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Message
From: Thomas P Moran [thomas.p.morani,
Sent: 27/11/2016 13:27:01
To: Jane MacLeod [jane.macleod! j
cc: Parsons, Andrew [/o=Exchange-Org/o change Administrative Group
(FYDIBOHF23SPDLT)/cn=Recipients/cn=ad9ed344815e47e4aaa3c0e7e1740919-Andrew Pars]
Subject: Re: Letter to Freeths - legally privileged [BD-4A.FID26896945]
Ok thanks, sounds sensible.
On Nov 27, 2016, at 1:06 PM, Jane Macleod!, wrote:
My proposal - which I discussed with the team on Friday) was to mention it to GE tomorrow morning
and then circulate the 'remote access’ section to Paula, Al, Mark D and Rob H for any final comments
during tomorrow.
Jane MacLeod
Sent from my iPhone
On 27 Nov 2016, at 11:04, Thomas P Moran i GRO “7 wrote:
Thanks for this, will read it later today.
Jane - what do you think we should do re GE (or a subset thereof) briefing and/or sign
off?
Tom
On Nov 27, 2016, at 9:39 AM, Parsons, Andrew:
wrote:
All
Please find attached a draft Letter to Freeths in response to their last
substantive letter (copy also attached). This incorporates comments
from Tony and Rod.
The majority of this letter addresses legal and procedural points. The
key substantive area is section 9 on Remote Access (in particular, Rob,
I'd be really grateful if you could review this section).
Following feedback from Deloitte, we cannot definitively say that PO (as.
distinct from FJ) never had the ability to change Horizon data because
Deloitte and the current staff at FJ just don't have enough knowledge of
Old Horizon to confirm this. This was a point made in an early draft but it
has now been removed.
We have (I hope) now found a formulation of words that avoids having to
overtly throw FJ to the wolves and avoids any risk of waiving privilege in
any documents, but still gives us a fair story to tell. We have also toned
down the admissions of making incorrect statements, though they are
still there. I hope this might make it easier to get this letter cleared
through GE and Fu.
We have a call scheduled for 5pm tomorrow with Tony which we can use
to run through any comments. Comments by email before then are also
welcomed.
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The final version of the letter will be thoroughly proof read before sending
so please ignore any typos.
Kind regards
Andy
Andrew Parsons
Partner
Bond Dickinson LLP.
<imagec819cf.PNG> <image3388e3.PNG>
www.bonddickinson.com
Bond Dic LY is authorised and
<Letter of Response.pdf>
<_DOC_34430591(1)_ Response to Letter of Reply_ 27 November
2016.DOCX>
Po De
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