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BINDMANS LLP

Authorised and regulated

by the Solicitors

Regulation Authority

with SRA authorisation

number 484856

Contracted with

the Legal Aid

Agency

Bindmans LLP

236 Gray’s Inn Road London WC1X 8HB

DX 37904 King’s Cross Telephone 020 7833 4433 Fax 020 7837 9792

www.bindmans.com info@bindmans.com

Bindmans LLP is a limited liability partnership registered in England and Wales under number OC335189. Its registered office is as

set out above. The term partner means either a member of the LLP or a person with equivalent status and qualification.

Your ref:

Date: 1 October 2020

FAO

Government Legal Department

Commercial Law Group

By email only to:

Dear Madam or Sir

Project Moonshot: Judicial Review Pre-Action Protocol

correspondence

We write in relation to your letter of 28 September 2020.

Our letter of 24 September 2020 contained two requests:

(i) confirmation of whether the defendants have already awarded

any contracts in connection with Project Moonshot; and

(ii) an undertaking that the Defendants will not enter into any new

contracts in respect of Project Moonshot until five working days

after the response to our pre-action letter is received.

You have strikingly not confirmed whether or not you have already

awarded any contracts in connection with Project Moonshot. You have

also not undertaken that you will not enter into any new contracts in

respect of Project Moonshot until five working days after the response to

our pre-action letter is received.

Your letter states that (i) “there has been no decision to approve and

commit £100 billion of public money, or anything approaching this

amount, ... to Project Moonshot’...” and (ii) the Defendants “have not

signed, and will not in the next two weeks be signing, any contracts for

“provision of facilities, planning and storage” in relation to “Project

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Moonshot” (emphasis added). These are carefully chosen words that leave

the current position completely unclear. We expect a full and clear

response in your pre-action response letter, and of course we reserve the

right to bring this correspondence to the attention of the court as

appropriate in respect of remedies, costs and any other relevant matters

should that become necessary.

Yours faithfully

Bindmans LLP