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Message
From: Parsons, Andrew
Sent: 03/07/2014 13:
To: Belinda Crowe 4; Chris Aujard
cc: Rodrit illic E i i Thorp, Ben
Subject: RE: Mediation for M022 and M127 [BD-4A.FID20472253]
Belinda
I'm happy with this draft.
Kind regards
Andy
Andrew Parsons
Senior Associate
for and on behalf of Bond Dickinson LLP
Follow Bond Dickinson:
Blin
www.bonddickinson.com
From: Belinda Crowe [mailto:
Sent: 03 July 2014 14:38
To: Parsons, Andrew; Chris Aujard
Cc: Rodric Williams; David Olivers; Thorp, Ben ¢é
Subject: RE: Mediation for M022 and M127 [BD-4A.FID20472253]
Andy
I think that we have Tony’s attention for an hour. Need to get this to him quickly. Some comments below
Belinda Crowe
148 Old Street, LONDON, EC1V 9HQ
_GRO
From: Parsons, Andrew [mai
Sent: 03 July 2014 14:10
To: Belinda Crowe
Cc: Rodric Williams; David Oliver}; Thorp, Ben
Subject: RE: Mediation for M022and M127 [BD-4A.FID20472253]
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Belinda
A slightly revised version of the email below with a few tweaks from Rod.
From: Chris
To: WG
TO BE SENT AS A REPLY TO IAN's EMAIL ATTACHING THE NEW ATM EXTRACT FROM THE PART 2 REPORT
All
Post Office's priority is to mediate cases M022 and M127 as soon as possible and would be reluctant to move the agreed
mediation dates (if for no reason other than I suspect that the Applicants may have had to take time off work to attend on
the agreed dates and may have also already made travel / accommodation arrangements). The WG has already decided
that both cases could proceed to mediation without the Part 2 Report and
Releasing a draft additional report at this late stage may confuse the preparation for those mediations. In both cases, the
parties are likely to be finalising, and will shortly be exchanging, mediation statements based on the information already in
circulation and pre-mediation discussions with the mediators may already have been set up. These steps would probably
need to be delayed if new information was released now.
Having briefly reviewed the revised draft Part 2 Report, it appears not to have changed significantly from the previous
draft. It is recognised that this is a “work in progress" and so it has not yet addressed a number of concerns raised by
Post Office previously (ie. only the highlighted comments in the attached have been addressed so far). It is Post Office's
view that this document is a long way short of being ready for release to Applicants and is concerned that, in its current
form, it may in fact cause greater disagreement rather than bring clarity TERT TSS CS GEOR STSPCES
Regards
Chris
Andrew Parsons
Senior Associate
for and on behalf of Bond Dickinson LLP
Follow Bond Dickinson:
www.bonddickinson.com
From: Parsons, Andrew
Sent: 03 July 2014 13:26
To: ‘Belinda Crowe!
Cc: Rodric Williams; David Oliver; Thorp, Ben ¢_
Subject: RE: Mediation for M022 and M127 [BD-4A.FID20472253]
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Belinda
Please find below a draft response on the Part 2 report for your consideration. I've gone for a slightly tougher line in that I
think we should outright resist the disclosure of the report rather than leave open a slight possibility of the report going
out. Happy to re-draft though.
Having reviewed the draft report it is still a deeply unsatisfactory document.
Kind regards
Andy
From: Chris
To: WG
TO BE SENT AS A REPLY TO IAN's EMAIL ATTACHING THE NEW ATM EXTRACT FROM THE PART 2 REPORT
All
Post Office's priority is to mediate cases M022 and M127 as soon as possible and would be reluctant to move the agreed
mediation dates (if for no reason other than I suspect that the Applicants may have had to take time off work to attend on
the agreed dates and may have also already made travel / accommodation arrangements). The WG has already decided
that both cases could proceed to mediation without the Part 2 Report and I don't see why we should re-open that decision,
particularly as the WG has passed control of this case to the parties and CEDR.
Releasing a draft additional report at this late stage may confuse the preparation for those mediations. In M022, the
Applicant is not expecting any further documentation. In M127, the Applicant is unrepresented so it is preferable to keep
the process as simple as possible. In both cases, the parties are finalising, and will shortly be exchanging, mediation
statements based on the information already in circulation and pre-mediation discussions with the mediators have been
set up. These steps would probably need to be delayed if new information was released now.
Having briefly reviewed the revised draft Part 2 Report, it appears not to have changed significantly from the previous
draft. It is recognised that this is a “work in progress" and so it has not yet addressed a number of concerns raised by
Post Office previously (ie. only the highlighted comments in the attached have been addressed so far). It is Post Office's
view that this document is a long way short of being ready for release to Applicants and is concerned that, in its current
form, it may in fact cause greater disagreement rather than bring clarity.
Regards
Chris
Andrew Parsons
Senior Associate
for and on behalf of Bond Dickinson LLP
www.bonddickinson.com
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From: Belinda Crowe [mailto
Sent: 03 July 2014 11:27
To: Parsons, Andrew .
Cc: Belinda Crowe; Rodric Williams; David Oliver!
Subject: FW: Mediation for M022 and M127
Would you be able to have a quick look at this? Could we also draft out a quick note from Chris as a response based on
our initial view of this. Measured.
The gist will be that — POL would be reluctant to delay mediation and we agreed that we would pass these cases through
Remain concerned about the WG agreeing an approach and then not following it — not in the interests of applicants
Would rather any document goes out than any suggestion that information is being withheld
Post Office considers the draft a long way short of what it needs to be and it can only get into a proper state (if that’s the
case)
However, if the document is submitted for mediation, will make those points at mediation.
Sorry —v brief In haste
Thanks
B
Belinda Crowe
148 Old Street, LONDON, EC1V 9HQ.
0207 250 2418 Postline: 5460 2418
From: Ian Henderson [mailt
Sent: 03 July 2014 10:51
To: Belinda Crowe; Angela Van-Den-Bogerd; ‘Parsons, And: Nn Warmington’; alan.bate
kay Chris Aujard; ‘Anthony Hooper’; cwhi
Cc:
Subject: RE: M
iation for M022 and M127
All
I attach an updated DRAFT version of the ATM section of Part 2. We have taken account of POL’s comments on the
previous draft, but may still wish to make further changes in due course.
We'd be happy for this to be disclosed to CEDR as a draft document for both M022 and M0127.
We always envisaged that both Part 1 and Part 2 would be living documents that continue to be updated in the light of
new information.
With best wishes
Ian R Henderson CCE CISA FCA
Advanced Forensics - London, UK
Forensic computing expert witness and electronic disclosure specialist
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From: Belinda Crowe [mailto:
Sent: 03 July 2014 09:47
To: Ian Henderson; Angela Van-Den-Bogerd; ‘Parsons, Andrew’ i Warmington’; alan.bates!
kay: Chris Aujard; ‘Anthony Hooper’; cwhi-
Cc: Belinda Crowe; David Oliver’:
Subject: Mediation for M022 and M127
All
Please find below a message from Tony.
We have learnt that CEDR has fixed the dates for the mediation in M22 and M127 for next week. By then the
Part 2 extract will not have been discussed by the WG and we will not have discussed whether to change our
original decision that M22 would not be accompanied by what would at the time of that decision have been a
document which we had not seen. As far as M127 is concerned, we were due to discuss on July 10th whether
to forward the Part 2 extract as part of the mediation pack. We took the precaution in the final SS reports in
both cases to say that there might be further documents.
lam sure that we are all very reluctant to postpone the mediations.
I would like your views please.
Tony
Belinda Crowe
148 Old Street, LONDO
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