office has worked report, the post office has worked collaboratively? is that true? to a very small — collaboratively? is that true? to a very small degree. _ collaboratively? is that true? to a very small degree. and _ collaboratively? is that true? to a very small degree. and designed l collaboratively? is that true? to a i very small degree. and designed the initial mediation _ very small degree. and designed the initial mediation scheme _ very small degree. and designed the initial mediation scheme and - very small degree. and designed the initial mediation scheme and it - very small degree. and designed the initial mediation scheme and it was l initial mediation scheme and it was agreed with you and put on your website, that is correct? yes. the post office _ website, that is correct? yes. the post office remained _ website, that is correct? yes. the post office remained true to the aims of the scheme, is that correct? to a degree. aims of the scheme, is that correct? to a degree-— to a degree. committed substantial resource to — to a degree. committed substantial resource to make _ to a degree. committed substantial resource to make sure _ to a degree. committed substantial resource to make sure of _ to a degree. committed substantial resource to make sure of its - to a degree. committed substantial| resource to make sure of its success and respect of the confidentiality of the working group? and then there is about sharing a platform on the 24th of march. and then the letter sent to the minister has come as a shock and disappointment, it says, to her, ifind two things shock and disappointment, it says, to her, i find two things troubling, the latter appears to breach the confidentiality of the working group —— the latter. and it paints a

picture which is inconsistent of the position as i understood it to be. that is another one of these things where, _ that is another one of these things where, is _ that is another one of these things where, is she getting the right information from her staff? she never— information from her staff? she never attended these meetings. never ever attended one of the working group _ ever attended one of the working group meetings to the best of my knowledge. this group meetings to the best of my knowledue. . . group meetings to the best of my knowledge-— group meetings to the best of my knowledue. , , , ., ., , knowledge. this is to be set against the context of _ knowledge. this is to be set against the context of the _ knowledge. this is to be set against the context of the e-mail _ knowledge. this is to be set againstl the context of the e-mail discussion the context of the e—mail discussion which is how do we inform the minister's replied to this letter without describing that we have... without disclosing that fact. the second point she makes is the fact you have bypassed the working group. i remain committed in principle to making the scheme work, your letter has damaged the trust the post office has invested in you as a member of the working group. there are a number of specific points and i have asked chris to prepare a more

detailed response and in the meantime i have got to consider the position of the post office in relation to the scheme over the coming days. did you know that the post office was having an internal debate at this time over whether your letter presented a golden opportunity because of your alleged breach of confidentiality for the post office to back out of the scheme and bring it to a quick close? i scheme and bring it to a quick close? .. . scheme and bring it to a quick close? ., , ., ., ., scheme and bring it to a quick close? ., ., ., ., ., close? i was not aware of that. i resume close? i was not aware of that. i presume this — close? i was not aware of that. i presume this is _ close? i was not aware of that. i presume this is something - close? i was not aware of that. i presume this is something that l close? i was not aware of that. i. presume this is something that was discussed _ presume this is something that was discussed in a project sparrow, i don't _ discussed in a project sparrow, i don't know. _ discussed in a project sparrow, i don't know, may be a question for them _ don't know, may be a question for them my— don't know, may be a question for them. my concern has always been the group _ them. my concern has always been the group first— them. my concern has always been the group first and what is best for the group _ group first and what is best for the group and — group first and what is best for the group and not what is best for post office _ group and not what is best for post office in _ group and not what is best for post office in all— group and not what is best for post office in all of this. i was representing the group in these discussions and with what was going on, discussions and with what was going on. and _ discussions and with what was going on. and to— discussions and with what was going on, and to stand up for what was right— on, and to stand up for what was right at_ on, and to stand up for what was right at the — on, and to stand up for what was right at the time for them. we can turn to paragraph _ right at the time for them. we can turn to paragraph 157 _ right at the time for them. we can turn to paragraph 157 of _ right at the time for them. we can turn to paragraph 157 of the - right at the time for them. we can l turn to paragraph 157 of the witness statement, please. it is on page 53.

yes. ., ., .,, statement, please. it is on page 53. yes. ., ., ' ., yes. you say in paragraph 157, that ou yes. you say in paragraph 157, that you believe — yes. you say in paragraph 157, that you believe the _ yes. you say in paragraph 157, that you believe the mediation - yes. you say in paragraph 157, that you believe the mediation schemel you believe the mediation scheme failed as it was part of the cover—up by pol. is that what you said based on information from sub—postmaster? i suppose, to the feedback from working — suppose, to the feedback from working the scheme, that many

months. — working the scheme, that many months, for those years, and knowing the way— months, for those years, and knowing the way post — months, for those years, and knowing the way post office operated. i have been dealing with them then for many years and _ been dealing with them then for many years and i_ been dealing with them then for many years and i could see the way they operated _ years and i could see the way they operated and what they were up to and whether they were forthcoming on issues _ and whether they were forthcoming on issues in _ and whether they were forthcoming on issues. .. . . , ., . , issues. in what circumstances did the post office _ issues. in what circumstances did the post office terminate - issues. in what circumstances did the post office terminate the - the post office terminate the scheme? i the post office terminate the scheme? ., ., , ., , ., scheme? i got a phone call, 'ust to sa , oh, scheme? i got a phone call, 'ust to say. on. we — scheme? i got a phone call, 'ust to say. on. we have i scheme? i got a phone call, 'ust to say, oh, we have decided h scheme? i got a phone call, 'ust to say, oh, we have decided toh scheme? i got a phone call, just to say, oh, we have decided to send i scheme? i got a phone call, just to i say, oh, we have decided to send the case to— say, oh, we have decided to send the case to mediation now so there is no need _ case to mediation now so there is no need for— case to mediation now so there is no need for the — case to mediation now so there is no need for the working group to meet. interestingly, that was the day before — interestingly, that was the day before a — interestingly, that was the day before a meeting was due to be held in which _ before a meeting was due to be held in which we — before a meeting was due to be held in which we were going to see the draft _ in which we were going to see the draft of— in which we were going to see the draft of the second site part two report _ draft of the second site part two report which was damning, one of the reasons— report which was damning, one of the reasons they — report which was damning, one of the reasons they did that was to stop the report— reasons they did that was to stop the report from coming out, i think. what _ the report from coming out, i think. what was _ the report from coming out, i think. what was your view of the decision

