Client Instruction Schedule

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.

Workflow

1. Read everything, identify by content

• Read every document in the case folder. Identify documents by their content, never by filename — filenames lie (exhibit bundles stamped with the wrong witness's initials, cover sheets certifying the wrong exhibit name). Content-based identification can also be wrong: record the basis for each identification in the report-back (step 10) so the solicitor can check it.
• Note any document that is referenced in the papers but absent from the folder (a statement that mentions an exhibit not supplied, correspondence referring to an enclosure). List these in the report-back — the folder cannot be assumed complete.
• Scanned PDFs with no text layer must be OCR'd (pdftoppm at 200dpi + tesseract, pages in parallel). Verify OCR'd figures and quotations against the page image before relying on them.
• Hash files (md5sum) to find duplicates before reading.
• Note every internal inconsistency found in the papers (dates, exhibit labels, misquoted figures) — these become highlighted solicitor notes (step 6), not silent corrections.

2. Extract the disputed issues

List every issue on which the client's input — an answer, a recollection, or a document — is actually needed. Sources: witness statements on both sides (paragraph by paragraph), counsel's advice (especially "we need instructions on…" passages), solicitors' letters to the client with unanswered requests, and the client's own partial responses. Exclude:

• procedural and legal argument (no client input needed);
• costs and strategy points;
• anything already answered in the papers — but exclude only where a complete answer exists and can be cited; cite it in the exclusions list (step 3).

Decision points awaiting the client (e.g. "do you agree to instruct an accountant?") count as rows; broad strategy decisions belong in the covering note or a separate advice, not the schedule.

3. Build a coverage map (source-to-row)

The most dangerous failure of this workflow is a silently missed issue: the reviewing solicitor sees a polished table and has no way to see what was dropped. So, before drafting, produce a source-to-row map: every witness-statement paragraph raising a factual dispute, every "we need instructions on…" passage in counsel's advice, and every unanswered request in correspondence must appear as either (a) a schedule row, or (b) an entry in an "Issues considered and excluded" list with a one-line reason each. That exclusions list goes into the schedule document itself, as a solicitor-notes appendix after the table (same highlighting convention as step 6), not only into the chat report — the artefact under review must carry its own account of what it left out.

4. Cross-check against what is already held

For each issue, check whether the material about to be requested already exists in the folder. Never ask the client for a document the firm already holds — instead ask them to identify the relevant entries in it (e.g. "the bank statements are already with us (exhibit X) — point us to the matching entries"). The "Evidence we already hold" column is the enforcement mechanism: filling it honestly exposes any lazy request.