POL00103534 - The Post Office Group Litigation - Action List as at 10 May 2019

Evidence on official site

THE POST OFFICE GROUP LITIGATION

ACTION LIST AS AT 10 MAY 2019

Legally Privileged and Confidential
10 May 2019

POL00103534
POL00103534

0. De 0 Respo Dead °

Wet Mey zara

4 Updated Grounds of Appeal and Skeleton to be DCQc 7 May 2019 Complete

*_I circulated
2 Review updated Grounds of Appeal and Skeleton I Full team 7/8 May 2019 Complete
3 Prepare and circulate board paper on Common HSF 7/8 May 2019 Complete
: Issues appeal
4. Meeting with GLO Sub-Committee on Common Full team 9 May 2019 Complete
Issues Appeal
5. Decision on approach to costs hearing on 23 May I WBD/HSF wic 29 April 2019 Complete with respect to Common Issues
2019 costs. There is a separate matter concerning
Recusal costs to be determined (see below)
6 Write to Freeths regarding Common Issuses WBD 10 May 2019 Complete
“_I costs
7. Confirm to Freeths that Common Issues appeal WBD 7 May 2019 Complete ~ the plan is to send to Freeths the
issues will be brought to their attention in draft Grounds of Appeal
advance of 14 May
8. Agree cease and desist letters regarding PO PO/HSF/WBD wic 7 May 2019 Complete
variation letter for mailwork services.

9. Finalise engagement letter HSF/PO wic 7 May 2019 Ongoing - draft with Ben Foat and will be
finalised once precise scope of work
determined (see below)

10. I Decision on whether Dr Worden will file further WBD/TGQC wie 7 May 2018 Ongoing ~ A letter reserving the PO's position

supplemental report in Horizon trial

but giving an indication of current thinking
pending that expert meeting has been sent to

Legally Privileged and Confidential

POL00103534
POL00103534

10 May 2019

No. ime Status/Comments
the Freeths and a response received.

44. Paper on historical settlement discussions WBD wic 7 May 2019 Ongoing - HSF following up with WBD.

wie 2019

12. I Send draft Grounds of Appeal to Freeths WBD 13 May 2019 This may change depending on the date of the
hearing (see below)

13. I Exchange skeletons for Common Issues appeal DCac 14 May 2019 This may change depending on the date of the

hearing hearing (see below)
14. I Common Issues appeal hearing Full team 16 May 2019 Currently listed for 16 May however Freeths
have written to the Court (10 May 2019)
requesting that the hearing be moved to 23
May to afford them further time to respond to
PO draft Grounds of Appeal.
15. I Claimant case summaries. WBD/PO wic13 May 2019 To provide not just a summary of the relevant
facts pertaining to each claimant but also what
the Judge's position is and what are PO's
honest version of the facts.
16. I Paper outlining the extent to which the substance I PO wic 13 May 2019 This is to discover at high level how big the
of any of the 20 implied terms are covered by differences are between the parties
Necessary Cooperation or Stirling v Maitland
terms

17. I Paper on historical settlement discussions WBD wic 13 May 2019 HSF following up with WBD

18. I Advice to PO legal team on addressing the HSF wic 13 May 2019 HSF following up with Rod Williams
operational impact of Cl judgment on NTC Local
contracts

19. I Prepare note on governance and reporting lines HSF/PO 14 May 2019 HSF meeting with Ben Foat and Rod Williams.

to progress on 14 May.

Legally Privileged and Confidential

POL00103534
POL00103534

10 May 2019
Respon y Deadiine/Timeframe Status/Comments
20. I Advice on approach to recusal costs for hearing WBD 14 May 2019 This has been delayed as a result of Freeths'
on 23 May 2019 claim for additional costs and wasted costs ~

confirmed to us 10 May. This new information
will inform approach to these costs.

21. I Finalise engagement letter HSF/PO wic 13 May 2019 See above

22. I Finalise approach to Dr Worden's supplemental WBD/TGQCIHSF I wic 13 May 2019 See above

report in Horizon trial