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From: Mark Underwood
Sent:
To: Parsons, Andrew;
MacLeod: _ GRO
Ce: Lukas, Elisa
Subject: RE: Remote Access Wording
Thanks Andy,
My greatest concern is that we don’t qualify the statement that transaction data can be deleted / changed by
detailing that - although theoretically possible — because the logistical challenges that would need to be overcome
are so huge, it really is not a credible line of enquiry.
I really do think we need to include a qualification which, in some detail, set outs the logistical challenges. Without
this qualification, I think the letter could be quite damaging (particularly if leaked to the Network / Media) as it
provides soundbites that give credibility to an allegation that actually lacks any merit.
If I recall correctly; we are not obligated to respond to Freeths Reply, but we have a desire to do so and before we
receive Particulars on 1 Dec? I think this gives us enough time to apply suitable pressure on Deloittes to provide us
with this information? If they are confident enough to have made statements that this is possible, then presumably
they have the information necessary to be able to detail exactly how it can happen?
Mark
From: Parsons, Andrew
Sent: 20 November 2016 13:17
To: Mark Underwoodi=!Jane MacLeod; Rodric Williams
Cc: Lukas, Elisa; Prime, Amy
Subject: RE: Remote Access Wording
Thanks Mark.
I've updated the attached. Where I agreed with your suggested amendments, I've included them and deleted the
respective comment. In relation to your other questions, I've added my answers to the attached.
A
Andrew Parsons
Partner
Bond Dickinson LLP
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From: Mark Underwood
Sent: 18 November 2016 21:15
To: Parsons, Andrew; Jane MacLeod; Rodric Williams
Cc: Lukas, Elisa; Prime, Amy
Subject: RE: Remote Access Wording
Andy, Jane & Rod,
I have track changed my comments, for your consideration, in the attached version.
Mark
From: Parsons, Andrew
Sent: 18 November 2016 19:25
To: Jane MacLeod; Rodric Williams
Cc: Mark Underwood!-! Lukas, Elisa; Prime, Amy
Subject: Remote Access Wording
Jane, Rodric
As discussed in the con with Tony, please find attached our draft wording on the "remote access" issues. This wording
will be part of a longer letter to Freeths that we hope to circulate next week.
In the attached, we refer to certain information provided by FJ to Post Office about editing transaction data. This
information was by way of an email (attached) that was arguably subject to litigation privilege. By referring to this
information in our letter (i) we may be waiving privilege in that email and (ii) Freeths could push for a collateral waiver
of privilege in other emails from FJ on the same topic.
We have not expressly referred to the email in the letter to minimise this risk. However, my view is that if we do not
explain that Post Office relied on information provided by FJ, Post Office's story is severely weakened and hence
some risk of waiving privilege should be taken.
Happy to discuss this point in more detail. All comments on the attached are welcomed.
Kind regards
Andy
Andrew Parsons
Partner
Bond Dickinson LLP
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