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Stephen Dilley
mandy.talbot@ ~~
05 April 2006 09:51
Stephen Dilley
Re: Bajaj and Castleton
If that is the best time fore everyone else I can work with it.
Please note that Friday is my last day in the ofice until 24/4 and then I will be baed in London with new telephone
details but my mobile number will remain the same.
Regards
Mandy Talbot
Litigation Team Leader
Company Secretary's Office
Legal Services
Royal Mail, Impact House, 2 Edridge Road, CROYDON, CR9 1PJ
__>, "Tom
Beezer" <.
04/04/2006 10:35 Sui
Dear Mandy,
Following your recent discussion with Tom, I have provisionally arranged a joint telephone conference to take
place this Friday 7 April at 10.30am with you, us and Ian Herbert to brainstorm what I.T information we seek and
how to get more meaningful information from Fujitsu and internally at the P.O. Is this a good time for you? If so,
1 propose to contact you then.
I look forward to hearing from you.
Kind regards.
Stephen Dilley
Solicitor
www.bondpearce.com
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1
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Page 1 of 4
Stephen Dilley
From: _ lan Herbert §
Sent: 04 April 2006 1
To: Stephen Dilley
Subject: RE: Post Office - Bajaj and Castleton
Cheers,
My direct line is
Regards,
lan.
-----Original Message-----
From: Stephen Dilley [mailto:
Sent: 04 April 2006 10:13
To: Ian Herbert
Subject: RE: Post Office - Bajaj and Castleton
Thanks. Shall we say 10.30am? What number should we call you on?
From: Ian Herbert [mailto:
Sent: 03 April 2006 15:09
To: Stephen Dilley
Ce: Tom Beezer
Subject: RE: Post Office - Bajaj and Castleton
Friday is now good for me.
Regards,
fan.
-----Original Message----~
From: Stephen Dilley [mailto!
Sent: 03 April 2006 09:28
To: Ian Herbert
Ce: Tom Beezer
Subject: RE: Post Office - Bajaj and Castleton
Thanks for your email of 31 March.
I look forward to hearing from you during the course of today re availability on
Wednesday or Friday. I'll then go back to Mandy.
Kind regards.
Stephen Dilley
From: Ian Herbert [mailt
Sent: 31 March 2006 18:21
To: Stephen Dilley
Cc: Tom Beezer
Subject: RE: Post Office - Bajaj and Castleton
Sorry. I have been tied up all day on a particularly large group action. Next week is tricky. I
may have to be in London 1 day but don’t know which day yet. Could I tentatively suggest
Wednesday or Friday but will know more on Monday once I have made a few calls.
Regards,
07/04/2006
07/04/2006
fan.
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Page 2 of 4
--+--Original Message-----
From: Stephen Dilley [mailto;_
Sent: 31 March 2006 10:30
To: Ian Herbert
Cc: Tom Beezer
Subject: Post Office - Bajaj and Castleton
Dear Mr Herbert,
I tried to call you this morning and left a message.
Mandy Talbot would like a joint telephone conference with us next week
to brainstorm what I.T information we seek and how to get more
meaningful information from Fujitsu and internally at the P.O in our
respective cases.
Mandy cannot do Monday am or all of Tuesday. Please could you give me
a call to confirm your availability?
I look forward to hearing from you.
Yours sincerely,
Stephen Dilley
Solicitor
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for any loss or damage which may be caused by software viruses.
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Wales number 0C311430.
Registered Office: Bristol Bridge House, 138-141 Redcliff Street, Bristol, BS1
6BI.
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__Disclaimer
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Solicitors and are intended for the confidential use of the named recipient(s) only.
If they have been received in error you must maintain confidentiality, notify us of the
error, destroy copies and delete them from your computer system.
Hugh James Solicitors is authorised and regulated by the Financial Services
Authority.
www.hughjames.com
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legally privileged and protected by law. The intended recipient only is authorised to
access this e-mail and any attachments. If you are not the intended recipient, please
notify the sender as soon as possible and delete any copies. Unauthorised use,
dissemination, distribution, publication or copying of this communication is
prohibited.
Any files attached to this e-mail will have been checked by us with virus detection
software before transmission. You should carry out your own virus checks before
opening any attachment. Bond Pearce LLP accepts no liability for any loss or damage
which may be caused by software viruses.
Bond Pearce LLP is a Limited Liability Partnership registered in England and Wales
number 0C311430.
Registered Office: Bristol Bridge House, 138-141 Redcliff Street, Bristol, BS1 6BJ.
A list of Members is available from our registered office. Any reference to a Partner
in relation to Bond Pearce LLP means a Member of Bond Pearce LLP. Bond Pearce
LLP is regulated by the Law Society.
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__ Disclaimer
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are intended for the confidential use of the named recipient(s) only.
If they have been received in error you must maintain confidentiality, notify us of the error,
destroy copies and delete them from your computer system.
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For more information please visit http://www.messagelabs.com/email
The information in this e-mail and any attachments are confidential and may be legally
privileged and protected by law. The intended recipient only is authorised to access this e-
mail and any attachments. If you are not the intended recipient, please notify the sender as
soon as possible and delete any copies. Unauthorised use, dissemination, distribution,
publication or copying of this communication is prohibited.
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attachment. Bond Pearce LLP accepts no liability for any loss or damage which may be
caused by software viruses.
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00311430.
Registered Office: Bristol Bridge House, 138-141 Redcliff Street, Bristol, BS1 6BJ.
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relation to Bond Pearce LLP means a Member of Bond Pearce LLP. Bond Pearce LLP is
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__ Disclaimer
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intended for the confidential use of the named recipient(s) only.
If they have been received in error you must maintain confidentiality, notify us of the error, destroy
copies and delete them from your computer system.
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* Stephen Dilley
an
From: mandy.talbot@”
Sent: 29 March 2006 18:31
To: Stephen Dilley; Tom Beezer
Subject: Re: Post Office Limited v Lee Castleton
Attachments: BM Shobnall Road SPSO 150405.doc; fad 213337 dec 04 to mar 05 calls Marine
Drive.xls; fad 140114 dec 04 to date Torquay.xls; Torquay rd.doc; fad 233313 dec 04 to
mar 05 calls Bowburn.xls
a, & a &
BM Shobnall Road fad 213337 dec 04 fad 140114 dec 04 Torquay rd.doc (30 fad 233313 dec 04
SPSO 150405.d.... tomarQ5ca... to date Torq... KB) to mar 05 ca...
