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From: Amy Prime
To
Katie Simmonds { Lucy Bremner
Ce: Andrew Parsons} __.... GRO i
Subject: RE: Witness Statement - OCR and Peak [WBDUK-AC.FID26896945]
Date: Mon, 17 Jun 2019 22:05:35 +0100
Importance: Normal
Attachments: 544 Bates_18th_Witness_Statement_of_Andrew_Parsons_-
_17_June_19_ORD_te (....docx
Embedded: New_Peak_[WBDUK-AC.FID123822914];
RE:_7_additional_bug_reports:_disclosure_[WBDUK-AC.FID 123887118]
Inline-Images: image001.png; image002.png; image003.png; image004.png; image29424b.PNG;
image7bb2b4.PNG; imagec2eb73.PNG; image48148f.PNG
Hi All
Two questions from TRQC on the Peak disclosure — if you could respond first thing in the morning that would be
helpful as I can then get the witness statement over to FJ.
1. [WHAT ABOUT ALL THE OTHER POST 17 AUGUST 2018 PEAKS THAT HAVE COME INTO EXISTENCE —
HAVE THEY NOT BEEN DISCLOSED AT ALL?]
My understanding is that no other peaks which postdate 17 August 2018 have been disclosed since neither
Freeths nor Coyne have asked for disclosure of these documents. Please could you check whether you know
of any other peaks which were disclosed separately (ie. other Peaks which FJ gave us as when doing the bug
work?
2. [CAN WE ADD A SENTENCE EXPLAINING WHY IT TOOK FROM 3 APRIL TO 31 MAY FOR THE
DOCUMENT TO BE DISCLOSED, TO FORESTALL A DEMAND FROM THE JUDGE FOR A FURTHER
WITNESS STATEMENT EXPLAINING THIS?]
The Peak was provided to Katie by Matthew on 29 March 2019 (email attached), the documents were
processed into R on 4 April, but my understanding is that we waited until the bug investigations were
substantially complete and we had what we believed to be all of the new documents which we thought would
come out of these investigations and then disclosure was given all in one go. Does this match your
understanding? This comes partially from Katie's email to Charlie on 22 May 2019 (attached) which just
predates the disclosure of this peak.
Thanks
A
Amy Prime
Associate
Womble Bond Dickinson (UK) LLP
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From: Anthony de Garr Robinson [mailto}
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,
T 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 Prim
Sent: 17 June 2019 13:59
_} Jonathan
; Lucy Bremner
>; Katie Simmonds {
; Andrew ParsonsI,
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.
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
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