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From: Andrew Parsons
To: Gideon Cohen +
Ce: David Cavender < Kl
Subject: RE: Statement [WBDUK-AC.FID26896945]
Date: Thu, 23 Aug 2018 15:53:24 +0000
Importance: Normal
Inline-Images: image2d9511.PNG; imagee26ad3.PNG; image5d37f5.PNG
Owain Draper <
Another one...
You've also deleted footnote 23 in para 88, regarding remote access. If we do not cover remote access, then the
entire statement needs to changed, because the statement is premised on the notion that SPMRs have control over
their accounts. That point is not 100% true, due to the remote access argument, but is 99.99% true so we need to
explain the remote access concept otherwise AVDB won't be telling the truth.
Given the sensitivities on this point, we need to cover it off.
Thoughts please?
A
Andrew Parsons
Partner
Womble Bond Dickinson (UK) LLP
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From: Gideon Cohen [mailto
Sent: 23 August 2018 16:07
To: Andrew Parsons
Cc: David Cavender; Owain Draper
Subject: Re: Statement
Understood.
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Ok — I'm putting these back in but in simplified form. There is nothing secret about any of these — they are
all publicly available points of law.
A
Andrew Parsons
Partner
Womble Bond Dickinson (UK) LLP
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i di
From: Gideon Cohen [mailto;
Sent: 23 August 2018 16:02
To: David Cavender
Cc: Andrew Parsons; Owain Draper
Subject: Re: Statement
Those were exactly my thoughts.
On 23 Aug 2018, at 17:54, David Cavender < ee GRO I
<mailto
Andy,
Gideon deleted those paragraphs.
T assume he did so on the basis that whilst the earlier paragraphs in that section are generic (and therefore
could be said to have been reasonably in the contemplation of the parties at the time of contracting ) it would
be more difficult to justify the later more granular and specific examples (which have been deleted) on the
same basis.
Gideon — is this correct ?
Best,
Dz.
David Cavender Q.C.
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From: Andrew Parsons [mailto
Sent: 23 August 2018 15:48
To: David Cavender ¢ :
<mailto:
Subject: RE: Statement
David
Quick question... why did you delete the section on regulatory requirements at para 62 onwards?
This is a major pressure on POL's business and drives lots of its pressures. Indeed, Post Office is probably
the most highly regulated business in the country.
A
Andrew Parsons
Partner
Womble Bond Dickinson (UK) LLP
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From: David Cavender {mailto}
Sent: 23 August 2018 10:30
To: Andrew Parsons
Cc: Owain Draper; Gideon Cohen
Subject: RE: Statement [WBDUK-AC.FID26896945]
Dear Andrew,
I attach a tracked version of Angela’s statement which includes comments from Gideon and from me. These
(relatively few) comments have been made upon the clean version provided. My comments on admissibility
have also been discussed with Owain.
Best,
D.
David Cavender Q.C.
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Temple
London EC4Y 9AR
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From: Andrew Parsons [mail
Sent: 20 August 2018 17:53
To: David
<mailto!__
Ce: Owain Draper
David
As discussed earlier — any comments appreciated on Angela's statement.
A
Andrew Parsons
Partner
Womble Bond Dickinson (UK) LLP
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From: Andrew Parsons
Sent: 20 August 2018 16:32
To: 'Angela Van-Den-Bogerd'; Rodric Williams
Ce: Victoria Brooks; Ivan Roots
Subject: RE: Statement [WBDUK-AC.FID26896945]
Angela
Please find attached your updated statement (+ a comparison showing the changes from the original version
sent to you). This includes your comments, further amendments from Counsel and some comments from me.
Once you've had a chance to review, it might be easiest for us to setup a call to go through the remaining
points.
Thanks
Andy
From: Angela Van-Den-Bogerd [mailto} GRO
Sent: 17 August 2018 16:59 ~ ~
To: Andrew Parsons; Rodric Williams
Ce: Victoria Brooks
Subject: RE: Statement
Importance: High
Andy
Please find attached the latest version of my statement. This is still work in progress as I have some queries
out with the business. I will pick this up again on Monday when I should have the information I’ve
requested. In the meantime I’m returning to you as I have some comments for you/WBD that I’ve tracked —
could you review and let me have a response/update please. Where we’ve referenced other witness
statements it would be helpful if I could see them. Is this possible?
I had intended to be on leave next week but in light of this being unfinished I am now in work on Monday
and will pick up for the rest of the week to finalise this statement ahead of submission deadline.
Thanks,
Angela
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Angela Van Den Bogerd
People Services Director
Ist Floor,Ty Brwydran,
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From: Andrew Parsons [mail
Sent: 08 August 2018 21:15 —
To: Angela Van-Den-Bogerd tex - GRO
Subject: Statement
Angela
Please find attached the latest draft of your statement. All comments welcomed. This has been restructured
from the last version you saw, added a number of new sections and have cut out some material to make it
shorter / where we have considered material to be to far over the line of admissibility.
Rod — your comments also welcomed. In particular, there are some comments marked in green for your
attention.
Kind regards
Andy
Andrew Parsons
Partner
Womble Bond Dickinson (UK) LLP
GRO
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