POL00067097
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FrisbyétCof
solicitors
andrew.broome( Our ref: AB/TC/LJB
simon.belfield(
tom.cleary
Your ref: CRM/239850
Date: 25" January 2005
For the attention of: Debbie Helszajn
Royal Mail
Legal Services
Impact House
2 Edridge Road
Croydon
\CRO 1PJ
Dear Ms Helszajn
RE: RvCARL PAGE
STAFFORD CROWN COURT
We refer to previous correspondence in this matter. Thank you for all the disclosure and, in
particular, the documents provided with your letter dated 7" October 2004. We also note the
contents of your letter dated 8" October 2004 regarding unused materiai held by HM Customs and
Excise.
In response to your letter dated 30 December 2004, we confirm that we have instructed a financial
expert who will provide us with a report in due course. It was due to be issued at the beginning of
December, but following the change of date of trial, we have permitted further time for completion.
We will, of course, serve this report in due course if our expert is subsequently able to allude to
matters of an expert nature upon which we intend to rely.
Wwe recently received correspondence from this expert in which he seeks clarification on two
matters to assist him in his analysis of the evidence disclosed by the prosecution.
setbneandevensaad /2
Partners Consultant Practice Manager
Andrew W Broome Peter AC Frisby Judith A Read
Kevin Downes Tom Cleary *
David Wassell Associate Conveyancing Executive
Simon C Belfield Elizabeth A Thompson Sylvia Bullock
DX14564 Stafford
Andrew Broome is a Supervisor for serious fraud appointed by the Legal Services Commission.
Kevin Downes is a member of the Family Law Panel
This firm is regulated by the Law Society
* Non solicitor
cmipat
Depance service
ga Beriee
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fave already sought documentation in relation to one of these areas, namely the clarification
Mr Hutchins exhibit LHO4. Our expert is keen to obtain the raw data that went to the production
‘this exhibit because of its importance in proper analysis, particularly, in relation to the charge of
theft against our client. Therefore, our expert believes it to be of utmost importance that he is able
check the ordering and delivery of Euros to Rugeley Post Office. With respect, LH/04 is an untitled
computer printout and even Mr. Hutchins concedes in his supplemental statement that although
the volume of Euros is correct, the sterling equivalent is incorrect and the expected date of delivery
may not match exactly with when delivery was so affected.
You have replied by stating that the volume and amount of currency sent to any particular post
office is keyed into a computerised access programme on a daily basis and that the hard copy
documents are destroyed when this is complete. Mr Hutchins keying into the system produced
LGH/04. We wonder how you can rely on them as being the correct figures input onto the system
without raw data to support that supposition. Therefore, we would ask you to confirm that you are
in possession of no materials/documents that assisted with the production of Exhibit LGH/04.
Quite separately, it would appear that you have provided us with a list (16 pages) compiled by Mr.
Patel, which shows all currency types, sent to Rugeley Post Office between 3/01/02 — 1/01/04.
Can you please confirm what data was used to compile this list?
Our expert’s second area of concern is with regard to the COMMAND 10 printout of the Forde
Moneychanger. Our expert would like a fuller explanation of the “Revalue” figure that appears just
below the “cash held” figure. The only description of this “revalue” figure we can find is in the
statement of Mr. Kalsi. He states that his basic understanding of this revaluation figure is the profit
r loss made by buying or selling of currencies at different exchange rates and the fluctuations in
exchange rates during the week. It is possible to provide our expert with a fuller explanation as to
the meaning of this figure and or the Operators Manual for the Money Changer assuming it
provides a description.
Other matters
We note your contention regarding the role of Cust
receive a schedule listing Euro note buy backs from
New Street, Lichfield, Cannock and Tamworth. Can you please confirm who produced this
schedule and from what materials? We ask this question in case there is relevant material we have
not seen.
Also, we have not received information concerning the remaining Customs and Excise as indicated
in paragraph 13 of your letter dated 7 October 2004. We are currently considering our position in
relation to disclosure from Custom and Excise.
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ir Coney expand on exactly what arrangement he made with Cannock Post Office for the
ly to be made available for our client to shadow a Branch Manager? Our client had no
owledge of such arrangements being made or indeed being told that such arrangements had
en made?
Can you please confirm when the Counter Operations Manual 2002, exhibit RK/01 was issued to
branches?
‘Can you confirm that a publication providing instructions and procedures to be followed in relation
to money laundering sent out to all post offices in September 2002 was “Keep us clean — your
guide to money laundering — important information about Money Laundering and your
responsibility’? Can you also confirm that the form you refer to is the money laundering suspicion
report (P4677)?
In your letter dated 7" October 2004, at paragraph 2 on page 4, you state that no records were
passed to the Post Office Investigation Department advising them of the extent of the police
enquiries. We therefore wonder how you have complied with your duties regarding secondary
disclosure in respect of any materials the police may hold.
As you know, our client instructed another firm of solicitors, Hand Morgan & Owen, during his early
dealings with you. We were informed by our client that considerable documentation passed
between you and this firm regarding the freezing of our client's bank accounts and the instigation
of civil proceedings. Unfortunately, our client does not hold personal copies. We requested that
Messrs Hand Morgan and Owen release this information to us; however, as they are unsecured
creditors in our client’s bankruptcy, they have refused to release the papers. We considered that
documentation relating to both freezing of bank accounts and civil proceedings fall into the
category of primary disclosure. We therefore request that you provide us with all the
documentation the Post Office hold and not previously provided in relation to both these matters.
Finally, it is possible that we may need to speak to Margaret Pearce. Obviously, the normal rules
apply and as a Crown witness, we would seek to confirm such arrangements through yourselves.
You! rs. sincerely...
GRO
Andrew Broome
FRISBY & CO SOLICITORS
e
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