This Checklist provides a suggested approach for dealing with and responding to a freezing injunction. It is intended as a starting point, listing various key matters which you should consider when preparing your response. It is assumed that: • the freezing injunction was granted pre-action and without notice, and • your client is the defendant in the underlying substantive claim For further guidance on freezing injunctions generally, see Practice Notes: • Freezing injunctions—guiding principles • Freezing injunctions—the application • Freezing injunctions—the draft order Ensuring you have all the necessary documentation The applicant should have provided the following documentation (at the very least): • the application notice • the affidavit(s) in support • the sealed order • a transcript of the hearing • the skeleton argument (if one was used at the hearing) If any of the above documents are missing, ask the applicant’s solicitors for them as a matter of urgency. In addition, check whether you have all of the documents relied upon at the without notice hearing and whether, depending on the circumstances,

This Practice Note considers how to respond to a letter of claim in accordance with the Practice Direction Pre-Action Conduct and Protocols (the Practice Direction). It covers: • initial considerations on receipt of a letter of claim, including an assessment of whether the letter is compliant with the Practice Direction • document preservation and collection • information gathering • analysing the material available • privilege • identifying any potential counterclaims and agreeing an early case strategy • settlement and ADR • preparation of a letter of response • early case management considerations This Practice Note provides guidance on the interpretation and application of the relevant provisions of the CPR. Depending on the court in which the claim may be commenced, you might also need to be mindful of additional provisions—see further below. For a high-level summary of the content covered below, see Practice Note: How to respond to a letter of claim. Initial considerations Does the letter of claim comply with the Practice Direction? As indicated above, this Practice

This Practice Note examines the practical steps an employer should consider when faced with an employee who has resigned, where potential competitive activity is suspected. It covers the initial response, tactics where resignation is in breach of contract, exit interviews, and issues in relation to suspension of the employee. Garden leave is examined, as well as dismissal and constructive dismissal. Finally, enforcing post-termination restrictions is considered. Initial response It is not inconceivable that the first indication an employer will have about potential competitive activity by an employee is when that employee resigns. The employer's response is critical, and so managers who are likely in practice to receive an employee’s notice of resignation should be given appropriate training on how to respond. In many cases, an adequate response will simply be for the manager to take the employee's letter, if there is one, say that they will contact HR and state that the employee will be called to a meeting later to discuss the relevant details and arrangements for their departure. However, it may be helpful if the manager

This Checklist sets out some of the key considerations for an individual or company who has received a statutory demand (referred to throughout as a debtor) from a party who claims they are owed money (referred to throughout as a creditor). It is intended as a high-level summary of the key considerations from a dispute resolution lawyer’s perspective. For detailed guidance and case law concerning statutory demands, see: Statutory demands for restructuring and insolvency professionals—overview. Otherwise, for a general understanding of contractual debt claims and, in particular, the considerations that apply in the context of disputed debts, see: • Practice Note: Debt claims • Practice Note: Starting a contractual debt claim — a practical guide, and • Starting a contractual debt claim—checklist For a checklist setting out some of the key considerations for a creditor when making a statutory demand, including general details on statutory demands from a dispute resolution perspective, see: Making a statutory demand for dispute resolution lawyers—checklist. What are the initial considerations when served with a statutory demand? Issue Considerations What

This is an example of a guide which can be sent to clients. This client guide explains how a commercial tenant in England and Wales should prepare for and respond to a landlord's end of lease claim about the condition of commercial premises. A landlord may claim money at the end of a commercial lease because it says the tenant has not left the property in the condition required by the lease. This is commonly called a terminal dilapidations claim. The amount claimed is not automatically the amount the tenant must pay. The lease terms, the condition of the property, the landlord's plans and the landlord's actual losses all need to be considered. What is this guide about? This guide explains the practical steps a commercial tenant should take before the lease ends and after receiving a claim. It covers: • checking the lease and other property documents • checking the landlord's schedule of dilapidations (ie alleged breaches) (the Schedule) and its quantified demand (the Demand) for money • preparing an item-by-item response to the Schedule • considering

