Letter of claim for a noise-induced hearing loss claim against an employer

Produced in partnership with Simon Ellis of Hugh James
Precedents

Letter of claim for a noise-induced hearing loss claim against an employer

Produced in partnership with Simon Ellis of Hugh James

Precedents
imgtext
AddressYour Ref:
Our Ref:
Please ask for:
Date:
Telephone:
Email:

Dear [insert organisation name]

Noise-induced hearing loss (NIHL) Letter of Claim

Part A

We are instructed by [insert Claimant’s name] in respect of a Noise Induced Hearing Loss claim against [insert Defendant’s name].

We are writing this letter in accordance with Annex E of the Pre-Action Protocol for Disease and Illness Claims.

To enable the Defendants to fully investigate the matter, we attach the following information (tick to confirm attached):

  1. •

    ELTO Search(es)

  2. •

    HMRC

  3. •

    Completed questionnaire

  4. •

    Completed Part B for each proposed Defendant

  5. •

    Audiogram

  6. •

    GP and hospital records

  7. •

    Anticipated valuation

  8. •

    Provisional Schedule of Special Damages with supporting evidence

  9. •

    Personnel/OH file or signed authority from Claimant to obtain copy from insured

  10. •

    Declaration of previous claims

    1. 1

      Claimant’s Details:

      1. 1.1

        Full Name:

      1. 1.2

        Address:

      1. 1.3

        Date of birth:

      1. 1.4

        National Insurance Number:

      1. 1.5

        Solicitor’s reference:

    1. 2

      Employment History

      1. 2.1

        The following table details our client’s full working in both noisy and non-noisy environments:

        DefendantEmployerEmployment datesExposure to noise? (Yes/No)Hearing protection? (Yes/No)Pursued? (Yes/No)Lead Insurer detailsFSCS Interest? (Yes/No)
Simon Ellis
Simon Ellis

Simon is a Partner with Hugh James and specialises in industrial disease cases. Simon assists clients suffering with a wide range of industrial diseases, including asbestos related illnesses, hearing loss, HAVS and work related cancers. He has extensive experience in this field and represents clients in both unitary claims and large group actions. Due to his experience and reputation Simon is often approached to deal with more unusual types of industrial disease. He has been at the forefront of seeking justice for clients suffering with less common industrial diseases and has been involved in a number of cases considered by the Court of Appeal. He regularly contributes articles and participates in media interviews for the press regarding industrial disease issues. Recent testimonials from Simon's clients include the following: Professional, responsible and trustworthy. You have restored my confidence in the legal process.

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Jurisdiction(s):
United Kingdom
Key definition:
Noise definition
What does Noise mean?

This term is used to mean uncertainty about the future not directly related to investment market uncertainty, eg an insurance company's uncertainty about the size of future claims on its policies.

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