John is joined by Richard East, founder and senior partner in Quinn Emanuel’s London office. They discuss the key differences between litigating in the US and the UK, including the pre-action protocols that are mandatory in the UK before initiating a lawsuit, the UK presumption that the loser will pay the winner’s attorneys’ fees, and the differences between the broad discovery procedures in the US and the more narrow disclosure rules in the UK. They also discuss the inability to prepare witnesses before testifying in the UK, the division of UK bar into solicitors and barristers, and the restrictions on public access to court records in the UK. Finally, they discuss the comparative rarity of jury trials in civil cases in the UK and the differences in the types of interim relief available in the UK, including powerful asset freezing injunctions which are recognized by jurisdictions around the world.
Published: Sep 13 2023