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From: Angela Van-Den-Bogerd GRO Hi
To: Shirley Hailstones { GRO +, "Parsons, Andrew"
, Kathryn Alexander
GRO as
Ce: "Prime, Amy" < GRO >, "Porter, Tom"
4 GRO a
Subject: RE: Letter of Response to Freeths - Legally privileged [BD-4A.FID26859284]
Date: Tue, 19 Jul 2016 20:45:24 +0000
Importance: Normal
Attachments: _DOC_33380020(1) DRAFT _Letter_of_Response_16_July_2016_SH_190716_AVDB_
190716.docx
Inline-Images: image003.png; image004.jpg; image005.jpg; image006 jpg; image002.png
Andy
I tracked my changes into the document Shirley sent you earlier.
Thanks,
Angela
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From: Shirley Hailstones
Sent: 19 July 2016 17:16
To: Parsons, Andrew; Kathryn Alexander
Cc: Angela Van-Den-Bogerd; Prime, Amy; Porter, Tom
Subject: RE: Letter of Response to Freeths - Legally privileged [BD-4A.FID26859284]
Hi Andy
Please see attached. For ease of use, I’ve amalgamated comments from Kath & I (Kath’s have a (KA) after the
comment).
Anything else, then please let us know.
Thanks
Shirley
Shirley Hailstones
Support Services Resolution
Manager
Post Office Limited
Guildhall, 57 Queen St
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@
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From: Parsons, Andrew [mailto:
Sent: 18 July 2016 13:24
To: Kathryn Alexander; Shirley Hailstones
Cc: Angela Van-Den-Bogerd; Prime, Amy; Porter, Tom
Subject: Letter of Response to Freeths - Legally privileged [BD-4A.FID26859284]
Kath, Shirley
Please find attached our draft Letter of Response (LOR) to Freeths on the Group Litigation.
This letter responds to the Letter of Claim from Freeths and presents Post Office's legal defence. In doing so, we set
out a number of factual points about Post Office and how it operates. Although this letter has built on the many reports
produced over the last few years, we wish to re-verify that the facts we are putting forward are correct. To that end,
would you both mind carefully reviewing the sections highlighted below to make sure that what we are saying is
correct?
Sections to be reviewed:
e — Section 4A: Factual background to the Post Office and postmaster relationship
¢ — Section 5 in full
e Schedule 4: Background to operation of a Post Office branch
* — Schedule 5: Contract Models and Variations
If possible, please could you provide any comments or amendments by track changes. Please err on the side of
caution — if you're not sure if something is correct, please flag it. Apologies for the short notice but I should be grateful
if could come back with any comments / amendments by cob tomorrow.
In order to preserve legal privilege, please do not circulate the draft LOR to anyone else. You may discuss it with
colleagues if necessary to do so but if you need to forward it to someone else for input, please can you speak to me
first.
Kind regards
Andy
Andrew Parsons
Partner
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