My name is Mark Jameson and I live at 3, Grange Street, Sunderland, SR4 911. I am 23 years old and my date of birth is 6 March 1985. I am currently employed as a part time barman at the Gold Restaurant & Club. My duties involved serving customers, checking stock and clearing up the bar at close of business. My duties require me to stand for the majority of my shift and my salary is approximately £300 per month after tax. My place of work is approximately fifteen minutes walking distance from my home and on 27 June 2008, I decided to stay at work to have some drinks with my colleagues.
[...] Special Damages Loss of Income to Trial: Monthly Income £300 Months Incapacitated: 4 Calculation £300(monthly earnings) x 4(months unable to work) Total net loss of income General damages Pain and Suffering: £4000 Total £4000 OVERALL TOTAL £5200 AND THE CLAIMANT CLAIMS: Damages Interest pursuant to section 35A of the Supreme Court Act 1981. Dated: 3 February 2009 STATEMENT OF TRUTH I believe that the facts stated in these Particulars of Claim are true Signed The Claimant's Solicitors are [name and address] of where they will accept service of proceedings on behalf of the Claimants. BIBLIOGRAPHY Blackstones Civil Practice (2007). Oxford University Press. Brown, K & Catlow, M (2008). Civil Litigation. College of Law Publishing. Kemp and Kemp (Yearly) Quantum of Damages. [...]
[...] A Practical Approach to Civil Procedure 11th Edition Oxford University Publishing Civil Justice Council Report “Calculating Reasonable Success Fees for RTA Claims” at www.costsdebate.civiljusticecouncil.gov.uk/updocs. Lord Woolf, Access to Justice, Final Report to the Lord Chancellor on the Civil Justice System of England and Wales (London HMSO) 1996. Pre-Action Protocol for Personal Injury claims is available at www.justice.gov.uk/civil/procrules Civil Procedure Rules www.justice.gov.uk The Judicial Studies Board Guidelines available at www.jsboard.co.uk Road Traffic Accidents Act 1988 Section of the Road Traffic Accident Act 1988. [...]
[...] the accident, the Defendant has been convicted of a road traffic offence under section 4 of the Road Traffic Accidents Act 1988 for driving or being in charge when under the influence of drink. I have been provided with the incident number, which is 0191565B Since the accident, I have been out of work for four months as a direct result of injuries suffered and wish to make a claim for compensation against the Defendant in respect of my injury and loss of income arising from the accident MEMORANDUM REGARDING APPROPRIATE SUCCESS FEE FOR CONDITIONAL FEE AGREEMENT MEMORANDUM TO: Partner FROM: DATE: 2 February 2009 SUBJECT: Mark Jameson Conditional Fee Agreement This memorandum sets out my advice regarding the determination of a reasonable success fee in the proposed conditional fee agreement for the legal representation of Mark Jameson's claim against the defendant Brian Platt for personal injury and loss of earnings. [...]
[...] Please note that the insurers will need to see this letter as soon as possible and it may affect your insurance cover and/or conduct of any subsequent legal proceedings if you do not send this letter to them. The circumstances of the accident are as follows: The Claimant was walking home from his place of work at approximately 11.55 pm. He was crossing the road on Row Street, at which point your car hit the Claimant, knocking him over. As a direct result of this accident, a nearby resident called an ambulance and the Claimant was kept in hospital for observation for two days, suffering from a broken ankle, two fractured ribs and nervous shock. [...]
[...] Civil Justice Council Report “Calculating Reasonable Success Fees for RTA Claims” at www.costsdebate.civiljusticecouncil.gov.uk/updocs. Lord Woolf, Access to Justice, Final Report to the Lord Chancellor on the Civil Justice System of England and Wales (London HMSO) 1996. Ibid. Civil Justice Council Report “Calculating Reasonable Success Fees for RTA Claims” at www.costsdebate.civiljusticecouncil.gov.uk/updocs Pre-Action Protocol for Personal Injury claims is available at www.justice.gov.uk/civil/procrules . The Pre-Action Protocol requires a letter of claim to be sent to the Defendant before a claim is issued setting out the exact details of a claim, what happened and why fault is alleged. [...]
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