Affidavit by director authority to commence proceedings
Affidavit of authorised officer authority to commence proceedings
Affidavit of consent to be joined as a Plaintiff

4. Notice of Change of Address for Service

Requests for further and better particulars

6. Request for further and better particulars

Setting aside default judgment

7. Notice of Motion - set aside entry of default judgement

8. Defence
Example Defence

9. Affidavit in support of Notice of Motion to set aside default judgment

Cross Claims by the Defendant

10. Statement of Liquidated Cross-claim

11. Cross-summons

12. Example Cross-Claim

13. Letter serving Cross-Claim

Claims for contribution or indemnity

14.

Statement of Claim

15. Summons

If required

Security for costs

Letter to Plaintiff or Cross-Claimant in relation to provision of security for costs
Skeleton Bill of Costs
Notice to Produce to Plaintiff or Cross-claimant on Security for Costs Applicatiion
Notice of Motion for Security for Costs
Affidavit in support of Notice of Motion for security for costs

Striking out of pleadings

Letter to Plaintiff Foreshadowing Striking Out Statment of Claim
Notice of Motion to strike out statement of claim
Affidavit in support of Notice of Motion to strike out

Discovery

16. Letter to other side with categories of documents for Discovery

17. List of Documents

18. Timetable up to completion of Discovery

If required

Interlocutory steps in the proceedings

Notice of Motion
Affidavit

Summary dismissal

Notice of Motion for summary dismissal
Affidavit

Summary judgment

Notice of Motion for summary judgment
Affidavit

Continuation of proceedings following partial judgment

Separate decision of questions

Notice of Motion for separate determination
Affidavit

Consolidation

Notice of Motion for consolidation of proceedings

Interrogatories

Interrogatories
Statement in Answer to Interrogatories

If required

Filing and service of affidavits

Affidavit
Affidavit of Service

19. Affidavit

20. Annexure Certificate

21. Exhibit certificate

Expert witnesses

22. Letter instructing Expert Witness

23. Letter instructing single Expert Witness

24. Affidavit - Expert witness annexing report

25. Expert Witness Code of Conduct

Subpoenas and Notices to produce

26. Application to issue obtain a return date for subpoena for production

27. Subpoena

28. Notice to Produce

29. Notice Of Motion to set aside Subpoena

30. Notice Of Motion to set aside Notice to Produce

31. Affidavit in support of Notice Of Motion to set aside subpoena or notice to produce

Costs in default of attendance

Withdrawal of matter

Pretrial directions before the trial judge

Agreed list of exhibits / the tender bundle

32. Agreed List of Exhibits

Notices to admit facts and authenticity of documents

33. Notice to Admit Facts and Authenticity of Documents

34. Notice Disputing Facts and Authenticity of Documents

If required

Usual undertaking as to damages

The usual undertaking as to damages

Service and cost of injunctions

Summons Injunctive relief in relation to land
Affidavit
Affidavit of Service

A demonstration of the use of the precedents

Last Updated: 08/01/2010

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All Areas of Law > Litigation > Supreme Court (NSW) - Step-by-Step Legal Practice Guide and Precedents

Supreme Court (NSW) - Step-by-Step Legal Practice Guide and Precedents

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Step-by-Step Guide and Precedents for Supreme Court of NSW matters when acting for the Plaintiff or Defendant in either the Common Law or Equity Division.

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