FUJ00124337 - Comments on Defence Expert’s Report by Gareth Jenkins - R v Khayyam Ishaq.
FUJ00124337
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Comments on Defence Expert’s Report
Ref: g:\ locuments\poa\prosecution support\ishaq\beverley\comments.defencereport.docx.
Author: Gareth I Jenkins
Date: 25/02/2013 21:22:00
1. Introduction
Here are my comments on the Defence Expert’s Report.
I’ve reproduced the report in Section 2 and coloured it blue added in my comments in
Black.
Sorry it isn’t very tidy, but I’m short of time.
2. Report
Regina -v- Khayyam Ishaq
Expert Report of Beverley
Ibbotson
22 February 2013
Prepared by:
Beverley Ibbotson
Position and firm:
Forensic Accounting Director
PKF (UK) LLP
31a Floor
10 South Parade
Leeds
LS1 5QS
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Contents
1 Introduction .
2 Background .
3 Findings ...
4 Summary and conclusions .
5 Expertis Declaration .
Appendices
A Curriculum Vitae
B List of documents relied upon
C Copies of the Prosecution Exhibits SB/3 to SB/10; SB/21 & SB/23
D1 Reversals of sales, from Horizon data, for November 2010, by date order,
user identity order and in detail showing product descriptions
D2 Reversals of sales, from Horizon data, for December 2010, by date order,
user identity order and in detail showing product descriptions
D3 Reversals of sales, from Horizon data, for January 2011, by date order,
user identity order and in detail showing product descriptions
D4 Reversals of sales, from Horizon data, for February 2011, by date order,
user identity order and in detail showing product descriptions
E1 Sales and reversals of sheets of stamps November 2010
E2 Sales and reversals of sheets of stamps December 2010
E3 Sales and reversals of sheets of stamps January 2011
F1 Sheet stamp purchases/stock inwards 14 October 2010 to 9 November
2010
F2 Sheet stamp purchases/stock inwards 10 November 2010 to 10 December
2010
F3 Sheet stamp purchases/stock inwards 11 December 2010 to 10 January
2011
F4 Sheet stamp purchases/stock inwards 11 January 2011 to 9 February
2011
G1 Comparison of exhibits SB/3, SB/4 & SB/6
G2 Stock roll forward of product codes 2463; 2464; 20274; & 20275 (sheets of
stamps)
G3 Summary of reversals
Brews
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1 Introduction
The writer
4.1 My name is Beverley Ibbotson. I am a Chartered Accountant and a Director in PKF (UK)
LLPis forensic services practice. My experience spans audit work, fraud investigations,
reconstruction of accounts and the preparation of expert accounting evidence. Further
details of my qualifications and experience are set out at Appendix A.
Summary of the case
1.2 Mr Khayyam Ishaq (iMr Ishaqi or the iDefendanti) has been charged with a single count
of theft of £21,168.64 from the Post Office Ltd.
1.3 Mr Ishaq has pleaded not guilty to the charge.
My instructions
1.4 I am instructed by Musa Patels solicitors, on behalf of Mr Ishaq, to prepare an expert
accountancy report. My instructions are as follows:
a) to consider whether the factual contentions raised by the Prosecution are correct;
b) whether there has been any double or multiple accounting of monies and/or stock;
c) prepare a report considering:
i) the Prosecution material and defence material (including the Defendantis
instructions)
ii) the full business documents (if any supplied) by the Defendant
ili) the Defendantis full and comprehensive signed instructions as to all issues
raised by the Prosecutoris case summary
d) the report to establish a full and documented audit trail in respect of all issues of
relevance to the case and the prosecution assertions.
e) the report to comment upon the methodology used by the Prosecution; the findings
and conclusion of the Prosecution, the interpretation and significance of those findings
and alternative interpretation(s) to be placed on those findings.
Other matters
1.5 I have not, unless specified, attempted to obtain independent verification of the financial
information referred to in this report.
1.6 This report should not be construed as expressing any opinions on matters of law.
1.7 My report is confined to a consideration of matters of accountancy expertise. Where it is
necessary to refer to matters outside my experience, I draw attention to such matters but
offer no opinion on them.
