Dispute Resolution

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Commercial litigation
Our firm has an extensive experience and background dealing with all types of commercial dispute.
Our firm is accredited with Higher Rights of Audience, which means that we are able to implement the right planning of action at the very start and represent you at all hearings.
All cases need to be established as a matter of fact and law and this requires consideration of the issues surrounding the case.
We deal with all commercial disputes e.g. company, business, banking, shareholder, partnership, consumer, retailer and professional disputes.
Legal costs vary on case by case basis, but can provide costing after initial consultation – Terms and conditions apply.
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Property litigation
We also have vast experience dealing with property disputes and these sort of cases require careful planning.
Disputes regarding properties can involve neighbours and/or their land boundaries; mortgagors who have security on property and require possession; equity claim against share of property for contribution(s) made; insurance etc.
If you are in a dispute concerning your property, then we are able to assist.
Legal costs vary on case by case basis, but can provide costing after initial consultation – Terms and conditions apply.
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Debt
If you or your company/business are in debt we can provide advice as to best way forward .
We can discuss matters with you to establish some clarity.
We can advise on debt consolidation, bankruptcy and insolvency.
Debt Recovery
We also advise creditors with regard to recovering debt from an individual or corporate entity.
Legal costs vary on case by case basis, but can provide costing after initial consultation – Terms and conditions apply.
OUR FIRM’S COSTS AND GENERAL DISBURSEMENTS
We charge £250.00 (plus VAT, £50.00) for the first initial consultation, details of which were provided to you when your appointment was made to attend our offices. No advice will be provided in writing. We charge an additional £150.00 (plus VAT, £30.00) for receiving the advice provided during your consultation in writing.
If we are instructed further we estimate the following costs:
i. Our firm’s costs to be between £1,500.00 (plus VAT, £300.00) and £3,000.00 (plus VAT, £600.00) concerning debt of up to £10,000.00.
ii. Our firm’s costs to be between £3,000.00 (plus VAT, £600.00) and £7,500.00 (plus VAT, £1,500.00) concerning debt between £10,001.00 to £25,000.00.
iii. Our firm’s costs to be between £7,500.00 (plus VAT, £1,500.00) and £20,000.00 (plus VAT, £4,000.00) concerning debt between £25,001.00 to £50,000.00.
iv. Our firm’s costs to be between £20,000.00 (plus VAT, £4,000.00) and £35,000.00 (plus VAT, £7,000.00) concerning debt between £50,000.00 to £100,000.00.
v. Our firm’s costs to be between £35,000.00 (plus VAT, £7,000.00) to £75,000.00 (plus VAT, £15,000.00) concerning debt in excess of £100,000.00.
vi. Disbursement such as court fees (No VAT payable on court fees), expert’s fees (VAT may be applicable) other than Counsels fees can vary and depend on your matter. If you are a creditor and wish to issue proceedings for recovery of debt you can obtain up to date information from www.gov.uk. Disbursements can range between £250.00 to 20,000.00 (plus VAT if applicable as stated, not VAT on court fees).
vii. Counsel’s fees can vary depending on how senior Counsel is and legal issues. The following is an illustrative guide with regard to Counsels fees, taking into account the amount of debt defended or claimed:
– Debt amount up to £10,000.00: between £1,500.00 (plus VAT, £300.00) and £3,000.00 (plus VAT, £600.00).
– Debt amount up to £25,000.00: between £3,000.00 (plus VAT, £600.00) and £5,000.00 (plus VAT, £1,000.00).
– Debt amount up to £50,000.00: between £5,000.00 (plus VAT, £1,000.00) and £7,500.00 (plus VAT, £1,500.00).
– Debt amount up to £100,000.00: between £7,500.00 (plus VAT, £1,500.00) and £10,00.00 (plus VAT, £2,000.00).
– Debt amount in excess of £100,000: between £10,000.00 and £15,000.00 (excluding VAT)
The above are estimates and can vary on a case by case basis and certainly how the case may progress.
Work carried out on your matter by our firm’s Mr Andreou will be based on the hourly rate of the caseworker at £250.00 per hour (plus VAT, £50.00), letters sent are charged at £25.00 per letter (plus VAT, £5.00) telephone calls no more than 6 minutes are charged at £25.00 per telephone call (plus VAT, £5.00) and letters received charged at £12.50 per letter (plus VAT, £2.50) .
