Zoe Earnshaw

Year of Call: 2001, Lincoln's Inn

Zoe earnshaw
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Zoe is a Personal Injury specialist. 

She is described in the Legal 500 as a leading junior, particularly recognised for her expertise in catastrophic injury work. Her practice focuses on complex and high value litigation. She represents both Claimants and Defendants.

Zoe is able to combine a robust approach in Court and in negotiations with a sensitive manner towards her own clients. Known for her meticulous preparation and detailed analysis of cases, Zoe is tactically astute and well suited to complex cases, particularly where confident handling of experts is required.

She is a member of the Civil and Insurance Fraud team. She has significant expertise in defending fraudulent and exaggerated claims across the spectrum of personal injury work. She has secured findings of fundamental dishonesty and has provided training to solicitors on the topic.

Zoe is proficient in handling cases involving chronic pain. She is practiced in analysing issues of medical causation, competing expert evidence and credibility in this context.

Zoe has previously been led by Tim Horlock KC in a High Court tetraplegic claim arising from a road traffic accident between a car and a cyclist. Liability was settled on the morning of trial. Quantum proceedings are ongoing.  

Zoe is happy to provide seminars. Previous topics have included fundamental dishonesty, employer’s liability post the Enterprise and Regulatory Reform Act 2013, tactics on quantum and resiling from admissions of liability.

“Zoe has a great ability to turn around voluminous papers and has a swift analytical brain. She’s also commercial minded and not afraid of fighting.”

Chambers & Partners, 2024

Notable Cases

  • Instructed in successful appeal against the refusal to allow the withdrawal of a pre-action admission. The modest claim value initially pleaded was “fundamentally wrong” and new evidence changed the character of the claim

    Clyde & Co success offers further guidance on withdrawal of pre-action admissions : Clyde & Co (clydeco.com)

  • W v A

    Instructed by the Defendant in a severe traumatic head injury claim with permanent memory deficit, cognitive impairment, and risk of epilepsy. Claim pleaded at £1.3 million. Settlement secured at JSM at 20% of the pleaded value.

  • R v M

    Acted for a Defendant in a liability and quantum dispute where a young motorcyclist suffered multiple injuries including a severe knee fracture. He was likely to deteriorate in the future, require surgery and suffer disadvantage in his manual job. The case was pleaded at £875,000 and was successfully settled at JSM at £194,500.

  • T v A

    Instructed on behalf of a Claimant who suffered a severe knee injury when he was knocked off his bicycle and reversed over by the Defendant driver. Ongoing chronic pain, limitation and restricted mobility. Case settled shortly after CCMC.

  • R v H

    Acted for the Defendant in a chronic pain claim where the Claimant alleged she failed to recover from minor orthopaedic injuries. Orthopaedic, pain and psychological experts instructed on both sides. Credibility was in issue.

  • G (on behalf of RD, deceased) v D

    Acted for a young Claimant in a fatal accident claim after her fiancée was killed in a motorcycle accident. Settlement secured for c£400,000 prior to commencement of proceedings.

  • A v K

    Acted for a cyclist struck by a car who suffered multiple injuries including a head injury. Significant dispute within the expert evidence as to whether a mild traumatic brain injury had been sustained.

  • S v NMS

    Acted for a Claimant who suffered chronic pain following a crush injury to his leg after a JCB was driven into him at work. Key issues were injury diagnosis / prognosis and future loss of earnings / earnings capacity. Case settled at JSM.

  • Farnworth v Davis

    Successful appeal overturning a Part 36 costs decision on a point of law. Issue was the correct interpretation of “proceedings” in CPR 36.13(1). Case reported on Lawtel (LTL 21/06/2016)

  • SC v Blackpool Pleasure Beach

    Acted for a teenage girl who suffered serious gynaecological injuries while playing in water fountains at the Pleasure Beach. Liability and quantum were disputed. Case reported in the media.

  • K v P

    Case arising from a fall down steps at a pub which caused a fracture dislocation of the ankle. Orthopaedic expert dispute re future deterioration. Acted for the Defendant and settled at JSM.

Professional Associations

  • Northern Circuit
  • Personal Injuries Bar Association

Education

  • Kings College London- BA (Hons)
  • Manchester High School for Girls

Awards

  • Richard Isaacson Memorial Scholarship (Northern Circuit)
  • Hardwicke Scholarship (Lincoln’s Inn)
  • Thomas Moore Bursary (Lincoln’s Inn)