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IN HER MAJESTY’S COURT OF APPEAL IN
NORTHERN IRELAND
THE QUEEN
-V-
Alan McLaughlin
BUNDLE OF APPEAL IN SUPPORT OF AN APPLICATION FOR LEAVE TO THE SINGLE JUDGE
Prepared by Madden and Finucane Solicitors
for the Applicant/Appellant
1, Form 2 Notice of Appeal or Application for Leave of Court ... 1-3
2. Form 3 Grounds of Appeal or Application for Leave of Court ... 4.5
3. Skeleton Argument in Support of an Application for Leave to Appeal Against
Conviction to the Single Judge... 6-29
4. Expert Report of McClure Watters Accountants... 30-244
5. Skeleton Argument in Support of an Application to Extend Time to Appeal... 245-250
6. PE Papers... 251-1231
Criminal Procedure
FORM 2
CRIMINAL APPEAL (NORTHERN IRELAND) Act 1980
Notice of appeal or application for leave of Court
To the Master
Queens Bench & Appeals
Court of Appeal
Royal Courts of Justice,
BELFAST BTI 3JF
Part 1
Particulars of appellant
Full names: ALAN WILLIAM MCLAUGHLIN
Age on conviction 45
Address: .....
Particulars of court of triat
Name of court of trial BELFAST CROWN COURT
Name of judge of the court of trial
Date of decision (if convicted and sentenced on different days, give both dates)
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Offences of which convicted
(3)...
(4).
Total sentence
Did the Judge of the court of trial grant a certificate that the case is fit for appeal? NO.
Part 2
Particulars of application
The appellant is applying for-
(i) Extension of time within which to give notice of appeal or application for leave to ap-
peal
(ii) Leave to appeal against conviction
{iii) Legal Aid
Signed
Date
Notes:
1. This form should be sent to the Registrar within 28 days from the date of conviction, sentence, verdict or
finding appealed against. If the’ appellant is in custody the form should be handed to the prison author-
ity (or other person having custody) for forwarding’ to the Registrar; and the date of handing In should
be recorded on the form by the prison authority or other person having custody. The period of 28 days
can with the leave of the court be extended except In the case of a conviction involving ‘sentence of
death,
2. The grounds of the appeal or application for leave must be given on Form 3 and must accompany this
form.
4.
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The court of trial means the court from which the, appeal lies. This always means a court of assize or
county court and never means a magistrates’ court.
In Part 1 of the form give particulars of all convictions and sentences against ,which the appellant has a
right of appeal (with or without leave), A person may appeal against conviction and sentence only if he
was convicted on indictment. A person may appeal against sentence only with leave. There is no appeal
against sentence if the sentence is one fixed by law. If the appeal is against a verdict of not guilty on the
ground of insanity, Part 2 should be adapted accordingly.
Separate forms should be submitted for convictions or sentences which do ‘not arise in the same pro-
ceedings.
If the form Is not signed by the appellant, his counsel or solicitor, it may be treated as not constituting
notice In accordance with the Criminal Appeal (Northem treland) Rules 1968 unless there is also a state-
ment signed by the appellant that he has authorised the person In question to sign the form cn his be-
half.
This notice will be treated as a notice of appeal in the case of an appellant who does not require leave to
appeal, .e.g. because the trial judge has given a certificate or because leave has been given by the Court
of Criminal Appeal.
8. An application for teave to be present, ball, or leave to call witnesses may be made subsequently.
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Criminal Procedure
FORM 3
CRIMINAL APPEAL (NORTHERN IRELAND) Act 1980
Grounds of appeal or application for leave of Court.
To the Master
Queens Bench & Appeals
Court of Appeal
Royal Courts of Justice,
BELFAST BTl 3JF
Full names of appetlant: Alan William McLaughlin
Grounds of application for extension of time:
A skeleton argument in support of an application to extend time has been
appended to this application.
Grounds of appeal or application for leave to appeal against conviction /
sentence:
The Applicant advances the following two grounds of appeal against his
convictions:
Ground 1: the reliability of Horizon data was essential to the prosecution
and, in the light of all the evidence including Fraser J’s findings in the
High Court, it was not possible for the trial Process to be fair; and,
Ground 2: the evidence, together with Fraser J's findings, shows that it
was an affront to the public conscience for the appellant to face prosecu-
tion.
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Signed
Date
Notes
1, This form must accompany Form 2 and must be completed so far as is practicable at that time
and whether the transcript has been received or not. Where one of the grounds of appeal is mis-
direction ‘particulars of the alleged misdirection must be given. If further grounds need to be
given to amend or amplify the grounds given on this form, they should be forwarded to the
Registrar as an amendment to this form.
2. If this form relates to more than one application or to both an application and an appeal, they
should be dealt with separately and in order.
3. An appellant who is applying for extension of time within which to give notice of appeal or ap-
plication for leave to appeal, must give the reasons for the delay; he must also give details of
the appeal or application for leave to appeal...
4. An appellant who is applying for leave to appeal against conviction, must set out each convic-
tion against which he is applying for leave to appeal, and the grounds of the application. The
grounds may be the same for each conviction.
5. If the appellant requires, for the purposes of his appeal against conviction, any exhibits pro-
duced at his trial, he should specify them in the form.
6. An appellant who is applying for leave to appeal against sentence, must set out each sentence
against which he is applying for leave to appeal, and the grounds of the application. The
grounds may be the same for each sentence,
7. An appellant who is applying for leave to appeal against conviction and sentence, must deal
with each conviction and each sentence separately.
8. This notice will be treated as a notice of appeal in a case in which leave to appeal is not re-
quired,
9. If the appeal or application is against a verdict of not guilty on the ground of insanity references
in this form to conviction should be construed as references to such a verdict,
10. An appellant who is applying for leave to appeal against sentence and wishes to call a witness
to give evidence in mitigation. should give his name and address, But the Registrar is not re-
sponsible for arranging for the attendance of the witness,
11. Documents sent with this form should be specified at the end of the form.
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IN HER MAJESTY’S COURT OF APPEAL IN
NORTHERN IRELAND
THE QUEEN
vV-
ALAN McLAUGHLIN
SKELETON ARGUMENT IN SUPPORT OF AN APPLICATION FOR LEAVE TO
APPEAL AGAINST CONVICTION TO THE SINGLE JUDGE
1, On 16 February 2005, Mr. Alan McLaughlin (hereinafter ‘the Applicant’)
pleaded guilty to 15 offences of false accounting contrary to Section 17 (1)(a)
of the Theft Act (Northern lreland) 1969. By letter dated 1 June 2003, the Di-
rector of Public Prosecutions had indicated that the 15 charges were speci-
mens and the total loss alleged to have been caused by the Applicant was
£10,248.77.
2. The charges faced by the Applicant alleged that he had falsified accounting
records in his role as the Sub-Postmaster (‘SPM)) of Brookfield Post Office,
Tennent Street, Belfast.
3. The Applicant denied the allegations in interview and pleaded not guilty at ar-
taignment. He commissioned an expert accountant's report in support of his
defence and only pleaded guilty at the doors of the Court.
4. He now seeks leave to appeal against conviction and an extension of time of
some 16 years 8 months within which to appeat against conviction.
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5. That period of time is obviously extremely lengthy, especially given that the
Applicant pleaded guilty to the offences. However, the Applicant's applications
arise in the context of a number of recognised miscarriages of justice caused
by the Horizon software deployed by Post Office Limited (‘POL’) in Post Of-
fices across England, Wales, Scotland and Northern Ireland. A large number
of convictions have been quashed in the Court of Appeal (Criminal Division) of
England and Wales; the first 39 of which were reported in Hamilton and Oth-
ers [2021] EWCA Crim 577.
6. Since the first successful appeals reported in Hamilton and Others, a large
number of other SPMs prosecuted by POL have seen their convictions
quashed. The principles established in Hamilton and Others have been ap-
plied in each of those cases. In all the cases where the Court of Appeal (Crim-
inal Division) in London has quashed the convictions of SPMs, it has beena
prerequisite that the use of Horizon software was essential to the prosecution
of the Appellant (see§§120, 126 and 138 of Hamilton and Others). For rea-
sons explained by the Court of Appeal, it has been irrelevant to the determina-
tion of those appeals whether the Appellant pleaded guilty or not at first in-
stance (see §§69 and 129 of Hamilton and Others).
7. In the Applicant's case it is submitted that it is clear that Horizon software was
essential to the prosecution of him. Indeed, it is submitted that his is one of
the clearest cases of injustice caused by Horizon software to come before the
courts. It is a paradigm case of the means by which miscarriages of justice
were caused by Post Office reliance on Horizon software.
8. It is to be recognised that the Applicant was prosecuted by the Public Prose-
cution Service and was not prosecuted by POL. A number of convictions
which followed prosecutions by the Crown Prosecution Service in England
and Wales are now before the Court of Appeal (Criminal Division). None have
yet been the subject of substantive appeal hearings, but the Crown Prosecu-
tion Service has conceded in each case that, provided Horizon was essential
to the case, the terms of the Court of Appeal's judgment in Hamilton and Oth-
ers dictate that no different approach should be taken to the safety of the con-
viction. That concession has been accepted by the Court of Appeal in Eng-
land and Wales,
9. Accordingly, whilst recognising that Hamilton and Others does not bind the
Court of Appeal of Northern Ireland, because Horizon was essential to the
prosecution of the Applicant, it is submitted that the Applicant's convictions
are unsafe and should be quashed.
10. Before elaborating upon that submission and setting out the grounds of ap-
peal advanced by the Applicant, the terms of the judgment in Hamilton and
Others and the factual background to this appeal are explained.
The Judgment in Hamilton and Others
11. Following a four day hearing in the Court of Appeal (Criminal Division) of Eng-
land and Wales the Court ruled in Hamilton and Others that any POL prosecu-
tion of SPMs, where Horizon software was essential to that prosecution, con-
stituted an abuse of the process of the Court.
12. The Court explained the operation of the Horizon system at paragraphs 9 to
18 of the judgment.
13. It was designed and installed by ICL, which was taken over by Fujitsu Limited
in about 2002. The Horizon system provided a computerised system of ac-
counting within branch post offices, and between the branches and POL.
14. By recording ail transactions at a branch, Horizon calculated how much cash
and stock should be held in the branch. SPMs were required to make a daily
declaration of the amount of cash held at the branch. At the end of a trading
period (initially one week), the SPM was required to complete a Branch Trad-
ing Statement. The branch could not move into a new trading period without
making the requisite declaration.
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15. There was no facility within the Horizon system for SPMs to dispute Horizon's
figures: they were required instead, to contact the Helpline. if at the end of a
trading period there was a discrepancy or shortfall between the cash on hand
and the figures generated by Horizon, the SPM was required to make good
any shortfall, either by putting in his or her own money (“settling in branch") or
by asking for the sum to be deducted from his or her future income (“settling
centrally”)
16. The Court explained at paragraph 14 that:
“POL had a contractual right to seek recovery from SPMs for losses
relating to branch accounts. The precise terms and legal effect of the
relevant contractual provisions were considered in detail by Fraser J in
his “Common Issues” judgment. For our present purposes, it suffices to
Say that the approach adopted in practice by POL was that if Horizon
showed a shortfall, however inexplicable to the SPM, the SPM was re-
quired to make it good at the end of a trading period. Some of the ap-
pellants did so, using their own funds, or borrowing, to make good a
loss for which they did not in fact accept responsibility. Others re-
Sorted to offences of false accounting in order to cover upa
shortfall for which they did not accept responsibility and which
they were unable to make good”. (emphasis added).
