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From: Andrew Parsons <
To: Thomas P Moran I G RO
Ce: Amy Prime <.
:, Rodric Williams
GRO.
Subject: RE: PLSG meeting on Wednesday 24 May 2017 @12 in Tonbridge (1.11)
Date: Thu, 13 Jul 2017 09:07:17 +0000
Importance: Normal
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Tom
Thanks for the comments. I've set out below a few explanations for the approach taken on some of your comments.
We've (including Rodric — cc'd) taken an intentional decision to refer to Crown branches rather than Directly Managed
branches because this mirrors the wording in the GPOC. We considered trying to change terminology but decided it
could become confusing if we refer to DMBs through the litigation and Freeths refer to Crowns. A judge would just get
irritated by this and would likely end up using "Crown" because its shorter to say! I appreciate that this is not the
currently used Post Office terminology but we believe this is the best approach. Hope that's ok?
The word "embarrassing" has a particular legal meaning in Defences. It's a signal to the Judge that a bit of the Claim
has been very poorly written to cover up for the fact that the Claimants don't believe it to be true.
The word "typically" has been used to mirror the language in the GPOC. In a normal defence, you would never say
"typically" something happens, but give a definitive view on the subject. Due to the generic nature of the Defence that
definitive approach would create hostages to fortune so we've used "typically" to soften certain points. This is the
same word used by the Claimants and so by using their language we cannot be criticised.
At a number of points you ask whether we can positively frame the case. Although I understand why you would want
to do this, it would then create an evidential burden on Post Office to prove that positive case. For example., if we say
that people were instructed to behave honestly, we would then need to adduce evidence of those instructions (which
may mean trawling through thousands of documents and producing witness statements for dozens of people). If we
say that people were not instructed to behave dishonestly, then the absence of any evidence proves our point and it is
Freeths that need to find the evidence to support their allegation.
Kind regards
Andy
Andrew Parsons
Partner
Bond Dickinson LLP
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Fed okt rhare —> CARLYLE
From: Thomas P Moran [mailto:
Sent: 13 July 2017 00:08
To: Andrew Parsons
Cc: Amy Prime
Subject: RE: PLSG meeting on Wednesday 24 May 2017 @12 in Tonbridge (1.11)
Andy and Amy
I’ve gone through the draft (and their doc). Here are my (very minor) comments.
Thanks
Tom
From: Andrew Parsons [mailto} GRO “y
Sent: 12 July 2017 14:49
To: Mark Underwood! < GRO. >; Jane MacLeod
_ ; Angela Van-Den-Bogerd < GRO ig
Mark R Davies < ; Stuart Nesbit <j_~ >; Patrick
Bourke Houghton <j ; Rodric
William: GRO ls Thomas P #; Tom
Wechsler 5 Mark Ellis “>; Melanie Corfield
{ GRO i
Ce: Kevin Morgan 4 GRO >; Amy Prime GRO. P
Subject: RE: PLSG meeting on Wednesday 24 May 2017 @12 in Tonbridge (1.11)
All
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Please find attached the draft Defence for your review and comment. As discussed earlier, if possible please provide
comments rather than amendments to the actual text. I've also attached the Claimants’ Generic Particulars of Claim
for reference.
You'll see a few points where input from Deloitte and Fujitsu is needed — we expect to get this today.
Please send any comments to me and Amy Prime (copied).
Thanks
Andy
Andrew Parsons
Partner
Bond Dickinson LLP
www.bonddickinson.com
A new-breed of Cond Diclaagen
transatlantic law firm
Fite ott more , CARLYLE
WOMBLE
From: Mark Underwood! [mailto} GRO ]
Sent: 12 July 2017 14:40
To: Jane MacLeod; Angela Van-Den-Bogerd; Mark R Davies; Stuart Nesbit; Patrick Bourke; Rob Houghton; Rodric
Williams; Thomas P Moran; Tom Wechsler; Andrew Parsons; Mark Ellis; Melanie Corfield
Ce: Kevin Morgan
Subject: RE: PLSG meeting on Wednesday 24 May 2017 @12 in Tonbridge (1.11)
Dear all, please find attached the open action list, which includes those taken today.
T have highlighted in yellow those that require people’s imminent attention.
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Many thanks
Mark
° Mark Underwood
Head of Portfolio: Legal, Risk & Governance
Ground Floor
20 Finsbury Street
2017 Winner of the 1°70" £°7 942
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From: Mark Underwood!
Sent: 11 July 2017 13:46
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To: Jane MacLeod; Angela Van-Den-Bogerd; Mark R Davies; Stuart Nesbit; Patrick Bourke; Rob Houghton;
Rodric Williams; Thomas P Moran; Tom Wechsler; 'Parsons, Andrew’; Mark Ellis; Melanie Corfield
Ce: Kevin Morgan
Subject: RE: PLSG meeting on Wednesday 24 May 2017 @12 in Tonbridge (1.11)
Dear all, further to my note earlier today, please find attached the final Decision Paper.
Mark
* Mark Underwood
Head of Portfolio: Legal, Risk & Governance
Ground Floor
20 Finsbury Street
2017 Winner of the ‘707 &°Y 940
Global Postal
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Experience
From: Mark Underwood!
Sent: 11 July 2017 09:30
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To: Jane MacLeod; Angela Van-Den-Bogerd; Mark R Davies; Stuart Nesbit; Patrick Bourke; Rob Houghton;
Rodric Williams; Thomas P Moran; Tom Wechsler; 'Parsons, Andrew'; Mark Ellis; Melanie Corfield
Ce: Kevin Morgan
Subject: PLSG meeting on Wednesday 24 May 2017 @12 in Tonbridge (1.11)
Dear all,
We have a PLSG meeting on Wednesday 12 July @12 in Tonbridge (1.11). Ahead of that meeting please
find attached:
The Agenda
Decision Paper: Access to Second Sight
Decision Paper: Standstill Agreement with Fujitsu
Decision Paper: Communications Strategy
Decision Paper: Wider Risks to POL [To follow later today]
Open actions list as at 11 July 2017
Please let me know if you are intending to dial in.
Many thanks, and apologies for the delay in circulating these papers.
Mark
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° Mark Underwood
Head of Portfolio: Legal, Risk & Governance
Ground Floor
20 Finsbury Street
2017 Winner of the ‘°7¢" £°7Y 942
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Customer Mobile numbers oH GRO 1
Experience
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