Stephen
I have no objection to the slight delay and agree that it suggests a inability to answer the questions properly.
Availability between now and 4/5/06.1 am on annual leave between and 10 and
23 rd April. My whole team is moving from Croydon to Old St on the 12/4/06 so its going to be a tricky old time.
T have no dates which cannot be moved in my diary after I return from leave though a few days grace would be
useful.
Tom
The proposed bill including counsel's fees feel fine given the horrendous amount of work which has been done on
this file since the original slip up last year.
Both
I copied you into my epic e-mail 1/3/06 but the response to the same has been limited in the extreme.
I attach the responses of Graham C Ward and Dave Hulbert. I have also been contacted by John Cole asking for
assistance in preparing a spec for an external expert or experts but I think that this is of limited use until we have
reports completed by Fujitsu on the system and POL on the data provided. However in respect of an external
expert from the field of computer systems and accounting can you suggest any names or firm who may be
suitable?
Stephen
In the collation of evidence did you come across anyone who you believe could actually interpret the information
which was obtained from Fujitsu via Graham or the paper documents which were available from the Post Office.
As you can see I am still getting the run around on these cases by people who are not prepared to assist.
Please can you review the information which has been obtained from Graham and Dave which I assume you now
have or can get.
1
Mandy
Firstly, apologies for the delay in replying, I've just returned from annual leave. I did have a brief chat with Dave
on receipt of this e mail
re: the call logs and he agreed that he would obtain them (in Excel format) from the NBSC at Dearne.
To clarify, the call logs that I can obtain from Fujitsu are those that relate to technical faults with the system
(printer problems / monitor faults etc) and which are dealt with by the HSH (Horizon System Helpdesk) only ....
any calls that relate to procedural problems on Horizon are dealt with by our own NBSC Helpline, details of which
can be obtained by Dave. (The NBSC can also provide brief details of the HSH calls as well, but I don't think they
go into the same depth as the details we receive from Fujitsu)
With regards to my knowledge of Horizon, I can obtain data as and when required being the SPOC between PO Ltd
and Fujitsu, but I do not have the working knowledge of the system to analyse data and comment on whether
Horizon was working correctly or not, or whether transactions have been processed correctly and may have
affected the office balance. I know Tony U has agreed to have a look at the Marine Drive data, but he is still
waiting to hear exactly what information needs analysing.
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» Fujitsu should be able to offer a technical perspective of the system working properly. I have searched my records
of previous statements received and have found one where Brian Pinder's predecessor Bill Mitchell provided a
statement (see below) commenting on individual calls to the HSH and then including a general paragraph stating
that "None of these calls would have had an effect on the integrity of the data on the system.
Perhaps I should formally ask Fujitsu to provide a similar type statement in respect of Marine Drive & Torquay
Road, what do you think ?
(See attached file: BM Shobnall Road SPSO 150405.doc)
If someone within PO Ltd can then provide a similar type statement in respect of NBSC procedural calls, I think we
will then have all areas covered but this, as we discussed at the meeting needs to be coordinated by one ‘expert’ ,
has someone been appointed ?
Just to clarify my understanding of where we are at this moment in respect of all 3 cases
Marine Drive
With regards to Castleton, we have the transaction data and HSH call logs covering the 01/01/04 - 31/03/04, this
does not include calls made to the NBSC.
Presumably Dave will have now obtained the NBSC call logs for this period, or is there a further period of HSH
calls required ?.
In your e mail below, you mention the period 01/12/04 - 31/03/05, is this a new period of data / analysis required
?
Torquay Road
We have the transactional data covering the 01/03/05 - 31/08/05 and HSH calls covering 10 days 11/11/05 -
20/11/05. I will request data to cover the new dates namely 01/08/04 - 28/02/05 and 01/09/05 - 21/12/05. I will
also ask for details of all HSH calls to cover the entire period.
In respect of the new case at Bowden, I will arrange to obtain all data covering the period 04/02/04 - 22/02/06. I
will also ask that Fujitsu provide us with details of all calls made to the HSH. Presumably Dave will obtain the
NBSC version of calls over the period. When received I'll let you know and you can advise me who to pass the
information onto. If we need to ask for a statement from Fujitsu outlining calls details we can do, but I won't ask
for one at this point.
Fujitsu's responses thus far haven't really helped answer the questions posed in each case, their written responses
have been brief to say the least.
My own opinion therefore is that PO Ltd needs to cover off all questions relating to office mis-balancing &
transaction details, (we should have NBSC call records detailing any issues bought to our attention) and that
Fujitsu should provide us with a general statement for each case (as per the statement above from Bill Mitchell)
detailing calls made to the HSH. If you agree then I will ask Brian Pinder to provide such a statement in respect of
Marine Drive & Torquay Road covering the periods detailed above.
No doubt we'll speak soon.
Regards
Graham
Casework Manager
Post Office Ltd Investigation Team
PO BOX 1, CROYDON, CR9 1WN
Mobil
Postline: N/A, STD Phone
N/A, Mobex
2
Mandy,
I'm forwarding you on the reply from my team - it's adding to your email - from me in Red and Gary in reply in
Blue. Apologies for the delayed response.
With regards to the Excel attachments - Gary covers most of it off in his text, but with regards to the one for
Marine Drive theres only one entry i.e. the second one on the HSH tab that has any bearing on potential losses
- but it looks like BAU stuff.
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* Should you need anything else, please let me know.
Regards
Dave
Head of System Operations
Operations Control
Post Office Ltd
Gary Blackburn
10/03/2006 1 Nicola
Wood/e4.. i
Subject: Re: Horizon URGENT Private and Confidential(Document link: Dave
Hulbert)
Dave
I have added comments / MI etc in blue text underneath each action point.
regards
Gary
Adam / Nic
Can we discuss this process on my return from A/L piease.
Systems Live Service Manager
Post Office Ltd
Operations
Ast Floor, Post Office Ltd, Cortonwood Business Park, Cortonwood Drive, BARNSLEY, S73 OTB
I Mobile:
Fax: N/A, VoiceMail: N/A, Mobex:
Dave Hulbert
To:
03/03/2006 10:58 cc: Adam Martin/e/._ “} Nicola
Wood/ei_.
jubject: Horizon URGENT Private and Confidential
Gary,
I'm asking you in your old capacity to kick off the actions I've added to this long email (highlighted in red).
