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Message
From:
Sent:
To:
Lord, William
Subject: FW: CONFIDENTIAL SETTLEMENT DEED - Undertakings conditional on settlement
Attachments: Letter to Post Office Ltd. pdf; Signed undertaking.pdf
Undertakings offered from JH and Therium, attached. Held to my order for the time being.
From: James Hartley!
Sent: 09 December 2!
To: Emanuel, Catherine <
Cc: Watts, Alan I
b Imogen Randall
jen Miletic
b James Hartley < }
Subject: RE: CONFIDENTIAL SETTLEMENT DEED - Undertakings conditional on settlement
Patrick Green QC
Kate
Please find attached signed undertakings, worded as agreed in our previous email exchanges. These are sent strictly on
the basis that the undertakings only become effective, and are only given, if and when a settlement agreement is
executed to settle the Post Office Group Action. These undertakings are therefore to be held by you to our order and in
the event that no settlement is concluded you will return the undertakings, which will have no effect and will not be
binding.
Please confirm your agreement that the attached undertakings are received and held on the basis set out above. If you
are not able to give that confirmation then please return the undertakings by return of email.
Regards
James
From: Emanuel, Catherine
Sent: 09 December 2019 16:45
To: Patrick Green
!Ognjen Miletic <
; stephen. ruttle”
DEED - Updated Master Version
All,
When can I expect the drafting on the 2 outstanding points (related parties and press coverage) as well as the proposed
undertakings?
Kate
From: Patrick Green QC ¢_ GRO
Sent: 09 December 2019 15:43
“yJames Hartley <
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stephen.ruttle,___GRO__
Subject: Re: CONFIDENTIAL SETTLEMENT DEED - Updated Master Version
Kate
Just working on the [AAA] points on Related etc — haven’t forgotten them
Best, Patrick
James Hartley
Freeths LLP
Floor 3, 100 Wellington Street
Leeds LS1 4LT
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On 9 Dec 2019, at 15:25, Ognjen Miletic 4
Dear Kate,
As promised, please find attached the compare document showing changes from the version
you circulated at the weekend.
Best,
Ognjen
From: Ognjen Miletic
Sent: 09 December 2019 15:20:40
To: Emanuel, Catherine; James Hartley
Cc: Watts, Alan; Patrick Green QC; Henry Warwick; Imogen Randall; Charles Flint QC;
stephen.ruttle:
Subject: CONFIDENTIAL SETTLEMENT DEED - Updated Master Version
Dear Kate,
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Please find attached a revised version of the Settlement Agreement. It is a clean document
but a compare document will be sent shortly to show changes made from the last version
which you circulated at the weekend.
Also attached is a compare document showing the minor changes in the Joint Press
Statement. The new statement from Alan Bates is contained within the body of the
attached Settlement Agreement.
There a couple of minor matters still to come which will follow as soon as possible.
Many thanks,
Ognjen
<Compare Document (9 December 2019 at 3.24pm).docx>
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Herbert Smith Freehills LLP and its subsidiaries and Herbert Smith Freehills, an Australian Partnership, are
separate member firms of the international legal practice known as Herbert Smith Freehills.
This message is confidential and may be covered by legal professional privilege. If you are not the intended
recipient you must not disclose or use the information contained in it. If you have received this email in error
please notify us immediately by return email or by calling our main switchboard on +44 20 7374 8000 and
delete the email.
Further information is available from www.herbertsmithfreehills.com, including our Privacy Policy which
describes how we handle personal information.
Herbert Smith Freehills LLP is a Limited Liability Partnership registered in England and Wales with registered
number OC310989. It is authorised and regulated by the Solicitors Regulation Authority of England and Wales
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