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From: Gideon Cohen
To: Amy Prime <”
Ce: David Cavender <j.
Anthony Grabi
Tom Beezer <
i “>, Dave Panaech
Subject: Re: Recusal Application - Timetable [WBDUK-AC.FID26896945]
Date: Thu, 21 Mar 2019 19:01:20 +0000
Importance: Normal
Inline-Images: image033b9c.PNG; image6daf45.PNG; imaged8af7e.PNG
Stephanie Wood <¢
Owain Draper <
+, Andrew Parsons <-
Ok, let me know when you want to speak.
G
On 21 Mar 2019, at 17:34, Amy Prime <
wrote:
Gideon
Thanks, once I have spoken with Andy it might be helpful if we discuss the scope/contents of the witness
statement just to make sure that it covers exactly what the Judge is looking for. Owain was also in Court (I
believe) so may be able to provide you directly with some thoughts on the extent of the statement as well.
Kind regards
Amy
Amy Prime
Solicitor
Womble Bond Dickinson (UK) LLP
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From: Gideon Cohen [mailto!
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Sent: 21 March 2019 17:15
To: Amy Prime; David Cavender; Stephanie Wood; Anthony Grabiner; Owain Draper
Cc: Tom Beezer; Andrew Parsons; Dave Panaech
Subject: RE: Recusal Application - Timetable [WBDUK-AC.FID26896945]
Yes, that's fine. We will obviously want to frame it as arising "in particular" from these paras, so that we
don't limit ourselves in future argument.
Gideon Cohen
Barrister
One Essex Court
Temple
London EC4Y 9AR
www.oeclaw.co.uk<http://www.oeclaw.co.uk>
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From: Amy Prime (00 "ERO eee ']
Sent: 21 March 2019 16:42
To: David Cavender; Gideon Cohen; Stephanie Wood; Anthony Grabiner; Owain Draper
Cc: Tom Beezer; Andrew Parsons; Dave Panaech
Subject: Recusal Application - Timetable [WBDUK-AC.FID26896945]
Dear All
Further plans of actions and thoughts will follow, but in the meantime the timetable for the recusal
application is as follows:
1. Post Office to file a witness statement by 12pm on 26 March (further detail below)
2. Cs to confirm whether they will oppose the application by 12pm on 27 March
3. Cs responsive evidence to be filed on 29 March
4, Skeletons on 2 April
5. Hearing on 3 April
The first work stream is the Post Office witness statement, for which the Judge has directed that (taken from
transcript):
"Post Office to provide a witness statement by noon on Tuesday 26th -- but we can come and discuss the
timing in a moment -- that sets out: 1, the specific findings in the judgment referred to in paragraph 24 of Mr
Parson's 14th witness statement; 2, the critical invective referred to in paragraph 25 of Parsons 14; and 3, the
criticisms of the Post Office witnesses referred to in paragraph 25."
I anticipate that the work which has already been done towards the draft skeleton argument will cross-over
with the information which the Judge now wishes to be included within a witness statement. Gideon — would
it be possible for this information to be lifted out / to be finessed into a witness statement?
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Kind regards
Amy
Amy Prime
Solicitor
Womble Bond Dickinson (UK) LLP
d:
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