From: Alexander Richardson (Litigation, Regulatory & Tax) <Alexander.Richardson@pinsentmasons.com> Sent: Thursday, May 25, 2023 10:08:29 AM To: Daniel Kidby <d.f.p.kidbv@outlook.com>; lona Wilson <Iona.Wilson@pinsentmasons.com> Cc: Julian Diaz-Rainey <Julian.Diaz-Rainey@pinsentmasons.com>; Trevor Watkins <Trevor.Watkins@pinsentmasons.com> Subject: RE: JCR v (1) Daniel Kidby; and (2)-(8) Persons Unknown
Dear Mr. Kidby,
Ahead of tomorrow's Hearing, please find attached our skeleton argument and Authorities Bundle.
Kind regards,
Alex
Alexander Richardson Senior Associate
Pinsent Masons
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From: Alexander Richardson (Litigation, Regulatory & Tax) Sent: Wednesday, May 24, 2023 4:17 PM To: 'Daniel Kidby' <d.f.p.kidby@outlook.com>; lona Wilson <lona.Wilson@Pinsentmasons.com> Cc: Julian Diaz-Rainey <Julian.Diaz-Rainey@pinsentmasons.com>; Trevor Watkins <Trevor.Watkins@pinsentmasons.com> Subject: RE: JCR v (1) Daniel Kidby; and (2)-(8) Persons Unknown
Dear Mr. Kidby,
Thank you for your email, and for the professional and courteous tone in which it was sent. Thank you also for confirming that you have received the claim documents.
As you might expect, we do not agree with your points on the rule of law. As to the minutes from the meeting, from our client's perspective, they correctly record what was stated from their recollection. If this does not accord with your memory of the meeting, you are of course entitled to make points in this respect in your submissions to the Court.
In this regard:
1. we have been asked to file the Hearing Bundle with the Court this afternoon. We will include your email in the Bundle so the Court has sight of it. We will provide you with a copy of the finalised Bundle later this afternoon, in electronic form; 2. if you have submissions you want to file with the Court, we have been conversing with the following individual at the Court in respect of this matter - susan.woolley Justice.clov.uk. You may wish to do the same; and 3. we will be filing our skeleton argument with the Court at 10:00am tomorrow morning and will provide you with a copy of the same. We should be grateful if you would send us your submissions at the same time — i.e., by 10:00am.
We encourage you to seek independent legal advice in relation to this case.
We reserve all of our client's rights, howsoever arising.
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Kind regards,
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