day on the day we were right on the day on the day before, the release of the second site interim report. that is my recollection that that is the media conversation that we were having. what we are talking about here is how far _ what we are talking about here is how far back review of possible miscarriages ofjustice should go. yes, _ miscarriages ofjustice should go. yes. and — miscarriages ofjustice should go. yes. and i— miscarriages ofjustice should go. yes, and i am not... you miscarriages ofjustice should go. yes, and i am not...— miscarriages ofjustice should go. yes, and i am not... you say that is the most — yes, and i am not... you say that is the most urgent, _ yes, and i am not... you say that is the most urgent, the _ yes, and i am not... you say that is the most urgent, the second - yes, and i am not... you say that is the most urgent, the second being | yes, and i am not... you say that is i the most urgent, the second being to manage _ the most urgent, the second being to manage the media. | the most urgent, the second being to manage the media. i am the most urgent, the second being to manage the media.— manage the media. i am pretty sure that was in relation _ manage the media. i am pretty sure that was in relation to _ manage the media. i am pretty sure that was in relation to the _ manage the media. i am pretty sure that was in relation to the interim i that was in relation to the interim report which was you out any time, which, as the inquiry has seen, and herfrom other people, there which, as the inquiry has seen, and her from other people, there were issues in that report which the post office disagreed with the felt second sight hadn't taken account of. that, ithink, was second sight hadn't taken account of. that, i think, was the issue we were talking about. this was a really urgent, today or tomorrow,

issue. then there was the concerns looking forward... m0. issue. then there was the concerns looking forward. . ._ issue. then there was the concerns looking forward... no, no, what you are saying — looking forward... no, no, what you are saying here _ looking forward... no, no, what you are saying here is _ looking forward... no, no, what you are saying here is that _ looking forward... no, no, what you are saying here is that you - looking forward... no, no, what you are saying here is that you are - are saying here is that you are right. — are saying here is that you are right, mark. we will put the past behind _ right, mark. we will put the past behind us — right, mark. we will put the past behind us. we won't look at past cases _ behind us. we won't look at past cases we — behind us. we won't look at past cases. we will focus on the future. that isn't— cases. we will focus on the future. that isn't what happened. that simply isn't the case because the scheme was open to past cases. the burden was put on the sub—postmaster to prove their case, wasn't _ sub—postmaster to prove their case, wasn't it? _ sub-postmaster to prove their case, wasn't it? . . sub-postmaster to prove their case, wasn't it? ,. ., , ., , ., wasn't it? the scheme was open to any postmaster— wasn't it? the scheme was open to any postmaster who _ wasn't it? the scheme was open to any postmaster who wanted - wasn't it? the scheme was open to any postmaster who wanted to - wasn't it? the scheme was open to l any postmaster who wanted to bring their case forwards. it was advertised in various ways to encourage people to come forwards. there were other conversations going on at the same time as this exchange with colleagues. it was very clear

that any cases that included criminal convictions would need to go through the court of appeal in the normal legal roots. i don't think i understood it any more about the legal side of things to have got involved in anything more complex than that. i believed, very sincerely, that the scheme we were putting in place would help. do sincerely, that the scheme we were putting in place would help.- putting in place would help. do you acce -t that putting in place would help. do you accept that this _ putting in place would help. do you accept that this exchange _ putting in place would help. do you accept that this exchange of - putting in place would help. do you | accept that this exchange of e-mails accept that this exchange of e—mails shows_ accept that this exchange of e—mails shows that. — accept that this exchange of e—mails shows that, in making decisions as the substance as to what the post office _ the substance as to what the post office should do, ie whether it itself — office should do, ie whether it itself should seek to review, whether— itself should seek to review, whether there had been passed miscarriages ofjustice, you took into account the views of your media advisor_ into account the views of your media advisor as _ into account the views of your media advisor as to — into account the views of your media advisor as to the extent to which your— advisor as to the extent to which your decision would meet with front—page news? |

