16 But that still leaves the question of what purpose will be served by these interrogatories. The answer, I think, is very little. It is general practice in this Court for parties to exchange witness statements prior to trial: see, generally, Practice Direction No 4 of 1995, Witness Statements. There is no reason to expect that, in this case, there would not be an order for exchange of witness statements. No submission to the contrary was made by the defendant's counsel. What that effectively means is that well before trial the defendant will know what evidence the plaintiff and the third party will lead in relation to the Deed and the circumstances in which it was signed. Moreover, the plaintiff is the party who will almost certainly have the right to begin. Of course, this is a matter which will finally be determined by the trial Judge, but there is nothing in the material presently before the court which suggests that the defendant would have the right to begin. That ensures the plaintiff's witnesses will be called first. Counsel for the defendant will have the opportunity to cross-examine the plaintiff's witnesses and explore all of the matters covered by these interrogatories. It is difficult to see what advantage, either in savings of time or cost, that would be occasioned by the administration of these interrogatories. In my view, they will not in any way limit the issues before the court.