List of Exhibits
THE QUEEN - V — Josephine Hamilton
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COURT IDENTIFICATION
PAGE SHORT DESCRIPTION OF
EXHIBIT MARK RETAINED BY
NUMBER . NUMBERS EXHIBITS IN
' NA/O1 1-2 I Training Requirements For All exhibits retained
Incoming Subpostmasters form by Graham Brander
Post Office Ltd,
14 High St,
Eastleigh,
Hants,
SO50 STA
Qa NA/O2 S- s Photocopy of section 12 of the
Sub postmaster's contract
% I prot A-\& I Fujitsu ARQ 046/0607
PT/02 NX Coprcl Fujitsu CD ROM (ARQ 046/0607) I Not copied .
+ RP/01 if] Outlet Log Entries V
(a AS/01 (2 Schedule detailing audit
discrepancies
AS/02 13 Cash On Hand Summary
t GDB/1 ih Cash On Hand Schedule
q GDB/2 \S—U. I Photocopy of Hamilton prepared
statement
lo GDB/3 {7-1 CS001 Legal Rights form
ay GDB/4 N&k CoprechI Master Tape 042769 Not copied
1a GDB/5 Nu Core cl] Master Tape 042770 Not copied
1 GDB/6 14— QS I Typed summary of working tape
reference 042769
ty GDB/7 2lo — Z& I Typed summary of working tape
reference 042770
* eg. AB/1 etc,
cso12
Version 3.0 14/02
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Dotails of incoming subpostmaster (SPMR)
GRO
ae
To enable us to p
aining, please answer the following questions.
1. OFFICE TYPE Restricted hours [J spso fi = MSPO
Combi format a Community [i
2 Does the Office require training? yes [7 no &
3. Are they willing to undertake classroom training? yes [§ no @
4, Please indicate which NON STANDARD transactions are conducted at the office? Those with
transactions indicated by * will be offered 10 days classroom training by TDT.
4. Is the office relocating and or reopening? yes @ no @
IF YES ~ please ask the Network Implementation and Equipment Team to contact the Training Delivery
‘Team to-discuss a preferred transfer date. 0161.886.6121
or via email:- Training Delivery Team@postoffice.co.uk
5. Has SPMR had any previous Post Office™ experience?
4 Aug 2003
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TRAINING REQUIREMENTS FOR INCOMING SUBPOSTMASTERS, I
1. Have any of the assistants had previous experience? yes @ no @
From To From To
10, _ Are there any other comments or recommendations you wish to make, that may be of benefit to
the training! trainer? Eg whether the office has smoke & dye packs ete
11, Where should the Performance standards, training action plan, and Sales proforma be sent?
Email to Training Delivery Team and cc. SG_IS. ~Agent-Resxuitment_ Support on lotus notes
@Enguiree GRO I 4 Aug 2003 9
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CREDIT STOCK OF STAMPS ETC.
1, The Subpostmaster on taking up his appointment is supplied with suitable Post Office
stock, the amount of which is fixed by the Regional General Manager.
CASH BALANCE
2. The Subpostmaster is permitted to hold Post Office Counters Ltd cash normal to meet
payments at his sub-office after due allowance has been made for expected receipts and _
in accordance with official accounting and security instructions.
3. The Subpostmaster is expressly forbidden to make use of the balance due to Post Office
Counters Ltd for any purpose other than the requirements of the Post Office service;
and he must, on no account apply to his own private use, for however short a period,
any portion of Post Office Counters Ltd funds entrusted to him. He must also be
careful to keep the Post Office money separate from any other monies. Misuse of Post
Office Counters Ltd cash may render the offender liable to prosecution and, or, the
termination of his Contract of Appointment.
ACCOUNTS
4. The Subpostmaster must ensure that accounts of all stock and cash entrusted to him by
Post Office Counters Ltd are kept in the form prescribed by Post Office Counters Ltd.
He must immediately produce these accounts, and the whole of his sub-office cash and
stock for inspection whenever so requested by a person duly authorised by the
Regional General Manager
47 Issue
September 1994
©Copyright reserved 2g
SECURITY OF CASH, STAMPS ETC.
10.
11.
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The Subpostmaster is held strictly responsible for the safe custody of cash, stock of all
kinds and other Post Office Counters Ltd property, papers and documents, whether
held by himself or by his Assistants, and should keep them in a place of security,
especially at night.
The Subpostmaster is responsible for maintaining a standard of security sufficient to
enable him to meet the obligations laid on him by paragraph 5 for the safe keeping of
Post Office Counters Ltd cash and stock placed in his care. If any circumstances arise
which lead him to doubt whether he can do so he should immediately consult the
Regional General Manager.
