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Message
From: Rodric Williams [rodric.williams:
Sent: 06/11/2019 00:17:52...
To: Ben Foat [Ben.Foai i
cc: Watts, Alan [/ Emanuel, Catherine [Cath
arsons [andrew.parson’ GRO
jichael Wharton [michael-whartoi
Kenneth Garvey [Kenneth.Garve
[Alex.Lerne.
[jonathan.gri
[Sherrill Taggart.
[Ainsliecranwet GRO :
Subject: UPDATED KEL Disclosuré Actions Table - as at 05.11.19
Attachments: KEL Disclosure Actions Table (05.11.19).docx
Ben.
I have further updated the KEL Action table in light of the progress made with the audit (see SharePoint link below, also
attached in Word).
https:/
luk. sharepoint.com/:w:/s/POAGOI/legal /EVnirAvM5HBPn91BOxaceIMBHYFowPmec-vO485OPatsce
I understand that the auditors were today finishing off their final checks before they proceed to write up their report.
We will be confirming this with them first thing tomorrow, at which point the Table may need some final tweaking.
I have again also sought to flag the main developments in the form of a draft covering email for you to send to the Board
as you see fit.
DRAFT EMAIL BEGINS
All,
Attached is our KEL’s action tracker which outlines the progress made. In summary:
1. The Claimants, having been provided with the further information they requested about this issue and told
about the audit commissioned on the KEL disclosure, have informed us and the Court that they do not intend to
review the new KELs or make further submissions on this issue.
2. The audit is nearing completion, with final checks to be completed before the audit report is written. We expect
to receive that report early next week.
3. The audit has not yet identified any further KELs which need to be disclosed to the Claimants or would require
Post Office to change the submissions we made about Horizon when the trial closed. If (as seems likely) this
remains the position following completion of the audit, the KEL issue will not require the Horizon trial to be
reopened or delay delivery of the judgment on the trial (which is now imminent).
Please do let me know if you have any queries.
DRAFT ENDS
Please let me know if you require anything further.
Rod
From: Ben Foat
Sent: 02 November 2019 14:32
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Kenneth Garvey <Kenneth.Garvey GRO »; Sherrill Taggart <Sherrill.Tagga
Subject: RE: UPDATED KEL Disclosiiré Actioris Tablé~'as at 01.11.19
Thanks Rod
This is helpful but I think timing wise it would be helpful for this to be urgently update on Monday morning re the audit
issue so we cant finalise it properly. So, lets get the audit issue sorted so we can give a final view to the Board Monday
morning.
Thanks
Ben
Ben Foat
Group General Counsel
Ground Floor
20 Finsbury Street
LONDON
EC2Y 9AQ
From: Rodric Williams <rodri
Sent: Friday, November :
To: Ben Foat <Ben. Foot
Lerner, Alex
andrew. parsons <an,
“Kei 1 Garvey <Kenneth.Garvey:
Subject: UPDATED KEL Disclosure ‘Actions Table - as ot 01.11.19
Ben,
I have updated the KEL Action table in light of the response received from Freeths today (see SharePoint link below, also
attached in Word).
>RCoxZ17 NDtynkVweFXEUBgP3QiSHBGHD I doQzEw0Ce:
orn /:w:/s/POA00I/leg:
https: .sharepoi
I have again also sought to flag the main developments in the form of a draft covering email for you to send to the Board
as you see fit.
Please let me know if you require anything further.
Rod
DRAFT EMAIL BEGINS
All,
Attached is our KEL’s action tracker which outlines the progress that has been made. In summary:
1. The Claimants have now indicated to the Court that they do not intend to make further submissions on the KEL
issue because they do not want to delay delivery of the Horizon judgment.
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2. The audit of the completeness of Fujitsu’s KEL disclosure has commenced and is proceeding at pace. A
preliminary view will be provided on Monday 4 November on whether Post Office may need to take further
action to comply with its legal duties around document disclosure in the litigation.
3. Advice on what (if anything) should be communicated to the Court and/or Claimants about the audit, and the
impact this could have on the litigation, will be provided at that time.
Please do let me know if you have any queries.
DRAFT ENDS
® Rodric Williams
Head of Legal - Disoute Resolution & Brand
20 Fins!
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