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Message
From: Andrew Parsons} GRO :
Sent: 24/03/2018 07:50:11" °
To: Rodric Williams
ce: Amy Prime
Subject: Re: Draft UKGI Information Sharing Protocol
Rod.
Looks good. One thought....
Should the background section extend beyond the group lit? le. Should it cover the CCRC and “other issues covering the
same subject matter as the group lit” (I’m thinking here of overlapping BAU issues; any attempt to restart prosecutions,
etc.).
’'m happy with para 1.6.
A
From: Rodric Williams
Sent: Saturday, March 24, 2018 2:14 am
Subject: Draft UKGI Information Sharing Protocol
k
Veronica
“T Patrick Bourke
Branton { +, Amy Prime
All
Further to our call this evening, I attach a draft Protocol for sharing information about the Group Litigation with
BEIS/UKGI (I have tried to cover off both), which I propose to send to UKGI’s General Counsel under cover of the draft
email set out below once finalised at our end.
Please let me know of any comments you may have.
Andy/Amy — can you please take a particular look at the “Background” section and Appendix B to see if it goes far
enough for privilege purposes in establishing a common interest in both the litigation and the need to maintain
confidentiality in the material we may be sharing?
Please also look at clause 1.4.6 and 1.6 to see if they go far enough to help us resist (or at least give us visibility of) any
FOIA or CCRC/Criminal Justice Act request that could be made to BEIS/UKGI.
Thanks, Rod
DRAFT COVERING EMAIL TO UKGI BEGINS
Thank you for sending through your draft protocol identifying the touchpoints in the Post Office Group Litigation on
which you would like visibility.
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Your touchpoints overlap substantially the matters on which we will be reporting to our Board of Directors as part of our
governance for managing the litigation and its risks. That governance includes the establishment of a Board
Subcommittee to receive legal advice on Post Office’s defence as the litigation proceeds. It is proposed that Tom
Cooper, BEIS/UKGI’s shareholder representative on the Board, be appointed a member of the Litigation Subcommittee,
which will meet shortly before full Board meetings so as to provide the full Board with contemporaneous, focussed
updates.
In addition to the updates BEIS/UKGI will receive through its Board and Litigation Subcommittee representation, we are
also happy to provide updates on the litigation to BEIS/UKGI’s legal advisors. These should be done in-person or via
telephone conference call, immediately following the full Board meetings to ensure continuity and consistency of
reporting.
The above approach is reflected in the attached revised protocol, which attaches as appendices:
- areporting timetable prepared around key stages in the litigation and our Board’s calendar; and
- the obligations which will accompany the disclosure of confidential information.
Please note that as part of our continuous assessment of the risks presented by the litigation, we are seeking in May
2018 Leading Counsel’s opinion on its merits. This has been timed to follow the close of individual pleadings for the 6
Lead Claimants selected for the November 2018 Common Issues trial. We intend to review that opinion again in
October 2018 once all documentary and witness evidence submitted for the Common Issues trial has been exchanged.
Please also note that the litigation timetable is very likely to change in response to the proactive case management
being applied by the Managing Judge Sir Peter Fraser. It is also likely to change in response to developments in the
litigation itself. We do not however propose to make any changes to scheduled update meetings unless they require
Post Office to consider materially changing its approach to the litigation.
We look forward to receiving your comments on the proposal. I am very happy to discuss those in person or over the
telephone if you would find that easiest.
Yours etc...
DRAFT ENDS
* Rodric Williams
Head of Legal - Dispute Resolution & Brand
20 Finsbury Street
London EC2¥ 9AQ
2017 Winner of the Global Postal Award for Customer
Experience
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POST OFFICE LIMITED is registered in England and Wales no 2154540. Registered Office: Finsbury Dials,
20 Finsbury Street, London EC2Y 9AQ.
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Andrew Parsons
Partner
Womble Bond Dickinson (UK) LLP
wombiebonddickinson.com
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