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Message
From: Rodric Williams
Sent: 22/06/2016 14
To: Th
Patrick Bourke I; Mark R Davies
Rob Houghton Tom Wechsler
Nick Sambridge
cc: Parsons, Andrew
Subject: RE: Postmaster Litigation Steering Group - Confidential and Subject to Legal Privilege
Attachments: PLSG Agenda 22.06.16.docx;_DOC_33198938(1)_Group Action - Work Plan - 21 June 2016.docx
All —I attach the updated Agenda for today’s meeting, which includes two a resource points (item 6) and the scheduled
date for the next meeting (item 8).
I also attach the litigation work plan which focuses on the work being done to respond to Freeths’ Letter of Claim.
See you at 4pm,
Rodric
From: Rodric Williams
Sent: 20 June 2016 19:08
To: Thomas P Moran; Angela Van-Den-Bogerd; Patrick Bourke; Mark R Davies; Rob Houghton; Tom Wechsler; Nick
Sambridge
Cc: Jane MacLeod; Parsons, Andrew
Subject: Postmaster Litigation Steering Group - Confidential and Subject to Legal Privilege
All,
Thank you all for your engagement in the first Steering Group meeting on 7 June 2016. I now attach the proposed
agenda for the next meeting on Wednesday 22 June at 1600. Please let me know if you have any comments or
additions.
The follow up actions to the first meeting were:
1. Circulate Second Sight’s Reports
Please find attached Second Sight’s:
a. “Interim Report into alleged problems with the Horizon system” dated 8 July 2013;
b. “Mediation Briefing Report - Part One” dated 22 May 2014 (this was essentially written by Post Office, and
provides non-contentious descriptions of branch operating procedures and related Horizon functions); and
c. “Briefing Report - Part Two” dated 9 April 2015 (this contains Second Sight’s more contentious statements and
allegations).
lalso attach the “Reply of Post Office Limited to Second Sight's Briefing Report — Part Two” dated April 2015, which
should be read in conjunction with Second Sight’s Briefing Report - Part Two.
Second Sight also produced individual “case review reports” for cases submitted to the Complaint Review and Mediation
Scheme. We therefore have these reports for the 70 Scheme applicants who are now Claimants in the Postmaster
Litigation, and can share them with the Steering Group as and when they become relevant.
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2. Letter of Response - Timetable
The current timetable for Post Office’s response to Freeths’ Letter of Claim is:
- 28 June 2016: Bond Dickinson to provide draft Letter of Response to Post Office Legal.
- 29 June to 14 July 2016: Refinement of draft with a view to circulating to Steering Group as soon as possible
before meeting on 15 July 2016. This is likely to require input from various parts of the business.
- 15 July 2016: Deadline for circulating draft to Steering Group.
- 20 July 2016: Steering Group Meeting to approve draft.
- 28 July 2016: deadline for sending Letter of Response.
3. PLSG Terms of Reference
I attach the final Terms of Reference, which reflect Angela’s point that the PLSG needs to protect Post Office generally,
not just the Network (para. 2.1).
4. Communications Protocol
Please remember:
- All documents, including emails, should be marked “Confidential and Subject to Legal Privilege”.
- Donot forward or circulate documents connected to the Claim beyond the agreed distribution list.
- Be careful when creating new documents which concern the litigation - ideally, you and your teams should only
have to reply to / comment on an email or document generated by one of our lawyers.
- Donot destroy any documents that may be relevant.
- If in doubt about any document, consult Legal.
5. Internal Stakeholder Communications
l attach the Reactive Lines that Comms prepared in May 2016, shortly after the Freeths Litigation was started. Please
consider (and keep under review) whether your teams require anything more (see Agenda item 2.a).
Please let me know if you have any questions on the above or generally.
Kind regards, Rodric
° Rodric Williams
Solicitor, Corporate Services
Post Office Ltd
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