POL00104198 - Email chain from Martin Smith to Laura Irvine re: Post Office Ltd - Apparent dispute between Post Office Ltd and Second Sight

Evidence on official site

POL00104198

POL00104198

From: Martin Smith
Sent: 24 September 2015 11:54
To: ‘Irvine, Laura’
Ce: Durham, Rana; Rodric Williams
Subject: RE: Post Office Ltd - Apparent dispute between Post Office Ltd and Second

Sight
Hi Laura,

A conference call at 10 a.m. on Monday 5‘ October fits well with me.

Simon Clarke of counsel will also be in attendance at the meeting on 6'* October 2015.
Although there is clearly some overlap in our knowledge, Simon and I have also dealt
with different issues over the last year or so quite separately, all of which may well be
relevant to the PF’s line of investigation.

Kind regards,

Martin.

Cartwright King

meer SOLS CET ORS mmm

Offices Nationwide
www cartwrightking.co.uk

Irvine, Laura
Sent: 22 September 2015 14:49
To: Rodric Williams
Cc: Martin Smith; Durham, Rana
Subject: RE: Post Office Ltd - Apparent dispute between Post Office Ltd and Second Sight

Rodric

My secretary will make the arrangements for you to be collected at the airport and brought here.

1808
POL00104198
POL00104198

Is 10am on Monday 5 October good for everyone?

Kind regards
Laura

Laura Irvine
Associate
Solicitor Advocate

bto solicitors

onal
Awat ds 213

edevetire

INNER -

UK DATA PROTECTION

LAW FIRM OF THE YEAR Follow us on:

From: Rodric Williams
Sent: 21 September 2015 1.
To: Irvine, Laura

Ce: ‘martin.smithy”
Subject: RE: Post Office Ltd - Apparent dispute between Post Office Ltd and Second Sight

Hi Laura.
I have confirmed flights for the meeting with the PF on 6 October 2015.
{arrive in Edinburgh at 0820am, with my return flight departing 1640pm.

Given that time might be tight, is there any chance you could arrange for me to be picked up at the airport
and brought to your office? [t would also be helpful to have a conference call at some point on Monday 5
October 2015 to make sure I have what I need with me.

Kind regards, Rodric

"a Rodric Williams
Solicitor, Corporate Services

Post Office Ltd

20 Finsbury Street, London EC2Y 9AQ

1809
POL00104198
POL00104198

From: Irvine, Laurai____ GRO
Sent: 14 September 2015
To: Miele, Paul
Cc: 'martin.smit!
Subject: RE: Post Office Ltd -

iRodric Williams
pparent dispute between Post Office Ltd and Second Sight

Paul

Many thanks. I have copied in the other two attendees so you have their email addresses. Martin is from
Cartwright King who prosecute on behalf of the Post Office and Rodric is in house counsel with the Post
Office.

Kind regards
Laura

Laura Irvine
Associate
Solicitor Advocate

bto solicitors

‘guntainbridge Edinburgh EH3 9QG

Awate

fvariss

UK DATA, PROTECI TION
LAW FIRM OFTHEYEAR Folic

From: Miele, Paul) ~ GRO
Sent: 14 September 2015 09:26
To: Irvine, Laura

Subject: RE: Post Office Ltd - Apparent dispute between Post Office Ltd and Second Sight

Morning Laura,

6" October appears to be the only date that suits.

Can you confirm e-mails of those who will be attending and I'll get an invite issued for calendars?
Vif ensure the meeting is late morning or early afternoon to accommodate those travelling up.
Thanks,

Paul Miele

1810
POL00104198
POL00104198

Procurator Fiscal Depute
Policy Divisi

From: Irvine, Laura
Sent: 11 September 2015 15:39
To: Miele, Paul

Subject: RE: Post Office Ltd - Apparent dispute between Post Office Ltd and Second Sight

Paul
Thanks you for your email.

How would Monday 5' October or Tuesday 6" October suit? Peopie are travelling so late morning or early
afternoon would probably best.

