POL00070767
POL00070767
Page 1 of 1
Stephen Dilley
From: Stephen Dilley
Sent: 06 December 2005 08:42
To: mandy.talbot:
Ce: Tom Beezer; Julian Summerhayes
Attachments: LETTER_1096127.D0C
Dear Mandy,
Tom and I had a brief conversation with Counsel Richard Morgan on 30 November and I spoke
again with him yesterday evening. He has made some helpful suggestions for John Jones' draft
statement which I will incorporate and recirculate.
Counsel also advised that to try to protect the Post Office's position on costs, that you should
now consider making a CPR Part 36 offer at around the £25k mark. (The claim is for
£27,115.83 plus interest). An offer would help put pressure on Mr Castleton (a) to settle and
(b) at least to agree to set aside the Default Judgment on the Counterclaim, or face a potential
costs risk in relation to that hearing. Accordingly, I attach a draft CPR Part 36 offer to Mr
Castleton's solicitors offering to accept payment of £24,750 in full and final settlement with
each party bearing their own costs, for your approval. (The costs of applying to set aside the
default judgment will be born by BP).
I look forward to hearing from you.
Kind regards.
Stephen Dilley
Solicitor
06/12/2005