Build Extended Disclosure Order Draft (PD57AD Models A–E)

Skill: Assemble Issues for Disclosure and search params into an Extended Disclosure draft

Region: United Kingdom Category: Legal / eDiscovery Does: Takes the agreed Issues for Disclosure and proposed search parameters and assembles a draft Extended Disclosure order, assigning a Disclosure Model (A–E) to each issue and recording search terms, sources and custodians, under CPR PD57AD. Spec: CPR Practice Direction 57AD — Disclosure in the Business & Property Courts; Disclosure Review Document (DRD) / Extended Disclosure Models A–E

Used in the Business & Property Courts disclosure regime. The draft order and DRD-style content below follow PD57AD and the DRD, not a verbatim schema.

When this applies

• A claim in the Business & Property Courts subject to PD57AD (after Initial Disclosure, where Extended Disclosure is sought).
• The parties have produced a List of Issues for Disclosure and are completing the Disclosure Review Document (DRD) before the CMC.
• Each issue is matched to a Disclosure Model and (for Models C–E) to search parameters.

Structure (issues + search → Extended Disclosure draft)

For each Issue for Disclosure:
  - Issue reference and short description
  - Disclosure Model requested:
      Model A — no search-based disclosure (known adverse docs only)
      Model B — limited disclosure (key/known docs)
      Model C — request-led search-based (specified requests)
      Model D — narrow/broad search-based ("train of inquiry" optional)
      Model E — wide search (exceptional; train of inquiry)
  - For C–E: custodians, data sources, date ranges, keyword/concept
    search terms, document types, technology (TAR/CAL) if used
DRD Section 2: search/data summary, proportionality, costs estimate
Draft order: models per issue, search methodology, timetable

Data rules

• Model per issue — every Issue for Disclosure assigned a Model (A–E); narrative justification for C–E.
• Known adverse documents — duty to disclose persists under all models (PD57AD para 3.1(2)).
• Search parameters — custodians, sources, date ranges and search terms defined proportionately; technology-assisted review noted where used.
• Proportionality / costs — DRD records reasonableness factors and a costs estimate; over-broad searches challenged.
• Identifiers — claim number, parties, court; consistency with the List of Issues.

Worked example (outline)

Claim BL-2026-000123, Acme Ltd v Beta plc
  Issue 1 (existence of oral variation): Model C — 3 custodians,
    Exchange + Teams, 2023-01..2024-06, terms ("variation" w/2 "supply") ...
  Issue 2 (quantum of loss): Model B — known finance docs only
  Issue 3 (notice of breach): Model D — 4 custodians, broad search, TAR
  DRD costs estimate £85,000; draft order with per-issue models + timetable

Filed with the DRD ahead of the CMC; the court orders the Models adopted.

Validation checklist

• Every Issue for Disclosure assigned a Model A–E
• Known adverse documents duty acknowledged across all models
• For C–E: custodians, sources, date ranges, search terms set out
• Proportionality and costs estimate in the DRD
• TAR/CAL methodology noted where used
• Claim number / parties consistent with the List of Issues
• Draft order and timetable ready for the CMC

Last updated: 2026-06-04 — confirm the current CPR PD57AD, Disclosure Review Document and Model definitions against current authority (justice.gov.uk, CPR PD57AD) guidance before use.