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  • APIL Model Letters for Personal Injury Lawyers

APIL Model Letters for Personal Injury Lawyers


A comprehensive collection of letters for use by all claimant PI lawyers

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These letters provide a comprehensive work flow system to guide the reader through all the stages of a personal injury claim, from initial instructions through to resolution of the claim. The letters are also designed to deal with many of the practical problems that can arise in the conduct of a personal injury claim taking account of the requirements of the pre-action Protocol, the Civil Procedure Rules and relevant case-law. The letters ensure the claim is progressed and issues relating to liability, quantum and general tactics are dealt with effectively whilst keeping the client fully advised throughout.

 This edition has been extensively revised and updated and takes on board significant changes to the conditional fee regime and the referral fee code, the introduction of predictable costs, the new rules on pre-action admissions and part 36, as well as important new case-law.

 All major areas of PI practice are covered and are grouped within the following categories:
  • Client care
  • Initial Steps and the Pre-action Protocol
  • Evidence
  • Quantum
  • Proceedings
  • Trial
  • Appeals
 APIL Model Letters for Personal Injury Lawyers also comes complete with a CD-ROM containing all the letters from the book for you to use and adapt to your needs.

10% discount for APIL Members, to take advantage of this offer please call Customer Services on +44 (0)330 161 1234.

Client Care and Instructions

  • Initial Letters
  • Client Care Letters
  • Authorities and Confirmation of Instructions

Initial Investigations

  • Client Statement
  • Witnesses
  • Police
  • Health and Safety Executive
  • Photographs
  • Other Enquiries
  • Advising the Client

Medical Evidence

  • Advising the Client and Getting Medical Re cords
  • Instructions to Medical Expert
  • Appointment with Medical Expert
  • Receipt of Medical Re port

Expenses and Losses

  • Earnings Details
  • Tax and NI Re cords
  • The Schedule
  • Compensation recovery

The Protocol and Liability

  • Preliminaries: Disease and Illness
  • Letter of Claim
  • Acknowledgment and decision on liability
  • Documents
  • Failure to comply with the protocol
  • Further defendants
  • Motor Insurers' Bureau

Negotiation and Quantum

  • Advising on Quantum
  • Disclosure of Information on Quantum
  • Advising on ADR
  • Acknowledging and Advising on Offers
  • Making Offers
  • Withdrawing/Changing Offer

Stocktake Prior to Issue of Proceedings

  • Stocktake
  • Pre-Action Applications

Issue and Service of Proceedings

  • Issue
  • Service

The Defence

  • Acknowledgment of Service and Extension of Time
  • Receipt and Review of Defence

Allocation and Case Management

  • Allocation Questionnaires
  • Initial Case Management


  • Disclosure by the Claimant
  • Disclosure by the Defendant
  • Disclosure by Other Parties
  • Inspection of Documents
  • Videos

Exchange of Factual Evidence

  • Preparing for Exchange of Witness Statements
  • Dealing With Exchange of Witness Statements

Exchange of Expert Evidence

  • Request by the Defendant for Facilities to Obtain Expert Evidence
  • Dealing With Exchange of Evidence
  • Questions to Claimant's Experts
  • Questions to Defendant's Experts
  • Joint Statements

Applications and Enforcement of Case Management Directions

  • Non-compliance with Case Management Directions
  • Issue and Service of Application Notice
  • Telephone Hearings
  • Hearing of Application Notice

Interim Payments

Review of Quantum

Listing and Further Case Management


  • Review and Advice on Evidence
  • Trial Date
  • Witness Orders
  • Bundles of Documents
  • Final Checks
  • Following Trial

Settlement and Final Reports

  • Acceptance of Offers
  • Judgment After Acceptance of Part 36 Offer
  • Implementing Settlement
  • Final Reports


"this publication will save practitioners an enormous amount of time ... a useful learning tool for newer entrants to PI practice. Well worth buying."
APIL Newsletter

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