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Message
From: Rodric Williams [
Sent: 21/04/2016 12
To: Mark Underwood! ___ ] Parsons, Andrew [/O=BOND PEARCE/OU=First
Administrative Group/c!
cc: Matthews, Gavin [/O=BOND PEARCE/OU=First Administrative Group/cn=Recipients/cn=grm1]; Lukas, Elisa
[/O=BOND PEARCE/OU=EXCHANGE ADMINISTRATIVE GROUP (FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=Elisa
Lukasd54]
Subject: RE: Group Action - action list
to the minister meeting with anyone about this case...
From: Mark Underwood:
Sent: 21 April 2016 13:
To: Rodric Williams; Parsons, Andrew
Cc: Matthews, Gavin; Lukas, Elisa
Subject: RE: Group Action - action list
Attached. It includes the same line.
Mark
From: Rodric Williams
Sent: 21 April 2016 13:41
To: Mark Underwoodsr'Parsons, Andrew
Cc: Matthews, Gavin; Lukas, Elisa
Subject: RE: Group Action - action list
Mark — can you pis send me the letter to BNR which formed the basis of the letter to lan Wright?
From: Mark Underwoode«!
Sent: 20 April 2016 20:34
To: Parsons, Andrew; Rodric Williams
Cc: Matthews, Gavin; Lukas, Elisa
Subject: RE: Group Action - action list
All,
Please find attached:
1. ~ email chain detailing what we had thought to be the position in respect of publically made statements about
limitation periods. This includes a letter from Lord Arbuthnot to Paula, and her reply.
2- The Letter to lain Wright MP which, in the second to last paragraph on the 2 page, we state we will not “use as a
defence in any subsequent court proceedings the fact that the 6 year time limit availabfe in all contractual disputes has
expired, where that time limit has expired while a case has been in the Scheme”
3-the template used to send to MPs who signed the EDM in September which, in the 4” paragraph of the 2™ page,
repeats the line quoted in 2 above
POL-0037618
Mark
From:
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Parsons, Andrew [mailto:andrew.parsons{
Sent: 20 April 2016 19:07
To: Rodric Williams
Cc: Matthews, Gavin; Mark Underwooderel
Subject: Group Action - action list
Rodric
Action
list from our meeting. I've also added in some other actions that we have discussed previously so we have
everything in one place. Your actions are in yellow.
Group Action
Strategy
1. Mark to send round "time bar" letter.
2. BD to draft notice for D&O insurer / broker
3. BD to prepare timeline of events / process map for litigation
4. Rod to raise with Jane the issue of a standstill agreement on claims against FJ
5. BD to advise on costs recovery (including in-house legal time) in context of group action.
6. BD to prepare short briefing note on Group Litigation procedure.
7. BD to do bullets for Rod on Chairman / Minister meeting.
8. Rod to set up meeting with Mark Davies to test the litigation strategy from a comms perspective (if Jane agrees)
Team
9. Rod to pitch "steering group” idea to Jane
10. BD to refine list of Counsel into a recommendation
Documents
11. BD to prepare letter to FJ re document preservation
12. BD to speak to Kath / Shirley re getting full story on past document gathering exercises
Short-term steps
13.
14.
CCRC
15.
16.
17.
. BD to prepare protocol on "What to do on receipt of Letter of Claim"
. BD to prepare response to Freeths last letter.
. BD to circulate updated CCRC tracker
. BD to check whether "payments mismatch" document is in CCRC data room
. Rod to circulate CK email re the effect of the "payments mismatch" issue on Misra / ask BAQC for advice on this
Chairman report
18.
19.
. Rod to revert to BD on Deloitte privilege question.
. BD to liaise with BAQC re reviewing criminal files
Kind regards
Andy
Andrew Parsons
Managing Associate
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