Maverick is a 68-year-old man suffering from age-related macular degeneration (a condition that damages part of the retina). He is now blind following an experimental stem cell procedure which, it was claimed, might improve his quality of life by reducing his symptoms. The medical procedure, which involved the injection of stem cells (derived from his own fat tissue) into his eyes, was performed by Dr Jones at a private clinic (StemGenMed) located in Surry Hills. The contest form was for a medical procedure, not a study. StemGenMed also conducts collaborative research and clinical trials on vaccination for coronavirus with various non-governmental establishments (in Australia and overseas). In January 2020, a statement of claim was issued on behalf of Maverick in the Supreme Court of New South Wales claiming damages against StemGenMed.

Assume that notwithstanding that StemGenMed file and serve a notice of appearance and defence within the time prescribed by the rules, Maverick's lawyers believe there is no defence to the claim. What are the appropriate steps they need to take?