In deciding the standard of security which it would be reasonable to require under
paragraph 6 Post Office Counters Ltd will have regard to (a) the circumstances in
which the Subpostmaster was appointed, and in particular the standard of security
then accepted; (b) the length of time since his appointment; and (c) any particular
circumstances affecting the sub-office which appear to be relevant. :
All vouchers for payments e.g. Postal Orders, Allowance Dockets etc., should be placed
ina suitable receptacle (cardboard box or strong envelope), labelled “Paid Vouchers”
and at the close of business kept separately from cash and stock in another secure
place, such as a locked drawer or cupboard.
The Subpostmaster must be careful to keep his stocks of all kinds in such a manner that
they remain in good condition. The stocks must be protected against damp and dust.
Datestamps used for authenticating documents (e.g. Postal Orders) or stamping
correspondence must be kept in a position on the counter where they are out of reach
of members of the public. When not needed for work they must be locked away.
Precautions should be taken to guard against the risk of fire.
48 Issue
September 1994
©Copyright reserved
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LOSSES
12. The Subpostmaster is responsible for all losses caused through his own negligence,
carelessness or error, and also for losses of all kinds caused by his Assistants.
Deficiencies due to such losses must be made good without delay.
13. The financial responsibility of the Subpostmaster does not cease when he relinquishes
his appointment and he will be required to make good any losses incurred during his
term of office which may subsequently come to light.
GAINS
14. Surpluses may be withdrawn provided that any subsequent charge up to the amount
withdrawn is made good immediately.
THEFT OR BURGLARY
15. Ifa theft or burglary is committed or attempted at a sub-office, whether or not official
cash or stock is stolen, the facts must be reported at once to the Police and to the
Regional General Manager by the person who first makes the discovery.
MISSING OR STOLEN STOCK
16. If a Subpostmaster considers that any stock items have been accidentally lost, or stolen
he should make a report, in accordance with Appendix 1, as quickly as possible to the
Regional General Manager.
49 Issue
September 1994
©Copyright reserved
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RELIEF
17. COUNTER LOSSES A Subpostmaster may exceptionally not be required to make good
the full amount of certain losses at his office. If he feels entitled to relief in making
good a loss he should apply to the Retail Network Manager.
18. THEFT OR BURGLARY The question of granting relief will depend upon whether the
Subpostmaster has taken reasonable precautions to safeguard the official cash and
property.
19. FRAUD All cases of fraud or attempted fraud should be reported immediately to the
Regional General Manager.
(APPENDIX 1 FOLLOWS)
50 Issue Fa
September 1994
©Copyright reserved lo
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APPENDIX 1
ACCIDENTAL LOSS
If at any time any items of stock (including stock of no intrinsic value such as motor vehicle
licences) is found to be missing. Steps must be taken at once to ascertain what has
happened to the missing items. The serial numbers must be ascertained (see 2(a)) and
verified by examination of items in stock, and the requisition forms examined to
discover whether or not any of the items purport to have been issued out of sequence.
All the requisition forms for the previous 3 months must at the same time be
impounded and held for instructions. If, after careful search, the missing items cannot
be found and are thought to have been mislaid only, or inadvertently destroyed, a
preliminary report of the loss giving the serial numbers of the items in question must
be sent to the Regional General Manager.
STOLEN ITEMS
1. Ifasa result of burglary, break in, theft, or suspected theft any items of stocks are
missing the facts should be reported as quickly as possible to the Regional General
Manager.
2. The further details which will be required, and which should be obtained and
submitted to the Regional General Manager at the earliest opportunity, are as follows:
(a) The denominations, total values and serial numbers of missing or stolen items, so
far as they are known, with serial numbers of any remaining stocks.
(b) A statement as to whether the date stamp of the sub-office has been stolen, and if
SO, particulars of the type in it when stolen. If the date stamp has not been stolen
a statement should be given which should intimate whether there is a reason to
believe that it has been used upon the stolen items.
(c) I Aspecimen impression of the date stamp and, if it was stolen, particulars of the
type in it when stolen.
51 Issue
September 1994
©Copyright reserved
(d)
@
A statement of the circumstances which are thought to show that a theft has been
committed and of the supposed date, time and method of commission. It should
include, if possible, written report from the person who last saw the missing
items and the person who first discovered the loss. The former should say when
the items were last seen, in what place and in what kind of receptacle (locked or
unlocked) they then were. The latter should state how and when the loss was
discovered and describe exactly the condition of the place and of the receptacle
from which the items were apparently taken.
