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From: Rodric William
To:
Thomas P Moran , Angela Van-Den-Bogerd
Patrick Bourke
D
ark Underwood1
Subject: Postmaster Litigation Steering Group - Confidential and Subject to Legal Privilege - Do
Not Forward
Date: Fri, 8 Jul 2016 15:27:07 +0000
Importance: Normal
Attachments: PLSG_Action_List.docx; PLSG_Agenda_14.07.16.docx;
_DOC_33332371(1)_Group_Action_-_Work_Plan_-_Meeting_on_14_July_2016.docx
Inline-Images: image001.png
All,
Please find attached a draft agenda for the next Steering Group meeting on 14 July 2016 at 1600, along with
the Action List and updated Bond Dickinson litigation work plan.
Bond Dickinson are near to having a draft Letter of Response (LOR) ready for review by the Steering
Group. The current plan is to circulate this on 15 July 2016 with a table directing each of you to the parts
most relevant to your sections of the business.
As noted in the agenda, to complete the LOR for circulation we need to make the tactical decisions set out
below and in the attached "one-page" paper covering each issue:
NAWRWNHE
. Do we address in detail the "bugs" in Horizon identified by Second Sight?
. Do we attack Second Sight's credibility / expertise in order to undermine their reports?
. Do we let Second Sight speak to Freeths?
. Do we lodge counterclaims against Claimants who have outstanding debts?
. Do we agree not to assert any Official Secrets Act obligations against claimants?
. Do we engage in further mediation?
. Do we explain whether part of Post Office's motivation for bringing prosecutions is a desire to recover
money?
Unfortunately, I am out of the office next week and cannot attend the meeting, for which I apologise. I have
however been through the questions with Andy Parsons from Bond Dickinson, who will be at the meeting to
provide my legal input on these issues.
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If you have any other items to add to the agenda, or any questions generally, please let me know (copying
Mark Underwood, cc’ed, who will help coordinate as necessary).
Kind regards, Rodric
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