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From: Swil, Jonathan
Sent: 05 March 2014.17:
To: .
Ce: Band, Christa; 4
Subject: RE: Mediation Scheme- confidential and privileged
Follow Up Flag: Follow up
Flag Status: Flagged
David
Ahead of the meeting tomorrow, I set out below a list of documents we have either seen reference to or which might
be helpful and which don’ appéar to be in our bundle. I appreciate that, as you mentioned, some of these documents
may not in fact exist:
e Any examples of the final form of the Post Office/Subpostmaster contract i.e. not the internal Post Office
administrative version we have seen.
e Any other key documents which might govern the Post Office/Subpostmaster relationship (e.g. operating
procedures or policies relating to Horizon).
Any internal written policy for the recovery of losses from Subpostmasters.
The final version of the Scheme Settlement Policy.
Records of Bond Dickinson’ s advice.
Records of Cartwright King’ s advice.
Any relevant Post Office prosecution policy.
Any records of the disposal/outcomes (including appeals) of the various criminal proceedings.
Any examples of the complaint-specific reports from Second Sight (apparently these were becomingavailable
from 27 February).
e Minutes of the Working Group.
eee e eee
Many thanks
Jonathan
From: Swil, Jonathan
Sent: 05 March 2014. 11:56
To: David Oliver.
Cc: Band, Christa;
Subject: RE: Mediation Scheme- confidential and privileged
David
To confirm, we will come to you at 9am tomorrow. We will need to leave by about 9.45am for Christa to be back for a
meeting here.
We will come ready to discuss what we can propose for the Board and with any key questions we have so far on the
documents (and will let you know in advance to the extent the questions are about missing documents).
Kind regards
Jonathan
From: Swil, Jonathan
Sent: 04 March 2014 17:41
To: David OliveieI Belinda Crowe
Cc: Band, Christa
Subject: RE: Mediation Scheme- confidential and privileged
1
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Dear Belinda and David
Further to Christa’ s email below, I attach the draft work plan. It sets out the potential issues you discussed with
Christa last week or which we have so far identified and the work we propose to do in respect of them with a view to
preparing the report. Please do let us know if you have any comments.
Kind regards
Jonathan
<< File: A17823075 v0.2 140304_Work Plan.docx >>
From: Band, Christa
Sent: 04 March 2014 16:35
To: David Oliveri; Belinda Crowe
Cc: Swil, Jonathan
Subject: Mediation Scheme- confidential and privileged
Dear Belinda and David
Thank you for the documents you sent through following our meeting last week.
Jonathan Swil is the Managing Associate who is going to work on this matter with me and he and I have put together
a brief workplan which Jonathan can send you later. All comments will be gratefully received. In the meantime, we
are working our way through the documents and issues and I thought that it would be sensible to catch up by
telephone on Thursday so that we can tell you where we have got to and what questions we have.
Please let Jonathan and/or me know if you think that this is a sensible way to proceed.
Best regards
Christa
Christa Band
Partner, Litigation Department
Linklaters LLP, London
www.linklaters.com