of the post office to terminate the scheme? . . , .,, , of the post office to terminate the scheme? ._ , , scheme? publicly i was very dismayed about it and — scheme? publicly i was very dismayed about it and privately _ scheme? publicly i was very dismayed about it and privately i _ scheme? publicly i was very dismayed about it and privately i was _ about it and privately i was ecstatic— about it and privately i was ecstatic about it because i had been thinking _ ecstatic about it because i had been thinking of— ecstatic about it because i had been thinking of bringing down the scheme for about— thinking of bringing down the scheme for about 12 months and i had been sitting _ for about 12 months and i had been sitting in— for about 12 months and i had been sitting in there to get as much information and reports out of them information and reports out of them in order— information and reports out of them in order for— information and reports out of them in order for us to move onto the next _ in order for us to move onto the next step— in order for us to move onto the next step of— in order for us to move onto the next step of legal action. did you then make _ next step of legal action. did you then make a _ next step of legal action. did you then make a decision _ next step of legal action. did you then make a decision that - next step of legal action. did you then make a decision that it - next step of legal action. did you then make a decision that it was| then make a decision that it was necessary to commence legal proceedings? late necessary to commence legal proceedings?— necessary to commence legal ”roceedins? ~ .. , proceedings? we had been looking around for little _ proceedings? we had been looking around for little while _ proceedings? we had been looking around for little while and - proceedings? we had been looking around for little while and the - around for little while and the writing — around for little while and the writing was on the wall and had been for a of— writing was on the wall and had been for a of months. we spoke to a few firms— for a of months. we spoke to a few firms -- _ for a of months. we spoke to a few firms -- a — for a of months. we spoke to a few firms —— a number of months. the firms -- a number of months. the first claimant _ firms -- a number of months. the first claimant was _ firms —— a number of months. tue: first claimant was issued in firms —— a number of months. tu2 first claimant was issued in april 2016 regarding the group litigation? the first claim? yes. we eventually found a firm —

the first claim? yes. we eventually found a firm in _ the first claim? 1213 we eventually found a firm in september the first claim? i2; we eventually found a firm in september 2015 and that is— found a firm in september 2015 and that is when they came on board and they really— that is when they came on board and they really took over. one that is when they came on board and they really took over.— they really took over. one of the first steps _ they really took over. one of the first steps was _ they really took over. one of the first steps was an _ they really took over. one of the first steps was an application - they really took over. one of the first steps was an application by | first steps was an application by the claimants for a group litigation order? .. . the claimants for a group litigation order? .. , . the claimants for a group litigation order?_ that - the claimants for a group litigation order?_ that was i order? that is correct. that was o- osed order? that is correct. that was opposed by _ order? that is correct. that was opposed by the _ order? that is correct. that was opposed by the post _ order? that is correct. that was opposed by the post office? - order? that is correct. that was l opposed by the post office? that order? that is correct. that was - opposed by the post office? that is correct. opposed by the post office? that is correct- the — opposed by the post office? that is correct. the court _ opposed by the post office? that is correct. the court order _ opposed by the post office? that is correct. the court order that - opposed by the post office? that is correct. the court order that the . correct. the court order that the claim should _ correct. the court order that the claim should be _ correct. the court order that the claim should be managed - correct. the court order that the claim should be managed under| correct. the court order that the l claim should be managed under a group litigation order from the 22nd of march, 2017, despite that? that is riuht. i of march, 2017, despite that? that is right. i think— of march, 2017, despite that? that is right. i think the _ of march, 2017, despite that? that is right. i think the announcementl is right. i think the announcement was made by _ is right. i think the announcement was made by press _ is right. i think the announcement was made by press release - is right. i think the announcement was made by press release by - is right. i think the announcement was made by press release by the j was made by press release by the jfsa of the making of the group litigation order? i jfsa of the making of the group litigation order?_ jfsa of the making of the group litigation order? i don't recall but it probably _ litigation order? i don't recall but it probably did. _ litigation order? i don't recall but it probably did. do _ litigation order? i don't recall but it probably did. do you _ litigation order? i don't recall but| it probably did. do you remember litigation order? i don't recall but i it probably did. do you remember if there was a — it probably did. do you remember if there was a time _ it probably did. do you remember if there was a time when _ it probably did. do you remember if there was a time when people - it probably did. do you remember if. there was a time when people wanted to join there was a time when people wanted tojoin in the there was a time when people wanted to join in the litigation, there was a time when people wanted tojoin in the litigation, a cut—off point? to join in the litigation, a cut-off oint? . to join in the litigation, a cut-off oint? , ., ,

