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Stephen Dilley
From: Tom Beezer
Sent: 24 November 2005 11:42
To: Stephen Dilley
Ce: Julian Summerhayes; Bob Heckford; Andrew Tobey; Simon Richardson
Subject: RE: Castleton - disclosure
good point
esp' the 2nd
bear it in mind and action (for my review) when reply from PO received.
I have spoken to other side on a WP basis.
A bit of a brutal but constructive call. He accepts (on a WP basis) that judgment will be set
aside - he will "see what he can do" with his client - i.e. I think he now accepts that the full
might of BP will wheel into action unless they consent to set aside. I think he would, but he has
a stroppy client to carry with him. We may...may...get somewhere on this in the next week or
so.
T
From: Stephen Dilley
Sent: 24 November 2005 11:36
To: Tom Beezer
Cc; Julian Summerhayes; Bob Heckford
Subject: Castleton - disclosure
Dear Tom,
I spent a huge amount of time yesterday going through every receipt we have received from
the P.O with a fine tooth comb and attach a list of docs we have and are missing. As you can
see from my earlier email of this morning, I've asked the P.O some questions about these docs.
There are 2 other points arising:
1. We have not sent to Mr C's solicitors all the receipts we are holding. However, we do
appear have sent to them all those receipts that they have asked for and that we have received
them from the P.O. This includes a limited number of daily balance snapshots. We could if we
wanted to appear co-operative, volunteer further receipts, such as the Sales Reports and
Miscellaneous Transactions etc listed in para 4 in the attached list.
2. More significantly, it is clear from both Castleton's experts reports that neither expert had
seen the majority of the documents we sent to Castleton's solicitors as long ago as 16 February
2005. For example, we sent to them 14 weeks worth of cash accounts, 12 weeks worth of giro
receipts and 12 weeks worth of declared cash receipts. Their expert only says he has seen a
cash account for 1 week i.e week 49. This begs the question as to why they have not given
their experts everything that we gave them. After all, their experts have asked for more info to
be able to form a firmer view. This is a point we should raise with C's solicitors in
correspondence BUT before we do so, I want the P.O to reply to my email today, so I can firstly
bottom out whether the P.O did in fact remove more receipts from the Marine Drive branch
than it has sent to us or whether we can deny that the P.O ever had the daily snapshots that
Castleton alleges were removed.
24/11/2005
POL00070475
POL00070475
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Stephen Dilley
From: Stephen Dilley
Sent: 24 November 2005 11:36
To: Tom Beezer
Ce: Julian Summerhayes; Bob Heckford
Subject: Castleton - disclosure
Attachments: DOC_1093098.DO0C
Dear Tom,
I spent a huge amount of time yesterday going through every receipt we have received from
the P.O with a fine tooth comb and attach a list of docs we have and are missing. As you can
see from my earlier email of this morning, I've asked the P.O some questions about these docs.
There are 2 other points arising:
1. We have not sent to Mr C's solicitors all the receipts we are holding. However, we do
appear have sent to them all those receipts that they have asked for and that we have received
them from the P.O. This includes a limited number of daily balance snapshots. We could if we
wanted to appear co-operative, volunteer further receipts, such as the Sales Reports and
Miscellaneous Transactions etc listed in para 4 in the attached list.
2. More significantly, it is clear from both Castleton's experts reports that neither expert had
seen the majority of the documents we sent to Castleton's solicitors as long ago as 16 February
2005. For example, we sent to them 14 weeks worth of cash accounts, 12 weeks worth of giro
receipts and 12 weeks worth of declared cash receipts. Their expert only says he has seen a
cash account for 1 week i.e week 49. This begs the question as to why they have not given
their experts everything that we gave them. After all, their experts have asked for more info to
be able to form a firmer view. This is a point we should raise with C's solicitors in
correspondence BUT before we do so, I want the P.O to reply to my email today, so I can firstly
bottom out whether the P.O did in fact remove more receipts from the Marine Drive branch
than it has sent to us or whether we can deny that the P.O ever had the daily snapshots that
Castleton alleges were removed.
Kind regards.
Stephen Dilley
Solicitor
24/11/2005