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Litigation Strategy: Beautiful Carbon Ltd v Shutter-Ways Ltd
Instructions
This is a litigation task, please help to find the best strategy.
This should be from the position of an applicant in a summary judgment and it will be good to find the best strategy to make the applicant position clear
This is based on UK law, please use appropriate legislation, case law, CPR rules etc. and the own documents (e.g. witness statement) and for example the Sale of Goods Act etc.
1. You are the applicant
2. The other part will be sitting as a judge.
3. You must behave at all times as an advocate in a court of law.
4. Please remember that Professional Conduct is pervasive and that points of Professional Conduct can arise.
5. Your submission are 10 minutes.
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Or you can divide the Task in:
– Introduction and Chronology
– Substantive Legal Issues and CPR Rules
– Relevant Facts Agreed and in Dispute (Witness statements etc.)
– Procedural Issues / Procedures
– Possible Judgements and Costs
– Conclusions
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Statement of agreed facts for Applicant and Respondent
The Claimant is Beautiful Carbon Ltd. The Defendant is Shutter-Ways Ltd. The parties are in a dispute regarding the supply and installation of a heavy duty steel roller shutter door by the Defendant at the Claimant’s premises.
Proceedings have been issued and served. The Defendant served a Defence. The Claimant has issued an application for summary judgment. The Defendant’s solicitors have filed a witness statement opposing the application.
The hearing has an agreed time estimate of 20 minutes.
The parties have exchanged summary statements of costs and have agreed a sum of
£1,500 should any order for costs be made.
Please assume for the purpose of that hearing is taking place on Wednesday, 18 August 2021 at 10.00am.
The Claimant is represented by ULaws LLP and the Defendant is represented by Swallows & Co.
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Please Note:
(1) The letter before claim, claim form, acknowledgment of service form, draft order and summary statements of costs are not provided. You may assume that these documents are irrelevant to this application.
Claim Number: HQ21 4859
IN THE HIGH COURT OF JUSTICE QUEEN’S BENCH DIVISION
Birmingham District Registry BETWEEN:
Beautiful Carbon Ltd and
Shutter-Ways Ltd
Claimant
Defendant
PARTICULARS OF CLAIM
1. At all material times the Claimant was a retailer, manufacturer and importer of jewellery and the Defendant was a manufacturer, retailer and installer of security shutters and doors.
2. On 15 January 2021 at approximately 12.00pm, Tommy Linn (“Mr Linn”), acting for the Claimant, spoke on the telephone to Juris Petersons (“Mr Petersons”) acting on behalf of the Defendant. Mr Linn entered into a contract with the Defendant through Mr Petersons, for the Defendant to supply and install at the Claimant’s premises in Birmingham a 7 metre (high) by 4 metre (wide), electrically powered, heavy duty steel roller shutter door that met the LPS1175 security specification (“the Shutter”) for the price of £40,000 inclusive of VAT (“the Contract”).
3. In that telephone conversation and before placing the order, Mr Linn described the site at which the Shutter was to be installed as the garage and security door at the back entrance to the Claimant’s retail, storage and manufacturing hub at Vyse Street, Birmingham. Mr Petersons confirmed that the Shutter would be electrically powered and have an anti-drop safety brake. He then gave Mr Linn an Order No. of 21-0115-2 and the Contract was concluded.
4. The Contract included implied terms that the Shutter would be of satisfactory quality; reasonably fit for its specified purpose as a garage and security door; and installed with reasonable care and skill.
5. The Claimant paid the contract price of £40,000 to the Defendant on 22 January 2021 and in purported performance of the Contract the Defendant’s workmen installed the Shutter at the Claimant’s premises on 12 March 2021.
6. In breach of the implied terms of the Contract the Shutter was not of satisfactory quality and not reasonably fit for its specified purpose as the garage and security door at the back entrance to the Claimant’s retail, storage and manufacturing hub. Further and in the alternative the Shutter was not installed with reasonable care and skill.
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PARTICULARS OF BREACH
6.1 On 19 May 2021 at 09.30am, the Shutter’s counterbalanced spring (“the Spring”) failed in operation as it was insecurely attached to the spring housing.
