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A part of the problem it seems to me is that a lot of claimants' solicitors expect matters will settle and jog along exchanging letters in the hope that an offer will be forthcoming. Insurers know this, well some anyway, especially the less ethical ones, assuming the word ethical has any place here, and play along in the hope that a limitation period will expire. Claimants' lawyers should get all their evidence together as earl;y as possible and, subject to protocol compliance then issue and serve and keep at the defence issuing "unless" applications and asking for costs payable immediately orders each time, every time 14 days elapse with nothing happening. The other side will soon get the message.

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