A useful way to create further particulars when trying to particularize a saga of misdemeanours (normally the stories going back years are connected with discrimination or constructive dismissal) without legal reference was suggested today: Simply set in columns:
2)Facts alleged by Claimant
3)Respondent's answer to those facts
4) Type of breach/discrimination
5)R's legal defence
6)Comparator hypothetical/real if relevant
7)Respondents response to comparator
Not the most exciting of tasks but a necessary one!