POL00025188 - Letter from the Post Office Limited to Ron Warrington and Ian Henderson of Second Sight Support Services Limited

Evidence on official site

POL00025188
POL00025188

@ Post Office Limited
Finsbury Diats

20 Finsbury Street

London

EC2Y 9AQ

PRIVATE AND CONFIDENTIAL

By post and email

Ron Warrington & Ian Henderson
Second Sight Support Services Limited
Tythe Farm

Maugersbury

Cheltenham

Gloucestershire

GL54 LHR

2 June 2015

Dear Sirs
M035 ~ Josephine Hamilton (the “Applicant”)

We refer to the above Applicant and, in particular, to your final Case Review Report
(CRR) dated 24 March 2015 in relation to the Applicant‘s case.

At paragraph 4.10 of the CRR, you quote from a “Post Office Investigator’s Report
dated 17 May 2006” (the “Security Report”). At paragraph 4.11 of the CRR, you
speculate about the impact the Security Report may have had on the criminal
prosecution brought against the Applicant.

The Security Report was not appended to the final version of the POIR because it is
protected from disclosure by legal professional privilege. That privilege belongs to
Post Office Limited and does not extend to anyone beyond Post Office Limited and its
professional legal advisors. Post Office Limited continues to assert privilege over the
Security Report.

As a consequence of your disclosure, on 6 May 2015 we received a request from the
Applicant for a copy of the Security Report which noted that the document quoted in
the final CRR at paragraph 4.10 was not present in the pack of documents appended
to the POIR. We have responded refusing the Applicant’s request on the basis that the
document is privileged (see attached).

We nevertheless remain concerned about your disclosure of the Security Report.
Please therefore explain to us in writing why:

1. you considered its disclosure to be consistent with the undertaking provided on
19 October 2012, a copy of which is appended to this letter, confirming that
certain documents provided by Post Office Limited are privileged, that the
benefit of that privilege shall at all times belong to Post Office Limited, and that
the documents and their contents “will be held in complete confidence and will
not be disclosed to any other party or used for any other purpose whatsoever
without the prior written consent of Post Office Ltd”;

2. you referred to it when it was not appended to the POIR;

3. you referred to it in your final report only, and not in the draft CRRs on which
Post Office Limited was able to provide comment;

Post Office Limited is registered in England and Wales. Registered No. 2154540. .
Registered Office Finsbury Dials, 20 Finsbury Street, London, EC2Y 9AQ PostO ffice.co.u k

Post Office and the Post Office logo are registered trade marks of Post Office Limited

POL00025188
POL00025188

4. you commented on it as you have when you are not in possession of all
material information and when matters of criminal law and procedure are
outside your scope of expertise,

We look forward to receiving your response within the next 7 days. Post Office
Limited’s position remains fully reserved in the meantime.

_..Yours faivfifully

GRO

Solicitor
For and on behalf of Post Office Limited