It sounds as though the court has directed that she (her solicitors)
produce a summary lof the offers which have been made, up to now, by each
party.
If this is so, this would include them setting out any
proposals he has made, so it would not be necessary for him to put anything
in writing although of coruse if he feels that the summary which her
solicitor produices is inaccurate he would be able to respond to it if he
wishes.
I am a bit concerned that he's saying there is no
changce of his cooperating with her
solicitors to give information. He has an
ongoing duty to provide full & frank disclosure, so if he refuses to
cooperate and to provide infoarmation whichis relvent and yes, like it or
not, his PI claim is relevent) then he is likely to cause further delays
and make it harder to reach a settlement.