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Ash, Solicitor
Category: Law
Satisfied Customers: 10916
Experience:  Solicitor with 5+ years experience
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For Alex W. The defendants solicitors are asking me to

Resolved Question:

For Alex W.
The defendants solicitors are asking me to disclose the complete file of my conveyancers (I do not have it and cannot obtain it) the solicitors in question went out of business some years back. They are also requesting the 'file' re my mortgage application/offer/and correspondence, again I have limited paperwork as it relates back nearly 7 years. How long should the paperwork be kept? I have moved and paperwork has been lost/disposed of. They wish me to delay the pre trial hearing because they do not have their witness statements ready and are blaming it on my 'late disclosure'. I sent my list on time but they told me i could not include 'privileged' paperwork so i resubmitted a revised copy to the courts and the solicitors. Does the original SDL date count or the revised date? I am desperate to go to trial as soon as possible.
Submitted: 3 years ago.
Category: Law
Expert:  Ash replied 3 years ago.

Alex Watts :

Hello my name is XXXXX XXXXX I will help you with this. Please note that I am a working Solicitor and may be on and offline as I have to attend Court and meet with clients, even at weekends. As such you may not get an instant response when you reply, but rest assured I will be giving your question my immediate attention upon return You do not need to wait here as you will get an email when I reply.

Alex Watts :

You are not a business so you don't actually have to keep paperwork at all.

Alex Watts :

If it was a business it would be different

Alex Watts :

But an individual you do not have to keep anything.

Alex Watts :

If they can't comply with Court directions THEY must make an application, not you.

Alex Watts :

You can refuse to accept and cite the case of Mitchell

Alex Watts :

The original date for disclosure counts UNLESS the court has ordered otherwise

Alex Watts :

Can I clarify anything


Ask Alex:


Is this suitable form for a core bundle index

In the Brighton County Court Claim No: 3HM00399

1 Orders from Horsham County Court

2 to 3 Orders from Brighton County Court

4 Claim Form/Witness Statement, In the Horsham County Court (SD5 included))

5 to 9 Notice seeking possession of a property. SD 1

10 to 18 Defence and Counterclaim SD 2

19 to 25 Defence form SD 3

26 to 31 Reply to Defence and Counterclaim SD 4

32 to 34 Witness Statement XXXXX XXXXX Claimant SD 6

35 to 41 Witness Statement of Mr Jon Smith SD 80

42 to 46 Standard Disclosure List (Defendant's)

47 to 49 Standard Disclosure List (Claimants')


50 – 53 Copies of Power of Attorney SDL 7.

54 – 58 Copies from Sellers Conveyancer SDL 8, 9, 10, 11, 12 & 13

59 Letter JV to BD SDL 14

60 Sellers Property Information Form SDL 15

61 Replies to Completion Information …... SDL 16

62 Letter JV to BD dated 6/11/2007 SDL17

63 Application to change Register AP1 SD 18

64 – 65 Letters from DB to BD SD 19

66 – 72 Assured Shorthold Tenancy Agreement SD 20

73 Second Tenancy Agreement SD 21

74 Land Registry Title SD 22


75 Letter DB to CF 27/02/2010 SD 23

76 Letter DB to MS 01/03/2010 SD 24

77 & 78 Letter SG to DB 18/06/201 SD 25

79 Letter DB to SG 22/06/2010 SD 26

80 Statement DB to Horsham CC 06/07/2010 SD 27

81 - 92 Statements from CF, MF & MS to Horsham CC SD 28

93 Invoice Southern Counties Glass 17/11/2008 SD 29

94 & 95 Letter SG to DB 05/08/2010 SD 30

96 Email response DB to SG 06/08/2010 SD 31

97 Letter SG to DB 06/08 2010 SD 32

98 Letter DB to CF 03/10/2010 SD 33

99 & 100 Letter MS to DB 27/10/2010 & 30/10/2010 SD 34

101 Letter DB to CF 02/11/2010 SD 35

102 Letter DB to CF 09/11/2010 SD 36

103 General Form of Judgement 22/01/2011 SD 37

104 Notification CF Bankruptcy Order 02/02/2011 SD 38

105 & 106 Notice of Application to register restriction SD 39

107 Letter DB to CB (HDC) 21/02/2011 SD 40

108 Letter DB to MS giving notice SD 41

109 & 110 Letter PJ to CG (estate agent) 24/03/2011 SD 42

111 Letter DB to PJ 28/03/2011 SD 43

112 Invoice No IN5572 Little Peeps Party Shop SD 44

113 & 114 Letter PJ to DB 29/03/11 SD 45
115 & 118 Letter JS to PJ re. Defamation & PJ response SD 46

