WBONO001311
WBON0001311
From: Owain Draper {
To: Gideon Cohe:
Ce: David Cavende:
Subject: Re: Statement [WBDUK-AC.FID26896945]
Date: Thu, 23 Aug 2018 16:16:05 +0000
Importance: Normal
ndrew Parsons
I think it got deleted by accident. I agree it should go back in.
From: Gideon Cohen{_~
Date: Thursday, 23 August 2018 at 16:57
To: Andrew Parsons
Ce: David Cavender
Subject: Re: Statement [WBDUK-AC.FID26896945]
Ok, in that case happy to retain. If it was my deletion I obviously didn't realise the ramifications!
On 23 Aug 2018, at 18:53, Andrew Parsons {
wrote:
Another one...
You've also deleted footnote 23 in para 88, regarding remote access. If we do not cover remote access, then
the entire statement needs to changed, because the statement is premised on the notion that SPMRs have
control over their accounts. That point is not 100% true, due to the remote access argument, but is 99.99%
true so we need to explain the remote access concept otherwise AVDB won't be telling the truth.
Given the sensitivities on this point, we need to cover it off.
Thoughts please?
A
Andrew Parsons
Partner
Womble Bond Dickinson (UK) LLP
Stay informed: sign up to our e-alerts<https://www.womblebonddickinson.com/uk/preferences>
<image2d9511.PNG>
WBD_001181.000001
WBONO001311
WBON0001311
womblebonddickinson.com<http://www.womblebonddickinson.com>
<imagee26ad3.PNG><http://www.twitter.com/wbd_uk>
<image5d37f5.PNG><https://www.linkedin.com/company/womble-bond-dickinson-uk-Ip/>
From: Gideon Cohen [mailto:i~
Sent: 23 August 2018 16:07
To: Andrew Parsons
Cc: David Cavender; Owain Draper
Subject: Re: Statement
Understood.
On 23 Aug 2018, at 18:06, Andrew Parsons <
I <mailtoy_
Ok — I'm putting these back in but in simplified form. There is nothing secret about any of these — they are
all publicly available points of law.
A
Andrew Parsons
Partner
Womble Bond Dickinson (UK) LLP
d:
Stay informed: sign up to our e-alerts<https://www.womblebonddickinson.com/uk/preferences>
<image7fad14.PNG>
womblebonddickinson.com<http://womblebonddickinson.com><http://www.womblebonddickinson.com>
<imagec62fee.PNG><http://www.twitter.com/wbd_uk> <image9edc62.PNG>
From: Gideon Cohen [mailtoj_~
Sent: 23 August 2018 16:02
To: David Cavender
Ce: Andrew Parsons; Owain Draper
Subject: Re: Statement
Those were exactly my thoughts.
On 23 Aug 2018, at 17:54, David Cavender a
WBD_001181.000002
WBONO001311
WBON0001311
<mailto!. _p<mailto{
Andy,
Gideon deleted those paragraphs.
I assume he did so on the basis that whilst the earlier paragraphs in that section are generic (and therefore
could be said to have been reasonably in the contemplation of the parties at the time of contracting ) it would
be more difficult to justify the later more granular and specific examples (which have been deleted) on the
same basis.
Gideon — is this correct ?
Best,
Dz.
David Cavender Q.C.
<image001.jpg>
One Essex Court
Temple
London EC4Y 9AR
Direct dial:
Fax number:
Mobile:
www.oeclaw.co.uk<http://www.oeclaw.co.uk><http://www.oeclaw.co.uk><http://www.oeclaw.co.uk/>
The contents of this email are CO TIAL and may be PRIVILEGED. If you are not the intended
and delete this email.
Sent: 23 August 2018 15:48
WBD_001181.000003
WBONO001311
WBON0001311
<mailtof”
<mailto: :
Subject: RE: Statement
David
Quick question... why did you delete the section on regulatory requirements at para 62 onwards?
This is a major pressure on POL's business and drives lots of its pressures. Indeed, Post Office is probably
the most highly regulated business in the country.
A
Andrew Parsons
Partner
Womble Bond Dickinson (UK) LLP
d:
m:
t
e
“Kmailtof GRO. “><mailtof GRO
Stay informed: sign up to our e-alerts<https://www.womblebonddickinson.com/uk/preferences>
<image002.png>
womblebonddickinson.com<http://womblebonddickinson.com><http://womblebonddickinson.com>
<http://www.womblebonddickinson.com>
<image003.png><http://www.twii wl >
<image004.png><https://www.linkedin.com/company/womble-bond-dickinson-uk-Ip/>
From: David Cavender [mailto:
Sent: 23 August 2018 10:30
To: Andrew Parsons
Cc: Owain Draper; Gideon Cohen
Subject: RE: Statement [WBDUK-AC.FID26896945]
Dear Andrew,
I attach a tracked version of Angela’s statement which includes comments from Gideon and from me. These
WBD_001181.000004
WBONO001311
WBON0001311
(relatively few) comments have been made upon the clean version provided. My comments on admissibility
have also been discussed with Owain.
Best,
D.
David Cavender Q.C.
<image001.jpg>
One Essex Court
Temple
London EC4Y 9AR
Direct dial:
Switchboard:
Fax number:
Mobile:
The contents of this email
recipient, please telephon
From: Andrew Parsons [mailto}
Sent: 20 August 2018
To: David Cavender <
Subject: FW: Statement [WBDUK-AC.FID26896945]
David
As discussed earlier — any comments appreciated on Angela's statement.
