POL00069641 - PO v Lee Castleton Estimate of Claimant’s and Defendant’s costs

Evidence on official site

IN THE HIGH COURT OF JUSTICE
QUEEN’S BENCH DIVISION

BETWEEN:

POST OFFICE LIMITED

- and -
LEE CASTLETON

POL00069641
POL00069641

Claim No. HQ05X02706

Claimant/Part 20
Defendant

Defendant/Part 20
Claimant

ESTIMATE OF CLAIMANT/PART 20 DEFENDANT'S COSTS
DATED 20 NOVEMBER 2006

Fee Earners

Tom Beezer, Partner,
Grade A (over 8 years post qualification experience)

Julian Summerhayes, Associate

Grade B (over 4 years post qualification experience)
Stephen Dilley, Solicitor

Grade B (over 4 years post qualification experience)

Denise Gammack

Grade C (under 4 years post qualification experience)
Laura Peto, Paralegal Grade D

Trainee Solicitor Grade D

PART A:

£165 per hour until 31 October
2006, thereafter £238.50 per
hour

£150 per hour

£110 per hour per hour until 31
October 2006, thereafter
£175.50 per hour

£110 per hour

£85 per hour

£50 per hour until 31 October
2006, thereafter £90 per hour

CLAIMANT/PART 20 DEFENDANT'S BASE COSTS ALREADY

INCURRED UNTIL 31 OCTOBER 2006

Telephone cot ti id

Tom Beezer, Partner
Julian Summerhayes, Associate

Denise Gammack, Solicitor
Laura Peto, Paralegal
Trainee Solicitor

3 hours at £165
0.7 hours at £150
Stephen Dilley, Solicitor 38.8 hours at £110
3.8 hours at £110
2.1 hours at £85
1.3 hours at £50

nce with Clien'

£495
£105
£4,268
£418
£178.50
£65

elephone conversations and correspondence with Defendant/Part 20 Claimant's

solicitors

Tom Beezer, Partner
Stephen Dilley, Solicitor
Denise Gammack, Solicitor
Laura Peto, Paralegal

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1.0 hours at £165
36.1 hours at £110
2.5 hours at £110
2,1 hours at £85

£165
£3,971
£275
£178.50
Trainee Solicitor 0.3 hours at £50

Tel ne conversations and correspondence with Court

Stephen Dilley, Solicitor 2.4 hours at £110
Denise Gammack, Solicitor 0.7 hours at £110
Trainee Solicitor 0.2 hours at £50

‘elephone conversations and corré indence with Counsel

Tom Beezer, Partner 1.2 hours at £165
Stephen Dilley, Solicitor 22.1 hours at £110
Denise Gammack, Solicitor 0.1 hours at £110

Telephone conversations and correspondence with others

Tom Beezer, Partner 0.4 hours at £165
Stephen Dilley, Solicitor 6.8 hours at £110
Laura Peto, Paralegal 0.2 hours at £85
Reviewing, perusing and/or collating documents

Tom Beezer, Partner 0.6 hours at £165
Julian Summerhayes, Associate 0.3 hours at £150
Stephen Dilley, Solicitor 16.5 hours at £110
Denise Gammack, Solicitor 3.8 hours at £110
Laura Peto, Paralegal 5.0 hours at £85
Trainee Solicitor 14.7 hours at £50

Discussion with colleagues

Tom Beezer, Partner 4.7 hours at £165
Julian Summerhayes, Associate 1.0 hours at £150
Stephen Dilley, Solicitor 11.6 hours at £110
Denise Gammack, Solicitor 1.5 hours at £110
Laura Peto, Paralegal 0.4 hours at £85

Trainee Solicitor 2.5 hours at £50

Preparing Claim Form and Particulars of Clai

Laura Peto, Paralegal 2 hours at £85

Reviewin fence and Fclail

Denise Gammack, Solicitor 0.6 hours at £110
reparing Allocation Questionnaii

Denise Gammack, Solicitor 0.6 hours at £110

Prepari ly to Det fenc ie erclaim

Julian Summerhayes, Associate 0.5 hours at £150

Trainee Solicitor 1.0 hours at £50

reparing First Witness St me: if Catherine

Julian Summerhayes, Associate 0.5 hours at £150
Stephen Dilley, Solicitor 28.5 hours at £110

