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PRECEDENTS
[Date] [Client's name and address] Dear [insert client name] Re: Injunctive relief I am writing to advise you in respect of your proposed application for an interim injunction against [name of party] in order to [insert reason for and type of injunctive relief being sought]. An injunction is an order of the court that requires a party either to do a specified act (known as mandatory injunctions) or to refrain from doing a specified act (known as prohibitory injunctions). The aim of an interim injunction is to maintain the status quo and/or limit potential injustice in advance of a claim or issue being determined. When considering whether to grant an injunction, the court will address whether: • there is a serious question to be tried; • damages are likely to be an adequate remedy in respect of any loss that might be suffered if the injunction is not granted; • it
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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 relation to [insert matter name / details]. [This letter accompanies our retainer OR Our retainer will follow under separate cover]. It [has been confirmed OR is likely OR is possible] that your dispute with [describe other parties] will be dealt with in the Business and Property Division [if it proceeds to formal litigation]. The purpose of this letter is to advise you specifically about what disclosure under the Disclosure Scheme (DS) that applies in the Business and Property Division entails and what you need to know about the process. Even if you have dealt with disclosure previously, you should carefully review this document to understand how the DS applies to your case. [If you have dealt with disclosure before, you may well find that the DS requires more actions (including a proactive collaboration) to be taken by the
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Private & confidential [insert name and address of client] [insert date] Dear [insert name of client] [insert case heading] As we have already discussed, the use of expert evidence is required to prove or refute a number of issues in this claim. To be able to rely on such evidence, the court’s permission is required and will be need to be sought during the case management conference fixed for [date]. Prior to that, we will need to complete a directions questionnaire to provide the court with the information in relation to all different aspects of the proceedings including the need for expert evidence and the subject of the expertise required. While we are still at an early stage of the claim, we ought to provide specific information about the issues that require expert evidence and, if possible, seek to agree these with the other parties, including an estimate of the likely costs associated with using expert evidence. This estimate is important for the purpose of cost budgeting. [Insert any information specific to your case in relation
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[enter name of client] [enter address of client] [enter date] Dear [enter name of client] Estate of [enter
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[name of client] [enter address of client] [enter date] Dear [name of client] The late [enter name of deceased] The grant
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Dear [insert name of client] As agreed, we have instructed [insert name of barrister] of [insert name of chambers] to [state what you have instructed the barrister to do]. [We expect to receive the barrister’s advice within [insert time period] OR We have arranged a conference with the barrister on [state date, time and location and whether it is necessary for the client to attend]]. We have agreed fees for [state what you have instructed the
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Dear [insert client name] Costs estimate to final hearing As we have now had the financial dispute resolution (FDR) appointment on [insert date], I am sending you a costs summary up to the final hearing on [insert date]. As set out in our terms of business dated [insert date], my hourly rate is £[insert amount] [plus VAT]. [insert name] will continue to have overall supervision of the case and input into the final hearing preparation. We also have other fee earners in the team at different hourly rates to whom tasks will be delegated where appropriate in order to save costs. I enclose a schedule of hourly rates for your information. Issues In summary, the main issues in your case are: • [insert issue] • [insert issue] Final hearing preparation Substantial costs are likely to be incurred in the weeks leading up to the final hearing which the court has listed to take place on [insert date] from [insert time] at [insert location] with a time estimate of [insert number] day[s]. The solicitors representing your [former]
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[We have reached a stage in your matter where OR Now that we have concluded your matter], we believe it would be in your best interests to [state what you wish to introduce the client for]. Relationship with [name of separate business] [State precise relationship between the firm and separate business, eg The partners in this firm own 50% of the shares in [name of separate business]]. [Name of separate business] is, however, an entirely separate business to this firm[, even though:] • [we share the same or similar name, branding, or staff • our premises are shared with or close to [name of separate business] • we have shared or linked or websites and contact details • we will conduct joint publicity with [name of separate business]] It is important that you understand: • we are not instructing [name of separate business] on your behalf—we are simply referring you to [name of separate business] and you will instruct them direct for [state what you wish to introduce the client for] • [name of separate business] will advise you independently
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[Name of client] [Address of client] [Date of this letter] Dear [insert name of client] [We have reached a stage in your matter where OR Now that we have concluded your matter], we believe it would be in your best interests to [state what you wish to introduce the client for, eg take advice on tax planning]. This is something we have already discussed and you have agreed that we will refer you to [state name of third party to whom you have introduced the client]. We have
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Dear [insert client’s name] [Divorce OR Dissolution] I confirm that the application has been issued by the court and served on your [husband OR wife OR civil partner]. I enclose a copy of the issued application for your records. The next step is for your [husband OR wife OR civil partner] to file an acknowledgment of service within 14 days beginning with the date on which the application was served. This means that they must file the acknowledgment of service by [insert date] if they are using the online system. If they are not using the online system, then we will be notified as to the date they are required to file the acknowledgment of service by. [As your [husband OR wife OR civil partner] is outside of England and Wales, that period of time is extended to [insert date].] Your [husband
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[insert date] Dear [insert client’s name] Following on from the financial agreement reached between you and your [former] [husband OR wife OR civil partner], I enclose: • a draft consent order, and • a statement of information for a consent order in relation to a financial remedy (Form D81) for you to consider and approve. Statement of information for a consent order in relation to a financial remedy (Form D81) Form D81 is a standard form court document, the purpose of which is to set out the facts of your case in a way which is easy for a judge to assimilate. It is intended to give a summary of each party's finances. Form D81 sets out your current capital and income and the capital and income as it will be after the implementation of the proposed order. The court requires this information so that the judge can decide whether it is appropriate to approve the consent order which you are seeking.
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Dear [insert client’s name] Conditional order I have received the certificate of entitlement to conditional order and I enclose a copy for your records. As you will see, the court has fixed the date of [insert date] at [insert time] for the pronouncement of conditional order. A conditional order means that the court has agreed that you are entitled to a [divorce OR dissolution], but has not yet made it final. Conditional orders are made in open court. This means the judge reads out a list of names of people whose applications have got to conditional order stage. Although anyone can go to court to hear this if they want to, you do not have to attend court when this