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A standard comment will now be inserted in all third party clinical negligence correspondence.

'Our client is taking the following steps...

because of the following reasons...

If any action is unnecessary please confirm this immediately so we may avoid the incurring of any unnecessary costs. If an action is subsequently deemed unnecessary we will be seeking the costs in any event, without regard to proportionality, because you failed to make any attempt to narrow the issues so as to avoid disproportionate costs.'

Notices to Admit will be running rampant throughout every claim as will Part 36s. A Part 36 on liability can be made in every letter of claim and off we go!

All crazy of course, but what can you do when a little old lady might die 1 week after a botched op (PSLA of £2k plus funeral costs, say £7k all in), yet a Precedent H might run to £100k inclusive of experts and Counsel.