Bundles - 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 just by an exhibit number - e.g. I refer to a photo which I took of the garden on 3 September 1995 marked JJS1. It is usual for non-digital photos to be referred to just by Exhibit number (since they contain no simple identifying feature) and it is usual for most other documents to be referred to simply by an obvious identifying feature and not be exhibited but sometimes other documents are exhibited even though they have an identifying feature.

It is usual for copies of photos and non-photo documents to be arranged in the Trial Bundle in chronological order. Some documents, particularly non-digital photographs, may have been exhibited and, if they are, it is usual to include the exhibits, for reference, in a special section at the end of the Trial Bundle named All Exhibits. However copies of all the documents in the exhibits should be included individually in the chronological sections and it is the documents in the chronological sections 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 document, the link should be not to the any copy of the document in the All Exhibits section but to the copy of the document in the chronological sections.

How to add links using DCS

See here for a video showing how to add links


This information page is mainly designed to be used by clients of John Antell who have entered into an agreement for the provision of legal services, with the intention that it be used in conjunction with specific advice to the individual client about the individual case. If you are not a client please bear in mind that in order to be reasonably concise I have had to leave some details out - details which are likely to affect what the procedural law would say about your own situation, so please do not rely on the above but contact me for advice.

The information on this page about specific computer techniques is provided for information purposes only. Every reasonable effort has been made to ensure that the information is accurate and up to date at the time it was written but no responsibility for its accuracy, or for any consequences of relying on it, is assumed by me. You should satisfy yourself, before using any of the techniques, software or services described, that the techniques are appropriate for your purposes and that the software or service is reliable.

This page was lasted updated in May 2019. Disclaimer