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Points of Dispute & Reply: Arguments that Pay (CPR 47)

We draft PoDs/Replies that defend rates, necessity, proportionality and disbursements—with evidence. Timetables, interest and settlement leverage managed. Free Trial.

Points of Dispute & Points of Reply
justice buisness man

Points of Dispute & Reply — The Arguments That Pay

Updated: 28/09/2025

We write Points of Dispute that cut noise and Replies that land results. Focus: defend rates, necessity, proportionality and disbursements with evidence—then close. Timetables and interest are managed to keep leverage until payment.

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What we do

• Audit the Bill — phase, rate and necessity checks; identify tactical concessions

• Draft PoDs (paying parties) or Replies (receiving parties) with exhibits and authorities

• Model concessions that unlock settlement without leaving money behind

• Timetable control — 21-day PoDs window, Default Costs Certificate risk, and interest preserved

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Why DMD

• Procedural discipline → fewer adjournments, faster outcomes

• Evidence-led arguments tied to pleadings, risk, disclosure volume and outcome

• Specialists in HDR & MOD NIHL where disclosure and expert work are heavy

• Free first Bill to settlement—judge us on recovery

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Typical arguments we run (and win)

Rates & grades

• SCCO benchmarks + locality; Grade uplift where conduct/complexity justified

• Trainee/paralegal time: kept in where genuinely non-mechanical and supervised

Necessity & duplication

• Multiple attendances traced to opponent delay or statutory breaches (e.g., Awaab timelines in HDR)

• File-building tasks cross-referenced to pleadings / orders / disclosure

Proportionality

• Present value, risk, complexity and outcome; ring-fence admin from strategic work

Disbursements

• Surveyor/ENT/audiology/records: vouchers + short necessity narratives; market comparisons

Part 36

• For receivers: beat your own 36 → indemnity period and 36.17 add-ons

• For payers: Calderbank/36 to cap exposure and drive concessions

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Our process

1. Review Bill & vouchers — risk map and settlement route

2. Draft PoDs / Replies — exhibits, authorities and model concessions

3. Negotiate — to a payable figure with interest preserved

4. Escalate if needed — Default Costs Certificate or Detailed Assessment (advocacy/counsel)

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What we need

• Bill/e-Bill (Precedent S where used), time records, disbursement invoices

• Key orders/pleadings, budgets (if any), and correspondence relevant to necessity

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Outcomes you can expect

• Higher net recovery (receiving) / reduced exposure (paying) with fewer write-offs

• Faster settlements via disciplined procedure and targeted concessions

• Clear audit trail for DA if the matter must be heard

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Pricing & free trial

Free first Bill to settlement. After that, £500 all-in per file (drafting + negotiations + settlement paperwork). 5-day SLA. Costs Lawyer-led. UK-wide, paperless.

CTA: Send a live costs file → info@dmdcosts.co.uk • +44 7724 108 587



FAQs
Can you step in after weak PoDs?
Yes—supplement and re-focus arguments.
Do you handle disbursement challenges?
Yes—experts, records, travel, restoration/tracing.
What about interest?
We plead and preserve it where applicable.
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