KB-2022-003316 - [2025] EWHC 1716 (KB)

Where the Claimants (or any one of them) has produced a document for inspection otherwise than in its original form, that relevant Claimant shall produce for inspection copies of the relevant document disclosed in its original form.

The Second Claimant shall search for (to the extent not done already), disclose and produce for inspection: (i) her letters of claim in respect of her claims against NGN and Mirror Group Newspapers (“MGN”); and (ii) her Particulars of Claim in respect of her claims against NGN and MGN.

The Third and Fourth Claimants shall search for (to the extent not done already), disclose and produce for inspection: (i) their letters of claim in respect of their claims against NGN and MGN; and (ii) their Particulars of Claim in respect of their claims against NGN and MGN.

The Seventh Claimant shall search for (to the extent not done already), disclose and produce for inspection her Particulars of Claim in respect of her claim against NGN.

The Fifth Claimant shall disclose and produce for inspection a signed copy of Mr Miskiw’s affidavit dated 20 August 2019.

PI material marked for the attention of Caroline Graham (see main judgment [87]).

Capitol Inquiry Invoices.

Backstreet Investigations/Investigator’s Support Services/British American News invoices/reports.

Schedule to JJ Services invoices.

Alma Security invoices.

Jonathan Stafford invoices.

System Searches invoices.

Email from Sharon Churcher to Sian James and Su Blanch of 12/12/2004 re payments to Capitol Inquiry.

ELI Invoices.

Payments to Greg Miskiw.

Cash payment chits.

Mike Behr invoice.

List of petty cash payments.

Email from Sharon Churcher to Su Blanch dated 11/02/2009, subject line “FW: Hanks bill”.

Payment slip to Warner Detective Agency.

Daily Mail 2009/10 Petty Cash Week 42/2010 (see main judgment [85]).

Charles Garside’s Investigations Given to Legal 16/9/11.

John Wellington’s papers on Whittamore spreadsheet.

ELI Ledger Card.

Daily Mail Green Book.

Daily Mail Yellow Book.

Record of interview with Neil Sears re use of Whittamore.

Record of interview with Amanda Perthen re use of Whittamore.

Record of interview with various journalists re use of Whittamore.

Email from Mike Behr to Sam Greenhill, with the subject RE: [Redacted] words dated 22/11/2013.