From: Tom Beezer <_
To: Rob Smith <
Amy Prime
Subject: RE: Post Office Group
Date: Fri, 15 Mar 2019 11:29:34 +0000
Importance: Normal
Andrew Parsons <
“>
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itigation - Appeal [WBDUK-AC.FID26896945]
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Rob.
That is fine. Stephanie to assist too please.
Tom Beezer
Partner
Womble Bond Dickinson (UK) LLP.
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From: Rob Smith [mailto:
Sent: 15 March 2019 11:03
To: Andrew Parsons; Amy Prime
Cc: Tom Beezer
Subject: RE: Post Office Group Litigation - Appeal
I have spoken to all counsel and they would like Stephanie to assist with the preparation.
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Can you let me know when she has the green light.
Thanks
Rob
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From: Andrew Parsons <
Sent: 15 March 2019 07:17
To: Rob Smith <
Ce: Tom Beezer
Subject: RE: Post Office Group Litigation - Appeal
Amy Prime <
Rob
Fees are fine. Please invoice whatever is on the clock for Lord Neuberger.
Tom — have you told Jane about the timing of the second part of the advice?
A
Andrew Parsons
Partner
Womble Bond Dickinson (UK) LLP
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From: Rob Smith [mailtof~
Sent: 14 March 2019 12:43
To: Amy Prime
Cc: Andrew Parsons; Tom Beezer
Subject: RE: Post Office Group Litigation - Appeal [WBDUK-AC.FID26896945]
Dear Amy,
Please find the advice from Lord Neuberger attached. Also attached is the documents David was given and a
note that was prepared by David and Gideon. David did go over the £12,000 budget but he is happy to stick
to this.
The advice for the appeal will depend on the timescale that he is given by you. He will need 40 to 50 hours
to prepare this and his preference is for this to be at the beginning on April. I do understand that this may be
too far off for you.
Iam happy to discuss.
Thanks
Rob
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From: Amy Prime
Ce: Andrew Parsons ¢
Subject: RE: Post Office ppeal [WBDUK-AC.FI.
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Rob
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Just so as I can manage expectations, would you be able to let me know an estimated timeframe for the appeal
opinion (work stream 3 below)?
Many thanks
Amy
Amy Prime
Solicitor
Womble Bond Dickinson (UK) LLP.
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From: Rob Smith [mailto GRO 4
Sent: 12 March 2019 15:
To: Amy Prime
Cc: Andrew Parsons; Tom Beezer
Subject: RE: Post Office Group Litigation - Appeal [WBDUK-AC.FID26896945]
Sorry. You are correct. It should read 1&2
Thanks
Rob
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Sent: 12 March 201
To: Rob Smith <~
Ce: Andrew Par: “>; Tom Beezer <
Subject: RE: Post Officé
Rob
Please could I clarify whether that is "1 & i I - £10,000 to £12,000".
Many thanks
Amy
Amy Prime
Solicitor
Womble Bond Dickinson (UK) LLP
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From: Rob Smith [mailto
Sent: 12 March 2019 15:48
To: Amy Prime
Cc: Andrew Parsons; Tom Beezer
Subject: RE: Post Office Group Litigation - Appeal [WBDUK-AC.FID26896945]
Amy,
I have spoken to Lord Neuberger and he estimates between 10-12 hours for him to advise on 1 & 3 - £10,000
to £12,000. This will be with you by close of play on Thursday latest.
At this moment in time he does not have a view on 3. I will be back to you on that as soon as I can.
Thanks
Rob
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From: Amy Prime ¢
Sent: 12 March 2019 14:04
To: Rob Smith
Ce: Andrew Parsons +. Tom Beezer +
Subject: Post Office Group Litigation - Appeal [WBDUK-AC.FID26896945]
Hi Rob
Further to our discussion, Post Office would like to instruct Lord Neuberger to:
Provide advice on the merits of a recusal application and whether such an application should be made.
If the answer to (1) is that Post Office should make a recusal application, then please could Post Office be advised on
the process and procedure for making a recusal application, and the approach that the Court would take in
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determining such a matter.
Provide an opinion on the appeal of contractual issues and the implication of terms.
Questions (1) and (2) are more urgent and we would appreciate if this advice could be provided before (3). Once Lord
Neuberger has had an opportunity to consider the papers, it would be appreciated if he could provide estimated
timings for the advice being produced and confirm fee estimates.
Electronic reading bundles will follow shortly, with hard copies to be couriered to One Essex Court. In the meantime,
please could you could discuss with David Cavender QC providing a verbal briefing to Lord Neuberger.
In relation to Lord Grabiner QC, as discussed please could Lord Grabiner QC be placed onto a first right of refusal for
the potential to attend on behalf of Post Office at a recusal hearing. Please could this arrangement be put in place up
until his trial which begin on 30 April 2019. If availability does become an issue, please could you let either Andy, Tom
or me know. It would be appreciated if this arrangement could be confirmed by email?
If there are any questions on the above, please let me know.
Kind regards
Amy
Amy Prime
Solicitor
Womble Bond Dickinson (UK) LLP.
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