Hello my name is XXXXX XXXXX I will help you with this. Please note that I am a working Solicitor and may be on and offline as I have to attend Court and meet with clients, even at weekends. As such you may not get an instant response when you reply as this is not an ‘on demand’ live service, but rest assured I will be giving your question my immediate attention upon return. There is no need to wait here, you will get an email when I reply.
You can wait but if you have the document it is discloseable and if you don't disclose it, they can make an application to Court for it to be disclosed.
It needs to be on the disclosure list, not on the witness exchange list. This is because you are relying on the document as an exhibit to your statement rather than calling this person as a witness of fact
Can I clarify anything for you about this today please?