Some of this would reside with you in future anyway, such as the incident capture of any potential claims or noise
about Horizon creating losses.
Also the production of the relevant MI.
I could do with an initial response by Tuesday next week, with a more detailed on by next Friday, please.
Adam, Nic, - at this point in time this is for info. although I suspect Gary may need to use one of your team to
assist with this. Also I'd welcome your views on how we can tighten up going forward i.e. working proactively with
Fujitsu to avoid such claims in the first place - tall order but I'm sure there's things we can do.
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Thanks
Dave
=~» Forwarded by Dave Hulbert/e/POSTOFFICE on 03/03/2006 09:30 ----~
Mandy Talbot
John
Tony R Utting/e,
Lesley Joyce/e/'
+ Marie
} Graham C
} Keith K
Gallagher/e/”
ce: Clare Wardle/e;
stephen.dilley@
Subject: Horizon
I write further to the meeting in December 2005 which most of us attended to bring you up to date with the
current state of play.
I should be obliged if you could let me know in return what progress has been made with making a business case
for the appointment of an individual to analyse date from Fujitsu for the benefit of POL and in particular to assist
on civil claims?
If the case has been accepted have any steps been taken towards making an appointment? If not when is this
likely to occur?
Castleton- formerly of Marine Drive Branch office
For the benefit of you who are new to this matter, Castleton was a sub postmaster whose contract was terminated
and who was sued by POL for approximately 25K. His response was to assert that it was a fantasy debt created by
the HORIZON system and as such he should not be asked to repay the sums. Due to an error judgement was
entered against POL on his counterclaim for an unspecified sum of money. I am pleased to report that he has now
been persuaded to consent to that judgment being set aside.
Evidence has been obtained from his retail line manager, auditor, area intervention manager and appeals
manager which is robust in detailing with why his contract was terminated and the basis for it. The area which
does remain to be clarified is his allegation that there was something wrong with HORIZON and on which precise
dates it went wrong, as the totality of his evidence so far is that it went wrong between December 04 and
23/03/05.
Castleton has obtained an accountants report in support of his claim but its findings are incorrect because it has
assumed that the daily trial balances or snap shots actually represent the amount of cash which was in the office
at any one time.
Graham has obtained access to the Fujitsu data for marine drive for December to March and also the helpline
logs. Graham can you confirm whether these are all the calls logged from Marine Drive or merely the ones logged
onto the HORIZON call desk? If so can you now arrange to obtain all of them. Can we have the NBSC incidents for
this branch between 1st December 2004 and 23rd March 2005,
(See attached file: fad 213337 dec 04 to mar 05 calls Marine Drive.xis)
Dave Hulbert - if you were provided with these would it be possible to drill down into the data to discover what
was done to try to assist the postmaster and whether or not this cured the alleged problems? Would a member of
your team be able to give a statement dealing with the number of calls, the resolutions and if any approaches to
Fujitsu were considered warranted and if not why not? I need a view on how long it will take to review the
relevant incident logs i.e. those relating to balancing, losses, gains, system "faults" etc.... I also need to know
whether we made any representation to Fujitsu with regards to this branch.
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Investigating the call logs was done by Rich B ( unsure of the date early 2005, but he did e mail you with his
* conclusions ) Richard's conclusion was that this wasn't a system error . He did note a pattern with regard to a
new member of staff who started work in October 2004 and removal of that
staff member in March 2008. It took Richard 1 day to investigate the calls thoroughly . Richard also spoke with
Graham Ward and POL security with regard to this issue.
Fujitsu would interrogate / provide message store information on balancing , losses etc. Richard can't remember
whether or not this happened but says that this would be a normal activity when investigating this type of
scenario. I f you can't find the email in your archive we would have to do this work again.
Graham has also asked Fujitsu for their assistance with less than impressive results. I attach as a PDF document a
copy of the exchanges.
Tony Utting has provided me with a useful draft statement which he created which attempts to explain to the
Court how the HORIZON system works. I appreciate that this will now need some work to bring it up to date.
Please could somebody from the technology side of the business volunteer to up date this document. This
document could usefully form the basis a report from Fujitsu or the business with the specific detail about the
system and the particular office added onto the end.
I should be obliged for your comments upon what we believe that Fujitsu should be able to provide by way of
evidence and what they are obliged to provide under the contract.
I would have thought that as a very minimum they should be able to say that they have run a check on the whole
network between 1/12/04 and 31/3/05 and can confirm that either there were no problems affecting the whole
system, detail the ones which did occur, comment upon which areas they affected and whether they would be
likely to cause the problems complained of by Castleton. I'd like your views on this - I'm down the lines of
thinking the last part of this request is perfectly reasonable i.e. state any problems that could have caused the
issues or a statement of no relevant issues. In the meantime, I will forward elements of this on to Fujitsu for
comment.
I don't see any reason why Fujitsu couldn't supply this information or a combination of Fujitsu , P&BA ( error
notices / TC'S) and Marc Reardon for releases that possibly related to known problems . If Fujitsu concur this can
be built into the new process around investigation of these issues.
I would have thought that Fujitsu should be able to check the system with particular reference to Marine Drive
between the dates above and possibly afterwards to confirm whether or not they have found any evidence of the
problems complained of by Castleton. Castleton's lawyers claim that the current postmistress is experiencing
identical problems! We must look into this! i.e. let's have a look at the incidents raised from April 2005. I need to
know whether there's any justification for this allegation.
Dave 12 incidents have been raised with HSH since April 2005 , 66 with NBSC. no evidence to support the
lawyers claim unless the issue is with regard to the Auto Rem process. The branch appears to have had some user
related issues around May 2005 but NBSC have explained the reason for these.
These calls are within the marine Drive spreadsheet attached above.
Do we think that a site inspection by Fujitsu would have any merit as I recall being told of cases where problems
were caused by family members hacking in and abusing the system or where rare geographical conditions caused
problems?
