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® Post Office Limited
Finsbury Dials
20 Finsbury Street
London
EC2Y 9AQ
Mr Frazer Stuart
Criminal Cases Review Commission
5 Philip's Place
Birmingham
B3 2PW
2 April 2015
Dear Mr Stuart
Criminal Cases Review Commission ("Commission")
Horizon Computer System — Requirement to Produce Materials
I write in response to your letter dated 19 March 2015 in which you make a request
pursuant to section 17 Criminal Appeals Act 1995 (CAA) for Post Office Limited to:
i, produce a copy of the final report by Second Sight:
ii. produce a copy of the Rose Report, referred to at paragraphs 48-50 of Brian
Altman QC's report;
iii. preserve all material relating to:
« all cases considered by Second Sight;
* all cases considered by Cartwright King; and
¢ all applications for participation in the mediation scheme.
1 will deal with each request in the order set out above,
Final report by Second Sight
Second Sight's Final Report is not due to be delivered by Second Sight until 7 April
2015. This report is otherwise known as its "Part 2" Report, the Part 1 Report having
been published on 22 May 2014.
The purpose of the Part 2 Report was to describe and expand on common issues
raised by multiple applicants to the Complaint Review and Mediation Scheme, which
Post Office established to help resolve individual concerns regarding the Horizon
system and associated issues.
Second Sight produced a first iteration of its Part 2 Report on 21 August 2014, Post
Office did not agree with much of the report and responded on 22 September 2014. I
enclose a copy of both of these reports, which have already been disclosed to some of
the Complaint Review and Mediation Scheme applicants. Both documents are
confidential, having been prepared solely for use in connection with the Complaint
Review and Mediation Scheme.
We will of course forward a copy of Second Sight's final Part 2 Report to you once it is
received by Post Office, and for the sake of completeness will also send you any
response from Post Office. I can also tell you that Second Sight sent a draft of its
final Part 2 report to Post Office on 11 March 2015 to which Post Office responded on
27 March 2015. I have not included these documents with this letter given the
Post Office Limited Is registered in England and Wales. Registered No. 2154540. .
Registered Office Finsbury Dials, 20 Finsbury Street, Landon, EC2Y 9AQ PostOffice.co.uk
Post Office and the Post Office logo are registered trade marks of Post Office Limited
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imminence of the Final Report, but please let me know if you would like to see this
exchange of drafts and I will send them to you.
Please note that the above reports are highly confidential and Post Office discloses
them to the CCRC in reliance upon section 25 CAA such that the Commission is not to
disclose the reports without Post Office’s prior written consent.
Rose Report
Please find enclosed a copy of the "Rose Report" as requested,
Please note that although this report is marked "confidential and legally privileged"
Post Office does not assert any legal privilege in the document. However the
document is highly confidential and Post Office discloses it to the CCRC-in reliance
upon section 25 CAA such that the Commission is not to disclose the Report without
Post Office’s prior written consent.
Preservation of material
(i) Cases considered by Second Sight - Post Office has requested that during
their retainer with Post Office, Second Sight hold all documentation and
other materials to our order. We have requested that once they have
concluded working for Post Office they return to us all materials in their
possession and destroy any duplicate copies in their possession.
(il) Cases considered by Cartwright King - I confirm that Post Office has
requested Cartwright King to preserve all cases considered by them.
(iil) All applications for participation in the mediation scheme - I confirm that
Post Office will preserve all materials relating to applications for
participation in the Complaint Review and Mediation Scheme.
(iv) I Royal Mail Group - to the extent that there may be case material which
remains in the possession of Royal Mail Group, we have written to Royal
Mail Group requesting that no criminal files are destroyed under existing
protocols,
Please let me know if you require any clarification of the above information.
Yours sincerely ,
Solicitor
For and on behalf of Post Office Limited
Enc.