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Message
From:
Sent:
To: Andrew Parson:
Subject: RE: PLSG meeting on Wednesday 24 May 2017 @12 in Tonbridge (1.11)
Hi Andy
Ihave read the Defence all the way through ona stand alone basis (not yet side by side against the GPOC!) and have no
comments. I’m convinced ~ but I guess it’s not my judgement that counts!!!
You and Mark were locked away when I came back to my desk. Mark said that you thought the discussion had gone
well, although I was kicking myself for talking about the black hat’ work, as that took us down an unnecessary rabbit
hole. Still we got it back .....
So, in terms of minutes of the discussion yesterday, my suggestion ~ subject to your thoughts, would be:
“SM and Andrew Parsons, Partner from Bond Dickinson briefed GE on the proposed Defence that would be filed on
behalf of Post Office on 18 July in the Postmaster litigation. The following points were made:
@ Mr Parsons described the role of the Defence document in the proceedings, and noted that the document
would be signed by the General Counsel on behaif of Post Office.
@ The accuracy of the factual statements included in the Defence had been reviewed internally by those Post
Office staff with knowledge of the relevant facts.
e« Mr Parsons summarised the key themes arising in the litigation and the approach to those themes in the
defence.
e freeths were still advertising for additional claimants however the window for applicants to apply to join the
litigation would close on 26 July and Post Office would receive details of the total number and names of
applicants shortly thereafter. Present indications suggested that the total number of claimants in the
proceedings would be 400-500.
* The Claimants have the opportunity to respond to Post Office's Defence in a formal document called a
Reply. This is due to be served on Post Office and filed with the Court on 20 September 2017. {tis not
mandatory for the Claimants to serve a Reply but given the complexity and importance of this case it is expected
that they would do so.
« ACourt hearing, called a Case Management Conference, will take place on 19 October 2017. This hearing, and
the preparation for it, will provide an opportunity for Post Office and the Claimants to agree further steps
leading up to trial, including the selection of those postmasters' cases which the parties wish to put forward as
Lead Cases; disclosure of documents; witness evidence and expert evidence. Once selected, the Lead Cases will
be examined in greater detail by the Court at mini-trials with the aim of using those cases to determine points of
principle or fact that apply broadly to many cases. To be able to do this, the parties will need to set out their
positions in relation to these Lead Cases in further, case-specific Particulars of Claim, Defences and Replies.
GE noted the briefing and requested that a further update be provided to GE and the Board following the Case
Management Conference. This update should include an assessment of the potential impact on Post Office and its
business and operations of the range of possible outcomes, based on the issues to be considered through the Lead
Cases.”
Many thanks,
Jane
Jane MacLeod
Group Director of Legai, Risk & Governance
POL-0021106
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Ground Floor
20 Finsbury Street
LONDON
ECZY 9AQ
Mobile number:
From: Andrew Parson:
Sent: 12 July 2017 14:49
To: Mark Underwood!
Van-Den-Bogerd
5 Mark R Davies ¢
Thomas P Moran
4 Mark Ellis
Rodric Williams ["”
Tom Wechsler ¢
; Amy Prime
Subject: RE: PLSG ‘meeting on Wednesday 24 May 2017 @12 in 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. I'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.
Please send any comments to me and Amy Prime (copied).
Thanks
Andy
Andrew Parsons
Partner
Bond Dickins:
Mobile:! .G RO.
Office: 4
Follow Bond Dickinson:
www.bonddickinson.: com
new breed of
tlantic at tan
From: Mark Underwoo: i.
Sent: 12 July 2017 14:40
To: Jane MacLeod; Angela Van-Den-Bogerd; Mark R Davies; Stuart Nesbit; Patrick Bourke; Rob Houghton; Rodric
POL-0021106
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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 all, please find attached the open action list, which includes those taken today.
! have highlighted in yellow those that require people’s imminent attention.
Many thanks
Mark
N Mark Underwood
Head of Portfolio: Legal, Risk & Governance
Ground Floor
i 20 Finsbury Street
2017 Winner of the Global Postal Award f°") oAQ
for Customer Experience
Mobile number:
From: Mark Underwood-I
Sent: 11 July 2017 13:46
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: RE: PLSG meeting on Wednesday 24 May 2017 @12 in Tonbridge (1.11)
Dear ail, further to my note earlier today, please find attached the final Decision Paper.
Mark
“ Mark Underwood
Head of Portfolio: Legal, Risk & Governance
Ground Floor
. 20 Finsbury Street
2017 Winner of the Global Postal Award London EC2Y 980
for Customer Experience
Mobile number:
From: Mark Underwood !
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
Ce: 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:
POL-0021106
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.
Dial-in numbers:
ited Kingdom Freefone
United Kingdom International direct:
Chairperson passcode: 85009207 then #
Participant passcode: 82368934 then #
* Mark Underwood
Head of Portfolio: Legal, Risk & Governance
Ground Floor
i 20 Finsbury Street
2017 Winner of the Global Postal Award London EC2Y SAQ
for Customer Experience
Mobile number:
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