10-20-2026, 08:57 AM
@pcnappeal, yes, I would send one final, short response. Not because Gladstones deserve another explanation — they plainly have not engaged with the one already given — but because it creates a useful contemporaneous record for the court if they now issue a claim.
Their response is particularly helpful to you because they have effectively confirmed that, despite being expressly told what documents remain outstanding, they have simply re-sent the same evidence pack and stated that proceedings will follow.
I would send:
After that, I would stop corresponding with them and wait for the claim form. They have been given more than enough opportunity to comply. There is little value in entering into an endless exchange with a legal assistant sending the same template response.
In fact, if they do now issue, this paper trail is considerably more useful than another lengthy argument: Gladstones cannot credibly say they were unaware of the deficiencies or the outstanding disclosure requests.
Their response is particularly helpful to you because they have effectively confirmed that, despite being expressly told what documents remain outstanding, they have simply re-sent the same evidence pack and stated that proceedings will follow.
I would send:
Quote:Subject: Your response dated [date] – Ref: [reference]
Dear Sirs,
Thank you for your response.
You have not addressed the points raised in my email of 14 September 2026 and have not provided any of the outstanding documents specifically requested. Instead, you have merely re-sent the same evidence pack previously supplied following your first Letter of Claim.
For the avoidance of doubt, that evidence pack does not contain, amongst other things, the requested contemporaneous site plan, evidence of your client's standing and landholder authority, the contractual documentation relied upon, or the proper legal basis for the additional £70 claimed.
Your firm is therefore now expressly on notice, for the second time, that the pre-action disclosure remains incomplete.
If your client nevertheless elects to issue proceedings without first providing the outstanding documents and properly addressing the matters raised, your correspondence and the complete pre-action history will be placed before the court. Your repeated failure to engage with reasonable requests for documents central to the proposed claim will be relied upon in the Defence and as evidence of unreasonable conduct by both your client and your firm, including on the question of costs pursuant to CPR 27.14(2)(g).
The alleged debt remains disputed in full.
I will not repeat requests already clearly made. Should your client choose to issue proceedings notwithstanding the above, the claim will be defended.
Yours faithfully,
[Name]
After that, I would stop corresponding with them and wait for the claim form. They have been given more than enough opportunity to comply. There is little value in entering into an endless exchange with a legal assistant sending the same template response.
In fact, if they do now issue, this paper trail is considerably more useful than another lengthy argument: Gladstones cannot credibly say they were unaware of the deficiencies or the outstanding disclosure requests.
Never argue with stupid people. They will drag you down to their level and then beat you with experience. - Mark Twain
