead R e oad Crestway Dover Park Drive Dover House Drive Roehampton High St Medfield Street Westmead Holford Way Clarence Lane Danebury Avenue Laverstoke Gardens Ibsley Garde ns Alton Road Bessborough Road Telegraph Road Portsmouth Road Wildcroft Road Howards Lane Hazlewell Road Malbrook Road Colinette Road Larpent Avenue Luttrell Avenue Chartfield Avenue Gwendolen Avenue St John’s Avenue Cambalt Road Westleigh Avenue Genoa Ave Cortis Road St John’s Avenue Carlto n Drive Keswick Road Portinscale Road Lytton Grove Rusholme Road Kersfield Road Eastfields Ave O akhill Road Schubert Road Galveston Road Mexfield Road Cromford Road Santos Road Wandsworth High Street East Hill Swandon Way Trinity Road Wandsworth Common North Side Trinity Road Plough Road Nantes Close Harbut Road Alma Road Elsynge Road Spencer Rd Wandsworth Common West Sdi e Spencer Park Windmill Rd Spencer Park Geraldine Road Melody Rd Heathfield Road Westover Road Allfarthing Lane St Ann’s Hil V l ermont Rd Iron Mill Rd Swaffield Road St Ann’s Hill Kimber Road Aslett Street Bassingham Rd Wilna Rd Lydden Rd Winfrith R d Brathway Road Merton Road Ringford Road Haldon Road West Hill Road West Hill Road Melrose Road Granville Road Wimbledon Park Road Seymour Road Pulborough Rd Sutherland Grove Gi rdwood Road Skeen a Hill Combemartin Roa d Beaumont Road Princes Way Augustus Road Augustus Road Victoria Drive Albert Drive Inner Park Road Victoria Drive Princes Way Gartmoor Gardens PirbrightRo ad Merton Road Merton Road Durnsford Rd Replingham Road Balvernie Grove Standen Road Longfield St Brookwood Road Lavenham Road Revelstoke Road Elsenham Street Heythorp Street Clonmore street Engadine Street Elborough Street Trentham Street Astonville Street Ravensbury Road Mount Rd Penwith Road Strathville Rd Haslemere Ave Garratt Lane Wandle Way Vanderbilt Rd Brocklebank Rd Tranmere Road Swaby Road Openview Fieldview Godley Road Tilehurst Road Ellerton Road Loxley Road Frewin Road Herondale Avenue Lydford Road Beechcroft Road Brodrick Road Wandle Road Hendham Road Dalebury Road St James’s Drive Balham Park Road Sarsfeld Road Boundaries Road Row fant Road UpperTooting Park Marius Rd Oakme ad Road Elmfield Road Cloudesdale Rd Byrne Road Bedford Hill Dornton Road Fernlea Road Rossiter Road Sistova Road Laitw ood Road Ormeley Ro ad Old Devonshire Rd Balham New Rd Ravenslea Road Mayford Road Chestnut Grove Endlesham Road Ramsden Road Balham Grove Oldridge Road Alderbrook Road Badminton Road Dinsmore Rd Yukon Rd Dagnan Road Cathles Road Gaskarth Road Hazelbourne Rd Englewood Road Sudbrooke Road Thurleigh Road Montholme Road Gayville Road Devereux Road Hillier Road Wroughton Road Kyrle Road Broxash Road Manchuria Road Roseneath Road Honeywell Road W Chatto Road ebb’s Rd S Wakehurst Road alcot Road Leathwaite Road Bennerley Rd Mallinson Rd Shelgate Road Grandison Road Alfriston Road Muncaster Road Canford Road CulmstockRd Winsham Grove Clapham Common West Side Salcott Rd Wakehurst Rd Belleville Rd Kelmscott Rd Bramfield Rd Old Par k Ave Baskerville Road Bolingbroke Grove Lavender Sweep Lavender Walk Lavender Gardens Grant Road Ingrave Street Este Road Cabul Road Lombard Road Gwynne Road Vicarage Crescent Battersea High Street Shuttleworth Road Orbel Street Bridge Lane Surrey Lane West bridge Road BatterseaChurch Road Parkgate Road Cambridge Rd Rosenau Rd Albert Bridge Road Prince of Wales Drive Brynmaer Rd Warriner Gardens Lurline Gardens Queenstown Road Dagnall Street Burns Road Sheepcote Lane Culvert Road Eversleigh Road Eversleigh Road Tyneham Road Ashbury Road Sabine Road Elsley Road Eland Road Stanley Grove Ingelow Road St Philip Street Tennyson Street Sugden Road Mysore Road Sto mr ont Road Taybridge Road Gowrie Road Dorothy Road Thessaly Road Stewart’s Road Robertson Street Wandsworth Road Victoria Rise The Chase Macaulay Road Lillieshall Rd North Street Larkhall Rise Clapham Manor St Gauden Road Edgeley Road Union Road Chelsham Road Timber Mill Way Larkhall Lane Jeffreys Road Studley Road Lansdowne Way Priory Grove Wandsworth Road Hartington Road Thorne Road Guildford Road Dorset Road Fentiman Road Fentiman Road Palfrey Place Harleyford Road Meadow Road Vauxhall Street Black Prince Road Sancroft Street Courtenay Street Vauxhall Walk Lambeth Walk Fitzalan Street Wincott St Renfrew Road Lambeth Palace Road Westminster Bridge Road Hercules Road Hayles Street Brook Drive York Road Belvedere Road Upper Ground Stamford Street The Cut Hatfields Southwark Street Union Street Borough High Street Southwark Bridge Road Trinity Street Newington Causeway Tabard Street Manciple Street Falmouth Road Deverell Street Snowsfields WestonStreet Newcomen St St Thomas Street Tooley Street Shad Th ames Tooley Street Druid Street Tower Bridge Road Spa Road GrangeWalk Willow Walk Mandela Way Bath Terrace Rodney Road Heygate Street East Street Brandon Street Thurlow Street Chatham Street Congreve Street East Street Portland Street Merrow Street Inville Road Dawes Street Surrey Square Kinglake Street Mina Road Penton Place Braganza Street De Laune Street Kennington Park Place Cook’s Road Royal Road John Ruskin Street Grosvenor Terrace Bethwin Road Wyndham Road Medlar Street C omber Grove Fielding Street Penrose Street Manor Place Lorrimore Road Edmund Street Benhill Road Elmington Road St Giles Road Havil Street Dalwood Street St George’s Way Chandler Way Sumner Road Sumner Road Cobourg Road Glengall Road Haymerle Road Green Hundred Road Friary Road Naylor Road Meeting House Lane Asylum Road Asylum Road Fenham Road Carlton Grove Montpelier Road Goldsmith Road Clifton Way Caldwell Street Vassall Road Foxley Road Cranmer Road Hackford Road Hillyard Street Stockwell Park Road Groveway Lorn Road Robsart St Sidney Road S ot ckwellParkC er s Aytoun Road Liberty Street Lingham Street Combermere Road Dalyell Road Mordaunt St Hargwyne Street Ferndale Road Hubert Grove Sandmere Road Solon Road Corrance Road Ballater Road Cowley Road Mosty n Road AkermanRoad Co mr ont Road Knatchbull Road Paulet Road Lilford Road Minet Road Loughborough Road Barrni gton Road Wiltshire Ro ad Flaxman Road Denmark Road Flodden Road Calais Stre et Camberwell Station Road Warner Road Crawford Road Coldharbour Lane Atlantic Road Nelsons Row St Alphonsus Road Crescent Lane Elms Road Park Hill Crescent Lane Lepoc Road Elms Crescent Rodenhurst Road Narbonne Avenue Ha mbalt Road Klea Ave Clarence Cresce nt Lyham Road Kingswood Road New Park Road Dumbarton Rd Jebb Avenue Lambert Road Branksome Road Strathleven Road Sudbourne Road Hayter Road Baytree Road Atkins Road Weir Road Hydethorpe Road Cambray Road Midmoor Road Radbou rne Road Burnbury Road Haverhill