6.2 Following the failure set out in paragraph 6.1 above, the anti-drop safety brake of the Shutter operated, but when the weight of the Shutter was placed upon it the brake’s flange broke, as it was of inadequate strength to take the weight of the Shutter.
6.3 The assembly and installation of the Shutter, in particular the Spring, was carried out without reasonable care and skill, in that the bolt that attached the Spring to its housing was damaged and cross threaded such that the nut could not be fully tightened and the Spring securely attached to its housing.
7. As a consequence of the breaches of the implied terms, the Shutter fell in an uncontrolled manner onto a car owned by the Claimant, which was damaged beyond repair. The Shutter required immediate emergency repairs to secure the Claimant’s premises. The Shutter was later fully repaired and rebuilt to ensure future safe use.
8. By reason of the above the Claimant has suffered loss and damage.
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PARTICULARS OF LOSS AND DAMAGE
Brand new – purchased 1 May 2021
Mercedes S Class Coupe AMG S65
(incl Night package) – written off 186,675.00
(less scrap value – estimated) (10,000.00)
Emergency Repairs to Shutter (incl VAT) 5,000.00
Final Repairs and Rebuild to Shutter (incl VAT) 15,000.00
9. In respect of damages awarded the Claimant is entitled to interest under s35A Senior Courts Act 1981 at such rates and for such period as the court thinks fit.
AND the Claimant claims:
a. Damages pursuant to paragraph 8 above
b. Interest pursuant to paragraph 9 above
Dated 25 June 2021 ULaws LLP
ULaws LLP
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STATEMENT OF TRUTH
I believe that the facts stated in this Particulars of Claim are true. I understand that proceedings for contempt of court may be brought against anyone who makes, or causes to be made, a false statement in a document verified by a statement of truth without an honest belief in its truth. I am duly authorised by the Claimant to sign this statement.
Tommy Linn
Tommy Linn, Managing Director of Beautiful Carbon Ltd
The Claimant’s solicitors are ULaws LLP of 37 Temple Row, Birmingham B2 5LF (Ref BH/kj/2021) where they will accept service on behalf of the Claimant.
To: the Defendant and Court Manager
Claim Number: HQ21 4859
IN THE HIGH COURT OF JUSTICE QUEEN’S BENCH DIVISION
Birmingham District Registry
BETWEEN:
Beautiful Carbon Ltd and
Shutter-Ways Ltd
Claimant
Defendant
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DEFENCE
1. All names and abbreviations in this Defence are those used and defined in the Particulars of Claim.
2. The Defendant admits paragraphs 1 to 4 of the Particulars of Claim.
3. As regards paragraph 5 of the Particulars of Claim, the Defendant admits the payment of £40,000 by the Claimant and asserts that the installation of the Shutter at the Claimant’s premises on 12 March 2021 was wholly in accordance with the Contract and was in full and complete performance of the Contract.
4. The Defendant denies it was in breach of contract as alleged in paragraph 6 of the Particulars of Claim or at all. The Shutter was of satisfactory quality and reasonably fit for its specified purpose as the garage and security door at the back entrance to the Claimant’s retail, storage and manufacturing hub. The Shutter was installed with reasonable care and skill.
5. In particular, the Spring was securely attached to its housing by 2 bolt and nut combinations that were secured and then checked by the Defendant’s supervisor upon installation.
6. The anti-drop safety brake of the Shutter was of sufficient strength and effectiveness to hold the Shutter safely open for an indefinite period. It was designed and manufactured to specifications capable of holding a heavy duty steel roller shutter of up to 10 metres by 8 metres.
7. If, as alleged by the Claimant, the Spring did fail and the anti-drop brake flange broke, the Defendant denies that this was due to any defect in the Shutter or lack of care in its installation, but was the result of interference, by persons unknown to the Defendant, with the mechanism of the Shutter.
8. The Defendant is unable to admit or deny and requires the Claimant to prove the matters set out in paragraph 7 of the Particulars of Claim as the Defendant has no knowledge of these matters.
9. If, which the Defendant is unable to admit or deny, the Claimant has suffered any of the damage and loss set out in paragraphs 7 and 8 of the Particulars of Claim the Defendant denies that they occurred as a result of any breach of contract by the Defendant for the reasons set out in paragraphs 5-7 above. Further, the Defendant alleges that if the Claimant has suffered any losses it has failed to mitigate them as it is claiming the full cost of a new car and excessive amounts for any repairs needed to the Shutter.
