The defence have issued a notice of application to: amend their defence and have part of claim claim struck out/summarily adjudged in their favour. They've also asked me to consent to their amended defence.

I want to:

1. consent to their amendmenticon

2. make that consent conditional on their accepting an amendment to my claim

3. allow them two weeks to make any changes to their proposed defence

4. consent in advance to that amended defence, regardless of what it may contain


5. ask to have the strike out/summary judgement application dismissed

I have arguments why all these should be done. My only issue is how I should go about submitting them to the court. I haven't been able to find any info on the form my response should take. At the moment I'm thinking I'll just put everything in a witness statement and send it with a covering letter, any evidence, draft order, and proposed amendments to my statement of case, to the court manager.

Does this sound right, or is there some better way of doing it?

If it helps, the application I'm responding to is here:

thanks for any help anyone can give,


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