Road Emmanuel Road Kings Avenue New Park Road Drewstead Road Sternhold Avenue Criffel Ave Telford Avenue Tierney Road Kirkstall Road Palace Road Wavertree Road Downton Avenue Cricklade Avenue Barcombe Avenue Hillside Road Lanercost Road Palace Road Daysbrook Road Abbots Park Gaywood Close AthloneR oa C d laverdale Road Elm Park Leander Road Helix Road Arodene Road Fairview Place Brixton Water Lane St Matthew’s Road Dalberg Road Rattray Road Saltoun Road Somerleyton Road Loughborough Park Shakespeare Road Moorland Road Mayall Road Kellett Road Me rvan Road Talma Road Barnwell Road Effra Parade Chaucer Road Spenser Road Shakespeare Road Milton Road Herne Hill Road Lowden Road Fawnbrake Avenue Poplar Road Finsen Road Ferndene Road Poplar Walk Brantwood Road Dorchester Drive Kestrel Avenue Red Post Hill Sunray Avenue Dylways Woodfarrs Red Post Hill Beckwith Road E ml woodRoad Danecroft Road Frankfurt Road Elfindale Road Homdene Avenue Hollingbourne Road Ruskin Walk Champion Hill Champion Hill Denmark Hill Lowth Road De Crespigny Park Grove Lane Camberwell Grove McNeil Road Grove Park Grove Park Chadwick Road Choumert Road Copleston Road Danby Street Avondale Rise Bellenden Road Oglander Road Ondine Road Adys Road Choumert Rd Rye Lane McDermott Road Fenwick Road Vestry Road Grace’s Road Shenley Road Crofton Road Bushey Hill Road Talfourd Road Lyndhurst Grove Denman Road Lyndhurst Way Bellenden Road Hanover Park Clayton Road Cope al nd Road Consort Road Heaton Road Peckham Rye Nutbrook Street Amott Road Gowlett Rd Peckham Rye Gordon Road Kirkwood Road Lugard Road Cossall Walk Brayards Road Hollydale Road Ansdell Road St Mary’s Road Lausanne Road Deronda Rd Lovelace Road Rosendale Road Rosendale Road Rosendale Road Carson Road Thulow Hill Croxted Road Turney Road Park Hall Road Gallery Road College Road College Road Burbage Road Burbage Road Turney Road DulwichVil al ge Frank Dixon Way Court Lane Woodwarde Road Calton Avenue Dovercourt Road Beauval Road Townley Road Me bl ourne Grove Ashbourne Grove Pytchley Road Crystal Palace Rd Upland Rd Crystal Palace Road Whateley Road Landcroft Road Fellbrigg Road Silvester Roa Pellatt Roa d d Ulversfcroft Rd Darrell Road Hindmans Road Goodrich Road Friern Road Friern Road Henslowe Road Friern Road Upland Road Upland Road Du nstans Road Overhill Road Underhill Road Wood Vale Langton Rise Wood Vale Hillcourt Road Landells Road Dunstans Road St Aidan’s Road Ryedale Colyton Road Oakhurst Grove Westwood Park Westwood Park Tewkesbury Avenue Canonbie Road Netherby Road Manor Mount Devonshire Road D evonshire Road DunoonRoa d Mundania Road Therapia Road Marmora Road Scutari Rd Shelbury Rd Dovedale Rd Brenchley Gardens Kelvington Road Waldram Park Roa d Church Rise Sunderland Road Kemble Road Crans ot n Road Beadnell Road Malham Road Garthorne Road Bovill Road Colfe Road Kilmorie Road Elsinore Road Hurstbourne Road Vancouver Road Marler Road Blythe Vale Elm Lane Faversham Road Blythe Hill Lane St German’s Road Brockley Park Lowther Hill Brockley View Duncombe Hill Codrington Hill Montem Road Bankhurst Road Ravensbourne Park Cres Ravensbourne Park Stillness Road Brockley Rise Crofton Park Road Salehurst Road Bexhill Road Manwood Road Ewhurst Road Marnock Road Sevenoaks Road Grierson Road Buckthorne Road Manwood Road Brenchley Gardens Athenlay Road Inverton Road Brockley Way Turnham Road St Norbert Road Limesford Road Water Mew s Linden Grove Nunhead Lane Kimberley Avenue Lynton Road St James s’ Road Galleywall Road Blue Anchor Lane Marlborough Grove Chambers Street George Row Bevington Street Drummond Road Southwark Park Road Raymouth Road Camilla Road Lynton Road Catlin St Verney Road Credon Road Ilderton Road Surrey Canal Road Mercury Way Avonley Road Surrey Quays Road QuebecWay Rotherhithe Street Rotherhithe Tunnel Needleman Street Rotherhithe Street Rotherhithe Street Finland Street Rope Street Timber Pond Road Hawkstone Road Rotherhithe New Road Bush R oad Trundley’s Road Oldfield Grove Silwood Street Plough Way Grove Street Oxestalls Road Grinstead Road Ca nal Approach Scawen Road Landmann Way Bacl khorse Road Gosterwood Street Juno Way Rolt Stre et Childers Street Abinger Grove Arklow Rd Edward Street Amersham Vale Brocklehurst Street Camplin Street Kender Street Pag nell Street Achilles St Watergate Street Prince St Deptford Green Creekside Deptford High Street Watson’s Street Milton Court Road New Cross Road Am ersham Road Florence Road Heald St Albyn Rd Vanguard St Friendly Stree Ta t nner’s Hill Lucas Street Albyn Rd Cranbrook Rd Ashmead Road Brookmill Road Thur ston Ro ad Shardeloes Road St Donatts Road Barr ei da el Rokeby Road Upper Brockley Road Ashby Road Lewisham Way Upper Brockley Road Manor Avenue Wickham Road Breakspears Mews Breakspears Road Wickham Mews Ashby Mews Geoffrey Rd Cranfield Road Harefield Rd Wickham Road Tressillian Road Harefield Road Tyrwhit Road Hilly Fei lds Cres cent Jerningham Road Jerningham Road Musgrove Road Pepys Road Erlanger Road Arbuthnot Road Waller Road Kitto Road Vesta Road Endwell Road Shardeol es Road Sprules Road Wallbutton Rd Pepys Road Gellatly Road Dennett’s Road Bousfield Road Avignon Road St Asaph Road St Norbert Road Revelon Road Pincott Place Aspinall Rd Harlescott Road Howson Rd Braxfield Road Comerford Road Brockley Road Harcourt Road Dalrymple Road Ivy Road Brockley Grove Montague Avenu e Ladywell Rd Chudleigh Road Arthurdon Road Amyruth Road Elsiemaud Road Malyons Road Vicars Hill Brookbank Road Ellerdale Street Marsa al Road Algernon Road Emb el ton Road Shell Road Cliffview Road Sandrock Road Slagrove Pl ace AlbacoreCrescent Doggett Road Hawstead Road Bradgate Road Canad ai n Avenue Holbeach Road Fordmill Road Sangley Road Culverley Road Bargery Road St Fillans Road Thornsbeach Road Sandhurst Road Dowanhill Road Torridon Road Wellmeadow Road Muirkirk Road Hither Green Lane Springbank Road Stainton Road Davenport Road La el ham Road Minard Road Hither Green Lane Fur he t r Gree n Road St Mildreds Road Burnt Ash Hill Alnwick Road Sibthorpe Road Winn Road Mottingham Lane Guibal Road Horncastle Road Middle Park Avenue The Vista Eltham Palace Road Middle Park Avenue Kingsground Churchbury Road Upwood Road Horn Park Lane Crathie Road Cambridge Drive Leyland Road Woodyates Road Manor Lane Holme Lacey Road Southbrook Road Wantage Road Manor Park GilmoreRoad Brandram Road Dacre Park Lee Park Manor Way Weigall Road Moorhead Way Tudway Road Edgeworth Road Meadowside Elt ham Green Road Shawbrooke Road Briset Road Purneys Road Phineas Pett Road Langbrook Road Bournbrook Road Broad Walk Blackheath Park Foxes Dale Dursley Road Woolacombe Road Wricklemarsh Road Holburne