10. It is denied that the Claimant is entitled to the relief claimed or any relief.
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DATED 9 July 2021 Swallows & Co
Swallows & Co
STATEMENT OF TRUTH
I believe that the facts stated in this Defence are true. I understand that proceedings for contempt of court may be brought against anyone who makes, or causes to be made, a false statement in a document verified by a statement of truth without an honest belief in its truth. I am duly authorised by the Defendant to sign this statement.
Valdis Petersons
Valdis Petersons, Managing Director of Shutter-Ways Ltd.
The Defendant’s solicitors are Swallows & Co of 39 Victoria Street, Wolverhampton, WV1 3DH (Ref LP / ert / 342) where they will accept service of proceedings on behalf of the Defendant.
To: The Claimant and Court Manager
N244
APPLICATION NOTICE
For help in completing this form please read the notes for guidance form N244 Notes Name of court
High Court of Justice
Queen’s Bench Division Birmingham District Registry Claim No.
HQ21 4859
Fee account no.
(if applicable) Help with Fees – Ref No. (if applicable)
WDE 45367 HWF –
Warrant No.
(if applicable)
Claimant’s name (including ref)
Beautiful Carbon Ltd (Ref BH/kj/2021)
Defendant’s name (including ref)
Shutter-Ways Ltd (Ref LP/ert/342)
Date 23 July 2021
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1. What is your name or, if you are a legal representative, the name of your firm?
2. Are you a [ ]Claimant [ ]Defendant [X] Legal Representative [ ] Other (please specify)
If you are a legal representative who do you represent?
3. What order are you asking the court to make and why?
4. Have you attached a draft of the order you are applying for? [ X ] yes [ ] No
5. How do you want to have this application dealt with? [X] at a hearing [ ] without a hearing
[ ] at a telephone hearing
6. How long do you think the hearing will last? [ ] Hours [20] Minutes Is this time estimate agreed by all parties [ X ]Yes [ ] No
7. Give detail of any fixed trial date or period
8. What level of Judge does your hearing need?
9. Who should be served with this application?
9a. Please give the service address, (other than details of the claimant or defendant) of any party named in question 9
10. What information will you be relying on, in support of your application? [ X ] the attached witness statement
[ X ] the statement of case
[ ] the evidence set out in the box below
11. Signature and address details
Signed
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ULaws LLP
Applicant(‘s Solicitor) (‘s litigation friend)
Dated 23 July 2021
Position of office held
(if signing on behalf of firm or company)
Applicant’s address to which documents about this application should be sent
37 Temple Row, Birmingham If applicable
Phone No. 0121 426 5800
Fax No. 0121 426 5900
Postcode B2 5LF DX No. 795135
Birmingham 50
Ref No. BH/kj/2021
Claimant
1st
T. Linn Exhibit TL 1- 4 22 July 2021
Claim Number: HQ21 4859
IN THE HIGH COURT OF JUSTICE QUEEN’S BENCH DIVISION
Birmingham District Registry
BETWEEN:
Beautiful Carbon Ltd and
Shutter-Ways Ltd
Claimant
Defendant
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WITNESS STATEMENT OF TOMMY LINN
I, Tommy Linn, company director, of 31 Vyse Street, The Jewellery Quarter, Birmingham B6 1SQ, will say that:-
1. I am the Managing Director of the Claimant and I am duly authorised by the Claimant to make this witness statement in support of its application for summary judgment. Save as otherwise indicated, the contents of this witness statement are within my own knowledge and are true. Where the contents of this witness statement are not within my knowledge, I have set out the source of my information and belief.
2. I founded the Claimant business in 1987 and I take a close and daily interest in running the business. When the rear garage entrance to our premises in Vyse Street needed a new security shutter door I set out to try and find a replacement (“the Shutter”). I made enquires as to suitable retailers.
3. My enquiries led me to the Defendant and I rang them on 15 January 2021. I was put through to a man called Juris Petersons. He sounded so young that I asked him if he was the most senior negotiator for the Defendant and he responded crisply that he was the son of the family
and was the most senior available. I negotiated with him pretty hard and thought I had secured a real bargain when I got him down to £40,000 to include installation and VAT for the Shutter.
