POL00249553
POL00249553
From: Parsons, Andrew‘,
Sent: Wed 28/06/2017 7:30:03 PM (UTC)
To: Rodric William:
Ce:
Subject: Draft Defence
Attachment: Protocol for Second Sight 14 06 17 (CsI suggested amends)-1.docx
Attachment: 100 Bates draft Defence.docx
Rodric, Mark
Please find attached the draft defence from Tony.
There are lots of minor points chase down - many of which are already with Kath / Shirley and FJ.
The key ones that would be good to discuss tomorrow are:
1. Paras 28, 35 and 55 - these relate to the process for disputing shortfalls. We're struggling to get to the bottom
of those processes and how those disputes are resolved.
2. Para 50(2) - do we say that POL previously relied on incorrect statements from FJ in relation to remote
access? This is basically dropping FJ in it.
The other points I have on my mini agenda for tomorrow are:
1. Prep needed for the GE meeting.
2. Comms lines around the defence and addition of more claimants.
3. Second Sight protocol. We've had a proposal (attached) from Freeths that I can explain tomorrow.
4. Debt team protocol - next steps.
Kind regards
Andy
Andrew Parsons
Partner
Bond Dickinson LLP
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