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Message
From:
Sent:
To: Parsons, Andrew i" I; Mark Underwoo
Rodric Williams{- "GRO.
ce: Lukas, ElisafSSSCGRO. y; Prime, Amy
Subject: RE: Remote Access Wording
Attachments: Remote Access Rider.pdf
lve attached my minor comments, but there is a more substantive one as to how we present the argument under
‘Administrator Access’.
I think the sequence of statements should be as follows — note this is not drafting(!) and much of the existing wording
could be used:
* The question of access has come up many times starting with the Rudkin allegations, and including many specific
questions raised by SS
« inreiation to such specific questions, PO reverted to FJ to clarify the technical details in order to respond
appropriately to the specific question asked
* PO has recently commissioned further work and this is wider in scope than the specific questions previously
asked.
e In summary:
» PO does not have access or the ability to change transaction data
© There are a small number of staff within FJ who currently and historically have had administrator access.
This means ....
© Fihave advised us that there are controls in place to ensure that this administrator access is not used
inappropriately .... [tbc]
Happy to discuss.
jane
e Jane MacLeod
General Counsel
Ground Floor
20 Finsbury Street
LONDON
EC2Y 9AQ
Mobile number
From: Parsons, Andrew [mailto:Andrew.Parsons'
Sent: 20 November 2016 13:17 _
To: Mark Underwood! GRO __._Pi Jane MacLeod <
Williams
Cc: Lukas, Elisa é_
Subject: RE: Remote Access Wording
Rodric
Prime, Amy . _.GRO_ P
Thanks Mark.
I've updated the attached. Where I agreed with your suggested amendments, I've included them and deleted the
respective comment. In reiation to your other questions, I've added my answers to the aitached.
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Andrew Parsons
Partner
Bond Dickinson L
www.bonddickinson.com
From: Mark Underwood!”
Sent: 18 November 2016 21:
To: Parsons, Andrew; Jane MacLeod; Rodric Williams
Cc: Lukas, Elisa; Prime, Amy
Subject: RE: Remote Access Wording
Andy, Jane & Rod,
i have track changed my comments, for your consideration, in the attached version.
Mark
From: Parsons, Andrew C
Sent: 18 November 2016 19:25
To: Jane MacLeod; Rodric Williams
Cc: Mark Underwoor es 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 FJ, 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
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Andrew Parsons
Partner
Bond Dickinson LLP
tected by law. mark underwo
andrew parson
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