GOOD BUNDLES, GOOD ADVOCACY, POOR WITNESS STATEMENTS
The final paragraph of the judgment of HH Judge Behrens in Royal National Institute for Deaf People -v- Turner  EWHC 3301 Ch speaks volumes. I will allow it to speak for itself.
“I cannot leave this case without expressing my gratitude to all those involved in its preparation. It was helpful to have electronic copies of the bundle. The skeleton arguments, closing oral and written submissions were of a high quality and of great assistance in determining a by no means straightforward and anxious case. In so far as there is a criticism of the preparation it relates to the preparation of and contents of the witness statements which were not confined to the factual material which they addressed but included numerous comments and statements of opinion which were, of course, inadmissible. The parties are referred to Appendix 9 of the Chancery Guide for details of what should and should not be included in a witness statement.“