Lastly do Fujitsu know enough about POL products and systems to comment on the data produced or would this
be a job that can only be handled by someone within the business? If so who other than Tony and Graham now
have the knowledge to go through the data to determine whether there is evidence of the system
malfunctioning? I'd like a view on who has the skills - Graham and Tony being Investigations still seem to me to
be the best option, but do we have others?
I'm not sure why Fujitsu would need in depth product knowledge? Fujitsu understand the system and how
transactions are processed.
with regard to who within POL , I would suggest design authority type people or Training. e.g Katren Hillsden ,
Alan Orpe etc.
Are there any other matters we believe that Fujitsu could comment on that would assist us in demonstrating the
robustness of the system in the round and in the circumstances of this case?
The agents dealing with case need instructions from the business on how to proceed now that the judgement has
been set aside on the following matters
should we try to settle the claim
should we apply for further and better particulars of his evidence
should we employ agents to investigate Castletons finances
should we offer mediation again
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expert evidence
on which I have given some preliminary comments.
Please may I have your comments?
Given the existence of the cases of Bajaj and Bilkhu together with the publicity given to HORIZON problem in The
Subpostmaster I think that to settle the claim now ,even on confidential terms, may cause almost as much harm
to the business as fighting and loosing the claim. The statement evidence is good but this case will be won or
lost on the quality of the internal and external reports on the data produced by and onthe robustness of the
HORIZON system.
I think that there Is very little to loose in making a formal application for further information about precisely what
Castleton thinks is wrong with the system and for details of the precise dates on which he claims the problems
arose. The difficulty with addressing his vague allegations is the fact that they cover such a long period of time
given the enormous number of transactions which will have occurred during that time and if we can narrow them
down it will make any investigation much more cost effective.
He will also be asked for precise details of the elements which make up his counterclaim as they are extremely
vague at present. The response to this should at the very least advise us as to the potential maximum value of
the counterclaim.
In all cases it is advisable to try to ascertain if the person has the capital to meet a claim but in this case it may
give us an indication of how much additional resource he can afford to expend on it. He appears to be financing
the litigation privately and we have already managed to cast doubt on the assertions made by his accountants
report thereby making it more or less worthless. He was not awarded the costs of the application to set
judgement aside as the costs have been reserved to be dealt with at a latter date. He will probably also have to
amend his defence and counterclaim which will all cost money and which may in total recommend a settlement to
him.
I see no downside in offering mediation once more as if accepted it may force Castleton to take a more realistic
view of his chances, whilst always looking good in the eyes of the Court and giving us additional time to select and
brief an expert witness.
Selection of an expert witness will be crucial in this case. Preliminary enquiries should begin as soon as possible.
The selection should demonstrate the importance that POL places on this matter so a well known firm with a
national reputation should be selected. The firm and expert must have a firm grasp of technology. As this case
may set the trend for future litigation firms should be invited to tender on the basis that expertise picked up in
this case will lead to future work coming their way.
For that reason it may be that a strong second tier firm may be preferable to one of the top four where such
repeat work would not be so financially attractive.
I have seen and approved an agreement prepared by Fujitsu over the status of any information divulged to such
an expert.
Can any of you make specific recommendations as to suitable firms or fee earners?
Bajaj - current postmaster at Torquay Road
Mr Bajaj has been complaining about the HORIZON system since Xmas 2004 and has alleged that it has
manufactured errors which have resulted in him to date paying 14K to POL which he claims was not justified. He
has resigned and withdrawn his resignation, written articles in the Subpostmaster inviting fellow postmasters who
have suffered to contact him, complained to the Board, his MP etc. His allegations were not particularised to any
degree until a letter before action with an accompanying schedule was received ,a copy of which I attach.
Graham I know that you have made Fujitsu aware of this problem and have received some limited comments from
them copies of which I attach. Looking at the schedule attached to the letter before action can you confirm
whether you have (a) all the fault logs between Torquay Road and the HORIZON helpline and the postmasters
helplines between the earliest and latest of the dates referred to (b) can you request copies of the transactional
data between the two revised dates as I believe the information which you have is more limited.
Dave Hulbert would your team be able to produce a statement based on the logs similar to one referred to in
Castleton above. As per the request can the NBSC call logs be produced and the give an estimate of how long it
would take to analyse the call logs.
(See attached file: fad 140114 dec 04 to date Torquay.xls)(See attached
file: Torquay rd.doc)
Dave this work was done last year after the November edition of the subpostmaster contained a letter from
Torquay Road. Interestingly one of the NBSC calls made by Marine Drive since April 2005 was requesting Torquay
Roads contact details.
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* Tony/Graham unless the team is able to identify any other suitable person will you be able to analyse the
transactional data to explain the so called discrepancies and losses. Many of the items in the schedule may not
result in an actual loss at all and are probably part of the settling process which the accountants and solicitors do
not appreciate.
Do we think that it would be sensible or useful for Fujitsu to arrange for an engineer to look at the HORIZON
equipment just to eliminate local anomalies? What has been done, if anything, with this branch to date. I'm pretty
sure we backed off sending one of the BIMs there for reasons of not wanting to aggrivate the situation or
compromise any individual.
Details are above but yes we did not send a BIM for the reasons you suggest.
New Case- Bilkhu postmaster at Bowburn Post Office.
I attach the claim form together with supporting schedule for Graham to order the help desk logs and
transactional data. Graham's on leave now so can we provide the NBSC and HSD call logs, please.
(See attached file: fad 233313 dec 04 to mar 05 calls Bowburn.xls)
I will put our agents in touch with the relevant members of staff within POL who may have partially investigated
this claim already.
Correspondence from Tolhust Fisher indicate that they have been contacted by another disgruntled postmaster
but they are not as yet instructed on his behalf.
Keith and Dave Hulbert have brought the case of Hughie Noel Thomas to our attention as being yet another
discipline case where HORIZON is being blamed. Also that of Hogsworth Post Office Skegness.
All the above emphasise the importance of identifying and appointing a suitably qualified member of staff who can
deal with the investigation of these claims swiftly and robustly so as make other postmasters less inclined to
expend money on making claims in the future.
I look forward to hearing from you as soon as possible.
