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Witness Name: Simon Recaldin
Statement No: WITN09890400
Dated: 15 May 2024
POST OFFICE HORIZON IT INQUIRY
FOURTH WITNESS STATEMENT
OF SIMON RECALDIN
I, Simon Recaldin, of 100 Wood Street, London say as follows:
Introduction
1 Except where I indicate to the contrary, the facts and matters contained in this
witness statement are within my own knowledge. Where any information is not
within my personal knowledge, I have identified the source of that information
or the basis for my belief. In particular, the content of this statement is
substantially informed by the enquires and disclosure review of Burges Salmon
LLP and their contractor Fieldfisher LLP (together "BSFf"), who are instructed
by Post Office Limited ("POL") and who represent POL in the Inquiry. The facts
in this witness statement are true to the best of my knowledge and belief.
2 I have provided three previous witness statements to the Inquiry. I continue to
be employed by POL as Remediation Unit Director, leading the business unit
which POL established to administer its redress schemes. This is now known
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as the Remediation Unit (or ‘RU’) but was previously known as the Historical
Matters Unit (sometimes also referred to as the Historical Matters Business Unit
or ‘HMU’).
3 This witness statement has been prepared in response to paragraph 3(c) of
Annex A to the Notice given by the Inquiry on 9 October 2023 pursuant to
Section 21 of the Inquiries Act 2005 ("Notice No.8"). Notice No.8 was amended
by the Inquiry’s letter of 23 October 2023. Its terms were amended so that
references to a “Convicted SPM” were replaced with references to a Potential
Future Appellant “PFA”, meaning an appellant or potential future appellant as
defined in paragraph 15 to 16 of my first witness statement to this Inquiry. The
Inquiry also amended the time for compliance with Notice No.8 so that all limbs
of that notice were required to be complied with by 4pm on 15 November 2023".
4 This witness statement briefly sets of the scope of Notice No.8, the scope of
enquiries undertaken to comply with it, the resulting document review, the
results of that review and the information sought at paragraphs 3(a) and (b) of
Annex A of the Notice.
Notice No.8
5 Paraphrasing and adopting the same defined (capitalised) terms of Notice No.8,
it required that POL provide (or if already provided identify):
1 This was via its letter of 23 October 2023 extending the deadline to 13 November
2023, and email of 09 November 2023 extending the deadline by a further 48 hours.
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(a) Any Relevant Documents or Redacted Relevant Documents sent by
POL? to a PFA, pursuant to POL’s duty of post-conviction disclosure,
between 1 January 2000 and 16 December 2019.
(b) Any correspondence’ sent by POL, to a PFA or their agents, with or
further to the disclosure of such Relevant Documents or Redacted
Relevant Documents that provided details of: (i) the nature or content of
the disclosure; (ii) the reason for the disclosure; (iii) the timing of the
disclosure; or (iv) the existence of or reason for any redactions.
(c) A statement with a schedule setting out, for each Relevant Document
and Redacted Relevant Document, and for each piece of
correspondence, to which PFA it was sent and on what date.
The scope of enquiries undertaken
6 The scope of the post-conviction duty applies to any material affecting the safety
of aconviction of a PFA. There are known to be some 700 PFAs and the scope
of Notice No.8 applies to a period just short of 20 years.
rd To respond to Notice No.8 POL (internally and through BSFf) has undertaken
enquires of relevant personnel and organisations to establish whether any such
2 In 6(a) and 6(b) the references to POL should be read as including any of its
predecessor organisations or parent companies, or its agents.
3 Paragraph 4 provided that where there are multiple identical (save for addressee and
date) or materially similar letters, POL is only required to produce one version of that
letter.
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post-conviction disclosure exercises or instances had taken place, and then
conducted targeted searches in response to the exercises and/or instances
identified.
8 Enquiries were made of:
(a) Peters & Peters ("P&P") and Simon Baker KC, who as explained in my
first witness statement to the Inquiry were instructed by POL to conduct
the post-conviction disclosure exercise (or ‘PCDE’) following the Horizon
Issues judgment’, and who have acted for POL during the Inquiry;
(b) Herbert Smith Freehills (“HSF”) as the former recognised legal
representative of POL in previous phases of the Inquiry;
(c) The firm which now trades as Cartwright King solicitors (‘Current CK”).
Cartwright King was instructed by POL in relation to a large number of
prosecutions during the period covered by the scope of Notice No.8;
(d) I Andy Cash, formerly of Cartwright King who has been assisting P&P with
its enquiries in relation to Cartwright King’s work for POL; and
4 Bates & Others v Post Office Limited [2019] EWHC 3408 (QB) which was handed
down on 16 December 2019.
