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POL00151297
From: Matthews, Gavinf.
Sent: Thur 26/02/2015
To: Rodric Williams[I
Subject: FW: Draft Letter to CCRC
Attachment: image001.png
Rod
Brian’s comments — interesting point re SS — my view is we should spell out the limitation on privilege.
Regards
Gavin
From: Brian Altman [mailto:
Sent: 26 February 2015 15:15
To: Matthews, Gavin
Subject: RE: Draft Letter to CCRC
Gavin
I have read through the letter and considered it against the CCRC letter.
I agree with option 1.
We should put the ball back in the CCRC’s court so that they tell us what interests them or it’ll be a never-ending hunt
for irrelevance.
My one other thought re option 1 is this: we don’t know why the CCRC have started enquiring now, but a good guess
would be the MPs’ interest and perhaps the parliamentary committee. While I never subscribe to conspiracy theories
it may be the case that Second Sight is in cahoots with certain parliamentarians or others and has reported POL to the
CCRC or sought an enquiry, which leads me to the point: do we need to make clear who a “third party” is for the
purposes of para 1.? i.e. that the definition includes Second Sight? Or looked at another way should we make clear in
the letter for the avoidance of doubt (or is it sufficiently clear) that the privilege POL is asserting is POL’s and does not
extend to anyone other than POL and its legal advisers.
Maybe that is too paranoid but it was a thought.
Otherwise I am content with the option 1 draft.
Brian
From: Matthews, Gavin [mailto!
Sent: 26 February 2015 14:43
To: Brian Altman
Subject: FW: Draft Letter to CCRC
Brian
As just discussed, here is Rod’s email and the draft letter to the CCRC.
Please can we have your comments. Although I drafted it on the basis of option 2 above I believe option 1 as drafted
by Rod is more sensible.
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As stated, POL want to send the letter by the end of the week.
Kind regards
Gavin
From: Rodric Williams [mailt
Sent: 26 February 2015 13:19
To: Jane MacLeod
Cc: Chris Aujard; Matthews, Gavin
Subject: Draft Letter to CCRC
Jane,
With apologies for the delay, please find attached my revised draft letter to the CCRC. I also attach the letter to which
it responds for ease of reference.
The main change to Gavin’s first draft concerns our response to the requirement that POL provide "an updated
summary of the decisions and actions taken by the Post Office as a result of Brian Altman QC's report or copies of the
documents recording those decisions and actions."
Brian’s report makes a quite a few recommendations. Reporting on each of them is likely to be a time consuming
exercise which may produce a lot material irrelevant to the CCRC’s investigation. I think we can therefore respond in
one of two ways, either:
1. ask the CCRC (nicely) to identify the specific recommendations in the report which are pertinent to its
investigation; or
2. commit to providing everything within a longer time frame.
My preference is for Option 1, but I have included both alternatives in the draft.
Please let me have your comments. Gavin — can you please forward to Brian for his comments.
Kind regards, Rod
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