Steven Eldred offers consultancy services for noise induced hearing loss (NIHL) cases, with over 20 years of experience in this area. He can provide advice on sourcing cases, setting up legal teams, choosing medical experts, identifying defendants and insurers, obtaining engineering evidence, and maximizing damages and costs awards. His services include consultancy at a macro level to set up NIHL practices, assistance on individual cases, and advising on witness statements and responses to Part 35 questions from defendants.

1. NIHL Consultancy Services
• Steven Eldred(eldreds22@hotmail.com)
• Unlock the money invested in your NIHL
cases

2. My Experience
• Undertaken NIHL case load
since 1997
• Recommended in Chambers
since 2005 for NIHL
• Once described as the NIHL
Guru

3. Macro Advice
• Sourcing the sources of work
• Setting up the team structure
• Choosing the right medical experts
• Knowing ELTO and the Portal, finding the Second Defendant
• Knowing Defendants and their insurers

4. ELTO Skills
• Being able to locate an insurer
• Using Companies House to assist ELTO searches
• Suing a defunct Defendant has its advantages
o No documents
o Understand possible FSCS involvement
o Restoring Company to the register

5. Know Your Medical Expert
• Choose your medical expert, don’t be stuck with your
medical expert
• Direct the content of your medical reports with the right
information
• Know how to deal with those Part 35 questions
o Limitation based (Johnson v MoD, 2kHz, WHO, Coles-Worgan)
o Causation based (knowing CLB inside out, exceptions and all)
o Material disability based (Hughes v Rhondda Cynon, Jones vs
Tompkinson)
• Know the Defendants’ experts and what they favour

6. Know Your Defendant
• Different dates of knowledge
• Special knowledge of lower noise levels
• Exploiting ‘’no documents to disclose’’ with statements,
engineering evidence and Okeefe v Steam Packet

7. Engineering Evidence
• Access to a large library of noise data spanning many
different industries
• Getting the right acoustic engineer
• Knowing 1963, 1972 and the 1989 guidance, such as 4.5.1
• Knowing your NILs and CLB and questions to ask
engineers and validating an engineer’s evidence

8. Quantum and Costs
• Parkes v Meridian, Romford schedule, material
contribution
• Costs at 62.5%, don’t fall for 25%, CJC and detailed
statement

9. Looking Ahead
• Macro consultancy
• File by file consultancy
• Witness statement consultancy
• Part 35 consultancy