5 Cartwright King Ltd went into Administration in 2022 and the entity which now trades
as Cartwright King is a phoenix company. To reflect this I refer to the entity which now
trades as Cartwright King as ‘Current CK’ in distinction to the original entity which I
refer to as ‘Cartwright King’.
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(e) — Simon Clarke, formerly of Cartwright King, who had deep involvement in
Cartwright King’s work for POL for a large part of the period covered by
Notice No.8.
9 In addition, enquiry has been made of relevant individuals/repositories of data
within POL.
Summary outcome of enquiries
10 As a result of these enquiries POL can confirm that one post-conviction
disclosure exercise was undertaken during the relevant period. This exercise
was conducted by Cartwright King in two phases between 2013 and 2015 and
is known as the Cartwright King Sift Review (the “CK Sift’).
11 The scope, process and outcomes of the CK Sift are described in the following
contemporaneous documents:
(a) A Cartwright King document titled “Observations and analysis of the
Cartwright King Prosecution Review Process” dated 5 December 2013°
(the “2013 CK Observations”);
(b) I Adocument titled ‘General Review’ dated 15 October 2013’ produced by
Brian Altman QC®; and,
® POL00040194.
7 POL00040042.
8 As he then was.
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(c) An update to the 2013 CK Observations document also titled
“Observations and analysis of the Cartwright King Prosecution Review
Process” dated 19 September 2014 (“2014 CK Observations’)’.
12 In addition to these documents, Simon Clarke prepared a document titled “The
Sift Review -— an Explanation” dated 15 July 20191 Whilst not
contemporaneous to the CK Sift being conducted, this document is, I believe,
useful in establishing that no similar review exercise was conducted after the
CK Sift concluded in late 2014. I am informed by BSFf that Mr Clarke has
confirmed that this is correct.
13 Having identified the CK Sift, I am informed that BSFf sought to identify both:
(a) whether any post-conviction disclosure exercises or instances were
known to have been undertaken other than the CK Sift; and,
(b) where documents relating to the CK Sift and any post-conviction
disclosure instances would now be located.
14 None of the parties of whom enquiries were made were, to the best of their
knowledge and belief, aware of any post-conviction disclosure review or
exercise other than the CK Sift. Supporting this position, BSFf did not identify
® POL00169034: “Observations and analysis of the Cartwright King Prosecution
Review Process” dated 5 December 2013.
10 POL00169024: “The Sift Review — An Explanation”.
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any other post-conviction disclosure exercises or instances during the course of
its review of relevant documents/document repositories.
15 In relation to the location of documents:
(a) _ it was identified that all of Cartwright King’s electronic and hardcopy files
relating to instructions by Royal Mail Group (‘RMG’) and POL, insofar as
still retained by Cartwright King at the date of request, had been
requested by one or other of HSF and P&P during the Inquiry such that
all of those files now exist in POL’s Relativity Platform (the “CK Files’).
This includes:
(i) two very large single pdf extractions of what Current CK believed
to be the electronic client matter files for the each phase of the CK
Sift (the “CK Sift Files”); and
(ii) either hardcopy or electronic files for some of those individuals in
whose cases post-conviction disclosure had been advised by
Cartwright King (the “CK’s Individual Files”), although BSFf and
POL were not able to locate files for all such individuals.
(b) Further hardcopy files labelled with the names of some individuals where
post-conviction disclosure had been advised by Cartwright King were
also held by POL’s hardcopy archive provider Oasis (the “POL Individual
Files”).
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The CK Sift
16 As summarised in the 2013 CK Observations document and its subsequent
update:
(a) _ the CK Sift involved 533 cases, within which 83 cases were subjected to
a ‘full review’;
(b) the CK Sift was conducted on the premise that, if post-conviction
disclosure was to be provided, the documents that would be disclosed
were the Second Sight Interim Report and potentially also the Helen
Rose Report;
(c) disclosure of the Second Sight Interim Report was advised in 36 cases";
(d) in a subset of 12 of those 36 cases" it was also advised that the Helen
Rose Report should be disclosed’; and
‘1 The 2013 and 2014 CK Observations documents report that disclosure was advised
in 36 cases. However, for the reasons explained below there is some uncertainty as
to exactly how that figure is derived.
12 The 12 cases shown in Appendix 1: Allen, Boyle, D'Arcy, Dixon, Hirani, Hutchings,
Ishaq, Robinson, Sefton, Neild, Threlfall and McQue, all of which were ‘first phase’
cases save for McQue.
