Disclosing documents means providing copies of the documents each having a concise descriptive filename including the document name and date and also a serial number - "disclosure number", along with a list of the documents ("disclosure list"). If you have already provided a numbered set of key documents, at the Statements of Case stage at the beginning of litigation, the disclosure number should continue, where you left off in the number sequence, when you come to do the main disclosure exercise.
Similarly if you are doing a supplementary disclosure because new documents have come to light after the main disclosure of documents stage, you would continue the numbering where you left off.
The disclosure number order of documents in each disclosure exercise should be some convenient and logical order, usually grouped according to which folder the document is held in, and in chronological sequence within each group. It is important that the disclosure number should be recorded within your document management system, not just in the copies you send out, in case of later query.
An efficient way of accomplishing this is explained below.
The names of each of your documents which you have disclosed (or which are to be disclosed) and the names of each document disclosed by the other side (if any have been so far) should have a prefix such as A, C, D, or R to indicate which is which. A stands for Applicant, C for Claimant, D for Defendant, R for Respondent etc. The capital letter will be followed by one or more lower case letters, a hyphen, and a disclosure number if the document has already been disclosed. For example App-1 App-2 App-3 up to App-19 might be documents listed on, and sent with, the Applicant's statement of case, Ad-20 to Ad-54 documents provided in the Applicant's main disclosure, and As-55 As-56 and As-57 documents sent by the Applicant as supplementary disclosure.
(In complex cases where two cases are being heard together with the Applicant/Respondent being reversed in the second case a slightly different prefix system may be used.)
You will be holding copies of documents in a series of folders within a specialised document management system, such as Bundledocs or Litigation Ready which can download copies having filenames commencing with the date in yyyy-mm-dd format. Or your "document management system" might consist simply of a master set of copy documents for the case, held in a series of ordinary sub-folders on your computer with each document having a filename commencing with the document's date in yyyy-mm-dd format so that the documents appear in sub-folders in chronological order. In either case the procedure for each disclosure exercise is much the same. Do the following for the first folder which contains, or may contain, some documents to be disclosed:
List the documents in chronological order using a filter so that only those documents which are to be disclosed are shown. For example if you have previously disclosed key documents at the statement of case stage and are now disclosing the remaining relevant documents, you can exclude from the filtered folder list documents previously disclosed by using a filter of e.g. NOT *App NOT *Resp (exact syntax may vary between systems). Or if you are doing a supplementary disclosure because new documents have come to light you might have temporarily added tbso (which stands for To Be Sent Out) to the filenames of the new documents (to be replaced by a disclosure number as soon as you have collected all the new documents and are sending them out), in which case you can use tbso as the filter.
Edit the name of every document in the filtered folder list, which you are about to disclose, to add a unique disclosure number. If this is not your first disclosure you should look at the disclosure list you sent out with your last disclosure, note the last disclosure number used on that list, and number the currently unnumbered documents continuing the numbering where the previous list left off.
Select the documents in the filtered folder list (which you have just added numbers to and will be disclosing) and create a ZIP file on your computer containing them. If you are using Litigation Ready you have to do this in two steps: (1) tap Bulk Actions - Create Download - Create (2) when the ZIP download is ready, download it to your computer.
Then repeat the above for any other folder which contains, or may contain, some documents to be disclosed, continuing the adding of unique disclosure numbers in sequence from where you left off with the previous folder. At the end of this process you will have one or more ZIP files on your computer which together contain copies of the documents you will be disclosing (and no other documents).
Create a new Word document.
Start the WinRAR program and list the folder containing the ZIP files you have just created and select the ZIP files all together. Choose Tools - Generate Report and select copy report to clipboard and text, and tap OK. Then Paste into the Word document.
The filenames you now have a list of in the Word document will start with a date in yyyy-mm-dd format. Delimiters need to be inserted so that the date and prefixed disclosure number can be made to appear in separate columns when you create a table and, at the same time, the date needs to be changed to dd-mm-yyyy format to improve readability.
To do this do a Find/Replace ticking Use Wildcards and using a Find of ([0-9]{4})-([0-9]{2})-([0-9]{2}) ([! ]{3,}) and a Replace of @\3-\2-\1@ \4@ Then select all the text and tap Insert - Table - Convert Text to Table and choose separate text at Other @ and tap OK. This will create a table with the document name in the last colum, the prefixed disclosure number in the penultimate column, and the document date in the third-from-last column. Earlier columns may have superfluous data such as a folder name and file size and those columns can be deleted leaving a three column table.
Adjust to create a neat table. You can also add headings to the three columns and add a title above the table. If any of the documents have partial dates indicated by tildes add a note below the table saying e.g.:
Where the exact date of a document is unknown a day-of month of 01 will appear in the date column and the document name contains, highlighted with tilde characters, the approximate date e.g. ~ Jun 2000 ~
Save the completed disclosure list file as a PDF.
If the document management system you are using is Litigation Ready you can go to the Downloads panel and create a sharing link for each of the ZIP downloads which you created previously. You can then send the links by email attaching the disclosure list PDF to your email.
An alternative is to send the ZIP files as attachments to one or more emails, also attaching the disclosure list PDF. You will need to ensure each ZIP file does not exceed your email size limit. Different email systems impose different size limits but 20MB is common.
When sending to the other side in the litigation there may be restrictions on what method you can use if it is to count as "valid service". If you are sending to the tribunal office then you may find that there is an upload facility which the tribunal requires to be used (rather than emailing a download link or emailing documents as attachments).
Disclaimer
This information page is designed to be used by clients of John Antell who have entered into a written agreement for the provision of legal services.
The information about specific computer techniques is provided for information purposes only and you should satisfy yourself, before using any techniques, software or services mentioned, that the techniques are appropriate for your purposes and that the software or service is reliable.
Every reasonable effort has been made to ensure that the information in this page 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.
This page was lasted updated in November 2025. Disclaimer