Q: As a favour to good client, I have issued a small debt claim for £120.

The defence is an obvious time-spinner: 'I cannot trace this bill.' The court demands an £80 fee to allocate the claim.

Is there any way my client can escape having to pay?A: The fee is payable by the claimant on filing of the allocation questionnaire or, if the questionnaire is dispensed with, on the claim being allocated.

Try a letter to the court manager asking for the file to be shown to a district judge so as to determine whether the so-called defence should have been treated as a defence.

Quite possibly, the district judge will strike it out.

That would mean no fee would be payable and you should be able to request judgment (unless, of course, the defendant files a defence of substance).

In a less obvious case, you could apply for summary judgment, before filing the allocation questionnaire.

The fee payable is £25 if you mark the application notice to the effect that a hearing is not required: otherwise, £50 has to be found.

Note, however, that if the application fails and the claim is then allocated to a track, that £80 fee will have to be paid in addition.Q: My local county court is forever redrafting perfectly well-drawn orders - even consent orders - which my firm produces.

Why? What can I do about it?A: Part of the problem lies in the fact that court staff are working with a computer system which assumes that solicitors and judges will follow the standard wording to be found in the appendix to CPR PD28.

When formulating orders, district judges themselves are working to tick-box forms which follow that standard appendix.

This makes life easier for the staff who do not have to type out every order, word for word.

So when the judge is asked to approve a draft consent order, he will try to ensure it follows the format of the tick box forms.

We suggest you adopt the tick box forms yourself to avoid this endless reworking of what you have sent in.

There is nothing secret about them.

Next time you are before the district judge, ask for a set of the forms and copy them around the office.

And have another look at the PD28 appendix.

A lot of time was spent drafting the standard orders to be found there and you would be well advised to follow them.Q: The county court I normally use is notoriously slow in dealing with paperwork.

I am repeatedly getting orders which require me to take steps in a case the deadlines for which have passed or are imminent by the time they have arrived on my desk.

What action do you suggest?A: CPR r 2.9(2) requires c alendar dates to be inserted in court orders, wherever practicable.

Gone is the old habit of ordering steps to be taken 'within 14 days' or whatever.

Have a word with the district judge.

It may be possible for the problem to be overcome by the judge when drafting the order to provide for action within, say, X days of service of the order, leaving it to the staff to insert the correct date when the order is produced.

Another is for you to offer to draw orders up yourself, in appropriate cases.

If, alas, the problem persists, then write to the court manger each time asking for the district judge to review the order and give more realistic dates.Q: I have agreed the terms of an order with my opponent including the exact amount of costs one side is to pay to the other.

But the court will not agree the costs.

Surely this is unreasonable?A: This raises the very difficult issue of proportionality.

Hopefully, benchmark costs will be issued under the auspices of the Supreme Court Costs Office quite soon which will set out the 'normal' costs appropriate for particular steps in a claim, Until then, costs have to be assessed at large, or agreed.

We are surprised that your district judge is not approving the costs which you have agreed.

If the figures suggested are sensible, then the court should allow them.

The problem comes when the amount of costs concerned does not seem to be proportionate to the value of the claim or the work likely to have been done.

Generally, though, district judges do not intervene unless the figure is so much out of line that it cannot be 'nodded through'.

If you have agreed a figure which you think your judge may consider too high, you can always back up the draft order with a letter explaining why the agreed costs are as they are.

In the lower value claims, explain why, say, a lot of time has been spent on just one discrete aspect of the case.

Deal with the question of proportionality.Q: My client, who is just financially outside the legal aid scheme, is one of two defendants.

The claim has been allocated to the multi-track but the amount claimed is modest.

A case management conference has been fixed but the court is miles from my practice.

The expense of attending would be disproportionate.

Can I instruct a local agent or write in?A: If you can agree directions (subject to the court's approval) and explain the circumstances, the procedural judge may well excuse your attendance in a straightforward case.

However, if the court is minded to dispose of issues etcetera (see CPR r 3.1(2)), your client may be prejudiced by your absence.

Instructing a fully briefed agent is better than nothing, but why not ask the court to conduct the conference by telephone or at least allow your participation by telephone? Generally, procedural judges will be sympathetic.

They have been surprised by the low level of demand for this facility.

Guidance on telephone applications given in the CPR Part 23 PD will be helpful but the restrictions set out there on the use of the procedure do not apply to case management conferences or prevent the procedural judge from applying the overriding objective to the conduct of the hearing.

Conference call arrangements must be made in advance so that the court can ensure the judge has a suitable telephone.

A conference call will not be needed if only one party wishes to participate by telephone.Q: What can I do to try and ensure a realistic timetable is imposed at a multi-track case management conference?A: We suggest that before the conference you get an idea from the court diary manager of wha t trial window is likely to be available.

You can then invite the procedural judge to work backwards from that.

If the trial is not to be for, say, 12 months then a pre-trial review ten months away would be sensible and perhaps four or five months could be allowed for exchange of the experts' reports rather than the 14 weeks suggested at CPR PD28 para 3.12.

But if a realistic timetable is set at the outset, the procedural judge will be much less inclined to vary it at a later date.

'Milestone dates' - such as those set for a pre-trial review of for a trial - cannot be varied without a court order, which may be very difficult to obtain.