Often, while writing, you will leave gaps to fill in later.

It is useful to have a standard bit of text, such as ‘xxx’ to use as a placeholder. Every time you leave a gap, use a placeholder to mark it. Then you can use the ‘find’ or search function to quickly locate the gaps.

This has two useful functions. Firstly, you can quickly find out what you have left to do. Secondly, when you think you are finished, you can check that there is nothing left undone.

Sometimes you really have to complain to the tribunal about how the other side has behaved – in order to ask for costs, for instance, or to explain your inability to do something you are supposed to have done. But don’t be too trigger-happy, especially about minor things. There are a lot of pit-falls in litigation, and you may find yourself in need of the tribunal’s or the other side’s indulgence at some point. If you’ve thrown a hissy fit every time the respondent has done anything a little bit late, or vaguely careless or annoying, you’ll find them much less sympathetic when it’s you having difficulty complying with a deadline or getting your witnesses to the tribunal at the right time.

This is a particular instance, of course, of the general rule about only fighting the battles you actually need to fight in order to win the case.

The eighth edition of Tamara Lewis’ Employment Law: An Advisors Handbook has been published by Legal Action Group. It remains the best single volume guide to employment law and both of us keep a copy to hand.

It’s available from most legal book shops, direct from LAG or from Amazon. If you follow the link below, about 5% of the purchase price will be donated to the Free Representation Unit.

We are working on the manuscript of the third edition of the book, which should be available in legal bookshops and from the publisher in late December.

The second edition is now out of print, and we’ve noticed that second hand copies seem to have changed hands on the Internet for over £100. If you can wait about another 9 weeks, you can have a brand new 3rd edition for a much more reasonable £35. You can pre-order from Amazon using the link on the right hand side of this page.