POL00069555
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Stephen Dilley
From: Stephen Dilley
Sent: 27 September 2006 12:18
To: ‘Richard Morgan‘
Subject: RE: Amended second statement of John Jones: P.O -v- Castleton
Richard,
Anne Chambers and Liz Morgan have already returned signed statements.
I wonder whether I should wait until I've got every witness statement into final form before sending it to you?
There are 14 witnesses of fact. 2 I haven't interviewed yet. 4 witness statements (Ken Crawley, Mike Johnson,
Gillian Hoyland and Mery! Ludditt) will change when I hear back from Carol King about the (1) excel schedule of
errors (2 lottery errors are omitted from it) and (2) who is going to replace Meryl Ludditt. Andrew Wise and Cath
Oglesby I'm still waiting their comments on. Given that the witnesses keep disappearing on holiday (it shouldn't
be allowed!), there's a risk that as not all of the final versions of the statements are going to be ready just yet,
that I delay sending the whole lot out and consequently then we don't get them back as quickly as we'd like.
I think if you're happy with this what I propose to do is send you 12 of the 14 statements by the end of this week
(those 12 should be in final form then) and the remaining 2 statements for the people I've not yet spoken to (if
prepared by then) in draft.
Kind regards.
Stephen
——- Original Message:
From: Richard Morgary_.
Sent: 27 September 20
To: Stephen Dilley
Subject: RE: Amended second statement of John Jones: P.O -v- Castleton
Stephen,
I thought we were going to review them all again in final form, and if he signs then any subsequent amendments
will have to go into a second statement. However, if there is to be no further review, then I agree that he should
sign.
Richard
3tement of John Jones: P.O -v- Castleton
Dear John,
Thanks for your email of 18 September. Given your comments below, I have made some further changes to
those paragraphs of your statement. I have also paginated the exhibit. I attach now what should hopefully be the
final version for signature. Please can you print, sign and date 2 copies and return 1 to me.
I will send to you a copy of the exhibit in the post.
1 look forward to hearing from you as soon as possible.
Kind regards.
Stephen Dilley
Solicitor
fe
half of Bond Pearce LLP.
POL00069555
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From:) 1.h.jones
Sent: 18 September’ ‘2006 15!37
To: Stephen
Subject: Re: Amended second statement of Johin Jones: P.O Vv" dastieton
Stephen
I can confirm , in answer to your questions :-
(Paragraph 11) I reviewed the interview notes taken from the interview of the 10th May. This is aside from
reading all the documentation that accompanies the case file.
(Paragraph 13) I can confirm that the cash deposited from the car auction company had no Giro deposit slip, nor
receipt slip completed by the customer.
The deposit pouch I examined from the company at my visit to the branch, contained a large amount of cash and
was accompanied by a blank inpayment book and receipt slip.
I was advised by the Interim Subpostmaster that this was normal practice for the branch to check the amount in
the pouch and then complete the deposit and receipt slip on behalf of the customer. The amount deposited was
then processed without any verification with the customer.
The pouch would then be returned to the customer with the receipt slip on their next visit to the branch.
(Paragraph 25) Actioned.
I have signed the statement and returned, marked for your attention.
Regards
John
John Jones
Area Change Manager
Network Change
Post Office Ltd
Sales & Service
Upper Floors, The Markets DMB, 6/16 New York Street, Leeds LS2 7DZ
3 "Tom Beezer"
13/09/2006 12:27 <andy. r pearsoni_
Subject: Amended second statement of John Jones: P.O -v- Castleton
Dear John,
Thanks for meeting us in conference on Monday.
I attach an amended statement of your witness statement and a marked up version for ease of reference.
Please can you read this through carefully, make any changes you want (bearing in mind Counsel's comments
about softening it and also that you have to be 100% happy with it) and also let me have your answers to the
questions in bold italics. Don't worry about the page numbering of the exhibit for now.
2
POL00069555
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Jalso attach various docs in pdf you might find helpful including:
1. The FOSACS statement of outstanding debt so you can see the reversal of the £1,256.88 error.
2. Summary of events and interview notes (relevant for my question in para 11).
I look forward to hearing from you as soon as possible.
Kind regards.
Stephen Dilley
Solicitor
for and on behalf of Bond Pearce LLP
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