Application Form
POL00112928
POL00112928
For Second Sight use only
Case ref:
Your Details PR/752033/TTC7/SPM/SFF
Surname: Cousins
Forenames: Wendy
Your address:
2
°
Telephone number 1
Telephone number 2:
Email addres:
i GRO '
My current Member of Parliament is:
Mark Prisk
Your Branch
Please insert the details of the branch where you worked. If you worked at more than one branch,
please provide details on an extra sheet of paper.
Name of branch:
Hertford Heath
FAD Code of branch:
119 129 2
Address of branch:
14 London Road
Hertford Heath
Hertfordshire
Postcode: SG13 7RH
Your role at the branch (ie. Subpostmaster, Subpostmistress, clerk, etc.):
Subpostmistress
When did you begin in this role?
23” April 1997
Are you still in this role?
O YES
v NO 5" December 2006
If no, when did you leave this role: 5" December
2006
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Initial Case Overview
To the best of your knowledge, is your case (or any part of it) currently subject to any on-going criminal
investigations or proceedings (including the issue of a summons, sentencing hearings or a confiscation
order)?
O YES - you may still submit your case, but Second Sight may not be able investigate it whilst criminal
investigations or proceedings are on-going.
vy NO
The purpose of the ‘Initial Case Overview’ is to summarise the main issues you wish Second Sight to
consider. If your case is accepted for mediation, you will then have an opportunity to supply much more
detail together with supporting evidence.
The following Key Questions may help you with this Initial Case Overview but please feel free to supply
any information that you consider may help explain your complaint.
What is the main issue or issues you wish us to consider that relate to Horizon or its associated
processes?
Missing pouches containing green Giros
When did the incidents relating to the main issue or issues occur?
21/4/05 — 6/12/06
What prior contact have you had with the Post Office in regard to the incidents/issues that you are now
reporting?
Audit carried out 12/10/06 at P.O investigation team lead by Lisa Allan
How was the issue or issues resolved at the time they occurred?
None
What is the monetary value of the issue or issues you are now reporting?
£18,017.91
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Were you the subject of either civil recovery action or criminal prosecution regarding the main issue or
issues you are now reporting?
Criminal Prosecution
Repayment of approximately £20,000 this included 200 hours community service
Criminal record
How were these actions against you (if any) resolved?
I pleaded guilty
What is your explanation for the events forming the main issue or issues you are now reporting?
On the 6/10/2000 the horizon system was installed at Hertford Heath Post Office at the time there were
two of us working in the office myself and a part-time assistant Mrs Elizabeth Ann Lobacz (June 1998-
September 2006). We were given only 1 ID user password as the office was very small.
This was picked up in an audit on 3" May 2005. I tried on numerous occasions to correct this to give Mrs
Lobacz her own ID. I also contacted the Post Office helpline but they were unable to assist. On the 12"
October 2006 a further audit took place and again the auditor stated “obsolete users had not been
deleted from the horizon system” for security reasons these must be deleted to avoid the user account
being accessed and utilised without the knowledge of the original user.
There were no obsolete users on my system we couldn't put on the existing member of staff. I know now
that I should have queried this at the time to find out who had access to my computer but I didn’t (copies
of above audit migration forms available).
There were also discrepancies regarding transactions out of hours, copies of these I assume the Post
Office will still have.
I do have copies of horizon migration, audit reports etc if required. The case against me was produced by
the Post Office investigation team with “evidence” taken from the horizon system which I do believe to be
at best flawed.
REF: PR/752033/TTC7/SPM/SFF
On the 4" of December 2006 I received a call from the Post Office audit team asking what time the post
office opened as they were due to come and close the branch removing all items. I stated at the time that
I had no knowledge of any closure.
At 8:30am Tuesday 5" December 2006 two investigating officers lead by Lisa Allan plus an auditor
arrived, the Post Office was closed, never to reopen. I was informed that 14 pouches containing Green
Giros had gone missing and that they had proof that these giros had been reintroduced or over claimed.
The total being £30,121.69. The following day I tried to contact the Post Office with the number I had
been given by Lisa Allan and again tried on a daily basis, after writing to my local Parish Council and my
MP Mark Prisk (copies of all their correspondence and meetings with Post Office representatives
available) the Post Office agreed to meet with me. Up to this point however I had still not received any
paperwork or information regarding any of the alleged missing pouches so was unable to answer any
queries regarding them. The meeting proved to be pointless. A further meeting was arranged and I was
allowed some of the information but my contract was terminated on 26/04/2007.
In December 2007 I was informed that the Post Office were going to prosecute, I went to see a solicitor
and requested copies of all relevant paperwork, information etc. This was eventually received after
various court appearances the finale one on 29/7/2008 where an application to the court was made for
disclosure. These were then handed over 17/09/08. The case against me then showed an amount of
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£18,017.91 made up of reintroductions £14,553.32 and over claims of £3,464.59.
My best defence was to prove all giros that were cashed in my Post Office were all genuine (between 05
and 06) of which there were hundreds or plead guilty to some of them which I did following receipt of a
letter advising me what to pack as if found guilty I would be going directly to Holoway Prison.
I have never believed that these pouches went missing nor have I ever understood the Post Office
reluctance to at least and explain what could have happened. They have seemed all the way through this
to just accept what they think happened regardless.
I have a copy of an “extract of Incidents Database for the SG postcode in relation to missing vouchers
reported covering April 2005 and December 2006” this document shows 12 missing pouches at
£23,535.82 not 14 at £30,121.69.
I also have copies of giros attached to several DSS Identification dockets G6311 R/04 from various Post
Offices not mine with FAD codes ranging from 091/935 — 238-418 Fleet and Cumbria etc.
If these have been mixed up, misfiled is it not possible so have the missing giros. Missing postman's
collection sheets which I was advised had been destroyed although I had asked for copies of these as far
back as Friday 8" December 2006, the only ones which were not destroyed were the ones the Post
Office took at least two of which were not mine and 1 which was 1 year out of date.
I have been unable to list all the information but would be pleased to if requested.
The Post Office investigation team didn't only steal my families money but I also have a criminal record
for the rest of my life. I have no hope of ever getting another job and am restricted in whatever I might
wish to do as a result of this.
At an “off the record” meeting my solicitor and Lisa Allan agreed that they didn’t think that I was guilty,
well surely if they had their doubts then the prosecution was unsafe at best.
If you could please look into my case I would of course be most grateful as I am sure there are many
people who have or indeed work for the Post Office and they will never know when their life could be
turned upside down as mine was.
Did you request assistance from the Post Office regarding the issue or issues you are now reporting?
Yes
What assistance if any was provided?
None
Please attach additional sheets of paper if you require more space.
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Declaration
I acknowledge that:
° As part of the Scheme, I must promptly provide information about my case to Second Sight. If I
do not provide full information in a timely manner, I accept that it may not be possible to
investigate or mediate my case.
° Information I provide about my case or the findings of Second Sight's investigation may help
reach a resolution with Post Office but that it may also reveal further claims against me.
° 1am only entitled to financial support from Post Office if I have signed a Funding Agreement.
I confirm that:
. My case relates to the Horizon system or an associated issue.
. Post Office may communicate details of my case to Second Sight, JFSA, my Member of
Parliament and/or its professional advisors.
° The facts and matters set out in this Application are true and accurate to the best of my
knowledge and belief.
I confirm that I am:
O Currently serving as a Subpostmaster and have already raised my case with Post Office and have
completed all Post Office's internal complaint processes.
v Not currently serving as a Subpostmaster.
(Please tick one box)
If you are unable to give all the above acknowledgements and confirmations, your case may not be
eligible for the Scheme. In that circumstance, please contact the JFSA for assistance.
This Application Form and your involvement in the Scheme do not create any legally binding contract or
obligations between Post Office and you.
The Working Group, its members and their advisors owe no obligations or duties, and accept no liability,
to you in connection with the Scheme.
Signed W.Cousins
Name Wendy Cousins
Date 10/10/2013
CartwrightKing
Client Details somo $0 L 1 PY 0 RS ssmmmmniie
Full name Post Office Ltd
Greeting Sir
Case Number 41714
Account Ref
P00830-180-0
UFN Number Not a Legal Aid Matter
Supervisor Andy Cash
Fee earner Martin J Smith
Address
Date of birth _— _—
Home telephone number
Work telephone number }
Mobile number
Email address
NINO
Ethnicity
Disability
Gender Unknown
Source EXISTING
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Investigation Case Details
CartwrightKing
Full name Post Office Ltd
Case Number 41714
DSCC number 0
Police station None
Telephone number
Officer in case fe}
Officer's contact 0
number
Custody record number
Bail back date and time
30th day of December 1899 at 12:00 am
Offence
0
Date of offence
19 November 2013
Anticipated plea
Bail status
Unconditional police bail
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Client: Post Office Ltd
Case No.: 41714
Account Ref: P00830-180-0
UFN:
Fee Earner: MS2Matter: POL Mediation -
Cousins, W
POL MEDIATION SCHEME
APPLICANT: Wendy Cousins [ NUMBER: M052
POST OFFICE BRANCH: Hertford Heath In Post 23/4/97-5/12/06
Convicted / Cautioned / Acquitted (please
circle)
Pleaded guilty — 200 hours community service and
repayment of approx. £20K
Issues Raised in the Application
Monetary Value £18,071.91
Period: 21/4/05 — 6/12/06
1.
2.
3.
Horizon system — I consider to be flawed at best.
There was an issue relating to 14 missing pouches containing green giros.
I was told that there was proof that these giros had been reintroduced
(£14,553.32) or over claimed(£3464.50). it was difficult to prove my
innocence so entered guilty plea to avoid prison
Applicant claims to have evidence of mixed up giros from other offices. if
these had been mixed up or misfiled, he asks if it is not possible the same
has happened to the missing giros in his case.
CATEGORY
Horizon System yes
Training Issues
Support
Other
Loss of
green
giro
pouches
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Bundler 1
From: Leigh-Doyle, Cathal
Sent: 06 March 2014 15:42
To: martin smith
Subject: M052 Legal Report [BD-4A.FID25887221]
Attachments: _DOC_28357260(1)__DOC_28318542(1)_M052_POL Preliminary Investigation
Report_PML amends 5 March 2014.D0C
Hi Martin
Please find M052's legal investigation report attached. Your comments would be appreciated.
The solicitor has asked me to highlight one comment:
I would also flag this as one that may have early settlement potential — the claim is not properly quantified but
currently stands at around £30,000 which is close to BD's assessment against the settlement policy. The evidence put
forward by POL in the investigation report rebuts a lot of the allegations put forward by the applicant to the extent that
a small offer may persuade the applicant to settle (this is caveated with that the evidence POL has may lead it to take
the view that out of principie it will not settle this claim). As the applicant was subject to criminal prosecution any
settlement offer would need to be carefully worded.
Kind regards
Cathal
Cathal Leigh-Doyle
Trainee Solicitor
for and on behalf of Bond Dickinson LLP
Follow Bond Dickinson:
Hin}
www.bonddickinson.com
POL00112928
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Bundler 1
From: Leigh-Doyle, Cathal <_
Sent: 06 March 2014 15:42
To: martin smith
Subject: M052 Legal Report [BD-4A.FID25887221]
Attachments: _DOC_28357260(1)__DOC_28318542(1)_M052_POL Preliminary Investigation
Report_PML amends 5 March 2014.D0C
Hi Martin
Please find M052's legal investigation report attached. Your comments would be appreciated.
The solicitor has asked me to highlight one comment:
I would also flag this as one that may have early settlement potential — the claim is not properly quantified but
currently stands at around £30,000 which is close to BD's assessment against the settlement policy. The evidence put
forward by POL in the investigation report rebuts a lot of the allegations put forward by the applicant to the extent that
a small offer may persuade the applicant to settle (this is caveated with that the evidence POL has may lead it to take
the view that out of principie it will not settle this claim). As the applicant was subject to criminal prosecution any
settlement offer would need to be carefully worded.
Kind regards
Cathal
Cathal Leigh-Doyle
Trainee Solicitor
for and on behalf of Bond Dickinson LLP
Follow Bond Dickinson:
Hin}
www.bonddickinson.com
ievied by law. martin, sm
POL00112928
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Bundler 1
From: Leigh-Doyle, Cathal </
Sent: 06 March 2014 15:42
To: martin smith
Subject: M052 Legal Report [BD-4A.FID25887221]
Attachments: _DOC_28357260(1)__DOC_28318542(1)_M052_POL Preliminary Investigation
Report_PML amends 5 March 2014.D0C
Hi Martin
Please find M052's legal investigation report attached. Your comments would be appreciated.
The solicitor has asked me to highlight one comment:
I would also flag this as one that may have early settlement potential — the claim is not properly quantified but
currently stands at around £30,000 which is close to BD's assessment against the settlement policy. The evidence put
forward by POL in the investigation report rebuts a lot of the allegations put forward by the applicant to the extent that
a small offer may persuade the applicant to settle (this is caveated with that the evidence POL has may lead it to take
the view that out of principie it will not settle this claim). As the applicant was subject to criminal prosecution any
settlement offer would need to be carefully worded.
Kind regards
Cathal
Cathal Leigh-Doyle
Trainee Solicitor
for and on behalf of Bond Dickinson LLP
Follow Bond Dickinson:
Hin}
www.bonddickinson.com
and mnay he.
ot martin smith
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Bundler 1
From: martin smith
Sent: 07 March 2014 09:34
To: Harry Bowyer
Ce: Simon Clarke; Chris Powell
Subject: FW: M082 Legal Report [BD-4A.FID25887221]
Attachments: DOC_28357260(1)__DOC_28318542(1)_M052_POL Preliminary Investigation
Report_PML amends 5 March 2014.D0C
Harry,
Please see the attached.
This relates to a convicted applicant and it is clear from the e-mail below that POL/BD are
considering a settlement in relation to this case.
I doubt that we will have reviewed this case as, according to the proposed response, it was
concluded prior to 1/1/10.
This is not a case which can be dealt with urgently. You will undoubtedly need to see the lever
arch file and I propose to ask JS to have the criminal file sent through to us.
M
From: Leigh-Doyle, Cathal [mailt
Sent: 06 March 2014 15:42
To: martin smith
Subject: M052 Legal Report [BD-4A.FID25887221]
GRO
Hi Martin
Please find M052's legal investigation report attached. Your comments would be appreciated.
The solicitor has asked me to highlight one comment:
I would also flag this as one that may have early settlement potential ~ the claim is not properly quantified but
currently stands at around £30,000 which is close to BD's assessment against the settlement policy. The evidence put
forward by POL in the investigation report rebuts a lot of the allegations put forward by the applicant to the extent that
a small offer may persuade the applicant to settle (this is caveated with that the evidence POL has may lead it to take
the view that out of principle it will not settle this claim). As the applicant was subject to criminal prosecution any
settlement offer would need to be carefully worded.
Kind regards
Cathal
POL00112928
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Cathal Leigh-Doyle
Trainee Solicitor
for and on behalf of Bond Dickinson LLP
www.bonddickinson.com
environment! Do
s e-mail ay attachment
> access this e-mail and
<i by law. martin.smitit” GRO i
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POL00112928
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Bundler 1
From: martin smith
Sent: 07 March 2014 13:54
To: ‘Leigh-Doyle, Cat
Ce: Jarnail A Singh (~~
Subject: RE: M052 Legal Repoi
Hi Cathal,
We will need to see the criminal file in relation to this case. Could you arrange for it to be sent
through to us please?
Many thanks,
Martin.
From: Leigh-Doyle, Cathal [mailtoy
Sent: 06 March 2014 15:42
To: martin smith
Subject: M052 Legal Report [BD-4A.FID25887221]
Hi Martin
Please find M052's legal investigation report attached. Your comments would be appreciated.
The solicitor has asked me to highlight one comment:
I would also flag this as one that may have early settlement potential - the claim is not properly quantified but
currently stands at around £30,000 which is close to BD's assessment against the settlement policy. The evidence put
forward by POL in the investigation report rebuts a lot of the allegations put forward by the applicant to the extent that
a small offer may persuade the applicant to settle (this is caveated with that the evidence POL has may lead it to take
the view that out of principie it will not settle this claim). As the applicant was subject to criminal prosecution any
settiement offer would need to be carefully worded.
Kind regards
Cathal
Cathal Leigh-Doyle
Trainee Solicitor
for and on behalf of Bond Dickinson LLP.
POLO00112928
POL00112928
Follow Bond Dickinson:
www.bonddickinson.com
martin.smith” "GRO,
please notify cathaleigh-
on, publicabion or copying of this
dential and
nents, If you ave not martin.smithi
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This email is sent for and on behalt of Bond Dickinson LLP which is a liewfed lability partnership eegistered in England and Wales under nuotber OC3
s Wharf, 12) , Newcastle Upon Tyne, NE? ADX, where a list of mentbe
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Bond Dickinson LLP is authorised and regolated by the Soficitors Regufation Authority
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Bundler 1
From: Leigh-Doyle, Cathal
Sent: 07 March 2014 13:55
To: martin smith
Subject: Automatic reply: M052 Legal Report [BD-4A.FID25887221]
Thank you for your email.
lam now out of office for the day. I will have access to my emails tonight and I will respond to your email then. If you
ssistance in the meantime please contact my secretary Tiffany Readhead. Tiffany can be contacted on
GRO Sor at ti tiffany.readhead:
Kind regards
Cathal
POL00112928
POL00112928
Bundler 1
From: Leigh-Doyle, Cathal
Sent: 09 March 2014 10:
To: martin smith
Subject: RE: M052 Legal Report [BD-4A.FID25887221]
Hi Martin
1 will chase this.
