When a witness is making and signing their statement, they will have in front of them a copy of each document they refer to in the statement. They will identify the document by description and usually also by an exhibit mark - e.g. "...the letter I sent him on 25th March 2024: I refer to the letter marked PMJ21". The exhibit mark might be in the form PMJ21 (the 21st document referred to in the statement of Paula Mary Jones) or it might be in the form Resp12 (the 12th document listed in the Respondent's statement of case). As a consequence of seeking to avoid duplication in the eventual eBundle, and of seeking to place a single copy of each document in its logical position, a copy of each document referred to in a statement will not immediately follow the statement in the eBundle: a single copy will be in the appropriate position in a chronological section elsewhere within the eBundle. So each mention of an exhibit mark in statements should be hyperlinked to the relevant document within the eBundle so that the user, when reading through a statement within the eBundle, can quickly bring up each document referred to. To save the laborious task of manually setting up a hyperlink for each mention of an exhibit mark, automatic hyperlinking is desirable but sometimes hyperlinking automatically is not easy to do...
But you might come across the situation where one statement uses references which are not suitable for automatic hyperlinking. For example a Statement of Case might not have document references in the text but just have a numbered list of the documents referred to at the end. Or a Statement of Case might refer to documents in the text just by a number 1, 2, 3, etc. so that any attempt at automatic hyperlinking based just on a digit would pick up too many random occurrences.
In this, and other situations where automatic hyperlinking is not possible, you can, as a second best, arrange matters so that the user of the eBundle can locate referred to exhibits using the Find function of their PDF software. To do this you first ensure that a suitable unique reference is included in the bookmark name of each referred to document (the format to use is explained below) and then you add a note page just before each affected statement in the eBundle providing the user with guidance about locating referred-to documents using the Find function.
If the Respondent's statement of case has, for example, just a numbered list of the documents referred to at the end, or if it refers to documents in the text just by a number 1, 2, 3, etc., you could use the references Resp1 Resp2 Resp3 etc. in bookmarks.
If documents accompany the statement of case with pagination - e.g. if there are, say, 30 documents accompanying a statement of case page numbered 1 to 40 (40 rather than 30 because some documents consist of more than one page) - then if each document also has a serial number and is referred to with that serial number in the statement text that should be used rather than than a page number but if the documents are not numbered and all there is available to use is the pagination (or if the documents do have a serial numbers but the text only refers to each document's page number) then the page number of the first page of each document could be used. For example you could use App1 App4 App6 etc. if the first document accompanying the Applicant's statement of case is three pages long, and the second document is two pages long, etc. In this case the numbers will not be consecutive but it is better to use numbers actually quoted in the statement of case - so that it is possible to cross-refer - even though they are not consecutive, rather than create a wholly new consecutive numbering system.
Using a prefix naming convention such as Resp1 Resp2 etc. for documents referred to in the Respondent's statement of case) is normally suitable and unambiguous but not always. For example you might have a case where two legal cases are being heard together so that each litigant is the Applicant in one case and the Respondent in the other case. In such situations, in order to provide clarity, you may need to use a longer prefix which more explicitly identifies the type and author of the referring document. For example:-
[JJS-App-3] for a document referred to as 3 within the Applicant's statement of case of litigant John James Smith
[JJS-Resp-R7] for a document referred to as R7 within the Respondent's statement of case of litigant John James Smith
[PMB-App-A5] for a document referred to as A5 within the Applicant's statement of case of litigant Paul Martin Baker
[JJS-Resp-26] for a document referred to as 26 within the Respondent's statement of case of litigant John James Smith
Avoidance of duplication means that there should only be one copy of each document in the eBundle and if the same document is referred to using more than one reference then the usual way of catering for that would be to include all references in the bookmark of the one included copy. However if the references are quite lengthy - as in the above example - adding multiple long references to the bookmark of the included copy might make the eBundle less easy to use in which case an alternative would be to replace the duplicates with a single page (possibly smaller than A4), just before the included copy containing the bookmark name and text such as "DOCUMENT OMITTED FROM THE BUNDLE TO AVOID DUPLICATION Please see next page for an identical copy of this document". The position of the documents can be locked in the bundle generating system to ensure that they stay together in the correct order.
If a witness statement refers to an exhibit which contains more than one document then the statement is likely to quote the page number within the exhibit of each document referred to like this:
The first invoice I received was dated 1 May 2015. I refer to a paginated collection of invoices marked JJS12 - this invoice is on page 1. The next month I received an invoice dated 15 June 2015. A copy if this invoice is on page 3 of exhibit JJS12...
In this case you could use the following references in bookmarks:-
JJS12.1
JJS12.3 etc.
assigning each document a starting page number suffix.
In the eBundle, add a page just before each affected statement saying e.g.:-
"You can use the Find function in your PDF software to easily locate documents referred to in the following statement of case because the bookmark of the referred-to document contains the reference used in the statement. For example paragraph 3 of the statement refers to a Conveyance document as 23. That document has Resp23 in its bookmark so you can go to it by doing a Find for Resp23. Similarly paragraph 5 of the statement refers to an email as 19 and that can be located by doing a Find for Resp19."
Exactly how you do a Find depends on which PDF software is being used. You could add to the instructions brief information on how to do a find with popular PDF software.
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This information page is designed to be used only by clients of John Antell who have entered into an agreement for the provision of legal services. The information in it is necessarily of a general nature and will not be applicable to every case: it is intended to be used only in conjunction with more specific advice to the individual client about the individual case. This information page should not be used by, or relied on, by anyone else.
The information on this page about specific computer techniques is provided for information purposes only. Every reasonable effort has been made to ensure that the information is accurate and up to date at the time it was written but no responsibility for its accuracy, or for any consequences of relying on it, is assumed by me. You should satisfy yourself, before using any of the techniques, software or services described, that the techniques are appropriate for your purposes and that the software or service is reliable.
This page was lasted updated in September 2025. Disclaimer