Private & Confidential: Subject to Legal Privilege
Group Litigation Strategy
Monday 14 November 2016, 12:00-13:30 (Cloak Lane, 0.05)
Attendees
Tony Robinson QC Jane MacLeod
Owain Draper Thomas Moran
Andrew Parsons Rodric Williams
Elisa Lukas Mark Underwood
Agenda
1. Thoughts on / response to Freeths substantive letter
2. Remote access — what next?
3. Approach to pleadings / preliminary issues
4. Approach to GLO and preparatory steps
5. AOB
a. Likely media flashpoints
b. Potential impact on operations
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Private & Confidential: Subject to Legal Privilege
Bond Dickinson’s initial impressions of Freeths’ Reply
Headlines
They largely stand by their original claims (apart from dropping the “misfeasance in
public office” claim).
They generally counter-punch Post Office's points rather than develop the claims in any
detail.
No further detail has been provided on (i) the circumstances of the individual claims (ii)
the fraud allegations or (iii) the value of the claims.
They somewhat clarify their arguments on the legal relationship between Post Office
and postmaster, and want the Court to look at the contract issues first before moving on
to other issues.
Freeths expressly identify the "remote access" point and the possible contradiction with
previous statements by Post Office, but have not developed this further.
Other points
1.
Freeths have changed the scope of the proposed GLO to now focus on the Postmaster
Contract.
Freeths propose pausing the criminal cases / malicious prosecution claims until the CCRC
completes its review.
We will receive draft Generic Particulars of Claim by 1 December 2016.
The Second Sight access protocol has been rejected. Freeths are insisting on full
unfettered access.
There are continuing satellite disputes around a number of other issues (e.g. limitation,
causation, etc).