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Message
From: Mark Underwoodt
Sent: .
To: ; Jane MacLeod ; Rodric
cc: Lukas, Elisa I
Subject: RE: Remote Access
Attachments: _DOC_34370494(1)_Letter to Freeths - Remote Access Wording v2 mu.docx
Andy, Jane & Rod,
{ have track changed my comments, for your consideration, in the attached version.
Mark
From: Parsons, Andrew!
Sent: 18 November 2016 19:25
To: Jane MacLeod; Rodric Williams
Cc: Mark Underwood1; Lukas, Elisa; Prime, Amy
Subject: Remote Access Wording
Jane, Rodric
As discussed in the con with Tony, please find attached our draft wording on the "remote access" issues. This wording
will be part of a longer letter to Freeths that we hope to circulate next week.
In the attached, we refer to certain information provided by FJ to Post Office about editing transaction data. This
information was by way of an email (attached) that was arguably subject to litigation privilege. By referring to this
information in our letter (i) we may be waiving privilege in that email and (ii) Freeths could push for a collateral waiver of
privilege in other emails from FJ on the same topic.
We have not expressly referred to the email in the letter to minimise this risk. However, my view is that if we do not
explain that Post Office relied on information provided by Fu, Post Office's story is severely weakened and hence some
risk of waiving privilege should be taken.
Happy to discuss this point in more detail. All comments on the attached are welcomed.
Kind regards
Andy
Andrew Parsons
Partner
Bond Dickinson LLP
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