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From:
: Tom Beezer <t.
: Gideon Cohen
David Cavender <}_
>, Stephanie Wood <
Subject: Re: Application docs [WBDUK-AC.FID26896945]
Date: Wed, 20 Mar 2019 14:22:29 +0000
Importance: Normal
Inline-Images: image306b08.PNG; image1c37a2.PNG; imagea860f7.PNG
Thanks Tom. I really don’t think the clients had any choice. I’m not one for adjectives and adverbs anyway
so it should be firm but polite.
Regards,
Tony
Lord Grabiner QC
One Essex Court
Temple
London, EC4Y 9AR
On 20 Mar 2019, at 14:17, Tom Beezer
wrote:
All
Just spoken to Jane M from Post Office.
Instructions from Post Office Board are "do it". Make the application.
One point — Post Office Board did not enjoy what it read about Post Office in CIT Judgment (the "vitriol"
points from the Judge). Jane asks that we collectively bear that in mind and when drafting letters, witness
statements etc we err on the reasoned side of life — in other words fewer adjectives than normal — to try and
demonstrate that we are very reasonable.
But main point — instructed to do it.
I have predicted, to Jane, but not promised, that we would be likely to issue and serve at some point
tomorrow ?
t
Tom Beezer
Partner
Womble Bond Dickinson (UK) LLP
d:
m:
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From: Gideon Cohen [mailtof~
Sent: 20 March 2019 13:22
To: Tom Beezer; Andrew Parsons; Dave Panaech; Amy Prime
Ce: David Cavender; Anthony Grabiner; Owain Draper; Stephanie Wood
Subject: Application docs
a]
In anticipation of (hopefully) getting the green light for this application from PO, please see attached the
application documents. There are various bits to be filled in (particularly references in the WS).
Grateful if everyone could take a careful look at all of these though.
I have gone for a time estimate for the hearing of 4 hrs. Thoughts on that appreciated too.
Thanks
Gideon
Gideon Cohen
Barrister
One Essex Court
Temple
London EC4Y 9AR.
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