That is why a experienced lawyer will send a letter requesting particular evidence to be preserved. (castellilaw.com)
This was especially so in the context of filing of statements and other particular evidence. (newlawjournal.co.uk)
He did, however, acknowledge that practitioners may be concerned with the limiting of the factual evidence so early in the process because it may later become apparent, with the benefit of hindsight, that the exclusion of particular evidence was misguided and caused unfairness. (newlawjournal.co.uk)