POL00242882
POL00242882
www.bonddickinson.com
26 April 2016 Bond Dickinson LLP
Oceana House
39-49 Commercial Road
Southampton
. SO15 1GA
Deloitte LLP ~ aa
Tet: 1
fot GRO I
Dx: 8517 Southampton 3
By email only andrew_parsons¢
Direct: #
Ourref:
GRM1/AP6/364065.1369
Your ref:
Dear Sirs
Alan Bates and 90 others v. Post Office Limited
Claim number: HQ16X01238
We act for Post Office Limited in relation to the above Court proceedings.
You have been historically instructed by Post Office to undertake certain analytical work in relation to
contemplated claims against Post Office by certain subpostmasters regarding the Horizon system.
Those claims have now crystallised into the above proceedings. As such, we write to provide you with
further instructions.
For the sake of clarity, all your past and future work for Post Office is subject to litigation privilege. Your
role in this matter is as an expert advisor to Post Office and not as an expert witness who may be called
to give evidence in Court. Although you may on occasion receive instructions from us, you will remain
directly engaged by Post Office.
We understand that you have now scoped the core procedures that may be subject to examination
during the above Court proceedings and which may therefore to be subject to further review by you.
Before you provide a written report of your findings to date, we should be grateful if you would present
those findings to Post Office at a meeting. This presentation will assist Post Office in scoping any future
work as well as enabling it to seek advice from us and / or Jonathan Swift QC in relation to any other
steps Post Office could be taking in relation to the claims being bought by the subpostmasters.
We recognise that in order to give this presentation you may need to make certain notes and / or
produce slides. If you do so, please be aware that these documents will be subject to privilege and
should be marked "Private and Confidential — Subject to Privilege".
Please can you liaise with Mark Underwood at Post Office in order to arrange a convenient time for your
meeting.
Yours faithfully
[ata
Bond Dickinson LLP
Bond Dickinson LLP is a limited liability partnership registered in England and Wales under number 0C317661. VAT registration number is
GB123393627. Registered office: 4 More London Riverside, London, SE1 2AU, where a list of members’ names is open to inspection. We use the
term partner to refer to a member of the LLP, or an employee or consultant who is of equivalent standing. Bond Dickinson LLP is authorised and
Tegulated by the Solicitors Regulation Authority.
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