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From: Rob Smith
To: 'Amy Prime’; _ GRO .
Ce: Andrew Parsons! GRO I Tom Beezer! GRO
Subject: RE: Post Office Group Litigation - Appeal [WBDUK-AC.FID26896945]
Date: Tue, 12 Mar 2019 14:57:39 +0000
Importance: Normal
Inline-Images: image001.png; image002.png; image003.png
Dear Amy,
Thank you for the below.
David has spoken to Lord Neuberger and has provided some documents for him to review. They are also
meeting again tomorrow.
I will get back to you about timescale and fees asap.
In relation to Lord Grabiner. I will of course make a note that you have first refusal on his time and I have
mentioned this matter to him. He is interested but it will all depend on when the application is needed. If it is
at a critical stage in his current preparation or significantly close to his trial we may need to reassess.
I will be in touch.
Kind regards
Rob
Robert Smith
www.oeclaw.co.uk
From: Amy Prime:
Sent: 12 March
To: Rob Smith
Direct dial:
Switchboard:
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Ce: Andrew Parsons
Subject: Post Office Group Litigation - Appeal [WBDUK-AC.FID26896945]
Hi Rob
Further to our discussion, Post Office would like to instruct Lord Neuberger to:
Provide advice on the merits of a recusal application and whether such an application should be made.
If the answer to (1) is that Post Office should make a recusal application, then please could Post Office be advised on
the process and procedure for making a recusal application, and the approach that the Court would take in
determining such a matter.
Provide an opinion on the appeal of contractual issues and the implication of terms.
Questions (1) and (2) are more urgent and we would appreciate if this advice could be provided before (3). Once Lord
Neuberger has had an opportunity to consider the papers, it would be appreciated if he could provide estimated
timings for the advice being produced and confirm fee estimates.
Electronic reading bundles will follow shortly, with hard copies to be couriered to One Essex Court. In the meantime,
please could you could discuss with David Cavender QC providing a verbal briefing to Lord Neuberger.
In relation to Lord Grabiner QC, as discussed please could Lord Grabiner QC be placed onto a first right of refusal for
the potential to attend on behalf of Post Office at a recusal hearing. Please could this arrangement be put in place up
until his trial which begin on 30 April 2019. If availability does become an issue, please could you let either Andy, Tom
or me know. It would be appreciated if this arrangement could be confirmed by email?
If there are any questions on the above, please let me know.
Kind regards
Amy
Amy Prime
Solicitor
Womble Bond Dickinson (UK) LLP.
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