From: Mandy Robertson
To: Michael R Haworth {
Ce: Beth Hooper
Subject: RE: URGENT Confidential - Horizon Group Action (final version of your witness
statement) [WBDUK-AC.FID26896945]
Date: Thu, 23 Aug 2018 09:56:51 +0100
Importance: High
Attachments: Witness_statement_Michael_Haworth_(unsigned).pdf; C-0157-0000035_native.pdf;
200009210_native.pdf
Inline-Images: image3b002f.PNG; imagea29a58.PNG; image39a2ab.PNG; image025.png;
image026.png; image027.png; image028.png; image029.png; image030.pn;
image031.png; image032.png; image033.png; image034.png; image035.png;
image036.png
Dear Michael
I have now finalised the statement, it has been proof read and the formatting has been checked. I have converted the
statement to a pdf so that the formatting does not change when I email it to you.
The finalised statement is attached for your signature.
There are two reference numbers for each document (sorry if this wasn't clear before). There is a "control number’,
which are the numbers above and the number we need to insert into the statements which links it to the electronic trial
bundle. If you need pdf copies of all of the documents referenced before you are happy to sign it, please let me know
asap.
Signing a statement of truth
The purpose of the witness statement is to provide written evidence to support Post Office's case that will be used as
evidence in court. The statement is a crucial part of the case, designed to show it in its strongest light.
You may be asked to attend court to explain the issues covered in the witness statement to the Judge, and be asked
questions on the evidence by the other side.
Awitness statement must have a "statement of truth". This is a statement confirming that the person making it
believes that the facts stated in the document are true. The penalties for signing a statement of truth without an honest
belief in the truth of the facts being verified are potentially severe. A person who makes a false statement in litigation
in an attempt to interfere with the course of justice will be in contempt of court, which is punishable by a prison
sentence of up to two years.
Please could you
carefully review your witness statement;
if you are satisfied with the content of the same, please print and sign the statement of truth;
email me a PDF of the signed witness statement; and
send the original signed witness statement to Victoria Brooks at Womble Bond Dickinson, Temple Quay, 3 Temple
Back East, Bristol BS1 6DZ.
WBONO0001301
WBON0001301
WBD_001171.000001
Thank you very much for your hard work in getting this over the line.
Kind regards
Mandy
Mandy Robertson
Solicitor
Womble Bond Dickinson (UK) LLP.
Proud sponsors of the Grand Appeal 2018. Find out more here
‘Stay informed: sign up to our e-alerts
WOMBLE womblebonddi
BOND
DICKINSON v fin)
From: Mandy Robertson
Ser 2 August 2018 18:35
To: ‘Michael R Haworth’
Subject: RE: URGENT Confidential - Horizon Group Action (final version of your witness statement save for yellow
queries) [WBDUK-AC.FID26896945]
Thank you Michael.
I will work in these final changes and be in contact tomorrow with your final version for signature.
Kind regards
Mandy
From: Michael R Haworth [mailtd~
Sent: 22 August 2018 17:10
To: Mandy Robertson
Subject: RE: URGENT Confidential - Horizon Group Action (final version of your witness statement save for yellow
queries) [WBDUK-AC.FID26896945]
Hello Mandy
I am much better now thanks.
I have read through my statement and made tracked changes as requested.
WBONO0001301
WBON0001301
WBD_001171.000002
Please let me know if you need anything further
Regards
Michael
° Michael Haworth
Network Engagement Manager
Network Gateway Team
Branch & Customer Support
2017 Winner of the
Global Postal Award ropite number]
for Customer
Experience Email
From: Mandy Robertson [mailto},
Sent: 22 August 2018 1
To: Michael R Haworth ¢.
Subject: RE: URGENT Confidential -
for yellow queries) [WBDUK-AC.FID26896945]
Importance: High
ction (final version of your witness statement save
Hi Michael
As expected, the barrister team made a couple of small amendments to your statement.
