The Civil Liability and Courts Act, 2004 (the “2004 Act”) introduced an obligation on Plaintiffs in personal injuries actions to deliver formal offers of settlement not later than 14 days after service of the Notice of Trial.  In practice, Plaintiffs are reluctant to deliver their offers first and have pressed for simultaneous exchange which is not provided for in the Act.  William Fry has brought two successful applications before the High Court in the cases of Sheila O’Donnell v G.P. McEntee and Sean Tierney and Helen Ahern v John Waterstone compelling the respective Plaintiffs to furnish their formal offers.  The former application was decided by the President of the High Court, Mr. Justice Kearns, (“the President”) on 18 December 2009 with the latter decided by Mr. Justice Quirke on 1 March 2010.