POL00041482
POL00041482
20 September 2017 Bond Dickinson LLP
‘Oceana House
39-49 Commercial Road
‘Southampton
S015 1GA,
For the Attention of Mr J Hartley
Freeths LLP
Floor 3 ‘Southampton 3
100 Wellington Street andrew parsonsé”
Leeds Direct:
LS1 4LT
Our ref:
. AP6/AP6/364065.1369
By email only Your ref:
IFR/1803/212876/1/ER
Email: james.hartleyt_.
Dear Sirs
The Post Office Group
Known Error Log ("KEL")
We refer to your third letter of 13 September 2017.
We note that in your letter you have sought to portray Post Office as refusing to provide access to the
KEL. The possibility of accessing the KEL was not at any stage refused by Post Office. Our client's
position was that the KEL was not relevant to these proceedings for the reasons stated in its Generic
Defence, but that it would try to facilitate access to the KEL at an appropriate time. We had stated that in
our view the appropriate time was at the same time as similar disclosure was given.
Whilst we disagree with a number of the points in your letter (including your right to inspect the KEL
under CPR 31.14), given your anxiety to inspect it Post Office has discussed with Fujitsu the methods by
which access can be provided.
The KEL is a database which cannot easily be downloaded and provided to you. Fujitsu has therefore
kindly agreed that the Claimants’ IT expert may inspect the KEL at its premises in [Bracknell??]. This will
enable your expert to understand the nature of the KEL and to satisfy himself as to the relevance of any
of the entries in it.
We anticipate being able to arrange a date for inspection within the next [7] days. Please could you
confirm the name of your expert and his dates of availability. Please also confirm that any information
gathered by your expert from the KEL will be treated as being subject to CPR 31.22.
Yours faithfully
Bond Dickinson LLP
Bond Dickinson LLP is a limited liability partnership registered in England and Wales under number 0C317661. VAT registration number is
GB123393627. Registered office: 4 More London Riverside, London, SE1 2AU, where a list of members’ names is open to inspection. We use the
term partner to refer to a member of the LLP, or an employee or consultant who is of equivalent standing. Bond Dickinson LLP is authorised and
regulated by the Solicitors Regulation Authority.
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