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From: Andrew Parsons +
orden <7
i “GRO >. Ps Lucy Bremner <<
Subject: RE: eport 3 to court [WBDI
Date: Wed, 22 May 2019 13:45:54 +0000
Importance: Normal
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Email is fine but just remember who you are writing to — the email will be to the clerk but with a view to it being passed
to the Judge.
Also, please copy the following people to the email:
Me
Coyne
James Hartley
Andrew Parsons
Partner
Womble Bond Dickinson (UK) LLP
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From: robert worden <_
Sent: 22 May 2019 14:44
To: Katie Simmonds <
‘robert worden!
Andrew Parsons <{"
Jonathan Gribben ; Lucy Bremner e
Subject: RE: Report 3 to court [WBDUK-AC.. FID 123887118]
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Katie -
I assume my letter can take the form of an email. That is what I would prefer. Otherwise it makes several
attachments and is confusing.
Robert
From: Katie Simmonds +
Sent: Wednesday, May 22, 2019
To: robert worden <
Ce: 'Chris Emery’ <"
Jonathan Gribben
Robert,
In terms of the email address to send the report to, this should be sent to Angela Fraser (who is the Judge's clerk) at
and you should explain that you are writing to email the Managing Judge in the Post
Office Group Litigation case. We would address your email to "Ms Fraser" and ask her if you letter could be passed to
the Managing Judge.
In relation to the wording of your email, we recommend you cover the following points:
1. You should address your letter to "Mr Justice Fraser" and start it "Dear Judge".
2. Heading line should include "Post Office Group Litigation".
3. Your email/ letter is written on your own initiative, although explain that you have asked for some
guidance on drafting it from Post Office's lawyers.
4. Refer to the discussion in Court on 11 April during which Tony Robinson QC (1) outlined the further
analyses which you wished to discuss further with Mr Coyne relating to Horizon Issues 1, 12 and 13 and
(2) confirmed that as a result of these further analyses, you believe that your views had changed and were
obliged to inform the Court. Explain that this further work was your own initiative, and not prompted by
Post Office or its lawyers.
5. Explain that it is your view that the changes in your analyses are material and have therefore prepared
the further supplemental report.
6. Explain that a draft version of the report was first provided to Mr Coyne on 25 April, nearly 4 weeks ago,
and a final version on an open basis last Thursday 16 May.
7. Explain that when cross-examined on the Horizon Issues, you may need refer to your updated / new
views in contained within your further supplemental report.
8. Update the Court in terms of your discussions with Mr Coyne and explain you have not been able to have
what you would describe as a substantive discussion concerning the further supplemental report.
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9. Confirm on the basis that trial will be resuming on 4 June, you believe the Court should now be aware of
the further supplemental report and are therefore providing a copy to the Managing Judge.
10. Explain that your understanding is that it is not Post Office's intention to make any application to the Court
in relation to the further supplemental report.
Kind regards
Katie
Katie Simmonds
Associate
Womble Bond Dickinson (UK) LLP
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DICKINSON &
Sent: 21 May 2019 17:51
To: Andrew Parsons; Jonathan Gribben; Katie Simmonds; Lucy Bremner
Cc: 'Chris Emery’
Subject: Report 3 to court
Andy -
As you know, I will send report 3 to the court tomorrow. No changes from the open version I sent to Coyne.
Please could you tell me the email address to send it to, the correct form of address, and some minimal
required words, that I might add to?
Thanks
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Robert
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