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From: Owain Draper
To: imon Henderson’
Ce:
jonathan Gribben { ____.GRO ~ i
Subject: Re: Post Office Group Litigation - Redactions [WBDUK-AC.FID26896945]
Date: Sun, 10 Mar 2019 09:24:19 +0000
Importance: Normal
Inline-Images: image001.png; image002.png; image003.png
(This email failed to send yesterday)
Dear Amy,
Thank you for the further input.
I am satisfied that the remaining redactions are appropriate. I do not say that they could not be challenged,
but they are legitimately made.
Kind Regards,
Owain
Owain Draper
One Essex Court, Temple
EC4Y 9AR
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From: Amy Prime’
Date: Saturday, 9 March 2019 at 15:50
To: Owain Draper: ‘Simon Henderson’
Ce: Andrew Parso
Jonathan Gribben/ ___GRO .
Subject: RE: Post Office Group Litigation - Redactions [WBDUK-AC.FID26896945]
Owain
Please find our comments below in red.
Kind regards
Amy
Amy Prime
Solicitor
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Womble Bond Dickinson (UK) LLP
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From: Owain Draper [mailto
Sent: 08 March 2019 20:07
To: Amy Prime; 'Simon Henderson’
Cc: Andrew Parsons; Lucy Bremner; Jonathan Gribben
Subject: Re: Post Office Group Litigation - Redactions [WBDUK-AC.FID26896945]
Dear Amy,
Revised draft letter attached (it of course still needs amending for the notes to counsel, etc).
Save where indicated below, I agree that the redactions are appropriate for the reasons given in your note. In
some cases, all I have is a query.
1. Doc 2 — no comments.
1. Doc 3 — I do not understand the full context to the Data Centre Tower procurement. If it is irrelevant to
Horizon and accounting, then I agree with the redaction. This is not relevant to the Horizon Issues trial. This
programme was a procurement exercise in 2014 which was cancelled without a contract being awarded,
which seems to have related to the restructuring of POL's IT following the separation from Royal Mail.
1. Doc 4 as above re Data Centre Tower (pp. 97-99). See above
1. Docs 5-9: I have not reviewed these given that the intention is to remove the redactions.
1. Doc 9 — pages 39-46 are borderline. This is partly discussion of business strategy but partly reflects
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ongoing legal advice, even discussing the legal strategy for the scheme. I don’t think it can be spliced. I
would retain the redaction, but there is risk here. Others could take a different view. Have discussed with
Andy and we agree — redactions will remain.
1. Doc 10 —no comments.
1. Doc 11 — this is the first time a big issue comes up. I am not sure (but could be persuaded) that it is a safe
tule to apply that all references to Project Sparrow are privileged. Imagine the reference were purely to
“SPM Horizon allegations” or similar. It often seems to be used as shorthand for that, rather than reflecting
advice or the conduct of claims. The redaction on p. 2 looks to be legal advice, but the redaction on p. 6
looks to be more about the lessons PO learned from the process of defending complaints — i.e. a business
output based on the experience so far. Have discussed with Andy and redactions to the single word
"Sparrow" will remain, but we will narrow slightly the larger redaction on page 6 so as just the reference to
Sparrow is just redacted.
1. Doc A— no comments.
1. Doc B— no comments.
1. Doc C —I do not understand the practical rationale for redacting the updates for the un-redacted mitigation
item. I think this will be challenged (even though the material looks irrelevant to me). Given this document
was redacted on the basis of irrelevance and confidentiality, we will un-redact the entire document (subject
to a privilege check), with an overarching comment in the letter that we have unredacted this document not
because we think the material is relevant but so as to prevent disputes between the parties on redactions.
1. Doc D - no comments.
1, Doc E—no comments.
