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From: Andrew Parsons {
To: Anthony de Garr Robinson‘
Subject: RE: Board speaking note [WBDUK-AC.FID26896945]
Date: Fri, 15 Feb 2019 20:41:28 +0000
Importance: Normal
Attachments: _DOC_153532945(1) UPDATED _Risk_Assessment_Table_-_3_January_2019.docx;
_DOC_154310620(1)_Horizon_-_Risk_Assessment_Table_-_18_Feb_2019.DOCX
Inline-Images: image001.png; image002.png; image003.png; imagef40588.PNG; imaged4243d.PNG;
imageb4cdb9.PNG
Tony
I have a confession... before the Common Issues trial I took your beautiful Merits Opinion and converted it into risk
assessment table. Nothing makes you feel more valued more than having your hard work reduced to Red, Amber and
Green boxes! I suspect you see this as heresy but the PO board wanted a simplified version that they could use to
plan risk mitigation strategies against an adverse outcome. It was then updated after the trial to show where our views
had changed. I've attached a copy for info only — it will probably make you scream!
PO have asked for a similar thing for the HIT. My first draft is attached. I'm sending this to you for info, because it will
be discussed at the board on Thursday. To be clear, I'm not asking you to endorse this — I appreciate that is asking too
much of you and it is somehow easier for me to provide this assessment as a solicitor than you as leading Counsel.
That said, any comments appreciated. If possible, we should try to dovetail this to what you may say at the board next
week.
Yours, with much shame....
Andrew Parsons
Partner
Womble Bond Dickinson (UK) LLP.
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From: Anthony de Garr Robinson
Sent: 15 February 2019 12:08
To: Andrew Parsons
Subject: RE: Board speaking note
Thanks, Andy. I'll look at this tomorrow and let you know what I think, probably on Monday.
You absolutely don't need to worry about any risk of putting words into my mouth!
Tony
Sent: 15 February 2019 12:04
To: Anthony de Garr Robinson
Subject: Board speaking note
Tony
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I hope that this is helpful rather than inappropriate — I've bashed out a "starter for 10" speaking note for the board next
week.
Feel free to amend, delete or totally disregard as you see fit, but I hope this gives you a flavour of what I think is
needed. If anything, this might too much detail.
One to discuss next week perhaps.
A
Andrew Parsons
Partner
Womble Bond Dickinson (UK) LLP
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