How to use AIOOJ v10.1 — sliders, KPIs, heat map, settlement corridor, scenario analysis, and what not to do. Updated 25 March 2026.
P1 — Integrated Methodology Breach from 1 July 2005. CC-13 admission, 135 documented breaches, and Double Modification Lock are all documentary evidence. Rarely below 70%.
P2 — Deed / Summary Judgment. Demand issued 25 November 2025, default 120+ days as at 25 March 2026. Rarely below 80% given Ankar 1987 authority, specialty limitation, and Stonebridge Letter. Default 89% (v10.1).
P3 — GPR-TIMAP standing. Default increased to 81% (v10.1, 25 March 2026): Mount Bruce Mining [2015] HCA 37 closes the incorporation argument; GEC Marconi v BHP (2003) 128 FCR 1 closes the Double Modification Lock upstream variation gap. B.3 Counsel written opinion gate remains outstanding — if adverse on primary incorporation ground, reduce to 74%.
OR-gate: plaintiff wins on limitation if ANY ONE of three routes succeeds. Even with P4, P5, and P6 each at 50%, the OR-gate produces 87.5% success. This makes limitation extremely difficult for the defendant to defeat.
P4 — Route A: s.16 Specialty Limitation. Default 89% (v10.1). The 12-year specialty period runs from Deed accrual 3 December 2025 to 3 December 2037. Issue B.5 s.63 extinguishment three-limb rebuttal fully resolved 25 March 2026: Limb 1 (guarantor obligation parallel and independent — Moschi v Lep Air Services [1973] AC 331); Limb 3 (s.55 postponement extends effective period; s.63 operates only at end of extended period — Hepburn v TCN Channel Nine [1983] 2 NSWLR 682); commercial purpose backstop (a company does not execute a deed of guarantee unless it intends that guarantee to be enforceable). Hard cap 92%.
P5 — Route B: s.55 Fraudulent Concealment. Default 78%. Five concealment pillars; D3.70 (2 August 2024, 99.9% certainty). Two-tier discovery date architecture: primary August 2024 (CC-15 — actuals withheld); secondary October 2020 (CC-4 — formula-driven admission). Hard cap 82%.
P6 — Routes C/D/E. Default 72%. Route C: 2025 fresh fraud (s.249K). Route D: s.54 acknowledgment — February 2024 corrective payment $3,319,108 resets clock to February 2030. Route E: s.56 equitable discretion. Any one independently sufficient.
P7 boosted most by IDO toggle (+8%). IDO toggle applies boosts to six inputs simultaneously: P1 +5%, P2 +3%, P4 +6%, P5 +4%, P6 +3%, P7 +8% (all subject to 99% hard cap). Use the IDO Sensitivity scenario (toggle on/off) to quantify the direct value of obtaining a disclosure order. P8 is evidentiary only — does not gate the win function. Do not move P8 above 85% until TAB_38_3 reserve is authorised for deployment. P9 default 95% — reduce only on specific adverse intelligence about TLIC.
Not a win probability. The percentage of $100.7m representing minimum defensible recovery in an adversarial worst-case. Default 35% = ~$35.3m settlement resistance floor.
| KPI | What it means | Target at defaults |
|---|---|---|
| Expected Recovery | WinProb × claim. Primary negotiating anchor. | >$70m |
| Conservative / Base / Favourable | 62% / 100% / 118% of base EV. | All three >$40m |
| Overall Win Probability | OR-gate across all three streams. Hard cap 99.5%. | >90% |
| Deed SJ Probability | P2 × P4 only. Cleanest, most auditable probability. At v10.1 defaults: 0.89 × 0.89 = ~79.2%. | >79% |
| Settlement Floor | P10-derived minimum. Use as BATNA. | Never settle below this |
| SAI Index | Structural Asymmetry. >5.0 is exceptional. | >3.0 |
| EFI Index | Evidence Fragility. <0.75 = reliance on contested inference. | >0.78 |
| Joint Failure Probability | All 3 streams fail simultaneously. | <0.1% |
Tab 1 — P2 × P4 Base EV: Full model output at current sliders. Identifies which cell your current inputs place you in.
Tab 2 — P2 × P4 Deed EV: Deed-stream contribution only. Isolates the guarantee enforcement component.
Tab 3 — P10 Stress Floor: Grid at stressed E-inputs (all at 30%) with P10 floor. Range ~$35m–$73m. Use to show the defendant’s best case — even under maximum adverse stress, the floor holds above $35m.
Ranks nine inputs by marginal contribution — how much win probability moves when that input increases by 10 percentage points. At v10.1 defaults, expected order: P7, P2, P4, P1, P5, P3, P6, P9, P8. P8 always ranks last — correct, as it is excluded from the win-function gate (evidentiary reinforcement only). The v9.1 Route C correction ensures P6 registers genuine marginal contribution. Note: because P7 and P9 are sequential multipliers on the win function (not OR-gate inputs), P7 ranks higher than its individual probability suggests — a low P7 suppresses the entire win output.
Switch to Counsel mode. Adjust P1–P7 to your honest best case. This is your ceiling — do not present to funders as the base case.
Toggle IDO on and off. The EV difference is the direct value of obtaining the disclosure order.
Switch to Defendant mode. Move P1, P3, P5, P6 to levels Allens would argue. The floor’s resilience is the most powerful negotiating tool in the model.
Hold inputs constant and move through the corridor stages. The increasing range as each milestone passes demonstrates that delay works against the defendant.
The Contracts page presents the seven–agreement contractual framework. Each contract is provided in two formats: the executed PDF (the operative instrument, with wet–ink signatures and seals) and a searchable DOCX edition for use with Word’s Find function and Navigation Pane.
Use the searchable editions to locate specific clauses, definitions, percentages, or party obligations across the framework without opening the scanned originals. The operative wording in any pleading or filed document must be cited from the executed PDF.
signed by or written amendment. Every clause across all seven contracts is found in seconds, with the navigation pane showing which agreement each hit belongs to.
1.875. Every reference is highlighted with its surrounding clause context, including the relevant Schedule entry. To see whether the same rate appears in the GPR–TIMAP Agreement and the Memoranda, switch to the Combined edition and repeat the search.