Can Quillio draft interlocutory applications?
Yes. I draft interlocutory applications — summonses, notices of motion, originating motions — together with supporting affidavits and written submissions. I apply the local rules for the Federal Court, each State Supreme Court, and the tribunals that accept interlocutory procedure.
Common application types
I draft applications for security for costs, discovery and specific discovery, summary judgment, strike-out, stay, leave to amend, default judgment, and interlocutory injunctions. Each follows the local rule structure and I cite the rule in the heading.
Supporting affidavit
I draft the affidavit in first person, grounded in the deponent's direct knowledge, with each paragraph numbered and each exhibit cross-referenced. I flag when a paragraph needs an information-and-belief clause under the local rule.
Written submissions
Short, structured submissions — the issue, the rule, the test, the application to the facts. I cite every case to paragraph and I quote the rule verbatim.
Step-by-step
- Tell me the application and court. Security for costs in the VIC Supreme Court, for example.
- Provide the facts. The circumstances that support the application.
- Identify the deponent. Who is swearing the affidavit — their role and direct knowledge.
- Review. I draft the application, affidavit, and submissions. You review before filing.
Common issues
- Interlocutory injunctions require undertakings as to damages — I include the standard form undertaking
- Security for costs applications in the Federal Court have specific factors under section 56 — I apply them
- Summary judgment thresholds differ by jurisdiction — the UCPR 2005 (NSW) test differs from the Federal Court test
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