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Letter before claim, build the response plan

A letter of claim under the Pre-Action Protocol for Construction and Engineering Disputes is stress-tested as if acting for the other side, then built into the plan the team runs the pre-action meeting from.

Litigation and disputes · Litigation fee-earner, disputes partner

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Agents
Research, Litigation & Disputes
First draft
Two grounded research answers in under a minute each, then a Work-Stream Memo response plan the same day.

The problem

Waiting until the response arrives to plan is the common mistake. Building the plan while the file is fresh means finding the weaknesses in the firm's own letter before the other side does.

  1. Step 01 of 06

    Add key dates to the matter

    The letter of response due date and the pre-action meeting deadline go on the facts strip; the letter and the engineer's reports are added.

    Matters · Project Halcyon · SPA warranties and disclosureOpen

    Project Halcyon: SPA warranties and disclosure

    Buy-side warranty review, disclosure analysis and cited due-diligence grid.

    Client
    Halcyon Bidco Ltd
    Reference
    WC-2026-0412
    Practice area
    Corporate / M&A
    Jurisdiction
    England and Wales
    Responsible partner
    E. Vance
    No conflict check on file.

    Chat, on this matter

    Compare warranties with the disclosure letter.

    Three high-priority exceptions require action: the unregistered charge, the change-of-control right and the tribunal claim.

    Send a message… (@ to mention tools)BalancedPrepare for
    1. 25 Aug

      Disclosure exceptions matrix

      Chat

    2. 21 Aug

      Disclosure exceptions matrix

      Run · completed · 560 credits

    3. 18 Aug

      Project Halcyon: Disclosure Letter

      Document · indexed

    4. 16 Aug

      Project Halcyon: Share Purchase Agreement

      Document · indexed

    5. 4 Aug

      Matter opened

      Opened

  2. Step 02 of 06

    Stress-test the letter

    Asked to assume the other side and identify weaknesses, the answer finds the quantum breakdown gap, a liquidated-damages arithmetic point, and a missing non-completion certificate.

    Matters · 14 Rowan Court, Flat 9 · ResearchSources ranked
    Matter: 14 Rowan CourtEngland and WalesResearch Agent
     
    Prepare for: Court-Ready · Deliver as: Word

    Where we looked

    • 1Your documentsLease, demand, correspondence
    • 2Primary law3 statutes, 1 judgment
    • 3Regulators and the recordNothing needed
    • 4Web searchOff for this question

    Authorities · 4

    • 1

      Law of Property Act 1925, s 146

      c 20
      not yet checked
    • 2

      Housing Act 1996, s 81

      c 52
      not yet checked
    • 3

      Commonhold and Leasehold Reform Act 2002, s 168

      c 15
      not yet checked
    • 4

      Escalus Properties Ltd v Robinson

      [1996] QB 231 (CA)
      not yet checked

  3. Step 03 of 06

    Check the notice point

    A second question on the employer's notice obligations before deducting liquidated damages returns the relevant machinery, citing the standard form's own wording where no reported authority applies.

    Matters · 14 Rowan Court, Flat 9 · ResearchSources ranked
    Matter: 14 Rowan CourtEngland and WalesResearch Agent
     
    Prepare for: Court-Ready · Deliver as: Word

    Where we looked

    • 1Your documentsLease, demand, correspondence
    • 2Primary law3 statutes, 1 judgment
    • 3Regulators and the recordNothing needed
    • 4Web searchOff for this question

    Authorities · 4

    • 1

      Law of Property Act 1925, s 146

      c 20
      not yet checked
    • 2

      Housing Act 1996, s 81

      c 52
      not yet checked
    • 3

      Commonhold and Leasehold Reform Act 2002, s 168

      c 15
      not yet checked
    • 4

      Escalus Properties Ltd v Robinson

      [1996] QB 231 (CA)
      not yet checked

  4. Step 04 of 06

    Build the response plan

    The Litigation & Disputes Agent runs on Thorough with Prepare for: Work-Stream Memo, producing the anticipated letter of response, a chronology, an evidence schedule and a meeting agenda.

    Agents · Contract Agent · New runMatter: Northgate · senior associate hire

    Agent

    Jurisdiction

    Prepare for

    Deliver as

    Instruction

    What should the agent look for?

    Documents

    Drop a contract, or pick one from the matter

    Also on the matter

    • Offer_letter_v3.pdf2 pages
    • Staff_handbook_2025.docx61 pages
    • Board_minute_14_Aug.pdf3 pages
    Platform model · zero data retention · audit register on

  5. Step 05 of 06

    Work the next actions

    Nine items with owners and dates, including obtaining the non-completion certificate and instructing a delay expert.

    Agents · Contract Agent · Employment Contract Compliance ReviewCompleted

    • Replace the UK/Ireland/EU non-compete with a 3 to 6 month restriction tied to competing corporate-law work.

    • Replace blanket data consent with a lawful-basis clause and a separate monitoring notice.

    • Remove the five-day carry-over cap and reference the statutory carry-over rules.

    • Narrow the client non-solicit to clients dealt with in the final 12 months.

    • Add an explicit working-time opt-out withdrawal mechanism.

    • Confirm the bonus clause states the discretion is exercised in good faith.

  6. Step 06 of 06

    Sign off

    The partner reads it, ticks the items, clicks Verify all on the seven authorities, and signs off.

    Authorities · 14 · Where we looked
    #ReferenceVerdict
    1

    Tillman v Egon Zehnder Ltd

    [2019] UKSC 32    		not yet checked
    2

    Working Time Regulations 1998

    SI 1998/1833, regs 4 to 5, 10 to 14    		not yet checked
    3

    Coppage v Safety Net Security Ltd

    [2013] EWCA Civ 1176    		not yet checked
    4

    UK GDPR, Articles 6 and 9

    Retained Regulation (EU) 2016/679    		not yet checked
    5

    Employment Rights Act 1996, s 1

    c 18    		not yet checked
    6

    Harlow v Artemis International

    [2008] EWHC 1126 (QB)    		not yet checked

A document, not a transcript.

  • A weaknesses analysis of the firm's own letter of claim, each point tied to a paragraph in the document.
  • An anticipated Letter of Response with the firm's answer set beside each point.
  • A chronology, an evidence schedule and a meeting agenda for the pre-action meeting.
  • A next-actions list with owners and dates, and open questions the partner alone can answer.

Authorities it checks

  • JCT Design and Build Contract 2016
Every source it may cite

What it does not do

  • It does not obtain the non-completion certificate or the expert's underlying report; it names what is needed and who should get it.
  • It does not instruct the delay expert; that is flagged as a partner decision.
  • Where a point turns on the standard form's wording rather than reported authority, it says so rather than presenting a contractual construction as settled law.

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