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Is there anything to be said for taking an initial witness statement from the client shortly after being first instructed, and while their memory if fresh. Clearly this will not cover all the aspects that emerge as the case proceeds, but it could be served with a supplementary statement covering other issues.
You often get this in effect if you have a claim that has a number of interlocutory hearings, where initial statements are often supplemented as things go on.
I can see that there may be dangers if a client’s first impressions turn out to be incorrect, or legally flawed, but it would avoid the problems in this and many other cases where statements are fine-tuned into nonsense.
I usually take a fairly formal initial statement for my file so the client is committed to his story, but don’t normally serve it. Am I missing a trick?