Claim No. [insert number]

In the County Court at [insert location]

Between

1. [Insert Claimant’s name]        Claimant

1. and

1. [Insert defendant name]        Defendant

_____________________________________________________________________________

PARTICULARS OF CLAIM

_____________________________________________________________________________

1. 1. 1

      This is a claim for damages for Noise-induced hearing loss.

   1. 2

      The Defendant employed the Claimant as a [insert job title] from [insert date] to [insert date].

   1. 3

      In the course of [his OR her] employment with the Defendant the Claimant was persistently exposed to dangerously high levels of noise in the high 90s dB(A) LEP,d, in the following circumstances:

      1. (a)

         The Claimant worked on big building projects, such as hotels and bus stations.

      1. (b)

         [He OR She] used power tools such as drills, electric planers and circular saws on a daily basis. [He OR She] used drills for at least [insert number] hours a day and circular saws for [insert number] hours a day.

      1. (c)

         [He OR She] used the drills to drill into concrete and steel. Two cement mixers were in constant operation.

      1. (d)

         While