Timetabling Questionnaire to be filed after close of pleadings

 

A	Mediation
A1	Have you filed and served any Mediation Certificate? □ Yes          □ No
A2	Have the parties attempted mediation so far? □ Yes          □ No
A3	Do you have intention to settle this case by mediation? □ Yes          □ No (go to B1)
A4	If the answer to A3 is “yes”, when do you think you will have enough materials to participate in a meaningful mediation? □ Now □ After discovery □ After exchange of witness statements □ After filing of experts’ reports □ After obtaining counsel’s advice on merits □ Others: _____________________
A5	Do you seek for a stay of proceedings to attempt mediation? □ Yes, for ______ weeks          □ No
B	Parties
B1	Do you intend to add another party to this case?
	□	Yes, I will apply on or before ______________ to add ____________________ as a [Plaintiff / Defendant / Third Party / _______________]*
	□	No
C	Pleadings
C1	Do you intend to amend your pleadings?
	□    □	Yes, I will apply on or before __________ to amend ____________________ No
C2	Do you intend to take out a summons for Further and Better Particulars?
	□	Yes, I will make an application for Further and Better Particulars in respect of _______________________ on or before ______________
	□	No
C3	Is there any outstanding request(s) received from the other party for Further and Better Particulars of any of your pleadings? □ Yes          □ No (go to D1)
C4	If the answer to C3 is “yes”, do you intend to give any answer thereto?
	□	Yes, I will give an answer in relation to [all the requests / requests No.____________]* on or before ________________
	□	No
D	Related Proceedings
D1	Are there any proceedings pending in any Court and/or any Tribunal involving the same parties herein / related parties? □     Yes, the other case number(s) is/are: ___________________________________ □     No (go to E1)
D2	If the answer to D1 is “yes”, should those proceedings be consolidated with this action or tried with the present action before the same Judge?
	□	Yes, a court order has been made already
	□	Yes, I will take out a summons and make an application on or before __________________
	□	Yes, I will apply to transfer case No._____________________________ to the Court on or before _________________
	□	No, because _____________________________________________________
E	Split trial
E1	Do you intend to apply for split trial in this case? □     Yes, I will do so on or before ________________ □     No
F	Evidence
F1	Have you served any list of documents?
	□	Yes
	□	No, I intend to serve my list of documents on or before _________________ (go to F3)
	□	No, I do not have any document to disclose (go to F3)
F2	If the answer to F1 is “yes”, do you intend to serve any supplemental list of documents?
	□	Yes, I intend to do so on or before __________________
	□	No
F3	Do you intend to call any witnesses of fact including yourself at the trial?
	□	Yes, I need _____ days [after the filing and/or exchange of list of documents / _____________]* to file/serve/exchange the statements of the following witnesses:
	□	Yes, I have filed/served/exchanged all witness statements
	□	No
G	Expert evidence on liability
G1	Do you intend to adduce expert evidence on liability at the trial?
	□	Yes, I will apply for leave to adduce expert evidence on liability at the trial on or before ____________________
	□	Yes, expert directions have been given by ____________________________ on ________________ (go to G5)
	□	No (go to H1)
G2	I intend to adduce evidence from ___ expert(s) on liability as follows:
	Expert’s name                                         Field of Expertise
G3	The precise issue(s) to be addressed by the experts on liability is/are:
G4	Do you agree to appoint a single joint expert?   □     Yes.  The name of the proposed single joint expert is ______________________ □     No, because _______________________________________________________
G5	When can your expert complete his expert report? □     _____ days from [today / date of expert directions / ______________]* □     The report has already been done pursuant to the court’s direction
G6	Is there any need to have examination or inspection by the experts? □ Yes          □ No (go to G8)
G7	If the answer to G6 is “yes”, do you agree to arrange a joint examination or inspection by the experts of each of the parties?
	□	Yes, a joint examination or inspection of ________________ by experts of each of the parties [was held / is to be held]* on _________________
	□	Yes.  However, no arrangement has been made for any joint examination or inspection of ________________ by experts yet.  I suggest that such joint examination or inspection be held within ____ days from [today / ___________________]*
	□	No, because _____________________________________________________
G8	Do you agree to have a joint report by experts of each of the parties?
	□	Yes, I suggest that the experts do attend a “without prejudice” meeting within _____ days [after the exchange of their respective expert’s reports / from ___________________________]*, and that they complete the joint report within _____ days thereafter