your decision would meet with front—page news? i do your decision would meet with front-page news?— your decision would meet with front-page news? i do not recall that... i front-page news? i do not recall that--- i see _ front-page news? i do not recall that... i see what _ front-page news? i do not recall that... i see what is _ front-page news? i do not recall that... i see what is written - front-page news? i do not recall| that... i see what is written here. there were other conversations going on at the same time. the highlighted paragraph isn't as clear as what you are saying. i do not think... i would not have taken, personally, any decision on review of historic cases. that was not my role. i wasn't qualified or competent to do that. i did not take that decision. what i was trying to do at this stage was to find a way forwards for the cases that had come into the post office and to encourage more to come forwards, which would have enabled any case to go through normal legal roots if the post office couldn't help it. so no, i absolutely don't accept that i took absolutely don't accept that i took a decision to not review past criminal cases based on a outcome. i didn't take any decision on that. i

wouldn't have been able to do so, and it would have been such an important decision. that would have had to have gone to the board. can important decision. that would have had to have gone to the board. cami had to have gone to the board. can i 'ust had to have gone to the board. can i just asked. — had to have gone to the board. can i just asked. and _ had to have gone to the board. can i just asked, and this _ had to have gone to the board. can i just asked, and this may _ had to have gone to the board. can i just asked, and this may be entirely my fault— just asked, and this may be entirely my fault 50— just asked, and this may be entirely my fault so i— just asked, and this may be entirely my fault so i preface _ just asked, and this may be entirely my fault so i preface it _ just asked, and this may be entirely my fault so i preface it by— just asked, and this may be entirely my fault so i preface it by that, - my fault so i preface it by that, but i _ my fault so i preface it by that, but i am — my fault so i preface it by that, but i am not _ my fault so i preface it by that, but i am not clear— my fault so i preface it by that, but i am not clear that, - my fault so i preface it by that, but i am not clear that, as- my fault so i preface it by that, but i am not clear that, as of. my fault so i preface it by that, i but i am not clear that, as of the 6th of— but i am not clear that, as of the 6th ofjuiy. — but i am not clear that, as of the 6th mm. or— but i am not clear that, as of the 6th ofjuly, or 7th _ but i am not clear that, as of the 6th ofjuly, or 7th of— but i am not clear that, as of the 6th ofjuly, or 7th ofjuly, - but i am not clear that, as of the 6th ofjuly, or 7th ofjuly, or- but i am not clear that, as of the 6th ofjuly, or 7th ofjuly, or thisi 6th ofjuly, or 7th ofjuly, or this period _ 6th ofjuly, or 7th ofjuly, or this period of— 6th ofjuly, or 7th ofjuly, or this period of time. _ 6th ofjuly, or 7th ofjuly, or this period of time, this _ 6th ofjuly, or 7th ofjuly, or this period of time, this discussion. 6th ofjuly, or 7th ofjuly, or this| period of time, this discussion of how to _ period of time, this discussion of how to approach _ period of time, this discussion of how to approach the _ period of time, this discussion of how to approach the issue - period of time, this discussion of how to approach the issue of- period of time, this discussion of| how to approach the issue of past cases— how to approach the issue of past cases is— how to approach the issue of past cases is taking _ how to approach the issue of past cases is taking place _ how to approach the issue of past cases is taking place in _ how to approach the issue of past cases is taking place in the - how to approach the issue of past i cases is taking place in the context of second _ cases is taking place in the context of second sight— cases is taking place in the context of second sight continuing - cases is taking place in the context of second sight continuing its - of second sight continuing its investigative _ of second sight continuing its investigative work— of second sight continuing its investigative work beyond - of second sight continuing its| investigative work beyond the interim — investigative work beyond the interim report, _ investigative work beyond the interim report, or— investigative work beyond the interim report, or in - investigative work beyond the interim report, or in context. investigative work beyond the l interim report, or in context of investigative work beyond the - interim report, or in context of the idea of— interim report, or in context of the idea of a _ interim report, or in context of the idea of a mediation _ interim report, or in context of the idea of a mediation scheme. - interim report, or in context of the idea of a mediation scheme. do i interim report, or in context of thel idea of a mediation scheme. do you understand — idea of a mediation scheme. do you understand the _ idea of a mediation scheme. do you understand the distinction - idea of a mediation scheme. do you understand the distinction i- idea of a mediation scheme. do you understand the distinction i am - understand the distinction i am trying — understand the distinction i am trying to— understand the distinction i am trying to make? _ understand the distinction i am trying to make? hot— understand the distinction i am trying to make?— understand the distinction i am | trying to make?_ as understand the distinction i am i trying to make?_ as i trying to make? not entirely. as i see it, in simple _

