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Dave M King
"Porter, Tom" i
"Parsons, Andrew’
{ GR I
RE: IMPORTANT EMAIL PRESERVATION OF DOCUMENTS / HIGH COURT
LITIGATION [BD-4A.FID26859284]
Fri, 3 Jun 2016 14:14:26 +0000
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} Rodric Williams
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Hi Tom
As usual there are no rooms available in FD, but we'll find somewhere.
I'll call your mobile to find you at 2
From: Porter, Tom [mailto!
Sent: 03 June 2016 15:01
To: Dave M King
Ce:
Dave King
Senior Technical Security Assurance Manager
1 Future Walk,
Chesterfield,.249 PF
arsons, Andrew; Rodric Williams.
Subject: FW: IMPORTANT EMAIL PRESERVATION OF DOCUMENTS / HIGH COURT LITIGATION [BD-4A.FID26859284]
Hi Dave
As discussed, I am about to send you a meeting invite for Tuesday at 2pm.
Assuming that you can make this time, please could you make the necessary room arrangements?
There is no agenda for the meeting because the main goal is to get a download of what you know. However, as part of
the discussion it would be useful to cover off the four areas that we discussed on the call yesterday:
e Potential electronic document locations by software type (we discussed Microsoft, Office 365, SharePoint,
Proofpoint, Mimecast, BIL, and File Servers)
e Potential further companies who will hold relevant documents (we discussed RMG, Fujitsu, Atos and CSC)
eBusiness areas within POL that would have dealt with sub postmasters and/or Horizon
e — People who remain with POL and have been involved throughout the life of Horizon
Andrew Parsons is attending another meeting in Finsbury Dials at 3pm so he is going to join us if that is okay.
I also copy Rodric by way of an update.
Kind regards
Tom Porter
Associate
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From: Porter, Tom
Sent: 31 May 2016 15:06
To: 'Dave M King’
Subject: RE: IMPORTANT EMAIL PRESERVATION OF DOCUMENTS / HIGH COURT LITIGATION [BD-
4A.FID26859284]
Thanks Dave
I'm afraid I'm not at Finsbury Dials today — but a call on Thursday morning would be good.
I'll send you an invite shortly.
Tom
Tom Porter
Associate
Follow Bond Dickinson:
Blin
www.bonddickinson.com
From: Dave M King [mailt:
Sent: 31 May 2016 10:59
To: Porter, Tom
Subject: RE: IMPORTANT EMAIL PRESERVATION OF DOCUMENTS / HIGH COURT LITIGATION [BD-
4A.FID26859284]
Hi Tom
Unless you happen to be in Finsbury Dials for anything today, how does Thursday morning grab you far a call??
Thanks
° Dave King
Senior Technical Security Assurance Manager
1 Future Walk,
fe!
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From: Porter, Tom [mailto
Sent: 31 May 2016 10:45
To: Dave M King
Subject: FW: IMPORTANT EMAIL PRESERVATION OF DOCUMENTS / HIGH COURT LITIGATION [BD-4A.FID26859284]
Good afternoon Dave
I am a colleague of Andrew Parsons' in the Dispute Resolution team at Bond Dickinson.
I understand that you assisted Andrew, Kath Alexander and Shirley Hailstones with the Mediation Scheme
investigations.
As I'm sure you will know — certain sub postmasters have now issued a court claim against POL. As such POL now
has a duty to preserve all potentially relevant documents, related to the action.
On discussing this with Kath and Shirley they mentioned that I should get in touch with you. As set out in Rod's email
dated 20 April (below), Post Office is under a duty to preserve any documents (electronic or hard copy) that may be
relevant to the issues in dispute. I am hoping that you (and various others) might be able to help us work out:
What potentially relevant documents exist;
Where they are stored (and whether they are periodically backed up);
Who is the stakeholder/controller for those documents;
Is there a retention policy that affects those documents (that may result in them being lost unless otherwise
preserved); and
« What would we need to do to now protect and/or take copies of those documents.
I don't expect that you will have answers to all (or indeed any) of the above questions but, if possible, I would like to set
up a brief call with you to discuss issues more generally — such as the work you did with the investigations, which
departments interacted with the sub postmasters, any thoughts you may have on the types of documents that we
should be looking for etc.
Please could you let me know if you have any availability for a call this afternoon or later this week?
I look forward to hearing from you.
Kind regards
Tom Porter
Associate
Follow Bond Dickinson:
Blin
www.bonddickinson.com
From: Rodric Williams
Sent: 20 April 2016 22:53
To: Alwen Lyons! j; Craig Tuthill; Lin Norbury!
Breeden; Joe Connor; Hector Campbell; Angela Van-Den-Bogerd; Kathryn Alexander; Shirley Hailstones; Chris Broe;
Andy Garner; Julie George; John M Scott; Nick Beal (~ ~); Anne Allaker
Cc: Jane MacLeod; Patrick Bourke; Mark Underwood jeena Sharma; Lorraine Lynch; Piero D'Agostino; Jessica
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Madron; Ben Foat; Elisa Lukas
Subject: IMPORTANT EMAIL RE: PRESERVATION OF DOCUMENTS / HIGH COURT LITIGATION
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 this
email to your team members who may hold documents related to the claimants and/or their claim.
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
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.
END
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