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Me Fabb. Details are provided below in paragraphs 56-67, Tunderstand that at the hearing Mr Fabb did rot stace tha he wished to appeal ‘he order und neither did he ask District Judge Needhain for pertnission 10 do so. Now responding to Mr Fabb's skeleton argument using the same headings for ease of reference, Disclosure 24, 28. 26. 21, {would add in this regard sha Hist of deouients was provided to MrFabb via Mr Febb complains that requests for disclosure have had no suceess or very limited euccess within the meaning of section 6(3) of the Human 1998. Is Ae ‘This paragreph is without prejudice to the primary position that Mr Fabb did not, 4s 1 understand matters from my solivitors, make any application at case ‘management conférence for disclosure and thus do not know how this issue ean properly be said to form part of the appeal. In this regard, J inderstand that Mr Fabb, during the course of the hearing, did mention disclosure during his submissions, however, District Judge Needham made it clone that Me Fabb should make 2 formal application and he was not prepared to hear any pplication without a formal application, Therefore, my primary contention is fat this issae cannot be subject to an appeal. fully appreciate the Joint Administrators’ disclosure obligations, In this regard the Joint Administrators have carried out a full and thorough search for documents in connection with this matter in accordance with rule 31.6 of the Civil Brocedure Rules. le. fa this regard, MrFabb attended the administrators’ offices to camy out _ My solicitors have stated to Mr Pabb on numerous cecasions that at i 1 30 wish, altermatively if ‘he wishes to highlight any documents on the list he would like copies of, the Joint Administrators will provide him with copies of the same,

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