4. I was at our Vyse Street premises when the installation took place on 12 March 2021. I was a little surprised to meet Juris Petersons in person on site and in workman’s overalls; but he said he was getting to know his father’s business from all angles and had been involved in installing shutters for over 10 years. We joked he must have started young. Juris Petersons appeared to be in charge of the installation and I did see him with a checklist talking to his workers.
5. Once the Shutter was installed it was immediately in use. Numerous times a day I, my employees and delivery vans used the Shutter to enter and exit the premises.
6. On 19 May 2021 at about 09.30am I had just arrived at Vyse Street. My driver Maria Jenkins set me down at the front door and drove round the back of the building to park the car in the garage. It was only a few seconds later that I heard a loud rumble and crash from the back of the building. I ran round to the back entrance and saw that my new Mercedes had been smashed, almost into 2 parts, by the fallen Shutter. I was terrified that Maria was in the car and had been killed, but she appeared from out of the dust and told me that she had got out of the car to see what was blocking her way into the garage and so was not hurt. I was very relieved.
7. I was also angry. My new car, which I had only bought on 1 May 2021, was smashed and a write off. I attach the loss adjuster and insurance reports as exhibits TL1 and TL2 (not attached here). Also, I had to get the premises secured immediately. You cannot have an unsecured entrance to a jewellery business.
8. I contacted the Defendant later that morning. I spoke to Valdis Petersons this time and I told him that the Shutter had to be sorted that day. Valdis said he had no one available. He asked me to leave it as it was for a few days so he could get it checked. I said I had to get it repaired immediately but was willing to preserve any broken parts for his team to inspect. He said that I could not expect any help from him if his men didn’t get access to the Shutter as it was. The conversation did get a little confrontational at that point and quickly ended.
9. I engaged the services of Shut-Rite Ltd to do emergency and final repairs to the Shutter and to preserve any damaged parts for later inspection. A copy of their account is attached as exhibit TL3. I also had the damaged parts inspected by a consulting engineer I know called Brian Matthews. His report is attached as exhibit TL4. As can be seen, his opinion is that the Shutter was poorly installed and the anti-drop brake was inadequate for the weight of the Shutter.
10. On the available evidence I believe that, despite the Defence filed, the Defendant has no real prospect of successfully defending the claim and I know of no other compelling reason why this matter should be disposed of at trial. I ask the court to grant summary judgment, with damages to be assessed at a later disposal hearing.
11. I believe that the facts stated in this witness statement are true. I understand that proceedings for contempt of court may be brought against anyone who makes, or causes to be made, a false statement in a document verified by a statement of truth without an honest belief in its truth.
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Signed: Tommy Linn
Tommy Linn Dated: 22 July 2021
Claim Number: HQ21 4859
IN THE HIGH COURT OF JUSTICE QUEEN’S BENCH DIVISION
Birmingham District Registry
BETWEEN:
Beautiful Carbon Ltd and
Shutter-Ways Ltd
Claimant
Defendant
EXHIBIT TL3
I verify that this is the document referred to as TL3 in my witness statement made on 22 July 2021.
Tommy Linn
Tommy Linn
“TL3”
Shut-Rite Ltd 12 Anchor Rd
Hockley Birmingham
B7 4RE 07912345698
www.shutrite.co.uk
FAO Tommy Linn Beautiful Carbon Ltd 31 Vyse St
The Jewellery Quarter Birmingham B6 1SQ
Invoice No. 26th May 2021 £
21 5 5DK Item 1. Heavy duty steel roller shutter Spec. 4166.67
LPS1175. Emergency Repair 19/5/21, clear up
and preservation of damaged parts as VAT 833.33
instructed.
Item 2. Rebuild of Heavy duty steel roller 12500.00
shutter 26/5/21 as above to Spec LPS1175
VAT 2500.00
Total works and parts 16666.67
Total VAT 3333.33
To be paid by close of business 9th June £20,000.00
2021
Claim Number: HQ21 4859
IN THE HIGH COURT OF JUSTICE QUEEN’S BENCH DIVISION
Birmingham District Registry
BETWEEN:
Beautiful Carbon Ltd and
Shutter-Ways Ltd
Claimant
Defendant
EXHIBIT TL4
I verify that this is the document referred to as TL4 in my witness statement made on 22 July 2021.
