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Claim No.:HQ [insert claim number]

IN THE HIGH COURT OF JUSTICE

KING’S BENCH DIVISION

ROYAL COURTS OF JUSTICE

MEDIA AND COMMUNICATIONS LIST

PARTIES:

1. (1)

   [Insert full name of claimant/first claimant]

1. (2)

   [[Insert full name of second claimant]]        [Claimant OR Claimants]

1. and

1. [Insert full name of defendant]        Defendant

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REPLY

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1. 1. 1

      The [Claimant joins OR Claimants join] issue with the Defendant on his Defence save for the admissions it contains and those averments therein which are expressly admitted below. Paragraph references are to the Defence.

   1. 2

      The [Claimant denies OR Claimants deny OR that the words complained of in the meanings set out at paragraph 8.1 of the Defence are true. Without limitation to the generality of this denial as to the particulars of truth advanced to support those imputations, the [Claimant pleads OR Claimants plead] as follows:

      1. 2.1

         [set out the claimant’s/claimants’ response to the Particulars of Truth set out by the defendant in his defence, admitting or denying as appropriate].

   1. 3

      It is denied that the words complained of were honest expressions of opinion as alleged at paragraph 9 of the Defence:

      1. 3.1

         [The