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From: Anthony de Garr Robinso1
To: ‘Andrew Parson: .
I, Owain Draper
- I, Elisa Lukas
} Jonathan Gribben
‘GRO
Subject: RE: The Post Office Group Litigation - Claim Numbers HQ16X01238 and
HQ17X012637 [BD-4A.FID26896945] - Inspection of Known Error Logs
Date: Thu, 14 Sep 2017 10:08:14 +0000
Importance: Normal
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Thanks for sending the 13 October 2016 letter, Amy.
I’m a little concerned that we may be playing into their hands by provoking a CPR 31.14 application for inspection of
the KEL. Unless we play our cards right, this could give them the chance to portray us as unnecessarily (and therefore
suspiciously) defensive, obstructive and possibly even evasive about the KEL.
Could you also send over our letter dated 1 September 2017 — if their summary of it is fair (which I doubt) I would like
to understand why we seem to have claimed that the KEL is not a document, when it plainly is, and why we don't seem
to have mentioned that it is not in our control, which seems to me to be a critical point.
On the question of control, we need to be absolutely clear that we have no right to inspect or take copies of the KEL,
either under the Fujitsu contract or under the law of agency (is Fujitsu holding it as our agent?), and that there is no
practice under which we are habitually or usually allowed to inspect documents of this sort if we want to see them.
Best wishes,
Tony
From: Andrew Parsons [mailto:¢
Sent: 14 September 2017 08:08
To: Anthony de Garr Robinson
Cc: Amy Primef ~
Gribben/ GRO” ~ ~~
Subject: FW: The Post Office Group Litigation - Claim Numbers HQ16X01238 and HQ17X012637 [BD-
4A.FID26896945] - Inspection of Known Error Logs
Tony, Owain
See attached - One more issue to discuss at today's con.
Mini agenda:
1. Current thinking on directions (look at Owain's draft Order)
2. Terminal preservation and inspection of KEL (as per attached).
3. Plan of action to CMC.
4. Content of witness evidence and skeleton
5. Deloitte work — what next?
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Andrew Parsons
Partner
Bond Dickinson LLP
naviei GRO
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From: Megan Atack [mailt:
Sent: 13 September 2017 18:
To: Elisa Lukas; Amy Prime; Andrew Parsons; Peter O'Connell
Cc: James Hartley; Imogen Randall; Miranda Bond
Subject: RE: The Post Office Group Litigation - Claim Numbers HQ16X01238 and HQ17X012637 [BD-
4A.FID26896945] - Inspection of Known Error Logs
Dear Sirs
Please find attached our firm’s third letter of today’s date.
Yours faithfully
Freeths LLP
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Freeths LLP, Floor 3, 100 Wellington Street, Leeds, LS1 4LT
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