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Message
From: Rodric Williams
on behalf of — Rodric Williams
Sent: 13/03/2014 22:
To: Chris Aujard £ "y; 'andrew.parsons¢
ce: Belinda Crowe [
Subject: Re: Access to legal files
Sensitivity: I Company Confidential
Andy - I will fwd you the dox we have around the past disclosure to give context to the response.
Kind regards, Rodric
From: Chris Aujard
Sent: Thursday, March I
To: Parsons, Andrew <
Cc: Belinda Crowe; Rodric Williams
Subject: Re: Access to legal files
Thanks Andy- I do agree; if you could pen something out for me to send, that would be much appreciated. Kind regards
Chris
Sent from my iPhone
> wrote:
On 13 Mar 2014, at 06:31 pm, "Parsons, Andrew" <p
Chris
My thoughts on lan’s request below for access to legal files:
First, I'm not sure if this means civil legal files or prosecution files or both.
Second, providing access would almost certainly destroy any legal privilege.
Historically, I understand that SS may have had some limited access te legal files for their first report. I
assume that this is the "agreement" that lan refers to below. This was controlled (1 think) under a
NDA/privilege agreement. In this context, the risk to privilege was reduced because the case specific
information was not being disclosed in SS report - rather they were drawing general threads from the
files.
The situation now is markedly different. The info in the legal files, if disclosed to SS, is now inevitably
going to the Applicants. In this situation, there is practically no chance of preserving privilege.
For this reason my recommendation is to (1) refuse disclosure of the legal files and (2) remind SS of the
previous agreement so to prevent disclosure of any privileged material in their possession already
{assuming that agreement exists - which I'll go away and check).
if you agree, I believe that this is something that should be addressed in writing, even if that is only an
email. I'd be happy to pen something for you to send if that helps.
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Kind regards
Andy
Andrew Parsons
Senior Associate
for and on behalf of Bond Dickinson LLP
From: Belinda Crowe }
Sent: Thursday, March 13; 2014 04:58 PM
To: Parsons, Andrew
Cc: Rodric Williams <"
'; Chris Aujard
; Belinda Crowe <
Subject: FW: Access to legal files
As discussed. Please copy me into any response to lan.
Best wishes
Belinda
Belinda Crowe
i
From: Ian Henderson [~
Sent: 13 March 2014
To: Belinda Crowe
Ce: Chris Aujard; riw'
Subject: Access to legal files
Sensitivity: Confidential
David Olivert
Belinda
We have previously agreed that in cases where Second Sight requires access to any legal files held by
POL, we will ask for the files to be recovered from storage and sent to London. I will then come in to
148 Old Street and review the files.
This is obviously much more cost effective than us asking for paper or scanned copies of the entire file,
which was the previous process under the Spot Review procedures.
As a result of reviewing the latest batch of CQRs I would be grateful if you can request the following
legal files:
1. M041 - Wendy BUFFERY
2. M118 - Carl PAGE
Please let me know when these files are available for me to review.
Many thanks
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With best wishes
Tan R Henderson CCE CISA FCA
Advanced Forensics - London, UK
Forensic computing expert witness and electronic disclosure specialist
Linkedin: http: //linkedin.com/in/forensicgod
Twitter: http://twitter.com/forensicgod
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