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Message
From: Melanie Corfield {
Sent: 21/03/2019 11
To: Jane MacLeod [}._. I; Tom Beezer [/o=Exchange-Org/ou=Exchange Administrative Group
(FYDIBOHF23SPDLT)/cn: 79d9#227294473d81bS0¢72aacb0623- Tom Beezer]; Amy Prime
[/o=Exchange- ‘Org/ou=Exchange Administrative Group
[FYDIBOHF23SPDLT)/ ts/cn=ab7222dda3a9453eaed5751238a59562-A\ ; Rodric Williams
I; Mark Underwood: Ben Foat
cc: Andrew Parsons [/o: Exchange- -Org/ou=Exchange Administrative Group
(FYDIBOHF23SPDLT)/cn=Recipients/cn=ad9ed344815e47e4aaa3c0e7e1740919-Andrew Pars]; Dave Panaech
[/o=Exchange-Org/ou=Exchange Administrative Group
(FYDIBOHF 235! 's/cn=0310835f6adc435ab 1b160664f370de9-Dave Panaec]; Mark R Davies
[mark.r.davies Patrick Bourke [patrick.bourke@
Subject: RE: Recusal application - filed documents [WBDUK-AC.FID26896945]
ce-ing Mark D and Patrick.
lf agree ~ no reason to do anything differently.
Mel
From: Jane MacLeod
Sent: 21 March 2019 11:37
To: Tom Beezer <té
‘odric Williams
} Melanie Corfield
Cc: andrew.parsons Dave Panaech <
Subject: RE: Recusal application - filed documents [WBDUK-AC.FID268:
Thanks Tom — I agree with that, and its consistent with the approach adopted in the trial which is that documents (eg
witness statements) aren’t provided until they are discussed in Court (eg witness sworn in}.
® Jane MacLeod
Group Director of Legai, Risk & Governance
Ground Floor
20 Finsbury Street
LONDON
EC2Y
From: Tom Beezer [mailto
Sent: 21 March,201.9.11:
it Rodric Williams
_I Melanie Corfield
Cc: andrew.parsons <a ; Dave Panaech <}__
Subject: RE: Recusal application - filed documents [WBDUK-AC.FID26896945]
Mei
I have spoken to Amy. I have a different view here. I don't think you should give out any documents at all, save for the
holding statement you have been working on with Jane.
My thinking is as follows:
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- Post Office is (put simply} launching an application that criticises this Judge.
- if this judge feeis that Post Office does anything that could be seen as publically briefing against him, he may
use that as further rationales in his own narrative of “aggressive” etc.
- As to which of these documents is publically available, itis certainly NOT the witness statement or exhibit as
that is only public once referred to in open court — and that has yet to happen.
- The letter is private to the court.
- The Appiication Notice is an odd one. I don't know if the public could eventually get a copy of such a
document.
But my rationale remains. In this sensitive scenario err on the side of extreme caution and avoid any possibility of Post
Office being seen to launch a briefings campaign against the Judge. And certainly release nothing until we KNOW the
public could get in through other channels, and that does not (yet) include the witness statement (and as I have said, I'd
need to work on the issue of the Application Notice).
tT
Tom Beezer
Partner
Wombie Bond Dickinson (UK) LLP
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From: Amy Prime
Sent: 21 March 2019 11:09 .
To: Jane MacLeod; Rodric Williams; Mark Underwood ¢
Cc: Andrew Parsons; Tom Beezer; Dave Panaech
Subject: Recusal application - filed documents [WBDUK-AC.FID26896945]
Melanie Corfield; Ben Foat
Dear All
Please find attached a copy of the application documents which will be filed with the Court in the next 10 minutes. A copy
of the exhibit to the witness statement is not attached due to its size but can be provided separately.
We have requested that the application be heard on either Thursday 28 March, or Friday 29 March. The next stage of the
process is for the Judge to list the hearing date and we will update you further once we have received confirmation of this.
Mel — Andy is going to let me know if the application is mentioned by the Judge during Court today. If so, we will let you
know. If any of the press in the court room ask for copies of the application documents, Andy is going to direct them
towards your team. From a legal perspective, we don't have any objections to the application documents being provided
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to the press today, but please feel free to handle this in a way which fits in with your communications strategy - if it is your
preference to wait until the day of the hearing, this is fine.
Kind regards
Amy
Amy Prime
Solicitor
Womble Bond Dickinson (UK) LLP
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