This Practice Note explains how a respondent submits an answer to an appeal and the potential to include a cross-appeal. It also explains the consequences of failing to submit a respondent’s answer in response to an appeal, as well as the time limits for submitting an answer and/or cross appeal and the procedure for applying for extensions to those time limits. It considers the procedure when a respondent wishes to argue at the full hearing that the Notice of Appeal raises a point of law not argued in the employment tribunal below, and considers the procedure for an appellant to serve a reply in response to a cross-appeal. The EAT will send to all parties who are respondents to the appeal: • the Notice of Appeal, with any amendments which have been permitted • any submissions or skeleton argument lodged by the appellant Within 28 days of the seal date of the order, unless some other period is directed, each respondent to the appeal must present a respondent's Answer, including any cross-appeal if one is to

This Practice Note gives guidance on what a respondent should do if served with an appellant’s notice of appeal in the County Court, the High Court or the Court of Appeal under Part 52 of the CPR. It looks at filing a written statement in response to an application for permission to appeal (PTA) under para 19 of Practice Direction 52C, when a respondent’s notice is needed, what it should contain, whether it can be amended and when it should be filed and served. It also considers the circumstances in which an appeal notice can be struck out under Rule 52.9 together with skeleton arguments and PTA. The Practice Note contains guidance to the provisions contained within CPR 52 and CPR PD 52A. These general provisions apply to: • appeals to the Civil Division of the Court of Appeal • appeals to the High Court • appeals to the County Court • applications made in the High Court or the Court of Appeal for permission to appeal to the Supreme

This Checklist sets out the key points which respondents will need to consider when responding to an imaging order. It should be read in conjunction with the following Practice Notes: • Search and imaging orders—guiding principles • Search and imaging orders—making an application • The model search and imaging order • Search and imaging orders—execution of the order and next steps For guidance from the perspective of an applicant seeking an imaging order, see: Applying for an imaging order—checklist. 6 April 2025 changes The CPR provisions relevant to interim injunctive relief, including search and imaging orders, were amended on 6 April 2025. In particular, CPR 25 was revised extensively and the accompanying Practice Directions, including the standard draft search order and form for an imaging order (included respectively in Annex A and Annex B of Practice Direction 25A), were revoked. In their place, the model search and imaging order came into force on 6 April 2025 (the ‘model search and imaging order’). For further background, including links to the provisions in force immediately

A dual-track investigation arises where the UK’s Financial Conduct Authority (FCA) seeks to obtain evidence capable of supporting either a criminal prosecution or a regulatory/civil action, pending a decision on the appropriate course of action to pursue or whether take no further action. Dual-track investigations are a serious matter for those who are, or are likely to become, the subject of one, presenting significant legal, financial and reputational risk. This Practice Note explains their legal basis, potential outcomes and the strategic considerations for those facing them. What is a dual-track investigation? A dual-track investigation enables the FCA to investigate suspected misconduct without committing at the outset to either a a criminal prosecution or a regulatory/civil action. It can therefore gather evidence to support either course of action, until the time comes to decide which type of action to pursue or whether take no further action. Although not expressly provided for in statute, this approach is grounded in the FCA’s information gathering and investigation

The term used in adjudication for the defence'.

See offeree board circular and defence document.

IN THE MATTER OF THE housing grants, construction and regeneration act 1996 And IN THE MATTER OF AN ADJUDICATION BEFORE [Name of Adjudicator] Between [Name of party 1]        The Referring Party and [Name of party 2]        The Responding Party _______________________________________ RESPONSE _______________________________________ Introduction 1 This is the Responding Party’s Response to the Referring Party’s Referral Notice served on [date] (the Referral). 2 This Response is accompanied by a bundle, which includes the following materials: 2.1 chronology of relevant events at tab [insert] (Tab [insert]) 2.2 [insert] at tab [insert] (Tab [insert]) 2.3 [insert] at tab [insert] (Tab [insert]) 3 In this Response, references to the documents and materials accompanying the Notice of Adjudication and Referral are in the form used by the Referring Party. 4 This Response addresses the key issues in dispute. It does not respond to the Referral on a paragraph-by-paragraph basis, nor answer every allegation made in the Referral. For the avoidance of doubt, however, all allegations made by the Referring Party in the Notice of Adjudication and Referral are denied, save where admitted in, or coincidental with the content of, this Response. 5 For the adjudicator’s ease of reference, this Response as far as possible follows the