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  • POL00294869 - Memo from Rod Ismayu to Angela Van Den Bogerd and others on 12/10/11 re: JFSA and Shoosmiths / Access Legal - Response to Challenges - Proposed Steering Group and Purpose.

POL00294869 - Memo from Rod Ismayu to Angela Van Den Bogerd and others on 12/10/11 re: JFSA and Shoosmiths / Access Legal - Response to Challenges - Proposed Steering Group and Purpose.

Evidence on official site

CONFIDENTIAL

To Angela Van Den Bogerd, Head of Network Services Cc Mike Young, Chief
Operating Officer

Lesley Sewell, Head of IT Kevin Gilliland, Network & Sales
Director

Mike Granville, Head of Regulatory Relations Susan Crichton, Legal &
Compliance Director

Dave Pardoe, Senior Security Manager Chris Day, Chief Financial Officer

Rebekah Mantle, Principal Lawyer Sue Huggins, General Manager
Network

Hugh Flemington, Head of Legal John Scott, Head of Security

David Simpson, Press Office
From Rod Ismay, Head of Product & Branch Accounting 12 October 2011

JFSA and Shoosmiths / Access Legal — Response to Challenges
Regarding Horizon System
Proposed Steering Group and Purpose

Purpose

To define and manage a co-ordinated response plan which defends existing
challenges and deters future challenges, in the most pragmatic and efficient
manner.

Background

Throughout the last 10 years, the Horizon accounting system has been
subject to a number of unfounded criticisms in the national press. It has also
faced questions in the Houses of Parliament and allegations in court by
former subpostmasters and their legal defence teams. Post Office has
consistently won its prosecutions, and presiding judges have made
statements which had been expected to deter further baseless allegations,
however, the challenges continue to be made.

The situations have arisen in a minority of cases where POL has dismissed a
subpostmaster for financial irregularities and the subpostmaster has claimed
that it was the accounting records that were wrong due to IT issues, rather
than that money had been stolen.

Current Situation

Shoosmiths (Access Legal) are acting for several former subpostmasters.
These individuals come together in the JFSA (Justice For Subpostmasters.
Alliance). POL has now received commonly worded “Letters Before Action”
from Shoosmiths on behalf of 4 former subpostmasters. These are
precursors to claims for damages against POL. They request significant
materials to be disclosed.

POL had around 20 cases which it wished to take to court, where the defence
blamed Horizon. POL is confident that Horizon is not at fault, however, some
of the predicted legal costs outweighed the debts being pursued. POL could
not economically justify individual cases but to abandon such cases risked
giving unwarranted credence to the jfsa’s allegations.

The counter claims have now brought these to a head. POL now has to
defend onerous requests from Shoosmiths and consider its response to all
the cases above.

POL00294869
POL00294869
POL00294869
POL00294869

CONFIDENTIAL

Live Actions and Content For First Steering Group

1.

APRON

>

Legal advice on POL’s options for pragmatic response to the LBA’s

Rebekah
Allocation of Project Manager Lesley
Funding for Project Manager Rod

Clarity on data gathering underway (Security, P&BA, Network, IT) All

Reactive statement stance should Private Eye type coverage continue
David

Learning from past cases including Ferndown Angela, Dave

Key Risks To Note

Media — the challenges are gathering momentum and interest

Resource and dependencies — onerous requests and dependencies on
key individuals

Capacity — impractical to support multiple legal actions in parallel

Focus — resource distraction from strategic programme

Literal response — risk of current fact gathering continuing at cost when
not needed

Sustainability - risk of “but what if’ by future defendants, even when these
cases are won

Cost — expensive court cases and low likelihood of debt recovery, but POL
must defend itself

Perception — loss of confidence by potential new network partners and
clients

Records — missing files which could undermine our ability to proceed
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Converted by Matthew Somerville.