WBON0000322 - Letter from Womble Bond Dickinson to Freeths LLP RE Post Office Group Litigation - Horizon Issues Trial - Disclosure of Audit Reports

Evidence on official site

WBONO000322
WBON0000322

13 March 2019 Womble Bond Dickinson (UK) LLP

Oceana House
39-49 Commercial Road
Southampton
S015 1GA
Freeths LLP =

100 Wellington Street

Leeds
West Yorkshire andrew.parsons@”
LS1 4LT Direct: ii
: Our ref:
By email only AP6/AP6/364065.1369
Your ref:

Email: james.hartley@_ imogen.randall@__

Dear Sirs

The Post Office Group Litigation
Horizon Issues Trial — Disclosure of Audit Reports

We write further to your letter of today's date.

The pre-2011 annual audit reports produced by Ernst & Young relating to Horizon are not within Post
Office's control and it cannot therefore provide disclosure of them. Post Office cannot compel Royal Mail
Group to provide these documents and we explained in our letter of [x] that it may be necessary to obtain
an order from the Court for disclosure of these documents. The Claimants have not sought to obtain
such an order.

To resolve this matter, it is proposed that the Judge is asked jointly by both parties to make an Order that
Royal Mail Group provide disclosure of the pre-2011 annual audit reports of Horizon produced by Ernst &
Young, which they are able to locate under a reasonable and proportionate search. Please could you
confirm that you agree with this approach.

Yours faithfully

Womble Bond Dickinson (UK) LLP

Womble Bond Dickinson (UK) LLP is a limited liability partnership registered in England and Wales under number 0C317661. VAT registration
number is GB123393627. Registered office: 4 More London Riverside, London, SE1 2AU, where a list of members’ names is open to inspection. We
use the term partner to refer to a member of the LLP, or an employee or consultant who is of equivalent standing. Womble Bond Dickinson (UK) LLP
is authorised and regulated by the Solicitors Regulation Authority

Womble Bond Dickinson (UK) LLP is a member of Womble Bond Dickinson (Intemational) Limited, which consists of independent and autonomous
law firms providing services in the US, the UK, and elsewhere around the world. Each Womble Bond Dickinson entity is a separate legal entity and is,
not responsible for the acts or omissions of, nor can bind or obligate, another Womble Bond Dickinson entity. Womble Bond Dickinson (International)
Limited does not practise law. Please see www.womblebonddickinson.comv/legal notices for further details,

‘AC_184771370_1

WBD_000192.000001