Tommy Linn
Tommy Linn
“TL4”
BRIAN MATTHEWS
BSc HONS ENG FI Mech eNG
FAO Tommy Linn Beautiful Carbon Ltd 31 Vyse St
The Jewellery Quarter
BUILDING SERVICES CONSULTNG ENGINEER
(communication services are my speciality)
Birmingham B6 1SQ 31 May 2021
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Dear Tommy
Here are my views on your shutter disaster.
Today I had a look at the parts of the original Shutter-Ways shutter that the Shut-Rite lads had put to one side. I looked at the following items:-
Counterbalanced Spring Spring Housing
Spring securing bolts (2 of) – I couldn’t find any nuts Anti-drop brake flange
Two things struck me immediately.
1. The anti-drop brake flange is broken. It looks as if the weight of the shutter was too much for it. Poor design in my view.
2. A key part of the mechanism for the shutter is the counterbalanced spring (the Spring). When in use it is vital that the Spring is held securely in place within its housing. If it is not secure it can distort, slip and fail and the shutter would descend without any control.
That is what seems to have happened here. I have seen the bolts that held the Spring to the housing and one of the bolts has damaged threads; so it would have been cross threaded when installed and could not be tightened properly. This would mean that the Spring was not held in place securely. The Spring shows physical evidence of distortion.
Anyway Tommy I hope this is useful to you in getting this sorted. This is a freebie for a pal but if you want a formal report I will have to charge my usual fee of £1500 plus VAT and I would want to commission a metal fatigue test on the flange and that will cost another £500 at least.
Cheers
Brian
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Defendant
1st
V. Petersons Exhibits VP 1- 2 6 August 2021
Claim Number: HQ21 4859
IN THE HIGH COURT OF JUSTICE QUEEN’S BENCH DIVISION
Birmingham District Registry
BETWEEN:
Beautiful Carbon Ltd and
Shutter-Ways Ltd
Claimant
Defendant
WITNESS STATEMENT OF VALDIS PETERSONS
I, Valdis Petersons MSc, company director, of Unit 6, Parkside Industrial Estate, Sutton SM3 8BF, will say that:-
1. I am the Managing Director of the Defendant and I am duly authorised by the Defendant to make this witness statement in response to the Claimant’s application for summary judgment. Save as otherwise indicated, the contents of this witness statement are within my own knowledge and are true. Where the contents of this witness statement are not within my knowledge, I have set out the source of my information and belief.
2. I founded the Defendant business in 2004. I have degrees in civil and mechanical engineering from Riga Technical University and wanted to set up a business in the UK using my skills.
3. The Defendant sells and installs the electrically powered roller shutter doors that it manufactures. We specialise in one type of product and offer a shutter that is of high quality and tailored to the customer’s needs. Each shutter is manufactured to order and is manufactured and installed in accordance with strict and documented quality guidelines.
4. The shutter installed at the Claimant’s premises on 12 March 2021 (the Shutter) was to my design. I have designed shutters for over 20 years. This design is appropriate for shutters up to 10 metres high and 8 metres wide. An anti-drop safety brake is standard in this design and is of sufficient strength to stop and hold a shutter of up to 10 metres by 8 metres. I have read Mr Brian Matthews’ letter at exhibit TL4. His claims that the Shutter was too much weight for the anti-drop brake flange and that it was a “poor design” are nonsense. If the flange he inspected was broken in use I can only think that it was the result of the Claimant’s staff meddling with the Shutter after it was installed. The standard instructions left with the Claimant after installation clearly state that any servicing, repairs or alterations must be done by qualified and experienced personnel or the safety of the Shutter will be compromised. I attach a copy of the instructions as exhibit VP1.
5. The Shutter was manufactured at the Defendant’s factory on 17 February 2021 and installed at the Claimant’s premises by one of the Defendant’s experienced work teams on 12 March 2021. I attach the installation instructions and completed installation checklist as exhibit VP2. As can be seen the installation was correct and complete and this included an inspection of the counterbalanced spring and its housing. This document was completed and signed by my eldest son Juris Petersons (Juris) who was acting as supervisor for the work team on that day.