1.8 This report has been prepared for the Court solely for the purpose set out above. It may
not be used for any other purpose, reproduced or disclosed to any other party in whole or in
part without my prior written consent.
1.9 I have consulted with and have been assisted by PKF personnel in the preparation of this
report. I have supervised such work carried out on my behalf and I confirm that the views
and opinions expressed herein are my own.
1.10 I understand that my duty in providing this report is to the Court and this report is
addressed to the Court and not to those instructing me.
1.11 In accordance with Part 33 of the Criminal Procedure Rules and the Practice Direction
supplementing it, I set out my expertis declaration at the conclusion of the body of this report.
1.12 I reserve the right to amend my conclusions if further information is made available to
me.
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2 Background
2.1 The Defendant was the sub postmaster at Birkenshaw Post Office. On 8 February 2011
the Network Support Field Team (iNSFTIi) visited the Birkenshaw Post Office to undertake a
check of the cash. A count took place and the Prosecution say a shortage of £536 was
noted. A ibalance snapshot exercise1i was then undertaken in which the shortfall was noted
as being £2,569.19 (Exhibit SB/3).
1 This term is not defined by the Prosecution in the Exhibits or witness statements but is understood to refer to a print
out from the computerised system, at a particular time isnapshott of the balances of stock and cash held based on
previously agreed records and trading since the last branch trading statement
This £2,569.19 is the cumulative set of discrepancies from BP rollovers during the current TP
Mainly Cash but also some Stamps and Currency at BP rollovers during the TP. NB small amount positive.
There seem to be Cash Discrepancies every Balance Period ~ mostly > £1,000. NB a few are Excess Cash!
Stamp and Currency Discrepancies tend to be <£20, Max of £112 for stamps.
2.2 AiTier 221 audit was subsequently carried out which revealed, say the Crown, a shortage
of £21,168.64. Mr Ishaq was suspended at 12.45pm on 8 February 2011.
2 This term is similarly not defined but is understood to refer to a comprehensive audit and full stock and
cash/cheques count for the branch.
2.3 A repeat balance snapshot exercise was carried out on 11 February 2011, 3 days after
the Defendant had been suspended, at which time the shortfall was identified as being
£21,213.79 (Exhibit SB/5).
These are clearly different but I can’t explain the differences at this point.
Difference is £45.15
2.4 An internal Post Office email from Mr Dennis Watson (Exhibit DW/1), dated 11 February
2011 states that the shortage identified by the audit was made up of a positive discrepancy
in stock of £12.90 and a negative discrepancy iper office snapshoti of £21,181.54, equating
to a net difference of £21,168.64 (£21,181.54 - £12.90). No further explanation has been
provided as to how this total has been arrived at, or why the sum differs from that stated at
Exhibits SB/3 and SB/5.
SB/3 is the Balance Snapshot at the start of the audit. It doesn’t include the value of the missing stock.
Following the stock take, adjustments were made (SB/4) that effectively converted missing (and excess) stock
into cash equivalents. It is at this point the figure increases significantly.
NB my analysis show that there were other adjustments not included in SB/4. However SB/4 does cover the
most significant ones (see later comments).
2.5 The Post Office computer system is known as Horizon. In the Prosecutionis case
summary it is stated that there has been an investigation (by the Post Office) into reversals of
sales of large quantities of stamps at the Birkenshaw Post Office
2.6 The Prosecution assert that Mr Ishaq inflated the stock figures at the branch to cover the
cash discrepancy and that he falsified the branch accounts having stolen funds which
belonged to the Post Office Ltd.
