DCS - 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 copies of documents to be arranged in the Trial Bundle in a section or sections in chronological order. Some documents may have been exhibited and, if they are, the exhibits may be included, for reference, in a special section at the end of the Trial Bundle named 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 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 Exhibits section but to the copy of the document in the chronological sections.

See here for a video showing how to add links


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This page was lasted updated in May 2020. Disclaimer