T’is the season to be jolly and once more LPG has a jolly good read for you with the Xmas edition of ATEMatters. We start with a very interesting decision concerning a liability insurer and whether they should be the subject of a third-party costs order. ATEMatters would not be the same without a Part 36 judgment and we fail to disappoint with the inclusion of Ho v Adelekin which considers Part 36 offers alongside the fixed costs regime. The wording of and departure from the Law Society model CFA has come out of the cold again in the case of Healys LLP v Partridge leading to a judgment with huge potential costs ramifications. One for your injury litigation colleagues next with a look at a case dealing with the difficult and emotive subject of ‘loss of chance’ and at which point medical evidence should be considered. Finally, and to finish off 2019, do the circumstances of a late service of witness statement by the defence allow for relief from sanctions? Dootson v Newhouse seeks to show us the way.