6. Unfortunately Juris is currently in Riga and has been there for the last month. His maternal grandmother is terminally ill and I could not be spared from the business. It is anticipated that he will return by the end of this month. Juris will then be available to give evidence at any trial of this claim. [Please Note: Here you may assume that there are no relevant Covid-19 travel restrictions involved].
7. Juris’ evidence is vital for the Defendant. I spoke to him immediately after Mr Linn telephoned me on 19 May. Mr Linn had been almost incoherent when he phoned and from the little he told me I couldn’t see why or how such an incident could have occurred. Mr Linn just kept shouting that I had to secure his back door immediately or thieves would steal his gold. My offer to inspect the Shutter within a day or so was shouted down, as was my suggestion that security guards would stop thieves. When he started to threaten me I just put the phone down. I needed information about the job and so I spoke to Juris.
8. Juris assured me that the installation had gone well and that he had left the standard instructions with Mr Linn. He also told me that he did have concerns about Mr Linn’s garage staff who, even as Juris demonstrated the operations and controls of the fully installed Shutter, were already complaining about how slowly the Shutter moved and asking if it could be speeded up. Juris said he had warned them not to mess about with the mechanics of the Shutter.
9. The above facts make it clear that the Defendant has a defence with a real prospect of succeeding at trial. In addition, it is submitted that the Defendant be given the opportunity to obtain further factual and expert evidence and this is a compelling reason why this case should be disposed of at trial.
10. I believe that the facts stated in this witness statement are true. I understand that proceedings for contempt of court may be brought against anyone who makes, or causes to be made, a false statement in a document verified by a statement of truth without an honest belief in its truth.
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Valdis Petersons Valdis Petersons Dated: 6 August 2021
Claim Number: HQ21 4859
IN THE HIGH COURT OF JUSTICE QUEEN’S BENCH DIVISION
Birmingham District Registry
BETWEEN:
Beautiful Carbon Ltd and
Shutter-Ways Ltd
Claimant
Defendant
EXHIBIT VP1
I verify that this is the document referred to as VP1 in my witness statement made on 6 August 2021.
Valdis Petersons
Valdis Petersons
“VP1”
Unit 6,
Parkside Industrial Estate,
Sutton SM3 8BF TEL. 0208 6539783
www.shutterways.co.uk
[EXTRACTS FROM INFORMATION LEAFLET – Please may assume that the remainder of this document is irrelevant to this application.]
Looking after your Shutter-Ways shutter + SAFETY INFORMATION
You have just purchased a quality product from a reputable manufacturer and it is important to keep it in good repair. Follow these few simple steps and your Shutter-Ways shutter will give you many years of good and SAFE service.
1. Service Intervals. To ensure your shutter is safe in use you must have it serviced by a Shutter-Ways approved engineer in accordance with the following intervals:
• 1st service, 6 months after installation
• Subsequent services to be performed every 12 months
2. Service provider, alterations and improvements
Your shutter is a precision instrument and must be repaired, serviced and cared for by experienced personnel. We strongly recommend you use a Shutter-Ways approved engineer and Shutter-Ways approved parts for any service, repairs or alterations.
If you do not use a suitably experienced and qualified Shutter-Ways approved engineer and high quality spare parts your shutter could become dangerous.
3. ……
Claim Number: HQ21 4859
IN THE HIGH COURT OF JUSTICE QUEEN’S BENCH DIVISION
Birmingham District Registry
BETWEEN:
Beautiful Carbon Ltd and
Shutter-Ways Ltd
Claimant
Defendant
EXHIBIT VP2
I verify that this is the document referred to as VP2 in my witness statement made on 6 August 2021.
Valdis Petersons
Valdis Petersons
“VP2”
Installation Instructions & Checklist.
No Shutter can be logged as final and complete unless ALL checks listed are done and signed off by your supervisor.
Valdis Petersons (Chairman)
Part Installed Checked Notes
Safety plate Yes JP
Springlock hanger Yes JP
Housing Front Yes JP
Housing Bottom Yes JP Small scratch – checked ok with Tommy Linn
Motor Bracket Yes JP
Counterbalanced spring
Yes JP
Counterbalanced spring
Housing
Yes JP
[EXTRACT FROM CHECKLIST – Please may assume that the remainder of this document is irrelevant to this application.]
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