119 & 120 Letter DB to PJ 31/03/2011 SD 47

121 Letter on behalf of PJ to DB 07/04/2011 SD 48

122 Letter DB to PJ 08/04/2011 SD 49

123 Letter DB to PJ 27/04/2011 SD 50

124 Letter CC to PJ 17/08/2011 SD 51

125 Letter CC to PJ 02/05 2012 SD 52


126 Letter BD to CF 07/08/2013 SD 53

127 – 145 Transcript of video recordings SD 54

146 – 150 Photographs from 59 Hill Mead 30/07/2013 SD 55

151 - 153 Letter JS to Dr. D 13/08/13 SD 56

154 DB to GL re Tenancy Agreement 14/08/2013 SD 57

155 & 156 Letter PJ to DB 07/09/2013 SD 58

157 & 158 Letter DB to MS 07/09/13 SD 59

159 Letter DB to GL 08/09/13 SD 60

160 Letter CC to PJ 17/09/2013 SD 61

161 – 171 Letter DB to PJ SD 62

172 Letter SR (CQC) to DB 25/09/2013 SD63

173 Letter SR(CQC) to DB 20/12/2013 SD 64

174 Letter DB to PJ 18/10/2013 SD 65

175 Letter PJ to DB 18/10/13 SD 66

176 Letter JS to GL 30/10/2013 SD 67

177 & 178 Letters JS & DB to PJ 03/11/2013 SD 68

179 Letter DB to PJ 11/11/2013 SD 69
180 Letter DB to PJ 14/11/2013 SD 70

181 & 182 Letter PJ to DB & JS 15/11/2013 SD 71

183 – 188 Letter DB & JS to MS via PJ 17/11/2013 SD 72

189 & 190 Letter PJ to DB & JS 29/11/2013 SD 73

191 - 193 Letter DB to PJ 30/11/2013 SD 74

194 Letter DB to PJ & GL 06/12/2013 SD 75

195 & 196 Letter PJ to Go Law 09/12/2013 SD 76

197 Letter DB to PJ (via Go Law) 31/01/2014 SD 77

198 Letter DB to HM (HDCSS) 13/03/2014 SD 78

199 Letter HM (HDCSS) to DB 17/03/2014 SD 79

at as core trial bundle index?

Alex Watts : Yes that is fine
Alex Watts : You also want to include all court orders too
Alex Watts :

If this answers your question could I invite you leave feedback on my service which I hope has been excellent today, if you need more information or help then please click reply.

Please remember that I am always happy to help if you have future questions, even if I am in Court I can normally respond within a few hours. For future information, please start them with ‘For Alex W’.


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for Alex W . We have had to vacate the PTR and the trial window. The next (earliest) date would be more than 6 months time. As I cannot wait I have decided to drop the case. Am I liable for the other sides costs or any court costs?

Alex Watts :

If you drop it - yes

Alex Watts :

That is the Court rule - unless they agree otherwise


They were not trial ready either, does that make a difference? and made mistakes on their STD list, which they have admitted to. I believe they deliberately delayed knowing my financial circumstances.

Alex Watts :

If you drop it then you are liable for costs. You could have refused to vacate it and ask that the Judge strike out their claim


If I don't drop it will will


the costs just continue to escalate?

Alex Watts :

They could. But if you drop it you are liable for costs anyway

Alex Watts :

Of course if you win then they wouldnt get costs anyway


True, thanks for your input, you are my saviour at the moment!

Alex Watts :

No problem

Alex Watts :

Please remember to leave feedback before you go today


Will do.

Alex Watts :


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