Formatting a Document Bundle for UK County Court
Discussion
Hi all,
I'm preparing for a small claim in a UK County Court and would really appreciate some up-to-date advice on how best to format a document bundle.
I’ve assembled six documents:
1. Skeleton Argument
2. Witness Statement 1 (personal statement)
3. Witness Statement 2 (personal statement)
4. Witness Statement 3 (analysis of correspondence)
5. Evidence Bundle 1 (letters, plans, photos)
6. Evidence Bundle 2 (emails only)
All documents were prepared in Word and exported to PDF. The total comes to about 250 pages. Each of the three witness statements ends with a signed page (with no other substantive content on that page). These signature pages will be scanned and reinserted into the relevant PDFs before merging into the final bundle.
Here’s how I’ve structured things so far:
• The final PDF will include a front page (Master Index) listing each document and its corresponding page range.
• Page numbers will run continuously from the start of the Skeleton Argument (page 1) through to the end (page ~249), shown in the bottom centre of each page.
• Each document will also retain its own relative page numbering (e.g., Page 1 of 10) in the bottom right corner.
• Longer documents include a table of contents (TOC) that refers to the continuous PDF page numbers (not their internal page numbers).
• The PDF text will remain fully searchable (apart from the final signature pages).
• The hard copy will be printed single-sided, bound in a ring binder, and separated with coloured dividers.
Does this sound about right for a County Court bundle?
Any feedback on potential pitfalls - or things the court might prefer to see done differently, would be hugely appreciated.
I'm preparing for a small claim in a UK County Court and would really appreciate some up-to-date advice on how best to format a document bundle.
I’ve assembled six documents:
1. Skeleton Argument
2. Witness Statement 1 (personal statement)
3. Witness Statement 2 (personal statement)
4. Witness Statement 3 (analysis of correspondence)
5. Evidence Bundle 1 (letters, plans, photos)
6. Evidence Bundle 2 (emails only)
All documents were prepared in Word and exported to PDF. The total comes to about 250 pages. Each of the three witness statements ends with a signed page (with no other substantive content on that page). These signature pages will be scanned and reinserted into the relevant PDFs before merging into the final bundle.
Here’s how I’ve structured things so far:
• The final PDF will include a front page (Master Index) listing each document and its corresponding page range.
• Page numbers will run continuously from the start of the Skeleton Argument (page 1) through to the end (page ~249), shown in the bottom centre of each page.
• Each document will also retain its own relative page numbering (e.g., Page 1 of 10) in the bottom right corner.
• Longer documents include a table of contents (TOC) that refers to the continuous PDF page numbers (not their internal page numbers).
• The PDF text will remain fully searchable (apart from the final signature pages).
• The hard copy will be printed single-sided, bound in a ring binder, and separated with coloured dividers.
Does this sound about right for a County Court bundle?
Any feedback on potential pitfalls - or things the court might prefer to see done differently, would be hugely appreciated.
When I was in County Court recently, my solicitor submitted the evidence as a statement, and all the supporting evidence (400+ pages) put into a PDF document with page numbers ('paginated bundle' is the term). There were no indexes, or anything fancy; you can easily refer to a particular document with the page number.
I would add copies of the claim form etc. at the front of the bundle along with any orders made - such as directions etc- County courts are hopelessly under resourced and things can and do go missing.
Best of luck- main thing is to take hard copies which I note you are and originals of any documents if you have them.
Best of luck- main thing is to take hard copies which I note you are and originals of any documents if you have them.
Ganglandboss said:
When I was in County Court recently, my solicitor submitted the evidence as a statement, and all the supporting evidence (400+ pages) put into a PDF document with page numbers ('paginated bundle' is the term). There were no indexes, or anything fancy; you can easily refer to a particular document with the page number.
Is there not a 50 page limit if sent by email or did he send by post?LimmerickLad said:
Ganglandboss said:
When I was in County Court recently, my solicitor submitted the evidence as a statement, and all the supporting evidence (400+ pages) put into a PDF document with page numbers ('paginated bundle' is the term). There were no indexes, or anything fancy; you can easily refer to a particular document with the page number.
