WBONO001248
WBON0001248
From: Jane MacLeod <
To: Mark Underwood1 < GRO. : >, Andrew Parsons
{ GRO R V
Thomas P Moran <_ GRO >, Melanie Corfield
H GRO I
: Amy Prime
: Re: Skeleton arguments [BD-4A.FID26896945]
Date: Fri, 1 Jun 2018 05:56:34 +0000
Importance: Normal
Inline-Images: image001.png; image002.png; image003.png; image004.png
I think we should flag to BEIS/UKGI in advance given the possibility (even if remote) of this being picked
up by the press.
Equally we should flag to GE, the Board and the auditors. I’ll draft a note and circulate shortly for comment.
Jane MacLeod
Group Director Legal, Risk & Governance
Post Office
From: Mark Underwood1
Sent: Thursday, May 31, 2018 8:51:35 PM
To: Andrew Parsons; Rodric Williams; Jane MacLeod; Thomas P Moran; Melanie Corfield
Cc: Amy Prime; Jonathan Gribben.
Subject: RE: Skeleton arguments [BD-4A.FID26896945]
Thanks Andy — I am not sure, I will pick this up with Jane on Monday, as I am on leave tomorrow. I note the
following sentence may indicate that we don’t and provide insight into what appears to be a rather crude
tactic ahead of Tuesday:
should be relied upon solely as a suitable guide for the purposes of proportionality considerations in costs budgeting.
Mark
Mark Underwood
Head of Portfolio: Legal, Risk & Governance
Ground Floor
20 Finsbury Street
2017 Winner of the ‘707 £7 942
Global Postal
Award for
Customer
Experience
Mobile number}
WBD_001118.000001
WBONO001248
WBON0001248
From: Andrew Parsons is
Sent: 31 May 2018 19:39
To: Rodric Williams
>; Jane MacLeod
Melanie Corfield ¢
Subject: Skeleton arguments [B
126896945]
All
Please find attached each parties' skeleton arguments for the CMC next week. Most of this was expected. There was
one surprising paragraph in the Claimant's skeleton:
39. The likely aggregate value of the case is estimated to be of the order of £80 to £90 million (or in excess thereof,
subject to further quantum analysis and formulation).s1 The Claimants have not been directed to produce detailed
schedules of loss, though the Schedules of Information contain detailed information on relevant heads of loss. The
range given here derives from the Claimants’ solicitors’ analysis of the information contained in the Schedules of
Information. By its nature, it is an estimate based upon present information. There are inherent difficulties to setting
out the quantum of these claims at this stagessand the figures should be relied upon solely as a suitable guide for the
purposes of proportionality considerations in costs budgeting.
This is the first time that we have had any aggregated claim valuation (and this is much lower than the total of their
SOls).
A few thoughts:
Mel — just FYI in case this is reported in the press.
Rod — do you need to tell UKGI about this?
Mark — do we need to tell the auditors?
Kind regards
Andy
WBD_001118.000002
WBONO001248
WBON0001248
Andrew Parsons
Partner
Womble Bond Dickinson (UK) LLP.
WOMBLE womblebonddickinson.com
BOND
DICKINSON v in]
Please consider the environment! Do you need to print this email?
“ply is authorised
‘SoH aS POSBTe and delete any
unlawful, Information about how
The information in this
ail and a
copies. Unauthorised use, dissemination, distribution, publication or copyin;
‘we use personal data is in our Privacy Policy on our website
to access this e
Any files attached to this e-mail will have been checked by us with virus detection software before transmission. Womble Bond Dickinson (UK) LLP accepts no liability for
any loss or damage which may be caused by software viruses and you should carry out your own virus checks before opening any attachment.
Content of this email which does not relate to the official business of Womble Bond Dickinson (UK) LLP, is neither given nor endorsed by it.
This email is sent by Womble Bond Dickinson (UK) LLP which is a limited liability partnership registered in England and Wales under number OC317661. Our registered
office is 4 More London Riverside, London, SEI 2AU, where a list of members’ names is open to inspection. We use the term partner to refer to a member of the LLP, or an
Dur VAT registration number is GB123393627
employee or consultant who is of equivalent standi
Womble Bond Dickinson (UK) LLP is a member of Womble Bond Dickinson (International) Limited, which consists of independent and autonomous law firms providing
services in the US, the UK, and elsewhere around the world. Each Womble Bond Dickinson entity is a separate legal entity and is not responsible for the acts or omissions of,
nor can bind or obligate, another Womble Bond Dickinson entity. Womble Bond Dickinson (International) Limited does not practice law. Please see
www.womblebonddickinson.com/legal notices for further details
Womble Bond Dickinson (UK) LLP is authorised and regulated by the Solicitors Regulation Authority.
Joba pd oid Ia iol SSIS ISS ID ISDS ADS SDEI ISD SE SIDI SDIS DSIRE SEG SI ADI
This email and any attachments are confidential and intended for the addressee only. If you are not the
named recipient, you must not use, disclose, reproduce, copy or distribute the contents of this
communication. If you have received this in error, please contact the sender by reply email and then delete
this email from your system. Any views or opinions expressed within this email are solely those of the
sender, unless otherwise specifically stated.
POST OFFICE LIMITED is registered in England and Wales no 2154540. Registered Office: Finsbury
Dials, 20 Finsbury Street, London EC2Y 9AQ.
SIE CISISIOICIC ISIC ICICI CCI A CAE CSI RCA IR ECAR EAA oR A IK A AR EC AR EA A
WBD_001118.000003