POL00209725
POL00209725
PRIVATE AND CONFIDENTIAL — NOT FOR ONWARD TRANSMISSION
Ron Warmington & lan Henderson
Second Sight Support Services Limited
(By email)
24 September. 2014
Dear Sirs,
Second Sight’s Engagement
As mentioned at last week’s Working Group meeting; it is with, regret that I am now compelled to
write to you in connection with the meeting to which you,Second Sight, will be invited to shortly
to deal with the delivery of your services to Post Office and the Working Group. As you know,
the reason for my writing is that there have been a.number of events over the last month
(including your firm’s rate of progress in dealing with case reports and the preparation of the
Part Two Report) which have given us)cause.for concern.
Below I have set out, in general:terms, the matters that I will be covering in my meeting with you
next week. This should allow you sufficient time to consider the necessary remedies. Let me be
clear, Post Office in no way.wishes to fetter your independence, findings, or opinions you
express, merely the manner in which they are being delivered.
1) Of most concern tous has been the rate of delivery of your case Reviews. At the
Working Group meeting on 12 June you proposed a Schedule for the delivery of your Case
Review Reports which the Working Group endorsed. The minutes record that
target for a.week. The knock on effect for the prompt and cost effective resolution of the
Scheme is obvious. Equally, you committed repeatedly to deliver the Part Two Report in March
but we received it in August.
2) The manner of the delivery is also of concern to us. There have been a number of
instances where Second Sight as a service provider to the Working Group, has failed to properly
engage in the manner we would expect of external professional advisors. In particular, in
relation to the spot reviews (ten reviews), the detailed briefing notes (four sets) and the
feedback/comments provided on the draft CRRs (twenty four sets of comments) you have failed
to explain why and where you disagree with Post Office in such a way that Post Office and, most
importantly, other readers can understand your perspective on the competing positions. Indeed
PRIVATE AND CONFIDENTIAL — NOT FOR ONWARD TRANSMISSION
POL00209725
POL00209725
PRIVATE AND CONFIDENTIAL —- NOT FOR ONWARD TRANSMISSION
when Post Office has attempted to schedule meetings with you to discuss substantive factual
issues of concern this has proved very difficult.
In future, I will expect a Second Sight Director to attend Post Office offices within a reasonable
time of a meeting being requested, just as Post Office expects and receives from the other
professionals it engages.
Finally, Post Office has concerns about the value for money it has received from Second Sight’s
services. Second Sight has been engaged continuously by Post Office. During that time, Post
Office has invested a considerable amount of valuable time and resource to’provide Second
Sight with information, in some instances on more than one occasion, to assist your
investigation into Horizon. However, since 2012, aside from attending Working. Group meetings,
Second Sight has only produced two, “thematic reports” and investigated and)reported on
twenty five applications the utility of which have not yet been established: You have now
provided Post Office with a suggested new billing arrangement linked to report production and I
understand that you have discussed your thinking with my team. Having carried out a
preliminary review of your proposal it still requires further ‘work. Thesrate is still too high and I
will need you to link the rate of your case report production.explicitly to your fees. Please
respond to Belinda’s outstanding question this week so that'we.can discuss your proposal when
we meet.
I realise that there are always two sides to every.coin and appreciate you may have a different
perspective on these issues but as your:Client, albeit where there are others interested in your
work product, our expectations are not being met. Post Office is not looking to fetter your
independence or to undermine Second, Sight’s position, although the requirement to be
independent does not absolve you of the requirements on you to deliver to the Working Group
(including Post Office) the work which you are contracted to provide, and to report to and
engage with Post Office on the. management of your services: time, billing and quality.
Yours sincerely
Chris Aujard
General, Counsel, Post Office Ltd
PRIVATE AND CONFIDENTIAL —- NOT FOR ONWARD TRANSMISSION
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