Case management Flashcards
(249 cards)
1
Q
What are the key Civil Procedure Rules (CPR) that outline the court’s case management powers?
A
CPR 3.1 to 3.5
2
Q
What Practice Direction is also relevant to the court’s case management powers?
A
3A PD
3
Q
According to CPR 3.1(2)
A
what is the general scope of the court’s case management powers?
4
Q
Give an example of the court using its case management powers to adjust timelines.
A
Extending or shortening the time for complying with a rule
5
Q
Name another example of a case management power related to court hearings.
A
Adjourning hearings or bringing them forward.
6
Q
What is a case management power that allows the court to ensure participation?
A
Requiring a party or their legal representative to attend court.
7
Q
Describe the case management power that allows the court to pause proceedings.
A
Staying the whole or part of the proceedings or judgment
8
Q
What is a case management power related to the costs of litigation?
A
Ordering any party to file and serve a costs budget.
9
Q
What is the significance of CPR 3.1(2)(m) in relation to the court’s case management powers?
A
It allows the court to take any other step or make any order to manage the case and further the overriding objective.
10
Q
What does the court’s power to make an order of its own initiative (CPR 3.3) mean?
A
The court can issue new directions or end a case without either party requesting it.
11
Q
If the court makes an order on its own initiative without a hearing
A
what must it include regarding the parties’ rights?
12
Q
If the court doesn’t specify a period to apply to set aside an order made on its own initiative
A
what is the default timeframe?
13
Q
Define “strike out” in civil procedure.
A
The deletion of written material from a statement of case
14
Q
What can be the extent of a strike out order?
A
It can involve deleting part or all of a statement of case
15
Q
What is the primary purpose of the court’s power to strike out a statement of case?
A
To address cases that are inadequately drafted or are an abuse of the court process.
16
Q
How can the court initiate the process of striking out a statement of case (CPR 3.4)?
A
On its own initiative or following an application by a party.
17
Q
When is the optimal time to make an application to strike out a statement of case?
A
As soon as possible and preferably before the case is allocated to a track.
18
Q
At what stage is the court most likely to consider striking out a statement of case on its own initiative?
A
Around the allocation or case management stage.
19
Q
Why do courts use the power to strike out sparingly?
A
Because there are often more suitable ways to deal with defective cases
20
Q
What is the key difference in focus between a strike out and summary judgment?
A
Strike out focuses on a defective statement of case
21
Q
What is the fundamental difference between a strike out and default judgment?
A
Default judgment occurs when a defendant fails to respond
22
Q
What is the first ground for striking out a statement of case?
A
The statement of case discloses no reasonable ground for bringing or defending the claim.
23
Q
Explain what it means for a statement of case to disclose “no reasonable ground”.
A
It fails to present a legally recognizable claim or defence as a matter of law.
24
Q
Give an example of a claim that might be struck out for disclosing no reasonable ground.
A
A claim stating “money owed £5
25
Give an example of a defence that might be struck out for disclosing no reasonable ground.
A defence that simply denies a claim without providing any reasons.
26
What is the second ground for striking out a statement of case?
The statement of case is an abuse of the court’s process or otherwise likely to obstruct the just disposal of proceedings.
27
Define "abuse of process" in the context of striking out a statement of case.
Using court procedure for a purpose or in a way significantly different from its ordinary and proper use.
28
Provide an example of what might be considered an abuse of process.
A vexatious litigant commencing a claim with no intention of pursuing it.
29
What does "obstructing just disposal" include as a ground for strike out?
Claims that are vexatious or obviously ill-founded (as per 3A PD 1.5).
30
What is the third ground for striking out a statement of case?
There has been a failure to comply with a rule
31
What type of conduct does the third ground for strike out (failure to comply) relate to?
The way the claim or defence has been conducted
32
Give examples of a failure to comply that could lead to a strike out application.
Late service of documents
33
Why is the court unlikely to strike out for a minor technical breach if a fair hearing is still possible?
Because it would be unjust to bar a litigant for a minor error; a lesser sanction is more likely.
34
What can the other party generally obtain if a statement of case is struck out due to non-compliance with a conditional order?
Judgment with costs
35
In summary
what is the purpose of the court's case management powers?
36
What is a key characteristic of the court's list of case management powers?
It is non-exhaustive.
37
When can the court make orders for case management without a specific application from a party?
