POL00329553
POL00329553
NZ = HERBERT
SMITH
ZI FREEHILLS
a
Herbert Smith Freehills LLP
Exchange House
Solicitor to the Inquiry Primrose Street
Post Office Horizon IT Inquiry London EC2A 2EG
5th Floor, Aldwych House
71-91 Aldwych
London, WC2B 4HN
www.herbertsmithfreehills.com
Our ref
9100/31043642
By email
Date
27 December 2023
Dear Solicitor to the Inquiry
Post Office Horizon IT Inquiry — Disclosure by POL: Phase 4 hearings and witnesses
We enclose a note prepared by Peters & Peters Solicitors LLP. This note refers to the Inquiry's letter
dated 14 December 2023 in relation to the Phase 4 hearings andwitnesses and relates to those
January witnesses dealing with prosecutions in the devolved jurisdictions and criminal case studies.
POL will update the Inquiry in respect of the other January witnesses to the extent that it becomes
necessary to do so.
Yours faithfully
Nerbut Sindh Priechille LLP
Herbert Smith Freehills LLP
Enc.
Herbert Smith Freehils LLP and its subsidiaries and Herbert Smith Freehills, an Australian Partnership, are separate member fms ofthe international legal practice
known as Herbert Smith Freeh
Herbert Smith Freehils LLP is a limited lability partnership registered in England and Wales with registered number OC310989.. It is authorised and regulated by the
Solicitors’ Regulation Authority of England and Wales, A list of the members and their professional qualifications is open to inspection atthe registered office,
Exchange House, Primrose Street, London EC2A 2EG. We use the word partner of Herbert Smith Freehills LLP to refer to a member of Herbert Smith Freehills LLP,
fr an employee or consultant with equivalent standing and qualifications.
11184618416_1 1
POL00329553
POL00329553
Post Office Horizon IT Inquiry
Note provided by Peters & Peters regarding disclosure by POL inrelation to Phase 4
hearings and witnesses
1. In its letter to HSF dated 14 December 2023 (the ‘Letter”), the Inquiry sought prompt disclosure
of any further documents in respect of Rule 9 requests, Section21 Notices or other documents.
of interest in order to ensure that the Inquiry's Phase 4 hearhgs can remain listed as scheduled,
if at all possible.
2. The Inquiry therefore sought disclosure of any additional documents by the following deadlines:
a. Any additional documents said to be in relation to Stephen Bradshaw by 4pm on 20
December 2023; and
b. For all other persons listed in Annex 1 to the Letter, no laer than 4pm on 10 January
2024.
3. This note is intended to provide an update on POL's progress with respect to meeting the
deadlines set out in the Inquiry’s Letter.
Stephen Bradshaw
4. On 19 December 2023, HSF wrote to the Inquiry enclosing a note prepared by Peters & Peters
explaining that the current exercise of reviewing and producing material relating to Stephen
Bradshaw had finished. However, there are two further mattersrelating to Stephen Bradshaw's
data that POL wishes to bring to the Inquiry’s attention.
Audio Tape Transcripts
5. Peters & Peters understands that POL's CIU team has identified a number of audio tape
recordings of interviews conducted by POL in connection with sub-postmaster investigations.
We understand that these audio tapes have been catalogued as pat of POL’s reindexing
exercise. Peters & Peters only became aware of these additiond tape recordings following
receipt of the results of that reindexing exercise. In light of the deadline to provide the Inquiry
with all relevant material in connection with Stephen Bradshaw,Peters & Peters has undertaken
an urgent review of the reindexed spreadsheets of the audio tapes to identify any cases in which
Stephen Bradshaw was the interviewing officer. Peters & Peters has identified three working
tapes that have not previously been provided to the Inquiry relating to Stephen Bradshaw's
interview of “Joan Francis Boiley”, which we assume is the case of Joan Bailey. POL is therefore
urgently working to locate these tapes and provide them to Petes & Peters in order that they
can be digitised and transcribed as soon as possible. The transcripts will be disclosed in
response to R9(14) Q42. POL will update the Inquiry as to the likely timing of that disclosure
when it can. POL notes, however, that the Inquiry already has Record of Taped Interview
summaries in relation to Joan Bailey, so POL expects that the broad substance of what is
contained in the transcripts of these three new audio tapes is likely already to be in the Inquiry's
possession.
6. Further work is also ongoing to establish whether any other material from these newly indexed
audio tapes falls to be disclosed to the Inquiry. POL will provide a further update on that work in
due course.
COPFS Disclosure Exercise
7. Material relating to Stephen Bradshaw is also being considered by Peters & Peters for a Crown
Office and Procurator Fiscal Service (“COPFS”) disclosure exercise owing to his involvement in
one of the Scottish cases (though not a case POL understands tobe under consideration by the
Inquiry, per the Inquiry's email of 19 December 2023). Since HSF's 19 December 2023 letter to
the Inquiry, the Peters & Peters COPFS team has begun some addtional checks to ensure that
all Stephen Bradshaw material has been caught. From the investgations into the MS Exchange
365 issues, potential additional email addresses and display nanes have been identified (for
example, a secure CJSM email address) and checks are underway to ensure that material has
already been captured.
11184618416_1 2
POL00329553
POL00329553
Irrelevant to disclosure hearing held 12 January 2024
Peters & Peters Solicitors LLP
27 December 2023
11184618416_1 3