This is to create a hard copy.

Buy A4 size Binder type folders: you may need more.

Organising:

Make a space on your floor or table.

spread all the papers you have out.

Put the papers in order.

Have cardboard dividers and label each index section index sections A. B. C. D. etc.

IN The first section YOU NEED TO PUT THE ORDER IF YOU ARE APPEALING AND ALL PREVIOUS ORDERS IF THERE ARE ANY, YOUR SKELETON ARGUMENT WHICH SHOULD LEAD THE JUDGE TO THE PAGE THAT YOU ARE ASKING HIM TO SEE AND ANY OTHER IMPORTANT DOCUMENTS

Your skeleton argument is important as this is the bones of your story.

Explain in the skeleton argument what you think was wrong and lead the judge to the section and number where he/she will find the evidence.

ie. I request that you go to section B page 5 and see the evidence that shows the messages that I received from the respondent /applicant/ professional/judge, and which shows what he/she did or did not do.

Put the papers IN EACH SECTION into chronological ORDER

Place each document into the sections and label each with what they are in the index which does at the back

CONTINUE THE THROUGH THE REST OF THE BUNDLE

Your bundle: -

will be labelled in these sections in this order:

Section A:

'Pre court documents (or preliminary documents);

Section B: '

Court Applications to Court and or Court Orders;'

Section C:

Party statements (ie parents, local authority, Cafcass guardian,

barristers opening and closing statements, arguments);

Section D:

Care Plans (local authority);

Section E:

Experts and assessments;'

Section F:

Medical records (ie GP records - or hospital etc);

Section G:

Police statements (or disclosures);

Section H:

'Child Contact Notes;'

The Process

The First-stage is making section A and calling this 'Pre court documents (or preliminary documents).

For section A,

put 'A1' in the top right-hand corner (use a pencil at first to avoid mistakes and can easily erase)

and turn the page over and put A2 on the other side, top right. All the papers you use in section A mark them A1- A60

For each of the following

sections, B

(see above) etc), C. D, E… start from 1, ie B1, C1, D1, E1, F1, G1, H1;

After section A, make a section B

and call this 'Court Applications and Court Orders.'

Then do the same for section B what you have done for section A,

ie B1 (top right, using both sides of the paper), B2 (top right for the other side of the paper),

then, B3, turn over, B4 and so on;

Repetition:

Follow the same process for Sections A, B, C, D, E, as above,

depending on whether you have suitable papers for A-D, or beyond, ie A-H;

Final Process:

Bundle Contents page:

When you have finished the complete process,

make another page and call it 'INDEX' and list all the sections in the same order as above,

of how you have actually put together (paginated) all the relevant paperwork ('the bundle');

For example, the contents pages should look something like this:

CONTENTS (underline in and put in bold letters, big enough to stand out.)

Put this (contents) page at the very beginning of the bundle so that the family court professionals

when opening it will know where you have all your paperwork, as in my example:

BUNDLE CONTENTS

Section A: 'Pre court documents(or preliminary

documents) pp. A1- A50;

Section B:' Court Applications to Court

and or Court Orders,' pp. B1-B80;'

Section C: Party statements, pp.C1-C69;

Section D: Care Plans (local authority), pp. D1-D80;

Section E: 'Experts and assessments,' pp. E1-E200;

Section F: Medical records (ie GP records - or hospital etc), pp. F1-F60;

Section G: Police statements (or disclosures), pp.G1-G30;

Section H: 'Child Contact Notes,' pp. H1-H150;

OR.

Guide TWO for making a court bundle for public law in the family court jurisdiction:

(Just in case guide one is too hard to follow)

HERE IS a good way for you to challenge a family court

professional in an effective and professional way.

For instance, in your position statement, see the psychologist, Mrs Farnworth's statement at paragraph 20, PAGE 4 YOU WILL SEE THAT THE PSYCHOLOGIST DID NOT SAY WHAT THE OTHER PARTY IS SAYING. tHE OTHER PARTY IS NOT A PROFESSIONAL IN THIS AREA.

