Pre-action: general

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Practice notes
What is a reserved judgment?A reserved judgment is a draft judgment that is circulated by the judge. At the end of the hearing the judge will usually...
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9th Nov
Practice notes
This Practice Note considers the requirement for completing Court Form N510 (Notice for service out of the jurisdiction where permission of the court...
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Produced in partnership with K & L Gates 12th Jan
Practice notes
Note:•this Practice Note gives specific guidance on matters proceeding in the Technology and Construction Court (TCC) under the provisions set out in...
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9th Nov
Practice notes
As set out in The economic torts—overview, the law makes provision to protect a person’s trade or business from acts which are considered to be...
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9th Nov
Practice notes
This Practice Note considers the jurisdiction for obtaining interim and final charging orders as provided for in the (amended) CPR 73 and CPR PD 73 in...
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9th Nov
Practice notes
Brexit: The UK's departure from the EU on exit day ie Friday 31 January 2020 has implications for practitioners in a number of areas covered in this...
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Produced in partnership with Robert Brodrick and Stephen Woodward of Payne Hicks Beach 12th Jan
Practice notes
This Practice Note considers in detail when damages for loss of a chance (loss of an opportunity damages) may be recoverable, with reference to the...
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Produced in partnership with Anneliese Day QC and Christopher Knowles of Fountain Court Chambers 12th Jan
Practice notes
Note: this Practice Note deals with the preparation of bundles for trial. For information on preparing bundles for interim applications, see Practice...
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9th Nov
Practice notes
Claims for knowing receipt (sometimes also known as ‘unconscionable receipt’) and for dishonest assistance are sometimes referred to as ‘accessory...
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9th Nov
Practice notes
This Tracker lists a number of decisions of the English courts in which the Court of Justice decision in Owusu v Jackson has been considered. This...
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9th Nov
Practice notes
Coronavirus (COVID-19): if serving documents outside the jurisdiction, this may be affected by the impact of coronoavirus on the availability of both...
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Produced in partnership with Camilla McPherson 12th Jan
Practice notes
This Practice Note looks at the admissibility of expert evidence under CPR Part 35 and the Civil Evidence Act 1972 (CEA 1972). In particular, it...
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9th Nov
Practice notes
What are proprietary remedies?General principlesA proprietary remedy is one which attaches to specific property (as opposed to a ‘personal remedy’ ie...
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9th Nov
Practice notes
DefinitionsThe following definitions are used in this Practice Note:•interest—this is an additional award made to the winning party to effectively...
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9th Nov
Practice notes
What is discontinuance?Discontinuance is the means by which a claimant can bring all or part of the proceedings it has instigated to an end by serving...
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9th Nov
Practice notes
What is allocation?At an early stage in a claim, the court will provisionally allocate the claim to what it thinks is the most appropriate 'track' for...
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9th Nov

