POL00192192
POL00192192
From: Matthews, Gavin _ J
Sent: Tue 16/07/2013 5:24:01 PM (UTC)
To: Susan Crichton[,
Cc: Richardson, Simoni
Subject: PRIVATE - For discusion
Susan
I've just had a brief conversation with Simon before he disappeared into the tube so have caught up about Second
Sight.
Separately I received calls after sending the message below from both Rodric (from Portugal) and Hugh (from Ireland)
I won't recount the full details but Rodric suggested initially that instead of a criminal barrister POL may use DAC
Beachcroft. I said that was of course up to POL but I thought one more firm being involved in this matter might get
complicated and the advantage of a barrister was that they would be completely independent and have no pre
conceived ideas. Rodric thought that was sensible.
Hugh subsequently called me to say that he had spoken to DAC Beachcroft (Mary Lawrence) having spoken to you but
that I should continue to consider criminal silks who POL may want to use to oversee what Cartwright King are doing.
I am just a bit concerned that there may be too many law firms involved looking at things through different lenses. Of
course it is up to you whom POL instructs but you may just want to reflect on this overnight.
I have copied in Simon for when he emerges from the underground system!
Happy to discuss at any time
Kind regards
Gavin
Gavin Matthews
Partner
for and on behalf of Bond Dickinson LLP
G pe
and Didkingon
Direct: j
st GRO
Office: I
www.bonddickinson.com
From: Matthews, Gavin
Sent: 16 July 2013 15:48
To: ‘Susan Crichton’; Parsons, Andrew
Cc: Richardson, Simon; Hugh Flemington; Rodric Williams; Jarnail A Singh
POL00192192
POL00192192
Subject: RE: For discusion [BD-4A.FID20472253]
Susan
I know that you are with Simon and Andy today so I have taken an initial look at this for you. I agree with you that I
would expect the advice to me more prescriptive ie you need to say this in response.
I do also have concerns from a civil point of view over a couple of statements in the draft response. In particular
where it states;
"He has done so both to POL and, in expert witness statements and oral evidence, to the court. In particular he has:
attested to the presence of defect detection and rectification systems; the robustness of the prosecution audit trail;
and stated that, in his expert opinion, Horizon accurately records and processes all information submitted into the
system. The Second Sight Interim report demonstrates that this was not the case."
I consider this to be unhelpful given that the SS report found there to be no systemic problems with Horizon.
It shows the need for all POL letters (criminal and civil) to contain a consistent message — so that the right hand and
the left hand know what they are each doing.
I am not a criminal lawyer but I would query whether the CCRC have the power to review a case where the SPM
entered a plea of guilty in the magistrates’ court.
I would be happy to suggest some criminal barristers to take a look at this for you
Perhaps you could discuss this with Simon and Andy today if you get the chance.
Kind regards
Gavin
Gavin Matthews
Partner
for and on behalf of Bond Dickinson LLP
Mobile: GRO
www.bonddickinson.com
From: Susan Crichton
Sent: 16 July 2013 13:58
To: Parsons, Andrew
POL00192192
POL00192192
Cc: Richardson, Simon; Matthews, Gavin; Hugh Flemington; Rodric Williams; Jarnail A Singh
Subject: For discusion
Andy — we received a letter from the CRCC yesterday which I have asked Cartwright King to review......their advice
feels odd to me as if given on a take it or leave it basis and I am not comfortable that’s particularly useful in this
context. Could we discuss, I am happy to go to another firm that specialises in Criminal law or a barrister, somehow
it feels as if there is a conflict here which I am not sure I understand.
Thanks
Susan Crichton I HR & Corporate Services Director
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