Preliminary Hearing for case management - questions

[MrBio]

Hello,

Any advice on this matter would be much appreciated.

My partner has an upcoming preliminary hearing. She is representing herself against her former employer, and we are up against a City law firm which is daunting to say the least!

The Respondent's lawyers have put together a draft bundle, which includes the ET1 and ET3, as well as a list of issues. However, since the ET3 was completed, more information has come to light (a late DSAR response from the employer). We were wondering where we can include this extra information - does it need to go in the bundle which is being sent to the tribunal? Also, there are a number of inaccuracies/lies in the ET3, should these also be addressed in the bundle to be sent to the tribunal, or can that be dealt with elsewhere?

Thank you!

[ULA]

A Preliminary Hearing (PHR) is not a full hearing and the purpose for this hearing is to enable the tribunal to understand the basis of the claim and defence, identify the issues and set appropriate case management directions to help both your partner and the respondent prepare for the final hearing. If required then only a minimal bundle is prepared as there are very few papers/documents that have been exchanged between the parties at this time. The hearing can cover:

* Date and time of the final hearing
* Estimated length of the final hearing
* Witnesses to be called and documents to be disclosed
* A timetable for exchange of statements and documentation.

Prior to the PHR both parties are usually required to complete a Case Management Agenda, which is sent out by the Tribunal in advance of the hearing and must be submitted no later than 2 days before the hearing unless Ordered otherwise. I have uploaded this for you, so your partner can start to think about what to include to complete it. Both parties are encouraged to agree the agenda but if this cannot be done, then each will submit their own version.

The issue of inaccuracies in the ET3 will be dealt with by way of any documentation your partner has to prove this is the case, which can be requested to be placed in the bundle prepared for the final hearing or in their witness statement.