In response to several e-mails over recent months I have prepared two courses, available in-house only: one on drafting witness statements, the other on “avoiding procedural pitfalls”.


“Too often (indeed far too often) witnesses who have had statements prepared for them by solicitors tell the Judge that matters in the statement are not correct; they say (all too believably) that they simply signed what the solicitor had drafted for them without reading it through carefully and critically. This reflects badly not only on the witness, but on the whole case presented by the party calling the witness.”*

This course is three hours long it looks at:

  • The mandatory requirements for witness statements and the consequences of non-compliance.
  • The ethical considerations of drafting witness statements.
  • Signature of the witness statement.
  • Witness reliability and credibility.
  • Preparing the witness statement.
  • Protecting the witness from the lawyer.
  • Protecting the lawyer from the witness.
  • Witness statements and proportionality.
  • Where lawyers go badly wrong with witness evidence.
  • The consequences of not calling a witness.
  • A checklist for taking a statement.
  • “Proving things” at trial.

The course has already been delivered to a wide range of firms. It has been of particular interests to firms where fee earners have only limited experience of trials and of their witness statements being “tested”.

It is also “interactive” in that people get to try out their witness statement taking skills.


“the court will be far less tolerant of breaches that it has been in the past. Parties and practitioners must understand that they must obey court orders and comply with them, or promptly apply for relief from sanction.”**

Again this is three hours long:

Topics include:-

  • The reasons lawyers make mistakes.
  • Limitation.
  • Service of the claim form and other documents.
  • Evidence.
  • Time limits.
  • Effective applications for relief from sanctions.
  • Effective systems to prevent problems.
  • Having effective systems in place if things go wrong.
  • Working to a budget and trying to avoid disproportional costs that will not be recovered.

These are only available “in-house”. They can be done separately or together over a whole day. For details of the courses and the charges contact me on

* the Handbook for Litigants in Person (written by six experienced Circuit Judges)

** Mr Justice Snowden in Walton -v- Allman [2015] EWHC 3325 (Ch)