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And there was I thinking Standard Disclosure, as set out in CPR 31.6 was limited to
Documents upon which the party relies, and
documents which adversely affect his own case;
adversely affect another party's case; or
support another party's case; and
the documents they are required to disclose by a relevant practice direction.
How do you:
a) constrain that, or
b) have disclosure prior to close of pleadings?
Doubtless the top top will explain