WBON0001328 - Email from Amy Prime to David Cavender CC: Andrew Parsons, Owain Draper and others RE: Trial Bundle [WBDUK-AC.FID27103678]

Evidence on official site

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WBON0001328

From: Amy Prime
To: David Cavender
Ce: Andrew Parsons

Subject:
Date: Fri, 21 Sep 2018 16:36:01 +0000
Importance: Normal

Attachments: 2018.09.12 Fifth Letter_to_Freeths _(Trial_Bundle_Index) (1).pdf;
2018.09.12 Enclosure_to_Fifth_Letter_to Freeths _WBD_Draft_Index_579152_1_(1).d
ocx

Inline-Images: image001 jpg; image002.png; image003.png; image004.png; image55f9d1.PNG;
image6868e4.PNG; imageb5e538.PNG

David

Please find attached a first draft of the trial bundle index which we sent to Freeths on 12 September. The bundle

naming does not exactly reflect the outline in Schedule 1 of 6!" CMC Order as this index was produced beforehand,
but Bundle E is Section D in the attached index.

Your understanding is correct. This bundle is intended to contain a chronological run of the documents which relate to
the Lead Claimants (mix of exhibits and other documents in disclosure). So far we have inserted the documents which
have been disclosed and are dated prior to the contract being entered / the C entering into the branch. We have
asked the Cs to confirm any other documents which they wish to include in this section and to add the documents.
which they disclosed late after we had already produced the index.

We have chased Freeths for a response to this, but no comments have been received yet. We will chase again on
Monday.

Kind regards
Amy

Amy Prime
Solicitor
Womble Bond Dickinson (UK) LLP

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From: David Cavender [mailto:
Sent: 21 September 2018 13:32

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WBON0001328

To: Amy Prime
Cc: Andrew Parsons; Owain Draper; Gideon Cohen
Subject: Trial Bundle

Hi Amy,

I have been thinking about Bundle E of the proposed trial bundle “Lead Claimants Documents Bundle”. I
am right in thinking that this will be a mix of the documents in their exhibits and relevant (additional parts)
of the disclosure in chrono order ??

When might that part of the bundle be ready ? It is obviously particularly important for my cross
examination prep to get that part as soon as possible.

Best,

David Cavender Q.C.

One Essex Court ‘ ONE ESSEX COURT

Temple
London EC4Y 9AR WY

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www.oeclaw,co.uk

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From: Amy Prime [mailto:
Sent: 17 September 2018 1
To: David Cavender
Subject: FW: Post Office Group Litigatior

Strike Out Application

David

WBD_001198.000002
WBON0001328
WBON0001328

Please find attached the strike out application as served.

Thanks

Amy

Amy Prime
Solicitor
Womble Bond Dickinson (UK) LLP.

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