17. Through ARQ data, the ability to trace transactions on Horizon was substan-
tial. Fujitsu recorded bugs, errors and defects in two types of document; a first
level PEAK (generated when an SPM phoned the Helpline) and a higher level
Known Error Log ("KEL"). (para. 17). None were ever disclosed in any crimi-
nal trial proceedings.
18. From paragraphs 19 to 32 inclusive of the Judgment, the Court set out the
history of problems encountered with Horizon and the response of POL.
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19. The initial roll-out of Horizon was delayed by technical issues. From an early
Stage of its introduction, some SPMs were experiencing, and reporting, dis-
crepancies and shortfalls in their branch accounts which they considered were
caused by faults in Horizon. (para. 19 of the judgment). In that vein, it should
be noted that this Applicant's case is one of the very earliest examples of a
Prosecution of this nature to be founded on Horizon data. Horizon had been
installed at the Brookfield Post Office in September 1999. The alleged of-
fences occurred over a period from 2000 to 2001. Minutes of POL board
meetings in 1999 demonstrated concerns that delayed acceptance and rollout
of the system (see para. 96 of the judgment). Plainly, Horizon was installed in
the Applicant's Post Office at a time when such concerns were being venti-
lated at the highest level in POL.
20. Despite the problems encountered by SPMs from the start, POL consistently
declined to initiate an independent review of the functionality of Horizon. In-
stead, its default position was that any losses were due to dishonesty or in-
competence on the part of the SPM. SPMs were either given time to pay the
debts that POL asserted were owed, or were Prosecuted.
21.In 2015, convicted SPMs began to make applications to the Criminal Cases
Review Commission (see para. 27 of the judgment). In 2015, POL ceased to
conduct private prosecutions. (see para. 29 of the judgment)
22. In 2017 a Group Litigation Order was made in respect of legal action pursued
by hundreds of claimants. Mr. Justice Fraser presided over the trial. At the
end of 2019, shortly before Fraser J was due to hand down his Horizon Issues
judgment, a settlement was reached. (see paras. 27 to 30).
23. The Court of Appeal dealt with the terms of the judgments that Fraser J
handed down before settlement was agreed in paras. 33 to 51 of its judgment.
Those paragraphs repay careful attention and it is hopefully sufficient for the
purposes of this document if only a timited number of the relevant findings
identified by the Court of Appeal are set out, as follows:
(i)
(i)
(ill)
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From para. 33 — “In his “Common Issues” judgment, Fraser J found that
POL, in demanding repayment of a shortfall shown by Horizon, misstated
the factual and legal liability of an SPM to make good any losses.
From para. 44 - Fraser J went on to note, in relation to a number of the
bugs found in Horizon, that POL did not communicate the existence ofa
bug to all SPMs or even to SPMs whose branches were known to have
been affected by it. He found POL’s approach to this in the proceedings
before him to be “simply extraordinary’. He referred at [442] to a number of
points which —
“... all lead to the same conclusion in my judgment, namely that the
Post Office ought to have notified, at the very least, all those SPMs
whose branch accounts had been impacted by this bug that this had
occurred, and that it had occurred as a result of a software bug. The
fact that the integrity of Horizon data was a live issue at this time
should not have influenced the decision to notify SPMs of a software
bug. Further, the Post Office's explanation in its submissions that
SPMs had their accounts “corrected in the ordinary course” is not a
suitable phrase, unless by “ordinary course” one means keeping the
cause or reason for the correction secret and therefore hidden from the
other party in the accounting transaction, namely the SPM.”
At para. 46 — “Fraser J later referred to part of the evidence of a witness
called before him, Mr Latif, who described how he had performed some
basic, routine steps to transfer a sum of £2,000 between terminals, only to
find that the sum disappeared from the Horizon system. Mr Latif had been
a trainer, entrusted by POL to train other SPMs. His evidence was none-
theless challenged by POL, whose witness on this point asserted that the
sum could not have disappeared as Mr Latif had described. Fraser J ac-
cepted Mr Latif's evidence and at [928]-[929] expressed his view as fol-
lows:
“928. The approach by the Post Office to the evidence of someone
such as Mr Latif demonstrates a simple institutional obstinacy or re-
fusal to consider any possible alternatives to their view of Horizon,
6 11-
(iv)
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which was maintained regardless of the weight of factual evidence to
the contrary. That approach by the Post Office was continued, even
though now there is also considerable expert evidence to the contrary
as well (and much of it agreed expert evidence on the existence of nu-
merous bugs).
929. This approach by the Post Office has amounted, in reality, to bare
assertions and denials that ignore what has actually occurred, at least
So far as the witnesses called before me in the Horizon Issues trial are
concerned. It amounts to the 21st century equivalent of maintaining
that the earth is flat.”
At para. 48 “Fraser J found that there were numerous bugs, errors or de-
fects in Horizon which were capable of causing, and did in fact cause,
shortfalls in post office branches, He found that the evidence he had heard
established 25 different bugs with the potential to impact upon branch ac-
counts, with evidence of actual lasting impact having occurred as a result
of 22 of them. Horizon itself did not alert SPMs to the existence of any
such bugs, errors or defects. His overall findings included the following:
“968. ... It was possible for bugs, errors or defects of the nature alleged
by the claimants to have the potential both (a) to cause apparent or al-
leged discrepancies or shortfalls relating to Subpostmasters’ branch
accounts or transactions, and also (b) to undermine the reliability of
Horizon accurately to process and to record transactions as alleged by
the claimants,
969. Further, all the evidence in the Horizon Issues trial shows not only
was there the potential for this to occur, but it actually has happened,
and on numerous occasions. This applies both to Legacy Horizon and
also Horizon Online. ...
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970. I accept the claimants’ submissions that, in terms of likelihood,
there was a significant and material risk on occasion of branch ac-
counts being affected in the way alleged by the claimants by bugs, er-
rors and defects. ...
978. ... In my judgment, there is a material risk that such a shortfall in a
branch's accounts was caused by the Horizon system during the years
when both Legacy Horizon and HNG-X were in use, which is 2000 to
2010 and 2010 to 2017 respectively. ...
983. ... there is a material risk for errors in data tecorded within Hori-
zon to arise in (a) data entry, (b) transfer or (c) processing of data in
Horizon in both the Legacy Horizon and HNG-X forms.”
(v) At para. 50 - “He concluded, at [975] and for the reasons which he ex-
plained in his Technical Appendix, that Legacy Horizon was -
“not remotely robust. The number, extent and type of impact of the numerous
bugs, errors and defects that [ have found in Legacy Horizon makes this
clear’,
24. From paragraphs 51 to 59, the Court of Appeal explained the process of re-
ferral of the cases before it. For the purposes of their referral, the CCRC was
of the view that the three most important points to emerge from the judgments
of Fraser J were:
1, That there were significant problems with the Horizon system and
with the accuracy of the branch accounts which it produced. There was
a material risk that apparent branch shortfalls were caused by bugs, er-
rors and defects in Horizon.
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2. That POL failed to disclose the full and accurate position regarding
the reliability of Horizon.
3. That the level of investigation by POL into the causes of apparent
shortfalls was poor, and that the Post Office applicants were at a signif-
icant disadvantage in seeking to undertake their own enquiries into
such shorifails.
25. The grounds of appeal to emerge from the CCRC’s analysis were twofold:
Ground 1: the reliability of Horizon data was essential to the prosecu-
tion and, in the light of all the evidence including Fraser J's findings in
the High Court, it was not possible for the trial process to be fair; and,
Ground 2: the evidence, together with Fraser J's findings, shows that it
was an affront to the public conscience for the appellants to face prose-
cution.
26. The appeal before the Court of Appeal of England and Wales proceeded to
hear both grounds advanced by the Appellants.
27. The legal framework for the Court's consideration of the appeals is set out at
paragraphs 60 to 69 of the judgment. At paragraph 68, the Court observed:
68. Where a defendant has entered an unequivocal and intentional
plea of guilty, the resultant conviction will rarely be found to be unsafe.
It is nonetheless possible for fresh evidence to be admitted and for an
appeal to be allowed in such circumstances: see R v Jones [2019]
EWCA Crim 1059 at [25]. In R v Togher and others it was held that a
conviction may be quashed on grounds of abuse of process even when
a guilty plea has been entered, though only if “it would be inconsistent
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with the due administration of justice to allow the pleas of guilty to
stand” (see paragraph [33]). In a case in which a defendant who has
pleaded guilty appeals against his conviction on grounds of non-disclo-
sure, the court must consider whether the plea was entered in igno-
tance of evidence going directly to his guilt or innocence. As it was ex-
pressed in R v Togher and others at [59], the question is whether the
guilty plea was “founded upon" the irregularity of non-disclosure. InR v
Early and others [2002] EWCA Crim 1904 at [18] the court emphasised
the crucial importance of a Prosecuting authority making full relevant
disclosure before trial. It held that a defendant who pleaded guilty at an
early stage should not, if adequate disclosure had not been made, be
in a worse position than a defendant who, as a consequence of an ap-
plication to stay the Proceedings as an abuse, benefited from further
orders for disclosure culminating in the abandonment of proceedings
against him.
28. The judgment ultimately reached by the Court of Appeal and the reasons for it
are set out at paragraphs 120 to 138 of the judgment.
29. The Court ruled that, in Horizon cases (that is to say, where Horizon data was
essential to the prosecution), both Grounds of Appeal formulated by the
CCRC were made out. (POL had conceded prior to the appeal that Ground 1
was made out in relation to all Horizon cases, but had resisted Ground 2). The
Court quashed the convictions of all appellants whose prosecutions could be
categorised as Horizon cases.
30.{n respect of Ground 1 of the appeals, the Court noted that:
121. We have no doubt that the concessions made by POL in relation
to Ground 1 were rightly and Properly made. Those concessions relate
to failures of investigation and disclosure in all the “Horizon cases”
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across a period of 12-13 years. In each of those cases, there was no
independent evidence of an actual shorifall, and it was essential to the
prosecution case that the Horizon data was reliable. We accept and
adopt Fraser J’s findings that throughout the relevant period there were
significant problems with Horizon, which gave rise to a material risk
that an apparent shortfall in the branch accounts did not in fact reflect
missing cash or stock, but was caused by one of the bugs, errors or
defects in Horizon. POL knew that there were problems with Horizon.
POL knew that SPMs around the country had complained of inexplica-
ble discrepancies in the accounts. POL knew that different bugs, de-
fects and errors had been detected well beyond anything which might
be regarded as a period of initial teething problems. In short, POL knew
that there were serious issues about the Teliability of Horizon. If POL
needed further information, it could have obtained it from Fujitsu. It was
POL's clear duty to investigate all reasonable lines of enquiry, to con-
sider disclosure and to make disclosure to the appellants of anything
which might reasonably be considered to undermine its case. Yet it
does not appear that POL adequately considered or made relevant dis-
closure of problems with or concerns about Horizon in any of the cases
at any point during that period. On the contrary, it consistently asserted
that Horizon was robust and reliable. Nor does it appear that any at-
tempt was made to investigate the assertions of SPMs that there must
be a problem with Horizon. The consistent failure of POL to be Open
and honest about the issues affecting Horizon can in our view only be
explained by a strong reluctance to say or do anything which might
lead to other SPMs knowing about those issues. Those concerned with
Prosecutions of SPMs clearly wished to be able to maintain the asser-
tion that Horizon data was accurate, and effectively steamrolled over
any SPM who sought to challenge its accuracy.
