WBON0001025 - Email from Andrew Parsons to Anthony de Garr Robinson, Owain Draper, Paul Loraine & Ors RE: Post Office - Letter of Response v2

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WBONO001025
WBON0001025

From: "Parsons, Andrew" <_.
To: Anthony de Garr Robinson GRO

"Porter, To:

Subject: esponse v2 [BD-4A.FID26859284]
Date: Sun, 10 Jul 2016 12:13:26 +0000
Importance: Normal

Attachments: _DOC_33329095(1) Note_on_Malicious_Prosecution.docx;
_DOC_33327965(1)_Note_on_Unlawful_means_Conspiracy.docx;
_DOC_33327897(1) Note_on_Harassment.docx;
_LETTER_33142705(4) Letter_of_Response.DOCX

Inline-Images: image001 jpg; image002.jpg; image003.jpg

Tony

Please find attached an updated version of the LOR. There are still a number of points to be bottomed out but I hope
the structure is now a bit tighter (it also needs a good proof read and formatting sorting out)

I would be grateful if you (or Owain) could help draft the following sections:

e Section 4: Legal duties
¢ — Section 6A: Breach of contract.

In terms of other activities that will feed into the LOR:

e We have just received Deloitte's report on remote access. We're speaking to Deloitte tomorrow and will then
update you.

e We're re-reviewing the Letter of Claim to make sure we haven't missed anything.

e I'm meeting POL on Thursday to work through the tactical points (and would welcome your input on the
decision papers when you get a chance).

Otherwise, the plan is to submit a near final draft of the LOR to POL for approval on Friday. When do you think you
might be able to draft the above sections? Also, could we have a chat about running through the whole letter?

FYI — please find attached brief research notes on malicious prosecution, unlawful means conspiracy and
harassment. Notes to follow on misfeasance and HRA.

Kind regards
Andy

Andrew Parsons
Partner

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