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Jane MacLeod <
Tom Beezer <{___
Andrew Parsons <7" :
< GRO p, Amy Prime
FW: Post Office Litigation - CONFIDENTIAL AND SUBJECT TO LEGAL
PRIVILEGE
Tue, 19 Mar 2019 20:05:00 +0000.
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Rodric Williams
Tom
See correspondence below from the UKGI GC requesting:
Update on proposed timing — could we get an update on readiness please - that is tomorrow morning can we say
whether we'll be ready to serve immediately/ Thursday /later? And
Written advice from LGQC by way of confirmation of our con yesterday.
Many thanks,
Jane
Jane MacLeod
Group Director of Legal, Risk & Governance
Ground Floor
20 Finsbury Street
LONDON
EC2Y 9AQ
Mobile number
From: Jane MacLeod
Sent: 19 March 2019 20:00
‘Watson, Richard - UKGI'
Cc: Cooper, Tom - UKGI
Te
Subject: RE: Post Office Litigation - CONFIDENTIAL AND SUBJECT TO LEGAL PRIVILEGE
Thanks Richard
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Our advice is that the application should be made this week. Ideally if we approve it tomorrow, then (I think) the
earliest timing is as follows:
the application would be served on the claimants and the judge on Thursday
application to be heard on Friday.
At that point the judge could accept and recuse himself, reject the application (in which case we would appeal) , or
he might ask to consider it over the weekend and/or suggest another judge hears the application. Counsels’ view
is that he will say ‘no’ either immediately or after consideration.
So, the point at which it would become public is definitely at the hearing, and potentially earlier following service
of the notice of the application on the Claimants (if they choose to make it public) — so Thursday on the above
timetable.
I will get confirmation on the state readiness and recommended timing for the calls for tomorrow.
Kind regards,
Jane
e Jane MacLeod
Group Director of Legal, Risk & Governance
Ground Floor.
20 Finsbury Street
LONDON
EC2Y 9AQ
Mobile number:
From: Watson, Richard - UKGI [mailto:
Sent: 19 March 2019 19:50
To: Jane Macleod <-
Cc: Cooper, Tom - UKGI <i ‘an GRO_ a
Subject: Re: Post Office Litigation - CONFIDENTIAL AND SUBJECT TO LEGAL PRIVILEGE
Jane
If a decision to make the application is made tomorrow when do you think the application will be lodged
with the court, and presumably the claimants at the same time - good to understand when it would become
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public?
Kind regards
Richard
Sent from my BlackBerry — the most secure mobile device
From: Richard.Watsot
Sent: 19 March 2019 7:24 pm
To: jane.macleod! 1} rodric.williamsf
Cc: Tom.Cooper
Subject: Re: Post Office Litigation - CONFIDENTIAL AND SUBJECT TO LEGAL PRIVILEGE
Jane
Thanks for the call earlier. As discussed I think it is essential that the board have the clearest possible advice
on the recusal application and its merits from Lord Grabiner in writing. It needn't be long, could refer to Lord
Neuberger's advice and could be a note approved by him.
kind regards
Richard
Sent from my BlackBerry — the most secure mobile device
From: Richard.Watsor
Sent: 19 March 2019 4:37 pm
Cc: Tom.Cooper}
Subject: Re: Post Office Litigation - CONFIDENTIAL AND SUBJECT TO LEGAL PRIVILEGE
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Jane
I understand from Tom that Neuberger's advice is to the effect that if POL want to appeal on procedural
unfairness then they must make a recusal application. Is the legal advice being updated in advance of
tomorrow's board meeting to reflect this? Does Lord Grabiner agree with Neuberger's advice? So far the
lawyers appear to say the prospects of success are "reasonable". Is Counsel willing to express that in
percentage terms?
Sorry for the questions but it will help handling at our end to have a clearer understanding of what legal
advice the board are being given regarding recusal and what the prospects of success are
Happy to discuss. I'm on
Kind regards
Richard
Sent from my BlackBerry — the most secure mobile device
rodric.williams"”
Subject: RE: Post Office Litigation - CONFIDENTIAL AND SUBJECT TO LEGAL PRIVILEGE
Thanks for the clarification Richard — my apologies if I misunderstood.
I will separately forward over the relevant information.
Kind regards,
Jane
Jane MacLeod
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Py Group Director of Legal, Risk & Governance
Ground Floor
20 Finsbury Street
LONDON
EC2Y 9AQ
Mobile number: [
From: Watson, Richard - UKGI [mailto: ]
Sent: 18 March 2019 /
To: Jane MacLeod <
Ce: Cooper, Tom - U
Subject: RE: Post Office Litigation - CONFIDENTIAL AND SUBJECT TO LEGAL PRIVILEGE
Rodrie Williams
Jane
Tom has forwarded your below email.
As I explained when we spoke, the concern from our end is HMG being seen as not upholding the
independence and integrity of the judiciary, hence the concern about Tom making a decision as a Director of
POL on whether to make a recusal application. However, it is perfectly proper that Tom, as a director, should
to ensure the Board fully realised the seriousness of what was proposed including the impact on the
shareholder (and the difficulties of distinguishing between strategic direction and operational matters in
Parliament and the media) as well as the wider litigation strategy, that the Board had taken and properly
considered legal advice, and finally has reflected properly on whether there was bias or (painful as it is)
inferences/findings drawn ultimately properly from hearing the evidence expressed in pithy and robust
language. In supporting Tom I would like to receive the information relating to the recusal issues.
Apologies if I suggested otherwise in our call.
Happy to discuss
Kind regards
Richard
Richard WatsonIGeneral Counsel
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UK Government Investments
1 Victoria Street I London I SW1H OET
W: https://www.ukgi.org.uk/
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From: Jane MacLeod
Sent: Monday, March 18, 2019 8:32:12 AM
To: Thomas Cooper
Ce: Rodric Williams
Subject: Post Office Litigation - CONFIDENTIAL AND SUBJECT TO LEGAL PRIVILEGE
Tom
Please find attached the note referred to.
In my call with Richard on Friday, he gave me the impression that the UKGI legal team would not want to
be seen to have received the information relating to the Recusal issues. To that end I have not provided any
of the advice to him. If that position has changed, would you please ask him to let me know?
Kind regards,
Jane
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