Subject:
From: Victoria Brooks I G RO
To: Andrew Parsons;
Importance: Normal
Attachments:
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Angela statement - implied terms [WBDUK-AC.FID26896945]
Date: Tue, 24 Jul 2018 11:12:29 +0000
_DISPUTERESOLUTION_150892375(2) Witness_Statement_of_Angela_Van_Den_Bo
_DOC_150432261(13)_List_of_witnesses_and_issues_to_be_covered_20_Jul_18.nrl
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Hi Andy
Here is a version of AVDB's statement for your input on the implied terms section. See first link attached.
See paras 212 — 245 for existing material and questions on implied terms.
Some of the implied terms arguments touch on suspension and termination. These are in general going to be dealt
with by John Breeden but since we discussed this with AVDB for her proof, we have left those paras in too in case they
may be of any help. This is paras 201-211.
I have also attached as a link the latest version of the issues list. The issues to be covered by Angela on implied terms
are a little spread around within that list, so I have copied below a table I did for Ivan setting out what I thought might
be a good order for the statement. Please see section 7 which deals with what needs to be covered.
Section Broad overview heading Relevant paras from issues list
(only from those issues allocated
to AVDB)
a Overview of Post Office's business 1.1-1.5 (include 22.3 within info on
Network Transformation), 1.7,
(sub-heading for Products and Services)
1.8 [may fit more naturally with
Shortfalls]
16.1, 16.2
a How a Post Office branch works 13, 13.7, 13.8, 13.10,
(including sub-heading of Horizon)
a Subpostmasters. 3, 3.2, 3.4, 7, 12, 15 and the 2 bullet
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points under 15,
(including a sub-heading of Becoming a Subpostmaster to
deal with point 3.4, and Fees paid to Sub postmasters, and
Trust and Confidence) 14.6, 14.7, 14.8
Training 9, 10
(sub-headings for Subpostmasters and Assistants)
Investigations 17, 18
Shortfalls 19, 19.2, 19.5, 1.8 [if not included in
overview]
Implied Terms 16, 4.1, 4.2,5.1,5.2,5.3,54
Finally, I've attached lvan's email to AVDB yesterday with the latest draft (from which the implied terms section has
been deleted) just in case also of interest.
Hope this makes sense, please shout if not.
Thanks
Victoria
Victoria Brooks
Managing Associate
Womble Bond Dickinson (UK) LLP.
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From: Ivan Roots
Sent: 23 July 2018 18:28
To: Angela Van-Den-Bogerd
Cc: Victoria Brooks
Subject: RE: Your Witness statement [WBDUK-AC.FID26896945]
Dear Angela
¥®
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Please find attached the rough draft of your witness statement which I have prepared in conjunction with Victoria.
Victoria is dealing separately with issues raised by Counsel relating to implied terms.
This is very much a working draft and I have highlighted in yellow the questions I will need to ask you in order to fill out
the statement and deal with the issues that counsel have raised.
Some of the questions I need to ask you may strike you as a little basic but then again I am to some extent in the
same position as the Trial Judge who will need to be led through your evidence and have the operations of Post Office
explained to him.
I should say that I am still reviewing the documents relating to training to see if I can supply more material for your
statement as I appreciate that your knowledge of the training given to Subpostmasters is not extensive.
It would be really helpful if we could set up an appointment to discuss the statement on the phone in the first instance.
Are you likely to have any time this week?
Kind regards
Ivan
Ivan Roots
Associate
Womble Bond Dickinson (UK) LLP.
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From: Angela Van-Den-Bogerd [mailto! : GRO ~ j
Sent: 09 July 2018 08:38
To: Ivan Roots
Cc: Victoria Brooks; Mark Underwood1; Rodric Williams
Subject: RE: Your Witness statement [WBDUK-AC.FID26896945]
Hi Ivan
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That’s fine. If you could have it in my inbox before the 23 that would be helpful.
Thanks,
Angela
Angela Van Den Bogerd
People Services Director
1' Floor,Ty Brwydran,
Atlantic Close,Llansamlet
Swansea SA7 9FJ
2017 Winner of the Global Postal
Award for Customer Experience
2017 Enillydd Gwobr Post Byd-eang
ar gyfer Profiad y Cwsmer
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From: Ivan Roots [mailtoi
Sent: 06 July 2018 16:20
To: Angela Van-Den-B
ictoria Brooks + >; Mark Underwood1
“TERE odric Williams oo SRO }
Subject: Your Witness statement [WBDUK-AC.FID26896945]
Dear Angela
This is just a brief email to introduce myself. I have been asked by Victoria Brooks to assist in the drafting of your
witness statement and I am based in this firm's Southampton office.
I appreciate that we have quite a detailed proof of evidence for you already and — given you are on holiday from 11 to
23 July inclusive - I propose to turn that proof into a draft witness statement while you are on holiday so that you have
it to consider upon your return.
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In the statement I will try to anticipate what your answers are likely to be to the questions we have but I anticipate there
will be some points I cannot address without either meeting you or speaking with you on the phone.
I trust this all makes sense but please contact me if you have any queries.
Kind regards
Ivan
Ivan Roots
Associate
Womble Bond Dickinson (UK) LLP.
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