POL00023950
POL00023950
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Amy Prime
‘odric William:
Subject: pplication - itness Statement ['
Attachments: _DOC_154958621(2)_15th Witness Statement of Parsons - Recusal.DOCX; Bates v Post Office.draft directions order
v2.docx; 2019.03.21 Fourteenth Witness Statement of Andrew Paul Parsons.pdf
Jane, Rodric
Please find attached the witness statement which is due to be filed at 12pm today. A copy of the 14" witness statement
and the order by which the 15" witness statement is pursuant to are also attached for reference.
The witness statement contains 7 paragraphs, with the remainder being extracts from the Judgment. We have sought to
include in the statement as much as possible from the Judgment so as no points are missed, which has been weighed
against the risk of including such a large volume of material that we are accused of being unhelpful.
In relation to matters which have arisen in the Horizon Issues Trial that could be useful examples of the Judge's apparent
bias, the scope of the witness statement is only focussed on the Common Issues Trial however, there is ongoing
consideration as to whether this material could be used in the skeleton argument / oral submissions. Owain Draper has
been re-tasked from the HIT to the recusal application for a couple of days so as to consider this and the HIT transcripts
have been added to the application bundles so as to enable Counsel to do so.
Any thoughts or comments on the witness statement would be welcomed.
Kind regards
Amy
Amy Prime
Solicitor
Womble Bond Dickinson (UK) LLP
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