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Message ne ee
From: Jane Macleod: GRO '
Sent: 21/03/2018 15:
To: Rodric William:
cc: Patrick Bourke:
Veronica Brantor
Subject: FW: Litigation and Appoifitment= next steps
Attachments: Draft Protocol.docx
(Veronica — for awareness re Monday committee meeting; Di — for awareness re setting up a possible call on Friday)
All
lam being chased by UKGI for our views on this ~ can I have your thoughts? We have the first Board sub-committee
meeting on Monday and {I wouid like to flag this to them?
Also, we need to work up an agenda for that sub-committee meeting. So far my suggestions would be:
© ToR
* Litigation timetable & suggested dates for future meetings
e Update on developments since January board meeting:
© Scope of disclosure
© Scope of Horizon hearing
o Appointment of IT expert
© Application for security for costs
© Engagement with UKGI
e Contingency planning
« AOB
Anything else — we only have an hour? Could we have a call on Friday to discuss?
Thanks
Jane
Jane MacLeod
Group Director of Legal, Risk & Governance
Ground Floor
20 Finsbury Street
LONDON
EC2Y 9AQ
From: O'Neill, Elizabeth - UKG
Sent: 01 March 2018 1!
To: Patrick Bourke
Cc: Jane Macleod
Richard - UKGI
'Rodric Williams ¢ GRO —__icallard,
Cooper, Tom - UKG
aambert, Helen - UKGI
Patrick, Helen,
Thank you for your time last week.
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As discussed, I attach a standard form litigation protocol along the lines of what we would propose to submit to the
Permanent Secretary. As you will see, this sets out various touchpoints in the litigation process, and the steps we intend
to take to ensure the Permanent Secretary remains fully informed at each salient point.
If you are able to provide more detail on the litigation timetable, or indeed if you have any comments or suggestions, we
would be happy to amend the protocol bespoke to the current litigation.
Separately I’d be grateful, as I indicated in my email to Helen on Monday, if in anticipation of Tom Cooper’s
appointment, you could let me know if you intend to agree an NDA similar to the one you have with Richard, and if so,
forward me the proposed text so that Tom and I may consider.
Kind regards,
Elizabeth
From: Patrick Bourke}
Sent: 23 February 2018 15?
To: O'Neill, Elizabe'
Cc: Jane Macleod
Richard - UKGI <
Subject: Litigation Meeting
Dear Elizabeth
It was a pleasure to meet with you this morning.
I just wanted to confirm that we have understood the need for an appropriately structured information flow in
relation to the matters we discussed earlier, and agree that some form of protocol to govern those arrangements
makes very good sense.
While recognising that there is no set format in this regard, it would nonetheless be helpful for us to draw
inspiration from similar arrangements you have put in place with other ALBs. You kindly offered to share
something with us for that purpose.
We will come back to you with our take on how this might work best in our case, having regard to the
particularities of our governance arrangements and the litigation itself.
In the meantime, do please feel free to get in touch if there is anything you'd like to discuss.
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Kind regards
Patrick
° Patrick Bourke
Corporate Affairs Director
1 Floor
20 Finsbury Street
2017 Winner of the
Global Postal Award for
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London EC2Y SAQ
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