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Witness Name: Robert George Wilson
Statement No.: WITN04210200
Dated: S41), Novenhy 2025
POST OFFICE HORIZON IT INQUIRY
SECOND WITNESS STATEMENT OF ROBERT GEORGE WILSON
I, ROBERT GEORGE WILSON, will say as follows:
This witness statement is made to assist the Post Office Horizon IT Inquiry (the
“Inquiry”) with the matters set out in the Rule 9 Request dated 19th October 2023 (the
“Request’). The statement, my second made in the Inquiry, covers action taken by
Post Office Ltd (“POL”) against Subpostmasters. My first witness statement, dated 11
May 2023, was made in response to a Rule 9 Request dated 14 April 2023. I repeat
the contents of that statement to the extent that they are relevant to the most recent
Request.
The Prosecution of Seema Misra
1. I first became involved in the case of Seema Misra when I allocated the case to
Mr Jarnail Singh to deal with the prosecution. I make the following comments:
1.1, I recall that Mr Warwick Tatford was instructed as Counsel by Mr Singh
and represented POL in the prosecution of Seema Misra. Thereafter my
involvement was restricted to a letter I wrote to Miss Issy Hogg, Mrs
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Misra's solicitor, dated 15.09.2010 serving a schedule of non-sensitive
unused material (POL00055236) and serving a disc containing Horizon
data on Miss Issy Hogg dated 05.03.2010 (POL00054303). I do not recall
why I wrote the letters referred to but can only assume that Mr Singh was
out of the office at the time and I considered that the letters should not be
delayed until his return but I cannot say for certain. Mr Singh may have
sought my advice from time to time but I cannot recall any specific
instance or advice provided. I can see that an attendance note written
by Mr Singh refers to myself being asked about a refusal by Fujitsu to
allow Gareth Jenkins to meet the Defence expert. My advice appears to
be that someone would need to attend Court from Fujitsu to explain why
authority for the experts to meet was not given but I cannot recall this.
The authority for the experts to meet was granted shortly after the Fujitsu
representative received this message (POL00054999). I do recall that
issues concerning disclosure were referred to the Judge dealing with the
prosecution of Seema Misra but was not involved in these proceedings.
As the Criminal Team Leader (“CTL”) I was responsible for all of the
prosecutions conducted by POL which included Royal Mail and
Parcelforce prosecutions. I was also responsible for advising the
Business and dealing with POL’s relationships with external bodies such
as the Courts. I managed my team, agents and Counsel. I estimate that
the time I had to spend on POL work was probably less than 15% of my
working time. I did not have a great deal of involvement in other lawyers'
cases albeit if there was an issue on any prosecution or any member of
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my team required assistance I would always attempt to help them.
I have considered the following documents:
2.1.
2.2.
2.3.
2.4.
2.5.
2.6.
2.7.
2.8.
2.9.
2.10.
2.11,
2.12.
2.13.
2.14.
2.15.
the Audit Report dated 16 January 2008 at POL00058550;
the record of the interview of Seema Misra at POL00119329 (part 1) and
POL00119330 (part 2);
the Investigation Report at POL00044541;
Jarnail Singh's memo to the Investigation Team dated 1 April 2008 at
POL00049658;
the emails from April 2008 at POL00049716;
Jarnail Singh’s memo to the Fraud Team dated 18 November 2008 at
POL00044539;
the draft Schedule of Charges at POL00045010;
the letter dated 13 May 2009 at POL00051441;
the emails dated 22 and 27 May 2009 at POL00119335;
the Summary of Facts at POL00044613;
the Schedule of Non-Sensitive Unused Material dated 23 January 2009
at POL00050750;
the Schedule of Sensitive Material dated 23 January 2009 at
POL00050751;
the draft instructions to Counsel to settle indictment and advise on
evidence and brief for the Prosecution dated February 2009 at
POL00044585;
the letter to Counsel's clerk dated 17 February 2009 at POL00050950;
Counsel's email dated 10 March 2009 at POL00051092:
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2.16. _ the letter from Jarnail Singh to the Castle Partnership dated 17 February
2009 at POL00050942;
2.17. the letter from the Castle Partnership dated 2 March 2009 at
POL00051045;
2.18. the signed indictment dated 16 March 2009 at POL00051149; and
2.19. the attendance note dated 3 June 2009 at POL00051773
as requested by the Inquiry.
I first become involved in the case of Seema Misra when I allocated it to be dealt
with by Mr Singh.