Kind regards
Cathal
Cathal Leigh-Doyle
Trainee Solicitor
for and on behalf of Bond Dickinson LLP
Follow Bond Dickinson
ty
www.bonddickinson.com
From: martin smith [mailto
Sent: 07 March 2014 13:54
To: Leigh-Doyle, Cathal
Cc: Jarnail A Singh
Subject: RE: M052 Legal Report [BD-4A.FID25887221]
Hi Cathal,
We will need to see the criminal file in relation to this case. Could you arrange for it to be sent
through to us please?
Many thanks,
Martin.
POL00112928
POL00112928
From: Leigh-Doyle, Cathal [mailto GRO
Sent: 06 March 2014 15:42 . a ~~
To: martin smith
Subject: M052 Legal Report [BD-4A.FID25887221]
Hi Martin
Please find M052's legal investigation report attached. Your comments would be appreciated.
The solicitor has asked me to highlight one comment:
I would also flag this as one that may have early settlement potential — the claim is not properly quantified but
currently stands at around £30,000 which is close to BD's assessment against the settlement policy. The evidence put
forward by POL in the investigation report rebuts a lot of the allegations put forward by the applicant to the extent that
a small offer may persuade the applicant to settle (this is caveated with that the evidence POL has may lead it to take
the view that out of principie it will not settle this claim). As the applicant was subject to criminal prosecution any
settlement offer would need to be carefully worded.
Kind regards
Cathal
Cathal Leigh-Doyle
Trainee Solicitor
for and on behalf of Bond Dickinson LLP
jaw. martin smith}
athal.leigh-
an or copying of this
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GRO H
This en
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Bond Dickinson LLP is authorised and regelated by the Solie
Initial Complaint Review and Mediation Scheme
Post Office Preliminary Investigation Report
Branch Name: Hertford Branch Code: I 119129 Case Number: I M052
Heath
Applicant Name: I Wendy Status of Mediation Date of 23 April 1997
Susan Case: Application Appointment:
Cousins
Executive summary
Background
The Applicant held the post of Subpostmaster at the Hertford Heath branch from 23 April 1997 until
her precautionary suspension of 6 December 2006. The Applicant was subject to an audit at the
branch on 5 December 2006. The suspension was due to a security investigation related to Green Giro
Cheque fraud and not as a result of the audit findings.
Following an investigation into discrepancies at the branch, the contract at Hertford Heath was
terminated on 26 April 2007 and the Applicant gave notice to appeal against the decision. The appeal
was undertaken and the outcome was to uphold the termination of the Applicant's contract. The
decision was communicated on 15 June 2007.
The Applicant was subject to a criminal prosecution following the security investigation. On 5 May
2009, at St. Albans Magistrates Court, the Applicant pleaded guilty to 11 charges of theft and asked for
23 other offences to be taken into consideration — the whole amounting to £13,759.38 (£13,000 was
repaid on 21% May 2009).
On 28 May 2009, the Applicant was sentenced to 9 months imprisonment suspended for 2 years with
a requirement to complete 200 hours of unpaid work. She was ordered to repay the remaining
£759.38 and £2000 towards the prosecution costs.
A plea of guilty to a charge entails a complete admission to the offence. In this case she has admitted
stealing £13,759.38. When a defendant asks for offences to be taken into consideration she is
admitting the offences and asking the judge to take account of them in sentencing. This is effectively a
final disposal of those offences which cannot be resurrected in subsequent proceedings.
Further to her guilty pleas she offered in mitigation that the thefts occurred to assist her elderly
mother financially. Such mitigation cannot be advanced by counsel unless counsel have instructions
from the defendant to that effect.
Applicant’s complaint
The Applicant’s complaint centres on missing Green Giro Pouches/Cheques between 27 April 2005
and 4 October 2006.
The other key areas raised by the Applicant are:
1) Inadequate training provided by Post Office;
2) Horizon issues /reconciliation discrepancies;
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3) Unhelpful communications with the helpline, auditors and investigators;
4) Hardware problems experienced in the Hertford Heath branch;
5) Flaws in the investigation; and6) Various forms of loss suffered by the Applicant in relation to this
matter.
Issues with the Applicant’s branch and subsequent investigations The accounting process for Green
Giro Cheques dispatched from Hertford Heath Post Office highlighted concerns with this branch. At
the end of each accounting week, the Green Giro Cheques accepted from customers for cash
payments were summarised and forwarded to Girobank in pre-addressed pouches. The Green Giro
Cheques are verified against the branch accounting records and client reconciliation. It was noted by
Girobank that several pouches from this branch were not received and the contents did not reconcile
with the Giro Cheques entered manually on Horizon.
It was noted in Girobank, and notified to Post Office, that some Green Giro cheque pouches that were
recorded as being dispatched by the branch were not received by Girobank. It was further noted that
some of the Green Giro Cheques received were date-stamped (which records the branch details and
date of transaction) with a later date than would have been expected and these dates correlated with
the dates of weeks when an expected pouch was not received at Girobank.
These are described as ‘overclaims’ as the Green Giro Cheques have been claimed once in the week of
the “missing” pouch and again in a subsequent week when the pouch was received. These were
overclaims as without the supporting Green Giro Cheque, Post Office cannot reclaim the money from
Girobank that was paid by the branch to the customer.
If these overclaims were the result of genuine errors, these activities would have created positive
discrepancies in the branch which would offset the overclaims (eg. the branch would still be holding
the Green Giro Cheques that were missed from the remittances which would create a positive surplus
of Green Giros in the branch).
However, given the volume of the overclaims and the fact that positive discrepancies were not
reported by the branch, it is Post Office’s view that these were not errors but deliberate acts of
recording duplicate remittances of the same Giro cheque. The effect of this is that any surplus that
would have been recorded from a genuine error has not occurred and it is likely that this was a sign of
theft within the branch.
This is further supported as no issues with Green Giro cheques were raised during the Applicant’s
period away from the branch in Barbados in April 2006.
Post Office Security, consequently, conducted an investigation into the activities at the branch
relating to Green Giro cheques. This led to the audit of 5 December 2006.
It is accepted by Post Office that an error was made in contacting the branch the day prior to the
audit. This was due to a misunderstanding between the Audit Manager and the Auditor and should
not have happened.
The purpose of the audit undertaken on 5 December 2006 was to verify assets (cash and stock) held
in the branch at that time. Given that the overclaims and reintroductions of Green Giro cheques had
taken place before the audit and no positive discrepancies were reported as they should have been,
the audit result would not reflect the overclaims and reintroductions. Any resultant negative
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discrepancy from the Green Giro Cheque activity would only come to light when remote checks were
undertaken, as they were in this case, and returned to the branch as a transaction correction.
Post Office presented its findings to the Applicant on the day of the Audit and the Applicant attended
an interview with the Contracts Manager on 20 February 2007 to offer reasons why the Applicant’s
contract should not be terminated. At the interview, the Applicant stated that she had not received
the evidence relating to the Green Giro Cheque discrepancies and the Contracts Advisor offered to
reschedule but the Applicant wished to continue. A further interview was offered once the evidence
had been supplied to allow the Applicant time to prepare her arguments as to why her Contract
should not be terminated. The second interview took place on 2 April 2007. Post Office cannot
support the Applicant’s claim that it was not interested in her perspective as the Applicant was given
sufficient opportunity to state her explanation for what took place in the face of evidence presented
to her by Post Office.
At St Albans Crown Court on 28 May 2009, the Applicant pleaded guilty to 11 counts of theft and
accepted 23 other offences. She subsequently offered in mitigation that she had perpetrated this
fraud to assist her elderly mother financially. The evidence supplied by Post Office was subject to
scrutiny by the judicial system at this time. Therefore it is Post Office’s view that the evidence
supplied was not poor or flawed as the Applicant claims.
The Applicant cites that training on Horizon was inadequate. The standard training package was
delivered at the time Horizon was introduced. There were no requests for additional training logged
by the Network Business Support Centre (“NBSC”) during the Applicant’s period of tenure. Given that
there were no balancing issues and only three transactional corrections issued, Post Office would
state that this indicates an adequate working knowledge of Horizon procedures.
During the period examined, there was one call to the NBSC logged relating to Horizon hardware,
specifically the back office printer which would have no effect on frontline services. There is one call
logged relating to a loss of online services on 4 August 2005. This is a considerable time before the
issue with the Green Giro Cheques. Post Office is unable to support the view that Horizon hardware
or software issues had any bearing on this complaint. In conclusion, the Green Giro Cheque activity
undertaken at this branch, to which the Applicant pleaded guilty in criminal proceedings, led directly
to the Applicant’s suspension and termination of her contract. In Post Office’s view, the Horizon
training delivered was adequate and this is supported as no additional training was requested by the
Applicant and no balancing discrepancies reported. There is no evidence of any Horizon hardware or
software issues causing discrepancies at the branch.
The Applicant's complaint
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The Applicant has raised issues concerning missing giro cheque pouches. Her complaint was received
by Post Office via Second Sight on 8 November 2013. A more detailed Case Questionnaire (CQR) was
received on 16 January 2014.
The Applicant claims:
1. Post Office’s actions have had a devastating impact on her health, relationships, family life,
financial situation and her standing in the community.
2. Post Office treated her dismissively, placed upon her the burden of proving her innocence
and provided sketchy, flawed documentation in support of its assertions.
The Applicant was only able to obtain a copy of transactional documentation from Post
Office after she had her contract terminated and only as a result of a court order forcing Post
Office to produce the information.
There is ample evidence that the analysis undertaken by Post Office was weak and flawed
because the audit trail for Giro cheques is non-existent and relies purely on Post Office
assuming cheque values relating to specific individuals. The weak controls over Giro cheques
after they leave the branch mean that it is an area where fraud could easily be perpetrated
by pouches being tampered with or redirected and Giro cheques cashed again at other Post
Offices. The Applicant claims that if this was the case it is totally outside of her control at the
branch where they were cashed in the first place.
No transaction corrections were raised during the 18 month period Post Office claimed the
Giro pouches had gone missing.
Post Office’s investigative interviews cannot be described as serious attempts to either
identify underlying reasons or listen to and address the Applicant’s concerns.
Post Office's notes of the interview undertaken by the Contract Advisor on 2 April 2007 were
only loosely related to the actual verbatim transcript of the recording taken by the Applicant.
Absent from the interview notes were the 6 pages of detailed arguments forwarded by the
Applicant to either explain or undermine the points raised by Post Office in relation to the
missing Giro pouches.
Post Office deliberately manipulated data to make it look as if overclaims and
reintroductions had occurred when in fact there were much simpler and more obvious
explanations available.
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Case Review Actions
Information available from Post Office records:
Information area Information Information not Information not available for
provided with available as beyond other reason
this response retention period
NBSC Call Logs x
Record of Transaction x
Corrections
Training Records x
Audit Reports x x
Fujitsu Data x
Contract Manager x
Contacts
Financial Service Centre I x
Report
Post Office Investigation I x
Crown Court x
Prosecution
Record of Network Business Support Centre Call logs ~ (Doc 001 refers)
© 43 calls were recorded between 6 April 2005 ~ 19 December 2006
24 calls from Applicant, 14 from Elizabeth Lobacz (staff member), 2 from Auditor, 1 from Hoddesdon Crown
Office, 2 from Horizon Service Desk (HSD).
© 2005
6 calls refer to transactional knowledge for customer service, 5 refer to balancing, 1 wrong number.
Lrefers to Horizon
4 August 2005 — Elizabeth Lobacz reports online service not working (this allows banking transactions to take
place).
° 2006
17 calls refer to transactional knowledge for customer service, 2 refer to balancing, 3 refer to operational
processes, 2 requests for contact from the Contracts Advisor, 2 refer to Auditor procedures, 1 request for
branch status
3 refer to Horizon
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12 April 2006 — Elizabeth Lobacz reports that the back office printer has not printed Branch Trading
Statement (BTS) and requests advice on how to reprint the BTS.
24 April 2006 — The HSD contacts the branch to inform it that the BTS is overdue and the call is closed on
production of the BTS.
5 December 2006 — The HSD updates the branch status on the NBSC databases
Record of Transaction Corrections (TC) (Doc 002 refers)
5 December 2005 — 21 October 2006
3 Transaction Corrections issued — Total £345.00 invoice.
2 refer to cheques dispatched
L refers to a Stock Remittance discrepancy
Audit Reports (Doc 003,004 refer]
03 May 2005 — discrepancy of £60.31(-) (£6.86 (+) in cash, £56.92 (-) in stock, £10.25 (-) previous discrepancy
not made good)
12 October 2006 — discrepancy of £4.10(+), (£1.18(-) in cash, £5.28(+) in stock)
05 December 2006 — discrepancy £32.91(+) cited on CQR. Post office unable to locate report.
Post Office are unable to determine why the Applicant was suspended the day after the date of the audit.
Fujitsu Data
HSD logs are not available as the retention period has expired.
The records of calls on Horizon hardware issues have been sourced from the NBSC Call Logs.
Response to issues raised by Applicant
Issue raised Investigation findings
1 Insufficient Training to impart a full The standard induction training for new
understanding of Horizon - initial two Subpostmasters in 1997 consisted of 10 days training
weeks and 1.5 days when Horizon in branch followed by 1 day of support for the first
installed. balance. The standard training was considered
adequate and effective. This training related to the
pre-Horizon era.
Post Office is unable to confirm when this training
was delivered for this branch as the retention period
for the relevant data has expired.
It is stated on the Applicant’s CQR that the initial two
weeks of training was received.
The standard training for Horizon prior to the system
going live was one day of off-site training for agents
and staff covering customer service and balancing
with an additional day for agents to cover branch
accounting and back office functions.
Training Manuals and workbooks were supplied to
each branch. This branch went live with Horizon on 6
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October 2000.
Records indicate that there were no requests for
additional training by the Applicant registered with
the NBSC. (Doc 012 Refers)
Records indicate there were no discrepancies or
balancing issues reported by the branch from the
date of appointment on 23 April 1997 until
suspension on 6 December 2006 as cited in the
Applicant’s CQR.
It is Post Office’s view this indicates that the
Applicant and staff member had knowledge of Post
Office transactions and balancing procedures.
Applicant received a call from Post Office I Post Office audit procedures require an auditor to
Audit Team regarding branch closure on _I contact a branch in advance of attending a branch
4 December 2006. that is closing. Other audits are not notified to
Subpostmasters in advance.
Evidence shows that the branch was contacted by an
auditor on the day prior to the audit of 5 December
2006. This was due to a communication failure
between the auditor’s line manager and the auditor.
The auditor believed arrangements were being made
for a business as usual closure.
In summary this call should not have been received
by the Applicant and was an error on Post Office’s
part.
Final audit result was a discrepancy of __I Acash and stock audit undertaken on 5 December
£32.01 (+). How does this relate to 2006 resulted in a discrepancy of £32.01 (+). This was
discrepancy of £18,000(-) claimed by cash and stock verification audit whereby cash and
Post Office. stock on hand at the branch is compared to the
reported figures on Horizon.
The audit was undertaken due to concerns from the
Security & Investigation Team regarding office
accounting procedures at the branch. Asset
verification of the branch is the initial course of
action that is taken in such circumstances.
Acash and stock verification audit would not have
included the discrepancy of £18,000(-) regarding
reintroductions or overclaims in respect of the Giro
cheques as these had been accounted for in previous
balances.
The practice of reintroducing Giro cheques would
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have resulted in a surplus at the branch. As there
were no surpluses declared, an investigation was
undertaken to understand what had occurred at the
branch.
Why were no transaction corrections There is evidence that Post Office was made aware of
raised in respect of over-claimed Green missing Green Giro cheque pouches for this branch
Giros during the period concerned? on 10 February 2006. This information was passed to
the Security Team to conduct an investigation. (Doc
019 refers) This document contains no indication of
who it was created by.
Green Giro Cheque Process
Green Giro cheques are input into Horizon at the
time the customer is at the counter. As a minimum,
these should be checked to the print out report from
Horizon. If this is reconciled, the cheques report
printout is finalised and remain in branch until the
weekly dispatch. These finalised cheques will not
appear on the next report listing but will remain on
the office accounts until the end of the week balance
is completed. The cheques are then dispatched
weekly from the branch to Girobank, Bootle. These
are verified against the branch accounting records
and client reconciliation.
The investigation centred on missing Giro pouches.
The over-claiming of Giro cheques through Horizon
was identified as part of this investigation into
missing pouches.
Re-introduction & Overclaims
Re-introduction occurs when a cheque from a
previous accounting week is introduced to the batch
of cheques sent to the processing centre in a
following week.
Overclaims occur when an amount is claimed as paid
to customers but there is no cheque to support the
claim.
If the outcome of the investigation had identified an
alternative cause for the missing pouches, the issuing
of TCs to the branch would have been incorrect.
The Applicant was only ordered to pay the amount of
the admitted offences (namely £13,759.38) following
the outcome of the criminal proceedings.
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Post Office never addressed the Examination of NBSC call logs from 17 October 2000
hardware issues regarding printer to 19 December 2006 shows a total of five calls
problems and screen freezes despite referring to Horizon. (Doc 012 refers)
repeated requests from the Applicant
Four of these callls refer to the Applicant reporting
Horizon switching off or screen freezes between 2
May 2001 and 24 July 2002. There were no
discrepancies reported by the branch between these
dates.
On 12 April 2006, the branch assistant reported a
fault with the back office printer, and requested
information on reprinting the branch trading
statement.
There were no other calls relating to Horizon
hardware or software issues.
There is no evidence that these hardware events
caused any discrepancies and the Applicant states in
the CQR that discrepancies did not occur in branch.
Only allowed one Horizon user in branch I 6 October 2000 - Horizon was introduced at this
when Horizon was installed. branch.
