practice direction 18.1

8/19/2019 practice direction 18.1

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To

Defendant

Dear Sirs

Re: Claimant ’ s full name

Claimant ’ s full address

Claimant ’ s I.D. Number

Claimant ’ s Date of Birth

Claimant ’ s Clock or Works Number

Claimant ’ s Emlo!er "name and address#

We are instructed b! the abo$e named to claim dama%es in connection &ith an

accident at work / road traffic accident / tripping accident on at " place

of accident which must be sufficiently detailed to establish location#.

'lease confirm the identit! of the insurers. 'lease note that the insurers &ill

need to see this letter as soon as ossible and it ma! affect !our insurance co$er if !ou

do not send this to them.

The circumstances of the accident are:

"brief outline#

The reason &h! &e are alle%in% fault is:

" simple explanation e.g. defective machine, broken ground, ignoring traffic

lights; excess speed, etc.#

( descrition of our clients’ in)uries is as follo&s:

"brief outline#

or as aears from medical reort"s# b! treatment hositals * clinics attached hereto.

+e &as rior to the accident emlo!ed as "occupation# and has been %ranted

sick lea$e on the follo&in% dates:

Durin% the ,- months reaccident his a$era%e monthl! income &as "amount #.

+e has * has not returned to &ork since the accident &orkin% as "occupation# and

earnin% "amount # a month.

The accident did * did not occur in the course of emlo!ment. * /ur client has

brou%ht Emlo!ees’ Comensation roceedin%s in the District Court under DCEC

No. of .

'a%e , of (endi0 (

Appendix A



If you are our client’s employers, please provide us with the usual earnings

details gross and net for the 1 months prior to accident which will enable us to

calculate his financial loss.

We enclose co! documents on Schedule ( attached rele$ant to issues of

liabilit! and 1uantum.

We ha$e also sent a letter of claim to "name and address# and a co! of that

letter is attached. We understand their insurers are "name, address and claims number

if known#.

2(t this sta%e of our en1uiries &e &ould e0ect the follo&in% documents to be

rele$ant to our client’s claim and re1uest that !ou ro$ide coies to us &ithin

one month. "insert as aroriate from Schedule B#3

2We &ould ad$ise our client to enter into ne%otiations for settlement at this

sta%e b! all suitable means &hether b! &a! of &ithout re)udice ne%otiations and * or other mode"s# of (DR.3

( co! of this letter is attached for !ou to send to !our insurers. 4inall!5 &e

e0ect a constructi$e rel! to this letter &ithin one month b! !oursel$es or !our

insurers5 failin% &hich &e shall forth&ith commence roceedin%s.

6ours faithfull!

'a%e - of (endi0 (



Schedule (

Claimant’s Documents

Road Traffic (ccident Cases

,. 'olice Witness Statements

-. 'olice Sketch 'lan

7. 'hotoco! 'olice hotos

8. Brief 4acts of Case

9. edical reorts

;. Income roof < reasonabl! sufficient roof b! either a! slis5 statement"s#

obtained from his emlo!er"s# or bank account * other records. "refer to

ara%rah ;;"-# and "7# of 'ractice Direction ,=.,#

>. Ta0 returns lod%ed &ith the Inland Re$enue Deartment b! the claimant and hisemlo!er"s#5 and his /RS/ and * or '4 statements "refer to ara%rah ;;"-#

and "7# of 'ractice Direction ,=.,#

=. Co! Identit! Card "for roof of a%e#

?. edical and other e0ense receits

Industrial (ccident Cases

,. 4orm - Notice of (ccident

-. @abour Deartment Witness Statements

7. @abour Deartment (ccident Reort

8. 4orm 95 4orm > and 4orm ?9. edical reorts

;. Income roof < reasonabl! sufficient roof b! either a! slis5 statement"s#

obtained from his emlo!er"s# or bank account * other records. "refer to

ara%rah ;;"-# and "7# of 'ractice Direction ,=.,#

>. Ta0 returns lod%ed &ith the Inland Re$enue Deartment b! the claimant and his

emlo!er"s#5 and his /RS/ and * or '4 statements "refer to ara%rah ;;"-#

and "7# of 'ractice Direction ,=.,#

=. Co! Identit! Card "for roof of a%e#

?. edical and other e0ense receits

4or other cases5 documents of similar nature %i$in% similar information as

aroriate.

'a%e 7 of (endi0 (



Schedule B

'roosed Defendant’s Documents

Road Traffic (ccident Cases

,. 'olice Witness Statements

-. 'olice Sketch 'lan

7. 'hotoco! 'olice hotos

8. Brief 4acts of Case

9. a%istrates Notes of 'roceedin%s

;. edical reorts

Industrial (ccident Cases

,. 4orm -

-. (ccident Reort

7. @abour Deartment Witness Statements

8. @abour Deartment (ccident Reort

9. 4orm 95 4orm > and 4orm ?

;. edical reorts

>. Income roof of the 'laintiff < a! slis5 ta0 returns5 /RS/ or '4 statements

"see ara%rah ;>"8#5 "9#5 "># of 'ractice Direction ,=.,#

=. Sick lea$e certificates

?. Summar! * records of Emlo!ees’ Comensation aid * ad$ance a!ments

4or other cases5 documents of similar nature %i$in% similar information as

aroriate.

'a%e 8 of (endi0 (