POL00329552
POL00329552
NZ HERBERT
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Day, FREEHILLS
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Herbert Smith Freehills LLP
Exchange House
Solicitor to the Inquiry Primrose Street
Post Office Horizon IT Inquiry
5th Floor, Aldwych House
71-91 Aldwych
London, WC2B 4HN
www.herbertsmithfreehills.com
Our ref
9100/31043642
By email
Date
19 December 2023
Dear Solicitor to the Inquiry
Post Office Horizon IT Inquiry — Disclosure by POL: Phase 4 hearings and witnesses
We enclose a note prepared by Peters & Peters Solicitors LLP. This note refers to the Inquiry’s
letter dated 14 December 2023 in relation to the Phase 4 hearings and witnesses.
Yours faithfully
Herbert Smith Freehills LLP
Enc.
Herbert Smith Freehills LLP and its subsidiaries and Herbert Smith Freehills, an Australian Partnership, are separate member firms ofthe international legal practice
known as Herbert Smith Frechils
Herbert Smith Freehills LLP isa limited labilty partnership registered in England and Wales with registered number OC310989, It is authorised and regulated by the
Solicitors’ Regulation Authority of England and Wales. A list of the members and their professional qualifications is open to inspection atthe registered office,
Exchange House, Primrose Street, London ECZA 2EG. We use the word partner of Herbert Smith Freehills LLP to refer to a member of Herbert Smith Freehills LLP,
(or an employee or consultant with equivalent standing and qualifications.
11/84515065_3 1
POL00329552
POL00329552
Post Office Horizon IT Inquiry
Note provided by Peters & Peters regarding disclosure by POL in relation to Phase 4
hearings and witnesses
1. Peters & Peters Solicitors LLP ("Peters & Peters") are assisting POL with the work in relation
to the Criminal Case Studies. The content of this note has been provided by Peters & Peters.
2. In its letter dated 14 December 2023, the Inquiry directed POL to disclose the following
categories of additional documents by the following deadlines:
a. Any additional documents said to be related to Stephen Bradshaw by 4.00pm 20
December 2023.
b. For all other persons in Annex 1 (of the Inquiry’s letter), no later than 4.00pm 10
January 2024.
3. As confirmed in Herbert Smith Freehills' letter to the Inquiry dated 24 November 2022, the
current exercise of reviewing and producing material relating to Stephen Bradshaw is
complete.
4. At paragraph 5(b) (and Annex 1) of its letter, the Inquiry seeks disclosure of documents
related to the Rule 9 and Section 21 requests or of interest in respect of 19 potential
witnesses in the Inquiry. Taking into account the inherent constraints due to the forthcoming
holiday period POL would be grateful for confirmation from the Inquiry as to which cases
from the Devolved Jurisdictions the Inquiry has selected as case studies, in order that POL
can begin actioning this request in respect of all potentially relevant witnesses as soon as
possible. To that end POL respectfully requests this information by 4.00pm on Tuesday 19
December 2023.
5. This information is essential for POL to devise appropriate search terms to be applied over
the relevant repositories managed on behalf of POL.
6. POL notes the Inquiry's position that the list of custodians included at Annex 1 of its letter is
provisional only. In respect of its efforts to harvest, review, and produce material to the
Inquiry, POL would be greatly assisted by any indication (as soon as the Inquiry is able to
provide it) as to which of those custodians will not be called to give evidence and the order
in which any witnesses will be called to give evidence.
19 December 2023
Peters & Peters Solicitors LLP
11/84515065_3 2