POL00103336 - Email from Jane MacLeod to Tim Parker; Ken McCall; Carla Stent; Tim Franklin, re: Postmaster Litigation - Confidential and subject to Legal Privilege - Do not Forward.

Evidence on official site

POL00103336
POL00103336

Message
From:
on behalf of
Sent:
To: a
‘ooper, Tom - UKGi
Shirine Khou!
ce: Paula Vennel 5 Alisdair Camerort__
Branton/
Subject: Postmaster Litigation - Confidential and subject to Legal Privilege - Do not Forward.
All

A further Case Management Conference in relation to the Postmaster Litigation is scheduled for the afternoon of
Tuesday 5 June. The purpose of the hearing is to make orders in relation to disclosure of documents relating to the
March 2019 hearing on the Horizon issues, and cost management. In accordance with normal procedure, Skeleton
Arguments have now been filed with the Court by both sides. The purpose of this note is to flag that Freeths have made
reference in their skeleton argument to the potential value of the claims as being £80-£90 million. The relevant
statement is:

“The likely aggregate value of the case is estimated to be of the order of £80 to £90 million (or in excess thereof,
subject to further quantum analysis and formulation). The Claimants have not been directed to produce detailed
schedules of loss, though the Schedules of Information contain detailed information on relevant heads of loss. The
range given here derives from the Claimants’ solicitors’ analysis of the information contained in the Schedules of
Information. By its nature, it is an estimate based upon present information. There are inherent difficulties to
setting out the quantum of these claims at this stagessand the figures should be relied upon solely as a suitable
guide for the purposes of proportionality considerations in costs budgeting. “

It is possible that this figure will be picked up by the press, and therefore we wanted you to be aware. Should there be
any press commentary, our response will be:

“We note that the claimants’ solicitors have provided an estimated value of claims of £80-90 million in a hearing
regarding potential costs. That estimate recognised that no detailed schedules of loss have been produced to
date by the claimants and that the number is therefore speculative. Post Office continues to vigorously defend
the claims, and welcomes the opportunity to have these issues finally addressed through the Court process”

{ will shortly send a similar briefing to the UKGI lawyers in accordance with the draft information Sharing Protocol.. I will
also flag the above statement to EY. Given the qualifications around the statement, we continue to believe that no
provision should be required, and as the statement is speculative, we do not believe that any reference to this number
should be included in the disclosure in the draft accounts.

Please let me know if you have any questions.

Jane

a Jane MacLeod
Group Director of Legal, Risk & Governance
Ground Floor
20 Finsbury Street
LONDON
EC2Y AQ

Mobile number:

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POL00103336

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