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Message
From: Alisdair Cameron [alisdair.cameron(,
Sent: 16/05/2019 11:27:21
To: Watts, Alan [/O=EXCHANGE/OU=EXCHANGE ADMINISTRATIVE GROUP .
(FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=Alan.Watts]; Ben Foat [Ben.Foat!_ GRO
cc: HSF Post Office [/O=EXCHANGE/OU=EXCHANGE ADMINISTRATIVE GROUP.
(FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=HSF Post Office6e6]; Thomas Cooper [tom.cooper}
Subject: RE: Privileged & Confidential frome
Thanks, so we remain at risk that only Coulson will adjudicate our right to appeal? Al
Al Cameron
Interim Chief Executive
20 Finsbury Street
London
EC2Y 9AQ
From: Watts, Alan <Alan.Watts}_
Sent: 16 May 2019 12:12
To: Alisdair Cameron <alisdair.camero!
Cc: HSF Post Office <HSFPostOffice
Subject: Privileged & Confidential
Al, Ben
We had a brief chat with Helen Davies QC earlier to start to get her up to speed on the issues in the case. She has read
very little but did have a few observations that I thought you would be interested to hear:
e She agrees with the strategy of keeping more arguments on the table at the hearing before Fraser next
week. There is a difference between taking arguments that are well-versed to the trial judge and taking them
cold to the Court of Appeal.
e She is keen to work out if there is anything that can be cut before we apply to the Court of Appeal — the appeal
will be of more interest if it looks more manageable.
e The discrete factual points and procedural unfairness may not be worth pursuing — but obviously further
reading in needed.
e She thinks the first key point — good faith — will be of interest to the Court of Appeal.
e She agrees that removing the request to replace the Managing Judge was the right thing to do.
@ She has not heard of 3 Lord Justices being asked to consider an application for leave (neither have we) so this
will need thought
e She mentioned, colloquially, that in her experience the Court of Appeal almost always rejects applications for
permission to appeal recusal decisions in harsh terms. So, without having read it, she is unsurprised by
Coulson's harsh treatment.
Next step is for us to meet with her next Thursday afternoon once she has had a proper opportunity to read in.
If you have any questions please let us know.
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Regards
Alan
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