WBD_001181.000005
WBONO001311
WBON0001311
Andrew Parsons
Partner
Womble Bond Dickinson (UK) LLP
GRO. ><mailto:! GRO
Stay informed: sign up to our e-alerts<https://www.womblebonddickinson.com/uk/preferences>
<image002.png>
womblebonddickinson.com<http://womblebonddickinson.com><http://womblebonddickinson.com>
<http://www.womblebonddickinson.com>
<image003.png><http://www.twitter.com/wbd_uk>
From: Andrew Parsons
Sent: 20 August 2018 16:32
To: 'Angela Van-Den-Bogerd'; Rodric Williams
Ce: Victoria Brooks; Ivan Roots
Subject: RE: Statement [WBDUK-AC.FID26896945]
Angela
Please find attached your updated statement (+ a comparison showing the changes from the original version
sent to you). This includes your comments, further amendments from Counsel and some comments from me.
Once you've had a chance to review, it might be easiest for us to setup a call to go through the remaining
points.
Thanks
Andy
From: Angela Van-Den-Bogerd [mailto:angela. van-den-bogerd:
Sent: 17 August 2018 16:59 =
To: Andrew Parsons; Rodric Williams
Cc: Victoria Brooks
Subject: RE: Statement
WBD_001181.000006
WBONO001311
WBON0001311
Importance: High
Andy
Please find attached the latest version of my statement. This is still work in progress as I have some queries
out with the business. I will pick this up again on Monday when I should have the information I’ve
requested. In the meantime I’m returning to you as I have some comments for you/WBD that I’ve tracked —
could you review and let me have a response/update please. Where we’ve referenced other witness
statements it would be helpful if I could see them. Is this possible?
Thad intended to be on leave next week but in light of this being unfinished I am now in work on Monday
and will pick up for the rest of the week to finalise this statement ahead of submission deadline.
Thanks,
Angela
<image005.png>
Angela Van Den Bogerd
People Services Director
Ist Floor,Ty Brwydran,
Atlantic Close,Llansamlet
Swansea SA7 9FJ
Confidential Information:
This email message is for the sole use of the intended recipient(s) and may contain confidential and
privileged information. Any unauthorised review, use, disclosure or distribution is prohibited. If you are not
the intended recipient please contact me by reply email and destroy all copies of the original message.
From: Andrew Parsons [mailto:
Sent: 08 August 2018 21:15
20
Subject: Statement
Angela
Please find attached the latest draft of your statement. All comments welcomed. This has been restructured
from the last version you saw, added a number of new sections and have cut out some material to make it
shorter / where we have considered material to be to far over the line of admissibility.
Rod — your comments also welcomed. In particular, there are some comments marked in green for your
attention.
WBD_001181.000007
WBONO001311
WBON0001311
Kind regards
Andy
Andrew Parsons
Partner
Womble Bond Dickinson (UK) LLP
d:
m:
t
e
Stay informed: sign up to our e-alerts<https://www.womblebonddickinson.com/uk/preferences>
<image002.png>
womblebonddickinson.com<http://womblebonddickinson.com><http://womblebonddickinson.com>
<http://www.womblebonddickinson.com>
<image003.png><http://www.twitter.com/wbd_uk>
Please consider the environment! Do you need to print this email?
The information in this e-mail and any attachments is confidential and may be legally privileged and
protected by law. angela. van-den-bogerd)
' GRO ><mailto! RO, : k><mailto
nly is authorised to access this e-mail and any attachments. If
GRO Kmailt .
you are not
~ as soon as possible and
delete any copies. issemination, distribution, publication or copying of this
communication or attachments is prohibited and may be unlawful. Information about how we use personal
data is in our Privacy Policy<https://www.womblebonddickinson.com/uk/privacy-policy> on our website.
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
WBD_001181.000008
WBONO001311
WBON0001311
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,
SE1 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 employee or consultant who is of equivalent standing. Our VAT registration
number is GB123393627.
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<http://www.womblebonddickinson.com/legal>
<http:/Avww. womblebonddickinson.com/legal><http://www.womblebonddickinson.com/legal> notices for
further details.
Womble Bond Dickinson (UK) LLP is authorised and regulated by the Solicitors Regulation Authority.
Jes eidcicidideici icici dai ickeck daicicici idiaicicicicicick iddcicick iedeok icici aac acai ok cai aka ak
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.
Je SESSA SI GSS EE SIC ES AEGIS GRC ISIE IAGIACK AICI ACR ACI ACCA Ac aaa R ca i ko acai
This email has been scanned by the Symantec Email Security.cloud service.
For more information please visit http://www.symanteccloud.com
This email has been scanned by the Symantec Email Security.cloud service.
For more information please visit http://www.symanteccloud.com
This email has been scanned by the Symantec Email Security.cloud service.
For more information please visit http://www.symanteccloud.com
This email has been scanned by the Symantec Email Security.cloud service.
For more information please visit http://www.symanteccloud.com
This email has been scanned by the Symantec Email Security.cloud service.
For more information please visit http://www.symanteccloud.com
WBD_001181.000009
This email has been scanned by the Symantec Email Security.cloud service.
For more information please visit http://www.symanteccloud.com
This email has been scanned by the Symantec Email Security.cloud service.
For more information please visit http://www.symanteccloud.com
This email has been scanned by the Symantec Email Security.cloud service.
For more information please visit http://www.symanteccloud.com
WBONO001311
WBON0001311
WBD_001181.000010