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From: Gideon Cohe
To: 'Amy Prime’!
Ce: Stephanie Wood }
Owain Draper ¢
David Cavender {.
Anthony Grabiner
Subject: RE: Letter from Freeths - Recusal [WBDUK-AC.FID26896945]
Date: Tue, 26 Mar 2019 15:05:15 +0000
Importance: Normal
Inline-Images: image001.png; image002.png; image003.png
Andrew Parsons {.
Yes. If they think our submissions go beyond the scope of the WS, that is something they can complain about at
the appropriate time. They have more than enough information.
From: Amy Prime [mailto::
Sent: 26 March 2019 15:02
To: Gideon Cohen
Cc: Stephanie Wood; Tom Beezer; Owain Draper; Dave Panaech; David Cavender; Andrew Parsons
Subject: Letter from Freeths - Recusal [WBDUK-AC.FID26896945]
Gideon
Please find attached a letter from Freeths complaining that Post Office have not complied with the Order since the list
provided in Parsons 15 is non-exhaustive and did not identify all matters, and that we have simultaneously gone
further than permitted by the Order by seeking to rely on the “structure, tenor and subject-matter of the judgment as a
whole”.
The Cs have requested that we confirm whether we intend to rely on other parts of the Judgment and to identify them
in a further witness statement by 6pm today. If we do not do so the Claimants are considering to seek an unless order
/ tell Fraser.
I assume the approach when responding will be that the information required to understand the basis for POL's
application and to enable the Cs to respond has been provided, but we would welcome your thoughts and comments.
In particular, POL may ask what is the risk of the Managing Judge forcing POL to provide further information and
thereby delaying the recusal hearing.
Kind regards
Amy
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Amy Prime
Solicitor
Womble Bond Dickinson (UK) LLP
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