Thank you for the response. Is it okay for me to ask for information prior to mediation which was not referred to in the defence, for example how the company calculates daily rate of holiday pay? Also, the defendant admitted in its defence that it has underpaid payment in lieu but did not make a formal part admission using N8? Form and make payment, they asked for a full and final settlement agreement which I rejected; could they still make the payment before the hearing without my acceptance? I don't want them to do this, as I'm claiming damages for breach of contract as they haven't made the contractual Pilon . Finally, if the defendant owed in fact £200 more holiday pay than I claimed in the particulars of claim, would a judge award a higher figure than originally claimed for at the hearing without prior amendment of particulars of claim?
Thank you for your assistance.