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£15

£264
£77
£10

£198
£2,431
£11

£66
£748
£17

£99
£105
£1,815
£418
£425
£735

£775.50
£150
£1,276
£165
£34
£125

£170

£66

£66

£75
£50

Nes and Helen Rose

£75
£3,135

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Drafting Instructions to Counsel
Stephen Dilley, Solicitor 4.1 hours at £110 £451

Drafting consent order for CMC hearing on 9 March 2006

Stephen Dilley, Solicitor 0.5 hours at £110 £55
Drafting Directions
Stephen Dilley, Solicitor 0.3 hours at £110 £33

Preparing CPR Part 18 Request

Julian Summerhayes, Associate 4 hours at £150 £210

Stephen Dilley, Solicitor 1.0 hours at £110 £110
win R Part 1 Hi

Stephen Dilley, Solicitor 1.6 hours at £110 £176

Disclosure

Tom Beezer, Partner 0.7 hours at £165 £115.50

Stephen Dilley, Solicitor 12.8 hours at £110 £1,408

Trainee 24,9 hours at £50 £1,245

Inspection of Defendant's Documents

Tom Beezer, Partner 0.2 hours at £165 £33
Stephen Dilley, Solicitor 1.6 hours at £110 £176
Trainee 5.3 hours at £50 £265
Drafting and in nsent order 2

Tom Beezer, Partner 0.2 hours at £165 £33
Stephen Dilley, Solicitor 0.9 hours at £110 £99
Trainee 0.5 hours at £50 £25
Conferences wit! unsel on 16 A\ September 23 r 2001
Tom Beezer, Partner 10.8 hours at £165 £1,782
Stephen Dilley, Solicitor 20.8 hours at £110 £2,288
Trainee 11.6 hours at £50 £580

Meeting and interviewing witnesses and drafting 15 witness statements for trial
To include travel, interviews, drafting, correspondence and telephone conversations
with witnesses to prepare their statements

Tom Beezer, Partner 10.1 hours at £165 £1,666.50
Stephen Dilley, Solicitor 143.8 hours at £110 £15,818
Trainee 31.6 hours at £50 £1,580

Liaising with and instructing Experts

Tom Beezer, Partner 1.2 hours at £165 £198
Stephen Dilley, Solicitor 11.5 hours at £110 £1,265
Trainee 5.4 hours at £50 £270

14_1155577_2 3
iewing Amended Particulars of Claim and Amended Rep)

