Telephone Attendance Note of Stephen Dilley with Mr.Castleton re-examination of Anne Chambers and Ruth and further call with R.Morgan re Mr.Castleton’s application to re-examine.

Evidence on official site

POL00070060
POL00070060

fod bs

Telephone attendance

Client: Royal Mail Group PLC Sub Postmaster Litigation

Matter: Mr Lee Castleton Matter no: 348035.134

Attending: Mr Castleton

Name: Stephen Dilley Location: N/A Date: 4 January 2007

Start time: Units:

I had a telephone conversation with Mr Castleton. He said that he had prepared a reply to
my letter. He said that the events on the Tivoli log show there was no power failure on 1
April 2004 until 12:47 p.m. whereas Mrs Simpson said she had to reboot at 9:00 a.m. He
therefore wants to cross examine Mrs Simpson and Ann Chambers again. I said to him that
Ruth Simpson’s evidence was that she didn’t log until the afternoon because she was busy
serving customers in the morning and that was why she waited until then to log on. He said
that was not her evidence. I said that was her evidence in the transcript. He asked me for a
copy of the transcript. I asked him if he was willing to pay for half of the cost and he said
that he was not.

I said that I would take instructions and revert to him.

Time Engaged: 6 Minutes

Thereafter I had a tel sation with Richard Morgan and explained to him the
position (tel. mobile’, }. Richard thinks that we should not agree to the
application although not strongly oppose it. We should say that it would be disproportionate
to recall witnesses given that they have been released and the points that Mr Castleton
wants to make are not material. We don’t disagree that there was a power failure and that
Ruth Simpson had to reboot. The events log does not show that there were massive
computer failures in February 2004. Therefore this is at best a peripheral issue. It is just an
immaterial event.

I said to Richard that if the witnesses could be there next Thursday (and I will need to check
with the Court how long is available and whether the witnesses can be there) then we could
just ask them to be there so that we can get it out the way on that day. I had tried to call
the Court and had left them a message to ask them how long the hearing had been listed
for. In the meantime I will ask Mr Castleton how long he wishes to be with each witness and
what issues that his questions are material to.

Richard’s concern is that Mr Castleton is just going to go on for evermore.

Time Engaged including attendance note: 18 Minutes

Thereafter printing a copy of the transcript from Mr Castleton of three days which took about
12 minutes to print.

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