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Precedent - Response to Halsey Mediation Letter

Document Cited authorities 3 Cited in Related
Vincent
AuthorStephen Walker/David Smith
Pages229-229
Appendix 8


Precedent – Response to

Halsey Mediation Letter

This precedent is based on a reply to a fictional letter quoting Halsey to illustrate how a response might be made.

Thank you for your offer of mediation made in your letter of XXX. This offer is declined.

We note that you have made reference to the case of Halsey v Milton Keynes General NHS Trust [2004] EWCA Civ 576 in your letter. We do not accept that the criteria in Halsey apply to this situation.

We see no reasonable prospects of the mediation succeeding. We have made reasonable offers to settle this matter which have been refused. Your own offers are unreasonable and you have refused to consider reasonable offers on our part. In short, the parties are so far apart that we see little prospect of a settlement at mediation, however skilled the mediator. We refer you to the case of Mason & Ors v Mills & Reeve (A Firm) [2012] EWCA Civ 498 in this regard.

We do not...

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