r!tiank you for your letter dated 15th April 1991, relating to the tragic events at Hillsborough on Saturday, 15th April 1989.

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1 our Ref: GHM/JB/D15 19th April 1991 Messrs. Russell Jones & Walker, Solicitors, Quebec House, 9 Quebec Street, Leeds. LSI 2HA Re: Andrew Barlow r!tiank you for your letter dated 15th April 1991, relating to the tragic events at Hillsborough on Saturday, 15th April As you may well be aware, the Chief Constable of South Yorkshire Police has agreed with the Steering Committee, representing Claimants forming the Hillsborough Group, to pay damages, without admission of liability, to all Claimants, whether or not they form part of the group, subject to any remoteness of damage issues in nervous shock cases. We have been advised by air Solicitors that in these circumstances all claims should be referred to Mr. Ken Holmes of the Municipal Mutual Insurance Company Limited at Park Fouse, 57/59 Well Street, Bradford, BBl PS!. Ifre Municipal Mutual are the Insurers for South Yorkshire Police and Mr. Holmes is responsible for the co-ordination of all claims. M y queries regarding the agreement reached with the Steering Committee should be addressed to him. A copy of your letter, together with a copy of this letter in reply has been passed to the club's solicitors, Messrs. Davies Arnold Cooper of 6-8 Bouverie Street, London, EC4Y 8DB (ref: 117). Yours sincerely, G.H. Mackrell Secretary

2 RUSSELL JONES & WALKER SOLICITORS Quebec House 9 Quebec Street Leeds LSI 2HA Telephone: Fax: DX Sheffield Wednesday Football Club, Hillsborough, SHEFFIELD, South Yorkshire. S6 1SW Your Ref: Our Ref: SA/TG/BARL0W/ Date: 15th April 1991, re : Hillsborough Football Tragedy - 15th April 1989 We are acting for Andrew Barlow of 41 Crawford Road, Norton Lees, Sheffield in respect of personal injury suffered on the 15th April 1989 at the Hillsborough Football tragedy during the course of his employment with the South Yorkshire Pol ice. Damages are claimed for negligence and breach of statutory duty. Yours fai RUSSELL J ny. & WALKER J.M. W ebber T.D.B. Taylor I.J. Walker A.F. Wrhitehead R. M. A bbey I.R. Fletcher G.C. Solly W.D. O Brien R.A. Plane P.J. Davis R.C. Langton D.R. Louw J.L. Raskin S. Raskin E.J.O. C ooper S.G. Ingram N.B. H olroyd J.C. ClarkeAVilliams S.L. W ebb D.A.B. Twigg P R. Ashurst J.M. Pirrie S J.N. Allen I.F. Walker Consultants:].^. Walker J.M.P. Colman Regulated by T h e Law Society in the conduct of Investment Business L O N D O N LEEDS BIRM INGH AM BRISTO L M A N C H E ST E R

3 Our Ref: GHM/JB/D15 19th April 1991 Messrs. Deacon Goldrein Green, Solicitors, Princes Buildings, 81 Dale Street, Liverpool. L2 2JA Re: Thank you for your letter dated 15th April 1991, relating to the tragic events at Hillsborough on Saturday, 15th April As you nay well be aware, the Chief Constable of South Yorkshire Police has agreed with the Steering Committee, representing Claimants forming the Hillsborough Group, to pay damages, without admission of liability, to all Claimants, whether or not they form part of the group, subject to any remoteness of damage issues in nervous shock cases. We have been advised by our Solicitors that in these circumstanoes all claims should be referred to Mr. Ken Holmes of the Municipal Mutual Insurance Company Limited at Park House, 57/59 Well Street, Bradford, BB1 FSM. The Municipal Mutual are the Insurers for South Yorkshire Police and Mr. Holmes is responsible for the co-ordination of all claims. Any queries regarding the agreement reached with the Steering Committee should be addressed to him. A copy of your letter, together with a copy of this letter in reply has been passed to the club's solicitors, Messrs. Davies Arnold Cooper of 6-8 Bouverie Street, London, EC4Y 8DD (ref: 117). Yours sincerely, G.H. Mackrell Secretary