Regards
Mandy Talbot
Litigation Team Leader
Company Secretary's Office
Legal Services
Royal Mail, Impact House, 2 Edridge Road, CROYDON, CR9 1PJ)
“i, Fax: I
Mobile:
External Email:
>>>> bajaj fujitsu.pdf attachment was removed from this email <<<<
>>>> bajaj letter before action.pdf attachment was removed from this
>>>> email
<<<<
>>>> Castleton fujitsu.pdf attachment was removed from this email <<<<
>>>> Bilkju 1.pdf attachment was removed from this email <<<<
>>>> Bilkhu2.pdf attachment was removed from this email <<<<
Mandy Talbot
Litigation Team Leader
Company Secretary's Office
Legal Services
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” Royal Mail, Impact House, 2 Edridge Road, CROYDON, CR9 1P3
“Stephen Dilley"
‘Stephen. Dil
To: <mandy.talbot@
ce:
Subject: Post Office Limited v Lee Castleton
28/03/2006 19:31
Dear Mandy,
I refer to my e-mail of 20 March.
l attach a fax from Mr Castleton's solicitors dated 28 March, just for your information. They state that they will
not be in a position to serve a reply to the Part 18 request this coming Friday because of the “logistical”
difficulties. My reading of this is that they may well be in difficulty properly answering the questions we have
raised. They have asked for a short extension until 7 April to reply to the Part 18 request and I propose to agree.
I will revert to you once we have received their Part 18 Reply.
In the meantime, I would be grateful if you could provide me with your availability before 4 May to
attend the mediation.
Kind regards.
www.bondpearce.com
The information in this e-mail and any attachments are confidential and may be legally privileged and protected
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Registered Office: Bristol Bridge House, 138-141 Redcliff Street, Bristol,
BS1 6B).
A list of Members is available from our registered office. Any reference to a Partner in relation to Bond Pearce LLP
means a Member of Bond Pearce LLP.
Bond Pearce LLP is regulated by the Law Society.
>>>> Rowe Cohen.pdf attachment was removed from this email <<<<
JOOS ISIE AEE AGE CIDER AOS ISIE IEE IEICE ERICA IES IEA IRI ICAI CE
8
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Telephone attendance
Client: Post Office Limited
Matter: Mr Lee Castleton - DEBT £30027.47 Matter no: 348035134
Attending: Cheryl
Name: Laura Peto Location: N/A Date: 28 February 2006
Start time: N/A Units: N/A
Attending OUT.
LRB confirming that she will request the information and update me.
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Laura Peto
trom: Stephen Dilley
Sent: 24 February 2006 18:49
To: Julian Summerhayes
Ce: Tom Beezer; Simon Richardson; Laura Peto; Gareth Kagan
Subject: Post Office -v- Castleton
Dear Julian,
Since my last email, I have spoken to Mandy to agree the strategy moving forward. She said:
(1) Internally, the P.O feel conflicted about the Castleton case. The P.O believes to be the
Horizon system is robust, but the downside is the cost (in P.O time and money) of proving a
negative (i.e that there are no faults) is expensive. For example, she'd need to get a report
from Fujitsu (who apparently have difficulty writing in plain English) and get someone in the
P.O to review Fujitsu data to see if there are any anomalies.
(2) However, her view is that the P.O must not show any weakness and even if this case will
cost a lot, there are broader issues at stake other than just Castleton's claim: if the P.O are
seen to compromise on Castleton, then "the whole system will come crashing down" i.e it will
egg on other sub postmasters to issue speculative claims. She knows that Castleton is talking
to Bajaj (the other subpostmaster bringing a Horizon based claim). Her clear message is that
we must be seen to take a firm line. With this in mind, our instructions are as follows:
(a) Please can you draft a Part 18 request on the Defence and Counterclaim, send it to her for
approval and then fire it off to Castleton asap. (she agrees that we need to better understand
his case and give him pause for thought. She thinks the counterclaim is weak because even if
the P.O had dismissed him on notice (3 months) (which she thinks they can do w/out reason),
instead of summarily, his compensation would be those 3 months pay. [We need to check the
Subpmr contract to see if it says that and if so, ram this point home to him in the Part 18 e.g
"Given P.O could have terminated on 3 months without reason and payment would be limited to
£X, please explain how you calculate your claim at £250k" -sthg a bit more sophisticated but
along those lines]. She therefore thinks Castleton's counterclaim appears optimistic.
(b) Please can Laura arrange to do a discreet asset check on Castleton.
(c) Please can we draft and send directions to Castleton to include (1) He must answer the Part
18 by X date, then (2) a 1 month stay for settlement... etc The settlement point will make the
P.O "looks good" from the Court's perspective but also will give Castleton a chance to settle.
However, she is not holding much hope out for Castleton paying anything voluntarily and is
mindful that making any concession to him could send out the wrong message and egg on other
claims.
(d) The P.O does not have a preferred expert. She wants us to instruct a well known
accountant with a speciality in IT (but not their auditors, Ernst & Young) e.g KPMG as expert.
She thinks the expert will need a long time to understand the Horizon system (certainly a very
full briefing and demonstration but for obvious reasons I suggest not exclusively at Marine drive
The fact that Castleton's "experts" got it so wrong by misunderstarftting
the limited info they were given, amply demonstrates that the expert needs to be familiar with
the system to get it right. We need to consider how to build this into the directions. (Gareth
this will be an opportunity for us to make a decent referral to an accountant albeit not on the IP
side, so we need to identify some potentials).
(e) Generally, she wants us to build a long time for everything in the directions because it is
going to take her a while to get info from Fujitsu and an internal P.O report on Fujitsu info.
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I am copying this to Tom and Simon for info as it gives a useful insight into the way the P.O is
ap aching Horizon issues.
Kind regards.
Stephen
From: Stephen Dilley
Sent: 24 February 2006 14:56
To: Julian Summerhayes
Cc: Tom Beezer
Subject: FW: Post Office -v- Castleton
Julian,
If I do not manage to speak to Mandy this afternoon, please could I ask you to drive this
forward next week in my absence and give her a call o Tactically, I do not
want us to take our foot off the gas now we have the initiative - it has taken a lot of work to get
us there. However, I have had difficulty getting hold of Mandy to take instructions. My view is
that:
1. P.O likely to be sensitive about pursuing this claim to trial because of Horizon issues and
publicity. For no other reason than this, they therefore may want a settlement meeting. I
think we should not have such a meeting until after we Part 18 Castleton and get reply, but
before disclosure.
