WBONO001021
WBONO0001021
From: Anthony de Garr Robinson
To: "Parsons, Andrew" < GRO i
Subject: RE: Bates & Others v Post Office Limited // Claim no: HQ16X01238 [BD-
4A.FID26859284]
Date: Tue, 5 Jul 2016 14:51:58 +0000
Importance: Normal
Attachments: 039.Bates.note_on_draft_letter_of_response.docx
Inline-Images: image001 jpg; image002.jpg; image003.jpg; image004.png; image005.png;
image006.png; image009.jpg; image010.jpg
Here are my thoughts — not proof read, so I apologise for the inevitable errors. I also apologise for the delay. With
more time it would have been better organised and shorter.
Best wishes,
Tony
From: Parsons, Andrew {mailto}.
Sent: 05 July 2016 15:21
To: Anthony de Garr Robinson <_
Subject: RE: Bates & Others v Post Office Limited // Claim no: HQ16X01238 [BD-4A.FID26859284]
Tony — any ETA on your comment on the LOR?
I'm sorry to chase. POL are pushing us to scope out how the next 2 weeks might look so that we can line up the right
people to review the LOR and it would be good to understand your thinking before we do anything.
Andy
Andrew Parsons
Partner
Bond Dickingow
Direct:
Mobile: I.
Follow Bond Dickinson:
Blin)
www.bonddickinson.com
From: Parsons, Andrew
Sent: 04 July 2016 19:17
To: Anthony de Garr Robinson
Cc: Porter, Tom; Loraine, Paul
Subject: RE: Bates & Others v Post Office Limited // Claim no: HQ16X01238 [BD-4A.FID26859284]
Agreed on a short but polite response to Freeths.
Tomorrow lunchtime is fine for comments on the LOR.
The scheme provided no protection against "victimisation". Indeed, it said the opposite- that POL could use
anything found during the scheme to take action (eg. termination, civil proceedings, prosecution, etc) against a
postmaster. I'm really reluctant to give anything on this point but lets discuss next time we speak.
WBD_000891.000001
WBONO001021
WBON0001021
A
Andrew Parsons
Partner
Bond Dicki
Tel:
LLP
From: Anthony de Garr Robinson
Sent: 04/07/2016 18:46
To: Parsons, Andrew
Ce: Porter, Tom; Loraine, Paul
Subject: RE: Bates & Others v Post Office Limited // Claim no: HQ16X01238 [BD-4A.FID26859284]
This is beyond a joke. They are running up costs for no good reason (or for no good reason that they have
identified). A courteous but firm response seems to me to be in order. Happy to discuss over the phone tomorrow
morning.
I’m conscious that I was supposed to let you have my headline comments on the draft letter of response by COB
today, and that I have failed to meet that deadline. You will have something by lunchtime tomorrow, but if that
causes you problems please tell me and I will get up early to accommodate you.
On your previous “victimisation” email, it seems to me that we could formulate a fair assurance that leaves our
ability to take lawful action in accordance with our ordinary practices. Given the terms of our April letter, I infer
that the complaint review and mediation scheme had some terms that might give us a good starting point. If there
are any terms relevant to victimisation, could you let me know what they are?
Tony
From: Parsons, Andrew [mailto} ~ GRO i
Sent: 04 July 2016 18:20
To: Anthony de Garr Robinsc
Cc: Porter, Tom + __j; Loraine, Paul
Subject: FW: Bates & Others v Post Office Limited // Claim no: HQ16X01238 [BD-4A.FID26859284]
Tony
FYI — latest letter from Freeths on the GLO. They have asked us to identify now which of the GLO issues we consider
are not common or related issues, despite us saying that we will pick up this point in the Letter of Response (LOR).
I've attached our last letter for ease of reference.
I'll have a think about a response — are you around tomorrow to discuss?
Kind regards
Andy
Andrew Parsons
Partner
wou: I GRO I
Follow Bond Dickinson:
Blin)
WBD_000891.000002
WBONO001021
WBONO0001021
www.bonddickinson.com
From: Imogen Randall [mailto::
Sent: 04 July 2016 17:34
To: Porter, Tom
Cc: Matthews, Gavin; Parsons, Andrew; James Hartley
Subject: Bates & Others v Post Office Limited // Claim no: HQ16X01238
Sirs
See attached.
Freeths LLP
Imogen Randall
Associate
Dispute Resolution
FREETHS
BEST COMPANIES
TO WORK FOR
Ea (ii
Freeths LLP, Floor 3, 100 Wellington Street, Leeds LS1 4LT
Legal 500 Guide 2015: Listed 'Top Tier’ in 20 categories I 93 'Recommended' Lawyers I 17 ‘Elite Leading Lawyers’
Chambers UK Guide 2015: Ranked in 32 categories I 58 Lawyers listed as 'Leaders in the field’
Please consider the environment! Do you need to print this email?
The information in this e-mail and any attachments is confidential and may ally privileged and protected by Jaw, arobinso nly is authorised to access
this e-mail and any attachments. If you are not arobinsong please notify andrew.parsons( i ind delete any copies.
Unauthorised use, dissemination, distribution, publication or Copying of this communication or attachments Is prohibited and may
Any files attached to this e-mail will have been checked by us with virus detection software before transmission. Bond Dickinson LLP accepts no liability for any loss or
damage which may be caused by software viruses and you should carry out your own virus checks before opening any attachment.
WBD_000891.000003
WBONO001021
WBON0001021
Content of this email which does not relate to the official business of Bond Dickinson LLP, is neither given nor endorsed by it.
This email is sent by Bond Dickinson LLP which is a limited liability partnership registered in Engl:
London Riverside, London, SEI 2AU, where a list
consultant who is of equivalent standing. Our VAT
gland and Wales under number 0C317661. Our registered office is 4 More
mbers' names is open to inspection, We use the term partner to refer to a member of the LLP, or an employee or
istration number is GB123393627,
Bond Dickinson LLP is authorised and regulated by the Solicitors Regulation Authority
This email has been scanned by the Symantec Email Security.cloud service.
For more information please visit http://www.symanteccloud.com
This email has been scanned by the Symantec Email Security.cloud service.
For more information please visit http://www.symanteccloud.com
This email has been scanned by the Symantec Email Security.cloud service.
For more information please visit http://www.symanteccloud.com
This email has been scanned by the Symantec Email Security.cloud service.
For more information please visit http://www.symanteccloud.com
WBD_000891.000004