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Back in the 60s and 70 bundles of more than 50 pages were rare. The reason they have grown in size is that, following the change in the ciosts rules which allowed for a payment per page the chourts began to demand more and more detail. Now the judiciary are complaining there is too much where once they complained there was not enough.

A solution might be to limit the bundle to 350 pages but have the other documents to hand in a secondary bundle in case they are needed. The process of dividing the documents between the actual bundle and the backup will be more than enough to show what is necessary. If you are caught out the backup bundle can be referred to and the document produced - untidy at trial perhaps but would a judge refuse to let such a document in, particularly if the issue has been pre-agreed between the parties?

Actually, the risk is that the judge would refuse to allow the document in, the lack of the document would then be highlighted to the client and negligence claims will follow.