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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
line-Images: image2398bf.JPG; image9ce89c.PNG; image401ade.PNG; imagece0685.PNG
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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