to Counterclaim

Stephen Dilley, Solicitor 0.2 hours at £110 £22

Prepari licatiol second Case Management Conference on 23 October 2006

and draft Order

Tom Beezer, Partner 0.6 hours at £165 £99

Stephen Dilley, Solicitor 0.5 hours at £110 £55

Preparing Second witness statement of Stephen John Dille

Stephen Dilley, Solicitor 3.8 hours at £110 £418

Reviewing and commenting on Counsel's skeleton argument for the hearing on 23

October 2006

Tom Beezer, Partner 0.2 hours at £165 £33

Stephen Dilley, Solicitor 0.3 hours at £110 £33

Preparation of bundle for CMC in 2: r 2006

Tom Beezer, Partner 2.2 hours at £165 £363

Stephen Dilley, Solicitor 3.8 hours at £110 £418

Travel to and from CMC hearing on 23 October 2006

Stephen Dilley, Solicitor 8.9 hours at £110 £979

Trainee 8.9 hours at £50 £445

Attending CMC hearing on 23 October 2006

Stephen Dilley, Solicitor 1 hour at £110 £110

Trainee 1 hour at £50 £50
iew of Defendant's First Witness Statement

Stephen Dilley, Solicitor 0.4 hours at £110 £44

General preparation and Case Management

Tom Beezer, Partner 3.6 hours at £165 £594

Stephen Dilley, Solicitor 6 hours at £110 £660

Trainee 1.6 hours at £50 £80

Preparation of Trial Bundle

Stephen Dilley, Solicitor 3 hours at £110 £143

Trainee 1.8 hours at £50 £90

Preparation of First Statements of Costs

Stephen Dilley, Solicitor 4 hours at £110 £440

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-o Defence and Def

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Sub-total solicitors fees up to 31 October 2006 £58,675.50
VAT on Solicitors fees up to 31 October 2006 £10,268.21
Counsel's invoiced fees up to 31 October 2006 £23,925
VAT on Counsel's Fees £4,186.88
Other Expenses incurred up to 31 October 2006
Court Fees £150
Travel costs £1,497.81
Photocopying charges £1,447.67
Other expenses £71.87
VAT on other expenses (where chargeable) £528.04
Part A: Total Claimant/Part 20 Defendant's

costs to 31 October 2006 £100,750.98*
PART B: CLAIMANT/PART 20 DEFENDANT'S BASE COSTS ALREADY

INCURRED FROM 1 TO 20 NOVEMBER 2006

Telephone conversations and correspondence with Client

Tom Beezer, Partner 1.8 hours at £238.50 £429.30
Stephen Dilley, Solicitor 8.4 hours at £175.50 £1474.20

Teleph conversations and correspondence with Defendant/Part 20 Claimant

Tom Beezer, Partner 0.9 hours at £238.50 £214.65
Stephen Dilley, Solicitor 8.1 hours at £175.50 £1421.55
Telephone conversations and corre lence with Coun:

Tom Beezer, Partner 0.2 hours at £238.50 £47.7
Stephen Dilley, Solicitor 8.4 hours at £175.50 £1474.20

Telephone conversation correspo! ce with expert

Tom Beezer, Partner 0.4 hours at £238.50 £95.40
Stephen Dilley, Solicitor 2.4 hours at £175.50 £421.20
Telephone conversation and correspondence with others

Tom Beezer, Partner 0.3 hours at £238.50 £71.55
Stephen Dilley, Solicitor 2.2 hours at £175.50 £386.10
Discussion with colleagues

Tom Beezer, Partner 0.5 hours at £238.50 £119.25
Stephen Dilley, Solicitor 0.6 hours at £175.50 £105.30

Drafting second witness statement for one witne:

Stephen Dilley, Solicitor 1.6 hours at £175.50 280.80
Review of Amended Defence and Counterclaim

* This sum excludes the Claimant/Part 20 Defendant's costs of and occasioned by the Application
dated 17 November 2005 up to 18 November 2005, excluded pursuant to the Order dated 8
February 2006

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Stephen Dilley, Solicitor 0.2 hours at £175.50 £35.10

Preparing si mental disclosure list
Stephen Dilley, Solicitor 0.9 hours at £175.50 £157.95

Trial Preparation (assuming 10 day hearing)

Tom Beezer, Partner 3.4 hours at £238.50 £810.90
Stephen Dilley, Solicitor 2.5 hours at £175.50 £438.75
Trainee 8.7 hours at £90 £783
Sub-total solicitors fees from 1 to 20 November 2006 £8,766.90
VAT on Solicitors fees from 1 to 20 November 2006 £1,534.21
Apportionment of Counsel's Brief Fee
already deemed delivered £25,000
VAT on Counsel’s Fee already deemed delivered £4,375
Expert’s Fees £17,937.05
VAT on Expert's Fees £3,138.98
Part B: Total Claimant/Part 20 Defendant's

costs to from 1 to 20 November 2006 £60,752.14
PART C: ESTIMATE OF CLAIMANT/PART 20 DEFENDANT'S BASE COSTS

TO BE INCURRED FROM 21 NOVEMBER 2006 TO TRIAL

Telephone conversations and correspondence with Client

Tom Beezer, Partner S hours at £238.50 £1192.50
Stephen Dilley, Solicitor 10 hours at £175.50 £1755
Trainee Solicitor 10 hours at £90 £900
Telephone conversations and correspondence with Defendant/Part 20 Claimant
Stephen Dilley, Solicitor 10 hours at £175.50 £1755

hi conversations ie ondence with Court
Stephen Dilley, Solicitor 1 hours at £175.50 £1755
Trainee Solicitor 2 hours at £90 £180

