Sending Instructions as PDFs in civil cases

Trial bundles are still generally delivered in hardcopy form (even if a bookmarked PDF copy is also provided) but instructions to barristers to advise or to draft documents are increasingly being sent in PDF form only. Individual barristers will prefer to do different things when they receive instructions in PDF form. Some will print everything out, some may work entirely from computer, and many will print out key documents but refer to other documents on their computer. But even those barristers who instinctively print everything out will very often prefer to receive instructions in PDF form because it means they are received earlier and can be printed wherever the barrister happens to be at the time.


Traditional Paper Instructions

The traditional way of assembling paper instructions involved inserting cardboard tabs before each document. Tab 1 might contain a copy of the Register of Title for one property, Tab 2 the Register of Title for another property, Tab 3 a conveyance dated 1 September 1950, etc. Usually there is one tab for each key document, and then some tabs might contain groups of documents such as inter partes correspondence. The Instructions to Counsel are then accompanied by a typed List of attachments for Counsel by means of TAB numbering which lists each document with its tab number - e.g.

Tab 1        Register of Title SY123456

Tab 2        Register of Title SY654321

Tab 3        Conveyance dated 1 September 1950

...

...


Tab 20        Inter partes correspondence


Individual documents are then referred to in the Instructions to Counsel either by description (e.g. Conveyance dated 1 September 1950) or by tab number (e.g. Tab 3).


PDF Instructions         

When sending Instructions to Counsel as a PDF by email it is tempting to attach to the email the individual documents referred to simply by tapping attach and selecting the documents from your computer folder, but this is not generally a good idea for two reasons. First, whatever order you attach the documents to the email in, when they are downloaded by the recipient they will appear in a computer folder in alphabetic order according to the file name of each document and (unless all the documents have filenames commencing with the document date in yyyy-mm-dd format) that will not be chronological order. Secondly, the filenames of the PDFs, as they currently exist on your computer, are probably not really descriptive names, such as Letter Smith to Jones but probably in abbreviated form, and quite often there may be no consistent style of abbreviation because PDFs, using an different abbreviated naming system, which are received by email from the other side, will probably have been stored "as is".     

So some work will be necessary to arrange the documents accompanying the PDF Instructions to Counsel. Two ways in which this can be done are explained below. The first method is the tabbed method, following as closely as possible the way in which traditional paper instructions are arranged. If you are used to the traditional paper method, this first method is probably the easiest to follow, but the second method, explained below, is probably more efficient once you get the hang of it.


Method 1 

Make PDF copies of the documents and rename the copies so that they each contain the tab number followed by a descriptive name - generally the kind of concise name you would have typed up on the List of attachments for Counsel by means of TAB numbering, like this:-

Tab 3.  Conveyance dated 1 September 1950

Renaming all the PDF copies might take a little while but when you have done it you can get the computer to generate a list, rather than typing up a list, so it is swings and roundabouts.

(To make a tab containing more than one document, you can use www.sejda.com/merge-pdf. Upload the documents, drag them into the correct order, tap Merge PDF files. Download the resulting PDF and rename it as appropriate - e.g. Tab20. inter partes correspondence.)   

Once you have a PDF for each tab load them using www.sejda.com/merge-pdf, tap More options and select Bookmarks...One entry each doc and Table of Contents...Based on file names and tick Add filename to page footer. Then tap Merge PDF files. Download the resulting PDF. This PDF will contain a table of contents listing the tabs and there will be a PDF bookmark for every tab.

You can then send this bookmarked PDF, together with the Instructions to Counsel, by email. If the bookmarked PDF is too large to send by email you could load it to Filemail using the Send as link option and then send just the Instructions to Counsel by email pasting into the email the FileMail link so that the recipient can download the bookmarked PDF from FileMail.  


Method 2

Method 2 is similar to method 1 except that a document date in the form yyyy-mm-dd is used. The advantage is that you do not need to organise documents in tabs as the documents will automatically appear in chronological order.  

Make PDF copies of the documents and rename the copies so that they each contain a descriptive name starting with the document date in yyyy-mm-dd format like this:-

1950-09-01 Conveyance

Renaming all the PDF copies might take a little while but when you have done it you can get the computer to generate a list, rather than typing up a list, so it is swings and roundabouts.

Load the PDFs using www.sejda.com/merge-pdf, tap More options and select Bookmarks...One entry each doc and Table of Contents...Based on file names and tick Add filename to page footer. Then tap Merge PDF files. Download the resulting PDF. This PDF will contain a table of contents listing the documents and there will be a PDF bookmark for every document.

You can then send this bookmarked PDF, together with the Instructions to Counsel, by email. If the bookmarked PDF is too large to send by email you could load it to Filemail using the Send as link option and then send just the Instructions to Counsel by email pasting into the email the FileMail link so that the recipient can download the Bookmarked PDF from FileMail.  


This page was lasted updated in October 2019          Disclaimer