Work carried out on your matter by our firm’s Solicitor will be based on the hourly rate of £160.00 per hour (plus VAT, £32.00), letters sent are charged at £16.00 per letter (plus VAT, £3.20), telephone calls no more than 6 minutes are charged at £16.00 per telephone call (plus VAT, £3.20) and letters received charged at £8.00 per letter (plus VAT, £1.60).
Work carried out on your matter by our firm’s Paralegals/Trainee solicitors based on the hourly rate of £120.00 per hour (plus VAT, £24.00), letters sent are charged at £12.00 per letter (plus VAT, £2.40), telephone calls no more than 6 minutes are charged at £12.00 per telephone call (plus VAT, £2.40) and letters received charged at £6.00 per letter (plus VAT, £1.20).
If this firm does not complete the work or the matter becomes abortive (for any reason whatsoever) we will charge you an abortive fee based on our hourly rate. The abortive fee will be equivalent to the work carried out by us but will not exceed the estimated quotation above.
In the event that this matter becomes unduly protracted we shall inform you of any cost changes at the appropriate time.
SERVICES INCLUDED
1. Pre-Action Phase
Initial Consultation & Documentation Review
– Take detailed instructions on the debt (terms, agreements, invoices, correspondence).
– Verify debt validity, including contractual terms, statutes of limitation, and any disputes.
– Assess debtor’s solvency (searches at Companies House/land registry for corporates; credit checks for individuals).
Demand Letters & Negotiation
– Draft and send a Letter Before Action (LBA) compliant with the Pre-Action Protocol for Debt Claims.
– Allow a reasonable period (typically 14–30 days) for response/payment.
– Engage in settlement negotiations (e.g., payment plans, lump-sum offers).
2. Court Proceedings (If Unpaid)
Issuing the Claim
– Draft and file the Claim Form (N1) and Particulars of Claim.
– Serve the claim via the debtor’s preferred method (or court service if disputed).
– Pay applicable court fees (recoverable from the debtor if successful).
Judgment in Default
– If no Acknowledgment of Service (N9) or Defence is filed within 14 days (individuals) or 28 days (corporates):
– Apply to the court for Default Judgment (N205/N225).
– Serve the judgment on the debtor with a final payment demand.
Contested Claims
i. Defence Filed Allocation Questionnaire
– File a Reply to Defence (if required) to counter the debtor’s arguments.
– Complete the Allocation Questionnaire (N150) to assign the case to the appropriate track:
ii. Case Management Conference (CMC)
– Purpose: Set deadlines, identify issues, and approve expert evidence.
– Submit Directions Questionnaire (proposed timeline for evidence, disclosure, trial).
– Argue for/against interim applications (e.g., strike out, summary judgment).
– Address expert witness requests (court approval required for most debt cases) (if applicable).
iii. Disclosure & Evidence Exchange
– Standard Disclosure: Both parties share relevant documents (contracts, emails, payment records).
– Witness Statements: Submit signed statements from key parties (e.g., creditor’s account manager).
– Expert Evidence (Rare in debt cases, but may apply for e.g. forensic accounting):
– Court must approve use of experts.
– Joint experts often ordered to save costs.
iv. Trial Preparation & Hearing
– Pre-Trial Review (PTR): Finalise trial logistics (if case is multi-track).
ADDTIONAL WORK NOT INCLUDED IN THE ABOVE PRICE
Interim Applications (If Required)
Common applications during contested claims:
– Summary Judgment (CPR Part 24): Argue the debtor has no real prospect of success.
– Strike Out Application: Challenge deficient defences (e.g., no legal basis).
– Security for Costs: Demand the debtor pays funds into court (if insolvency risk exists).
We will need to quote separately for interim applications, but based on previous cases we estimate our firm’s costs, disbursements and Counsels fee could range as follows:
– Our firm’s costs between £10,000.00 (plus VAT, £2,000.00) to £15,000.00 (plus VAT, £3,000.00)
– Disbursements such as court fee no more than £500.00 (VAT not applicable).
– Disbursement such as enquiry agent no more than £2,500.00 (plus VAT, £500.00 if the agent changes VAT).
