Filed on behalf of the [claimant OR defendant] Witness statement of [insert initials and surname of witness] Number of witness statement: [insert number of witness statement in relation to the witness] Exhibit details: [insert initials and number of each exhibit referred to] Date on which the statement was made: [insert date] [Date of translation (if applicable): [insert date]] Claim No. [insert claim number]. [IN THE HIGH COURT OF JUSTICE [BUSINESS AND PROPERTY COURTS [OF ENGLAND AND WALES OR IN [insert location]] ] [Specify division] [Specify specialist court] [Insert location] DISTRICT REGISTRY OR THE COUNTY COURT AT [insert location] [BUSINESS AND PROPERTY COURTS LIST] ] between: [insert name]        Claimant and [insert name]        Defendant _______________________________________ [NUMBER OF

While both liquidators and administrators can now bring fraudulent trading claims under sections 213 and 246ZA of the Insolvency Act 1986 respectively, this Precedent is drafted from the perspective of a liquidator bringing such a claim. Applicant(s): [insert initials and surname] [insert number of witness statement eg 1st] Exhibit: [insert exhibit description] Date: [insert date of witness statement] CASE NO: [insert case number] [ IN THE HIGH COURT OF JUSTICE BUSINESS AND PROPERTY COURTS OF ENGLAND AND WALES INSOLVENCY AND COMPANIES LIST (ChD) OR IN THE HIGH COURT OF JUSTICE BUSINESS AND PROPERTY COURTS IN [insert location] INSOLVENCY AND COMPANIES LIST (ChD) OR IN THE COUNTY COURT AT [insert location] BUSINESS AND PROPERTY WORK ] IN THE MATTER OF [insert company’s name] AND IN THE MATTER OF THE INSOLVENCY ACT 1986 BETWEEN [Insert name(s) of the Applicant(s)]        Applicant(s) AND

Applicant(s): [insert initials and surname] [insert number of witness statement eg 1st] Exhibit: [insert exhibit description] Date: [insert date of witness statement] CASE NO: [insert case number] [ IN THE HIGH COURT OF JUSTICE BUSINESS AND PROPERTY COURTS OF ENGLAND AND WALES INSOLVENCY AND COMPANIES LIST (ChD) OR IN THE HIGH COURT OF JUSTICE BUSINESS AND PROPERTY COURTS IN [insert location] INSOLVENCY AND COMPANIES LIST (ChD) OR IN THE COUNTY COURT AT [insert location] BUSINESS AND PROPERTY WORK ] IN THE MATTER OF [insert company’s name] AND IN THE MATTER OF THE INSOLVENCY ACT 1986 BETWEEN [Insert name(s) of the Applicant(s)]        Applicant(s) AND [Insert name(s) of the Respondent(s)]        Respondent(s) [INSERT NUMBER] Witness statement of [Insert name OF OFFICE-HOLDER] I, [insert name of the office-holder] of [insert the office-holder's business address] WILL SAY as follows: General 1 I am a [insert position] in [insert the name and address of the office-holder’s firm]. 2 I am the liquidator of [insert name of the company] (the Company) and make this witness statement in support of my application for:

Filed on behalf of the Claimant Witness statement of [insert initial and surname of witness] Number of witness statement: [insert number of witness statement in relation to the witness] Exhibit details: [insert initials and number of each exhibit referred to] Date on which the statement was made: [insert date] [Date of translation: [insert date]] Claim No. [insert claim number] [IN THE HIGH COURT OF JUSTICE [BUSINESS AND PROPERTY COURTS [OF ENGLAND AND WALES OR IN [insert location]] ] [Specify division] [Specify specialist court] [Insert location] DISTRICT REGISTRY OR THE COUNTY COURT AT [insert location] [[BUSINESS AND PROPERTY COURTS LIST]] ] IN THE INTENDED ACTION between: [insert name]        Intended Claimant/Applicant and [insert name]        Intended Defendant/Respondent _______________________________________ [NUMBER OF WITNESS STATEMENT EG FIRST] witness statement of [insert name of witness] On behalf of the intended claimant/applicant _______________________________________ I, [insert full name of witness] of [insert professional address], will say AS FOLLOWS: 1 Preliminaries 1.1 I am the Managing Director of the Applicant and make this statement on its behalf.

