POL00040201
POL00040201
Message
From: Parsons, Andrew [Andrew.Parson
Sent: 03/06/2014 09:08:42 . . ;
To: Belinda Crowe (belinda.crowt GRO [belinda.crowe
[angela.van-den-bogert J]; David Oliver1 (davi
(david.oliver1/’ Rodric Williams (rodric.william’
[rodric.willia } Jessica Barker (jessica.barke:
[jessica.barke} GRQ
cc: Thorp, Ben (beii.thorpi \
Subject: M127 - CRR response and settlement analysis [BD-4A.FID25887823]
Attachments: Comparison of M127 - POL response (full) v3 with M127 - POL response (fu....doc;_DOC_28834396(1)_M127 - POL
response (full) v4 - 3 6 14.D0C; _DOC_28834153(2)_M127 - Settlement Analysis.DOCX
All
Please find attached for your review:
e Updated CRR response (+ comparison showing the changes)
e A first draft of the settlement analysis for this case.
The Settlement Analysis on this case has been very difficult. There is clearly a material disagreement between POL, SS
and the Applicant however POL's position is that it perceives little or no risk. As such, it is a finely balanced call on
whether this case should or should not be mediated and/or whether or not a small settlement should be offered.
The attached Analysis is therefore very much a "starter for 10" for discussion. I'd be grateful if we could have a call to
discuss this so to sound out the Post Office position. As the Settlement Policy has been withdrawn, we are at present
providing our advice on purely legal / litigation risk grounds (in line with the Linklaters advice). However, we'd be happy to
incorporate on any non-legal factors if required — we just need a bit of guidance on what they may be.
With regard to the draft CRR response — we'd be grateful for any final comments by close today (submission date is
tomorrow).
Kind regards
Andy
Andrew Parsons
Senior Associate
for and on behalf of Bond Dickinson LLP
POL-0036683