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Security for costs
It is often best to instruct specialist costs counsel where an application for security for costs is going to be made (or defended), but where trial counsel wishes to keep hold of the reins, the costs team is able to give advice which will enhance counsel’s performance.
If the instructions come from the applicant, then they ought to include a draft witness statement setting out the evidence upon which reliance will be placed. Ideally, counsel ought to be given opportunity to advise on that draft before it is served.
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