WBON0000438 - Email from Anthony de Gar Robinson to Andrew Parsons CC: Amy Prime and Johnathon Gribben RE: Remote Access [BD-4A.FID26859284]

Evidence on official site

WBON0000438
WBON0000438

From: Anthony de Garr Robinson {"
arsons, Andrew" {7
rime, Amy" + _. GRO
L GRO =
Subject: Re: Remote Access [BD-4A.FID26859284]
Date: Wed, 20 Jul 2016 19:54:33 +0000
Importance: Normal

, "Gribben, Jonathan"

Dear Andy,

I've had a quick look at the drafting and I don't think it will wash. First of all, we appear to have ignored the second route by which I
understand it is possible for data to be altered remotely - the one that involves PO and has happened only once since 2010.

Second, we boldly say that they haven't given proper particulars of our concealment of the remote data alteration facility, but for years
virtually every document we submitted positively said that data could not be altered remotely. We need to say something that at least
provides a basis for explaining how we came to do this, even if we can't bring ourselves actually to acknowledge that we have made
false statements in the past and to explain why.

We must me that this letter is going to be pored over for many hours at trial, at which time the court will know everything.
Attempting to brush this under the carpet to avoid short term embarrassment would do profound damage to our long term credibility.
In my view it would be the worst possible thing to do. It really is the case that in many cases cover ups give a much worse impression
and are much more serious than the things sought to be covered up (in this case, our previous inconsistent statements).

It may well be that I have got the wrong end of the stick, but this drafting makes me very nervous indeed.
Talk tomorrow?
Tony

Sent from my iPhone

On 20 Jul 2016, at 20:06, Parsons, Andrew f GRO.
wrote:

GRO

Tony

Please find attached the latest version of the letter — this hasn't materially changed since your amendments. I've highlighted in Blue in
the attached letter where these two sections on remote access will be fit in — see pages 22 and 45.

Kind regards

Andy

Andrew Parsons

Partner

WBD_000308.000001
Follow Bond Dickinson:

www. bonddickinson.com<http://www.bonddickinson.com>

-----Original Message-----

From: Anthony de Garr Robinson [mailtof
Sent: 20 July 2016 19:47

To: Parsons, Andrew

Ce: Prime, Amy; Gribben, Jonathan
Subject: Re: Remote Access [BD-4A.FID26859284]

WBON0000438
WBON0000438

Ok. I see it's only a small section anyway. Could you send me the longer version you've taken it from? I don't want to read and review

it, I just want to get the context clear in my head

Sent from my iPhone

On 20 Jul 2016, at 19:42, Parsons, Andrew f~

ay

‘mailtof

‘GRO

wrote:

Push on —T'll sort out the fees.

Post Office loved our letter so we're in credit!

>

Andrew Parsons
Partner

<image001jpg><http://www.bondickinson.cony>

Direct:

Mobile:

Follow Bond Dickinson:

WBD_000308.000002
WBON0000438
WBON0000438

<image002.jpg><https://twitter,com/Bond_Dickinson><image003.jpg><http:/www linkedin,com/company/3098928?trk=tyah>

www.bonddickinson.com<http://www.bonddickinson.com/>>

From: Anthony de Garr Robinson [mailtof”

Sent: 20 July 2016 19:16

To: Parsons, Andrew

Ce: Prime, Amy; Gribben, Jonathan

Subject: RE: Remote Access [BD-4A.FID26859284]

Dear Andy,

I'm more or less at my budget limit. What do I do?

Best wishes,

Tony

From: Parsons, Andrew [mailtof~” Ro" a

Sent: 20 July 2016 19:05

To: Anthony de Garr Robinson {

‘>; Gribben, Jonathan

‘Emailtor

Subject: Remote Access [BD-4A.FID26859284]

Tony,
Would you mind reviewing the attached wording on the remote access issues?
Having reviewed the Letter of Claim, the remote access point is only specifically raised in relation to limitation / s.32 concealment,

Itis not cited as a ground for (i) deceit or (ii) unwinding the settlement agreements — although it could in due course be used for these
purposes.

WBD_000308.000003
WBON0000438
WBON0000438

We have expressly referred to balancing transactions and Super User access in the attached, without drawing specific attention to
them. Is this transparent enough or should we go further?

Kind regards

Andy

Andrew Parsons
Partner

<image001,jpg><http://www.bondickinson.com/>

GRO

Direct:

Mobile:

Follow Bond Dickinson:

<image002.jpg><https://twitter.com/Bond_Dickinson><image003,jpg><http://www.linkedin,com/company/3098928?trk=tyah>

www. bonddickinson.com<http://www.bonddickinson.com/>>

Please consider the environment! Do you need to print this email?

The information in this e-mail and any attachments is confidential and may be legally privileged and protected by law.
arobinsof GRO. Kmailto! GRO + only is authorised to access this e-mail and any attachments. If you are
not arobinson GRO mailto} GRO ..please notify

andrew.parsons} GRO. Emailiof ‘GRO as soon as possible and delete any copies.

Unauthorised use, dissemination, distribution, publication or copying of this communication or attachments is prohibited and may be
unlawful.

Any files attached to this e-mail will have been checked by us with virus detection software before transmission. Bond Dickinson LLP

accepts no liability for any loss or damage 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 Bond Dickinson LLP, is neither given nor endorsed by it.

This email is sent by Bond Dickinson LLP which is a limited liability partnership registered in England and Wales under number

WBD_000308.000004
WBON0000438
WBON0000438

0C317661, Our registered office is 4 More London Riverside, London, SE1 2AU, where a list of members’ names is open to
inspection, We use the term partner to refer to a member of the LLP, or an employee or consultant who is of equivalent standing, Our
VAT registration number is GB123393627.

Bond Dickinson LLP is authorised and regulated by the Solicitors Regulation Authority,

This email has been scanned by the Symantec Email Security.cloud service.

For more information please visit http://www.symanteccloud.com

This email has been scanned by the Symantec Email Security.cloud service.

For more information please visit http://www.symanteccloud.com

This email has been scanned by the Symantec Email Security.cloud service.

For more information please visit http://www.symanteccloud.com

This email has been scanned by the Symantec Email Security.cloud service.

For more information please visit http://www.symanteccloud.com

This email has been scanned by the Symantec Email Security.cloud service.
For more information please visit http://www.symanteccloud.com

<_DOC_33380020(1)_DRAFT Letter of Response 16 July 2016.docx>

This email has been scanned by the Symantec Email Security.cloud service.
For more information please visit http://www.symanteccloud.com

WBD_000308.000005