2.7 The Prosecution allege that based upon Horizon data for the period 2 November 2010 to
31 January 2011, the following large quantities of stocks of stamps were sold and then the
sales reversed:
Exhibit SB/21 Sales Reversals__I Difference:
Sheets of 50 x Taclass large stamps 465.00__[ 4,290.00 4,125.00
Sheets of 50 x 2n class large stamps 535.50 _I 4,080.00 3,544.50
Sheets of 100 self adhesive first class stamps. 4,271.00 I 6,068.00 4,797.00
Sheets of 100 self adhesive second class stamps I 864.00 I 3,200.00 2,336.00
2,835.50 I 17,638.00 14,802.50
3 Differences are explained in the witness statement of Stephen Brayshaw 19 June 2072, but are the net between
sales made and sales reversed.
Tassume she means Bradshaw.
2.8 The Prosecution allege that other than on 24 Ni
transactions were conducted by user Ki or Ki
mber 2010, all of the above reversal
2, which they state was Mr Ishaqis
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user name on the Horizon computer system. Exhibit SB/21 (attached within Appendix C for
ease of reference), shows a summary of the reversals made, including the dates and
computer user identities.
Thave confirmed this and the values in the table above.
2.9 The 24 November 2010 transactions are stated as having been carried out by user
identity ULisroi4, which is stated as belonging to Mr Umair Liaqat.
2.10 In his witness statement dated 24 June 2011, Mr Liaqat states:
a) He has worked at Birkenshaw Post Office from 2009 (in the shop) and then from August
2010 in the Post Office counters, serving customers;
b) He works Monday to Friday 9.00am to 5.30am with no break for lunch;
c) He worked on counter position 1;
d) He had his own login and password, both of which were given to him by the post master
(i.e. the Defendant);
e) He advised the postmaster of his password fi i.e. he shared it / made it known.
) He participated in the counting of stocks of coins and stamp books, but only the post
master counted the safe contents;
g) He was never present when the balancing figures were reached at the end of each day;
h) He was never made aware of any discrepancies.
2.11 The witness statement of Kathleen Smith, a Network Field Support Advisor (iFSAj), with
the Post Office Ltd, dated 8 May 2012, states that she attended Birkenshaw Post Office on 8
February 2011 (with fellow FSA Mr Dennis Watson) and carried out an audit, which she
states revealed imajor discrepancies in the stock of 100 x first and second class stamps self
adhesive sheets and the 50 x first and second class stamps self adhesive sheetsi.
2.12 Ms Smith states that the audit iidentified overall deficit in the accounts of £21,168.64i.
2.13 The Prosecution allege that the Defendant inflated the stock figures for stamps, in order
to balance the cash deficiencies which had arisen. The Prosecution thereby infer that the
cash shortages were as a result of theft on the part of the Mr Ishaq of monies belonging to the
Post Office Ltd.
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3 Findings
3.1 I have been provided with exhibits DW/1, SB/1 to SB/10, SB/13 to SB16, SB/19 to SB21
and SB/23. I have attached copies of the Exhibits marked as SB at Appendix C for ease of
reference. I have also been provided with electronic copies of Horizon data for the period 1
November 2010 to 31 January 2011.
This was one ARQ. [also have a separate ARQ with Data from 9/9/10 to 9/2/11
In fact I think Beverley has the same data as me from her analysis.
Agreed
Agreed
3.2 I have reviewed and reanalysed the exhibited material and have noted the following:
Stock per isnapshoti and stock adjustments (SB/3 and SB/4)
3.3 Exhibit SB/3 is the isnapshot figuresi taken from the Horizon system at 08.50 on 8
February
2011, when Mr Watson arrived to carry out the audit. The snapshot comprises a printout of
stock on hand at the branch by type and by volume according to Horizon, for example the
first item reads Euro TChq fi Euro travellersi cheques fi and the number according to the
computerised records shows stock levels of 300. At the side of this figure is a hand written
annotation of either a mark to indicate agreement (a tick) or the actual number or difference
if there is one.
3.4 Instructing solicitors have confirmed that the photocopy provided to me of SB/3 is as it
was served and that the hand written annotations were already on the exhibit. As such I have
assumed that the handwriting is that of the branch auditor(s), who undertook the stock count
on 8 February 2011 having printed out the isnapshoti.
