Start with what the other side disputes
For each disputed point, identify what would establish it. A payment confirmation may show that money moved; the agreement or exchange of messages may explain why it was paid. If the dispute concerns defective work, proof of payment alone does not establish the defect or the cost of correction.
A useful case explanation connects the promise, its performance or breach, the resulting loss and the remedy sought. Organise the material around those questions.
A message needs its context
Preserve the whole relevant conversation and the original files. A cropped screenshot can hide the reply or make the sender and date unclear. Explain which sentence matters and what it establishes. Where authorship, translation or alteration is disputed, counsel can identify the further proof needed.
Do not edit an original to make it clearer. Make a separate working copy for annotations and retain the original in its existing form.
Act before third-party evidence disappears
CCTV may be overwritten and a witness may become unavailable. Identify the holder, the relevant time period and the fact the material would prove. Counsel can assess a prompt preservation request or an application for the court to obtain particular evidence.
Use lawful access. A dispute does not give you general permission to enter another person’s account or obtain confidential school, medical or business material by deception.
Prepare the submission, not a pile of attachments
Each attachment should have an identifiable purpose in the claim or response. Discuss admissibility, any necessary translation and when it must be submitted. If important material cannot yet be obtained, explain who holds it and what procedural assistance is requested.
Example: a contractor says the work was accepted. The relevant answer may be the handover wording, the customer’s timely complaint and an expert’s explanation of the defect. Hundreds of unrelated photographs can obscure those three points.
Official sources
Sources checked on 22 October 2026.
Build the proof around the disputed point
Explain what the other side denies. Start with the agreement, the relevant exchange and the proof of performance or loss so the lawyer can identify the missing link.