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

Each search for (to the extent not done already), disclose and produce for inspection all documents relating to, evidencing or referring to the point in time when they each first became aware directly or through any agent of any potential unlawful information gathering by the Defendant, including all documents relating to their alleged Personal Watershed Moments as pleaded at §20 of their respective Replies.

Each search for (to the extent not done already), disclose and produce for inspection all documents that contain or refer to the information provided to them directly or through any legal adviser or other representative at or around the time of their alleged Personal Watershed Moments and from which it is alleged they discovered they may have a worthwhile claim against Associated (in so far as not included in response to 2(a) above).