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From: Jarnail Singh[/O=MMS/OU=EXCHANGE ADMINISTRATIVE GROUP
(FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=JARNAIL.A.SINGH6CEADABD-67E9-4ECA-94F2-
005716658847]
Sent: Tue 17/06/2014 11:24:33 AM (UTC)
To:
Cc:
Subject:
Andy
1am happy with the proposed approach and its sensible in the circumstances, I would suggest that issues continued to
be dealt with on case by case basis.
Jarnail Singh I Criminal Lawyer
@ 148 Old Street, LONDON, EC1V 9HQ
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From: Parsons, Andrew [i
Sent: 17 June 2014 11:
To: Chris Aujard; Rodric Williams; Jarnail Singh; Angela Van-Den-Bogerd; Belinda Crowe; David Oliver1; Kathryn
Alexander; Shirley Hailstones
Cc: Simon.Clarké~~ “imartin.smith€
Subject: Helen Ro: [BD-4A.FID204
_k; Matthews, Gavin
All
I've just spoken with CK about a new CQR from Howe & Co that references the Helen Rose report.
You'll recall that the HR Report was retrospectively disclosed in a number of prosecution cases as it drew into question
some of the statements made by POL's expert witness, Gareth Jenkins. A copy of the HR Report has made its way to
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Howe who are now referencing it generally in their CQRs. For example, the CQR on M060 refers to the HR report
however the HR report was not sent to this Applicant.
The point of concern is that the M060 CQR is starting to make the link between (1) the fact that the HR report makes
clear that GJ knew of issues with Horizon and (2) the fact that GJ never mentioned these issues in his prosecution
evidence (see para 53 in the attached). This line of enquiry draws into question the credibility of GJ's evidence.
The sharing of the HR report between Applicants is potentially a breach of solicitors ethics / contempt of court.
However, CK and I don’t believe attacking the solicitors on this point would be of benefit — if anything it may draw
more attention to the HR Report.
Instead, our preferred approach is to try to down play the importance of the HR report in any POL Investigation
Reports. We recommend minimalizing or ignoring entirely the HR Report when responding to CQRs.
If the investigation team need guidance on how to address any HR Report related questions, I suggest that they (or the
lawyer here at BD) addresses these directly with CK on a case by case basis.
Please let me know if you are happy with this proposed approach? Martin, Simon and I are available if you have any
questions.
Kind regards
Andy
Andrew Parsons
Senior Associate
for and on behalf of Bond Dickinson LLP
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