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Very good, Robert. And who will be the first to come up with ".. and your former solicitor failed to argue that as your opponent failed to get his costs schedule in in time he, your former solicitor, was negligent, and in breach of contract, in not taking the point, and he's insured, well he should be anyway, so sue him and his insurers will cough up, they usually do, so as not to set a precedent/can't be bothered to defend/ can no longer find their way around the ever more complex court procedure/ know they will make good their outlay on future PII premiums/can't find their former insured/all of the above..."