POL00258255 - Email from Mark Underwood to Sarah Rimmer, Michael Haworth and others re: Postmaster Litigation Trial - Feedback from Training & Logistical Information

Evidence on official site

POL00258255
POL00258255

From: Mark Underwood1
Sent: Thur 18/10/2018

8 PM (UTC)

To: Sarah Rimmer{s.
Subject: Postmaster Litigation Trial - Feedback from Training & Logistical Information: Private &
Confidential - Subject to Legal Privilege - Please do not forward
Attachment: 181018 Common Issues Trial POL Witness Briefing - Subject to Legal Privilege.docx
Dear all,

I think you have now all received your witness familiarisation training. The feedback received to date has been that
the training was excellent but that you would appreciate more information regarding logistics and the court case
more generally - apologies, this is an oversight on my part.

have any questions at all — please do feel free to send me an email or give me a call on: GRO i We recognise
that giving evidence is not part of your day job and is a daunting task so if there is anything the business can do to
better support you, please do let me know and I will do my very best to make that support available to you all.

Trial Timetable

The Trial will begin on Monday 5 November 2018 and is scheduled to end on Thursday 6 December. The Court will
not however ‘sit’ on Fridays, except to deal with ad hoc issues which may arise.

The Court has ordered that by 26 October 2018 the parties are to have agreed and informed the Court of the order /
timing in which each witness will be heard at trial. Before then, the only information we know is that:

¢ — The cross examination of witnesses will take place between Thursday 8 November and Monday 26
November — 10 hearing days
e¢ The Claimants, who have 6 witnesses, will ‘go first’.

Naturally, as soon at the trial timetable is finalised, it will be shared with each of you.
Court bundles

Our Lawyers will be producing folders of relevant documents for each witness, tailored to your specific areas of
evidence. The bundles will include:

¢ The formal court documents, including the Lead Claimants' witness statements of what they say happened.
You will each receive a note setting out which sections of these court documents will be useful to read before
trial. They will generally contain the legal arguments for the barristers and Judge to grapple with, but will give
you a flavour of how your evidence ties into the bigger picture.

¢ General documents relating to your contact with the Lead Claimants which are in your name (such as emails,
letters) or related to your area of expertise (such as documents used by your team or policies you relied on at
the relevant time).
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These bundles will be made available to you next week, both electronically (via the High Q portal) and in hard copy.
The lawyers will be in touch in the next few days with instructions for how to access the electronic copies and to ask
where you would like your respective hard copies to be sent to.

Hotel

We are booking Apex Temple Court, 1-2 Serjeants' Inn, Fleet Street, London EC4Y 1LL
(https://www.apexhotels.co.uk/apex-temple-court-hotel)

Each witness will have a room booked (with breakfast included) on their behalf for:

e The day and night before giving evidence;

e — Each day and night they are giving evidence; and

e For some witnesses, on the days that the Claimants are giving evidence.
If however you would feel better prepared by staying, for example, a couple of days before giving evidence, please do
let me know and I will alter the booking accordingly. There will always be at least 2 Post Office witnesses in the hotel
at the same time, so you will not be alone and I am of course happy to meet you each morning or in the evenings.

Court Location

The Trial will take place in the Rolls Building (7 Rolls Buildings, Fetter Lane, London, EC4A 1NL) which is a ‘stones
throw’ away from the hotel. More information is available via the below link:

https://courttribunalfinder.service.gov.uk/courts/rolls-building

Attending Court the before you are giving evidence

So that you are familiar with the court settings, the style of claimants’ QC, and as you will already be in London, you
may wish to attend court the day before you give evidence (or indeed, before that). If this would be of benefit, please
let me know and we will make the necessary arrangements.

Travel

Once the trial timetable is finalised (26 October 2018) we will be in touch to share the timings and witness schedule.
We can then make the appropriate travel bookings. If you are happy to book your own travel please:

e Book via the capita
* Use cost Centre: IRRELEVANT!

Alternatively, I am happy to book the travel on your behalf. If you would like me to book your travel, please do let me
know.

Elaine, as you no longer work for Post Office, please just keep a copy of your receipts and I will reimburse you on the
day, in person.

Other

A number of you have also asked to be provided with a short paper which provides the background to the litigation
along with a summary of each of the 6 lead claimants. This is attached.

If you do have any concerns or questions please do not hesitate to get in touch. Otherwise, thank you very much for
your continued support.
Mark

2017 Winner of the
Global Postal Award
for Customer
Experience

Mark Underwood
Head of Portfolio: Legal, Risk &
Governance

Ground Floor
20 Finsbury Street
London EC2Y 94Q

Mobile number

POL00258255
POL00258255