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From: Andrew Parsons I
To: Gideon Cohen <"
! GRO >, Mandy Robertson
IGRO__ >, Amy Prime < GRO +, Victoria Brooks
Owain Draper <.
Subject: RE: Examination in chief
Date: Tue, 13 Nov 2018 21:22:46 +0000
Importance: Normal
Inline-Images: image2a7db1.PNG; image7d3da8.PNG; imaged0ce00.PNG
Gideon - These are fine.
Dave / Victoria — between you, please can you let the witnesses know the general nature of the questions they will
get.
Gideon - two other points.
What are we doing about the Stubbs defence that refers to docs from Paul Williams that Paul did not send? This is not
a problem with Paul's evidence but a mistake by the legal team in preparing the Defence so I think we need to own up
to this.
I'm really not comfortable that the Judge has a clear understanding of how SPMRs can dispute either transactions
corrections or end of trading period shortfalls. We could pick this up with Angela?
Thoughts?
A
Andrew Parsons
Partner
Womble Bond Dickinson (UK) LLP
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From: Gideon Cohen [mailto
Sent: 13 November 2018 18:35
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To: Dave Panaech; Mandy Robertson; Amy Prime
Cc: Andrew Parsons; David Cavender; Owain Draper
Subject: Examination in chief
All,
Please see attached the 2 documents we are currently intending to present as typo-corrections for our
witnesses.
There are a number of other points which will be canvassed in examination in chief rather than by written
correction, because they are (a) new evidence and/or (b) more involved than a typo correction. Currently, we
have questions for Beal (clarifying which hotline was 24 hr); Haworth (clarifying which checklist he used,
and mentioning the CoA for the Crossflatts branch); Trotter (explaining why he didn’t go through the
contract in his first interview with Dar); and Van Den Bogerd (giving figures on how many branches, both
generally and of the Cs in this case, are run by (a) companies and/or (b) multiples).
The additional points for examination in chief which arose today were for Longbottom (explaining the nature
of the 2 page balancing guide, and that it was not a replacement for the manuals) and Ridge (explaining that
there were 2 different Christines with different jobs).
Please let me know if there are any queries, internally or from the witnesses, on what will be covered.
Thanks
Gideon
Gideon Cohen
Barrister
One Essex Court
Temple
London EC4Y 9AR
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