INQ00002008
INQ00002008
POST OFFICE HORIZON It
INQUIRY
Post Office Limited
clo Gregg Rowan Post Office Horizon IT Inquiry
Herbert Smith Freehills LLP PO Box: Post Office Horizon Inquiry
Exchange House 1 Victoria Street
Primrose Street Westminster
London London
EC2A 2EG SW1H OET
By email to: Gregg.Rowant....
Andrew.Lidbettet
Antonia.smithf
“3 Christine.laconf” “GRO I
HSFPOLInquiryServi
Our ref: POLR9-14/JB/20220615
Your ref:
15 June 2022
Dear Mr Rowan
Request for information pursuant to Rule 9 of the Inquiry Rules 2006 — Request Number 14 concerning
documents of relevance to Phase 4
am writing to you to make a formal request on behalf of the Chair of the Post Office Horizon IT Inquiry under
Rule 9 of the Inquiry Rules 2006 for documents. This is the fourteenth request that has been made to your
client under the Inquiry Rules 2006. The purpose of this request is to address issues of relevance to Phase 4 of
the Inquiry. Accordingly, please provide the following information and documents:
A. Contractual Liability for Shortfalls
1. Policies and guidelines (applicable in the four countries of the United Kingdom) relating to the
contractual liability of subpostmasters and other end users (such as Crown office employees) for
shortfalls shown by Horizon during the relevant period’.
2. Any formal legal advice relating to the policies and guidelines described at 1. above.
3. Please confirm which department(s) held responsibility for the policies and guidelines described at 1.
above. Who held responsibility for the management and oversight of that department?
4. Any guidance, training or instruction (applicable in the four countries of the United Kingdom) given to
those responsible for conducting audits of subpostmasters’ branch accounts.
5. Please provide details of the experience and qualifications of those responsible for conducting audits of
subpostmasters’ branch accounts.
1 As defined in the Inquiry's completed list of issues.
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Please confirm which department(s) held responsibility for conducting audits of subpostmasters’ branch
accounts during the relevant period. Who held responsibility for the oversight and management of that
department?
Any reports, reviews, formal legal advice or investigations (produced by POL or by an external firm on
POL's behalf) which address the quality of the audits conducted in respect of subpostmasters’ branch
accounts.
Any guidance, training or instruction (applicable in the four countries of the United Kingdom) given to
those responsible for making determinations in relation to the suspension, reinstatement or termination
of subpostmasters and any consequent appeals.
Please provide details of the experience and qualifications of those responsible for making
determinations in relation to the suspension, reinstatement or termination of subpostmasters and any
consequent appeals.
I. Please confirm which department(s) held responsibility for making determinations in relation to the
suspension, reinstatement or termination of subpostmasters and any consequent appeals. Who held
responsibility for the management and oversight of that department?
. Any reports, reviews, formal legal advice or investigations (produced by POL or by an external firm on
POL's behalf) which address the quality of the decisions taken in relation to the suspension,
reinstatement or termination of subpostmasters and any consequent appeals.
. Any reports, briefings or formal legal advice relating to the decision to remove the contractual right of
appeal from subpostmasters.
. Any guidance, training or instruction (applicable in the four countries of the United Kingdom) given to
those responsible for taking civil enforcement action to recover shortfalls shown by Horizon.
. Please provide details of the experience and qualifications of those responsible for taking civil
enforcement action to recover shortfalls shown by Horizon.
. Please confirm which department(s) held responsibility for making determinations in relation to the
bringing of civil enforcement action against subpostmasters to recover shortfalls shown by the Horizon.
Who was responsible for the management and oversight of that department?
. Any reports, reviews, formal legal advice or investigations (produced by POL or by an external firm on
POL's behalf) which address the fairness and / or appropriateness of taking civil enforcement action
against subpostmasters to recover shortfalls shown by Horizon.
Civil Case Studies
. All records relating to the conduct of branch audits, civil interviews, decisions on suspension,
reinstatement, termination and appeal, as well as the threat, instigation and pursuit of civil enforcement
action in respect of the following individuals:
Aslam Ramtoola, subpostmaster between 1988 — 2000, Rochdale, England.
Katherine McAlerney, subpostmistress between 2000 — 2008, County Down, Northern Ireland.
