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Message
From: Amy Prime T-y4 Y
on behalf of — Amy Prime <. GRO
Sent: 26/07/2018 19:
To: Rodric Williams [f
cc: Mark Underwood ( , Jonathan Gribben
_ Andrew Parsons £7
Subject: Project Zebra - Privileged document query [WBDUK-AC.FID26896945]
Attachments: 151077627.msg
Sensitivity: Private
Rodric
As part of Stage 3 Disclosure we have come across a number of documents which relate to Project Zebra (Deloitte's
report). Whilst most of these documents are covered by privilege and therefore do not need to be disclosed, we have
come across one document relating to Project Zebra which does not seem to be covered by privileged. I have attached
the email chain but the document of interest is the Zebra Action Summary attached to the email. This is a document
produced in response to the Zebra Report which sets out the recommendations from the Report and the remediation
which should be implemented to Horizon.
Counsel's initial view is that privilege cannot be claimed over the whole of the Zebra Action Summary but the parts which
repeat or summarise the contents of the Deloitte report can be redacted. To finalise this conclusion it would be helpful to
obtain some further information on the background to the Deloitte Report and the Action Summary. I have set out
Counsel's questions below but would you be available for a call tomorrow to discuss these? Stage 3 Disclosure is
due on 31 August so there is some urgency to work out how to deal with this document, apologies.
Counsel's queries:
1. For what dominant purpose was the Deloitte report commissioned — e.g. obtaining legal advice or obtaining
information in connection with the conduct of anticipated litigation? Counsel would also like to understand
whether the Deloitte report was also obtained for the general purpose of making Horizon more robust.
2. What are the roles within Post Office of James Rees and Emma McGinn who produced the Action Summary
(Julie George was Head of Information Security); who was the Action Summary produced for; what were the roles
of the individuals cc'ed to the document; and for what purpose was it produced.
If the role information is not known then WBD can find out from POL HR if these people still work for POL and
their roles.
3. Was the Action Summary disseminated and any actions taken as a result of it (ie. were the recommendations
implemented)?
Kind regards
Amy
Amy Prime
Solicitor
Womble Bond Dickinson (UK) LLP
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