Road Kidbrooke Park Road Eastbrook Road Merriman Road Kidbrooke Grove Kidbrooke Park Road Kidbrooke Gdns Morden Road Pond Roa d St Joseph’s Vale Marischal Road Lewisham Park Moun t Pleasant Road George Lane Campshill Road Ringstead Road Fe rnbrook Road Longhurst Road Mounts Pond Road Granville Park Hare and Billet Road Golfers Road Lewisham Hill Wat Tyler Road Lewisham Road Lewisham High M Street olesworth Street Greenwich South Street Point Hill Royal Hill Hyde Vale Crooms Hill King George Street Devonshire Drive The Avenue Blackheath Avenue Charlton Way Maze Hill Vanbrugh Park Prince Charles Road Dartmouth Hill Greenwich High Road Westcombe Park Road Foyle Road Coleraine Road HardyRoad Humber Road Beaconsfield Road Mycenae Road Westcombe Hill Langton Way Vanbrugh Hill Pelton Road Tunnel Avenue Tunnel Avenue West Parkside East Parkside Riverside Anchor and Hope Lane Bugsby’s Way Westmoor Street Woodland Terrace Heathwood Gardens Kinveachy Gardens Charlton Lane Maryon Road Thorntree Road EastcombeAvenue Wyndcliff Road Victoria Way Elliscombe Road Charlton Park Lane Canberra Road Hornfair Road Prince Henry Road Charlton Dene Sutlej Road Indus Road Marlborough Lane Old Dover Road Brooklands Park Parkgate St John’s Park Corelli Road Teilson Avenue Lodge Road Penfold Street Broadley Street Harewood Avenue Outer Circle Outer Circle Ches In ter Road ner Circle St John’s Wood High Street BROMPTON RD EDGWARE ROAD MAIDA VALE HOLLOWAY ROAD A1 UPPER STREET A1 KINGSLAND ROAD BLACKWALL TUNNEL NORTHERN APPROACH BOW ROAD EAST CROSS ROUTE EAST INDIA DOCK ROAD LEWISHAM WAY BRIXTON ROAD KENNINGTON PARK ROAD CLAPHAM ROAD CLAPHAM HIGH STREET STOCKWELL ROAD VAUXHALL BRIDGE ROAD NEW KENT ROAD WEST CROSS ROUTE HOLLAND ROAD WESTWAY A40 WESTWAY MARYLEBONE ROAD HAMPSTEAD ROAD EUSTON ROAD BATTERSEA PARK ROAD NINE ELMS LANE GROSVENOR ROAD CHELSEA EMBANKMENT LATCHMERE ROAD TRINITY ROAD ROEHAMPTON LANE UPPER RICHMOND ROAD SHOOTERS HILL ROAD BLACKHEATH HILL FINBOROUGH RD REDCLIFFE GDNS BATTERSEA BRIDGE ROAD BRIXTON HILL POYNDERS RD BROWNHILL ROAD SOUTH CIRCULAR A205 LORDSHIP LANE SOUTH CIRCULAR A205 GREAT WEST ROAD TALGARTH RD HAMMERSMITH FLYOVER CROMWELL RD HIGH ROAD A407 A4088 WALM LANE HIGH ROAD CRICKLEWOOD BROADWAY A5 KILBURN HIGH ROAD A5 MAIDA VALE A5 WILLESDEN LANE BRONDESBURY PAR SI K DMOUT H ROAD ALL SOULS AVENUE CHAMBERLAYNE ROAD A404 HIGH STREET HARLESDEN WROTTESLEY ROAD HARROW ROAD A404 HARROW ROAD A404 HARROW ROAD A404 ELGIN AVENUE KILBURN LANE HARVIST ROAD CARLTON VALE SALUSBURY ROAD BRONDESBURY ROAD WEST END LANE FORTUNE GREEN ROAD FINCHLEY ROAD A41 FINCHLEY ROAD FINCHLEY ROAD A41 BELSIZE ROAD ABBEY ROAD WEST END LANE GROVE END ROAD LISSON GROVE FITZJOHN’S AVENUE ROSSLYN HILL HAVERSTOCK HILL A502 ADELAIDE ROAD MALDEN ROAD MANSFIELD ROAD HIGHGATE ROAD FORTESS ROAD KENT SI H TOWN ROAD BRECKNOCK ROAD CAMDEN ROAD HILLMARTIN ROAD YORK WA CA Y MDEN PK RD YORK WAY CALEDON AI N ROAD CALEDONIAN ROAD LIVERPOOL ROAD CANONBU RY ROAD HIGHBURY GROVE ST PAUL’S ROAD NEW NI GTON GN RD GREEN LANE A105 ALBION LAN H E GI HBURY PARK ESSEX ROAD BALLS POND ROAD SOUTHGATE ROAD STOKE NEWINGTON ROAD DALSTON LANE GRAHAM ROAD DALSTON LANE AMHURST ROAD DALSTON LANE PEMBURY ROAD LOWER CLAPTON ROAD HOMERTON HIGH STREET HOMERTON ROAD EASTWAY A12 HIGH ROAD LEYTON CROWNFIELD ROAD LEYTONSTONE ROAD A11 CANN HALL ROAD FOREST LANE LEYTON ROAD WATER LANE ROMFORD ROAD A118 DAMES ROAD ROMFORD ROAD A118 HIGH STREET NORTH A117 KATHERINE ROAD SHREWSBURY ROAD GREEN STREET UPTON LANE A114 PLASHET GROVE PLASHET ROAD PORTWAY ROAD VICARAGE LANE WEST HAM LANE GREAT EASTERN ROAD STRATFORD HIGH STREET A118 PLAISTOW ROAD MANOR ROAD UPTON LANE STOPFORD ROAD KATHERINE ROAD GREEN STREET BARKING ROAD A124 BARKING ROAD A124 GREENGATE STREET THE BROADWAY CENTRAL PARK ROAD BOUNDARY ROAD LONSDALE AVENUE NEWHAM WAY A13 PRINCE REGENT LANE BALAAM STREET BARKING ROAD A124 NEWHAM WAY A13 NEW BARN STREET MANOR ROAD PR NI CE REGENT LANE TOLLGATE ROAD STANSFELD ROAD ROYAL ALBERT WAY CONNAUGHT BRIDGE ALBERT ROAD A112 NORTH WOOLWICH ROAD FREEMASONS ROAD SILVERTOWN WAY LOWER LEA CROSSING MORNING LANE WICK ROAD CASSLAND ROAD WELL STREET KENWORTHY ROAD VICTORIA PARK ROAD VICTORIA PARK ROAD GROVE ROAD MARE STREET MARE STREET OLD FORD ROAD OLD FORD ROAD ROMA N ROAD ROMAN ROAD PARNELL ROAD FAIRFIELD ROAD GROVE ROAD GLOBE ROAD BETHNAL GREEN ROAD WARNER PLACE CHESHIRE STREET SEWARDSTONE RD BISHOP’S WAY HACKNEY ROAD QUEENSBRIDGE ROAD HACKNEY ROAD NEW NORTH ROAD CITY ROAD GREAT EASTERN STREET OLD STREET P TI F EI LD STREET OLD STREET GOSWELL ROAD A1 ESSEX ROAD CLERKENWELL ROAD LEVER STREET ST JOHN STREET ROSEBERY AVENUE PENTONVILLE ROAD CHISWELL ST LONDON WALL BUNHILL ROW BATH STREET BISHOPSGATE COMMERCIAL STREET COMMERCIAL ROAD A13 WHITECHAPEL ROAD BRICK LANE CAMBR DI GE HEATH ROAD MILE END ROAD STEPNE Y GREEN VALLANCE ROAD NEW ROAD CANNON ST ROAD CABLE STREET THE HIGHWAY CABLE STREET LIMEHOUSE LINK COMMERCIAL ROAD A13 EAST INDIA DOCK ROAD BURDETT ROAD ST PAUL’S WAY VIOLET ROAD CHRISP STREET WESTFERRY ROAD MANCHESTER ROAD WESTFERRY ROAD KING’S CROSS ROAD GRAY’S INN ROAD GUILFORD STREET THEOBALD’S ROAD HIGH HOLBORN JUDD STREET SOUTHAMPTON ROW UPPER WOBURN GOWER STREET TOTTENHAM COURT RD GOODGE STREET GREAT PORTLAND STREET PORTLAND PLACE EVERSHOLT STREET OUTER CIRCLE PRINCE ALBERT ROAD PARK ROAD PANCRAS ROAD PANCRAS WAY CAMDEN STREET ROYAL COLLEGE STREET WIGMORE STREET OXFORD STREET MARYLEBONE HIGH STREET BAKER STREET GLOUCESTER PLACE OXFORD STREET REGENT STREET SHAFTESBURY AVENUE PICCADILLY PALL MALL PARK LANE PRAED STREET SUSSEX GARDENS BAYSWATER ROAD BAYSWATER ROAD BISHOP’S BRIDGE ROAD WESTBOURNE TERRACE PEMBROKE VILLAS WESTBOURNE GROVE CHEPSTOW ROAD WESTBOURNE PARK ROAD LADBROKE GROVE KENSINGTON PARK GROVE CLARENDON ROAD HOLLAND PARK AVENUE LADBROKE GROVE BARLBY ROAD WESTWAY A40 WESTWAY A40 SCRUBS LANE WOOD LANE UXBRIDGE ROAD GOLDHAWK ROAD ASKEW ROAD OLD OAK ROAD SHEPHERD S’ BUSH ROAD GOLDHAWK ROAD KING STREET H AMMERSMITH ROAD WARWICK ROAD KENSINGTON HIGH STREET KENSINGTON C HURCHSTREET KENSINGTON ROAD KENSINGTON GORE KNIGHTSBRIDGE GLOUCESTER ROAD WEST CROMWELL ROAD WARWICK GARDEN S BROMPTON ROAD FULHAM ROAD PONT STREET SLOANE STREET GROSVENOR PLACE EATON GATE KING’S ROAD KING’S ROAD NEW KING’S ROAD GUNTER GROVE EDITH GROVE CHELSEA BRIDGE ROAD ROYAL HOSPITAL ROAD PIMLICO ROAD BUCKINGHAM PALACE ROAD BELGRAVE ROAD VICTORIA STREET HORSEFERRY ROAD MILLBANK VICTORIA EMBANKMENT WHITEHALL STRAND VICTORIA EMBANKMENT ALDWYCH KINGSWAY FARRINGDON HATTON GARDEN TOWER BRIDGE LONDON BRIDGE SOUTHWARK BRIDGE MILLENNIUM BR BLACKFRIARS BR WATERLOO BRIDGE WESTMINSTER BR LAMBETH BR VAUXHALL BR CHELSEA BR ALBERT BRIDGE BATTERSEA BR WANDSWORTH BR