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Panicking and desperate

  • inastate
  • inastate's Avatar Posted by
  • Senior Member
  • Senior Member
13 May 12 #330272 by inastate
Topic started by inastate
My several messages here mention that I have a barrister, and my frustration at his lack of contact or help, despite the sky high charges. Final Hearing barely over a week away and the Trial Bundle needs to be in the Court by coming Wednesday.

The ex stated he''d have a solicitor at hearing...now says he can''t so the Trial bundle needs to be done and I suppose my barrister has been pushed into having to prepare it, and he says he will be, but on the other hand he says he will be sending us both an Index list to prepare ''our bundles''.

My desperation is, despite e-mails & phone calls stating the time issues and that I don''t really know how to do it ( plus of course the ex is in same position now ) I get nowhere. No Index list so far. My research says it should be put together by the legal representative, but he seems to be short-cutting that, and still charging a fortune. BUT we cannot do it without the Index it seems.

PLUS....I have lots and lots of issues with the ex...re false accounting, false...everything in every statement basically. Masses and masses of evidence here and there in all sorts of documents, statements etc.

My question is ....these pieces of evidence....do I list them as ''exhibit 1 - a million'' and is it best to put all exhibits in one portion of the file, to make them easy for access ???

The barrister has some of the really crutial evidence too....and I don''t have a copy of it, as he took the original when I had my first appointment with him. So how do I include that...it''s the most important too.

Please tell me somebody......I have photocopied 4000 pieces of paper ( yes really...it''s a very, very complicated case ) and have them in piles of subject matter. Do I just put file dividers between each and number 1 - whatever for each section...or do they get numbered from the first page to the last in the whole file. Also does each file start at 1, or does it carry on from the last number on the last one.

Questions I need to know so at least I can be in the know, ''when'' he decides to give me the index. We could have had this back in February after last hearing.

I''m so upset, confused, frustrated, feeling let down, depressed...everything. Without my case being put together with all the evidence...how on earth will the outcome be fair? I suppose I''m just small fry to the barrister and go to the bottom of the pile all the time. I''m so wrecked with all this.

Please help.... anybody with the answers, you are an angel if you can give me the advice my costly barrister doesn''t. Thanks.

  • Fiona
  • Fiona's Avatar
  • Platinum Member
  • Platinum Member
13 May 12 #330281 by Fiona
Reply from Fiona
Usually it is a solicitor who instucts a barrister on behalf of a client and prepares the bundle. Guidance for contents and format are in the Practice Direction here;


Only include documents that will be referred at the hearing. Limit lever arch files to about 350 pages each. You can create a separate core bundle containing the most important documents, or at least a reading list directing the judge to those documents which are vital to read before the case starts.

At the beginning of each file, include an index covering all the files. Then begin with the case summary, the schedule of the issues to be decided by the judge, the chronology, and a draft or summary of the orders sought. Use page dividers to separate each section of the bundle, such as pleadings, witness statements, experts’ reports and so on. All documents should be numbered. All the information must be divided correctly, clearly legible, and the same in each copy of the bundle.

  • inastate
  • inastate's Avatar Posted by
  • Senior Member
  • Senior Member
13 May 12 #330288 by inastate
Reply from inastate
Thankyou so much.

I have never had a solicitor....I went straight to the top...but to be honest have my doubts about this now. Direct Access is very new to most Chambers it seems and they simply do not realise they are not dealing with solicitors. We as members of the public need to be held by the hand and led every step of the way...something this barrister has not learnt yet !!

I have so many issues about the ex and his dirty tricks and accounting etc...do you know if it is better to simply put all those issues in one section along with all the relevant ''exibits'' of ''this and that document and statement''. Surely it is easier than thumbing back and forth through the file...or is that too logical for the system as it stands?

I don''t even know how I am supposed to write out the list of ''issues'' and the relevant list of ''evidence'', apart from the word ''exibit ....number 2 etc''

It is 3 years since the ex had his mid life crisis and left...and I have copied all my bank and building soc. statements for 4 accounts for 3 years....because I need to prove the financial crisis he created and caused. He crippled the family financially and as we are not in a positiion to claim any help from the DSS we have been left to suffer. Do you think it will be better for me to simply have all those bank statements in one file...and all the other issues in another for ease of handling??

I''m getting into such a frenzie over all of this.

Thankyou for any help you can offer.....I really appreciate it.

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