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Stephen Turner v Coupland Cavendish Limited

[2023] EWHC 2721 (SCCO)
The claimant wanted recordings of calls, answers to questions about money, and a company number. The judge said he hadn't followed the right rules and didn't have enough evidence to prove his case, so he didn't get any of it.

Key Facts

  • Six detailed assessment cases under the Solicitors Act 1974 were heard consecutively.
  • The hearings were adjourned due to insufficient time estimates and complex disputes.
  • Three preliminary applications were heard in the case of Turner, impacting other cases.
  • Mr. Turner sought assessment of a bill from Coupland Cavendish Ltd.
  • Disputes arose regarding disclosure, Part 18 requests, and information about a Gibraltar company (AJG Limited).

Legal Principles

Disclosure of documents mentioned in statements of case, witness statements, etc.

CPR 31.14

Specific disclosure requires a formal application with evidence (PD 31A, paragraph 5.1).

Practice Direction 31A, paragraph 5.1

Court's case management powers (CPR Part 3) can supplement Part 31 in Solicitors Act assessments (Edwards v Slater and Gordon).

Edwards v Slater and Gordon

Proportionate approach to disclosure; court considers the ease of retrieval and relevance (PD 31A, paragraph 5.4).

Practice Direction 31A, paragraph 5.4

He who asserts must prove; claimants must provide evidence to support their claims.

Brown v JMW Solicitors

A principal is entitled to access to their agent's records unless expressly excluded (Yasuda Fire and Marine Insurance Co v Orion Marine Insurance Underwriting Agency Ltd).

Yasuda Fire and Marine Insurance Co v Orion Marine Insurance Underwriting Agency Ltd

ATE premiums are not part of the solicitor's bill but are in the client's cash account; disputes about the cash account can lead to questions about ATE insurance and commissions (Herbert v HH Law).

Herbert v HH Law

Solicitors must notify clients of any interest (including commission) in recommending ATE insurance (Tankard v John Fredericks Plastics).

Tankard v John Fredericks Plastics

CPR Part 1: overriding objective of dealing with the case justly and at proportionate cost.

CPR Part 1

Outcomes

Refusal of the claimant's application for disclosure of call recordings.

Procedural irregularity (lack of formal application and evidence); claimant failed to demonstrate relevance to their case.

Refusal of the claimant's application for Part 18 requests.

Lack of evidence to support the allegations of undisclosed commissions; procedural irregularity (no Part 18 requests before the court).

Refusal of the claimant's application for the Gibraltar company number.

Information readily obtainable elsewhere; disproportionate cost and effort.

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