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Andrew Parsons
Mandy Robertson {
Victoria Brooks ¢
RE: Paul Williams statement [WBDUK-.
Mon, 13 Aug 2018 18:10:12 +0100
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Mandy
Thanks for this. A few small comments and changes attached. However, I don't think this addresses the big
questions on Bates' case.
The key question for me though is whether POL sent out the full contract terms with the Transfer Pack or
not. If not, how did Bates get a copy of the full contract?
I think (and this might be a guess) that the process might have been as follows:
e¢ Aconditions of appointment document was sent out before the branch transferred.
e The branch transferred and on the same day the SPMR signs his acknowledge of appointment (in the
Transfer Pack).
The full contract was left in the branch by the old SPMR. This was ok though because it was in the
branch when they signed the contract.
e However, what happened for new branches where there was no existing branch?
Also can you look at para 18 again and also re-read the first 36 paras of the Bates Defence. Can Paul say
that the Two Page Document was a mistake.
Lets discuss.
Andrew Parsons
Partner
Womble Bond Dickinson (UK) LLP
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soon Original Message-----
From: Mandy Robertson
Sent: 09 August 2018 10:05
To: Andrew Parsons
Ce: Victoria Brooks
Subject: RE: Paul Williams statement [WBDUK-AC.FID26896945]
Hi Andy
Hope all is well.
Please find attached the latest version of Paul's witness statement.
Many thanks
Mandy
Mandy Robertson
Solicitor
Womble Bond Dickinson (UK) LLP
www.womblebonddickinson.com
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coed Original Message-----
From: Victoria Brooks
Sent: 09 August 2018 09:39
To: Mandy Robertson
Cc: Andrew Parsons
Subject: Paul Williams statement
Mandy
Could you send the latest word version of this to Andy please? Andy, Paul actually signed it as he was going
to be away and we hadn’t yet applied for an extension, but he is back before the 24th so we intend to change
as needed.
Thanks
Victoria
Victoria Brooks
Managing Associate
Womble Bond Dickinson (UK) LLP
www.womblebonddickinson.com
Sent from my iPhone
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