When exercising its power to act on its own initiative.
38
Under what three main circumstances can the court strike out a statement of case?
No reasonable grounds
39
What potential consequence can follow the striking out of an entire statement of case?
The court might also give judgment for the other party.
40
How can the power to strike out be initiated by the court?
On its own initiative or following an interim application by a party.
41
What are the primary Civil Procedure Rules (CPR) that outline the court's case management powers?
CPR 3.1 to 3.5
42
What Practice Direction is also relevant to the court's case management powers?
3A PD
43
According to CPR 3.1(2)
what is the general purpose of the court's case management powers?
44
Give an example of the court using its case management powers to adjust timelines.
Extending or shortening the time for complying with a rule
45
Name another example of a case management power related to court hearings.
Adjourning hearings or bringing them forward.
46
What is a case management power that allows the court to ensure participation?
Requiring a party or their legal representative to attend court.
47
Describe the case management power that allows the court to pause proceedings.
Staying the whole or part of the proceedings or judgment
48
What is a case management power related to the costs of litigation?
Ordering any party to file and serve a costs budget.
49
What is the significance of CPR 3.1(2)(m) in relation to the court's case management powers?
It allows the court to take any other step or make any order to manage the case and further the overriding objective.
50
What does the court's power to make an order of its own initiative (CPR 3.3) mean?
The court can issue new directions or end a case without either party requesting it.
51
If the court makes an order on its own initiative without a hearing
what must it include regarding the parties' rights?
52
If the court doesn't specify a period to apply to set aside an order made on its own initiative
what is the default timeframe?
53
Define "strike out" in civil procedure.
The deletion of written material from a statement of case
54
What can be the extent of a strike out order?
It can involve deleting part or all of a statement of case
55
What is the primary purpose of the court's power to strike out a statement of case?
To address cases that are inadequately drafted or are an abuse of the court process.
56
How can the court initiate the process of striking out a statement of case (CPR 3.4)?
On its own initiative or following an application by a party.
57
When is the optimal time to make an application to strike out a statement of case?
As soon as possible and preferably before the case is allocated to a track.
58
At what stage is the court most likely to consider striking out a statement of case on its own initiative?
Around the allocation or case management stage.
59
Why do courts tend to use the power to strike out sparingly?
Because there are often more suitable ways to deal with defective cases
60
What is the key difference in focus between a strike out and summary judgment?
Strike out focuses on a defective statement of case
61
What distinguishes a strike out from a default judgment?
Default judgment occurs when a defendant fails to respond
62
What is the first ground for striking out a statement of case?
The statement of case discloses no reasonable ground for bringing or defending the claim.
63
Explain what it means for a statement of case to disclose "no reasonable ground".
It fails to present a legally recognizable claim or defence as a matter of law.
64
Give an example of a claim that might be struck out for disclosing no reasonable ground.
A claim stating "money owed £5
65
Give an example of a defence that might be struck out for disclosing no reasonable ground.
A defence that simply denies a claim without providing any reasons.
66
What is the second ground for striking out a statement of case?
The statement of case is an abuse of the court’s process or otherwise likely to obstruct the just disposal of proceedings.
67
Define "abuse of process" in the context of striking out a statement of case.
Using court procedure for a purpose or in a way significantly different from its ordinary and proper use.
68
Give an example of conduct that might be considered an abuse of process.
A vexatious litigant commencing a claim with no intention of pursuing it.
69
What does "obstructing just disposal" include as a ground for strike out?
Claims that are vexatious or obviously ill-founded (as per 3A PD 1.5).
70
What is the third ground for striking out a statement of case?
There has been a failure to comply with a rule
71
What type of conduct does the third ground for strike out (failure to comply) relate to?
The way the claim or defence has been conducted
72
Give examples of a failure to comply that could lead to a strike out application.
Late service of documents
73
Why is the court unlikely to strike out for a minor technical breach if a fair hearing is still possible?
Because it would be unjust to bar a litigant for a minor error; a lesser sanction is more likely.
74
What can the other party generally obtain if a statement of case is struck out due to non-compliance with a conditional order?
Judgment with costs
75
In summary
what is the purpose of the court's case management powers?
76
What is a key characteristic of the court's list of case management powers?
It is non-exhaustive.
77
When can the court make orders for case management without a specific application from a party?
