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From: Amy Prime
To: Anthony de Garr Robinson
Ce: Owain Draper!” 3 'Simon Henderson'
{ GRO I Jonathan Gribben + GRO i
Katie Simmonds GRO. . Lucy Bremner
, Andrew Parsons
Subject: RE: Witness Statement - OCR and Peak [WBDUK-AC.FID26896945]
Date: Tue, 18 Jun 2019 08:21:14 +0000
Importance: Normal
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Tony, Owain
Thank you. In response to your queries:
No other post 17 August 2018 Peaks have been disclosed. There was no disclosure ordered requiring these to be
provided and the Cs / Coyne have not asked for disclosure of these documents. This is in contrast to the KELs where
the Cs did ask for a further export to be run and disclosure of the newer KELS was given.
On the timing of the disclosure, PC0273234 was disclosed due to it being a known adverse document. WBD waited
until the investigations into the Coyne bugs were substantially completed and therefore the likelihood of further
disclosure being uncovered was thought to be low. Once we had this batch of documents that had come to light as
part of the investigations into the bugs, disclosure of them was provided all together. With hindsight, yes the document
could have been disclosed sooner but we were seeking to not drip-feed documents to the Cs on a daily basis.
We will be sending the draft witness statement to FJ and POL this morning and will circulate any revisions shortly.
Kind regards
Amy
Amy Prime
Associate
Womble Bond Dickinson (UK) LLP
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From: Anthony de Garr Robinson [mailt«
Sent: 17 June 2019 19:10
To: Amy Prime
Cc: Owain Draper; 'Simon Henderson’; Jonathan Gribben; Katie Simmonds; Lucy Bremner; Andrew Parsons
Subject: RE: Witness Statement - OCR and Peak [WBDUK-AC.FID26896945]
Dear Amy,
I enclose Owain’s and my combined suggestions for your draft statement. The last sentences of paras 6 and
16 need to be checked for absolute accuracy and may well need to be toned down. As regards the questions
at the end of para 21 and in para 22, I’m hoping we have satisfactory answers. If we don't, we know how the
judge will react. Quite apart from anything else, he may require further witness statement to be made.
Best wishes,
Tony
From: Amy Prime
Sent: 17 June 2019 13:59
To: Anthony de Garr Robinso1
Ce: Owain Draper
Jonathan Gribbe: Katie Simmonds
Lucy Bremner £. ndrew Parsons ¢
Subject: Witness Statement - OCR and Peak [WBDUK-AC.FID26896945]
‘Simon Henderson"
Dear Tony
Please find attached a draft witness statement explaining the recent OCR disclosure and the disclosure of the drop
and go Peak — comments and thoughts welcome.
We also have two questions:
1. Should this witness statement come from Andy or Katie (or another solicitor at WBD)? Andy wasn't particular
involved in either of these matters so is giving a lot of hearsay evidence in this statement. Katie was closest to
the OCR disclosure, with Jonny being closest to the Peak disclosure.
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2. Do we want to waive privilege and exhibit to the witness statement the attached emails between Katie and FJ?
We would propose disclosing up to (and including) the email on 12 April 2019 @1620. Disclosing emails past
this point runs the risk of disclosing to Freeths the matters concerning the deletion.
Jonny — please could you also read the section which discusses your conversations with Pete Newsome re extraction
of the Peak system and confirm they are correct?
Kind regards
Amy
Amy Prime
Associate
Womble Bond Dickinson (UK) LLP.
" GRO
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