WBON0000320 - Email from Amy Prime to Andrew Parsons, Cc’s Lucy Bremner and Jonathan Gribben Re: Post Office Group Litigation: HIT - Disclosure of Audit Reports [WBDUK-AC.FID26896945]

Evidence on official site

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From: Amy Prime
To: Andrew Parsons

_}, Jonathan Gribben

Subject: FW: Post Office Group Litigation: HIT - Disclosure of Audit Reports [WBDUK-
AC.FID26896945]

Date: Wed, 13 Mar 2019 18:44:14 +0000
Importance: Normal
Attachments: Letter_to_WBD_-_Audit_Reports.pdf;
_LETTER_154771370(1)_Freeths_13_Mar_19__Disclosure_of_Audit_Reports.docx
Inline-Images: image001.png; image4e570a.PNG; imaged499b5.PNG; imagec65 1c6.PNG;
imageda3ccc.PNG; image24d044.PNG; imagedf69bd.PNG

Andy

Sorry this is my mistake — I completely forgot to phone Rod about the RMG audit reports.

Attached is a draft letter to Freeths. My plan (which needs some help from Rod is):

« Rod calls RMG legal and confirms that they won't give disclosure of the documents. If so, Rod warns them

that we are going to jointly ask with the Claimants that the Judge makes an order for third party disclosure.
The order should be limited to pre-2011 annual audit reports of Horizon produced by Ernst & Young, which
they are able to locate under a reasonable and proportionate search. It would be helpful if RMG could confirm
how long it would take them to find the documents.

« We need to work out how to deal with the costs of the third party disclsoure — I think they should be borne by
the Cs, but not sure if the joint approach to the judge causes an issue with this.

e Once this has been set up we can then send the attached letter to Freeths.
Sorry and let me know if you want me to phone Rod.

Thanks
A

Amy Prime
Solicitor
Womble Bond Dickinson (UK) LLP

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From: Angélique Richardson [mailto:
Sent: 13 March 2019 13:45
To: Andrew Parsons; Amy Prime; Emma Campbell-Danesh; Victoria Brooks; Jonathan Gribben; Michael Wharton; Anna

WBD_000190.000001
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Martin; Dave Panaech; Lucy Bremner; Beth Hooper; Katie Simmonds; Sushma MacGeoch; Rachel Lawrie; Jane

Atkinson; Charlie Temperley
Cc: James Hartley; Imogen Randall; Dean Hill; Stephanie Jameson; Chloe Oram; Nicola Pettit; Francesca See; Miranda

Bond; Angélique Richardson
Subject: Post Office Group Litigation: HIT - Disclosure of Audit Reports

Dear Sirs,
Please see attached correspondence.

Yours faithfully,
Freeths LLP

Angélique Richardson
inI Freeths LLP

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