Lee Castleton, subpostmaster between 2003 — 2004, Marine Drive, Bridlington, England.
Susan McKnight, subpostmistress between 2005 — 2009, Wigan, England.
Rachel Williams, subpostmistress 2006 — 2008, Somerset, England.
Keith Macaldowie, subpostmaster 2006 — 2011, Greenock, Scotland.
Tracey Etheridge, subpostmistress between 2008 — 2011, Gurnos Estate Post Office, Merthyr
Tydfil, Wales.
Kevin Palmer, subpostmaster between 2007 — 2016, Essex, England.
Frank Holt, subpostmaster 2008 — 2017, Invernessshire, Scotland.
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C. Private Prosecutions
18. Policies and guidelines (applicable in the four countries of the United Kingdom) relating to the bringing
of private prosecutions against subpostmasters and other end users (including Crown Office
employees) alleged to be responsible for shortfalls shown by Horizon during the relevant period.
19. Any formal legal advice relating to the policies and guidelines described at 18. above.
21. Any reports, briefings or formal legal advice relating to the decision to suspend and / or cease the
bringing of private prosecutions.
22. Any guidance, training or instruction (applicable in the four countries of the United Kingdom) given to
those responsible for conducting criminal investigations into the conduct of subpostmasters and other
end users alleged to be responsible for shortfalls shown by Horizon.
25. Any reports, reviews, formal legal advice or investigations (produced by POL or by an external firm on
POL's behalf) which address the quality of the criminal investigations conducted into subpostmasters.
and other end users alleged to be responsible for shortfalls shown by Horizon.
26. Any guidance, training or instruction given to those responsible for making charging decisions in
respect of subpostmasters and other end users alleged to be responsible for shortfalls shown by
Horizon.
IRRELEVANT
30. Any guidance, training or instruction given to those responsible for conducting the prosecution of
subpostmasters and other end users alleged to be responsible for shortfalls shown by Horizon.
34. Any guidance, training or instruction given to those responsible for disclosure in criminal proceedings
brought against subpostmasters and other end users alleged to be responsible for shortfalls shown by
IRRELEVANT
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IRRELEVANT
37. Any reports, reviews, formal legal advice or investigations (produced by POL or by an external firm on
POL’s behalf) which address the fairness and / or appropriateness of the disclosure given in criminal
proceedings.
38. Any guidance, training or instruction given to those responsible for the negotiation and acceptance of
pleas by subpostmasters and other end users alleged to be responsible for shortfalls shown by
Horizon.
c. inal Case Studies
42. All records relating to the conduct of the criminal investigations and interviews, the laying of charges
and the conduct of the private prosecutions, and decision in relation to the disclosure of documents, as
well as the negotiation and acceptance of pleas in respect of the following individuals:
Lisa Brennan
David Yates
David Blakely
Tahir Mahmood
Hughie Thomas
Carl Page
Janet Skinner
Jo Hamilton
Paula Stonehouse
Julian Wilson (deceased)
Peter Holmes (deceased)
Seema Misra
. Allison Henderson
Lynette Hutchings
Khayyam Ishaq
Angela Sefton
Ann Nield
Susan Rudkin
Susan Hazzleton
Oyeteju Adedajo
Joan Bailey
Nichola Arch
Suzanne Palmer.
Es Eryn evoOa3Z Tm ATT sap aN oD
All documents must be provided to the Inquiry in unredacted form. Any requests for redactions and/or
applications for restriction orders should be made in accordance with the Inquiry's published Protocol on
Redaction, Anonymity and Restriction Orders, which provides that such requests should not be made until after
the Inquiry confirms that it wishes to disclose the document (or within 7 days of the Inquiry confirming that it will
not be making the redaction on relevance grounds, if later).
In order to respond to this Request, you will be provided with a Quatrix link via email to your email address.
Please provide all documents separately (i.e. do not combin i e pdf). Please also
provide any covering letter in response to both Solicitior@ “and
Julie Beaumont@ 3 quoting our reference above.
-4-
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Deadline for responding to this request
Please respond to this Rule 9 Request by 4.00pm on Friday 15" July 2022.
If you have any questions, please do not hesitate to contact me. I look forward to hearing from you.
Yours sincerely
ry
oO.
Julie Beaumont
Lawyer
Post Office Horizon IT Inquiry