LCAS0000625
LCAS0000625
fr 13:41 FROM BOND PEARCE LLP PLYMOUTH P.a3
. - -
. : Inthe High Court of Justice .
List of documents: Oe te
standard disclosure
Notes Claim No. I HQ05x02706
© The rules relating to standard disclosure are contained Post Office Limited
in Part 31 of the Civil Procedure Rules. Claimant I Post Omce Crm
¢ Documents to be included under standard disclosure §)D3/348035.134 y
are contained in Rule 31.6 Defendant IMrLee Castleton I
= A document has or will have been in your control if you I !eve90 ren }
have or have had possession, or a right of possession, 7
of it or a right to inspect or take copies of It. Date 22 Nox me 20ck
Disclosure Statement an
‘
I, the above namad i
Claimant ) Defendant !
Party (if party making disclosure ia 8 company, firm or other organisation Identify here who the person making the
disclosure statement is and why he is the appropriate person to make it) '
1am the person with averall responsibility at Post Office Limited for this case.
A
!
state that I have carried out a reasonable and propartionate search to locate all the documents which lam
required to disclose under the order made by the court on (date of order) 9 March 2006
I did not search for documents:-
Gx] pre-dating [1 juiy 2003
[) located elsewhere than
Documents with accounting teams in Chesterfield, personal records held In Leeds,.tog rwith HSH
and NBSC call logs, transaction Information, Girobank and Inventory team in Leeds and Fujitsu.
(0 in categories other than
C for electronic documents
{[&] I carried out a search for electronic documents contained on or created by the following:
(ist what was searched and extent of search) :
(a) The electronic data we have searched for Is from an Electronic filling cabinet (EFC) which Has all
documents relating contractual Issues in one piace for ease of reference and retrieval. F
(b) The categories of electronic documents not searched (see next page) for Is either because Its not
believed such categories exist, or because such electronic documents (if any) would. not fall inder CPR
31.6,
: ;
N285 Btoncard discioaure (10.05) @Cre ce rs
own Coma be aayese I
[a , 7 6
22-NOU-2086 13:55 I GRO 3% P.a2
LC0227.0001
LCAS0000625
LCAS0000625
fr 13:41 FROM BOND PEARCE LLP PLYMOUTH . P.04
y i
#3] did not search for the following:~ :
4
: .
[1 documents created before 18/7/03 for financial docs . i
documents contained on or created by the [7] Claimant (() Defendant i
C1 Pcs [x] portable data storage media © .
( databases CO servers :
{x) back-up tapes DD off-site storage .
mobile phones EX] saptops “4
Ld
[x] notebooks {x} handheld devices °
[x] PDA devices i
t
documents contained on of oreated by the [[] Claimant [[] Defendant i
( mali files (© document files : ;
{x] calendar files [x] web-based applications : .
C spreadsheet files (2] graphic and presentation files ;
documents other than by reference to the following keyword(s)/concepts Fi .
(delete if your search was not confined to specific keywords or concepts) ‘
t
1 certify that I understand the duty of disclosure and to the best of my knowledge I have’ out that duty.
I further certify that the list of documents set out in or attached te this form, is a complete list’ all documents
which are or have been in my control and which I am obliged under the order to disclose. . *
J understand that I must inform the court and the other parties Immediately if any further documerit required to
be disclosed by Rule 31.6 comes into my contro! at any tima before the conclusion of the case,
CT thave not permitted inapection of documents within the category or class of documents (as set out below)
required to be disclosed under Rule 31(6)(b) or (c) on the grounds that to do so would be proorinae to
the Issues in the case.
Date bn [1 / 0%
Se ntathe oe
1207885,
‘ 77
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LC0227.0002
LCAS0000625
LCAS0000625
f= 13:41 FROM BOND PEARCE LLP PLYMOUTH P.85
' :
)
Uslandrumoer I have control of the documents numbered and listed here. I do not objact'té you
ere inagrweneet inspecting them/producing copies. 4
bundles cf 4
cccunsnetiorne 58¢ ettached list. ‘"
samme nature, @.9. :
invojcen) ® your
cantrol. which you do
‘n0k object to being
Inspected, Give a
short desctigtion
of each document
‘or bund ao that
can ba identified,
and way Hits kept
elsewhere i.6. with &
‘bank oF Bolicltor
Listens number I have control of the documents numbered and listed here, but I object to you
here, ss stove, inspecting them: « :
your contr wich Correspondence passing between the Claimant/Part 20 Defendant and thelr.sdicitors for the
you oboct ms bew'g purposes of this actlon, Instructions and opinions of counsel, drafts of pleadings and other’
poe stiay documentation settled by Counsel, Experts’ drafts and opinions and all other documents ota a
confidential nature brought into being for the purposes of this proposed actlork
i
4
Saywnstyor —_I object to you inspecting these documents because: 4
‘epjociions are ®
they are privileged. Tg
Ustand number) have had the documents numbered and listed below, but they are no. long in my. control
Jovenshedinesr — Originals of documents described as copies which are in the hands of recipients or
‘contol, butwnien —-tlost/destroyed.
you no longer heve. ‘
Fer each document t
listed, sey whee
Thwes teat in your
contol Bnd whers it
je now. }
}
4
$
14 , i
2 1237665 -
‘ ‘78
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LC0227.0003
LCAS0000625
LCAS0000625
Ue 13:41 FROM BOND PEARCE LLP PLYMOUTH P.@6
;
No, DOCUMENT. Dal
1 Horizon Message Store Various:
2. jorizon system user guide Varlous
3. Horizon Operations Manual Various "4 :
4. List of Software updates 01/2004: tp: 04/2004
5. Spreadsheet of stock remittances 01/2004 f 03/2004
6. Spreadsheet of errors brought to account 2003 to! 2004
Z. Spreadsheet of total daily cash declaration 01/2004 3
8. Spreadsheet of total dally cash declaration 02/2004
9. Spreadsheet of total dally cash declaration 03/2004 ¢
10. Spreadsheet of dally cash declarations by denomination 11/03/2084 to
31/03/2004
iL. Spreadsheet of notes delivered to the Marine Drive branch 18/07/2003 to
34/03/2004.
12. Spreadsheet of coin delivered to the Marine Drive branch 18/07/2093 to
31/03/2004
13, Spreadsheet of notes and coin delivered to the Marine Drive branch I 18/07/2003 to
34/03/2004
14. Dally procedures and Horizon Reports Edition 4/10/2005
15. Balance Procedure 03/2006 ¥
16. ubpostmasters Contract 09/3994 Edition
17. Amended Particulars of Claim 23/10/7006,
18. Oraer of Deputy Master Nussey on behalf of Master Fontaine 25/08/2006
19, Order of Master Turner 23/10/2006 : .
0. Notice of Trial 04/12/2006.
21. Notice of date for Returning Pre-Trial Checkliat 23/19/2006
22. Emall from John Jones to Catherine Oglesby 25/06/2004
23. Letter from Defendant to Cheryl Woodward Undated +
24, Letter from Defendant to Chery! Woodward 19/08/2004
2. Letter from Defendant to Cheryl Woodward 24/08/2004
26. Latter from Defendant to Cheryl Woodward 01/12/2004
27. Letter from Defendant to Cheryl Woodward 15/12/2094
28. Latter from Cheryl Woodward to Defendant. 15/12/2004
29. Letter from Defendant to Chery! Woodward 16/12/20D4
30. Interpartes solicitors Correspondence post dating the Claimant's first I 18/5/2004 onwards
disclosure list _ :
3412376083
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@s
P.
LC0227.0004