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Laurence Lee & Co
Miss Waters
Our Ref: LML.BW.JW.NEI
" . 529 West Derby Road
2" April 2013
Tuebrook
Liverpool L13 844
URGENT. United Kingdom
DX 10825
LEICESTER
DX 14123 Liverpool
Dear Sirs,
Re; REGINA -V- ANNE NEILD
LIVERPOOL CROWN COURT T2012 0934
FOR TRIAL WIC 15™ APRIL 2013
We refer to the above.
We would be obliged if you would provide us with the following items:-
1. Unmodified, unedited call logs in original electronic format of all calls to
the Business Support Centre and the Fujitsu help desk.
2. A full set of Horizon transaction records for the sub post office during our
Client's tenure and in the 3 months following our Client’s suspension to
permit initial examination of pattern of transactions and end of day
balances in relation to the behaviour of the system as well as conduct any
necessary forensic accounting examination for the theft / fraud. Electronic
format required.
3. A full set of Lottery system transaction records provided by the Lottery in
relation to the sub post office and the corresponding records held by the
Post Office to enable analysis of the Lottery records in their original
electronic format for the sub post office of our Client for the period as
above.
4. A full set of system transaction records from the centre that distributes and
collects cash, stamps and Lottery scratch cards in their original electronic
wwulaurenceleesolicitors.co.uk
criminal
Laurence Lee & Co Solicitors (incorporating Cyril Carr Laurence Lee & Co) ence Service
Laurence M Lee LLB. Hons John R Ablett LL.B. Hons Alison & Sharples BA Hons
Regulated by the Solicitors Regulation Authority
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format for the sub post office of our Client for the period as above to
enable patterns and any discrepancies to be analysed.
5. The vouchers corresponding to the period for the transactions disclosed
above to enable reconciliation between the computer records and the
paper vouchers.
6. All records in the Business Support Centre relating to the period for the
transactions disclosed above to enable reconciliation between the Horizon
records and the records held by the Business Support Centre.
7. All Electronic Fund Transfer (EFT) logs relating to the period for the
transactions disclosed above to enable reconciliation between the Horizon
records and EFT transactions.
8. All3” party provided corrections as provided to the Business Support
Centre relating to the period for the transactions disclosed above (e.g.
incorrect account number, etc) to enable reconciliation between Horizon
records and the 3 party corrections.
9. The version of the operations manual provided to our Client and any
subsequent updates provided for the use of the sub post master.
10. The training materials provided to our Client for Horizon and any
subsequent updates.
11.The training provided to our Client.
12. The set of system issues recorded for consideration by Fujitsu during the
tenure of our Client across the Horizon system and those systems it
interfaces to, together with those systems issues unresolved at the
commencement of our Client’s tenure.
13. The previous audit reports for the audits at the sub post office of our
Client.
14. The technical systems architecture and processes implemented by the
Post Office to support the integration of Lottery sales and scratch card
delivery together with any internal or external audit reports into the
integrity of these processes.
15.Witness statements and other submissions by Shoosmiths Access Legal
to the Post Office in relation to any proceedings initiated as per the
complaints referenced in Shoosmiths’ submission to the parliamentary
enquiry.
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16. The terms of reference for Second Sight Ltd, the forensic accountants
instructed by Post Office Ltd to conduct a full enquiry into the Horizon
system and any interim or final findings from their enquiry.
17. Page 98 of the exhibits refers to an email from Kevin Ryan dated 14/09.
May we please have a copy of this email?
18.A copy of any notes or order documents completed by Mr Gordon-
Pounder in respect of the audit that he conducted on 6" January 2012.
19.On page 37 of Mr Gordon-Pounders statement reference is made to
reports printed off the Horizon system and branch trading statements
which were passed to the Post Office Ltd security team. Ma we please
have a copy of these documents?
20.On page 105 of the depositions Mr Gordon-Pounder states “We
conducted the audit as per the audit process manual”. May we please
have a copy of said audit process manual?
21.We note that Mr Ali Askar was suspended on 29" September 2009 in
relation to an allegation of Assault which he subsequently successfully
appealed. Would you please provide us with details of said allegation?
Furthermore we confirm that we will require the attendance of the Prosecution
Witnesses Tim Gordon-Pounder and Stephen Bradshaw to give evidence at our
Client’s Trial.
We would be grateful if you would endeavour to disclose the aforementioned
items as soon as possible given the imminence of our Client’s Trial. We thank
you in anticipation of your assistance.
--Mouree faithfully...
GRO
LAURENCE LEE & CO