Each branch was supplied with a Horizon System
User Guide that consisted of 2 ring binders with
booklets detailing how to:
(a) process transactions on Horizon
(b) complete general administration and balancing
procedures.
In Volume 2 under the heading of General
Administration, subheading Security, Subsection
20.1, Breaches of Security, (Doc 011 refers) clearly
states that:
e (i) ‘Any misuse of the system could lead to
an offence under the Computer Misuse
and/or Data Protection Acts’,
(ii) ‘Users are accountable for any action
undertaken with their user name and
password’
(iii) ‘Users are responsible for ensuring their
password is kept private and not revealed to
any other person’.
Subsection 20.3 states that:
e ‘Whenever you need to use the Horizon
system, you will be required to personally
identify yourself by entering your user
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name. Your user name is unique within your
office and is used to control what you do,
according to the requirements of your job. It
will allow you to access information and to
change what you are authorised to change,
but will prevent you from accessing or
accidentally changing anything else.’
This would also have been emphasised in the initial
training given and as a part of any subsequent audit
activity undertaken at branches.
Specifically in response to the complaint that only 1
user was allowed when Horizon was installed, every
user is able to have 2 User IDs and as many users on
Horizon as is required to operate the branch, usually
determined by number of staff employed at branch.
Setting up stock units and User IDs at the Initial on-
site support when Horizon was installed would have
been the responsibility of the migration officer. The
fact that obsolete user issues were raised indicates
that there was more than one user on Horizon. Post
training, the addition of users to Horizon would be
the responsibility of the Subpostmaster.
Unable to create additional users despite I There is no evidence on any of the NBSC call logs that
contact with the Helpline on numerous _I the Applicant had requested assistance with regards
occasions to assist with this. to creating additional user accounts on Horizon (doc
012, 001 refer).
The process for adding user accounts is clearly stated
in the Horizon System User Guide Volume 2, General
administration, User Administration, Subsection 11
pages 35 -39 (doc 013 refers).
The note of the interview conducted by the Contracts
Advisor on 20 February 2007 shows the Applicant
was asked to confirm when she had contacted the
NBSC about setting up user accounts.
The Applicant was also asked to provide the branch
copy of the audit report indicating that the auditor
could not create a user account for her assistant. The
Applicant failed to provide evidence on both counts
{doc 006 refers).
There is no evidence that auditors unsuccessfully
attempted to create users on Horizon.
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The Applicant invites Post Office to
explain how ‘obsolete’ users could be on
Horizon as advised on audit of 12
October 2006.
Obsolete users are User Ids that relate to staff who
are no longer employed in the branch.
Post Office was unable to obtain details of any
obsolete users at the time of this audit due to the
expiry of Fujitsu data.
Checks with Human Resources show that there were
no assistants registered at this branch since 2002.
(Doc 023 refers).
The Applicant asks Post Office to
determine whether the existence of
‘obsolete’ users implies that the
terminals could have been accessed
remotely by Post Office or Fujitsu.
Post Office and Fujitsu cannot access remotely any
live transactions and cannot impact on branch
balances. (Doc 017 refers)
10
The Applicant claims that the
investigation and subsequent evidence
was flawed
Records shows that the Investigation was reviewed
by Post Office legal advisors.(Doc 018 refers)
The investigation and subsequent evidence were
subject to scrutiny by the judicial system and any
flaws would have caused the court case to cease.
Additional Information
There is evidence that during sentencing at St Albans
Crown Court on 28 May 2009, the Applicant offered
mitigating circumstances.
‘Her elderly and sick mother was unable to obtain
financial assistance for items needed such as a
wheelchair and a downstairs toilet as she owned her
‘own property. The Applicant had therefore
perpetrated this fraud to assist her mother with
obtaining these items’, (Doc 015 refers)
There is evidence that members of the Applicant's
family attempted to intimidate the investigating
manager (Doc 016 refers)
1
Post Office was not remotely interested
in her perspective and was routinely
slow to respond to requests for
supporting documentation.
Records show that a contractual interview was held
by the Contracts Advisor on 20 February 2007, having
been postponed twice to accommodate the
Applicant.
During the interview, the Applicant made it clear that
while she had not received the typed summary of the
investigation interview carried out on S December
2006, she had received the tape (as stated in the
interview notes from the meeting of 20 February
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2007 — Doc 006 refers).
The Applicant had also not received the evidence
supplied by the investigation manager relating to
Green Giro pouch discrepancies in weeks 22 to 31,
2006.
The Contracts Advisor immediately offered to stop
the interview and reschedule after the Applicant had
time to review the documentation. This offer was
declined by the Applicant and her representative
from the National Federation of Subpostmasters
(NFSP) who decided that the interview could
proceed,
The Contracts Advisor sent a letter containing
interview notes to the Applicant on 27 February
2007. The Applicant responded on 6 March 2007
saying she did not agree with the contents of the
notes as a true record of events mainly because she
had not previously received the copies of the
Investigation Report relevant to her case.
The contracts advisor then wrote to the Applicant on
7 March 2007 exceptionally offering a further
interview due to the Applicant having not received
the relevant paperwork prior to the first interview
and to ensure that the Applicant was offered the best
opportunity to put forward her case.
Copies of the Green Giro cheque summaries and the
interview transcript from 5 December 2006 were
sent with the letter. On receiving no response from
the Applicant, the Contracts Advisor contacted her
‘on 14 March 2007 to ask whether the Applicant
intended to attend a further interview. The Applicant
claimed that she had not received the letter dated 7
March 2007 which had been sent by Special Delivery.
Royal Mail stated that they had attempted to deliver
the letter on 9 March 2007 but as no-one was there
to receive it, a card was left at the address. The card
would have shown the address where the item could
be collected.
Royal Mail was asked to re-deliver the letter and a
further copy was sent by ordinary post. Post Office is
unable to determine if either letter was received.
The Applicant attended a second interview with the
contracts advisor on 2 April 2007. As cited in the
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interview transcript supplied by the Applicant, the
Applicant attended the interview alone as the NFSP
member who had accompanied her at the previous
interview had been told by the NFSP not to represent
her as the Applicant was no longer a member of the
NFSP.
During the interview, the Applicant was given
numerous opportunities to put her case forward.
The notes of the interview of 2 April 2007 were sent
to the Applicant on 17 April 2007. The Applicant
responded with two letters bearing the same date of
18 April 2007, one letter stating that she had
received a copy of the interview notes and the other
stating that she had not. (Doc 009 refers)
Following termination of her contract on 27 April
2007, the Applicant stated her intention to appeal
which was acknowledged on 2 May 2007. (Doc 014
refers)
The Applicant invites Post Office to The Applicant is referring to the second interview
comment that the interview notes held on 2 April 2007. (Doc 005 refers)
prepared by the Contract Advisor omit
huge amounts of pertinent objections,
explanations and queries raised by the
Applicant and evident in the verbatim
transcript of the recording taken by the
Applicant.
In the Post Office interview notes it is evident that
the Applicant did not declare that a recording of the
interview was being made, nor was permission
sought. Point 52 of the notes states that the note-
taker ‘notices an electronic device’ and asks if the
Applicant has recorded the interview which the
Applicant confirms.
Following advice sought from the legal services team
in respect of the candid recording of the interview,
the notes were sent to the Applicant on 17 April
2007. It is Post Office’s view that this recording was
illegal. (Doc 010 refers)
The verbatim transcript of the interview has been
supplied by the Applicant. Post Office has not been
provided with a copy of the recording so is unable to
verify the accuracy of the notes.
The verbatim notes provided by the Applicant state
‘on page 10 that the man (the note-taker as this was
the only man in the room) left the room to take
photocopies of the papers provided by the Applicant.
This contradicts the Post Office interview notes at
point 33 where the interviewer, female, leaves the
room to photocopy the evidence.
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At point 14 of the Post Office Interview notes, the
note-taker states that it is impossible to record all of
the detail given and that he is recording all of the
salient points. This confirms that the interview notes
would not be a full verbatim statement.
At point 9 of the Post Office interview notes it is
noted that the Applicant refers to the Investigation
Report. At points 14 and 16 of the Post Office
interview notes, the note-taker seeks clarification
which is acknowledged and agreed by the Applicant
at point 17, confirming that the Applicant agrees with
the detail being recorded.
In summary, notes at interview are not ad verbatim
which is explained at the start of the interview
process.
13 Why were copies of cheques provided The evidence shows that the Giro cheques in
along with ID dockets with FAD codes question were processed through the Applicant’s
{unique branch code) unrelated to the branch. This is supported by the fact that they bore
Applicant’s branch? The Applicant asks __I the corresponding date on the Applicant’s branch
Post Office whether or not the specific date-stamp. It can be seen from the Green Giro
Giro Cheques in question were cashed Summary (Doc 008 refers) that cheques with dates
twice - once in the Applicant’s branch relating to a week where the pouch went missing
and once fraudulently in the branch the _I were processed through the Applicant’s branch in
ID docket refers to. the following week. This was corroborated with
statements obtained from customers by the
investigating officer stating that they would not cash
more than one week’s Giro cheques at any one time.
Evidence shows that the ID dockets (specific branch
coded facing sheet) relate to the next batch of Giro
cheques stored on the microfiche and not the branch
that the cheque shown emanates from. (Doc 022
refers)
14 The Applicant invites Post Office to As part of the investigation and court case,
prove that its internal control
procedures in place at the time
unequivocally prevent cheques from
being put back into the system after they
ion
have been processed. The impl
being that if the same cheques were
processed more than once it could have
been because the same cheques were
redirected after having been processed
centrally.
documentary evidence was gathered prior to the
audit and subsequent suspension.
This evidence was obtained from Post Office clients
processing the paid Green Giro Cheques received
from Post Office branches.
Records show that the re-introductions were
processed at the Applicant’s branch as supported by
the transaction logs on Horizon.
The evidence shows User ID, date and time of
transactions, Horizon session numbers, and amounts
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claimed for these transactions. (Doc 008 refers)
15
The applicant claims she was
demonstrably out of the country during
a period which Post Office claimed
reintroductions were happening at her
branch,
Post Office claims that Giro cheques from a missing
pouch relating to week 1 in 2006 covering the period
23 March 2006 to 29 March 2006 were reintroduced
the following week.
The Applicant states that she was on holiday in
Barbados in week 2 at the time of the reintroductions
and provides a copy of a Barbados date-stamp from
her passport dated Sunday 2 April 2006 as evidence
that she was out of the country. (Doc 007 refers)
Records show that the Giro cheques in question were
processed on Horizon on Friday 31 March 2006. This
is two days before the entry stamp for Barbados.
No reintroductions were made whilst she was out of
the country. (Doc 008 refers)
16
Final amounts claimed by Post Office are
disputed. The CQR cites £18,000 paid by
the Applicant to Post Office plus £2,500
of costs paid as a result of prosecution.
The evidence shows the total loss charged in court
was £18,017.91. (Doc 021 refers)
The Applicant pleaded guilty to the theft of
£13,759.38 of which £13,000 was repaid on 21 May
2009, leaving £759.38 outstanding. (Doc 020 refers)
Additionally the Applicant was ordered to pay the
outstanding £759.38 plus £2,000 towards
prosecution costs, to be paid within 12 months of 5
September 2009. (Doc 015 refers)
In summary, the Applicant has repaid £13,759.38
plus £2,000 costs and not the amounts totalling
£20,500 claimed by the Applicant.
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M052_POL_NBSC Call Logs_PH_001
NBSC Call logs 1 April 2005 — 31 December 2006
MO052_POL_Transaction Corrections_PH_002
Transaction Corrections
(M052_POL_Audit Report 03052005_PH_003
Audit Report 3 May 2005
M052_POL_Audit Report 12102006_PH_004
Audit Report 12 October 2006
MO052_POL_Interview Notes 02042007_PH_005
Interview Notes 2 April 2007
(M052_POL_Interview Notes 20022007_PH_006
Interview Notes 20 February 2007
™M052_POL_Passport Stamp_PH_007
Copy of Passport Stamp
M052_POL_Green Giros Summary_PH_008
Summary of missing Green Giros
M052_POL_Letters 18042007_PH_009
Letters from Applicant 18 April 2007
M052_POL_Email Interview Recording_PH_010
Email — illegal recording of interview 2 April 2007
M052_POL_Horizon User Guide_PH_011
Extract from Horizon User Guide/ User IDs
M052_POL_NBSC Call Log_PH_012
NBSC Call logs 17 October 2000 — 31 March 2005
M052_POL_Horizon User Guide_PH_013
Extract from Horizon User Guide / Creating Users
M052_POL_Appeal Confirmation_PH_014
Confirmation of Appeal
M052_POL_Email Mitigating
Circumstances_PH_015
Email stating Applicant’s plea for mitigating
circumstances
M052_POL_Witness Statement_PH_016
Witness Statement — Investigation Manager
M052_POL_Remote Access Response _PH_017
Remote access to Horizon - response from Fujitsu
(M052_POL_Legal Team Response_PH_018
Response from Post Office Legal Team to proceed
with prosecution
M052_POL_Missing Pouches_PH_019
Notification of missing pouches reported to Security
Team
M052_POL_Legal Memo Sentence imposed
29052009_PH_020
Memo from Post Office Legal Services
(M052_POL_Recovery Email_PH_021
Email detailing amounts recovered
(M052_POL_Email Santander_PH_022
Email from Patricia Greer Santander
M052_POL_Staff details email_PH_023
Email detailing staff registered at this branch.
CARTWRIGHT KING
BRIEFING NOTE
Branch Name: Hertford Heath
SPMR Name: Ms Wendy Susan Cousins
Case Number: M052
1.
Prosecution Case
© The Applicant held the post of Subpostmaster at the Hertford Heath branch from
23" April 1997 until her precautionary suspension of 6 December 2006
e The Applicant was subject to an audit at the branch on 5 December 2006. The
suspension was due to a security investigation related to Green Giro Cheque fraud
and not as a result of the audit findings.
2.
Court Proceedings
e The Applicant was subject to a criminal prosecution following the security
investigation. The evidence shows the total loss charged in court was £18,017.91.
e On 5 May 2009, at St. Albans Magistrates Court, the Applicant pleaded guilty to 11
charges of theft and asked for 23 other offences to be taken into consideration — the
whole amounting to £13,759.38 (£13,000 was repaid on 21°* May 2009).
e On 28 May 2009, the Applicant was sentenced to 9 months imprisonment
suspended for 2 years with a requirement to complete 200 hours of unpaid work.
She was ordered to repay the remaining £759.38 and £2000 towards the
prosecution costs.
3.
Applicant’s Response to Mediation Scheme
The Applicant’s complaint centres on missing green giro pouches/cheques between 27*
April 2005 and 4" October 2006. She also complains of:
¢ Inadequate training provided by POL
e Horizon issues/reconciliation discrepancies
e Unhelpful communications with helpline, auditors and investigators
e Hardware problems
¢ Flaws in the investigation
e Various forms of loss suffered by the applicant
4.
Analysis
e The reality in this case is that this Applicant pleaded guilty on legal advice and was
sentenced.
e A plea of guilty to a charge entails a complete admission to the offence. In this case
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she has admitted stealing £13,759.38. When a defendant asks for offences to be
taken into consideration she is admitting the offences and asking the judge to take
account of them in sentencing. This is effectively a final disposal of those offences
which cannot be resurrected in subsequent proceedings.
Further to her guilty pleas she offered in mitigation that the thefts occurred to assist
her elderly mother financially. Such mitigation cannot be advanced by counsel
unless counsel have instructions from the defendant to that effect.
The evidence in this case, including her guilty plea, is overwhelmingly in support of
the contention that the loss was brought about by the Applicant's dishonesty.
5
Dangers to Post Office Limited
If concessions are made that might render this conviction unsafe then the Applicant
may well be put ina position whereby she is able to appeal that conviction.
Were such an appeal to succeed, then POL would be open to a claim for damages
and/or restitution of monies paid by this appellant under any confiscation order.
Such concessions would have to be disclosed to those with similar convictions. This
may well necessitate a review of many hundreds of cases to establish who else may
be entitled to such disclosure.
If concessions are made that might render the sentence imposed in this case
manifestly excessive then the Applicant might well be put in a position whereby she
might be able to appeal that sentence, with similar consequences for POL.
And again those concessions would have to be disclosed to those with similar
convictions, with similar consequences for POL.
This is not a case where any concessions can or should be made; to do so has the
potential to render her conviction by guilty plea unsafe, or her sentence as
manifestly excessive; and accordingly to invite an application to the Court of
Appeal.
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Harry Bowyer 13™ March 2014
Barrister
Cartwright king Solicitors.
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Bundler 1
From: Martin Smith
Sent: 14 March 2014 12:
To: ‘cathal.leigh-d
Ce: Jarnail A Singh Chris Powell
Subject: M052 - Draft Response CK amended.
Attachments: POL Preliminary Investigation Report - CK Response.doc
Hi Cathal,
Please find attached the proposed report upon which we have made a number of amendments
and endorsed our comments.
We would advise against settlement. Not only did Wendy Cousins plead guilty to 11 charges of
theft, she also asked for 23 other offences to be taken into consideration. In mitigation she
explained that the thefts occurred to assist her elderly mother financially.
This is not a case where any concessions can or should be made; to do so has the potential to
render her conviction by guilty plea unsafe, or her sentence as manifestly excessive; and
accordingly to invite an application to the Court of Appeal.
Kind regards,
Martin.
