Build the document set
- Collect the signed contract, schedules, amendments, variations, purchase orders and incorporated terms.
- Add quotes, specifications, drawings, delivery records, invoices, account statements and payment records.
- Export the important emails and messages in date order and keep the original electronic copies.
- Include every formal notice, demand, response, mediation document or court document.
Prepare a chronology
- List the agreement date, performance dates, invoices, complaints, notices and key responses.
- Identify what each party was required to do and the first point at which performance allegedly departed from the agreement.
- Record oral discussions in a separate note, identifying who attended and when the discussion occurred.
Quantify the dispute
- Prepare a clear calculation of the amount claimed, paid, withheld or said to be lost.
- Separate direct loss, rectification cost, delay cost, interest and legal cost.
- Keep supporting invoices, expert material and accounting records.
Identify the practical objective
- State whether the priority is payment, completion, rectification, termination, preserving the relationship or an agreed exit.
- Check whether the contract requires notice, negotiation, mediation, expert determination or another step before proceedings.
- Identify urgent insolvency, security, limitation or court deadlines.
Before the appointment
Keep original documents safe, preserve electronic records and bring a short list of the questions and outcomes you want to discuss. Tell the solicitor about urgent deadlines at the beginning of the conference.