WBON0000439 - Email from Andrew Parsons to Amy Prime and Johnathon Gribben RE:

Evidence on official site

WBONO0000439
WBON0000439

From: "Parsons, Andrew" { GRO. i
To: Anthony de Garr Robinson

Ce: "Prime, Amy" {” GRO_

i GRO ]

"Gribben, Jonathan"

Subject: RE: Remote Access [BD-4A.FID26859284]
Date: Thu, 21 Jul 2016 09:24:18 +0100
Importance: Normal

Ok. Speak later (that's if you can speak at all!). A

Andrew Parsons
Partner

Bond Dickinson LLP
Tel:

From: Anthony de Garr Robinson
Sent: 21/07/2016 08:33

To: Parsons, Andrew

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

Thanks, Andy.

a GRO.
it looks like welll be speaking at 12.

ut should be back by 10am. So

Tony

-----Original Message-—---

From: Parsons, Andrew [mailto
Sent: 21 July 2016 07:58
To: Anthony de Garr Robi
Ce: Prime, Amy 7 : Gribben, Jonathan {
Subject: RE: Remote Access [BD-4A.FID26859284]

Tony
Fair enough.

Please find attached a re-worked version of the language - now more directly and transparently explaining how Post Office can
change branch accounts.

This re-draft draws a clearer distinction between:

1. The factual allegation that Post Office has been changing branch accounts and that this is the true reason for the shortfalls in
branches.

2. The allegation that Post Office concealed its capabilities in this regard - which, at the moment, only goes to the limitation point.

The second is the more difficult point to address. First, it is not yet 100% clear that the Super User access does affect branch
accounting, though this seems very likely. Second, the reason that Post Office made incorrect statements is that it relied on
confirmations from FJ (see attached email as an example). At some point, we may well wish to disclose the attached email in
order to show that Post Office did not "deliberately" mislead the Claimants. This will however need to be carefully managed with
Fujitsu. From a tactical perspective, this may be better done once Freeths have more accurately stated their case on concealment.

~}- would you be available

for a call at 9:30? If not, would 12 noon work?

WBD_000309.000001
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Kind regards
‘Andy

Andrew Parsons
Partner

Direct: f i
Mobile} GRO H

Follow Bond Dickinson:

From: Anthony de Garr Robinson [mailto:
Sent: 20 July 2016 20:55

To: Parsons, Andrew

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

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
L 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 assume 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 {77 SRO
wrote:

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

WBD_000309.000002
WBONO0000439
WBON0000439

Andrew Parsons

Partner

Direct:

Mobile:

Follow Bond Dickinson:

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

-----Original Message-—---
From: Anthony de Garr Robinson [mailto‘
Sent: 20 July 2016 19:47

To: Parsons, Andrew

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

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

fone nnn -

{ GRO

_.P>> wrote:

Push on - I'll sort out the fees.

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

Andrew Parsons

Partner

WBD_000309.000003
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From: Anthony de Garr Robinson [mailto’

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 [mailto:f GRO: a

Sent: 20 July 2016 19:05

To: Anthony de Garr Robinson

com%3cmailtos

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

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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. It is 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.

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

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