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Message
From: Rodric Williams
Sent: 11/05/2018 12:4:
To: Mark Underwood; ndrew Parsons [/o=Exchange-Org/ou=Exchange
Administrative Grou =ad9ed344815e47e4aaa3c0e7e1740919-Andrew Pars]
Subject: RE: PL Subcommittee minutes 260318 v1.docx [BD-4A.FID26896945]
Agreed.
From: Mark Underwood1
Sent: 11 May 2018 13:42
To: Andrew Parsons “} Rodric Williams
Subject: RE: PL Subcommittee minutes 260318 v1.docx [BD-4A.FID26896945]
I had thought so to. Lets discuss on our call at 330
* Mark Underwood
Head of Portfolio: Legal, Risk & Governance
Ground Floor
7 20 Finsbury Street
2017 Winner of the Global Postal Award f) "nh 9AQ
for Customer Experience
From: Andrew Parson:
Sent: 11 May 2018 13:29
To: Mark Underwood! < ; Rodric Williams <¢
Subject: Fwd: PL Subcommittee minutes 260318 v1.docx [BD-4A.FID26896945] ~~
What updates is Veronica referring to?
Have I missed something? I thought Tuesday was purely a verbal discussion.
From: VeronicaBrantons = GRO]
Sent: Friday, May 11, 2018 1:22 pm
Subject: RE: PL Subcommi' i
To: Rodric Williams
MacLeod GRO
Cc: Ben Foat
[BD-4A.FID26896945]
Jane
Dear all
Please could you let me know when the updates for the PL Subcommittee meeting on 15 May will be ready?
Best wishes
Veronica
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From: Rodric Williams
Sent: 08 May 2018 2
To: Andrew Parsons < Jane MacLeod Veronica
Branton <7 GRO 7
Cc: Ben Foat <j GRO b
Subject: RE: PL Subcommit
Jane,
26 March 2018 Subcommittee Minutes
I have no comments on your or Andy’s amendments to the Minutes. I have in the attached version merely:
- added in the dates of the meetings referred to in para’s 1.1 and 7; and
- deleted “RW” from the “Action” column for para’s 3.3 and 7, because as amended these para’s don’t call out
any specific actions.
15 May 2018 Subcommittee Agenda / Merits Opinion
The agenda set out in your 2 May 2018 email for next week’s meeting is dominated by the Merit’s Opinion. Andy and!
propose to deal with that as follows:
- we will review an advanced working draft as soon as it is available, and prepare a precis of what is sure to be a
long document.
- the precis's aim is to:
© summarise the Opinion for you and your communications to your GE colleagues;
© act as the QCs’ speaking note at the meeting (which we will ask David Cavender to lead);
o possibly be provided to UKGI as an update, but only once the information sharing protocol is agreed.
- while reviewing the draft Opinion, we will also consider whether the precis should cover the “next steps and
forward plan” and “contingency planning” agenda items, or if these should be kept separate.
UKGI information Sharing Protocol
UKGI have not yet responded to the email I sent on 2 May 2018 with the latest version of the protocol. I do not intend
to chase them for a response, as I think we can justifiably (but politely) refuse UKGI direct access to the Opinion or any
precis of it until we are comfortable that the appropriate structures are in place to protect the privilege in a highly
sensitive document.
Without the protocol, I believe we can offer UKGI an oral update on our current approach to the Group Litigation as
informed by the Opinion and Board discussions. I would prefer to provide this in a face-to-face meeting clearly stated to
be privileged. We could provide the update by phone, but that could require us to email an agenda, opening up the
possibility of a wider ranging email exchange (e.g. as per the 30 April email between UKGI and Patrick).
Against this, the “carrot” of a more detailed, written update on the Opinion may be what we need to get UKGI to agree
our version of the protocol.
Please let me know if you disagree with, or have any comments on, the proposed approach
Rod
From: Andrew Parsons {
Sent: 08 May 2018 08:36
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To: Jane MacLeod
Cc: Rodric Williams
Subject: RE: PL Subcommittee minutes 260318 Vi-docx [BD-4A.FID26896945]
; Veronica Branton <:
Jane
Please find attached a coupie of smail changes from me. My principal change is to add a statement at the top of the
minutes making clear that they are privileged (as if this wasn’t obvious enough!)
Andy
Andrew Parsons
Partner
Wombie Bond Dickinson (UK) LLP.
‘ WOMBLE womblebonddickinson.com
BOND
DICKINSON v ©
Andrew Parsons
Partner
Womble Bond Dickinson (UK) LLP
. WOMBLE womblebonddickinson.com
~ BOND
DICKINSON w ©
From: Jane MacLeod
Sent: 07 May 2018 23:05
To: Veronica Branton
Cc: Andrew Parsons; Rodric Williams
Subject: PL Subcommittee minutes 260318 v1.docx
Veronica
Please find attached my mark-up of the draft minutes of the first meeting of postmaster litigation committee. There are
a couple of names and dates to be inserted (date of January board meeting, May committee meeting and name of our IT
expert) and I have tried to make the language even more anodyne. Rod/Andy — please check that you are comfortable
with these?
Many thanks,
Jane
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