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or perhaps:
"My Lord, sadly my instructing solicitors are not in possession of a crystal ball. They are therefore mindful that the trial process is adversarial in nature and that this often throws up unexpected twists and turns during a hearing. Also, judges are often capricious, as well as happy to apportion blame (and costs penalties) for supposed deficiencies in court bundles, without fact finding. As a result, without being 100% sure in advance w t f you will need, they've put in everything that seemed relevant."