Most recent Pre-action: general content

Precedents
[ON THE HEADED NOTEPAPER OF THE CLAIMANT’S SOLICITORS][NAME OF PROPOSED DEFENDANT’S SOLICITORS, IF ANY][ADDRESS LINE 1][ADDRESS LINE...
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Produced in partnership with Nicholas Macklam of Radcliffe Chambers 16th Apr
Precedents
Private & confidential[insert name and address of expert][insert date]Dear [insert name of expert][insert case heading]Instruction to act as...
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16th Apr
Precedents
Private & confidential[insert name and address of expert][insert date]Dear [insert name of expert][insert case heading]Instruction to act as single...
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15th Apr
Practice notes
This Practice Note looks at the status and use of confidential information in civil proceedings including what confidential information is, how to...
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15th Apr
Q&As
Recovering rent arrearsBefore taking any action to recover rent arrears, landlords must consider:•whether they are able to, and if so whether to...
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15th Apr
Practice notes
Pre-action protocols and Practice Direction Pre-Action Conduct and ProtocolsOnce you have a dispute to resolve (as opposed to an abstract question of...
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9th Apr
Practice notes
This Practice Note provides guidance on the interpretation and application of the relevant provisions of the CPR. Depending on the court in which the...
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9th Apr
Precedents
[ON YOUR FIRM’S LETTERHEAD][Insert name and address of the claimant’s solicitors, including any reference number/name of the responsible lawyer if...
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9th Apr
Precedents
[ON THE HEADED NOTEPAPER OF THE CLAIMANT’S SOLICITORS][NAME OF PROPOSED DEFENDANT’S SOLICITORS, IF ANY][ADDRESS LINE 1][ADDRESS LINE...
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Produced in partnership with Nicholas Macklam of Radcliffe Chambers 9th Apr
Precedents
[ON THE HEADED NOTEPAPER OF CLAIMANT’S SOLICITORS]FAO [RELEVANT NAME][NAME OF DEFENDANT OR DEFENDANT’S SOLICITOR, IF KNOWN][ADDRESS LINE 1][ADDRESS...
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Produced in partnership with Thomas Evans of Henderson Chambers 9th Apr
Precedents
[ON THE HEADED NOTEPAPER OF CLAIMANT’S SOLICITORS]FAO [RELEVANT NAME][NAME OF DEFENDANT OR DEFENDANT’S SOLICITOR IF KNOWN][ADDRESS LINE 1][ADDRESS...
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Produced in partnership with Lynne Counsell of 9 Stone Buildings 9th Apr
Precedents
[ON THE HEADED NOTEPAPER OF CLAIMANT’S SOLICITORS]FAO [RELEVANT NAME][NAME OF DEFENDANT OR DEFENDANT’S SOLICITOR, IF KNOWN][ADDRESS LINE 1][ADDRESS...
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Produced in partnership with Thomas Evans of Henderson Chambers 9th Apr
Precedents
Private & confidential[insert name and address of client][insert date]Dear [insert name of client][insert case heading]As we have already discussed,...
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9th Apr
Precedents
[ON THE HEADED NOTEPAPER OF CLAIMANT’S SOLICITORS]FAO [RELEVANT NAME][NAME OF PROPOSED DEFENDANT’S SOLICITORS, IF ANY][ADDRESS LINE 1][ADDRESS LINE...
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Produced in partnership with Lynne Counsell of 9 Stone Buildings 9th Apr
Precedents
[On the headed notepaper of the creditor’s solicitors]FAO [Insert name of the debtor’s solicitors][Address line 1][Address line 2][Postcode][Date]Dear...
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9th Apr
Precedents
[ON THE HEADED NOTEPAPER OF CLAIMANT’S SOLICITORS]FAO [RELEVANT NAME][NAME OF DEFENDANT OR DEFENDANT’S SOLICITOR IF KNOWN][ADDRESS LINE 1][ADDRESS...
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Produced in partnership with Steven O'Sullivan 9th Apr
Precedents
[ON THE HEADED NOTEPAPER OF CLAIMANT’S SOLICITORS]FAO [insert name of addressee][ADDRESS LINE 1][ADDRESS LINE 2][POSTCODE][DATE]Dear [insert...
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Produced in partnership with Leigh Callaway of Fladgate 9th Apr
Precedents
[ON THE HEADED NOTEPAPER OF THE CLAIMANT’S SOLICITORS]FAO [RELEVANT NAME][NAME OF DEFENDANT OR DEFENDANT’S SOLICITOR IF KNOWN][ADDRESS LINE 1][ADDRESS...
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9th Apr
Precedents
[ON THE HEADED NOTEPAPER OF CLAIMANT’S SOLICITORS]FAO [RELEVANT NAME][NAME OF PROPOSED DEFENDANT’S SOLICITORS, IF ANY][ADDRESS LINE 1][ADDRESS LINE...
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Produced in partnership with Lynne Counsell of 9 Stone Buildings 9th Apr

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