POL00041866 - Email from Victoria Brooks to Angela Van Den Bogerd and others re Witness Statements in PO Group Litigation - re witness availability

Evidence on official site

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Message

From: Victoria Brooks’ -

Sent: 05/07/2018 07:23:20

To: Angela Van-Den-Bogerd:

cc: i 7 ; Rodric Williams
{ ‘Andrew Parson

Subject: : Timings for witness statements [WBDUK-AC.FID:

Thanks Angela.

Noted and will do.
Kind regards
Victoria

Victoria Brooks

Managing Associate
Wombie Bond Dickinson (UK) LLP

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Sent from my iPhone

On 5 Jul 2018, at 07:39, Angela Van-Den-Bogerd I wrote:

Hi Nick
lagree on Chris.

Victoria — I spoke with Alison Bolsover yesterday. She wili happily be a witness so please reach out to
her.

My leave is from 11° July, returning on 23° July.

Thanks
Angela

<image003.png> Angela Van Den Bogerd
People Services Director

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From: Nick Beal
Sent: 04 July 2018 12:18
To: Victoria Brook:

Mark Underwood:

ic Williams 4 ndrew Parsons!

Subject: RE: Timings for witness statements [WBDUK-AC.FID26896945]
Thx Victoria.

Juts to confirm that my lave is 21** July to 3" August — so definitely need to bear this in mind.

Angela - I think it would be good to add Chris Howard to the list also ~ whilst this is more about
contracts than remuneration, he does have a great working knowledge of this stuff too.

Andy ~ can you confirm I can share the Paul Inwood witness attachment with him.

tam about to send over Stewart’s review of Paul’s statement — straight to you Victoria marked legally
privileged?

Reds

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<image009.png> Nick Beal
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Postal Award for Customer 20 Finsbury Street,
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From: Victoria Brooks

Sent: 03 July 2018 16:23

; Nick Beal

POL-0038348
imings for witness statements [WBDUK-AC.FID26896945]

Dear Angela, Nick and Mark

Thanks for your time on the call earlier.

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I've prepared an indication of the timings for the phases of witness statements below. This isn’t intended
to be set in stone since we will need to fit around witness availability if they are doing something they

cannot change. However, your help (in particular I was thinking Mark and Rodric) in clearing their desks
and getting us priority access to them would be much appreciated.

I will also work into the below some time to deal with witness evidence on specific issues raised in relation
to specific Lead Claimants, but have focused on the evidence on generic issues for now.

lawyers working on statements and set up calls

Dates Task Who?

W\c 2 July 2018 Finalising issues to raise with witnesses on generic WBD and POL
issues
Arranging priority access for witnesses POL
Contact witnesses on generic issues to introduce WBD

W\c 9 July 2018 Calls and meetings with witnesses on generic issues WBD and POL witnesses
Working on witness statements WBD.

W\c 16 July 2018 Calls and meetings with witnesses on generic issues WBD and POL witnesses
Working on witness statements on WBD

Wic 23 July 2018

Reviewing draft witness statements

POL witnesses assisted by WBD.

Wic 30 July 2018

Final drafts / signing off.

WBD and POL witnesses

Wic 6 August 2018

Slippage

WBD and POL witnesses

10 August 2018

Witness statement deadline

All

For your information, I will be assisted with the preparation of the statements by a team consisting of
Dave Panaech, Ivan Roots, Helen Creech, Ed Duffield and Mandy Robertson. Depending on the
complexity of the evidence allocated to each team member, they may be able to work more quickly than
the above for certain of the witnesses.

Please let me know if you have any comments or queries on the above.

Kind regards

Victoria

Victoria Brooks
Managing Associate

Wombie Bond Dickinson (UK) LLP

GRO

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