to join in the litigation, a cut-off oint? . .. . ~ to join in the litigation, a cut-off oint? . ., , . , point? yes, there was. with this leual point? yes, there was. with this legal firm. _ point? yes, there was. with this legal firm. we — point? yes, there was. with this legalfirm, we had _ point? yes, there was. with this legal firm, we had to _ point? yes, there was. with this legal firm, we had to find - point? yes, there was. with this legal firm, we had to find the . legal firm, we had to find the funding — legal firm, we had to find the funding and then go out and recruit far more _ funding and then go out and recruit far more claimants. a whole batch of pa and _ far more claimants. a whole batch of pa and advertising was undertaken for a few— pa and advertising was undertaken for a few months to bring forward the numbers that were needed. the names— the numbers that were needed. the names that — the numbers that were needed. the names that go forward to be attached to the _ names that go forward to be attached to the glo. _ names that go forward to be attached to the glo, about three were attached _ to the glo, about three were attached to the 550 that went forward _ attached to the 550 that went forward. .. ., ., ~' attached to the 550 that went forward. .. ., ., ~ ., , ,, forward. can we look at the press release that _ forward. can we look at the press release that you _ forward. can we look at the press release that you made, _ forward. can we look at the press release that you made, that - forward. can we look at the press release that you made, that the l forward. can we look at the press . release that you made, that the jfsa release that you made, that the jfsa made. and go to the second page towards the bottom, please. this is an

e—mail from the bottom, please. this is an e—mailfrom melanie the bottom, please. this is an e—mail from melanie corfield, the bottom, please. this is an e—mailfrom melanie corfield, a name we will become familiar with in these phases, and she is a member of these phases, and she is a member of the post office's communications team. going back to the e—mail, you will see she e—mails roderick williams, andrew parsons, and others, saying we have been alerted to a issue by thejfsa and there is the statement a bit further down, cut into her e—mail. can you see that? cut into her e-mail. can you see that? , cut into her e-mail. can you see that?- you _ cut into her e-mail. can you see that?- you say _ cut into her e-mail. can you see that?- you say in _ cut into her e-mail. can you see that?- you say in the - cut into her e—mail. can you see that? yes. you say in the statement, jfsa that? yes. you say in the statement, jfsa announced _ that? yes. you say in the statement, jfsa announced today that the group litigation order against the post office has now been approved by the president of the queens bench division of the high court which means the case will continue through the court as a group action and post

office limited is defending the claim and over a thousand sub—postmasters have said they will join the action. sub-postmasters have said they will join the action-— join the action. about 1200 applied but b the join the action. about 1200 applied but by the time _ join the action. about 1200 applied but by the time we _ join the action. about 1200 applied but by the time we sifted _ join the action. about 1200 applied but by the time we sifted through i but by the time we sifted through then we _ but by the time we sifted through then we finished up with a 550. the second then we finished up with a 550. second page, then we finished up with a 550. ti2 second page, there, we have a quote from you, anna bates says the case is now up and running. —— alan bates. ijust want i just want to ask you some questions about the rest of the e—mail, even though you were not copied into it because they are relevant to later witnesses. if we scroll up the page. it is sent to andrew parsons amongst others. and

then in the e—mail, there is a reply from the head of portfolio, legal risk and governance, mark underwood, saying jfsa have issued a statement, the statement is included in the note below, it says, and i do not think there's anything you included in it, save for the claim that over 1000 sub—postmasters across the uk iooo sub—postmasters across the uk have to join the action, concerning they have used the word applied rather than just joint they have used the word applied rather than justjoint or similar. and then, further up... we are to hearfrom the group and then, further up... we are to hear from the group director of legal governance. the key words are underlined. and then further up the page, andrew parsons says that he is happy with the comms as a draft

reply, and do not forget that alan bates has a loose relationship with the truth. �* . the truth. laughter a couple _ the truth. laughter a couple of - the truth. laughter| a couple of questions the truth. laughter - a couple of questions on that, firstly, what you said in a press release, was it accurate?- firstly, what you said in a press release, was it accurate? yes. how ou had release, was it accurate? yes. how you had any — release, was it accurate? yes. how you had any dealings with mr parsons? , . you had any dealings with mr parsons?- had - you had any dealings with mr parsons?- had you | you had any dealings with mr. parsons?- had you had you had any dealings with mr- parsons?- had you had any parsons? oh, yes. had you had any deafinrs parsons? oh, yes. had you had any dealings with _ parsons? oh, yes. had you had any dealings with him _ parsons? oh, yes. had you had any dealings with him that _ parsons? oh, yes. had you had any dealings with him that might - parsons? oh, yes. had you had any dealings with him that might allowl dealings with him that might allow him to form the view that you had a loose relationship with the truth? no. andrew parsons used to be in the working _ no. andrew parsons used to be in the working group meetings, one of the many— working group meetings, one of the many lawyers the post office used to sendr _ many lawyers the post office used to send. and _ many lawyers the post office used to send. and i _ many lawyers the post office used to send, and i don't know why he has come _ send, and i don't know why he has come up _ send, and i don't know why he has come up with that. i might embellish but i do _ come up with that. i might embellish but i do not _ come up with that. i might embellish but i do not lie. anything to promote _ but i do not lie. anything to promote it, i suppose i spent too much — promote it, i suppose i spent too much time — promote it, i suppose i spent too much time around lawyers so the wording — much time around lawyers so the wording can seem a little bit that way _

wording can seem a little bit that way but — wording can seem a little bit that way. but we had had over 1200 people that did _ way. but we had had over 1200 people that did apply to join the scheme. out of— that did apply to join the scheme. out of that, 550 were signed up. in the out of that, 550 were signed up. the course of out of that, 550 were signed up. i�*i the course of litigation that can come down, there was an application to strike out passages from your witness statement, is that right? yes. .,, , . witness statement, is that right? yes. '. witness statement, is that right? yes. , . ., yes. the post office applied to strike it out. _ yes. the post office applied to strike it out. and _ yes. the post office applied to strike it out. and that - yes. the post office applied to l strike it out. and that application was dismissed for the references 4094. in the course of that judgment, is it right that the judge, and in a previousjudgment, livid warnings about aggressive litigation tactics? —— delivered warnings. litigation tactics? -- delivered warninrs. .

