I thought that it was not possible to change the statement after exchange date as set by the tribunal? Also, I do not want to give the respondent a reason to also change their statements.
So, would you advice changing the last paragraph and would this mean that the respondent would also feel free to change their own statements (I would not be happy about this)? The respondent did later agree to allow a separate mitigation statement to explain loss of earnings also which can be altered up to the hearing date. Is it worth deleting the whole last chapter and stating 'please refer to mitigation statement'?
Sorry to keep asking, but I want to be absolutely clear on this. If I delete the last paragraph of the witness statement which relates to mitigation, would this give the Respondent the right to change their own witness statements?
Thanks. I was thinking that myself - I just needed an expert opinion to confirm. I can explain any changes to the Schedule of Loss in my mitigation statement anyway.
Sorry - forgot to ask:
Should I be concerned that the statements submitted by the respondent when we exchanged via email were not signed or dated? The reason given by the respondent's solicitor was that they did not have time to do this by the given exchange date.