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JGM
JGM, Solicitor
Category: Scots Law
Satisfied Customers: 12535
Experience:  30 years as a practising solicitor.
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Thanks so much for your help. i have managed to get the

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Dear Sir,
Thanks so much for your help. i have managed to get the witness on 20th February 2018, i have few more questions if you could also help in them, i have attached my initial writ, adjusted defence, my minute of amendment and his answers lastly defender's list of witness. There is one name John O'Donnell and according to my enquirers i can confirm he is Tax matters expert in accountancy matters based in eastkilbride now:
1. As the defender did not mention any thing in adjusted defense or in answers to minute of amendment about John O'Donnell, could he be a witness in this case, if no then
2. could i move a motion asking court to exclude john O'Donnell from witness list of defender.
3. one of the witness in the defenders list is Defender himself,Zulfiqar Hussain. what could he be witness for?
4. Can i include myself in witness list as well.
5. Could you please also advise what will be the last date for me to provide all productions?
6. i have already provided list of my witnesses, could i add or remove any witness at this stage?Please give a detailed answer as my case is fixed for proof on 12 of March.
Regards

You have asked for a lot of things here. This will take some time to look at. I will need to send you a premium service request to cover the cost.

JGM and 3 other Scots Law Specialists are ready to help you
Customer: replied 5 months ago.
Could you please reduce the price i am litterly out of pocket just now, really struggling to get this continued. Please also advice if any other point comes in your mind
Customer: replied 5 months ago.
Could you plz bring price down to 160. Please

I’ll be back to you as soon as I’ve looked at this.

See attached and revert if you have any further queries.

Customer: replied 5 months ago.
thanks for detailed reply, I have one question the last answer to minute of amendment I received is attached here, I wont to know should we adjust it and new minute of amendment or as you said a general denial should cover it, if I don't adjust it now what impact of it I could have at the day of proof and if we adjust minute of amendment just now will the date of proof be changed to allow defender more time to adjust his pleadings or proof will be held on 12 March no matter whatever we do now about adjustment. what do you think should we leave it as it is?In Point number 5 of your reply you pointed out that you presume there is an amended record in in process? my question is who will that be preparing amended record. is it court or is it anything which i have to do.
Customer: replied 5 months ago.
I am trying to attach file but system is not letting me I already have sent you answer to minute of amendment in my separate question see you could get that one

What does the last interlocutor say. There would normally be a Rule 18.3 Hearing following an amendment procedure? Has there been such a hearing. You should be answering the averments in the Answers by adjusting your Minute of Amendment. It depends where you are in the procedure. As regards ***** ***** it is for the Pursuer to prepare these.

Customer: replied 5 months ago.
could you help me in preparing that record or give me idea so I could prepare it,
I send you last interlocutors copy

I would need word versions of all the pleadings and you would have to start a new question as this would be a premium service.

Customer: replied 5 months ago.
I have attached last 4 interlocutors please check if it was Rule 18.3 hearing, shall we do adjustment at this occasion or what will be the best course of action at this point.
Customer: replied 5 months ago.
I will start new question answer for Records so you could offer a premier offer but please considering my current situation give reasonable price. thanks
Customer: replied 5 months ago.
I am still waiting on an answer