13 For an example of a case in which disclosure of the Second Sight Interim Report
and Helen Rose Report were advised, and were disclosed in correspondence, see
document POL00040055 / POL00029112 / POLO0029128 / POL00091391 which is
a signed version of the post conviction disclosure letter from Cartwright King to the
solicitors of record for Susan Knight and which encloses copies of both reports. The
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(e) in one case it appears that disclosure of materials relating to the
Callendar Square bug (also called the Falkirk bug) was advised.
17 In seeking to identify all cases in which post-conviction disclosure was provided
to a PFA, BSFf undertook a manual document-by-document review of both CK
Sift Files. In doing so, it identified what appeared to be 36 cases in which
disclosure was advised by Cartwright King during the CK Sift, of which 26 were
advised in the first phase of the review, and the further 10 cases during the
second phase.
18 In the case of each individual listed in the CK Sift Files as being a person in
whose case post-conviction disclosure was advised BSFf looked at the list of all
CK Files and POL Individual Files identified and undertook a full manual review
of each of those files.
19 BSFf also reviewed the POL mailboxes" of the following members of POL’s
legal team: Susan Crichton, Chris Aujard, Jarnail Singh and Rodric Williams.
This is because BSFf had identified during the document reviews summarised
above that correspondence on the CK Sift Files concerning the outcomes of
Helen Rose Report was redacted to remove the name of the author and of the
postmaster involved.
14 For the avoidance of doubt, mailboxes here means both the emails stored in
Mimecast and in Exchange, save in the case of Jarnail Singh where, at the time of
review, Mimecast emails had been extracted but not Exchange data. Based on the
material found on Mimecast, a review of Exchange data once available is not
expected to identify further relevant material.
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these file reviews was primarily between Cartwright King and Jarnail Singh, but
often also copying one or more of Susan Crichton, Chris Aujard, and Rodric
Williams.
20 As a ‘sweeper search’ BSFf then undertook a further review of all documents
within the CK Files (excluding the CK Sift Files and CK Individual Files which
had been reviewed manually) applying the keywords at Appendix 2, and
reviewing responsive documents.
Post Conviction Disclosures to PFAs as a result of the CK Sift
21 Before explaining the outcome of the CK Sift, it is useful to explain that when
counting the number of instances for disclosure there is a distinction to be made
between:
(a) the number of cases and the number of individuals (because some cases
involved co-Defendants); and
(b) instances in which disclosure was advised and instance in which it was
given (because there was one case in which disclosure was advised but
not given).
First Phase
22 There are 16 cases, concerning 17 individuals'®, in which post-conviction
disclosure was provided (being the first 17 listed individuals in Appendix 1).
15 Angela Sefton and Ann Neild were co-Defendants, treated as a single case (see for
example the Full Review Case Note / Opinion at POL00168974) but each individual
received separate post-conviction disclosures (see Appendix 1).
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23 Although not requested by the terms of the Notice No.8, because they are not
cases of post-conviction disclosure, I am informed by BSFf that there are 9
cases concerning 12 individuals where disclosure was advised as follows:
(a) five further cases (involving five individuals) in which it appears from
contemporaneous documents that disclosure of the Second Sight Report
was advised and provided during an ongoing prosecution, and that in
each case those prosecutions were then either discontinued or the
prosecution offered no evidence and a not guilty verdict was therefore
entered’®.
(b) one case (involving one individual) in which disclosure was advised but
the case was discontinued before disclosure was given’’;
(c) three cases (involving six individuals) which were, at the time, at a pre-
trial stage, in which POL was not the prosecuting entity, this being either
the Crown Prosecution Service (CPS) or Procurator Fiscal, and in which
1® These cases concerned Rita Threlfall, Susan Knight, Nicola Grech, Danielle King
and Balvinder Kaur Samra. For completeness, I understand from BSFf that voluntarily
disclosure has been included within the documents produced in response to Notice
No.8 which evidence both the advice given by Cartwright King concerning disclosure
of the Second Sight Interim Report and Helen Rose Report in these cases, and the
letters or attendance notes of oral disclosures made in these cases.
17 In the case of George Thomas Brown disclosure of the Second Sight Interim Report
and Helen Rose Report was advised (see POL00168896) but did not occur in light of
the decision to discontinue that case (see POL00168901 and POL00169054).
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POL made the disclosure to the CPS or Procurator Fiscal for the relevant
prosecuting body to make disclosure to the PFA or their legal adviser'®.
