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* € phen Dilley
From: Stephen Dilley
Sent: 28 September 2006 15:16
To: ‘Richard Morgan’
Subject: RE: (1) Opening audit (2) Proving the losses: P.O -v- Castleton
ok will call you then
To: Stephen Dilley
Subject: RE: (1) Opening audit (2) Proving the losses: P.O -v- Castleton
Shall we talk about this tomorrow? Just give me a call when convenient.
Richard
To: Richard Morgan
Cc: Tom Beezer
Subject: (1) Opening audit (2) Proving the losses: P.O -v- Castleton
Dear Richard,
(1) Opening audit
One of the things you have been seeking is an opening audit in the theory that we can then
deduct the stock and cash in the closing audit from the stock and cash in the opening audit and
that the difference would be the shortfall. The aim of this would be that we would not therefore
need to rely on information from Horizon and it would be an academic issue.
I've been chasing lots of people at the P.O to get a copy of the opening audit. Iam told that:
1. There is no opening audit report available as they were not required to be kept at this time.
2. However, when the subpmr before Castleton left office, we can see from the attached
document that there was no transfer of a deficiency or surplus.
3. I asked whether there was a transfer of cash or stock. Apparently, what actually happens
when there is a change of spmr, is that the audit team for the outgoing spmr "rem out" the
stock and cash from the computer and the new spmr or his trainer "rems in" any cash or stock
handed over. We have the stock rems for January to March 2004 and I have asked the P.O to
provide all cash and stock rems for the entire period that Mr Castleton was in office. I have
also asked the P.O if we can find out who was the actual auditor who on or around 18 July
2003, so that I can confirm with them that they definitely would have remmed out the stock
and cash. I'll update you when I hear further on these points.
Even if we had the opening audit, I anticipate we'd still need to rely on the Horizon transaction
logs to see what transactions were performed between the two audits because surely our case
is "from Horizon we can see this is the amount of cash and stock the spmr has received, the
Horizon transaction logs show what transactions were done, we can therefore calculate the
amount due to the P.O from the transactions done and consequently that the Marine Drive
branch has a shortfall." In other words, I don't think we can take Horizon out of the picture by
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relying mainly on opening and closing audits.
(2) Proving the losses
You've asked for someone from the P.O to give evidence to say "there are £25,858.95 of
losses" So far, people seem remarkably coy about saying that. The auditor (Helen Rose) says
that it would be inappropriate for her to say that. The RLM (Cath Oglesby) is not familiar with
the document which has the losses on it. I've asked the P.O to identify a witness to say that. I
am informed that the Former Subpostmaster team collate all the information to start the case,
but the information on losses either comes from the final audit (Helen Rose) or from errors
outstanding at final account or arising after final account (i.e. our "procedural" witnesses such
as Gillian Hoyland, Michael Johnson, Ken Crawley). I have been told that if I take a statement
from the final account auditor (Helen Rose - done) and all the error people, that I have the
losses "fully covered." In other words, this means that there won't be any one single person
dealing with all the losses. However, Helen Rose's audit picks up most of them.
Happy to discuss any of the above if this would assist.
Kind regards.
Stephen Dilley
Solicitor
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