All changeIt is not just a change of name that translates 'pleadings' under the old rules into 'statements of case' under the new Civil Procedure Rules 1998 (CPR).

It is part of the whole culture change.

As always, the starting point is part one, the over-riding objective.

In actively managing cases the procedural judge needs to be able to identify the issues at an early stage, decide which of them justify the time and expense of a trial and be able to give directions to ensure that the trial of a case proceeds promptly and efficiently.The new culture operates even before the issue of proceedings.

Most readers will be now be familiar with the pre-action protocols.

But tucked away in the practice direction on pre-action protocols is an interesting paragraph 4 which says that even in cases not covered by a protocol the court will expect the parties to act reasonably in exchanging information and documents relevant to the claim and generally in trying to avoid the necessity for the start of proceedings.At the starting gateThere is nothing to be gained by tortuous statements of case which leave everyone, the judge included, bewildered as to what the drafter of the document actually meant, or the typical defence which says nothing bar a few denials.

It also means that solicitors have nothing to fear by preparing their own statements of case.

If they just tell the client's story, in simple words, then is it necessary in the run-of-the-mill type of case to incur the expense and delay of getting counsel to draft the statements of case?What is a statement of case?Part 2 defines a statement of case as a claim form, particulars of claim -- where they are not on the claim form itself -- defence, reply, part 20 claim and additional information given under rule 18.1.Statement of valueEvery claim form or (if necessary) a separate particulars of claim must have one.

Without it everyone is guessing the appropriate track for the case.

There is no set form for the statement.

The standard type of 'goods sold and delivered' endorsement on a summons now would suffice.

But if solicitors are acting for the defendant in, say, a personal injury case and think that the claimant's solicitors are over-egging the claim, then they should say so in the defence.

If the £50,000 claim is only worth £10,000 -- and should be in the fast track -- then they should say why in the defence.

If they do not, can they then complain when the allocation is to the wrong track? Yes is the simple answer, but it is not too difficult to guess who will pay the costs of the application to put matters right.Statement of truthRead part 22.

Every statement of case and every witness statement must have one.

Every application notice ought ideally to be verified by a statement of truth as well.

It means the advocate can then rely on what is in the application notice as evidence (see [1999], Gazette, 3 March, 35 ).

Where possible use the new style N244; the supporting evidence and the statement of truth go straight onto the reverse side of the form, so there is no need for a separate witness statement.

The practice direction supplementing part 22 sets out the wording and who can sign the statement.Solicitors should always give themselves time for their clients to sign the statement of truth.

A solicitor can -- as now -- sign the statement on the client's behalf but not before the requirements of practice direction 22, paragraph 3.7 and 3.8 have been followed.

As the consequence -- for the client, not the solicitor- of signing off a statement of case verified by a statement of truth without an honest belief in its truth is civil contempt it will be a brave solicitor indeed who assumes that responsibility for his client without putting the document to his client to check.How much time have I got?Basically, for filing a defence, 14 days from date of service.

That can be extended to 28 days if an acknowledgement of service form is filed and to a maximum of 56 days with the consent of the claimant.

Need any more time than that and the defendant's solicitor will have to apply to the court.

However, note that where a defendant files a counterclaim along with his defence then the claimant has only 14 days to file a defence to counterclaim -- as well as return the allocation questionnaire.

The period can be extended (as above) but the penalty for not filing a defence to counterclaim will be a default judgment on the counterclaim.Can I amend?Of course a claim form, defence or whatever can be amended.

The fact that the first version of the document has a statement of truth attached to it does not mean it is written in tablets of stone.

The important point is that the client must honestly have thought he had his statement right when he first signed it.

Part 17 of the CPR deals with amendments.Once served, either the consent of the parties or the permission of the court is needed to amend a statement of case.

The interesting departure from present practice is that it will no longer be necessary in the amended text also to set out the original text being amended.

If there is a particular reason for the court to be able to trace through all the amendments -- for instance, an argument regarding costs thrown away in a heavy chancery case -- then a statement can be prepared using the black, red, green, violet and yellow colouring (in that order) familiar to the present day.

However, the computer-literate may prefer to use the simpler 'numeric code in a monochrome computer-generated document', as happens now in the commercial court.

But in the normal case in future the amended statement of case will be typed entirely in black.The defencePart 16 and its accompanying practice direction must be read by anyone drafting a defence for the first time under the CPR.

For instance, if an allegation in the particulars of claim is denied then the defence has to say why and state the defendant's case if a different version of events is being put forward.

Or consider a medical report: if a defendant does not agree the claimant's report -- put to one side any protocol considerations -- the defence actually has to give reasons for doing so.And reply?A change to existing county court -- but not High Court -- practice is to provide formally for a reply to a defence.

It is not necessary to file one but (see r 16.7) anything not formally admitted in the reply will have to be proved by the defendant, with possible costs consequences.Strike it out?No longer w ill the court tolerate a bare denial; file one and the court will strike it out of its own initiative.

All statements of case are to be subject to much more judicial scrutiny, at a much earlier stage in the proceedings, than has ever been the case before, save for small claims.Tell me moreRequests for further and better particulars and interrogatories are now merged into a very simple part 18 of the CPR which requires a party to give such clarification of any matter in dispute or to give such additional information as the court may order.

The detail is in the accompanying practice direction.

Any application to the court must be preceded by a written request for the additional information or clarification.

The actual request may in future be down the left hand side of each sheet of paper, enabling the person responding to put the answers on the right hand side, with obvious savings in costs.