Hi, this is Jim, thanks for the question.
I have no template but you could say something like this :
FAO: The court manager, claim number:
Name of claimant v name of defendant
I write further to the above matter and to enclose correspondence from the defendant dated (insert date), which was a without prejudice communication to myself.
I ask the court to consider whether to grant summary judgment under CPR rule 24. To remind the court, under that rule:
The court may give summary judgment against a claimant or defendant on the whole of a claim or on a particular issue if –
(a) it considers that –
(ii) that defendant has no real prospect of successfully defending the claim or issue; and
(b) there is no other compelling reason why the case or issue should be disposed of at a trial.
I submit that the defendant has made an offer, the full sum was not offered given they are impecunious. I ask the court to exercise its general case management powers and to grant summary judgment. There is no reason why this case has to continue to trial, using up court time and incurring expense on my part, to include the commission of an expert report. My submission is that the trial judge is likely to interpret the defendant's correspondence as admission of liability, and the only reason why they have not paid this claim in full is that they do not currently have the means.
I thank the court for its assistance and await hearing from you,