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May wish to include names of witnesses. This is a tactical decision, do you want to let on you know these witnesses?
If you don't need to plead something to satisfy the cause of action/defence, it's likely evidence
? 'The claimant is required to prove all of the allegations set out in the particulars of claim save those that have been expressly admitted above.' Causation The Claimants are required to prove that they have suffered the alleged or any loss and damage, and it is denied that any loss and damage suffered by the Claimants was caused by the matters complained of. If, which the Claimants are required to prove, XYZ, this is the result of the Claimant's failure ...
MitigationCan't just say they didn't mitigate their loss, have to state what steps they should have taken but did not
Further or alternatively, if, which is denied, the Claimant(s) have suffered loss as a result of the matters complained of, they failed to take reasonable steps to mitigate such loss by: (a) XYA; and/or (b) ABC. Prayer AND the First Defendant counterclaims: Ending?
Don't actually sign your name A. COUNSEL
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