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Date: 23 April 2004
By Fax & Post
For the attention of : Debbie Helszain
Royal Mail
Dear Sirs
RE: Rv CARL PAGE
STAFFORD CROWN COURT
We refer to the above matter, and Indeed your letters dated the 12" and 29" March 2004.
Having perused the contents of these documents, you will not be surprised that we do require sight
of a number of the items listed.
VA isting to the schedule of non sensitive unused material, may we please have copies of all of the
items on the said list, save for the notice of bail relating to! and the similar
document in relation to; Both of these superfluous ites appear Git Page 1.
pa? Regarding the police schedule, (MG6C) may we also have copies of items 1-13, and item 17, but
cy excluding items 14-16. May we also have copies of items 1-6 on the further schedule, which we
Qow assume comprises of all the documents in the possession of the FIU.
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Partners Consultant Practice Manager 28 EASTGATE STREET, STAFFORD
Andrew W Broome Peter A C Frisby Judith A Read STIS 22
Kevin Downes Tom Cleary * tt
David Wassell Associate Conveyancing Executive -
Simon C Belfield Elizabeth A Thompson Sylvie Bufook
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 tha Lew Saciaty
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Frisby&tColf
solicitors
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ROYAL MAIL
Re: Carl Page
23.04.04
Given that there has been police involvement in this matter, as well as that from HM Customs, we
presume you have canvassed with them the possibility that they may have further relevant third
party materials in their possession, which may be required to be disclosed? Certainly, from the
involvement that those agencies appear to have had from the papers we have already seen, there
does appear to be very little disclosed, especially from HM Customs. Please confirm the position,
at your earliest convenience.
We would also be grateful for the disciplinary notes of the interview held on the 3 July 2002.
Arising from this meeting, we would be grateful for copies of the following documents, to the extent
that they are not contained in any of the material to be sent to us arising from out request in
paragraph 3 above:-
V4 A copy of the letter dated the 28" of June requesting Mr Page to attend interview.
“2 Copies of all warning letters purportedly sent to Carl Page.
. ae 3 Va Copies of all notes, documents and other memoranda, relating to any Audits on the Post
we c Office during Mr Page's tenancy. This must include, of course, any electronic record that
oe, Or, . Was used to undertake the audit, as we may wish to have such matters forensically
t pee” examined by our own Expert. We presume this will include the ONCH declarations if
they were used as part of the audit process,
Nir _ Avant . .
x4 Copy league table indicating STAM performance as handed to Carl Page.
Ne Ase me . .
75 Copies of any documents, letters, notes or other memoranda regarding the offer by Mr
~ Coney to have Mr Page shadow a “good branch manager’. This should also include any
g'
other documentation, which relates to any other issue as 4 consequence of the
disciplinary meeting, and not disclosed elsewhere in any schedule. This should include
any notes of advice or visits also referred to by Mr Coney in paragraph 3 of page 4 of the
note.
Turning generally to the case, there are a number of further matters which we note are not listed,
and which we will require sight of in order to assist our client in his Defence, These items are as
fallows:~ 7
De Mr Hugh Stacey refers in his evidence to an agreement with the Federation of Sub
Postmasters to pay £1.12 per transaction. May we please have a copy of this
agreement?
Va 2 Mr Stacey also refers to a contractual relationship with regard to corporate customers.
Perhaps, we could be supplied with 4 standard form contract, as is utilised by the Post
Office with corporate customers.
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. ROYAL MAIL
o” Re; Carl Page
apes 23.04.04
3 ~ Mr Stacey refers to the fact that the Post Office buys currency from FRTS on a daily
basis at a wholesale buy rate. This is apparently contractually agreed. We would like a
copy of this agreement.
> wy / Mr Stacey also refers to an agreement regarding revaluation. This relates to feature that
- money is generated at outlets and not centrally. May we again have a copy of this
f agreement.
w SJ, 9
5 He also refe I database, which lists corporate clients. Apparently, this did
not include: or his Company. We would request a copy of this. Also, on
VA this point, we would request sight of any document supporting the contention that
Rugeley does not conduct corporate business.
6 Mr Stacey indicates that he was asked to produce a report showing total losses at
Rugeley and at all other outlets. Again, may we see this report.
