The trial witness statement should not quote at length from documents, argue the case, set out a narrative that is already in the contemporaneous documents, or include commentary on other evidence.

I believe this trial witness statement complies with Practice Direction 57AC and paragraphs 18.1 and 18.2 of Practice Direction 32, and that it has been prepared in accordance with the Statement ...

The references in the solicitor’s witness statement that the instruction was for “ ballast in the correspondence ” were difficult to square with a claim for litigation privilege; ...