Key parts of most litigation include the Statements of Case stage ("pleadings stage") at which usually key documents accompany each party's Statement of Case (list the Statement of Case including a list of the key documents), and then, later, the Disclosure of Documents stage where each party is normally directed to supply the other party with a copy of every other relevant document which it has and a list of the documents. The lists, which will normally be numbered, will identify each document with a concise name and date. Normally the same concise name for the document will eventually be used, together with the date, as a bookmark name in the eBundle used for the final hearing (if the document is one of those selected to be included in the eBundle). It will also appear in the index of the eBundle.
Typically before there is any litigation in prospect, and whilst a legal question or potential dispute is at the early stages of consideration, copies of documents will be collected together in a computer folder and, perhaps, later on, loaded to a document management system. The document management system is used to store documents and can be used to generate lists, such as the disclosure list, and later the eBundle. It ultimately saves work and avoids confusion if the concise name of the document, used first in the filename, is chosen at the outset to be a name which will be suitable for all the later stages right up to inclusion in the eBundle PDF bookmarks and index.
The document name should normally include an indication of the type of document - email, letter, agreement, conveyance, etc. - normally followed (particularly for common document types) by some further brief identifying information, as in the example below. The name, together with the date, should contain enough to enable anyone to clearly identify the document whilst still being reasonably concise bearing in mind that the index of the eBundle will be A4 size and will have to incorporate within its width not only the document name and date but also the eBundle page number, and usually also some reference prefixing the document name: e.g.:-
Letter John Smith to Paul Jones
To get an idea of whether the document name you have assigned is sufficient, together with the date, to enable someone else to easily identify the document, imagine that someone else has a large number of documents, in paper form, spread out on a huge long table in front of them. Of course most people have more sophisticated methods of managing documents than that, but if you think of someone looking along a long table that will help you to think about the general mental process involved in someone looking for a a particular document amongst other documents and verifying that they have found the right document. Our hypothetical person looking along the long table should be able, just given a document name and date, to quickly locate the document and be sure that the document they have found is the right one. This means that the key details in the document name should be such that it is easy for the person looking along the long table to spot the document. Someone can see, even from a distance, that a document is a photo or a letter or an email or some other document type, so you should always include the document type. Then looking closer at a document it is usually fairly easy to spot the date - depending on the document type they can guess roughly where on the page to look for the date. Then to be sure they have the right document they need some easy-to-spot-and-check detail in the document. For an email the obvious detail to quote would be the time of the email and the name of the sender and possibly the first (or only) recipient. So for an email the word Email, the names of sender and recipient and time and date are used for identification. Even if only one email was sent by that sender to that recipient on that day, the time still needs to be included because our hypothetical person looking along the long table needs to be able not only to find an email with the right sender etc. and date but also to be sure that what they have found is definitely the right document and they cannot be assumed to know that there was only one email that day.
If the document is a letter or email or other document with narrative text, generally you should not include in the document name your own summary of what the document actually says. This is for two reasons:
Imagine the person looking for the document among the documents spread out on the long table. If they have to skim read a document to see if its contents correspond to your summary, that will take them extra time.
Although every tribunal case is concerned with some kind of dispute between the parties which will be finally decided by a judge, the tribunal process is designed to be civilised and efficient with as little dispute as possible in the practical preparations for the final hearing. At the final hearing itself and, where appropriate, in statements of case and perhaps witness statements, each party may argue that a particular email should be interpreted, or was interpreted by the witness at the time, in a particular way or that one part of an email is the most important, but before the hearing the tribunal expects the parties to co-operate in disclosing documents and in the compiling of the eBundle and to try to avoid unnecessary contention in such practical preparatory matters. If you attempt, in a document name, to summarise in your own words the content of an email or other document your summary may be (even if you do not intend it to be) contentious. You may characterise an email as making a request but the other side might see it as making a demand or even a threat. Or the other side may feel that you are trying to downplay some aspect of the email by referring to some more prosaic part of it and they may feel that they should refer to it in a way which mentions what they regard as its most significant point. This happens more often than you might expect and at worst it can lead, at the Disclosure of Documents and eBundle preparation stages, to you referring to an email with one name and the other side insisting on using a different name with the potential for mistakes and confusion and time wasted. If, however, you give a email a document name containing the word Email and the names of the sender, perhaps also the name of the first recipient, and perhaps the Subject from the header, that objective information, together with the time and date, can easily be used to identify the document without there being any cause for any fruitless pre-hearing wrangling over the name used to identify the document.
