POL00006600 - Email from Rodric Williams to Jonathan Swift cc Christopher Knight RE: Post Office Limited - Update and Request for Further Advice

Evidence on official site

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Message

From: Rodric Williams

Sent: 26/07/2016 10:

To: “lonathan. Swift:

ce: ‘Christopher Knight’ [

Subject: FW: Post Office Limited - Update and Request for Further Advice

Attachments: _SCANNEDLETTERS_33200537(1)_POL 21 Jun 16_ Bates & others v Post Office ....pdf

Dear Jonathan,
I hope this finds you well.

I write to update you on where matters stand following my email below, which we discussed by telephone on 27 May
2016. During our call, we understood your advice to be that it would be reasonable for Post Office’s Chairman to take
advice on the recommendations made in your January 2016 report from the legal team defending Post Office in High
Court Group Litigation which raises substantially the same issues as those which gave rise to your recommendations. We
also understood your advice to be that it would be equally reasonable for the Chairman to continue work started on
your recommendations, given that they stand as the outcome of your report irrespective of the Group Litigation.

On 9 June 2016, Post Office met with the external legal team advising it on the Group Litigation, which is being led by
Tony Robinson QC. I attach a letter dated 21 June 2016 from Bond Dickinson, Post Office’s solicitors in the Group
Litigation, which records the advice given during that consultation. Given the very strong advice from Leading Counsel,
the Chairman instructed that the work being undertaken in response to your recommendations should end, and instead
be addressed through equivalent work taken forward in the Group Litigation.

Please let me know if this raises any issue for you. Otherwise, we thank you for your valuable advice in this matter, and
would hope to be able to call on your services again should the need arise.

With kind regards, Rodric

From: Rodric Williams
Sent: 24 May 2016 O1
To: ‘Jonathan.Swift
Ce: ‘Christopher Knight’; Patrick Bourke; Jane MacLeod; Mark Underwood1; ‘John. Davitt¢
Subject: Post Office Limited - Update and Request for Further Advice

Jonathan,

POL has been progressing the 8 recommendations you made in your January 2016 Chairman’s report concerning the
further steps that POL might reasonably take in respect of the SPMR cases. With respect to the recommendations
concerning Horizon (recommendations 3, 4 and 5) and POL’s suspense accounts (recommendation 8), Deloitte LLP has
scoped work that could be taken to address the recommendations, and has provided to POL a range of procedures
which could be performed.

POL is now considering the further instructions it could provide to Deloitte. Influencing these considerations is that on
11 April 2016, court proceedings were started against POL when 91 Claimants issued a Claim Form in the High Court of
Justice, Queen’s Bench Division (copy attached). The Claim Form has not been served (it was provided to us for
information only), and is not currently supported by a Statement of Case. It has however been supplemented by a letter
dated 28 April 2016 from the Claimants solicitors, Freeths LLP, purportedly sent pursuant to the Practice Direction on

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Pre-Action Conduct. The letter is long (53 pages) and references (among others) issues with Horizon and POL’s suspense
accounts which overlap your recommendations 3, 4, 5 and 8, as well as issues with Post Office’s prosecution practices
(overlapping your recommendation 1) and branch support systems (overlapping your recommendation 7).

When you first considered this matter for POL’s Chairman, the SPMRs had been advancing their concerns through
extrajudicial means, e.g. through MPs and in the media. Now that POL has been sued, is it reasonable for POL to address
any further steps it might reasonably take in respect of the SPMR cases through the proceedings, rather than in
response to your report and recommendations?

I appreciate you may not have given this matter much thought over the past few months, so we would be happy to
discuss this with you further by telephone in the first instance. I have copied John Davitt to help with the arrangements
if you would find that more convenient.

With thanks and kind regards,
Rodric

° Rodric Williams
Solicitor, Corporate Services

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