4 Deacon BGoldrein 8 Green Princes Buildings, 81 Dale Street, Liverpool, Merseyside, L2 2JA. Tel Fax D X LIVERPOOL David Deacon Martin Green Richard Grimes Andrew MacFarlane Stephen W ilde Michael Coghlan Patricia Reynolds Martin Bracey Graham Cunliffe Andrew Gillespie Robert Ollerhead Christopher Broad Alan Sprince Neville Goldrein Consultant Your ref Ou r ref CD.JP.TO.EVANS Date 15th April 1991 When calling or telephoning please ask for:- Cost Department Dear Sirs Re: We have been instructed on behalf of of as a result of the incident at the Leppings Lane end of the Hillsborough Ground on the 15th April 1989, in which she watched the horrific experiences of listening, hearing and seeing the same on the media. From the information in our possession it would appear that the incident was caused and/or contributed to by the negligence of your servants or agents and/or breach of duty on your part and we should be grateful to hear from you that you are prepared to compensate our Client for her loss and injury. May we respectfully suggest you pass this letter to your Insurance Company. Yours fgfl-thj^ully Sheffield Wednesday Football Club Pic R/0 Hillsborough SHEFFIELD S6 1SW. ALSO AT LIVERPOOL: Peel House 5 Harrington Street L2 9XP Tel Park Road Dingle L8 6SE Tel Breck Road Everton L5 6PT Tel Broadway Norris Green L11 1BX Tel Derby Lane O ld Swan L13 3DL TeJ Prescot Road O ld Swan L13 5UR Tel Liverpool Road Page Moss L36 3RG Tel South Parade Speke L24 2SF Tel The Croft Stockbridge Village L28 1NR Tel Lodge Lane Toxteth L8 0QE Tel County Road Walton L4 3QN Tel South Road Waterloo L22 0N D Tel WIRRAL: 110Wallasey Road Wallasey L44 2AE Tel Bridge Street Neston L64 9UJ Tel Hoylake Road The Cross Moreton L46. OSJ Tel Chester Road Little Sutton L66 3RA Tel Allport Chambers 13/19 Allport Lane Bromborough L62 7HH Tel A Telegraph Road Heswall L60 OAF Tel Poulton Road Seacombe Wallasey L44 6LB Tel This firm is regulated by the Law Society in the conduct of investment business

5 Sheffield Wednesday Football Club pic RtA W ith compliments Hillsborough, Sheffield S6 1SW. Telephone: (0742) Telegrams: Wednesday Sheffield 6. Telex No WEDNES Fax No Registered in England No

6 Cur Ref: GHM/JB/D15 I2th March 1991 Messrs. J. Prodsham & Sons, Solicitors, 13/15 Atherton Street, Prescot, Merseyside. L34 5QW Re: Thank you for your letter dated 11th March 1991, relating to the tragic events at'hillsborough on Saturday, 15th April As you may well be aware, the Chief constable of South Yorkshire Police ha agreed with the Steering Coanittee, representing Claimants forming the Hillsborough Group, to pay damages, without admission of liability, to all claimants, whether or not they form part of the group, subject to any remoteness of daaaage issues in nervous shock cases. We have been advised by our Solicitors that in these circumstances all claims should be referred to Mr. Ken Holmes of the Jftinicipal Mutual Insurance Company Limited at Park House, 57/59 Well Street, Bradford, BB1 PSM. The Municipal Mutual are the Insurers for South Yorkshire Police and Mr, Holmes is responsible for the co-ordination of all claims. Any queries regarding the agreement readied with the Steering Ccusaittee should be addressed to him. A copy of your letter, together with a copy of this letter in reply has been passed to the club's solicitors, Messrs. Davies Arnold cooper of 6-8 Bouverie Street, London, EC4Y 8DD (refs 117). Yours sincerely, G.H. Mackrell Secretary

7 ALSO AT ST. HELENS J. FRODSHAM & SONS SOLICITORS OUR REF ASK FOR YOUR REF DATE DP.SJC. MR PORTER 11th March /15 ATHERTON STREET, PRESCOT, MERSEYSIDE. L34 5QW TELEPHONE: and DX PRESCOT A. C. FRODSHAM LL.B. - Notary Public D. M. PORTER LL.B. A. C. SHE1L H. M. MORRIS LL.B. D. V. E. FITZGERALD LL.B. Sheffield Wednesday Football Club, R/O Hillsborough, Sheffield, S6 ISW BE: We have been instructed on behalf of in regard to a claim for compensation for personal injuries arising out or the Hillsborough Disaster on 15/4/1989. We have only just received instructions. From the information in our possession it would appear that the incident was caused or contributed to by the negligence of your servants or agents and/or by a breach of duty on your part and we should be glad to hear from you that you are prepared to compensate our client for his loss and injury. May we respectfully suggest that you pass this letter through to your Insurance Company. Yours faithfully, J. FRODSHAM & SONS (In association with): Messrs. Lloyd Jones & Travers, Old Bank Road, Widnes, Cheshire. WAS 6EA DX WIDNES 2. Telephone No This firm is regulated by the Law Society in the conduct of Investment business

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