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From: Andrew Parsons
To: Owain Draper
Gideon Cohen
Ce: Tom Beezer I
Anthony Grabiner
Subject: RE: Post Office Group Litigation - Recusal Application
Date: Wed, 27 Mar 2019 10:44:30 +0000
Importance: Normal
Inline-Images: imagec08577.PNG; image43c5a2.PNG; imagee6195f.PNG
I prefer option 2 (with one change below).
I would welcome thoughts from the rest of the Counsel team?
A
Andrew Parsons
Partner
Womble Bond Dickinson (UK) LLP.
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From: Owain Draper [mailtof
Sent: 27 March 2019 10:35
To: Andrew Parsons; Amy Prime; Gideon Cohen; David Cavender
Cc: Tom Beezer; Dave Panaech; Anthony Grabiner
Subject: Re: Post Office Group Litigation - Recusal Application
The main alternative is to confirm that, subject to our point about the Judgment being read as a whole, we
have identified all the passages on which we intend to rely. We would, in effect, be deleting the words “in
particular” from the sentences that introduce each category of point.
Whether or not we want to do that depends on whether the rest of the counsel team thinks that amounts to
tying our hands too much.
One further option would be to say practically the same thing as below but with slightly more words. For
example:
“We have responded fully to your letter of yesterday. There are no further paragraphs that we wish to identify
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in accordance with the Order.
Your clients now have the benefit of a 44-page witness statement filed in accordance with the Order and have
notice of the parts of the Judgment to which Post Office objects. We offered to provide a Skeleton Argument,
which would have given you early sight of the arguments on the application as well as the relevant passages,
but you preferred to seek a witness statement.
Your clients can, on the basis of the witness statement, form a view as to whether or not they wish to oppose
the application. If your clients require more time to decide on whether to oppose the application, our client
has no objection to the deadline for this being extended from 12noon today to 5pm today. Weinviteyotte
f ith the-deadline-in-the-Order2.
*f SOTY t 9
Kind Regards,
Owain
Owain Draper
One Essex Court, Temple
EC4Y 9AR
www.oeclaw.co.uk<http://www.oeclaw.co.uk/>
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intended recipient, please delete it permanently and inform the sender.
From: Andrew Parsons ft
Date: Wednesday, 27 March 2019 at 10:21
To: Owain Draper .
_} Gideon Cohen
Dave Panaech Anthony
Subject: RE: Post Office Group Litigation - Recusal Application
I would normally agree, but given historic allegations of PO being dismissive, do we want to write
something more substantive?
A
Andrew Parsons
Partner
Womble Bond Dickinson (UK) LLP
d:
m:
t
e:
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From: Owain Draper [mailto
Sent: 27 March 2019 10:17
To: Amy Prime; Gideon Cohen; David Cavender
Cc: Andrew Parsons; Tom Beezer; Dave Panaech; Anthony Grabiner
Subject: Re: Post Office Group Litigation - Recusal Application [WBDUK-AC.FID26896945]
We could, however, respond with something like this (just so Cs cannot say we ignored their letter):
“We have responded fully to your letter of yesterday. We have nothing to add.”
Owain Draper
One Essex Court, Temple
EC4Y 9AR
Switchboard.
www.oeclaw.co.uk<http://www.oeclaw.co.uk><http://www.oeclaw.co.uk/>
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From: Amy Prime
Date: Wednesday, 27 March 2019 at 09:54
To: Gideon Cohen ~_}, David Cavender
“GRO
!Tom Beezer
Subject: FW: Post Office Group Litigation - Recusal Application [WBDUK-AC.FID26896945]
Dear All
Please find attached Freeths' response to our letter of last night. The back correspondence is also attached.
They are planning to "proceed on the basis that you will not be relying on any parts of the Judgment to
which you have not expressly referred in Parsons 15" unless we tell them otherwise by 11am and may seek a
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hearing with the Judge to discuss this matter and delay the recusal hearing.
Thoughts and comments welcomed.
Kind regards
Amy
Amy Prime
Solicitor
Womble Bond Dickinson (UK) LLP
erBe
oy
D
O
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From: Miranda Bond [mailto:
Sent: 27 March 2019 09:42
To: Dave Panaech; Charlie Temperley; Andrew Parsons; Amy Prime; Emma Campbell-Danesh; Victoria
Brooks; Jonathan Gribben; Michael Wharton; Anna Martin; Lucy Bremner; Beth Hooper; Katie Simmonds;
Sushma MacGeoch; Rachel Lawrie; Jane Atkinson; Mandy Robertson
Ce: James Hartley; Imogen Randall; Dean Hill; Stephanie Jameson; Chloe Oram; Nicola Pettit; Angélique
Richardson; Sarah Bogues; Francesca See
Subject: Post Office Group Litigation - Recusal Application
Dear Sirs,
Please see attached our firm’s letter of today’s date.
Yours faithfully,
Freeths LLP
Miranda Bond
Legal Assistant
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Freeths LLP
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