As to whether the Deed provides satisfactory security for the previous practitioner’s costs, one should consider Penbroke J’s judgment in Tyneside Property Management Pty Limited & Ors v Hammersmith Management Pty Limited & Ors [2011] NSWSC 22:
“satisfactory security will mean something of monetary value which will ensure the satisfaction of the possessory lien: Bechara v Atie (supra) at [64].”