litigation tactics? -- delivered warnings.- what - litigation tactics? -- delivered warnings.- what if - litigation tactics? —— delivered warnings. yes. what if any litigation _ warnings. yes. what if any litigation tactics _ warnings. yes. what if any litigation tactics were - warnings. yes. what if any litigation tactics were being used by the post office from your perspective?— by the post office from your --ersective? , , perspective? they were definitely t in: to perspective? they were definitely trying to outspend _ perspective? they were definitely trying to outspend us. _ perspective? they were definitely trying to outspend us. we - perspective? they were definitely trying to outspend us. we had - perspective? they were definitely trying to outspend us. we had to | trying to outspend us. we had to raise _ trying to outspend us. we had to raise commercial funding. they had a bottomless _ raise commercial funding. they had a bottomless pocket, being a government organisation, so anything they could _ government organisation, so anything they could do to spin it out and anything — they could do to spin it out and anything they could do to accuse the judge _ anything they could do to accuse the judge or— anything they could do to accuse the judge or whatever, they did. anything _ judge or whatever, they did. anything to cost us money and to try and get _ anything to cost us money and to try and get us _ anything to cost us money and to try and get us to stop the case. that was obvious. and get us to stop the case. that was obvious-— and get us to stop the case. that was obvious. ., ., . ., was obvious. you gave evidence and the reference _ was obvious. you gave evidence and the reference is _ was obvious. you gave evidence and the reference is pol _ was obvious. you gave evidence and the reference is pol treble - was obvious. you gave evidence and the reference is pol treble 02, - was obvious. you gave evidence and j the reference is pol treble 02, 296, the reference is pol treble o2, 296, and for reference, between pages 44 and for reference, between pages 44 and 51, thejudge deals and for reference, between pages 44 and 51, the judge deals with your evidence and the findings that he made about your truthfulness and

honesty which i will not display at the moment. in your witness statement you provide examples of what you say was the post office trying to prevent the truth coming out in the group litigation. ok. out in the group litigation. ok, es. can out in the group litigation. ok, yes- can you — out in the group litigation. ok, yes. can you assist _ out in the group litigation. ok, yes. can you assist us - out in the group litigation. ok, yes. can you assist us with - out in the group litigation. ok, | yes. can you assist us with what those tactics — yes. can you assist us with what those tactics were? _ yes. can you assist us with what those tactics were? obviously, l yes. can you assist us with what. those tactics were? obviously, to outsend those tactics were? obviously, to outspend us. _ those tactics were? obviously, to outspend us, that _ those tactics were? obviously, to outspend us, that was _ those tactics were? obviously, to outspend us, that was the - those tactics were? obviously, to outspend us, that was the key . those tactics were? obviously, to | outspend us, that was the key one throughout all of that. i listed the main _ throughout all of that. i listed the main points they have gone through, i main points they have gone through, i think _ main points they have gone through, i think it— main points they have gone through, i think. , ., main points they have gone through, i think. . ., , ., ., i think. it is right that you have ourself i think. it is right that you have yourself made _ i think. it is right that you have yourself made an _ i think. it is right that you have yourself made an application i i think. it is right that you have | yourself made an application for redress. . .. yourself made an application for redress._ when - yourself made an application for redress._ when was | yourself made an application for. redress._ when was the redress. yes, i have. when was the application — redress. yes, i have. when was the application made? _ redress. yes, i have. when was the application made? gosh. _ redress. yes, i have. when was the application made? gosh. it- redress. yes, i have. when was the application made? gosh. it must. redress. yes, i have. when was the i application made? gosh. it must have been, i application made? gosh. it must have been. ithink— application made? gosh. it must have been. i think it _ application made? gosh. it must have been, i think it was _ application made? gosh. it must have been, i think it was october _ application made? gosh. it must have been, i think it was october last - been, i think it was october last year~ _ been, i think it was october last ear. �* ., ., ., ., ., year. i'm not going to ask you what an of the year. i'm not going to ask you what any of the figures _ year. i'm not going to ask you what