1. Doc F —no comments.
1. Doc G — subject to any further context that you can give me, I think pages 30-33 are just about relevant
and arguably adverse. Pages 64-66 don’t seem to me to reflect legal advice, but Andy will know better. Are
the “controls” referred to in (e)-(f) on p.188 controls relevant to Horizon’s operation by FJ? If so, this looks
relevant to me. Given this document was redacted on the basis of irrelevance and confidentiality, we will un-
redact the entire document (subject to a privilege check), with an overarching comment in the letter that we
have unredacted this document not because we think the material is relevant but so as to prevent disputes
between the parties on redactions.
1. Doc H— no comments.
1. Doc I— p.6 I think the last sentence of the redacted section is not privileged (apart from the name Project
Sparrow). That is very borderline, however. Redaction will be narrowed to provide disclosure of the last
sentence (apart from Sparrow).
1. Doc J — this raises the issue whether we want to insist on redacting the name “Project Sparrow” every time
it is used. We know the Judge will attack on this, but there is a principled justification. In some documents,
“Sparrow” seems to be used in a very broad sense — see Doc R below. Redactions on the word Sparrow to
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remain
1. Docs K, L and M ~as above.
1. Doc N - I agree the line drawn here — the recommendations from Sparrow themselves are legal advice, but
how they are implemented is not privileged.
1. Doc O — see above re Sparrow for the first (small) redaction on page 7. The rest is properly redacted
whatever view is taken on the word Sparrow.
1. Doc P — advice/LP here.
1. Doc Q — advice/LP here.
1. Doc R~a good example of Sparrow being used in what I think is a very broad sense. One for Andy to
consider, in my view, as I am not persuaded at the moment that “Sparrow” is not sometimes used so loosely
as to risk losing any privilege. Have spoken with Andy and view is that all redactions to remain. Document
is dated 10/2016 after the claim was issued. This is a direct reference to litigation risk.
Kind Regards,
Owain
Owain Draper
One Essex Court, Temple
EC4Y 9AR
Switchboard:
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From: Amy Prime
Date: Wednesday,
To: 'Simon Henderson'
Ce: Andrew Parsons;
Jonathan Gribben
Subject: FW: Post Office Group Litigation - Redactions [WBDUK-AC.FID26896945]
Dear Simon, Owain
We have reviewed the redacted documents which the Cs have raised issue with and considered whether any
redactions should be removed. You will see in our draft response (attached) that for each document we have
set out the basis on which the redactions have been applied and included an additional column which
contains some further information for Counsel.
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Freeths have requested that Counsel review each of these documents as they anticipate raising issues with
them at trial. There are 32 documents in total. It would be appreciated if you could go through these
documents and let us know if you have any concerns with the redactions applied and if you agree with the
redactions which we are proposing to remove. If you need any further information or have any questions,
please let me know. The redaction watermark on the document has been changed to a transparent colour so
as you can see the text behind.
The documents can be accessed here: https://ukwbd.highg.com/clientnetuk/documentHome.action?
metaData.siteID=2. metaData.parentFolderID=208147&metaData.module View=columnView&metaDat
a.paginationNo=0&metaData,loadMoreNo=0&sortOrder=0&filterShared=0
We would like to respond to Freeths by Friday lunchtime.
Kind regards
Amy
Amy Prime
Solicitor
Womble Bond Dickinson (UK) LLP
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From: Miranda Bond [mailtoj
Sent: 05 March 2019 11:52
To: Charlie Temperley; Andrew Parsons; Amy Prime; Emma Campbell-Danesh; Victoria Brooks; Jonathan
Gribben; Michael Wharton; Anna Martin; Dave Panaech; Lucy Bremner; Beth Hooper; Katie Simmonds;
Sushma MacGeoch; Rachel Lawrie; Jane Atkinson; Mandy Robertson
Ce: James Hartley; Imogen Randall; Dean Hill; Stephanie Jameson; Chloe Oram; Nicola Pettit; Francesca
See; Angélique Richardson
Subject: Post Office Group Litigation - Redactions
Dear Sirs,
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Please see attached our firm’s second letter of today’s date.
Yours faithfully,
Freeths LLP
Miranda Bond
Legal Assistant
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