Parties:

1. [Mrs Jane Bloggs]        Claimant

1. -and-

1. [A Care Home]        Defendant

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Particulars of claim

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The parties

1. 1. 1

      The Claimant was at all material times under the care of the Defendant, its employees or agents in respect of her nursing and personal care.

   1. 2

      At all material times the Defendant operated, managed and administered a private residential care home known as [A Care Home], situated at [Address] (‘the care home’).

   1. 3

      At all material times referred to below:

      1. 3.1

         the Claimant was under the care of the Defendant and the Defendant owed a direct non-delegable duty to the Claimant in respect of that care;

      1. 3.2

         The Defendant’s staff, agents and employees owed the Claimant a duty of care in contract and/or tort to treat them with reasonable professional care, competence and skill; and

      1. 3.3

         The said staff, agents or employees had the care of the Claimant pursuant to their contracts of engagement or employment with the Defendant, and, accordingly, the Defendant is liable to the Claimant for