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Message
From: Amy Prime [/O=EXCHANGE-ORG/OU=EXCHANGE ADMINISTRATIVE GROUP
(FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=AB7222DDA3A9453EAED5751238A59562-AMY PRIME]
Sent: 29/09/2017 13:
To: Jane MacLeod;
cc: Rodric Williams Gavin Matthews [/o=Exchange-Org/ou=Exchange Administrative
Group (FYDIBOHF23SPDLT)/c! jents/cn=24fec6fc425343 1labbf6ce6acbbfS5be7-Gavin Matth]
Subject: RE: Tony tomorrow [BD-4A.FID26896945]
dane
That is fine, thank you for picking this up.
Kind regards
Amy
Amy Prime
Solicitor
Bond Dickinson LLP.
www.bonddickinson.com
We are pleased to announce we will be changing our name to Womble Sond Dickinson (UK) LLP on 1 November 2017:
From: Jane MacLeo
Sent: 29 September
To: Amy Prime
Cc: Rodric Williams; Gavin Matthews
Subject: Re: Tony tomorrow [BD-4A.FID26896945]
Amy
This may be difficult - I'm attending so I can pick these up, but I'm not really expecting any ‘actions’ as such.
Jane
Jane MacLeod
Group Director Legal, Risk & Governance
Post Office
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Amy Prime
Sent: Friday, September 29, 2017 11
To: Jane MacLeod
Ce: Rodric Williams; Gavin Matthews
Subject: RE: Tony tomorrow [BD-4A.FID26896945]
dane
For your information, Tony has asked if I can dial-in inte the meeting with Paula and Al today just fo sit in the background
and make a note of the meeting and any actions which may arise from this.
I hope that this is ok, but please let me know if you have any concerns or would like to discuss this.
Kind regards
Amy
Amy Prime
Solicitor
Bond Dicki
Follow Bond Dickinson:
Win)
www.bonddickinson.com
We are pleased to announce we will be changing our name to Womble Bond Dickinson (UK) LLP on 1 November 2047:
From: Andrew Parsons
Sent: 28 September 2017 18:44
To: Jane MacLeod
Cc: Amy Prime; Rodric Williams
Subject: Tony tomorrow [BD-4A.FID26896945]
Jane
I've spoken to Tony this evening. Below is a rough outline of what he plans to cover tomorrow with Paula / Al. This might
change before tomorrow — he's a barrister — last minute changes are what they do!
1. Why have we recommended focussing on the contractual points?
a. This will be the obvious starting point for the judge. Going against this makes POL look difficult in a case
where the Claimants are saying POL is an oppressive organisation.
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b. Not engaging on the contractual points, gives Freeths the chance to select which contractual issues to
promote and makes it difficult for POL to influence how those issues are framed. This may weaken POL's
case.
c. Itis difficult to see how we could address another issue first eg. to deal with Horizon you first need to
understand the contractual basis in relation to Horizon.
2. Claim advanced by Freeths
a. tis ambitious for them to imply numerous terms.
b. That doesn't mean that their case is hopeless, they may well win on some issues (ie. Post Office might
have an implied duty to offer adequate training).
c. We have a credible argument on the burden of proof issue but it is a complicated point.
3. Mood music
a. We need to weave into the story that losing on the "burden of proof" issue would be disastrous for POL,
but this needs to be done with great care and not over-exaggerated.
I've also prepped Tony on Paula and Al's respective styles.
rom 7:30am tomorrow so if you'd like to discuss, please do feel free to call this evening (any time — I'm on
the
Kind regards
Andy
Andrew Parsons
Partner
Bond Dickinson
www.bonddickinson.com
We are pleased fo announce we will be changing our name to Womble Bond Dickinson (UK) LLP on 1 November 2047:
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