7 VA Mr Raj Kalsi refers to booklets concerning cash and cheque acceptance, cash handling
and money laundering. Please supply copies.
8 He also mentions the fact that there is no instruction issued to say that business
cheques can be accepted for the Bureau de Change. May we have details of the
document in which this written instruction is given. Indeed, whilst on this point of
instruction, may we also have details of the training records relating to Wr Carl Page, to
include details of the syllabuses for the training provided. (ni Se Can. BS We Bee
Deen >,
9 Mr Hutchins refers to outlets that require high quantities of currency, and he includes
Rugeley within this list. May we be provided with a copy of the list.
(New ower, Bat Sus bar Severs pve Pee TT oT worse, (AR yew Queene
be ane) Gn No sos Pp Se 15 beat one pS.
40 Mr Hutchins also, in an attempt to explain his exhibit LGH/04, indicates that the entire
order may include other currencies. Please provide copies of the documents used to
produce this exhibit. No Lecce fast,
WA 4 For the purposes of our Experts, may we please have copies of the dally retails sell
rates that were provided by fax for the period in question.
JS 42 You will be aware that we have previously mentioned the lack of documentation from
customs. This includes issues such as notebooks etc. Please can you address this
. issue. he
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ROYAL MAIL,
Re: Carl Page
23.04.04
Given the large amount of numerical evidence in this case, we shall be instructing an
Expert to assist in this respect. Therefore, in relation to all of the schedules produced,
may we please have copies of all documentation notes, and other memoranda used in
the production of same.
In a statement by Deborah Edwards, she indicates that other foreign currency amounts
needed to be transferred into the Forde Moneychanger to get a final balance. May we
have copy documentation to indicate where the other currency originated.
Ms Edwards also refers to total stack and MOP. Again, may we have copies of the
documents used by her in the productlon of this statement?
Margaret Pearce indicates that some customers would have negotiated special rates
with Carl Page. To the extent that there are such customers, may we have
documentation in support.
Ms Batty refers to the fact of having “now received training.” Please provide copies of
the training records, tagether with a copy of the syllabus for such training and other
members of staff.
In a statement by Elaine Lieverlay she refers to a conversation with Mr Page which took
place more than one year prior too her statement. Please may we have a copy of any
note used in the preparation of this statement? (vy, Suse Nove Mare
Douglas Brown indicates that he investigated Post Office branches with excess cash
holdings, of which Rugeley was high on the list. Please provide a copy of this list. -
He also indicates that he requested a fax of actual cash holdings. This was apparently
destroyed. Are you able to confirm how and when this document was destroyed.
Further, he suggests that he contacted Carl Page and was concerned about his casual
attitude and previous history. To the extent that this alleged “previous history” Is
documented, please provide coples.
Gwen Talbot refers to the fact that she was unable to obtain daily rates that the coop
provided, other than those from the computer system archive records, Please may we
have a copy of the archive records to which she refers.
Mr Patel says in his evidence that he was contacted by Customs and Excise who were
concerned about Rugeley Past Office. Please may we have sight of any documentation,
which led to this concern, as agair xe documentation disclosed in relation to Customs.
involvement is limited, thus far. Tu this end, Mr Patel said that he was contacted by
Customs in January 2003 regarding a cheque to the value £112, 465.96 drawn on an
account of RPX Recycled Plastics Limited dated 11.11.02, payable to the Past Office
Limited and accepted at Rugeley post office. The disclosure supplied must please
include details as to thls cheque.
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- Frisby&tCoff
solicitors
5.
ROYAL MAIL
Re: Cari Page
23.04.04
S 23 Did Mr Patel have a notebook? If so, please may we have a copy.
A 24 We note that it is asserted that there was a “buy back” by Mr Page. Please provide any
. documentation in support of this contention.
Finally, we have repeatedly mentioned to your Solicitor, Mr Dove, that we are most unhappy
about the continued advancement of the Civil Proceedings. By any consideration of the
matter, it is wholly inappropriate for these procéedings to continue until such times as the
Criminal Proceedings are concluded. Please confirm that you will be applying for a stay of
these proceedings unti} this action has been finalised.
FRISBY & CO SOLICITORS
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