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From: "Parsons, Andrew" </O=BOND PEARCE/OU=FIRST ADMINISTRATIVE
GROUP/CN=RECIPIENTS/CN=A P6>
‘Shirley Hailstones"
GRO.
GRO ee
: "Parmenter, Claire", GRO a i "Harris, Matthew"
GR i
Bce: ''364065_00531 Horizon Challenges General E_Mails' <{F20472253}.4A-
LIVE@WCSBRIO2.bondpearce.com>
Subject: FW: M029 [BD-4A.FID20472253]
Date: Fri, 09 May 2014 10:43:55 -0000
Importance: Normal
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image029.png; image030.png; image031.png; image032.jpg; image033.jpg;
image034.jpg; image035.jpg; image036.jpg; image037.jpg; image038.jpg
Shirley, Kath, Angela
FYI below re using officer's reports in POL's investigation reports. Rod's email is the product of a lot of discussions in
the legal team so represents the firm view for Chris on the way to proceed.
I appreciate that this may cause a few headaches as the officer's reports are key doc but we just need to do our best in
working to the guidelines below.
Shirley — this will apply to M029 and M035 which both at present refer to the Officer's reports. Would you mind re-
visiting both reports to remove these references, making sure the Investigation Report still makes sense? If you can
send them back to me — I'll then double check them before they go on huddle.
I'm also going to have a paralegal go through all the reports on huddle to look for any other Officer's Reports that may
have been uploaded already.
Kind regards
Andy
Andrew Parsons
Senior Associate
for and on behalf of Bond Dickinson LLP
Follow Bond Dickinson:
STinI
www.bonddickinson.com
From: Rodric Williams} _. GRO
Sent: 08 May 2014 21:59
To: Jarnail Singh; Parsons, Andrew
Cc: Chris Aujard; Jessica Madron
Subject: Re: M029 [BD-4A.FID25887033]
All,
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Having discussed this with Chris and Jessica, the protocol for the use of "Officer Reports" (or as otherwise
described) by Project Sparrow investigators when responding to individual complaints is:
1. The report is NOT to be exhibited OR expressly referenced in Post Office's formal response to a complaint.
2. It can be used by the investigator to help them understand what happened in a particular case, and to identify
other documents relevant to the case (e.g. transcripts of interviews, branch account records etc).
3. If the report is the ONLY source document still available, the investigator can repeat material from the report
(provided it is not legally privileged), but CANNOT cite the report as a reference.
4. Any challenge received about the source of a Post Office statement made from the report must be referred to
Chris.
I hope that is clear and reflects the decision made. Please let me know if not.
Kind regards, Rod
From: Jarnail Singh
Sent: Thursday, May 08, 2014 01:08 PM
To: Parsons, Andrew! ~~ GRO” ~~
Cc: Rodric Williams; Chris Aujard; Jessica Madron
Subject: RE: M029 [BD-4A.FID25887033]
Andy
I anticipate Chris is the best person to make a decision on this point on behalf of POL.
Are allegations POL has NOT properly investigated being made generally or in specific cases?. One of the dangers of
investigation officers report being disclosed is that it will always be easy for the applicant to think of something not
specifically referred to in the report and allege that POL investigation has not been sufficiently through or
adequate. Of course it is highly unlikely that the investigation will have been deficient, but in the absence of full set
of papers it may become impossible for POL to rebut such new allegations.
Regards
Jarnail
Jarnail Singh I Criminal Lawyer
148 Old Street, LONDON, EC1V 9HQ
©O©OOOO®
@postofficenews
From: Parsons, Andrew GRO i
Sent: 08 May 2014 12:23
To: Jarnail Singh; Chris Aujard; Jessica Madron
Cc: Rodric Williams
Subject: RE: M029 [BD-4A.FID25887033]
Thanks Jarnail - There are two cases that are currently affected by this issue. They both urgently need to be cleared
and sent to Second Sight so how would you like to take this forward to a decision?
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Kind regards
Andy
Andrew Parsons
Senior Associate
for and on behalf of Bond Dickinson LLP
Follow Bond Dickinson:
LS ]inI
www.bonddickinson.com
GRO i
From: Jarnail Sing!
Sent: 08 May 2014 19
To: Chris Aujard; Jessica Madron
Cc: Rodric Williams; Parsons, Andrew
Subject: RE: M029 [BD-4A.FID25887033]
Chris/ Jessica
As I understand it, POL has been advised by senior counsel that investigation and offender report should not be
disclosed. It is of course matter for POL to make a decision whether
to accept this advice or not and of course it would be open for POL to decide to discourse such documents.
I personally would be unhappy for such documents to be disclosure for reasons set out in counsel Harry Bowyers
advice note.
Given the email correspondence between Bond Dickinson and cartwright King, I would be grateful if I could be
informed whether POL has made a decision or Bond Dickinson are proceeding along the disclosure route without
POL having made a decision.
P.S I will forward Andrew Parsons email to CK sent on 6/5/14 at 15.38.
Thanks
Jarnail
Jarnail Singh I Criminal Lawyer
148 Old Street, LONDON, ECIV 9HQ
©O©OBOOO®
From: Parsons, Andrew} GRO H
Sent: 07 May 2014 16:24
To: Martin Smith
Cc: Rodric Williams; Jarnail Singh
Subject: RE: M029 [BD-4A.FID25887033]
Martin
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Thanks — if you could mark on the docs any bits that you would prefer to be redacted that would be great.
Kind regards
Andy
Andrew Parsons
Senior Associate
for and on behalf of Bond Dickinson LLP
Follow Bond Dickinson:
Blin)
www.bonddickinson.com
From: Martin Smith __..GRO i
Sent: 07 May 2014 16:17
To: Parsons, Andrew 7
Ce: Rodric Williams; Jarnail A Singh; GRO
Subject: M0290 mmm
Hi Andy,
Thank you for your e-mail; It would appear that Harry Bowyer looked at an earlier version of the
proposed response sometime ago and before we were asked to suggest amendments on draft
responses using Track Changes. In those circumstances I have added comment to the latest version
of the proposed response which I have attached hereto.
Whilst we have advised that as a matter of principle investigation and offender type reports
should not be disclosed, I understand that there will be cases in which it is felt that there is no
alternative other than to disclose these. In such circumstances they should be appropriately
redacted. If you would like me to deal with that, please let me know.
The disclosure of redacted reports may lead to requests for the disclosure of such reports in other
cases.
Please do not hesitate to contact me should you wish to discuss.
Kind regards,
Martin.
Martin Smith
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