UKG100009793
UKGI00009793
From: Cooper, Tom - UKGI[/O=EXCHANGELABS/OU=EXCHANGE ADMINISTRATIVE GROUP
-{EYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=97888B27D7034E80AB21DE4583305D52-
Sent: Fri 17/05/2019 6:40:55 AM (UTC)
To: Rodric William:
“3 Watts, Alan
Ce: Ben Foatf.” Watson, Richard - UKGIf”
Subject: RE: Post Office Group Litigation - SUBJECT TO LEGAL PRIVILEGE - DO NOT FORWARD
Thanks Rod
If there are items in your first list (1-13) that are generally true, why would we appeal them?
On B, it bothers me that the only fact in the lead cases we can point to where we seem to have concrete evidence that
Fraser got it wrong is whether Bates saw the contract. Are there no others?
Take as an example Abdulla where Fraser says there were some errors in the make-up of the outstanding balance at
the time he was audited and terminated. If it turns out that (for example) he didn’t owe the post office any money at
the time he was terminated then he should not have been terminated or prosecuted. The consequences of that are
far greater than any issues in the Bates case it seems to me.
So if you’re saying we don’t need to challenge these findings at this stage, I’d like to understand why we’re picking out
the Bates contract point as being so special.
In general, I still want to go through the lead cases on a call and I assume the table that Ben outlined in his earlier
email is still being prepared so we can go through them?
Tom
From: Rodric Williams.
Sent: 16 May 2019 17:08
To: Cooper, Ti t
Cc: Ben Foa .IWatson, Richard - UKGI!
Subject: Post Office Group Litigation - SUBJECT TO LEGAL PRIVILEGE - DO NOT FORWARD
Tom
Further to your telephone conversation with Ben yesterday, please find attached a “one pager” listing the issues of
fact being appealed from the Common Issues judgment because an individual claimant’s experience has been
extrapolated to a finding applicable to the entire postmaster community, and those being appeal because we disagree
with them (i.e. because they were not open to the Judge on the evidence and/or are perverse).
Please let us know if you need anything further in this regard.
Separately, we have raised with the external legal team the issue of the costs of the recusal application given its stark
dismissal by the Court of Appeal. We will let you know how this progresses.
Kind regards, Rod
UKG100009793
UKGI00009793
Rodric Williams
Head of Legal - Dispute Resolution & Brand
20 Finsbury Street
EC2Y 9AQ
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