From:
To:
Ce:
Subject:
Date:
Importance:
Attachments:
Inline-Images:
WBON0001493
WBON0001493
Tom Beezer
David Cavender
Gideon Cohen: GRO Amy Prime! GRO 1
Andrew Parsons} GRO
RE: URGENT: Litigation Options - CONFIDENTIAL AND SUBJECT TO LEGAL
PRIVILEGE. [WBDUK-AC.FID26896945]
Fri, 15 Mar 2019 20:46:18 +0000
Normal
draftPOL.DOCX
imageb1821c.PNG; imagedcde97.PNG; image90d236.PNG
All
See attached.
I may be on Jane's wavelength — I may not be...
I took Jane's few questions verbatim and addressed them as best I could with the info know to me or that I can ferret
out. I limited myself to two pages.
All comments welcomed.
Andy, I followed Nick B's format and warning at the header of the doc. Normal ? Useful ?
All - be as harsh as you like. I am not proud.
I would like to get something out to Jane early tomorrow — 10am or earlier.
I hope I have broken the back of it for you and it is quick and easy to comment...
Cheers
Andy/Primer — note this is NOT a doc’ on the system yet it is from my desktop...
WBD_001363.000001
WBON0001493
WBON0001493
Tom Beezer
Partner
Womble Bond Dickinson (UK) LLP
Stay informed: sign up to our e-alerts
Join us for Disrupting Disputes 2.0
20 March 2019 at the British Library
Book your place here
WOMBLE womblebonddickinson.com
BOND
DICKINSON @&) (in)
From: David Cavender
Sent: 15 March 2019 19:
To: Tom Beezer
Cc: Gideon Cohen; Amy Prime; Andrew Parsons
Subject: Re: URGENT: Litigation Options - CONFIDENTIAL AND SUBJECT TO LEGAL PRIVILEGE. [WBDUK-
AC.FID26896945]
Tom,
Many thanks for this. Sounds like a plan.
I can attend the board meeting if necessary.
Best
Dz.
Sent from my iPhone
On 15 Mar 2019, at 18:50, Tom Beezeri_ __ GRO
wrote:
David, Gideon
The plan is that I cobble together a short note addressing Jane's points (see below — addressing the first set of
points anyway, perhaps not the financial impact questions on which I have no info') and then send that out to
you & Andy P later tonight or early tomorrow morning.
Andy will be in the land of the living again tomorrow am and so will comment and make into the kind of
note we would actually send to POL (as I am new into all of this and kind of shooting blind) and it would be
great if you could cast your eve over it too. It won't be long as it needs to be really punchy and accessible for
non-legal Board members. Either AP or I will send to Jane by (say) 10am tomorrow. This e mail is just to
give you a heads up on that, and if you are around to review, then great. If not then no worries.
David — there is talk of a POL Board Meeting on Monday afternoon at some point. 5pm has been mentioned.
Jane has not said it yet (and may not) but I can see the request coming that you (and perhaps me too) join
that meeting. If that request comes, are you free to do that ? I think this is the meeting at which they decide
WBD_001363.000002
WBON0001493
WBON0001493
yes/no on recusal application.
I have asked Rob at OEC (at Jane's request) to see if Lord Neuberger were available in theory to dial in.
I'll be in touch with a draft later.
Kind regards
Tom Beezer
Partner
Womble Bond Dickinson (UK) LLP
Stay informed: sign up to our e-alerts<https://www.womblebonddickinson.com/uk/preferences>
Join us for Disrupting Disputes 2.0
20 March 2019 at the British Library
Book your place here<https://www.womblebonddickinson.com/uk/insights/events/disrupting-disputes-20>
<imageb244c1.PNG><http://>
womblebonddickinson.com<https://www.womblebonddickinson.com>
<image966575.PNG><https://www.twitter.com/wbd_uk> <image6e0530.PNG>
<https://www.linkedin.com/company/womble-bond-dickinson-uk-Ip/>
From: Tom Beezer
Sent: 15 March 2019 15:52
To: Andrew Parsons; David Cavender{
Cc: Amy Prime; Gideon Cohen‘
Subject: RE: URGENT: Litigation Options - CONFIDENTIAL AND SUBJECT TO LEGAL PRIVILEGE.
[WBDUK-AC.FID26896945]
Parson...lets discuss this when you surface at some point.
David — copied to you too as we may need some input from you as my bank of historic knowledge on all this
is thin to put it kindly !
Jane says:
We are setting up a board call for Spm Monday, and I will need to issue a ‘plain English’ paper to the Board
over the weekend to get them familiarised with the issue. In particular that will need to address:
* Why we are considering a recusal application
WBD_001363.000003
WBON0001493
WBON0001493
* What the application (if successful) will achieve
+ Risks of not proceeding
+ Prospects of success: what advice have we received, who from
* Process & timing
In addition, the following Monday (25th) we have a scheduled Board meeting and I will need to be able to
brief in more detail on an appeal, recognising that it will still be a work in progress. However as we don’t
have another scheduled Board until end May, it is likely that we will need the Board to endorse the appeal
strategy at end March, with a further approval meeting/call once the appeal grounds are finalised and we can
assess ‘risk’.
As mentioned I think that as part of the initial Appeal discussion, the board will want to understand the scale
of the financial risk of:
(a) not appealing (and therefore how many existing & historic contracts will be affected by the judgement?)
(b) appealing and losing (same as above?)
(c) appealing and winning — restores contracts to pre-judgement position
Recognising in each case that the consequences apply not just to the claimant group but to all postmasters on
those contracts types, and potentially, all those on other contract types but who have substantially the same
provisions.
I copy this to us all at this point to get us all thinking.
t
Please consider the environment! Do you need to print this email?
legally privileged and
tonly is authorised to access
The information in this e-mai
protected by law. deavenderi_
this e-mail and any attach
please notify tom.beezer; __ _ jas soon as possible and delete
any copies. Unauthorised use, dis: ination, di on, 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.
f you are not deavender'
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 employee or consultant who is of equivalent standing. Our VAT registration
number is GB123393627.
WBD_001363.000004
WBON0001493
WBON0001493
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> notices for further
details.
Womble Bond Dickinson (UK) LLP is authorised and regulated by the Solicitors Regulation Authority.
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_001363.000005