Page 246 - Bundle for MF Final

Bates no 245

List and number I have control of the documents numbered and listed here. I do not object to you
here, in a convenient inspecting them/producing copies.
order, the documents
(or bundles of 1. Natwest bank statements
documents if of the .f; ,,,. , "" 0
same nature, e.g. 2. Photocopy of Natwest cheque /T V •
invoices) in your 3. Photographs
control, which you do
not object to being 4. Unsigned loan agreement with David Spencer Butler
inspected. Give a 5. Land Registry Office Copies
short description
of each document
or bundle so that it
can be identified,
and say if it is kept
elsewhere i.e. with a
bank or solicitor

List and number I have control of the documents numbered and listed here, but I object to you
here, as above, inspecting them:
the documents in
your control which 1. Correspondence, attendance notes, memoranda, instructions to counsel, counsels advice and
you object to being similar documentation between the Claimant and his solicitors.
inspected.
(Rule 31.19)
2. Correspondence between the Claimant's solicitors and any third parties and any documents
created.

Say what your I object to you inspecting these documents because:
objections are
They were created in connection with anticipated or actual litigation and are therefore by their
nature privileged.

List and number I have had the documents numbered and listed below, but they are no longer in my control.
here, the documents
you once had in your 1. Loan agreement with David Spencer Butler.
control, but which 2. Invoices and other documents relating to building work at Nutley Place.
you no longer have.
For each document
listed, say when These are contained within my personal files which are currently in the possession of the First
it was last in your Defendant.
control and where it
is now.