PUTNEY BR HAMMERSMITH BR WANDSWORTH BRIDGE ROAD FULHAM ROAD FULHAM PALACE ROAD DAWES ROAD LILLIE ROAD NORTH END ROAD FULHAM PALACE ROAD LONSDALE ROAD CASTELNAU ROCKS LANE STATIO N ROAD MILL HILL ROAD QUEEN’S RIDE LOWER RICHMOND ROAD PUTNEY BRIDGE ROAD ARMOURY WAY MERTON ROAD GARRATTLANE ST JOHN’S HILL LAVENDER HILL QUEENSTOWN ROAD SILVERTHORNE ROAD ELSPETH ROAD CEDARS ROAD CLAPHAM COMMO N NORTH SIDE LONG ROAD CLAPHAM COMMON SOUTH SIDE NORTHCOTE ROAD BROOMWOOD ROAD BOLINGBROKE GROVE NIGHTINGALE LANE BELLEVUE ROAD BALHAM HIGH ROAD BALHAM HILL ABBEVILLE ROAD CLAPHAM PARK ROAD ACRE LANE BEDFORD ROAD KINGS AVENUE CLARENCEAVENUE LANDOR ROAD EFFRA ROAD TULSE H LI L DULWICH ROAD RAILTON ROAD UPPER TULSE HILL ATKINS RO AD SOUTH CIRCULAR A205 CHRISTCHURCH ROAD SOUTH CIRCULAR A205 SOUTH CIRCULAR A205 CAVENDISH ROAD THURLOW PARK ROAD SOUTH CIRCULAR A205 DULWICH COMMON SOUTH CIRCULAR A205 ROEHAMPTON LANE PUTNEY HEATH PUTNEY HILL TIBBET’S RIDE WIMBLEDON PARK SIDE WIMBLEDON PARK ROAD EARLSFIELD ROAD BURNTWOOD LANE MAGDALEN ROAD THORNTON ROAD CAVENDISH ROAD NORWOOD ROAD TRINITY RISE CROXTED ROAD HALF MOON LANE MILKWOOD ROAD HERNE HILL DENMARK HILL COLDHARBOUR LANE CAMBERWELL NEW ROAD PECKHAM ROAD WALWORTH ROAD KENNINGTON LANE CAMBERWELL ROAD ALBANY ROAD SOUTHAMPTON WAY KENNINGTON ROAD KENNINGTON LANE LAMBETH ROAD ALBERT EMBANKMENT ST GEORGE’S ROAD LONDON ROAD BLACKFRIARS ROAD WATERLOO ROAD BOROUGH ROAD UNION STREET BERMONDSEY STREET LONG LANE GREAT DOVER STREET HARPER ROAD JAMAICA ROAD ABBEY STREET GRANGE ROAD SOUTHWARK PARK ROAD ROLLSROAD DUNTON ROA O D LD KENT ROAD A2 OLD KENT ROAD A2 ROTHERHITHE NEW ROAD TRAFALGAR AVENUE COMMERCIAL WAY PECKHAM HILL STREET PECKHAM PARK ROAD GROVE LANE VILLAGE WAY EAST DULWICH GROVE LORDSHIP LANE LORDSHIP LANE BARRY ROAD UNDERHILL PECKHAM RYE EAST DULWICH ROAD EVELINA ROAD DRAKEFELL ROAD PECKHAM RYE IVYDALE ROAD HONOR OAK ROAD FOREST HILL ROAD HONOR OAKPARK BROCKLEY R SI E BROCKLEY ROAD STONTON PARK ADELAIDE AVENUE CATFORD HILL STANSTEAD ROAD SOUTH CIRC ULAR A205 BROMLEY ROAD A21 LEWISHAM HIGH STREET VERDANT LANE BARING ROAD WESTHORNE AVENUE SOUTH CIRCULAR A205 SIDCUP ROAD A20 BURNT ASH ROAD ELTHAM ROAD KIDBROOKE PARK ROAD LOAM PIT VALE LEE HIGH ROAD BELMONT HILL LEE ROAD LEE TERRACE PRINCE OF WALES ROAD ELTHAM HILL ROCHESTER WAY A2 ROCHESTER WAY A2 ROCHESTER WAY A2 SHOOTERS HILL ROAD A207 ROCHESTER WAY CHARLTON ROAD A102 CHARLTON PARK ROAD CHARLTON CHURCH LANE A102 BLACKWALL LANE WOOLWICH ROAD WOOLWICH ROAD BUGSBY’S WAY TRAFALGAR ROAD WOOLWICH CHURCH STREET MILLENNIUM WAY ROMNEY ROAD CREEK ROAD DEPTFORD CHURCH STREET EVELYN STREET LOWER ROAD SALTER ROAD REDRIFF R OA LO D WER ROAD SANFORD STR EET NEW CROSS ROAD MALPAS ROAD SOUTH LAMBETH ROAD WANDSWORTH ROAD RANDOLPH AVENUE LANARK ROAD SUTHERLAND AVENUE WARRINGTON CRES WARWICK AVENUE CASTELLAIN RD BOURNE TERRACE WARWICK AVE BLOMFIELD ROAD MAIDA AVENUE WALTERTON ROAD CHIPPENHAM ROAD KILBURN PARK ROA M D ALVERN ROAD SALTRAM CRESCENT RANDOLPH AVENUE LANARK ROAD PRINCESS ROAD CA RLTON VALE GREVILLE PLACE BOUNDARY ROAD SPRINGFIELD ROAD CLIFTON HILL LOUDOUN ROAD QUEEN’S GROVE HAMILTON TERRACE MARLBOROUGH PLACE ST JOHN’S WOOD TERRACE ALLITSEN ROAD TOWNSHEND ROAD CIRCUS ROAD ORCHARDSON STREET FRAMPTON ST MARY’S TERRACE LEINSTER GARDENS GRANTULLY ROAD GREAT WESTERN RD PORTNALL ROAD BRAV NI GTON ROAD MARBAN RD FIFTH AVENUE SIXTH AVENUE THIRD AVENUE KINGSWOOD AVENUE MILMAN ROAD KEMPE ROAD KESLAKE ROAD HYTHE ROAD WHITMORE GARDENS BUCHANAN GARDENS PALERMO ROAD RUCKLIDGE AVENUE LEGHORN ROAD CROWNHILL ROAD HARLESDEN ROAD LEIGHTON GARDENS HARDINGE ROAD COLLEGE ROAD WRENTHAM AVENUE MOUNT PLEASANT HANOVER ROAD TIVERTON ROAD HARVIST ROAD GLENGALL RD PRIORY PARK ROAD DYNE ROAD CAVENDISH ROAD TORBAY ROAD CHRISTCHURCH WILLESDEN LANE ABERDA RE GARDENS GOLDHURST TERRACE GOLDHURST KINGSGATE ROAD MAYGROVEROAD FAIRFAX ROAD KING HEN RY’SROAD PARKH LI L ROAD TH URLOW RD FLEET ROAD AGINCOURT ROAD FROGNAL LYMIN GTON ROAD BRAC KNELL GDNS SUMATRA RD HILLFIELD RD LOVERIDGE ROAD IVERSON RD DARTMOUTH ROAD LYDFORD ROAD WALM LANE ANSON ROAD KENDALL ROAD GEARY ROAD FLEETWOOD ROAD SHERRICK GREEN ROAD DEWSBURY ROAD VILLIERS ROAD DEACON ROAD CHAPLIN ROAD SANDRINGHAM ROAD CHURCHILL ROAD PARK AVENUE BRONDESBURY PARK CRANHURST ROAD DONNINGTON ROAD CHAMBERS LANE DOBREE AVENUE UFFINGTON ROAD HERBERT GDNS HOLLAND ROAD CAMDEN HIGH STREET BLACKWALL TUNNEL SOUTHERN APPROACH KNIGHTSBRIDGE ROEHAMPTON VALE A3 KINGSTON ROAD A3 WEST HILL A3 YORK ROAD YORK ROAD BATTERSEA RISE ASPEN WAY Middle Dock North Dock Blackwall Basin Poplar Dock East India Dock Basin WEST INDIA DOCKS South Dock Millwall Outer Dock Royal Albert Dock Royal Victoria Dock North Greenwich Pier Greenwich Pier Masthouse Terrace Pier Greenland Pier Hilton Docklands Nelson Dock Pier Canary Wharf Pier Tower Millennium Pier Bankside Pier Blackfriars Pier Embankment Pier London Eye Pier Millbank Pier St George Wharf Pier Cadogan Pier Chelsea Harbour Pier Wandsworth Riverside Quarter Pier Putney Pier London Bridge City Pier River Lea or Lee Greenland Dock South Dock Marina Grand Union Canal –Paddington Ar m Little Venice Paddington Basin Regent’s Canal Boating Lake Regent’s Canal Battlebridge Basin City Road Basin Wenlock Basin Regent’s Canal K ni gs al nd Regent’s Canal Hertford Union Canal West Lake East Lake Lee Nav gi at oi n Lee Navigation River Lea or Lee City Mill River Waterworks River Three Mills Wall River Prescott Channel Abbey Creek Channelsea River Bow Back Rivers River Lea or Lee Limehouse Cut Bow Creek Regent’s Canal Limehouse Basin Millwall Inner Dock River Thames River Thames River Thames River Thames The Serpentine Round Pond St Katharine Docks Shadwell Basin Boating Lake River Wandle King’s Mere River Ravensbounr e River Quaggy Deptford Creek River Ravensbourne Battersea Park Clapham Common Wandsworth Common Wandsworth Park Hurlingham Park Bishops Park South Park Barn Elms Playing Fields Barnes Common Putney Lower Common Roehampton Golf Club Roehampton Playing Fields Barnes Green Eel Brook Common Parsons Green Imperial Park York Gardens Falcon Park Heathbrook Park Larkhall Park William Parnell Park Brompton Cemetery Ranelagh Gardens Burton Court Green Park St James’s Park Kennington Park Myatt’s Fields Slade Gardens Max Roach Park Wyck Gardens Windmill Gardens Burgess Park Ruskin Park Greendale Playing Fields Sunray Gardens Brockwell Park Dulwich Park Peckham Rye Nunhead Cemetery Brockley and Ladywell Cemetery Hilly Fields Park Deptford Park Folkestone Gardens Bridgehouse Meadows Southwark Park Stave Hill Ecological Park Greenwich Park Blackheath Mountsfield Park Blackheath Park Old Colfeians Sports Ground Lewisham Park Charlton Park Hornfair