2. P.O appear to have a strong case despite not having all documentation, but position
unlikely to become clear until expert independently confirms losses. We need to know if PO
favour using any particular experts.
3. We need a strategy chat with Mandy to discuss how P.O wants to play this. See my thoughts
below. If they want to do a discreet asset check, we can ask Laura to put this in hand.
4. If we go down the Part 18 route, we need to draft and serve sthg next week because we can
then send out draft directions incorporating a requirement for Castleton to reply to the Part 18
request. Whilst 1 believe we should be doing a Part 18, Counsel is all for getting to trial asap so
Castleton does not spend as much money on lawyers fees, reducing available assets for us to
enforce against if we win, This is a commercial decision for the client, but I think Part 18 will
push Castleton to settlement and give us a better idea of his defence and counterclaim and we
should do this.
Many thanks. Stephen
From: Stephen Dilley
Sent: 24 February 2006 14:42
To: 'mandy.talbot
Cc: Tom Beezer; Julian Summerhaye
Subject: Post Office -v- Castleton
Dear Mandy,
I tried to catch you today but you were engaged. It'd be great if we could catch up today, as 1
am away next week.
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Castleton's solicitors have today asked us to put forward a timetable for moving the case
fo’ «rd and invited us to organise the CMC to take place by telephone, to save costs. I'd like
to uscuss strategy with you so that I can reply to them. Now that we have served some strong
evidence and set aside the default judgment, the P.O has the initiative and Castleton is on the
back foot, so it would be great to capitalise on our advantage.
Please could you give me a call if you get a spare mome ? If not, please could
you call my colleague Julian Summerhayes next week on The CMC is on 10
March, so we'll need to send out a draft timetable to Castleton's solicitors shortly.
Kind regards,
Stephen Dilley
Solicitor
for and on behalf of Bond Pearce LLP
Main office phone
Fax:
www.bondpearce.com
From: Stephen Dilley
Sent: 20 February 2006 17:33
To: 'mandy.talbot@
Cc: Tom Beezer; Jul
Subject: Post Office -v- Castleton
Dear Mandy,
I refer to my 7 February email.
l attach a copy of the sealed order setting aside the default judgment, just for your information.
The Court has listed a CMC to take place on 10 March 2006 where it will set the timetable for
bringing the claim to trial. I have provisionally reserved Counsel to attend that CMC (since his
attendance is likely to be more cost effective than mine). However, if we are able to agree
directions with Castleton's solicitors before the next hearing, then we may be able to get it
vacated and save the costs of an attendance.
I'd like to have a chat with you about strategy, so that we can try to agree a timetable
with Castleton. It would be helpful to discuss the following points:
1. P.O's view of pursuing the claim in the light of the favourable evidence from John Jones, Cath
Oglesby and Helen Rose, balanced against any broader concerns over Horizon issues;
2. Whether to make a Part 18 Request on the Counterclaim - i.e trying to "flush out" Castleton's
position so we can better prepare for it and also to press him into negotiating;
3. Asset check - whether we should be discreetly checking Castleton's assets to see if he would
have assets available for us to enforce against, if successful at trial;
4. Mediation/settlement - Castleton previously rejected the P.O's offer of mediation, but it
would be interesting to see what his view is now in the light of the strong evidence served
against him and our critique of his "experts" reports; and
5. Expert evidence - This case will turn mainly on the figures and I anticipate both sides will
want to put forward someone to do a financial analysis. Is there anyone the P.O tends to use in
27/02/2006
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these sorts of cases who you would prefer us to instruct?
I around this week apart from Thursday and out of the office next week on holiday. Is there
a cuavenient time this week for you?
I look forward,to hearing from you.
Kind regards.
Stephen Dilley
Solicitor
for and on behalf of Bond Pearce LLP
27/02/2006
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Laura Pe’
Feu: Laura Peto
Sent: 06 March 2006 15:17
To: ‘Global Investigations’
Subject: URGENT - PRE-SUE/ASSET TRACE - LEE CASTLETON
Importance: High
Attachments: DOC_1133332.D0C
FAO John Cooper
Dear John
I refer to the attached letter of instruction. You advised that you have not received it but
agreed to instigate a search for me today. Please note that we are aware Mr Castleton owns
the Post Office and are seeking to obtain even more details information in relation to the assets
owned by him. We would be grateful if you would discreetly obtain as much information as
possible about this subject and would advise that if you require to increase your budget to
provide more substantive information, please let me know.
We would be grateful to receive your urgent response given that instructions were forwarded on
28 February.
Kind regards, Laura.
Laura Peto (AICM) Cert
Paralegal Supervisor
for and on behalf of Bond Pearce LLP
06/03/2006
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Telephone attendance
Client: Post Office Limited
Matter: Mr Lee Castleton - DEBT £30063.11 Matter no: 348035.134
Attending:
Name: Laura Peto Location: N/A Date: 6 March 2006
Start time: N/A Units: N/A
IFD with SJD3.
Being told he wants an a more details pre-sue report and is prepared to pay for it. We already
know he owns the Post Office and want additional information.
Being told he cannot find out instructions and LRB agreeing to e-mail to him. Urgently require
info. Being told he will deal with it now. (ref John Cooper).
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2
a’
24 March 2006 Bond Pearce LLP
Ballard House
West Hoe Road
Plymouth PL1 3AE
Land Registry York Office
DX 61599
York(2)
URGENT Our ref:
LRB1/348035.134
Your ref:
Dear Sir
Lee Castleton
Title Number:
We act for the Post Office Limited in this matter and are instructed to collect a debt on their behalf.
We enclose a copy of the Office Copy Entries for ease of reference and note that there is a Registered
Charge dated 17 October 2003 in favour of The Royal Bank of Scotland PLC, 19 Huntriss Row,
Scarborough, North Yorkshire, YO11 2ED.
Enquiries have revealed the value of the property but we are unable to establish the amount of equity
that the proprietor has in the property. We understand that the amount of the loan is stated on the
application for the registered charge and would be grateful if you would provide an office copy or confirm
in writing if you are able.
We confirm that if you require a fee, we authorise you to debit our account (Key No:
We look forward to receiving your response as soon as possible and thank you in advance for your
assistance.
Yours faithfully
Bond Pearce LLP
Bond Pearce LLP, a Limited Liability Partnership. Registered in England and Wales number OC311.
