POL00021863
POL00021863
Message
From: Loraine, Paul
Sent: 30/12/2014
To: j
cc: ipients/cn=ap6); Mark Underwoox
Subject: Subject to Legal Privilege — Prepared in Connection with Mediations - Letter to SS re Part 2 Questions. DOCX [BD-
4A.FID20472253)
Attachments: _DOC_29992457(1)_141230 P2 Questions not being answered - AP comments.DOCX
Rodric
I hope you had a good Christmas.
As you will no doubt be aware, we are currently working through the list of Second Sight's questions to POL in connection
with their Part Two report.
As part of this, we are providing reasons to Second Sight in relation to the questions POL is not proposing to answer.
Are you able to assist with Andy's query on question 13.1 of the attached document? Please can you copy Andy and Mark
in on your response.
Kind regards
Paul
Paul Loraine
Solicitor
for and on behalf of Bond Dickinson LLP
Follow Bond Dickinson:
www.bonddickinson.com
From: Parsons, Andrew [mail
Sent: 30 December 2014 10:4
To: Mark Underwood-; Loraine, Paul
Cc: Belinda Crowe
Subject: RE: Subject to Legal Privilege — Prepared in Connection with Mediations - Letter to SS re Part 2 Questions.DOCX
[BD-4A.FID20472253]
Mark
Some comments from me attached.
POL-0018342
POL00021863
POL00021863
I've tried to flesh out some of the "reasons" so that it doesn't look like we are just stonewalling. I also think there are a few
questions we may be able to answer or at least fudge an answer. I think it would be better to try to answer a question
than just refuse entirely wherever possible.
I wonder if we should remove the 5 questions we have answered already — rather than record these as a refusal to
answer we should perhaps take the benefit of saying already answered?
Paul — see questions 4.6(c) and 4.6(h) and 5.1. Did these questions go to Rob King in POL security — he should know the
answer to these. Also — pls can you action 13.1.
A
Andrew Parsons
Managing Associate
Follow Bond Dickinson:
Blin
www.bonddickinson.com
From: Mark Underwood:=:[mailto?
Sent: 30 December 2014 08:59
To: Belinda Crowe; Parsons, Andrew; Loraine, Paul (~
Cc: Angela Van-Den-Bogerd; Patrick Bourke
Subject: RE: Subject to Legal Privilege — Prepared in Connection with Mediations - Letter to SS re Part 2 Questions.DOCX
~); Rodric Williams; Tom Wechsler
Hi Belinda,
As requested, please find attached the list of questions we are not providing answers to, and the reasons why.
Andy — there is one question I have highlighted. Did we actually ever send out the response with regards to Suspense
accounts as I am unsure?
In total we are not providing answers to 41 of the 110 questions posed (37%). Splits by reason in the table below:
Total Questions 110 %
Fishing 28 25%
Out of scope 8 7%
Already answered Es 5%
41 37%
Any questions just shout,
Mark
POL-0018342
POL00021863
POL00021863
From: Belinda Crowe
Sent: 29 December 2014 11:00
H ndrew
7 ; Rodric Williams; Tom Wechsler
Cec: i ick Bourke
Subject: Subject to Legal Privilege — Prepared in Connection with Mediations - Letter to SS re Part 2 Questions.DOCX
; Loraine, Paul
Please see an attached some amendments to the draft letter for second sight to accompany the answers to their
questions.
Mark/Paul/Andy Parsons — would you be able to prepare the schedule of questions to which Post Office is not prepared
to respond and the reasons why — it would be that some of the text I have included in the letter is best placed in the
Schedule.
Best wishes
Belinda
Belinda Crowe
148 Old Street, LONDON, EC1V 9HQ
This email and any attachments are confidential and intended for the addressee only. If you are not the named recipient,
you must not use, disclose, reproduce, copy or distribute the contents of this communication. If you have received this in
error, please contact the sender by reply email and then delete this email from your system. Any views or opinions
expressed within this email are solely those of the sender, unless otherwise specifically stated.
POST OFFICE LIMITED is registered in England and Wales no 2154540. Registered Office: 148 OLD STREET,
LONDON EC1V 9HQ.
POL-0018342