WITNO0370200
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Witness Name: Calum Brian
Greenhow
Statement No.: WITN00370200
Dated: 6" November 2024
POST OFFICE HORIZON IT INQUIRY
SECOND WITNESS STATEMENT OF Calum Brian Greenhow
1, Calum Brian Greenhow, will say as follows...
1.
This witness statement is made to assist the Post Office Horizon IT Inquiry
(the “Inquiry”) and is given in order to provide updated information to the
Inquiry about an aspect of my oral evidence given on 26 September 2024 in
relation to questions about the NFSP’s efforts to meet with the Lord
Advocate and the Cabinet Secretary for Justice.
Prior to my oral evidence, I provided a witness statement (WITN00370100)
to the Inquiry. The NFSP provided a number of documents to the Inquiry to
accompany that witness statement, in particular in relation to the matter of
the correspondence with the First Minister, the Lord Advocate and the
Cabinet Secretary for Justice. The correspondence provided was the letter
from the NFSP to the First Minister and sent 16" January 2024
(WITN00370141) and to which the NFSP received a response from the Lord
Advocate on 11‘ March (WITN00370142). The NFSP also wrote to the
Cabinet Secretary for Justice by email on 19" April 2024 to request a
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meeting (WITN00370201). The NFSP provided the Inquiry with the letter it
received from Head of Criminal Justice at the Scottish Government dated
14" May 2024 (WITN00370140). This letter was sent to the NFSP on behalf
of both the Cabinet Secretary for Justice and the Lord Advocate. The letter
of 14'" May 2024 offered the prospect of meeting and asked that the NFSP
respond to the letter after which the Private Offices would be in touch to
arrange a meeting. The letter did not provide an email address to which the
response should be sent. I can now advise the Inquiry that the NFSP,
having received the letter of 14° May, subsequently sent three emails to the
generic email address from which we had received that letter, and from
which we had also received some of the earlier communications. Two of the
three emails were sent on 15" and 24'" May and made an offer regarding
attendees and dates for a meeting. A follow-up email was sent on 12” July.
We had not had a response to those emails by the date of my oral evidence
on 26" September. A meeting with the Lord Advocate and/or the Cabinet
Secretary had therefore not been arranged nor had one taken place by that
date.
. In the closing part of my oral evidence when I was being asked questions
by the representatives of the Core Participants, I was asked by Ms Christie
Allan of Livingstone Brown: “Can you please elaborate on your attempts to
meet with [the Scottish Justice Minister and the Lord Advocate]; when did
you first contact them, what was the format of your communication; and
have you been successful in receiving any kind of response?’ I replied,
“Well, we've received a response, which I think is within the core bundle
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and I can't remember the very specific details of it, but I think you'll have
been able to read that. But as far as, you know, trying to get to the Lord
Advocate and the Justice Minister of Scotland has proved difficult. I think
they've obfuscated that down the line.” (Transcript of Oral Evidence dated
26 September 2024, INQ000001 187 at pages 148 — 149).
. Following my oral testimony, there was a report within the Sunday Post
newspaper on 29 September 2024 part of which referred to the proposal of
a meeting between the Lord Advocate and the NFSP. Within the article
there was a statement which had been issued by the Lord Advocate’s office
which indicated that the NFSP had not responded to an offer of a meeting
made in a letter dated 14 May 2024. I was surprised by this as I knew the
NFSP had responded by email offering dates and attendees for such a
meeting.
. Asa result of all of this, we reviewed our correspondence regarding the
meeting with the Lord Advocate and Scottish Justice Minister. The letter
from the Head of Criminal Justice dated 14 May 2024 (WITN00370140)
was sent from a generic email address. The letter offered a joint meeting
with the Cabinet Secretary for Justice & Home Affairs and the Lord
Advocate, and asked us, “please respond to this letter and the Private
Offices will be in touch to identify a suitable date and time.” The letter did
not provide an alternative email address to respond to.
. The NFSP sent three emails to the generic email address from which we
had received this letter, seeking to arrange a meeting. These emails were
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sent on 15" May 2024, 24"" May 2024, and 12!" July 2024 (WITN00370202,
WITNO0370203, and WITN00370204 respectively). It has now transpired
that those emails to the generic email address from which we had received
the letter did not reach either the offices of the Lord Advocate or the
Cabinet Secretary for Justice and they were therefore not aware of them.
. In light of these matters, the NFSP sent a letter to the Lord Advocate and
Cabinet Secretary on 3 October 2024 (WITN00370205). We advised them
of the emails dated 15 May 2024, 24 May 2024, and 12 July 2024 and
confirming that, whilst we were unsure where these emails ultimately
reached, the NFSP would still wish to meet with them.
. The Lord Advocate responded on 21 October 2024, and I have provided
this letter to the Inquiry (WITN00370206). It is hoped a meeting can be
arranged in the near future.
. In light of the above, I therefore wish to provide this additional information
which directly relates to my answer to Ms Allan, in that it transpires that the
emails the NFSP sent in response to the letter from the Head of Criminal
Justice dated 14 May 2024 did not reach the offices of the Cabinet
Secretary or the Lord Advocate, who were therefore not aware that we had
responded. In turn, the NFSP were not aware about what had happened (or
not happened) to our emails. I am therefore content that the part of my
answer to Ms Allan where I said: “/ think they've obfuscated that down the
line” can be treated as withdrawn in light of the information now available to
me. I trust this additional information to clarify this particular situation is of
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assistance to the Inquiry.
Statement of Truth
I believe the content of this statement to be true.
Dated: 6!" November 2024
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Index to Second Witness Statement of Calum Brian Greenhow
WITNO00370200
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URN
Document
Description
Control Number
WITNO0370100
First Witness Statement
of Calum Greenhow
1TN00370100
WITNO0370141
Letter from the NFSP to
he First Minister dated
16 January 2024
1TNO0370141
WITNO0370142
Letter from the Lord
Advocate to the NFSP
dated 11 March 2024
ITN00370142
WITNO0370201
Letter from the NFSP to
he Cabinet Secretary for]
Justice dated 19th April
2024
ITN00370201
WITNO0370140
Letter from the Head of
Criminal Justice and PS
‘o the NFSP dated 14
May 2024
1TN00370140
INQ000001187
[Transcript of Oral
Evidence dated 26
‘September 2024
INQ000001 187
1TN00370202
Email from the NFSP to
case handling dated 15
May 2024
ITN00370202
ITN00370203
Email from the NFSP to
case handling dated 24
May 2024
ITN00370203
1TN00370204
Email from the NFSP to
case handling dated 12
July 2024
ITN00370204
10,
ITN00370205
Letter from the NFSP to
he Lord Advocate and
Cabinet Secretary dated
3 October 2024
ITN00370205
11
ITN00370206
Letter from the Lord
Advocate to the NFSP
(dated 21 October 2024
ITN00370206
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