122. We respectfully accept and adopt the findings of Fraser J as to
problems with Horizon being raised by SPMs from 2000 onwards, in re-
lation both to Legacy Horizon and Horizon Online, and in particular his
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finding8 that throughout the relevant period the bugs, errors and de-
fects in Horizon could, and on numerous occasions did, cause appar-
ent discrepancies and shortfalls in branch accounts.
123. These pervasive failures of investigation and disclosure went in
each case to the very heart of the prosecution. Whatever charges were
brought against an individual appellant, and whatever pleas may ulti-
mately have been accepted, the whole basis of each prosecution was
that money was missing from the branch account: there was an actual
shortfall, which had been caused by theft on the part of the SPM, or at
best had been covered up by false accounting or fraud on the part of
the SPM. But in the “Horizon cases”, there was no evidence of a short-
fall other than the Horizon data. If the Horizon data was not reliable,
there was no basis for the prosecution. The failures of investigation and
disclosure prevented the appellants from challenging, or challenging
effectively, the reliability of the data. In short, POL as prosecutor
brought serious criminal charges against the SPMs on the basis of
Horizon data, and by its failures to discharge its clear duties it pre-
vented them from having a fair trial on the issue of whether that data
was reliable.
124. In considering whether these failures justify a finding of category 1
abuse, we bear in mind that a stay on grounds of abuse is an excep-
tional remedy. It is on the face of it remarkable that in all the “Horizon
cases" the appellants contend that they would have been entitled to
that exceptional remedy if POL had made full disclosure at the time,
and had nonetheless persisted in pursuing the prosecutions. But these
are remarkable appeals, and the fact that similar considerations apply
to numerous cases is not in these circumstances a bar to a finding of
category 1 abuse.
125. We also bear in mind that many of the appellants pleaded guilty.
But as we have already said, R v Togher and others provides clear au-
thority that a conviction following a guilty plea may be quashed on
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grounds of abuse of process where the plea was “founded upon” the
irregularity of non-disclosure. We have no doubt that all the guilty pleas
of the appellants in “Horizon cases" were founded upon POL’s failures
of investigation and disclosure. The whole conduct of the prosecutions
was based upon the constant assertion that the Horizon data was relia-
ble and that the money must have been stolen, or at least a shortfall
dishonestly concealed. The appellants were denied the material which
could have been used to question
that assertion. They were, moreover, in the very difficult position of be-
ing charged with offences of dishonesty committed in breach of their
employer's trust. They are likely to have been advised that imprison-
ment is very often imposed for such offences, and that the mitigation
which would be available to them if they pleaded guilty could therefore
be of particular importance. Many may well have felt that they had no
teal alternative but to plead guilty on the most favourable basis which
could be agreed with POL.
126. In those circumstances, we are satisfied that a fair trial was not
possible in any of the “Horizon cases” and that Ground 1 accordingly
succeeds in each of those cases.
31.In respect of Ground 2, the Court analysed the position as follows:
128. In considering whether the failures of investigation and disclosure
which justify a finding of category 1 abuse are so serious as to justify
also a finding of category 2 abuse, the following considerations are rel-
evant.
129. First, we reiterate that POL deliberately chose not to comply with
its obligations in circumstances in which its prosecution of an SPM de-
pended on the reliability of Horizon data. It did so against a background
of asserting that SPMs were liable to make good all losses and could
lose their employment if they did not do so. It did so despite the fact
13 -18.
that POL itself had selected the SPMs as suitable Persons to hold their
position of trust. In the High Court proceedings, one of the agreed facts
was that POL “incurs expense and time-costs in recruiting (including
advertising for applicants and assessing and selecting applicants) and
training new Subpostmasters”. Yet if Horizon showed a shortfall which
an SPM did not accept as correct, POL invariably accepted the position
shown by Horizon, refused to countenance any possibility that the ap-
parent shortfall may be the result of an error or bug in the system, and
was quick to assume dishonesty on the part of the SPM. As we have
seen, in internal documents relating to at least some cases, an SPM
who attributed a shortfall to a system error was dismissed as ‘jumping
on the Horizon bandwagon’. These were very serious failures by POL
to fulfil its obligations as a prosecutor. We are driven to the conclusion
that throughout the period covered by these prosecutions POL's ap-
proach to investigation and disclosure was influenced by what was in
the interests of POL, rather than by what the law required.
130. Secondly, whilst we agree in principle that any issue of abuse of
process must be considered in the light of the facts and circumstances
felevant to the specific individual case, we are faced in these appeals
with clear evidence of systemic failures by POL over many years.
Given that the same failures occurred in case after case, year after
year, we think that later events shed legitimate light on the approach of
POL to earlier prosecutions. We note that even the four cases in group
A cover a period of 5 years, with the appellants being convicted be-
tween 2006 and 2011. We also note that no document has been shown
to us in which any POL employee or official made any adverse com-
ment upon the incorrect approach demonstrated in the documents to
which Fraser J, and we, have referred. Nor have we seen any contem-
poraneous document criticising the misconduct which has caused POL
to make concessions as to Ground 2 in relation to the four appeliants in
group A. We see powerful force in the points that as late as summer
2013 it was still necessary for Mr Clarke to spell out basic principles,
and that the response to his advice of at least some personnel! was to
14
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suggest that information should not be recorded, in the hope that it
would therefore not be disclosable. We think it clear that throughout the
relevant period, POL as prosecutor demonstrated, as Fraser J found in
the Horizon Issues judgment at [928], “a simple institutional obstinacy
or refusal to consider any possible alternatives to their view of Horizon,
which was maintained regardless of the weight of factual evidence to
the contrary”. Moreover, the longer that approach persisted, the more
POL was able to, and did, rely upon its own past abusive conduct by
asserting that no previous challenge to Horizon had succeeded,
131. In those circumstances, we are unable to accept POL’s submis-
sion that in relation to Ground 2 there may be a distinction to be drawn
in POL's favour between the seriousness of its conduct at an earlier
time, and the seriousness of its conduct at a later time. POL knew that
there were problems with Horizon which delayed its rollout. It knew, as
Fraser J found, that SPMs were reporting unexplained discrepancies
and shortfalls from 2000 onwards. The persistence of those reports
made it impossible to assume that all the initial problems, and any sub-
sequent teething problems, had been resolved. It was able to obtain all
relevant information from Fujitsu if it wanted to, and the fact that its own
contractual arrangements meant that it would have to incur expense in
doing so could not possibly justify its repeated failures to comply with
its legal duties. Moreover, to borrow Fraser J's phrase (the Horizon Is-
sues judgment at [1018}), POL “ought to have known how its own sys-
tem works”,
132. Thirdly, POL as prosecutor knew that the consequences of con-
viction for an SPM would be, and were, severe. Later in this judgment
we will mention individual cases, but it is important here to state that
many of these appellants went to prison; those that did not suffered
other penalties imposed by the courts; all would have experienced the
anxiety associated with what they went through; all suffered financial
15 -20-
losses, in some cases resulting in bankruptcy; some suffered break-
downs in family relationships; some were unable to find or retain work
as a result of their convictions — causing further financial and emotional
burdens; some suffered breakdowns in health; all suffered the shame
and humiliation of being reduced from a respected local figure to a con-
victed criminal; and three ~ all “Horizon cases” — have gone to their
graves carrying that burden. Inevitably, the families of the SPMs have
also suffered. In each of the “Horizon cases’ it is now rightly conceded
that those human costs and consequences were suffered after the de-
nial by POL of a fair trial. We unhesitatingly accept and endorse {coun-
sel's] submission that these were far more than cases of “simple” non-
disclosure.
133. Fourthly, and most importantly in the context of category 2 abuse,
POL’s failings of investigation and disclosure (in Ms Busch’s phrase)
“directly implicate the courts”. If the full picture had been disclosed, as
it should have been, none of these prosecutions would have taken the
course it did before the Crown Court. No judge would have been
placed in the unhappy position of learning — as some judges (or retired
judges) will do if they read this judgment — that they unwittingly sen-
tenced a person who had been prevented by the prosecutor from hav-
ing a fair trial.
135. Lastly, in relation to the balancing exercise which issues of cate-
gory 2 abuse require, we accept the appellants' submissions that if the
full picture had been disclosed, as it should have been, the public inter-
est in prosecution would have been heavily outweighed by the need to
maintain public confidence in the criminal justice system. The charges
were serious, but in all the “Horizon cases” the foundation of the
charges — namely, that there was an actual shortfall ~ would have been
in issue if the full picture had been known. There was no reason why a
prosecution had to be hurried through as a matter of urgency, and no
excuse for POL's failure to fulfil its duties. Moreover, whilst it is not nec-
essary for an accused who relies on category 2 abuse to prove that the
16
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prosecutor acted in bad faith, we are troubled by contemporaneous in-
ternal documents in which POL expressed concem that disclosure in
one case of problems with Horizon could have an impact on other
cases. Public confidence in the criminal justice system would be se-
verely damaged if a prosecuting authority were permitted to give prior-
ity to such a consideration over compliance with its duties as a prose-
cutor.
137. In those circumstances, the failures of investigation and disclosure
were in our judgment so egregious as to make the prosecution of any
of the “Horizon cases’ an affront to the conscience of the court. By rep-
resenting Horizon as reliable, and refusing to countenance any sugges-
tion to the contrary, POL effectively sought to reverse the burden of
proof: it treated what was no more than a shortfall shown by an unrelia-
ble accounting system as an incontrovertible loss, and proceeded as if
it were for the accused to prove that no such loss had occurred. Denied
any disclosure of material capable of undermining
the prosecution case, defendants were inevitably unable to discharge
that improper burden. As each prosecution proceeded to its successful
conclusion the asserted reliability of Horizon was, on the face of it, rein-
forced. Defendants were prosecuted, convicted and sentenced on the
basis that the Horizon data must be correct, and cash must therefore
be missing, when in fact there could be no confidence as to that foun-
dation.
138. Ground 2 therefore succeeds in each of the “Horizon cases’.
32.As is foreshadowed at paragraph 6 above, the convictions of a number of
other SPMs have subsequently been quashed; some have been conceded
but are waiting to be quashed; some await argument; some applications for
leave to appeal are currently being considered; and still more appeals are be-
ing prepared.
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33. The Crown Prosecution Service has now also indicated that, given the terms
of the judgment in Hamilton and Others, it would not seek to oppose any ap-
peal in an ‘Horizon case’.
The Factual Background to the Applicant's Case
34.Mr. McLaughlin had been a schoolteacher, teaching languages, before be-
coming the SPM of Brookfield Post Office in 1999. He was a man of good
character and has never offended again since the convictions to be consid-
ered by this Court. He was the SPM of Brookfield Post Office from July 1999
to July 2001.
35. The attention of POL was drawn to him and transactions at his Post Office
when it was noticed that there were discrepancies between the number of
foils which the Horizon generated records showed had been cashed, com-
pared to the number of foiis which were actually attached to that printout,
36. For example, on 21 December 2000, the Horizon record showed that two foils
to the value of £125.94 had been cashed, whereas only one foil to that value
was received. Similarly, on 27 December 2000 the Horizon record showed
that two foils to the value of £87.51 had been cashed, whereas only one foil to
that value was received.
