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Message
From: Mark Underwood1{
on behalf of I Mark Underwood.
Sent:
To: ; Mark Raymond
homas P Moran
Sheinaze Aboobakar
Simon Talbot
David Southall ; John Breeden
; Angela Bettison
cc: Rodric Williams a
Subject: Postmaster Group Li support from members of your team during October and November
Importance: High
Dear all,
On 11 April 2016, a High Court claim was issued on behalf of a number of postmasters against Post Office in relation to
various legal, technical and operational matters - many of which have been the subject of significant media coverage
over the past decade.
The litigation is being managed by the Court through a Group Litigation Order (GLO) and will be phased. The first trial
begins on 5 November 2018 and is currently scheduled for 4 weeks. It will consider the nature and effect of the legal
relationship that existed (and exists) between sub-Postmasters and Post Office as set out in the express terms of the
contracts; and whether as the Claimants argue, some or all of the additional 21 terms should be implied into the
contract.
This trial will involve witness evidence and the purpose of this email is to check that the members of your team who
have provided witness statements and will be required to attend court in November have made you aware that, for a
number of days in October and November, they will be unable to perform their BAU duties as they will either be:
1. Receiving witness familiarisation training
We have arranged witness familiarisation training for all of our witnesses. This is run by Bond Solon
vi i n/). The current scheduling is as per the below table:
Monday 15
onday Tuesday 16 October I Wednesday 17 October I Thursday 18 October Friday 19 October
October .
Bolton Bolton Chesterfield London London
Session 1 9:30-
Session 2 AM 9:30-
Session 1 AM 9:30-
Session 1 9:30-17:00
Session 2 AM 9:30-
17:30 12:30 13:30 12:30
. . . . Angela Van-Den-
Sarah Rimmer Sarah Rimmer David Longbottom Nick Beal Bogerd
Michael Haworth
John Breeden
Angela Van-Den-
Bogerd
Michael Shields
Session 2 PM 13:30-
16:30
Andrew Carpenter
Tim Dance
Session 2 PM 13:30-
16:30
Michael Webb
Paul Williams
Elaine Ridge
Nick Beal
Paul Williams
Session 2 PM 14:30-
17:30
Brian Trotter
John Breeden
Helen Dickinson
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2. Pre- reading
As you will understand, it is vital that our witnesses understand the wider background to this litigation and are familiar
with the Claimants’ evidence and relevant documents. Our Lawyers will be producing folders of relevant documents for
each witness, tailored to their specific areas of evidence. The case is very document heavy, so it may take each witness
2 - 3 days of reading to go through them.
3. Attending meetings with the legal team
We will need some of witnesses to attend meetings or conference calls with the legal team to discuss specific
issues. Placeholder appointments should already be each Witness’s diary.
4. In court, providing witness evidence
The Court has ordered that by 26 October 2018 the parties are to have agreed and informed the Court of the order /
timing in which each witness will be heard at trial. Before then, the only information we know is that:
e@ The cross examination of witnesses will take place from Thursday 8 November until Monday 26 November — 10
hearing days as the Court will not sit on Fridays, save for ad hoc issues that arise and need to be dealt with.
¢ The Claimants, who have 6 witnesses, will ‘go first’.
As soon at the trial timetable is finalised, it will be shared with the witnesses and yourselves.
Witnesses
Each witness has been asked to:
¢ Block out their diaries for the whole of November 2018 on the basis that we should be able to release most of
this time back to them once we have agreed the running order for witnesses.
e Let us know if they have any holidays or other unavoidable appointments between now and November so that
we can make arrangements for training and meetings.
e Let their line manager know that the trial is coming up and what will be required of them and to make plans for
their BAU work to be covered so that adequate time can be given to trial preparation.
e Change their privacy settings to "private" on all social media accounts that they use for personal matters until
the trial is over.
We are arranging hotels for each witnesses, nearby to the court for:
e@ The day and night before they are giving evidence;
e For each day and night they are giving evidence; and
e¢ For some witnesses, on the days that the Claimants are giving evidence.
The full list of Post Offices 14 Witnesses is included in the below table, along with what team they work in and who their
respective line managers and GE members are:
individual Team Line Manager GE Member
Angela Van-Den-Bogerd Group Litigation Team jane MacLeod ane MacLeod
John Breeden Agency Contracts and Agents pulie Thomas Alisdair Cameron
Services team (part of Network
(Operations)
Helen Dickinson Security Operations Mark Raymond Alisdair Cameron
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Tim Dance letwork Programmes [Debbie Jones [Debbie Smith
Nick Beal Agents Development and Tom Moran Debbie Smith
Remuneration
Sarah Rimmer Agent Remuneration and David Higham Alisdair Cameron
Expense
Michael Shields Agents Application Team Sheinaze Aboobakar (Alisdair Cameron
Michael Haworth Network Gateway team Katrina Holmes Alisdair Cameron
Mike Webb INetwork Support Team Simon Talbot Alisdair Cameron
Andy Carpenter Agents Contracts Deployment [David Southall Alisdair Cameron
[Team - North
David Longbottom letwork Operations team Angela Bettison Alisdair Cameron
Brian Trotter Agents Services Contract Team John Breeden lisdair Cameron
Paul F Williams Agents Contracts & Services john Breeden Alisdair Cameron
Elaine Ridge A — no longer in the business INA — no longer in the A —no longer in the
business fusiness
I hope the above note is helpful and that each of your team members who are witnesses have already informed you our
need for their time and expertise over the coming months.
If you do have any concerns or questions please do not hesitate to get in touch. Otherwise, thank you very much for
your support and please pass on my thanks to each of the individuals included in the above table who have each,
without exception, been fantastic in helping Post Office prepare for the upcoming trial.
Kind Regards
Mark
* Mark Underwood
Head of Portfolio: Legal, Risk & Governance
Ground Floor
2017 Winner of the Global Postal Award 2° Finsbury Street
London EC2Y 9AQ
for Customer Experience
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