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simon.belfielg
tom.cleary@
‘Your ref: CRM/239850
Date: 20 May 2005
By Fax & Post :}
For the attention of : Debbie Helszajn
Criminal Law Team
Royal Mail
Legal Services
Dear Ms Helszajn
RE: RvCARL PAGE
STAFFORD CROWN COURT
We refer to previous correspondence in this matter.
Firstly we trust that by now you will have had some time to digest the report of Mr David Liddell of
Messrs PKF chartered accountants. You will note that of the many matters to which he avers, he is
of the opinion that there was no evidence of any appropriation to justify Count 2 on the indictment
to remain.
You will appreciate that Count 2 has been advanced on the basis of a deficiency found on audit,
which Mr Liddell has now been able to clarify. It is plain therefore that there was in fact no
deficiency, either upon view of Mr Liddell, or even on the evidence of Glyn Burrows who confirmed
zat the shortage at audit was as a result of cheques seized by the police (page 318 of the exhibits
file). Also on this point, may we refer you to the explanation of Mr Page at page 236 and 237 of the
interview bundle, in which the particulars of the cheque for £278,181.82 were explained. Plainly it
would not appear that Mr Patel’s investigation gave sufficient attention to the fact that Mr Page in
fact honoured this cheque. Indeed it is clear that the “appropriation” of the alleged offence is based
upon the internal documentation which depicted a steady inflation from weeks 22 to 41.
cuensesvaoearenn 2
Partners Consultant Practice Manager 26 EASTGATE STREET, STAFFORD
Andrew W Broome Peter AC Frisby Judith A Read S746 212
Kevin Downes Tom Cleary *
David Wassell Associate Conveyancing Executive
Simon C Belfield Elizabeth A Thomps~n Sylvia Bullock
DX14564 Staffor
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 tr the Law Society
* Non sol
nt
g Family <p
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jusly such an approach is flawed, as it would in effect have resulted in accounting for stock
had already been sold.
circumstances, it would not appear to us that Count 2 can properly stand, and we would be
eful please for your observations.
furing to the directions given on the 13" of May, we would make the following comments.
‘In so far as the Jury Bundle is concerned, we do not feel that only part extracts of any document
~ should be included. Clearly given the nature of this case, we believe complete copies of Exhibits
RK/01 and RK/01A should be provided.
As far as Exhibit MP/3 is concerned, you will note our expert's observations in relation to this
document. Therefore we cannot agree to its inclusion in its present form.
We are not at this stage minded to agree the inclusion MP /102 given that we cannot see its
relevance to any trial issue. Perhaps you could explain its relevance and the reasons for its
inclusion. Please note there is no reference to this document in your case summary.
Having regard to exhibit ref MP/104, you will recall HHJ Woods comments with regards to loss,
namely it was one of profit and not loss per se. Therefore, we cannot agree a document being
included which does not accurately describe the loss in this way. No doubt the words “of profit” can
be added so as to remove its prejudicial effect.
Turning to the issue of the interviews, we are presently reviewing these, which as you know run to
many pages (nearly 250). We agree that there will need to be some editing, and we will let you
have our suggestions as soon as possible.
The following documents are those we intend to rely on and for ease of reference we refer to by
their exhibit number where possible:
HRS/3
LGH/04
HUNT/A
NJW/5,
GB/04
MEP/1
PB/116
All documents referred to in the appendix to David Liddell's report.
Copy of Letter from DC Deans re dated 7" May 2003
Search warrant issued by Staffordshire Magistrates
Copy of Audit notes by Mr. R Davies following his visit to Rugeley Post Office on 27" July
2002
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sopy of interview notes held on 3” July 2002
etter dated 28" June 2002 inviting Mr. Page for interview.
etter dated 6" March 2002 from Jim Coney to Rugeley Post Office.
Letter dated 21*' May 2002 from Jim Coney to Rugeley Post Office
Letter dated 7" August 2002 from Jim Coney to Rugeley Post Office
Acopy of Custom & Excise draft schedule
Copies of all documents relating to audits
learly, the above list should not be regarded as exhaustive.
witne
Your!
Tom anne
inally.. we would anoreciate. if vou.could_ provide us with the order in which you intend to call your
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