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Sent:
To:
Subject: FW: Second Sight
Rodric Williams I Litigation Lawyer
@ 148 Old Street, LONDON, EC1V SHQ
@) Post Office stories
© @postofficenews
®© ostofficenews
From: Rodric Williams
Sent: 09 January 2015 16:43
To: Belinda Crowe; Melanie Corfield; Patrick Bourke; Tom Wechsler; andrew.parsons'
Den-Bogerd
Cc: Chris Aujard; Mark R Davies
Subject: RE: Second Sight
All — my comments in red.
From: Belinda Crowe
Sent: 09 January 2015 15:54
To: Melanie Corfield; Patrick Bourke; Tom Wechsler; Rodric Williams; andrew.parsonst”
Van-Den-Bogerd “
Cc: Chris Aujard; Mark R Davies; Belinda Crowe
Subject: Second Sight
Just to be prepared in the event that either Second Sight go public or brief JFSA/others following the rather difficult
meetings about the part two questions I think we should have a line if questioned over the weekend/next week.
The accusation is likely to centre around (Angela, feel free to comment as I was not there for all of the meeting):
e POL refusing to answer SS’s questions and provide information — they are the independent investigators and
can, in their view, ask anything they like and we should respond.
e Narrowing the scope from commitments made to/by BIS and MPs and reneging on assurances by senior POL
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people that SS should be given access to anything they ask to get to the truth.
e¢ Clearly have something to hide otherwise we would provide all the information they want
I think our lines should be — depending, of course, on what comes up:
e Post Office has not refused to answer questions.
o We responded to X questions with materials running to Y pages.
e The Scheme is designed to investigate individual complaints about Horizon and associated issues.
o SS helped applicants articulate their complaints through their CQRs.
o POL has investigated and reported on the issues raised in the CQRs.
© If SS need more information on a CQR issue, they can ask for it by reference to the individual case/s.
o If SS now want us to look at something which has not been raised in a CQR, by definition it’s not an
issue/problem.
o We don’t need (SS to) investigate something that’s not a problem.
e Post Office has provided thorough and detailed investigation reports and, where information is held,
considerable amounts of evidence in relation to each case in the Scheme.
o As per previous bullet.
¢ Whilst Second Sight’s inquiry was to look across the piece at Horizon and associated issues, the nature of the
investigations and therefore Second Sight’s role changed with the establishment of the Scheme. The focus is
now exclusively ion investigating those cases.
o SS’s role is recorded in its 1 July 2014 engagement letter with POL, which supersedes any prior
“understanding” of their role.
o SS had c. 1 year to look at the totality of our Horizon use, which culminated in their July 2013 report.
That report did not identify any system-wide issues, hence the move to trying to understand
individual complaints.
o They cannot now have a “second bite of the cherry” at trying to do a generic, system-wide review.
e — It is not, and indeed never has been, Second Sight’s role to investigate every aspect of Post Office’s business.
o SS are not business process consultants. They are not, nor have they ever been, nor will they ever be,
instructed to undertake a root and branch review of our business practices, which is beyond their skill
set and “expertise”.
e It is in the interests of all parties, especially Applicants, for the cases to be resolved as quickly as possible.
Attempts to extend the scope and the matters being investigated simply prolongs the process.
o Agreed.
These are my initial thoughts =- grateful for the views of others (being in mind we will need a pick and mix.
Belinda Crowe
148 Old Street, LONDON, EC1V 9HQ
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