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Trial Bundles

Both parties will rely upon documentation at a trial and these should be included in a paginated file known as a trial bundle (in some courts these may be provided elec­tronically).

The bundle should include all statements of case, a case summary and chro­nology to assist the court, all witness statements/summaries and expert reports, any notice of intention to adduce evidence at trial (e.g. hearsay notices) and the response to these as well as any relevant orders such as orders made at interim hearings. Copies of the trial bundles should be made available to the court and each party.

In civil proceedings the claimant is responsible for preparing, filing and serving the trial bundle and this should be done not more than seven days and not less than three days before the trial (see CPR 39.5(2)). In criminal proceedings trial documenta­tion will usually consist of the prosecution evidence that has been served in advance as part of the disclosure process - see for example, CrimPR Parts 24.8(2) and 24.9(2).

In cases in the High Court, as well as in both the lower civil and criminal courts, the claimant/appellant must also lodge a ‘reading list' agreed by the advocates of the material that the judge should read in advance of the hearing. Skeleton arguments are also required for a trial in most courts.

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Source: D’Alton-Harrison Rita. Advocacy for SQE2: A Guide to Legal Practice. Routledge,2022. — 340 p. — (Legal Practice for SQE2). 2022
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