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From: Owain Draper
: Gideon Cohen}
_ Anthony
Grabine: ;
Subject: Re: Letter from Freeths - Recusal [WBDUK-AC.FID26896945]
Date: Tue, 26 Mar 2019 15:17:17 +0000
Importance: Normal
Inline-Images: image001.png; image002.png; image003.png
Agreed.
How about this?
“We do not agree that the witness statement fails to comply with the Order. If your client wishes to contend
at the hearing that any argument made by Post Office goes beyond the witness statement and/or amounts to
an “ambush”, that submission can be made. We do not propose to provide a further statement.”
Owain Draper
One Essex Court, Temple
EC4Y 9AR
Switchboard:
www.oeclaw.co.uk<http://www.oeclaw.co.uk/>
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From: Gideon Cohen
wain Draper
David Cavender
nthony Grabiner
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
Ce: Stephanie Wood; Tom Beezer; Owain Draper; Dave Panaech; David Cavender; Andrew Parsons
Subject: Letter from Freeths - Recusal [WBDUK-AC.FID26896945]
Gideon
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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.
T 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
Amy Prime
Solicitor
Womble Bond Dickinson (UK) LLP
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