POL00120837
POL00120837
Stephen Dilley
From: mandy.talbot¢_
Sent: 05 April 2006 09:51
To: Stephen Dilley
Subject: 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
“Tl, Mobile:
, "Tom
Beezer" <Tom.Beezer(
04/04/2006 10:35 Subject: Bajaj an
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,
I propose to contact you then.
T look forward to hearing from you.
Kind regards.
Stephen Dilley
Solicitor
behalf of Bond Pearce LLP
www.bondpearce.com
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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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.
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Stephen Dilley
From: lan Herbert{
Sent: 04 April 2006 10:
To: Stephen Dilley
Subject: RE: Post Office - Bajaj and Castleton
Cheers,
My direct line is!
Regards,
lan.
Sent: 04 April 2006 1u: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?
Sent: 03 April 2006-1S:097-—-""~
To: Stephen Dilley
Cc: Tom Beezer
Subject: RE: Post Office - Bajaj and Castleton
Friday is now good for me.
Regards,
lan.
07/04/2006
ono Original Message:
From: Stephen Dilley .
Sent: 03 April 2006 09:28
To: Ian Herbert
Cc: 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 availabi
Wednesday or Friday. I'll then go back to Mandy.
Kind regards.
Stephen Dilley
From: Ian Herbert [
Sent: 31 March 2006
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
lity on
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,
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lan.
-----Original Message--
From: Stephen Dilley [
Sent: 31 March 2006 1
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
for and on behalf of Bond Pearce LLP
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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
OBJ.
A list of Members is available from our registered office. Any reference to a
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__Disclaimer
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Hugh James Solicitors is authorised and regulated by the Financial Services
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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.
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
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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
From: mandy.talbott
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.xis; fad 140114 dec 04 to date Torquay.xls; Torquay rd.doc; fad 233313 dec 04 to
mar 05 calls Bowburn.xls
BM Shobnall Road fad 213337 dec 04 fad 140114 dec 04 Torquay 8 td.doc (30 fad 233313 dec 04
SPSO 150405.d... to mar 05 ca... to date Torq... KB) to mar 05 ca...
Ei
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. 1
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
Postline: N/A, STD Phone: {
N/A, Mobex:! GRO _ } Mobil
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
ject: 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 please.
Systems Live Service Manager
Post Office Ltd
Operations
1st Floor, Post Office Ltd, Cortonwood Business Park, Cortonwood Drive, BARNSLEY, S73 OTB
Mobile:
Fax: N/A, VoiceMail: N/A, Mobex:
jail: gary.blackburr
Dave Hulbert co
To: — Gary Blackburnj, GRO
B cc: = Adam Marti
Nicola
Subject: 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
alee” Forwarded by Dave Hulbert), GRO ~
Mandy Talbot
Elillhert/
‘e/POSTOFFICE(
GRO te
_ John D
Ward/e/POSTOFFICE,
Baines/e/POSTOFFICE; I Cc
‘ailagher/e/POSTOFFICE(”
cc: Clare J
stephen.dilley,
Subject: Horiz«
rivate and Conf
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 2005. 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.xis)
T 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 1P)
, Mobile:
External Email: mandy.talbot
>>>> bajaj fujitsu.pdf attachment was removed from this email <<<<
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>>>> email
<<<<
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Mandy Talbot
Litigation Team Leader
Company Secretary's Office
Legal Services
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* Royal Mail, Impact House, 2 Edridge Road, CROYDON, CR9 1PJ
4 STD Phone: ! } Fax:
I, Mobile:
To: <mandy.talbot!
i ee:
jubject: Post Office Limited v Lee Castleton
28/03/2006 19:31
Dear Mandy,
I refer to my e-mail of 20 March.
I 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.
Stephen Dilley
Solicitor
for and on behalf of Bond Pearce LLP
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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.
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Telephone attendance
Client: Post Office Limited
Matter: Mr Lee Castleton - DEBT £30027.47 Matter no: 348035,134
Attending: Cheryl 01246 542302
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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From: Stephen Dilley
Sent: 24 February 2006 14:42
To: 'mandy.talbot O H
Cc: Tom Beezer; Jullarsurmerrayes
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 I
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 uiscuss 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 moment. ? If not, please could
you call my colleague Julian Summerhayes next week o: ? 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
From: Stephen Dilley
Sent: 20 February 2006 1
To: 'mandy.talbott’ i
Cc: Tom Beezer; Julian Summerhayes
Subject: Post Office -v- Castleton
Dear Mandy,
I refer to my 7 February email.
I 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. 1 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
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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 vunvenient time this week for you?
I look forward.to hearing from you.
Kind regards.
Stephen Dilley
Solicitor
27/02/2006
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Laura Peto
bom: 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
www.bondpearce.com
06/03/2006
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