Gordon is also in breach of legislation regarding his admission to practice law in NSW as he lied about his previous charge of professional misconduct and being struck off the register of practitioners in South Africa. In regards to his poor communication and incivility towards Jacinta, Gordon breached clause s4.1.2 of the Solicitors Rules, which suggests that "a solicitor must be honest and courteous in all dealings in the course of the practice of law". He told Giacinta that she was becoming annoying and that he couldn't stand the sight of her, furthermore he rarely answered her phone calls and when he did he was abrupt. This was also represented in the Byrne case, where it was suggested that "if repeated or persistent incidents of discourtesy occur or other misconduct occurs, lawyers' conduct is more likely to attract sanctions". He was therefore not honest and courteous in his dealings with her, and therefore violated his duty to her. In relation to the change in billing costs, Gordon did not breach the legislation, in particular s180 of the LPULAA, which suggested that "a costs agreement must be in writing or be evidenced in writing". Since there was no written agreement between Gordon and Jacinta, and no evidence of such an agreement, he did not breach their agreement by sending her an invoice for $5000