WBONO0001658
WBON0001658
From: "Deas, Emma" <}
To: Andrew Parsons
GRO “"b, Rodric Williams
_..P, "Emanuel, Catherine"
Subject: RE: GLO Board Paper - (05.11.19) (004).docx
Date: Mon, 11 Nov 2019 22:13:50 +0000
Importance: Normal
Attachments: GLO_Board_Paper_-_(05.11.19) (004) _- Amended.docx
Inline-Images: image001.png; image002.png; image003.png
All,
Please see attached with our proposed changes. The changes of substance are:
To update the position on exchange of lead Claimant criteria — further to Freeths letter late last week we have
agreed to write to the Court re: the move to 12 December 2019 with a further CMC in January. I have not
amended the appendices bearing in mind we do need to write to the Court in respect of this change and the
further CMC.
The amendment to the numbers on the Claimants’ post termination losses.
T have also included Andy's suggested changes.
Kind regards,
Emma
>; Emanuel, Catherine
Rod
Just one point from me which is that I wouldn’t say that we are only disputing the unorthodox claims. The
claim for loss of profits is perfectly ordinary, the Cs are just adopting an interpretation of the law that
maximises their recoverable losses.
WBD_001528.000001
WBONO0001658
WBON0001658
If you agree, I would change the conclusion to read “unorthodox or potentially significant”.
And in the body of the report at the top of page 4, I would delete the word unorthodox so it just says “the
most contentious claims”.
Andrew Parsons
Partner
Womble Bond Dickinson (UK) LLP.
‘Sign up for legal updates, e-newsletters and event invitations
WOMBLE womblebonddickinson.com
BOND
DICKINSON © @)
From: Rodric Williams GRO. P
Sent: Monday, November 11, 2019 9:08 pm
To: andrew.parsons; Emanuel, Catherine; Deas, Emma
Subject: GLO Board Paper - (05.11.19) (004).docx
Andy, Emma, Kate,
With apologies for the lateness, but could you please take a look at the attached report to the Board
Subcommittee, which provides an update on the Group Litigation and — more importantly — an overview of
the approach being taken to the Further Issues Defences so that we can “bring them along” with us.
Could I please have your comments back tonight? I apologise for asking this, but I need to get it to our
Company Secretary tonight, so it can be distributed to the SubCo members ahead of the (brought forward)
meeting on Wednesday.
WBD_001528.000002
WBONO0001658
WBON0001658
Thanks, Rod
ASTER CSICIC I ICICI CCIE I CASI A EIR ACAI CHR ECAR CAH A HOR CA IK AAR ECAR I ER
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 CSI EI ICICI ICICI CASI A EIR CII CIR ECAR CAIN HOR CA I OA AOR ECR OE I A RO
“Post Office Limited is committed to protecting your privacy. Information about how we do this can be
found on our website atwww.postoffice.co.uk/privacy”
Please consider the environment! Do you need to print this email?
ed by law. emma.deasf
dissemination, distribution, publication or copying of this communication or attachments is profi
our Privacy Policy, on our website
ibiieA ad Way be unlawful. Information about how we use personal data is in
Any
es 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
loss or damage which may be caused by software viruses and you should carry out your own virus checks before openi
fachment.
Content of this email which does not relate to the offi
ial 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 0C317661. 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/egal notices for further details,
Womble Bond Dickinson (UK) LLP is authorised and regulated by the Solicitors Regulation Authority
Herbert Smith Freehills LLP and its subsidiaries and Herbert Smith Freehills, an Australian Partnership, are separate member firms of the
international legal practice known as Herbert Smith Freehills.
This message is confidential and may be covered by legal professional privilege. If you are not the intended recipient you must not disclose or
use the information contained in it. If you have received this email in error please notify us immediately by return email or by calling our main
switchboard onf” ind delete the email.
Further information is available from www.herbertsmithfreehills.com, including our Privacy Policy which describes how we handle personal
information.
Herbert Smith Freehills LLP is a Limited Liability Partnership registered in England and Wales with registered number 0C310989. It is authorised
and regulated by the Solicitors' Regulation Authority of England and Wales whose rules can be accessed via www.sra.org.uk/code-of-
conduct,page. A list of the members and their professional qualifications is open to inspection at the registered office, Exchange House,
Primrose Street, London EC2A 2EG. We use the word partner of Herbert Smith Freehills LLP to refer to a member of Herbert Smith Freehills LLP,
or an employee or consultant with equivalent standing and qualifications. Herbert Smith Freehills LP's registration number for Value Added Tax
in the United Kingdom is GB 927 1996 83.
WBD_001528.000003