My first message, so hello to everyone. I am fighting a child arrangements case against ex wife who has mentally and physically abused both me and our young child. I will keep the history short but she abused alcohol, hit me, hit our 4 year old child, admitted suicide attempts to her GP, was referred for anger management courses and was arrested for hitting our child. She is a compulsive liar and believes she can win any arguments by lying. After 5 years of abusive marriage I had enough and knowing her to be a liar, I started collecting evidences. I have video and audio evidences of her abusing and assaulting both me and our child.
Right now we are in court and her solicitor requested 2 day fact finding hearing. Between then and now her solicitor found out all the truth from her negative CAFCASS report and police / medical reports etc and has left her case. As she is without a council, creating bundle became my responsibility, I ran out of money and had to move to self representation myself (Although I am planning to hire a barrister for fact finding hearing), I do not want her to create bundle as she will deliberately ruin my part in it, so submitting it myself.
I am good at documentation and so far did all documentation myself. My solicitor had to just make minor adjustments to make those legal. But I am unable to find a format on internet for following documents:
1. Case summary / history - I need a format / example for this
2. Purpose of hearing - I need a format / example for this
3. Chronology - I don't think we will need it as I am planning to add brief events for case.
4. Do I need to attach applications and forms? This is fact finding hearing so I believe scot schedules and statements of both parties should be enough.
5. I don't think I need position statement separate from statements supporting scot schedules, do I?
I am ok with pagination etc for rest of the bundle.
(Note, I am open to pay reasonable amount of fee to any legal experts for this advice or for someone who can review my documentation)
I would seriously consider looking for a McKenzie's friend - that will help you to get all of the paperwork sorted out (get one by recommendation though), and you may find that you don't then need a barrister, and a MF will be much cheaper.