Please could you work on this version today and send me back your statement in tracked changes. Please do not
change the formatting, as this is in a specific form which the Court requires.
I look forward to hearing from you.
Kind regards
Mandy Robertson
Solicitor
Womble Bond Dickinson (UK) LLP
Proud sponsors of the Grand Appeal 2018. Find out more here
‘Stay informed: sign up to our e-alerts
womblebonddickinson.com
WBONO0001301
WBON0001301
WBD_001171.000003
WOMBLE sd ©
BOND
DICKINSON
From: Mandy Robertson
Sent: 21 August 2018 16:21
To: ‘Michael R Haworth’
Subject: RE: URGENT Confidential - Horizon Group Action (request for assistance) [WBDUK-AC.FID26896945]
Importance: High
Hi Michael
I hope you are feeling better.
Please find attached a draft copy of your witness statement, together with the key documents referred to.
You will see there are a couple of final queries in yellow. Please could you have a look at these queries and answer
them in tracked changes?
At the same time as you looking at the statement, the barrister team is also looking at your statement. There may be a
couple of further minimal changes.
I look forward to hearing from you on our queries in yellow. I will of course notify you of any final changes suggested by
the barrister team. I hope to be in a position to send you the finalised statement for you to sign by close of play
tomorrow. This needs to be signed by close of play on Thursday.
Thank you for your continued assistance.
Kind regards
Mandy
From: Michael R Haworth [mailto
Sent: 15 August 2018 12:41
To: Mandy Robertson
Subject: RE: Confidential - Horizon Group Action (request for assistance) [WBDUK-AC.FID26896945]
Hello Mandy
I am currently off work sick however, I’ve been through your questions below and
entered responses. Hope these help.
I should be back in work next week.
WBONO0001301
WBON0001301
WBD_001171.000004
Regards
Michael
» Michael Haworth
Network Engagement Manager
Network Gateway Team
Branch & Customer Support
2017 Winner of the
Global Postal Award
for Customer
Experience
Sent: 15 August 2018 10:20
To: Michael R Haworth { [GRO]. }
Subject: RE: Confidential - Horizon Group Action (request for assistance) [WBDUK-AC.FID26896945]
Hi Michael
am in the process of finalising your witness statement today. Would you be able to assist with a few final queries:
1 You mentioned a specific interview file - Do you still have this? Was this something personal to you or was it a
standard POL doc? (if not, we should note as much to avoid this question being asked) — this was a file that was
personal to me & no I do not still have this.
2 Since you were a CA until 2014, did you just appoint Subpostmasters or also Operators under the NT contracts? I
ask because would you have used the same structure even for different types of applicant? — thinking about it, it was
actually more like 2010 that I changed roles. I can't honestly accurately remember the contracts in place at the time I
was interviewing.
3 Are you able to send us a copy of the scoring frameworks which you used during your time as a CA? What was the
maximum number of points an applicant could score? — I don't still have this but it was a standard process that all CAs.
worked to at the time. Tab 25 from the previous docs you sent me contains some details relating to the scoring
framework. There were a total of 7 competencies and I think the each competency was marked out of 5.
4 Was your list of standard interview questions something you created, or a general Post Office document? Do you still
have a copy of your questions? — I created this but seem to remember it was based on a standard document that all
CAs used. I do not still hold a copy.
5 Please could you elaborate on the section of the interview about “following standards” — was this Post Office ones or
in general? - this section was aiming to identify what experience the applicant had in working to laid down guidelines,
legislation, quality standards, service standards, etc. and how they ensured they achieved / maintained these. This
was not related to Post Office standards (unless they had previous PO experience on which they wished to draw).