– Counsels fees between £2,500.00 (plus VAT, £500.00) to £5,000.00 (plus VAT, £1,000.00).
Enforcement Advice & Action and Post Enforcement
– If payment is not received within 21 days, recommend and initiate enforcement options:
– Writ/Warrant of Control (Bailiffs to seize goods).
– Third-Party Debt Order (Freeze debtor’s bank account).
– Charging Order (Secure debt against property for individuals/land for corporates).
– Attachment of Earnings (For employed individuals).
– Insolvency Proceedings (Statutory demand, winding-up petition for corporates; bankruptcy for individuals).
– Monitor payments and close the file upon full recovery.
– Advise on partial recovery scenarios or uncollectible debts (e.g., insolvent debtors).
We will need to quote separately for enforcement but based on previous cases we estimate our firm’s costs, disbursements and Counsels fee could range as follows:
– Our firm’s costs between £10,000.00 (plus VAT, £2,000.00) to £15,000.00 (plus VAT, £3,000.00)
– Disbursements such as court fee no more than £500.00 (VAT not applicable).
– Disbursement such as enquiry agent no more than £2,500.00 (plus VAT, £500.00 if the agent changes VAT).
– Counsels fees between £2,500.00 (plus VAT, £500.00) to £5,000.00 (plus VAT, £1,000.00).
Additional Services
– Insolvency Support
– Draft Statutory Demands (for debts over £5k).
– File Winding-Up Petitions (for corporates) or Bankruptcy Petitions** (for individuals).
– Cross-Border Recovery
– Enforce UK judgments in foreign jurisdictions (via EU/International enforcement regimes).
– Asset Tracing
– Investigate hidden assets (e.g., offshore accounts, nominee holdings).
We will need to quote separately for enforcement but based on previous cases we estimate our firm’s costs, disbursements and Counsels fee could range as follows:
– Our firm’s costs between £10,000.00 (plus VAT, £2,000.00) to £20,000.00 (plus VAT, £4,000.00)
– Disbursements such as court fee no more than £2,500.00 (VAT not applicable).
– Disbursement such as enquiry agent no more than £2,500.00 (plus VAT, £500.00 if the agent changes VAT).
– Counsels fees between £2,500.00 (plus VAT, £500.00) to £5,000.00 (plus VAT, £1,000.00).
OUR STAFF
Work on your matter may be done by a mix of Solicitor(s), Paralegal(s), Trainee(s) and experienced staff. Xen Andreou, solicitor since November 2003 and sole principal of this firm. Xen will have overall conduct and supervision of your matter who has had extensive experience in litigation matters and is a Higher Rights Advocate. Please see our team: Team – Proctor Moore SolicitorsProctor Moore Solicitors
TIMESCALE
The likely time scale for your matter is made in consideration of the issues known to the caseworker. We also make comparisons to other cases of similar issues, however generally litigation can take between 8 – 24 months to resolve, depending on the issues, the court listing and whether or not the matter settles before trial.
Although we endeavour to provide you with a realistic time scale this is an estimate and can change. If we anticipate a change we shall let you know in writing. There are many factors out of our control but we assure you that we will try to resolve your matter as quickly as possible.
It is due process for you to enter into a retainer with our firm and further terms and conditions will apply, details of which will be included in a client care letter provided to you at the outset.
Note: We can provide you with the above information in another format, and you can request this by emailing info@proctormoore.com or telephone 02083643111.
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Money
If you are owed money for service/goods rendered then we are happy to provide case plan to recover that money for you.
If you owe the money, we can advise as to what your rights are in relation to that claim.
We provide service for both debtor and creditor.
Legal costs vary on case by case basis, but can provide costing after initial consultation – Terms and conditions apply.
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Injunction
There are certain situations in litigation whereby an injunction is required and this can relate to money, property or a person.
A person may owe you money and you are aware that he/she has an asset to which they are attempting to dispose in order to avoid paying you. The term for this is a “freezing injunction”.
If you feel intimidated by a person’s conduct you can apply to court for injunction under the Protection from Harassment Act 1997.
We can assess your needs and advise accordingly.
Legal costs vary on case by case basis, but can provide costing after initial consultation – Terms and conditions apply.