Client Instruction Schedule

Purpose

Clients in document-heavy disputes often freeze when asked open-endedly for "their comments". This skill produces a client instruction schedule: a landscape Word table borrowing the discipline of a Scott Schedule, but written to the client in plain English, with one row per disputed issue and specific, mostly closed questions. It is paired with a short covering note telling the client how to complete it. Positions are sourced precisely to statements, letters and exhibit pages, so that a court-facing Scott Schedule can later be drafted from it far more easily (the client's plain-English answers will still need to be turned into pleaded positions — the schedule is a quarry, not a conversion).

Important limits

This skill drafts a working document for a solicitor to review, amend and approve. It does not give legal advice, it must not be sent to a client without human review, and every draft it produces carries a banner saying so. The solicitor remains responsible for the accuracy of every position, reference and question in the schedule. Four further limits apply:

• Confidentiality first. The skill reads an entire litigation folder, including counsel's advice. Before running it, check the firm's AI and confidentiality policy permits loading these papers into the tool in use, and anonymise or exclude material where policy requires.
• Witness evidence (PD 57AC). The schedule uses mostly closed questions and shows the client the other side's position before asking for their recollection. If any answer may later feed a trial witness statement, the solicitor should consider Practice Direction 57AC before sending: putting the opponent's account to the client may be criticised as leading on important disputed matters. Consider generalising or removing the "other side's position" column for contested recollection issues, and keep a record of what documents the client was shown.
• Client suitability. Confirm with the supervising solicitor that a written schedule suits this client. Some overwhelmed clients are vulnerable clients for whom this format is the wrong tool and a phone attendance is the right one.
• Residual risk. The verification steps below reduce, but do not eliminate, the risk of hallucinated references, unfair paraphrase and silently omitted issues. The coverage map (step 3) exists so the reviewing solicitor can see what was left out, not only what went in.

Jurisdiction and register

English law (England & Wales). UK spelling. £ for currency. No CPR jargon or statutory citations in anything the client must read or complete — "the court's disclosure order", not "the Order of ICCJ [X] under CPR 3.1(7)". Document references (e.g. "Mr [X]'s 2nd statement, para 22") are fine: they are what makes later conversion to a Scott Schedule possible. Practitioners elsewhere can adapt the register, but the plain-English discipline is the point everywhere.