BARRISTERS TRAINING COURSE

DRAFTING SEM 12:

Sample Request Further Information

IN THE COUNTY COURT AT SHREWSBURY Claim No EYL4634

BETWEEN

MISS REBECCA PETERS

Claimant

and

HOMEWOOD GARDEN CENTRE LIMITED

Defendant

REQUEST FOR FURTHER INFORMATION

UNDER CPR PART 18

This is a request made on 4 January 2021 by the Defendant of the Claimant for further
information and clarification of her Particulars of Claim. The Defendant expects a response
by 25 January 2021.

In relation to paragraph 6 of the Particulars of Claim

Of (a) “four glass panels on the greenhouses were cracked”:

1. Please state precisely:

a) how many of the 4 greenhouses had cracked panels and how many glass panels
per green house were cracked;

b) by way of a sketch plan, the position of the cracked panels;

c) how and on what date(s) the alleged cracks came to the attention of the
Claimant;

And of (b) “the heating systems were defective and incorrectly wired and completely ceased
to function after a few days, …”:

2. Please state with particularity and where appropriate by reference to dates:

a) how many of the 4 greenhouses had defective heating systems;

b) by way of a sketch plan, the position of the defective heating systems;

c) the date(s) upon which each of the heating systems was first used;

d) the date(s) upon which each of the heating systems ceased to function and
how many days after (i) initial supply and (ii) use thereof;

e) Please give full particulars of any expert reports establishing that the heating
systems were defective and incorrectly wired.

© Nottingham Trent University

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 BARRISTERS TRAINING COURSE
DRAFTING SEM 12:
Sample Request Further Information

In relation to paragraph 7 of the particulars of claim

Of “(3) Loss of profit on plants killed or damaged £11,590”

3. Please state with full particularity:

a) by reference to each of the four greenhouses separately, what plants, in

terms of species and quantities, were killed or damaged;

b) how the loss of profit is calculated, the value of the plants before the alleged
damage and the value after the alleged damage and the basis upon which
such values were calculated;

c) whether the alleged loss of profit is based on orders received or whether such
loss is estimated, and;

d) if the alleged loss of profit is estimated, the basis of such estimate;

e) what steps, if any, the Claimant has taken to mitigate her loss, in particular
the exact date(s) upon which repairs to the cracked glass panels and to the
heating systems were (i) requested and (ii) carried out.

MARTHA COSTELLO

Part 18.1===gives the court power to clarify a matter that is in dispute or give further
information whether or not it is in the statement.

Part 18.2== A Request should be concise and strictly confined to matters which are reasonably necessary
and proportionate to enable the first party to prepare his own case or to understand the case he has to meet.
It can also expose the weakness.

Pd 18 1.1==you have to request first and say this is the question we want answer for. If
they refuse, you can apply to court

You cannot ask for evidence in the request for further information

You may ask for further information, but you may not want to when it weaken your case.
E.g., if something is drafted poorly you don’t want to ask for further information which give
them the chance to further strong their case and weaken your case. You can fool them by
their doggedly drafted stamen of case.

© Nottingham Trent University

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