without-prejudice-drafter-andrew-bird

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SKILL.md

/without-prejudice-drafter

  1. Identify the correct footing: open, WP, or WPSATC.
  2. Apply the right header convention. WP is not protected just because labelled — the substance must be a genuine settlement attempt in an existing or contemplated dispute.
  3. Surface the Unilever exceptions: WP protection is not absolute.
  4. Draft accordingly. Keep open and WP material in separate documents.

Without prejudice / WPSATC correspondence

The three footings

Footing Disclosure at trial Use
Open Yes — fully admissible Statements of case, demands, pre-action letters not yet in negotiation
Without prejudice (WP) No — inadmissible to prove liability or quantum Genuine settlement negotiations
Without prejudice save as to costs (WPSATC) / Calderbank Inadmissible on liability/quantum; intended to be admissible on costs after judgment Settlement offers where the offeror wants costs protection but cannot use CPR Part 36 (e.g. Employment Tribunal) or wants Calderbank flexibility
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