UKG100008699
UKGI00008699
From: Cooper, Tom - UKGI[/O=HMT/OU=EXCHANGE ADMINISTRATIVE GROUP
(FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=8D968D43E33749AE9E59F9C9350E69D5-
COOPER, THOMAS (TCOO]
Sent: Mon 26/11/2018 10:32:39 AM (UTC)
To: Rodric Williams,
Ce: ‘ox, Joshua -
Subject: Re: Post Office Group Litigation - SUBJECT TO LEGAL PRIVILEGE - DO NOT FORWARD
Rod
Has the judge made any comment about the late submission of emails? I’d be interested to understand the
background
Tom
Sent from my iPhone
On 25 Nov 2018, at 21:53, Rodric William:
wrote:
Richard,
Thank you for your email. Given the way the trial timetable has been structured, rather than send an
email on Friday I intended to send you one following the conclusion of Post Office’s evidence tomorrow,
Monday 26 November 2018 (i.e. along the lines of the report I sent on 15 November 2018 following the
conclusion of the Claimants’ evidence). I trust that is ok.
I then propose to send you the parties’ closing submissions, which will be filed later this week on
Thursday 29 or Friday 30 November 2018, and then an update following the conclusion of each parties’
oral submissions. Again, I trust that is ok.
Kind regards, Rodric
From: Watson, Richard - UKG'
Sent: 21 November 2018 1.
Fox, Joshua - UKG!
ooper, Tom - UK
‘O LEGAL PRIVILEGE - DO NOT FORWARD
Rodric
We have found your updates helpful and would be grateful if we could have them on a weekly basis
while this trial and future trials are ongoing.
I trust that will be OK
Kind regards
Richard
Richard WatsonIGeneral Counsel
UKG100008699
UKGI00008699
UK Government Investments
1H OET
> https://www.uk;
From: Rodric William:
Sent: 15 November 2018 00:03
To: Watson, Richard - UKGI £”
Fox, Joshua - UKGI
Ce: ‘cooper, Tom - UKGIi-
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;
o 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.
- _ 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.
UKGI00008699
UKGI00008699
Kind regards, Rodric
Rodric Williams
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2017 Winner of the Global Head of Legal - Dispute Resolution & Brand
Postal Award for Customer 20 Finsbury Street
Experience London EC2Y 94Q
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