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From: Rodric Williams
To: "Parsons, Andrew" RO
Subject: RE: Group Action - Instructions to Deloitte [BD-4A.FID26859284]
Date: Tue, 26 Apr 2016 13:55:34 +0000
Importance: Normal
Inline-Images: image001 jpg; image002.jpg; image003.png
Andy -in the penultimate paragraph, please ask Deloitte to mark documents prepared for the presentation
“Private and Confidential — Subject to Privilege”, and then email it to Andy Whitton and Mark Westbrook at
Deloitee, cc’ing me and Mark Underwood.
Thanks,. Rod
From: Parsons, Andrew [mailt
Sent: 26 April 2016 13:16
To: Rodric Williams
Cc: Matthews, Gavin; Loraine, Paul; Mark Underwood:
Subject: Group Action - Instructions to Deloitte [BD-4A.FID26859284]
Rodric
Action required: please confirm that you are happy for us to send the attached letter / provide any comments
you may have.
Please find attached a draft letter from BD to Deloitte. The language of the letter is slightly strained due to having to
dovetail Deloitte's previous letter of instruction into the new environment where we have live litigation underway. I do
however believe that the letter makes sufficiently clear that Deloitte's work is covered by privilege and it is also
sufficiently neutral that it could be placed before a Court if any argument about privilege were to arise.
I don't have a contact address for Deloitte - do you have one? Also, to whom should the letter be addressed at
Deloitte?
All comments welcomed.
Kind regards.
Andy
Andrew Parsons
Managing Associate
Bond Dickinson LLP
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