The following PI & Clinical Negligence precedent provides comprehensive and up to date legal information covering:
[IN THE COUNTY COURT AT [INSERT]
IN THE HIGH COURT OF JUSTICE]
[[SPECIFY SPECIALIST COURT]]
[[INSERT LOCATION] DISTRICT REGISTRY]
[A B] Claimant
[X Y] Defendant
COUNTER SCHEDULE OF LOSS
The Defendant reserves the right to alter, amend or add to this Counter Schedule of Loss at any time up to and including trial.
Past loss of earnings
(i) Loss of earnings to [insert date eg 26 February 2019] are agreed in the pleaded claim of £[insert amount].
(ii)–(iii) Loss in the period [insert date eg 26 February 2019] to [insert date eg 25 August 2019] is not admitted. In principle, the Defendant would accept that it might take some time to obtain equally remunerative work. However, the Claimant’s evidence does not evidence reasonable steps to:
obtain work at a similar salary;
obtain an improved salary from that which he earned as a [insert job title eg HGV driver].
Past care and assistance
This is denied in part.
Both the net hourly rate (£[insert net hourly care rate claimed]) and the number of hours claimed ([insert number of hours claimed] or [insert number of hours claimed] hours a day) are excessive.
Having regard to the nature of the care, a fair net hourly rate is £[insert hourly care rate].
Given that the injury affected the Claimant’s non-dominant shoulder and taking account of the additional claim for window cleaning,
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