POL00040090
POL00040090
Message
From: Parsons, Andrew [Andrew.Parsonsi.
Sent: 12/03/2014 10:00:
To:
cc: Matthews, Gavin [Gavin.Matthe\
Subject: Advice for Linklaters [BD-4A.FID20472253]
Attachments: Advice for Linklaters.zip
David, Chris
Please find attached the key pieces of formal advice that have been prepared by BD. There are obviously 1000s of other
emails which provide further ad hoc advice.
A few documents to note in particular:
1. Note of meeting with Richard Morgan QC.
Back in 2012, before SS were engaged, the primary concern was that SPMRs would bring something akin to a class
action against POL. This was being driven by Shoosmiths and the 100+ SPMRs they had gathered together. Off the back
of Shoosmiths' attempts to get a test case off the ground (which was ultimately unsuccessful), we instructed Richard
Morgan QC to advise on whether POL should instruct an expert to a produce a pre-emptory report giving Horizon a clean
bill of health. (I think at this time the intention was to use Deloittes - apologies I was not directly involved in these events).
Attached is a summary of the key points from the con with RMQC in which he advises against instructing an expert.
2. Settlement presentation.
This presentation is for a talk I gave to what was at that time the Sparrow Steering Group. (Chris - you may recall that this
was the lead decision making body for Sparrow before the Programme Board was constituted and was attended by a
number of ExCo members). This presentation was the starting point for the settlement policy.
3. Insurances risks note
This note had the dual purpose of advising the board (its contents were later reflected in a board paper) and acting as
notification to POL's insurers — hence why this doesn't look like a traditional piece of legal advice.
Kind regards
Andy
Andrew Parsons
Senior Associate
for and on behalf of Bond Dickinson LLP
POL-0036572