How to put together disclosure documents

[RobRobRob!]

We are currently in a legal battle that is being heard at the High Court, as the legal costs have mounted, we are in a position where we have to dis-instruct our solicitor and continue the case alone. Our defence is being put together by council however we are now in a position where we have no legal backing or knowledge. We are in the stage of disclosure and have 30 days to file this with the court.

We have read articles online with regards to what disclosure consists of, however without the legal understanding we are not certain where to start. Can anyone point us in the right direction, for example is there a template or pack that we can download and expand on, or is it just a case of placing all required evidence in a folder, giving each a reference and putting this all on a spreadsheet?

Any assistance would be greatly appreciated

[pt2537]

What has the Court ordered in respect of disclosure?

[RobRobRob!]

Hello, thank you for your response, the exact wording is 'the parties must give to each other standard disclosure of documents by list and category'.

[alc1989]

You must serve a List of Documents on the Defendant before the time provided by the Court Order.

(https://assets.publishing.service.go...3/n265-eng.pdf)


You must complete the form in so far as applicable.

Where it says: "I did not search documents - pre-dating" - you bask back-date it as far as the evidence goes back.

Where it asks "located elsewhere than" and "in categories other than" you put in "those required under CPR P31"

I suggest you read CPR P31 (it's basically you must include all relevant documents in relation to the case - even if it is evidence which works against you"

Sign and date the statement of truth.

On page 3,

> where is says "I have control of the documents numbered and listed here. I do not object to you inspecting them/producing copies."
Number and list all the documents winch will form your evidence bundle (inducing evidence which could be used against you)

> where it says "I have control of the documents numbered and listed here, but I object to you inspecting them:"
just say "general notes, and memorandum connected with the case, correspondence between me and my legal representative(s)."

> where it says "I object to you inspecting these documents because:"
just say "they are privileged by nature"

> then in the last box, list any documents which you used to have but have been lost or destroyed.

[alc1989]

Further to the above, you should also be provided with the other side's list of documents.

You do not need to disclose the actual documents at this stage.

There will be a date in the Order which states when the documents from the list should be requested by, and the time that the request for documents should be complied with.

So when you send your disclosure list, the other side may say "please can i have items 1, 2, 3 and 4 from your list of documents".
Check when you must comply with this.

This will also apply to you, so make sure you request any documents the Defendant relies on too.

You may be barred from using evidence if you don't disclose it in time after it has been requested.

[GrumpyMonkey]

Disclosing documents isn't a problem as they are all emails and the dealer obviously has them as they were the recipient. There are documents they claim to have which should have been presented before the sale took place, but have never been provided, despite being requested, multiple times.

Would I be expected to provide printouts of emails they already have?

[Armughan]

Hi
I apologise to put my leg in for another person’s post. I’m in same boat and already sent the list as advised.I am now struggling to find the following information:
1. Do I need to include any letter with specific wording to send the documents to the claimant?
2. Do I need to send the same to court as well?
3. Can I send them as a bundle or segregate them according to list like Exhibit 1, 2, 3 and so on as I have provided 15 different items in standard disclosure?
4. Do I really need to send them by email or I can send them by post?

many thanks