any of the figures are _ year. i'm not going to ask you what any of the figures are or _ year. i'm not going to ask you what any of the figures are or what - year. i'm not going to ask you what any of the figures are or what the l any of the figures are or what the offers are but when did you first receive an offer? i offers are but when did you first receive an offer?— receive an offer? i received an offer, receive an offer? i received an offer. within — receive an offer? i received an offer, within 77 _ receive an offer? i received an offer, within 77 working - receive an offer? i received an offer, within 77 working days | receive an offer? i received an - offer, within 77 working days after my claim — offer, within 77 working days after my claim had gone in, which against a target _ my claim had gone in, which against a target of— my claim had gone in, which against a target of the department responding in 40 days. the offer that they— responding in 40 days. the offer that they actually made was only about _ that they actually made was only about i6 — that they actually made was only about 16 of the claim that had gone in -- _ about 16 of the claim that had gone in -- one _ about 16 of the claim that had gone in —— one sixth. i am trying to fight — in —— one sixth. i am trying to fight for— in —— one sixth. i am trying to fight for every one of's financial redress— fight for every one of's financial redress but i have also got to fight for my— redress but i have also got to fight for my own — redress but i have also got to fight for my own and i have no doubt that there _ for my own and i have no doubt that there is— for my own and i have no doubt that there is a _ for my own and i have no doubt that there is a bit— for my own and i have no doubt that there is a bit of vindictiveness coming — there is a bit of vindictiveness coming in _ there is a bit of vindictiveness coming in from the department and the post _ coming in from the department and the post office on this, the reason i the post office on this, the reason i say— the post office on this, the reason i say that— the post office on this, the reason i say that is— the post office on this, the reason i say that is quite simple, they do not think— i say that is quite simple, they do not think there is any worth to any of the _ not think there is any worth to any of the work— not think there is any worth to any of the work i — not think there is any worth to any of the work i have done over the years _ of the work i have done over the years my— of the work i have done over the years. my claim has gone in and it

has been — years. my claim has gone in and it has been treated exactly the same as everybody _ has been treated exactly the same as everybody else and they all have these _ everybody else and they all have these heads of claims in there and there _ these heads of claims in there and there are — these heads of claims in there and there are some heads of claim that are applied — there are some heads of claim that are applied to some people are not to others— are applied to some people are not to others and i was never made bankrupt — to others and i was never made bankrupt so that is not apply to me. i bankrupt so that is not apply to me. i was _ bankrupt so that is not apply to me. i was never— bankrupt so that is not apply to me. i was never suspended. so they do vary _ i was never suspended. so they do vary. but. — i was never suspended. so they do vary. but, this was without me knowing — vary. but, this was without me knowing the lawyers representing or dealing _ knowing the lawyers representing or dealing with my claim, and also the forensic— dealing with my claim, and also the forensic accountants dealing with my claim _ forensic accountants dealing with my claim, put— forensic accountants dealing with my claim, put it together and i was not involved _ claim, put it together and i was not involved with the figures, and they put it— involved with the figures, and they put it together and they included an amount— put it together and they included an amount for— put it together and they included an amount for the work i had done over the 20 _ amount for the work i had done over the 20 years. — amount for the work i had done over the 20 years, like another column heading — the 20 years, like another column heading it— the 20 years, like another column heading. it has been totally negated by them, _ heading. it has been totally negated by them, in other words the government does not think anything i have done _ government does not think anything i have done is worth anything. the first offer you — have done is worth anything. ti2 first offer you received is shortly before your appearance before the select committee injanuary? yes.

select committee in january? yes. you said publicly _ select committee in january? yes. you said publicly that _ select committee in january? yes. you said publicly that it _ select committee injanuary? yes. you said publicly that it was derisory? it you said publicly that it was derisory?— you said publicly that it was - derisory?_ have derisory? it was. it still is. have ou derisory? it was. it still is. have you received _ derisory? it was. it still is. have you received any _ derisory? it was. it still is. have you received any further - derisory? it was. it still is. have you received any further offers? j derisory? it was. it still is. have - you received any further offers? no. a challenge — you received any further offers? no. a challenge letter went in for my lawyer— a challenge letter went in for my lawyer and they were meant to hear last week, _ lawyer and they were meant to hear last week, a — lawyer and they were meant to hear last week, a response, but they never— last week, a response, but they never received it. so i still don't know— never received it. so i still don't know anything. never received it. so i still don't know anything-— know anything. from your perspective. _ know anything. from your perspective, has - know anything. from your perspective, has the - know anything. from your i perspective, has the process know anything. from your - perspective, has the process of seeking and obtaining redress been efficient and effective? ida. in your efficient and effective? no. in your case, what have been the principal problem is, aside from the time limits of the reply, with the operation of the scheme of redress? the initial problem was disclosure by post _ the initial problem was disclosure by post office, and once again, they would _ by post office, and once again, they would not _ by post office, and once again, they would not come forward with it and considering they knew the names of all of— considering they knew the names of all of those people involved in that

scheme, _ all of those people involved in that scheme, from the date when the minister— scheme, from the date when the minister announced the scheme which was 22nd _ minister announced the scheme which was 22nd of— minister announced the scheme which was 22nd of march, so there is no reason _ was 22nd of march, so there is no reason they— was 22nd of march, so there is no reason they could not have started. you mean _ reason they could not have started. you mean have a head start?- reason they could not have started. you mean have a head start? yes,. i do. i you mean have a head start? yes,. i do- i think — you mean have a head start? yes,. i do- i think it— you mean have a head start? yes,. i do. i think it was _ you mean have a head start? yes,. i do. i think it was fortuitous, - you mean have a head start? yes,. i do. i think it was fortuitous, the - do. i think it was fortuitous, the comment— do. i think it was fortuitous, the comment made first thing this morning — comment made first thing this morning about disclosure, and that you should — morning about disclosure, and that you should just carry on regardless and just— you should just carry on regardless and just ignore it if it hasn't come through. — and just ignore it if it hasn't come through, just get on with the job, and i_ through, just get on with the job, and i think— through, just get on with the job, and i think that is what should have happened _ and i think that is what should have happened quite a while ago. standing back, what happened quite a while ago. standing back. what is — happened quite a while ago. standing back, what is your _ happened quite a while ago. standing back, what is your experience - happened quite a while ago. standing back, what is your experience of - happened quite a while ago. standing back, what is your experience of the i back, what is your experience of the culture of the post office in your dealings with it over the years? they are an atrocious organisation and they— they are an atrocious organisation and they need disbanding and removing and building up again from the ground _ removing and building up again from the ground floor, and eyesight have been quoted quite commonly, the