37.An audit of the Applicant's Post Office was carried out on 26 July 2001. He
was interviewed under caution by Post Office investigators. The following con-
tents of that interview are of particular note:
) Exhibit 26 - p.352 — the Applicant had serious balancing problems with
the use of Horizon
(i) Exhibit 26 - p.353 — the Applicant explained that Horizon was intro-
duced to Brookfield Post Office in September 1999
(ii) Exhibit 26 - p.364 — the Applicant recounted further Horizon balancing
problems
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(iv) Exhibit 26 - p.365 — the interviewer informed the Applicant that he has
checked the records from the system and observes that the system
could be wrong
(v) Exhibit 26 - p.366 ~ the Applicant recounted how he had large unex-
plained shortages
(vi) Exhibit 26 — p. 367 — the Applicant explained that the balancing of the
accounts stores up problems for the future
(vii) Exhibit 26 - pp.371 and 372 - the Applicant provided more explanation
of the problems with balancing
(vill) Exhibit 26 - p.379 — the Applicant accepted adjusting the figures to bal-
ance
(ix) Exhibit 26 - p.384 — the interviewer Pointed out that a change to
the transaction log has happened when the PO is closed. That
change was from 17 x 206.60 foils to 18 x 206.60 foils
(x) Exhibit 26 - p.385 — the interviewer pointed out that Brookfield Post Of-
fice dealt with over £200,000 of pensions each week
(xi) Exhibit 26 - p.393 — the interviewer put to the Applicant the allegation
of false accounting — the Applicant denied it and explained that all
SPMs do the same
(xii) Exhibit 26 - p.400- the Applicant stated that he thought it was not a
criminal offence to do what he did
38. The Applicant was suspended after that interview and his contract was termi-
nated approximately one month later. A different SPM took over from the Ap-
plicant but the problems with accounting in Brookfield Post Office continued
under her stewardship. If anything, as is detailed below, the problems became
worse. Brookfield Post Office was eventually closed in February 2002.
39. The Applicant was charged with the offences set out in the Statement of Com-
plaint. Essentially, they comprise 15 charges of false accounting wherein it is
alleged that the Horizon record of the number of foils received has, in each
19 2h
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case, overstated the number of foils actually received. The Applicant is al-
leged to have altered the record in order to receive money that was never
paid out.
40. He was arraigned and pleaded not guilty to all counts on 27 April 2004.
41. Instructing Solicitors have sought to secure the case papers from his previous
solicitors in order to verify the applicant's account of the Proceedings against
him. On 20 October 2021, Mr. Paut Dougan of JJ Rice solicitors kindly in-
formed the Applicant's solicitors by email that:
We have reviewed our closed file archive and off site storage. It seems
the file itself was closed on the 19" June 2018 and archived; and then
destroyed a number of years ago. We do not have a soft copy of any of
the materials identified in your email unfortunately.
42. What follows is the Applicant's best recollection of the proceedings against
him. We have forwarded the grounds of appeal to the Applicant's trial counsel,
Mr. Jon Paul Shields, in order that he may check the factual accuracy of them.
Itis to be hoped that any records held by the PPS will be disclosed as part of
the appeal proceedings now initiated.
43. The Applicant believes he submitted a defence statement denying the of-
fences.
44.He also served an expert accountant report prepared by Messrs. McClure
Walters which is returned to below. That report was received by his then solic-
itors, JJ Rice in late December 2004. A copy is attached as Appendix 1 to
these grounds of appeal.
45.After a number of adjournments of the date fixed for trial, the Applicant even-
tually pleaded guilty to all counts on 16 February 2005. He did so because he
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was advised to do so. His plea was on an agreed basis that he had made no
actual gain from the offences to which he pleaded guilty.
46.He was fined £1100 on the same day and that was the end of the matter.
There were no confiscation proceedings following the sentence.
The Expert Accountant’s Report
47. In the light of what is now known about the unreliability of Horizon, the ac-
countant’s report prepared by McClure Walters is powerful evidence of the
miscarriage of justice that the Applicant has suffered,
48.As is pointed out at §§4.4 to 4.6, the allegations against the Applicant were
based on the assertion that the inclusion of a transaction on the weekly inputs
summary which is not supported by a foil is evidence that cash has been mis-
appropriated and the Applicant was responsible for it. No genuine real cash
shortfalls were ever alleged. Because the case relied completely on that
weekly inputs summary, Horizon was therefore essential to the prosecution of
the Applicant and his case can undoubtedly be described as ‘an Horizon case’
within the terms of Hamilton and others.
49. But the report of the accountants goes further.
50.At 4.7, the authors report their difficulties in understanding a Group Total
Casting Difference of £201.30 for the week of 31 January 2001. It shows that,
whilst no units have been claimed, £226.30 has been recorded in the value
column. The authors report that they have no explanation for this. They say at
§4.9:
Itis extremely unusual that the computer system should allow such an
entry to occur. The claim as set out at Appendix 5 is not supported by
any detailed adlist or any other information on which [sic] would give
any Indication of how this discrepancy has arisen. The transaction log
21 -26-
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for this particular period is not available. We are therefore unable to
comment further in relation this item.t
51. Knowing what is now known about the deficiencies of Horizon, such an unu-
sual event for a computer is now much more readily explicable.
52.Moreover, at §5.4 the authors identify negative balances for which there
would be no incentive for the Applicant to create, as is fully explained at §5.5.
The authors point out that such a Position could be due to ongoing computer
error.
53.At 5.13, the authors are unable to explain why the number of transactions as
Per the transaction logs, compared to the number of transactions as per the
daily adlists and weekly summaries do not agree. (In hindsight, that finding is
symptomatic of Horizon unreliability). And it is also noted that some of the
questioned transactions could not have involved the Applicant.
54. From 5.15 to 5.25, the authors explain how the accounting problems at
Brookfield Post Office continued and intensified after the Applicant had been
replaced.
55. The overall picture is one of unexplained accounting difficulties with no dis-
cernible actual shortfall. Again in hindsight, the pattern is classically sympto-
matic of Horizon unreliability.
Submissions
56. It is submitted that Horizon data was essential to the prosecution of the Appli-
cant. The case could not have proceeded without it. it can accordingly be de-
scribed as an Horizon case.
ee
‘Asis pointed out at §5.10 of the feport (and detailed at Appendix i), the transaction data was routinely de-
stroyed by Fujitsu after 18 months.
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57. But, additionally in this case, the tangible effects of Horizon unreliability are
clear to see in the report prepared by McClure Walters.
58. The Applicant's conviction is unsafe,
Conclusions
59. The Court is respectfully asked to grant leave to appeal to appeal out of time
and to quash the convictions of the Applicant on the basis of the grounds ad-
vanced,
Tim Moloney QC
Bar Library
Belfast
14 October 2021
Annex A
LIST OF AUTHORITIES
NAME OF PROCEEDINGS: R-v- Alan McLaughlin
PARTY PROVIDING THE LIST: Applicant/Appellant
NAME OF COUNSEL: Tim Moloney QC
CASES
1*. Rv Togher and others [2001] 1 Cr App R 33 at para(s) [33] & [59]
2* Bates & Ors v Post Office Ltd ((No.3) "Common Issues") [2019] EWHC 606 (QB) at paras
(44), (222), {542}, [1121],[1115]
23 -28-
3*. Bates & Ors v the Post Office Ltd (No 6: Horizon Issues) (Rev 1) [2019] EWHC 3408
(QB) at paras [442], (928-929}, [968-970], [975], [978], (983).
4*. Hamilton and Others [2021] EWCA Crim 577 at paras [9], [14], [17-69], [96], [120-138].
5. Rv Early and others [2002] EWCA Crim 1904 at para [18].
6. R v Jones [2019] EWCA Crim 1059 at para [25].
24
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eS ‘Number One
AYN) McClure Watters tenyon Gry
-~ 4 Chartered Accountants Belfast 871 3GP
“oP Northern Ireland
> Gureet: 8135/RWG/SA
Your ret, TM/MP/CRIM
John J Rice & Co
-~ Solicitors
9-11 Crumlin Road
Belfast
~ BT14 GAA
22" December 2004
4
“Dear Sir,
Your Client: Alan McLaughlin
~ Further your letter of 14" December 2004 Please find enclosed a copy of our revised draft
report incorporating the additional information gathered from the consultation of 3 November
2004. I as yet have not received any comments on our draft report of 19" October 2004 and
~- would appreciate any observations so that may issue the enclosed report in its final form.
It has also come to my attention that although we quoted for 45 hrs of work this has now
- been exceeded significantly. { have attached an analysis of our time to date and would
apologise for the oversight in not obtaining prior approval for this level of time input. I would
be pleased to receive guidance on how we should Proceed in relation to these costs
St If you have any queries regarding the above please do not hesitate to contact me.
Partin }
RR, McClure FO A OS Katers £6 4, J Mansion FCA FABRE. DME Gray ca AW Gardiner FCA. {
Geccies {
18 Baw LL OETA P lrmncan CPA 2 tan AMA MC Got Sone Agreers Ke Cw tempsen sates a
1 Business on :80 Aenabhe ot Welnnd
Authoused by ihe Insiiise 9f Cnariured Accountunis .n lrelang 10 carry on invest
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-31-
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Consultants Hrs
{Description
Initial review «of materiaVexhibits 14
Meeting wit A McLaughlin (26/05/04) and review of information gathered 5
Preparation «f letters dated 14/07/04 and 30/07/04 2
Consultation vf 1/09/04 and review of exhibits and information gathered 5.5
Preparation v! letters dated 2/09/04 and 23/09/04 2
Consultation vf 8/09/04 and review of exhibits and information gathered 5.5
Consuttation vf 29/09/04 and review of exhibits and information gathered 55
Review of exnliional information received on 10, 13, 15 Sep 2008} > ——I
[Review of ad\tilonal information received on B/iOm4 7 7
Analysing ami Summarising Claim 7
Analysing ant Summarising Weekly Cash Account Summafies 2
Preparation «! draft report and associated Appendices [26
Consuttation vf 20/10/04 15
Consultation vf 3/11/04 and review of exhibits and information gathered 3
Review of aclillonal information received 3
Revision of «htft report 5
Total 05]
Description Partner ca
Initial review «il Material/exhibits TT
Consultation ot 1/09/04 z
Consultation « 29/09/04 3
Consultation «! 20/10/04 75
Review of dri! report 4
Total 705
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BI3SRWGISA,
TWDM
John J Rice & Co
Solicitors
9-11 Crumiin Road
Belfast
BT14 GAA
21" December 2004 ¥
Dear Sirs,
Your Client - Alan McLaughlin
In accordance with your instructions we have pleasure in setting-out-below our comments in
respect of the charges under Section 17 (1) (2) OF the Theft Act (Northém ireland) 1969
against your client Alan McLaughtin. +
For your convenience, our Feport is set out under the following main headings:
Section Z '
1 Introduction .
2 Background, rides,
3 The Horlzah Gomputer System and Post Office Procedures °
4 Statement of Compiatt
5 Comments in relation to the Statement of Compiaint
6 Condiusions
Schedute
1 Export Witness Declaration
Appendices
A Summary of Claim
8 Daily Report (Horizon)
c Weakly Summary (Horizon)
fo) Cash Account (Final) (Horizon)
€ Missing Dockeis/Foils Ciaim Example
F Group Total Casting Differences Claim Example
G Adlist + to Main Summary Claim Example
H Transaction Log - +1 July 2001
1 Transaction Log Avaitability
J Sample Transaction Logs
K Audit Report ~ 34 May 2001
L Audit Report ~ 11 January 2002
M Weekly Cash Account Summary
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We would draw your attention to the fact that our report is strictly limited to financial matters
and should not be construed as expressing opinions on matters of law, which are for the
Court to determine. However, it necessarily reflects our understanding of such matters.
