WBON0001449
WBON0001449
womblebonddickinson.com
WOMBLE
BOND
DICKINSON
9 March 2019 Womble Bond Dickinson (UK) LLP
Oceana House
39-49 Commercial Road
‘Southampton
SO15 1GA
Freeths LLP
100 Wellington Street
Leeds
West Yorkshire
LS1 4LT
By email only
Email: james.hartley_
Dear Sirs
Post Office Group Litigation
Redacted Documents
We write further to your letter of 5 March 2019.
The challenges to these redactions have been raised three working days before the beginning of the
Horizon Issues Trial. With the exception of two documents, the Claimants were provided with disclosure
of these documents in either July or August 2018. The Claimants have had 6 months to raise concerns
about the redactions applied but has chosen not to do so until now. The re-review of these documents is
a time-consuming process, and has been a regrettable distraction from preparation for trial. The
documents run to c.1000 pages in total.
As per your request, Post Office's legal team and junior Counsel have reviewed the redacted documents
with which you have raised concerns. A response to each concern is set out at Schedule 1 to this letter.
For some of the documents, the redactions applied have been narrowed and replacement documents will
be provided to Elevate. Where these documents are in the trial bundle we shall arrange for replacement
documents to be uploaded.
It should be noted that where redactions have been narrowed or removed we do not believe these
documents to have any bearing on the Horizon Issues Trial since the redactions covered irrelevant
information or, at best, material of only arguable peripheral relevance. These redactions have been
removed in many instances for the sake of pragmatic co-operation and to reduce the scope of any
disputes between the parties over the redaction of documents.
Yours faithfully
Leomete Band DiciinDn,
Womble Bond Dickinson (UK) LLP
Womble Bond Dickinson (UK) LLP is a limited liability partnership registered in England and Wales under number OC317661. 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 (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 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.worblebonddickinson.comv/legal notices for further details.
‘AC_154696514_1
WBD_001319.000001
WBON0001449
WBON0001449
Trial Begin Bates WBD Comment
Bundle
Reference
F/1415 & POL-0220141 As explained in our letter of 3 January 2019, an incorrect redacted version
F/1416 POL-0444078 of the document was exhibited to Mr Godeseth's witness statement.
Are-review of part-privileged documents which contain the term "mediation
scheme" has been undertaken. As a result of this review, some or all of the
redactions applied to the following documents have been removed.
The first four documents are email chains which had been part redacted. It
should be noted that the redacted data within these documents had already
been disclosed to the Claimants in later versions of these email chains.
The redacted information has therefore already been disclosed to the
I Claimants in January 2018 and no prejudice has been caused.
. POL-0022823 (disclosure of the previously redacted sections
of this email chain was provided on 25 January 2018 as POL-
0022822)
. POL-0024131 (disclosure of the previously redacted sections
of this email chain was provided on 25 January 2018 as POL-
0024128)
. POL-0025092 (disclosure of the previously redacted sections
of this email chain was provided on 25 January 2018 as POL-
0025090)
. POL-0025094 (disclosure of the previously redacted sections
of this email chain was provided on 25 January 2018 as POL-
0025090)
° POL-0511200
= POL-0221031
F/864 POL-0215569 Document has been redacted on the basis of confidentiality and
irrelevance. This document does not contain similar text to that contained
in POL-0215720 and all relevant / adverse sections have been disclosed.
[Note - your letter refers to POL-0121520 but the correct reference is POL-
0215720]
F/1017 POL-0215581 Document has been redacted on the basis of confidentiality and
irrelevance. This document does not contain similar text to that contained
in POL-0215720 and all relevant / adverse sections have being disclosed.
[Note - your letter refers to POL-0121520 but the correct reference is POL-
0215720]
F/619 POL-0215622 Document has been redacted on the basis of confidentiality and
irrelevance. Whilst we do not believe these sections to be relevant to the
Horizon Issues Trial, so as to reduce the scope of any disputes between
the parties over the redaction of documents, a unredacted version of this
document is being disclosed.
F/639 POL-0215539 Document has been redacted on the basis of confidentiality and
irrelevance. The section on "Executive Correspondence (flagcases)" is a
standalone paragraph in the document and the remainder of the document
‘AC_154696514_1 2
WBD_001319.000002
WBON0001449
WBON0001449
Trial Begin Bates WBD Comment
Bundle
Reference
does not assist with the context of understanding of this paragraph.
We understand that the "purdah" refers to the restrictions which were
placed on MPs during the 2010 elections.
F/658 POL-0215545 Document has been redacted on the basis of confidentiality and
irrelevance. Whilst we do not believe these sections to be relevant to the
Horizon Issues Trial, the redaction of the sections under the heading of IT
have been removed. We confirm there is no document author within the
redacted sections of the document.
F/657 POL-0215543 Document has been redacted on the basis of confidentiality and
irrelevance. The redaction at the end of this document has been removed
so as to show the author of the document.
F/1135 POL-0215589 The majority of the document has been redacted on the basis of
confidentiality and irrelevance. Some sections of the document have been
redacted on the basis of legal advice and/or litigation privilege. Whilst we
do not believe these sections to be relevant to the Horizon Issues Trial, so
as to reduce the scope of any disputes between the parties over the
I redaction of documents, some of the redactions have been removed from
this document.
F/1664 POL-0221328 The majority of the document has been redacted on the basis of
confidentiality and irrelevance. Some sections of the document has been
redacted on the basis of legal advice and/or litigation privilege.
For assurance, the pages which follow 87 and 88 do not relate to
transaction corrections.
F/1180 POL-0220835 Document has been redacted on the basis that it refers to legally privileged
material. The redactions on page 6 have been narrowed.
F/1217 POL-0220855 Document has been redacted on the basis that it refers to legally privileged
material.
F/N23 POL-0444058 The document which you have referred to is an unredacted document.
Please could you confirm the correct trial bundle reference.
F/1350 POL-0221527 Document has been redacted on the basis that it refers to legally privileged
material.
F/1420 POL-0143345 The document which you have referred to is an unredacted document.
Please could you confirm the correct trial bundle reference.
F/1501 POL-0221075 Document has been redacted on the basis that it refers to legally privileged
material.
F/1520 POL-0221124 Document has been redacted on the basis that it refers to legally privileged
material.
F/1540 POL-0220593 Document has been redacted on the basis that it refers to legally privileged
material.
F/1634 POL-0221290 Document has been redacted on the basis that it refers to legally privileged
material.
AC_154696514_1 3
WBD_001319.000003
WBON0001449
WBON0001449
Trial Begin Bates WBD Comment
Bundle
Reference
F/1495.2 POL-0511132 Document has been redacted on the basis that it refers to legally privileged
material.
F/1495.3 POL-0511131 Document has been redacted on the basis that it refers to legally privileged
material.
F/1549 POL-0220220 Document has been redacted on the basis that it refers to legally privileged
material.
‘AC_154696514_1
WBD_001319.000004