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Whose statement this is

Add a paragraph

The statement so far

Exhibits

Each one gets your initials and the next number, and the numbering stays right when you remove one.

The statement, and getting it out

What this is, and what it is not

Every paragraph comes from somewhere, and it should say where. What you saw. What you did. What somebody told you, and who. What you read, and in which document. What you believe, and on what basis. Marking each paragraph is a two-second decision at the time, and it is the decision that stops a statement being taken apart later, because the sentence that gets you is always the one where a thing you were told has quietly become a thing you know.

Say what you saw, not what it meant. "He was clearly trying to avoid the question" is a conclusion somebody will ask you to justify. "I asked him twice and both times he answered about something else" is evidence, and it gets you to the same place without the argument. The page marks paragraphs that read as argument rather than as observation.

Your own words, not your solicitor's. A statement in language you would not use is worse than one in plain words, because the first thing asked in cross-examination is whether you wrote it. Short sentences, ordinary vocabulary, first person. If a sentence would embarrass you to read aloud, rewrite it.

Exhibits number themselves, and stay numbered. Your initials and a number, in the order they first appear. Remove one halfway through and everything after it renumbers, and the references in the paragraphs follow, which is the part that goes wrong by hand and is never noticed until somebody cannot find PR4.

It stays on this machine. A draft statement is privileged, sensitive and unfinished, and the places people usually type one are a word processor that syncs and a form on a website. This is neither. Export the JSON, keep it with the file, and give the text to whoever is helping you.

Questions people ask

Is this legal advice?

No. It is a way of writing down what you remember, in the shape a statement usually takes. Whether you should make one, what it should cover, and what the rules where you are require of it are questions for somebody who knows your case.

What is the statement of truth?

A line at the end saying you believe what you have written is true, and acknowledging that making a false statement in one can be punished as contempt of court. The exact wording is set by the rules where you are, and the one here is the ordinary English and Welsh form. Check it against the rules that apply to you before you sign.

Can I say what somebody told me?

Yes, and you must say that is what you are doing, and who told you. "Mr Whitfield told me that the survey had come back badly" is a proper sentence in a statement. "The survey had come back badly" is not, if all you know is what he said.

How long should it be?

As long as the facts you actually know, and no longer. Statements get padded with background nobody disputes and argument nobody asked for, both of which give the other side something to work with. If a paragraph does not say something you witnessed, ask what it is doing.

What if I cannot remember exactly?

Say so. "I cannot now remember whether that was the Tuesday or the Wednesday" is an honest and perfectly normal sentence, and it costs you nothing. A statement that is precise about everything years later invites the question of how, and there is rarely a good answer.

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