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To: Parsons, Andrew [/o=Exchange-Org/ou=Exchange Administrative Group
(FYDIBOHF23SPDLT)/cn=Recipients/cn=ad9ed344815e47e4aaa3c0e7e1740919-Andrew Pars]
cc: Rodric Williams Jane MacLeod ; Prime, Amy
[/o=Exchange-Org/ou=Exchange Administrative Group
(FYDIBOHF23SPDLT)/cn=Recipients/cn=ab7222dda3a9453eaed5751238a59562-Amy Prime]
Subject: Re: Postmaster Litigation - Subject to legal privilege. [BD-4A.FID26896945]
Apologies - I have read it through and am content.
Mark Davies
Communications and Corporate Affairs Director
On 29 Nov 2016, at 16:34, Parsons, Andrew I - GRO. ~ “}wrote:
Mark — apologies for pressing — but have you had a chance to review the draft letter?
Andy
Andrew Parsons
Partner
Bond Dickinson LLP
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Direct
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www.bonddickinson.com
From: Jane MacLeod [mailte = GRO
Sent: 29 November 2016 09:07
To: Mark R Davies
Cc: Rodric Williams; Parsons, Andrew
Subject: RE: Postmaster Litigation - Subject to legal privilege.
Mark
Attached is the recent Freeths’ letter and Sunday’s draft of the full response — most of which is
procedural. There have been no material changes to that response other than in relation to section 9
which I sent you last night.
We want to get the response back to Freeths today if possible given that they are due to file their
Particulars of Claim on 1 December (Thursday). Please liaise with Rod and Andy if you have any queries
or comments.
Thanks
Jane
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® Jane MacLeod
General Counsel
Ground Floor
20 Finsbury Street
LONDON
EC2Y 9AQ
Mobile number:
From: Mark R Davies
Sent: 29 November 2016 09:
3 Rodric Williams
Hi both
Could one of you send me the full document and I will re-read. Sorry that I haven't been as close
to this as I should be.
Mark
Mark Davies
Communications and Corporate Affairs Director
On 28 Nov 2016, at 23:35, Jane MacLeod
Paula, Al
Following discussions with our QC and Bond Dickinson this afternoon, the
following is the recommended language to be included in the response to Freeths
in the wider section on remote access:
"At each stage, Post Office ascertained the position to respond to
the questions it believed it was being asked. With the benefit of
hindsight, some of Post Office's statements may have been
incorrect in light of what has since been identified in relation to
Fujitsu's administrator access rights (see below). But Post Office
tefutes any suggestion that it ever made false statements
deliberately or did so to mislead, deceive or conceal. The Post
Office personnel responsible for those statements made them in
good faith: what was said reflected what they understood the
position to be after they had made relevant enquiries at the time."
There have been no other material changes to the wider drafting around the
remote access issue which I circulated to you earlier today.
The challenge has been to balance the risk of adverse publicity ahead of the court
process (Post Office's concern) with the need to be open and transparent with the
Court in admitting that certain of the information we provided previously on this
issue could be construed as ‘wrong’.
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Given Mark D had other commitments today, I am taking him through this
wording early tomorrow.
Kind regards,
Jane MacLeod
General Counsel
The Post Office
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