Martin Smith
CartwrightKing
seme SD CTT ORS emma
Birmingham I Derby I Leicester] London I Newcastle I Nottingham I Sheffield
Majority House, 51 Lodge Lane, Derby, DEI 3HB
Pal
eb
"We have a new website" f
www.cartwrightking.co.uk Ww
ation
Save a tree - please only print emails that you must
POL00112928
POL00112928
Bundler 1
From: Rodric Williams
Sent: 20 March 2014 17:10
To: Martin Smith
Subject: FW: M052 POL legal for GC approval (incorporating CK's comments)
[BD-4A.FID25887221]
Attachments: image001.gif; image002.gif; image003.gif; image004.gif; image005.gif;
image008.png; image009.png; image010.png; image011.png; image012.gif;
image013.gif; image014.png; image015.jpg; MOS2_POL_Legal Team Response_PH_
018.doc; M0S2_POL_Legal Memo Sentence Imposed 29052009_PH_020.doc;
image016jpg
Martin —I attach the two documents that you wanted to see, i.e. “M052_POL_ Legal Team Response_ PH_018” and
“M052_POL_Legal Memo Sentence imposed 29052009_PH_020”.
I attach them. I don’t think they contain sensitive or privileged material. What's your opinion?
Kind regards, Rodric
Rodric Williams I Litigation Lawyer
§ Old Street, LONDON, ECT V 9HQ
5
Post Office stories
, @postofficenews
©
7,
From: Rodric Williams
Sent: 20 March 2014 17:01
To: 'martin.smith¢~
Subject: FW: M052 POL légal :) [BD-4A.FID25887221]
Hi Martin ~ thanks for your comments on this case report, including those concerning settlement (with which I
agree).
I would like to make a couple of tweaks to the report as set out below. Are you ok with them from a criminal law
perspective?
1.
FROM:
Further to her guilty pleas she offered in mitigation that the thefts occurred to assist her elderly mother financially. Such
mitigation cannot be advanced by counsel unless counsel have instructions from the defendant to that effect.
TO:
Further to her guilty pleas she offered in mitigation that the thefts occurred to assist her elderly mother financially. Counsel can
only advance such mitigation if specifically instructed to do so by the defendant.
POL00112928
POL00112928
2. Response to Issues raised by Applicant ; 10, [...] investigation and subsequent evidence was flawed
FROM:
The investigation and subsequent evidence were subject to scrutiny by the judicial system and any flaws would have
caused the court case to cease.
TO:
The investigation and subsequent evidence were subject to scrutiny by the judicial system, which afforded the
Applicant opportunity to raise any purported flaws in the investigation or evidence
Kind regards, Rodric
Rodric Williams I Litigation Lawyer
@® 148 Old Street, LONDON, ECLY 9H
©
@ Post Office stori
® @postofficenews
From: Leigh-Doyle, Cathalf GRO.
Sent: 16 March 2014 22:26
To: Rodric Williams; Jonny Gribben
Cc: Kathryn Alexander
Subject: M052 POL legal for GC approval (incorporating CK's comments) [BD-4A.FID25887221]
Hi Rodiric
Please find MOS2's legal investigation report (criminal application). CK’s comments are below.
Your comments would be appreciated.
Kind regards
Cathal
From: Martin Smith
Sent: 14 March 2014 12:58
To: Leigh-Doyle, Cat! _ _
Cc: Jarnail A Singh ¢ GRO ); Chris Powell
Hi Cathal,
Please find attached the proposed report upon which we have made a number of amendments
and endorsed our comments.
We would advise against settlement. Not only did Wendy Cousins plead guilty to 11 charges of
theft, she also asked for 23 other offences to be taken into consideration. In mitigation she
explained that the thefts occurred to assist her elderly mother financially.
POL00112928
POL00112928
This is not a case where any concessions can or should be made; to do so has the potential to
render her conviction by guilty plea unsafe, or her sentence as manifestly excessive; and
accordingly to invite an application to the Court of Appeal.
Kind regards,
Martin.
Martin Smith
CartwrightKing
women SS LECT TORS mmm
Birmingham I Derby I Leicester] London I Newcastle I Nottingham I Sheffield
Majority House, 51 Lodge Lane, Derby, DEI 3HB
"We have a new website"
www.cartwrightking.co.uk
(al
500
Save a tree - please only print emails that you must
rodric.williams,_.
thal.leigh-doyld GRO.
manication oF atiachowents i
s of Bond Dickinso
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: 148 OLD STREET,
LONDON EC1V 9HQ.
POL00112928
POL00112928
Bundler 1
From: Rodric Williams +
Sent: 20 March 2014 17:01
To: Martin Smith
Subject: FW: M052 POL legal for GC approval (incorporating CK's comments)
[BD-4A.FID25887221]
Attachments: image001.gif; image002.gif; image003.gif; image004.gif; image005.gif; POL
Preliminary Investigation Report - CK Response.doc; image008.png; image009.png;
image010.png; image011.png; image012.gif; image013.gif; image014.png;
image015.jpg
Hi Martin ~ thanks for your comments on this case report, including those concerning settlement (with which I
agree).
I would like to make a couple of tweaks to the report as set out below. Are you ok with them from a criminal law
perspective?
1. Executive Summary; Background
FROM:
Further to her guilty pleas she offered in mitigation that the thefts occurred to assist her elderly mother financially. Such
mitigation cannot be advanced by counsel unless counsel have instructions from the defendant to that effect.
TO:
Further to her guilty pleas she offered in mitigation that the thefts occurred to assist her elderly mother financially. Counsel can
only advance such mitigation if specifically instructed to do so by the defendant.
2. Response to Issues raised by Applicant ; 10. [...] investigation and subsequent evidence was flawed
FROM:
The investigation and subsequent evidence were subject to scrutiny by the judicial system and any flaws would have
caused the court case to cease.
TO:
The investigation and subsequent evidence were subject to scrutiny by the judicial system, which afforded the
Applicant opportunity to raise any purported flaws in the investigation or evidence
Kind regards, Rodric
Rodric Williams I Litigation Lawyer
148 Old Street, LONDON, ECIV 9HQ
@postofficenews
POL00112928
POL00112928
From: Leigh-Doyle, Cathal [mailt
Sent: 16 March 2014 22:26
To: Rodric Williams; Jonny Gribben
Cc: Kathryn Alexander
Subject: M052 POL legal for GC approval (incorporating CK's comments) [BD-4A.FID25887221]
Hi Rodric
Please find M052's legal investigation report (criminal application). CK's comments are below.
Your comments would be appreciated.
Kind regards
Cathal
From: Martin Smith [mailt
Sent: 14 March 2014 12:58
To: Leigh-Doyle, Cathal
Ce: Jarnail A Singh (;
Subject: M052 - Dra'
); Chris Powell
esporisé CK amen
Hi Cathal,
Please find attached the proposed report upon which we have made a number of amendments
and endorsed our comments.
We would advise against settlement. Not only did Wendy Cousins plead guilty to 11 charges of
theft, she also asked for 23 other offences to be taken into consideration. In mitigation she
explained that the thefts occurred to assist her elderly mother financially.
This is not a case where any concessions can or should be made; to do so has the potential to
render her conviction by guilty plea unsafe, or her sentence as manifestly excessive; and
accordingly to invite an application to the Court of Appeal.
Kind regards,
Martin.
Martin Smith
CartwrightKing
women SB CPT OR 5 emma
Birmingham I Derby I Leicester] London I Newcastle I Nottingham I Sheffield
Majority House, 51 Lodge Lane, Derby, DE1 3HB
“We have a new website"
www.cartwrightking.co.uk bd
this i
POL00112928
POL00112928
Authority N raion No:
Save a tree - please only print emails that you must
tware before
ry put your even viry
sf munber OC
We use the
This
tenor partner f0
faason LLP which
and on behalf of Bon
A dh
is St Ane’
Bond Dickinson LLP is authorised and regulated hy the Solicitors Regulation Authority
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: 148 OLD STREET,
LONDON EC1V 9HQ.
JOH SOO ISO IOI ISO ISO DIAS IODA IOI BIOSIS OO SISO NIST S.
POL00112928
POL00112928
Bundler 1
From: Martin Smith
Sent: 21 March 2014 08:56
To: Harry Bowyer
Subject: FW: M052 POL legal for GC approval (incorporating CK's comments)
[BD-4A.FID25887221]
Attachments: image001.gif; image002.gif; image003.gif; image004.gif; image005.gif; POL
Preliminary Investigation Report - CK Response.doc; image008.png; image009.png;
image010.png; image011.png; image012.gif; image013.gif; image014.png;
image015.jpg
Harry,
The second e-mail on cousins.
M
From: Rodric Williams [mailto:
Sent: 20 March 2014 17:01
To: Martin Smith
Subject: FW: M052 POL legal for GC approval (incorporating CK's comments) [BD-4A.FID25887221]
Hi Martin ~ thanks for your comments on this case report, including those concerning settlement (with which I
agree).
I would like to make a couple of tweaks to the report as set out below. Are you ok with them from a criminal law
perspective?
FROM:
Further to her guilty pleas she offered in mitigation that the thefts occurred to assist her elderly mother financially. Such
mitigation cannot be advanced by counsel unless counsel have instructions from the defendant to that effect.
TO:
Further to her guilty pleas she offered in mitigation that the thefts occurred to assist her elderly mother financially. Counsel can
only advance such mitigation if specifically instructed to do so by the defendant.
2. Response to Issues raised by Applicant ; 10. [...] investigation and subsequent evidence was flawed
FROM:
The investigation and subsequent evidence were subject to scrutiny by the judicial system and any flaws would have
caused the court case to cease.
POL00112928
POL00112928
TO:
The investigation and subsequent evidence were subject to scrutiny by the judicial system, which afforded the
Applicant opportunity to raise any purported flaws in the investigation or evidence
Kind regards, Rodric
Rodric Williams I Litigation Lawyer
®
©
@
® @postofficenews
From: Leigh-Doyle, Cathal [mailt
Sent: 16 March 2014 22:26 .
To: Rodric Williams; Jonny Gribben
Ce: Kathryn Alexander
Subject: M052 POL legal for GC approval (incorporating CK's comments) [BD-4A.FID25887221]
Hi Rodric
Please find MO52's legal investigation report (criminal application). CK's comments are below.
Your comments would be appreciated.
Kind regards
Cathal
From: Martin Smith [mailt
Sent: 14 March 2014 12:58
To: Leigh-Doyle, Cathal
Ce: Jarnail A Singh
Subject: M052 - Dra’
Chris Powell
Hi Cathal,
Please find attached the proposed report upon which we have made a number of amendments
and endorsed our comments.
We would advise against settlement. Not only did Wendy Cousins plead guilty to 11 charges of
theft, she also asked for 23 other offences to be taken into consideration. In mitigation she
explained that the thefts occurred to assist her elderly mother financially.
This is not a case where any concessions can or should be made; to do so has the potential to
render her conviction by guilty plea unsafe, or her sentence as manifestly excessive; and
accordingly to invite an application to the Court of Appeal.
Kind regards,
POL00112928
POL00112928
Martin.
Martin Smith.
GRO
CartwrightKing
mmm SOE GH Sm
Birmingham I Derby I Leicester] London I Newcastle I Nottingham I Sheffield
Majority House, 51 Lodge Lane, Derby, DE1 3HB
"We have a new website"
www.cartwrightking.co.uk
». rodric.william:
fy cathal.leigh-doyld
is authoris
an employee ¢
Bond Dickinson E
Pis authorised and regulated by the Sofi
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: 148 OLD STREET,
LONDON EC1V 9HQ.
POL00112928
POL00112928
Bundler 1
From: Martin Smith
Sent: 21 March 2014 08:56
To: Harry Bowyer
Subject: FW: M052 POL legal for GC approval (incorporating CK's comments)
[BD-4A.FID25887221]
Attachments: image001.gif; image002.gif; image003.gif; image004.gif; image005.gif;
image008.png; image009.png; image010.png; image011.png; image012.gif;
image013.gif; image014.png; image015.jpg; MOS2_POL_Legal Team Response_PH_
018.doc; M052_POL_Legal Memo Sentence Imposed 29052009_PH_020.doc
Harry,
I think you looked at Wendy Cousins - could you have a look at this e-mail please and the one I
am about to send.
Thanks.
M
__Martin Smith
From: Rodric Williams [mailto:!
Sent: 20 March 2014 17:10
To: Martin Smith
Subject: FW: M052 POL legal for GC approval (incorporating CK's comments) [BD-4A.FID25887221]
Martin ~{ attach the two documents that you wanted to see, i.e. “Vi052_POL_, Legal Team Response __ PH_018” and
“M052_POL_Legal Memo Sentence imposed 29052009_PH_020”.
I attach them. I don’t think they contain sensitive or privileged material. What's your opinion?
Kind regards, Rodric
Rodric Williams I Litigation Lawyer
Post Office stories
& @pos'
POL00112928
POL00112928
From: Rodric Williams
Sent: 20 March 2014 17:01
To: 'martin.smith@
Subject: FW: M052 POL legal for GC approval (incorporating CK's comments [BD-4A.FID25887221]
Hi Martin — thanks for your comments on this case report, including those concerning settlement (with which I
agree).
I would like to make a couple of tweaks to the report as set out below. Are you ok with them from a criminal law
perspective?
1. Executive Summary; Background
FROM:
Further to her guilty pleas she offered in mitigation that the thefts occurred to assist her elderly mother financially. Such
mitigation cannot be advanced by counsel unless counsel have instructions from the defendant to that effect.
TO:
Further to her guilty pleas she offered in mitigation that the thefts occurred to assist her elderly mother financially. Counsel can
only advance such mitigation if specifically instructed to do so by the defendant.
2. Response to Issues raised by Applicant ; 10. [...] investigation and subsequent evidence was flawed
FROM:
The investigation and subsequent evidence were subject to scrutiny by the judicial
caused the court case to cease.
TO:
The investigation and subsequent evidence were subject to scrutiny by the judicial system, which afforded the
Applicant opportunity to raise any purported flaws in the investigation or evidence
system and any flaws would have
Kind regards, Rodric
Rodric Williams I Litigation Lawyer
148 Old Street, LONDON, ECIY 9HQ
GRO
From: Leigh-Doyle, Cathal [mailt:
Sent: 16 March 2014 22:26
To: Rodric Williams; Jonny Gribben
Cc: Kathryn Alexander
Subject: M052 POL legal for GC approval (incorporating CK's comments) [BD-4A.FID25887221]
Hi Rodric
POL00112928
POL00112928
Please find MO52's legal investigation report (criminal application). CK's comments are below.
Your comments would be appreciated.
Kind regards
Cathal
From: Martin Smith [mailto} GRO
Sent: 14 March 2014 12:58
To: Leigh-Doyle, Cathal
Ce: Jarnail A Singh ¢
Subject: M052 - Draft Response CK amended.
Chris Powell
Hi Cathal,
Please find attached the proposed report upon which we have made a number of amendments
and endorsed our comments.
We would advise against settlement. Not only did Wendy Cousins plead guilty to 11 charges of
theft, she also asked for 23 other offences to be taken into consideration. In mitigation she
explained that the thefts occurred to assist her elderly mother financially.
This is not a case where any concessions can or should be made; to do so has the potential to
render her conviction by guilty plea unsafe, or her sentence as manifestly excessive; and
accordingly to invite an application to the Court of Appeal.
Kind regards,
Martin.
CartwrightKing
wm SL ETT ORS amen
Birmingham I Derby I Leicester] London I Newcastle I Nottingham I Sheffield
Majority House, 51 Lodge Lane, Derby, DEI 3HB
"We have a new website’
www.cartwrightking.co.uk
POL00112928
POL00112928
The
uthorise ess this oom
ible and delete
9, of this communication oF altachiney
, ; . . ; Dickinson LLP accepts no lability tor
hich may be caused by softw a * »
naail which does not relate to the olfici
business of Bond Dickinson LLP, is neither given nog endo
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: 148 OLD STREET,
LONDON EC1V 9HQ.
Senne tree etterte treet enter et ettetttereet errant irene ttreerettarttd
POL00112928
POL00112928
Bundler 1
From: Martin Smith
Sent: 21 March 2014 09:58
To: ‘Rodric Williams’
Subject: RE: M052 POL legal for GC approval (incorporating CK's comments)
[BD-4A.FID25887221]
Hi Rodric,
Ihave no objection to these documents being disclosed.
Kind regards,
Martin.
Martin Smith
From: Rodric Williams [mailto
Sent: 20 March 2014 17:10
To: Martin Smith
Subject: FW: M052 POL legal for GC approval (incorporating CK's comments) [BD-4A.FID25887221]
Martin — I attach the two documents that you wanted to see, i.e. “M052_POL_ Legal Team Response_ PH_018” and
“M052_POL_Legal Memo Sentence imposed 29052009_PH_020”.
l attach them. {don’t think they contain sensitive or privileged material. What’s your opinion?
Kind regards, Rodric
Rodrie Williams I Litigation Lawyer
©
POL00112928
POL00112928
From: Rodric Williams
Sent: 20 March 2014 17:01
To: ‘martin.smit! .
Subject: FW: M052 POL legal for GC approval (incorporating CK's comments) [BD-4A.FID25887221]
Hi Martin ~ thanks for your comments on this case report, including those concerning settlement (with which I
agree).
I would like to make a couple of tweaks to the report as set out below. Are you ok with them from a criminal law
perspective?
1. Executive Summary; Background
FROM:
Further to her guilty pleas she offered in mitigation that the thefts occurred to assist her elderly mother financially. Such
mitigation cannot be advanced by counsel unless counsel have instructions from the defendant to that effect.
TO:
Further to her guilty pleas she offered in mitigation that the thefts occurred to assist her elderly mother financially. Counsel can
only advance such mitigation if specifically instructed to do so by the defendant.
2. Response to issues raised by Applicant ; 10. [...] investigation and subsequent evidence was flawed
FROM:
The investigation and s
caused the court case to ¢
TO:
The investigation and subsequent evidence were subject to scrutiny by the judicial system, which afforded the
Applicant opportunity to raise any purported flaws in the investigation or evidence
juent evidence were subject to scrutiny by the judicial system and any flaws would have
e.