There may be some special cases where you need to mention in the document name what an email or letter says but, if so, you should choose some feature which is easy to check and which is likely to be non-contentious. For example usually a letter would be named like this
Letter John Smith to Paul Jones
and this, together with the date, is normally sufficient as it is not usual for for two letters to be sent by the same sender to the same recipient on the same day (because normally the sender will wait to see if they get a reply in the post in the following days before writing further). However if, unusually, two letters are sent by the same person to the same recipient on the same day the document name for each letter will need to contain some detail to distinguish between them. If both letters have an internal reference number (or title) and the internal reference numbers (or titles) of the two letters are different then the internal reference number (or title) can be used like this:
Letter Smith to Jones (ref AWS/145678)
Letter Smith to Jones (ref FWJ/675567)
but if there is no internal reference number or title (or if there is an internal reference number/title but both letters have the same internal reference number/title) then you may have no choice but to use your own two or three word summary of what each letter is about, like this:
Letter Smith to Jones (details of property)
Letter Smith to Jones (enclosing contract)
If you do have to do this make sure that for the two or three word summary you choose something non-contentious which makes it easy to identify which letter is which without any extensive reading.
If a document is a letter, the word Letter is the obvious word to describe it and the names of sender and recipient are the obvious further identifying information to use in the document name, but for less common document types you may not have come across before it can be less easy to decide what document name to use and the guidance below may help.
It should be easy to find the document type (Deed, Agreement, Statutory Declaration, Defence, Grant, etc.) for a formal legal document because it should appear prominently on the first page of the document. Although simply using the document type may sometimes be sufficient, in conjunction with the date, to identify the document, it is better to add the names of those who signed the document (or the name of the organisation they were signing on behalf of) as well.
Agreement Smith and Jones
In the case of statements of witnesses you start with the forename and surname of the witness who signed the statement followed by WS for a witness statement, SOT for a statement of truth, SD for a statutory declaration, or AD for an affidavit.
John Smith WS
Peter Jones SOT
In case of the second, third, etc. statement add 2nd, 3rd etc. at the end:
John Smith WS 2nd
The reason for this naming convention is to allow a user of the eBundle PDF to locate any statement by doing a bookmark Find (e.g. using PDF X-Change Editor) for the surname of the witness followed by WS or SOT etc.
In the case of an official copy of a Register of Title, or Title Plan, provided by the Land Registry, title number should always be included:
Official Copy - Register - AB123456
Official Copy - Title Plan - AB123456
Business documents which have a degree of formality about them, such as Purchase Orders and Invoices, will typically have an internal reference number which should be included in the document name:
Purchase Order AB1207
Invoice 100765
For emails a time as well as a date is essential as there may be several emails between the same parties in the course of a day.
Emails are more likely (than letters) to be sent to multiple recipients and it is common for an email message to contain, as a quotation, the text of the message it is a reply to. So rather than show sender and a single recipient it may be appropriate to, for example, have the name of the sender followed by the Subject.
It is becoming increasingly common for people to compose a communication in traditional letter format, save it as a PDF, and then send it attached to an email saying simply e.g. "Please see attached letter". Such emails should be named in the usual way but instead of saying just Email it can say Emailed Letter.
A screenshot copy of a message - or of a series of short related messages - would be named as shown below. If the messages included in the screenshot extend over more than one day the "document date" will be the date of the last message in the screenshot.
Messages between John Smith and Paul Jones 13.23 to 17.53
Where a document does not have its document type actually printed on it you should try to use a concise name which most people would instantly recognise, avoiding less well known abbreviations. Here are some examples:
Report
Bank Credit
Bank Statement
Webpage www.brownandsmith.co.uk/home
Statement of Case - Respondent
Notice of Hearing
Order
Judgment
Decision
For land documents the document type will generally be one of the following:
Abstract
Agreement
Assent
Assignment
Charge
Conveyance
Deed
Lease
Licence
Transfer
Application Form
For application forms used to make applications to the Land Registry, include the Land Registry form number - e.g. FR1, AP1, ADV1, CT1, CCT, etc. This makes it easier to search for particular documents.
