AVOIDING THE PITFALLS: BUNDLES, WITNESSES AND PREPARING FOR TRIAL: WEBINAR ON 29th MAY 2026: IT MAY BE A WHOLE BUNDLE OF FUN

In Serra -v- Harvey [2024], wasted costs were ordered on an indemnity basis against the claimant’s solicitors because the lateness and condition of the trial bundles. The bundles were described as “haphazard”.  This is just one of numerous posts on this site where judges have been critical of the way in which bundles have been prepared.  Inadequate preparation for trial can have a major impact on the hearing, the clients and the lawyers. This webinar looks at trial preparation as a whole and bundles in particular, with a detailed examination of the steps necessary to ensure a party is ready for trial. Booking details are available here. 

(Note that this webinar is for 1.5 hours).

(For those who are not familiar with Sedley’s Laws, they are summarised and considered in this post. )

18 USEFUL CHECKLISTS INCLUDED

The lecture material includes a series of 18 checklists on preparing for trial that deal with matters such as witness preparation, the run up to trial, the day of trial, planning and preparing bundles.

IF YOU DON’T THINK THIS IS IMPORTANT LOOK AT THESE HEADLINES (AND THEN READ THE POSTS…)

• LATE AND “HAPHAZARD” SERVICE OF TRIAL BUNDLES LEADS TO WASTED COSTS ORDER AGAINST CLAIMANT’S SOLICITORS (ON THE INDEMNITY BASIS)
• A TRIAL BUNDLE THAT WAS A “CHAOTIC MESS”; NON COMPLIANT WITNESS STATEMENTS AND EXPERT REPORTS AND “PROCEDURAL TRENCH WARFARE”
• “AN UNWIELDLY COLLECTION OF COURT DOCUMENTS”: A JUDGMENT THAT ENDS THE “BUNDLE DROUGHT”
• “A COMPLETELY UNACCEPTABLE WAY OF PREPARING FOR AN IMPORTANT HEARING”: NON-COMPLIANT AND INCOMPLETE BUNDLES: WITNESS STATEMENTS IMPROPERLY PREPARED
• DELAYS, ADJOURNMENTS AND THE SIZE OF THE TRIAL BUNDLE: NOT JUST AN ACADEMIC PROBLEM: ELECTRONIC BUNDLES DOESN’T MEAN YOU CAN JUST THROW EVERYTHING IN
• “E-MAIL EXCHANGES COULD BE 2,000 OR 4,000 PAGES APART”: A JUDGMENT ABOUT BUNDLES (WHERE YOU CAN SEE SOME FAIRLY GRUMPY CORRESPONDENCE)

THE WEBINAR

Bundles are often the source of judicial complaint and (adverse)  comment.  A good bundle can help a trial or application run smoothly.  Poor bundles can lead to delay, frustration and – as we have seen – wasted costs.  This webinar is designed to head off problems in bundles and preparing for trial.

This webinar looks at:

• Trial preparation: advocates, witnesses and experts at trial.
• Why bundles are important.
• What a bundle says about you…
  “What is the point of handling a claim for a couple of years and then failing to present it well to the court? You are selling yourself short and doing a disservice to your client.”
• The rules for preparing bundles for applications.
• The rules for trial bundles.
• The rules for bundles on the assessment of costs.
• Are the costs of preparing bundles recoverable?
• Useful guidance and hints for the preparation of bundles.
• Avoiding judicial ire. Judges criticism of bundles.
• Useful links on the preparation of bundles.

It is important viewing for anyone involved in litigation who is likely to be involved in any type of application or trial.  Both those preparing the bundle and those supervising and overseeing the task need to be fully aware of the rules and guidance.