We invite all opponents and parties to adopt this agreement.
In the current situation there will undoubtedly be times where parties to litigation may face some difficulties which wouldn’t be the case but for COVID-19.

I have directed all legal staff at Alison Law Solicitors to be pragmatic and understanding in these circumstances whilst of course protecting our client’s interests. Undoubtedly, the courts would not view uncooperative behaviour in a good light given the difficult times our community is facing.

In line with Government guidance, and to further social distancing, our people at Alison Law Solicitors are working from home wherever possible. This change in working habits requires a change in behaviours and practices both within Alison Law Solicitors and by the legal industry. As such I am writing to you requesting your agreement and co-operation on the matters relating to litigation (in England and Wales):


Our preferred method of written communication is email that has been the case prior to COVID-19 and is even more so in the current situation. If we receive documents by post, that requires more of our people in the office to handle those documents which is contrary to society’s aim in having as many people work from home as possible. It is understandable that some communication may still need to be sent by post.

In the short term, whilst adapting our infrastructure to home working and with a number of our handlers having to work more flexibly since the closure of schools, we would like to reduce the number of incoming calls where possible. I refer you to my previous communication regarding this. E-mail is currently the most effective method of contacting us. If you require a telephone discussion, please email the relevant file handler including a contact number and the most appropriate time to call. We will call you back.

Service of Documents

On-going cases:

We accept service of documents by email. We ask you reciprocate. By doing this, it will enable all to work in the current climate as safely as possible and reduce the need for staff to attend offices to deal with physical post.

If you wish to serve documents electronically in ongoing proceedings, please email them to the file handler directly.

Where serving witness evidence or disclosure documentation – we are happy to agree secure electronic methods of service with you (including password encryption to allow mutually exchange still to take place and safeguard personal data).


New Proceedings:

All new proceedings, we do not accept service by email. These must be served by post. If we are instructed to accept service of proceedings, please ensure that you contact the relevant file handler to confirm which office the proceedings are to be sent to.

Varying the Court Timetable

We make it clear that during these testing times, we do not believe parties to litigation should be seeking to obtain tactical advantage which wouldn’t be the case but for COVID-19. We trust you will adopt a similar sensible approach. We have immediately taken the steps to agree to extend all direction for up to 56 days as long as the trial date is not affected. We ask that you agree and consent to the same.

In the event that either party feels the need to make an opposed application or issue enforcement proceedings as a result of an issue which would not have occurred but for the COVID-19 situation, we request such action is deemed as a last resort and that before that application is made or enforcement action taken, the matter is escalated to a senior partner at each firm.

We nominate Mr Faheem Ali (faheem.ali@alison-law.co.uk) request that you provide your designated escalation point by return.


As the courts are preparing for use of remote hearings, whether by telephone or video conference, we will ensure that our representing counsel will be equally equipped.

It is inevitable that adjournments will be required due to non-availability (or lack of video conferencing facility) of clients, witnesses or experts. We request you take a pragmatic and sensible approach should it be necessary to seek an adjournment. We confirm our handlers will do likewise.


To ensure the effective transfer of funds, whether damages or costs, it will be necessary to utilise BACS payments wherever possible. Again minimising the need for staff to be in the office to handle paper transactions. We therefore request you provide your BACS details by return.

Please do get in touch if you require our BACS details and please ensure you quote our case reference when processing payments.

If you wish to discuss matters further, please do not hesitate to contact me.

Mr Habib Rahman



7 April 2020