Registered office: Bristol Brdge House 136-141, Redciff Street bristol 6S. 66), VAT number GBi45 0282 07.
Allist of Members is available from our registered office, Regulated by the Law Society. www. bondpearce.com
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LAND REGISTRY
YORK OFFICE
JAMES HOUSE
JAMES STREET
YORK
YOL0 3YZ
DX: 61599 YORK 2
23 March 2006
Your Ref: LRB1/348035.134
Our Ref: HS98639 /0C/249
Official copy/copies
l enclose the official copy/copies of the document(s) you applied for.
Please contact the Land Registry office named above if you have any questions about the enclosed
official copy/copies.
LRBI/348035.134 LR Credit Account Ref: 23/03 63YK9XDG
Fee Debited: — £4.00
BOND PEARCE & CO
DX 8251
PLYMOUTH 2
ean
1955013003
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OFFICIAL COPY OF REGISTER ENTRIES
Thi. official copy shows the entries subsisting on the register on 23 March 2006 at 1 23.
Th. date must be quoted as the ’search from date’ in any official search application
based on this copy.
Under s.67 of the Land Registration Act 2002, this copy is admissible in evidence to the
same extent as the original.
Issued on 23 March 2006.
This title is dealt with by Land Registry York Office.
Land Registry
GRO
Edition Date : 17 October 2003
Title Number :
A: Property Register
This register describes the land and estate comprised in the title.
EAST RIDING OF YORKSHIRE
1. (13.03.1985) The Freehold land shown edged with red on
i i being a
he plan of the
2. The land has the benefit of the following rights granted by a Conveyance
of the land in this title dated 22 February 1985 made between (1)
Lawrence Prince and Ada Kathleen Prince and (2) James Frank Evamy and
Barbara Janet Evamy:-
"TOGETHER with all rights of road or way drainage and other appurtenances
thereto belonging as now used enjoyed therewith.
B: Proprietorship Register
This register specifies the class of title and identifies the owner. It contains any entries that affect the
right of disposal.
Title Absolute
1. (17.10.2003) PROPRIETOR: LEE CASTLETON and LISA-MARIE CASTLETON
3. (17.10.2003) The Transfer to the proprietor contains a covenant to
observe and perform the covenants referred to in the Charges Register and
of indemnity in respect thereof.
Lu cod vet a
1955013003
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Title Number
B: Proprietorship Register continued
4. (17.10.2003) RESTRICTION: No disposition of the registered estate by
the proprietor of the registered estate is to be registered without a
written consent signed by the proprietor for the time being of the Charge
dated 18 July 2003 in favour of The Royal Bank Of Scotland PLC referred
to in the Charges Register.
C: Charges Register
This register contains any charges and other matters that affect the land.
1 The land in this title together with other land is subject to the payment
of three perpetual yearly rentcharges of 5s payable to Joliffe Esq.,
£7.6s,8d. to the Church Wardens of the Parish of Kirby Misperton and
£3.14s.8d. to Thomas Grimston Esquire mentioned in a Deed dated 19
December 1871 made between (1) George Townshend Hudson and Sir James
Hudson (2) Godfrey Rhodes in which it is stated that the land in this
title is indemnified from the said rentcharges by a Deed dated 27 October
1963 made between (1) Harrington Hudson (2) George Townshend Hudson and
Sir James Hudson No other particulars of the rentcharges or of the said
indemnification were supplied on first registration.
2. A Conveyance of the land in this title and other land dated 15 March 1989
made between (1) Benjamin Stocks and James Staniland Stocks (2) Whitaker
Brothers Limited (3) The Reverend Joseph Bawden Allen and (4) Frederick
Walker and others contains stipulations details of which are set out in
the schedule of restrictive covenants hereto.
NOTE:- No copy of the covenant to observe the said stipulations was
supplied on first registration.
3. (17.10.2003) REGISTERED CHARGE dated 18 July 2003.
4. (17.10.2003) PROPRIETOR: THE ROYAL BANK OF SCOTLAND PLC
(Co,Regn.No.) of 19 Huntriss Row, Scarborough, North Yorkshire, YOl1 2ED
FOSS IOI IIIS ICI a ie
Schedule of Restrictive Covenants
1. The following are details of the covenants contained in the Conveyance
dated 15 March 1989 referred to in the Charges Register: -
And that no building other than a fence or wall shall be erected on the
said plot of land between the building line shewn on the said plan and
the roads to which the said plot of land has a frontage And will not dig
or remove or permit to be dug or removed on or from the said plot of land
any turf stone or soil except what may be necessary in excavating the
foundations of any buildings which may be erected thereon or in levelling
the site for a garden and will not quarry any stone thereon except for
use in building upon the said plot of land and will not sell off any such
stone so quarried And that the said plot of land shall not be used for
any purpose other than garden ground meadow land plant nursery or orchard
or for the purpose of erecting a temporary Mission Chapel or Schoolroom
as hereinafter mentioned until built upon nor shall any Deed or thing be
done on the said plot of land or in or upon any building thereon which
may be or grow to be an annoyance nuisance damage or disturbance to the
Continued on next page Page 2
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Title Number
Schedule of Restrictive Covenants continued
Vendors their successors or assigns or the owner or tenant of any
adjoining land but nevertheless the said buildings and erections or any
of them or any part of the said plot of land may be at all times
hereafter used for the purposes of a Church Chapel or place of religious
worship and also for Schools and Class rooms but such Schools and Class
Rooms shall only be carried on in connection with the said Church or
Chapel or Mission Chapel and shall not at any time be used as public
Elementary Schools under the Elementary Education Act And will permit
the Vendors their Successors or assigns so long only as the said plot
shall remain unfenced to take sell departure or otherwise deal with any
grass or similar crops from time to time growing upon the said plot of
land and to permit golf to be played thereon...... And will not erect or
allow to be erected upon the said plot of land at any time hereafter any
Beer Shop Public house or Hotel for the sale of Malt or Spirituous
liquors and that no noxious or offensive trade or business shall be
carried on upon the said plot of land And will not for a period of five
years from the thirty first day of December One thousand eight hundred
and ninety eight erect upon the said plot of land any building other than
a Church Chapel or place for religious worship and also for Schools and
Class Rooms in connection therewith as hereinbefore provided but after
the expiration of that time should they for any cause wish to discontinue
the said Church Chapel or place for religious worship or school or Class
rooms then any houses or shops which may be erected on the said plot of
land shall not be of a less rateable value than Thirty five pounds per
year.
