Adding cross-references to witness statements in a trial bundle


Witness statements typically refer to documents and, in a Trial Bundle, where a witness statement refers to a document, a link to the document, where it appears elsewhere in the bundle, should be added in the right hand margin of the witness statement. 

In witness statements, sometimes documents are referred to by some obvious identifying feature such as the email from from John Smith to Peter Jones timed at 13.10 on 10 July 2017 and sometimes a document is referred to by an exhibit number - e.g. I refer to a photo which I took of the garden on 3 September 2017 marked JJS01. It is usual for photos to be referred to as Exhibits and it is usual for documents other than photos to be referred to simply by an obvious identifying feature and not be be exhibited but sometimes non-photo documents are exhibited.

It is usual for copies of non-photo documents to be arranged in the Trial Bundle in chronological order. Some non-photo documents may have been exhibited and, if they are, it is usual to include the exhibits, for reference, in a special section named All Exhibits. However copies of the documents in the non-photo exhibits should be included in a separate chronological section and it is the documents in this chronological section which will generally be referred to at trial, not the All Exhibits section. Consequently when adding a link in the right hand margin where a witness statement refers to a non-photo document, the link should be not to the copy of the document in the All Exhibits section but to the copy of the document in the chronological section.

It is usual for photos to be in a separate Photos section in chronological order. If, as is usual, each photo exhibit contains a single photograph and no other documents (or several photos but all taken on the same day) the photo Exhibit itself can be in the Photos section. Otherwise copies of the individual photographs would be in the Photographs section without Exhibit frontsheet, but in every case when adding a link in the right hand margin where a witness statement refers to a photo document, the link should be to the photo in the Photos section, not to any document in the All Exhibits section.

How to add links using DCS

See here for a video showing how to add links


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This page was lasted updated in April 2018. Disclaimer