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From: "Loraine, Paul" +
To: "Rodric William:
Ce: "Porter, Tom"
{ “GRO
GRO
Subject: RE: LOC Work Plan and eSRF [BD-4A.FID26859284]
Date: Wed, 11 May 2016 12:06:01 +0000
Importance: Normal
Attachments: Briefing_note_for_counsel.docx
Inline-Images: image001 jpg; image002.jpg; image003.jpg; image55b97b.JPG; image4d47cd.JPG;
imagef55327.JPG; imagec928b9.JPG
3, "Matthews, Gavin"
} "Parsons, Andrew"
Rod
I have pulled together a draft briefing note for counsel which lifts heavily from the advice note prepared by Jonathan
Swift QC in February. We can provide this (once finalised) to Jeff Onions and Tony Robinson ahead of back-to-back
meetings with each of them, ideally next week. Is there any update from Jane on the counsel point (further to Andy's
email below)? Once I have the green light from you, I will set up meetings with Jeff and Tony.
Gavin is tied up until 2pm and has not looked at this draft note yet but for the sake of efficiency, I thought it best to
send it to you in its current form so you and Gavin can be looking at this in parallel.
Having discussed this with Andy, we were of the same mind that this need not be a traditional “instructions” document.
The attached note plus the letter of claim and claim form should give Jeff and Tony what they need to get them thinking
about the issues ahead of the meetings.
I'm happy to discuss the note if that would be helpful.
Thanks
Paul
Paul Loraine
Solicitor
Bond Dickinson LLP
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Office:
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From: Parsons, Andrewi.
Sent: 07 May 2016 12:44
To: Rodric Williams I
Cc: Loraine, Paul; Porter, Tom; Matthews, Gavin
Subject: LOC Work Plan and eSRF [BD-4A.FID26859284]
Rodric
Please find attached our Work Plan for responding to the LOC that encompasses the strategy and timings we
discussed previously.
You'll see that the actions have been allocated between Tom P and Paul L and they'll crack on with this work next
week.
There are two key points that I'd be grateful if you could help with:
1. Counsel — Please could you get Jane's approval to instruct Counsel. Once you get the green light, Paul L will
put the wheels in motion. The first step will be short meetings with Tony Robinson and Jeff Onions to see who
is the best fit.
2. FJ-—Please can you setup an internal meeting at POL to discuss the issues around FJ (disclosure, unlawful
conspiracy claim, limitation issues, etc.). If this could be arranged for w/c 16 May when I'm back that would be
great.
Below is an eSRF in line with the figures we discussed the other day. I presume that this matter will be coming out of a
separate project budget rather than your BAU budget. If this means that you need us to provide something else to
support the budget request, please let me know.
Kind regards
Andy
1. Firm Is this anew SRF orisachange I New
being sought? (If a change, add
to the scope in box 6 - highlight
the text)
2. Firm Matter description (brief): !
3. Firm Total Fees Quote Stage 1: £150,000 + VAT
(incl VAT and whether
fixed ~ a fixed charge irrespective of I Stage 2: To agreed
the Ceaeeh . 6
capped - means maximum charge i
wat the cap, depending on fear *Dn Wariable
spent, cap not to be exceeded; or elete as appropriate
= — variable): = —— ee
4, Firm Initial Work Description ani Stage 1: Preparing Letter of Response to Freeths
Work Plan (use stages when including:
appropriate): e Tactical advice on how to proceed
e Investigating complaints raised
e Managing document preservation and
disclosure issues
e Researching and advising on legal issues
e Instructing a QC to advise on the Letter of
Response and the matter generally
e Drafting the Letter of Response
See attached Work Plan for further details.
Stage 2: Further work in relation to the dispute as
5. Firm Detailed Fees Breakdown
(including any anticipated
disbursements and expenses) BD Fees - £100k
regarding Initial Work and Counsel - £50k
Charges (as appropriate):
BD's fees are based on the average monthly run
cost during project Sparrow (ie. £30k per month
for approx. 3.5 months).
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Counsel's fees are based on the historic costs of
engaging Brian Altman QC to advise during project
Sparrow.
.No expe exp! —
6. Firm Law Firm - Main Contact for Andy Parsons / Gavin Matthews
this matter:
7, Firm Panel Firm Partner Contact:
8. Firm Panel Firm Case Reference:
Firm Instruction/Change Date:
POL Please indicate whether this is a
project:
11. POL If a project, please provide the
Purchase Order Number (PON),
if PON not yet available please
inform us when it is, and in the
meantime supply CC and GL
Number (which we will use to
pay invoices in the interim):
12. POL If not a project, which legal BAU
legal budget is to be used?*
1e5POr POL Legal Contact:
legal
14. POL POL Business Contacts:
legal
15. POL POL Legal Ref:
legal
16. Firm Signed by Law Firm Partner (& Andy Parsons - 7 May 2016
date)
17. POL Signed by POL Head of Legal (&
legal
Andrew Parsons
Partner
piece GRO
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