Ahead of FDR

Hi

Could I ask for some advice please
I finally have my FDR coming up - my ex is represented by solicitor and barrister
I am self representing:
The court letter states to provide:

1 - a case summary and chronology - do I just states facts/dates leading up to court ?

2 - the parties position statement - is this for me to tell them my case - why I am requesting equality/ non ringfencing of his pension etc?



Any help or guidance would be really appreciated

Many thanks

The case summary should be a neutral setting out of the matter, ideally agreed by both parties. If the other side has a solicitor they should take the lead in preparing this and an agreed chronology. You should see both documents before they go into the bundle and have chance to ask for changes. It is open to you to prepare your own version.

The position statement should support the without prejudice offer you have made. So setting out why (in the context of s25) it is a fair proposal.

FDR is a negotiating hearing. You cannot be forced to settle although you may feel you are being pressured to do so. Go in with three figures in mind. The offer which would be your best outcome, a figure that is a red line below which you will not go and a mid point which is hopefully where you end up.
The offer needs to be a realistic attempt to settle but can include one or two negotiating points that you can concede if necessary.

The judge should give guidance as ro what they think a fair settlement should be based on the bare facts and figures they have in front of them. They may ask some questions but there will not be any rigorous cross examination.

Hadenoughnow

Thank-you so much hadenoughnow for your reply - really appreciate you taking the time to always offer me advice/support.