Letter Before Action and Invitation to Mediate

[Your address

XXX XXX]

[Other Parties Address

XXX XXX]

[Date]

Dear [Their Name]

Reference: [A single sentence summing up your claim]

So far it has not been possible to reach a mutually agreeable solution regarding our dispute, therefore; and regrettably, [insert your company name] now have to consider issuing court action. Please accept this ‘Letter Before Action’ to be in compliance with the Practice Direction- Pre-Action Conduct and Protocols paragraph 6.

The facts of the dispute are that [Provide a summary of the facts of the dispute]

In respect of the above disputed facts, from you we are claiming [State what you want from the party you are claiming from]

We calculate this sum as follows:

[Provide a breakdown of how you have calculated the amount being claimed]

Listed below are the documents on which we intend to rely in our claim against you:

[List the key documents that you will need to use to prove your claim]

In accordance with the Practice Direction- Pre-Action Conduct we would request that you provide us with copies of the following documents:

[List any documents you want from the party you are claiming from]

This is a relatively straight forward claim and therefore we expect to hear from you within the next 31 days. Should we not receive a response to this letter within this time frame then we anticipate that court proceedings will be formally commenced without further reference to you.

Alternative Dispute Resolution

We can confirm that [insert your company name] would be agreeable to using mediation in order to resolve this matter without going to court; and would ask that you consider the same. In pursuit of this, we have contacted Mediatelegal for information.

Mediatelegal are listed on the Ministry of Justice approved mediation provider list and are available to facilitate a mediation. Please look over their website at and feel free to contact Joseph Mulrooney (Founder member) on 0151 363 3972 to discuss any questions you may have regarding mediation. We would invite you to put forward your proposals regarding mediation.

In closing, I would draw your attention to paragraph 11 of the Practice Direction- Pre Action Conduct and Protocols, which gives the courts the power to impose cost sanctions on the parties if they fail to comply with the direction including failing to respond to this Letter Before Action and unreasonably refusing to mediate.

Yours sincerely

[Your name]