Witness statement in support of an application for return of inadvertently disclosed privileged documents

Copyright © 2025 LexisNexis
Produced in partnership with Mathew Purchase of Matrix Chambers
Precedents

Witness statement in support of an application for return of inadvertently disclosed privileged documents

Copyright © 2025 LexisNexis

Produced in partnership with Mathew Purchase of Matrix Chambers

Precedents
imgtext

[DETAILS OF DEPONENT ETC.]

IN THE [COURT]Claim no.: [insert claim number]

BETWEEN

  1. [CLAIMANT]        Claimant

  1. and

  1. [DEFENDANT]        Defendant

______________________________________________________________________________

[Insert number of] [AFFIDAVIT OR WITNESS STATEMENT] OF [NAME]

______________________________________________________________________________

I [FULL NAME] of [ADDRESS] [make oath and OR will] say as follows:

    1. 1

      I make this witness statement in support of the [claimant’s OR defendant’s OR application for the return of certain inadvertently divulged documents and for other related orders. The [claimant OR defendant] contends that those documents are protected by legal professional privilege.

    1. 2

      [[I

Mathew Purchase
Mathew Purchase

Matrix Chambers

Mathew Purchase's practice includes all aspects of employment law, discrimination law, public law and human rights and civil liberties. He is on the Attorney General's B Panel and is a member of the Bar Pro Bono Unit and ELAAS. He is recommended in Chambers and Partners and the Legal 500, which have described him as: ‘extremely intelligent’, ‘just superb - smooth, engaging and perfectly pitched’, and as someone who ‘always does excellent work’. Mathew has broad experience in public law and human rights, including community care, education, housing and civil actions against the police, from early advisory work to judicial review. Mathew has a strong interest in all aspects of education law and acts for parents/children, local authorities and schools at all levels. He has appeared in a number of judicial review claims; recent cases include R (UNISON) v Lord Chancellor (QBD, employment tribunal fees), R (Care North East Northumberland) v Northumberland County Council (CA, care home fees), R (Davis) v West Sussex Council (QBD, safeguarding of vulnerable adults), and R (Green) v Gloucestershire County Council (QBD, libraries closures).

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Jurisdiction(s):
United Kingdom

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