whole _ been quoted quite commonly, the whoie of— been quoted quite commonly, the whole of the postal service these days. _ whole of the postal service these days it _ whole of the postal service these days it is — whole of the postal service these days, it is a dead duck, beyond saving. — days, it is a dead duck, beyond saving. and _ days, it is a dead duck, beyond saving, and to be quite truthful it needs— saving, and to be quite truthful it needs to — saving, and to be quite truthful it needs to be sold to someone like horizon. — needs to be sold to someone like horizon, sorry, i don't mean that, sold _ horizon, sorry, i don't mean that, sold to _ horizon, sorry, i don't mean that, sold to someone like amazon, it needs— sold to someone like amazon, it needs a — sold to someone like amazon, it needs a big injection of money, and ithink— needs a big injection of money, and i think that — needs a big injection of money, and i think that can only happen coming from outside otherwise it willjust be a bugbear for the government for years— be a bugbear for the government for years to _ be a bugbear for the government for years to come. be a bugbear for the government for years to come-— years to come. thank you very much for answering _ years to come. thank you very much for answering my — years to come. thank you very much for answering my many _ years to come. thank you very much for answering my many questions i for answering my many questions today. only one set of questions from sub—master groups and that is from sub—master groups and that is from mr henry. i from sub-master groups and that is from mr henry-— from sub-master groups and that is from mr henry. i will move over here so i can from mr henry. i will move over here so i can see — from mr henry. i will move over here so i can see mr— from mr henry. i will move over here so i can see mr henry, _ from mr henry. i will move over here so i can see mr henry, unimpeded i from mr henry. i will move over here j so i can see mr henry, unimpeded by a large _ so i can see mr henry, unimpeded by a large piliar~ — so i can see mr henry, unimpeded by a large pillar-— a large pillar. thank you, mr bates. you have exposed _

a large pillar. thank you, mr bates. you have exposed over _ a large pillar. thank you, mr bates. you have exposed over many i a large pillar. thank you, mr bates. you have exposed over many years| a large pillar. thank you, mr bates. i you have exposed over many years the post office's _ you have exposed over many years the post office's suppression of disclosure, covering up the truth over— disclosure, covering up the truth over horizon's floors but you have also exposed the government's reckless — also exposed the government's reckless indifference to the post office's — reckless indifference to the post office's misconduct over many years, would _ office's misconduct over many years, would you _ office's misconduct over many years, would you agree? | office's misconduct over many years, would you agree?— would you agree? i think that is the case. would you agree? i think that is the case- since — would you agree? i think that is the case. since all— would you agree? i think that is the case. since all this, _ would you agree? i think that is the case. since all this, since _ would you agree? i think that is the case. since all this, since this i case. since all this, since this year, i suppose, case. since all this, since this year, isuppose, since case. since all this, since this year, i suppose, since the drama, we have had far more publicity, about theissue, have had far more publicity, about the issue, nationally, and i have noticed there is a general frustration with many other organisations that have that problem with government as well. it seems to be a fundamental flaw in the way government works, that they cannot deal with these type of things easily. and sensibly.- deal with these type of things easily. and sensibly. could i take ou to a easily. and sensibly. could i take you to a letter — easily. and sensibly. could i take you to a letter you _ easily. and sensibly. could i take you to a letter you received i easily. and sensibly. could i take you to a letter you received and l easily. and sensibly. could i take i you to a letter you received and we will deal _ you to a letter you received and we will deal with it very briefly, but

it is pol— will deal with it very briefly, but it is pol 001,02, will deal with it very briefly, but it is pol 001, 02, 385, and this is a letter_ it is pol 001, 02, 385, and this is a letter you _ it is pol 001, 02, 385, and this is a letter you received shortly after the i9th — a letter you received shortly after the 19th of march 2015 from the minister— the 19th of march 2015 from the ministerjo swinson. you had written to her— ministerjo swinson. you had written to her on— ministerjo swinson. you had written to her on the 10th of march regarding the post office mediation scheme _ regarding the post office mediation scheme. have you had a chance to look at _ scheme. have you had a chance to look at this— scheme. have you had a chance to look at this letter before coming here today?— look at this letter before coming here today?- would i look at this letter before coming | here today?- would you look at this letter before coming i here today?- would you care here today? possibly. would you care to read it to — here today? possibly. would you care to read it to yourself _ here today? possibly. would you care to read it to yourself and _ here today? possibly. would you care to read it to yourself and when - here today? possibly. would you care to read it to yourself and when you i to read it to yourself and when you have _ to read it to yourself and when you have done — to read it to yourself and when you have done so, could you let me know? i have done so, could you let me know? i want _ have done so, could you let me know? i want to _ have done so, could you let me know? i want to take — have done so, could you let me know? i want to take you to just one passage _ i want to take you to just one passage in it but i want to give you the opportunity to refresh your memory— the opportunity to refresh your memory in case there is anything you would _ memory in case there is anything you would like _ memory in case there is anything you would like to point out.