The report provides financial and arithmetical information to assist you, Counsel and the
Court in assessing the case against Mr McLaughlin. This can only be done in the light of
all of the evidence, arguments and contingencies that may have to be considered.
1. INTRODUCTION
4 In accordance with the instructions from John J Rice &.Co* Solicitors we have
reviewed the Statement of Complaint and have commented thereon:on behalf of the
Defendant, Mr Alan McLaughlin. The report-has been prepared ‘on- behalf. of Mr
McLaughlin and has been based on information provided to us by’ the Post ‘Office and
as set out in the Statement of Complaint prepared by Chief Superintendent J Lindsay-
White, District Commander of the Antrim Road Police Service of Northern Ireland and
the Department of the Director of Public Prosacutions.. We have not carried out any
verification of this information other than as specifically stated In this report.
1.2 In undertaking the assignment we have reviewed the following key documents
provided to us:
(i) ‘Statement of Complaint detailing 15 charges under Section 17 (1) (a) of the
Theft Act (Northem Ireland) 1969 against Mr Alan McLaughlin;
(ii) Letter from the Départment of the ‘Director of Public Prosecutions dated 1
June 2003 detailing that the 15 charges at (i) above are specimen charges
and that it is intended to put forward evidence in relation to £10,288.47 of an
alleged loss;
(iti) Breakdown of £10,288.47 alleged loss; °
{iv) ‘List of Exhibits;
(vy) Available transaction and events logs from Fujitsu;
(vi) I Weekly cash reconelliations;
(vii) “ Brookfield Post Office Call Analysis 1o Help Desk (June 99 - Feb 02); and
{wili) Audit reports of Brookfield Post Office dated 31/05/01 and 41/01/02
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2, BACKGROUND
2.1 We understand that the Defendant was the sub-postmaster at Brookfield Post
Office, Tennent Street, Belfast from July 1999 to July 2001. We also understand
that he was self-employed in this regard operating the Post Office under a franchise
agreement. Although he was self-employed he was paid a salary by the Post Office
reflecting the amount of monthly business conducted.
2.2 The offences in question are alleged to have occurred in the course of his
employment from December 2000 to July 2001 and reiate to the alleged
misappropriation of cash by the Defendant. The total amount claimed is
£10,288.47 as detailed at Appendix A. This amount is discussed in detail at Section
4 of our Report.
2.3. The Statement of Complaint schedules a sample of the alleged offences and each
offence is “worded” as follows :-
“That you (the Defendant) .... dishonestly and with a view io you for yourself or
another or with the intent to cause foss to another; falsifiéd a document required for
an accounting purpose .... contrary to Section 17 (1) (a) of the Theft Act (Norfhern
tretand) 1969",
2.4 On 26 July 2001 the Post Office sent an.Audit Team to investigate the affairs of the
business and suspended the operation of the business.
2.5 The Defendant's contract was terminated approximately 1 month after the audit
team investigation.
2.6 The Post Office continued to operate under the control of an agent but was
eventually closed in February 2002.
I
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3.2
3.3
3a
THE HORIZON COMPUTER SYSTEM AND POST OFFICE PROCEDURES
The following is our understanding of the Horizon Computer System which was
operated at Brookfield Post Office and the associated procedures in relation to the
posting and processing of Pension and Allowances transactions. This
understanding is based on our discussions with Mr McLaughlin, Ms Suzanne Winter
(Post Office Investigating Officer) and our review of the various documentation
supplied.
(i) The foit from a particular Pension/Allowances Book (P/A Book) is input to the
computer system. The employee must key in the amount of the transaction
and the identifying group. It is possible that various differing amounts can be
input in relation to a particular transaction.
(ii) Cash given to the customer and the foll ls removed from the P/A Book.
(iii) The foil is placed in a tray which separately identifies each payment and
allowance group. :
(iv) At any point in time, an “adlist” can be printed (showing every group, no per
group, total value) and checked to the total number and values foils per the
tray. This is generally taken either once or twice daily.
(v) Any discrepancies identified are rectified on the computer system at this stage
and a final report is printed (Appendix B) and wrapped around the
counterfoits.
(vi) The system is balanced forward so that the new transactions are recognised
in a new adlist. .
(vii) Every Wednesday at {pm a weekly summary is printed (Appendix C) which
shows all transactions per group for each time an adiist has been closed off.
(viii) A weekly cash and stock count is performed and totals input to the Horizon
system.
(ix) A cash reconciliation report is printed (Appendix D) from the Horizon system
comparing the theoretical closing cash balance (using fast weeks b/f and all
cash input and output transactions) and the actual cash balance counted.
Any discrepancies between theoretical cash held and actual cash held are
noted in the discrepancies table on the front page of the cash account.
(x) The weekly summary and aif the counterfoils are sent to the Paid Order Unit,
Lishatly, Londonderry.
We understand from Mr McLaughlin (confirmed by Ms Suzanne Winter) that 4 tills,
operating a joint balancing system where in use at Brookfield Post Office. This
system combined the transactions of ali 4 tills so that all reports showed a collective
position.
Each eniployee had a separate logon and user name with their password changing
every month (per Alan McLaughlin}
Tne iirizon System has the capatiity to i@producs reperts showing all
transactions completed during speciied period. These ‘ports known as
Transaction Logs” delail ihe user, the date, the transaction group and the
transaction amount. It is noted! that the data recorded on these reports is not
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ie
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transaction specific /.e. specific foils inputted cannot be directly traced against
specific User IOs.
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~ 23
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STATEMENT OF COMPLAINT
A copy of the schedule detailing the £10,288.47 loss is atlached at Appendix Aand
is summarised as follows:
5
Nature of “Logs Clalni.? xs » * Totat
Keying Errors (763)
Reversal of Transactions {224.96}
* (229.58)
Missing Dockets/Foits B 6422.23
Group Total Casting Differences 201,30
Adlist ¢ Main Summary tena 3,694.52 .
Total »,_ 10,288.47
We have not commented on the above Keying Errors and Reversal of Transactions
which total (£229.58) as these reduce the’total claimed against Mr McLaughlin and
also because they are not considered matetial in the context of the overall claim.
We have commented below On the each ofthe emaining categories as follows:
Missing Dockets/Folls - £6,/ 42223 ’
The claim in relation to.missing docketsteils arises due to the number of inputs in
relation. 0 a particular Perision and Allowance grouping {P/A grouping) not equalling
the number of foits received i.e. the number of P/A inputs on the weekly summary
and daily adlist equal each other, but are not matched by the number of foils
received
‘Attached at Appendix E is an.exampie of the Post Office workings in relation to the
claim for the week ending 27 December 2000. The variance in relation io this week
totals £213.45 (detailed at Appendix A) and is analysed as follows:
Date er Horizon Per Foils Variance
tl £
21200 I 13 I 2x£125.94 claimed I 1 x£125.94 received 125.94
271200 I 13 I 2x£87.Sicaimed I 1 x £87.51 received 87.51
213.45
The claim is based on the assertion that inclusion of a transaction in the absence of
a Supporting counterfoil is evidence thal cash has been misappropriated and that
Mr McLaughlin was responsible for the discrepancy and hence the alleged toss.
La
ad
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Group Total Casting Differences - £201.30
4.7 The above loss in relation to group total casting differences can be broken down as
follows: .
Date Group I PerHorizon Per Foils Variance
: : £
31/01/01 7 Iox€226.30claimed I 0 x £226.30 received 226.30
04/04/01 42 I-1x£25.00claimed I 0x £25:00 received (25.00)
: By 201.30
4.8 Attached at Appendix F are the Post Office, workings in relation to the claim of
£226.30 for the week ending 31 January 2001. The-workh show that although
zero units have been claimed in the volume, ‘olamin, an amount of- £226.30 has
registered in the value column. At present we have an explanation.or know,
of a reason as to why this did and could have: ‘occuired, _
49 It is extremely unusual that the computer system should allow such an entry to
occur. The claim as set out at Appendix F is not supported by-any detailed adiists
or other documentation on which would give any indicatlon of how this discrepancy
has arisen. The transaction log for'this pat licular period is not available. We are
theretore unable to comment further in relation to this Item.
Adiist # Main Summary - £3,894:52
due to the number of iaputs.in relation to @ particular P/A grouping on the weekly
summary not equalling thie ‘daily adlist and the number of fails received. After a
period of trading it is possible to print an adlist which will agree to the number of
foils processed in that ‘petiod. “If, after this adlist has been printed an aditional
transaction Is processed; whenever the weekly summary is printed, the total
volumes and values will not agree.
4.40 The claim in relation to the ‘adlist printoytnot equalling the main summary arises
4.41 Attached at Appendit.G is an example of the Post Office workings in relation to the
claim for the week ending 13 June 2001. The variance in relation to this week totals
£67.50 (per Appendix A) and Is detailed as follows:
e Group I Sup tora) of Adiist [Main Summary PerI Variance
‘zon Horizon
£
13/06/01 41> I-49 foils at £3.270.78 I 50 foils at £3338.28 67.50
67.50
4.12 Whilst the means by which the difference is identified under this heading is different
from missing dockets (see 4.4 lo 4.6) the fundamental issue is the same i.e. that
transactions have been processed which are not supported by P/A foils.
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COMMENTS IN RELATION TO THE STATEMENT OF COMPLAINT
In broad terms the information provided by means of exhibit and discovery does
support the assertion that transactions have been processed through the Horizon
system which are not supported by apprapriate payment counterfoils.
These transactions relate to cash payments made to the public/customers of the
Post Office and as such the absence of appropriate vouchers may be an indication
that cash has been deliberately misappropriated, +
However the following issues relating to the nature of the ¢laim and the “adequacy”
‘of supporting evidence are highlighted,
Negative Balances
following negative balances are incorporated into the alleged ‘loss ‘totalling
£10,288.47 (Appendix A): 5
E
Keying Errors (12.57)
Reversals (221,95)
Missing Dockets (221.65)
Group Total Casting (25.00)
Adlist # to Main Summary (260.45)
- (741.62)
The above amounts have, in effect been contrad against alieged losses of
£11,030.09 to arrive at the loss of £10,288.47 {i.e. £11,030.09 less £741.62 =
£10,288.47). Mr Mctayghiin ‘has been accused of dishonestly and with a view to
gain for himself or anotlier or’ with intent to cause loss to another, falsifying
documents required for accounting ‘Purposes. With the inclusion of negative
batancés totalling’ £721.62 Mr McLaughlin, Is in effect being accused in part of the
opposite i i.e. dist tly. and with a view'to loss for himself or another or with intent
to cause gain to another, falsifying a document required for an accounting purpose.
The logic of such an assertion would appear flawed. The existence of such
amounts would be more tikely'to arise as a result of:
(i) ; ‘Poor bookkeeping and controls;
(ii) Ongoing inaccuracies in the computerised system; or
(iit) A combination of these factors.
Incomplete Audit Trail
The Horizon System has the capability to reproduce reports showing ali transactions
completed during a specified period. These reports known as “Transaction Logs”
detail the user, the date, the transaction group and the transaction amount. A major
limitation to these reports is that the lransactions recorded by Horizon and reported
‘on the logs are not transaction specific i.e. specific foils inputted cannot be traced
against specific User !Ds. Therefore if false transactions are input into the Horizon
computer system, it is not possible to detail who created these.
