POL00219796
POL00219796
From: Rodric Williams[/O=MMS/OU=EXCHANGE ADMINISTRATIVE GROUP
(FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=RODRIC WILLIAMSE9C114F4-B03F-4595-B082-
CE89BE5C79D47B]
Sent: Thur 22/01/2015 7:50:03 PM (UTC)
To: Angela Van-Den-Bo erd. A Belinda
Crowe}
Subject: MO86 (Griffiths/Hope Farm Road) - draft Settlement Agreement - URGENT
Attachment: M086 - draft Settlement Agreement 22.01.2015.docx
Angela, Belinda,
Please find attached the draft settlement agreement setting out the basis on which the Griffiths/Hope Farm Road has
been resolved.
The agreement has been drafted to resolve all claims that either the Deceased (Mr Griffiths) or the Applicant (Mrs
Griffiths) may have against POL. Equally, the agreement also resolves any claims POL has against the Deceased or his
estate, i.e. we will not be able to seek recovery of any outstanding losses in the branch accounts or incurred through
the robbery at the branch. Please let me know if this is not our intention.
You will also note from para 2.1 that Mrs Griffiths has agreed to staged payments, which we asked for as an incentive
to Mrs Griffiths maintaining confidentiality. As drafted, if Mrs Griffiths were to breach confidentiality, we could stop
any further payments but not recoup sums already paid. Please let me know if you would like the agreement to be
amended to give us that right.
In case it assists, our suggestion to stage payments so as to preserve confidentiality was accepted without demur, and
Mrs Griffiths solicitor mentioned that he had been instructed in part because her previous advisors (Howe & Co) had
been very keen to use the tragic facts of this case as the lead case in a group action, which did not sit well with Mrs
Griffiths. To me, this not only demonstrates a commitment by Mrs Griffiths to keeping this matter private and
confidential, but also provides further support for POL settling this case on the agreed terms.
Please let me have your responses on the underlined issues above, and any other comments you may have on the
draft, as soon as possible. Once we are agreed, I will send it over to Mrs Griffiths’ solicitor to finalise. Ideally I would
like to do this tomorrow.
Thank you for your help in wrapping this up, especially you Angela for the hard work you did to get a resolution in
very difficult circumstances.
Rod
Rodric Williams I Litigation Lawyer
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