Lost Earnings Guidance

How to fight some of the main heads of special damages in personal injury cases for both claimants and defendants.

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Course Overview

A well drafted schedule will make recoverability easier and lead to a swifter settlement.

Preparing schedules of loss can be a daunting task for any fee-earner; Knowing what you can claim is only half the battle. This session will give you the skill and confidence needed to draft schedules of losses successfully.

Often called a schedule of special damages, this is not necessarily an accurate title and can lead to confusion. In accordance with CPR PD 16.4.2, a schedule of loss should include ‘details of any past and future expenses and losses’ and should have a statement of truth at the end.

During this session Nicky Carter will remind viewers of the two distinct types of damages; General and special damages and how this affects the layout of the schedule of loss. Consideration will be given to what should be included within the claimant’s statement and the information that will be required when undertaking the following nett loss of earnings calculations:

·         Self employment

·         Partnership

·         Limited Company

·         Illegal earnings


Other topics considered during this session include:

·         Past / future losses

·         Variations

·         Reclaiming sick pay

·         Employee benefits and loss of ‘perks’

·         Deductions – charitable payments, redundancy payments, benefits

What are the requirements?

  • This course provides 0.5 - 1 CPD point (depending on length of time spent reviewing the supporting documentation).
  • Watch the recorded webinar, review the slides and complete the short quiz to test your legal knowledge.

Learning Outcomes

  • On completion of this course you will:
  • • Understand what can /cannot be claimed within a schedule of loss
  • • Be able to advise the client regarding what to include within the claimant statement
  • • Know what information is required to calculate loss of earnings and how to do so in practice
  • • Feel confident in your ability to draft a well-executed schedule of loss

What is the target audience?

  • This course is suitable for qualified PI practitioners who represent both claimants and defendants
  • This course will also be of interest to clinical negligence practitioners


About Instructor - Nicky Carter

Nicky has over 20 years experience as a claimant PI lawyer and works with a number of leading national firms and regularly presents courses for several of the country's largest providers of legal training. In addition she lectures on the BPTC and in the coming months will be lecturing on the CILEX level 3 and level 6 courses.

Course Curriculum

Recorded Webinar

  • Webinar

Supporting Documentation

  • Slides
    32 Page


  • Quiz


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  • Price
  • £ 70