POL00054185
POL00054185
Jarnail A Singh
Sent by: Marilyn
Benjamin
REGINA v SEEMA MISRA
24/02/2010 14:01 GUILDFORD CROWN COURT
TRIAL - 15TH MARCH 2010E5)
Dear Ms Hogg,
Ihave heard from Gareth Jenkins who informed me that he had a 90 minute lengthy discussion with
your Expert Charles McLachlan as long ago as Friday 12th February 2010.
In the meantime I now enclose the replies to the third disclosure request. However if any of the items
you have requested have not been dealt with if you can give a reason wanting that item then of course
the prosecution will consider those. As always I am continuously and constantly keeping the
disclosure under review.
THIRD DISCLOSURE REQUEST
1 That was the contract in the form it was served.
2 We are well aware of our Statutory duty of disclosure as you know the Prosecution have reviewed a
large volume of material. The only material disclosable is Callender Place as we know Mr Jenkins is making full
investigations so the full position can be ascertained.
TRAINING.
1 The training material is at West Byfleet Post Office. Presumably you want simply an opportunity to
inspect or view it on site.
2 We do not understand the relevance to dates to which your Client received the documents. The real
'ssue is did she steal the money or make mistakes. This is an issue for the experts when they look at the
Horizon data.
3 See above.
4 —
5 The prosecution is under no obligation to Provide witness statements. You have full details of the
witness and can contact him if you wish.
6(a) This statement is in the most useful format. The Purpose of this statement was to provide material in
digestive form. Logs are impossible to follow unless undertaken by an expert. We do not see the relevant calls
made prior to your Client's taking Office. We have provided the information in the most useful form in the light
of the data.
(>) The analysis data confirms that.
7(@) You have been provided with all available training material.
(b) What are the real issues in the case.
(c) ____Are we looking at the quality of the training but Mrs Misra made mistakes which will be investigated by
{wo experts. In fact the real issue in this case, did she steal the money or deliberately attribute it to mistakes by
her and the training background is information only.
8 We believe we have complied with our disclosure obligation. Whether any mistakes were made.
Experts can examine them themselves.
9 We stand by our position. Our response is that there has been a misunderstanding, there is no reason
to put this in a statement form. If it carries to trial it carries with it a risk that your expert and your Miss Hogg
will become witnesses in the case which is highly undesirable. We suggest you re-consider.
10 tiga 2° 2¥e24Y answered this request. There are no back up teams no more than the Police Force
Investigating crime. Investigators consider all reasonable explanations. Your Client did not give an explanation
POL00054185
POL00054185
other than other people were responsible. If your Client had made mistakes that will be ascertained by two
experts in their enquiries.
W Costs is a consequence of Royal Mail contractual relationship with Fujitsu. Our duty of disclosure is
whether material which undermines the prosecution case and supports your Client's deferes, Wa hope if the
© Our disclosure obligation do not require us to justify why data for a year period is so expensive.
12 We anticipate the areas are for the experts to discuss.
13 The audit was not completed.
14,15 We have disclosed all information in Our possession. We are not required to serve witness statements.
It Is clear that Steamline has no relevance.
16 lems Vo 2"2,2°t Prepared to make any promise in relation to criminal or civil action. The issue is whether
Problems referred to was happening at Byfleet is something for the experts to examine
17 The equipment is being updated. The original equipment is preserved after updating has occurred.
18 Prosecution Counsel has reviewed the case of Hosi. There is no material that requires disclosure.
19 Please refer to our answer to Paragraph 8. Prosecution Counsel has reviewed all material. We are still
investigating Callender Place. We recognise our duty of disclosure is a continuing one.
20 We repeat our answer in respect of Callender Place.
Yours sincerely,
Jarnail A Singh
Senior Lawyer
Criminal Law Team
Tel.No:!
Fax.No},