	□	Yes, the joint report [has already been prepared / will be completed by the experts by ______________]*
	□	No, because _____________________________________________________
H	Expert evidence on quantum
H1	Do you intend to adduce expert evidence on quantum at the trial?
	□	Yes, I will apply for leave to adduce expert evidence on quantum at the trial on or before ____________________
	□	Yes, expert directions have been given by ____________________________ on __________________ (go to H5)
	□	No (go to I1)
H2	I intend to adduce evidence from ___ expert(s) on quantum as follows:
	Expert’s name                                         Field of Expertise
H3	The precise issue(s) to be addressed by the experts on quantum is/are:
H4	Do you agree to appoint a single joint expert? □     Yes.  The name of the proposed single joint expert is ______________________ □     No, because _______________________________________________________
H5	When can your expert complete his expert’s report? □     _____ days from [today / date of expert directions / ______________]* □     The report has already been done pursuant to the court’s direction
H6	Is there any need to have examination or inspection by the experts? □ Yes          □ No (go to H8)
H7	If the answer to H6 is “yes”, do you agree to arrange a joint examination or inspection by the experts of each of the parties?
	□	Yes, a joint examination or inspection of ________________ by experts of each of the parties [was held / is to be held]* on ______________
	□	Yes.  However, no arrangement has been made for any joint examination or inspection of ________________ by experts yet.  I suggest that such joint examination or inspection be held within ____ days from [today / ___________________]*
	□	No, because ____________________________________________________
H8	Do you agree to have a joint report by experts of each of the parties?
	□	Yes, I suggest that the experts do attend a “without prejudice” meeting within _____ days [after the exchange of their respective expert’s reports / from __________________________]*, and that they complete the joint report within _____ days thereafter
	□	Yes, the joint report [has already been prepared / will be completed by the experts by ______________]*
	□	No, because _____________________________________________________
I	Interlocutory Applications
I1	Do you intend to apply for security for costs? □     Yes, and I will make an application on or before ________________  □     No
I2	Are there any other interlocutory applications that you intend to make which have not been mentioned in this questionnaire (for example, summary judgment, specific discovery, etc.)?
	□	Yes, I will make an application for ________________________________ on or before __________________
	□	No
I3	Have you made/brought any other interlocutory application(s) or appeal(s) which has/have not been disposed of by the court?
	□	Yes, the application(s)/appeal(s) for ________________________________ which was/were taken out on ______________will be [heard by the court on ___________________ / fixed to be heard]*
	□	No
I4	Are there any outstanding directions which are yet to be complied with by you?
	□	Yes, the following directions have not yet been complied with: _______________________________________________________________ , and I expect to comply with the above directions on or before ________________
	□	No
I5	Are there any outstanding directions which are yet to be complied with by the other parties?
	□	Yes, the ________________ has not yet complied with the following directions: _______________________________________________________________
	□	No
J	Case Management Conference / Pre-Trial Review / Trial Date
J1	Do you request to have a Case Management Conference date fixed? □ Yes          □ No
J2	Do you request to have a trial date / trial period fixed at the forthcoming Case Management Summons hearing?  □ Yes          □ No
J3	Do you request to have a Pre-Trial Review before the trial? □ Yes          □ No
K	Long Cases
K1	Do you estimate that the trial of the present case will last for 15 days or more?  □ Yes          □ No (go to L1)
K2	If the answer to K1 is “yes”, have you made any application to have the matter assigned to a trial judge?
	□	Yes, the case has been assigned to _______________
	□	Yes, but the case has not been assigned to any judge
	□	No, I will make an application on or before ___________________
L	Proposed Directions
L1	Have you attached any proposed directions to this questionnaire/ filed a consent summons?
	□	Yes, I have attached proposed directions herewith
	□	Yes, consent summons has been filed on __________________
	□	No, but I agree with the directions proposed by ______________
	□	No proposed directions or consent summons has been attached/filed as I am not legally represented.
M	Other matters
M1	Set out any other information you consider will help the court in case management.
N	Brief Factual Background and Issues
N1	You are required to attach with this questionnaire a one-page summary of the brief factual background of this case and the issue(s) to be tried.  Have you done so?  □ Yes          □ No
O	Declaration
Signed:				Date:

 

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