trying to make? not entirely. as i see it, in simple terms, _ trying to make? not entirely. as i see it, in simple terms, second . see it, in simple terms, second sight _ see it, in simple terms, second sight began _ see it, in simple terms, second sight began try— see it, in simple terms, second sight began by investigating - see it, in simple terms, second sight began by investigating inl see it, in simple terms, second i sight began by investigating in the context— sight began by investigating in the context of— sight began by investigating in the context of a — sight began by investigating in the context of a number— sight began by investigating in the context of a number of— sight began by investigating in the context of a number of cases. - sight began by investigating in the| context of a number of cases. yes. after the interim _ context of a number of cases. yes. after the interim report _ context of a number of cases. after the interim report somehow context of a number of cases.“ after the interim report somehow a transition _ after the interim report somehow a transition took— after the interim report somehow a transition took place _ after the interim report somehow a transition took place so, _ after the interim report somehow a transition took place so, what - after the interim report somehow a transition took place so, what i - transition took place so, what i would — transition took place so, what i would call— transition took place so, what i would call a _ transition took place so, what i would call a mediation - transition took place so, what i would call a mediation scheme| would call a mediation scheme emerged _ would calla mediation scheme emerged i_ would call a mediation scheme emerged lam _ would call a mediation scheme emerged. i am not _ would call a mediation scheme emerged. i am not sure, - would call a mediation scheme emerged. i am not sure, as i would call a mediation scheme emerged. i am not sure, as of| would call a mediation scheme - emerged. i am not sure, as of this date. _ emerged. i am not sure, as of this date. at _ emerged. i am not sure, as of this date. at or— emerged. i am not sure, as of this date, at or about _ emerged. i am not sure, as of this date, at or about the _ emerged. i am not sure, as of this date, at or about the time - emerged. i am not sure, as of this date, at or about the time when i date, at or about the time when second — date, at or about the time when second sight— date, at or about the time when second sight was _ date, at or about the time when second sight was to _ date, at or about the time when second sight was to produce - date, at or about the time when second sight was to produce its| second sight was to produce its interim — second sight was to produce its interim report, _ second sight was to produce its interim report, whether- second sight was to produce its interim report, whether the - interim report, whether the discussions _ interim report, whether the discussions of— interim report, whether the discussions of how- interim report, whether the discussions of how to - interim report, whether the discussions of how to deal i interim report, whether the i discussions of how to deal with interim report, whether the - discussions of how to deal with past cases— discussions of how to deal with past cases was— discussions of how to deal with past cases was in— discussions of how to deal with past cases was in context _ discussions of how to deal with past cases was in context simply - discussions of how to deal with past cases was in context simply of - cases was in context simply of second — cases was in context simply of second sight— cases was in context simply of second sight moving - cases was in context simply of second sight moving forward. cases was in context simply of. second sight moving forward with their investigation, _ second sight moving forward with their investigation, or— second sight moving forward with their investigation, or by- second sight moving forward with their investigation, or by that - their investigation, or by that stage. — their investigation, or by that stage. in— their investigation, or by that stage. in the— their investigation, or by that stage, in the post _ their investigation, or by that stage, in the post office's - their investigation, or by that i stage, in the post office's mind, that was— stage, in the post office's mind, that was at— stage, in the post office's mind, that was at an _ stage, in the post office's mind, that was at an end _ stage, in the post office's mind, that was at an end and - stage, in the post office's mind, i that was at an end and something stage, in the post office's mind, - that was at an end and something new was emerging — that was at an end and something new was emerging bio. _ that was at an end and something new was emerging-— was emerging. no, ithink... that is a helful was emerging. no, ithink... that is a helpful question. _ was emerging. no, ithink... that is a helpful question. i— was emerging. no, ithink... that is a helpful question. ithink— was emerging. no, ithink... that is a helpful question. i think there - a helpful question. i think there was a process of evolution. sure, but i was a process of evolution. sure, but i wanted _ was a process of evolution. sure, but i wanted to _ was a process of evolution. sure,

