The “exhibiting” of documents to witness statements and affidavits is common. It is surprising how common it is for the exhibit, and the witness statement, to fail to comply with the rules. Here we look at the rules relating to exhibits and useful guidance in relation to the use of exhibits at tria...
It seems to be normal practice among defendant firms to exhibit documents to every witness statement and, very often, the witnesses all exhibit the same documents.
Unless there is a really good reason for the exhibit, I tend to put the statements in one section of the bundle (but leave out the exhibits) and then ensure that the exhibited documents appear in the documents section at the end. There is clearly no need for them to appear twice.
Please can people just stop exhibiting documents to statements except in interlocutory applications when they actually do serve a purpose???