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POL00024489
Message
From: Thomas P Moran
Sent: 16/07/2017 21:
To: Andrew Parson:
cc: Amy Prime ; iams j_.
Subject: RE: PLSG meeting on Wednesday 24 May 2017 @12 in Tonbridge (1.11)
Andy
For the record, my reply confirming I am happy with your answers below. I have also confirmed the outstanding point to
Amy re employees/temps in DMBs so all signed off from my perspective.
Thanks
Tom
From: Andrew Parsons {
Sent: 13 July 2017 10:07
To: Thomas P M
Ce: Amy Prime <. Rodric Williams
Subject: RE: PLSG meeting on Wednesday 24 May 2017 @12 in Tonbridge (1.11)
Tom
Thanks for the comments. I've set out below a few explanations for the approach taken on some of your comments.
4. We've (including Rodric ~ cc'd) taken an intentional deci to refer to Crown branches rather than Directly
Managed branches because this mirrors the wording in the GPOC. We considered trying to change terminology
but decided it could become confusing if we refer to DMBs through the litigation and Freeths refer to Crowns. A
judge would just get irritated by this and would likely end up using "Crown" because its shorter to say! I
appreciate that this is not the currently used Post Office terminology but we believe this is the best
approach. Hope that’s ok? - YES FINE BUT GOOD TO KNOW FOR REFERENCE INTERNALLY, PLEASE
NOTE TO MARK D/MEL C FOR FUTURE.
2. The word "embarrassing" has a particular legal meaning in Defences. It's a signal to the Judge that a bit of the
Claim has been very poorly written to cover up for the fact that the Claimants don't believe it to be true. - GOOD
EXAMPLE OF WHAT WE HAVE BEEN DISCUSSING, FINE.
3. The word “typically” has been used to mirror the language in the GPOC. In a normal defence, you would never
say “typically” something happens, but give a definitive view on the subject. Due to the generic nature of the
Defence that definitive approach would create hostages to fortune so we've used “typically” to soften certain
points. This is the same word used by the Claimants and so by using their language we cannot be criticised.,
AGAIN, FINE.
4. Ata number of points you ask whether we can positively frame the case. Although I understand why you would
want to do this, it would then create an evidential burden on Post Office to prove that positive case. For exampie.,
f we say that people were instructed to behave honestly, we would then need to adduce evidence of those
instructions (which may mean trawling through thousands of documents and producing witness statements for
dozens of people}. If we say that people were not instructed to behave dishonestly, then the absence of any
evidence proves our point and it is Freeths that need to find the evidence to support their allegation. - AGAIN, I
APPRECIATE THE LEGAL DISTINCTION RE EVIDENTIAL BURDEN AND ACCEPT THIS IS THE RIGHT
APPROACH.
Kind regards
Andy
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Andrew Parsons
Partner
Bond Dickinson
ein
(OMBLE
ARLYLE
From: Thomas P Moran
Sent: 13 July 2017 00:08
To: Andrew Parsons
Cc: Amy Prime
Subject: RE: PLSG meeting on Wednesday 24 May 2017 @12 in Tonbridge (1.11)
Andy and Amy
’'ve gone through the draft (and their doc). Here are my (very minor) comments.
Thanks
Tom
From: Andrew Parson:
Sent: 12 July 2017 14:49
Ce: Kevin Morgan! _ a “GRO __ .
Subject: RE: PLSG meeting on Wednesday 24 ‘May 2017 @12in Tonbridge (1.11)
All
Please find attached the draft Defence for your review and comment. As discussed earlier, if possible please provide
comments rather than amendments to the actual text. f've also attached the Claimants’ Generic Particulars of Claim for
reference.
You'll see a few paints where input from Deloitte and Fujitsu is needed — we expect to get this today.
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Please send any comments to me and Amy Prime (copied).
Thanks
Andy
Andrew Parsons
Partner
Bond Dickinson £
>
Gord Diccinsen.
WOMBLE
CARLYLE
Sent: 12 July 2017 14:40
To: Jane MacLeod; Angela Van-Den-Bogerd; Mark R Davies; Stuart Nesbit; Patrick Bourke; Rob Houghton; Rodric
Williams; Thomas P Moran; Tom Wechsler; Andrew Parsons; Mark Ellis; Melanie Corfield
Cc: Kevin Morgan
Subject: RE: PLSG meeting on Wednesday 24 May 2017 @12 in Tonbridge (1.11)
Dear ail, please find attached the open action list, which includes those taken today.
I have highlighted in yellow those that require people’s imminent attention.
Many thanks
Mark
* Mark Underwood
Head of Portfolio: Legal, Risk & Governance
Ground Floor
i 20 Finsbury Street
2017 Winner of the Global Postal Award London EC2Y 9AQ
for Customer Experience
Mobile number:
From: Mark Underwo:
Sent: 11 July 2017 13:46
To: Jane MacLeod; Angela Van-Den-Bogerd; Mark R Davies; Stuart Nesbit; Patrick Bourke; Rob Houghton; Rodric
POL-0020968
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Williams; Thomas P Moran; Tom Wechsler; ‘Parsons, Andrew’; Mark Ellis; Melanie Corfield
Cc: Kevin Morgan
Subject: RE: PLSG meeting on Wednesday 24 May 2017 @12 in Tonbridge (1.11)
Dear all, further to my note earlier today, please find attached the final Decision Paper.
Mark
Mark Underwood
Head of Portfolio: Legal, Risk & Governance
Ground Floor
hi 20 Finsbury Street
2017 Winner of the Global Postal Award f°") ng
for Customer Experience
From: Mark Underwoode=!
Sent: 11 July 2017 09:30
To: Jane MacLeod; Angela Van-Den-Bogerd; Mark R Davies; Stuart Nesbit; Patrick Bourke; Rob Houghton; Rodric
Williams; Thomas P Moran; Tom Wechsler; ‘Parsons, Andrew'; Mark Ellis; Melanie Corfield
Cc: Kevin Morgan
Subject: PLSG meeting on Wednesday 24 May 2017 @12 in Tonbridge (1.11)
Dear all,
We have a PLSG meeting on Wednesday 12 July @12 in Tonbridge (1.11). Ahead of that meeting please find attached:
1. The Agenda
2. Decision Paper: Access to Second Sight
3. Decision Paper: Standstill Agreement with Fujitsu
4. Decision Paper: Communications Strategy
5. Decision Paper: Wider Risks to POL [To follow later today]
6. Open actions list as at 11 July 2017
Please let me know if you are intending to dial in.
Many thanks, and apologies for the delay in circulating these papers.
Mark
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Dial-in numbers:
United Kingdom Freefone,
United Kingdom Internation:
Chairperson passcode: 85009207 then #
Participant passcode: 82368934 then #
\d Mark Underwood
Head of Portfolio: Legal, Risk & Governance
Ground Floor
7 20 Finsbury Street
2017 Winner of the Global Postal Award 7) Pn AQ
for Customer Experience
Mobile number:{”
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