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• Multi-Track and Fast Track Litigation in claimant personal injury compensation claims of high value, multiple injury.
• General Civil Litigation dispute areas: boundary disputes and trespass, breach of contract, commercial debt recovery, TOLATA claims and constructive and resultant trusts, defendant personal injury for private defendants.
• Drafting all court documentation: court forms, Particulars, Defences, Schedules, Witness Statements, Application Notices, Case Summaries, Statements of Costs for Summary Assessment.
• Advocacy in interim applications and CMC’s.

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You’re expected capable, as a locum, to parachute into, then take-over, an existing caseload. You have to quickly get a grip on claims at any stage of the dispute process, some pre-action, just starting out, others just weeks away from trial.

I started working as a locum-temp by necessity; keeping my career moving, when my face, and perceived style didn’t fit with the factory-style claims processing injury law firms of the nineties and the noughties. Most of the small firms, desperate to compete but modest on marketing wanted rainmakers, who could bring, or poach a following.

There were a lot of non-qualified claims handlers. Training was limited to procedures necessary to the job process. Too often, the case plan appeared to be to do the basics. Get the medical report, hold out for a settlement offer from the insurance company, and the scramble from there.

Often time had not been taken to take detailed proofs of evidence from clients and witnesses. Rarely did they give me a good reception on being contacted so long after the accident about matters seemingly so vital, even to being assured of their prospects for success at all.

I realised, whilst attending to all of that, and adopted as my strategy in new claims, that front-end preparation in litigation is key. It means arriving at the point of issuing proceedings, or, more expectedly nowadays, going into Dispute Resolution, having already identified the weaknesses of your client’s case; establishing what isn’t likely to be proven from your witnesses alone, and then researching and obtaining such evidence as you gain, to bridge that gap.

Front-loaded preparation, my preferred style, makes the difference between entering a pre-trial conference with Counsel, assured that I’ve done the best by the firm and client; contrast coming away with a shopping list of desperate, late, efforts at backfilling evidence, applications to file supplemental statements, or vary directions.

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