The charges that appeared on the summonses were drafted by Mr Singh.
I do not know who authorised the prosecution of Seema Misra.
I understand from the documents that the disclosure officer was Mr John
Longman.
As set out above, my role in relation to disclosure in these proceedings was
restricted to writing a letter to Miss Issy Hogg dated 15.09.2010 and serving a
schedule of non-sensitive unused material (POL00055236). I also served a disc
containing Horizon data on Miss Izzy Hogg dated 05.03.2010 (POL00054303).
I do not recall when I first became aware that there was a challenge to the integrity
of the Horizon IT system in this case but have looked at an attendance note
prepared by Mr Singh dated 3/6/2009 (POL00051773) regarding the trial that was
listed the previous day. I understand from the documents that the issue of the
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10.
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integrity of Horizon was raised by the Defence at court on 2/6/2009. I believe that
I may have been told shortly after this date but cannot recall precisely when.
I am not sure when I first became aware of the contractual issue raised in relation
to the ARQ material. My view was if ARQ data was relevant to POL’s prosecution
cases it should be obtained irrespective of any contractual provision in the
contract between POL and Fujitsu.
I have considered the following documents:
10.1.
10.2.
10.3.
10.4.
10.5.
10.6.
10.7.
10.8.
10.9.
10.10.
10.11.
the letter from Coomber Rich dated 1 October 2009 at POL00052487
and the enclosed application for disclosure at POL00052462 and further
request for disclosure at POL00058503;:
the email from Mark Dinsdale to me, copied to others, dated 11
December 2009 at POL00053723;
Counsel's Advice dated 5 January 2010 at POL00044557;
the letter from Jarnail Singh to Messrs Coomber Rich dated 11 January
2010 at POL00053746;
Jarnail Singh’s letter to Messrs Coomber Rich dated 27 January 2010 at
POL00044553;
the attendance note dated 27 January 2010 at POL00053849;
Jon Longman’s email dated 29 January 2010 at POL00053880;
the audit report dated 14 October 2005 at POL00093865;
the attendance note dated 1 February 2010 at UKGI00014903;
the emails dated January and February 2010 at POL00053938;
the letter from Juliet MacFarlane to Counsel's clerk dated 2 February
2010 at POL00053954;
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10.12. the email from Juliet MacFarlane dated 5 February 2010 at page 3 of
POL00114272;
10.13. the emails dated January and February 2010 at POL00053938;
10.14. the email dated 3 February 2010 at UKGI00014895;
10.15. the emails dated 5 February 2010 at POL00054010;
10.16. the email dated 24 February 2010 at POL00054185;
10.17. the emails from February and March 2010 at POL00054254;
10.18. the email dated 1 March 2010 at POL00054248;
10.19. the email dated 8 March 2010 and attachment to that email at
POL00054335 and POL00054346;
10.20. the attendance note relating to a hearing on 7 May 2010 at
POL00045565;
10.21. the Schedule of Non-Sensitive Unused Material dated 8 September 2010
at POL00055217 sent under cover of a letter dated 15 September 2010
at POL00055236; and
10.22. the emails dated 6 and 8 October 2010 at POL00055421.
In relation to those documents
11.1. I do not recall my view of the Defence requests in December 2009
(POL00053723). I appear to have simply forwarded the email to Mr Singh
who was dealing with the prosecution. My view on any issue of disclosure
however would have been that if POL could comply with the requests and
assist the Defence then such action should be taken.
11.2. I do not recall providing any advice on the merits of disclosure requests
made by the Defence at this or any stage of the prosecution.
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11.3. Counsel provided advice in January 2010. I do not recall the advice which
would have been sent to Mr Singh.
11.4. I do not recall what the reaction was by POL to Counsel’s Advice. I note
paragraph 23 of Counsel's Advice and also note Juliet McFarlane’s
concern. I do not remember either Ms McFarlane or Mr Singh raising
these matters with me but, had they done so, I would have asked them
to liaise with Mr Tatford Prosecuting Counsel.
11.5. I note from the attendance note (POL00053849) that reference is made
to Prosecuting Counsel being the only person who could comment on
"case papers" which I assume was a reference to the prosecution papers
concerning Mr Hosi but cannot be sure. I do not recall this case. I
understand that Counsel was able to see the case papers as the
instructing solicitor was Ms McFarlane and she had instructed Counsel
working in the same chambers as Mr Tatford.