Park Maryon Wilson Park Maryon Park Greenwich Peninsula Ecology Park Mudchute Park West Ham Park East London Crematorium Hermit Road Recreation Ground Plaistow Park Queen Elizabeth Olympic Park Victoria Park Well Street Common London Fields Haggerston Park Shoreditch Park Weavers Fields Bethnal Green Gardens Millennium Park King Edward VII Park Meath Gardens Mile End Park Stepney Green Park Tower Hamlets Cemetery Park Hackney Downs Hackney Marsh Wanstead Flats Manor Park Cemetery Woodgrange Park Cemetery Plashet Cemetery Plashet Park Beckton District Park North Thames Barrier Park Brampton Park Wick Woodland Drapers Field Mabley Green Highbury Fields Millwall Park Sutcliffe Park Horn Park Northbrook Park Sports Ground Sports Ground Sports Ground Sports Ground London Marathon Playing Field Althletic Ground Middle Park Field Queenscroft Recreation Ground Eltham Green Greenwich Cemetery Kidbrooke Playing Fields Honor Oak Park One Tree Hill Golf Course Blythe Hill Fields Brockley Hill Park Manor House Gardens Guy’s Hospital Athletic Grounds Ladywell Fields Horniman Gardens Camberwell Old Cemetery Camberwell New Cemetery Belair Park Edward Alleyn Club Ravenscourt Park Margravine/Hammersmith Cemetery Lillie Road Park Bayonne Park Normand Park Fulham Palace Rd Cemetery Holland Park Hyde Park Regent’s Park Primrose Hill Queens Park Lord’s Cricket Ground Saint Mary’s Catholic Cemetery Kensal Green Cemetery Paddington Old Cemetery Kilburn Grange Park Hampstead Cemetery Roundwood Park Willesden New Cemetery Willesden Sports Ground Tiverton Green Wormwood Scrubs Park Little Wormwood Scrubs Paddington Recreation Ground Barnes Wetland King George’s Park Wandsworth Cemetery Tooting Bec Common Putney Heath Richmond Park Wimbledon Common Wimbledon Park Russell Square Lincoln’s Inn Fields Gray’s Inn Brunswick Square / Coram’s Fields Barnard Park Paradise Park Caledonian Park St Mary Magdalene Garden Inner Temple Gardens Bunhill Gardens Victoria Embankment Gardens Kensington Gardens Vauxhall Park Pasley Park Lambeth Palace Gardens Archbishop’s Park Vauxhall Pleasure Gardens The Oval Jubilee Gardens Victoria Tower Gardens Buckingham Palace Gardens The O2 Buckingham Palace Houses of Parliament St Thomas’s Hospital National Gallery London Eye Southbank Centre Oxo Tower Courtauld Gallery King’s College LSE Tate Modern Tower of London St Paul’s Cathedral Barbican St Bartholomew’s Hospital Tate Britain Westminster Abbey V & A Science Museum Kensington Palace Natural History Museum The Shard Shakespeare’s Globe Guy’s Hospital Imperial War Museum British Museum Homerton Hospital Great Ormond Street Children’s Hospital Hospital of St John and St Elizabeth Royal Free Hospital UCH SOAS Birkbeck Moorfields Eye Hospital City University London Newham University Hospital The Royal London Hospital Queen Charlotte’s & Chelsea, and Hammersmith Hospitals St Mary’s Hospital King’s College Hospital Charing Cross Hospital Chelsea & Westminster Hospital Royal Marsden Hospital Royal Brompton Hospital Design Museum Royal Opera House London Transport Museum Museum of London National Maritime Museum Queen’s House Royal Observatory Geffrye Museum V&A Museum of Childhood Mile End Hospital Queen Mary University of London HMS Belfast Horniman Museum Royal Academy of Arts Saatchi Gallery Serpentine Gallery Whitechapel Gallery Camden Arts Centre Dulwich Picture Gallery Estorick Collection Wallace Collection White Cube Gallery The Gherkin Westfield London Shopping Centre Harrods Harvey Nichols Selfridges John Lewis Fortnum & Mason Peter Jones Bank of England Leadenhall Market Camden Market Southwark Cathedral Borough Market Columbia Road Flower Market Portobello Market Spitalfields Market Covent Garden Market Madame Tussauds British Library ExCeL London Chelsea FC Earl’s Court Exhibition Centre Westfield Stratford Shopping Centre West Ham United FC New Covent Garden Market Flower Market Imperial College Royal Albert Hall UCL 0 1 km 0 1 mile National Rail Station DLR Station London Overground Station Tube Station Map base © maproom.net James Freeman and Jeffrey Sullivan, Allen and Overy • To help clients win, it is first necessary to understand what winning looks like. Only by understanding the client’s goals can a successful case strategy be formulated. • It is rare for the lawyers to win on their own; they will need help – from their clients and from experts who are indispensable in most complex commercial disputes. A good legal team will have the contacts book to identify the help it needs and the project management skills to coordinate the different moving parts. • Too often in commercial disputes we see length and complexity in submissions. The real skill is brevity: identify what is truly important and build a narrative and an argument around that. • One of the key distinguishing features of the leading legal teams is their ability to provide a fully integrated service right up to the advocacy. In international arbitration, most clients expect their law firm to be able to argue the case not only on paper but also orally. • In both litigation and arbitration, it is vital to understand the decision-maker, whether judge or arbitrator. This gives an advantage to the most experienced legal teams who appear most often in front of them. Peter Goldsmith and Patrick Taylor, Debevoise & Plimpton In our view, the 5 key ingredients to successful representation of clients in arbitration are: • Select the right team for the job. • Know your arbitrators. • See everything through the eyes of the tribunal. • Know your case and test your assumptions. • Be meticulous and don’t overreach. [Continued overleaf] LONDON “In both litigation and arbitration, it is vital to understand the decision-maker, whether judge or arbitrator.“ James Freeman and Jeffrey Sullivan, Allen and Overy “it is essential to work closely with the client at the outset to fully understand all the facts and background, and to map out the client’s ultimate objectives.“ Bruce McCauley and Melis Acuner, Skadden, Arps, Slate, Meagher & Flom “there’s no substitute for walking into the hearing with the confidence that you know the facts and understand the arguments better than anyone else in the room.“ Charlie Lightfoot and Christian Tuddenham, Jenner & Block “Embrace detail and get into the weeds – facts win cases.