WBON0001188 - Email from Paul Loraine to Rodric Williams, Andrew Parsons and Gavin Matthews - Re: CCRC update [BD-4A.FID26610170]

Evidence on official site

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From: Paul Loraine }
To: "Rodric Williams

Ce: Andrew Parso
4

Subject: CCRC update [BD-4A.FID26610170]
Date: Fri, 18 Aug 2017 17:05:41 +0100
Importance: Normal
Attachments: 107020752_office_transfer.pdf; _DOC_36655676(1)_Misra_BTS_14.11.07-
15.12.07.PDF;
_DOC_36678847(1) SH 2017 08 04 Questions to POL (POL_Responses).DOCX
Inline-Images: image001 jpg; image002.jpg; image003.jpg; image52018e.JPG; imagecf0257.PNG;

image4df3fl.PNG; image3clfc4.PNG

>, Gavin Matthews

Hi Rod,
I hope you are well.

So you have visibility of where things are, here is an update on all things CCRC related. I'm happy to tweak this email
so you can send it to the CCRC as an update — just let me know how you want to play it.

1. GT questions.

Kath and Shirley have helpfully given initial answers to GT's questions — please see attached. There is clearly a
chance the answers could spawn more questions but perhaps we could share this as a starting point.

2. KEL

You may have seen that FJ (Pete Newsome) have answered the CCRC's questions on the KEL. The CCRC's
questions are in black and FJ's responses are in red below.

e Paragraph 50(4) of the defence refers to the KEL as a “document” in the singular, am I right in
thinking it exists as a single document rather than multiple different logs? The KEL is a single
database which changes with new KELs being added, changed, and removed on a regular basis.

e — In terms of scale, in your email of 13/11/2016 you referred to “thousands of entries” and “voluminous
entries” in the KEL, is it possible to say how many pages the document runs to? FJ has confirmed that
the KEL currently runs to 3973 KELs.

e — In your email of 13/11/2016 you stated: “We have asked Fujitsu for some random examples of these
entries, and will provide these to you in due course”. I don’t think we have received any examples to
date. I would be grateful if we could see some sample pages, as this would give us a clearer idea of
the kind of information the KEL contains, and whether further analysis of the document is likely to be
of any relevance to our review. Examples copied at the bottom of this email.

3. MISRA

There were a couple of points raised by the CCRC on Misra: (1) can we confirm the opening hours for the indictment
period (2005-2008); and (2) are there any further Branch Trading Statements for Misra other than December 2007-
January 2008?

On point 1, Kath has sent me the attached "Office Transfer" document dated 15 June 2005 which shows that the
opening hours are 9am-5.30pm Monday to Friday and 9am-1pm on Saturday.

On point 2, I have done some searches on the data room and found the attached BTS covering November-December
2007. I have found 2 other documents which I believe to be branch trading statements covering November-December

2006 and May-June 2007 but they are not legible. I will see if I can trace back who is holding the original document in
case we just need to re-scan these. In the meantime, I suggest we provide the one we've found to the CCRC.

4. OTHER LIVE POINTS

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Queries on transaction logs — can these queries now go direct to Pete Newsome at FJ, cc Chris Jay or do you
want to manage this?

e — Broughton /McDonald document — I'm due an update from Kath/John Breeden so I'll keep on it and keep you
posted.

Rubbina Shaheen hard copy documents — I have emailed Mark Raymond in POL Security for confirmation of
whether POL still hold hard copy documents. Again, I'll keep you posted.

« Documents relating to CK's review processes — I want to double check with Martin Smith whether there is

anything further not already on the data room relating to CK's review processes, particularly for the more
recent applicants which may have post-dated CK's original searches. I'm looking to arrange a call with Martin

for next week.
it you want to chat any of this through, I'm in next week.
Thanks,

Paul

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Paul Loraine

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Associate
Bond Dickinson LLP

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