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From: Rodric William:
To: Andrew Parsons } G RO
Subject: RE: Statement [WBDUK-AC.FID26896945]
Date: Thu, 23 Aug 2018 23:26:41 +0000
Importance: Normal
Attachments: FINAL_DACB Letter_to VOA_20.06.13.PDF;
Signed_Witness_statement_of_Rob_Scott_dated_27_October_2016.pdf; RFS1.pdf;
SF1.pdf;
Witness statement_of Sean Farrow dated 27 October 20 16(215905686_1) (2).pdf;
_DOC_151448389(1)_Witness_Statement_of_Angela_Van_Den_Bogerd_v6_20 Aug 2
018 _(RW_comments_23.08.18).docx
Inline-Images: image002.png; image003.png; image004.png; image005.png
Andy — pls see my comments on AvdB’s statement.
We discussed this earlier today , but in addition to those comments, please note:
Re: counsels’ comment on 55.2 (“Customers can cash ATM security requirements?”), I wasn’t not sure what
this meant, but I attach a letter DACB sent for us to the Valuation Office Agency on ATMs, which sets out at
length (from para 35) various obligations for Bol’s ATMs which flowed through POL to the SPMs...
Re para’s 60 to 64: I attach two witness statement prepared on MoneyGram, Rob Scott’s dealing at para’s 11
to 17 with the processing of MoneyGram transactions, and Sean Farrow’s dealing with our AML regime...
More generally, please note that last financial year Legal created a Legislative & Regulatory Framework,
which in table format set out the leg’s and reg’s POL is subject by reference to business area and
accountabilities. We followed that up with a Material Contract Framework which did the same thing for our
more important contracts. I mention these now so that we can refer to them if need be down the line, as I
don’t think they can be (or indeed should be) used in the witness statements at his juncture (if for no other
reason, the leg’s and reg’s are matters of law which counsel should be able to refer to without a witness
statement).
One overarching point on the witness statements: please make sure you are giving the witnesses the
“health warning” on signing a statement of truth, i.e. they need to be confident that what they say in the
statement is true to the best of their knowledge and belief, and that they don’t accept something just because
it’s been through the lawyers.
Thanks, Rod
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From: Andrew Parsons [._
Sent: 20 August 2018 16:32
Pp; Rodric Williams
Ce: Victoria Brooks
Subject: RE: Statement [WBDUK- Te. FiD36806045]
Angela
Please find attached your updated statement (+ a comparison showing the changes from the original version sent to
you). This includes your comments, further amendments from Counsel and some comments from me.
Once you've had a chance to review, it might be easiest for us to setup a call to go through the remaining points.
Thanks
Andy
Andrew Parsons
Partner
Womble Bond Dickinson (UK) LLP
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From: Angela Van-Den-Bogerd [
Sent: 17 August 2018 16:59
: Andrew Parsons; Rodric Williams
: Victoria Brooks
Subject: RE: Statement
Importance: High
Andy
Please find attached the latest version of my statement. This is still work in progress as I have some queries
out with the business. I will pick this up again on Monday when I should have the information I’ve
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requested. In the meantime I’m returning to you as I have some comments for you/WBD that I’ve tracked —
could you review and let me have a response/update please. Where we’ve referenced other witness
statements it would be helpful if I could see them. Is this possible?
Thad intended to be on leave next week but in light of this being unfinished I am now in work on Monday
and will pick up for the rest of the week to finalise this statement ahead of submission deadline.
Thanks,
Angela
Angela Van Den Bogerd
People Services Director
1 Floor,Ty Brwydran,
Atlantic Close,Llansamlet
Swansea SA7 9FJ
GRO
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From: Andrew Parsons {”
Sent: 08 August 2018 21:15
To: Angela Van-Den-Bogerd GRO } Rodric Williams
i GRO
Ce: Victoria Brooks +
Subject: Statement
Angela
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Please find attached the latest draft of your statement. All comments welcomed. This has been restructured from the
last version you saw, added a number of new sections and have cut out some material to make it shorter / where we
have considered material to be to far over the line of admissibility.
Rod — your comments also welcomed. In particular, there are some comments marked in green for your attention.
Kind regards
Andy
Andrew Parsons
Partner
Womble Bond Dickinson (UK) LLP
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