POL00070457
POL00070457
Stephen Dilley
From: Stephen Dilley
Sent: 25 November 2005 17:21
To: ‘mandy.talbot
Ce: Tom Beezer ~
Subject: RE: Draft witness statement of John Jones (Post Office Limited -v- Lee Castleton)
Thanks Mandy. I have made the suggested changes and emailed it to John for his comment and have copied you
in. I will keep you updated.
Kind regards.
Stephen Dilley
Solicitor
7 GR i [mailto: mandy. talbot
Sent: 25 November 2005 17701
To: Stephen Dilley
Subject: Re: Draft witness statement of John Jones (Post Office Limited -v- Lee Castleton)
Thanks for site of the draft statement.
I only have a few points to make.
I know that in the application to set aside judgement and in this statement we ask for an extension of time for
service of the defence and reply to counterclaim to the 15/11/05 but as I was still discussing drafts with your
colleagues until well after 5 PM that evening valid service would not have occurred until the morning of the
16/11/05.
In paragraph 7 we need to get John if possible to confirm the dates on which the errors occurred and when they
were reported as these are usually two separate dates. to use an old fashion example under the paper based
system if an error was made and too little money was charged for a driving license 1/1/05 the problem would not
be notified to POL by DVLA for months leading to the date 1/3/05 appearing on the print out of erors. Part of
Castleton's case appears to be that after the temporary postmaster was appointed he was not liable for any errors
which were notified after that date. That is incorrect because he would still be liable if the error occurred prior to
23/3/ even if it was not notified until afterwards.
In paragraph 15 I do not know that John could give a complete explanation of what happens from transaction to
the end of the process. Perhaps Tony R Utting or Keith Baines could suggest the identity of somebody who could
help you on this point even if it does mean another statement.
Regards
Mandy
Litigation Team Leader
Company Secretary's Office
Legal Services
Royal Mail, Impact House, 2 Edridge Road, CROYDON, CR9 1PJ
Mobile:
“Stephen Dilley”
POL00070457
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<Julian.Summerhayes:____ a)
25/11/2005 12:12 Subject: Draft witness statement of John Jones (Post Office Limited -v-
Lee
Castleton)
Dear Mandy,
I refer to my emails of 24 November. I
I attach a draft witness statement and Exhibit that I propose to send to John Jones. I have put some comments
in bold italics to discuss with him. Do you have any comments in it before I email it to John?
I look forward to hearing from you as soon as possible.
Kind regards.
Stephen Dilley
Solicitor
for and on behalf of Bond Pearce LLP
(0), 870 120 0000
www.bondpearce.com
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