An example of this is can be viewed at Appendix H where a transaction log appears
to detail Group 7 Pension and Allowance transactions in the amount of £302.60
from 8.02 am to 12.52 pm on 11 July 2001. An amount of £302.60 is included in
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5.9
5.10
5.4
5.12
5.13
the £10,288.47 alleged loss at Appendix A for the week ending 11 July 2001
described as “received Sub Total of adlist 166 foils at £30,795.53 claimed on Main
Summary as 167 foils at £31,098.13. This would appear to suggest that an
additional “false foil” for an amount of £302.60 was input to the Horizon system. As
can be viewed at Appendix H the following initials relating to the following
employees ail input Iransactions of £302.60 during the morning of 11 July 2001:
initial_I Employee. No of Transactions Input
AMC I Alan McLaughlin _[ 6
CKE _I Caro! Kerr 8
MW [Mary Woods 7
It is not possible to identify which one. of the above employees and which
transaction relates to the missing foil of £302.60 .
Incompiete Information
The Horizon system is operated by Fujits: and all transactions recorded by each
Post Office is backed up and held. After a period of 48 moniths-the transactions are
deleted from the Fujitsu system. The Post Office did not fi ‘thelr investigations
choose to ask for the transaction logs to" he provided or fetaihéd for the pariod
covering the investigation. The elapse of. time is now such that the logs cannot be
obtained (See Appendix I)
ft has therefore not been possiblé to trace the amounts: per the alleged loss of
£10,288.47 to transaction logs to see if any trend in relation to the employee
postings and the time these’ occur
The weaknesses regarding ‘the content of the transaction logs (i.e. the fact that
individual transaction entries cannot be traced to specific User IDs) is referred to
above. This weaknéss:would teduce the usefulness of the transaction logs to an
extent. However in the absence of-the relevant reports we are unable to conclude
as to wiether: review of the logs in their entirety may have assisted our
investigation.
Postings not made by Mr McLaughlin
We have reviewed the transaction logs available to us and compared these with
adlists and counterfoils including related stamp markings (summarised at Appendix
J). Theoretically if the transaction logs are complete it should be possible to trace
the number of transactions of a specific vaiue from the transaction log to the adilist
and number of counterfolls. Any difference in these numbers of transactions could
indicate that aloss may have taken place, A comparison of the stamps made on
the counterfoil also took place to see if any trend could be established. We would
note the following:
(i) The number of transactions per the transaction togs (Appendix J) and the
number of transactions per the daily adlists and weekly summaries (per the
exhibits) do not agree. As commented upon above it would be expected that
a difference of one should arise i.e, the alleged false transaction. As can be
observed al Appendix J on 3 occasions a difference of 2 arises and on one
occasion a difference of minus 2. This would suggest that additional
transaction logs or adlists would be required to fully reconcile the amounts.
We are unable to comment as to why this has occurred except to highlight a
further absence of information.
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oh) lad
ited
5.14
5.16
SA?
5.18
(i) There are 3 transactions in relation to an alleged loss created by Mr
McLaughlin as follows:
Date Week Ending I Alleged Loss Employee
£
=}
06/07/01 19/07/04 55.30 I Carol Kerr
Ruth Lavery
Mary Woods
A Lorraine Archer
09/07/01 11/07/01 403.40 I Marty Woods’
Carat Kerr
Ruth Le
Lorraine Archer
Caroler
LL ef Rutti Lavery}!
19/07/07 25/07/01
As noted above based on the transactions logs Mr McLaughlin did not input
any of the transactions which it is alleged tave'resulted.in the loss.
(iil) No apparent correlation is noted when. comparing: the employees who input
transactions per the transaction log:and ‘those who would normally have used
a specific stamp. : .
As noted at 5.18 below at the audil of 31. May 2001 it was noted that the Sub
Postmaster was using a former staff member's ID. It is our understanding that the
above staff were all in employment at Brookfield Post Office up until the time in
which Mr McLaughlin's contrachwas terminated.
Audit Reports
5.15 We have obtained cdples of two audits which occurred at Brookfield Post Office on
31 May 2001 (Appendix K)end 44- January 2002 (Appendix L). The audit was 2
review“ 6fthe product/process’ controls in place at the branch. The following
weakriessés Were noted:
ae 3 May 2007 11 Jan 2002
Issa, __ Controls Controls
ra ‘Low I High in Low I High
Place I Risk I Risk Place I Risk I Risk
_v v
vl. Not Tested
wv Vv
Nol Tested v
v1 I wa
From the above il would appear that contro! weaknesses in both the cash account
and cash management worsened after ‘Mr McLaughlin left Brookfield Post Office in
July 2001.
In the May 2001 audit it was noted in respect of cash management that cash
holdings were found to be adequately controlled. Cash produced to the auditors.
reconciled to cash declared by the Sub Postmaster with @ difference of only £39.28.
In the May 2001 audit high contro! isk was noted with respect of Horizon Systems
Controls. It was noted thal passwords were not confidential to the individual
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operator. The Sub Postmaster was using a former staff member's ID at the time of
the audit.
5.19 In the January 2002 audit it was noted in respect of cash management that cash
holdings were found to be a high risk. Cash counted at the audit was compared to
the declared figure and it was found that the cash was not accurately declared at
the close of business. A discrepancy of £5,985 was discovered.
§.20 Overall at the time of the audit in January 2002 a full check of cash, stock and
vouchers revealed a shortage of £(1,031.93).
National Business Support Centre Calls
5.21. The National Business Support Centre Call'I'og was. fevibWed gfler the wperiod in
which Mr McLaughlin's contract with the‘Post Office'was teriiiated. ‘The’ following
calls which we believe are of relevance to this:case are noted below:
Date Tneident 10 I Detalled Description’ ~
Zaper2001 I H20422759 I PM took over office’in Adgust-andhad #600 discrepancy
she was told she could clear thig:but forgot to take It out of
suspense ttey have "now taken out-and: fave a loss of #600
but haverno accounting instructions
TaRaOOT I 11010273 I Doing’a find! account On av office and wanls to put through
a discrepancy #620.70 from cash shortages into final
account deficienicy ,
t challenge!c&ll'620.70 hot cleared *“*see incident lop"**
240g9/2001_[ 011037385 7F
Bime/2001 I H11046651 4PM has done ine! taken reconeliiation and there are 42
ising from week 24 she took over office in week 26 and
6 wants to know where to report to
40/10/2001 H20473397 I Dir WK29 #232.90, loss unauthorised unidentifiable loss:
17/40/2004, 720475625 Week £313.11 loss unauthorised below minimum amount
781072001 _I H20476484 “I How to make good a loss
TaN2r2001 I 11241159: I Escalation for over 11 errors in 3 months. PD6 0 PO? B POS
: 6
yariz2001 I H20529896 I ‘Dir Wk39 #511 77 loss unauthorised *"*see incident log by
using infoview before replying thank you""”_
751012001 I 11299524 I 5 arrors #20.00 all cash acc discussed report with Lorraine
advised her to double check parcel traffic entries against
printout prior to rollover
Horizon Support Help Desk Calls
5.22 The Horizon Support Help Desk Call Log was reviewed for the period June 1999 to
February 2002. Of 175 calls made to Horizon 45 (8.6%) were in relation to
forgotten or changing passwords or a user being tocked out or not being able to
fogout of the compuler system.
me Be eB? Be’
aa
a
%
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~
5.23
5.25
Weekly Cash Accounts
A weekly cash and stock count Is performed and totals input to the Horizon system.
A cash reconciliation is printed (Appendix D) from the Horizon system comparing
the theoretical closing cash balance (using last weeks b/f and all cash input and
output transactions) and the actual cash balance counted. Any discrepancies
between theoretical cash held and actual cash held are noted in the discrepancies
table on the front page of the cash account. Attached at Appendix M is a summary
of the weekly cash accounts discrepancies between 29 March 2001 and 7 February
2002. As can be viewed the largest discrepancy noted while Mr McLaughlin was
working in Brookfield Post Office was a shortageof'£70.43-0n the week ending 5
July 2001. After Mr McLaughlin's employment was terminated by the Post Office
discrepancies of over £100 were noted reguitarly.
A further anomaly is the fact that after Mr Metaughiin left the Post Office’ both
surplus discrepancies and shortage discrepancies can be noted in'the majority of
the weekly cash accounts. This is in contrast to the period prior to Mr. ‘McLaughlin's
departure when the trend was for either a surplus. ora shortage to occur (but not
both).
The data provided in relation to the Support Centre calls (5885.24 above) and the
Cash differences after Mr McLaughlin’s departure would indicate that there were
continuing difficulties experienced regarding the reconciliation of cash balances at
Brookfield Post Office
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6.2
63
6.4
6.5
6.6
Conclusion
The Horizon System operating within the Post Office is designed to manage and
track cash transactions passing through the Post Office. Comparison of 2
“theoretical cash balance” with an actual cash balance on @ weekly basis identifies
any discrepancies arising as @ result of cash being over or under stated (cash
surpluses or deficits).
The theoretical cash balance is calculated by taking the previous weeks opening
balances, adding receipts and deducting payments to calculate a closing cash
bafance. * aed
As with any system the accuracy and int
ty of the information ig:impacted upon
by a number of differing but interdependi ‘ 7
factors: Fe
(i) the integrity of the computer software Geir;
(i) the controls surrounding the system; “:
(iil) the controls ‘surrounding data input;
(iv) the accuracy of data input; and 7
(v) _ the training and quality of staff operaiirig the system. ©
From our review work in relation to the Horizon system operating in Brookfield Post
Office we would conclude that thérg:were clearly ongoing difficulties regarding the
reconciliation of cash balances tthe Post Office. This'Is evidenced as follows:
(i) _ the discrepancies I fenttied asa result of the current investigation;
(ii), ongoing cash surpluses. and deficits which occurred not only during the period
of Mr. McLaughlin's: employment but which continued after his departure
(indeed the'magnitude of reportéd differences increased after his departure in
oraround July 2001);
(il) a high number ‘of-calls-to the help line many of which related to difficulties
regarding the cash. feconciliation’s on the system.
‘The evidence produced from the investigation has identified that for a significant
number of cash payments made during the period December 2000 to July 2001 that
supporting pension or allowance vouchers are not available.
The absence of such vouchers could be explained by any of the following (or 2
combination of these):
(i) thatan individual transaction is valid but that the supporting voucher has been
tost; or
(i) that the transaction has been keyed in error and thal cash was not in fact paid
‘oul; oF
(ii) that thé transaction has been deliberately created to reduce weekly cash
discrepancies bul that cash was not in fact paid out; or
(iv) that the transaction has been deliberately created and thal cash ‘has also
been laken
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6.7 Our review has been Festricted by the fact that the Transaction Logs which detail at
entries to the system are not available. These logs record transactions but also
record user ID's which show who has keyed each entry,
68 The usefulness of these reports is reduced significantly by the fact that individual
vouchers cannot be traced through to individual entries on the log and therefore
Cannot be traced to individual user 1D's, However we cannot comment further on
whether a review of the full available logs may have assisted Our investigation in
identifying recurring pattems in relation {o the entries identified,
The charges brought against Mr McLaughlin are stated inthe following terms:
"That you dishonesily and with 6 view (0 you for yours if Or:another or with the intent to
fhe joss to another, falsified @ document required fc ni
{© Section 17 (1) (a) of the Then Act (Northens Ireland) 19
vouchers have been deliberately created by Mr. McLaughtin to “cover up” cash
taken by him or another person,
The inference therefore is that the transactions which are not supported by
Our review has identified the following: ‘weaknesses in Supporting this assertion:
{i) The differences identified by the revisw include transactions which have
money into the system is not @pparerit, Such differences are more consistent
with keying errors or system errors rather than theft,
(i) For the entries identified and included in-the Claim there is no direct evidence
to trace these entra:
ni
ries to Mr McLaughlin, although Clearly as the Sub-Post
Master he had ultimate responsibility for the Operations of the system,
iii) Furthermore based on the restricted logs available for a fumber of the
transactions ‘claimed in the foss, it would appear that Mr. McLaughlin made
None of thie-relevant entries for the relevant days,
(v)- - Differences Continued and indeed increased after Mr. McLaughlin's departure
from the Post Office: Thi
~ is would Suggest that issues ‘Surrounding the cash
discrepancies were not directly related to his involvement (at least fully so).
