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From: "Rodric Williams" +
Sent: Wed 11/06/2014 1
To: “Hocking, Stephen
Ce: ! " linda Crowe"
Subject: Strictly Private & Confidential - Subject to Legal Privilege
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NAL. pdf
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Stephen,
As we have just discussed, following its meeting yesterday our Board is minded to pursue “Option 2” for taking forward
the “Initial Complaint Review and Mediation Scheme” (see para 3.1 of the attached “Board Summary Paper”).
The Board would now like you to advise whether decisions to take any of the steps associated with Option 2 could give
rise to an application for judicial review. Those steps (outlined in paras 3.3-3.7 of the attached “Annex Sub Committee
Paper...”) are:
Making it clear that Post Office will deal with criminal cases last (they take longer because of the volume of
documentation and the legal clearance is more complicated and dealing with them in the bulk of other investigations
slows down progress on other cases) and that we would only mediate in these cases in exceptional circumstances,
believing that the correct next step for any of these applicants would be the Criminal Courts.
Moving Second Sight to a fixed fee structure with a clear work-plan (potentially with incentives to increase the
speed of work) and regular quality and delivery review meetings — potentially saving several hundred thousand pounds
depending on the fee level agreed.
For cases which date back to pre-2007, for which records should have been destroyed under Post Office’s data
retention policies (as is best practice), carrying out a review of any available data to see if it supports a full investigation
being taken forward. Where insufficient evidence still exists, no further work would be undertaken.
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Disseminating the Linklaters advice, making clear that Post Office considers itself to have very limited liability and
almost no liability in respect of consequential loss. [nb. In practice this will involve disseminating a statement of our legal
position informed by advice which will remain privileged.]
Setting and enforcing hard deadlines for the 40 outstanding Case Questionnaire Reviews, requiring all to be
submitted within a month or have their application removed from the Scheme.
In providing your advice, please again assume that any JR application would be properly articulated with the assistance
of specialist counsel, and please again identify for us any steps which we could take to minimise the risk of a JR
application, and/or increase our ability to successfully defend such an application.
As we discussed, we would like to receive your advice by Friday 13 June 2014 so that it can inform our approach to a
meeting of the Scheme’s Working Group on Monday 16 June 2014.
Please let me know if this will present any difficulties for you, or if you need anything further.
With thanks for your continuing support, Rodric
Rodric Williams I Litigation Lawyer
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