WBONO0001301
WBON0001301
WBD_001171.000005
6 We talked about losses and gains. You said you would tell Subpostmasters that sometime errors would correct
themselves at a later date. What did you mean by this, and how would this happen? - I would mention that sometimes
a corresponding error may be identified at a later date which could result in an accounting Transaction Correction
being issued to the branch, eg if an incorrect amount had been claimed for cash remitted out to the cash centre. Or
perhaps, if the stock had been incorrectly declared when balancing and on rechecking at the next balance, the correct
figure was then declared. I did however state that in the meantime they would be showing a shortage in their balance
and they would be responsible for making this good. As we discussed, I did also make it clear that if for example,
payment wasn't taken from a customer or incorrect cash paid out to a customer, then these were errors that would not
come back and they were fully responsible for making them good.
7 When you ran over the summary of the contractual requirements, you mentioned a crib sheet. Are you able to
provide us with a copy of that? How long was the crib sheet? This is the one where you would use the book example.
~ the sheet I ran through was a copy of the document that had previously been sent to the applicant (I think this was 2
pages and went with the invite to interview letter). I do not stil hold a copy of this document.
8 Can you remember when the process switched from letters to calls, informing the applicant that they had been
successful at interview? - sorry, I can't remember. When it did change, it was purely the addition of a phone call and
did not replace the letters. The calls would be made to both the successfully and unsuccessful applicants (if there
were several being interviewed for the same branch).
9 Was the date of transfer often the date after audit? If so, why? How do you know this? - sorry, I can't remember. I
don't remember referring to this when we spoke. I suggest you contact HR about this or perhaps someone in the
Agent Contract Deployment team (eg, John Breeden).
I will work your answers into your statement, which should be with you by the end of this week for signing.
Thank you for your continued assistance with this.
Kind regards
Mandy
Mandy Robertson
Solicitor
Womble Bond Dickinson (UK) LLP
Proud sponsors of the Grand Appeal 2018. Find out more here
‘Stay informed: sign up to our e-alerts
From: Mandy Robertson
DICKINSON Ain)
Subject: RE: Confidential - Horizon Group Action (request for assistance) [WBDUK-AC.FID26896945]
WBONO0001301
WBON0001301
WBD_001171.000006
Hi Michael
Ihave added a few more points to your draft statement to cover later today, for you to have a skim over before our call
(if you have time).
Kind regards
Mandy
From: Mandy Robertson
Sent: 31 July 2018 13:58
To: ‘Michael R Haworth’
Subject: RE: Confidential - Horizon Group Action (request for assistance) [WBDUK-AC.FID26896945]
Hi Michael
Ahead of our meeting tomorrow, please find attached the bones of your statement, with some questions for us to cover
on our call as a starting point.
I look forward to speaking to you.
Kind regards
Mandy
From: Mandy Robertson
Sent: 27 July 2018 16:26
To: ‘Michael R Haworth’
Subject: RE: Confidential - Horizon Group Action (request for assistance) [WBDUK-AC.FID26896945]
Hi Michael
Thank you for getting back to me so quickly. Please could I pencil some time in your diary for 2pm on Wednesday for
an hour next week? I should have the start of the draft statement by then and we can pick it up again the following
week on your return (I hope you are ok).
Kind regards
Mandy
WBONO0001301
WBON0001301
WBD_001171.000007
From: Michael R Haworth [mailto:
Sent: 27 July 2018 16:06
To: Mandy Robertson
Subject: RE: Confidential - Horizon Group Action (request for assistance) [WBDUK-AC.FID26896945]
AGF
Hello Mandy
Unfortunately I have limited availability next week. I am scheduled to have an eye
operation on Thursday and will be off on the Friday. If all goes to plan, I should be
available the following week.