Kind regards
Laura

Laura Irvine
Associate
Solicitor Advocate

bto solicitors

GLOBAL} ©
Awatdssis
¢ “liveltivre

- WENNER -
UK BATA PROTECTION
LAW FIRM OF THE YEAR

From: Miele, Paul: _
Sent: 10 September 2015 13:03
To: Irvine, Laura

Subject: RE: Post Office Ltd - Apparent dispute between Post Office Ltd and Second Sight

Laura,

1811
POL00104198
POL00104198

Thanks for this. I spoke to DSC’s office and happy with the proposal to meet at Crown Office.

Can I leave you to identify a range of possible dates in early October when Post Office Ltd/Cartwright King
are available? I'll relay in turn to DSC and hopefully we can manage to find one that suits everyone.

Paul Miele
Procurator Fiscal Depute
Policy Di

From: Irvine, Laura:__
Sent: 04 September 2015 17:15
To: Miele, Paul

Subject: RE: Post Office Ltd - Apparent dispute between Post Office Ltd and Second Sight

Paul

{do not expect anyone from Second Sight to be there. It would be a lawyer from the Post Office and a lawyer
from the firm who prosecute on behaif of the Post Office.

jam waiting to hear from them but it seems that the week commencing 28 September will be the earliest I
can get them ail together.

Kind regards
Laura

Laura Irvine
Associate
Solicitor Advocate

bto solicitors

UK BATA PROTECTION sy
LAW FIRM OF THEYEAR = Eo rs

1812
POL00104198
POL00104198

From: Miele, Pauli
Sent: 04 September 2015 17:11

To: Irvine, Laura

Subject: RE: Post Office Ltd - Apparent dispute between Post Office Ltd and Second Sight

Laura,

Thanks for getting back to me and for providing the link. I’ve updated DSC’s office and will update as soon
as he gets back to me.

Also, just to clarify something but when you say others should be there at any prospective meeting do you
mean reps from Second Sight also?

Thanks,

Paul Miele
Procurator Fiscal Depute
Policy Division

From: Irvine, Laura
Sent: 03 September
To: Miele, Paul

Subject: RE: Post Office Ltd - Apparent dispute between Post Office Ltd and Second Sight

5 17:5

Paul

I was informed today that the second Second Sight report is publicly available and can be found here:

https:/Awww.scribd.com/fullscreen/262552400?access_key=key-
f3INShrw9boGLrYdmLwx&allow_share=true&escape=false&view_mode=scroll

Or do a Google search if that link does not work.

The Post Office response is not in the public domain and I do not have a copy, although I am told I
will sent a copy.

In any event, I think it is fair to say that things have moved on from the events earlier this year and
indeed from the Panorama programme. The Post Office has asked me to try and set up a meeting
with you, and the Director of Serious casework, if appropriate/possible to discuss where the Post
Office are with Horizon in a legally privileged setting. It is proposed that two solicitors attend — one
in house from the Post Office and another from Cartwright King — who prosecute on behalf of the
Post Office.

1813
POL00104198
POL00104198

What is your view on this proposal? I am happy to discuss things beforehand but my view is that
you require the others’ input to make a fully informed decision about the Post Office cases that are
in the COPFS system.

For your information we can identify 7 cases with COPFS at the moment. 4 have been reported by
the Post Office and 3 by the police as follows:

Post Office cases

HM13003852 against Christine Gourlay who appeared on petition in January 2015 and is with
Lauren MacRoberts

Case against Mr Hussein from Pollockshields Post Office which is with Angus Crawford (may have
marked no pro meantime)

Case against Aktar Bashir from Toryglen Post Office which is with Angus Crawford

Case against Anaum Khan from Winchburgh Post Office which was only reported in July 2015

Police cases

ED14019049 which is a summary case against Saquib Hussan who has a trial fixed for next week
1N15004777 against Holt — not marked yet we understand

DB15002295 against the SPM from Hardgate Post Office who is alleged to have stolen £6,500 from
a customer

I hope that this assists and I look forward to hearing your views on a meeting.