Please do not hesitate to contact either Richard Gardiner or Stephen Armstrong of our
Office should You require any further clarification of the above.
a
2 McClure Watters
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4
Prrte xr x «
Expert
Witness Declaration In The Matter of Mr. Alan McLaughlin
1understand that my primary duty in furnishing written reports and giving evidence
is to assist the court and that this takes priority over any duties which I may owe to
the party or parties by whom I have been engaged or by whom I have been paid or
am liable to be paid. I confirm that I have complied and will continue to comply vith
this duty,
[ have endeavored in my reports and in my opinions to be accurate and to have
covered all relevant issues concerning the matters stated, which I have been asked
to address, and the opinions expressed represent my true and camplete
professional opinion;
I have endeavored to include in my report those matters of which I have knowledge
and of which I have been made aware which might adversely affect the validity of
my opinion;
[ have indicated the sources of all information that I have used;
I have where possible formed an independent view on matters suggested to me by
others including my instructing lawyers and their client; where I have relied upon
information from others, including my instructing lawyers and their client, {I have so
disclosed in my report,
I will notify those instructing me immediately and confirm in writing if, for any
reason, my existing report or opinion requires any correction or qualification;
{ understand that:
(a) My report, subject to any corrections before swearing as to its correctness,
will form the evidence which I will give under oath or affirmation;
(b) I may be cross-examined on my report by a cross-examiner assisted by an
expert;
(c) I am likely to be the subject of public adverse criticism by the judge if the
court concludes that I have not taken reasonable care in trying to meel the
standard set out above.
1 confirm that I have not entered into any arrangement whereby the amount or
payment of my fees, charges or expenses is in any way dependent upon the
oulcome of this case
Signed:
Richard Gardiner
Date:
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APPENDIX A
SUMMARY OF CLAIM
ae
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Appendix A
"Alan McLaughlin - Claim Analysis
£ £
Keying Errors (7.63)
Reversal of Transactions 5)
(229.58)
Missing Dockets 6,422.23
Group Total Casting 201.30
Adlist # to Main Summary 3,894.52
10,288.47.
= ’
5
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£S'96 €5°96 th
00% 00'z wh
ooze 00'Le Z ry
09°01) O9'ObE s
joe’ss Oe'ss th jersey BOstz'122 Izzose'tzz I to-sew-ez 6
3 3 3 3 Ej 3 3 3 3
Ausuiuung I Bugsep
besyansy ue 1830) syaygog I sioug pawyeIa49AQ I oN paaesey pauls papug
VeISHPYI drop Guyssiw I Suey qunowly =f dnoig I uoneyey ved ved poliag yaa
Aq pasiieuy °
Sishjeuy Wie] - UGBne ow Oey
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Se1ze- jesyee'e = for Loz eezer's jegl LP887'0F Le'S8Z'OL
27 se'2e soze oo
o9"907 o9'90z L
Sh 26 siz6* eh
S062 SO'6L th Iso0g¢ vO'veS'¥1Z_ I69'PeO'SLz Lo-nr-$z ci
oe'ss jor’ss tb
OS'S b- OS'St- tb
og'oLt log'ort $
los'6e} og'set vb
Os'6Lz 08°62z Z
0z'0 02'0 Ss }00'OLS wieed'egt jy eoe'6ss s0-inr-Bt ray
0s'Z0£ jos'zoe Z
oe'ss cess eb
Or'0- Ov'O- bb
Ov'eoh Ov E01 $s 06"'09b 9209662 I 91 1Zy'0SZ Loan-t) Ey
loz'est oz'yst vb
tobe ie ub
EERTA S8'Se $s 9497 gS ere’oiz Izeszo'ziz 40-INf-¥0 si
MERZ o9'ySt £ jogyst _Iesyaz'giz__jze'sey'gt2 I bo-unr-2z bb
Ov'sth Ov'Shh L .
06 LZ 0622 fb joer SeriL'zb2 Iszess'zle bo-unp-02 tt
3 3 3 3 3 3 3 3 3
Aeuung I Suysea
fesuenay wey 1E}OL syeyv0g I slog pawje[eag I oN paaiasay paueId pepul
crxisupyI dnoig I Guissiw I Bujhoy qwnouy —Idnaig I uonenen ved wed poyag 482M
Aq pasijeuy
sishjeuy Wielo - UGE TOW UeTY
OS Ree EE Ee
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-81-
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APPENDIX B
DAILY REPORT (HORIZON)
- -82-
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mtr 7 CAP204 BP: 0]
P and &~ Client Copy : baal
Allovances
NE gp 05
Total
AI gp 06
inte
Total
NL gp 67
eh
Totak
XI gp is
ee
Pees
BSE OR,
SRTRRE
ce
REE
SAS
BS:
ai
PESSSsyy
RRRRRRE
se
a
EER
BEERS
RB Bie
SRR
a
n
=
z
aR
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Total
NI gp 12
Total
ML yp 13
fRICE — VOLURE wary
God 37.00 2 ney,
gO 40.40 4 104
yore EB 6 ee
gg MSAD 2 6.807,
yee ba
Awd Mead I eee
Peariiie cant } 44.8
3.00 . 1 i
gio
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2
1
H
j 67.59
63.42 Le 64a
9.52 1 69.527
76.86 1 18g
82.05 1 82.097
WAS { 51.85
96.65 1 8.65
101.26 I 126
103.01 tino
103.09 1 109.09
116,50 1 16.307
$4
12271 {ed
135.00 2 200-7
= 60 1 I
139.83 1 a
151.44 1$1.2
Total HI gp 44
8A milk (HE) .
PRICE yoLUnE tae
Total Pia nik Dg
TOTALS: VOLUME
Allowances
Grp 05 - 35
Grp 06 = ¥ 2
Brp 07 ~ D 15
Sub Tota): R
Pens ions
Grp t= 1 1
Grp 12 - f 4
Grp 13 - k 4
Grp 4-1 Fe]
Sub Total: 138
Wilk Tokens 9 8A
BEN Wik 8
Sub Total: 3
SunBARY TOTAL: 270
SCO END OF RESORT tee
O54G25-08
2712.04
id Gh
0.00
&
Tig S2
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I Site ———
re)
APPENDIX C
WEEKLY SUMMARY (HORIZON)
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PENSIONS AND ALLOWANCES
OFFICE NAME: Brookfield OFFICE CODE: 1917043
ADDRESS: 213 Tennent strset
‘C/A WEEK No: 04
Belfast
BT13 36g ‘TIME: 18/04/2001 23:54
This summary should be despatched with the CASH Accounr,
WEEK ENDING: 18/04/2001
GROUP NUMBER OF oADERS TOTAL AMOUNT
NO FPS1/287—-PENSToNs ALLOWANCES
Pp
MOD.ARMY 1 o 0.00
+. MOB.Ind rnjy 2 ° 0.00
MOD.AIS 3 Qo 0.00
4 oO 0.00
Child/one ?, 5 133 3676.15.-—~
War Pension 6 We" -622. 18 -
Dis Living ary 7 180_— 30695.12
. Family credic 8 ° 0.00%
fal D.O.H. 9 o 0.00
~ Pension/tncsupp 10 o 9.00
I Income Support 11 365. 25261.42—
Ind Inj/Deach Ben 12 40 1569.a5 —
im Ret Pensionsary 13 467 33872564 9319564
t Sickness Ben/ary 14 163.— 15774, 96
PESEavzD 4s : ° 0.00 —
For 16 Q 0.00
FUTURE 17 ) 0.90
uss 1g ° 0.00
TOTALS; a oO
Hil Token Pc a
FULLY CHES
ROLL,
I FAID ORD
an en a a
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FOR INSPECTIO.
yg
Brookfiela FAD 1817063
13:50 18/04/2001 : i
fons and Allowances u!
Srp 06 ~ yw
Srp 06 = w
TOTAL Grp of - x i
Grp 07 - 5 Ryol
Grp 0? - PAvOL
D a/01
Grp 97 = y PA/OL
TOTAL Grp 07 ~ p
Stet eee teeeay
TOTAL Allowances
Gp ay ay BAvoL
I ABs/CL
Gzp 11 -y AR/OI
Grp ane AA/OL
-. —
135.4¢
225.08_—, .
11.46
1097.837
= 1563.85 “I ‘
19293.00. ec
resvias OB E-CS”
-1r 2x01
Gp la 25/01
Grp qe AvG! }
Sta leoy AS/OL
TOTAL Grp 4 y
tt ttiteertteey ay,
TOTAL Pensions
PO Mag
PCA Meiy
Per mai,
PEA Midy
s
TORAL Pea mi yy
Poletti tteteere pee
TOTAL Hitz a3teas pes
SURRY Tore,
+ NN
109QS-32
625 I -94-
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a a: a a a
APPENDIX D
CASH ACCOUNT (FINAL) (HORIZON)
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1 RRbwatapergemcemncmemencemccmstmame = —
Office code: 1817043 week No: 04 Week Ending: 18/04/2001 Date: 19/04/2001 tine: 09:59
wi temas 2001/2002 Week No
HORIZON
Cash Account (Final)
213 Tennent Street
Bellast
T1366
- Week Ended: 1emn4i2001
= 181 7043 30
f TO BE SIGNED BEFORE DESPATCH OF CASH ACCOUNT __
‘SUBPOSTMASTERFRANCHISEE/BRANCH MANAGER:_!
