Legal fees

[Kazdoyle]

Thank you so much ULA. I can wait for your email.

[ULA]

You can adapt to suit your style but I suggest something along the following lines:

Dear xxx

Further to your response to my email of this morning, I would like to remind you that in your correspondence of [insert date] it was you that said you would be ready to exchange witness statements on 10 April, despite me being ready to exchange witness statement on the deadline date of 16 Feb 2024, as set out in the Case Management Orders. As you should be fully aware deadline dates, as set out in Case Management Orders can be extended by a maximum of 14 days if agreed by both parties and any extension beyond that requires an application to the Tribunal. To my knowledge, as you have not copied me in to any correspondence as required under Rule 92, you have not made an application to extend the date for the exchange of witness statements, which is now nearly 8 weeks since the deadline date.

As you are aware I am a litigant in person (LiP) and as qualified solicitor representing your client, not do you owe a duty to your client but also to the court and the administration of justice. You have already set out that you have numerous witness statements which I will need to review in preparation for the hearing set for June. The longer you have extended the deadline for exchanging witness statements the closer to the hearing and the less time I have as a LiP to prepare. This does not give me a fair and reasonable chance of preparing and therefore is contrary to your duty in the administration of justice.

If you are not ready to exchange witness statement by mid-day on Friday 12 April, I will be making an application to the Tribunal for an Unless Order and will detailing your continued delays and extensions of Tribunal set deadlines.


I would suggest you then this so that it is with them for opening of business tomorrow.

[Kazdoyle]

Thank you very much ULA. I just sent that email out with the date. Will keep you posted what happens on Friday.