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Court Bundles

Could you link the software? Sounds very timesaving.
 
If it helps any LIP with lots of documents, here is what my bundle looks like (Bear in mind there has been more document filed since this bundle was produced)
 
Could you blank out the dates as well - for all the docs and orders - just in case they're identifiable? I'll remove it for now if you could add it again then?
 
I honestly don't think that it is worth the money to pay a solicitor to complete either the bundle or other exchange of statements. This whole process is a money pit, why not hold on to the money you haven't got (!) until you may need a barrister for a Hearing?

The bundle can be achieved as others as helpfully suggested online. There is only ever one bundle, updated at each court hearing with new documents. It's a big deal because it will always be a point of reference and must be complete; the other side completed the bundle in my case and because the ex's solicitor changed twice, documents were missing; in fact most of one year's papers. The judge was very clued up and we're on their case both about missing documents and the incorrect format.

Standard procedure is for an order to state that statements must be filed at court and served on other parties by a certain date and time. Having experienced that sleight of hand when mine was but theirs wasn't, you could ask the judge to order (just a suggestion, don't know if they'll allow this) that the statement is filed at court by a certain date and once paries have confirmed by email with the court that both have been received, must serve statements on each other no more than 24 hours afterwards.
 
Im a bit confused here. On my latest order it says I should create a bundle. I'm using the bundle docs website to create it.

In the Statement of Issues section should I be listing things like who he lives with, who and how much time he should spend with or should I be going into further detail using some of the things said in my position statement that was made as a response to the section 7 such as should a hair strand test be ordered should police reports be disclosed etc?

Its for the DRA hearing
 
OK Figured that out after reading Kyles post on page 3.

Now just the Chronology. Would this just be mother born, father born, child born, child removed, c100 submitted, gateway hearing, fhdra with dates? Basically other than the DOB's a list of court dates?

Or would I include other significant events such as police turned up, ex admitted to hospital etc etc?
 
For example using Kyles example and adding a few things it would look like this. Plus a lot more? It just seems like Im making a list of things against the mother here. But shes done so many things the chronology would be a page long. Or should I just stick to court dates etc rather than each individual event.

Children’s Father Born
Children’s Mother Born
Child Born
• Police Called to Mothers Address
• Mother Admitted to Hospital
• Mother referred by gp to social services
Children’s parents separate

Child spending weekends with Father
Police Called to Mothers Address
Child’s contact with Father denied by Mother
• Police Called to Mothers Address
MIAM held with Mediator
Mother called police on father for welfare check
• Police Called to Mothers Address
Application for Child Arrangements Order submitted to court
 
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I think a chronology is usually shorter than that and based on various things. As for exchange of statements - a Dad on here had a good tip that worked. You send your statement password protected, and then say you will only give the password when you receive their statement. It's as good as sending it because you can't withdraw it again - it just means they can't read it until you give them the password.
This seems to be a good guide to preparing a bundle. See the section on Case Summary (which needs to be neutral) and chronology

• A chronology for a final hearing
or if you think the case summary
is not enough
This is a list of dates, starting with
the oldest, when important things
happened, for example, the dates
of birth of any children, dates of
incidents of domestic violence, dates
of applications to court and hearings.

 
This is the thing Ash,

It says dates of and DV instances. In this case its not so much DV thats significant but alcohol abuse (police turning up finding her intoxicated), (her doing a welfare check on me only for police to note it was her that was drunk), (her being admitted to hospital), ( her being referred to to ss).

That's just a few of them, there are a whole lot more. I feel I might be going a bit overboard adding all of that to the chronology as it just looks like Im using it just to criticize her but at the same time they are key events that highlight her drinking.

Thanks Rev, yes I just copied and pasted Kyles list and then added a few things to show what I meant so all made up.
 
I filed my own bundle multiple times without any issue. I used an online software - cost £25 (a month - I only pay for the month I use. Mother's solicitor is her family friend, therefore always hides documents that would go against her. The software saves the all the files, so every hearing I add the new documents e.i court order and new statements filed. My last bundle is near enough 900 pages. Judges often used my bundle or both. Saves me creating new bundle every time or paying a solicitor. Ofcourse this only work if you're LIP, I don't think the judge would be impressed if you prepared it and that there are soilicitors on both side.
Hi Dadoftwo, what was the name of the software?
 
