POL00154271
POL00154271
WOMBLE
BOND
DICKINSON
LEGALLY PRIVILEGED AND CONFIDENTIAL
POST OFFICE GROUP ACTION
INFORMATION FOR WITNESSES
Background
Post Office is defending a claim brought against it by 500+ postmasters who are being represented by
solicitors, Freeths (Group Action). The postmasters include Subpostmasters, Crown Office employees,
Assistants, Franchisees, and Operators under the Network Transformation contracts (Claimants).
Womble Bond Dickinson (UK) LLP is representing Post Office in this litigation.
The Claim is proceeding in the High Court in London. It began in 2016 and may well last for quite a while
longer, with a first stage trial due to take place in November 2018.
The claims brought by the Claimants are robustly denied by Post Office. The broad areas of Post Office's
operation which are relevant to the claims are:
Recruitment and interview process
Location of branch
Preparation of contracts and manuals
Signing of contracts and changes to contracts once signed / new products
Practical arrangements for branches
Contact / support between Post Office and postmasters during ongoing relationship
Holiday and sickness
Training for those working in branch
Assistants
Dealing with problems in branch/ shortfalls
Dishonesty / false accounting by postmasters
Helpline / NBSC
FSC (role of)
Security team (role of)
Audit team (role of)
Accounting
Horizon
Contractual breach / performance issues
Suspension
Temporary substitutes
End of Post Office's relationship with postmaster (however that happens)
Criminal investigations and prosecutions
Civil claims / recoveries action / Chesterfield
Your evidence
You have been nominated as someone with knowledge of one or more of these areas. We need to
speak to you so that we can understand the areas about which you are knowledgeable. From the
information we receive from you and other documentary evidence, we will prepare your witness
statement. The witness statement will outline and explain Post Office's practice and processes regarding
the above issues and how these practices have changed during the relevant time (from 1998 to 2016).
We will use your proof of evidence as a basis for drafting your witness statement. It is important that you
are comfortable with everything that is said in your witness statement and that the text of the statement is
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in your own words. We may need to speak to you again about particular points and there may be several
drafts for you to review. Once finalised, we will ask you to sign the statement of truth (explained below).
After the exchange of witness statements has taken place, we may ask you to read what is being said by
the witnesses appearing for the Claimants. Your comments on those statements could be helpful in
preparing for the trial.
Statement of truth
Your evidence is very important and you need to be comfortable that what you are saying is accurate.
Your witness statement will be verified by a "statement of truth". This is a statement confirming that the
person making it believes that the facts stated in the document are true. When you are signing the
statement of truth, you are confirming that the facts contained within the statement are true to the best of
your knowledge.
The penalties for signing a statement of truth without an honest belief in the truth of the facts being
verified are potentially severe. A person who knowingly makes a false statement in litigation in an
attempt to interfere with the course of justice will be in contempt of court, which is punishable by a prison
sentence of up to two years.
Where you do not have first-hand knowledge of facts and matters which are set out in the witness
statement, you should carry out sufficient investigation to satisfy yourself of the truth of the matters
stated. We will assist you in undertaking these checks from the available documentation.
Future steps
The trial of this matter is listed for November 2018. Please could you continue to keep November 2018
free in your diaries. If you already have commitments or intend to book any holiday in this period, please
could you let dave.panaec ind victoria.brooks¢_
You will most likely be asked to attend court to explain the issues covered in the witness statement to the
Judge. You will need to prepare for giving evidence at the hearing by carefully reviewing your statement
and any relevant documents referred to in it. You will also be asked questions on the evidence by the
Claimant's representatives.
If you are required to attend trial and give evidence, we will arrange for you to have some training on
what to expect in a court room beforehand, to help make you feel as comfortable as possible on the day.
Questions
If you have any questions about scheduling meetings, please contact Ria Hattam on ria.hattani GR
GRO.
/e any other questions, please contact Victoria Brooks on victoria.brooksi
Womble Bond Dickinson (UK) LLP
10 July 2018
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