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IN THE HIGH COURT OF JUSTICE
BUSINESS AND PROPERTY COURTS
OF ENGLAND AND WALES
TECHNOLOGY AND CONSTRUCTION COURT (QBD)
AND ADMINISTRATIVE COURT
THE QUEEN
on the application of
(1) THE GOOD LAW PROJECT
(2) EVERYDOCTOR
Claimants
-and- THE SECRETARY OF STATE FOR HEALTH AND SOCIAL CARE
Defendant
-and- CRISP WEBSITES LIMITED (trading as PESTFIX)
Interested Party
B E T W E E N
COURT BUNDLE
Rook Irwin Sweeney LLP
107-111 Fleet Street
London
EC4A 2AB
Ref: AIR/066
CASE NO: HT-2020-000226
CASE NO: CO/2144/2020
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Index
A. Pleadings
i
N461 Sealed Claim Form 15/06/2020 A1 - A7
Statement of Facts and Grounds 15/06/2020 A8 - A13
N463 Application 15/06/2020 A14 - A17
Draft order 15/06/2020 A18 - A19
Order of Mr Justice Swift 17/06/2020 A20
Order of Mrs Justice O’Farrell DBE 24/06/2020 A21 - A22
N244 Application Notice 10/07/2020 A23 - A25
Draft Consent Order (signed by Claimant and 13/07/2020
Defendant)
A26 - A27
Draft Consent Order (signed by Claimant and 13/07/2020
Interested Party)
A28 - A29
Amended Statement of Facts and Grounds 15/07/2020 A30 - A67
N244 Application Notice 15/07/2020 A68 - A70
Draft order 15/07/2020 A71
B. Witness Statements
i
Witness Statement by Mr Jolyon Maugham QC 15/07/2020 B1 - B5
Exhibit ‘JTDM1’ B6
Good Law Project Annual Report 2019/20 31/01/2020 B6i - B6xxiv
Exhibit ‘JTDM2’ B7
Tussell Factsheet #3 03/06/2020 B7i - B7xii
Exhibit ‘JTDM3’ B8
Companies House Documents 14/07/2020 B8i - B8xx
Exhibit ‘JTDM4’ B9
Contract Award by Plymouth City Council 02/04/2020 B9i - B9iv
Exhibit ‘JTDM5’ B10
The Times News and Pestfix Crowdfunding Page 13/07/2020 B10i - B10vi
Exhibit ‘JTDM6’ B11
List of Updates to Government Guidance 14/07/2020 B11i - B11ii
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B. Witness Statements (cont...)
ii
Government Guidance, Amended 18 June 2020 14/07/2020 B11iii - B11xv
Exhibit ‘JTDM7' B12
Cabinet Office Procurement Policy Note 01/20 03/2020 B12i - B12vii
NHS England Guidance on the Cabinet Office 20/04/2020
Procurement Policy Note 02/20
B12viii - B12xii
Exhibit ‘JTDM8’ B13
Public Accounts Committee NHS Capital Expenditure 12/07/2020
and Financial Management Report
B13i
Exhibit 'JTDM9' B14
Email by Department of Health and Social Care 29/06/2020 B14i
Witness Statement by Dr Julia Patterson 14/07/2020 B15 - B20
Exhibit ‘JGP1’ B21
EveryDoctor Parliamentary Briefing 30/04/2020 B21i - B21vii
EveryDoctor Parliamentary Briefing 07/05/2020 B21viii - B21xiv
C. Correspondence
ii
Pre-Action Letter to The Secretary of State for Health 10/06/2020
and Social Care
C1 - C24
Letter to Government Legal Department 11/06/2020 C25 - C26
Letter from Government Legal Department 12/06/2020 C27 - C28
Pre-Action Letter from EveryDoctor Ltd 15/06/2020 C29 - C35
Letter by Government Legal Services to Court 16/06/2020 C36 - C38
Letter by Claimants to Court 17/06/2020 C39 - C40
Letter by Government Legal Services to Court 17/06/2020 C41 - C42
Letter by Claimants to Court 18/06/2020 C43 - C44
Letter by Interested Party to Court 23/06/2020 C45 - C47
Formal response by Government Legal Services 01/07/2020 C48 - C58
Email from Claimants to Government Legal 03/07/2020
Department
C59 - C60
Letter from Interested Party to Claimants 03/07/2020 C61 - C65