Is there not a 50 page limit if sent by email or did he send by post?Thanks for the replies. It seems there is some leeway and that the courts are not overly pedantic about the bundle.
I haven't yet taken legal advice but with the internet these days there is a lot of help available. Once I've formatted the bundle as best I can I will need an expert to have a quick look at it.
I believe my skeleton argument (and documentary proof) is devastating to the defendant. The main legal mechanisms will be: beneficial ownership, proprietary estoppel, specific performance.
I have already prepared a list of cross exam questions for the defendant. Over 100 very hard hitting leading questions. How much time would the court give me to cross examine the defendant - more than 1 hour? There might be one or two other witnesses on his side - but 20 mins each would be enough to question them.
I haven't yet taken legal advice but with the internet these days there is a lot of help available. Once I've formatted the bundle as best I can I will need an expert to have a quick look at it.
I believe my skeleton argument (and documentary proof) is devastating to the defendant. The main legal mechanisms will be: beneficial ownership, proprietary estoppel, specific performance.
I have already prepared a list of cross exam questions for the defendant. Over 100 very hard hitting leading questions. How much time would the court give me to cross examine the defendant - more than 1 hour? There might be one or two other witnesses on his side - but 20 mins each would be enough to question them.
agtlaw said:
Thanks - this was useful.
Mediation is not on the agenda given that the defendant's egregious behaviour (denial of knowledge, refusal to carry out a documented commitment, etc) has shown he is incapable of acting in good faith. So in my skeleton argument I have asked for the court to make the determination (of a boundary line) without input from the defendant. I expect once he sees the weight of evidence against him he will try to negotiate out of court but I will resist this - and I think his documented lies and evasion will count against him.
LouthLad said:
agtlaw said:
Thanks - this was useful.
Mediation is not on the agenda given that the defendant's egregious behaviour (denial of knowledge, refusal to carry out a documented commitment, etc) has shown he is incapable of acting in good faith. So in my skeleton argument I have asked for the court to make the determination (of a boundary line) without input from the defendant. I expect once he sees the weight of evidence against him he will try to negotiate out of court but I will resist this - and I think his documented lies and evasion will count against him.
Many hundreds of pages of stuff sounds excessive but what do I know?
Also, the people here who actually are legally qualified (which I stress is not me) seem to me to be posting very warily of you which makes me wonder if they see signs in you of being a classic pro se nut. I don't mean that in a bad way, I know if I tried to mount a legal case on my own I'd look like one (which is why I would pay a solicitor to do it).
Edited by Somewhatfoolish on Friday 18th April 14:46
I assume the OP means a “small case” not small claims/money claim.
IANAL but I do know that the court will take a very dim view of refusing mediation, may stay the case until you have considered it and even if you win the case they may not award you costs if you have refused mediation.
Court is regarded as the last resort for boundary claims and they very, very much want you to try mediation first.
IANAL but I do know that the court will take a very dim view of refusing mediation, may stay the case until you have considered it and even if you win the case they may not award you costs if you have refused mediation.
Court is regarded as the last resort for boundary claims and they very, very much want you to try mediation first.
charltjr said:
I assume the OP means a “small case” not small claims/money claim.
IANAL but I do know that the court will take a very dim view of refusing mediation, may stay the case until you have considered it and even if you win the case they may not award you costs if you have refused mediation.
Court is regarded as the last resort for boundary claims and they very, very much want you to try mediation first.
As well as compulsory Mediation I would have thought it would require an expert land surveyor (possibly jointly appointed) RICS or similar to assist the Court ....I have been an LIP in High Court and currently due to attend a 2hr Hearing in a small Claims on a separate matter in May, but I am struggling to follow the OP's posts...not even sure he's started a Claim yet let alone had it allocated to a Track, completed N180 Questionnaire etc IANAL but I do know that the court will take a very dim view of refusing mediation, may stay the case until you have considered it and even if you win the case they may not award you costs if you have refused mediation.
Court is regarded as the last resort for boundary claims and they very, very much want you to try mediation first.
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