‘Tagging’ the bundle

Occasionally, it will be useful to know whether the tribunal were taken to a particular document in the bundle. This may become important if, on appeal or review, there is doubt about whether evidence was put before them.

It is worth developing a habit of putting a cross in the top right-hand corner of every document the tribunal is referred to. That way, you can easily record what has been placed in evidence.

In some cases, more advanced systems may be useful. If it is important to make sure that certain witnesses are all taken through certain documents, you might mark each document with the witness’s initials as you cross-examine on it.

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