yes. thank you. you can see at the conclusion — yes. thank you. you can see at the conclusion that _ yes. thank you. you can see at the conclusion that the _ yes. thank you. you can see at the conclusion that the minister - yes. thank you. you can see at the| conclusion that the minister states, to conclude, i note that the second site report — to conclude, i note that the second site report and the subsequent investigations, there is no evidence of a system — investigations, there is no evidence of a system wide problem with horizon — of a system wide problem with horizon and this conclusion has stood _ horizon and this conclusion has stood firm _ horizon and this conclusion has stood firm through nearly two years of investigation. so when did you become — of investigation. so when did you become aware that the post office had in _ become aware that the post office had in fact— become aware that the post office had in fact written to their insurers _ had in fact written to their insurers nearly two years before

that to — insurers nearly two years before that to notify them of issues with horizon. — that to notify them of issues with horizon, potential issues with horizon. _ horizon, potential issues with horizon, which was originally going to be _ horizon, which was originally going to be described as financial discrepancies, that have occurred in horizon? _ discrepancies, that have occurred in horizon? when did you become aware that the _ horizon? when did you become aware that the post office had written to their insurers?— that the post office had written to their insurers? well. there are two arts to their insurers? well. there are two parts to that _ their insurers? well. there are two parts to that answer _ their insurers? well. there are two parts to that answer and _ their insurers? well. there are two parts to that answer and the i their insurers? well. there are two parts to that answer and the first i parts to that answer and the first one, i think, parts to that answer and the first one, ithink, is parts to that answer and the first one, i think, is when a lot of people became aware of it which was, it was the overturning of convictions, over those cases, the appeal courts, that is one of the times it arose. but also, there is a similar reference that i have seen recently in a document disclosed to me for the hearing, and i'm trying to think of the date, it wasjuly...

2013? to think of the date, it was july. .. 2013? , to think of the date, it was july. .. 2013? . , ., ,., ., to think of the date, it was july. .. 2013? . , ., ., ., to think of the date, it was july. .. 2013? , , . . ., y 2013? this is about, what do they call it, 2013? this is about, what do they call it. the — 2013? this is about, what do they call it, the insurance? _ 2013? this is about, what do they call it, the insurance? i— 2013? this is about, what do they call it, the insurance? i will- 2013? this is about, what do they call it, the insurance? i will take. call it, the insurance? i will take ou to call it, the insurance? i will take you to it- _ call it, the insurance? i will take you to it- if— call it, the insurance? i will take you to it. if we _ call it, the insurance? i will take you to it. if we could _ call it, the insurance? i will take you to it. if we could go - call it, the insurance? i will take you to it. if we could go to i call it, the insurance? i will take you to it. if we could go to pol, | you to it. if we could go to pol, 001. _ you to it. if we could go to pol, 00i. 457, — you to it. if we could go to pol, 001,457,156, you to it. if we could go to pol, 001, 457, 156, please. you to it. if we could go to pol, 001,457,156, please. i'm going to ask you _ 001,457,156, please. i'm going to ask you to— 001,457,156, please. i'm going to ask you to look at some correspondence between charles cahoon _ correspondence between charles cahoon and this is a page numbering doddie _ cahoon and this is a page numbering doddle also andrew parsons —— numbering _ doddle also andrew parsons —— numbering four of six, this also includes —

numbering four of six, this also includes andrew parsons, and it says they have _ includes andrew parsons, and it says they have worked out the attached version _ they have worked out the attached version which has not been sent, any comments~ — version which has not been sent, any comments... up a little bit. andy, could _ comments... up a little bit. andy, could you — comments... up a little bit. andy, could you have a look at the draft letter _ could you have a look at the draft letter regarding the horizon issue? i letter regarding the horizon issue? i have _ letter regarding the horizon issue? i have not— letter regarding the horizon issue? i have not looked at it, thanks, susan — i have not looked at it, thanks, susan. then we have mr parsons, the 24th of— susan. then we have mr parsons, the 24th ofjuiy. _ susan. then we have mr parsons, the 24th ofjuly, 2013, at 651 in the evening — 24th ofjuly, 2013, at 651 in the evening, the letter does nothing more _ evening, the letter does nothing more than put the insurers on notice of the _ more than put the insurers on notice of the horizon issues. it is very bland _ of the horizon issues. it is very bland and — of the horizon issues. it is very bland and my only hesitation is whether— bland and my only hesitation is whether this is strictly necessary to do— whether this is strictly necessary to do from — whether this is strictly necessary to do from a pr perspective, because it would _ to do from a pr perspective, because it would look bad of this got into the public— it would look bad of this got into the public domain. sign of guilt, oblique — the public domain. sign of guilt, oblique concern from the board. i would _ oblique concern from the board. i would be — oblique concern from the board. i would be happy to have one of our insurance — would be happy to have one of our insurance employers look at this, look over—

insurance employers look at this, look over the policy, directors and officers _ look over the policy, directors and officers policy to see if pol is required _ officers policy to see if pol is required to notify the insurers. if not _ required to notify the insurers. if not. we — required to notify the insurers. if not, we might want to hold fire on this _ not, we might want to hold fire on this i_ not, we might want to hold fire on this i would — not, we might want to hold fire on this. iwould recommend not, we might want to hold fire on this. i would recommend tweaking the first paragraph, current versions suggest — first paragraph, current versions suggest there are problems with horizon. — suggest there are problems with horizon, when at present there are no systemic— horizon, when at present there are no systemic problems to report. it should _ no systemic problems to report. it should iust — no systemic problems to report. it should just say that the press have reported _ should just say that the press have reported on potential issues with horizon — reported on potential issues with horizon rather than financial discrepancies have occurred in horizon — and if we could go to page one of the internal numbering, and we can see again. — the internal numbering, and we can see again, this time on the 29th of july. _ see again, this time on the 29th of july, further e—mail from mr parsons, _ july, further e—mail from mr parsons, and a bullet point summary at the _ parsons, and a bullet point summary at the top. _ parsons, and a bullet point summary at the top, six bullet points. would you be _ at the top, six bullet points. would you be kind — at the top, six bullet points. would you be kind enough to read those six bullet _ you be kind enough to read those six bullet points to yourself, mr bates?

