WBON0000891 - Email from Mark Westbrook to Rodric William RE: Draft Report - Release to Bond Dickinson LLP and Cartwright King LLP

Evidence on official site

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From: "Westbrook, Mai
: Rodric Williams

. }, "Parsons, Andrew"
James, Gareth (UK - Manchester)"

RE: Draft Report - Release to Bond Dickinson LLP and Cartwright King LLP [BD-
4A.FID20472253]

Date: Fri, 22 Aug 2014 17:41:07 +0000
Importance: Normal
Attachments: Project_Zebra_Consolidated_Report_Draft_Subject_to_Change_21_08 2014 18 06.pdf
Inline-Images: image001 , image002.png; image003.png; image004.png; image005.png;
image006.gif; image007.gif; image008.png; image009.jpg; image010.jpg; image011 jpg

Subject

Thanks Rodric.

Please find attached the version of the report requested, and detailed in the HH.
Have a great weekend.

Thanks,

Mark

From: Rodric Williams [mailt¢
Sent: 22 August 2014 17:25
To: Westbrook, Mark (UK - Manchester); Parsons, Andrew; James, Gareth (UK - Manchester)

Subject: RE: Draft Report - Release to Bond Dickinson LLP and Cartwright King LLP [BD-4A.FID20472253]

Thank you Mark.
Please find attached the letter countersigned by Bond Dickinson and Post Office Limited.

Have a good weekend!

Rodric Williams I Litigation Lawyer

©GBOGO®

@postofficenews

From: Westbrook, Mark (UK - Manchester) [mailto:

Sent: 22 August 2014 13:00

To: Parsons, Andrew; Rodric Williams; James, Gareth (UK - Manchester)

Subject: RE: Draft Report - Release to Bond Dickinson LLP and Cartwright King LLP [BD-4A.FID20472253]

Andrew, Rodric,

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Please find attached hold harmless as requested. If you can sign and send back (both parties) I will issue the report

to Andrew.
Many thanks,

Mark

From: Westbrook, Mark (UK - Manchester)

Sent: 22 August 2014 07:08

To: ‘Parsons, Andrew’; Rodric Williams; James, Gareth (UK - Manchester)

Subject: RE: Draft Report - Release to Bond Dickinson LLP and Cartwright King LLP [BD-4A.FID20472253]

As an update HH ready to go barring final approvals which I am hoping I will get today.
Will issue as soon for signature as soon as able.
Thanks,

Mark

From: Parsons, Andrew [mailto:
Sent: 21 August 2014 09:14
To: Rodric Williams; Westbrook, Mark (UK - Manchester); James, Gareth (UK - Manchester)

Subject: RE: Draft Report - Release to Bond Dickinson LLP and Cartwright King LLP [BD-4A.FID20472253]

Mark

Have you had a chance to get clearance for BD to look at your report? It would be good to get this done asap (ie. this

week).

Kind regards
Andy

Andrew Parsons
Senior Associate
for and on behalf of Bond Dickinson LLP

From: Rodric Williams}

Sent: 15 August 2014 16:29

To: Westbrook, Mark (UK - Manchester); James, Gareth (UK - Manchester)

Cc: Parsons, Andrew

Subject: RE: Draft Report - Release to Bond Dickinson LLP and Cartwright King LLP

Mark,

As we have just discussed, I appreciate that the “Horizon: Desktop Review of Assurance Sources and Key Control
Features; Draft for discussion” report dated 23 May 2014 (the “Draft Report”) does not yet incorporate all of Post

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Office Limited’s comments. However, I am concerned that given our current workloads and resources, getting the
Draft Report to a “final Draft” stage may take some time. In order to progress matters (which I am anxious to do), I
would like to release the Draft Report to Bond Dickinson (Andy Parsons, cc’ed) in its current format, subject of
course to them providing to Deloitte a suitable “hold harmless” letter.

I have looked at the “hold harmless” letter which Linklaters provided on 30 April 2014 (copy attached), and wonder
whether if the Draft Report could be released to Bond Dickinson on similar terms, subject to the first paragraph
being amended as follows (1 would have provided you with a mark-up, but don’t have a Word version!):

“We have now had an opportunity to consider your request for access to our report “Horizon: Desktop Review of
Assurance Sources and Key Control Features; Draft for discussion” dated 23 May 2014, which was prepared for
Post Office Limited under the terms of our engagement letter dated 9 April 2014 and Change Order Number 01
dated 6 May 2014. Post Office Limited has instructed Bond Dickinson LLP as advisors and have asked that we allow
Bond Dickinson LLP access to the Draft (in its current draft form) to enable them to provide legal advice to Post
Office Limited, to prepare documents based on the Draft for internal Post Office Limited use, and to make
reference to the Draft in future communications with Post Office Limited as required (the “Purpose”).”

Please let me know if we can proceed on this or some other basis.

Kind regards, Rodric

Rodric Williams I Litigation Lawyer

148 Old Street, LONDON, ECIV 9HQ

Post Office stories

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@postofficenews

From: Westbrook, Mark (UK - Manchester) [mailto

Sent: 24 July 2014 08:43

To: James, Gareth (UK - Manchester); Rodric Williams

Subject: RE: Draft Report - Release to Bond Dickinson LLP and Cartwright King LLP

Hi Rod,

Further to Gareth’s note, and in anticipation of you sending through your final edits, could you provide the postal
addresses and contacts for both firms mentioned below in order that I might insert into the HH.

Thanks,

Mark

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From: James, Gareth (UK - Manchester)

Sent: 21 July 2014 12:59

To: Rodric Williams; Westbrook, Mark (UK - Manchester)

Subject: RE: Draft Report - Release to Bond Dickinson LLP and Cartwright King LLP

Hi Rod — thanks for this. There is a light-weight process for your solicitors in this regard, which we will progress
whilst you're away.

I would however like to get the report into a final version (or at least an agreed “final draft”) before sharing
externally. Are you ok for us to receive and process such changes that you’re on with and then share the ‘final
draft’ version from that point?

All the best

Gareth

From: Rodric Williams [mailto:{ i
Sent: 21 July 2014 12:23
To: James, Gareth (UK - Manchester); Westbrook, Mark (UK - Manchester)

Subject: Draft Report - Release to Bond Dickinson LLP and Cartwright King LLP

Gareth, Mark,

So that we can share your draft Report with our solicitors to enable them to provide Post Office Ltd with legal
advice, can you please send through “release”/ “hold harmless” letters for:

Gavin Matthews, Partner
Bond Dickinson LLP
Oceana House

39-49 Commercial Road
Southampton SO15 1GA

-and-

Martin Smith, Partner
Cartwright King LLP
Majority House

51 Lodge Lane,

Derby DE1 3HB

Alternatively, please let me know if such letters are not required.
Kind regards, Rod

Rodric Williams I Litigation Lawyer

@ 148 Old Street, LONDON, ECIV 9HQ

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Post Office storie:

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@postofficenews

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