but i wanted to pinpoint... - was a process of evolution. sure, but i wanted to pinpoint... i- was a process of evolution. sure, but i wanted to pinpoint... i am i but i wanted to pinpoint... i am t in: to but i wanted to pinpoint... i am trying to think _ but i wanted to pinpoint... i am trying to think through. - but i wanted to pinpoint...m trying to think through. second sight had done the work it had done up sight had done the work it had done up to the publication of the interim report. there was still a number of cases that hadn't been looked at which needed to be continued. i had been disappointed about the way the post office team hadn't worked as well or been able to contribute to the work second sight had done, and i say that i would like it is to work collaboratively with the jsa which had a serious vested interest in that, and a proposal was made to form a working party, i think, was the word that was used. that was, i recollect, an attempt to work together to go through the remaining cases. at some stage... and as we were going through this, because it was an iterative process, people were contributing ideas as to how this might play out, i had a

conversation... and this i remember clearly because i remember where it was, i had arrived home and i was standing on the station and she called me and susan suggested that a way of bringing... the trouble is i now know what didn't happen, but some of these cases, all these cases to a conclusion, would be to introduce mediation. what she said was that, and again, this is in documentation somewhere, is that mediation, sometimes what was needed is for people to hear the post office apologise and say that it was sorry that it got things wrong, or for the post office to explain to a sub—postmaster that perhaps they had done something wrong, and that, once the cases had been reviewed through this working party process, that might then be a way to reach some

finality in those cases. what was also talked about at the same time was that if this was a good thing to do, which clearly it was, the post office then needed an ongoing process, possibly an adjudication process, possibly an adjudication process, an external ombudsman, on a permanent basis, so that if this type of challenge arose again there was an external appeal process, if you like, for some past two postmasters to go through. and i think i am missing in telling you all of that, is, if susan knew, which of course she did and i wouldn't have known sue well, that criminal cases couldn't be resolved through mediation, and this is simply a question, did she know that they would need to have been a further review or was her understanding at that time, which is a fact that was later described,

there are any criminal case is going through the mediation scheme would be open to all of the investigation work that was done by post office and second sight and fujitsu, which would then give them information to take through the normal legal roots through the court of appeal or the cc rc. ., ., 4' through the court of appeal or the cc rc. ., ., ~ ., ,., ., through the court of appeal or the cc rc. ., ., ~ ., ., ., , cc rc. look at page two of this document- _ cc rc. look at page two of this document. scroll— cc rc. look at page two of this document. scroll down. - cc rc. look at page two of this document. scroll down. this i cc rc. look at page two of this document. scroll down. this isi cc rc. look at page two of this - document. scroll down. this is your thoughts _ document. scroll down. this is your thoughts on — document. scroll down. this is your thoughts on the proposal is at the 6th of— thoughts on the proposal is at the 6th ofjuly. thoughts on the proposal is at the 6th ofjul . . thoughts on the proposal is at the 6th ofjuly. yes. this is a direct answer to _ 6th ofjuly. yes. this is a direct answer to the _ 6th ofjuly. fies this is a direct answer to the chairman's questioned, isn't it— answer to the chairman's questioned, isn't it the _ answer to the chairman's questioned, isn't it the case that second sight were _ isn't it the case that second sight were to _ isn't it the case that second sight were to play no part going forwards. there _ were to play no part going forwards. there were — were to play no part going forwards. there were conversations about whether second sight should or shouldn't because there were concerns about the fact that this had run on too long and was way over budget and this, again, is in many documents. there were concerns that

