Trial Bundle Preparation: A Checklist for Busy Litigation Teams

This trial bundle checklist starts from a simple fact: trial bundles are unforgiving. A missing exhibit, a wrong pagination reference, or an out-of-sequence document does not just look untidy, it can genuinely disrupt a hearing. Here is a working checklist for getting bundle preparation right when time is tight.

Before you start assembling anything

• Any trial bundle checklist has to start with the court’s specific bundle requirements. Practice Direction 32 and the relevant court guide are the starting point, but individual courts and judges often have their own preferences on format, tabbing and page limits.
• Agree the index structure with the other side where the rules require a joint bundle, well before the deadline, not the day before.
• Confirm whether an electronic bundle, a hard copy, or both are required, and in what format (searchable PDF is now the default expectation in most courts).

Trial bundle checklist: structure and pagination

• Paginate continuously through the entire bundle, not section by section, unless the court has specifically directed otherwise.
• Cross-check every reference in skeleton arguments and witness statements against the final pagination before filing, references drift every time a document is added or removed.
• Use consistent, court-compliant tab labelling, and keep a master index that mirrors the physical or electronic tabs exactly.

Document quality

• Check scan quality on every page, not just a sample. A single illegible page in a key exhibit is a real problem in front of a judge.
• Remove duplicate documents unless there is a specific reason to include them twice (for example, where a document appears in correspondence and as a standalone exhibit).
• Confirm redactions, where required, are genuinely irreversible in the final PDF, not just visually covered in a way that can be copied out.

Final checks before filing

• Do a full read-through against the index, not just a page count check, to confirm every listed document is actually present and in the right place.
• Confirm the bundle has been sent to, or is accessible by, everyone who needs it: the court, counsel, and the other side where applicable, within the court’s filing deadline.
• Keep a dated record of what was filed and when, in case a dispute arises later about what was or was not included.

Where this fits into a wider workload

Bundle preparation is exactly the kind of detailed, deadline-driven work that benefits from a dedicated pair of hands rather than being squeezed into a fee earner’s evening. A supervised paralegal, briefed properly and checked before filing, can carry this end to end while the fee earner focuses on strategy and advocacy. If bundle season is a recurring pressure point for your team, our Pricing page sets out how a flat-rate paralegal fits into that workflow.