3.5 On Exhibit SB/3 the hand written figures for stock are inconsistently written. For example
for stocks of stamp cards the actual stock is written in the second column of hand written
figures as 298 and the difference from Horizon of 1 (Horizon stock being 299) is written in the
first column. On the next idiscrepancyi down the list the first column reads /-1200i for ist
class stmpi with no difference attributed, yet Horizon shows the stock should be 1499.
3.6 This may simply be a recording error as on SB/4 the adjustment to stock has been written
as 299 1sclass stamps @ 0.41 each - £122.59. The correct layout of a stock taking record
should be consistent between items, to avoid potential confusion and errors in recording.
3.7 On the next item on the list i1s: class /argei the Horizon stock is 920 with a figure of i-97
next to it and then 19117 thereafter. This suggests the actual stock was 911 a difference of 9
items; however the presentation is different to the item immediately above.
3.8 A number of items (MVL discs, bus day rover adv, air letter single, special 97p) are
recorded in a different style from paragraphs 3.5 and 3.7 above in that the actual stock
counted is not recorded just the positive difference (i.e. that more stock is held than the
Horizon system shows). Again, it is usual and best practice when stock taking to record all
items counted in a consistent manner to avoid inaccuracies.
3.9 Notwithstanding the recording style, I note that these stock lines where more stock is held
than there should have been have not been adjusted for on SB/4 fi thereby overstating the
stock difference figure (these items should be valued and credit given).
Looking at the logs there were a number of adjustments. SB/4 is only on of them.
They appear to have been done as a number of “sales” and reversals. I can see Reversals forfirst 3 and then a
further 9 items which I think may explain these oddities.
There are also discrepancies to Prod 21 (Other stamps)
3.10 A similar item (postal orders) is also recorded again in a different style from paragraphs
3.5 and 3.7 above in that the actual stock counted is not recorded, just the negative difference
(i.e. that less stock is held than the Horizon system shows). Again, it is usual and best
practice when stock taking to record all items counted in a consistent manner to reduce
inaccuracies.
Tagree it is messy, but is it relevant?
POs have zero value even when sold so are handled differently.
Stock per Tier2 audit stock check and subsequent stock
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adjustments (SB/6 and SB/4)
3.11 I have reviewed the stock record served as Exhibit SB/6, which is signed by both Mr
Dennis Watson and Ms Kath Smith who carried out the full audit on 8 February 2011.
3.12 I have summarised, at Appendix G1, the stock figures on a stock line by line basis,
between the stock on hand according to the snapshot (Exhibit SB/3) and the hand written
stock count under taken during the Tier 2 audit, the results of which are shown on Exhibit
SB/6.
3.13 For ease of reference I have colour coded various apparent anomalies and make the
following observations:
3.14 A number of stock lines have not been included in the Tier 2 stock check. These are
shaded beige on Appendix G1. No explanation has been provided in the Prosecution witness
statements of Mr Watson & Ms Smith to explain why they did not carry out a complete stock
count during the course of what is described as a full audit at the branch.
T can’t answer this one.
3.15 Furthermore, despite not undertaking a physical stock count (per SB/6), adjustments
have been made on SB/4 for apparent stock discrepancies. These items are shaded in pink at
Appendix G1.
T can’t answer this. However values are trivial.
3.16 As previously stated (paragraph 3.9 above) where physical stock on hand exceeded that
shown on the Horizon records, adjustments have not been made at Exhibit SB/6 to reflect the
positive discrepancies. These are shown in yellow at Appendix G1.
T can’t answer this one, but again values are trivial.
3.17 At Appendix G1, I have shown in red the negative differences (i.e. stock shortages)
between the physical stock quantities at the branch on 8 February 2011, when compared to
stock quantities according to the Horizon records. The most significant discrepancies (in
terms of number of items and value) are in stocks of 1stclass stamps, and sheets of stamps
(shaded in green at Appendix G1). These discrepancies are considered in more detail, from
paragraphs 3.18 onwards below.
I think these are covered in SB/6?
Marks on SB/3 look like dashes rather than ticks?
