UKG100008632
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From: Watson, Richard - UKGI[/O=HMT/OU=EXCHANGE ADMINISTRATIVE GROUP
(FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=E8568E9D213F4097A7A65F3DA4F63CC1-
WATSON, RICHARD (RWA]
Sent: Thur 15/11/2018 8:28:57 AM (UTC)
To: Rodric William:
Fox, Joshua - UKGI
Ce: Jane MacLeod! _{Cooper, Tom - UKG'
Subject: RE: Post Office Group Litigation - SUBJECT TO LEGAL PRIVILEGE - DO NOT FORWARD
Rodric
Thanks for this helpful update
Kind regards
Richard
Richard Watson IGeneral Counsel
UK Government Investments
1 Victoria Street I London I SW1H OET
From: Rodric William:
Sent: 15 November 2018 00:03
To: Watson, Richard - UKGI ‘ox, Joshua - UKGI
Cc: Jane MacLeod GRO }Cooper, Tom - UKGI_
Subject: Post Office Group Litigation - SUBJECT TO LEGAL PRIVILEGE - DO NOT FORWARD
Post Office Group Litigation - SUBJECT TO LEGAL PRIVILEGE - DO NOT FORWARD
Richard, Josh,
In accordance with the Information Sharing Protocol agreed on 11 June 2018, I set out below a summary of the
Claimants’ evidence following the conclusion today of our cross-examination of the six Lead Claimants.
Overall, our cross-examination:
° was effective in establishing that the Lead Claimants:
© understood and accepted core agency duties to Post Office when they entered into their contracts with
us, which included accounting to us for our cash and stock and branch losses;
© received their written contracts, and had ample opportunity to request the contract if (as some
maintained) they had not;
© received good training when they took over their branch.
* revealed very little to support claims that Horizon may have been responsible for their branch losses, with
plausible alternative operational reasons for the losses being advanced.
* demonstrated that several Lead Claimants had engaged in false accounting, corrupting those accounts.
* also demonstrated the difficulty in taking to trial very old cases which would typically be statute-barred from
a Court hearing.
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* less favourably, highlighted the Lead Claimants’ confusion with:
© the “settle centrally” process for disputing Transaction Corrections and branch accounts at the end of a
Trading Period (a matter we aim to address in our evidence);
© the suite of documents received through the appointment process on the day they take over branch
operations (although this was better with the more recent Network Transformation documents and
processes).
* also highlighted that Post Office’s investigations into disputed branch losses were not always visible to the
Lead Claimants.
Tomorrow, the first two Post Office witnesses (Nick Beal and Paul Williams) will give their evidence. This marks a
turning point in the trial, as over the next six days the majority of court time will be spent with the Claimants’ counsel
Patrick Green QC cross-examining our witnesses, putting to them questions designed to advance the Claimants’ case
and harm ours. We therefore expect significant criticism to be levelled at Post Office and our practices and
procedures during this period, the scope of which will become clearer tomorrow.
Kind regards, Rodric
Rodric Williams
Head of Legal - Dispute Resolution & Brand
20 Finsbury Street
2017 Winner of the Global
Postal Award for Customer
Experience
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