WBONO001362
WBON0001362
14 November 2018 Womble Bond Dickinson (UK) LLP
Oceana House
39-49 Commercial Road
Southampton,
S015 1GA
Freeths LLP
100 Wellington Street
Leeds
West Yorkshire
LS1 4LT
Our ref:
AP6/ALP 1/364065.1369
Your ref:
Dear Sirs
Post Office Group Action
Waiver of Privilege - POL-0218577
We refer to your Counsel's comment during the course of today concerning whether the heading on
document G/40 has been properly redacted.
As a result of this, it has come to our attention that the document title within Magnum of G/40 contains
the word "Zebra". This word, when considered within the context of the wider document, is privileged.
The inadvertent inclusion of this word within the title of this document was due to this information being
pulled from the metadata behind this document. That metadata should not have been, but was
inadvertently, disclosed.
As explained in our third letter of 23 October 2018, at your request the redactions applied to this
document have already been reviewed by junior trial Counsel. Mr Draper and Mr Cohen confirmed that
the redactions have been correctly applied on the basis of legal advice and litigation privilege. The
redaction of the word "Zebra" fell within these considerations.
We therefore propose that G/40 is renamed in the trial bundle to remove reference to "Zebra" and an
overlay providing the same fix is produced so as to amend the details of the document which has
disclosed. Please provide your agreement to the above by 4pm tomorrow or before the document is
referred to in Court (whichever is sooner) so as the amendments to the trial bundle as soon as possible.
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_152823899_1
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