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

Disclose and produce for inspection all versions of each of the pages of the Mulcaire Notes relied on by her in her possession or control.

Confirm, with a statement of truth: (i) when each version of each page of the Mulcaire Notes came into her possession or control and their source; and (ii) when each version came into the possession or control of the MTVIL claimant group and their legal advisers.

In respect of the document disclosed by the Seventh Claimant listed as “Sadie Frost v (1) NGN and (2) Glenn Mulcaire - Met Disclosureincluding additional disclosure (11 pages)”, (a) confirm that the disclosure referred to in this document (other than the “additional disclosure (11 pages)”) refers to MPS disclosure in 2011 and (b) explain what is meant by ‘additional disclosure’, including when and by whom it was provided and with whom it was shared and when.

Disclose and produce for inspection a copy of the covering letter(s) from the MPS which provided disclosure pursuant to the Order(s) of Vos J dated 15 April 2011 and 7 October 2011 in the Seventh Claimant’s claim against NGN and Mr Mulcaire and any additional disclosure.

Disclose and produce for inspection the documents referred to at (b) in the application notice at Document 26 of the Seventh Claimant’s disclosure: “[NGN and/or Mr Mulcaire] specifically targeted [the Seventh Claimant]: her name is included on a ‘project’ document andalso a list of targets along with Simon Hughes MP who I also act for”.

Disclose and produce for inspection all versions of the 2006 Emails in her possession or control.

Confirm, with a statement of truth: (a) when each version of the 2006 Emails came into her possession or control and their source; and (b) when each version of the email exchanges came into the possession or control of the MTVIL claimant group and/or the legal advisers to the MTVIL claimant group.