POL00053008
POL00053008
R. v. PALMER 25" July 2006
Advice on Evidence
THE CROWN COURT AT BASILDON
THE QUEEN
-V-
SUZANNE LESLEY PALMER
ADVICE ON EVIDENCE
1. I have drafted the Indictment, which accompanies. It is substantially
in accordance with that drafted by Mr Singh. However, I have re-
drawn the Particulars and corrected the cash on hand figure in Count
2 [see Exhibits @ pp 17 and 22].
2. I have assumed that this was a snap audit rather than a pre-arranged
audit: please confirm, in due course.
FURTHER INQUIRIES
3. There are a few issues arising from the papers which I would be
grateful to have answered by the Investigation Manager, and
appropriate statements made and served to confirm:
a) To whom would the Defendant report scratch card errors? Are
any records kept? If so they should be made available.
POL00053008
POL00053008
R. v. PALMER 25" July 2006
Advice on Evidence
b) When were the error notices to which the Defendant refers in
interview processed? The I.M. could not supply this answer
when her Report was submitted.
c) Is there any record of the Defendant’s training [see LUSHER @
p 5]? Experience has shown that statements to the effect that
“training would have been given” are of no value when this is
disputed.
FURTHER EVIDENCE
4. The following maters of evidence should, please, be attended to:
a) Does the Counter Operations Manual contain a section which
deals specifically with how scratch card sales should be dealt
with (on Horizon)? If so, the relevant portion needs to be
copied and served with a supporting statement.
b) The SPM contract signed by the Defendant should be
obtained, copied and served as above.
c) A statement should be obtained from Nick KERR to deal with
the matters raised in the interview at EXX pp 32-33 and 48-49.
5. When the Jury Bundle comes to be prepared, it should omit the
existing pages 7-10 of the Exhibits.
6. If not already disclosed to the defence Solicitors, they should be told
that the Defendant had not previously been the subject of audit (by
way of disclosure).
7. I do not presently see the need for a conference, but this should be
re-considered when the evidential position is further advanced.
POL00053008
POL00053008
R. v. PALMER 25" July 2006
Advice on Evidence
8. I shall not be available to appear at the PCMH on 18" August 2006 as
lam sitting on a Case Management hearing at Kingston Crown Court
that day. I would be grateful if whoever attends in my place has
available my dates to avoid. My time estimate would be 3 days at
most.
9-12 Bell Yard STEPHEN A. JOHN
LONDON
WC2A 2JR. 25% July 2006
R. v. PALMER
Advice on Evidence
25" July 2006
CROWN COURT AT BASILDON
THE QUEEN
-V-
SUZANNE LESLEY PALMER
ADVICE ON EVIDENCE
Solicitor to Royal Mail Group pic
Corporate Security
REF: CRM/252496/JSX
DOC: PALMER.ADVICE
POL00053008
POL00053008