Particulars of any cheques, including the transaction for which they were
accepted.
END
52 Issue
September 1994
©Copyright reserved
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AUDIT RECORD QUERY
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Originato I Graham Ward Date I 24/04/06
rr Post Office Ltd Security :
Casework Manager
PO Box 1
CROYDON
CR9 1WN
Telephon I) GRO...
e:
Witness No REF NO. I ARQ
Statement 0607/046
(delete as
applicable)
Information Requested
Date range: 09/02/06 — 08/03/06 Post SOUTH
Office WARNBOROU
GH SPSO
092904
GENERAL A report of all transactions and events for the office
DESCRIPTION I for the relevant days (See attached list), including
FORMAT remittances received, transfers between stock units
REQUIREMEN I and error notices.
TS:
We would like the following format for logs (in Excel
format with each category in a separate column):
Balancing Period; Cash Accounting Period;
Session Type - i.e. Serve Customer, Reversal. Rem
In etc Transaction No; Session Indicator; Date; Time;
Stock; User ID; Transaction Type; Amount £p
2 columns specifying whether an OBCS (& state) of
scan accompanied the transaction
(Session Indicator is whatever way the system has of
indicating that individual transactions are linked)
Specific (PAN or equivalent identifier)
Details:
Signed Graham Ward Date I 24/04/06
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Special 3.5k for SD del 13/03. Office will reopen on Mon 13/03.
Delivered
09-Mar-2006 I kingmi01 I Branch ‘Week 49. Office is well over holding indeed, looking at
Exceptions wed planned retums. office isnt returning anything at all.
apprantley office now closed see log entry below.
03-Mar-2006 I kingmift I T/P Call Call om Bournemouth Area Intervention Manager, Of Office
Received closed as Spm: suspended, re-opens on Monday with
Relief Spm. SD requested for debvery on Monday
13.03.06 of 3.5k.SM. I
08-Mar-2006 I kingmi01 I Useful [Audits going in to office. Closed UFN. RP
Information
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ae 08/02/2006 shot} ference
[Cash on hand 35,515.83 37,360.06 37,360.06 1,933.48 I 35,426.58
[Cash awaiting collection 2,751.00 0.00 3,126.00 3,126.00
Suspense 375.00 3,126.00 3,126.00 0.00) “3,126.00
Other MOP = 0.00 0.00) 0.00
Forex 21452 282 "282 0.00) 282
5,690.00 5,194.24 5,194.24 4675.03 519.21
44,546.35 0.00 -640.15 -640.15
4255148 45(67.48 909436[ -36583.12
[Summary of Receipts ~ 1695338
Summary of Payments 15731.93) 0.00 0.00
Soe 45,767.80] 45,677.48. 736,583.12
45,677.48
Current Trading Position’ I -36,583.12I
“(See Measures Sheet)
NB: I_I
1) F10 Should agree with Office Snapshot at all times.
2) F19 should agree with 115 except when amounts are entered on Measures
sheet for pending transaction corrections or outstanding debt - ro
as advised by transaction correction duty on day of audit. SS
3) For full breakdown of discrepancies refer to Measures page. a
4) Measures page should be used to write report and for R/B reports.
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WS CASH ON HAND ce
.
HAND II DECLARED [I DIFFERENCE I
0.00 0.00
50.00 50.00 50.00
460.00 460.00 460.00
330.00 330.00 330.00
95.00 95.00 95.00)
0.00 0.00
15.00 15.00 15.00
38.00 38.00 38.00
315.00 315.00 315.00
703.50 703.50 103.50
250.20 250.20 250.20
703.50 103.50 103.50
56.30 56.30 56.30
32.44 32.44 32.44
22.03 2203 22.03
6251 6251 6251
1,933.48 0.00 1,933.48
0.00 0.00 7,933.48]
