A defence is filed and the Court decides that the matter sho…
A defence is filed and the Court decides that the matter should continue to trial. The parties complete their Directions Questionnaires and these are filed with the Court. The first court direction deals with disclosure and inspection of documents. You write to your client explaining the duty of disclosure and your client then faxes you a list of all the documents which it has in relation to this matter. This is below. a) Attendance Note of telephone conversation between Bill Waters and Sarah Gilly dated 11 November 2020. b) Hand written notes taken by Bill Waters at his meeting with Sarah Gilly on 14 November 2020. c) Letter from Bill Waters to Sarah Gilly dated 21 November 2020 proposing a further meeting on 2 December 2020. d) Minutes of meeting marked WITHOUT PREJUDICE between Bill Waters and Sarah Gilly dated 2 December 2020. e) Copy of Purchase Order signed by Bill Waters dated 2 December 2020. f) THL bank transfer receipt (value of £200,000 to MDL) dated 13 December 2020. g) Report of Mr Fowler, Metallurgy Expert, dated 17 December 2020, commissioned by THL. h) The draft witness statement amended by Bill Waters. i) Attendance Note taken by Bill Waters of a telephone conversation with Mark Jones of your firm discussing the legal and factual issues of the dispute with MDL. j) Letter from your firm to the defendant marked WITHOUT PREJUDICE, containing an offer to settle during the pre-action stage. Please explain which of the documents must be disclosed as part of standard disclosure, which documents will be privileged and, if applicable, what type of privilege will apply to the document. You must give reasons for your answer.