An agent's liability to a third party under the Bowstead & Reynolds attornment principle requires an overt or positive engagement to pay; silence alone, even in a professional context where ethical obligations might create an expectation of response, is insufficient. A solicitor's particular lien extends to proceeds of sale of property dealt with under Family Court orders as 'fruits of the cause', but the lien must be asserted by timely notice to the party holding the fund; failure to do so for six years, combined with failure to properly formulate the claim, will constitute laches defeating the equitable right.
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