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From: Jonathan Swift <[
To: Rodric Williams <j"
Ce: Christopher Knight <j
Subject: Re: Post Office Limited - Update and Request for Further Advice
Date: Tue, 26 Jul 2016 14:06:14 +0000
Importance: Normal
Inline-Images: image001.png
Dear Rodric,
Thank you for letting us know. Chris and IU are content with this — as we discussed, counsel instructed on
the litigation are much better placed to make this type of judgement. Best of luck with the defence to the
claim. And our sincere thanks to all for the assistance since last year.
Regards,
Jonathan
Jonathan Swift QC
11 KBW
11, King's Bench Walk,
Temple, London. EC4Y 7EQ.
www. 11kbw.com
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From: Rodric Williams <
Date: Tuesday, 26 July 2016 11:35
To: Jonathan Swift <
Cc: Christopher Knight <
Subject: FW: Post Office Limited - Update and Request for Further Advice
Dear Jonathan,
I hope this finds you well.
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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
To: ‘Jonathan. Swi .
Ce: ‘Christopher Knig] ick Bourke; Jane MacLeod; Mark Underwood seJohn.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 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?
l 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
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