Confidential and legally privileged
WORKPLAN - ACTIONS AND TIMINGS.
POL00242335
POL00242335
1. TIMINGS
Date Event
28 April 2016 LOC received
29 April 2016 Acknowledgment sent by POL
6 May 2016 Holding response sent by BD
May 2016 BD to complete Letter of Response Actions as per below
7 June 2016 First Steering Group meeting
9 June 2016 Strategy Conference with Counsel
14 June 2016
Draw up list of missing info for Letter of Response based on Counsel's Strategy
28 June 2016
First draft of Letter of Response to be submitted to Rodric Williams
30 June 2016
Draft letter returned to BD with RW comments
1-14 July 2016
Work on Letter of Response
15 July 2016 Final letter submitted to Steering Group for, approval
20 July 2016 Steering Group meeting to approve Letter of Response
28 July 2016 Letter of Response deadline
11 August 2016
Deadline for service of Claim Form
2. LETTER OF RESPONSE ACTIONS
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Section Comment BD Action / Deadline POL Action / Deadline
LOC General The letter is long and raises lots of issues — BD to prepare para by para analysis of None at present
many of which are not covered in the information needed / response required to
schedule of questions at the end of the LOC form basis of letter of response.
14 June 2016
Paul Loraine
LOC A: On one level this section is irrelevant as it BD to set out corrected version of history. None at present
Background does not go to the substance of any claim. We largely have this knowledge already so
section setting out
history of Horizon
investigations
However it should be addressed as it is a
twisted version of history that (i) taints any
other response by POL and (ii) sets a
canvass against which Post Office is then
accused of fraud and / or ignorance of issues
with Horizon.
little further investigation will be required.
28 June 2016
Andy Parsons
LOC B: Legal
relationship
between POL and
SPMRs.
This section looks to imply new duties on
POL. The aim is to reverse the burden on
SPMRs to investigate their own losses
(presumably because Freeths know thatthe’
SPMRs cannot show any problem with
Horizon on their own).
Instruct\Counsel to advise on analysis of
legal duties.
Conference with Counsel on 9 June 2016.
Speak to Paul Inwood about historic contract
variations — 10 June 2016
Paul Loraine
Paul Loraine to speak to Paul Inwood.
LOC Cc:
Description of
problems with
Horizon and POL
operating
practices.
The problems raised are almost exclusively a
recitation of the Second Sight Part Two
Report.
BD to cross check LOC against POL
Response to P2 Report to ensure that all
points are covered.
Any new points to be identified and
investigated with the help of Kath and
Shirley.
8 June 2016
Paul Loraine
None at present
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LOC D:
Relationship
between POL and
Fujitsu
Freeths make a small number of statements
about how the POL / FJ relationship works.
Further recitation of points raised in SS P2
Report specifically in relation to FJ and
Helplines.
BD to review FJ contract to address
questions; if further info is needed, questions
to be addressed to POL IT team.
Remaining answers should be covered by
POL Response to P2 Report.
13 June 2016
Tom Porter
Rodric to provide the Fujitsu contract
Approach to FJ issues to be discussed
with Steering Group — 7 June 2016
LOC E: Post Office
This section appears to be an attempt to pre-
No further factual information required.
None at present
concealed empt POL's limitation defence by saying that I Response to call out issues with limitation
problems with POL concealed the cause of action which is and push Freeths to particularise.
Horizon one of the grounds on which limitation can be I "concealment" on case by case basis
extended. Counsel to provide insight on how to address
limitation issues:
Conference with Counsel on 9 June 2016
LOC F: List of Although this section raises several causes The lack of factual particulars means little None at present
specific causes of
action alleged
against POL
of action, it provides little particulars to
support each claim. An initial review
indicates that Freeths have provided
insufficient information to justify many of the
heads of claim.
investigation will be required.
BD to review each claim and identify missing
particulars / legal flaws in claims.
DONE
Tom Porter
LOC G: Loss and
damage suffered
by SPMRs
Broad heads of claims set out but no details
or figures included
BD to highlight all known legal and causation
issues with losses raised.
DONE
Paul Loraine
None at present
LOC H: Invitation
to mediation
BD to research cases where mediation has
been reasonably refused.
Tactical decision to be taken on how to
respond to invitation.
DONE
Approach to mediation to be discussed
with Steering Group once final LOR
produced
Steering Group meeting on 20 July
2016.
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Paul Loraine
LOC I: Disclosure
requests
Initial review indicates that the disclosure
requests are disproportionately wide.
Complying with the request would be
disproportionately expensive.
BD to investigate sources of documents to
be preserved / disclosed before BD and POL
taking tactical decision on how to respond to
requests.
13 June 2016
Tom Porter
Various people at Post Office involved —
activity being co-ordinated by Tom
Porter
LOC J: Request for
assurance that
POL will not
victimise SPMRs
Same request as before
No factual information needed.
BD and POL to discuss,tactical approach to
responding.
Conference with Counsel on 9 June 2016
To be discussed at Steering Group
meeting on 22 June 2016
LOC K: Official
Secrets Act
It is unclear why Freeths are so nervous
about the OSA section in the SPMR contract
BD to speak to Paul Inwood.
BD to research OSA requirements.
DONE
Paul Loraine
None at present
LOC L: Request
for POL consent to
GLO
Initial view is that POL should oppose
formation of GLO due to lack of commonality
of issues.
Advice to be sought from Counsel
Conference with Counsel on 9 June 2016
None at present
LOC M: Procedure
for litigation
The idea of holding preliminary issues is
sound.
Correspondence on this topic sent to
Freeths. Awaiting Freeths response to
providing directions to trial.
No action.
None at present
LOC N: Timing of
response
Holding response to be sent stating that POL
will require more time to respond.
DONE
None at present
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3. OTHER ACTIONS
POL00242335
POL00242335
1. Litigation
Consequences
Doc
Document setting out the potential legal
and factual ramifications of if the litigation
goes against POL.
Drafting a table setting out this information
for review/consideration.
28 July 2016
None at present
2. Jonathan Swift
QC work streams
Tony Robinson QC to advise on the
various work streams arising from the
report and the extent to which they
overlap
Conference with Counsel on 9 June 2016
None at present
3. Brian Altman QC
work streams
Tony Robinson QC to comment on the
adequacy of the investigations/reviews
Conference with Counsel on 9 June 2016
None at present
4. Deloitte enquiries
Tony Robinson QC to review and
comment on the sufficiency/utility of the
work being done to investigate the core
Horizon points
Conference with Counsel on 9 June 2016
None at present
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