POL00069601
POL00069601
« Stephen Dilley
From: Stephen Dilley
Sent: 08 September.2006.09:46......
To: ‘rmorgani________ 4 GRO.
Cc: Tom Beezer
Subject: FW: Amended draft witness statement of Ken Crawley: Post Office -v- Castleton
Attachments: STATEMENT_1209673.DOC; MARINE Drive.XLS
STATEMENT_12096MARINE Drive.XLS.
73.DOC (50 KB) (22 KB)
Dear Richard,
I attach the latest version of Ken Crawley's statement. He's the witness who talks about what happens when a
customer collects their pension or allowance. He was not involved at the time.
We need to think about whether or not to use Ken's statement. Paras 5 and 6 of the statement may give the
impression that the Paid Order Unit in Lisahally manually check EVERY single paid foil received against the weekly
Horizon summary that accompanied them and that if the 2 don't match, an error notice is generated. However,
this is not the case.
When I interviewed Ken he said that in actual fact the POU get such vast quantities of foils that they do not
manually check all of them. Instead, unbeknown to the branches, they get put on a rota when their P&A
counterfoils will be checked against the Horizon summary. Approximately 400 to 500 branches get checked each
week meaning each branch would only be checked about once every 2 years. Marine Drive was checked:
1. on rota on 19 to 26 September 2002;
2. because of a £1,655 discrepancy, again from 14 to 19 August 2003; and 3. on rota on 27 January to 8
February 2005.
My understanding of the implications of this are that nobody would ever really know whether the P&A data was
being accurately inputted/recorded into Horizon because no-one was regularly comparing that against the foils
received from the branch. Therefore, the question for us is whether we put Ken's statement in as evidence.
Kind regards.
Stephen Dilley
Solicitor
for and on behalf of Bond Pearce LLP
Original Message-----
From: Stephen Dilley
Sent: 08 September 2006 09:22
~3 mandy. talbot..
‘atement of Ken Crawley: Post Office -v- Castleton
Cc: cheryl.woodward¢~
Subject: RE: Amended
Dear Ken,
Thanks for your email of 5 September.
I attach an amended version of your statement for approval, taking on board your comments. Just 2 points:
1. I assume filing of weekly (as opposed to daily) summaries was mandatory (para 6).
2. I understand that the attached excel spreadsheet shows some identical errors twice. Presumably this is just
needless repetition and those errors only occurred once? If so, would you mind deleting the duplicates from the
1
POL00069601
POL00069601
attached spreadsheet? (I think that might reduce the total errors to 16 and if you agree, we'll amend para 10 of
your statement accordingly).
T look fo: _-d to hearing from you as soon as possible.
Kind regards.
Stephen Dilley
Solicitor
From: ken.crawley;
Sent: 05 September 2006 11:25
To: Stephen Dilley
Subject: Re: Draft witness statement of Ken Crawley: Post Office -v- Castleton
Stephen
Thank you for your e-mail and attachments.
I've had a look at the Witness Statement and have made a few changes mainly involving the daily summary
aspect of the work. I have checked the process with a colleague from the Investigation Team and am now happy
that the statement is as good as it can be.
T have attached the revised version of the statement and changes are in red type. Answers to your questions are
also indicated in red.
(See attached file: P&A STATEMENT (Stephen Dilley).DOC)
Please do not hesitate to contact me again should you require any further information or clarification.
See you Monday.
Regards
Ken
Current Agents Debt Team
Post Office Ltd
1st floor West, 1 Future Walk, West Bars, CHESTERFIELD, S49 1PF
Postline External Email: ken.crawley:
Subject Draft witness statement of Ken Crawley: Post
Office -v- Castleton
Dear Ken,
I refer to our telephone conversation today and to our meeting on 29 August.
POL00069601
POL00069601
I attach_a draft Witness Statement for your approval. I have included some questions in bold italics and look
forward to hearing from you as soon as possible.
Kind reg,
Stephen Dilley
Solicitor
_for and on behalf of Bond Pearce LLP
www.bondpearce.com
The information in this e-mail and any attachments are confidential and may be legally privileged and protected
by law. The intended recipient only is authorised to access this e-mail and any attachments. If you are not the
intended recipient, please notify the sender as soon as possible and delete any copies. Unauthorised use,
dissemination, distribution, publication or copying of this communication is prohibited.
Any files attached to this e-mail will have been checked by us with virus detection software before transmission.
You should carry out your own virus checks before opening any attachment. Bond Pearce LLP accepts no liability
for any loss or damage which may be caused by software viruses.
Bond Pearce LLP is a Limited Liability Partnership registered in England and Wales number 0C311430,
Registered Office: 3 Temple Quay, Temple Back East, Bristol, BS1 6DZ.
A list of Members is available from our registered office. Any reference to a Partner in relation to Bond Pearce LLP
means a Member of Bond Pearce LLP.
Bond Pearce LLP is regulated by the Law Society.(See attached file:
STATEMENT_1207766.DOC)(See attached file: MARINE Drive.XLS)
FEO RISE OES RSS OSI ISIS SS OEE OR IEEIOSI ISIS OSE SKI RASS ARI AGRA AEA AKA AAA
This email and any attachments are confidential and intended for the addressee only. If you are not the named
recipient, you must not use, disclose, reproduce, copy or distribute the contents of this communication.
If you have received this in error, please contact the sender and then delete this email from your system.
JO RIO ORI RISE IESE OKIS OIRO OC SOROS EOS OFOBERIE GIRO IC ISI ICRA ASIII AE