their work was not, at this stage, sufficiently evidenced based. your - ro osal sufficiently evidenced based. your preposal didn't — sufficiently evidenced based. your proposal didn't involve any role for second _ proposal didn't involve any role for second sites, did it live look at the e-mail_ second sites, did it live look at the e—mail on the screen. your written — the e—mail on the screen. your written proposal did not contain any role for _ written proposal did not contain any role for second sight, did it? i... it doesn't at this stage because we were in this process of evolution... because we were in this process of evolution- - -— evolution... this process of evolution — evolution... this process of evolution that _ evolution... this process of evolution that doesn't - evolution... this process of l evolution that doesn't involve evolution... this process of - evolution that doesn't involve a role for — evolution that doesn't involve a role for second sight. i�*m evolution that doesn't involve a role for second sight.— evolution that doesn't involve a role for second sight. i'm not sure. what it says _ role for second sight. i'm not sure. what it says is _ role for second sight. i'm not sure. what it says is they _ role for second sight. i'm not sure. what it says is they will _ role for second sight. i'm not sure. what it says is they will explore - what it says is they will explore things. i am what it says is they will explore things. iam being what it says is they will explore things. i am being frank with you that there were conversations about whether. .. that there were conversations about whether... there was criticism of

the work that second sight had done but there was equal understanding that they had the support of mps, notably james arbuthnot, and that we had committed to do that work. back to -a~e had committed to do that work. back to page one — had committed to do that work. back to page one please. _ had committed to do that work. back to page one please. you say you are i’i l i'it to page one please. you say you are right to — to page one please. you say you are right to call _ to page one please. you say you are right to call this out. i will take your— right to call this out. i will take your sphere. no issue. do you agree that this _ your sphere. no issue. do you agree that this e—mail chain reads as if the pr_ that this e—mail chain reads as if the pr man _ that this e—mail chain reads as if the pr man has influenced you conclusively as to a decision as to whether— conclusively as to a decision as to whether or— conclusively as to a decision as to whether or not the post office would itself review whether, and to what extent. _ itself review whether, and to what extent, there had been past miscarriages ofjustice? | extent, there had been past miscarriages ofjustice? miscarriages of 'ustice? i wouldn't take that on — miscarriages of 'ustice? i wouldn't take that — miscarriages ofjustice? i wouldn't take that on a legal _ miscarriages ofjustice? i wouldn't take that on a legal matter- miscarriages ofjustice? i wouldn't take that on a legal matter from i take that on a legal matter from mark davies. he clearly... he was

talking about, and again, in the timescales we are talking about, we are talking about publicity within the next couple of days of a report coming out. but i wouldn't have taken a decision on anything at all to do with legal matters from mark davies. i’m to do with legal matters from mark davies. �* ,., to do with legal matters from mark davies. �* , , to do with legal matters from mark davies. �* , ., davies. i'm so sorry, i spoke of ou. davies. i'm so sorry, i spoke of you- let's _ davies. i'm so sorry, i spoke of you- let's see _ davies. i'm so sorry, i spoke of you. let's see what _ davies. i'm so sorry, i spoke of you. let's see what the - davies. i'm so sorry, i spoke of you. let's see what the it - davies. i'm so sorry, i spoke of i you. let's see what the it person was telling — you. let's see what the it person was telling you on what to do about looking _ was telling you on what to do about looking at _ was telling you on what to do about looking at possible miscarriages of justice _ this is a separate chain, remembering that mark davies had 'ust remembering that mark davies had just replied to you. this is leslie

