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Message
From: Jeff Smyth
Sent: 23/11/2016
To: Peter Minshul '
Subject: FW: IMPORTANT EMAIL RESERVATION OF DUCUMENTS / HIGH COURT LITIGATION
Attachments: Disclosure of documents in litigation. pdf; rodric.williams_20-04-2016_18-26-31.pdf; image001.png
From: Rodric Williams
Sent: 23 November 2016 11:05
To: Rob Houghton; Jeff Smyth
Subject: FW: IMPORTANT EMAIL RE: PRESERVATION OF DOCUMENTS / HIGH COURT LITIGATION
Rob, Jeff - please read the email below and attachments, and cascade as appropriate. Point no. 3 in the email highlights
the need for care when creating documents.
Thanks, Rod
From: Rodric Williams
Sent: 20 April 2016 22:53
Craig Tuthill; Lin Norbury ¢_
Garner; Julie George; John M Scott; Nick Beal f a ; Anne Allaker
Ce: Jane MacLeod; Patrick Bourke; Mark Underwood Neena Sharma; Lorraine Lynch; Piero D'Agostino; Jessica Madron;
Ben Foat; Elisa Lukas
Subject: IMPORTANT EMAIL RE: PRESERVATION OF DOCUMENTS / HIGH COURT LITIGATION
IMPORTANT — PLEASE READ THIS MESSAGE IN ITS ENTIRETY. IT IS ESSENTIAL THAT ITS CONTENTS ARE COMPLIED
WITH.
IF YOU HAVE ANY QUESTIONS IN RESPECT OF ITS CONTENTS OR EFFECT THEN PLEASE CONTACT ELISA LUKAS OR
RODRIC WILLIAMS IN LEGAL SERVICES.
As you may be aware, 91 mostly former postmasters have issued a High Court claim against Post Office Limited
advancing allegations about the Horizon IT system and Post Office’s engagement with them. A list of the 91 claimants is
attached, and we have been told that others may join the claim in due course.
Now that Post Office has seen the claim, you and your team members must familiarise yourselves with Post Office’s
document disclosure obligations, and ensure that you comply with them. Please therefore circulate this email to your
team members who may hold documents related to the claimants and/or their claim.
In short, the three crucial document rules that must be followed are:
(1) You must not destroy or delete any documents which may be relevant to the claim. In particular, make sure
that any automatic deleting/archiving systems are suspended now until further notice. If you have any question
about whether a document is relevant, please contact Legal Services and preserve the document in the
meantime;
(2) You must not amend any existing documents which may be relevant to the claim. For example, do not make
handwritten notes on existing documents or try to change the content of a document; and
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(3) You must recognise that any documents that you create from now on may have to be disclosed to the other
side in the case. If in any doubt, think about whether you would be happy for the email or document to be read
out loud in court.
l attach a more detailed note on this, which can be used as a reference going forward.
If you have any questions concerning these requirements, please contact Elisa Lukas or me for further guidance.
With thanks for your cooperation, Rodric
FAQs
1. What is a ‘document’?
Documents are defined very broadly to mean anything in which any information is recorded. Examples include: emails,
paper documents, handwritten notes, Word/Excel/PowerPoint documents (including draft versions of these
documents), database records, minutes of calls or meetings, text messages, internal memos, meeting agendas or tape
recordings.
2. What are ‘relevant’ documents?
Relevant documents are any documents that could: either support or undermine the case of any party to the
litigation.
END
° Rodric Williams
Solicitor, Corporate Services
Post Office Ltd
20 Finsbury Street, London EC2Y 9AQ
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