“ Robert Wheal and Sabharwal Dipen, White and Case 20 | VANNIN CAPITAL Funding in Focus Content Series Experience, thought leadership, and knowing the market will allow you to do these five things well and, therefore, to best serve your clients’ needs. James Kennedy and Reza Mohtashami, Freshfields Bruckhaus Deringer • One of the first things that we try to do when a new arbitration instruction comes in is to identify the theme or general narrative of the case. The theme is important because it provides a structure for your case presentation that influences the presentation of the facts and the law and it is a way to make the case accessible to the arbitrators at the outset. • Second, choose your witnesses with care. You may not have much choice over the fact witnesses, but your choice of experts can make or break the case. That’s why deep experience of working with industry and quantum experts is critical to identify and engage the expert teams that are the perfect fit for the case. • Third, maintain the trust of the arbitrators. Experienced advocates with a professional reputation and standing in the field will sometimes have an advantage over less experienced advocates who are not known to the arbitrators. But that trust can be lost by pursuing unreasonable or over-inflated claims. • Fourth, tone down the rhetoric. Keep the hyperbole, emotive advocacy and guerrilla tactics out of the case. Serious arbitration practices focus on the key building blocks of the case to provide the necessary tools to the arbitrators to prepare their awards. • Finally, the client and the legal team must work together as a coherent joined-up team. That’s why its important to build strong relations with the client teams – not just legal but the business units also. An engaged, active client working closely with their external counsel is critical to success. Richard Lewis and Markus Burgstaller, Hogan Lovells A number of factors allow a legal team to provide its client with the greatest chance of securing victory. • First, understanding the client’s situation and goals: a good legal team works closely with the client to tailor the case strategy to meet the client’s commercial objectives. • Second, mastering the facts: sound arguments must be rooted in facts and supported by appropriate evidence. • Third, knowing your audience: a good legal team is able to craft its pleadings to convey the submissions to the arbitrator/ judge effectively. • Fourth, remaining flexible, but focused: it is paramount to address the opponent’s arguments while not losing sight of the client’s positive case. • Fifth, assisting with enforcement: to reach the client’s objectives, a good legal team is able to foresee how and where to enforce an award / judgment – it does not seek to win for winning’s sake and keeps in mind at all times the need to obtain an award / a judgment that can be enforced and monetised for the client. Charlie Lightfoot and Christian Tuddenham, Jenner & Block There are many critical steps that good lawyers will take which can mean the difference between winning or losing a difficult case. It goes without saying that understanding the perspective of the decision-maker and pursuing a strategy of written and oral advocacy carefully tailored to the persuasion of that individual or tribunal is paramount. But if experience has taught me one thing, it’s that there’s no substitute for walking into the hearing with the confidence that you know the facts and understand the arguments better than anyone else in the room. Adrian Lifely and Greg Fullelove, Osborne Clarke • The first thing is to understand what the claimant wants to achieve and then to be clear about what you think is possible/the best course. • Second, a good team will master the key facts early and identify (as far as possible) the strongest claims from the outset. • Third, you need to understand the other actors: the judge or arbitrator as the case may be and the other side (including its legal team). A ‘one approach fits all’ policy is essentially doomed – particularly in international arbitration where you will be up against opponents from different “choose your witnesses with care. You may not have much choice over the fact witnesses, but your choice of experts can make or break the case. That’s why deep experience of working with industry and quantum experts is critical to identify and engage the expert teams that are the perfect fit for the case.” James Kennedy Reza Mohtashami, Freshfields Bruckhaus Deringer Funding in Focus Content Series VANNIN CAPITAL | 21 legal backgrounds and training. In other words, do your research if required to adapt your game. • Fourth, keep both the written and oral advocacy as concise as possible: the judge or arbitrator needs to understand your claim and will appreciate being guided to the key points rather than having to pick them out of a weighty tome or lengthy oral submissions. • And fifth and finally, it pays to be reasonable both in the way that you present the case and also the procedural requests that you make. Arbitrators and judges have generally seen it all before. In a good litigation/ arbitration practice you will often have bounced ideas off colleagues to check that your baseline for reasonableness remains (viewed objectively) ‘true’. Mark McNeill and Jeremy Sharpe, Shearman and Sterling There are many things a good legal team can do to help its clients prevail in international commercial or investment arbitrations. • The first is to understand the interests and goals of the client – whether an individual, company, or a State – as well as the full context in which the dispute arises. • Next is knowing how to use the tools of dispute resolution to deliver for a client. Broad practice experience before various courts and tribunals allows a legal team to bring the most effective tactics and strategies to bear. Experience and expertise are key to identifying the right arbitrators for every dispute; mastering the content and history of the applicable contract or law (whether public or private, domestic or international); and leveraging deep knowledge of different sectors and industries. It all adds up to increased credibility before the tribunal. • Finally, efficiency is essential. Skill at quickly identifying and putting forward the essential facts, witnesses, experts – and arguments – with a leanly staffed team helps deliver not only victory but good value for clients. Bruce McCauley and Melis Acuner, Skadden, Arps, Slate, Meagher & Flom Our approach to each case is tailored according to its specific and unique dynamics and challenges; there can be no one-size fits all on how to win. That said, it is essential to work closely with the client at the outset to fully understand all the facts and background, and to map out the client’s ultimate objectives. We then work in small and focused teams of high-calibre attorneys in close cooperation with the client to try to achieve those objectives. This