Kind regards, Rodric
Rodric Williams I Litigation Lawyer
© 148 Old Street, LONDON, ECLV 9HQ
©
©
©
From: Leigh-Doyle, Cathal [mai
Sent: 16 March 2014 22:26
To: Rodric Williams; Jonny Gribben
Cc: Kathryn Alexander
Subject: M052 POL legal for GC approval (incorporating CK's comments) [BD-4A.FID25887221]
Hi Rodric
Please find M052's legal investigation report (criminal application). CK's comments are below,
Your comments would be appreciated.
POL00112928
POL00112928
Kind regards
Cathal
From: Martin Smith [mailto 1
Sent: 14 March 2014 12:58
Chris Powell
Subject: M052 - Draft Response CK amended.
Hi Cathal,
Please find attached the proposed report upon which we have made a number of amendments
and endorsed our comments.
We would advise against settlement. Not only did Wendy Cousins plead guilty to 11 charges of
theft, she also asked for 23 other offences to be taken into consideration. In mitigation she
explained that the thefts occurred to assist her elderly mother financially.
This is not a case where any concessions can or should be made; to do so has the potential to
render her conviction by guilty plea unsafe, or her sentence as manifestly excessive; and
accordingly to invite an application to the Court of Appeal.
Kind regards,
Martin.
Martin Smith
CartwrightKing
commen ST GR S seem
Birmingham I Derby I Leicester] London I Neweastle I Nottingham I Sheffield
Majority House, 51 Lodge Lane, Derby, DEI 3HB
"We have a new website’
www.cartwrightking.c
inson LLP accepts no Habity
POL00112928
POL00112928
nay be caused by software viruses and yor should carry out your own virus checks before opening any attacl
Content of this email which does aot mfate to the official business of Bond Dickinson
Bond Dickinson LLP is author regulated by the Solicitors
tion Authority,
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: 148 OLD STREET,
LONDON EC1V 9HQ.
renee reer et rare etter et etrer etter ec terse teeter tt tren et eererrt titer
POL00112928
POL00112928
Bundler 1
From: Martin Smith
Sent: 21 March 2014 09:56
To: ‘Rodric Williams’
Subject: RE: M052 POL legal for GC approval (incorporating CK's comments)
[BD-4A.FID25887221]
Hi Rodric,
Ihave no issues with regard to the proposed amendments, thanks.
Kind regards,
Martin
Martin Smith
From: Rodric Williams [mailto: "GRO
Sent: 20 March 2014 17:01, 70>
To: Martin Smith
Subject: FW: M052 POL legal for GC approval (incorporating CK's comments) [BD-4A.FID25887221]
Hi Martin ~ thanks for your comments on this case report, including those concerning settlement (with which I
agree).
I would like to make a couple of tweaks to the report as set out below. Are you ok with them from a criminal law
perspective?
FROM:
Further to her guilty pleas she offered in mitigation that the thefts occurred to assist her elderly mother financially. Such
mitigation cannot be advanced by counsel unless counsel have instructions from the defendant to that effect.
TO:
Further to her guilty pleas she offered in mitigation that the thefts occurred to assist her elderly mother financially. Counsel can
only advance such mitigation if specifically instructed to do so by the defendant.
2. Response to issues raised by Applicant ; 10. [...] investigation and subsequent evidence was flawed
FROM:
The investigation and subsequent evidence were subject to scrutiny by the judicial system and any flaws would have
caused the court case to cease.
TO:
POL00112928
POL00112928
The investigation and subsequent evidence were subject to scrutiny by the judicial system, which afforded the
Applicant opportunity to raise any purported flaws in the investigation or evidence
Kind regards, Rodric
Rodric Williams I Litigation Lawyer
@ 148 Old Street, LONDON, ECIY 9HQ
© “om
ee
From: Leigh-Doyle, Cathal [mailto!
Sent: 16 March 2014 22:26
To: Rodric Williams; Jonny Gribben
Cc: Kathryn Alexander
Subject: M052 POL legal for GC approval (incorporating CK's comments) [BD-4A.FID25887221]
Hi Rodric
Please find MO52's legal investigation report (criminal application). CK's comments are below.
Your comments would be appreciated.
Kind regards
Cathal
From: Martin Smith [mailto GRO
Sent: 14 March 2014 12:58
To: Leigh-Doyle, Cathal...
Ce: Jarnail A Singh ¢.
Subject: M052 - Draft Response CK amended.
); Chris Powell
Hi Cathal,
Please find attached the proposed report upon which we have made a number of amendments
and endorsed our comments.
We would advise against settlement. Not only did Wendy Cousins plead guilty to 11 charges of
theft, she also asked for 23 other offences to be taken into consideration. In mitigation she
explained that the thefts occurred to assist her elderly mother financially.
This is not a case where any concessions can or should be made; to do so has the potential to
render her conviction by guilty plea unsafe, or her sentence as manifestly excessive; and
accordingly to invite an application to the Court of Appeal.
Kind regards,
POL00112928
POL00112928
Martin.
Martin Smith
GRO
Direct: I GRO
CartwrightKing
women SS CTT ORS som
Birmingham I Derby I Leicester] London I Neweastle I Nottingham I Sheffield
Majority House, 51 Lodge Lane, Derby, DEI 3HB
‘inI PAL
200
"We have a new website"
Solicitors Reg
www.cartwrightking.co.uk
This
bis
Abstot
Author
vo Vat Reyisieation No:
Save a tree - please only print emails that you must
orowtion in This e-mail ar
any atfachone
J and any atiachments
y copies. Unauthoriser
dand Wales
nes Is open
sistration
ins
eepeernneeenresrererrrenrrrsserregrenrrrerseresrirrerrererrtrt terri!
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: 148 OLD STREET,
LONDON EC1V 9HQ.
POL00112928
POL00112928
Bundler 1
From: Martin Smith
Sent: 31 July 2014 16:10
To:
Ce: Parsons, Andrew; Matthew Harris
Subject: RE: M052 - Response to CRR / Settlement Analysis
Hi Paul,
May we have a copy of the CRR please?
Many thanks,
Martin.
Martin Smith
[L _ GRO
RO
Sent: 31 July 2014 12:23
To: jessica.barket
Cc: Parsons, Andrew; Matthew Harris
Subject: M052 - Response to CRR / Settlement Analysis
Dear all
Please see attached a draft response to Second Sight’s draft CRR for MO52 along with the settlement analysis.
Kind regards
Paul
Paul Loraine
Solicitor
POLO00112928
POL00112928
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ged and protected by
I Andrew.Parsong GRO H
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i Andrew.Parsong
0 _______j45 Scon as possible and delete
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martin.smith,
“I please notify Paul.Loraine:
emination, distribution, publication
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Matthew. Harris¢~~
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nson LLP, is neither given nor
This email is sent for and on behalf of Bond Dic!
and Wi: under number OC3176614. Our regist
NE1 3DX, where a list of member:
LLP, or an emy
on LLP which is a limited liability partnership registered in England
's St Ann's Wharf, 112 Quayside, Newcastie Upon Tyne,
'$' names is open to inspection. We use the term pariner fo refer fo a member of the
ee oF consultant who is of equivalent standing. Our VAT registration number is GB123393627.
do
Bond Dickinson LL! uthorised and regulated by the Solicitors Requiation Authority.
POL00112928
POL00112928
Confidential - subject to litigation and legal advice privilege
Cond Dideingor
INITIAL COMPLAINT REVIEW AND MEDIATION SCHEME
SETTLEMENT ANALYSIS
Background Information
Applicant details Claim no. M052
Name Mrs Wendy Susan Cousins
Branch Hertford Heath
Loss position Branch loss £13,759.38 (note that the theft charges related
to losses totalling £18,017.91 but the Applicant
pleaded guilty to theft of £13,759.38)
Date of loss 27 April 2005 — 27 August 2006
Debt position
The sum of £13,759.38 was repaid by Applicant
following criminal proceedings
Consequential losses
claimed
Loss of value in home after loss of business (not
quantified)
Pain and suffering (not quantified)
Contract / termination
position
SPMR / employee / other
SPMR
Former or current
SPMR?
Former.
Termination route
Contract summarily terminated
Termination date
26 April 2007
Applicant position
Bankrupt / IVA?
Not as far as we are aware
Prosecuted?
Yes
Outcome of criminal
prosecution
Pleaded guilty to 11 charges of theft and 23
other offences and was sentenced on 28 May
2009. The sentence given was 9 months
imprisonment suspended for 2 years with a
requirement to complete 200 hours of unpaid
work (and to pay back the sum of £13,759.38 to
Post Office)
Civil proceedings?
No
High profile media / MP
case?
No
Professional advisor
Howe & Co Solicitors
4A_20010541_2
Bond Dickinson Legal Analysis
POL00112928
POL00112928
Confidential - subject to litigation and legal advice privilege
Cond Dideingor
POL have no responsibility for the loss (see analysis below) so should make no restitutionary payment to
the Applicant.
Legal risk adjusted claim value
Legal analysis of branch losses
Legal factor Legal risk Legal risk
(0% = no risk adjusted
to POL) claim value
Claim value £13,759.38
POL has received payment for £13,759.38 from Applicant
Has the claim already been barred / determined so that legal 100% £13,759.38
proceedings cannot be brought against POL?
No — there is probably no legal bar to the Applicant bringing a claim
against POL — see additional notes.
Responsibility for loss 0% £0
The Applicant pleaded guilty to theft of £13,759.38 from Post Office.
Post Office remains of the view that the loss in the branch was caused by
the Applicant's fraudulent handling of benefit transactions.
Other legal issues 0% £0
N/A
Interest £0 £0
Interest is due to Post Office on the net outstanding debt
Approximately 18 months @ 3% per annum
Legal analysis of consequential losses resulting from termination
Legal factor Legal risk Legal risk
(0% = no risk adjusted
to POL) I claim value
Value of claim based on Applicant's figures Amount not
quantified
Total amount not quantified by Applicant
Are the claimed consequential losses recoverable at law? 50% Amount not
quantified
Loss of value in home after loss of business (not quantified) — probably
not recoverable as a matter of causation but we would require more
information to be certain
Pain and suffering (not quantified) — not recoverable at law.
4A_20010541_2 2
POL00112928
POL00112928
Confidential - subject to litigation and legal advice privilege
Cond Dideingor
Has the claim already been barred / determined so that legal 100% Amount not
proceedings cannot be brought against POL? quantified
No — there is no legal bar to the Applicant bringing a claim against POL.
Is there the possibility of an unlawful termination claim because the 100% Amount not
Applicant's contract was not terminated on 3 months’ notice? quantified
Yes — Applicant's contract was summarily terminated
Was contract termination unlawful? 0% £0
No evidence to suggest that termination was unlawful.
Post Office conducted an investigation into discrepancies at the branch
which led Post Office to the conclusion that the Applicant was improperly
accounting for Giro Cheques. This was the basis on which the Applicant's
contract was terminated.
Is there evidence that the Applicant could have “sold” his / her n/a £0
branch as a going concern if given 3 months' notice?
No evidence provided yet
Interest na £0
Suitability for mediation
This case is not believed to be suitable for mediation because:
- Post Office remains of the view that the loss in the branch was caused by the Applicant's
fraudulent handling of benefit transactions;
- The Applicant pleaded guilty to theft in respect of £13,000 worth of losses at the branch; and
- Post Office is not responsible for any portion of the loss at the branch.
Bond Dickinson contact
Name:
Tel:
Email:
Additional Notes
The loss occurred in 2006 and therefore would be ordinarily time barred. However, the Applicant repaid
the loss in 2009 in response to a Court Order. It is complex legal question as to when the 6 year time
limit on bringing legal claims would commence in this scenario.
Assuming that the Applicant were to bring a restitutionary claim (see Linklaters’ advice) our initial view
would be that time would run from the point of payment and therefore this claim would not be time
barred.
Advice qualifications
1. This advice has been produced by applying the principles set out in the Advice from Linklaters dated
20 March 2014.
4A_20010541_2 3
POL00112928
POL00112928
Confidential - subject to litigation and legal advice privilege
Cond Dideingor
2. No further legal analysis of the underlying legal principles has been carried out, in particular we
have not considered any other possible legal bases for the Applicant's claims including without
limitation malicious prosecution, defamation, malicious falsehood, breach of confidence, tortious
causes of action or privacy law.
3. We have not analysed the possibility that failures by Post Office in training or supporting the
Applicant, or subsequently investigating losses, may have contributed to the Applicant's ability to
prevent losses in branch.
4. Our advice is based on only the information in the Applicant's Case Questionnaire Response, the
Post Office Investigation Report and Second Sight's Case Review Report. Our advice does not
factor in the possibility of further information being available at a later date that may change our
analysis.
5. We have not considered the Applicant's appetite or capacity to bring proceedings against POL or
any of the "other" factors set out in the settlement mandate.
6. We have not considered any criminal law issues or whether any conviction / sentence may be
unsafe. We have assumed that there are no criminal law risks unless such risks have been
previously highlighted by Cartwright King.
7. We have applied a de minimis threshold to legal risk. Where the legal risk is very small (less than
20%) we have recorded this as 0% in our analysis.
4A_20010541_2 4
Confidential - subject to litigation and legal advice privilege
Post Office Settlement Mandate
Legal risk adjusted claim value
£13,759.38 — amount paid to Post Office by Applicant.
Other settlement factors
POL00112928
POL00112928
Cond Dideingor
Factor Adjustment Adjusted
settlement
threshold
Legal risk adjusted claim value £13,759.38
Actual cost of settlement to POL
As the branch losses have been repaid by the Applicant, any financial
settlement would take the form of re-payment of this money in restitution.
Other admissions of fault by POL
There are no admissions of fault in the Post Office Investigation Report.
PR / media implications
We are not aware of any special PR / media issues specific to this case.
Applicant expectations / experience from any previous negotiations
N/A
Criminal case — need to protect safety of convictions
This is a criminal case (please see details above)
Risk of future litigation / court costs
Given the lack of legal merit in any restitutionary claim by the Applicant,
this risk appears to be low.
Cost savings through early settlement
In the context, this is not applicable as settlement is not being considered.
Other factors
N/A
Mandated financial settlement range
Alternative / additional non-financial settlement proposals that can be offered
4A_20010541_2
POL00112928
POL00112928
Confidential - subject to litigation and legal advice privilege
Cond Dideingor
Other matters
Approved for mediation
Post Office Approval
Name: Date:
4A_20010541_2 6
POL00112928
POL00112928
Bundler 1
From: Loraine, Paul <,.
Sent: 31 July 2014 12:23 .
To: jessica.barkert_______ GRO iMartin Smith
Ce: Parsons, Andrew; Matthew Harris
Subject: M052 - Response to CRR / Settlement Analysis
Attachments: M052 - Response to CRR 31 July 14.DOCX; Settlement Advice - M052 - 31 July
14.DOCX
Dear all
Please see attached a draft response to Second Sight's draft CRR for MO52 along with the settlement analysis.
Kind regards
Paul
Paul
Loraine
Solicitor
for and on behalf of Bond Dickinson LLP
aw
Matthew. Harri
ged ang protected by
ly priv
Andrew. Parsons
formation
jessica.bai
jessica barker.
Andrew .Parsonst
Matthew. Harris} GRO.
2-Angrew Parsons,
Any fi
Dick:
carry out your own virus checks: before opening any attac
Content of this email which does not 1
LLP,
Bone
i Dickinson
vefore transmission. Bond
sho
@ been checke
y loss or dai
d by us with virus detection softwar:
which may be caused by
ment.
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slate to the official business of Bond Dick:
England
Tyne,
nt for and on behalf of Bond Dic!
under number OC317661. Our regi
or an employee or co:
author
POL00112928
POL00112928
Bundler 1
From: Loraine, Paul <
Sent: 31 July 2014 1
To: Martin Smith; jessica.barker
Ce: Parsons, Andrew; Matthew Harris
Subject: RE: M052 - Response to CRR / Settlement Analysis
Attachments: M052__DRAFT_CRR.PDF
Martin
Please see the draft CRR attached.
Thanks
Paul
Paul Loraine
Solicitor
www. bonddickinson.com
From: Martin Smith [mailto;_,
Sent: 31 July 2014 16:10
To: Loraine, Paul; jessica.barkel
Cc: Parsons, Andrew; Matthew Harris
Subject: RE: M052 - Response to CRR / Settlement Analysis
Hi Paul,
May we have a copy of the CRR please?
Many thanks,
Martin.
Martin Smith
POL00112928
POL00112928
From: Loraine, Paul [mailto:
Sent: 31 July 2014 12:23
GRO
To: jessica.barkeré ; Martin Smith
Cc: Parsons, Andrew; Matthew Harris
Subject: M052 - Response to CRR / Settlement Analysis
Dear all
Please see attached a draft response to Second Sight’s draft CRR for MO52 along with the settlement analysis.
Kind regards
Paul
Paul Loraine
Solicitor
for and on behalf of Bend Dickinson LLP
www.bonddickinson.com
The i ation in this e-mail and any attachment confidential and may be legally led and protected hy
law. jessica.barker¢ GRO iL martin.smith GRO. } Andrew.Parsons! GRO H
Mi “only is a sed in access this e-mail and any atta nis, I vou are not
jessica barker, martin.smitht GRO _k.Andrew.Parsons¢ GRO. i
Matthew.H: ‘I please notify Paul Lorain S
any copies.
Ame!
nd delete
il will have
ty for a
before ope:
is sent for anc on behalf of Bond Dickinson L
s under number OC317667. Our regi
NE1 3DX, where a list of members’ names is op
LLP, or an employee or consultant who is of eq!
n England
i, Newcastie Upon Tyne.