When exercising its power to act on its own initiative.
78
Under what three main circumstances can the court strike out a statement of case?
No reasonable grounds
79
What potential consequence can follow the striking out of an entire statement of case?
The court might also give judgment for the other party.
80
How can the power to strike out be initiated by the court?
On its own initiative or following an interim application by a party.
81
What is the aim of imposing sanctions in civil litigation?
To ensure compliance with court rules and court orders.
82
Give three examples of potential sanctions a court can impose.
- Reducing interest payable
83
- Ordering indemnity costs
84
- Striking out a statement of case
SQE1: Sanctions & Relief
85
How can a court order impose a sanction?
Either immediately or by making an unless order.
86
What is an "unless order"?
An order providing for an automatic sanction if a party fails to comply by a specified date and time (CPR 2.9).
87
Give an example of an unless order.
'Unless the defendant serves its list of documents by [date and time]
88
Name two examples of automatic sanctions imposed by the CPR.
- Failure to disclose an expert report preventing its use at trial (CPR 35.13)
89
- Failure to file a costs budget being treated as filing only applicable fees (CPR 3.14)
SQE1: Sanctions & Relief
90
What is the general rule regarding the variation of time limits set by the CPR or court orders?
Parties can agree in writing to vary time limits
91
What is the exception to the general rule about varying time limits when a sanction for non-compliance is specified?
Parties can agree to an extension of time by prior written agreement (before the deadline) for a maximum of 28 days
92
What happens if a party fails to comply with a rule
practice direction
93
What is the overarching principle the court considers when deciding on an application for relief from sanctions (CPR 3.9(1))?
To deal justly with the application
94
What two specific needs does CPR 3.9 expressly require the court to consider when deciding on relief from sanctions?
- The need for litigation to be conducted efficiently and at proportionate cost.
95
- The need to enforce compliance with rules
practice directions
96
What must support an application for relief from sanctions?
Evidence.
97
What is the leading case authority on relief from sanctions?
Denton and others v TH White Ltd and another
98
What are the three stages of the Denton test for relief from sanctions?
1. Identify and assess the seriousness and significance of the failure to comply.
99
2. Consider why the default occurred.
100
3. Evaluate all the circumstances of the case
giving particular weight to efficient/proportionate litigation and enforcement of rules/orders.
101
According to Denton
what is a useful test for determining if a breach is serious or significant?
102
At which stage of the Denton test should the court generally *not* consider the general conduct of the parties (e.g.
a history of non-compliance)?
103
According to Denton
if a breach is neither serious nor significant
104
In the Denton case
why was relief from sanctions refused in Denton's appeal?
105
In the Denton case
why was relief from sanctions granted in Decadent Vapours' appeal?
106
In the Denton case
why was relief from sanctions granted in Utilise TDS Ltd's appeal?
107
What is the difference between an application for relief from sanctions and an "in-time application"?
Relief from sanctions is applied for *after* a deadline has been missed. An in-time application (e.g.
108
How is an application to set aside default judgment treated when the defendant relies on the discretionary ground (CPR 13.3)?
It is treated as an application for relief from sanctions
109
In summary
what power does the court have regarding sanctions?
110
What is the consequence if a party fails to comply with an order imposing a sanction?
The sanction takes effect unless relief is granted by the court (CPR 3.8 and 3.9).
111
What is the maximum extension of time parties can agree on without court approval
provided it doesn't risk a hearing date or contradict CPR/court orders?
112
What is the key case that provides the test for granting relief from sanctions?
Denton.
113
What is the purpose of 'allocation' in civil procedure?
To decide which 'track' (small claims
114
List the four tracks to which a claim can be allocated.
Small claims track
115
Why is the allocation of a claim to a specific track important?
Because the court manages claims on different tracks in different ways.
116
What is the primary factor the court considers when deciding which track to allocate a claim to?
The value of the claim.
117
When assessing the value of a claim for allocation purposes
what elements are disregarded?
118
What is the normal value limit for a claim to be allocated to the small claims track (CPR 27)?
Not more than £10
119
What is a specific type of claim with a different value limit for the small claims track?
Claims by a residential tenant against a landlord for repairs where neither the repairs nor damages total more than £1
120
What is the normal value limit for a claim to be allocated to the fast track (CPR 28)?
