Reading the papers

Getting familiar with the hearing bundle is one of the most important things you have to do when preparing to represent a client (or yourself) in the employment tribunal.

To do this efficiently, you need to have a range of different reading speeds. Some (often most) of the papers in the bundle will be completely irrelevant to anything you have to argue about, and you can skip over them very fast. Often there will be a few pages that are absolutely key – and by the end of the case, you will have pored over them for hours, decorating them with highlighters and cross-referencing them to other documents. Other pages will have a significant line or two, but mostly not be very interesting.

What this means is that you need to read some documents carefully; skim-read others; and – at any rate on your first pass through the bundle – just note that others are there without reading them at all.

A related point is that you need different reading speeds for different stages of preparation. If the case is new to you, you will probably want to start with the ET1 and the ET3 to find out what the case is all about; then read the witness statements for a bit more detail; and then go through the bundle. But this first read through of everything will probably be quite fast: the pleadings and statements are important, and you are going to have to get to know them well before the end: but at this stage, you just don’t know what the case is about, so you can’t tell which bits to focus on. So don’t read everything as if your life depended on it: just get the big picture. You can fill in the detail later.