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Court Bundle — Standard Structure

A bound, tabbed, numbered bundle handed to the bench at the start of the hearing carries different weight than a sloppy stack of papers or a USB stick. The judge can find anything in seconds. The clerk can reference exhibits. The opposing side sees you came prepared.

This is the standard structure used by E&W family-court practitioners. Adapt to your jurisdiction's local rules.

File order

COURT BUNDLE — [Case name] — Hearing [date]

[Tab A] Index
[Tab B] Latest order(s) in the case
[Tab C] Latest position statement (your side)
[Tab D] Latest position statement (other side, if disclosed)
[Tab E] Witness statements
        E1 — your statement, sworn [date]
        E2 — third-party witness statement (grandfather)
        E3 — third-party witness statement (teacher)
[Tab F] Expert reports
        F1 — Cafcass / GAL / court-psychologist report
        F2 — your retained expert's report (if any)
[Tab G] Chronology
[Tab H] Contact log (exported from spreadsheet, dated)
[Tab I] Documentary exhibits (numbered, chronological)
        I-001 to I-NNN
[Tab J] Authorities (cases + statutes cited in your skeleton argument)
[Tab K] Skeleton argument

Format rules

  • Single-sided printing.
  • Page-numbered throughout. Bottom-right corner. Continuous numbering across tabs (so the judge can ask for "page 87" not "tab I exhibit 23").
  • Index hyperlinks if delivered electronically.
  • Tabs labelled clearly.
  • Coil-bound or in a ring binder. Not stapled.
  • Maximum 350 pages per binder (E&W typical limit — check local rule).

The skeleton argument

The single most important page (front matter at Tab K). Structure:

  1. Issue — what is the court being asked to decide today (1 sentence).
  2. Background — three sentences max.
  3. The relevant statute / authority — one short paragraph with cite.
  4. Application to the facts — three to five bullet points, each pointing to an exhibit.
  5. The order sought — the specific words you want in the order.

Keep it to one or two pages. The judge has minutes, not hours.

Common mistakes to avoid

  • Wall of text in your statement. Number paragraphs.
  • Exhibits in random order. Always chronological.
  • Duplicate exhibits across tabs. Pick one location per document.
  • Citing cases you haven't actually read.
  • Including "for context" material that isn't directly relevant. The judge reads less than you think.

Practical: how to print

Most copy-shops will produce a 200-300-page coil-bound bundle for £25-50 / $30-60 / €30-50. Production time: same day if you bring a USB. Print two copies — one for the bench, one for you. Opposing counsel usually has their own.

For high-volume cases, a portable Brother PJ7-series mobile thermal printer + a coil-binder lets you produce updated bundles overnight from home.

Disclaimer. This is a starter template, not legal advice. Adapt to your jurisdiction and case facts. Have a licensed practitioner review before filing. Statutes and procedural rules vary and update — verify against primary source.

— AntiAlienate.com · CC BY 4.0

Sources & authoritative references

Topic baseline (independently verifiable):