WBON0001071 - Email from Amy Prime to Anthony de Garr Robinson, Owain Draper, Andrew Parsons and others re: Horizon - GPOC

Evidence on official site

WBONO001071
WBONO0001071

From: "Prime, Amy"
To: Anthony de Garr Robinsot

Owain Draper

Ce: "Parsons, Andrew" ; GRO :"Lukas, Elisa"

i - GRO J
Subject: Horizon - GPOC [BD-4A.FID26896945]
Date: Fri, 24 Mar 2017 17:06:48 +0000
Importance: Normal

Attachments: Signed_Generic_Particulars_of Claim_23.03.17.pdf;

In!

Appendix_A_Subpostmasters_contract.pdf;
Appendix_B_Redacted_Temporary_SPM_contract.pdf;
Appendix_C_Redacted_NT_Contract.pdf;
Appendix_D_Redacted_Franchise_Agreement.pdf;
Comparison_of_GPOC_at_23012017_and_23032017.pdf

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Tony,

Owain

Attached is the GPOC which were provided yesterday (there is also a comparison the revised draft GPOC).

Itis a fairly chunky document and we are still reviewing it but thought it would be helpful to have a call next week to
discuss a high level strategy for how we wish to respond. I have asked your clerk to find a suitable time.

Our current thinking points on the defence are:

Is it forensic / what level of detail do we go into?

Do we refuse to plead to some points?

Do we keep to a strict pleading only?

Are we just reactive to the matters pleaded or assert a positive position?

Do we assert a counterclaim (this brings with it the need to state a positive case.

The best approach may be for Owain to put together a very rough first draft so as we can get a feel for the approach

and tl

Kind
Amy

the areas which require further investigation and refine from there — of course welcome to thoughts.

regards

Amy Prime
Solicitor

Bond

Dickinson LLP

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