07-18-2026, 02:41 PM
The only thing changed by the latest order was the trial date. The original deadline for witness statements and evidence was not expressly varied, which means Gladstones have also failed to comply with it.
The statement you are filing now records that non-compliance and preserves the prejudice caused to you. It is not a substitute for your full substantive witness statement, which we will prepare if the court confirms how it intends to deal with the missed deadline and any late evidence from the Claimant.
Gladstones will probably instruct a hearing advocate who has had little or no involvement in the case before the hearing. Do not accept legal advice from that advocate or become drawn into an informal discussion about the merits. You may listen to any settlement proposal, but you are entitled to say that you will leave the disputed issues for the judge.
You must expressly raise costs at the end of the hearing if you succeed. Prepare and serve a costs schedule in advance. It should include the £123 N244 fee, reasonable travel and parking or public-transport expenses, and any proven loss of earnings or leave for attending the hearing, capped at £95 for the day. You may also seek litigant-in-person preparation costs at £24 per hour under CPR 27.14(2)(g), but those are not automatic: they depend upon persuading the judge that the Claimant’s conduct throughout the proceedings was unreasonable..
Keep a contemporaneous record of the time reasonably spent dealing with the Claimant’s defaults, including the ignored requests for consent, the N244 application, the defective and amended pleadings, and the failure to serve evidence. Do not inflate the hours. A restrained and properly evidenced schedule is more persuasive than an exaggerated one.
The statement you are filing now records that non-compliance and preserves the prejudice caused to you. It is not a substitute for your full substantive witness statement, which we will prepare if the court confirms how it intends to deal with the missed deadline and any late evidence from the Claimant.
Gladstones will probably instruct a hearing advocate who has had little or no involvement in the case before the hearing. Do not accept legal advice from that advocate or become drawn into an informal discussion about the merits. You may listen to any settlement proposal, but you are entitled to say that you will leave the disputed issues for the judge.
You must expressly raise costs at the end of the hearing if you succeed. Prepare and serve a costs schedule in advance. It should include the £123 N244 fee, reasonable travel and parking or public-transport expenses, and any proven loss of earnings or leave for attending the hearing, capped at £95 for the day. You may also seek litigant-in-person preparation costs at £24 per hour under CPR 27.14(2)(g), but those are not automatic: they depend upon persuading the judge that the Claimant’s conduct throughout the proceedings was unreasonable..
Keep a contemporaneous record of the time reasonably spent dealing with the Claimant’s defaults, including the ignored requests for consent, the N244 application, the defective and amended pleadings, and the failure to serve evidence. Do not inflate the hours. A restrained and properly evidenced schedule is more persuasive than an exaggerated one.
Never argue with stupid people. They will drag you down to their level and then beat you with experience. - Mark Twain
