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From: Amy Prime ¢
To: Mark Underwoo
GRO _J Rodric Williams
Ce: Andrew Parsons} GRO 7
Subject: RE: Stage 2 Disclosure - KEL / Technical documents [BD-4A.FID26896945]
Date: Thu, 5 Apr 2018 09:54:11 +0000
Importance: Normal
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Mark
Yes, happy to take this decision to SteerCo.
We would like to disclose 99 of the technical documents this week in advance of the expert meeting on 11 April. The
Court deadline for these is 13 April but providing them early will gain Post Office some "brownie points" with Freeths.
For these documents we will undertake a full review for privilege so as they can be disclosed prior to the Steerco.
Many thanks
Amy
Amy Prime
Solicitor
Womble Bond Dickinson (UK) LLP
WOMBLE womblebonddickinson.com
BOND
DICKINSON + Ain)
mailto: GRO
Sent: 04 April 2018 19:29
To: Amy Prime; Rodric Williams
Cc: Andrew Parsons
Subject: RE: Stage 2 Disclosure - KEL / Technical documents [BD-4A.FID26896945]
Hi Amy, option 2 sounds like a sensible approach to me, but I think this actually needs to go to SteerCo. The
next call is on Weds 11" — can we pull together a very short DP for that ?
Mark
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° Mark Underwood
Head of Portfolio: Legal, Risk & Governance
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Sent: 03 April 2018 16:14
To: Rodric William:
Ce: Andrew Parsons {”
Subject: Stage 2 Disclosure -
Rodric, Mark
For Stage 2 Disclosure, Post Office have been ordered by the Court to provide Freeths with the KEL and Fu's technical
documents. There are two items which we need instructions / assistance with — actions are underlined.
POL information security sign off
Chris Jay has confirmed that FJ are happy to disclose the KEL to Freeths and is double checking that there are no
concerns with disclosing the technical documents. Chris Jay would like confirmation from Post Office Information
Security that Post Office is happy for the documents to be disclosed.
Chris Jay seeking this assurance stems from the fact that some of these documents contain security sensitive
information (ie. information on accessing the live Horizon system, etc.) and would not normally be placed into the
public domain. A non-disclosure agreement is in place between FJ and Jason Coyne which provides some protection,
but once the information is disclosed to Freeths there is a risk that it could be placed into the Court records and
therefore be public. We have had a brief discussion with Freeths about placing controls over such documents so as to
provide further protections (ie. placing in separate private Court bundles), they were not adverse to the idea but we will
need to have further discussions with them about how this would work in practice.
It would be helpful if Mick Ebsworth could sign off on the disclosure of these documents.
Mark — we will arrange a call with Mick Ebsworth to discuss the above but it would be helpful if you could join this call
and assist with getting Mick on-board.
Document review
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The KEL and Fu's technical documents are all relevant documents and unlikely to contain privileged material, however
there is a risk that they may contain privileged material. Since we do not need to review the documents for relevancy,
we would be reviewing 90k documents purely for privilege and looking for a limited number of documents.
The options are:
1. Not to review the documents and explain to Freeths that if privileged material has been disclosed then Post
Office has not waivered privilege over this. This is a risky approach as it is reliant on trusting Freeths to
inform us of privileged material and they will still hold the knowledge of what has been disclosed to them.
2. Keyword search the documents for words which are commonly included in privileged documents and
manually review these documents. There is still some risk of disclosing privileged material but this can be
mitigated by the keyword searching and we can still reserve Post Office's position that it is not waiving
privilege of any documents inadvertently disclosed.
3. Full review of all documents for privilege. This approach still contains some risk of disclosing privileged
material as identifying this within technical documents would not be a simple document review process and
there is an element of human error in all review processes.
We would recommend proceeding with Option 2, but please could you confirm you are happy with this approach.
If you have any questions, please feel free to call.
Kind regards
Amy
Amy Prime
Solicitor
Womble Bond Dickinson (UK) LLP
WOMBLE womblebonddickinson.com.
BOND
DICKINSON Ain)
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