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Updates and Commentary on Civil Procedure, by Gordon Exall, Barrister, Kings Chambers
Browse: Home » 2016 » October

"DID NOT PRETEND TO UNDERSTAND THINGS ATTRIBUTED TO HER IN HER WITNESS STATEMENT…"

October 31, 2016 · by gexall · in Civil evidence, Members Content, Uncategorized, Witness statements

There are several high profile cases in which judges have expressed scepticism (sometimes profound scepticism) about whether a witness statement really reflects the knowledge of a witness.  A short, but telling, passage in the judgment of Mr Justice Mitting in…

TALES FROM COSTS LAW CONFERENCE II: THE RISE OF SOLICITOR AND OWN CLIENT COSTS DISPUTES

October 31, 2016 · by gexall · in Assessment of Costs, Costs, Members Content, Uncategorized

One of the predictions made by several speakers at the Association of Costs Lawyers conference last week was the likelihood of a rise in the number of solicitor and own client disputes in relation to costs. Clients are now paying…

COSTS BUDGETING: PILOT SCHEME IN THE CHANCERY DIVISION IN LEEDS

October 30, 2016 · by gexall · in Case Management, Costs, Members Content, Uncategorized

 Leeds District Registry has a pilot scheme in relation to costs budgeting. It enables the parties to agree to limit the extent of costs budgeting.  The parties can, by agreement, file a simple costs budget with the Directions Questionnaire. If…

ANOTHER EXPERT WITNESS GOES AWRY: PATENTLY A PROBLEM

October 30, 2016 · by gexall · in Case Management, Expert evidence, Experts, Members Content, Uncategorized

It is easy for the non-technical reader to pass over judgments relating to patents. These often involve highly technical issues.  However there is one aspect of the judgment in Thoratec Europe Limited -v- AIS GMBH Aachen Innovative Solutions [2016] EWHC…

COSTS BUDGETING: IT'S JUST A PHASE I'M GOING THROUGH

October 29, 2016 · by gexall · in Case Management, Costs, Costs budgeting, Members Content, Uncategorized

One advantage of going to conferences is that it usually gives rise to ideas for the blog. So speaking at the Association of Costs Lawyers conference yesterday has given rise to a whole host of issues which will be explored…

EVIDENCE, RETAINERS, ATTENDANCE NOTES AND WITNESS CREDIBILITY

October 29, 2016 · by gexall · in Civil evidence, Members Content, Uncategorized, Witness statements

There have been a number of recent cases where disgruntled clients have attempted to sue their lawyers.  The judgments highlight the difficulties for trial judges who have to assess evidence after some lapse of time.  They also highlight the importance…

PART 36 OFFERS AND COSTS: COSTS NOT TAKEN INTO ACCOUNT WHEN CONSIDERING WHETHER AN OFFER HAS BEEN "BEATEN"

October 27, 2016 · by gexall · in Members Content, Part 36, Uncategorized

In Transocean Drilling UK Ltd -v- Providence Resources PLC [2016] EWHC 2611 (Comm) Mr Justice Popplewell considered the impact of a Part 36 offer in unusual circumstances.  These circumstances led the court to consider whether the impact of costs should…

HIGH COURT OVERTURNS DECISION TO GRANT RELIEF FROM SANCTIONS: NON-COMPLIANCE CANNOT AMOUNT TO "GOOD REASON"

October 27, 2016 · by gexall · in Appeals, Applications, Members Content, Relief from sanctions, Security for Costs, Uncategorized

  In Pittville Ltd -v- Hunters & Frankau Limited [2016] EWHC 2683 Mr Justice Snowden overturned the decision of a Deputy Master granting relief from sanctions.   The judgment contains an important consideration of the question of “good reasons” for…

WHEN SHOULD A WINNING PARTY PAY THE COSTS OF THE OTHER SIDE?

October 26, 2016 · by gexall · in Assessment of Costs, Costs, Members Content, Uncategorized

In Hospira UK Limited -v- Cubist Pharmaceuticals LLC [2016] EWHC 2661 Pat Mr Justice Henry Carr considered the question of when an “issue based” costs order should be made. “In my view, this apparent dichotomy may be resolved by a…

REASONABLENESS AND PROPORTIONALITY: A DIRECT IMPACT UPON LITIGATION DECISIONS

October 26, 2016 · by gexall · in Costs, Costs budgeting, Members Content, Uncategorized

I have been writing for some time about the impact of “proportionality” upon the practice of litigation itself.  One example of this can be found in the judgment of Master James in  Briggs & 598 others -v-  First Choice Holidays…

WHEN IS EXPERT EVIDENCE ADMISSIBLE: A MASTERLY EXPOSITION

October 24, 2016 · by gexall · in Case Management, Civil evidence, Civil Procedure, Expert evidence, Experts, Members Content, Uncategorized

The judgment of Master Matthews in Darby Properties Ltd -v- Lloyds Bank Plc [2016] 2494 (Ch) contains an important consideration of the rules relating to the admissibility of expert evidence. In particular when is expert evidence “necessary”? “… although I…