11.6. Ido not recall whether Counsel advised after January 2010 or the nature
of any advice.
11.7. I have no recollection of Defence disclosure requests in so far as they
related to the Horizon IT system. I understand from the document that
Prosecuting Counsel was referred to in the attendance note dated 27
January 2010 (POL00053849) where he was recorded as saying that:
"... we should disclose everything we can disclose at this stage so the
defence will know where we are coming from. We should be seen to be
willing".
I believe the PO endeavoured to heed this advice.
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11.8. Each morning I received the post and allocated it to the relevant members
of my team. Accordingly, as I dealt with this disclosure, I assume that Mr
Singh was absent from the office at the time. In order to deal with the
schedule of non-sensitive material I will have had to retrieve the case
papers, check the previous disclosure schedule of non-sensitive material
and then dictate the letter informing the Defence that the additions to the
schedule commenced at entry number 19. In addition, had there been
copy documents I would have copied them before sending to the Defence
Solicitors. I believe I will have reviewed the papers to understand whether
the PO’s obligations had been complied with but cannot recall doing so.
Had I any concerns I would have raised them with Mr Singh or
Prosecuting Counsel.
12. Ihave considered:
12.1. the email from Issy Hogg dated 1 March 2010 at POL00054248;
12.2. _ the notification of fixture dated 2 March 2010 at POL00054275;
12.3. the email from Warwick Tatford dated 8 March 2010 and draft skeleton
argument at POL00054335 and POL00054346; and
12.4. the emails dated 11 and 16 March 2010 at POL00054430.
12.4.1. Having considered the above documents, I do not recall when I
first became aware that Seema Misra’s Defence team were
applying to stay count 1 (theft) for abuse. I believe Mr Singh told
me of the application in February or early March of 2010. I do not
recall whether I had a view concerning the application. I do not
believe that I provided any advice. Advice would have been given
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by Prosecuting Counsel. I do not recall what the Post Office’s
response to the application was other than to defend the
application to stay the proceedings. I understand from the
documents that the Defence application to stay the proceedings
failed.
13. 1 have considered the transcripts from the 11th and 18th October at
UKG100014994 and UKG100014845. The Defence renewed their application to
stay the proceedings before His Honour Judge Stewart on the first day of the trial
on 11th October 2010. His Honour Judge Stewart ordered that the trial should
proceed and any issue in relation to the Calendar Square branch could be
explored during the course of the trial. If it was felt that the consequence of the
trial was not and could not be fair then His Honour Judge Stewart would retain
the power to stay the proceedings. His Honour Judge Stewart expressed the view
that it was not appropriate at that stage to order a stay of the prosecution. On
18th October 2010 the Defence renewed their application to stay the proceedings
alleging that the trial had been unfair. As part of his deliberation His Honour Judge
Stewart considered that the issue could properly be dealt with as part of the trial
process which the jury could consider when deciding whether or not Mrs Misra
was guilty of theft. I believe that I was unaware of the applications referred to
above until I read the transcripts submitted with the Request. I was not present in
Court during the course of the trial and provided no advice. I understand from the
documents that Prosecuting Counsel argued that there should not be a stay to
the proceedings. At the end of the trial, Mrs Misra was convicted of the theft.
14. I have considered the following documents:
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14.1.
14.2.
14.3.
14.4.
14.5.
14.6.
14.7.
14.8.
14.9.
14.10.
14.11.
14.12.
14.13.
14.14.
14.15.
14.16.
14.17.
14.18.
