A hearing into covert surveillance of Northern Ireland journalists was adjourned after the PSNI presented a further 78 pages of evidence.
A lawyer representing journalists Trevor Birney and Barry McCaffrey described the case as a "shambles".
Ben Jaffey KC accused the PSNI of an "obdurate lack of understanding" of the points being raised.
"Information has not been provided until well beyond the last possible moment," he said.
The Investigative Powers Tribunal is investigating complaints of covert surveillance by Mr Birney and Mr McCaffrey.
They claim that covert surveillance was used by the PSNI to discover who their sources were.
The tribunal was already investigating two instances of surveillance, but the latest statement has revealed two more.
The PSNI had already admitted unlawful surveillance of Mr McCaffrey in 2013 aimed at identifying a source within the PSNI concerning an allegation of corruption.
There was also an application to Apple in 2018 to gain access to Mr Birney's iCloud account.
Durham Constabulary were at the time investigating the leaking of information concerning the Northen Ireland police investigation into the killing of six Catholic men in Co Down in 1994.
Mr Birney and Mr McCaffrey were arrested in 2018 a year after the release of an investigative documentary about the attack called 'No Stone Unturned'.
Mr Jaffey said that Durham Constabulary's Senior Investigating Officer Darren Ellis misled Apple by claiming the information was needed because of a risk to life.
The request was made the day after the arrest of the two journalists who then took a High Court action against the PSNI.
Mr Jaffey added that the request to Apple was unlawful and made despite a High Court order that electronic records belonging to the two men should not be examined pending a judicial review.
He said the latest information showed another Covert Surveillance Order was granted regarding a third party on the day of the journalists' arrest.
He said the hope was that the journalists would contact this person once they were released.
There is also a fourth instance of covert surveillance disclosed by London's Metropolitan Police in 2011.
Justice Rabinder Singh adjourned the Investigative Powers Tribunal hearing so the new evidence could be considered.