24 We note this appears to be confirmed by paragraphs 31 and 32 of the 2013 CK
Observations document which states:
“There are a number of cases which have been prosecuted by the Crown
Prosecution Service. ...we have ensured that the Crown prosecution
Service Branches are aware of the issues with which the review process
is concerned and have disclosed to them copies of the Second Sight
Interim Report and the Helen Rose Report.”
25 The above gives rise to some uncertainty as to how Cartwright King came to
summarise the number of disclosures advised as being “26”, as it appears that
disclosure was advised in respect of 29 individuals in 25 cases, and disclosure
was then given to 28 individuals in 24 cases"?.
18 These cases concerned individuals called: (1) Gould, Townley, Renshaw &
Renshaw, (2) Rerrie and (3) Ali. For completeness, I understand from BSFf that
voluntarily disclosure has been included within the documents produced in response
to Notice No.8 which evidence the disclosure of information from POL to the CPS and
Procurator Fiscal respectively in these cases. Further I understand from BSFf that it
is understood that Renshaw & Renshaw may be treated as a single case (being the
same family) which is why this is reported as a total of 26 cases in which disclosure
was advised, rather than 27. See in particular CK’s internal summary at
POL00169021 which lists these three cases and six individuals, and provides details
of the ways in which disclosure was provided.
19 Per paragraphs 23 and 24 above:
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Second Phase
26 ‘The 10 cases in which disclosure was advised by Cartwright King during the
second phase are those 10 individuals listed as such in Appendix 1. However,
despite the searches described above, POL (and BSFf) has been unable to
locate a letter or other evidence of any post-conviction disclosure being
provided to Jerry Kwame Hosi (one of the PFA’s) although BSFf have identified
the opinion document produced by Cartwright King in which it was advised
disclosure should be given”°.
oF During the manual review of the CK Sift Files and the wider review described
below, BSFf did not identify any cases other than those listed in Appendix 1 in
which it appeared post-conviction disclosure had been given, nor to the best of
my knowledge and belief is POL aware of any such further cases.
Letters to PFAs or their legal advisers
28 lam informed by BSFf that:
(i) 16 + 5 + 1 + 3 = 25 cases in which disclosure was advised, within which
disclosure was given in 24 cases.
(ii) 17 +5 + 1 + 6 = 29 individuals in respect of whom disclosure was advised, within
which disclosure was given to 28.
20 In particular, it was advised that disclosure should be given not only of the Second
Sight Interim Report and Helen Rose Report but also materials relating the Callendar
Square bug.
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(a) The letter that went from Cartwright King to a PFA or their legal adviser
was materially the same letter in all instances, tailored to the post-
conviction disclosure provided in that instance;
(b) Save for the case of Jerry Kwame Hosi referred to above, BSFf have
been able to locate unsigned letters to a PFA or their legal adviser
providing post-conviction disclosure in all cases;
(c) It was not the practice of Cartwright King to retain copies of signed letters
to PFAs or their legal advisers as proof that such disclosure had been
provided. Rather, BSFf inform me that the Cartwright King practice was
that an unsigned copy of a letter to a PFA or his or her legal adviser would
stand as the ‘office copy’ record of the letter that was sent. I am informed
Cartwright King sought to operate a paperless office and that this
approach was part of that practice;
(d) I Cartwright King produced two schedules to record progress of the CK
Sift, the relevant extracts of which have been disclosed as POL00169054
(First Phase CK Sift) and POL00169055 (Second Phase CK Sift). In most
cases?! these record: (i) its advice as to whether or not post-conviction
disclosure should be provided and, if so, what the disclosure should be;
and (ii) whether or not the disclosure was provided. Accordingly, in those
21 Both schedules are incomplete in some respects.
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cases where the schedules are complete, they serve as a useful way of
checking whether post-conviction disclosure was in fact provided.
(e) In 3 cases BSFf has located a signed letter to a PFA or their legal adviser.
It appears that POL holds these signed copies only as a result of the
relevant legal advisers to those PFAs providing them to POL as
enclosures to correspondence flowing from POL’s post-conviction
disclosure.
29 In all the circumstances there are therefore reasonable grounds for POL to be
confident that post-conviction disclosure was provided as described above, to
the 29 individuals listed in Appendix 1 of this statement. As I have noted above,
although the CK Sift resulted in disclosures being made in 36 cases, the
remaining seven cases were pre-trial disclosures.
Information sought by Notice No.8
30 lam advised by BSFf that the tables in Appendix 1 below contain all information
POL has been able to obtain responsive to the requests at paragraphs 3(a) and
3(b) of Annex A to the Notice.