S 7
iL Sa
Ol > EXAMINED IN TP:,
ely,
€
. TABLE 2 UNCLAIMED PAYMENTS : bj
2 50 te Date :
. 26 Unpaid Choques A i
. 27 rp Cheqoes 8 :
~ 28 Uren Cheques C :
: 29 i
30 Voodnors i
BL vee eeeee 14.65 Storage AROS . a
32 Bargy we Loses Bs
fa 33 POCL Clq perlan hemes
34 e
35 Mecrion
36
- 37
38
et TABLE 22] AUTHORISED CASH SHORTAGES
50
- Gach Shores
Gach Shrtones 8
: Cad Borges C
Cork State
TABLE 3 UNCHARGED RECEWPTS
Bl 50
60
61
~ 62
; 63 Prepuckce
64 Coch Sup A
65 Cach Serpe B
66 Surphostin Rams et
is 67
68 Magton
7
72
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J Bepememmneneneeeeenseseomenteenameeeneen
———
fe page: 2 Office code:1817043 Week No: o4 Week Ending: 18/04/2001 Date: 19/04/200} Tine: 00:59
t
ie TABLE St) STOCK IN HAND BREAKDOWN TABLE 5 CASH, STOCK ETC, 1H HAND
50 fp Pestage
a
ul: 271.08 ttGssi: 20 te
"i 12: 523.64 tdCexSps
Ol - +5,294.15 OterPostage home 50 -+++73,945.26 Con
ra 02 Sp Bis Vending 51 Cheer ‘
10 - +544.36 SpGa0he 52 FaCur St Er
ke 13° +r 23B1,00 Sead Sps tet Clos 53 Gare Licences
= sa Pato hee
* ST + +5++6, 714.23 Podge Sys
7 99 Di Hse Spa
le B4
ay
+ ++1S.00 DET Phone Conds
£ [5 6 £10 Phone Cords
be Home Hep 1 Care Sips
ry ‘OFR
; ‘TABLE 10(a) NUWJER OF TRANSACTIONS 3,344.00 POFeevave
jt a1 "*288.10 POFees 4
72 ‘E111 Certicxtes: Ober £3 Comen Coin
73 OB Chqs ‘Vilosen Aawiy 15 cia
ut 78 NS ISACach Croce ot evan Vovchar £10
haf e2 (Clank M Order ‘Amazon Voucher £20
+ al Nerrefive Colecton +++350.00 Vebide Lic Sips
F . 4173 Porcetorcny9 6 19 +++976.00 Wiese
65 Parcoberee 2448 ote Ay Sips
¥ 66 ernst Dotopoet
Wi Lae Cover
63 Hosier Gover 801 vgs Sot
75 High Cover SEEBcord Sigs Sp
i BO Contract Pee tdont
67 Ctra Paras nto ‘Sera £20
ee I ‘Spackd Defy tom
: ee
7A err Registered ich Gas Srorteds
BT veeseeee 2 tetera Rocordod adowcods 8
: BS Swit + Resid Open Veto POF te
i 69 ‘Salfir + Recorded £28 One 2 One Pregey
4: pane 210 One 2000 repay
930 Pareatiovoe by n008 AS Orange Prepay
B4 Vescods Rejeraon £5 Orarge Prepay
H 77 Dine Wise Pecks 10 Grange Prepay
' 1 ‘Pestrrans Pouches 155 Vodafone Propay
ea ‘sonN £15 VatalooePrapay
in ] 69 (8Ges Recon/Oiscon (EBS Vedotone Propsy
a 92 Comeb Vouchort {18 Vodafone Prepay
F 93 TVLUTS Pretyptcotin
t 70 MANA oars ed 10 Vigia Prepey
: 63 Preorder Buy Bok 128 Vigin Prepay
64 (Chango OF Address
q BY -+++++-28 ‘Home Shop Acdiras
y 58
s9 ‘Standard Life SHP Apps
a, 60 POL Smartcerd Applications: ‘£10 OT Cetnet Prepay
q H 61 OWE Repsis (20 BY Cednet Prepay
cla 4
86
(C10 BT Giobal Cords:
E2081 Geos Carts
at et tard
Uedsined Payments
Cach Shortages (2a),
Sub Teed
Lest Unsies god Reesipts
TABLES TOTAL
-100-
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3 Office code:19170€3 weak No: oq week Ending: 18/04/2001 Date: 19/04/2001 Tice: 08:59
get
_. I RECESTS RECELPTS (Cont)
30 ‘ntos 00 tp 30 0 Mnbes 9g tp
Lf OL --++76,099.92 Baoree tought Fd 27 [5.8 £1081 Phone Cords “]
02 POC Ch BALK HX 52 Hae thdp oe a
: 20 Priteic UR Pry
” 05 vre-- 210.00 ONS Deposts inc 806M 34 PO Fmavin
j 08 Pest Orde UR 21 POF ees
u. 08 Telephone Reps 82
TB ccccee 11311: Gro epeymts 18 te 05 Car in
7 12 ++ Giro Trenecesh Fees 33 Victorian Aan tf Coin
‘ o7 {et Oring Permits a7 Amazon Voces (18
Lfs 13 Gas Corl Ractrge 32 ‘rein Yoke 29
10 06 Rod Ucences Sales 38 Vets i Son
15 Temp Fist Licences 35 Wie Sg Spt
- 410 Giex Koy Recharge 37 Wetor Asby bys
22 Pastoge UR 44
9 219 10 Motor Vetihe 56
20 “VET Ue Ri Foor 83 ‘BGas Seg Spr
2 58 DA Phas co Fees 53 SEEBoard 9 ps
84 Ue Accept Charge 61 .
Ld 03 Dise Whale Sips UR 62 ‘Smartereds 0
75 Travel inswrance 63
59 eee Schemes 67
j as 49 Bitch Gan Sets
ie 73 90 Uitewoods Sead
@9 ----- 8,290.92 Armen ink
eg 4
oFR
‘Chg Prize Poy fad Esy on tp
Net Lot Game
*400..00 ator Win Acrets 1d pea Vale POI
Moneygram Send 20 20.000 2056 Prop
Be CA Carminion 21 £190 2 One rp
B te Co Revehvaten i7 £15 Orange Prey
Trav Gigs Sos 18 £5 Crenga Prepay
‘Business Purchaces 24 (£10 Crenge Prepay
Procter Fon Eich 25 £3 Vedat Frgay
19 {15 Vaden regs
26 + 28 Vodetone Prepay
27 £10 Vedatne Pepa,
Cha 9 Add Reset 05
Rediocton Biches 06 £10 Vegin Prey
+222.00 Redescton Sod 28 T20Vegin Prepay
+216.00 Weiwce Fevs 29
31
32
Rc th Lo Cords 33
CARAS - Parcel 12 £0 BF Calne Popa,
URPAF eos, 13 20 BT Cotnet Prepay
UKPA Chergos 14
Fronking Surioe 15
Other Ler Surizo 16
22 £1087 Geba Cats
++ +126 ,550.00 ems tem One cas 23 MST Gea Cae
(Cours Rev Schad 40 Geo EM BTA MEH
39 Loan Te PO {net BOs} 41 BG Smartcard Tri
40 acd Aocouen Supls 42 (Vogt Coes born TP
24 Guna Gcencea 43
Geottent j
PUR KS I
Fosixe UR bey I
OW Sips WI My H
31.80 RELERTS 10rAL {
i
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ie
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na € Off1ce code:1617043 week no: 04 week Ending: 19/04/2001 Date: 19/04/2002 Tize: 00:59
AYMENTS. PAYMENTS (Contd)
£e ao Members 10 ep
‘Loan Wd (SPSOMSPO} 32 34
POCL CL EN Wk Nfs} 39 40
Monaflind TW Refunds 98 ATM Withdrawals:
DNS WedsPyts, Es 67 Gro Reot Bd Entry
+ ++110,792.32 pPensions and 40 41
. 86 Fast Accond Dany
B5 +--+ 86,855.06 Bsns Dute Pet Oke
oe OFR
i cP
++ ++20,252.04 Greece heat
mt 20
2t
cee eeee 644.41 Gro Oxtpoyments 22
Travel Inace Refund 23
Not Lot inst OBACT o1 30
eee ee eh T,00 ABHat Loo Prizes 23 31
‘SWALEC Cashed Cheques: 27 22 .
MuMecttotim Peers — I 43 33
Uitencds Pris 45 34
MOO Penton 47 35
Cheques te CHES
Post Order DR + ++219,701.80 PATMENTSTOTAL
Ailes PagiPore bark
Pridstake DAR OFR OFR
‘Canadian Money Ordors
I: az Posaxze OF TABLE 12 PARCEL TRAFFIC
ag Enoathed 08 Cheques
AS Disc. What Sips YR
60 sytem SockersI
? OL Debi Cords:
04
36
t 06
77 ‘ck Rates $50
i 96 Moneygram Receive
32 ~
lod 50 Bre de Change: Revel TABLE 6 REMITTANCES FROM OTHER POST OFFICES
97 Test Fires
2 21 ‘Business Sex 60 tp
13 POF gn Exchange OL
82 -eeeeee 654,00 Raveto Char Fee 14 ---226,550,00 Co
3 55 Coup Baines Chq Cathet is
69 VL Stornps Rodd 16 Fgn Curr Stor Equir
{ JBowt nee ees BE.00 TWieSgsRetnd
65 Water Auy SS Rednd OFR
61 BT Sips Reand
os 8 Gas Sips Rodind TABLE 6{a) STOCK RECEPTS FROM SUPPLIES DIVISION
a 70 SEES0ad S73 Redind
79 61 Powtage
25 ‘Swadee Blox Stys Rodd —
BL SHED SipsRednd os 1sCtom: Spx
5 78 09 2rd Chass $0
24 23 tar Porage hans
3 94 ‘UK Passport Fce Rind 46 ‘Stump Books Vandeng
mn 80 UK Presport Charge Ring: 22 ‘Stamp Books cher
Intorrestionsl Reply Coupons 10 SoS Sys 1h Ores
Vouchers Sent To TP ai . Sa Ad Sipe 2nd Class
remind Voudhars
Postat Onder Fees
Geo Eni OTA NO ——— -
37 Bond)
‘Unpsid Cheques 0 TP 38 Gord 2
ne ie Ww Bond J
Band
Bond 5
Bond §
-104-
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ages 5 Office code:1017043 week No: 04 Week Ending: 18/04/2001 Date: 19/04/2001 Tine: 08:59
‘FABLE 10f) GROBANK TRANSACTION BREAKDOWAY TABLE & STOCK RETURNS TO Supp DIVICHESTERFIELD (Corl
10 70 te?
setae 213 1 Tromeach 0692 13 Wate ity Spe ~]
‘0° 2 Banivess Ooposts 17 ‘
NSC Purchased 73
4PS8 Purchased 48 B Got Sy Sp
TB Gos Teh 25 ‘SEEBOOrd 9 Spt
18 Ba Coded Teach 90
19 Gas Tekan Teach 38 Smarereds 20
‘ota ISA 83
21 POBERSS 82
a BO Bish Gos brertorts
a 53 Uniornods
x 01 Open Vale PO Fle
2 66 £20 One 20ne Prepay
‘SPerscnat Chq Oop 67 £10 One 2000 Prepay
‘8 Brs Chq Orty Dep 61 £15 Orange Prepay
Cnet Tax Caste 62 Orange Prey
9 Rast Veushors 35 £10 Orache Prepay
10 Rent Cards 39 (65 Vodetene Prepay
wv 31 15 Voda Prapay
» 43 £23 Veale Prepay
MOdppresMids aa £10 Vedeone Prepey
A2URKSAVE 45
13 Bas Cech Wats 46 £10 Vigin Propey
bed 49 20 Vigia Repay
ss 50
6 26
16 Change Ging 27
- 29
02 ‘10 BT Cost Prepay
1 £20 BT Cede Prepay
5 14
bbrane 6 STOCK RETURNS TO SUPP DIVICHESTERFIELD 64
56 eo Gacrds
isl 79 te 57 18 Gb Corts
63 7 Rae ete et
36 Gare tfoerces ‘OFR
if 03 Pratee s
15 {stClae Spe
be 16 nd Giese Boa ‘TABLE 9 RENS TO OTHER POST OFFICES
07 (Other Poctage Howe
. 08 Stamp Bis Vong
ke] 09 Stamp Bes Ofer 80 cp
32 Sct Ad Sips tst lcs
33 ‘Sol Ad Sys nd Coes o1-
Ose Whe Sips 02 -
43
CBT code OFR,
£5 410 BT Cords
Homo Help Kare Spe
PO Foxe Valve
POF ea Band t
POF oe Band?
POF Band
POF ee Bantt
POF ce Bats
POF ee Dead 6
Other £5 Coren in
ictorsn Anir £5 Coin
‘Amazon Voues £10
‘Aenazon Vous £20
Veticl tic Spx
TVUe 94g See
-106-
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i alii
iY ,
ee ee tO A a ee en ee
APPENDIX E
MISSING DOCKETS/FOILS
CLAIM EXAMPLE
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-108-
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I Coma