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From: Andrew Parsonsi_
Sent: Wed 17/04/2019 11:03:45 AM (UTC)
To:
Ce:
‘] Amy Prime?
Subject: DEN 24 RE: Revised letter for the CA
Thanks. I'll drop that paragraph in at the end of the letter.
A
Andrew Parsons
Partner
Womble Bond Dickinson (UK) LLP
) WOMBLE womblebonddickinson.com
OND
DICKINSON
From: David Cavender{,
Sent: 17 April 2019 11:57
Andrew Parsons I nol
David Neuberger
This is an important point.
Even raising the point will probably involve Coulson U having to consider bringing it to the attention of someone else-
which is one step along the road of seeking to undermine the Fraser/Coulson axis.
The more we can say in the letter the more effective it will be — but we seem to have one hand tied behind our back
at the moment.
Even Owain’s muted version of what we could say would be very much better than saying nothing.
Best,
D.
David Cavender QC
ONE
SEX COURT
CY
WS
One Essex Court
Temple
London EC4Y 9AR
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From: Owain Draper
Sent: 17 April 2019 1
; David Cavender {2
Cc: Gideon Cohen <gcohe' nthony Grabiner
“juk>; Amy Prime “GRO,
‘evised letter for the CA [WBDUK-AC.FID26896945]
David Neuberger
Subject: Re:
I defer to the QCs on this one, Andy. I do not know what we can say (without referring to the specific issues in the
Common Issues appeal) that has much content or force. We could say this: “Post Office respectfully asks that, in light of
importance of the issues raised in the two proposed appeals, the applications for permission be referred to three Lord
Justices for decision”
Neuberger <
Subject: RE: Revised letter for the CA [WBDUK-AC.FID26896945]
I'm speaking to Jane at lunchtime about this. Please can you add in the extra material if you want it to go in the letter
and send over to me asap. I'll then see what I can get approved
A
Andrew Parsons
Partner
Womble Bond Dickinson (UK) LLP
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From: Owain Draper <~
Sent: 17 April 2019 10:59
To: David Cavender
>; Andrew Parsons:
> Anthony Grabiner ¢
David Neuberger
Subject: Re: Revised letter for the CA
It would be good to be able to mention the legal significance of some of the points in the Common Issues
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Appeal (relational contract or termination on notice, for example). Other than that, we only have that the
issues are important, which seems a bit lame.
From: David Cavender
Date: Wednesday, 17 A
To: Owain Draper
Ce: Gideon Cohen
Neuberger ¢. fe
Subject: RE: Revised letter for the CA
>, Andrew Parsons I
GRO k>, Anthony Grabiner i>, David
Owain,
I think that such a request is a good idea. I think we can justify it on vanilla grounds (rather than a
Fraser/Coulson axis) on the basis of the nature of the decision being appealed.
Best,
D.
David Cavender QC
[cid:image002 jpg@01CF1C35.04ACED80]
One Essex Court
Temple
London EC4Y 9AR
www.oeclaw.co.uk<http://;www.oeclaw.co.uk>
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From: Owain Draper
Sent: 17 April 2019 10:48
To: Andrew Parsons
Ce: David Cavender
Grabiner:
Subject: Revised letter for the CA
Importance: High
>; Gideon Cohen! “k>; Anthony
Dear Andy,
We think the letter is still worth sending.
There is an outstanding point as to whether or not to add a request that the two applications for permission go
before 2/3 Judges. It appears from the CPR that this is a request we can make: a single Judge “may refer any
matter for a decision by a court consisting of two or more judges” (r.52.24(8)). I have no idea how such a
request would be received.
Kind Regards,
Owain
Owain Draper
One Essex Court, Temple
EC4Y 9AR
Switchboare
www.oeclaw.co.uk<http://www.oeclaw.co.uk/>
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