Statement of truth
I believe the content of this statement to be true.
Signed:
Dated: 15 May 2024
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Appendix 1
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The 17 Cases from the First Phase of the Cartwright King Review
Name of PFA
Khayyam
Ishaq
Jamie
Dixon
Grant (lan)
Allen
Hitesh
Hirani
Angela
(Mary)
Sefton
Ann Neild
Document
Reference
POL00132862
POL00060711
POL00066786
POL00157189
POL00168971
POL00089682
POL00168973
POL00066798
POL00066799
Document Name of
Description PFA’s
Solicitors
Unsigned Draft Musa Patels
Letter enclosing Solicitors
the Helen Rose
Report (HRR)
and Second
Sight Interim
Report (SSIR) aun
Substantively Harding &
identical to Rowe
Susan Knight
22
letter??. Linda
Enclosures not Pennington
actually attached Maidments
but inferred to _—_ Solicitors Ltd
have been
attached as they Davies &
were in the case Jones
of the Susan Solicitors
Knight letter
above. Hogan
Brown
Solicitors
Lawrence
Lee & Co
Solicitors
Date of Letter
and Reference
12" July 2013
Ref number:
MS2/24676
17% July 2013
Ref Number:
MS2/37142
25% July 2013
Ref number:
MS2/37142
12'" July 2013
Ref number:
MS2/37142
24" July 2013
Ref number:
MS2/37142
25" July 2013
Ref number:
MS2/37142
22 The Susan Knight version of this letter is a signed version and includes the
enclosures for both the Helen Rose Report (HRR) and Second Sight Interim Report
(SSIR) - POL00040055 / POL00029112 / POL00029128 / POL00091391.
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ts
8.
9.
10.
Lynette
Hutchings
Deborah
D’Arcy
Robert
John Boyle
Della
Robinson
11.
Jahira
Begum
POLO0060945
POL00066843
POL00066834
POL00168972
POL00169005
POL00169011
POL00169019
Messrs.
Coomber
Rich
Only content Teign
which differs Advocates,
from the above 123 Queen
letters are the Street,
details of the Newton
PFA’s solicitor, I Abbot,
letter date, and TQ122BN
reference
number (each Broadbents
shown right). Solicitors
Opas House
However, the DX 24814
introductory Sutton-in-
paren Ashfield
summarising the
PFA's offence
and associated NESSES.
sentence is David
unique in each Phillips and
letter. The Partners, DX
located 13017
(unsigned) Birmingham
copies of these
letters are
disclosed to the
Inquiry therefore.
The content of Messrs.
these letters is Pattichi, Hill
substantively the & Croques
same as those
above save for:
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LML.BW.JW.N
El
8" October
2013
Ref:
MS2/22796
12" July 2013
Ref number:
MS2/37142
30" August
2013.
Ref:
MS2/24676/LP
1
8" October
2013.
Ref:
MS2/25271
13! December
2013
Ref:
MS2/22796
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[i] the details of Ref:
details of the 28/07/10/130
PFA’s solicitor,
12. POL00169020 etter date, and Messrs. 20'" December
Allen John reference Canter Levin 2013.
Reynolds number (each & Berg
shown right).
Ref: MS2/
[ii] The 22796.
introductory Ref: PM/VL
paragraph
ia POL00169017 SUMmarising the essrs. 13" December
Rajesh PFA offence aidments 2013
Lakhanpaul and associated
sentence is
unique in each
letter. Ref:
MS2/37142
a NK/RD/LAKOOO
[iii] In these 4/0001
cases only the
14. PoLooteso1g Sout WAS = Cohen 13!" December
Mohammed notthe HRRor Cramer 2013
Naveed any other
Anwar document.
Ref Nos:
The located MS2/37142
(CNH NES)) CY JSG/180811/30
of these letters 2
are disclosed
15. Potootesses therefore tothe Tudor Qwen 13! December
Damian Inquity, Roberts 2013
Peter Owen In Mr Hussain’s Gynne & Co
case there is
also a follow-up Ref Nos:
letter MS2/37142
(POMEL) BW/LH/10821
in which the only
16. POLO0168866 Substantive B.H. 13! December
Neelam paragraph isa = Mohammed 2013
Shanez confirmation from
Hussain CK that “Our Ref Nos:
Client has MS2/37142
confirmed that NI/181010/009
the West
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dif
Kangasund
aram Prince
POL00168881
Bromwich Post
Office was
unaffected by the
two defects
referred to in the
Second Sight
Interim Report
previously
disclosed to
you.
