POL00023435
POL00023435
Message
From: Parsons, Andrew [Andrew.Parsons
Sent: 20/11/2016 13:17:07
To: Mark Underwood! [mark.underwood _..... Jane MacLeod [jane.macleodi Rodric
Williams [rodric.williams?
cc: Lukas, Elisa (Elisa.Luk "GRO.___ 1]; Prime, Amy [Amy.Prime®,
Subject: RE: Remote Access Wording
Attachments: _DOC_34374809(1)_Letter to Freeths - Remote Access Wording v3.DOCX
Thanks Mark
I've updated the attached. Where I agreed with your suggested amendments, I've included them and deleted the
respective comment. in relation to your other questions, I've added my answers to the attached.
A
Andrew Parsons
Partner
Bond Dickinson LLP
www.bonddickinsen.com
From: Mark Underwood! [mailto:mark.underwood 1+
Sent: 18 November 2016 21:15 .
To: Parsons, Andrew; Jane MacLeod; Rodric Williams
Cc: Lukas, Elisa; Prime, Amy
Subject: RE: Remote Access Wording
Andy, Jane & Rod,
{have track changed my comments, for your consideration, in the attached version.
Mark
From: Parsons, Andrew [mailto:Andrew. Parson:
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
POL-0019914
POL00023435
POL00023435
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
Andrew Parsons
Partner
Bond Dickinson LLP
www.bonddickinson.com
and
mark.underwood1!
on. publi
‘v, mark.underwood!
aused by
LLP
email is
Riversl
2A A 2124 RR Rf A 21 R28 2 10K 28 2 FFA 2 RF BK 0K 08 RB 10K 08 28 of aa a
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: Finsbury Dials,
20 Finsbury Street, London EC2Y 9AQ.
POL-0019914
POL00023435
POL00023435
POL-0019914