WBON0001710 - Email from Andrew Parsons to Gavin Matthews and Simon Richardson re FW: Response to Brian Altman QC’s Interim Report

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"Parsons, Andrew" GR fe)

"Matthews, Gayin'"
H GRO >

FW: Response to Brian Altman QC's Interim Report.

Thu, 15 Aug 2013 08:20:24 +0100

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RESPONSE_TO_BRIAN_ALTMAN_QC'S_INTERIM_REPORT pdf;
REVIEW_PROTOCOL.pdf; DISCLOSURE_-_ DUTY_TO_RECORD_& RETAIN.pdf
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, "Richardson, Simon"

FYI re Brain Altman

and criminal issues.

Attached is CK's response to BAQC's advice.

Susan and Hugh called me on Tues around their disclosure duty. CK are essentially saying that POL needs to track
and investigate every single complaint, query or issue about Horizon in order to comply with criminal disclosure duties.
This is obviously very difficult, if not impossible, for POL to achieve.

POL are going to ask CK for an alternative proposal. They're also going to check with CK whether POL is obliged to
investigate every query or whether it is just required to disclose what it knows and not look any deeper.

They also want to put the same questions to BAQC.

When BAQC is back, there needs to be a con with CK (see CK's note) and a separate con with just POL.

Nothing we can do until BAQC is back.

Gavin — we can pick this up when you're back from hols.

A

Andrew Parsons

Senior Associate

for and on behalf of Bond Dickinson LLP

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From: Susan Crichtor, GRO. —
Sent: 13 August 2013 18:28

To: Parsons, Andrew

Subject: FW: Response to Brian Altman QC's Interim Report.

Thought you might be interested to see what had started that particular “hare” running!

Susan Crichton I General Counsel

1 Floor, Central Wing, 148 Old Street, London, EC1V 9HQ

susan.crichtoy

From: martin smith { GRO
Sent: 13 August 2013 16:33

To: Susan Crichton

Subject: Response to Brian Altman QC's Interim Report.

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Susan,

Please find attached Harry Bowyer's Response to Brian Altman QC's Interim Report. I asked Harry
to draft the response in Simon Clarke's absence given the urgency of the situation.

I would be grateful if Harry's Response could be sent to Brian Altman QC together with the Review
Protocol and Simon Clarke's Advice on Disclosure.

Kind regards,

Martin.

Martin Smith

martin.smit ‘I
martin.smith GRO j
Direct),

CartwrightKing

me solic TroRs —
Nottingham I Birmingham I Derby I LeicesterI Sheffield I Newcastle Gateshead

Majority House, 51 Lodge Lane, Derby, DEI 3HB

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