POL00281725
POL00281725
From: Andrew Parsons[é_
Sent: Wed 28/08/2019 3:23:41 PM (UTC)
To: Melanie Corfield[;
Ce: Angela Vi
Tarling[t.
Martine MunbyI
Underwos Drummond,
Subject: RE: GLO - in strictest confidence and subject to legal privilege - collateral [WWBDUK-
AC.FID26896945]
Attachment: Collateral.zip
Mel
I have no comments on documents 4, 8 and 22. My comments on the other documents are attached as track
changes / comment bubbles. They are largely repetition of the same points. I haven't double checked all the dates
and figures but they seem to be in the correct ball-park.
The one repeating message throughout the documents is that Horizon is robust because both experts say so. This is
correct as at today, but if the Judge finds that Horizon is not robust then he will likely have found a reason to side-step
or disavow the expert evidence. In those circumstances then I'm not sure that this comms message will hold water. It
may be worth working up an alternative comms package on the basis that the Judge throws out the expert's views.
Also if the Judge finds that Horizon is bad, will you still be putting out a comms line that is directly contrary to the
Judge's view? I can understand why you might want to put any a counter-measure that Horizon is robust but you
might be criticised for saying that Horizon is fine when the Judge says that it is not. This could then be spun as Post
Office failing to listen. This is a comms point (so feel free to tell me to go away!) but do you need a plan for some
more contrite lines around accepting that Horizon is not robust?
Just my two cents...
A
Andrew Parsons
Partner
Womble Bond Dickinson (UK) LLP
Manage your e-alert preferences
WOMBLE womblebonddickinson.com
‘ BOND (Gn)
DICKINSON Vin)
From: Melanie Corfield
Sent: 28 August 2019
To: Andrew Parson:
Cc: Angela Van-Den-Bogerd <.
Martine Munby <.
>; Drummond, James
in strictest confidence and subject to legal privilege - collateral
Subject: GLO
POL00281725
POL00281725
Hi Andy,
With apologies later than I planned, I attach the folder of comms collateral for a high level legal view please regarding
our positioning and messaging. This is in line with our strategy that in all circumstances we must, overall, be
confident about the system.
Please give me a ring if you want to discuss.
Document 6 (questions and answers) is one still very much in development as we are still working through more
detail which will go into some of the answers, particularly on technical matters re Horizon itself — and we will need
your help as previously discussed about engaging with Fujitsu legal team at a sensible point.
Many thanks
Mel Corfield
Communications Team
Mobil ~
FIO SI SISI CII SISIOI SII SI GICICICI SI SICIGICICI I SICICICI I ICICI IR aI C31 1 I a8 CCF oR aR ICA RoR CACAO oR aR ACCS RoR aR CAC
This email and any attachments are confidential and intended for the addressee only. If you are not the named
recipient, you must not use, disclose, reproduce, copy or distribute the contents of this communication. If you
have received this in error, please contact the sender by reply email and then delete this email from your
system. Any views or opinions expressed within this email are solely those of the sender, unless otherwise
specifically stated.
POST OFFICE LIMITED is registered in England and Wales no 2154540. Registered Office: Finsbury Dials,
20 Finsbury Street, London EC2Y 9AQ.
1 AR RR RR 8 8 Ag A RR 2 RR IR A AR oR 0 RR RR AS oo RR RR RR oA oo oR SR RR Ro oo og oR SR OR oO
“Post Office Limited is committed to protecting your privacy. Information about how we do this can be found
on our website at www.postoffice.co.uk/privacy”
Please consider the environment! Do you need to print this email?
The information in this e-mail
to access this e-mail and any attachments. If you are not
copies. Unauthorised use, dissemination, distribution, publi
use personal d
any attachments is confidential and may be I
la.van-den-bogerd,
tion or copying of
rd nly is authorised
Soon as possible and delete any
inlawful. Information about how we
and protected by law. angela.van-den-bo
please notify andrew. parsons
jon or attachments is prohibited a
a is in our Privacy Policy on our website.
<i to this e-mail will have been checked by us with virus detection software before transmission, Womble Bond Dickinson (UK) LLP accepts no liability for any
which may be caused by software viruses and you should carry out your own virus checks before opening any attachment.
Content of this email which does not relate to the official business of Womble Bond Dickinson (UK) LLP, is neither given nor endorsed by it.
This email is sent by Womble Bond Dickinson (UK) LLP whieh is
is 4 More London Riverside, London, SE1 2AU, where a list of n
or consultant who is of equivalent standing. Our VAT reg
limited liability partnershi
mbers’ names is
-gistered in England and Wales under number OC317661. Our registered office
n to inspection, We use the term partner to refer to a member of the LLP, or an employee
tration number is GB 12
Womble Bond Dickinson (UK) LLP is a member of Womble Bond Dickinson (International) Limited, wh
services in the US, the UK, and elsewhere around the world. Each Womble Bond Dickinson entity is a se
can bind or obligate, another Womble Bond Dickinson entity
www. womblebonddickinson.comv/legal notices for further details.
sists of independent and autonomous law firms providing
entity and is not responsible for the acts or omissions of, nor
‘omble Bond Dickinson (International) Limited does not practice law. Please see
Womble Bond Dickinson (UK) LLP is authorised and reg
lated by the Solicitors Regulation Authority