7h 5min, oct 4, 2019 y - Depp v NGN & Wootton Louis Charalambous SMB (NGN) Brown Rudnick LETTER

Description:

Simons Muirhead & Burton wrote to Brown Rudnick on 4 October 2019 inter alia objecting to this form of disclosure statement. Brown Rudnick did not suggest that they were entitled to sign the disclosure statement in the manner that they did, but said that SMB would be provided with a disclosure statement signed by the Claimant as soon as possible. The Claimant did eventually provide a signed disclosure statement, but not until 9th January 2020.

The disclosure which the Claimant did provide on 13 September included a spreadsheet said to contain about 400 text messages. When the spreadsheet was examined by SMB, it was also found to contain approximately 70,000 further messages. In their letter of 4 October 2019 SMB said that these had been examined 'to ascertain whether they had been included as an "obvious mistake'. They had concluded that
some were because they related to a business dispute with another party.

As set out at paragraph 4 (d) of my firm's letter to Brown Rudnick dated 4 October
2019, exhibited at pages 117-122 of LC 3, the Claimant has made a positive case in his Amended Reply about periods of his sobriety. We stated that there would be documents in his control which are relevant to these and his other assertions about his sobriety which needed to be disclosed.

SOURCE:
UK Court Documents:
- Louis Charalambous Witness Statement 03 paras 12-24, 46-48
- Disclosure Judgment 6 March 2020

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