Horizon data (SB/7 to SB/10)
3.18 Exhibits SB/7 to SB/10 consists of copies of the branch trading statements, for
Birkenshaw
Post Office, for the following periods:
Period Exhibit
15/09/10 to 13/10/10 SBI7
13/10/10 to 17/11/10 SB/B
17/11/10 to 15/12/10 SB/9
15/12/10 to 12/01/11 SB/10
3.19 I have summarised, at Appendix G2, the stock figures according to the branch trading
statements as exhibited above, for the four trading periods immediately prior to 8 February
2011. I have also summarised the stock figures as shown on 8 February 2011 from the
snapshot (Exhibit SB/6) and the stock on 11 February 2011 when the branch hand over took
place (Exhibit SB/5).
3.20 Using the starting stock positions on 13 October 2010 and following only the main four
stock lines where the apparent discrepancies were noted at the branch audit (shown in green
at Appendix G111), I have carried out an analysis of the stock movements, which includes the
four trading periods above and a further period from 13 January 2011 up to and including the
branch audit visit.
11 Self adhesive 1aclass stamps in sheets of 100 (product code 2463); self adhesive 2nclass stamps in sheets of
100 (product code 2464); sheets of 50 x 1«class large (product code 20274); & sheets of 50 x 2nsclass large (product
code 20275).
3.21 I have limited my analysis to the following four stock lines, as these concern the largest
volume of alleged discrepancies and also allow a direct comparison of my results with the
analysis carried out by the Prosecution, in their Exhibit SB/23.
3.22 I have obtained the data for sales of sheet stamps from the Horizon spread sheets
provided to me and my summary analysis is set out for each separate period at Appendix E1.
Thave done some checking on this.
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See comments below.
3.23 I have obtained the data for purchases of sheet stamps from the Horizon spread sheets
provided to me and my summary analysis is set out for each separate period at Appendix
F1.
3.24 In doing so, I have taken account of sales and purchases of sheets of stamps only and
show, at Appendix G2, what the stock holdings should have been as at 8 February 2011,
which may be summarised as follows:
Stock type Sheets of
Self
adhesive
2na class
stamps
Sheets of
50 x 2na
class
large
stamps
Sheets of
Self
adhesive 1s
class
stamps
Sheets of
50x 431
class large
stamps
Product code 2464 20275 2463 20274
Period 4 (13.10.10)
Opening stock 137 110 82 99
Purchases 100 30 80 Nil
Sales (15) (1) (10) (6)
Closing stock 222 139 152 93
Closing stock per Branch Trading
Statement
252 139 152 93
Unexplained difference 30 nil nil nif
Period 2 (17.11.10)
Opening stock 252 139 152 93
Purchases Nil Nil Nil Nil
Sales (11) (20) (9) (1)
Closing stock 241 119 143 92
Closing stock per Branch Trading
Statement
290 279 271 122
Unexplained difference 49 160 128 30
Period 3 (15.12.10)
Opening stock 290 279 271 122
Purchases 100 Nil Nil Nil
Sales (2) Nil (7) Nil
Closing stock 388 279 264 122
Closing stock per Branch Trading
Statement
407 278 283 222
Unexplained difference 19 (1) 19 100
Period 4 (12.01.11)
Opening stock 407 278 283 222
Purchases Nil Nil Nil Nil
Sales (115) (162) (159) (131)
Closing stock 292 116 12491
Closing stock per iSnapshoti 395 277 274 221
Unexplained difference 103 (161) 150 130
T’ve gone through the first column (Prod 2464) and can see where the problem lies. Beverley has taken the
figures from the BTS as Opening Figures from the period when in fact they are Closing figures. By adjusting so
that there is the correct initial figure, then it all matches.
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I may come back and check the other columns if I have time, but I assume they have a similar issue.
3.25 As the analysis above and at Appendix G2 demonstrates, the stock movements
according to Horizon data (opening stock + purchases - sales = closing stock), produces
stock levels, for sheet stamps which for all periods except period 1, are significantly below the
stock levels declared on the branch trading statement (see the figures highlighted at
paragraph 3.24 as iunexplained differencei).
