POL00145359
POL00145359
From: Susan Crichton[IMCEAEX-
_O=MMS_OU=EXCHANGE+20ADMINISTRATIVE+20GROUP+20+28FY DIBOHF23SPDLT+29
_CN=RECIPIENTS_CN=SUSAN+20CRICHTONC5FA6431-DC28-49AB-8F0F-
BE4237A4AD4F @C72A47.ingest.local]
Sent: Thur 11/07/2013 10:
To: Rodric Williams
Ce: Hugh Fleminaton! ]; Jarnail A
Singh.
Subject: RE: POL -v- Ishaq - Proposed letter to defence solrs
Did we ever answer the ques as to why the HR report was created?
Susan Crichton I HR & Corporate Services Director
t I Wing, 148 Old I Street, London, EC1V 9HQ
From: Rodric Williams
Sent: 10 July 20
To: 'martin.smitht._.
Cc: Hugh Flemington; ig)
Subject: FW: POL -v- Ishaq - Proposed letter to defence solrs
Further thought on privilege — if Helen’s investigation into this was undertaken purely for the Second Sight Spot
Reviews, the entire report could be privileged.
I attach a couple of emails which set out the basis on which we have sought to claim privilege over our work on the
Spot Reviews, including our communications with Fujitsu which sought to create a joint/common interest privilege.
Please let us know if Helen’s report is still disclosable in light of this.
Happy to discuss as necessary.
Kind regards, Rodric
From: Rodric Williams
Sent: 10 July 2013 15:49
To: ‘martin smith’; Hugh Flemington
Cc: Jarnail A Singh; Susan Crichton
Subject: RE: POL -v- Ishaq - Proposed letter to defence solrs
Thanks Martin.
First point - we presume that Helen Rose’s report is being disclosed because POL’s evidence in the prosecution
included an ARQ report. Is that right?
POL00145359
POL00145359
Second point - Helen Rose’s Report is marked “Confidential and legally privileged”.
I understand that she did this because she prepar
implications of her investigation (please call her o
give to Post Office Legal for legal advice on the
ito confirm).
Please therefore consider what information from the report needs to be disclosed to Ishaq’s solicitors, and in what
format, i.e. whether parts of the Report should be removed or redacted (e.g. the “Recommendations” section), or the
non-privileged material (e.g. the background transaction data) repackaged for disclosure to the Defence.
If you advise that Helen’s report does not attract any privilege, please ensure the reference to privilege is removed
from the header (I don’t want to someone else to say that the Report is privileged, but that we waived thereby giving
rise to possibly difficult issues of collateral waiver).
Kind regards, Rodric
Rodric Williams I Litigation Lawyer
iO} 148 Old Street, LONDON, EC1V SHQ.
a}
© I
(oy) Post Office stories
© @postofficenews
From: martin smith GRO
Sent: 10 July 2013 10:56
To: Hugh Flemington
Cc: Jarnail A Singh; Susan Crichton; Rodric Williams
Subject: POL -v- Ishaq - Proposed letter to defence solrs
Dear Hugh,
Please find attached a copy of the letter which we propose, subject to your agreement, to send to
Ishaq's solicitors.
Kind regards,
Martin.
martin.smith'
martin,smith
Direc!
GRO !
CartwrightKing
mu SOL CTT ORS
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