[Insert name and address of recipient] [Insert date] PRIVATE, CONFIDENTIAL AND PRIVILEGED Dear [insert name of recipient] [Insert case name and claim number] We [are a firm of solicitors and] act for [name of client], your [former] employer. We write further to [our OR [name of (former) employer]] letter of [insert date][, a copy of which is enclosed for ease of reference]. In addition to [the Company’s OR the organisation’s] obligations to preserve any 'documents' which might be relevant to the proceedings, [the Company OR the organisation] must also, among other things, disclose to its opponent[s] in the proceedings various 'documents' relevant to the dispute and, in particular, those which are or may be ‘adverse’ to its case. A document is ‘adverse’ if it, or any information it contains: contradicts or materially