WBONO0000608
WBON0000608
From: Victoria Brooks 4
To: Helen Creech
Andrew Parsons
Subject: Fwd: Statements of Kendra
AC.FID27103678]
Date: Tue, 14 Aug 2018 16:49:44 +0100
Importance: Normal
Inline-Images: image001.png; image002.png; image003.png; imageda7fa2.PNG; imagea3218e.PNG;
imagecc7484.PNG
. Ed Duffield ¢
ison Bolsover [WBDUK-
ickinson and
Please see final confirmation from Counsel that these statements will not be served.
Andy are you happy for Ed/ Helen To let Alison and Kendra know this, and saying we will need to finalise
the statements in a couple of weeks for potential use for the Horizon issues trial? Please thank them for their
efforts.
Also Mark U is coordinating availability / cover and Angela is creating a team approach so is it ok for me to
let them know too? I’ll explain we will need time from them but not availability throughout November.
Thanks
Victoria
Victoria Brooks
Managing Associate
Womble Bond Dickinson (UK) LLP.
‘Stay informed: sign up to our e-alerts
WOMBLE womblebonddickinson.com
BOND
DICKINSON ¥@O
Sent from my iPhone
Begin forwarded message:
From: Owain Draper <
Date: 14 August 2018
To: Andrew Parsons <
Ce: Anthony de Garr.
Victoria Brooks <
Subject: Re: Statements of Kendra Dickinson and Alison Bolsover [WBDUK-AC.FID27103678]
Gideon Cohen j
—”}, David Cavender +
Dear Andy,
I agree. I cannot see how either statement is material to the Common Issues.
WBD_000478.000001
WBONO0000608
WBON0000608
A few quick observations on the content (for another day):
(1) As a matter of presentation, it would be good not to refer to the provision of “services” by Post Office
to SPMs (here, the Helpline). I know that it is common in big organisations refer to any assistance or
interaction as a “service” provided to a “customer” (see HMRC for example), but we should avoid this
language where possible because of the Supply of Goods and Services Act 1982.
(2) There are a few unhelpful passages in the Dickinson statement where she puts things a lot lower than I
would expect — for example, she does not reject in strong terms the suggestion that Helpline advisers may
have advised SPMs to submit false accounts. I expect this is because the draft is in a relatively early stage
of development, but I raise it now because it is potentially an important point. Surely any adviser providing
that kind of highly inappropriate advice would be in breach of important rules and guidance, would be
taken to task, etc etc (?)
Kind Regards,
Owain
Owain Draper
One Essex Court, Temple
EC4Y 9AR
Switchboard:
www.oeclaw.co.uk<http://www. law. k/>
The content of this email is confidential and may subject to legal professional privilege. If you are not the
intended recipient, please delete it permanently and inform the sender.
From: Andrew Parsons <_
Date: Tuesday, 14 August 2018 at 13:48
To: Gideon Cohen {7 GR
Ce: Anthony de Garr Robinson
Victoria Brooks { GRO 7
Subject: RE: Statements of Kendra Dickinson and Alison Bolsover [WBDUK-AC.FID27103678]
wain Pepe
Thanks Gideon
I agree. Any alternative views from anyone else?
If not, we will stop further work on these statements.
A
Andrew Parsons
Partner
Womble Bond Dickinson (UK) LLP
d:
m:
t
e
WBD_000478.000002
WBONO0000608
WBON0000608
Stay informed: sign up to our e-alerts<https://www.womblebonddickinson.com/uk/preferences>
[Womble Bond Dickinson (UK) LLP Logo]
womblebonddickinson.com<http://www.womblebonddickinson.com>
[Twitter Logo]<http://www.twitter.com/wbd_uk>
[LinkedIn Logo]<https://www.linkedin.com/company/womble-bond-dickinson-uk-llp/>
From: Gideon Cohen [mailto
Sent: 14 August 2018 13:04
To: Andrew Parsons; Owain Draper
Cc: Anthony de Garr Robinson; David Cavender; Victoria Brooks
Subject: RE: Statements of Kendra Dickinson and Alison Bolsover [WBDUK-AC.FID27 103678]
Andy,
I have now been through these - my view is that they are almost entirely inadmissible (although obviously
likely to be relevant to breach in due course). Small sections in the Bolsover statement are admissible, but
these overlap with evidence which is already being given by other witnesses. So my view is that we should
not serve either statement (or take any sections for deployment in other statements).