Final signed My Brief
letter located and Solicitors
is the same for
as 13 to 18
above.
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13'" December
2013
Ref Nos:
MS2/37142
JJB/MB/PRINCE
The 10 Cases from the Second Phase of the Cartwright King Review
Name
1. Katherine
McQue
Ref
POL00169051
Name of
Solicitors
Summary
Substantially
identical to cases
1 to 8 above (i.e.
disclosing both
the SSIR and
HRR). The only
content which
differs from the
above letters are
the details of the
PFA‘s solicitor,
letter date, and
reference
number (each
shown right).
Lewis Rogers
However, the
introductory
paragraph
summarising the
PFA’s offence
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Date of
Disclosure (per
the /etter)
25 September
2014
Ref No:
MS2/44948
2. Jerry N/A
Kwame
Hosi
3. Daljit Singh POL00169044
Benning
4. Angela POL00169045
Jane
Hodgson
5. Jacqueline POL00169049
McDonald
and associated
sentence is
unique in each
letter. The
located
(unsigned)
copies of these
letters are
disclosed to the
Inquiry therefore.
As at the date of Erica Peat &
this BSFf Diable / Peat
statement Diable
neither BSFf nor
POL has been
able to locate a
copy of the post
conviction
disclosure letter
provided to Mr
Hosi. What has
been located is
an opinion by
Cartwright King,
advising POL
that Mr Hosi
should receive
post conviction
disclosure of the
SSIR, HRR and
materials relating
to the Falkirk /
Solicitors.
Callendar
Square bug.
The content of I Thomson,
these lettersis Webb &
substantively the Corfield
same as those
above save for: Michael J
Fisher & Co
[i] the details of
details of the
PFA‘s solicitor, I Marsden
letter date, and Rawsthorn
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Unknown
25 September
2014
Ref: MS2/44948
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Appendix 2 - Keyword Search terms
[First CK Sift Case Names and their Solicitors]
1. Khay*am w/3 Ishaq OR Musa w/2 Patel*
2. Rita w/3 Threlfall OR Lawrence w/2 Lee
3. Jamie w/3 Dixon OR Brewer w/2 Harding
4. Susan w/3 Knight OR Howell w/2 Hylton
5. Deborah w/3 D*Arcy OR Teign w/2 Advocates
6. Grant w/3 Allen OR Linda w/2 Pennington
7. Hitesh w/3 Hirani OR Davies w/2 Jones w/5 solicitors
8. Angela w/3 Sefton OR Hogan w/2 Brown
9. Ann w/3 Nield OR Lawrence w/2 Lee w/5 solicitors
10. Robert w/3 Boyle OR Broadbents
11.Della w/3 Robinson OR David w/2 Phillips w/50 Robinson
12. Lynette w/3 Hutchings OR Coomber w/2 Rich
13.Jahira w/3 Begum OR Pattichi w/2 Hill
14. Allen w/3 Reynolds OR Canter w/2 Levin
15.Kang* w/3 Prince
16.Rajesh w/3 Lakhanpaul OR Maidments
17.Mohammed w/3 Anwar = OR Cohen Cramer
18.Damian w/3 Owen OR (Tudor w/2 Owen) OR (Roberts w/2 Gynne)
19.Neelam w/2 Hussain OR “B. H. Mohammed” OR “B*H*Mohammed”
Page 22 of 28
WITNO9890400
WITN09890400
WITNO09890400
[Second CK Sift Case Names and their Solicitors]
1.
2.
8.
9.
Daljit w/3 Benning OR Thomson w/2 Webb w/2 Corfield
Angela w/3 Hodgson OR Michael W/2 Fisher
Katherine w/3 McQue OR Lewis w/2 Rogers
Jacqueline w/3 McDonald OR Marsden w/2 Rawsthorn
Jerry w/3 Hosi OR (Erica w/2 Peat) OR (Peat w/3 Diable)
Siobhan w/3 Sayer OR Dawbarns
Rabina w/3 Shaheen OR Coomber w/2 Rich
Senapathy w/3 Narenthiran OR (Raja w/2 company) OR (Raja w/2 co)
Peter w/3 Huxham OR Nunn w/2 Rickard
10. Alison w/3 Henderson OR Belmores
[CK Sift Case Names where POL was not prosecutor and with uncertain
outcomes]
1.
2.
3.
(Gould OR Townley OR Renshaw OR Renshaw) AND (CPS OR “South Wales”
OR “Second Sight Interim”)
(Rerrie) AND (CPS OR Hirst OR Newcastle)
(Ali) AND (“KC13001814” OR “Tracy Plant” OR “Tracey Plant” OR
Dunfermline)
[Generic Phases appearing in disclosure letters]
1.