@ the term pariner to refer to a member of the
rnumber is GB123383627.
Bond Dickinson LLP is auth
The information i
‘aw. martin.smi
Matthew. Hards
martin.smithy
Matthew. Harris!
sand arotected, by
GRO
1 Andrew.Parsons¢
horised t mail and any alfjache:
rker, “Andrew.Parsong
please notify Paul.Loraine} GRO fa:
POLO00112928
POL00112928
any copies. Unauthorised use, dissem
attachments is prohibited and ray be u
tion, distribution, publication or copying of this communication or
wful.
Any files attached to this e-rnail will have been checked by us with virus detection software bet
ckinson LLP acc
carry out your own
re transmission. Bond
no liability for any loss or damage which may be caused by software viruses and you should
checks before opening any attachme!
Content of this email which does not relate to the official business of Bond Dickinson LLP, is neither given nor
endorsed by it.
‘This email is sent for and on behalf of Bond Dickinson LLP which is a limited liabil arinersnip regis
and Wales under number OC317661. Our registered office is St 's Wharf, 112 Quayside, Newcastie Upon Tyne,
NE1 3DX, where a list of members’ names is open to inspection. We use the term partner to refer to a member of the
LLP, or an employee or consultant whe is of equivalent standing. Our VAT registration number is GB123393627.
fin England
Bond Dickinson LLP is auth
ised and regulated by the Solicitors Requiation Authority.
POL00112928
POL00112928
Bundler 1
From: Loraine, Paul <!_
Sent: 31 July 2014 19:03
To: Martin Smith; jessica.barket
Ce: Parsons, Andrew; Matthew Harris
Subject: RE: M052 - Response to CRR / Settlement Analysis
Attachments: M052__DRAFT_CRR.PDF
Martin
Please see the draft CRR attached.
Thanks
Paul
Paul Loraine
Solicitor
www. bonddickinson.com
From: Martin Smith [mailto
Sent: 31 July 2014 16:10
To: Loraine, Paul; jessica.barkel
Cc: Parsons, Andrew; Matthew Harris
Subject: RE: M052 - Response to CRR / Settlement Analysis
Hi Paul,
May we have a copy of the CRR please?
Many thanks,
Martin.
Martin Smith
POL00112928
POL00112928
From: Loraine, Paul [mailtoz
Sent: 31 July 2014 12:23
To: jessica. barke: Martin Smith
Cc: Parsons, Andrew; Matthew Harris
Subject: M052 - Response to CRR / Settlement Analysis
Dear all
Please see attached a draft response to Second Sight’s draft CRR for MO52 along with the settlement analysis.
Kind regards
Paul
Paul Loraine
Solicitor
for and on behalf of Bend Dickinson LLP
www.bonddickinson.com
The i
aw. jessica. bark:
Mi artis
jessica, barker¢
Matthew.H.
any copies.
Ame!
ation in this e-mail and any attachment confidential and may be legally
GRO “Lmartin.smith¢ GRO }, Andrew. Parsons.
jonly is a nail and any atk
martin.smith Andrew.Parsonsé GRO
Las Soon as p
iG Of this communic:
il will have
ty for a
before ope:
is sent for anc on behalf of Bond Dickinson L
s under number OC317667. Our regi
NE1 3DX, where a list of members’ names is op
LLP, or an employee or consultant who is of eq!
n England
i, Newcastie Upon Tyne.
@ the term pariner to refer to a member of the
rnumber is GB123383627.
Bond Dickinson LLP is auth
ed and regulated by the Solicitors Regulation Authority.
The information i
‘aw. martin.smitt
tlachments is confiden t legally pr
GRO. Ljessica barker JAndrew.Parsonsq”
Matthew. Harri only is authorised t
martin. smith¢ GRO k, jessica barker GRO.
Matthew. Harris¢ GRO please notify Paul Loraine!
POLO00112928
POL00112928
any copies. Unauthorised use, dissem
attachments is prohibited and ray be u
tion, distribution, publication or copying of this communication or
wful.
Any files attached to this e-rnail will have been checked by us with virus detection software bet
ckinson LLP acc
carry out your own
re transmission. Bond
no liability for any loss or damage which may be caused by software viruses and you should
checks before opening any attachme!
Content of this email which does not relate to the official business of Bond Dickinson LLP, is neither given nor
endorsed by it.
‘This email is sent for and on behalf of Bond Dickinson LLP which is a limited liabil arinersnip regis
and Wales under number OC317661. Our registered office is St 's Wharf, 112 Quayside, Newcastie Upon Tyne,
NE1 3DX, where a list of members’ names is open to inspection. We use the term partner to refer to a member of the
LLP, or an employee or consultant whe is of equivalent standing. Our VAT registration number is GB123393627.
fin England
Bond Dickinson LLP is auth
ised and regulated by the Solicitors Requiation Authority.
POL00112928
POL00112928
Confidential and legally privileged draft
POST OFFICE RESPONSE TO CRR ON M052
[TO GO ON POST OFFICE LETTERHEAD]
Second Sight
By email only
[DATE]
Ref: M052
Dear Sirs
Post Office’s Response to Second Sight’s Case Review Report on case M052
This letter sets out Post Office’s response to Second Sight’s Case Review Report for application M052
(the CRR).
Post Office has no substantive comments to make on the body of the CRR at this stage. However, it
should be made clear that Post Office maintains its view that the loss suffered in the Applicant's branch
was caused by her fraudulent handling of benefit transactions.
Yours faithfully
Angela Van Den Bogerd
Head of Partnerships
Post Office Limited
Appendix
Line-by-line comments
Paragraph I Post Office comment
in CRR
1.9 The Applicant pleaded guilty at the St. Albans Magistrates Court on 5" May 2009 to 11
charges of theft and she asked for 23 other offences to be taken into consideration by the
court. She was sentenced on 28" May 2009.
1.10 A plea of guilty to a charge entails a complete admission to the offence. Accordingly the
Applicant has admitted the theft charges in respect of which she entered her guilty pleas.
By asking the court to take additional offences into consideration, the Applicant was
admitting them and asking the court to take them into account when passing sentence.
4.41 The Applicant advanced by way of mitigation that the thefts occurred to assist her elderly
mother financially. Such mitigation could not be put forward by the Applicant's
representative unless the Applicant had advanced instructions to that effect.
‘48_28868405_1 1
POL00112928
POL00112928
Bundler 1
From: Martin Smith
Sent: 01 August 2014 11:29
To: ‘Loraine, Paul’
Ce: Harris, Matthew Parsons, Andrew;
jessica.barker¢
Chris Powell ”
Subject: M052 - URGENT
Attachments: M052 - Response to CRR 31 July 14.DOCX
Paul,
Please find attached the draft response to the CRR. We have made a number of comments and
suggested amendments to the document.
Kind regards,
Martin.
Martin Smith
“Tel:
CartwrightKing
emt SOLE CTIORS
Birmingham I Derby I Leeds I Leicester London I Nottingham I Sheffield I Tyneside
www.cartwrightking.co.uk
POL00112928
POL00112928
Bundler 1
From: Belinda Crowe <
Sent: 06 November 20’
To: ‘andrew.parsons:
Alexander; Martin Smith; Jarnai
Ce: Rodric Williams; ‘victoria.brooks
Subject:
Thanks Andy
My only comment would be whether the statements about the behaviour of the applicant's family members actually
add anything.
They are not in the category of docs that SS want or need and are not relevant to the conviction.
1am not sure whether the applicant has ever seen them but I do not think this information should be provided
unless there is a good reason for us to provide it.
Best wishes
Belinda
From: Parsons, Andrew [mailto/ ~~ ” GRO
; Durston, Joel
All
SS have requested disclosure of all documents from Post Office's prosecution file in the above case. We have re-
reviewed the prosecution files and those "non-privileged" documents (ie. anything that is not legal advice and does
not relate to internal Post Office investigation steps) that could be disclosed are attached.
Paul / Kath - I'd be grateful if you could confirm whether any of the documents to be disclosed have any material
impact on our POIR.
Martin / Jarnail - I'd be grateful if you could confirm whether you have any objection to these additional documents
being released to SS.
Belinda - we can then take a final view on if, what and how to release any documents to SS.
Password is the same as used for the POIR.
Kind regards
Andy
Andrew Parsons
Managing Associate
Direct: {
Mobile: I
POL00112928
POL00112928
siren me
ss Regulation
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: 148 OLD STREET,
LONDON EC1V 9HQ.
POL00112928
POL00112928
Bundler 1
From: Martin Smith
Sent: 07 November 2014 10:42 oo
To: ‘Parsons, Andrew’; Belinda Crowe; ‘paul.loraine¢_
Alexander; Jarnail Singh
Ce: Rodric Williams; Brooks, Victoria; Durston, Joel
Subject: RE: M052 - further disclosure [BD-4A.FID25887221]
Andy,
From a criminal perspective, we would advise as a general rule against the disclosure of any
documents from a criminal file which have not previously been disclosed to the defendant during
the course of the original proceedings. To do otherwise may well enable the Defendant or Second
Sight to attempt to criticise the way in which the prosecution was conducted or how the
prosecution policy was applied. Clearly such arguments in a public arena would be
uncomfortable for POL.
We remain concerned that Second Sight are pushing for the disclosure of files and advise that a
robust stance be taken by POL in relation to all such requests.
Please do not hesitate to call me to discuss this in more detail should you so wish.
Kind regards,
Martin.
Martin Smith
CartwrightKing
seme SD CTT ORS emma
Birmingham I Derby I Leeds I LeicesterI London I Milton Keynes I Nottingham I Sheffield I
Tyneside
www.cartwrightking.co.uk
POL00112928
POL00112928
To: Belinda Crowe; ‘paul.lorainé.. GRO 3 Kathryn Alexander; Martin Smith; Jarnail Singh
Cc: Rodric Williams; Brooks, Victoria; Durston, Joel
Subject: RE: M052 - further disclosure [BD-4A.FID25887221]
Belinda
Thanks — just to confirm..
There is only one statement about the actions of the Applicant's husband — the statement from Lisa Allen and this has
already been disclosed with the POIR so there's nothing we can do about this now. Noted however for other cases.
Kind regards
Andy
Andrew Parsons
Managing Associate
From: Belinda Crowe [mailto GRO H
Sent: 06 November 2014 19:1
To: Parsons, Andrew; ‘paul.loraine
Jarnail Singh
Cc: Rodric Williams; Brooks, Victoria; Durston, Joel; Belinda Crowe
Subject: Re: M052 - further disclosure [BD-4A.FID25887221]
Kathryn Alexander; ‘martin.smitl
Thanks Andy
My only comment would be whether the statements about the behaviour of the applicant's family members actually
add anything.
They are not in the category of docs that SS want or need and are not relevant to the conviction.
1am not sure whether the applicant has ever seen them but I do not think this information should be provided
unless there is a good reason for us to provide it.
Best wishes
Belinda
From: Parsons, Andrew [mailto?
Sent: Thursday, No ber 06, 20
To: Loraine,
_>; Jarnail Singh
_>; Durston, Joel
S'[BD-4A.FID25887221]
All
SS have requested disclosure of all documents from Post Office's prosecution file in the above case. We have re-
reviewed the prosecution files and those "non-privileged" documents (ie. anything that is not legal advice and does
not relate to internal Post Office investigation steps) that could be disclosed are attached.
POL00112928
POL00112928
Paul / Kath - I'd be grateful if you could confirm whether any of the documents to be disclosed have any material
impact on our POIR.
Martin / Jarnail - I'd be grateful if you could confirm whether you have any objection to these additional documents
being released to SS.
Belinda - we can then take a final view on if, what and how to release any documents to SS.
Password is the same as used for the POIR.
Kind regards
Andy
Andrew Parsons
Managing Associate
eeennrennerserrrenrcnennrerrrererrrcrersec srr rrrrerrcrrerettt ttt!
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: 148 OLD STREET,
LONDON EC1V 9HQ.
JOH SOD aS ORI SOOO DIO AOIS IO DIIS IORI S IORI SSO NSIS S
POL00112928
POL00112928
Bundler 1
From: Parsons, Andrew 4
Sent: 07 November 2014 09:58
To: Belinda Crowe; ‘paul.loraine Kathryn Alexander; Martin Smith;
Jarnail Singh
Ce: Rodric Williams; Brooks, Victoria; Durston, Joel
Subject: RE: M052 - further disclosure [BD-4A.FID25887221]
Belinda
Thanks — just to confirm...
There is only one statement about the actions of the Applicant's husband ~ the statement from Lisa Allen and this has
already been disclosed with the POIR so there's nothing we can do about this now. Noted however for other cases.
Kind regards
Andy
Andrew Parsons
Managing Associate
www.bonddickinson.com
From: Belinda Crowe [mailto:
Sent: 06 November 2014 19:
To: Parsons, Andrew; ‘paul.lorains
Jarnail Singh
Cc: Rodric Williams; Brooks, Victoria; Durston, Joel; Belinda Crowe
Subject: Re: M052 - further disclosure [BD-4A.FID25887221]
Thanks Andy
My only comment would be whether the statements about the behaviour of the applicant's family members actually
add anything.
They are not in the category of docs that $S want or need and are not relevant to the conviction.
1am not sure whether the applicant has ever seen them but I do not think this information should be provided
unless there is a good reason for us to provide it.
Best wishes
Belinda
From: Parsons, Andrew [mailto}
Sent: Thursday, November 06, 2014 05:12 PM
To: Loraine, Paul {
>; Kathryn Alexander;
“>; Durston, Joel
>
POL00112928
POL00112928
Subject: M052 - further disclosure [BD-4A.FID25887221]
All
SS have requested disclosure of all documents from Post Office's prosecution file in the above case. We have re-
reviewed the prosecution files and those “non-privileged" documents (ie. anything that is not legal advice and does
not relate to internal Post Office investigation steps) that could be disclosed are attached.
Paul / Kath - I'd be grateful if you could confirm whether any of the documents to be disclosed have any material
impact on our POIR.
Martin / Jarnail - I'd be grateful if you could confirm whether you have any objection to these additional documents
being released to SS.
Belinda - we can then take a final view on if, what and how to release any documents to SS.
Password is the same as used for the POIR.
Kind regards
Andy
Andrew Parsons
Managing Associate
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: 148 OLD STREET,
LONDON EC1V 9HQ.
2
POL00112928
POL00112928
Bundler 1
From: Durston, Joel £
Sent: 07 November 2014 15:15
To: Martin Smith
Subject: RE: M052 - further disclosure
Good afternoon Martin,
Could you please send over the following files for our consideration:
M012;
M025;
M040;
M051;
M05;
Mos!
M07:
M077;
MOg7;
M108;
M109;&
M118
eevee ee ee eee
Kind regards
Joel Durston
www.bonddickinson.com
Sent: 07 November 2014 10:42 :
To: Parsons, Andrew; Belinda Crowe; 'paul.lorainei.
Cc: Rodric Williams; Brooks, Victoria; Durston, Joel
Subject: RE: M052 - further disclosure [BD-4A.FID25887221]
} Kathryn Alexander; Jarnail Singh
Andy,
From a criminal perspective, we would advise as a general rule against the disclosure of any
documents from a criminal file which have not previously been disclosed to the defendant during
the course of the original proceedings. To do otherwise may well enable the Defendant or Second
Sight to attempt to criticise the way in which the prosecution was conducted or how the
prosecution policy was applied. Clearly such arguments in a public arena would be
uncomfortable for POL.
POL00112928
POL00112928
We remain concerned that Second Sight are pushing for the disclosure of files and advise that a
robust stance be taken by POL in relation to all such requests.
Please do not hesitate to call me to discuss this in more detail should you so wish.
Kind regards,
Martin.
Martin Smith
Tel:
CartwrightKing
Birmingham I Derby I Leeds I LeicesterI London I Milton Keynes I Nottingham I Sheffield I
Tyneside
www.cartwrightking.co.uk
CONFR
This
From: Parsons, Andrew [mailtos” GRO
Sent: 07 November 2014 09:
To: Belinda Crowe; ‘paul.loraing...
Cc: Rodric Williams; Brooks, Victoria; Durston, Joel
Subject: RE: M052 - further disclosure [BD-4A.FID25887221]
Kathryn Alexander; Martin Smith; Jarnail Singh
Belinda
Thanks — just to confirm...
There is only one statement about the actions of the Applicant's husband — the statement from Lisa Allen and this has
already been disclosed with the POIR so there's nothing we can do about this now. Noted however for other cases.
Kind regards
Andy
Andrew Parsons
Managing Associate
POL00112928
POL00112928
lin)
www.bond:
inson.com
From: Belinda Crowe [mailto:
Sent: 06 November 2014 19:
To: Parsons, Andrew; ‘paul. loraine!
Jarnail Singh
Cc: Rodric Williams; Brooks, Victoria; Durston, Joel; Belinda Crowe
Subject: Re: M052 - further disclosure [BD-4A.FID25887221]
Kathryn Alexander; 'martin.smitt
Thanks Andy
My only comment would be whether the statements about the behaviour of the applicant's family members actually
add anything.
They are not in the category of docs that SS want or need and are not relevant to the conviction.
1am not sure whether the applicant has ever seen them but I do not think this information should be provided
unless there is a good reason for us to provide it.
Best wishes
Relinda..
From: Parsons, Andrew [mailto
Sent: Thursday, Nove
To: Loraine, Paul (
Kathryn Alexander;
~ <martin.smitht.
is; Brooks, Victoria
; Durston, Joel
SS have requested disclosure of all documents from Post Office's prosecution file in the above case. We have re-
reviewed the prosecution files and those "non-privileged” documents (ie. anything that is not legal advice and does
not relate to internal Post Office investigation steps) that could be disclosed are attached.
