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From: Stephanie Wood <
To: Gideon Cohen <
Ce: Amy Prime <~ David Cavender <i
Andrew Parsons i
Subject: RE: timing of readiness for recusal [WBDUK-AC.FID26896945]
Date: Tue, 19 Mar 2019 22:29:31 +0000
Importance: Normal
Attachments: Draft_application_notice_19.03.2019_v2.doc
Dear all,
I attach the draft application notice.
Kind regards,
Stephanie
From: Gideon Cohen
Sent: Tuesday, March 19, 2019 9:21 PM
To: Tom Beezer
Cc: Amy Prime; David Cavender; Andrew Parsons; Stephanie Wood
Subject: Re: timing of readiness for recusal [WBDUK-AC.FID26896945]
On 19 Mar 2019, at 20:28, Tom Beezer <.
wrote:
All
Jane at POL is wanting an update on timing of readiness for recusal if the button is pressed tomorrow.
Could each of you comment on what I set out below (and what I do set out below is just my understanding of
where we are, so do correct at will...)...:
- Letter to Freeths — Amy is doing that. Yet to be done, but is only short.
- Application Notice. Gideon. Done I believe?
Stephanie has done a draft, on which I have commented. Stephanie, once you are happy with it, could you
please circulate?
- Draft Order. Done I believe. I think I have seen a copy.
Yes, circulated on Sunday. Please let me know if any comments.
- Draft witness statement. Work in progress. Amy P is collating the back story (quotes from hearings etc) and
then Amy and Gideon to bully that into a first draft. Realistic for tomorrow ?
Difficult to comment on timings until I’ve seen a draft. More fundamentally, spoke about this to Tony today.
His view was that we might want to hold this back for the hearing, and not put in a WS at all. That would
involve beefing up the App Notice slightly.
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- Skeleton Arg’. David, Gideon — where is that sitting and how far off a draft to AGQC are we ?
I spent much of today drafting it with AGQC. We are well advanced - and anyway we will obviously not be
putting this in with the application notice.
Are there any other bits I have missed ?
If POL said "yes" tomorrow when would we serve Freeths and Judge ? When do we think we will try an
engineer the hearing to be ? Friday ? Next week ?
Won’t be Friday, because it will be contested and the other side will want to put in a skeleton argument. I
think back end of next week would be the very earliest.
Also, we need to think REALLY carefully about ensuring that Lord Grabiner is available to do the hearing.
Andy P says this Judge is very much of the "do it when I say" camp and not when Counsel is free.
David, Gideon — how can we ensure that lord Grabiner will be free for the hearing ? Is that a note from him
to the Judge ? Is that something the Clerks sort out ?
Have you spoken to the clerks?
All thought gratefully received.
Jane wants me to send her a timing update early tomorrow morning.
T
Tom Beezer
Partner
Womble Bond Dickinson (UK) LLP
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