WBON0001339
WBON0001339
FREETHS
Womble Bond Dickinson (UK) LLP
DX 38517 Southampton3
Email: james.
22 October 2018
Second letter
Our Ref: JXH/1684/2113618/1/MB
Your Ref AP6/364065. 1369
Dear Sirs
POST OFFICE GROUP LITIGATION
DEFENDANT'S DISCLOSURE - REDACTED DOCUMENTS
We write further to your third letter of today’s date.
Thank you for confirming that a claim for privilege is the basis on which these redactions have been
made.
We do however remain concerned about these redactions and whether too wide an approach has
been adopted to the process of redacting PO’s documents. We do not understand how the document
title of G/40 could properly be redacted on the basis provided, nor the varying approach throughout
that document to redacting selected words in some paragraphs (e.g. the introduction), and complete
other paragraphs e.g. under the heading “Technical” (which itself seems unlikely to be a place where
legal advice would be recorded).
We invite you please to reconsider these redactions, and confirm to us that (1) your trial counsel
have reviewed each of these redactions and the reasons given for them, and (2) the person within
your firm with control of the disclosure process has done likewise, and (3) as a result of these
reviews, whether any redactions may be removed.
Please provide your response by 4pm on Tuesday 23 October 2018. We will then further consider
the Claimants’ position.
Please read our Data Protection Privacy Notice at www.freeths.co.uk
Frochs LLP i lites lablty partnership, registred in England and Wales, partnership number OC304688. Registered Otfice: Cumberland Cour, 80 Mount Sweet, Notingham NGI 6HH.
‘Authorised and regulated by the Sotors Regulation Author, All otthe members rests LLP is aval or inspection atthe regitred fic,
www.freeths.co.uk Freeths LLP, Floor 3, 100 Wellington Street Leeds, LS1 4LT DX 310016 Leeds Park Square
WBD_001209.000001
WBON0001339
WBON0001339
FREETHS
22 October 2018
Page 2
Yours faithfully
treads?
Freeths LLP
Please respond by e-mail where possible
Frochs LLP i lites lablty partnership, registred in England and Wales, partnership number OC304688. Registered Otfice: Cumberland Cour, 80 Mount Sweet, Notingham NGI 6HH.
‘Auorsed and regulated by the Sore Heguaton Autor. Ault ofthe members of Feats LLP is aval for nspection atthe rgistred ofc.
www.freeths.co.uk Freeths LLP, Floor 3, 100 Wellington Street Leeds, LS1 4LT DX 310016 Leeds Park Square
WBD_001209.000002