Kind regards
Laura

Laura Irvine
Associate
Solicitor Advocate

bto solicitors
One Edinburgh Q Quay 133 Fountainbridge Edinburgh EH3 9QG

AGS. BALy ©
Awat ie

UK BATA. PROTECTION
LAW FIRM OPTHEYEAR — Fotioy

1814
POL00104198
POL00104198

From: Miele, Paul
Sent: 03 September 2015 17:27
To: Irvine, Laura

Subject: RE: Post Office Ltd - Apparent dispute between Post Office Ltd and Second Sight

Thanks Laura.

I've been asked to update the DSC by the 11" September so grateful for any update by then.

From: Irvine, Laura‘.
Sent: 03 September 2015 10:19

To: Miele, Paul

Subject: RE: Post Office Ltd - Apparent dispute between Post Office Ltd and Second Sight

Paul
Apologies for the delay. I have a call with the Post Office today and will get back to you afterwards.

Kind regards
Laura

Laura Irvine
Associate
Solicitor Advocate

bto solicitors

GLOBAL

Awards.

edivedtive
~ WINNER

UK BATA PROTECTION

LAW FIRM OF THE YEAR

From: Miele, Paul {_
Sent: 26 August 2015 11:15

To: Irvine, Laura

Subject: RE: Post Office Ltd - Apparent dispute between Post Office Ltd and Second Sight

Thanks Laura.

From: Irvine, Laura
Sent: 26 August 2015 11:12
To: Miele, Paul

Subject: RE: Post Office Ltd - Apparent dispute between Post Office Ltd and Second Sight

1815
POL00104198
POL00104198

Paul

Thank you for your email. I will obviously have to consult with my client and get back to you as
soon as I can.

Kind regards
Laura

Laura Irvine
Associate
Solicitor Advocate

bto solicitors

Follow us on:

oon Original Message-.
From: Miele, Paul
Sent: 26 August 2015 10:47

To: Irvine, Laura

Subject: Post Office Ltd - Apparent dispute between Post Office Ltd and Second Sight

Good Morning Laura,

IT hope you're well and no doubt unsurprised that I'm getting in touch re Post Office Ltd.

The issue that's arisen is due to operational deputes getting in touch with me to highlight a
publicised dispute between Post Office Ltd and Second Sight following publication of the final
Second Sight report:

http://postandparcel.info/64576/news/the-uks-post-office-responds-to-horizon-report/

In turn I raised this with the Director of Serious Casework for his thoughts.

Unfortunately, we don't know, in the absence of the report and reply, if we require to do make any
changes to our policy/operational approach to prosecutions as a result.

I've been asked therefore to obtain copies of the final report and Post Office Ltd's reply in order that
we can consider what impact, if any, they have on our prosecution of Post Office Ltd cases.

Can these be provided in confidence to me and only for the purpose of inclusion in a minute to the
DSC?

1816
POL00104198
POL00104198

Thank you,

Paul Miele
Procurator Fiscal Depute
Policy Divi

This e-mail (and any files or other attachments transmitted with it) is intended solely for the
attention of the addressee(s). Unauthorised use, disclosure, storage, copying or distribution of any
part of this e-mail is not permitted. If you are not the intended recipient, please destroy the e-mail,
remove any copies from your system and inform the sender immediately by return.

Correspondents should note that all communications to or from the Crown Office and Procurator
Fiscal Service may be automatically logged, monitored and/or recorded for lawful purposes. Unless
expressly indicated, the views or opinions contained within this e-mail do not necessarily reflect
those of the Crown Office and Procurator Fiscal Service.

This message has been checked for the presence of computer viruses. Visit www.crownoffice.gov.uk
for details of the work of the Department.

The original of this email was scanned for viruses by the Government Secure Intranet virus scanning
service supplied by Vodafone in partnership with Symantec. (CCTM Certificate Number
2009/09/0052.) This email has been certified virus free.

Communications via the GSi may be automatically logged, monitored and/or recorded for legal
purposes.