1,933.48 0.00 1,933.48
0.00 Please note: £5 Trafalgar coin return by 10-02-06 (see.
3730.25
3,730.25
D AT AUDIT
South Warnborough Cash On Hand Schedule
CASH ACCOUNT
PERIOD/BRANCH CASH ON INWARD OUTWARD
TRADING PERIOD DATE HAND REMITTANCE] REMITTANCE I DISCREPANCY
11 09/03/2006 I £ 1,933.48
10 08/02/2006 I £ 35,515.83 £ 2,500.00 £6.74
9 13/01/2006 I £ 32,629.81 £177.62
8 07/12/2005 I £ 29,977.65 £7.76
Page 1of statement missing, thus cash on hand & discrepany
7 09/11/2005 _Ifigures not known
28 05/10/2005 I £ 26,393.96 I£ 1,290.00 £14.39)
27 28/09/2005 I £ 25,871.53 £7.57
26 21/09/2005 I £ 25,772.05 -£0.98
25 44/09/2005 I £ 25,313.95 I £ 750.00 £142.44
24 07/09/2005 I £ 23,470.76 -£171.07
23 31/08/2005 _I Cash Account Final not available
22 24/08/2005 I £ 24,667.19I£ 2,000.00 £188.31
21 17/08/2005 I £ 23,722.92 I£ 1,250.00 -£185.60I
20 10/08/2005 I £ 22,220.92 £177.79)
19 03/08/2005 I £ 23,349.29 £195.54
18 27/07/2005 I £ 23,917.86 £200.04
17 20/07/2005 I £ 22,674.01} £ 1,000.00 £202.27
16 13/07/2005 _I £ 22,423.18 £233.87
15 06/07/2005_I Cash Account Final not available
14 29/06/2005 I £ 20,303.85 £50.78)
13 22/06/2005 I £ 20,916.29 £138.14)
12 15/06/2005 I £ 20,937.28 £145.55
14 08/06/2005 I £ 20,258.84I/£ 2,500.00 -£36.52
10 01/06/2005 I £ 19,250.58} £ 1,250.00 Nil
9 25/05/2005 I £ 19,039.05 £160.91
8 18/05/2005 I £ 18,880.86 £24.55
7 41/05/2005 I £ 19,149.24 £31.92
6 04/05/2005 I £ 18,813.67 I£ 2,500.00 -£30.69)
5 27/04/2005 I £ 17,913.67 I£ 2,000.00 £8.68
4 20/04/2005 I £ 17,871.35I£ 1,000.00 £7.25
3 13/04/2005 I £ 18,109.82 £274.54)
2 06/04/2005 I £ 18,578.14 ]£ 2,500.00 £259.91
1 30/03/2005 I £ 15,992.33 -£730.40
52. 23/03/2005 I £ 18,441.16 I£ 2,250.00 -£724.34I
51 16/03/2005 I £ 15,740.43 I£ 2,000.00 £732.85
50 09/03/2005 I £ 14,978.54 £717.18
49 02/03/2005 I £ 14,944.55 -£710.54)
48 23/02/2005 I £ 18,055.60 I£ 3,500.00 -£725.40}
47 16/02/2005 I £ 14,941.38 I £ 750.00 £9.84
46 09/02/2005 I £ 15,049.72 -£22.59)
45 02/02/2005 I £ 15,401.07 £17.39)
44 26/01/2005 I £ 17,080.12 £23.06
43 19/01/2005 I £ 17,609.56 £19.44)
42 12/01/2005 I £ 18,193.50 £20.11
44 05/01/2005 I £ 21,345.34/£ 4,500.00 -£20.09;
40 29/12/2004 I £ 18,727.61 £41.40)
39 22/12/2004 I £ 19,775.89I£ 1,500.00 -£47.85)
38 15/12/2004 I £ 17,633.02]£ 2,000.00}£ 2,000.00 -£47.54)
37 08/12/2004 I £ 14,576.02I£ 2,000.00 £52.14
36 01/12/2004 I £ 15,951.92[£ 2,000.00 £47.38)
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Prepared Statement
Of
Jo Hamilton
I took over the running of South Warnborough village shop in October 2001. At the
time there was a sub-postmaster and another woman who was trained to work in the
Post Office. However after one month she handed in her notice to leave on Christmas
Eve.
I was persuaded to take over the sub-post office under the direction of the sub-
postmaster.
My first day of training was 24" December 2001 by someone from the Post Office. I
then had two weeks of half day training sessions. At the time I did not attend any
training days. At the beginning, we basically sold stamps and cashed pension books.
There was nothing very technical about it. I was shown how to balance the end of
week, which I mastered with the help of one of my staff.
When I took over the shop and was running the Post office for the sub postmaster,
there were manuals in the office, but they were old and not updated. Whilst I
continued to receive updates, I had no training as to how to update the manual, nor did
I know how old the manual was in the first place. In addition to this, I have always
been encouraged to ring the help desk rather than refer to the manual.
The Post Office authorities became more and more remote.
I took over as sub-postmistress in October 2003. I was not audited at any stage after I
took over as sub-postmistress.
On one occasion after I took over there was a shortage of £1500 which I could not
explain or work out how it had happened. I cannot remember who I spoke to about it.