“We have thorougly reviewed” OR “We have thoroughly reviewed both the
prosecution case” OR “We would also remind you of your duty not to disclose
this material”?
23 There is a deliberate misspelling of “thorougly” (without an “h”) as it was only
corrected to “thoroughly” in some of the later disclosure letters.
Page 23 of 28
WITNO9890400
WITN09890400
WITNO09890400
Index to Fourth Witness Statement of Simon Recaldin
No
URN
Description
Control no.
POL00040194
Observations and analysis of the Cartwright
King Prosecution Review Process
POL-0036676
POL00040042
Post Office Ltd, General Review
POL-0036524
POL00169034
The Cartwright King Review re Post Office Ltd
and the Royal Mail Group Ltd: Observations and
Analysis of the Cartwright King Prosecution
Review Process relating to duties of disclosure
in Criminal Prosecutions
POL-BSFF-
0132625
POL00169024
The Sift Review — An Explanation by Simon
Clarke — 15th July 2019
POL-BSFF-
0132615
POL00040055
Email from Martin Smith to Hylton Howell RE:
Susan Knight (and attachments)
POL-0036537
POL00029112
Bundle of Documents containing: Email from
Martin Smith to Howell Hylton, re: Susan Knight;
Letter from Cartwright King Solicitors to Howell
Hylton Solicitors, re: Susan Knight; Interim
Report into alleged problems with Horizon
System.
POL-0025594
POL00029128
Email from Martin Smith to Howell Hylton re
Susan Knight
POL-0025610
POL00091391
Bundle of Documents containing: Email from
Martin Smith to Howell Hylton, re: Susan Knight;
Letter from Cartwright King Solicitors to Howell
Hylton Solicitors, re: Susan Knight; Interim
Report into alleged problems with Horizon
System.
POL-0090413
POL00168974
Case Review re R. v Angela Sefton and Ann
Nield by Simon Clarke — 17th July 2013
POL-BSFF-
0132565
Page 24 of 28
10.
POL00168896
WITNO9890400
WITN09890400
WITNO09890400
Case Review re R. v Thomas George Brown by
Simon Clarke — 15th July 2013
POL-BSFF-
0132487
11.
POL00168901
Email chain from Susan Crichton to Rodric
Williams , Martin Smith, Hugh Flemington and
others RE: Kevan Jones MP and the Thomas
Brown case
POL-BSFF-
0132492
12.
POL00169054
Table of cases Filtered by Disclosure Required
POL-BSFF-
0132645
13.
POL00169021
POL Cases in which disclosure has taken place
table: showing defendant name, date of
disclosure, solicitors receiving disclosure
POL-BSFF-
0132612
14,
POLO0169055
Table of live cases
POL-BSFF-
0132646
15.
POL00132862
Letter from Simon Clarke to Musa Patels
Solicitors re: Khayyam Ishaq - 12th July 2013
POL-0125260
16.
POLO0060711
Letter from Simon Clarke to Musa Patels
Solicitors re: Khayyam Ishaq - 12th July 2013
POL-0057190
17.
POL00066786
Letter from Simon Clarke to Musa Patels
Solicitors re: Khayyam Ishaq - 12th July 2013
POL-0063265
18.
POL00157189
Letter from Simon Clarke to Musa Patels
Solicitors re: Khayyam Ishaq - 12th July 2013
POL-0145651
19.
POL00168971
Letter from Harry Bowyer to Brewer Harding &
Rowe Solictors RE: Jamie Dixon - Second Sight
Interim Report.
POL-BSFF-
0132562
20.
POLO0089682
Letter from Simon Clarke to Linda Pennington
te : Grant Allen Chest Crown Court -24th
January 2013
POL-0086657
21.
POL00168973
Letter from Harry Bowyer to Davies & Jones
Solicitors re: Hitesh Hirani Plymouth Crown
Court - 8th February 2013
POL-BSFF-
0132564
Page 25 of 28
22.
POLO0066798
WITNO9890400
WITN09890400
WITNO09890400
Angela Sefton Case study. Letter from Simon
Clarke to Hogan Brown Solicitors re: Angela
Sefton outcome and potential grounds to appeal
POL-0063277
23.
POLO0066799
Ann Nield Case Study: Letter from Simon
Clarke to Laurence Lee& Co Solicitors Re Anne
Nield Liverpool Crown Court
POL-0063278
24.
