POL00041825 - Email from Rodric Williams to Jane MacLeod and others re PO Group Litigation

Evidence on official site

POL00041825

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Message
From: Rodric Williams?
Sent: 30/05/2018 16:53:36
To: Jane MacLeod! Mark Underwood; GRO 45 Andrew
Parsons I
ce: Ben Foat {” GRO
Subject: FW: Post Office Group Litigation - SUBJECT TO LEGAL PRIVILEGE

Attachments: BBC Belfast 24 May 2018.pdf; Campaign4Change May 30 2018.pdf

Jane, Mark, Andy,

Please see below for your information the update sent today to UKGI’s lawyers. I have expressly referred to this as
having been sent pursuant to the Information Sharing Protocol I emailed to them on 22 May 2018. They have not
however responded on that draft as yet.

Rod

From: Rodric Williams
Sent: 30 May 2018 17:49
To: O'Neill, Elizabeth - UKGI
Subject: Post Office Group Litig:

‘Lambert, Helen - UKG
VILEGE

Post Office Group Litigation - SUBJECT TO LEGAL PRIVILEGE

Elizabeth, Helen,

I write to update you on the following matters connected to the Postmaster Complaints (as defined in the draft
Information Sharing Protocol emailed to you on 22 May 2018, pursuant to which this update is sent):

Case Management Conference (CMC) — 5 June 2018 at 2pm

The Post Office Group Litigation will be back before the court for a CMC on 5 June 2018, primarily to discuss:

- Costs Budgets. As part of the standard litigation costs management processes, both parties submitted costs
budgets to take the claim through to the conclusion of the March 2019 Horizon Issues trial. At the CMC, the
parties will test the budgets (each being c.£13m, including all costs and disbursements incurred to date), with
Mr Justice Fraser ultimately deciding the reasonableness of the budgets. The outcome of this exercise will assist
in determining the level of security the Claimants may have to provide in response to Post Office’s application
for Security for Costs (which has not yet been listed for hearing).

- Horizon Issues / Expert. At the CMC, we expect the Court to make orders for the provision of further
information to assist the parties’ experts provide their opinions on the Horizon Issues being tried in March
2019. As with the scope of disclosure for the Common Issues trial, the principal point of dispute between the
parties concerns the very wide breadth of request made by the Claimants and their expert.

It is also possible that the CMC will consider the time for Post Office to file its Defences to the 6 Individual Particulars of
Claim filed for the Common Issues trial. These are currently scheduled to be filed on 1 June 2018, but an extension is
required due to Freeths indicating that it wants to file amended Particulars of Claim in one case. The only issue is
whether a one or two week extension is appropriate, but if this comes before Mr Justice Fraser, he may take the
opportunity to comment on the need to progress the case expeditiously, e.g. if he is concerned about any consequential
impact an extension may have on the Common Issues trial’s start date of 5 November 2018.

I will update you again following the CMC, or earlier if developments warrant.

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Media Coverage

I attach a 24 May 2018 BBC website (Northern Ireland / politics) article which concerns a temporary outage in Northern
Ireland of the Horizon system. I also attach a blog published today on the “Campaign4Change” website, which seeks to
connect that outage to the matters in issue in the Group Litigation. Our Communications team notes that the blog is
fairly obscure (the writer is a former editor of Computer Weekly, which has long covered the Postmaster

Complaints). We were not asked to comment on the blog, and do not accept the veracity of its content.

We also note that tonight at 730pm, BBC Panorama will broadcast a programme titled “Last Chance for Justice” on the
Criminal Cases Review Commission (“CCRC”), focussing on two murder cases and questioning whether the CCRC is fit for
purpose. The CCRC is currently reviewing applications made by 33 former postmasters of convictions which had been
brought by Post Office. Retired Court of Appeal judge Sir Anthony Hooper, who chaired the Complaint Review and
Mediation Scheme which considered 136 postmaster complaints between 2013 and 2015, is a contributor the
programme.

We do not however believe that the programme will discuss any Post Office cases, and we were not invited to comment
on the programme.

Criminal Appeal

As noted in the briefing note emailed to you on 14 May 2018, on 14 August 2017 Post Office received notice that a
former postmaster, Mr Harjinder Singh Butoy, was seeking permission to appeal his 25 September 2008 conviction on 11
counts of theft following losses of £208,000 at the Post Office branch where he had been postmaster (see footnote to
para.6).

We understand following enquiries made of the Criminal Appeal Office last week, that Mr Butoy’s application for
permission to appeal had been refused by a Single Judge, but he has since renewed it to the Full Court for consideration
at a hearing yet to be listed. We have asked the Criminal Appeal Office to notify us of the hearing date as an interested
party (we are advised that the prosecutor is never invited to attend this type of hearing, which although conducted in
open court, is rarely covered by the media).

Kind regards, Rodric

@ Rodric Williams
Head of Legal - Dispute Resolution & Brand
20 Finsbury Street
_bondon EC2Y 9AQ

2047 Winner of the Global Postal Award for Customer
Experience

JES HICH OE IS IOI ORIORI ORI IG ISK IOK IGRI RII TOR IOR IORI ORIORICRICOI I IR IGRI ORIG AAI A I HOR HOR HK
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recipient, you must not use, disclose, reproduce, copy or distribute the contents of this communication. If you
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Any views or opinions expressed within this email are solely those of the sender, unless otherwise specifically
stated.

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