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I'm sure all solicitors have had the experience of having to prepare bundles - either at the instance of counsel or the other side - which contain huge numbers of documents which in the event are never referred to at trial; presumably on the basis that if some unforeseen point crops up at trial the documents are there so no harm's done - except to the solicitor who's wasted hours and paper which probably won't get paid for . In the Court of Appeal there is already a rule that the core bundle can't exceed 350 pages and if you want more you can make an application and show cause why the extra material is relevant. So if you and/or counsel really want to cover your back the better answer is to prepare your own supplementary bundle and take it along to court only to be called into play if actually needed to rebut some point made by the other side.

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