Up to £25
121
What two additional conditions must a claim meet to be normally allocated to the fast track?
a. The trial is likely to last no longer than one day (five hours).
122
b. Only one oral expert per party in no more than two expert fields.
SQE1: Allocation to Track
123
What is the normal value limit for a claim to be allocated to the intermediate track (CPR 28)?
Up to £100
124
What two additional conditions must a claim meet to be normally allocated to the intermediate track?
a. The trial is likely to last no longer than 3 days if managed proportionately.
125
b. Oral expert evidence is likely to be limited to two experts per party.
SQE1: Allocation to Track
126
What type of cases are normally allocated to the multi-track (CPR 29)?
All other types of case that do not fall within the criteria for the small claims
127
What is the normal value limit for a personal injury claim to be allocated to the small claims track?
Not more than £10
128
What is an *additional* value limit for pain
suffering
129
What is the *additional* value limit for pain
suffering
130
What is the *additional* value limit for pain
suffering
131
What is the first step in the overview of the allocation process after the defence is filed?
The court sends out the notice of proposed allocation.
132
What do parties need to file after receiving the notice of proposed allocation?
Directions questionnaires.
133
What additional document do parties provisionally allocated to the fast track
intermediate track
134
What does the court serve on the parties after considering the directions questionnaires (and a hearing if necessary)?
A notice of allocation.
135
What usually happens regarding directions when a claim is allocated to the small claims track or fast track?
The court will usually give directions.
136
What might happen regarding directions when a claim is allocated to the intermediate track or multi-track?
The court will either give directions or fix a case management conference to consider them.
137
When does the court officer provisionally decide the track for a claim?
Following the receipt of a defence.
138
What document does the court serve on each party indicating the proposed track?
A notice of proposed allocation (CPR 26.3(1)).
139
What are the parties required to do upon receiving the notice of proposed allocation?
- File and serve a directions questionnaire.
140
- (For fast/intermediate/multi-track) File proposed directions.
141
- (For costs management regime claims) File a costs budget and agreed budget discussion report.
SQE1: Allocation to Track
142
What are the names of the two main direction questionnaire forms and which tracks are they used for?
- Form N180: Small claims track.
143
- Form N181: Fast track
intermediate track
144
What must parties confirm in the directions questionnaire regarding pre-action protocols?
Whether they have complied with them.
145
What should a party do if they have failed to comply with pre-action protocols?
Explain why in the directions questionnaire.
146
What can parties request in the directions questionnaire to facilitate settlement?
That the court stay the proceedings.
147
If all parties request a stay for settlement in the DQ
how long will the stay typically be?
148
What information about disclosure is requested in the directions questionnaire?
The extent of disclosure anticipated for the case.
149
What information about witnesses is requested in the directions questionnaire?
The names of witnesses the party intends to call and what they will help to prove.
150
What must a party obtain from the court if they wish to rely on expert evidence?
The court's permission.
151
What information about the trial is requested in the directions questionnaire?
An estimate of the time needed for the trial.
152
In multi-track cases under automatic costs management
what financial document must be filed with the directions questionnaire?
153
What are parties required to do regarding proposed directions when responding to a notice of proposed allocation for the fast
intermediate
154
List some of the "other matters" about which the directions questionnaire seeks information.
- Which court the claim should be heard in.
155
- Which track the parties think the case should be allocated to.
156
- Which complexity band the parties think the case should be assigned to it is to be allocated to the fast or intermediate track.
157
- Whether interim applications have been made or are planned.
158
- Any other relevant facts or documents for the judge on allocation.
SQE1: Allocation to Track
159
What might the court do if it needs more information to allocate a claim after receiving the directions questionnaires?
Order a party to provide further information about the case or hold an allocation hearing (CPR 26.7(4) and (5)).
160
What does the court send to the parties after making an allocation decision?
A notice of allocation together with a copy of the DQs (CPR 26.9).
161
What is the principal criterion (but not the only one) the court uses to allocate a case to one of the three tracks?
The financial value of the claim.
162
List some of the factors (beyond financial value) that the court will consider when deciding which track to allocate a case to (CPR 26.13(1)).
- The nature of the remedy sought.
163
- The likely complexity of the facts
law or evidence.
164
- The number of parties or likely parties.
165
- The value of any counterclaim or other Part 20 claim.
166
- The amount of oral evidence which may be required.
