Letter to client on disclosure obligations under CPR 31

The following Dispute Resolution precedent provides comprehensive and up to date legal information covering:

  • Letter to client on disclosure obligations under

Letter to client on disclosure obligations under CPR 31

This Precedent letter covers disclosure obligations under CPR 31. It does not apply to proceedings subject to the disclosure pilot scheme under CPR PD 51U. For guidance on the disclosure pilot scheme, see: Disclosure pilot scheme—overview. For a client letter on disclosure under the disclosure pilot scheme, see Precedent: Letter to client about disclosure under the Business and Property Courts disclosure pilot scheme.

Private, confidential & PRIVILEGED

[Insert name and address of client]

[insert date]

Dear [insert name of contact at the client]

Explaining the Disclosure Process and your Obligations

Thank you for your instructions in this matter. [This letter accompanies our retainer OR Our retainer will follow under separate cover].

[The purpose of this letter is to make you aware that OR As we have previously discussed] you have duties to the court to reveal the existence of documents relevant to this case and to provide them to your opponent. This process is called “disclosure”. Disclosure is a crucial feature of the litigation process, perhaps the most important, and consequently we need to start preparing for it immediately. It is my duty, as your legal representative, not only to explain the existence and scope of your disclosure obligations but also to supervise the process and ensure you make full and proper disclosure of all relevant documents. I will therefore be contacting you

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