Issuing proceedings obviously takes you out of the predictive fees structure... but was it reasonable so to do?

Limitation Period
No response to Part 36 offer made
Defendant warned on realistic timetable to respond
Whilst primary liability conceded: causation: medical issues on pre existing, exaggeration, wrong facts and challenges on veracity.
Failing to respond in protocol and beyond

Butcher v Wolfe (1999) 1 FLR 334
Farmer v Dix 2006 SCCO 5RG08511

Watch your WIP: prepare your file notes: terminology and words used. Would you be happy for the court to see your file at detailed assessment?

Agencies

Are you properly utilising their services; your instructions, their invoices. The test of reasonableness and chronology
Issues of referral fees: acquisition of files:

Copley v Stringer 2002
Wollard v Fowler SCCO 05007

Location

Where is the client: local court and hourly rate
Client choice but the test
remains: "was it reasonable; is the work undertaken excessive by reason of the location/choice"?

Wraith v Sheffield Forgemasters 1996 TLR 20

Chappell v De Bora's of Exeter SCCO No. 3 2004

Enhancement

Hourly rates are guide lines
What was unusual CPR 44.5

What additional skills were needed to make the recovery and settlement. What steps did you consider and take at the time (file notes!) to progress the matter
Opposed by Counsel: senior grade of fee earner

Proceedings

Drafting: use of Counsel
Proper notification N252
Timetable: forum: value

Metcalfe v Clipston 2004 EWHC 9005