It was either the helpline or Colin Woodbridge. I was told what to do and it
immediately doubled the shortfall to £3000. I was told to send in a month’s
transaction logs which I did. They could not work out what had happened and told me
I had to repay all of the £3000 which they took out of my pay.
After that there was another error making a shortfall of £750. They took that out of
my pay as well.
Neither error triggered an audit. In fact I have never been audited during my time as
sub-postmistress until now.
Since taking over we have moved to card accounts, electronic banking and all sorts of
systems have been introduced. It has turned a very small sub-post office into a bank
for which I have received no training.
When we switched from weekly cash accounts to monthly trading, my training
consisted of the Post Office sending me a DVD when I do not have a DVD player.
EXHISITNO 9
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All transactions are now done on a screen. But the screen would not let me question
any errors.
The Post Office systems are shambolic. On one occasion I swiped a debit card for
foreign currency which I subsequently discovered I should not have done as it ended
up with the customer being charged twice. I had to refund the customer but I never
knew whether the Post Office credited me.
J returned traveller cheques to Hemel Hempstead in the wrong pouch. I was never
credited for them.
If I missed the cut off date for obsolete stock overnight the value of the stock would
be converted to cash on the system even though the cash is not there. There is no way
of going into the screen to alter it because the icon has disappeared.
We only ever had one user ID, as I had received no training in how to change or
create new user IDs. Consequently, all the staff used the same user ID.
These are just a very few examples of problems that spring to mind,
have never been trained properly.
Thave never understood the system except right at the beginning.
Consequently I cannot answer any questions as J do not know the answers.
I can say that I have never stolen any money or acted dishonestly.
G
RO. KATE SOLICITOR
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This document explains your legal
rights. It is important that you
read and understand it.
omesnonn 5 /S106. nme 12:1 os
Because you are suspected of having committed a criminal offence which may result in a criminal
prosecution I must inform you that:
You do not have to say anything, but it may harm your defence if you do not mention when
questioned something which you later rely on in court. Anything you do say may be given in
evidence.
des.
(Reply to be written by person being interviewed) #
Do you understand?
(If necessary the interviewee should be asked if they require any clarification of the caution and if so be
provided with an explanation)
1 must also inform you that:
1. You are not under arrest.
2. You are free to leave if you wish. (If the interview is being conducted anywhere other than Royal Mail
premises consent must also be obtained from the interviewee and person entitled to grant entry to
premises, to carry out the interview there)
3. If you do remain you have the right to legal representation and advice including the right to speak with
a Solicitor either in person or on the telephone. (The Solicitor will give you advice regarding Legal
Aid’). I can provide you with assistance in contacting a solicitor if you wish.
4. You are entitled to read the Police and Criminal Evidence Act 1984 Codes of Practice if you wish. The
Codes set out your legal rights and the rules governing the conduct of this interview.
AES.
(Reply to be written by person being interviewed) #
Do you understand 1 - 4 above? YES.
Reply to be written by Person being I interviewed) #
Have you read 1 - 4 above?
° I wish to speak with a Solicitor as soon as it is practical. SIGNED! re RO I
° I do not want to speak to a Solicitor at this time SIGNEI
# If you do not want to speak to a Solicitor at this time, you can change your mind at any time
eing interviewed)
SIGNED
PRINT NAME
TIME (2,101, HRS
This sentence to be deleted when the interview is conducted at a police station
# Ifa Solicitor is requested at any stage, the interview must be immediately suspended
° Delete as applicable
C8001 Side A Version 9.0 03/06
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REMINDER OF LEGAL RIGHTS ON CONTINUATION OF INTERVIEW
S151 06
Time and Date: MS : \
Time and Dat
Time and Date:
I confirm that I have been *reminded that I remain under caution/ *re-cautioned and reminded of my legal
rights. nave-cine-hoonreeinded that I am not under arrest and am free to leave if I wish.
GRO
# If you do not want to speak to a Solicitor at this time, you can change your mind at any time during the
interview.
Do you understand? MES
Do you understand?
Do you understand? .....
* Delete as applicable
** When there is a break in questioning under caution and there is any doubt that the person being
questioned is aware that he remains under caution, the caution shall be given again in full when the
interview resumes.
