Concurrent complex submissions

Every so often, a rent review is referred to an arbitrator or independent expert, depending upon the dispute resolution procedure in the lease. And, every so often, depending upon whether I am acting for the landlord or the tenant, the dispute resolution procedure requires me to comply with a timetable for submissions and counter-submissions or reports and replies depending on whether I am acting as an advocate or an expert witness. Such submissions or reports are never short: generally, I write approximately 20,000 words, followed by another 10,000 or so for the counter-submissions or replies.

Unless instructed at the dispute resolution stage, I rarely charge extra for “going to arbitration”. Concentrating on carefully crafted writing is so demanding that time slips by. Usually, referrals, as the dispute procedures are known by, occur occasionally, but recently, I have been dealing with two concurrently—one for a landlord of a trade counter and one for the tenant of a nightclub.

Usually, my typical working day is from about 09:00 until 19:00, but two referrals took them until 22:30 and the last few days of one until 23:45 on a Sunday. 12-14 hours working days is exhausting but satisfying; fortunately, I sleep well. I thanked the nightclub client for what I have found the most challenging referral I have dealt with in my entire career: I suppose, too, I should thank the landlord - for had it not been for the landlord’s desire to double the rent of premises of the Government’s enforced closure from the start of Covid-19 lockdown 1 in March 2020 until July 2021 the opportunity to exercise my skills to the limit might never have arisen.