involves constantly challenging and testing our strategy and case theory as the case unfolds, always remaining focused on the hearing, the decision makers and the ultimate objectives. It is a dynamic and rigorous process which requires not only hard work from everyone on the team, but also a large degree of agility and tenacity. Robert Wheal and Sabharwal Dipen, White and Case • Tailor arguments to fit the background of the arbitrators; too many practitioners approach an international tribunal as if it were a domestic court. • Don’t oversell the case – it undermines credibility before the Tribunal and is counter-productive. • Embrace detail and get into the weeds – facts win cases. • Don’t lose sight of the numbers – winning a legal argument has little value if the damages calculation unravels under scrutiny. • Keep it simple – clear, concise advocacy cuts through the clutter and is most persuasive for busy arbitrators. Ali Malek and Christopher Harris, 3 Verulam Buildings • Understand the client’s commercial aims and tailor a strategy to meet them. • Research and understand the background of your tribunal, whether a judge or arbitrator, and factor in to how the case is presented. • Identify the core merits of the case at an early stage. • Pick your strong points and focus on them; do not run bad points too, they distract from the good ones. • Constant assessment of the merits to make sure the client gets the best outcome. Recognise the vagaries of any legal process and give the client all the options. “efficiency is essential. Skill at quickly identifying and putting forward the essential facts, witnesses, experts – and arguments – with a leanly staffed team helps deliver not only victory but good value for clients.” Mark McNeill and Jeremy Sharpe, Shearman and Sterling 22 | VANNIN CAPITAL Funding in Focus Content Series 06 The court steps in: recent developments in the regulation of litigation funding in Australia The Australian litigation funding market is largely unregulated. However, certain Australian Courts have developed rules and practices to address circumstances where a third party to the litigation may influence how that litigation is conducted. For example, the Federal Court of Australia requires funded plaintiffs in class actions to disclose to the Court and the defendant a copy of a litigation funding agreement, save for such parts of the agreement where disclosure would confer a “tactical advantage” on the defendant. Obviously, a key question is what parts can be redacted and what parts must be disclosed? The recent decision of Coffs Harbour City Council v Australian and New Zealand Banking Group Limited [2016] FCA 306 provides some useful guidance. ‘the litigation funding market in Australia has flourished, assisted by favourable court decisions which have recognised the benefit of litigation funding.’ By Tom McDonald, Counsel, Vannin Capital Overview of regulation of litigation funding in Australia In 1993, legislation was introduced in New South Wales and Victoria to abolish champerty and maintenance as common law torts and crimes. Some other Australian states have followed suit with similar legislation, and in any event, case law suggests that champerty and maintenance are now obsolete as crimes under the common law of Australia. Since then, the litigation funding market in Australia has flourished, assisted by favourable court decisions which have recognised the benefit of litigation funding. One of the most notable of these is the High Court of Australia decision in 2006 in Campbells Cash and Carry Pty Limited v Fostif Pty Ltd (Fostif).1 There, the High Court found that a litigation funding arrangement was not an abuse of process or contrary to public policy (and, indeed, noted the access to justice benefits that can flow from litigation funding). Since the Fostif decision, active legislative intervention in the Australian litigation funding market has largely been confined to responses to significant court decisions. Two examples of such decisions are the cases of Brookfield Multiplex Limited v International Litigation Partners Pte Ltd2 (Brookfield) and International Litigation Partners Pte Ltd v Chameleon Mining NL3 (Chameleon), where the Full Federal Court and the NSW Court of Appeal, respectively, found that a funding agreement for a class action suit was a ‘managed investment scheme’ and required a litigation funder to have an Australian Financial Services License. For a short period, both decisions caused the Australian funded class action market to grind to a halt. Whilst the Chameleon decision was subsequently overturned in the High Court in 2012, the Australian Government subsequently enacted amendments to the Corporations Act to exclude class actions from the definition of a managed investment scheme and to exempt funders of single or multi party litigation from holding a financial services licence, provided they have in place appropriate processes for managing conflicts of interest. This later requirement is currently the only substantive regulatory impost on litigation funders operating in Australia. Following a review into the Australian civil justice system, in its September 2014 report entitled “Access to Justice Arrangements”, Funding in Focus Content Series VANNIN CAPITAL | 23 the Australian Productivity Commission expressed the view that having regard to various consumer protection and public policy objectives, formal regulation of litigation funding was warranted. It recommended that the Australian government establish a licence for third party litigation funding companies designed to ensure that they hold adequate capital relative to their financial obligations and properly inform clients of relevant obligations and systems for managing risks and conflicts of interest. On 29 April 2016, the Federal Government released its formal policy response to the recommendations made by the Productivity Commission.4 However, the Government’s response was silent in relation to the Productivity Commission’s recommendation regarding the regulation of third party litigation funding. Amendments to court rules and practices While courts have inherent jurisdiction to make orders that would be binding on funders, it has been noted that, in reality, this power may be limited, especially in circumstances where the involvement of the funder is not always known (at least initially) and imposing sanctions for breach of orders or rules of Court against a funder can be problematic. Accordingly, certain Australian courts have adopted rules which require the disclosure of the identity of any third party who exercises