POL00053746
POL00053746
41" January 2010 Legal Services
Messrs Coomber Rich
Solicitors
Yard House
May Place
BASINGSTOKE
RG21 7NX www.royalmail.com
Our Ref: CRM/258932/JSX
Your Ref: ICH/03/06/09
Dear Sir
Rl v SEEI
GUILDFORD CROWN COURT
IAL - 15™ MARCH 2010
I have now reviewed the papers In the above case parlicularly your request for
disclosure and comment as follows.
We will respond to all reasonable requests and seek material that may
undermine the prosecution case and support your Client's Defence. We
understand in general terms that you are seeking to challenge the integrity of
the Horizon system. We feel obliged to point out, however, that you have not as
yet served a Defence Statement which raises any issue whatsoever with the
Horizon system. if any apparent errors were occurring in the Indictment period
your Client should have a good knowledge of what they might be, simply
because she would have regularly been checking the stock against the Horizon
records. We take the viéw that a detailed Defence Statement is required in this
case Which fully particularises any problems with the Horizon upon which your
Client would seek to rely at trial. The Defence Statement should obviously
make clear what the issues in the case are. At the moment we do not know
whether your Client still claims that she was hiding thefts by members of staff
and to what extent those alleged thefts contributed to the deficiency at the
Office. We are handicapped in fulfilling our disclosure obligations by the
absence of an adequate Defence Statement. The credibility of your Client may
also be damaged at trial if no adequate Defence Statement is served.
Yours faithfully
Jarnail Singh
Senior Lawyer
Criminal Law Division
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