As there is a limited period of no more than seven months (30 weeks) in which to prepare the case for trial, claimants are advised to ensure that their cases are in an advanced state of preparation before they issue proceedings, to ensure that they do not fall behind schedule once the timetable starts running.

Claimants Should:

• Fully comply with any pre-action protocol.
• Ensure they have the disclosable documents for disclosure.
• Have identified and traced witnesses, and prepared drafted witness statements.
• Obtained expert evidence that might be necessary, including identifying possible experts, and seeking agreement with prospective defendants for the joint instruction of experts.

Defendants Should:

• Fully comply with any relevant pre-action protocol.
• Have available all disclosable documents.
• Obtained drafted statements from witnesses.
• Seek to reach agreement on the joint instruction of experts

Given the limited costs recovery for trial costs on the fast track, always consider settlement at an early stage and revisit this throughout the case.

There are limitations in costs recovery on the fast track due to fixed fast track trial costs. Always consider whether the amount in dispute justifies the expense of starting proceedings or defending a claim, given the likely costs recovery.

Altion Law can consider agreeing fixed fees for specific elements of work, such as drafting the particulars of claim or defence or drafting witness statements.