# — Ifa Solicitor is requested at any stage, the interview must be immediately suspended.
S001 Side B Version 9.0 03/0
Record of Tape
Recorded Interview
Person Interviewed
Place of Interview
Date of Interview
Time commenced
Duration of interview
Interviewing Officer(s)
Other persons present
Josephine Hamilton (JH)
Tanner & Taylor Solicitors Office, Aldershot
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officer producing exhibit
05 May 2006
12.13 Time concluded 12.58
45 minutes Tape referenceno 042769
Graham Brander (GB) Colin Price (CP)
Kate Taylor (KT) - Solicitor
Tape Person Text
counter speaking
times
0.10 GB Introductions and voice verification.
1.22 GB Goes through CS001 Legal Rights form, including administering caution and
giving an explanation of it.
6.50 GB Goes through CS003 Post Office Friend form.
9.04 GB States that Kate Taylor gave him a prepared statement prior to the
commencement of the interview. States he will come back to that in a minute.
States that he wants to go back to the day of the audit, 09 March 2006. Asks Jo
Hamilton if it is correct that he attended her house on day of the audit.
9.36 KT Don't answer any of those questions. Asks if she can have the opportunity to
read out the prepared statement first of ail.
9.58 KT Reads out prepared statement. On completion, states that she is advising her
client to answer no comment to all subsequent questions.
GB States that having read the prepared statement there are a number of questions
that he wishes to ask as well as a number of items that he would wish to seek
clarification on.
14.19 GB I appreciate that you said your client is going to answer no comment but is your
client able to clarify anything relating to this prepared statement.
KT States that at this stage will only be putting forward the prepared statement.
GB States to Jo that she wasn't in attendance on day of audit
that correct?
JH No comment.
csoi5
> 13] Version 3.0 11/021 4
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Record of Tape Recorded Interview (continued)
Tape Person Text
counter speaking
times
17.44 GB States that she went [6R0! following requests from the Post office to return money
in the region of £25,000. Is that correct?
JH No comment.
cp Asks if she is prepared to name the assistants that work in the Post Office so
that we can get to the bottom of this.
JH No comment.
GB Refers to part of statement stating that due to lack of training all staff use the
same user ID. Were you really not aware that you could create user ID's/
JH No comment.
GB States that it is a requirement to comply with the Financial Services Act whereby
it should be possible to identify who has done what transactions. Asks if she has
read and signed something to state that she understands and will comply with
the Financial Services Act?
JH No comment.
20.44 GB States that the only user name he can find on Horizon system is JHAO01. Is that
your user name?
JH No comment.
GB Are you suggesting that other people work in the Post Office and serve against
the user name JHA001?
JH No comment.
cP States that once again it would help our enquiry if Jo could advise on who works
in the Post Office.
KT States that her advice remains I that her client answers no comment at this
stage.
22.02 GB States that the auditors found cash on hand to the value of £1,933.48. Showing
on the Horizon system was £37,360.06, a difference of £35,426.58. Are you able
to give any explanation as to why there was such a large difference in the cash
shown on the system to what was actually there?
JH No comment.
GB
CSO15A
States that if she isn’t going to answer his questions then he will be treating
everyone who works in the shop as a potential suspect or witness. States that
ultimately he will have to speak to her staff to ascertain who works in the Post
Office and asking them if they have stolen Post Office money. If you’re ina
position to explain this to me and save those ladies having those questions put
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Record of Tape Recorded Interview (continued)
Tape Person Text
counter speaking
times
to them, then you've got the opportunity to tell me now.
23.49 JH No comment.
cP Asks if she will give us bank disclosures?
KT Perhaps we can discuss that after the interview.
25.25 GB Shows Branch Trading Statement for period 11. Asks why the cash figure of
£35,515.83, carried forward from previous Trading statement went down to the
£1933.48 found by the auditors.
JH No comment.
GB Can you think of any possible error or genuine reason why it would have dropped
by that amount?
JH No comment.
GB States that the prepared statement mentions lack of training and alleged errors
but he can’t see anything on it that would shed any light on the £36,583.12
deficit. So can you help me out in respect of that?
JH No comment.
GB Do you produce the Branch Trading Statements or Cash Accounts?
JH No comment.
GB Are you aware that in producing an account you are declaring that it is the true
cash and stock on hand?
JH No comment.
28.52 GB Have you ever inflated the cash figure on any account at South Warnborough
Post Office?
JH No comment.
GB Asks if the cash figure of £35,515.83 brought forward onto Branch Trading
Statement period 11 was a true amount of cash on hand from the previous
Trading Statement?
JH No comment.
29.52 GB Shows Cash Account Final week 36 (w/e 01/12/04). Asks is that your signature
on the form.
JH No comment.
GB States that it shows a £47.38 shortage. Was that a true reflection of how the
accounts balanced in that week?
JH No comment.
