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From: Nicky Mal [mailto;
Sent: Thursday, March 1
To: Swil, Jonathe
Ce: David Oliver.
Subject: FW: M
lard Time
Belinda Crowe ¢_
iation Scheme- confidential and privileged
Hi Jonathan,
Please find attached the skeleton argument for the Castleton case.
Regards
Nicky
From: Swil, Jonathan {
Sent: 11 March 18:21
To: David Oliver:
Cc: Band, Christa; Belinda Crowe
Subject: RE: Mediation Scheme- confidential and privileged
David
In respect of my list below the key outstanding items we would be most interested in seeing are the Bond Dickinson
and Cartwright King advice(s), although the other documents would be useful too if they can be obtained or exist. A
copy of counsel’ s skeleton if#sdeton case, as Frank Tao mentioned, would also likely be very helpful to us.
There is mention in the documents of a generic report expected soon from Second Sight. Is that likely to become
available in the remaining time before the report is due?
Many thanks
Jonathan
From: Swil, Jonathan
Sent: 05 Marc
To: David Oliv
Cc: Band, Christa; Belinda Crow
Subject: RE: Mediation Scheme- confidential and privileged
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’ t appear to be in our budippreciate that, as you mentioned, some of these documents
may not in fact exist
Any examples of the final form of the Post Office/Subpostmaster contract i.e. not the internal Post Office
administrative version we have seen
Any other key documents which might govern the Post Office/Subpostmaster relationship (e.g. operating procedures
or policies relating to Horizon).
1
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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 becoming available from
27 February).
Minutes of the Working Group.
Many thanks
Jonathan
From: Swil, Jonathan
Sent: 05 March 2014 11:56
To: David Oliver!
Cc: Band, Christa; Belinda Crowe (¢
Subject: RE: Mediation Scheme- confidential and privilege
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 Oliver:
Cc: Band, Christa
Subject: RE: Mediation Scheme- confidential and privileged
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.
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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
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