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Sent: Thur 13/07/2017 34 PM (UTC)
To: Andrew Parsons} i
Ce: Prime, Amy; Rodric Williamst_
Subject: RE: PLSG meeting on Wednesday 24 May 2017 @12 in Tonbridge (1.11)
Andy
I’ve just completed my reading and I’m bound to say that this is a really excellent job. Try as I might, I can’t find
anything which gives me real pause for thought. Insofar as that’s not a terrible reflection on my attention to detail, it’s
quite a piece of work.
If I might just raise one tiny exception to this — the reference in paragraph 9 “and to provide any necessary
cooperation” did just strike me as setting a pretty high bar — perhaps it needs to be, but I’d prefer to lose “any” or,
better still, refer to providing “appropriate and reasonable cooperation”.
Best wishes
Patrick
From: Andrew Parsons
Sent: 13 July 2017 10:07
To: Mark Underwood. Jane MacLeod; Angela Van-Den-Bogerd; Mark R Davies; Stuart Nesbit; Patrick Bourke; Rob
Houghton; Rodric Williams; Thomas P Moran; Tom Wechsler; Mark Ellis; Melanie Corfield
Cc: Kevin Morgan
Subject: RE: PLSG meeting on Wednesday 24 May 2017 @12 in Tonbridge (1.11)
All
FYI - The section list below has been updated with who has reviewed each section.
Thanks Tom and Tom for your comments last night
Andy
Andrew Parsons
Partner
Bond Dickinson LLP
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From: Andrew Parsons
Sent: 12 July 2017 08:48
To: 'Mark Underwood-3; Jane MacLeod; Angela Van-Den-Bogerd; Mark R Davies; Stuart Nesbit; Patrick Bourke; Rob
Houghton; Rodric Williams; Thomas P Moran; Tom Wechsler; Mark Ellis; Melanie Corfield
Cc: Kevin Morgan
Subject: RE: PLSG meeting on Wednesday 24 May 2017 @12 in Tonbridge (1.11)
All
Please find attached an extract from the full Defence. This is the summary section — it provides a good overview of
the Defence that we will be discussing later today.
One point that would also be good to discuss is whether anyone would like to review the Defence (its 80 pages) or
sections of it. To help with this, I've set out below a brief index to the Defence.
Section A: This is the fact heavy section of the defence; the rest of the defence is more legal.
Overview of postmaster contracts - KATH / SHIRLEY / ANGELA
Branch accounting contracts - KATH / SHIRLEY / ANGELA
Fujitsu, Horizon and remote access — FUJITSU / DELOITTE
Helplines - KATH / SHIRLEY / ANGELA / GAYLE PEACOCK
Post Office investigations - KATH / SHIRLEY / ANGELA
Termination of postmaster contracts KATH / SHIRLEY / ANGELA
Termination of postmaster contracts KATH / SHIRLEY / ANGELA
Suspense accounts — STILL BEING WORKED ON BY DELOITTE
PNANMPWNr
The sections below are more legally focused and have been reviewed by Rodric Williams
Section B: Contract terms and legal duties re postmasters
Section C: Contract terms and legal duties re assistants and employees
Section D: Duties in tort
Section E: Agency duties
Section F: Fiduciary duties
Section G: Breaches by Post Office
Section H: Claims for deceit
Section I: Harassment claims
Section J: Duress and unconscionable dealing
Section K: Malicious prosecution
Section L: Unjust enrichment
Section M: Loss and damage
Section N: Generic defences raised by Post Office
Post Office's counterclaim
Kind reg:
Andy
From: Mark Underwood:
ards
Sent: 11 July 2017 13:46
To: Jane MacLeod; Angela Van-Den-Bogerd; Mark R Davies; Stuart Nesbit; Patrick Bourke; Rob Houghton; Rodric
Williams; Thomas P Moran; Tom Wechsler; Andrew Parsons; Mark Ellis; Melanie Corfield
Ce: Kevi
Subject: RE: PLSG meeting on Wednesday 24 May 2017 @12 in Tonbridge (1.11)
Dear all, further to my note earlier today, please find attached the final Decision Paper.
Mark
in Morgan
Mark Underwood
Head of Portfolio: Legal, Risk &
Governance
2017 Winner of the
Global Postal Award Ground Floor
for Customer 20 Finsbury Street
Experience London EC2Y 9AQ
Mobile number
Sent: 11
Dear all,
July 2017 09:30
To: Jane MacLeod; Angela Van-Den-Bogerd; Mark R Davies; Stuart Nesbit; Patrick Bourke; Rob Houghton; Rodric
Williams; Thomas P Moran; Tom Wechsler; ‘Parsons, Andrew’; Mark Ellis; Melanie Corfield
Ce: Kevin Morgan
Subject: PLSG meeting on Wednesday 24 May 2017 @12 in Tonbridge (1.11)
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We have a PLSG meeting on Wednesday 12 July @12 in Tonbridge (1.11). Ahead of that meeting please find attached:
1.
The Agenda
Decision Paper: Access to Second Sight
Decision Paper: Standstill Agreement with Fujitsu
Decision Paper: Communications Strategy
Decision Paper: Wider Risks to POL [To follow later today]
Open actions list as at 11 July 2017
Please let me know if you are intending to dial in.
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Many thanks, and apologies for the delay in circulating these papers.
Mark
Dial-in numbers:
Chairperson passcode:
Participant passcode: I
Mark Underwood
Head of Portfolio: Legal, Risk &
Governance
2017 Winner of the
Global Postal Award Ground Floor
for Customer 20 Finsbury Street
Experience London EC2Y 9AQ
Mobile number}
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