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Thomas Saunders was called to the Bar in 2019 and became a tenant at Keating Chambers in 2020 following successful completion of his pupillage.
During pupillage, Thomas worked across Chambers’ main practice areas, including construction and engineering, energy, procurement, and professional negligence, and gained experience of litigation, arbitration and adjudication as well as advisory work. He has worked with a number of major standard forms, including JCT, NEC, FIDIC and RIBA forms, as well as bespoke contracts and PFI agreements.
- Drafted Particulars of Claim in a claim against welding contractors following a fire in a power plant.
- Drafted Particulars of Claim concerning the collapse of a suspended ceiling which caused property damage and personal injury.
- Drafted Defence in third-party proceedings brought by a developer against a contractor following construction of a new-build home.
- Drafted Defence in a dispute concerning the installation of bathrooms at a luxury residential development.
- Drafted Particulars of Claim in a claim against a contract manager for remedial costs and consequential losses following the failure of a steam boiler.
- Drafted Particulars of Claim in a claim against both architect and design-and-build contractors for faulty design of a housing development leading to damp, decay and structural issues.
- Drafted Points of Claim and Points of Reply in an arbitration concerning power generation from landfill gas.
- Drafted Reply Contentions in an arbitration concerning the construction of a fuel loading jetty.
- Drafted skeleton argument for a case management conference involving an application to amend Particulars of Claim and an application for security for costs.
Drafted skeleton argument in an application for interim relief to restrain a sub-contractor from returning to site and damaging property following a payment dispute.
- Advised on and drafted Particulars of Claim in a claim by an adjudicator for unpaid fees.
- Drafted Particulars of Claim in a claim to enforce an adjudicator’s decision made pursuant to the Scheme for Construction Contracts.
- Drafted advice on the prospects of successfully resisting an adjudication enforcement on various grounds, including crystallisation of a dispute and overlap with a previous adjudication.
- Drafted advice on the prospects of successfully enforcing an adjudicator’s decision, requiring analysis of the extent of the adjudicator’s jurisdiction and whether the notice of adjudication had been properly served.
- Drafted advice, notice of adjudication and referral notice in a notified sum dispute concerning the validity of a purported interim application and subsequent notices.