Sample Pre action Letter to opposition suggesting mediation

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Dear Sirs

Your Clients: Bob Building Co Ltd

We have now had the opportunity to consider your Letter of Reply and for the following reasons we do not believe your Client’s Defence has any merit:


It would seem that it will now be necessary for us to issue proceedings, but before doing so we are mindful that paragraph 3 of the Practice Direction on Pre-Action Conduct and Protocols requires us both to consider mediation. 

As we indicated in our Letter of Claim we are prepared to mediate. In our Letter of Claim we suggested North West Mediation Solutions as a suitable mediation organisation to provide a selection of mediators. We have reviewed their website and in view of the nature of the dispute we believe that X, Y or Z would be an appropriate choice as mediator. We enclose copies of their CVs.

We look forward to receiving your thoughts on the mediation process and the mediators who we have identified.