Settlement offer note for client instructions

Nothing here is legal advice. A draft is a starting point for a qualified person, not a substitute for one.

Use this workflow when you need clear instructions after receiving settlement correspondence, pleadings and an offer. It produces a short client note that separates what the offer says from what you need the client to decide.

Nothing here is legal advice. The note is a draft work product for review by a qualified person. It is not a substitute for that review.

Set up the matter file

1. Create a working folder or matter workspace for the offer. Add only the documents needed to explain the current position:

   • the settlement offer and any covering email or letter;
   • the latest relevant pleadings or statements of case;
   • any correspondence that changes the offer, deadline or scope;
   • the client’s previous instructions, if they identify non-negotiable points;
   • a short case summary if the documents do not plainly identify the parties and claims.

2. Name each document by date, sender and document type. For example, 2026-08-20 Claimant solicitor offer letter. Keep the original files separate from extracted text.

3. Remove material that is not needed for the task. Do not include unrelated personal data, other clients’ information or internal comments that do not bear on the offer.

4. Check the current capabilities and document-handling requirements for the model you are using in the xAI documentation. Availability and limits are version-dependent. Follow your firm’s confidentiality, retention and information-security procedures before uploading matter material.

Extract the offer before asking for analysis

Give the model a narrow first task. Ask it to produce a factual extraction, not advice or a recommendation. This reduces the risk that an attractive summary hides a condition in the source text.

Use a prompt such as:

Read the attached settlement offer, covering correspondence and pleadings.

Create a factual extraction only. Do not advise on acceptance, rejection or merits.

Use these headings:
1. Parties and proceeding
2. Offeror and offeree
3. Exact offer terms
4. Money, payment timing and any tax wording
5. Costs wording
6. Confidentiality, non-disparagement, releases and admissions
7. Discontinuance, consent order or procedural steps
8. Conditions and documents to be signed
9. Deadline, time zone and stated consequence of non-acceptance
10. Points said to remain unresolved

For each item, give the source document name, date and page or paragraph reference. Quote exact wording for the deadline, costs, release and acceptance mechanism. Mark missing information as 'not stated'.

Keep the output alongside the source documents. Do not treat it as the final note.

Reconcile the offer against the case position

1. Compare the extraction with the latest pleadings and correspondence. Identify every point that affects what the client is being asked to give, pay, do or stop doing.

2. Ask the model to make a comparison table. Limit it to differences that need an instruction or could affect implementation. For example:

Topic	Offer says	Current case position	Instruction needed
Claims	Identifies claims to be discontinued	Pleading includes additional relief	Confirm all claims covered
Costs	States each side bears own costs	Costs are claimed in pleading	Decide whether wording is acceptable
Payment	Sum and payment period stated	No bank details in offer	Confirm payee and payment route
Release	Draft release is required	Scope not yet agreed	Identify entities and claims to include or exclude

3. Review the table against the actual documents. Correct any paraphrase that changes meaning. Add paragraph references where the client may need to inspect the wording.

4. Separate factual gaps from legal or strategic questions. A missing bank account is a factual gap. The consequences of a release are a matter for qualified review and client instruction.

Draft the client instruction note

Write for a client who needs to decide what to do, not for the court file. Keep the note short. Aim for one to two pages unless the offer has several linked documents.

Use this structure:

1. Purpose and deadline: state that the note seeks instructions on the offer. Give the stated response deadline, time zone, acceptance method and any immediate action needed to preserve time.
2. What is offered: set out the payment or non-monetary terms in plain language. State who is to do what, and when.
3. What you would give or do: cover discontinuance, releases, confidentiality, admissions, announcements, costs and procedural documents.
4. What remains unclear: list missing schedules, undefined terms, inconsistent dates or documents not provided.
5. Decisions required: ask focused questions that can be answered. Avoid asking the client simply whether they “accept the offer”.
6. Next step: state what you will do once instructions arrive, such as prepare a response, seek clarification or draft agreed documents for review.

Use direct questions, for example:

• “Do you authorise us to seek an extension of the response deadline?”
• “Is payment of the stated sum acceptable in principle, subject to review of the release wording?”
• “Should we seek to exclude [named entity or claim] from the proposed release?”
• “Do you approve the proposed confidentiality obligation, or are there disclosures we need to preserve?”

Do not state that the client should accept, reject or counteroffer. Record options and questions for the qualified person and client to consider.

Check the note before sending it

Read the original offer beside the draft. The most important errors are often small: a deadline, a condition precedent, an omitted release party or a costs term hidden in a covering letter.

If you see this	Check this	Do this before sending
A deadline in the note	Exact date, time zone and acceptance method	Confirm against the offer and calendar the internal review point
A monetary figure	Currency, whether inclusive of costs or tax, and payment period	Copy the stated wording or identify the uncertainty
“Full and final settlement”	Claims, parties, affiliates and unknown claims covered	Escalate the scope for qualified review
A proposed order or deed	Attached draft and signing requirements	Confirm it is included and identify who must sign

Check that the note names the correct parties, proceeding and offer date. Check that every open question is genuinely unanswered by the documents. Remove invented explanations, missing-source assumptions and confident language where the source is unclear.

A useful test is this: could a colleague locate the source for every material statement in under a minute? If not, add a reference, quote the term or revise the statement.

Send and record the handover

1. Send the note through the approved client communication channel.
2. Attach or link the offer and any document the client must read to answer a question.
3. State the response deadline prominently in the message subject or opening line.
4. Record when the note was sent, what instructions were requested and the internal owner for follow-up.
5. When instructions arrive, compare them with the questions in the note. Identify unanswered points before preparing any response.

When the workflow does not work

Stop and narrow the task if the documents conflict, pages are missing, the offer refers to unseen attachments, or the deadline is unclear. Ask for the missing document or prepare a short factual list of discrepancies for the supervising lawyer.

If the model merges parties, invents a term, omits a condition or cannot provide a source reference, discard that part of the output and return to the original documents. Use the model again only for a bounded extraction or redraft after the factual record has been corrected.