POL00424142
POL00424142
womblebonddickinson.com WOMBLE
BON
OND
DICKINSON
24 October 2019 Womble Bond Dickinson (UK) LLP
Oceana House
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Freeths LLP "
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West Yorkshire andrew.patsot
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By email only APOIAPSI364065. 1369
Your ref:
Email: james.hartley; imogen.randall(_
Dear Sirs
Post Office Group Litigation
KEL Disclosure
We write further to our letter of 3 October 2019, your letter of 11 October 2019 and our letter of 15
October 2019.
We note your confirmation provided on 23 October 2019 that Post Office's responses to the Claimants’
questions will not lead to any further, wider or collateral waiver of privilege. We are proceeding on the
basis that this confirmation applies to the contents of this letter.
As explained in our letter of 15 October 2019, we are treating your letter of 11 October 2019 with urgency
and will respond to that letter separately. However, we want to provide you with the currently available
back-versions of the KELs used at trial now so that you may start reviewing them if you so wish.
Please find enclosed with this letter a disclosure list which contains 346 versions of the KELs which were
included in the trial bundle. Consilio have been instructed to provide a load file containing these
documents to the Claimants’ e-disclosure bundle. For speed of access, we have enclosed a zip file of
the KEL versions in PDF format. We have also enclosed a list of the KELs in the trial bundle against
which is shown the versions now being disclosed. Please let us know if you believe that any other KELs
were used at trial.
Fujitsu has extracted from the KEL database approximately 14,000 KEL entries that existed on 13
December 2018, being the date on which the last extract was taken for the purposes of this litigation.
This new extract includes back-versions of those KELs already disclosed and also any newer versions
that were produced between dates of extraction of the first tranche of KELs disclosed in May 2018
(extracted on 19 March 2018) and of the second tranche of KELs disclosed in January 2019 (extracted
on 13 December 2018 following your request of 10 December 2018). Due to the way they have been
extracted, the new pool of KEL entries also includes the originally disclosed KELs. As the KEL database
is a live system, the underlying meta-data in the recently extracted entries does not perfectly match the
originally disclosed versions and so it is proving difficult to de-duplicate the originally disclosed versions
in our e-disclosure platform. Our initial estimate is that there are around 5,000 back-versions of KELs
within the new extract. If you would like all these documents we can provide them but in the meantime
we will continue to work on trying to find a technical solution to remove the already disclosed KELs from
the pool of c.14,000 entries.
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Of the c.14,000 entries, 658 were versions of KELs used at trial, including the original KELs themselves.
Given the de-duplication challenge described above, we have reviewed these 658 KELs and manually
removed the versions of those KELs that have already been disclosed, leaving the 346 versions now
being disclosed. From this review, it is apparent that not every back version of every KEL is within this
disclosure tranche. We are liaising with Fujitsu to gain a better understanding of this.
We believe that it should be possible for your e-discovery provider, Elevate, to produce red-line
comparisons between the original KELs and the back-versions so that you can more easily see the
differences. If that is not possible, please let us know and we will see if we can produce these in our e-
discovery platform and export them to you.
Yours faithfully
Q c és
Locmne Bord Orctnssen,
Womble Bond Dickinson (UK) LLP.
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