167
- The importance of the claim to any persons who are not parties.
168
- The views expressed by the parties.
169
- The circumstances of the parties.
SQE1: Allocation to Track
170
What is the first step in determining the correct track for a claim?
Identify the normal track based primarily on the value of the claim.
171
What is the second step in determining the correct track for a claim?
Consider whether there is a good reason to allocate the claim to a track other than the normal track
172
In the example provided
why might a £26
173
What is likely to happen after allocation if the claim is allocated to the small claims track or the fast track?
The court will likely also give directions as to how the claim should proceed.
174
What is likely to happen after allocation if the claim is allocated to the intermediate track or multi-track?
The court will likely either give directions
175
In summary
what is the primary purpose of the directions questionnaire?
176
What is a key characteristic of costs recovery in the small claims track?
Very limited costs recovery; the court will rarely order one party to pay the other's costs beyond fixed costs
177
What is a key feature regarding formalities in the small claims track?
Fewer formalities; certain CPR rules do not apply
178
What is a typical feature of the directions in the small claims track?
Abbreviated directions
179
Give an example of a standard direction in the small claims track.
Parties to file and serve documents they intend to rely upon 14 days before the hearing.
180
What is the typical timeframe for notice of a hearing in the small claims track?
At least 21 days' notice.
181
What are parties expected to do if a small claims track case settles by agreement?
Inform the court.
182
How are directions typically given in fast track cases?
Usually based on the directions questionnaire
183
What is the standard timeframe (in weeks from notice of allocation) for disclosure in the fast track?
4 weeks (though the type of disclosure can vary).
184
What is the standard timeframe (in weeks from notice of allocation) for the exchange of witness statements in the fast track?
10 weeks.
185
What is the standard timeframe (in weeks from notice of allocation) for the exchange of experts' reports in the fast track?
14 weeks (with limits on the number of experts
186
What is the standard timeframe (in weeks from notice of allocation) for filing pre-trial checklists in the fast track?
22 weeks.
187
What is the standard timeframe (in weeks from notice of allocation) for the trial date/period in the fast track?
30 weeks (trial should last no longer than 1 day).
188
Where are fast track trials usually held and what is the typical duration?
County Court
189
What is the significance of complexity bands in the fast track?
They determine the level of fixed costs that the Claimant can recover at the conclusion of the case.
190
Give an example of a type of claim typically in Fast Track Complexity Band 1.
Road traffic accident related
191
Give an example of a type of claim typically in Fast Track Complexity Band 2.
Road traffic accident related
192
Give an example of a type of claim typically in Fast Track Complexity Band 3.
Road traffic accident related PI claims not under RTA Protocol; employer's/public liability PI claims; possession/housing disrepair claims; other money claims.
193
Give an example of a type of claim typically in Fast Track Complexity Band 4.
Employer's liability disease claims (excluding noise induced hearing loss); complex possession/housing disrepair; property/building disputes; professional negligence; complex claims normally on fast track.
194
When was the intermediate track introduced and to what cases does it apply?
October 2023
195
What is the normal value limit for a claim to be allocated to the intermediate track?
Up to £100
196
What is the likely maximum trial length for a case on the intermediate track?
3 days
197
What is the likely limit on oral expert evidence per party on the intermediate track?
Two experts per party.
198
What are the page limits for witness statements/summaries and expert reports on the intermediate track?
Witness statements/summaries: 30 pages; Expert reports: 20 pages (excluding necessary attachments).
199
What are the party number limits for a claim to be normally allocated to the intermediate track?
Single claimant vs. one or two defendants
200
What is the significance of complexity bands in the intermediate track?
They determine the level of fixed costs that the Claimant can recover at the conclusion of the case.
201
Give an example of a type of claim typically in Intermediate Track Complexity Band 1.
Claims with only one issue in dispute and a trial not expected to last longer than one day (e.g.
202
Give an example of a type of claim typically in Intermediate Track Complexity Band 2.
Less complex claims with more than one issue in dispute
203
Give an example of a type of claim typically in Intermediate Track Complexity Band 3.
More complex claims with more than one issue
204
Give an example of a type of claim typically in Intermediate Track Complexity Band 4.
Claims normally on the intermediate track but unsuitable for Bands 1-3 (e.g.
205
What are parties required to state in the directions questionnaire regarding the complexity band for the intermediate track?
