Statment of issues

Hi MK,

I will list everything that we put in our court bundle ready for the fdr, but some of it has been updated because we went to a final hearing, (we are self representing also) hope it helps......................

On the first page should be an index paginated with all contents.
A page with facts and issues disputed and agreed.

A case summary

A schedule of assets and debts (include things like income)
(for both parties, you can get the info off her form E)

A Chronology of all relevant dates i.e when u were born kids, ex wife, date of marriage, ect ect.

A short narrative statement.

All offers from both parties. (With or without prejudice)(You have to take these out after FDR for final hearing if it gets that far.)

Any correspondence between her solicitors that you feel you need to include.( especially any lies she has told, if you can back them up)

Then all proof of debts, i.e mortgage, loans ect.

Any previous orders from the Court you feel are relevant.

And finally all questions and answers you may of had from the form Es you submitted.

Anything really that you feel helps you in any way shape or form.

One thing i will say though and you may of read in other posts.....

In our case the other parties solictor wrote to us (mind you this was for the final hearing) and said the Judge likes to work from one bundle, so they asked us what we wanted adding to theirs, we wrote back and gave them a list of all we wanted including. (they sent us a list of everything they were including) we spent hours going through all the documents they were putting in their bundle. Anyway when we finally received the bundle from them, it was on a saturday morning (it should of been filed at court 7 days before) and the final hearing was the following Tuesday morning. They never included one item we asked them too. So it was a good job we had filed our own 7 days before. As it turns out the Judge referred to ours all the way through the hearing as ours was spot on with pagination, easy to find exactly what was needed, and all backed up with documentary evidence.

Please dont accept what i have put verbatum as you may need to add other things, that we didnt need too, its just a guide as to what we made our bundle out of.

Anyway good luck and keep your chin up, i know how you are feeling at all the amount of paperwork you have to deal with, but it hopefully will pay of in the end for you.

Another thing whilst i remember, dont expect too much at the FDR, they expect you to come to an agreement between yourselves. The judge will tell you from what information they have in front of them what they think the likely outcome will be if it goes to a final hearing. At the Fdr my husband went to, the Judge never even read our or the other parties bundle. It was only at the Final hearing we finally had a Judge who had read it cover to cover and knew exactly what we had been trying to say for the past two years.

Kind regards
Louise.

P.S. please feel free to ask for any advice i may be able to help with.
P.P.S... As for the form E's, we didnt put them in the bundle but we took copies of them in another file so we could refer to them if need be.
Post edited by: Louise11, at: 2007/05/27 18:20<br><br>Post edited by: Louise11, at: 2007/05/27 18:24

Is it the FDR that the bundle is needed for? i'm self liting and thought it was for the FH! I'm the respondant so shouldn't need to but the other side have been consistantly late and unreliable so guess I'll need to be prepared. Judge didn't say anything about it at the first hearing.

Hi Vanessa,

Yes you do need a bundle to be filed at the FDR aswell as the final hearing. Did you not receive a court order telling you how and when to file your bundle?

Actually thinking about it now..... my husband (who is the respondant) went to the FDR which incidentely changed to a directions hearing as the other parties solicitor wasnt ready!!! (as usual) and he said to the judge i have filed my bundle! The judge replied well yes you should of! (but the judge thought he was the applicant) Its the applicants job to file a bundle for the FDR, but as a respondant its best you do too! That way you wont be caught out with any information that you may need or crops up. I will tommorrow go through the orders we receive and tell you on here exactly what ours said. But i think if you look at the divorce guide on here it will give you all the help you may need.

Kind regards
louise

Thanks for your help I'm feeling out of my depth at times. My court order is for questionnaires to be replied by ... valuation by .... and FDR for 30 mins 26 june also says costs in application of first meeting not sure what that bit means either.
Husband/apllicant had only given me his questionnaire that day so couldn't deal with issues etc.

Hi Vanessa,

I have no idea what costs in application means, i've never heard of it. It reads to me as if the costs are in the application, i.e does it mean the applicant pays for it??
What we found is that the judge will decide on the day who pays what, and will tell you so. If not it normally says something like...... (sorry i cant remember off hand, i cant find my file on all the orders at mo but when i do i will list them) anyway whatever it was i was going to say, it means costs will be decided at the end of the case.

As for the FDR, it is the applicant who files a bundle, but personally i would take one with you also. Just so they cant bomboozal you with misinformation.

I understand how you feel being out of your depth sometimes, but just try to take one step at a time. At times in the past two years i have felt so low, cant even begin to tell you. We had 11 letters sent to us in 14 days and each one expects an answer, i just think this is other parties solicitors way of mind blowing you. (Because we are self representing) But... we plodded on and answered them all!

Look at what you have acheived so far, your at the FDR stage, that is some feat in itself! Feel proud of yourself, as for things you dont understand then ask the judge for an explanation.

Chin up gal U CAN DO THIS especially with a little help from your friends!!!! (on this site) lol
Louise

Thanks for your encouragment. As you can see from the time 4.50am i'm not sleeping much, so far tonight not at all!!!
i have folders etc with form Es and ll correspondance etc and intend to take them is this what you refer to as the bundle?
I'll ring the court and check later on to see what the cost bit is. The judge didn't seem aware that i could claim costs for my time etc.

The bundle is basically everything that you want to be able to refer to during the hearing. Formally the judges like to have just 1 bundle that contains all the documents from both sides - everyone should have a copy of this same bundle. In practice it is often two bundles - one from each side.

You can claim costs for your time as described in the Divorce Guide on this site under the Self Representation section - im not so suprised the judge didnt know - i dont suppose they get too many self representers who know that they are entitle to claim costs.