The whole case just seems a little far fetched as they are suing for a figure that hasn't even been confirmed yet, in excess of 150k but the CMC figures were should the cost to take the case to court will be 220K on either side.
They are clearly suing for general damages, which means that the loss is to be assessed by the court. This is an extremely basic principle of litigation. No disrespect intended to you, but as the posters above have said, YOU should not be dealing with this yourself. The fact that you are dealing with this, when this most basic piece of information is unclear to you, is astonishing. It is also a gift to your opponents.
I don't really understand what you mean by "
the CMC figures were should the cost to take the case to court will be 220K on either side" but whatever that means, if they are suing for damages circa £150,000, their legal costs are going to £75,000-£100,000+ if they win.
My last position, before I started this business, was partner in a firm of solicitors. We had approx 30 full time litigators, and probably no more than 3 of them would be entrusted with a case of that size, and even then, they were rigorously supervised.
There are dozens of reasons why you should not only NOT be running this yourself, and probably as many questions as to why you are in this position, but the most pressing question is do you not have professional indemnity insurance, or some form of liability insurance, which covers this, and if so, why are your insurers' solicitors not dealing with this for you?
As far as the disclosure question is concerned, no-one here can reliably answer the question for you because no-one here has any sufficient knowledge of your case, and applications such as this are won and lost on specifics. I have made and defended numerous applications like this, and the applications are often heralded by an exchange of statements and evidence bundles totaling 100-200 pages. You need to stop wasting your time here and find a way to retain a firm of solicitors. If you haven't already looked into it, whatever insurance you may have is your first port of call.
Once again, this sounds harsh, and I mean no disrespect, but people do not just lose their livelihoods over cases like this, they lose their houses. I have seen it happen, but I have NEVER seen it happen to someone who was dealing with the case themselves. In fact when I first started reading this thread, I thought it was a joke!
I am sure it's not, but you appear to be in a state of denial or ignorance about the possible consequences of this litigation and you need to act now if you are to avoid this utterly ruining your life.
Good luck,
Dean