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From: "Parsons, Andrew" <
To: Mark Underwood; GRO. >
Subject: RE: Tim Parker Briefing [BD-4A.FID26859284]
Date: Tue, 12 Jul 2016 08:03:19 +0000
Importance: Normal
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Mark
Paragraph below. This is pretty vague but intentionally so as we can't share details of our legal advice with the
Minister for fear of waiving privilege in that advice. In all privilege arguments, the risk that pulling one thread leads to
the unravelling of privilege in other areas eg.
¢ We tell the Minister that the reason we are not progressing the review is due a risk that TP's review is not
privileged.
« — That communication to the Minister is, itself, not privileged. We may then need to disclose that
communication to the Minister to Freeths.
« Freeths then use that communication to attack the privilege in TP's work.
Suggested para:
"Once litigation is contemplated, confidential investigations and work done for the dominant purpose of furthering the
litigation will be covered by litigation privilege. Any work going forward should therefore be driven by the needs of the
litigation and not for other reasons, such as the Review, so to maximise the protection of privilege. If work is not
covered by privilege, this may force Post Office to disclose sensitive material to the Claimants, undermining Post
Office's position in the litigation."
Call if you'd like to discuss. In Rod's absence, I'd like to cast an eye of the briefing note if that is ok? I just want to
check that we're not crossing any privilege lines.
Call if you want to discuss.
Andy
Andrew Parsons
Partner
www.bonddickinson.com
From: Mark Underwood!
Sent: 12 July 2016 08:28
To: Parsons, Andrew
Subject: Tim Parker Briefing
Importance: High
Hi Andy,
Tim P has a meeting with the Minister on Tuesday. I am preparing his brief, to circulate tomorrow amongst Patrick,
Rod & Jane — all of whom are currently on Annual Leave.
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In conversations with the Minister’s office, they have confirmed that they understand (and indeed anticipated) the
need for prioritising the litigation and therefore for work to cease on the ‘Review’.
The Minister has been briefed by her officials and though our understanding is that she does not wish to challenge
this decision, she would like to better understand the reasons underpinning the legal advice received.
With Rod away, would you be able to provide me with a paragraph / couple of bullets on the reasons underpinning
the legal advice?
It would be great if I could have this by close today — will that be possible?
Mark
Jeiobiotoipicioloioioini iolbiinig oid odio oi dogg ag ab Sg SDI SEIS EASE SSE ISIE
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