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From: Andrew Parsons <,
To: Gideon Cohen <
Owain Draper <
Stephanie Wood ¢
“pb, Amy Prime <i.
“b, Anthony Grabiner <
>, Tom Beezer <__
“}, David Cavender
Ce:
Subject: RE: Witness Statement
Date: Tue, 26 Mar 2019 11:00:31 +0000
Importance: Normal
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Fair enough. We'll take it out.
But 32 is wrong in relation to TCs — for TC disputes the SPMs contact FSC not the helpline (as per the contact details
stated on the TC).
A
Andrew Parsons
Partner
Womble Bond Dickinson (UK) LLP
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From: Gideon Cohen [mailto
Sent: 26 March 2019 10:45
To: Amy Prime; Owain Draper; Andrew Parsons; Anthony Grabiner
Cc: Stephanie Wood; Tom Beezer; Dave Panaech; David Cavender
Subject: RE: Witness Statement [WBDUK-AC.FID26896945]
Sorry, one final point on this. Not sure we want to include Factual Matrix Point 32. We accept that this was true. So
even though it is being used illegitimately by the Judge (to determine the status of the BTS), I do not think it falls
within 23-24 of Parson 14, which is focused on findings which we say he has made too early, and in the absence of
full evidence and disclosure. Further evidence and disclosure will not make any difference to this point, because
we accept that it is true.
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From: Amy Prime [mailt
Sent: 26 March 2019 10:
To: Gideon Cohen; Owain Draper; Andrew Parsons; Anthony Grabiner
Cc: Stephanie Wood; Tom Beezer; Dave Panaech; David Cavender
Subject: RE: Witness Statement [WBDUK-AC.FID26896945]
Thanks Gideon
Amendment made.
Many thanks
Amy
Amy Prime
Solicitor
Womble Bond Dickinson (UK) LLP.
m GRO
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DICKINSON J) (in)
From: Gideon Cohen [mailto{
Sent: 26 March 2019 09:59
To: Amy Prime; Owain Draper; Andrew Parsons; Anthony Grabiner
Cc: Stephanie Wood; Tom Beezer; Dave Panaech; David Cavender
Subject: RE: Witness Statement [WBDUK-AC.FID26896945]
Amy,
On more thought re the factual matrix section: we should remove point 67. It is too close to the matrix we contend
for at Point 67 of the Factual Matrix document.
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Thanks
Gideon
Sent: 26 March 2019 09:47
To: Owain Draper; Andrew Parsons; Anthony Grabiner; Gideon Cohen
Cc: Stephanie Wood; Tom Beezer; Dave Panaech; David Cavender
Subject: RE: Witness Statement [WBDUK-AC.FID26896945]
Owain
Thank you, these have been fed into the witness statement.
Kind regards
Amy
Amy Prime
Solicitor
Womble Bond Dickinson (UK) LLP.
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DICKINSON (J) (in)
From: Owain Draper [mailto:
Sent: 26 March 2019 09:09
To: Andrew Parsons; Anthony Grabiner; Gideon Cohen
Cc: Amy Prime; Stephanie Wood; Tom Beezer; Dave Panaech; David Cavender
Subject: Re: Witness Statement [WBDUK-AC.FID26896945]
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Dear All,
Please find attached with some proposed changes. Many are simply agreement with Gideon’s suggestion that
paras be removed.
Kind Regards,
Owain
Owain Draper
One Essex Court, Temple
EC4Y 9AR
Switchboard:
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From: Andrew Parsons <
Date: Tuesday, 26 March 2019 at 07:49
To: Anthony Grabiner
“p, Gideon Cohen <
Ce: Owain Draper = i
David Cavender <dcavender@oeclaw.co.uk>
E: Witness Statement [WBDUK-AC.FID26896945]
Thanks all.
Happy with Gideon's changes. We'll finalise, get client approval and file at 12noon.
A
Andrew Parsons
Partner
Womble Bond Dickinson (UK) LLP
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From: Anthony Grabiner [mailtot_
Sent: 25 March 2019 22:15
To: Gideon Cohen
Cc: Andrew Parsons; Owain Draper; Amy Prime; Stephanie Wood; Tom Beezer; Dave Panaech; David
Cavender
Subject: Re: Witness Statement [WBDUK-AC.FID26896945]
If Gideon thinks they’re problematic please leave them out. We’ve got a lot of good material and I don’t
want it undermined by taking points that don’t really work. What time tomorrow is this due to be served?
I’m in an arbitration hearing all day but I could look at any disputed bits over lunch (1pm to 2pm) if that
would help.
Tony
Lord Grabiner QC
One Essex Court
Temple
London, EC4Y 9AR
“kmailto:{” >> wrote:
Thanks Andy. Agree with the approach. Nonetheless, I have highlighted a few of these which I think we
should not include - some of them seem a bit problematic to me. But subject to that, from my perspective
this is good to go.
All best
Gideon
Gideon Cohen
Barrister
One Essex Court
Temple
London EC4Y 9AR.
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From: Andrew Parsons} Kmailto; GRO I
Sent: 25 March 2019 19:01
To: Owain Draper; Gideon Cohen; Amy Prime; Stephanie Wood; Tom Beezer; Dave Panaech
Ce: Anthony Grabiner; David Cavender
Subject: RE: Witness Statement [WBDUK-AC.FID26896945]
All
As per my discussion earlier today with Gideon, we have added more sections of the Judgment to the
attached statement. Our approach has been to include anything that we might rely on, unless plainly not
relevant to the application. The objective being to avoid any challenge on appeal that a point in the Judgment
was not put to Fraser on the application.
All comments welcomed.
Kind regards
Andy
Andrew Parsons
Partner
Womble Bond Dickinson (UK) LLP
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From: Andrew Parsons
Sent: 25 March 2019 10:37
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To: 'Owain Draper’; Gideon Cohen; Amy Prime; Stephanie Wood; Tom Beezer; Dave Panaech
Ce: Anthony Grabiner; David Cavender
Subject: RE: Witness Statement [WBDUK-AC.FID26896945]
Thanks — I've got carriage of this now and will respond in the next couple of hours.
Andy
From: Owain Draper [mailto}
Sent: 25 March 2019 09:05
To: Gideon Cohen; Amy Prime; Stephanie Wood; Andrew Parsons; Tom Beezer; Dave Panaech
Ce: Anthony Grabiner; David Cavender
Subject: Re: Witness Statement [WBDUK-AC.FID26896945]
Dear All,
Attached with some minor changes from me.
Kind Regards,
Owain
Owain Draper
One Essex Court, Temple
EC4Y 9AR
www.oeclaw.co.uk<http://www.oeclaw.co.uk><http://www.oeclaw.co.uk><http://www.oeclaw.co.uk/>
The content of this email is confidential and may subject to legal professional privilege. If you are not the
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First draft of the WS attached. All comments gratefully received.
Thanks
Gideon
Gideon Cohen
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Temple
London EC4Y 9AR
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From: Amy Prime {_
Sent: 22 March 2019 18:11
To: Gideon Cohen; Stephanie Wood
Subject: Witness Statement [WBDUK-AC.FID26896945]
Hi Gideon, Stephanie
mailto;
Please could you let me know an ETA for the witness statement being circulated — not chasing, just planning
diaries.
Many thanks
Amy
Amy Prime
Solicitor
Womble Bond Dickinson (UK) LLP
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<_DOC_154958621(1)_15th Witness Statement of Parsons - Recusal. DOCX>
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