WBON0000684 - Email from Andrew Parsons to Anthony de Garr Robinson, CCing Tom Beezer, Amy Prime and others, Re: Recusal

Evidence on official site

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From: Andrew Parson:
To: Anthony de Garr Robinson
Ce: Tom Beezer I GRO 4} Amy Prime GRO i

Gideon Cohei GRO 1, "Owain Draper! GRO H

"David Cavender{ GRO I

Subject: RE: Recusal
Date: Wed, 20 Mar 2019 20:54:01 +0000
Importance: Normal
Inline-Images: imaged33ee8.PNG; imageeae657.PNG; image8fda3a.PNG

Tony — I've copied the rest of the team so we're all of the same mind.

The application won't be ready by 10:30am. It will go in during the course of the day tomorrow — probably in the
afternoon.

The plan is to ask for the application to be heard during Brexit week in the covering letter. The application will be filed
by email to the Judge's clerk, so he may not even know that it has been filed by the end of the Court day. We are not
looking to embarrass him (yet) so unless he raises it, I think our plan is to say nothing in Court.

My feeling is that we keep you ring-fenced from it, so that you can plead ignorance. If asked, you can say that you are
not aware of the details of the application, PO is being advised by Lord Grabiner and that you can relay any message
as required. But just so you know, the draft Order includes an immediate stay of the HIT.

Owain — can you make sure you have LGQC and Gideon's diaries for next week in case we get drawn into a listing
discussion.

Thoughts from anyone else? Feel free to disagree.

Andrew Parsons
Partner
Womble Bond Dickinson (UK) LLP.

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From: Anthony de Garr Robinson [mailto:
Sent: 20 March 2019 20:45

To: Andrew Parsons

Subject: Recusal

Dear Andy,

Am I right in thinking that the recusal application will be issued and will be in with the judge by the time
court starts at 10:30 tomorrow morning? If so, I have a strange feeling that he might want to discuss it with
me and that I will need to know what to tell him. When have we made the applic returnable, for example,
and what proposals are we making regarding its resolution? And do we have any suggestions to make about
the Horizon trial proceeding in the meantime?

Tony

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