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FREETHS
Womble Bond Dickinson (UK) LLP Direct dial:} a
DX 38517 Southampton 3 swe GRO
Email: james.hartleyé
13 March 2019
Our Ref: JXH/1684/2113618/3/AR
Your Ref AP6/364065.1369
By Email andrew.parsons
Dear Sirs
HORIZON ISSUES TRIAL: DISCLOSURE OF AUDIT REPORTS
We write further to our letter of 28 February 2019 in respect of pre-2011 audits of Horizon, which
have still not been disclosed.
As you know, the Claimants are due to begin cross examination of the Defendant's witnesses on
Monday. It is obvious that the content of the audits is likely to be relevant to the evidence of many of
the Defendant's witnesses, including potentially Mrs Van Den Bogerd, in addition to the evidence of
Mr Membery (whose witness statement is directly concerned with audits).
We first asked for audit reports on 19 September 2018 {H/115/2}:
“We would be grateful if you could now disclose the annual reports, produced by Ernst &
Young or otherwise, for each year since the introduction of Horizon, so that the experts and
the Court will be able to consider how the system developed over time.”
We again made a specific request on 21 December 2018, (as audits are referred to in Mr Membery’s
witness statement) {H/154/2}:
“Audit reports of Horizon carried out annually by Ernst and Young or otherwise”
You did not raise Royal Mail’s alleged concern about providing these documents until 27 February
2019, which we responded to very promptly, on 28 February making clear the Claimants’ position.
We do not repeat here the contents of that letter.
Please now disclose the audits, today, or otherwise clearly state Post Office's position.
Please read our Data Protection Privacy Notice at www.freeths.co.uk
Frochs LLP i lites labty partnership, registred in England and Wales, partnership number OC304688, Registered Otfice: Cumberland Cour, 80 Mount Sweet, Notingham NGI 6HH.
‘Aorsed and regulated bythe Sotors egulaton Ahoy. Ault ofthe members of Freaihs LLP is avalatle or inspection atthe registred office
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13 March 2019
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Please in any event provide a response to this letter today, so that, if required, this matter can be
raised at Court tomorrow.
Yours faithfully
hobo?
Freeths LLP
Please respond by e-mail where possible
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