WBON0001068 - Email from Mark Underwood to Rodric Williams, Andrew Parsons & Patrick Bourke RE: Events in Jan

Evidence on official site

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From: Mark Underwood{* GRO j
To: Rodric William: GRO. 4 "Parsons, Andrew"
d GRO I
Ce: Patrick Bourke <
Subject: RE: Events in Jan [BD-4A.FID26896945]
Date: Mon, 9 Jan 2017 15:57:03 +0000
Importance: Normal

Inline-Images: image001 jpg; image002.png; image003.png; image004.png

Thanks Rod, I will set this up with Laura.

Mark

From: Rodric Williams

Sent: 09 January 2017 11:48

To: Parsons, Andrew; Mark Underwood1

Cc: Patrick Bourke

Subject: RE: Events in Jan [BD-4A.FID26896945]

Morning.

To protect privilege we must not share any comms from our lawyers (internal or external), or any other documents
prepared in connection with this litigation, beyond those in Post Office with a “need to know”. This includes our
shareholder or its representatives in government, and applies even where the comms/documents appear benign.

If we have to make an exception to that rule (e.g. to discuss matters with Fujitsu), we need to consider whether we
can maintain a claim to privilege and record basis for disclosure accordingly.

From her email, Laura seems to understand the purpose of the hearing. I am however happy to talk to her about it
if it would help her answer any specific enquiries she anticipates receiving. If she would like this, I suggest she call
me after the 12 January deadline Freeths have to file any further evidence for the Claimants on the GLO
Application, say early next week to allow for the possibility that Freeths miss the deadline.

Thanks, Rod

From: Parsons, Andrew [mailto{ GRO
Sent: 09 January 2017 08:46 *
To: Mark Underwood1

Cc: Patrick Bourke; Rodric Williams

Subject: RE: Events in Jan [BD-4A.FID26896945]

Mark
The hearing is public — anyone can attend.

I would strongly advise against sharing my email (copy attached) with Shex — that email contains privileged information
and sharing it may well waive that privilege.

I've copied Rod as he may have a different view.

Kind regards
Andy

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Andrew Parsons
Partner
Bond Dickinson LLP

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From: Mark Underwood1 [mailt¢
Sent: 08 January 2017 18:42
To: Parsons, Andrew

Cc: Patrick Bourke

Subject: FW: Events in Jan

Hi Andy, we have received the below request from Shex.

1) AmIOk to share with Shex the information that you provided on 28 Dec and went into the CEO report? I
recall you saying it is was not for sharing, owing to maintaining legal privilege?

2) Is it a public hearing?

Many thanks

Mark

From: Thompson, Laura - UKGI [mailto:
Sent: 03 January 2017 09:49

To: Patrick Bourke; Mark Underwood1
Subject: Events in Jan

Hi Patrick, Mark

Happy New Year to you both, hope you have both had a nice break.

I understand there is a Court hearing at the end of this month, which seems largely administrative in nature
(determining the type of claim, timetable for the rest of the case, etc). It would be helpful to know whether the
hearing is open to the public — I can envisage a degree of campaign activity if it is, and would like to make sure
people here are prepared etc.

A catch up call might be helpful — let me know when would work. No immediate rush.

Many thanks

Laura

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Laura Thompson I Assistant Director
UK Government Investments
1 Victoria Street I London I SW1H OET

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