POL00329554
POL00329554
NZ Ze. HERBERT
=> SMITH
INS FREEHILLS
Herbert Smith Freehills LLP
Exchange House
Solicitor to the Inquiry Primrose Street
Post Office Horizon IT Inquiry
5th Floor, Aldwych House
71-91 Aldwych
London, WC2B 4HN
www.herbertsmithfreehills.com
Our ref
9100/31043642
By email
Date
29 December 2023
Dear Solicitor to the Inquiry
Post Office Horizon IT Inquiry — Disclosure of documents relating to Stephen Bradshaw
We refer to:
a. the email received from the Inquiry on 27 December 2023 at proximately 16:19 which
requested the production of all outstanding material in relation to Mr Stephen Bradshaw
by no later than 4 pm on Friday, 29 December 2023;
b. our letters to the Inquiry dated 19 and 27 December, both of which enclosed notes
prepared by Peters & Peters Solicitors LLP in relation to the Phase 4 hearings and
witnesse:
the Inquiry's letter dated 14 December 2023 in relation to the same topic; and
d. our letters to the Inquiry dated 20 October and 22 November2023 in relation to ongoing
document review and disclosure exercises.
Review exercises being conducted by this firm
2.
POL is conducting ongoing disclosure related exercises, as dscussed in the correspondence
referenced above. In this section of this letter we address ony current review exercises which
are being conducted by this firm for POL (i.e., not any disclosure related exercises which
have not been commenced nor any reviews that are being conducted by other firms).
Searches have been conducted across all ongoing review exerdses to locate documents
which refer to Mr Bradshaw, and/or which were sent to or received by Mr Bradshaw. For the
avoidance of any uncertainty, we confirm the searches were not limited to reviews that
specifically relate to Mr Bradshaw. To the contrary, a number of the reviews do not relate
directly to Phase 4 hearings and/or any other witnesses who arescheduled to give evidence
in the January hearings. Based on these searches, KPMG have identified 21 documents
which refer to Mr Bradshaw, copies of which are enclosed with this letter.
Of the 21 documents identified as relating to Mr Bradshaw, ve note that the tranche includes
organisational charts, lists of contact details, case summaries, spreadsheets, and pleadings.
None of the documents appear to be communications exchanged between Mr Bradshaw and
others.
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.
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Due to various pre-production checks and other steps that ar required prior to upload to
Egress, a formal production onto Egress will not be possible urtil the week starting 2 January
2024. In the circumstances, POL is today informally producing he 21 documents identified
as relating to Mr Bradshaw by providing a zip file of the docurrents in native format enclosed
within this letter. POL will produce these documents to the Inquiry formally as soon as
possible.
There may be technical duplicates within the documents being informally produced today.
So that the Inquiry can readily identify technical duplicates, the informal production contains
a list of documents together with MD5 values.
As ever, it is possible that documents relating to Mr Bradshaw may be identified through
other review exercises, including reviews which have not yet been commenced.
Review exercises being conducted by Peters & Peters
8.
Peters & Peters are assisting POL with its disclosure in refttion to the Criminal Case Studies
module of Phase 4 of the Inquiry (amongst other matters). A note prepared by Peters &
Peters Solicitors LLP is enclosed.
Please do not hesitate to contact us if you have any queriesor wish to discuss.
Yours faithfully
Nubut- Smith Fisrhille LLP
Herbert Smith Freehills LLP
Enc.
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Post Office Horizon IT Inquiry
Note provided by Peters & Peters regarding disclosure by POL inrelation to Phase 4
hearings and witnesses
1. In its email dated 27 December 2023 (sent at 4:19pm), the Inquiry requested that all
outstanding material relating to Stephen Bradshaw to be providd no later than 4:00pm on
29 December 2023. POL regrets that it is not possible to make aformal production of all
outstanding material by that time.
2. The three audio tapes relating to Stephen Bradshaw's intervew of “Joan Francis Boiley”
(which it is assumed relate to the case of Joan Bailey) were sent by courier to a third-party
company for digitisation on 27 December 2023. The digitisation process was completed on
28 December 2023 in the afternoon and the audio files are currently being transcribed.
3. POL will arrange for the informal production of the transcribed files as soon as they are
completed. However, it will not be possible to make a formal production of that material until
the week beginning 2 January 2024.
4. In the circumstances POL anticipates it being possible to produce the three transcripts
informally, by email, on Friday 29 December 2023.
5. In respect of the additional checks for Stephen Bradshaw, rdating to potential additional
email addresses and display names, it has not been possible tomake progress since the
update provided on Wednesday 27 December 2023. That is because of the time needed to
migrate data to the CCRC workspace maintained by KPMG on POL's behalf. It is currently
estimated that the data will be available for review by the end of Friday 29 December 2023
(although that may be after working hours). Peters & Peters have a review team in place,
and, following the application of search terms, will start to review the material as it arrives on
the CCRC workspace. Should there be any new material identified of relevance to the
Inquiry, POL anticipates producing it as soon as possible in the week beginning 2 January
2024.
6. POL apologises that it is unable to meet the deadline set bythe Inquiry in respect of Stephen
Bradshaw.
Peters & Peters Solicitors LLP
29 December 2023
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