You are about to tell a court, the other side, or an AI tool what a document, transcript or witness said.
A table you can hand up, paste into a submission, or check a draft against in seconds.
A barrister specialising in evidence and written advocacy.
The central rule
A passage remembered is a passage that has drifted. Every time you rely on what a document says, the reference comes from the document open in front of you, not from your notes, your last draft, or your certainty. The citation guide applies this to case law. This guide applies it to everything else.
The table
Four columns. Keep one per matter, or one per hearing if the matter is large.
- Where is precise enough for a stranger to find in ten seconds: document, date, page, line or paragraph.
- Exact words are exact. Copied, not paraphrased, with quotation marks. If you must shorten, use an ellipsis and keep the words either side.
- Label is your plain description of what the words do. It is the only column that contains your view.
- Add a fourth column for the source filename if your naming system does not make it obvious.
Using it
At a hearing, the table is what you read from when you say "your Honour said at page 12 that…", and what you may hand up as an aid where the court's directions allow it; it is a submissions aid, not evidence. Transcripts in some courts must be purchased or are restricted; build the table where you have lawful access to the transcript. In a submission, each cited fact carries its "where" in brackets. In an AI session, the table is what you give the tool instead of your memory, and what you check its output against; the factual spine is built from it. The upload check applies to the table itself: a quotation or paraphrase from compelled material carries the same restriction as the document, so those rows stay out of any tool.
The table works on you too. Your own emails go in it, because the other side will quote them, and you want to have read the exact words before they do. The limited consent guide is what to do with what you find.
If you cannot find the words, the row does not exist. Do not write what you think it said and plan to check later. Later is when you are standing up.
From Jordan's case file
Checklist
- Every quotation you rely on has a row: where, exact words, label
- Every row built with the source open, never from a draft or notes
- Your own words in the table as well as theirs
- Drafts and submissions checked against the table before they leave
- Table rebuilt or extended the day a new transcript, affidavit or letter arrives