NOTE:-The building line referred to is the existing line of building.
END OF REGISTER
NOTE: The date at the beginning of an eniry is the date on which the entry was made in the Register.
En pages
1955013003
Bond Pearce
Ballard House
West Hoe Road
Plymouth
PLI3AE
Dear Sirs
Client Ref No:
Name of Subject:
Subject Found
Address:
Subject Found
Telephone No:
Subject Property Type:
Marital States:
Employment Status:
Assets:
Credit Search:
Information verified by:
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GLOBAL INVESTIGATIONS
4 PENRHYN ROAD
KINGSTON
SURREY KTI 2BZ
GRO"! Facsimile! GRO}
21 March 2006
Presue & Asset Report
Trace Request 114044
LRB1048035.134
ir. Lee Castleton
j GRO j
Your subject and Wife jointly own the property (Title no. I
subject also owns a vehicle, however make and mods! ai
Files Clear
Extensive local and database enquiries.
All queries must be notified in writing withiee 30 days of receipt of this report,
The information above is xapplied for the sole use of the person or persons to whorn itis
supplied on the understanding thes the contents should be treated as highly confidential
and must not be disclosed to a third party. Whilst every endeavor is made to ensure that the
above information is corvect and accurate, no responsibility can be accepted if this does not
prove to be se. None of the above information has beer obtained in contravention of the
Crimizal Jastice and Public Order Act 1994 and the Data Protection Act 1984,
www. globalin vestigations.co.uk
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Flamingo Land. Wild Animals, Wilder Rides - Contact Page 1 of 2
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These are the notes referred to on the following official copy
The electronic official copy of the title plan follows this message.
Please note that this is the only official copy we will issue. We will not issue a paper official copy.
This official copy was delivered electronically and when printed will not be to scale. You can obtain a paper
official copy by ordering one from Land Registry.
Applications are pending in Land Registry, which have not been completed against this title.
Where the plans work for these pending applications has been partly completed, additional references may
appear on the title plan that are not referred to in the register.
This official copy is issued on 30 April 2007 shows the state of this title plan on 25 April 2007 at 09:26:18. Itis
admissible in evidence to the same extent as the original (s.67 Land Registration Act 2002). This title plan
shows the general position, not the exact line, of the boundaries. It may be subject to distortions in scale.
Measurements scaled from this plan may not match measurements between the same points on the ground
See Land Registry Public Guide 7 - Title Plans.
This title is dealt with by the Land Registry, York Office .
© Crown copyright. Produced by Land Registry. Reproduction in whole or in part is prohibited without the
prior written permission of Ordnance Survey. Licence Number 100026316.
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H.M. LAND REGISTRY
TITLE NUMBER
COUNTY
SHEET.
ORDNANCE SURVEY
PLAN REFERENCE @
Seale: 1/1250
‘The vfficwl copy i incomplete without the preceding notes pags.
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Land Registry
BOND PEARCE
DX 8251
PLYMOUTH
Date
28 March 2006
Title number
Your ref
LRB1/348035 Property
Our ref
HS98639/ERYK
Dear Sirs
Your application is returned to you because we do not hold the
information that you require. The copy of the charge registered on
17 October 2003 and dated 18 July 2003 does not contain the
amount of the loan. In some circumstances the AP1 lodged with the
an application to register a charge will state the value of the loan but
in this instance the value was not stated. Land Registry require the
value of a charge to be stated when the charge being registered
attracts a land registry fee in order that we can assess that fees
have been paid correctly. However in this instance the application
to register the charge also contained a transfer and the value of this
transfer was used to assess the fees.
If you would like to discuss this correspondence or require it in an
alternative format please contact me, quoting our reference.
Land Registry
York Office Yours faithfully
James House
James Street co —_
York YO10 3YZ H
Patricia Robinson.
DX 61599 York 2
r Direct line! GRO:
www.landregistry.gov.uk
2]
1of4
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19 June 2006 Bond Pearce LLP
Ballard House
West Hoe Road
Plymouth PL1 3AE
Global Investigations
11 Penrhyn Road
Kingston Upon Thames
Surrey
KTL 2BZ Our ref:
LRB1/348035.134
Your ref:
Dear Sir
Lee Castleton
Please find enclosed our cheque in the sum of £52.88 in settlement of your invoice number
27475.
Thank you for your assistance in this matter.
Yours faithfully
Bond Pearce LLP
Enclosures
1. Cheque £52.88
Bond Pearce LLP, a Limited Liability Partnership. Registered in England and Wales number OC331430
Registered office: Bristol Bridge House 138-141 Redciff Street Bristol BS1 6B). VAT number GB143 0282 07.
A\list of Members is available from our registered office. Regulated by the Law Society. www.bondpearce.com
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24 March 2006 Bond Pearce LLP
(73 2 Ballard House
West Hoe Road
Plymouth PLi 3AE
rx, GRO
Land Registry York Office He x 257 “plymouth”
DX 61599
York(2)
URGENT Our ref:
LRB1/348035.134
Your ref:
Dear Sir
Lee Castleton
Title Number
We act for the Post Office Limited in this matter and are instructed to collect a debt on their behalf.
We enclose a copy of the Office Copy Entries for ease of reference and note that there is a Registered
Charge dated 17 October 2003 in favour of The Royal Bank of Scotland PLC, 19 Huntriss Row,
Scarborough, North Yorkshire, YO11 2ED.
Enquiries have revealed the value of the property but we are unable to establish the amount of equity
that the proprietor has in the property. We understand that the amount of the loan is stated on the
application for the registered charge and would be grateful if you would provide an office copy or confirm
in writing if you are able.
We confirm that if you require a fee, we authorise you to debit our account (Key No:
We look forward to receiving your response as soon as possible and thank you in advance for your
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Bond Pearce LLP
Bond Pearce LLP, a Limited Liability Partnership. Registered in England and Wales number 0C311430.
Registered office: Bristol Bridge House 138-141 Redcilf Street Bristol BS1 6B). VAT number GBi43 0262 07.
Alllst of Members is available from our registered office. Regulated by the Law Society. www.bondpearce.com