1. Personal Information Name: Naomi Tara Williams Identity Number: 780218 0121 081 Date & Place of Birth: 18 February 1978, Durban 2. Qualifications: LLB [2000]; F. A. Arb F.A. Arb - Fellow of the Association of Arbitrators [2018] Completed Courses at Masters Level in Advanced Labour Law; Alternate Dispute Resolution and Legal Education; Accredited Mediator Accelerated Course for Attorneys and Advocates – Completed in 2017 3. Place of Tertiary Education: University of KwaZulu-Natal (Durban) - LLB 4. Accelerated Course for Attorneys & Advocates – Association of Arbitrators of South Africa – F.A.Arb 5. Date of Admission Admitted as an Attorney of the High Court on 21 February 2003 Admitted as a conveyancer of the High Court of South Africa on 27 October 2006 Right of Appearance in High Court 6. Work Experience  Graduate Assistant and Junior lecturer, University of Natal, Durban: 2000 to 2002 – Introduction to Law and Foundations of South African Law  Contributed to two publications which later became prescribed texts for law students  Candidate Attorney at Livingston Leandy Inc, 2002  Professional Assistant at Livingston Leandy Inc, from 2003 to 2006, Road Accident Fund Department  Director at Livingston Leandy Inc, from 2006 to date: Head of Road Accident Fund Department and of Litigation Department  attended seminars in respect of AMA Guidelines as referred to and relied upon in the Regulations to the RAF Act, as amended  attended seminars in respect of Accident Reconstruction, Labour law, and Consumer Protection Act.  Attended Mediator Accreditation course, July & August 2014  Completed Accelerated Course for Attorneys & Advocated offered by the Association of Arbitrators  Contribution to Review and Update of Personal Injury Law Course Material for School for Legal Practice  F.A. Arb – Fellow of the Association of Arbitrators 7. Experience in Relation to Civil Litigation and Personal Injury Law Personal Injury Law Naomi has 15 years post admission experience in Personal Injury Law in the Magistrates’ Court, Regional and High courts. This experience stems from acting on behalf of the Road Accident Fund (RAF) for approximately 15 years. In the firm’s long history of acting on behalf of the RAF we have not been found to be in breach of the Service Level Agreement. We have on numerous occasions been commended by the various branches of the RAF for our professionalism and service in executing our responsibilities for attorneys for the RAF. More specific information regarding Naomi’s experience follows below. Personal Injury Law Lecturing Experience Since 2016 Naomi has lectured the Personal Injury Law components of the training programme which is offered to candidate attorneys by the School for Legal Practice. The purpose of the course is to ensure that candidate attorneys have a sound understanding and knowledge of the law relating to personal injury law in general. In addition, Naomi was recommended by the Principal of the School for Legal Practice, Durban, to be part of the team who reviewed and amended the Personal Injury Law course notes, an exercise in which she participated and for which her contribution is acknowledged in the Personal Injury Law Course notes (extract of Personal Injury Law Manual attached). A letter of recommendation from the Principal of the School for Legal Practice is also attached. In the past this component of the course focussed only on personal injury litigation arising from motor vehicle collisions. Currently, the course has been enhanced and includes most aspects relating to the institution, prosecution and defence of all types of personal injury claims. In relation to personal injury litigation arising from motor vehicle collisions, Naomi’s lectures cover topics including but not limited to:  Background of the current RAF legislation;  The current RAF Act, as amended and Regulations;  Liability of the RAF;  Lodging a claim against the RAF and substantial compliance with the provisions of the RAF Act, as amended;  Prescription;  Jurisdiction;  Locus standi;  Apportionment of Damages;  Assessment of Damages;  The appointment of experts;  The difference between Special and General Damages;  Limitation / CAP on damages ito current legislation;  Regulation 3 and how to claim general damages;  Understanding Whole Person Impairment Rating and the Narrative test;  HPCSA and disputes iro RAF Form 4;  Basic Actuarial principles;  Drafting pleadings in RAF matters;  Applicability of COIDA;  Case Law applicable to RAF legislation. In practice and representing the Road Accident Fund, Naomi’s experience includes but is not limited to:  Providing general advice on the RAF Act, as amended and related legislation, paying particular attention to the interests, needs and impact on the RAF;  Drafting and exchanging of pleadings and notices;  Preparing interlocutory applications;  Opposing interlocutory applications;  Preparation of discovery affidavits; affidavits in support of or opposing interlocutory applications;  Assisting in investigation of claims;  Preparing instructions to assessors and accident reconstruction experts;  Attending to identify and instruct relevant medical experts in particular fields in order to deal with specific heads of damages;  Formulating instructions to actuaries;  Preparation for and attending consultations with lay and expert witnesses;  Preparation for and attending inspections in loco;  Conducting research and drafting opinions in respect of merits;  Conducting research and providing opinions in respect of claims for general damages, funeral expenses, loss of earning capacity, future medical expenses;  Advising RAF on issues relating to claims for loss of earning capacity particularly in relation to analysis of actuarial calculations and assumptions relied upon therein as well as the application of appropriate contingency deductions;  Analysis of medico-legal reports;  Attending pre-trial conferences;  Attending Rule 37(8) Conferences and Case Flow Management Hearings before Judges in Chambers;  attending to instruct and consult with the various role players including RAF claims officers, experts, advocates, and attorneys;  Consulting with witnesses in relation to the determination of the merits;  Consulting with expert witnesses in relation to the determination of quantum;  Appearing in Court to represent the RAF at trial;  Drafting and negotiating settlement agreements between the RAF and claimants;  Preparing for and attending taxations;  Attending to timeously submit court orders, allocators and settlement agreements to the RAF for the purposes of attending to payment;  Any other civil litigation required by the RAF relating to a specific claim. Civil Litigation Naomi has 15 years post admission experience in Civil Litigation in the Magistrates’ Court, Regional and High court. Naomi provides hands on strategic guidance in the litigation department. She is an accredited mediator and a Fellow of the Association of Arbitrators of South Africa. Naomi is well versed in legislation applicable to domestic and international arbitrations and is familiar with the rules applicable to arbitrations conducted under the auspices of the Association of Arbitrators of Southern Africa. Naomi also provides litigation and dispute resolution services to clients including Tongaat Hulett Developments, Santova Ltd and other large corporate clients. Naomi’s experience in civil litigation in the various courts includes but is not limited to:  Entering appearances to defend;  Drafting and exchanging of pleadings and notices;  Preparing interlocutory applications;  Opposing interlocutory applications;  Preparation of discovery affidavits; affidavits in support of or opposing interlocutory applications;  Preparation for and attending consultations with lay and expert witnesses;  Preparation for and attending inspections in loco;  Attending pre-trial conferences;  Attending Rule 37(8) Conferences and Case Flow Management Hearings before Judges in Chambers;  Preparing bundles of documents for trial;  Appearing in Court to represent the RAF or other litigants at trial;  briefing and consulting with Junior and Senior Advocates;  Negotiating drafting settlement agreements.