SURVEILLANCE EVIDENCE A BREACH OF ARTICLE 8 RIGHTS: ECHR DECISION

October 24, 2016 · by gexall · in Case Management, Civil evidence, Civil Procedure, Members Content, Uncategorized, Witness statements

In Vukota-Bojic -v- Switzerland the European Court held that the surveillance of an insurance claimant represented a breach of Article 8 rights (but use of that evidence at a hearing was not a breach of Article 6 rights).  It could…

NO RELIEF FROM SANCTIONS WHEN COSTS BUDGET FILED LATE: THE DECISION IN DETAIL

October 18, 2016 · by gexall · in Appeals, Applications, Members Content, Relief from sanctions, Uncategorized, Useful links

We have looked, briefly, at the Court of Appeal decision in Jamadar -v- Bradford Teaching Hospitals NHS Trust [2016] EWCA Civ 1001. I am grateful to Aaron Vodden   of  Hempsons for sending me a copy of the transcript which…

PAYING THE CORRECT COURT FEE AND LIMITATION: HIGH COURT DECISION CONSIDERING THE RELEVANT PRINCIPLES

October 18, 2016 · by gexall · in Amendment, Applications, Members Content, Uncategorized

One decision that has led to interlocutory skirmishing and opportunistic applications is  Lewis v Ward Hadaway [2016] 4 WLR 6, [2015] EWHC 3503 (Ch) and the consequences of failing to pay the correct court fee on issue.  This has left many…

PROVING THINGS 35: RECONSTRUCTION, DOCUMENTS AND MEMORY

October 18, 2016 · by gexall · in Members Content, Uncategorized, Witness statements

Most law reports will look at the findings of law made in a judgment. In this blog we are interested in findings of fact and the way in which a judge goes about making those findings.  A good example can…

PROVING THINGS 34 : THERE IS NO PRIMER FOR SCUTTLERS: WHEN YOUR SHIP DOESN'T COME IN

October 16, 2016 · by gexall · in Applications, Civil evidence, Members Content, Uncategorized, Witness statements

We have looked at many different types of case during this series. However this is the first time we have looked at an Admiralty case and at case about the “scuttling” of a ship.   The judgment of Mr Justice…

LATE ACCEPTANCE OF CLAIMANT'S PART 36 OFFERS: TWO CONTRASTING CASES & THE GREAT DEBATE

October 14, 2016 · by gexall · in Appeals, Members Content, Part 36, Uncategorized

There is an ongoing debate about whether the Defendant should, or does, face any adverse consequences when a Claimant’s Part 36 offer is accepted late.  I had a recent email from solicitor John McQuater of Atherton Godfrey.   Here I…

A JUDGMENT ON THE RELATIONSHIP BETWEEN COSTS BUDGETING AND THE ASSESSMENT OF COSTS: MAPPING & SURVEYING THE TERRAIN

October 13, 2016 · by gexall · in Case Management, Civil Procedure, Costs, Members Content, Uncategorized

In a judgment given today in Merrix -v-Heart of England NHS Foundation Trust Regional Costs Judge District Judge Lumb  (sitting in Birmingham) considered the extent to which the costs budgeting regime fettered the powers and discretion of the costs judge…

ADVOCACY THE JUDGE'S VIEW IX: WHAT YOU WEAR MATTERS

ADVOCACY THE JUDGE’S VIEW IX: WHAT YOU WEAR MATTERS

October 12, 2016 · by gexall · in Applications, Members Content, Uncategorized, Useful links

This is the ninth (and penultimate) post in this series. It is inspired by a search term on this blog today “Can a solicitor dress casually in county court”.  This caused a lot of attention when I mentioned in on…

CLAIMANT MUST REVEAL IDENTITY OF THIRD PARTY FUNDERS: HIGH COURT DECISION

October 12, 2016 · by gexall · in Members Content, Security for Costs, Third party funding, Uncategorized

In Wall -v- The Royal Bank of Scotland PLC [2016] EWHC 2460 (Comm) (Mr Andrew Baker QC sitting as a High Court Judge) the claimant was ordered to reveal the identity of third party funders. KEY POINTS The court has…

ALLEGATIONS AGAINST SOLICITORS THAT PROBABLY SHOULD NEVER HAVE BEEN MADE: CONSPIRACY, DISHONESTY AND DECEIT – ASSERTIONS THAT WERE JUST UNTRUE

October 12, 2016 · by gexall · in Civil evidence, Members Content, Uncategorized, Witness statements

There have been a number of recent cases of property companies, who have lost heavily in the property market, seeking to recover from solicitors (not necessarily always their own solicitors) for those losses.   This trend can be seen -…

ADVOCACY - THE JUDGE'S VIEW VIII: "CREDIBILITY IS ALL YOU HAVE"

ADVOCACY – THE JUDGE’S VIEW VIII: "CREDIBILITY IS ALL YOU HAVE"

October 11, 2016 · by gexall · in Civil evidence, Civil Procedure, Members Content, Uncategorized, Useful links