yes. do you see anything in there which ou yes. do you see anything in there which you consider— yes. do you see anything in there which you consider to _ yes. do you see anything in there which you consider to be - yes. do you see anything in there i which you consider to be symptomatic of the _ which you consider to be symptomatic of the post _ which you consider to be symptomatic of the post office's habitual problem with disclosure? certainly, the fifth bullet — problem with disclosure? certainly, the fifth bullet point, _ problem with disclosure? certainly, the fifth bullet point, the _ problem with disclosure? certainly, the fifth bullet point, the fourth i the fifth bullet point, the fourth and fifth, the risk of notification looks bad for pol if it became public knowledge that pol had notified its insurer to reduce —— and to reduce its risk it is recommended that rather than sending a formal written notification, jfsa speaks to charter wrists and verbally notifies them so as not to leave a paper trail —— pol speaks

to. they may be prepared to accept a verbal notification. 5a it to. they may be prepared to accept a verbal notification.— verbal notification. so it is about -lausible verbal notification. so it is about plausible deniability _ verbal notification. so it is about plausible deniability over- verbal notification. so it is about plausible deniability over the i verbal notification. so it is about i plausible deniability over the issue since _ plausible deniability over the issue since there is not anything written down? _ since there is not anything written down? no — since there is not anything written down? ., , ., no since there is not anything written down?_ no paperl down? no paper trail. no paper trail. down? no paper trail. no paper trail- could _ down? no paper trail. no paper trail. could i— down? no paper trail. no paper trail. could i now, _ down? no paper trail. no paper trail. could i now, this - down? no paper trail. no paper trail. could i now, this is- down? no paper trail. no paper trail. could i now, this is my i down? no paper trail. no paper. trail. could i now, this is my final topic, _ trail. could i now, this is my final topic, ask— trail. could i now, this is my final topic, ask you a few questions about the litigation that bears your name, and i— the litigation that bears your name, and i realise that you have already been _ and i realise that you have already been asked some questions on this but i been asked some questions on this but i want — been asked some questions on this but i want you to consider whether the no _ but i want you to consider whether the no holds barred approach adopted by the _ the no holds barred approach adopted by the post office may not have been motivated _ by the post office may not have been motivated simply to win at all costs to defeat _ motivated simply to win at all costs to defeat you and your fellow claimants, but to kill the prospects of any— claimants, but to kill the prospects of any future criminal appeals that rested _ of any future criminal appeals that rested on — of any future criminal appeals that rested on the outcome of your litigation? have you formed a view,

bearing _ litigation? have you formed a view, bearing in— litigation? have you formed a view, bearing in mind all that has passed, have you _ bearing in mind all that has passed, have you formed a view that the conduct — have you formed a view that the conduct of— have you formed a view that the conduct of the way in which they approached the horizon issues and the issues — approached the horizon issues and the issuesjudgment, may in part have _ the issuesjudgment, may in part have been— the issuesjudgment, may in part have been influenced by the fact that rather thanjust being that rather than just being concerned that rather thanjust being concerned about losing a money claim, _ concerned about losing a money claim, they were also concerned that if they— claim, they were also concerned that if they last _ claim, they were also concerned that if they last that money claim that you had _ if they last that money claim that you had brought against them, —— they had _ you had brought against them, —— they had lost that money claim, that you had _ they had lost that money claim, that you had brought against them, they would _ you had brought against them, they would be _ you had brought against them, they would be exposed to potential criminal— would be exposed to potential criminal appeals from people who had been wrongly prosecuted, some of whom _ been wrongly prosecuted, some of whom, of— been wrongly prosecuted, some of whom, of course, had been wrongly imprisoned? — whom, of course, had been wrongly imprisoned? have you formed any of about— imprisoned? have you formed any of about that? — the one i'm quite certain they were very concerned and a whole number of fronts and certainly that would have been one of them. and the other one

would have been protecting the brand at any cost, i think that was a key one. and protecting the roles of those involved in making the decisions over the years that they took so wrongly. i think there is a whole batch of reasons they went ahead with it. i had a comment that was meant to have come from the board at that time that it should be buried at any cost, this court case, and i think we saw that, then trying to do that along the way. so i have no doubt that they were desperate to get rid of it for a whole raft of reasons. �* .. get rid of it for a whole raft of reasons. ~ ., ., . reasons. and that would include those criminal— reasons. and that would include those criminal appeals - reasons. and that would include those criminal appeals which i reasons. and that would include i those criminal appeals which rested on the outcome?— those criminal appeals which rested on the outcome? absolutely and that the had on the outcome? absolutely and that they had known _ on the outcome? absolutely and that they had known they _ on the outcome? absolutely and that they had known they were _ on the outcome? absolutely and that they had known they were wrong i on the outcome? absolutely and that they had known they were wrong for. they had known they were wrong for many years. they had known they were wrong for many years-— many years. thank you, mr alan bates. i suppose _

many years. thank you, mr alan bates. i suppose following i many years. thank you, mr alan bates. i suppose following mr. many years. thank you, mr alan i bates. i suppose following mr henry,