While both liquidators and administrators can bring a wrongful trading claim under sections 214 or 246ZB of the Insolvency Act 1986 respectively, this Precedent is drafted from the perspective of a liquidator bringing such a claim.  Applicant(s): [insert initials and surname] [insert number of witness statement eg 1st] Exhibit: [insert exhibit description] Date: [insert date of witness statement] CASE NO: [insert case number] [ IN THE HIGH COURT OF JUSTICE BUSINESS AND PROPERTY COURTS OF ENGLAND AND WALES INSOLVENCY AND COMPANIES LIST (ChD) OR IN THE HIGH COURT OF JUSTICE BUSINESS AND PROPERTY COURTS IN [insert location] INSOLVENCY AND COMPANIES LIST (ChD) OR IN THE COUNTY COURT AT [insert location] BUSINESS AND PROPERTY WORK ] IN THE MATTER OF [insert company’s name] AND IN THE MATTER OF THE INSOLVENCY ACT 1986 BETWEEN [Insert name(s) of the Applicant(s)]        Applicant(s) AND [Insert name(s) of the Respondent(s)]        Respondent(s) [INSERT NUMBER] Witness statement of [Insert name OF OFFICE-HOLDER] I, [insert name of the office-holder] of [insert the office-holder's business address] WILL SAY as follows: General 1 I am a [insert position] in [insert the name and address of the office-holder’s firm].

Filed on behalf of the Claimant Witness statement of [initial and surname of witness] Number: [number of witness statement in relation to the witness eg ‘Second'] Exhibit: [initials and number of each exhibit referred to eg ‘MXW1'] Date: [date of statement] [Date of translation: [insert date]] Claim No. [insert claim number]. [IN THE HIGH COURT OF JUSTICE [BUSINESS AND PROPERTY COURTS [OF ENGLAND AND WALES OR IN [insert location] OR [Specify division] [Specify specialist court] [Insert location] DISTRICT REGISTRY THE COUNTY COURT AT [insert location] [BUSINESS AND PROPERTY COURTS LIST BEFORE [The Honourable Mr Justice OR The Honourable Mrs Justice OR His Honour Judge OR Her Honour Judge] [insert name] Dated: [insert date] Between

Filed on behalf of the Claimant Witness statement of [insert initial and surname of witness] Number: [insert number of witness statement in relation to the witness eg ‘Second’] Exhibit: [insert initials and number of each exhibit referred to eg ‘MXW1’] Date: [insert date of statement] [Date of translation: [insert date]] Claim No. [insert claim number]. [IN THE HIGH COURT OF JUSTICE [BUSINESS AND PROPERTY COURTS [OF ENGLAND AND WALES OR IN [insert location] OR [Specify division] [Specify specialist court] [Insert location] DISTRICT REGISTRY THE COUNTY COURT AT [insert location] [BUSINESS AND PROPERTY COURTS LIST BEFORE [The Honourable Mr Justice OR The Honourable Mrs Justice

Applicant(s): [insert initials and surname]: [insert number of witness statement eg 1st] Exhibit: [insert exhibit description]: Date: [insert date of witness statement] CASE NO: [insert case number] [ IN THE HIGH COURT OF JUSTICE BUSINESS AND PROPERTY COURTS OF ENGLAND AND WALES INSOLVENCY AND COMPANIES LIST (ChD) OR IN THE HIGH COURT OF JUSTICE BUSINESS AND PROPERTY COURTS IN [insert location] INSOLVENCY AND COMPANIES LIST (ChD) OR IN THE COUNTY COURT AT [insert location] BUSINESS AND PROPERTY WORK ] [ IN THE MATTER OF [insert company’s name] OR IN THE MATTER OF [insert bankrupt’s name] IN BANKRUPTCY ] AND IN THE MATTER OF THE INSOLVENCY ACT 1986 BETWEEN [Insert name(s) of the Applicant(s)]        Applicant(s) AND [Insert name(s) of the Respondent(s)]        Respondent(s) [INSERT NUMBER] Witness statement of [Insert name OF OFFICE-HOLDER] I, [insert name of the office-holder] of [insert the office-holder's business address] WILL SAY as follows: General 1 I am a [insert position] in [insert the name and address of the office-holder’s firm]. 2 I am the [insert office held] of [insert name of the company/bankrupt (the Company/Bankrupt)]

