WBONO0000654
WBON0000654
From: Amy Prime fy
Mark Underwood]
Subject: Appeal Review [WBDUK-AC.FID26896945]
Date: Mon, 11 Mar 2019 19:36:59 +0000
Importance: Normal
Inline-Images: imagea6a0eb.PNG; image23fcf6.PNG; imagebe8bdc.PNG
Dear All
We have discussed with Counsel in more detail the appointment of a senior QC to review the judgment, grounds of
appeal and provide advice on the merits of an appeal. There are two options:
e The Rt. Hon. Lord Neuberger — retired as the President of the United Kingdom Supreme Court in 2017. Lord
Neuberger would be able to provide strategic and merits advice on the appeal. He would however not be
able to represent Post Office in Court (having previously sat as a Judge). If we wish to,instructLord
Neuberger then it would be necessary to do so asap (ideally tomorrow). Hourly rate of}
e Lord Grabiner QC — a very senior QC who would be well placed to provide strategic advice and merits on the
appeal, but would also be able to represent Post Office in the Court of Appeal if it was decided that a senior
QC would assist with the presentation of Post Office's cas -ord.Grabiner is currently under brief for a
different matter but has some availability. Hourly rate 3
With either option we would also be looking to appoint a couple of junior Counsel to assist with the production
of the advice.
Since Lord Neuberger would not be able to represent Post Office in Court, we would recommend that Post Office
instruct Lord Grabiner QC to review the judgment (and surrounding documents such as the opening and closing
submissions, witness statements and pleadings) and provide advice on the strategy to be adopted for the appeal and
the merits of an appeal. We would roughly estimate the costs of obtaining this advice to be c.£80 to 100k, but would
be able to firm this estimate once we have provided Lord Grabiner QC with the papers.
These are the very best QCs/Judges available and clearly command a premium price. The alternative would be to
instruct a contemporary of David and Tony (noting that they are already very highly respected silks so this is already a
highly-qualified level) but at a more proportionate cost. If you would like us to look at this option, please let me know
and we will propose some names.
If you have any questions on the scope of the review to be undertaken, please let me know. Otherwise, please could
you confirm that we can begin with instructing Lord Grabiner QC?
Kind regards
WBD_000524.000001
Amy
Amy Prime
Solicitor
Womble Bond Dickinson (UK) LLP
Stay informed: sign up to our e-alerts
Join us for Disrupting Disputes 2.0
20 March 2019 at the British Library
Book your place here
WOMBLE womblebonddickinson.com
DICKINSON Ow
WBONO0000654
WBON0000654
WBD_000524.000002