Many documents, particularly business letters, purchase orders, and invoices, will, upon being created, include a reference number. But, separate from any internal reference number any document may or may not already have, when there is a litigation one or more additional reference numbers may be assigned to documents used in the litigation. For example, as a minimum, the filename of each document copy will indicate which party has introduced that copy document into the litigation. Beyond that minimum, where a document appears on a formal list as part of the litigation, or is referred to in a witness statement made in the course of litigation, there will typically be one or more unique references so that the document copy can be cross-referenced with the list or witness statement. For example:
Resp-10 FR1 Application Form 22 May 2024 (for document number 10 listed in the Respondent's Statement of Case)
JJS7 Email Jones to Smith 13.42 5 Jan 2020 (for a document exhibited by a witness statement with the exhibit mark JJS7)
LRCS-6 Conveyance 28 Oct 1971 (for document 6 listed in the official Case Summary produced by the Land Registry upon referral to the First-tier Tribunal)
Rd54 Letter Smith to Jones 15 Nov 2021 (for document number 54 listed in the Respondent's disclosure list)
Ad Letter Smith to Jones 15 Nov 2021 (for a document listed in the Applicant's unnumbered disclosure list or disclosed by the Applicant without a list, where tribunal rules allow this)
If, by the time you receive a copy document from the other side, you have already loaded a copy of the same document to your document management system (e.g. because you already had that document) then, unless there is something special about the copy just received, you can save time (both now and for future steps in the litigation) by not loading the newly-received copy but simply adding the reference of the newly-received copy to the already-loaded copy (after the existing reference which should always be first) so that it has more than one reference:
Resp-14 App-5 LRCS-6 JJS12 Conveyance 28 Oct 1971
Note that some references consist of more than one part separated by a hyphen. This is appropriate where the clickable alphanumeric string reference in the referring document is unique within that document but not unique amongst all referring documents because other referring documents may also use it. For example the Respondent's Statement of Case may refer to a document as [10] and there may also be a different document referred to as [10] in the Applicant's Statement of Case. When PDF software is used by a reader to find the referred-to document, in a PDF bundle of documents, by double-clicking on [10] in the Respondent's Statement of Case, although there will be two hits, one for App-[10] and one for Resp-[10] the first part of the reference shown in the hits enables the reader to choose the correct document i.e. Resp-[10]
Where pages of a document are missing, for example a report with page 5 missing, this should be indicated in the document name thus:
Report by Dr Smith (pages missing)
This is to alert anyone looking at the document that (a) pages are missing and (b) their omission is not due to any paper misfeed when you scanned in the documents: on the contrary you found the pages missing when you came to scan in the paper documents (or when you came to make a copy of an electronic document).
Sometimes, rather than simply saying “pages missing”, it is possible to be more specific whilst still being concise:
Conveyance Smith to Jones (plan missing)
If a document is partially illegible, this should be indicated thus:
Conveyance Smith to Jones (partially illegible)
This is to alert anyone looking at the document that the illegibility is not due to inadequate scanning by you (e.g. selecting too low a DPI setting), but because the original document you are scanning is only partially legible, so that they know that there is no point in requesting a better copy from you.
In the case of many documents, such as most invoices, it is not to be expected that they would be signed, but where there is a document which has a place set apart for a signature, but has not in fact been signed, this should be indicated thus:
Deed John Fisher and Peter Fisher (unsigned)
to draw attention to the fact that the document is an unsigned copy. Often the different parties signing a deed, agreement, etc. are based at some distance from each other and one party will sign the document, take a copy, and then send off the deed, signed at that stage only by them, to the other party for their signature. So having a copy of a deed signed by only one person is not unusual but if there are no signatures at all on a document which has places set apart for signature, that should be indicated.
This information page is designed to be used only by clients of John Antell who have entered into an agreement for the provision of legal services. The information in it is necessarily of a general nature and will not be applicable to every case: it is intended to be used only in conjunction with more specific advice to the individual client about the individual case. This information page should not be used by, or relied on, by anyone else.
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