This Practice Note provides practical guidance on key elements required to draft a compelling counter schedule of loss. There is guidance on the best way to set out the defendant's response to the claimant's schedule of special damages. Commonly claimed heads of past and future loss are considered in detail, together with links to relevant case law.
This Practice Note provides practical guidance on drafting schedules of loss. There is commentary on the appropriate wording at the introduction of a schedule, as well as a summary of the key case facts which should be included. Details of commonly recovered heads of loss are then considered, together with the supporting case law. Both past and future losses are included. Finally, there is a review of CPR Pt 22 and the requirements for a statement of truth.
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