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Anon 9.29 have you in everyone of your cases gone through every page of the 300 plus pages of bank and other financial documents. If so why and what was included in your questionnaire? Do you routinely ask for an explanation of all expenditure over £250?

I once costed such a question. There were 2or 3 hundred pages. The cost was likely to be many hundreds pounds to answer, review the question and take instructions on it, reply, review the reply and take instructions on it. In a bog standard modest value case.

Do you refer to the documents individually (possibly as categories) with explanation in your witness statements?

The reality is that bundles are used as a weapon. I've said elsewhere that a colleague made his own bundle of documents as one was referred to in evidence by taking it out of the trial bundles. As they were the only relevant ones.

A 3500 page bundle would take a week or more just to read. So it can't be read.

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