POL00070792
POL00070792
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Stephen Dilley
From: Stephen Dilley
Sent: 01 December 2005 12:00
To: Tom Beezer; 'tmorgani,
Subject: Draft Part 36 Offer (Post Office Limited -v- Lee Castleton)
Attachments: LETTER_1096127.D0C
Dear Tom and Richard,
I refer to our telephone conversation on 30 November.
I attach a draft CPR Part 36 letter that I propose to despatch to Mandy Talbot and a draft email
below). I think psychologically we should go in at just under £25k and £24,750 may make
Castleton think there is some science to the offer. If you have any comments on the letter
before I email it to Mandy then by all means please let me have them.
I look forward to hearing from you as soon as possible.
Kind regards.
Stephen Dilley
Solicitor
“Dear Mandy,
Tom and I had a brief conversation with Counsel Richard Morgan yesterday. He is reviewing
the papers and we will have a more in depth discussion next week.
In the meantime, Counsel 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). 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 a final settlement with each party
bearing their own costs, for your approval.
I look forward to hearing from you."
01/12/2005