saul's _ just replied to you. this is leslie saul's reply to your e—mail setting out your— saul's reply to your e—mail setting out your proposals. she does include everyone _ out your proposals. she does include everyone on— out your proposals. she does include everyone on the chain and doesn't cut people — everyone on the chain and doesn't cut people out. paula, just a couple of thoughts. if we state we will review — of thoughts. if we state we will review the cases in separation, that implies— review the cases in separation, that implies that there are material findings — implies that there are material findings in this second sight review and leaves us open to challenge against — and leaves us open to challenge against all cases. it may be better to offer. _ against all cases. it may be better to offer. in— against all cases. it may be better to offer, in the spirit of the review. _ to offer, in the spirit of the review, and how we have listened to those _ review, and how we have listened to those affected and how we want to change _ those affected and how we want to change our business. this is the delicate — change our business. this is the delicate line we are balancing and from _ delicate line we are balancing and from memory, susan quoted, more than 500 cases _ from memory, susan quoted, more than 500 cases in _ from memory, susan quoted, more than 500 cases in the last ten years. it may he _ 500 cases in the last ten years. it may he an — 500 cases in the last ten years. it may be an option to allow sub—postmasters to come forward and request— sub—postmasters to come forward and request a _ sub—postmasters to come forward and request a review. i agree on the point _ request a review. i agree on the point about— request a review. i agree on the point about a working group and user

group. _ point about a working group and user group. etc _ point about a working group and user group, etc. did you bring into account. _ group, etc. did you bring into account. in— group, etc. did you bring into account, in your decision—making, the view— account, in your decision—making, the view is — account, in your decision—making, the view is that the head of it was giving _ the view is that the head of it was giving you — the view is that the head of it was giving you on the extent to which the post— giving you on the extent to which the post office should itself ask independent lawyers to review past convictions? i would have read lesley saul�*s e—mail sent to be. i would not have taken any decision on legal matters personally, without the advice of the general counsel and done something this significant is the board. we can see that you have had what the pr expert has been telling you to do about past convictions. and here, the head of it telling

you _ and here, the head of it telling you i_ and here, the head of it telling you. i think your position is that you. i think your position is that you did — you. i think your position is that you did not _ you. i think your position is that you did not see simon clarke's advices. — you did not see simon clarke's advices, which address looking at past convictions, until after the court _ past convictions, until after the court of— past convictions, until after the court of appeal criminal does division — court of appeal criminal does division disclosures in late 2020, early— division disclosures in late 2020, early 2021~ — division disclosures in late 2020, early 2021. is division disclosures in late 2020, early 2021-_ division disclosures in late 2020, early 2021._ yes. i division disclosures in late 2020, | early 2021._ yes. so, early 2021. is that right? yes. so, ou did early 2021. is that right? yes. so, you did rtot _ early 2021. is that right? yes. so, you did not know— early 2021. is that right? yes. so, you did not know that _ early 2021. is that right? yes. so, you did not know that they - early 2021. is that right? yes. so, you did not know that they were i you did not know that they were lawyers — you did not know that they were lawyers advising on the very issues that you _ lawyers advising on the very issues that you were considering at this time. _ that you were considering at this time, bringing into account and pr manand— time, bringing into account and pr manand an— time, bringing into account and pr man and an it lady's views? | time, bringing into account and pr man and an it lady's views? i had no sitht man and an it lady's views? i had no sit ht of man and an it lady's views? i had no sight of the — man and an it lady's views? i had no sight of the simon _ man and an it lady's views? i had no sight of the simon clarke _ man and an it lady's views? i had no sight of the simon clarke advices, i sight of the simon clarke advices, no. ., , y ., sight of the simon clarke advices, no. ., , , ., , , no. you tell us in your witness statement. — no. you tell us in your witness statement, its _ no. you tell us in your witness statement, its paragraph - no. you tell us in your witness statement, its paragraph 562, i no. you tell us in your witness - statement, its paragraph 562, that you recall— statement, its paragraph 562, that you recall that you were told by susan _ you recall that you were told by susan crichton that due to advice

from _ susan crichton that due to advice from external lawyers, there was a