This email (including any attachments) is confidential. Its contents are protected by copyright and may be privileged. If received in error
please contact us on +44 (0)141 221 8012 or at lawyers¢ and delete it from your system. Brechin Tindal Oatts ("bto") does not
accept any responsibility for viruses and it is your responsibility to scan this email (and any attachments). bto's email system is subject to
random monitoring

No contract may be concluded by bto by email unless the sender is a partner or associate of bto and the email expressly states that it is

intended to create a contract. Views expressed in this email are the views of the sender and may not reflect the views of bto. A list of the
partners of bto is available for inspection during office hours at 48 St. Vincent Street, Glasgow, G2 SHS.

This email was scanned by the Government Secure Intranet anti-virus service supplied by Vodafone
in partnership with Symantec. (CCTM Certificate Number 2009/09/0052.) In case of problems,
please call your organisations IT Helpdesk.

Communications via the GSi may be automatically logged, monitored and/or recorded for legal
purposes.

The original of this email was scanned for viruses by the Government Secure Intranet virus scanning

service supplied by Vodafone in partnership with Symantec. (CCTM Certificate Number
2009/09/0052.) This email has been certified virus free.

1817
POL00104198
POL00104198

Communications via the GSi may be automatically logged, monitored and/or recorded for legal
purposes.

This email (including any attachments) is confidential. Its,
please contact us on +44 (0)141 221 8012 or at lawyers
accept any responsibility for viruses and it is your respon
random monitoring.

No contract may be concluded by bto by email unless the sender is a partner or associate of bto and the email expressly states that it is
intended to create a contract. Views expressed in this email are the views of the sender and may not reflect the views of bto. A list of the
partners of bto is available for inspection during office hours at 48 St. Vincent Street, Glasgow, G2 SHS.

are protected by copyright and may be privileged. If received in error
nd delete it from your system. Brechin Tindal Oatts ("bto") does not
can this email (and any attachments). bto’s email system is subject to

This email was scanned by the Government Secure Intranet anti-virus service supplied by Vodafone
in partnership with Symantec. (CCTM Certificate Number 2009/09/0052.) In case of problems,
please call your organisations IT Helpdesk.

Communications via the GSi may be automatically logged, monitored and/or recorded for legal
purposes.

The original of this email was scanned for viruses by the Government Secure Intranet virus scanning
service supplied by Vodafone in partnership with Symantec. (CCTM Certificate Number
2009/09/0052.) This email has been certified virus free.

Communications via the GSi may be automatically logged, monitored and/or recorded for legal
purposes.

This email (including any attachments) is confidential. Its, contents ae protected by copyright and may be privileged. If received in error
please contact us on +44 (0)141 221 8012 or at lawyers¢ dnd delete it from your system. Brechin Tindal Oatts ("bto") does not
accept any responsibility for viruses and it is your ae oe {6 S¢an this email (and any attachments). bto's email system is subject to
random monitoring.

No contract may be concluded by bto by email unless the sender is a partner or associate of bto and the email expressly states that it is
intended to create a contract. Views expressed in this email are the views of the sender and may not reflect the views of bto. A list of the
partners of bto is available for inspection during office hours at 48 St. Vincent Street, Glasgow, G2 SHS.

This email was scanned by the Government Secure Intranet anti-virus service supplied by Vodafone
in partnership with Symantec. (CCTM Certificate Number 2009/09/0052.) In case of problems,
please call your organisations IT Helpdesk.

Communications via the GSi may be automatically logged, monitored and/or recorded for legal
purposes.

The original of this email was scanned for viruses by the Government Secure Intranet virus scanning
service supplied by Vodafone in partnership with Symantec. (CCTM Certificate Number
2009/09/0052.) This email has been certified virus free.

Communications via the GSi may be automatically logged, monitored and/or recorded for legal
purposes.

