POL00329560
POL00329560
NU,
NZ HERBERT
Fy PREEMILLS
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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
05 January 2024
Dear Solicitor to the Inquiry
Post Office Horizon IT Inquiry — Disclosure by POL in relation to Stephen Bradshaw
We enclose a note prepared by Peters & Peters Solicitors LLP ("Peters & Peters"). This note refers
to the Inquiry’s email of 27 December 2023 (sent at 4:19pm) and Peters & Peters’ notes dated 27
and 29 December 2023 and 3 and 4 January 2024 in relation to outstanding material relating to
Stephen Bradshaw.
Yours faithfully
Nebut Smith Pisechille LLP
Herbert Smith Freehills LLP
Enc.
Herbert Smith Freehills LLP and its subsidiaries and Herbert Smith Freehills, an Australian Partnership, are separate member firms ofthe international legal practice
known as Herbert Smith Frechils
Herbert Smith Freehills LLP isa limited labilty 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 ECZA 2EG. We use the word partner of Herbert Smith Freehills LLP to refer to a member of Herbert Smith Freehills LLP,
(or an employee or consultant with equivalent standing and qualifications.
11184736647_2 1
POL00329560
POL00329560
POST OFFICE HORIZON IT INQUIRY
Note provided by Peters & Peters regarding disclosure by POL in relation to Stephen
Bradshaw
1. Inits email dated 27 December 2023 (sent at 4:19pm), the Inquiry requested that all outstanding
material relating to Stephen Bradshaw be provided no later than 4:00pm on 29 December 2023.
2. In our notes dated 27 and 29 December 2023 and 3 and 4 January 2024, we informed the
Inquiry that additional checks were being undertaken in respect of Stephen Bradshaw's data
relating to potential additional email addresses and display names. Those additional checks
have now been completed and POL has identified 942 documents (including families) that fall
to be produced as a result of that review work. POL has today arranged for these documents
to be produced to the Inquiry via Egress, together with production index PRODO65. 49 of the
942 documents have been produced in image format in order to ensure that privileged family
documents were not produced to the Inquiry. The remainder of the documents in the production
have been produced in native format.
3. POL is endeavouring to do its utmost to identify duplicative material to the Inquiry. Of the 942
documents in this production, 420 have been identified by KPMG as being either MD5#
duplicates or 98-100% textual near duplicates (TNDs) of documents previously produced to the
Inquiry. However, Peters & Peters believes that a substantial number of the remaining 522
documents in the production also appear to be TNDs of documents previously produced to the
Inquiry. These include ROTIs and investigation reports from Rule 9(14) Q42 cases which have
been produced to the Inquiry on multiple occasions. KPMG is therefore investigating why those
documents have not been identified as part of its duplicates analysis.
4. Relevant information from KPMG's analysis to date is provided in the production index, which
shows whether a document has been identified as an MD5# or TND duplicate of material that
has previously been produced to the Inquiry. Any MD5# duplicates at a family level have been
excluded from the production. POL understands that KPMG has identified 318 documents in
the Bradshaw production as exact item level MD5# duplicates of previously produced
documents, 58 documents that are 100% TNDs of previously produced documents and 44
documents that are 98-99% TNDs of previously produced documents.
5. Of the documents in the production that are potentially “new” (as referred to in paragraph 3
above): 352 are responsive to Rule 9(14); 84 are responsive to Rule 9(17); 23 are responsive
to CLI 49 and/or have been tagged as “of interest to the Inquiry”; and a further 63 are responsive
to Rule 9(6), which POL assumes will be of lesser interest to the Inquiry.
6. POL apologises that it has been unable to identify fully all duplicates in time for this production.
With KPMG's assistance, POL is endeavouring to provide an updated analysis of duplicates to
the Inquiry as soon as possible.
Peters & Peters Solicitors LLP
5 January 2024
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