Every claimant’s adviser will be familiar with the feeling of despair that can set in when your client arrives with several carrier bags – or worse, a suitcase – full of grubby and dog-eared papers, in no particular order, many of them in their original envelopes, some of them in a number of different copies, and not all of them dated.
The advice on this overlaps with an earlier post on difficult cases. First, sort the papers you have into chronological order. If any document doesn’t have a date on it, either put it in its approximate chronological place in the story, or, if it doesn’t seem to fit into the story or you can’t yet tell where it it fits in, make a separate pile of undated documents.
In the course of sorting the documents into chronological order, you should be able to identify any duplicates. If they are true duplicates – i.e. one is a photocopy of the other, or they are both unannotated photocopies of the same original – weed out the spare copy or copies. Make a separate pile of duplicates, either to throw away or to return to the claimant.
You should end up with a chronological pile of documents, and a (much smaller, you hope) pile of undated documents. Photocopy both piles, single-sided (but making sure you copy both sides of any double-sided pages), and return the originals to the client for safe-keeping.
Now punch holes in your nice clean piles of paper, and put them both in a lever-arch file or ring binder, the undated separated from the dated by a divider card.
See? You are feeling better about the case already. You have probably started to pick up a certain amount about the story just from identifying the documents and putting them in chronological order. The next thing is to write a chronology.