This email (including any attachments) is confidential. Its ¢¢
please contact us on +44 (0)141 221 8012 or at lawyers@_GRO.
accept any responsibility for viruses and it is your respon
random monitoring

No contract may be concluded by bto by email unless the sender is a partner or associate of bto and the email expressly states that it is
intended to create a contract. Views expressed in this email are the views of the sender and may not reflect the views of bto. A list of the
partners of bto is available for inspection during office hours at 48 St. Vincent Street, Glasgow, G2 SHS.

re protected by copyright and may be privileged. If received in error
ind delete it from your system. Brechin Tindal Oatts ("bto") does not
‘can this email (and any attachments). bto's email system is subject to

1818
POL00104198
POL00104198

This email was scanned by the Government Secure Intranet anti-virus service supplied by Vodafone
in partnership with Symantec. (CCTM Certificate Number 2009/09/0052.) In case of problems,
please call your organisations IT Helpdesk.

Communications via the GSi may be automatically logged, monitored and/or recorded for legal
purposes.

The original of this email was scanned for viruses by the Government Secure Intranet virus scanning
service supplied by Vodafone in partnership with Symantec. (CCTM Certificate Number
2009/09/0052.) This email has been certified virus free.

Communications via the GSi may be automatically logged, monitored and/or recorded for legal
purposes.

This email (including any attachments) is confidential. Its cor are protected by copyright and may be privileged. If received in error
please contact us on +44 (0)141 221 8012 or at lawyers@._ “and delete it from your system. Brechin Tindal Oatts ("bto") does not
accept any responsibility for viruses and it is your responsibility to scan this email (and any attachments). bto's email system is subject to
random monitoring.

No contract may be concluded by bto by email unless the sender is a partner or associate of bto and the email expressly states that it is

intended to create a contract. Views expressed in this email are the views of the sender and may not reflect the views of bto. A list of the
partners of bto is available for inspection during office hours at 48 St. Vincent Street, Glasgow, G2 5HS.

This email was scanned by the Government Secure Intranet anti-virus service supplied by Vodafone
in partnership with Symantec. (CCTM Certificate Number 2009/09/0052.) In case of problems,
please call your organisations IT Helpdesk.

Communications via the GSi may be automatically logged, monitored and/or recorded for legal
purposes.

The original of this email was scanned for viruses by the Government Secure Intranet virus scanning
service supplied by Vodafone in partnership with Symantec. (CCTM Certificate Number
2009/09/0052.) This email has been certified virus free.

Communications via the GSi may be automatically logged, monitored and/or recorded for legal
purposes.

This email (including any attachments) is confidential. Its contents are protected by copyright and may be privileged. If received in error
please contact us on +44 (0)141 221 8012 or at lawyers¢-~ ind delete it from your system. Brechin Tindal Oatts ("bto") does not
accept any responsibility for viruses and it is your responsi ‘an this email (and any attachments). bto's email system is subject to
random monitoring.

No contract may be concluded by bto by email unless the sender is a partner or associate of bto and the email expressly states that it is

intended to create a contract. Views expressed in this email are the views of the sender and may not reflect the views of bto. A list of the
partners of bto is available for inspection during office hours at 48 St. Vincent Street, Glasgow, G2 SHS.

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 by reply email and then delete
this email from your system. Any views or opinions expressed within this email are solely those of the sender,
unless otherwise specifically stated.

POST OFFICE LIMITED is registered in England and Wales no 2154540. Registered Office: Finsbury Dials,
20 Finsbury Street, London EC2Y 9AQ.

1819
POL00104198
POL00104198

This email (including any attachments) is confidential. Its contents are protected by copyright and may be privileged. If received in error
please contact us on +44 (0)141 221 8012 or at lawyers@ and delete it from your system. Brechin Tindal Oats ("bto") does not
accept any responsibility for viruses and it is your responsibility to scan this email (and any attachments). bto's email system is subject to
random monitoring

No contract may be concluded by bto by email unless the sender is a partner or associate of bto and the email expressly states that it is

intended to create a contract. Views expressed in this email are the views of the sender and may not reflect the views of bto. A list of the
partners of bto is available for inspection during office hours at 48 St. Vincent Street, Glasgow, G2 SHS.

1820