I think I have explained this above.
3.26 The closing balances produced by the Horizon data as shown in yellow at Appendix G2,
closely correlate with the actual stock levels as counted during both the Tier2 audit and on
hand over of the branch on 11 February 2011. The stock levels are however significantly
lower than those shown on the snapshot (Exhibit SB/3).
Yes. This is because the figures had been artificially inflated by the false reversals in SB/3. This had been
corrected by the auditors to get the actual figures in SB/6
3.27 It is the Crownis case that in order to balance the trading statements, the Defendant
carried out false entries to inflate the stock levels above what they in reality were, thereby
disguising the fact that the corresponding cash balances had been misappropriated. In other
word replacing the missing cash asset in the balance sheet (of the trading statements) with a
stock asset.
I believe it is, and the evidence in the logs seems to show that.
Reversals
3.28 As stated at paragraph 2.7 above, the Prosecution allege that the stock differentials were
achieved by reversing out sales of stamps over and above those sold. The Prosecution also
allege that other than on 24 November 2010, all of the reversal transactions were conducted
by user KE‘ 2, which they state was Mr Ishaqis user name on the Horizon
computer system. °
3.29 I have summarised, at Appendix G3, all reversals between 9 September 2010 (start of
branch trading statement period 1) and 8 February 2011, which I have further sub
categorised by user ID and by product code. As my analysis shows of the 248 reversal over
the period, 14 were made by Mr Dennis Watson, following the audit on 8 February 2011, 173
were carried out under the user names associated with Mr Ishaq and 61 reversals were
carried under the user name associated with Mr Liaqat.
T’ve also looked for all reversals and came up with 248 items (like Beverley). However if you look for those for
the 4 “inflated” products (2463, 2464, 20274 or 20275), then the statement becomes true. I assume that is what
‘was meant in that the investigators only looked at reversals for those products.
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4 Summary and conclusions
4.1 I have been instructed to:
4.2 Consider whether the factual contentions raised by the Prosecution are correct. I have
noted a number of apparent discrepancies in the stock take which I have commented upon at
paragraphs 3.5 to 3.10 above.
4.3 State whether there has been any double or multiple accounting of monies and/or stock.
My analysis of the stock movements suggests that the Horizon data, for the four stock lines.
concentrated upon was accurate, but the balance snapshot, taken on 8 February 2011, was
not. The Crown state this difference is due to inflation of stock on the snapshot to balance
cash misappropriated.
I don’t understand this.
4.4 Prepare a report considering:
a) the Prosecution material and defence material (including the Defendantis instructions).
My findings in this respect are set out at Section 3 above.
b) the full business documents (if any supplied) by the Defendant. I have not been
provided with any such documents, and as such can make no further comment in this
respect.
c) the Defendantis full and comprehensive signed instructions as to all issues raised by
the Prosecutoris case summary. I have not been provided with any such documents,
and as such can make no further comment in this respect.
4.5 I am instructed to prepare a report establishing a full and documented audit trail in respect
of all issues of relevance to the case and the prosecution assertions. In this respect see my
findings at Section 3 above.
4.6 My report was to comment upon the methodology used by the Prosecution; the findings
and conclusion of the Prosecution, the interpretation and significance of those findings and
alternative interpretation(s) to be placed on those findings. In this respect see my findings at
Section 3 above.
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5 Expertis Declaration
5.1 I, Beverley Ibbotson, declare that:
5.2 I understand that my duty is to help the Court to achieve the overriding objective by giving
independent assistance by way of objective, unbiased opinion on matters within my
expertise, both in preparing reports and giving oral evidence. I understand that this duty
overrides any obligation to the party by whom I am engaged or the person who has paid or is
liable to pay me. I confirm that I have complied with and will continue to comply with that
duty.
5.3 I confirm that I have not entered into any arrangement where the amount or payment of
my fees is in any way dependent on the outcome of the case.
5.4 I know of no conflict of interest of any kind, other than any which I have disclosed in my
report.
5.5 I do not consider that any interest which I have disclosed affects my suitability as an
expert witness on any issues on which I have given evidence.