GB Shows the cash on hand figure of £15,951.92. Was that a true amount of cash
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on hand on that day?
JH No comment.
31.10 GB Shows Cash Account Final for week 10 (w/e 01/06/05). Is that your signature on
the top of the form?
JH No comment.
GB States that there is no discrepancy shown. Asks if it is correct that the account
balanced to the penny on that particular week?
JH No comment.
GB Shows cash on hand figure of £19,250.58 and asks if that was a true amount of
cash on hand on that day?
JH No comment?
GB Had that figure been inflated by you on that day?
JH No comment.
32.12 GB Shows Cash Account Final week 24 (w/e 07/09/05). Have you signed that Cash
Account Final?
JH No comment.
GB States that there is a declared shortage of £171.07. Was that a true statement of
how the accounts balanced that week?
JH No comment.
GB Shows cash on hand figure of £23,470.76 and asks if it was a true amount of
cash on hand on that day?
JH No comment.
GB Had you deliberately inflated that cash figure?
JH No comment.
33.21 GB Shows Cash Account final week 28 (w/e 05/10/05). States that it was the last
Cash Account before moving on to monthly Branch Trading Statements. Have
you signed that Cash Account Final?
JH No comment.
GB States that there is a declared shortage of £14.39. Was that a true statement of
how the accounts balanced that week?
JH No comment.
GB Shows cash on hand figure of £26,393.96. Was that a true amount of cash on
hand for the day that was produced?
JH No comment.
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34.49 GB Shows Branch Trading Statement for period 10. States that the cash on hand
figure is £35,515.83. Was that a true amount of cash on hand for that Trading
statement?
JH No comment.
GB States that the discrepancy in the cash found on audit was £35,426.58. States
that this is approximately £90 less than the cash figure shown on Branch Trading
Statement period 10. States that either she was either operating on
approximately £90 or X amount of money has gone missing between that
statement being produced and when the audit was conducted on 09 March.
Are you aware of any problems or errors that had occurred that would have
resulted in any money going missing between those two periods?
JH No comment.
GB Had you stolen any money during that period?
JH No comment.
36.57 GB Have you stolen any Post Office money?
JH No comment.
GB {s that why the cash figures are so high because you got into financial difficulty
and you've gradually been stealing Post Office money and the cash is being
inflated and it's got to the stage where the auditors have come in and only found
£1,900 and something on hand. Is it the case that you've been stealing money
over a period of time from the Post Office?
JH No comment.
GB Is it that you have been deliberately inflated the cash figures to cover the fact
that you have been stealing Post Office money?
JH No comment.
GB Are you aware of anyone else that's stolen Post Office money?
JH No comment.
37.43 GB Has anyone put you under any pressure to steal Post Office money?
JH No comment.
GB Refers to prepared statement and asks her if she can tell him exactly what
training she received.
JH No comment.
GB States that at time she started working at Post Office Horizon had already been
implemented. Asks if she received any training on how to use the Horizon
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system?
JH No comment.
38.58 GB Refers to part of the prepared statement, which says ‘there was nothing very
technical about it’. Refers to section in prepared statement covering balancing
‘which I mastered with the help of one of my staff.
Is that correct that you've mastered the art of balancing?
JH No comment.
GB States that updates are available in a variety of productions including the
Counter News. Do you implement those updates?
JH No comment.
GB States that prepared statement says the manuals were old or out of date and
she was encouraged to ring the Helpdesk. States that is great because if you
don't know the answer or believe your manuals are out of date then the people
that are going to give you the answer are the Helpdesk. So whenever you had a
problem did you phone the Helpdesk for assistance?
40.49 JH No comment.
GB if you had a problem, did you phone anyone other than the Helpdesk for
assistance?
JH No comment.
GB Refers to prepared statement whereby it alleges a £1,500 error occurred. Asks
when this was?
JH No comment.
GB States that it says that following a telephone call to either the Helpline or Colin
Woodbridge the error doubled to £3,000. States that he has Cash Accounts
going back to 01/12/04 and hasn't come across a deficit of either £1,500 or
£3,000. States that he has produced a schedule detailing deficits in the
accounts, a copy of which was supplied to Kate Taylor.
Would this alleged shortage have occurred prior to 01/12/04?
JH No comment.
GB Even if it had, that's some fifteen months prior to the audit. On 01/12/04 the cash
on hand was £15,951.92. Are you saying that this £3,000 or £1,500 deficit would
have any bearing on the shortage identified on 09/03/06?
JH No comment.
