POL00003480 - Letter from Bond Dickinson to James Hartley RE The Post Office Group Litigation, Known Error Log

Evidence on official site

POL00003480
POL00003480

www.bonddickinson.cam

22 September 2017 Bond Dickinson LLP.
Oceana House
38-49 Commercial Road
Southameton

For the Attention of Mr J Hartley
Freeths LLP

Floor 3
100 Wellington Street
Leeds Direct:
LS1 4LT
Our ref:
APBIAPGI364065.1369
By email only Your tef:

WFR/1803/212876/ 1/ER

Email: james.hartley GRO

Dear Sirs

The Post Office Group Litigation
Known Error Log ("KEL")

We refer to your third letter of 13 September 2017.

We note that in your letter you have sought to portray Post Office as refusing to provide access to the
KEL. The possibility of accessing the KEL was not refused by Post Office. Our client's position was that
the KEL was not relevant to these proceedings for the reasons siated in its Generic Defence, but that it
would try to facilitate access to the KEL at an appropriate time. We had stated that in our view the
appropriate time was at the same time as similar disclosure was given.

Whilst we disagree with a number of the points in your letter (including your right to inspect the KEL.
under CPR 31.14), given your anxiety to inspect it Post Office has discussed with Fujitsu the methods by
which access can be provided.

The KEL is a database which cannot easily be downloaded and provided to you. Fujitsu has therefore
kindly agreed that the Claimants’ IT expert may inspect the KEL at its premises in Bracknell. This will
enable your expert to understand the nature of the KEL and to satisfy himself as to the relevance of any
of the entries in it.

Please could you confirm the name and details of your expert and his dates of availability over the next
two weeks. As the KEL contains some information that is confidential and commercially sensitive, Fujitsu
has asked that your expert signs a routine non-disclosure agreement. We have asked Fujitsu to provide
a draft for your approval.

Yours faithfully

Bond Dickinson LLP

Bond Dickinson LLP is a limited liability partnership registered in England and Wales under number 0C317661. VAT registration number is
GB123393627. Registered office: 4 More London Riverside, London, SE1 2AU, where a list of members’ names Is open to inspection. We use the
term partner to refer to a member of the LLP, or an employee or consultant who is of equivatent standing. Bond Dickinson LLP is authorised and.
regulated by the Solicitors Regulation Authority.

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