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From: David Cavender 4_
To: 'Amy Prime!
: Andrew Parsons
Subject: RE: Trial Bundle [WBDUK-AC.FID27103678]
Date: Fri, 21 Sep 2018 16:42:46 +0000
Importance: Normal
Inline-Images: image001 jpg; image002.png; image003.png; image004.png
Amy,
Many thanks for this.
Whilst I can see the logic of this —I think there are some documents which are post contractual that we might
want to put to witnesses for reasons of prejudice.
By way of example: cases such as Sabir and Abdula : the documents such as audit reports revealing their
deficits — how they were caused — what they said at the time etc: these will be useful in asking questions
which will assist on the optics of the case and go to the credibility of the witness.
I will try and identify as I go through the cases those documents in this category that it might be useful to
include to assist you in this process.
Best,
David Cavender Q.C.
One Essex Court
Temple
London EC4Y 9AR
ONE ESSEX COURT
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Switchboard:
Fax number:
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From: Amy Prime [mailta
Sent: 21 September 2018 17:36
To: David Cavender [G RO]
Ce: Andrew.Parson:
I GRO}
Subject: RE: Trial Bundle [WBDUK-AC.FID27103678]
Gideon
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 [mailtot
Sent: 21 September 2018 13:32
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
Direct dial:
Switchboard:
Fax number:
Mobile:
www.oeclaw.co.uk
The contents of this email are CONFIDE)
the intended recipient, please telephone
be PRIVILEGED. If you are not
ind delete this email.
From: Amy Prime [mailto:
Sent: 17 September 2018 1
To: David Cavender <_~ [GRO] —_——>
Subject: FW: Post Office Group Litigation: Strike Out Application
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David
Please find attached the strike out application as served.
Thanks
Amy
Amy Prime
Solicitor
Womble Bond Dickinson (UK) LLP
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