Property dispute: prepare counsel briefing notes

I am seeking a freelance UK solicitor (property litigation focus) to review a defined “core bundle” of case documents and produce a concise, legally rigorous briefing note for counsel (Direct Access).

Objective
• Read the core bundle and strip the matter back to its determinative legal issues.
• Identify the strongest “show-stopper” points in UK property law.
• Produce a clean route-map so counsel can present a short, technical argument by reference to a limited set of key documents.

Deliverables
1. Core legal “essence” note (8–12 pages)
o A structured route-map of the decisive issues, aligned to the Court-defined trial issues:
(1) Title/status of a newly registered title and what (if anything) was enforceable pre-registration
(2) Chain of indemnity / standing to enforce (benefit passing / annexation / assignment)
(3) Right of way + a later deed containing the operative contribution machinery
o Identify the governing statutory provisions and leading authorities for each issue (with pinpoint citations where possible).
o Distil the legal tests the judge must apply, and explain them clearly in plain English tied to the documents.
2. “Show-stopper” list (1–2 pages)
o Bullet list of the strongest points that defeat the claim or materially narrow it.
o For each show-stopper: (i) the rule/test, (ii) the authority, (iii) the document(s) that prove the factual predicate.
3. Pleadings and proof audit (4–6 pages)
o Check the operative pleading(s) against the title/deed documents and witness evidence:
 what is actually pleaded;
 what must be proved at trial;
 what is missing (non-pleaded bases, omitted deed machinery, missing chain documents, plan/extent gaps).
o Identify any procedural/candour points that properly support submissions on confinement to the pleaded case, adverse weight, and/or costs conduct.
4. Counsel briefing pack (draft-ready, 6–10 pages)
o A counsel-facing note suitable to hand to counsel:
 issues list + recommended order of argument;
 key documents by page reference;
 proposed short oral submissions on each major point;
 list of questions counsel should ask and documents that must be demanded if missing.
Scope and constraints
• Work from the supplied “Core Bundle” only online.
• UK law only: Land Registration Act 2002 (including ss.24/27 and registration gap implications), enforceability of positive covenants, benefit & burden principles, annexation/assignment/chain of indemnity, and deed construction.
• Focus on clarity and authority: this must be understandable to a judge who may not engage well with abstract argument. I need crisp legal explanation tied to the documents.
• This is an opinion + counsel briefing route-map, not advocacy drafting.
Bundle contents (high level)
• Court orders (including an order listing the trial issues)
• Claim/pleadings (operative versions), defence and reply
• Land Registry titles and plans (including roadway titles)
• Key deed extract(s) including the operative contribution machinery
• Key correspondence (including mediation-stay period correspondence)
• Selected witness statements/exhibits
Timescale and format
• Please confirm availability to deliver within 5 working days of receiving the bundle.
• Deliverables in Word (.docx) plus PDF, with a short bibliography of authorities.
• Include an “assumptions/limits” section stating what documents (if any) you expected but were not provided.
Commercials
• I need a capped-fee proposal (ceiling agreed in advance) with an estimated hour range and your hourly rate.
• Please provide two options:
Option A: Essence note + show-stoppers + pleadings/proof audit
Option B: All deliverables including the counsel briefing pack draft
Conflict / independence
• Please confirm no conflict of interest with any party/entities involved.
If you are interested, please reply with:
• relevant experience (property litigation, covenants, title/standing disputes, LRA 2002 issues),
• proposed fixed/capped fee and delivery timeline,
• any initial questions you would need answered to start.