Party lodging information sheet:
Name(s) of legal representative(s)
Name(s) of individual legal representative(s) for trial:
(1) Approximately how many documents and how many pages of documents do you intend to produce on standard production of documents?
(2) How do you intend to produce documents to the other parties under RDC 28.6? (For example by hard copy or electronically.)
(3) By what date can you provide standard production of documents?
(4) Please estimate the legal costs associated with standard production of documents.
(5) Have the parties discussed standard production of documents? In particular, have the parties discussed the production of electronic documents? If so, please provide a
summary of material areas of agreement and disagreement between the parties.
(6) Is production of specific documents likely to be required on any issue? If so, please give as much detail as is currently available.
(7) Have the parties discussed likely or potential requests for production of specific documents? In particular, have the parties discussed requests to produce electronic documents? If so, please provide a summary of material areas of agreement and disagreement between the parties.
(8) Are amendments to or is information about any
statement of case required? If yes, please give brief details of what is required.
(9) Can you make any additional admissions? If yes, please give brief details of the additional admissions.
(10) Are any of the issues in the case suitable for trial as preliminary issues?
(11)
(a) On the evidence of how many witnesses of fact do you intend to rely at trial (subject to the directions of the
Court)? Please give their names, or explain why this is not being done.
(b) By what date can you serve signed witness statements?
(c) How many of these witnesses of fact do you intend to call to give oral evidence at trial (subject to the directions of the Court)? Please give their names, or explain why this is not being done.
(d) Will interpreters be required for any witness?
(e) Do you wish any witness to give oral evidence by video link? Please give his or her name, or explain why this is not being done. Please state the country and city from which the witness will be asked to give evidence by video link.
(12)
(a) On what issues may expert evidence be required?
(b) Is this a case in which the use of a Court-appointed expert (see Rule 31.29) or an
assessor (see Rule 31 Part II) might be suitable?
(c) On the evidence of how many expert witnesses do you intend to rely at trial (subject to the directions of the Court)? Please give their names, or explain why this is not being done. Please identify each expert’s field of expertise.
(d) By what date can you serve signed expert reports?
(e) When will the experts be available for a meeting or meetings of experts?
(f) How many of these expert witnesses do you intend to call to give oral evidence at trial (subject to the directions of the Court)? Please give their names, or explain why this is not being done.
(g) Will interpreters be required for any expert witness?
(h) Do you wish any expert witness to give oral evidence by video link? Please give his or her name, or explain why this is not being done. Please state the country and city from which the witness will be asked to give evidence by video link.
(i) Do you consider it appropriate for Concurrent Expert Evidence (as explained in Practice Direction No. 1 of 2013) to be applied in this case? If not, please state why you think not.
(13) What are the trial advocates’ present provisional estimates of the minimum and maximum lengths of the trial?
(14) What is the earliest date by which you believe you can be ready for trial?
(15) Is this a case in which a Pre-Trial Review is likely to be useful?
(16) Is there any way in which the Court can assist the parties to resolve their dispute or particular issues in it without the need for a trial or a full trial?
(17)
(a) Might some form of
justice by reconciliation procedure assist to resolve or narrow the dispute or particular issues in it?
(b) Has the question at (a) been considered between the client and legal representatives (including those to appear at trial)?
(c) Has the question at (a) been explored with the other parties in the case?
(d) Do you request that the case is adjourned while the parties try to settle the case by justice by reconciliation or other means?
(e) Would an order for justice by reconciliation in the form of the Schedule to Part 27 be appropriate?
(f) Are any other special directions needed to allow for justice by reconciliation?
(18) What other applications will you wish to make at the Case Management Conference?
(19) Does provision need to be made in the pre-trial timetable for any application or procedural step not otherwise dealt with above? If yes, please specify the application or procedural step.
(20) Are there, or are there likely in due course to be, any related proceedings? Please give brief details.
Rights of Audience
(21) Do any of the parties’ legal representatives intend to request the Court to waive or vary any limitation on their right to appear before the Court? If so, please identify the limitation and the reasons relied upon.
(22) Has the legal representative’s client consented to the making of the request?
(23) Does the legal representative practice with a legal
practitioner already holding full rights of audience before the Court? If so, please identify the
Practitioner. Has the Practitioner agreed to provide appropriate guidance to the legal representative if such guidance is requested?
(24) Does the legal representative agree that in the event of their request being granted, they will be bound by, and conduct themselves during the proceedings in full accordance with, the requirements of the Code of Conduct for Legal
Practitioners in the
DIFC Courts?
[Signature of legal representative(s)]
Note: This information sheet must be lodged with the Registry at least 7 days before the Case Management Conference (with a copy to all other parties).