IN THE [COUNTY COURT AT [Insert] OR HIGH COURT] Claim No. [Insert claim number] Parties: [Insert name of Claimant] Claimant [(a patient, by his son and litigation friend XX (insert name of LF)] -and- [Insert name of Defendant] Defendant __________________________________ PARTICULARS OF CLAIM (CLINICAL NEGLIGENCE) __________________________________ The parties 1 The Claimant, a patient, was at all material times under the care of the Defendant, its employees or agents in respect of his nursing and personal care. 2 At all material times the Defendant operated, managed and administered a residential care home known as [Insert care home name], situated at [Address] (‘the care home’). 3 At all material times referred to below: 3.1 the Claimant was under the care of the Defendant and the Defendant owed a direct, non-delegable duty to the Claimant in respect of that care; 3.2 the Defendant’s staff, agents and employees owed the Claimant a duty of care to treat them with reasonable professional care, competence and skill; and 3.3 the said staff, agents or employees had the care