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F E Smith
F E Smith, Advocate
Category: Law
Satisfied Customers: 10395
Experience:  I have been practising for 30 years.
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I received a defence from one of the 3 defendants that I

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I received a defence from one of the 3 defendants that I served a claim on. The defence is full of lies, that I can prove they are as wrong. Do I reply? Or do I wait until the CMC meeting as bring it up with the master? If so do I serve it all the other defendants and do I include evidence?

You would normally reply to the defence in a timely fashion without actually waiting for the CMC and you would address each point in detail.

You would either admit each of the points or deny each of the points or neither admit nor deny/have no knowledge, and qualify each of the answers saying exactly why. Usually, if you are admitting any of the points made, there is no need to qualify.

Send a copy of your reply to the defence to the defendant solicitors and also to the court.

Can I clarify anything for you?

Please don’t forget to rate the service positive. It’s an important part of the process by which experts get paid.

Best wishes.


F E Smith and other Law Specialists are ready to help you
Customer: replied 1 year ago.

It could take up to couple of hours in all probability. I would submit this is separate proposal for you which is called a Premium Service.

You have to bear in mind that we don’t know all the facts here and hence, we could really only comment on the layout rather than the actual content although we could stop you tripping yourself up.

What you do, is put your reply headed Reply to Defence and all the rest of the layout including the paragraph numbering just like the defence.

I will submit a premium services proposal for you. The difficulty I have is time because I am extremely busy now until Monday. It depends whether that timescale is okay for you. Obviously it’s going to take you some time to put the document together and what you don’t want to do with that is rush. Normally, I would suggest that you take a couple of days yourself doing it so the timescale might not be a problem. You only got this document in the last day or so so I imagine there is no rush.

Best wishes

Customer: replied 1 year ago.
I want to go ahead with your offer. I have to get some money on my card 1st to pay you. can I start this with you on Friday?
Customer: replied 1 year ago.
I mean start on Monday or Tueday.

Yes thats fine. Accept the proposal. Then do your bit. Then send it over. As soon as you accept the proposal we can exchange email addys

Customer: replied 1 year ago.
I will accept tomorrow when I have the funds.

No problem at all. Whenever you are ready. It can wait till the weekend if you wish. Kind regards

F E Smith and other Law Specialists are ready to help you
Customer: replied 1 year ago.
I got the response from the defendant last week 17th June. Do you think two weeks is a in a timely fashion?
Customer: replied 1 year ago.
HiCustomerI have finished my reply to the defence. I accepted your offer for £79.00 to check it. How do I contact you to send it to you tomorrow. Can I have an email address for you?

I have just sent you my private email.

Customer: replied 1 year ago.
Hi FE,
Hope you had a nice weekend. What address did you send your email address to? I cant see it on***@******.***

I have sent you my Private email contact details. I sent you my email contact details not an email itself.

You need to reply to that.

As you have now posted your private email, I will now email you. You should have it now.