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POL00070049
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£ shen Dilley
From: Stephen Dilley
Sent: 08 January 2007 11:26
To:
Ce: Tom Beezer; ‘Richard Morgan’, martyn.mitchelt “GRO I
Subject: P.O -v- Castleton
Attachments: eCopy scanned document.pdf
Dear Mandy,
I refer to my email of 3 January. Please could you call me when you're out of your meeting
today?
I attach a copy of my letter dated 4 January to Mr Castleton and his reply of today. He has said
that he will be 45 minutes with each witness and that he wants to out questions to them arising
from the Tivoli logs and that they are relevant to the “integrity of the system and balances." As
I've said before, I think that he would construe anything we gave to him as the crown jewells,
irrespective of whether it was truly relevant.
If we oppose his application on Thursday (on the grounds that the issues he raises are
irrelevant and disproportionate) but he succeeds i.e the Court says he can examine 2 of our
witnesses, then we will have to go back to Court again. On the other hand, I have checked with
Anne Chambers and Ruth Simpson and they could both attend Court this Thursday. The Court
has sufficient time to accommodate their re-examination. Therefore, on balance, I think we
should recall them and let Mr Castleton ask any questions on Thursday (so at least he thinks
he's had a fair shot, thereby reducing the chances of him successfully getting permission to
appeal if judgment is against him). Hopefully, this would at least get it done and we will then
get judgment on the day or shortly afterwards. Do you agree? If so, I'll line up the Court and
witnesses.
I look forward to hearing from you.
Kind regards.
Stephen Dilley
Solicitor
__for and on behalf of Bond Pearce LL
08/01/2007