As far as next week is concerned, I am contactable:
Monday afternoon after 2pm
Tuesday - most of the day (I can re-arrange things around this)
Wednesday - 2pm - 5pm
Please let me know what fits in best for you
Regards
Michael
Michael Haworth
Network Engagement Manager
Network Gateway Team
Branch & Customer Support
2017 Winner of the Global Postal
Award for Customer Experience
Sent: 27 July 2018 14:56,
To: Michael R Haworth < [GRO] i
Subject: Confidential - Horizon Group Action (request for assistance) [WBDUK-AC.FID26896945]
Dear Michael
I hope you are well? Thank you for your help a couple of months ago regarding the claim brought against Post Office
by Mr Sabir. My colleague Victoria found your input was invaluable to getting the right information to finalise Post
Office's defence to his claim.
WBONO0001301
WBON0001301
WBD_001171.000008
We are now in the process of preparing witness statements, with a deadline of 8 August 2018. Please find attached a
briefing note which contains an update about the court process, the provision of witness statements and what is
required over the next few weeks to meet the court deadline.
We would like to take a short statement from you which covers some of the points you assisted with a couple of
months ago. I propose to draft a short statement based on the information you provided to Victoria early next week and
then, if possible, to arrange a call later in the week so that we can go through the relevant details which we will need to
cover in your statement. I envisage this will be a short statement of no more than four or five pages.
When would be convenient to speak late next week? I would like to set aside an hour in our diaries to talk through the
issues. Please could you also confirm you are available next week until 8 August 2018 to assist with finalising your
statement?
Thank you in advance for your assistance. It is much appreciated. If you need any help clearing your desk for time to
deal with this, please let me know and I can ask for help on this.
Kind regards
Mandy
Mandy Robertson
Solicitor
Womble Bond Dickinson (UK) LLP
[GRO]
Proud sponsors of the Grand Appeal 2018. Find out more here
gt3e
‘Stay informed: sign up to our e-alerts
WBONO0001301
WBON0001301
DICKINSON v in)
Please consider the environment! Do you need to print this email?
The information inthis e-mail and any attachments is confidential and may be k nly is authorised
toaccess this e-mail and any attachments. Ifyou are not michael,zhaworth notify mandy.robertsonf [Gi
es. Unauthorised use, dissemination, distribution, publication or copying of this communication or attachments is prohibited and may be unlawful
how we use personal data is in our Privacy Policy on our website.
Any files attached to this e-mail will have been checked by us with virus detection software before transmission. Womble Bond Dickinson (UK) LLP accepts no liability for
‘any loss or damage which may be caused by software viruses and you should carry out your own Virus checks before opening any attachment
WBD_001171.000009
WBONO0001301
WBON0001301
Content ofthis email which does not relate to the official business of Womble Bond Dickinson (UK) LLP, is nether given nor endorsed by it
This email is sent by Womble Bond Dickinson (UK) LLP which is a limited liability partnership registered in England and Wales under number 0C317661. Our registered
office is 4 More London Riverside, London, SEI AU, where a list of members’ names is open to inspection. W
employee or consultant who is of equivalent standing. Our VAT registration number is GB123393627,
se the term partner to refer to a member of the LLP, or an
‘Womble Bond Dickinson (UK) LLP is a member of Womble Bond Dickinson (International) 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 @ separa
ror can bind or obligate, another Womble Bond Dickinson entity. Womble Bond Dickinson (International) Limit
www womblebonddickinson com/legal notices for further details
al entity and is not responsible forthe acts or omissions of,
‘does not practice law. Please see
Womble Bond Dickinson (UK) LLP is authorised and regulated by the Solicitors Regulation Authority
Se er
This email and any attachments are confidential and intended for the addressee only. If you are not the
named recipient, you must not use, disclose, reproduce, copy or distribute the contents of this
communication. If you have received this in error, please contact the sender by reply email and then delete
this email from your system. Any views or opinions expressed within this email are solely those of the
sender, unless otherwise specifically stated.
POST OFFICE LIMITED is registered in England and Wales no 2154540. Registered Office: Finsbury
Dials, 20 Finsbury Street, London EC2Y 9AQ.
ISSO ESAS ESE aa EASE a OSES SSO CE OSC EOE CCEA DECC
WBD_001171.000010