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From: Jessica Madron <j
To: "Parsons, Andrew" <__.
Ce: Rodric Williams {~
Subject: RE: Post Office Group Action - Letter of Response [BD-4A.FID26859284]
Date: Tue, 19 Jul 2016 15:03:31 +0000
Importance: Normal
Attachments: _DOC_33380020(1) DRAFT _Letter_of_Response_16_July_2016_with_Jessica's_revie
w.docx
Inline-Images: image004.png; image005.png; image006.jpg; image007 jpg; image008.jpg
Andy
Please see my review up as far as 5.13 . I will try to do the rest tomorrow. I’m in meetings now for the rest of the
day.
Many thanks
° Jessica Madron
Head of Legal (Infrastructure and DR)
Finsbury Dials
20 Finsbury Street
R The Post Office Legal Team was recognised as one of the top
In-House Retail Teams at the Lawyer Awards 2016
From: Parsons, Andrew [mailte
Sent: 16 July 2016 1:
To: Jessica Madron
Ce: Rodric Williams <.
Subject: Post Office Group Action - Letter of Response [BD-4A.FID26859284]
Jessica
As discussed, please find attached the draft Letter of Response to Freeths that includes Counsel's approach to the
implied terms in the postmaster relationship. Section 4 is where we address contractual issues, in particular
paragraphs 4.34 and 4.35.
Other parts of the letter that you might find interesting are:
e Intro / executive summary
e — Section 4A: on the background to the postmaster relationship
* — Schedule 5: Contract models and variations.
Any comments on these paragraphs (or on any other part of the letter) are welcomed.
Kind regards
Andy
Andrew Parsons
Partner
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