POL00254995
POL00254995
FREETHS
Womble Bond Dickinson (UK) LLP
DX 38517 Southampton3
Email: james.
By Email andrew.parsons!
Third Letter
18 May 2018
Our Ref: JXH/1684/2113618/3/LB
Your Ref AP6/364065.1369
Dear Sirs
THE POST OFFICE GROUP LITIGATION
HORIZON ISSUES TRIAL — EXPERT EVIDENCE
We write further to your fourth letter dated 14 May 2018, and to your previously provided draft order
dated 17 April 2018, which incorporated amendments to our first draft of the Fifth CMC Order.
For the avoidance of doubt, in his original document, Mr Coyne clearly sets out whether his various
lines of enquiry involved requests for documents, information and/or access, consistent with the
approach agreed with you in the expert and solicitors meeting held on 11 April 2018. However, given
that the documentation and information is within your client's control, Mr Coyne will inevitably require
your client's cooperation and assistance in identifying some documents and information. In any
event, we understand that Mr Coyne has now made various requests for information which has been
circulated to the parties.
We now enclose an updated draft Fifth CMC Order for your review, together with a compare version
reflecting the amendments in your previous draft. The updated schedule of document requests will
follow early next week, incorporating your comments as far as possible.
In relation to the bullet points listed in your letter, please see our responses (with your questions)
below;
* Do you agree to use CPR 35.9 rather than interviewing witnesses?
This is a matter between the experts, but we understand that they have agreed to seek
documents and information where possible, before deciding on the need to speak with personnel.
* Does Mr Coyne want to inspect the PEAK system?
Yes, pursuant to our draft order enclosed.
e Have you made any progress in speaking to your clients in order to narrow any lines of
enquiry?
Frooths LLP is lint abityparnoreip, epistrodin England and Welos, partnership umber 0304888. Registored Ofico: Cumbetand Cour, 80 Mount Strect, Notngham NGI SHH.
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www.freeths.co.uk Freeths LLP, 1 Vine Street, Mayfair, London W1J OAH DX 37209 Piccadilly
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18 May 2018
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We are in the process of categorising the information which we already hold for each of the
Claimants, and we shall inform you if we believe this will help to narrow lines of enquiry as the
experts’ work progresses. In the meantime, please confirm whether your client is carrying out a
similar exercise using any data available to it regarding the nature of problems communicated to
it by Claimants.
We look forward to hearing from you with comments on the draft order.
Yours faithfully
A
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Hoods hel
Freeths LLP
Please respond by e-mail where possible
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