u/Strict-Fix-8715

I have a deadline to agree bundle in a few weeks. Disclosure has yet to take place. Most of my documents are held by the Respondent but I have copies of pretty much all of them already after getting a DSAR. How do I go about things? Do I simply list the documents I have already and send them the documents that I have in my possession that they would not have? Medical evidence for example.

Also if there is a long chain of emails do I just list the dates of the relevant ones?

The Respondent is responsible for the bundle creation.

I understand the witness statement is written as the events as i experience them. What I’m struggling to understand if I should directly describe how things relating to failure to make reasonable adjustments placed me at a disadvantage compared to non disabled colleagues.

Is the witness statement a place to do this? For example should I include paragraphs including things like this: …….this placed me at a substantial disadvantage compared to non disabled colleagues. Due to my disabilities, I cannot do x without (reasonable adjustment)?