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Anon at 4.28 hits the nail on the head. Except that I would have said real issues.

Anon at 5.35 misses the point. Making overstated points doesn't help. Facing up to the real issues and accepting those that are inescapable actually strengthens the arguments which are positive. Client's subjective evidence is not, in such circumstances, in their best interests.

Of course cases with complex issues will have more documents. More experts etc. But this in my time had become the norm. There has to be an introduction of realism - which applies to both sides of every case.

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