All best
Gideon
Gideon Cohen
Barrister
One Essex Court
Temple
London EC4Y 9AR
Swi
www.oeclaw.co.uk<http://www.oeclaw.co.uk>
The contents of this email are CONFIDENTIAL and may be PRIVILEGED. If you are not the intended
recipient, please telephone (020) 7583 2000 and delete this email.
From: Andrew Parsons} . GRO
Sent: 14 August 2018 10:22
To: Owain Draper; Gideon Cohen
Cc: Anthony de Garr Robinson; David Cavender; Victoria Brooks
WBD_000478.000003
WBONO0000608
WBON0000608
Subject: Statements of Kendra Dickinson and Alison Bolsover [WBDUK-AC.FID27103678]
Owain, Gideon
Please find attached the draft statements of
1. Kendra Dickinson — which principally relates to supports for postmaster
2. Alison Bolsover — which principally relates to Transaction Corrections and debt recovery
We had these put together to gain a understanding of these areas but my view is that (i) we don't need the
level of detail covered by these statements and (ii) this is all largely inadmissible.
Would you mind briefly reviewing and then advising on:
1. Whether we need these statements at all?
2. If there are any sections / paragraphs in these statements that might be useful? If there are short bits we
might be able to include these in someone else's statement.
Thanks
Andy
Andrew Parsons
Partner
Womble Bond Dickinson (UK) LLP
Kmailto:d GRO
Stay informed: sign up to our e-alerts<https://www.womblebonddickinson.com/uk/preferences>
[Womble Bond Dickinson (UK) LLP Logo]
womblebonddickinson.com<http://www.womblebonddickinson.com>
[Twitter Logo]<http://www.twitter.com/wbd_uk> [LinkedIn Logo]
<https://www.linkedin.com/company/womble-bond-dickinson-uk-IIp/>
Please consider the environment! Do you need to print this email?
The information in this e-mail and arm attachments i is confidential and may be legally privileged and
protected by law. gcohent.. “only i is authorised ° access this e-mail and any attachments. If
ou are not gcoheni GRO
GRO. d<mailto} .
use, dissemination, distribution, publication or “ copying of this communication or attachments i is prohibited
and may be unlawful. Information about how we use personal data is in our Privacy
WBD_000478.000004
WBONO0000608
WBON0000608
Policy<https://www.womblebonddickinson.com/uk/privacy-policy> on our website.
Any files attached to this e-mail will have been checked by us with virus detection software before
transmission. Womble Bond Dickinson (UK) LLP accepts no liability for any loss or damage which may be
caused by software viruses and you should carry out your own virus checks before opening any attachment.
Content of this email which does not relate to the official business of Womble Bond Dickinson (UK) LLP,
is neither given nor endorsed by it.
This email is sent by Womble Bond Dickinson (UK) LLP which is a limited liability partnership registered
in England and Wales under number 0C317661. Our registered office is 4 More London Riverside,
London, SE1 2AU, where a list of members’ names is open to inspection. We use the term partner to refer
to a member of the LLP, or an employee or consultant who is of equivalent standing. Our VAT registration
number is GB123393627.
Womble Bond Dickinson (UK) LLP is a member of Womble Bond Dickinson (International) Limited,
which consists of independent and autonomous law firms providing services in the US, the UK, and
elsewhere around the world. Each Womble Bond Dickinson entity is a separate legal entity and is not
responsible for the acts or omissions of, nor can bind or obligate, another Womble Bond Dickinson entity.
Womble Bond Dickinson (International) Limited does not practice law. Please see
www.womblebonddickinson.com/legal<http://www.womblebonddickinson.com/legal> notices for further
details.
Womble Bond Dickinson (UK) LLP is authorised and regulated by the Solicitors Regulation Authority.
This email has been scanned by the Symantec Email Security.cloud service.
For more information please visit http://www.symanteccloud.com
This email has been scanned by the Symantec Email Security.cloud service.
For more information please visit http://www.symanteccloud.com
This email has been scanned by the Symantec Email Security.cloud service.
For more information please visit http://www.symanteccloud.com
This email has been scanned by the Symantec Email Security.cloud service.
For more information please visit http://www.symanteccloud.com
WOMBLE
BOND
DICKINSON
is) 4
WBD_000478.000005