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FREETHS
Bond Dickinson LLP
DX 38517 4
Southampton3 Switchboard: +.
Email: james.hartle
By email: andrew.parsons
13 October 2017
Our Ref: = JXH/1684/2113618/1
Your Ref: AP6/364065.1369
Dear Sirs,
BATES & OTHERS -V- POST OFFICE LTD
Claim No: HQ16X01238
Fourth Witness Statement of Mr Parsons
We write to record our surprise at the position taken in your third letter of 10 October 2017, in
relation to the late witness statement.
In summary, you hinted at the possibility of a witness statement about disclosure at an unspecified
time; you sought no direction for the filing of any evidence before the CMC (whether immediately
after Order No.1, or at all) nor any agreement about the same; and the statement raised
controversial matters 6 minutes after the deadline for exchanging and lodging Skeleton Arguments.
We note that your letter fails to answer the simple questions which we asked as to (i) when you
decided to file a witness statement and (ii) when work began on it.
You have been less than forthcoming about this witness statement and its timing has been
extremely unhelpful and disruptive.
We are not in a position not to respond to all the matters which you have raised for the first time as
to disclosure, but will endeavour to do so before the CMC. On other particular points, we will
respond on Monday.
Yours faithfully
Frooths LLP is aiited abity partnership, registered in England and Wales, partnership number 06904688, Registered ice: Cumberland Cour, 80 Mount treet, Notingham NG1 SHH
‘Ruoreed and regulated by the Solctore Regulation Author, ful tof the members of Freethe LLP is available or inspection atthe registred fis,
www.freeths.co.uk Freeths LLP, Floor 3, 100 Wellington Street Leeds, LS1 4LT DX 310016 Leeds Park Square
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Freeths LLP
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