Maximise Recovery. Minimise Delay.
Short answer: In housing disrepair (HDR) cases, winning standard-basis costs means drafting a DA-ready electronic bill (Precedent S), serving N252, and neutralising Points of Dispute (PoDs) with particularised Replies that prove necessity, proportionality and conduct. Use tight evidence (surveyor/counsel notes, ADR record, access/vulnerability proof) and a negotiation cadence that lands agreement—or you walk into detailed assessment ready.
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• Serve N252 + e-bill (Precedent S) + exhibits.
• Triage PoDs → concede the noise; defend the money.
• File Replies to PoDs (short, particularised, evidence-backed).
• Run a three-step negotiation and time Part 36 to bite.
• If no deal, request detailed assessment with a DA-ready bundle.
Primary SEO terms used here: points of dispute housing disrepair, replies to points of dispute, standard basis, detailed assessment, electronic bill.
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PoDs are the paying party’s line-by-line challenges to your bill. The goal is not to win every skirmish; it’s to move the net figure with focused Replies plus leverage (conduct, Part 36, DA timing).
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• Hourly rates (GHR, grade challenge, location band).
• Proportionality (damages vs time; “routine claim”).
• Pre-action/ADR conduct (post-Churchill noise).
• Surveyor fees (aborted attends; re-inspection).
• Access/vulnerability (duplication; “unreasonable”).
• Disclosure & landlord conduct (delay; duplication).
• Correspondence “admin” (non-recoverable assertion).
• Counsel’s fees (short hearings; vacated lists).
• Travel/attendance (local counsel argument; remote option).
• e-Bill coding (mis-phasing; “hidden” time).
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• Sort by money: phases with the largest deltas first.
• Concede low-value fluff that buys goodwill.
• Defend with proof (attach exhibits); keep prose short.
• Box clever on rates: anchor to GHR + justification (complexity/vulnerability/senior supervision).
• Proportionality narrative: tie work to issues (access refusals, vulnerable tenants, landlord non-compliance).
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• Item/Phase: [e.g., CMC correspondence]
• Ground: [rate/proportionality/duplication]
• Reason: [short phrase]
• Proposed reduction: £[x] / [y%]
• Reply to PoD [#]:
Issue: [rate/proportionality/necessity]
Reason: [1–3 short lines tying time to issue]
Evidence: [exhibit ref: fee note/letter/email/order]
Position: [maintain £x / accept £y / counter-offer £z]
(Keep sentences tight; attach proofs. No filler.)
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Reply:
Rates are GHR-aligned for [Band/Location] and reflect complexity and supervision: [issue list—vulnerability/access/late disclosure]. Grade A oversight was proportionate to risk/novelty at [milestone]. Maintain claimed rates.
Reply:
Work was necessary and proportionate to the issues actually faced: repeated access refusals, vulnerability accommodations, landlord non-compliance with directions. The time claimed is phase-appropriate and evidenced (see [letters, orders]). Maintain.
Reply:
Two attends were required: first aborted due to access refusal, second completed after landlord engagement. Both were reasonably incurred and evidenced (invoices/attendance notes). Re-inspection was necessary to progress settlement. Maintain.
Reply:
ADR was proactively invited on [dates], with reasonable proposals. Landlord response was [late/refusal/no-engagement], increasing costs. Conduct supports the standard-basis claim; time spent is reasonable. Maintain.
Reply:
Challenged items are procedural correspondence required to progress the claim (inspection scheduling, disclosure chasing, compliance letters). These are recoverable inter partes; see [exhibits]. Maintain.
Reply:
Counsel was instructed reasonably given [application/complexity/timetable]. Fee is evidenced (note attached). Late vacation was outside our control; brief fee remains properly incurred. Maintain.
Reply:
Coding conforms to Precedent S phase definitions. Entries challenged sit naturally in [phase] (see narrative). No duplication; totals reconcile to WIP and disbursement exhibits. Maintain.
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• Surveyor invoices + note (aborted/why).
• Counsel fee note / brief.
• ADR invitations + responses.
• Access/vulnerability evidence (emails, notes, risk).
• Orders / listing notes.
• Disclosure chase trail.
• Client VAT status.
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1. Counter schedule (by phase): quick concessions + defended items.
2. Without-prejudice call: confirm deltas; set a 72-hour decision window.
3. Part 36: drop when your paper is strongest (post-Replies / pre-DA request).
4. Settlement wording: sum, interest, pay date, DA stage costs.
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• File the DA request and serve your bundle (bill/e-bill, PoDs, Replies, offers, exhibits).
• Keep a corridor figure ready. If agreement lands, record via consent order (who pays DA costs).
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• Generic Replies → replace with issue-based lines + exhibits.
• No ADR record → rebuild from sent items or concede modestly.
• Rates with no anchor → add GHR band + why uplift/Grade A applies.
• e-Bill miscoding → re-map high-value entries; add a one-line narrative.
• Letting dates drift → diary 21-day PoDs, Part 36 expiry, DA listing.
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• ☐ N252 served + e-bill + exhibits
• ☐ PoDs triaged (money phases first)
• ☐ Replies drafted (7 patterns used)
• ☐ Counter sent + WP call booked
• ☐ Part 36 timed; interest ready
• ☐ DA request pre-prepared
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Serve promptly after PoDs to keep leverage; don’t let the 21-day window post-N252 go cold.
In Part 7 multi-track, yes (subject to limited exceptions). Using an electronic bill usually lifts outcomes.
Issues-based narrative: access refusals, vulnerability, ADR conduct, landlord delay—each tied to time phases and proofs.
Yes, if reasonably incurred. Evidence the attempt and explain why re-inspection was necessary.
After Replies (paper strongest) and before DA request, so expiry aligns with a pressure point.
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We’ll draft the bill/e-bill and run negotiations to settlement on one HDR file, at no cost.
Standard-basis only. No advocacy. No lay clients.