control over litigation (control is interpreted broadly and includes anyone funding the litigation) and the terms of their control. Federal Court of Australia In the Federal Court of Australia, Practice Note CM17 (issued July 2010) provides (amongst other things) that at, or prior to, the initial case management conference, each party will be expected to disclose any agreement by which a litigation funder is to pay or contribute to the costs of the proceeding, any security for costs or any adverse costs order. Any funding agreement disclosed may be redacted to conceal information which might reasonably be expected to confer a tactical advantage on the other party. On 13 January 2016, the Court published a consultation draft class action practice note. The draft practice note provided that, subject to genuine objection, the plaintiff should disclose to the parties and to the Court any standard form litigation funding agreement, save that such a document: “may be redacted by the plaintiff or the plaintiff’s lawyers prior to disclosure to conceal any information which might reasonably be expected to confer a tactical advantage on another party to the proceeding including, without limitation, information: i. as to the funds available to the applicant, in total or for any step or stage in the proceeding; and ii. which might reasonably be expected to indicate an assessment of the risks or merits of the proceeding or any claim in or respect of the proceeding” (paragraph 6.3). Decision in Coffs Harbour Coffs Harbour concerned a dispute between the parties as to the extent of appropriate redactions to the funding agreement, which was the same funding agreement used in a series of related cases. In this case, Coffs Harbour had commenced proceedings against Australia and New Zealand Banking Group Limited (trading as ANZ Investment Bank), who was the vendor to Coffs Harbour City Council of certain synthetic collateralised debt obligations, which suffered capital losses during the global financial crisis. Standard & Poors, who provided an investment rating in respect of the underlying financial product, was also named as a defendant. Coffs Harbour had initially argued that it was entitled to retain privilege over the portions of the funding agreement that it had redacted, on the basis that those portions were subject of legal professional privilege. Justice Rares rejected this argument, finding that as the agreement was not “created for the dominant purpose of giving or receiving legal advice” legal professional privilege did not apply to the funding agreement. Justice Rares stated that the evident purpose of practice note CM17 and of the current draft practice note, was to “strike a balance between the rights and interests of the parties as they are, or may be, affected by the involvement of, relevantly, the funder” in the various proceedings. He remarked that “…the current practice note addresses that balance by creating an expectation of some transparency in respect of the funder’s role and involvement in the conduct of a representative proceeding or class action.” However, Justice Rares also noted that the current practice note retains flexibility and is subject to the court’s control in any individual proceeding. On this basis, Justice Rares stated that the rationale in practice note CM17 for permitting redactions was the protection of confidential information. He stated that one reason why such information would be confidential in a particular case is that its disclosure would “…confer a tactical advantage or would reveal the amount of resources available to the funded party…” Justice Rares held that it is for the plaintiff to justify that the redactions are appropriate. In this case he found that: • The plaintiff was not entitled to redact the whole of the provisions in the funding agreement dealing with financial matters; • It was appropriate for the plaintiff to redact the funder’s fee, including the percentage amounts and other rewards that the funder would be entitled to on a settlement. This was because this information, if disclosed, could confer on the defendants an advantage in settlement discussions; • The clause dealing with the precise settlement mechanism (including the barrister to be briefed in the case of a deadlock between funder and plaintiff) was properly redacted; and • The clauses dealing with termination by the plaintiff or funder, together with the consequences of termination, were likely to confer an advantage on the defendants if disclosed. The way forward Whilst there have been no positive statements from the Federal Government that it intends to legislate to implement the recommendation of the Productivity Commission to introduce a licensing scheme for litigation funders, it is possible that this recommendation may be addressed by the government in a later stage of responses to the Productivity Commission’s report. It also remains to be seen whether the approach of the Federal Court of Australia to disclosure of funding agreements in class action proceedings will be adopted by other Australian courts or adopted more generally in single party proceedings involving funders. In the absence of regulation of funders by governments, such further developments seem more likely. ‘Any funding agreement disclosed may be redacted to conceal information which might reasonably be expected to confer a tactical advantage on the other party.’ 1 (2006) 229 CLR 386. 2 (2009) 180 FCR 11. 3 (2011) 82 ACSR 517. 4 Australian Government, Attorney General’s Department, accessed 14 May 2016, Registered Office +44(0)1624 615 111 Vannin Capital PCC 13-14 Esplanade, St Helier, Jersey, JE1 1BD. [email protected] Sydney Office +61(0) 2 8310 5583 Vannin Capital AMP Tower, Level 34 50 Bridge St Sydney NSW 2000, Australia [email protected] Isle of Man Office +44(0)1624 615 111 Vannin Capital PCC 2nd Floor Capital House, Circular Rd, Douglas IM1 1AG, Isle Of Man [email protected] London Office +44(0)20 7139 8401 Vannin Capital PCC 1 Cornhill, London EC3V 3ND United Kingdom [email protected] © 2016 Vannin Capital PCC The views in this publication are those of the author(s) and are subject to change, and Vannin Capital has no obligation to update the opinions or the information in this publication. This publication does not constitute legal or financial advice. All rights reserved. No part of this publication may be reproduced in any manner without the prior written permission of Vannin Capital PCC. Vannin Capital PCC is registered in Jersey with registration number 119327 and having its registered office at 13-14 Esplanades, St Helier, Jersey JE1 1EE.