Bundle advice - court refused exceeding bundle page limit

[JC83]

The person emailing was likely just the admin front of desk person. The court do accept bundles over the 350 pages, but as he has already emailed I would do 2 bundles. The second bundle containing all the ordered disclosures. That way if no fact find is ordered the second bundle is there but essentially redundant.

Then at the hearing ask for future hearings will the court confirm they accept the bundles over 350 pages to be added to the order.

thanks Nana,

So just to be clear - one bundle with everything (Bundle 1) - all applications, orders, statements, disclsoures e.g. social services minutes, medical reports, contact centre reports, police disclosure, parenting course details, NMO proceedings

then one bundle without the disclosures (bundle 2) e.g no social services files, med reports, contact centre reports, police disclosure, parenting courses, NMO proceedings? This bundle will be tiny in comparison!

thank you nana, just trying to get it clear in my head!

 

[Ash]

Two bundles is a great tip Nana. I would think bundle 1 would be:

Applications, orders, statements, evidence for statements, contact centre reports, parenting course details, NMO details

Bundle 2 would be all court ordered disclosures like police reports, medical records

Does that sound right Nana?

 

[JC83]

Applications, orders, statements, evidence for statements, contact centre reports, parenting course details, NMO details

This will be around the 350 mark I think (give or take a few pages)

Bundle 2 would be all court ordered disclosures like police reports, medical records

Would that still then include everything else that was in bundle 1?

 

[Resolute]

A few thoughts.

If disclosure of certain documents has been ordered. I would send them to the court under heading of this form:

(Insert case number), Directions Hearing, (insert name of court), Hearing on dd/mm/yy at hh:hh, Applicant/Respondent (delet as apt.), Documents for Filing.

Your court should have a convention on how to title documents for filing. It will probably start with Case #. I would describe the docs as "Disclosure, 01, CHILD Medical Records; Disclosure 02, Applicant Medical Records...". This avoids having them as exhibits to your statement. The documents are then on record, they can be referred to and quoted in your statement. The bundle table of contents could then start with: "Ordered Disclosures, filed and served on dd/mm/yy", followed by document titles.

For the statement and exhibits. I have used headers in place of a cover page. This means you have the cover page info on every page of the statement/exhibit. If you then print to pdf you can use a free online pdf merge tool to combine. This will take care of page numbering and transfer headers (formerly cover pages) from different documents into one flow.

I claim no expertise, just sharing what has worked for me.

Edit, forgot to mention, last time I did the pdf merge, it would only let me do five doc merge per use. I combined groups of 5, the combined groups of groups of five, and so on. It was tiresome, but it worked.

 

[Ash]

I did the same - just had a header with name and case number and exhibit number and no front sheet.

It sounds like you have options JC. But I like the idea of two bundles. It’s more or less the same as resolute is suggesting if all the court ordered documents are in a separate bundle.

But to answer your question - no I don’t think you’d have any documents duplicated in both bundles - you’d just refer to bundle 1 or bundle 2

 

[Nanaforsonsjustice]

Two bundles is a great tip Nana. I would think bundle 1 would be:

Applications, orders, statements, evidence for statements, contact centre reports, parenting course details, NMO details

Bundle 2 would be all court ordered disclosures like police reports, medical records

Does that sound right Nana?

Yes thats correct Ash, this is how I would do it.

 

[JC83]

Yes thats correct Ash, this is how I would do it.

Thanks Nana, would you still start the disclosure bundle with Section A? Or would you do it as resolute advised above? Section A as per the practice direction 27a would usually be titled preliminary documents so I don't want to do something that annoys the judge.

The judge asked for the NMO (family law act proceedings to be disclosed into the current proceedings) so not sure which one this would sit in. I think it makes more sense to sit in the first bundle like Ash has mentioned above, but then technically its being disclosed...

thanks

 

[Nanaforsonsjustice]

Thanks Nana, would you still start the disclosure bundle with Section A? Or would you do it as resolute advised above? Section A as per the practice direction 27a would usually be titled preliminary documents so I don't want to do something that annoys the judge.

The judge asked for the NMO (family law act proceedings to be disclosed into the current proceedings) so not sure which one this would sit in. I think it makes more sense to sit in the first bundle like Ash has mentioned above, but then technically its being disclosed...

thanks

Both bundles should start with A from what I under and have done before. And NMO definitely in the first bundle.

 

[Resolute]

Do you have your ex's statement and exhibits to include?

Do you plan to send her a table of contents in advance?

Are you able to get a printed version to the court a few days before the hearing?

 

[JC83]

Yes I have ex statement and exhibits

Yes I can send her the table if contents in advance but she’s got an NMO on me at the moment. Technically, it allows for communication over child arrangements including resolving matters via litigation. Ex just sends her statements etc straight to court and they send them to me. I’m not sure even if the NMO allows it if I should contact her directly as she will say probably say its harassment or something.

Yes can get a version to court before the hearing. It is a remote hearing though so will they need a printed version?

 

[Resolute]

My ex's legal team provided a printed version to the court for remote hearings. I think the main reason they did this was to stamp a date after which anything I submitted would not be on the bundle before our judge. When they decided bundle was as they wanted they sent email to court, copying me, to file and serve. These emails stated that a printed version was in the post.

Could you provide the table of contents to her in the same way you will provide the bundle?

Showing the effort is more important than ensuring she has meaningful opportunity to provide feedback. It is good form to give her sight of bundle in preparation. It may also protect against her playing silly buggers on the day.

 

[JC83]

Thanks resolute, I had read to make sure she is sent a copy of the bundle index for agreement so I’ll make sure I do that

 

[Resolute]

My earlier message was unclear.

What I meant was you are sending her the bundle, presumably indirectly, perhaps sending to the court and asking them to forward to her. You could do the same with Table of Contents 2 or 3 days before you plan to file the 2nd bundle.

If you are going with the 2 bundle idea. I would do the 1st bundle - disclosures as per order - straight to the court asking them to forward to her. TOC for that is not open to contention.

 

[JC83]

My earlier message was unclear.

What I meant was you are sending her the bundle, presumably indirectly, perhaps sending to the court and asking them to forward to her. You could do the same with Table of Contents 2 or 3 days before you plan to file the 2nd bundle.

If you are going with the 2 bundle idea. I would do the 1st bundle - disclosures as per order - straight to the court asking them to forward to her. TOC for that is not open to contention.

Good idea, thanks Resolute. There really shouldn’t be much to argue about with even the non disclosure bundle really but I’m sure ex will find so,ething!