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From: Mark Underwood!
I, Veronica Branton
chard
Subject: RE: Litigation and Appointment - next steps
Date: Wed, 21 Mar 2018 17:35:19 +0000
Importance: Normal
Inline-Images: image001.png; image002.png
Hi Jane — the agenda looks good to me. Di is setting up the call on Friday, and I think Rod is looking at the
template from UKGI.
Though strictly speaking a separate matter, the only other agenda item to consider including or reference
when speaking is the CCRC?
Mark
° Mark Underwood
Head of Portfolio: Legal, Risk & Governance
Ground Floor
20 Finsbury Street
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From: Jane MacLeod
Ce: Patrick Bourke {
rc GRO - Ir
Blanchard ¢ GRO I
Subject: FW: Litigation and Appointment - next steps
(Veronica — for awareness re Monday committee meeting; Di — for awareness re setting up a possible call on
Friday)
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All
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I am being chased by UKGI for our views on this — can I have your thoughts? We have the first Board sub-
committee meeting on Monday and I would like to flag this to them?
Also, we need to work up an agenda for that sub-committee meeting. So far my suggestions would be:
e =ToR
¢ Litigation timetable & suggested dates for future meetings
e Update on developments since January board meeting:
o Scope of disclosure
o Scope of Horizon hearing
o Appointment of IT expert
o Application for security for costs
e Engagement with UKGI
e Contingency planning
e AOB
Anything else — we only have an hour? Could we have a call on Friday to discuss?
Thanks
Jane
@ Jane MacLeod
Group Director of Legal, Risk & Governance
Ground Floor
20 Finsbury Street
LONDON
EC2Y 9AQ
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From: O'Neill, Elizabeth - UKGI [mailt
Sent: 01 March 2018 15:
To: Patrick Bourke!
b
.j Rodric Williams
lard, Richard - UKGI <.
+ Lambert, Helen - UKG:
xt steps
Patrick, Helen,
Thank you for your time last week.
As discussed, I attach a standard form litigation protocol along the lines of what we would propose to submit
to the Permanent Secretary. As you will see, this sets out various touchpoints in the litigation process, and
the steps we intend to take to ensure the Permanent Secretary remains fully informed at each salient point.
If you are able to provide more detail on the litigation timetable, or indeed if you have any comments or
suggestions, we would be happy to amend the protocol bespoke to the current litigation.
Separately I’d be grateful, as I indicated in my email to Helen on Monday, if in anticipation of Tom Cooper’s
appointment, you could let me know if you intend to agree an NDA similar to the one you have with
Richard, and if so, forward me the proposed text so that Tom and I may consider.
Kind regards,
Elizabeth
From: Patrick Bourke [mailt
Sent: 23 February 2018 15
To: O'Neill, Elizabeth - UKG
jams
Callard, Richard - UKGI
Subject: Litigation Meeting
Dear Elizabeth
It was a pleasure to meet with you this morning.
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I just wanted to confirm that we have understood the need for an appropriately structured information flow in
relation to the matters we discussed earlier, and agree that some form of protocol to govern those
arrangements makes very good sense.
While recognising that there is no set format in this regard, it would nonetheless be helpful for us to draw
inspiration from similar arrangements you have put in place with other ALBs. You kindly offered to share
something with us for that purpose.
We will come back to you with our take on how this might work best in our case, having regard to the
particularities of our governance arrangements and the litigation itself.
In the meantime, do please feel free to get in touch if there is anything you'd like to discuss.
Kind regards
Patrick
° Patrick Bourke
Corporate Affairs Director
1t Floor
20 Finsbury Street
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