POL00060945
Lynette Hutchings case study: Letter from
Simon Clarke to Messrs. Coomber Rich re:
Lynette Hutchings
POL-0057424
25.
POLO0066843
Lynette Hutchings case study: Letter from
Simon Clarke to Messrs. Coomber Rich re:
Lynette Hutchings
POL-0063322
26.
POLO0066834
Letter from Simon Clarke to Messrs. Coomber
Rich re: Lynette Hutchings
POL-0063313
27.
POL00168972
Letter from Harry Bowyer to Teign Advocates re
Deborah D'Arcy - Post-Conviction disclosure of
Second Sight report
POL-BSFF-
0132563
28.
POL00169005
Letter from Simon Clarke (Cartwright King
Solicitors) to Broadbents Solicitors re Robert
John Boyle - Post-prosecution disclosure of
Second Sight Report and Helen Rose Report
POL-BSFF-
0132596
29.
POL00169011
Letter from Simon Clarke of Cartwright King to
David Phillips and Partners re R v Della
Robinson - Post conviction disclosure of
Second Sight Interim Report and the Helen
Rose Report
POL-BSFF-
0132602
30.
POL00169019
Letter from Simon Clarke to Messrs. Pattichi,
Hill & Croques Re: Jahira Begum
POL-BSFF-
0132610
31.
POL00169020
Letter from Simon Clarke to Canter Levin & Berg
re: Allen Reynolds - Second Sight Interim
Report.
POL-BSFF-
0132611
32.
POL00169017
Letter from Simon Clarke to Messrs Maidments
re: Rajesh Lakhanpaul
POL-BSFF-
0132608
Page 26 of 28
33.
POL00169018
WITNO9890400
WITN09890400
WITNO09890400
Letter from Simon Clarke to Messrs Cohen
Cramer RE: Mohammed Naveed Anwar
POL-BSFF-
0132609
34.
POLO0168865
Letter from Simon Clarke to Tudor Owen
Roberts Glynne & Co re: Damion Peter Owen -
13th December 2013
POL-BSFF-
0132458
35.
POL00168866
Letter from Simon Clarke to B.H. Mohammed &
Co re: Neelam Shanez Hussain - 13th
December 2013
POL-BSFF-
0132459
36.
POL00168881
Letter from Simon Clarke (Cartwright King) to
My Brief Solicitors re Kangasundaram Prince -
Disclosure of Second Sight Interim Report
POL-BSFF-
0132474
37.
POL00168867
Letter from Cartwright King to BH. Mohammad
— re Nellam Shanez Hussain - 04 March 2014
POL-BSFF-
0132460
38.
POL00169051
Letter from Simon Clarke to Messrs Lewis
Rogers, Re: Katherine McQue - Carlisle Crown
Court
POL-BSFF-
0132642
39.
POL00169044
Letter from Simon Clarke to Messrs Thomson,
Webb & Corfield, Re: Daljit Singh Benning —
Cambridge Crown Court
POL-BSFF-
0132635
40.
POL00169045
Letter from Simon Clarke to Messrs Thomson,
Webb & Corfield, Re: Angela Hodgson —
Carlisle Crown Court
POL-BSFF-
0132636
41.
POL00169049
Letter from Simon Clarke (Barrister) to Messrs
Marsden Rawsthorn Re: Jacqueline McDonalds
- Preston Crown Court
POL-BSFF-
0132640
Page 27 of 28
42.
POL00169047
WITNO9890400
WITN09890400
WITNO09890400
Letter from Simon Clarke to Messrs Thomson,
Webb & Corfield, Re: Siobhan Sayer - Norwich
Crown Court
POL-BSFF-
0132638
43.
POL00169048
Letter from Simon Clarke to Messrs, Re: Rabina
Shaheen - Shrewsbury Crown Court
POL-BSFF-
0132639
44,
POL00169043
Letter from Simon Clarke to Messrs Raja & Co
RE: Senapathy Narenthiran - Kingston Crown
Court
POL-BSFF-
0132634
45.
POL00169052
Letter from Simon Clarke to Messrs Thomson,
Webb & Corfield, Mr P Seigne Re: Peter
Huxham - Exeter Crown Court
POL-BSFF-
0132643
46.
POL00169050
Letter from Simon Clarke to Messrs Belmores
re: Alison Henderson — Norwich Crown Court
POL-BSFF-
0132641
47.
POL00168874
Letter from Norman Lamb MP to Paula Vennells
re Alison Henderson - Horizon System — 19
December 2014
POL-BSFF-
0132467
Page 28 of 28