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From: Thomas P Moran
Sent: 4 AM (UTC)
To: Parsons,
Jane MacLeor
Mark
Patrick
Ce: 7 “; Lukas, Elisa‘ 3
Subject: RE: Letter to Freeths - legally privileged [BD-4A.FID26896945]
Attachment: _DOC_34430591(1)_ Response to Letter of Reply_ 27 November 2016 TPM.docx
Dear All
I have now reviewed this and made some suggestions in the attached. Apologies for not having been able to make the
call on Friday.
My overall conclusion is that could very well have serious implications on the proceedings and we absolutely have to
make sure we are briefing and securing the support of the right people internally before issuing.
As I’m the lucky man with the responsibility for this as the SG chair, I must ask that we get this properly reviewed by
Mark Davies and also Angela who I don’t think are on this list. In particular we need a full assessment and media plan
based on the worst case consequences in place before sending.
am in tomorrow so available to discuss this. I’m not sure of the exact deadlines for submission (which at present, to
me are secondary to the briefing and planning we need to have in place first).
Thanks a lot
Tom
From: Rob Houghton
Sent: 27 November 2016 22:22
To: Parsons, Andrew; Jane MacLeod; Rodric Williams; Mark Underwood1; Patrick Bourke; Thomas P Moran
Cc: Prime, Amy; Lukas, Elisa
Subject: RE: Letter to Freeths - legally privileged [BD-4A.FID26896945]
I personally think we overdo the response on access and I’ve suggested some changes. As usual —I am relatively new
to all this but I would reduce down the sentiment and explain it once. Im on leave tomorrow; daughters 21° birthday
(I know I know —I was very young ;-)) — lm ona train back to London at 5pm so would be inappropriate to join a call
but can catch up on emails (or text me if required).
R
From: Parsons, Andrew I
Sent: 27 November 2016 09:
To: Jane MacLeod; Rodric Williams; Mark Underwood1; Patrick Bourke; Rob Houghton; Thomas P Moran
Cc: Prime, Amy; Lukas, Elisa
Subject: Letter to Freeths - legally privileged [BD-4A.FID26896945]
All
Please find attached a draft Letter to Freeths in response to their last substantive letter (copy also attached). This
incorporates comments from Tony and Rod.
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The majority of this letter addresses legal and procedural points. The key substantive area is section 9 on Remote
Access (in particular, Rob, I'd be really grateful if you could review this section).
Following feedback from Deloitte, we cannot definitively say that PO (as distinct from FJ) never had the ability to
change Horizon data because Deloitte and the current staff at FU just don't have enough knowledge of Old Horizon to
confirm this. This was a point made in an early draft but it has now been removed.
We have (I hope) now found a formulation of words that avoids having to overtly throw FJ to the wolves and avoids
any risk of waiving privilege in any documents, but still gives us a fair story to tell. We have also toned down the
admissions of making incorrect statements, though they are still there. I hope this might make it easier to get this
letter cleared through GE and Fu.
We have a call scheduled for 5pm tomorrow with Tony which we can use to run through any comments. Comments
by email before then are also welcomed.
The final version of the letter will be thoroughly proof read before sending so please ignore any typos.
Kind regards
Andy
Andrew Parsons
Partner
Bond Dickinson LLP
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