Fax
If any of this fax is missing or illegible
please telephone the number below
POL00069657
POL00069657
Band. learce
Bond Pearce LLP
Ballard House
West Hoe Road
Plymouth PL1 3AE
To: Mandy Talbot
cc:
Royal Mail Legal Services
Your ref:
From: Stephen Dilley
Our ref: S$JD3/KAK2/348035.134
Date: 22 November 2006
Number of pages:
VERY URGENT
Post Office
ited
Confident
Lee Castleton
nti
TipoRTANT = The Information in ths fax is confidential and may be legally privileged. If you are not the intended
recipient, please do not use, disclose, copy or distribute its contents. Instead, please notify the sender as soon
as possible and destroy the fax.
Bond Pearce LLP, a Limited Liabil
Registered office: 3 Temple Quay
Partnership. Registered in England and Wales number 0C311430.
remple Back East Bristol B51 6DZ. VAT number GB143 0282 07.
A list of members of Bond Pearce is open for inspection at the registered office. Regulated by the Law Society,
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www.bondpearce.com
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22 November 2006 Bond Pearce LLP
1 Ballard House
West Hoe Road
Plymouth PL 3AE
Mandy Talbot
Company Secretary's Office
Royal Mail Legal Services
Our ref:
$3D3/KAK2/348035.134
Your ref:
Dear Mandy
VERY URGENT
Post Office Limited -v- Lee Castleton
I refer to our telephone conversation this morning and as discussed,
you to approve, sign and date and fax back to me on!
attach a copy of the disclosure list for
I look forward to hearing from you as soon as possible today.
Kind regards.
p!
Solicitor
for and on behalf of Bond Pearce LLP
Enc
Bond Pearce LLP, a Limited Liability Partnership. Registered in England and Wales number 0C311430,
Registered office: 3 Temple Quay Temple Back East Bristol BS1 6DZ. VAT number GB143 0282 07.
A list of members of Bond Pearce is open for inspection at the registered office. Regulated by the Law Society. www.bondpearce.com
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List of documents: ne ee ao och ‘okcion
standard disclosure
Notes Claim No. I HQ05x02706
« The rules relating to standard disclosure are contained Cla Post Office Limited
in Part 31 of the Civil Procedure Rules. told a)
+ Documents to be included under standard disclosure $3D3/348035.134
are contained in Rule 31.6 Defendant I Mr Lee Castleton
+ A document has or will have been in your control if you I “esine re
have or have had possession, or a right of possession,
of it or a right to inspect or take copies of it. Date
Disclosure Statement
I, the above named
Claimant (1) Defendant
Party (if party making disclosure is a 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)
I am the person with overall responsibility at Post Office Limited for this case.
state that I have carried out a reasonable and proportionate search to locate all the documents which I am
required to disclose under the order made by the court on (date of order)
9 March 2006
I did not search for documents:-
[x] pre-dating [15 july 2003
[x] located elsewhere than
Documents with accounting teams in Chesterfield, personal records held in Leeds, together with HSH
and NBSC call logs, transaction information, Girobank and Inventory team in Leeds and at Fujitsu.
(J in categories other than
(J for electronic documents
I carried out a search for electronic documents contained on or created by the following:
(list what was searched and extent of search)
(a) The electronic data we have searched for is from an Electronic filing cabinet (EFC) which has all
documents relating contractual issues in one place for ease of reference and retrieval.
(b) The categories of electronic documents not searched (see next page) for is either because it is not
believed such categories exist, or because such electronic documents (if any) would not fall under CPR
31.6.
N265 Standard disclosure (10.05) © Crown Copyright Laserform Inti! 10/05
7%
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I did not search for the following:-
documents created before 18/7/03 for financial docs
documents contained on or created by the [_] Claimant [_] Defendant
(] PCs [x] portable data storage media
(J databases o servers
[x] back-up tapes (CO off-site storage
{x] mobile phones laptops
handheld devices
x] PDA devices
documents contained on or created by the [_] Claimant [[] Defendant
{J mail files (] document files
calendar files web-based applications
graphic and presentation files
(] spreadsheet files
documents other than by reference to the following keyword(s)/concepts
(delete if your search was not confined to specific keywords or concepts)
I certify that I understand the duty of disclosure and to the best of my knowledge I have carried out that duty.
