The pre-trial checklist, Form N170, requires, in section F, that various documents be attached and this includes an estimate of costs. However, at the top of the form is guidance for legal representatives only which states that if no costs management order (CMO) has been made: ‘You must attach estimates of costs incurred to date, and your likely overall costs. In substantial cases, these should be provided in compliance with CPR.’ In cases in which there is no CMO, CPR 29.6 or CPR PD 29, para 8, which deal with pre-trial checklists, do not provide any guidance as to form that a costs estimate should