Either the agreed complexity band or
206
What case management steps might the court fix in the intermediate track?
A case management conference (CMC) and/or a pre-trial review.
207
What are parties expected to do regarding directions in the intermediate track before a CMC (if one is listed)?
Endeavour to agree appropriate directions and submit them to the court 7 days in advance.
208
What is the typical timeframe for the trial of an intermediate track case from allocation?
Within 30 weeks of allocation.
209
What discretion do judges retain regarding allocation of cases valued under £100
000?
210
In summary
what are the key characteristics of the small claims track?
211
In summary
what are the key characteristics of the fast and intermediate tracks?
212
What is a key characteristic of case management on the multi-track?
Flexibility; the way each case is handled varies depending on its complexity and value.
213
What are the two most likely next steps after a case is allocated to the multi-track (CPR 29.2)?
The court giving directions
214
What is a case management conference (CMC)?
A hearing (by telephone or in person) to determine the future conduct of the case.
215
What is the purpose of a CMC beyond just setting directions?
To identify and understand the real issues
216
Name three specific matters the court will likely test the parties on at a CMC.
- Suitability of the case for settlement.
217
- The position the parties have reached in the litigation.
218
- Estimated costs of litigation and whether this is proportionate.
SQE1: Early Case Management (Multi-Track)
219
List three issues the court is likely to consider at a CMC (29 PD 5.3).
- Whether the claim is clear.
220
- What disclosure is required
if any.
221
- What expert evidence is required.
SQE1: Early Case Management (Multi-Track)
222
What is a requirement for any legal representative attending a CMC (CPR 29.3(2))?
They must be familiar with the case and have sufficient authority to deal with likely issues (e.g.
223
What is a likely consequence if a legal representative without sufficient authority attends a CMC
leading to postponement?
224
What documents should parties typically prepare *before* a CMC?
Disclosure report (not less than 14 days before)
225
What is an express obligation on parties in multi-track cases before a CMC?
To try to agree directions.
226
Why is agreeing directions before a CMC important?
It satisfies the overriding objective by saving time and money.
227
When must agreed (or proposed) directions be submitted to the court before a CMC (CPR 29.4)?
At least seven days before any CMC.
228
Where can parties find standard directions orders and model paragraphs for multi-track cases?
On the Ministry of Justice website (www.justice.gov.uk).
229
What is the starting point for drafting case management directions in multi-track cases?
The model and standard directions published by the Ministry of Justice.
230
What might happen if the parties agree all necessary directions and the court finds them appropriate?
The CMC may be vacated (cancelled).
231
What is the purpose of the CMC if the parties haven't agreed directions?
For the court to hear submissions and then give directions.
232
In multi-track cases (excluding personal injury claims)
what report must both parties produce in readiness for the CMC (CPR 31.5(3)-(8))?
233
When must the disclosure report be filed and served before the first CMC?
Not less than 14 days before.
234
What information must be included in the disclosure report?
Brief description of relevant documents
235
What is the purpose of the disclosure report requirement in multi-track cases?
To keep the costs of disclosure proportionate to the matters in dispute.
236
What form can be used for the disclosure report?
Form N263.
237
What additional form should parties consider using if there are electronic documents to be disclosed?
The Electronic Documents Questionnaire (EDQ)
238
When should the EDQ be filed if used?
With the Disclosure Report
239
What is a case summary (29 PD 5.6(3) and 5.7)?
A short document (max 500 words)
240
What should a case summary contain?
A chronology
241
When should a party make an application to court (e.g.
to amend a statement of case) in a multi-track case?
242
Can CMCs occur at stages other than the initial directions hearing in multi-track cases?
Yes
243
Are hearings to decide directions common in tracks other than the multi-track (e.g.
fast track)?
244
In summary
what are the likely initial steps in multi-track case management?
245
What is the broader purpose of a CMC beyond just setting directions?
To identify and narrow issues
246
What is expected of parties regarding directions before a CMC in the multi-track?
To attempt to agree them and submit agreed or proposed directions beforehand.
247
What is a key document (usually) required to be filed before the first CMC in a multi-track case?
A disclosure report (unless it's a personal injury claim).
248
What other document should parties consider preparing for a CMC to aid the court?
A case summary.
249
Can CMCs be held at later stages of multi-track proceedings?
Yes
