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Just to add a general comment - I would strongly advise against over complicating things as a litigant in person. Being effective in the courts requires real understanding of what you are talking about and good attention to detail. If you start talking at length about things you don't fully understand or try to make the judge read long documents which are only slightly relevant it will be a disaster.

 

As Ganymede has pointed out, the issue of relief from sanctions has totally changed since the 2013 White Book. The 2013 White Book is more likely to confuse you than help you on this. I think you are be better off just sticking the wording of CPR 3.9 itself, making sure you understand what the new Mitchell Three test is and explaining to the judge in plain English why your application satisfies that test. Note that this should be set out in a short witness statement attached to your application.

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