This post looks at at an article by Sidney Butcher in the ABA publication “Views from the Bench: Tips for Young Lawyers on How to Make a Good Impression.”  The Honorable Lynne Stewart, a District Court Judge and the Honourable…

THE MALLEABLE WITNESS: ANOTHER EXAMPLE WHERE LAWYERS WERE BLAMED FOR INCONSISTENT STATEMENTS

October 10, 2016 · by gexall · in Civil evidence, Members Content, Uncategorized, Witness statements

We have looked before at cases where witnesses point to their lawyers when discrepancies appear in their witness statements.  This can occur in every type of case as can be seen by the judgment of Mr Justice Edwards-Stuart in Fluor…

ADVOCACY THE JUDGE'S VIEW VII: WITNESS STATEMENTS - SHORT AND SWEET IS BEST

ADVOCACY THE JUDGE’S VIEW VII: WITNESS STATEMENTS – SHORT AND SWEET IS BEST

October 9, 2016 · by gexall · in Members Content, Uncategorized, Witness statements

We have already looked once this week at a judge’s viewpoint on the drafting of witness statements. In terms of advocacy they are crucial.  The rules only allow the witness to give additional evidence in exceptional circumstances.  Many cases that…

PROVING THINGS 33: CAUSATION AND THE BURDEN OF PROOF IN CLAIMS AGAINST SOLICITORS

October 7, 2016 · by gexall · in Applications, Civil evidence, Damages, Members Content, Professional negligence,, Uncategorized

We have looked before at the decision in The Connaught Income Fund, Series 1 -v- Hewetts Solicitors  [2016] EWHC 2286 (Ch). The previous post was in connection with witness evidence.  However the judgment on the burden of proof is significant in terms…

DESTINATION OF APPEALS: THE NEW RULES

October 7, 2016 · by gexall · in Members Content, Rule Changes, Uncategorized

The Access to Justice Act 1999 (Destination of Appeals) Order 2016 makes some important changes to the destination of appeals. It “simplifies” the appeals process so that, as far as possible, an appeal lies to the next level of judge….

JUDICIAL ASSESSMENT OF EXPERT EVIDENCE: NOT SIMPLY A CASE OF WHICH EXPERT IS PREFERRED

October 7, 2016 · by gexall · in Civil evidence, Credibility of experts, Expert evidence, Experts, Members Content, Uncategorized

There is a short passage in the judgment in Barclays Bank PLC -v- Christie Owen & Davies Limited [2016] EWHC 2351 (Ch) which considers the appropriate approach of the court when considering expert evidence. “To consider simply whether to prefer…

BEING A LITIGATOR – WHEN IT ALL GETS TOO MUCH (AND IT IS YOU THAT HAS TO PICK UP THE PIECES)

October 4, 2016 · by gexall · in Applications, Avoiding negligence claims, Case Management, Civil Procedure, Conduct, Members Content, Uncategorized

There have been a number of reported cases recently of young lawyers (sometimes trainees) obviously becoming overwhelmed by their workload.  This is not a new phenomenon, nor is it necessarily confined to young members of the profession. However it is…

LITIGANTS IN PERSON AND CASE MANAGEMENT: TIMELY SERVICE OF DOCUMENTS – DRAWING FROM THE FAMILY DIVISION

October 3, 2016 · by gexall · in Civil Procedure, Members Content, Uncategorized

Recent cases have made it clear that litigants in person do not have any special status during the conduct of litigation. However it is equally clear that, when making case management decisions, the court has to have regard to the…

WITNESS STATEMENTS, THE WEATHER AND THE DISTRICT JUDGE...

WITNESS STATEMENTS, THE WEATHER AND THE DISTRICT JUDGE…

October 3, 2016 · by gexall · in Members Content, Uncategorized, Witness statements

The observations by District Judge Etherington reported by John Hyde in the Law Society Gazette deserve repetition and the widest audience possible. (The Readers’ comments  on the article also make for interesting reading). THE GAZETTE REPORT The District Judge was speaking…

THIS COSTS BUDGETING THING – IT IS NOT THAT IMPORTANT: WELL THINK AGAIN

October 3, 2016 · by gexall · in Costs, Costs budgeting, Disclosure, Members Content, Security for Costs, Uncategorized

There are some important observations made by Mr Justice Roth in Agents’ Mutual Limited -v- Gascoigne Halman Limited [2016] EWHC 2315 (Ch) in relation to both costs budgeting and security for costs. KEY POINTS There is no duty on a…

RECOVERING LITIGATION FUNDING COSTS: A HIGH COURT CASE -BUT ABOUT ARBITRATION PROCEEDINGS

October 2, 2016 · by gexall · in Applications, Arbitration,, Assessment of Costs, Costs, Members Content, Uncategorized

I am grateful to Professor Dominic Regan and Nicholas Bacon QC for sending me a copy of the decision in Essar Oilfields -v- Norscot [2016] EWHC 2361 (Comm).A decision of His Honour Judge Waksman QC sitting as a Judge of…

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