5.6 I will advise the party by whom I am instructed if, between the date of my report and the
trial, there are any changes in circumstances which affect my answers to points 5.3 and 5.4
above.
5.7 I have shown the sources of all information I have used. I enclose as Appendix B to my
report a schedule of documents on which I have relied.
5.8 I have exercised reasonable care and skill in order to be accurate and complete in
preparing this report.
5.9 I have endeavoured to include in my report those matters of which I have knowledge or of
which I have been made aware that might adversely affect the validity of my opinion. I have
clearly stated any qualifications to my opinion.
§.10 I have not without forming an independent view included or excluded anything which has
been suggested to me by others, including my instructing lawyers. In carrying out my
instructions I have been assisted by colleagues in PKF. It would not have been practical or
efficient to carry out all the detailed work involved without assistance. I have reviewed and
discussed with them the work which they have performed under my direction in accordance
with the quality control standards imposed by my firm. For the purposes of this report, I refer
to all of PKFis work as if performed by myself.
5.11 I will notify those instructing me immediately and confirm in writing if for any reason my
existing report requires any correction or qualification.
5.12
5.13 I understand that:
a) my report, subject to any corrections before swearing as to its correctness, will form the
evidence to be given under oath or affirmation;
b) the Court may at any stage direct a discussion to take place between experts;
c) the Court may direct that, following a discussion between the experts, a statement should
be prepared showing those issues which are agreed and those issues which are not agreed,
together with a summary of the reasons for disagreeing;
d) I may be required to attend Court to be cross-examined on my report by a cross-examiner
assisted by an expert;
e) I am likely to be the subject of public adverse criticism by the judge if the Court concludes
that I have not taken reasonable care in trying to meet the standards set out above
f) I have read Part 33 of the Criminal Procedure Rules and I have complied with its
requirements.
g) I confirm that I have acted in accordance with the Code of Practice for Experts.
Statement of truth
5.14 I confirm that the contents of this report are true to the best of my knowledge and belief
and that I make this report knowing that, if it is tendered in evidence, I would be liable to
prosecution if I have wilfully stated anything which I know to be false or that I do not believe
to be true.
Signed .. .. Date 22 February 2013.
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Appendix A
Curriculum vitae of Beverley Ibbotson
Position Director in PKF Forensic Services.
Background
Over 20 yearsi accountancy experience, the last 16 of which has been spent solely working
as a specialist forensic accountant. A Fellow of the Institute of Chartered Accountants in
England and Wales, having a breadth of experience in criminal defence, fraud investigation,
expert witness, and advisory work.
Professional Associations
Fellow of the Institute of Chartered Accountants in England and Wales
Education
LLB (Hons) Leeds University 1986 to 1989
Professional History
Dates Company Position
2011 to date PKF Director, Forensic Services Department
2008 - 2011 Bartfields Business Services Senior Manager fi Forensic Services
2002 fi 2008 Forth Associates Senior Associate fi Forensic Services
1998 fi 2000 DTE Senior Manager fi Forensic Services
1996 fi 1998 RSM Tenon Manager fi Forensic Services
1995 fi 1996 Haines Watts Assistant fi Forensic Services
1990 fi 1995 Deloitte Training Contract & Supervisor Audit &
Assurance
Experience
All aspects of forensic accountancy including obtaining discovery of documents, analysis and
preparation of reports to assist the Court in personal, commercial and criminal cases.
Areas of experience include:
Matrimonial disputes
Business interruption claims.
Insurance claims
Fraud investigations
Criminal investigations
POCA proceedings
Professional negligence
Personal injury
Fatal accident
As well as attending conferences with Counsel and discussions with experts with a view to
preparing Joint Statements as directed by the Courts.
Appendix B
List of documents relied upon
! Witness statements of Dennis Watson, Kathleen Smith
! Copies of exhibits SB3 to SB10 and SB/21 and SB/23
I Excel spread sheets of Horizon data, for Birkenshaw Post Office, from September 2010 to 8
February 2011
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