Write lists

There are a lot of different things that need to be done in the immediate run-up to a hearing: writing a chronology, drafting a list of issues, making a start on written submissions, preparing to cross-examine witnesses A, B and C, researching a particular point, cross-referencing the witness statements with the bundle etc. etc.

You will improve your chances of remembering to do all the things you need to do if you keep a running ‘to do’ list, updating it every time you complete one task or think of another.

A ‘to take’ list is useful, too. It is surprising how easy it is to forget to take with you to the tribunal something you need – enough copies of your witness statement, a calculator, a notebook, the power supply for your laptop, pens, highlighters, post-its etc. etc.

Don’t on any account rely on ‘mental notes.’ They’re unreliable at the best of times, and particularly so when you’re under pressure.

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