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From: Rodric Williams 4
To: "Parsons, Andrew"
Subject: FW: IMPORTANT EMAIL RE:
LITIGATION
Date: Tue, 3 May 2016 17:52:45 +0000
Importance: Normal
Attachments: Disclosure_of_documents_in_litigation.pdf; rodric.williams_20-04-2016_18-26-31.pdf
Inline-Images: image001.png
RESERVATION OF DOCUMENTS / HIGH COURT
Andy,
Please see below the email sent after receipt of the Claim Form notifying sections of the business which
might be affected by the claims of the need to preserve documents (it has also been sent to others).
Now that we have received the Claimants’ lengthy letter of claim providing better information on the matters
they may seek to litigate, can you please identify for us from the Letter of Claim:
the documents and classes of document referred to in the Letter of Claim which might need to be disclosed
in any eventual litigation;
the sources of those documents, including any servers;
the best method for preserving the documents, at least until the scope of actual disclosure is known.
Can I suggest you pull together a table of the documents (point 1. above), which can then be populated with
the further information (points 2. and 3.) as it is obtained following discussion with the appropriate POL
personnel (e.g. for starters Chris Broe from IT and Julie George from ISAG).
Thope this is clear. Please let me know if you need anything further.
Kind regards, Rod
From: Rodric Williams
Sent: 20 April 2016 22:53
To: Alwen Lyons }
GRO.
}; Craig Tuthill; Lin Norbury
; John Breeden; Joe Connor; Hector Campbell; Angela Van-Den-Bogerd;
Hailstones; Chris Broe; Andy Garner; Julie George; John M Scott; Nick Beal
; Anne Allaker
Bourke; Mark Underwoodé; Neena Sharma; Lorraine Lynch; Piero D'Agostino;
Jessica Madron; Ben Foat; Elisa Lukas
Subject: IMPORTANT EMAIL RE: PRESERVATION OF DOCUMENTS / HIGH COURT LITIGATION
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IMPORTANT — PLEASE READ THIS MESSAGE IN ITS ENTIRETY. IT IS ESSENTIAL THAT
ITS CONTENTS ARE COMPLIED WITH.
IF YOU HAVE ANY QUESTIONS IN RESPECT OF ITS CONTENTS OR EFFECT THEN PLEASE
CONTACT ELISA LUKAS OR RODRIC WILLIAMS IN LEGAL SERVICES.
As you may be aware, 91 mostly former postmasters have issued a High Court claim against Post Office
Limited advancing allegations about the Horizon IT system and Post Office’s engagement with them. A list
of the 91 claimants is attached, and we have been told that others may join the claim in due course.
Now that Post Office has seen the claim, you and your team members must familiarise yourselves with Post
Office’s document disclosure obligations, and ensure that you comply with them. Please therefore circulate
In short, the three crucial document rules that must be followed are:
(1) You must not destroy or delete any documents which may be relevant to the claim. In particular,
make sure that any automatic deleting/archiving systems are suspended now until further notice. If
you have any question about whether a document is relevant, please contact Legal Services and
preserve the document in the meantime;
(2) You must not amend any existing documents which may be relevant to the claim. For example,
do not make handwritten notes on existing documents or try to change the content of a document; and
(3) You must recognise that any documents that you create from now on may have to be disclosed
to the other side in the case. If in any doubt, think about whether you would be happy for the email
or document to be read out loud in court.
I attach a more detailed note on this, which can be used as a reference going forward.
If you have any questions concerning these requirements, please contact Elisa Lukas or me for further
guidance.
With thanks for your cooperation, Rodric
FAQs
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1. What is a ‘document’?
Documents are defined very broadly to mean anything in which any information is recorded. Examples
include: emails, paper documents, handwritten notes, Word/Excel/PowerPoint documents (including draft
versions of these documents), database records, minutes of calls or meetings, text messages, internal memos,
meeting agendas or tape recordings.
2. What are ‘relevant’ documents?
Relevant documents are any documents that could: either support or undermine the case of any party to
the litigation.
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