I further certify that the list of documents set out in or attached to this form, is a complete list of all documents
which are or have been in my control and which I am obliged under the order to disclose.
I understand that I must inform the court and the other parties immediately if any further document required to
be disclosed by Rule 31.6 comes into my control at any time before the conclusion of the case.
(J) I have not permitted inspection 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 disproportionate to
the issues in the case.
Signed Date
(Claimant) (OOOO) KXXKGODOCIOOR
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List and number
here, in a convenient
order, the documents
(or bundles of
documents if of the
same nature, e.g.
invoices) in your
control, which you do
not object to being
inspected. Give a
short description
of each document
or bundle so that it
can be identified,
and say if it is kept
elsewhere i.e. with a
bank or solicitor
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I have control of the documents numbered and listed here. I do not object to you
inspecting them/producing copies.
see attached list.
List and number
here, as above,
the documents in
your control which
you object to being
inspected,
(Rule 31.19)
Say what your
objections are
I have control of the documents numbered and listed here, but I object to you
inspecting them:
Correspondence passing between the Claimant/Part 20 Defendant and their solicitors for the
purposes of this action, instructions and opinions of counsel, drafts of pleadings and other
documentation settled by Counsel, Experts’ drafts and opinions and all other documents of a
confidential nature brought into being for the purposes of this proposed action.
I object to you inspecting these documents because:
they are privileged.
List and number
here, the documents
you once had in your
control, but which
you no longer have.
For each document
listed, say when
it was last in your
control and where it
is now.
I have had the documents numbered and listed below, but they are no longer in my control.
Originals of documents described as copies which are in the hands of recipients or
lost/destroyed.
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No. DOCUMENT Date/Week
1. Horizon Message Store Various
2. Horizon system user guide Various
3. Horizon Operations Manual Various
4. List of Software updates 01/2004 to 04/2004
5. Spreadsheet of stock remittances 01/2004 to 03/2004
6. Spreadsheet of errors brought to account 2003 to 2004
7. Spreadsheet of total daily cash declaration 01/2004
8. Spreadsheet of total daily cash declaration 02/2004
9. Spreadsheet of total daily cash declaration 03/2004
10. Spreadsheet of daily cash declarations by denomination 11/03/2004 to
31/03/2004
11. Spreadsheet of notes delivered to the Marine Drive branch 18/07/2003 to
31/03/2004
12. Spreadsheet of coin delivered to the Marine Drive branch 18/07/2003 to
31/03/2004
13. Spreadsheet of notes and coin delivered to the Marine Drive branch 18/07/2003 to
31/03/2004
14. Daily procedures and Horizon Reports Edition 4/10/2005
15. Balance Procedure 03/2006
16. Subpostmasters Contract 09/1994 edition
17. Amended Particulars of Claim 23/10/2006
18. Order of Deputy Master Nussey on behalf of Master Fontaine 25/08/2006
19. Order of Master Turner 23/10/2006
20. Notice of Trial 04/12/2006
21. Notice of date for Returning Pre-Trial Checklist 23/10/2006
22. Email from John Jones to Catherine Oglesby 25/06/2004
23. Letter from Defendant to Chery! Woodward Undated
24. Letter from Defendant to Cheryl Woodward 19/08/2004
25. Letter from Defendant to Cheryl Woodward 24/08/2004
26. Letter from Defendant to Cheryl Woodward. 01/12/2004
27. Letter from Defendant to Cheryl Woodward 15/12/2004
28. Letter from Cheryl Woodward to Defendant 15/12/2004
29. Letter from Defendant to Cheryl Woodward 16/12/2004
30. Interpartes solicitors correspondence post dating the Claimant's first I 18/5/2004 onwards
disclosure list
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