Paul / Kath - I'd be grateful if you could confirm whether any of the documents to be disclosed have any material
impact on our POIR.
Martin / Jarnail - I'd be grateful if you could confirm whether you have any objection to these additional documents
being released to SS.
Belinda - we can then take a final view on if, what and how to release any documents to SS.
Password is the same as used for the POIR.
Kind regards
Andy
Andrew Parsons
Managing Associate
POL00112928
POL00112928
siren me
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: 148 OLD STREET,
LONDON EC1V 9HQ.
POL00112928
POL00112928
Bundler 1
From: Paul Morris
Sent: 07 November 2014 08:50
To: Martin Smith
Subject: FW: M052 - further disclosure [BD-4A.FID25887221] ck-out
Attachments: M052 Disclosure Index.DOCX; M052.zip
Email came in for you
Paul Morris
CartwrightKing
wm SLE GTP OR S mmm
Birmingham I Derby I Leeds I LeicesterI London I Milton Keynes I Nottingham I Sheffield I
Tyneside
www.cartwrightking.co.uk
From: Parsons, Andrew [mailt¢
Sent: 06 November 2014 17:12
H i ; Kathryn Alexander; Martin Smith; Jarnail A Singh
ms (} ; Brooks, Victoria; Durston, Joel
Subject: M052 - further disclosure [BD-4A:FID25887221]
All
SS have requested disclosure of all documents from Post Office's prosecution file in the above case. We have re-
reviewed the prosecution files and those “non-privileged"” documents (ie. anything that is not legal advice and does
not relate to internal Post Office investigation steps) that could be disclosed are attached.
Paul / Kath — I'd be grateful if you could confirm whether any of the documents to be disclosed have any material
impact on our POIR.
Martin / Jarnail - I'd be grateful if you could confirm whether you have any objection to these additional documents
being released to SS.
Belinda — we can then take a final view on if, what and how to release any documents to SS.
Password is the same as used for the POIR.
Kind regards
Andy
Andrew Parsons
Managing Associate
www_bonddickinson.com
D
1D.
OnE
e consider the er
o you need fo prin
POL00112928
POL00112928
The information in Unis e-mail and any attachments
only is authorised to access this eanad and any attach:
andrew.parsong
communication or attachments
soon as p
fed and may
Any files attached to this emai will have been checked by as with views detection
xy out your own vir
age which may be caused by software v
any lass,
Content of this email which does not relate to the official business of Bond Dickinson I
fesm partner ti
Bond Di
ihle and delete
« uniaw ful.
Miware before transotission. Bond Dickinson LLP
hocks hofare opens
is neither given nor endorsed by ih.
ing of this
opts ne liability for
POL00112928
POL00112928
Bundler 1
From: Jarnail Singh ¢,
Sent: 10 November 2014 11:39
To: Martin Smith; ‘Parsons, Andrew’; Belinda Crowe; ‘paul.loraine!_
Kathryn Alexander
Ce: Rodric Williams; Brooks, Victoria; Durston, Joel
Subject: RE: M052 - further disclosure [BD-4A.FID25887221]
Dear All
l agree a robust stance should be taken by POL in relation to such requests by second sight.
Jarnail
Jarnail Singh I Criminal Lawyer
INDON, ECTV 9HO.
® @postofficenews
From: Martin Smith [mailto{_
Sent: 07 November 2014 10:42 -
To: ‘Parsons, Andrew’; Belinda Crowe; 'paul.loraing__ GRO___}; Kathryn Alexander; Jarnail Singh
Cc: Rodric Williams; Brooks, Victoria; Durston, Joel
Subject: RE: M052 - further disclosure [BD-4A.FID25887221]
Andy,
From a criminal perspective, we would advise as a general rule against the disclosure of any
documents from a criminal file which have not previously been disclosed to the defendant during
the course of the original proceedings. To do otherwise may well enable the Defendant or Second
Sight to attempt to criticise the way in which the prosecution was conducted or how the
prosecution policy was applied. Clearly such arguments in a public arena would be
uncomfortable for POL.
We remain concerned that Second Sight are pushing for the disclosure of files and advise that a
robust stance be taken by POL in relation to all such requests.
Please do not hesitate to call me to discuss this in more detail should you so wish.
Kind regards,
Martin.
POL00112928
POL00112928
Martin Smith
CartwrightKing
comms DLT GR S seme
Birmingham I Derby I Leeds I LeicesterI London I Milton Keynes I Nottingham I Sheffield I
Tyneside
www.cartwrightking.co.uk
From: Parsons, Andrew [mailto}
Sent: 07 November 2014 09:
To: Belinda Crowe; ‘paul.lorain
Cc: Rodric Williams; Brooks, Victoria; Durston, Joel
Subject: RE: M052 - further disclosure [BD-4A.FID25887221]
Kathryn Alexander; Martin Smith; Jarnail Singh
Belinda
Thanks — just to confirm..
There is only one statement about the actions of the Applicant's husband ~ the statement from Lisa Allen and this has
already been disclosed with the POIR so there's nothing we can do about this now. Noted however for other cases.
Kind regards
Andy
Andrew Parsons
Managing Associate
From: Belinda Crowe [mailto! GRO 7
Sent: 06 November 2014 19:13
To: Parsons, Andrew; ‘paul.loraine._
Jarnail Singh
Cc: Rodric Williams; Brooks, Victoria; Durston, Joel; Belinda Crowe
Subject: Re: M052 - further disclosure [BD-4A.FID25887221]
Kathryn Alexander; 'martin.smitt
POL00112928
POL00112928
Thanks Andy
My only comment would be whether the statements about the behaviour of the applicant's family members actually
add anything.
They are not in the category of docs that SS want or need and are not relevant to the conviction.
lam not sure whether the applicant has ever seen them but ! do not think this information should be provided
unless there is a good reason for us to provide it.
Best wishes
Belinda
From: Parsons, Andrew [mailtof
Sent: Thursday, November 06,
To: Loraine, ”
Kathryn Alexander;
; Durston, Joel
<joel.durston wt
Subject: M052 - further disclosure [BD-4A.FID25887221]
All
SS have requested disclosure of all documents from Post Office's prosecution file in the above case. We have re-
reviewed the prosecution files and those "non-privileged” documents (ie. anything that is not legal advice and does
not relate to internal Post Office investigation steps) that could be disclosed are attached.
Paul / Kath - I'd be grateful if you could confirm whether any of the documents to be disclosed have any material
impact on our POIR.
Martin / Jarnail - I'd be grateful if you could confirm whether you have any objection to these additional documents
being released to SS.
Belinda - we can then take a final view on if, what and how to release any documents to SS.
Password is the same as used for the POIR.
Kind regards
Andy
Andrew Parsons
Managing Associate
Fax:
Direct: { i
mi: I GRO
POL00112928
POL00112928
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: 148 OLD STREET,
LONDON EC1V 9HQ.
SOHO IODA SIO SOO ISSO TIO IOI B ORAS IISA ISSO NIST A
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: 148 OLD STREET,
LONDON EC1V 9HQ.
POL00112928
POL00112928
Bundler 1
From: Jarnail Singh 4. _ .
Sent: 10 November 2014 16:32
To: Parsons, Andrew; Martin Smith; Belinda Crowe; Kathryn Alexander; Shirley
Hailstones
Ce: Rodric Williams; Brooks, Victoria; Durston, Joel
Subject: RE: M052 - further disclosure [BD-4A.FID20472253]
Andy
l understand there are 12 such cases. Disclosure which is sought is papers which would in any case be served on the
defence solicitors. Which is the committal bundle consisting of witness statements and exhibits .To safe guard POLs
position Disclosure in these cases should be restricted to the committal bundle only.
Regards.
Jarnail
Jarnail Singh I Criminal Lawyer
3)
®
@
i)
@
Post Office stories
=)
&® @postofficenews
From: Parsons, Andrew [mailto!
Sent: 10 November 2014 13:54
To: Jarnail Singh; Martin Smith; Belinda Crowe; Kathryn Alexander; Shirley Hailstones
Cc: Rodric Williams; Brooks, Victoria; Durston, Joel
Subject: RE: M052 - further disclosure [BD-4A.FID20472253]
All
i've discussed with Martin ~ the approach we are taking is as follows:
1. Kath / Shirley / CK to send prosecution papers to BD.
2. BD to review to identify documents that could be disclosed to SS (ie. anything that is not legal advice and
does not relate to internal Post Office investigation steps).
3. BD to index those documents and recommend which ones should be disclosed (ie. those that are relevant to
the case)
4. Kath / Shirley to comment on whether the docs have any material effect on the case.
5. CK to comment on whether disclosure is ok from a criminal perspective.
6. Me/ Belinda to action actuai disclosure of any docs to SS.
Kind regards
Andy
POL00112928
POL00112928
Andrew Parsons
Managing Associate
From: Jarnail Singh [mailto!
Sent: 10 November 2014 11:39
To: Martin Smith; Parsons, Andrew; Belinda Crowe; ‘paul.lorainef.
Cc: Rodric Williams; Brooks, Victoria; Durston, Joel
Subject: RE: M052 - further disclosure [BD-4A.FID25887221]
+ Kathryn Alexander
Dear All
l agree a robust stance should be taken by POL in relation to such requests by second sight.
Jarnail
Jarnail Singh I Criminal Lawyer
@ Post Office stories
@® @postofficenews
From: Martin Smith [mailto!.w-n.n.aean--GRO
Sent: 07 November 2014 10:42 ..
To: ‘Parsons, Andrew’; Belinda Crowe; ‘paul.loraing_
Cc: Rodric Williams; Brooks, Victoria; Durston, Joel
Subject: RE: M052 - further disclosure [BD-4A.FID25887221]
} Kathryn Alexander; Jarnail Singh
Andy,
From a criminal perspective, we would advise as a general rule against the disclosure of any
documents from a criminal file which have not previously been disclosed to the defendant during
the course of the original proceedings. To do otherwise may well enable the Defendant or Second
Sight to attempt to criticise the way in which the prosecution was conducted or how the
prosecution policy was applied. Clearly such arguments in a public arena would be
uncomfortable for POL.
We remain concerned that Second Sight are pushing for the disclosure of files and advise that a
robust stance be taken by POL in relation to all such requests.
2
POL00112928
POL00112928
Please do not hesitate to call me to discuss this in more detail should you so wish.
Kind regards,
Martin.
Martin Smith
CartwrightKing
women DLE CTT OR S eememe
Birmingham I Derby I Leeds I Leicester] London I Milton Keynes I Nottingham I Sheffield I
Tyneside
From: Parsons, Andrew [mailtc
Sent: 07 November 2014 09:58
To: Belinda Crowe; 'paul.lorain
Cc: Rodric Williams; Brooks, Vi i ,
Subject: RE: M052 - further disclosure [BD-4A.FID25887221]
} Kathryn Alexander; Martin Smith; Jarnail Singh
Belinda
Thanks — just to confirm...
There is only one statement about the actions of the Applicant's husband ~ the statement from Lisa Allen and this has.
already been disclosed with the POIR so there's nothing we can do about this now. Noted however for other cases.
Kind regards
Andy
Andrew Parsons
Managing Associate
Direct: i
zt GRO
Fax: t
POL00112928
POL00112928
From: Belinda Crowe [mailto:
Sent: 06 November 2014 19:13
To: Parsons, Andrew; ‘paul.lorainet
Jarnail Singh
Cc: Rodric Williams; Brooks, Victoria; Durston, Joel; Belinda Crowe
Subject: Re: M052 - further disclosure [BD-4A.FID25887221]
Thanks Andy
My only comment would be whether the statements about the behaviour of the applicant's family members actually
add anything.
They are not in the category of docs that SS want or need and are not relevant to the conviction.
1am not sure whether the applicant has ever seen them but I do not think this information should be provided
unless there is a good reason for us to provide it.
Best wishes
Beli
From: Parsons, Andrew [mailto:_
Sent: Thursday, November 06,
<paul.lorainet
To: Loraine, Paul (paul loraine: Kathryn Alexander;
martin.smith GRO. = Z .
Cc: Belinda Crowe; Rodric Williams; Brooks, Victoria <v -GRO_ >; Durston, Joel
Subject: M052 - further disclosure [BD-4A.FID25887221]
All
SS have requested disclosure of all documents from Post Office's prosecution file in the above case. We have re-
reviewed the prosecution files and those "non-privileged" documents (ie. anything that is not legal advice and does
not relate to internal Post Office investigation steps) that could be disclosed are attached.
Paul / Kath - I'd be grateful if you could confirm whether any of the documents to be disclosed have any material
impact on our POIR.
Martin / Jarnail - I'd be grateful if you could confirm whether you have any objection to these additional documents
being released to SS.
Belinda - we can then take a final view on if, wnat and how to release any documents to SS.
Password is the same as used for the POIR.
Kind regards
Andy
Andrew Parsons
Managing Associate
Mobile:
Fax:
Follow Bon
www.bonddickinson.com
POL00112928
POL00112928
atl De y
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: 148 OLD STREET,
LONDON EC1V 9HQ.
Seer ttree te tteree treet treertcetettcteseeterrartttrreeteserrttarttd
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: 148 OLD STREET,
LONDON EC1V 9HQ.
SOUS SIO IDOI IOI ISO ARIA AAO IDI SOB AAI IOI IIIA ISA
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: 148 OLD STREET,
LONDON EC1V 9HQ.
POL00112928
POL00112928
Bundler 1
From: Parsons, Andrew <
Sent: 10 November 2014 13:54
To: Jarnail Singh; Martin Smith; Belinda Crowe; Kathryn Alexander; Shirley Hailstones
Ce: Rodric Williams; Brooks, Victoria; Durston, Joel
Subject: RE: M052 - further disclosure [BD-4A.FID20472253]
All
I've discussed with Martin - the approach we are taking is as follows:
1. Kath / Shirley / CK to send prosecution papers to BD.
2. BD to review to identify documents that could be disclosed to SS (ie. anything that is not legal advice and
does not relate to internal Post Office investigation steps).
3. BD to index those documents and recommend which ones should be disclosed (ie. those that are relevant to
the case)
4. Kath / Shirley to comment on whether the docs have any material effect on the case.
5. CK to comment on whether disclosure is ok from a criminal perspective.
6. Me/ Belinda to action actual disclosure of any docs to SS.
Kind regards
Andy
Andrew Parsons
Managing Associate
Sent: 10 November 2014 11:39
To: Martin Smith; Parsons, Andrew; Belinda Crowe; ‘paul.lorain
Cc: Rodric Williams; Brooks, Victoria; Durston, Joel
Subject: RE: M052 - further disclosure [BD-4A.FID25887221]
Kathryn Alexander
Dear All
l agree a robust stance should be taken by POL in relation to such requests by second sight.
Jarnail
Jarnail Singh I Criminal Lawyer
148 Old Street
POL00112928
POL00112928
@® @postotticenews
From: Martin Smith [mailto?
Sent: 07 November 2014 10:4: .
To: ‘Parsons, Andrew'; Belinda Crowe; ‘paul.loraineé
Ce: Rodric Williams; Brooks, Victoria; Durston, Joel”
Subject: RE: M052 - further disclosure [BD-4A.FID25887221]
} Kathryn Alexander; Jarnail Singh
Andy,
From a criminal perspective, we would advise as a general rule against the disclosure of any
documents from a criminal file which have not previously been disclosed to the defendant during
the course of the original proceedings. To do otherwise may well enable the Defendant or Second
Sight to attempt to criticise the way in which the prosecution was conducted or how the
prosecution policy was applied. Clearly such arguments in a public arena would be
uncomfortable for POL.
We remain concerned that Second Sight are pushing for the disclosure of files and advise that a
robust stance be taken by POL in relation to all such requests.
Please do not hesitate to call me to discuss this in more detail should you so wish.
Kind regards,
Martin.
Martin Smith ;
“a S RO 7
ade
Birmingham I Derby I Leeds I Leicester] London I Milton Keynes I Nottingham I Sheffield I
Tyneside
www.cartwrightking.co.uk
POL00112928
POL00112928
From: Parsons, Andrew [mailto:
Sent: 07 November 2014 09:58
To: Belinda Crowe; ‘paul.lorain
Cc: Rodric Williams; Brooks, Victoria; Durston, Joel
Subject: RE: M052 - further disclosure [BD-4A.FID25887221]
Kathryn Alexander; Martin Smith; Jarnail Singh
Belinda
Thanks — just to confirm..
There is only one statement about the actions of the Applicant's husband ~ the statement from Lisa Allen and this has
already been disclosed with the POIR so there's nothing we can do about this now. Noted however for other cases.
Kind regards
Andy
Andrew Parsons
Managing Associate
www.bonddickinson.com
From: Belinda Crowe [mailto:
Sent: 06 November 2014 19:13
To: Parsons, Andrew; ‘paul.lorainé_
Jarnail Singh
Cc: Rodric Williams; Brooks, Victoria; Durston, Joel; Belinda Crowe
Subject: Re: M052 - further disclosure [BD-4A.FID25887221]
Kathryn Alexander; 'martin.smitl
Thanks Andy
My only comment would be whether the statements about the behaviour of the applicant's family members actually
add anything.
They are not in the category of docs that SS want or need and are not relevant to the conviction.
1am not sure whether the applicant has ever seen them but ! do not think this information should be provided
unless there is a good reason for us to provide it.
Best wishes
Belinda
From: Parsons, Andrew [mailto!
Sent: Thursday, November.06,.2014 05:12.
To: Loraine, Paul (:
: ; Kathryn Alexander;
I Jarnail Singh
; Durston, Joel
Subject: M052 - further disclosure [BD-4A.FID25887221]
All
POL00112928
POL00112928
SS have requested disclosure of all documents from Post Office's prosecution file in the above case. We have re-
reviewed the prosecution files and those "non-privileged" documents (ie. anything that is not legal advice and does
not relate to internal Post Office investigation steps) that could be disclosed are attached.
