In case of a money recovery suit these are:
Ascertain the value of your claim with a proper statement of accounts that takes into criteria the principal monies, the interest monies as applicable and any others such as liquated damages, penalty etc.
Obtain an acknowledgment of liability from the person who owes monies when the going is Good!
Feel free to take counsel at the very first instance when you foresee a rough transaction/ dispute, so that you don't end up missing out anything vital.
Get to know from your counsel which relevant provision/s of law would be of support to you.
Find out where the cause of action to lay your claim would be, in other words before which court of law in the given jurisdiction.
See that your claim is put forth well within the statutory limitation provided by law for the said transaction. While so take care to see that all court fee is paid without any deficit at the time of filing the suit itself.
Logically list out in points the manner in which the transaction was conducted and as to how the liability arose i.e. facts of the case, and the relief/s you seek (see also point no.1 supra) to assist your counsel quickly draft a plaint.
Most importantly (could be resolved in time vide point no.3 supra) see to that you have a justifiable written contract with the party transacting so as to avoid any ambiguity while dealing with the matter once a dispute arises.
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