In Estate of Napier v National Australia Bank Ltd [1992] FCA 167 the executor argued the loan was “… merely accounting items entered in account books”, did not constitute valuable consideration, relying on a text by Laurence Hoins titled “How to Screw ‘Your’ Bank” in which a template statement of claim states banks create “book-entry credit out of thin air” at negligible cost. These pleadings were struck out and the executor was permitted to file a fresh statement of claim.