Telephone conversations and correspondence with Counsel

Tom Beezer, Partner 1 hours at £238.50 £238.50

Stephen Dilley, Solicitor 5 hours at £175.50 £877.50

General Case Management/Rout orrespo' ice Telephoi I

Tom Beezer, Partner 2 hours at £238.50 £477

Stephen Dilley, Solicitor 10 hours at £175.50 £1755

Trainee 12 hours at £90 £1080
tinuing preparation of mental disclosure Ii

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Stephen Dilley, Solicitor 2 hours at £175.50 £351

ring Defendant/Part Jaimant’s Witness ments ing 4 witnesses’
Tom Beezer, Partner 6 hours at £238.50 £1,431
Stephen Dilley, Solicitor 10 hours at £175.50 £2,106
Reviewing expert's report (assuming 1 Expert for Claimant)
Tom Beezer, Partner 1 hours at £238.50 £238.50
Stephen Dilley, Solicitor 5S hours at £175.50 £877.50
Trainee 1 hours at £90 £90
Attendance and Pre, ion for Pre Trial Review (including travel,
Stephen Dilley, Solicitor 11 hours at £175.50 £1,903.50
Preparing Brief to Counsel
Stephen Dilley, Solicitor 2 hours at £175.50 £351
Trainee 6 hours at £90 £540

Trial Preparation (assuming 10 day heari

Tom Beezer, Partner 2 hours at £238.50 £477
Stephen Dilley, Solicitor 20 hours at £175.50 £3,510
Trainee 30 hours at £90 £2,700

Attendance at trial (assuming 10 day hearin

Stephen Dilley, Solicitor 65 hours at £175.50 £11,407.50

Trainee 65 hours at £90 £5,850

Travel to and from trial (assuming 10 day heari

Stephen Dilley, Solicitor 18 hours at £175.50 £3,159

Trainee 18 hours at £90 £1,620
rial work after each day’s hearing?

Stephen Dilley, Solicitor 20 hours at £175.50 £3,510

Trainee 20 hours at £90 £1,800

Part C sub total estimated Solicitor’s fees from 21 November 2006 to trial £53,887.50

VAT on estimated Solicitor’s fees from 21 November 2006 to trial £9,430.31
nticipates 21 Nov er tri

Counsel’s Fees

Balance of Brief Fee not yet deemed delivered £20,000

Refreshers £2,500 per day (9 days) £22,500

VAT on Counsel's Fees £7,437.50

2 This is during the evening and weekend during the trial when the Court is not sitting and does
not relate to enforcement of any judgment or order post trial

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Other Expenses

Photocopying, faxes couriers and general disbursements, say £3,000
Accountancy Expert, say £12,062.95
VAT on other Expenses £2,636.02

Part C: Total estimated costs from 21 November 2006 to trial £132,854.28°
GRAND TOTAL PARTS A, B AND C: £294,357.40

The costs estimated above do not exceed the costs which the Claimant/Part 20
Defendant is liable to pay in respect of the work which this estimate covers.

Dated 20 November 2006
Signed

Tom Beezer
Partner

Name of firm of solicitors - Bond Pearce LLP

Solicitors for the Claimant/Part 20 Defendant

3 This assumes that the trial will start on 4 December 2006. In the event of any
adjournment, this is likely to significantly increase the overall costs.

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IN THE HIGH COURT OF JUSTICE Claim No. HQ05X02706
QUEEN’S BENCH DIVISION
BETWEEN:
POST OFFICE LIMITED Claimant/Part 20
Defendant
-and-
LEE CASTLETON Defendant/Part 20
Claimant

ESTIMATE OF CLAIMANT/PART 20 DEFENDANT'S COSTS
DATED 20 NOVEMBER 2006

BOND PEARCE LLP
Ballard House

West Hoe Road
Plymouth PL1 3AE

DX 8251 Plymouth
Ref: SJD3/348035.134

Solicitors for the Claimant/Part 20
Defendant

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