[ON YOUR LETTERHEAD]

without prejudice SAVE AS TO COSTS

[SUBJECT TO CONTRACT]

[Insert date]

[Insert name and address of other party’s solicitor]

Dear [insert contact name]

[Insert subject of letter]

We refer to our open letter of [today’s date OR [insert date]].

1. 1. 1

      As set out in that letter, both we and our client are confident that, should your client issue proceedings in respect of its alleged claim detailed in your letter of claim dated [insert date] (the ‘Letter of Claim’), our client would be wholly successful in defeating such claim. [Were your client to issue such claim, our client would both defend the claim and issue a counterclaim in the terms set out in our letter dated [insert date of letter setting out threatened counterclaim] (the ‘Counterclaim Letter’) and we are equally wholly confident that our client would