Section B – Content

Court Applications/ Orders (pp. B1-B80):

Interim Care Order:

2.2.18: Interim Care Order, District Judge Higgins, B1- B12;

Full Care Orders/ Dual Orders:

6.8.18: Full Care Order, Judge Higgins, B13-B50;

12.6.19: Placement for adoption Order,

HH (His Honour) Judge Marshall (Circuit Judge), B51-B80;

Dual Order:

6.8.18: Full Care Order and Placement for Adoption Order,

HH (Her Honour) Judge Mackintosh (Circuit Judge), B13-B80

Section C - Party statements

Parties’ Position statements (pp. C1-C161)

London Metropol. Council:

Statements for the applicant London Metropolitan Council, C1-C50;

The Child:

Statements for the 1st respondent child c/o the Cafcass Guardian, C51-C100;

2 nd respondent parent:

Statements for 2nd respondent parent, C101– C130;

3 rd respondent parent:

Statements for 3rd respondent parent, C131-C162;

Section D – Content

Care Plans/ Threshold Document (pp.D1-D90);

Care and Adoption Plans:

Social worker degree (BA):

A social worker for the London Metropol on plans

for the 3 children: 2 for adoption and the older one

long term foster care, D1-D31;

Threshold Document:

London Metropol on the threshold, D32-D41.

Section E-Content

Experts (pp. E1- E131)

Joint appointment court experts:

New Medical doctor Psychiatrist report:

No diagnosis or prognosis:

Psychiatrist, Dr Schmidt report

showing no problems with the parents, E1-50;

Old reports:

Non-medical doctor, conflicting evidence:

Trauma and Bipolar diagnosis and prognosis (18 months of treatment):

Psychologist, Dr (PhD) Matthews report

on opinion on trauma and Bipolar, diagnosis and prognosis, E51-E131

guide for making a court bundle for public law in the

family court jurisdiction: Contents.

Note pp. means pages.

ELECTRONIC BUNDLES

Judiciary UK announcements notice from the financial remedies court RE: electronic-bundles

Notice from the Financial Remedies Court: Electronic Bundles

19 April 2022 |Family Court|Financial Remedies Court|News

MR JUSTICE MOSTYN
MR JUSTICE PEEL
HIS HONOUR JUDGE HESS
FRC ADVISORY NOTICE

The use of electronic bundles in the Financial Remedies Court in the last two years has moved from being fairly rare to almost universal. This is an excellent outcome for a number of reasons and we are keen that our procedures should support the continuation of this development.

It has been drawn to our attention that for litigants-in-person (‘LIPS’), the guidance on electronic bundle preparation[1] requires a modest degree of clarification.

Therefore, for clarity, we explain:

(i) The obligation to produce forms ES1 and ES2 applies as much to LIPS as it does to represented parties.

(ii) If one party alone has a solicitor then, absent an agreement or order to the contrary, it will be for that solicitor (and not the LIP) to prepare the electronic bundle.

(iii) If both parties are LIPS then there is still a requirement for an electronic bundle in PDF form to be created and, ordinarily, it will be the applicant who is responsible for preparing the electronic bundle.

(iv) We recognise that there may be circumstances when the applicant LIP simply has insufficient IT ability to prepare the bundle. If this happens then that person should contact the court and explain the difficulty as far as possible in advance of the relevant court hearing. Where possible that person should suggest a practical way of overcoming the problem, which may be that the respondent should be invited to prepare the bundle. A respondent in this situation is encouraged to offer assistance where possible.

(v) Where neither party has sufficient IT ability to prepare a bundle then the court will have to do its best to find a solution which overcomes the problem.

[1] in FPR 2010 PD27A, the Statement of Efficient Conduct of 11 January 2022, the President’s Guidance on E-Bundles of 21 December 2021 and the General Guidance on Electronic Bundles of 29 November 2021