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From: Rodric Williams[/O=MMS/OU=EXCHANGE ADMINISTRATIVE GROUP
(FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=RODRIC WILLIAMSE9C1 14F4-B03F-4595-B082-
CE89BE5C79D47B]
Sent: Fri 16/08/2013 11:38:22 AM (UTC)
To: Susan Crichton”
Subject: Draft Response to CK's note on Document Retention
Susan — here’s my draft response to Simon’s Advice Note on the Horizon Call minutes. I’ve put a hard copy on your
chair.
[Email or Letter?]
Dear Andy
Thank you for your letter of 2 August 2013 enclosing Simon Clarke’s advice on “Disclosure — the Duty to Record and
Retain Material”. That advice was prepared as a consequence of statements purportedly made in connection with the
weekly conference calls we established to share across Post Office Limited issues identified with the Horizon system
(the “Horizon Calls”).
A key purpose of the Horizon Calls is to ensure Horizon users are promptly made aware of any issues with it, so that
those issues can be effectively managed. Post Office Limited’s external law firms are asked to attend the Horizon
Calls so that they are made aware of any issues at the same time, and can therefore apply that knowledge when
acting for Post Office Limited. This is especially important for the work your firm does where Horizon-based evidence
is often central to the criminal prosecutions you conduct for Post Office Limited, which prosecutions must of course be
conducted in accordance with strict regulatory and ethical guidelines.
I am therefore deeply concerned at the suggestion in Simon’s note that there may have been an attempt to destroy
documentary material generated in connection with the Horizon Calls, specifically any minutes of the calls. [[I note
that Simon’s advice does not suggest that material connected to the operation of Horizon itself may have been
compromised.]]
Post Office Limited is committed to conducting its business in an open, transparent and lawful manner. Any
suggestion to the contrary would not reflect Post Office Limited policy, and would not be authorised or endorsed by
Post Office Limited. Accordingly, the purported statements referred to in Simon’s note do not reflect or represent
Post Office Limited’s position.
I can confirm that we will continue to hold the Horizon Calls for the foreseeable future, and that minutes of those calls
are and will continue to be taken. For administrative reasons, these minutes will be centrally stored with our
solicitors Bond Dickinson LLP, with access to those minutes being available to your firm and those you engage such as
expert witnesses.
I trust this clarifies Post Office Limited’s position on this matter. Please let me know if we need to discuss this further.
Yours etc
Rodric Williams I Litigation Lawyer
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148 Old Street, LONDON, EC1V 9HQ
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