44.41 Buzzer sounds.
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GB States that the tapes are coming to an end. States that during the break she may
wish to consult with her solicitor including whether bank authority disclosure will
be granted.
45.15 Master Tape seal ref 042769 signed.
GB Advises Jo that during the break in tapes that she remains under caution. States
that when the interview resumes he will go through the legal rights and friend rulr
again.
46.08 Tape machine switched off at 12.58.
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Record of Tape
Recorded Interview
Person Interviewed = Josephine Hamilton (JH)
Place of Interview Tanner & Taylor Solicitors Office, Aldershot
officer producing exhibit
Date of Interview 05 May 2006
Time commenced 13.09 Time concluded 13.32
Duration of interview 23 minutes Tape reference no 042770
Interviewing Officer(s) Graham Brander (GB) Colin Price (CP)
Other persons present Kate Taylor (KT) - Solicitor
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0.09 GB Introductions and voice verification.
1.15 GB Goes through CS001 Legal Rights form, including administering caution.
5.36 GB Asks if there is anything you wish to tell me following your consultation with Kate
Taylor.
KT States that Jo is happy to give consent to disclose details of her bank accounts.
6.56 GB States that the prepared statement refers to a loss of £750. States that he had
identified a number of discrepancies around that amount between week 48 (w/e
23/02/05) and week 01. States that in week 04 (w/e 20/04/05) it drops down to
£7.25. Asks if this is the period of time that she is referring to in her prepared
statement?
JH No comment.
GB The losses that I have just mentioned. Were they genuine losses that occurred
in each of those weeks?
JH No comment.
GB Were they losses that you hadn't made good and you'd rolled over a number of
weeks.
JH No comment.
GB Are you aware of your contractual requirement to make good losses at the time?
JH No comment.
GB Have you ever rolled losses, not having made them good at the time?
JH No comment.
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11.47 GB Refers to the prepared statement dealing with the move to Branch Trading,
States that it says she was sent a DVD but did not have a DVD player. States
that it is not acceptable if that is supposed to be an excuse for not complying
with the training.
Did you ask for it to be sent to you in video format or written format?
JH No comment.
GB Did you ask anyone how you would go about completing a Branch Trading
Statement?
JH No comment.
GB States that the last Trading Statement, period 11, was printed by the auditors but
there were four others produced prior to the auditors arriving. So were you
producing those Branch Trading Statements not knowing what you were doing?
14.00 JH No comment.
GB Asks her to explain the process for producing the Branch Trading Statements for
periods 7 ~10.
JH No comment.
GB States he is giving her one final opportunity to give an explanation as to why
there was such a large discrepancy identified in the accounts.
JH No comment.
GB Why is it that you wentisro} following requests to return money to the Post
Office?
JH No comment.
GB \s it true that you contacted somebody from the federation and advised them that
you'd been asked to return money but the money wasn’t there? Is that correct?
JH No comment.
GB Asks if there's any possibility of adding to the prepared statement, details of the
staff that work in the Post Office? States that he may have to obtain denial
statements from everyone working in the shop and if Jo can eliminate any that
don’t work in the Post office then it would save them being asked whether they
have stolen Post office money.
KT Can we take a break so that I can take instructions?
GB States that we can finish up and if wiling, Jo can supply that information via
yourself, either after the interview or at a later stage.
KT
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States that the amount of paperwork disclosed to her has been very limited.
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GB States that he disclosed prior to interview what he anticipated showing her client.
Stated that during the interview he had shown a number of cash Accounts and
Branch trading Statements. Agreed to allow Kate to take photocopies of the
accounts shown at interview.
20.29 GB Shows a schedule of Horizon extracts headed All sales Transactions referring to
Alliance & Leicester cash deposits for the period 01/02/06 — 06/03/06. States
that they are all whole amounts, rounded up to nearest ten pounds. Are you able
to give me an explanation as to what these cash amounts relate to?
JH No comment.
GB Would these be any of your accounts?
JH No comment.
22.01 GB Administers second caution.
Asks, do you wish to clarify anything you have said or add anything else before
the end of the interview.
JH No.
22.32 Master tape Seal ref 042770 is signed.
23.09 Tape machine switched off at 13.32 hrs.
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WINCHESTER CROWN COURT
THE QUEEN
v
JOSEPHINE HAMILTON
COPY LIST OF EXHIBITS
AND COPY EXHIBITS
General Counsel to Royal Mail Group ple
Legal Services
3" Floor
6a Eccleston Street
Victoria
LONDON SW1W 9LT
m:\criminal work folders\mefarlane juliet - crm\253367 - hamilton\253367 b.doc