POL00248962
POL00248962
From: Thomas P Moran{”
Sent: Mon 08/05/2017 7:35:35 AM (UTC)
To: Prime, Amy! GRO
Ce: Mark Uni Parsons,
Andrew[i__
Subject: RE: Bates & Others -
4A.F1D26940628]
Post Office Limited - Claim No: HQ16X01238 GLO Advertising [BD-
Amy
I can confirm that we have made George Thomson at NFSP aware, and the response should be as advised to re-direct
Freeths to NFSP directly as we have no control over the publication.
Regards
Tom
From: Prime, Am
Sent: 08 May 2017 08:32
To: Thomas P Moran <f
Cc: Mark Underwood:
Rodric Williams <.
ak>; Parsons, Andrew
Subject: RE: Bates & Others -v- Post Office Limited - Claim No: HQ16X01238 GLO Advertising [BD-4A.FID26940628]
Tom, Rodric
Please find attached a further letter we have received from Freeths on the subject of advertising. They are seeking
consent to advertise in three local newspapers (the Oxford Times, the Hampshire Observer and the Western Mail). As
such, we have slightly amended our response to Freeths (attached).
Tom — please could you confirm whether Nick Beal or yourself have spoken with George (NFSP)?
Rodric — please could you confirm that you are happy for Freeths to place notices within these newspapers.
Kind regards
Amy
Amy Prime
Solicitor
Bond Dickinson LLP
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LEGAL ADVISER
From: Prime, Amy
Sent: 04 May 2017 12:43
To: Thomas P Moran; Rodric Williams
Cc: Mark Underwood: si Parsons, Andrew
POL00248962
POL00248962
Subject: RE: Bates & Others -v- Post Office Limited - Claim No: HQ16X01238 GLO Advertising [BD-4A.FID26896945]
Tom
Please find attached our proposed response to Freeths. Please could you confirm once Nick Beal or yourself have
spoken with George (NFSP) and we will then send this.
Kind regards
Amy
From: Parsons, Andrew
Sent: 02 May 2017 13:44
To: Thomas P Moran; Rodric Williams
Subject: RE: Bates & Others -v- Post Office Limited - Claim No: HQ16X01238 GLO Advertising [BD-4A.FID26896945]
Agreed on the response.
A call with George is better than an email — no audit trail to disclose.
Thanks
Andy
Andrew Parsons
Partner
Bond Dickinson LLP
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2016-17
OVERALL BEST
LEGAL ADVISER
From: Thomas P Moran:
Sent: 02 May 2017 13:39
To: Parsons, Andrew; Rodric Williams
Cc: Mark Underwood: Prime, Amy
Subject: RE: Bates & Others -v- Post Office Limited - Claim No: HQ16X01238 GLO Advertising [BD-4A.FID26896945]
Thanks, noted. Nick Beal will be speaking to George on a planned call later today so will note this to him. He’s
absolutely confirmed that the magazine is entirely NFSP so our letter should simply make that clear and re-direct
them.
Cheers
Tom
From: Parsons, Andrew’
Sent: 02 May 2017 10:0
To: Thomas P Moran Rodric Williams
Ce: Mark Underwood Prime, Amy ¢
Subject: RE: Bates & Others -v- Post Office Limited - Claim No: HQ16X01238 GLO Advertising [BD-4A.FID26896945]
Tom — be careful about emailing George. Your email may not be privileged. Keep it neutral.
A
Andrew Parsons
Partner
Bond Dickinson LLP.
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From: Thomas P Moran {
Sent: 02 May 2017 09:47
To: Parsons, Andrew; Rodric Williams
Cc: Mark Underwoog Prime, Amy
Subject: RE: Bates & Others -v- Post Office Limited - Claim No: HQ16X01238 GLO Advertising [BD-4A.FID26896945]
Thanks. George is very negative about Freeths’s approach and I do not think will accept this in his publication. It is not
our decision.
For the avoidance of doubt, we have no direct control over the magazine which is edited independently by the NFSP.
So the obvious approach would be to inform them of that and redirect them to contact the NFSP direct. In the
meantime I would inform George of the position by forwarding the letter, which I’ll do now.
Nick — please can you confirm the position re the magazine?
I propose you draft a reply on that basis, Andy.
Thanks
Tom
From: Parsons, Andrew‘. GRO i
Sent: 02 May 2017 09:08
To: Thomas P Moran ¢_
Cc: Mark Underwood"
Subject: RE: Bates & Others -v- Post Office Limited - Claim No
Rodric Williams
Prime, Amy
(Q16X01238 GLO Advertising [BD-4A.FID26896945]
Tom, Rodric
May we have call to discuss the below? I'd like to get your thoughts on the NFSP angle.
I can do any time today (save for 14:30 to 16:30) and any time on Thursday. Let me know when is best for you.
Kind regards
Andy
Andrew Parsons
Partner
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POL00248962
Bond Dickinson LLP
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From: Parsons, Andrew
Sent: 27 April 2017 18:17
To: ‘Thomas P Moran’
Cc: Mark Underwood - C “~} Prime, Amy
Subject: FW: Bates & Others -v- Post Office Limited - Claim No: HQ16X01238 GLO Advertising [BD-4A.FID26896945]
Tom, Rodric
Please see attached a letter from Freeths re advertising the GLO. Most of this is just process points which we will deal
with in due course, however in the penultimate para they ask for POL's consent to place an advert in Subpostmaster
Magazine.
This raises an interesting opportunity. From POL's perspective, it is difficult for it to object to this advert. The
Subpostmaster Magazine is an obvious conduit through which to raise awareness of the GLO and a Court would look
dimly on POL trying to block this. However, the magazine is not, as I understand it, under POL's control; control rests
with the NFSP who are free to take whatever stance they like.
Are the NFSP still generally supportive of POL and Horizon? If so, it would be quite a powerful message if Freeths
approached the NFSP and the NFSP refused to allow the advert on the grounds that they thought the litigation was
meritless. This type of message would have to reported up to Freeths' insurers and funders, and it would perhaps
knock their confidence if a key "Union" was standing by POL rather than the Claimants.
Thoughts?
Andy
From: Imogen Randall
POL00248962
POL00248962
Sent: 27 April 2017 17:52
To: Parsons, Andrew; Prime, Amy
Cc: Lisa Bennett; Fenner, Kizzie; Lukas, Elisa; James Hartley
Subject: Bates & Others -v- Post Office Limited - Claim No: HQ16X01238 GLO Advertising
All
See attached.
Freeths LLP
Imogen Randall
Associate
Dispute Resolution
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