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From: Victoria Brooks
To: Ed Duffield
Ivan Roots <
, Helen Creech <
Dave Panaech
, Mandy Robertson <
GRO
Ce: Andrew Parsons <,
Subject: Group action - witness evidence - generic evidence [WBDUK-AC.FID26896945]
Date: Tue, 3 Jul 2018 14:02:46 +0000
Importance: Normal
Attachments: _DOC_150432261(5) List_of_witnesses_and_issues_to_be_covered_-_following....nrl;
_DOC_150578291(1)_Horizon_Group_Action_-_Witness_Contact_Sheet_3_Jul_18.nrl;
POST_OFFICE_EVIDENCE_-_list_of_subjects.docx;
Helen_Dickinson_Signed_Statement.pdf;
_DISPUTERESOLUTION_38847158(1)_Angela_Van_Den_Bogerd_Proof_of_Evidence
_(....doex;
DOC_150130033(1)_ Proof_of Evidence _Sarah_Rimmer_(amended_by_SR_22_May_
1....docx;
_DOC_150194633(4) Proof_of Evidence John_Breeden_final_version_16.05.18....doc
x; _DISPUTERESOLUTION_ 38104083(3)_Proof_of Evidence -
_Kendra_Dickinson.docx; _DOC_38565379(3)_Proof_of_Evidence_-
_Kim_Abbotts.docx; _E-MAIL_38235208(2)_Proof_of_Evidence_-
_Michael_Z_Shields.DOCX; _DOC_38270676(1)_Proof_of_Evidence_-
_Kjetil_Fuglestad.docx; _DISPUTERESOLUTION_38029946(2)_Proof_of_evidence-
_Alison_Bolsover.docx;
_DISPUTERESOLUTION_38103726(2)_Proof_of_Evidence_Dawn_Phillips.DOCX;
_DOC_38087595(2) Proof_of Evidence_-_Michelle_Stevens.docx;
_DOC_150432261(5)_List_of_witnesses_and_issues_to_be_covered_-_following....docx
Inline-Images: image10193c.PNG; image6c203c.PNG; image99f475.PNG
All
I attach:
Draft list of issues to be covered in witness evidence organised by name of witness (there will be some more issues
added/ fleshed out and some issues may be moved around a little which we are working on, but this will give you the
general theme of each witness's evidence. It is likely many of the unallocated issues will be added to Angela's
statement). Copy as is and link attached. I will circulate a new version when this is updated;
For context, counsel's original list from which the list of issues came;
Contact details list;
The plan for the generic evidence is for Angela Van-Den-Bogerd to give the main evidence, and this to be surrounded
by statements covering other areas. We will also need to do witness statements for some other witnesses to cover off
specific points in the individual defences — we will progress these once the statements below are in hand.
Back in January / February there was a project where we went out to see most of the witnesses below to proof them.
These were more general chats so the proofs we have done are often very informal and written as they spoke.
However, for those witnesses where we have done a proof, this is attached and I suggest this would be a good starting
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point for their evidence. Some of these have not been signed off, but we do not actually need those proofs signed off
since we are now moving to formal statements, and can just use the proofs as raw materials.
Please can you start calling your witnesses to introduce yourself and start doing the pre-work needed before seeing
them, and arrange calls or meetings with them as appropriate?
Dave is working on an email relating to policy documents which may need to be picked up with the witnesses, and this
will follow asap.
The deadline for statements is 10 August. This includes both generic and specific (which are not covered in this email)
so this will be a busy period.
Please do ask me any queries.
Thank you for your assistance with this.
Kind regards
Victoria
Name of WBD lawyer Name of witness Status of any proof done
previously
Ivan Angela Van-Den-Bogerd Signed - attached
Dave Nick Beal None — Paul Inwood proof may be
useful — Nick is doing a mark up of it
so this is to follow
Dave Stewart Barclay None — Paul Inwood proof may be
useful — Nick is doing a mark up of it
so this is to follow
Dave John Breeden Attached — in the process of being
finally approved by John
Ed Sarah Rimmer Signed — attached
Ed, Mandy did the proof on this one
so if you can't manage all 3, this is
probably the one to leave for
Mandy/me.
Ed Rachel Chari None
Ed Kendra Dickinson Attached — to be approved
Helen Kim Abbotts Attached — to be approved
Helen Helen Dickinson Signed - attached
Mandy Michael Shields Attached — to be approved
Mandy Kjetil Fuglestad Attached — to be approved
Helen — I Michelle's and Alison's are attached
please hold off contacting for now as_I ~ to be approved
we are still deciding about this
witness
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Dawn Philips may also be relevant -
attached
Victoria Brooks
Managing Associate
Womble Bond Dickinson (UK) LLP.
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