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Message
From: Rodric Williams
Sent: 19/11/2018 22:
To: Jane Macleod. Andrew Parsons [}
Underwood1! ] ‘
Subject: RE: Litigation
Thanks Jane.
Andy ~ let's pick this up tomorrow morning...
From: Jane MacLeod
Sent: 19 November 2012.22:N9...
To: Andrew Pars
Rodric Williams
Subject: Fwd: Litigation
Over to you....
Jane MacLeod
Group Director Legal, Risk & Governance
Post Office
: Jane MacLeod ¢
Sent: Monday, November 19, 2018
To: Rob Houghton
Subject: Re: Litigation
Thanks Rob.
FJ will be asked to review relevant sections of the report - the legal team are in the process of doing this at the moment.
FJ have filed witness statements already, but probably can’t comment on the matters that we are concerned about. At
this stage, I wanted to give you a heads up on the challenge. The legal team will be in touch about solutions.
Jane
Jane MacLeod
Group Director Legal, Risk & Governance
Post Office
GRO _
From: Rob Houghton < t
Sent: Monday, November 19, 2018 9:15 pm
To: Jane MacLeod
Subject: RE: Litigation
Jane — see below...
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POL00042147
From: Jane MacLeod
Sent: 19 November 2018
To: Rob Houghton <__ GRO
Subject: Litigation
Rob.
Two things to discuss/ get your views on:
1. Our experts opinion is due to be sumbmitted to the court on Friday week. It’s 300 pages fong ..... WBD received a
drafi today and have requested that someone from the POL IT team should review it. Presumably this will be you
and Catherine?
>> Yep definitely and FJ??
2. Our witness statements for the Horizon trial were submitted on Friday. We had hoped that Catherine would be
able to provide the POL commercial context, however understandably given that she is (relatively) new to POL
and the witness statement would need to cover matters from before her appointment, she was reluctant to give a
witness statement and be subject to potential cross-examination on matters before before her time. As a result we
now have no withness statement from POL and nothing to provide any context about how commercial decisions
are made in relation to IT matters - particularly relevant will be the issue as to whether/how we prioritise
operational simplifications etc that affect postmasters and customers.
>> [helped her on the witness statement and I thought it did cover how commercial decisions are made. The problem is
none of us can give evidence prior to 2.5 years ago other than probably FJ — have you thought about getting a witness
statement from FJ Pete (?) who has been within POL account since day I and can give a fair assessemtn that POL has
never acted on defects from a commercial angle due to the contractual type with FJ? It seems a much stronger line of
enquiry than internally. Is there an option to get a witness statement from people prior to our time here — ie my
predecessors?
The team will consider options around this, but I wanted to flag that this could become an issue and no doubt most of your
team will have similar concerns to Catherine given that most of them are also ‘new’.
>> Yep
Jane
Jane MacLeod
Group Director Legal, Risk & Governance
Post Office
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