POL00103554 - The Post Office Group Litigation Action List as at 17 May 2019

Evidence on official site

DTHE POST OFFICE GROUP LITIGATION

ACTION LIST AS AT 17 MAY 2019

Legally Privileged and Confidential
17 May 2019

POL00103554
POL00103554

0. De 0 Respo Dead °
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1. Advice on next steps in recusal Counsel 12 May 2019 Complete
2. Decision of GLO Sub-committee on which HSF 15 May 2019 Complete
grounds to appeal before Fraser J
3. Send draft Grounds of Appeal to Freeths WBD 16 May 2019 Complete
4. Exchange skeletons for Common Issues appeal DCQc 17 May 2019 Complete
hearing
5. Paper on historical settlement discussions WBD wic 13 May 2019 Ongoing - HSF awaiting information from WBD
6. Advice on approach to recusal costs for hearing WBD 14 May 2019 Complete
on 23 May 2019
7. Advice to PO legal team on addressing the HSF wic 13 May 2019 Complete
operational impact of Cl judgment on NTC Local
contracts
8. Instruct Helen Davies QC HSF wic 13 May Complete — telephone call on 16 May 2019
9. Meet with PO to discuss governance, reporting HSF/PO. wic 13 May 2019 Complete
lines and details of operational workstream
10. I Decision on whether Dr Worden will file further WBD/TGQC/HSF wie 13 May 2019 Ongoing — at present PO does not intend to

supplemental report in Horizon trial

apply for permission to introduce Worden 3 to
the Horizon Trial. However, Worden remains
adamant that this should be shared with the
Court. Worden 3 will be sent to the Claimants’

Legally Privileged and Confidential

POL00103554
POL00103554

17 May 2019

No. me  Status/Comments
expert Coyne on 17 May. There will then be a
call to discuss next steps early next week.

11. I Finalise engagement letter HSF/PO wic 13 May 2019 Ongoing - draft with Ben Foat and Rod
Willams

12. I Set up weekly legal working group calls HSF wic 13 May Complete

13. I Address recusal costs with Freeths. WBD 17 May Ongoing

a
I We 20 May 2018
14. I Decision on whether Dr Worden will file further WBD/TGQC/HSF 22 May 2019 See above. PO will formally confirm whether
supplemental report in Horizon trial or not it is applying for permission to introduce
by 22 May 2019.
15. I Common Issues leave to appeal and costs Full team 23 May 2019
hearing

16. I Initial substantive views from Helen Davies QC HSF 23 May 2019 Meeting scheduled for afternoon of 23 May
2019.

17. I Claimant case summaries PO wic 20 May 2019 To provide not just a summary of the relevant
facts pertaining to each claimant but aiso what
the Judge's position is and what are PO's
honest version of the facts.

18. I Paper outlining the extent to which the substance I PO wic 20 May 2019 As requested by Tom Cooper

of any of the 20 implied terms are covered by

Necessary Cooperation or Stirling v Maitland

terms
19. I Prepare structure chart of PO reporting lines HSF wic 20 May 2019 Following meeting with PO legal team
20. I Prepare note on governance recommendations HSF/PO wic 20 May 2019 Following meeting with PO legal tearm

POL00103554
POL00103554

Legally Privileged and Confidential
17 May 2019

No. Description Responsibility Deadiine/Timeframe Status/Comments

21. I Prepare contact team sheet HSF wic 20 May 2019 Following meeting with PO legal team

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