POL00025758
POL00025758
From: Jonathan Swift <
To: Rodric Williams
Ce: Christopher Knight <
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.
ri GRO
www. 11kbw.com
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From: Rodric Williams
Date: Tuesday, 26 July 2016 1.
To: Jonathan Swift <7
Ce: Christopher Knight ¢_ “
Subject: FW: Post Office Limited - Update and Request for Further Advice
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
POL-0022237
POL00025758
POL00025758
From: Rodric Williams
Sent: 24 May 2016 00:33
To: ‘Jonathan.Swift¢ i
Ce: ‘Christopher Knight’; Patrick Bourke; Jane MacLeod; Mark Underwood1; ‘John.Davitté..
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?
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
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POL-0022237