Regarding bundles: If the final order has been made, and the applicant then wishes to make a variation or an enforcement or a specific issues order (or all 3 of the above) then does the previous bundle get used and additional statement & exhibits just added to the existing bundle?
If not, then all the relevant history of the case will be lost.

Am I right in understanding that a Direct Access Barrister cannot do this for me? If the other party has a solicitor but I only have a DAB, does that mean responsibility falls on the other party for production of the bundle? (I’d rather this wasn’t the case as I suspect the Case Summary and Chronology etc would be presented in a biased manner if left to the other party)
 
Regarding bundles: If the final order has been made, and the applicant then wishes to make a variation or an enforcement or a specific issues order (or all 3 of the above) then does the previous bundle get used and additional statement & exhibits just added to the existing bundle?
If not, then all the relevant history of the case will be lost.

Am I right in understanding that a Direct Access Barrister cannot do this for me? If the other party has a solicitor but I only have a DAB, does that mean responsibility falls on the other party for production of the bundle? (I’d rather this wasn’t the case as I suspect the Case Summary and Chronology etc would be presented in a biased manner if left to the other party)

From my experience, I never used my Court Bundle as part of my Enforcement applications after a final Order had been made and later breached. It was composed to aid the courts decisions during the Final Hearing. Information that supported the Enforcement application when into the court form C79 accompanied by an additional Position Statement. And unless I'm mistaken, it would be the same for applying for a variation or a Specific Issues Order in a C100. The court should know the decision and details in the final Order.

Remembering my pre-Final Hearing court letter, it ordered that I must prepare the Court Bundle, as the Applicant. Unless the Respondent was represented and I wasn't. In which case the Respondent must prepare the Court Bundle.

A DAB will quote for considering the details in your Bundle. They don't prepare it. Which is why I created this thread. To help guide those using a DAB and preparing their own.

Who is the Applicant here?
 
From my experience, I never used my Court Bundle as part of my Enforcement applications. It was composed to aid the courts decisions during the Final Hearing. Information that supported the Enforcement application when into the court form C79 accompanied by an additional Position Statement. And unless I'm mistaken, it would be the same for applying for a variation or a Specific Issues Order in a C100. The court should know the decision and details in the final Order.

Remembering my pre-Final Hearing court letter, it ordered that I must prepare the Court Bundle. Unless the Respondent was represented and I wasn't. In which case the Respondent must prepare the Court Bundle.

A DAB will quote for considering the details in your Bundle. They don't prepare it. Which is why I created this thread. To help guide those using a DAB and preparing their own.

Who is the Applicant here?
Oh dear, all the evidence that I will have to rely on that is in the bundle? Exhibits and arguments and evidence of parental marginalisation. None of this can be included?
I suspect that the court will ask for an updating statement of 3 pages when in reality I need reams of pages to provide the background of the case. The final
Order obviously doesn’t include instances where the other party has breached the order over the years, or the Cafcass letter. The final order is just very basic info.

I intend to rely upon case law, the case law is applicable to certain scenarios which match my circumstances, the details of my circumstances are included in the bundle but nowhere else.

Is there a way around this?
 
What's the context here? You're applying to Enforce/Vary/SI your existing order? If the information in your Bundle supports this then you could use that.
 
What's the context here? You're applying to Enforce/Vary/SI your existing order? If the information in your Bundle supports this then you could use that.
All 3 yes. Enforce a SIO, vary a CAO, SI obstruction of holidays and SI child being removed from nursery. I just made a separate post that provides a bit more context. There are exhibits in the previous bundle that support this, but there is also rather detailed and lengthy discussion in my previous 4 statements that provide key context. I predict however that I will be asked to the court to produce an updating statement of not more than 3 pages (this is what usually happens) and I also suspect they will skim through all the bundle in 20 minutes as they are “pressed for time”. The history and context of the case is key and 3 pages won’t be nearly enough to articulate it
 
I am the respondent and have had to bare the cost of putting bundles together via my solicitor. With hindsight I probably would not have instructed a solicitor. I have one more hearing in six weeks before the final hearing.

My question is can I disinstruct my solicitor so that I am not responsible for putting the bundle together and use them to assist me as necessary. That would presumably put the responsibility back onto the applicant to prepare the paperwork?
 
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