John Pugh's Chambers
3 Shrewsbury Road
CH43 1UU

Specialist in consumer credit litigation

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John Pugh LLB (Hons)

Eileen Ashton JP LLB (Hons)
Practice Manager

Suzanne Thomas


This can only be generalised, depending on the type of case but there are some documents which are always needed which are set out below. Please send hard copies by post.

The Agreement

Whatever the agreement is, send a legible copy of it especially including any terms and conditions on the back of it. If there are any documents or terms and conditions which are referred to in the agreement please send those as well. If you have been provided with a brochure or booklet or any quotation or estimate please include that or the relevant parts of it.

If there are any related agreements send copies of them. E.G. In PPI claims please send a copy of the policy or policy summary.  In h.p. cases please send a copy of the original sale agreement and any part exchange agreement as well as the finance agreement. 

Account Documents

Any Statements of Account (in consumer credit work), invoices or statements (in Debt recovery work) or evidence of cost or expense (In Damages Claims).  In short documentary proof of what has been paid and what is owed.


All correspondence concerning or connected with the dispute including any relevant e-mails.

Court Documents

If your case has started, please include copies of the claim (including particulars of claim), defence, any reply or further information, any applications or witness statements. If the case has been allocated a copy of the allocation questionnaire. If it has been listed a copy of the listing questionnaire. It is vital you send copies of all court Orders which have been made and any Judgment which has been entered.

Your Instructions

You must send us a signed statement setting out what your case is and what your evidence is.  If the other side has provided you with any statement then supply us with a paragraph by paragraph commentary on it, admitting what you do not dispute and denying what you disagree with and stating the reasons for your disagreement.

Statements from Witnesses

If you rely on witness evidence (apart from your own evidence) send a copy of a statement from the witness setting out that to which he can attest. If you do not have a statement say what you believe the witness will say.


Please do not send original documents.  Please be aware that we cannot return documents sent to us (The Public Access Regulations Requires us to keep them).

Your Details

Your full name and full home address with post code and a contract telephone number and the e-mail address to which you wish any documents to be sent.

What you want us to do

We are not solicitors, so we cannot take over the conduct of your case.  We can advise. If you want written advice or if you want advice across a table in conference in Chambers in Liverpool, please state clearly what you wish us to advise upon. 

If you wish us to draft a document or documents (e.g. a Claim or a Defence) please identify the document you wish us to draft for you. Only use us for key documents, i.e. important documents you cannot draft yourself. 

If you wish us to appear at a hearing or conduct a telephone hearing for you please state the date of the hearing and the court where it is to be heard.

Please be aware that we can not undertake urgent work with no or little notice.  The sooner in your dispute you instruct us the better. If we accept your instructions we will cope with emergencies or deadlines which were previously notified to us. 

If we cannot meet your stated deadlines we will aim to decline your instructions within 3 working days so that you are not delayed in instructing another barrister. 




Tel: 0151 236 5415        Email:        DX 14182 Liverpool 1