Applicant(s): [insert initials and surname]: [insert number of witness statement eg 1st] Exhibit: [insert exhibit description]: Date: [insert date of witness statement] CASE NO: [insert case number] [ IN THE HIGH COURT OF JUSTICE BUSINESS AND PROPERTY COURTS OF ENGLAND AND WALES INSOLVENCY AND COMPANIES LIST (ChD) OR IN THE HIGH COURT OF JUSTICE BUSINESS AND PROPERTY COURTS IN [insert location] INSOLVENCY AND COMPANIES LIST (ChD) OR IN THE COUNTY COURT AT [insert location] BUSINESS AND PROPERTY WORK ] IN THE MATTER OF [insert company’s name] AND IN THE MATTER OF THE INSOLVENCY ACT 1986 BETWEEN [Insert name(s) of the Applicant(s)]        Applicant(s) AND [Insert name(s) of the Respondent(s)]        Respondent(s) [INSERT NUMBER] WITNESS STATEMENT OF [INSERT NAME OF OFFICE-HOLDER] I, [insert name of the office-holder] of [insert the office-holder's business address] WILL SAY as follows: General 1 I am a [insert position] in [insert the name and address of the office-holder’s firm]. 2 I am the [insert office held] of [insert name of the company] (the Company) and make this witness statement in support of my application pursuant to rule 18.23 of the Insolvency

On behalf of: Applicant By: [insert name] No: 1 Exhibits: [insert details] Date: [insert date] Filed: [insert date] Claim No. [insert claim number]. IN THE HIGH COURT OF JUSTICE BUSINESS AND PROPERTY COURTS [ OF ENGLAND AND WALES OR IN [insert location]] In the matter of [Insert company name] And In the matter of the companies act 2006 Statement of [Insert full name] I, [Insert full name], [insert role/job title] of [insert company name] of [insert address] Do state as follows: 1 Introduction I am the [insert role or job title] of [insert company name] (the Company), having been appointed on [insert date]. I have been the officer of the Company most closely connected with the proposal that is the subject of this witness statement. The facts and matters to which I refer in this witness statement are either within my own knowledge and are true, or derived from the sources to which I refer below, in which case they are true to the best of my information and belief. 2 I am duly authorised by the Company to make this statement in support

Applicant(s): [insert initials and surname]: [insert number of witness statement eg 1st] Exhibit: [insert exhibit description]: Date: [insert date of witness statement] CASE NO: [insert case number] [ IN THE HIGH COURT OF JUSTICE BUSINESS AND PROPERTY COURTS OF ENGLAND AND WALES INSOLVENCY AND COMPANIES LIST (ChD) OR IN THE HIGH COURT OF JUSTICE BUSINESS AND PROPERTY COURTS IN [insert location] INSOLVENCY AND COMPANIES LIST (ChD) OR IN THE COUNTY COURT AT [insert location] BUSINESS AND PROPERTY WORK ] IN THE MATTER OF [insert company’s name] AND IN THE MATTER OF THE INSOLVENCY ACT 1986 BETWEEN [Insert name(s) of the Applicant(s)]        Applicant(s) AND [Insert name(s) of the Respondent(s)]        Respondent(s) [INSERT NUMBER] Witness statement of [Insert

Applicant(s): [insert initials and surname] [insert number of witness statement eg 1st] Exhibit: [insert exhibit description] Date: [insert date of witness statement] CASE NO: [insert case number] [ IN THE HIGH COURT OF JUSTICE BUSINESS AND PROPERTY COURTS OF ENGLAND AND WALES INSOLVENCY AND COMPANIES LIST (ChD) OR IN THE HIGH COURT OF JUSTICE BUSINESS AND PROPERTY COURTS IN [insert location] INSOLVENCY AND COMPANIES LIST (ChD) OR IN THE COUNTY COURT AT [insert location] BUSINESS AND PROPERTY WORK ] IN THE MATTER OF [insert bankrupt’s name] IN BANKRUPTCY AND IN THE MATTER OF THE INSOLVENCY ACT 1986 [Insert name(s) of the Applicant(s)]        Applicant(s) AND [Insert name(s) of the Respondent(s)]        Respondent(s) [INSERT NUMBER] Witness statement of [Insert