POL00021991
POL00021991
Message
From: David Oliver {7
Sent: 12/03/2014 10:23:46
To: Swil, Jonathan [/O=LAW/OU=EXCHANGE ADMINISTRATIVE GROUP (FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=Jswil]
cc: Belinda Crowe I; andrew.parsong,
Subject: FW: Advice for Linklaters [BD-4A.FID20472253]
Attachments: Advice for Linklaters.zip
Jonathan
Please find attached the key BD advice. Please feel free to follow up directly with Andy (cc’d and contact details below.
D
David Oliver
From: Parsons, Andrew [mailto:andrewi
Sent: 12 March 2014 10:00
To: David Oliver1; Chris Aujard
Cc: Matthews, Gavin
Subject: Advice for Linklaters [BD-4A.FID20472253]
David, Chris
Please find attached the key pieces of formal advice that have been prepared by BD. There are obviously 1000s of other
emails which provide further ad hoc advice.
A few documents to note in particular:
1. Note of meeting with Richard Morgan QC.
Back in 2012, before SS were engaged, the primary concern was that SPMRs would bring something akin to a class
action against POL. This was being driven by Shoosmiths and the 100+ SPMRs they had gathered together. Off the back
of Shoosmiths' attempts to get a test case off the ground (which was ultimately unsuccessful), we instructed Richard
Morgan QC to advise on whether POL should instruct an expert to a produce a pre-emptory report giving Horizon a clean
bill of health. (I think at this time the intention was to use Deloittes - apologies I was not directly involved in these events).
Attached is a summary of the key points from the con with RMQC in which he advises against instructing an expert.
2. Settlement presentation.
This presentation is for a talk I gave to what was at that time the Sparrow Steering Group. (Chris - you may recall that this
was the lead decision making body for Sparrow before the Programme Board was constituted and was attended by a
number of ExCo members). This presentation was the starting point for the settlement policy.
3. Insurances risks note
This note had the dual purpose of advising the board (its contents were later reflected in a board paper) and acting as
Notification to POL's insurers — hence why this doesn't look like a traditional piece of legal advice.
Kind regards
POL-0018470
POL00021991
POL00021991
Andy
Andrew Parsons
Senior Associate
for and on behalf of Bond Dickinson LLP
Follow Bond Dickinson:
www.bonddickinson.com
Please consider the environment! Do you need to print this email?
The information in this e-mail and any attachments
this e-mail and any attachments. If you are not da
Unauthorised use, dissemination, distribution, publ
only is authorised to access
and del
possi
¢ any copies.
be unlawful
Any files attached to this e-mail will have b
which may be
n checked by us with virus detection software before transmission. Bond Dickinson LLP
ised by software viruses and you should carry out your own virus checks before opening any attachment.
pis no liability for any loss or damage
Content of this email which does not relate to the official business of Bond Dickinson LLP, is neither given nor endorsed by it.
This email is sent for and on behalf of Bond Dickinson LLP which is a limited liability partnership registered in England and Wales under number 0C317661. Our registered
office is St Ann’s Wharf, 112 Quayside, Neweastle Upon Tyne, NEI 3DX, where a list of member
the LLP, or an em
o.amember of
ames is open to inspection. We use the term partner to rel
ig. Our VAT registration number is GB123393627.
loyee or consultant who is of equivalent stai
Bond Dickinson LLP is authorised and regulated by the Solicitors Regulation Authority.
JOH ESOS USO HSI ISOS SOI IIA IOI SII I IISA I III ADI IAI IAI AI
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 Offic
LONDON EC1V 9HQ.
: 148 OLD STREET,
JOURS OIG ISO IIIS IDI ISO IDI ISAT RODD II AAI IOI AIA
POL-0018470