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From: "Parsons, Andrew"
odric Williams!
Subject: Draft Defence
Date: Wed, 28 Jun 2017 19:30:03 +0000
Importance: Normal
Attachments: Protocol_for_ Second_Sight_14_06_17_(Csl_suggested_amends)-1.docx;
100_Bates_draft_Defence.docx
Inline-Images: imagee51c24.JPG; image178204.PNG; image6f7c85.PNG; image535641.PNG
Rodric, Mark
Please find attached the draft defence from Tony.
There are lots of minor points chase down - many of which are already with Kath / Shirley and FJ.
The key ones that would be good to discuss tomorrow are:
1. Paras 28, 35 and 55 - these relate to the process for disputing shortfalls. We're struggling to get to the
bottom of those processes and how those disputes are resolved.
2. Para 50(2) - do we say that POL previously relied on incorrect statements from FJ in relation to remote
access? This is basically dropping FJ in it.
The other points I have on my mini agenda for tomorrow are:
1. Prep needed for the GE meeting.
2. Comms lines around the defence and addition of more claimants.
3. Second Sight protocol. We've had a proposal (attached) from Freeths that I can explain tomorrow.
4, Debt team protocol - next steps.
Kind regards
Andy
Andrew Parsons
Partner
Bond Dickinson LLP
Follow Bond Dickinson:
www.bonddickinson.com
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