POL00070850 - Memo of Telephone attendance, from Stephen Dilley to Royal Mail Group PLC Sub postmaster litigation

Evidence on official site

POL00070850
POL00070850

Telephone attendance

Client: Royal Mail Group PLC Sub Postmaster Litigation

Matter: Mr Lee Castleton Matter no: 348035.134

Attending: Mandy Talbot; Tony Utting - Post Office, lan Herbert of Hugh James Solicitors (Solicitor on Bajaj and
Bilkhu cases), Tom Beezer - Partner - Bond Pearce LLP, Stephen Dilley - Solicitor - Bond Pearce LLP

Name: Stephen Dilley Location: N/A Date: 7 April 2006

Start time: Units:

This was a telephone conference to explore how we could obtain more meaningful IT
information from Fujitsu.

Before the Post Office joined the call, Stephen Dilley and Tom Beezer had a telephone
conversation with Ian Herbert. Agreeing that the PO had had difficulty obtaining information
from Fujitsu and that the strategy should be to identify key individuals at Fujitsu who could
provide the relevant information we require in terms of evidence and then for Stephen Dilley
of Bond Pearce LLP and Ian Herbert at Hugh James to make an appointment to visit those
individuals at Fujitsu to take Proofs of Evidence. Each solicitor could prepare Witness
Statements for their respective cases for Fujitsu to sign, thereby making it easy for them.

The PO jointed the telephone conversation and Tom Beezer outlined our proposal to Mandy
Talbot. Mandy broadly agreed with it. Mandy explained that Graham Ward of the PO was
authorised to take a Statement on the Castleton case. The first draft prepared by Fujitsu was
appatling. Mandy agreed that the respective solicitors should visit Fujitsu.

Tom Beezer explained that if Fujitsu were not going to put forward an expert, we would need
to take Fujitsu through questions we have for them. The information we get from Fujitsu will
not be an independent expert report and we could not pay them for it, because we cannot
pay for evidence. We will need to obtain a separate independent expert report as well, but
this will be easier if we have Fujitsu’s evidence first because then we will be able to focus the
independent expert’s report (which the PO will need to pay for) on relevant issues.

Many explained that Slaughter and May were advising the PO in relation to ongoing
negotiations with Fujitsu to renew the service they provide for the PO. The fact that Fujitsu
had not been able to assist the PO on this particular point will feature in those negotiations.

Many said that Graham Ward should also attend the meeting between Fujitsu and the
solicitors,

Action Point: Graham to identify a person in Fujitsu to interview.

Mandy explained that Fujitsu were based in Feltingham and Cheadle. The solicitors were to
check with Graham were the Fujitsu witnesses are based.

Action Point: Mandy Talbot will give to us Graham Ward’s contact details.
Mandy also explained that Tony Utting had prepared his statement about how Fujitsu

operated that was used for criminal prosecutions and that it contained a general narrative
about Fujitsu, but had specific points that were adapted to each relevant case. Mandy said

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POL00070850
POL00070850

that she had sent us the transaction logs and that the PO needs to draw down on these in
more detail and get a Statement from the two helplines. She said that we needed Witness

© tements from both helplines. The NBSC is the General Post Office helpline and the HSH is
\. . Fujitsu Horizon helpline. Stephen Dilley confirming that Andrew Wise at NBSC and Julie
Welsh at HSH are the people that we need to interview.

Mandy pointed out that PO hadn’t pleaded that even if there was something wrong with the
system, it was open to the Sub-Postmaster to allege training errors. This was pertinent to
the Bilku case because some of the transactional logs seemed to contain elemental mistakes
by Bilku’s staff. It may be worthwhile identifying the training team who could demonstrate
that the system is intuitive to follow.

Ian Herbert confirmed that he had not heard from Bilku since his 24 February letter to him.
Mandy Talbot stated that Bilku had withdrawn his resignation, but she believes that Bilku is
so sloppy that he probably won’t go away and she pointed that he had gone into incredible
detail in his Letter before Action. However, the Post Office would focus on Castleton and
Bajaj for the time being because of the higher risks. In terms of information gathering, Ian
should add Bilku into the equation but try to keep costs down. Ian should wait to see what
Bilku comes back with.

lan confirmed that he knew somebody at Grant Thornton who deals with IT issues. Ian will
get their CV. Tony pointing that GT advised on card accounts ~ automated access to benefit
payments. It was a different product, but provided by sub-postmasters and Horizon, so there
may be a conflict in GT acting.

Summary

» Mandy Talbot to ascertain who was in charge of training teams to get names for Ian
Herbert.

e Solicitors to contact Andrew Wise and Julia Welsh. Mandy Talbot will provide their
contact details.

e Solicitors will contact Graham Ward to set up a meeting with Fujitsu to go and get
Witness Statements.

Time engaged in telephone conference and preparation for it. 1 hour 12 minutes.

Thereafter dictating attendances note: 18 minutes.

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