Paul / Kath - I'd be grateful if you could confirm whether any of the documents to be disclosed have any material
impact on our POIR.
Martin / Jarnail - I'd be grateful if you could confirm whether you have any objection to these additional documents
being released to SS.
Belinda - we can then take a final view on if, what and how to release any documents to SS.
Password is the same as used for the POIR.
Kind regards
Andy
Andrew Parsons
Managing Associate
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: 148 OLD STREET,
LONDON EC1V 9HQ.
OES ee Ee reetttteeetttrtet eter ttettertcteteettareret tren etteceret tented
POL00112928
POL00112928
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: 148 OLD STREET,
LONDON EC1V 9HQ
POL00112928
POL00112928
Bundler 1
From: Martin Smith
Sent: 11 November 2014 14:39
To: Jarnail A Singh
Subject: FW: M082 - further disclosure
Jarnail,
Please see the attached e-mail from BD below. Further to our telephone conversation this morning
I confirm that we will forward the buff proceedings files which we hold to BD so as to comply
with the request and advise further with regard to any proposed disclosure in individual
mediations in due course on a case by case bas
Kind regards,
Martin.
Martin Smith
CartwrightKing
comment SG LS CTT ORS mem
Bi
Tyneside
www.cartwrightking.co.uk
ningham I Derby I Leeds I LeicesterI London I Milton Keynes I Nottingham I Sheffield I
Sent: 07 November 2014 15:
To: Martin Smith
Subject: RE: M052 - further disclosure
Good afternoon Martin,
Could you please send over the following files for our consideration:
POL00112928
POL00112928
M012;
M025;
Modo;
M051;
M052;
M058;
M072;
M077;
M097;
M108;
M109;&
M118.
eoeeceee eee eee
Kind regards
Joel Durston
From: Martin Smith [mailto
Sent: 07 November 2014 10:
To: Parsons, Andrew; Belinda Crowe; 'paul.lorain€
Cc: Rodric Williams; Brooks, Victoria; Durston, Joel
Subject: RE: M052 - further disclosure [BD-4A.FID25887221]
Kathryn Alexander; Jarnail Singh
Andy,
From a criminal perspective, we would advise as a general rule against the disclosure of any
documents from a criminal file which have not previously been disclosed to the defendant during
the course of the original proceedings. To do otherwise may well enable the Defendant or Second
Sight to attempt to criticise the way in which the prosecution was conducted or how the
prosecution policy was applied. Clearly such arguments in a public arena would be
uncomfortable for POL.
We remain concerned that Second Sight are pushing for the disclosure of files and advise that a
robust stance be taken by POL in relation to all such requests.
Please do not hesitate to call me to discuss this in more detail should you so wish.
Kind regards,
Martin.
POL00112928
POL00112928
CartwrightKing
comms DLT GR S seme
Birmingham I Derby I Leeds I LeicesterI London I Milton Keynes I Nottingham I Sheffield I
Tyneside
www.cartwrightking.co.uk
From: Parsons, Andrew [mailto: !
Sent: 07 November 2014 09:
To: Belinda Crowe; ‘paul.lorain
Cc: Rodric Williams; Brooks, Victoria; Durston, Joel
Subject: RE: M052 - further disclosure [BD-4A.FID25887221]
Kathryn Alexander; Martin Smith; Jarnail Singh
Belinda
Thanks — just to confirm..
There is only one statement about the actions of the Applicant's husband ~ the statement from Lisa Allen and this has
already been disclosed with the POIR so there's nothing we can do about this now. Noted however for other cases.
Kind regards
Andy
Andrew Parsons
Managing Associate
From: Belinda Crowe [mailto:
Sent: 06 November 2014 19:
To: Parsons, Andrew; ‘paul.lorains
Jarnail Singh
Ce: Rodric Williams; Brooks, Victoria; Durston, Joel; Belinda Crowe
Subject: Re: M052 - further disclosure [BD-4A.FID25887221]
Kathryn Alexander; 'martin.smitt
POL00112928
POL00112928
Thanks Andy
My only comment would be whether the statements about the behaviour of the applicant's family members actually
add anything.
They are not in the category of docs that SS want or need and are not relevant to the conviction.
lam not sure whether the applicant has ever seen them but ! do not think this information should be provided
unless there is a good reason for us to provide it.
Best wishes
Belinda
From: Parsons, Andrew [mailtoi
Sent: Thursday, November 06,.2014.05:12.PM.
To: Loraine, Paul I.lorainet
Kathryn Alexander;
; Jarnail Singh
‘>; Durston, Joel
Cc: Belinda Crowe; Rodric Wi — Brooks, Victoria
Subject: M052 - further disclosure [BD-4A.FID25887221]
All
SS have requested disclosure of all documents from Post Office's prosecution file in the above case. We have re-
reviewed the prosecution files and those "non-privileged” documents (ie. anything that is not legal advice and does
not relate to internal Post Office investigation steps) that could be disclosed are attached.
Paul / Kath - I'd be grateful if you could confirm whether any of the documents to be disclosed have any material
impact on our POIR.
Martin / Jarnail - I'd be grateful if you could confirm whether you have any objection to these additional documents
being released to SS.
Belinda - we can then take a final view on if, what and how to release any documents to SS.
Password is the same as used for the POIR.
Kind regards
Andy
Andrew Parsons
Managing Associate
POL00112928
POL00112928
in vieus cheoks before up
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recipient, you must not use, disclose, reproduce, copy or distribute the contents of this communication. If you have
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POST OFFICE LIMITED is registered in England and Wales no 2154540. Registered Office: 148 OLD STREET,
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POL00112928
POL00112928
Bundler 1
From: Jarnail Singh < CG SRO p
Sent: 11 November 2014 14:54
To: Martin Smith
Subject: RE: M052 - further disclosure
Thanks Martin much appreciate it.
Jarnail Singh I Criminal La
@
©
DOS
@postofficenews
©
From: Martin Smit
Sent: 11 November 2014 14:39
To: Jarnail Singh
Subject: FW: M052 - further disclosure
Jarnail,
Please see the attached e-mail from BD below. Further to our telephone conversation this morning
I confirm that we will forward the buff proceedings files which we hold to BD so as to comply
with the request and advise further with regard to any proposed disclosure in individual
mediations in due course on a case by case basis.
Kind regards,
Martin.
Martin Smith
CartwrightKing
women $241 SRS mem
POL00112928
POL00112928
Birmingham I Derby I Leeds I Leicester] London I Milton Keynes I Nottingham I Sheffield I
Tyneside
www.cartwrightking.co.uk
srivileged information
From: Durston, Joel [mailto:
Sent: 07 November 2014 1:
To: Martin Smith
Subject: RE: M052 - further disclosure
Good afternoon Martin,
Could you please send over the following files for our consideration:
M012;
Mo25;
Mo40;
M051;
M052;
Kind regards
Joel Durston
Follow Bond
in]
www.bonddickinson.com
From: Martin Smith [mailto
Sent: 07 November 2014 1
To: Parsons, Andrew; Belinda Crowe; 'paul.loraine!
Cc: Rodric Williams; Brooks, Victoria; Durston, Joel
Subject: RE: M052 - further disclosure [BD-4A.FID25887221]
; Kathryn Alexander; Jarnail Singh
Andy,
POL00112928
POL00112928
From a criminal perspective, we would advise as a general rule against the disclosure of any
documents from a criminal file which have not previously been disclosed to the defendant during
the course of the original proceedings. To do otherwise may well enable the Defendant or Second
Sight to attempt to criticise the way in which the prosecution was conducted or how the
prosecution policy was applied. Clearly such arguments in a public arena would be
uncomfortable for POL.
We remain concerned that Second Sight are pushing for the disclosure of files and advise that a
robust stance be taken by POL in relation to all such requests.
Please do not hesitate to call me to discuss this in more detail should you so wish.
Kind regards,
Martin.
CartwrightKing
mnt SOLE TY HS em
Birmingham I Derby I Leeds I Leicester} London I Milton Keynes I Nottingham I Sheffield I
Tyneside
www.cartwrightking.co.uk
From: Parsons, Andrew [mailt
To: Belinda Crowe; ‘paul.loraine(.
Cc: Rodric Williams; Brooks, Victoria; Durston, Joel
Subject: RE: M052 - further disclosure [BD-4A.FID25887221]
Kathryn Alexander; Martin Smith; Jarnail Singh
Belinda
Thanks — just to confirm..
There is only one statement about the actions of the Applicant's husband — the statement from Lisa Allen and this has
already been disclosed with the POIR so there's nothing we can do about this now. Noted however for other cases.
Kind regards
Andy
Andrew Parsons
POL00112928
POL00112928
Managing Associate
From: Belinda Crowe [mailtd__
Sent: 06 November 2014 19:13
To: Parsons, Andrew; ‘paul.loraing
Jarnail Singh .
Cc: Rodric Williams; Brooks, Victoria; Durston, Joel; Belinda Crowe
Subject: Re: M052 - further disclosure [BD-4A.FID25887221]
Thanks Andy
My only comment would be whether the statements about the behaviour of the applicant's family members actually
add anything.
They are not in the category of docs that SS want or need and are not relevant to the conviction.
1am not sure whether the applicant has ever seen them but I do not think this information should be provided
unless there is a good reason for us to provide it.
Best wishes
From: Parsons, Andrew [mailto
Sent: Thursday, November 0¢
Kathryn Alexander;
; Durston, Joel
SS have requested disclosure of all documents from Post Office's prosecution file in the above case. We have re-
reviewed the prosecution files and those "non-privileged" documents (ie. anything that is not legal advice and does
not relate to internal Post Office investigation steps) that could be disclosed are attached.
Paul / Kath - I'd be grateful if you could confirm whether any of the documents to be disclosed have any material
impact on our POIR.
Martin / Jarnail - I'd be grateful if you could confirm whether you have any objection to these additional documents
being released to SS.
Belinda - we can then take a final view on if, what and how to release any documents to SS.
Password is the same as used for the POIR.
Kind regards
Andy
Andrew Parsons
Managing Associate
POL00112928
POL00112928
Fax:
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: 148 OLD STREET,
LONDON EC1V 9HQ.
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: 148 OLD STREET,
LONDON EC1V 9HQ.
POL00112928
POL00112928
Bundler 1
From: Belinda Crowe +
Sent: 11 November 2014 08:30
To: Jarnail Singh
Cc: Rodric Williams; Brooks, Victoria; Durston, Joel; Belinda Crowe; Martin Smith;
Kathryn Alexander; Shirley Hailstones; Parsons, Andrew
Subject: RE: M052 - further disclosure [BD-4A.FID20472253]
Hi Jarnail
The Working Group, including POL, agreed that SS should be provided with documents relevant to the prosecution
in certain cases.
Everyone agreed that there are likely to be few documents available and that the documents should not include
privileged material or other material which may be in a committal bundle (which, as I understand may not be
available/relevant in many cases). Whilst the committal bundle may be the best source of information there may be
other documents which we would need to consider disclosing.
{ suspect that in reality what you are suggesting will not be greatly different from what we may consider we need to
disclose but we cannot refuse to disclose information, for example, which may already have been provided to the
applicant at the time of the prosecution or that we would disclose in the event of a SAR being made.
I suggest what we do is consider this on a case by case basis when BD has completed its review of the documents
and reach a view on any individual documents as a query arises.
The process Andy is undergoing — that is to review the file, index the documents available and that could be
disclosed and we can all review (including CK) and agree what is appropriate for disclosure.
Best wishes
Belinda
Belinda Crowe
148 Old St
From: Jarnail Singh
Sent: 10 November 2014 16:32
To: Parsons, Andrew; Martin Smith; Belinda Crowe; Kathryn Alexander; Shirley Hailstones
Cc: Rodric Williams; Brooks, Victoria; Durston, Joel
Subject: RE: M052 - further disclosure [BD-4A.FID20472253]
Andy
I understand there are 12 such cases. Disclosure which is sought is papers which would in any case be served on the
defence solicitors. Which is the committal bundle consisting of witness statements and exhibits .To safe guard POLs
position Disclosure in these cases should be restricted to the committal bundle only.
Regards.
Jarnail
POL00112928
POL00112928
Jarnail Singh I Criminal Lawyer
@® @postofficenews
From: Parsons, Andrew [mailto:
Sent: 10 November 2014 1.
To: Jarnail Singh; Martin Smith; Belinda Crowe; Kathryn Alexander; Shirley Hailstones
Cc: Rodric Williams; Brooks, Victoria; Durston, Joel
Subject: RE: M052 - further disclosure [BD-4A.FID20472253]
All
I've discussed with Martin - the approach we are taking is as follows:
1. Kath / Shirley / CK to send prosecution papers to BD.
2. BD to review to identify documents that could be disclosed to SS (ie. anything that is not legal advice and
does not relate to internal Post Office investigation steps).
3. BD to index those documents and recommend which ones should be disciosed (ie. those that are relevant to
the case)
4. Kath / Shirley to comment on whether the docs have any material effect on the case.
5. CK to comment on whether disclosure is ok from a criminal perspective.
6. Me/ Belinda to action actuai disclosure of any docs to SS.
Kind regards
Andy
Andrew Parsons
Managing Associate
Direct
Mobile!
Fax: I
nd
Jin)
www.bonddickinson.com
From: Jarnail Singh [mailto ~~~
Sent: 10 November 2014 11:39
To: Martin Smith; Parsons, Andrew; Belinda Crowe; ‘paul.lorainet_
1; Kathryn Alexander
2
POL00112928
POL00112928
Cc: Rodric Williams; Brooks, Victoria; Durston, Joel
Subject: RE: M052 - further disclosure [BD-4A.FID25887221]
Dear All
l agree a robust stance should be taken by POL in relation to such requests by second sight.
Jarnail
Jarnail Singh I Criminal Lawyer
@® 148 Old Street, LONDON, EF!
From: Martin Smith [mailto GRO
Sent: 07 November 2014 10:42
To: ‘Parsons, Andrew’; Belinda Crowe; ‘paul.lorain
Cc: Rodric Williams; Brooks, Victoria; Durston, Joel
Subject: RE: M052 - further disclosure [BD-4A.FID25887221]
Kathryn Alexander; Jarnail Singh
Andy,
From a criminal perspective, we would advise as a general rule against the disclosure of any
documents from a criminal file which have not previously been disclosed to the defendant during
the course of the original proceedings. To do otherwise may well enable the Defendant or Second
Sight to attempt to criticise the way in which the prosecution was conducted or how the
prosecution policy was applied. Clearly such arguments in a public arena would be
uncomfortable for POL.
We remain concerned that Second Sight are pushing for the disclosure of files and advise that a
robust stance be taken by POL in relation to all such requests.
Please do not hesitate to call me to discuss this in more detail should you so wish.
Kind regards,
Martin.
Martin Smith
Te
CartwrightKing
women SDL CLT ORS me
POL00112928
POL00112928
Birmingham I Derby I Leeds I Leicester] London I Milton Keynes I Nottingham I Sheffield I
Tyneside
www.cartwrightking.co.uk
From: Parsons, Andrew [mailto! GRO
Sent: 07 November 2014 09;
To: Belinda Crowe; ‘paul.lorain
Cc: Rodric Williams; Brooks, Victoria; Durston, Joel
Subject: RE: M052 - further disclosure [BD-4A.FID25887221]
“} Kathryn Alexander; Martin Smith; Jarnail Singh
Belinda
Thanks — just to confirm..
There is only one statement about the actions of the Applicant's husband ~ the statement from Lisa Allen and this has
already been disclosed with the POIR so there's nothing we can do about this now. Noted however for other cases.
Kind regards
Andy
Andrew Parsons
Managing Associate
www.bonddickinson.com
From: Belinda Crowe [mailto:
Sent: 06 November 2014 19:13
To: Parsons, Andrew; ‘paul.lorainé
Jarnail Singh
Cc: Rodric Williams; Brooks, Victoria; Durston, Joel; Belinda Crowe
Subject: Re: M052 - further disclosure [BD-4A.FID25887221]
7 Kathryn Alexander; 'martin.smit
Thanks Andy
My only comment would be whether the statements about the behaviour of the applicant's family members actually
add anything.
They are not in the category of docs that SS want or need and are not relevant to the conviction.
lam not sure whether the applicant has ever seen them but I do not think this information should be provided
unless there is a good reason for us to provide it.
Best wishes
Belinda
POL00112928
POL00112928
From: Parsons, Andrew [mailtof
Sent: Thursday, November 06, 2
To: Loraine, Paul!
Kathryn Alexander;
Durston, Joel
ba Senn nO.» SONS
Subject: M052 - further disclosure [BD-4A.FID25887221]
All
SS have requested disclosure of all documents from Post Office's prosecution file in the above case. We have re-
reviewed the prosecution files and those “non-privileged" documents (ie. anything that is not legal advice and does
not relate to internal Post Office investigation steps) that could be disclosed are attached.
Paul / Kath - I'd be grateful if you could confirm whether any of the documents to be disclosed have any material
impact on our POIR.
Martin / Jarnail - I'd be grateful if you could confirm whether you have any objection to these additional documents
being released to SS.
Belinda - we can then take a final view on if, wnat and how to release any documents to SS.
Password is the same as used for the POIR.
Kind regards
Andy
Andrew Parsons
Managing Associate
POL00112928
POL00112928
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: 148 OLD STREET,
LONDON EC1V 9HQ.
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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: 148 OLD STREET,
LONDON EC1V 9HQ.
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: 148 OLD STREET,
LONDON EC1V 9HQ.