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the report of Charles McLachlan dated 21 September 2009 at
POL00093689;
the 2nd interim report of Charles McLachlan dated 19 November 2009 at
POL00094101;
the emails dated 1 February 2010 at POL00053930;
the attendance note dated 1 February 2010 at UKGI00014903;
the witness statement of Gareth Jenkins dated 2 February 2010 at
POL00053937;
the 3rd interim report of Charles McLachlan dated 3 February 2010 at
POL00053992;
the emails dated 3 February 2010 at POL00054085;
the email dated 3 February 2010 at UKG100014895;
the emails dated 5 February 2010 at POL00114272;
the emails dated January and February 2010 at FUJ00122804;
the email sent dated 5 February 2010 at FUJ00122729;
the email dated 8 February 2010 and attached witness statement from
Gareth Jenkins at FUJ00122808;
the emails dated 8 and 9 February 2010 at POL00054095;
the emails dated 22 and 23 February 2010 at POL00054183;
the emails dated 25 February 2010 at POL00054198;
the notice of additional evidence and attached witness statements dated
26 February 2010 at POL00058450;
the emails dated 25 and 26 February 2010 at POL00054220;
the emails dated 26 February and 1 March 2010 at POL00054252;
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14.19. Jarnail Singh’s email dated 1 March 2010 at POL00054267 (and what
appear to be the attachments — the 4th and 5th Interim Technical Expert's
reports prepared by Charles McLachlan - at POL00054126 and
POL00054257);
14.20. Jarnail Singh’s email to Jon Longman dated 1 March 2010 at
POL00054250;
14.21. Jarnail Singh’s email to Gareth Jenkins dated 1 March 2010 at
POL00054267;
14.22. Jarnail Singh’s email to Penny Thomas dated 3 March 2010 at
POL00054282; The emails dated 4 and 5 March 2010 at POL00054311;
14.23. the letter dated 5 March 2010 to Messrs Coomber Rich at POL00054326;
14.24. Gareth Jenkins’ witness statement dated 9 March 2010 at
POL00001643;
14.25. the notice of additional evidence and attached witness statements dated
18 March 2010 at POL00058440;
14.26. Gareth Jenkins’ witness statement dated 8 July 2010 at POL00001759;
14.27. the emails of 15 and 16 July 2010 at POL00055018;
14.28. the email dated 22 July 2010 at POL00055059;
14.29. the emails dated 27 July 2010 at POL00055100;
14.30. the email dated 11 August 2010 at POL00055150;
14.31. the memo from Jarnail Singh to Post Office Security dated 11 August
2010 (POL00055146);
14.32. the emails dated 1 and 4 October 2010 at POL00055356;
14.33. the report of Charles McLachlan dated 4 October 2010 at FUJ00083736;
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14.34. the email dated 6 October 2010 at UKGI00014898;
14.35. the emails dated 7 October 2010 at FUJ00123031;
14.36. the emails dated 8 October 2010 at FUJ00123050;
14.37. the draft statement of Gareth Jenkins at POL00110275;
14.38. the addendum report from Charles McLachlan dated 11 October 2010 at
POL00030298;
14.39. the Joint Statement to the Court by Gareth Jenkins and Charles
McLachlan dated 11 October 2010 at POL00001882;
14.40. the transcripts of 11, 14, 15 and 18 October 2010 at UKGI00014994,
POL00029406, POL00001856 and UKGI00014845; and
14.41. the transcript of submissions, closing speeches and the Judge’s
directions on 19 October 2010 at POL00065708.
In relation to those documents:
15.1. I do not know how Penny Thomas and Gareth Jenkins came to be
involved in these proceedings against Seema Misra. I believe that Gareth
Jenkins was identified as an expert on the Horizon IT system at the
inception of the computer system and had agreed to assist POL in
telation to its role when conducting private prosecutions. This was
probably in 1999 prior to myself becoming head of the CLT. I am not sure
when Penny Thomas commenced her role either before these
proceedings or in relation to these proceedings. I note the email
POL00053930 in which Dave King confirms that he is happy to speak to
Prosecuting Counsel and refers to witnesses needing to come from
“Fujitsu, Network and P&BA". I note from reading (FUJ00122670) a
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series of emails that Penny Thomas was a Security Analyst in Customer
Support. Her role appears to be to support Gareth Jenkins which included
preparation of draft witness statements. Any work that she undertook for
Mr Jenkins she logged against “prosecution support time”. The e-mails
show the Investigation Manager contacting Penny Thomas directly
regarding matters which appear to relate to Mr Jenkins’ evidence. Gareth
Jenkins describes himself as a “Distinguished Engineer and Applications
Architect. I understand from the documents that he was regarded as an
expert on the horizon IT system by POL. I understand from the
documents that the Investigation Manager will have requested evidence
from Mr Jenkins either directly or via Penny Thomas.
15.2. I understood that Gareth Jenkins was employed by Fujitsu and had a role
in engineering the Horizon IT system. I further understand that Fujitsu
owned the data that was to be relied upon in relation to the POL private
prosecutions. That data was looked at by Defence experts and I believe
that no objections were raised by Defence teams to Fujitsu employees or
specifically Mr Jenkins giving evidence. I also understand that no Judge
hearing Fujitsu employees or Mr Jenkins giving evidence where
deficiencies were alleged to emanate from the Horizon IT system
objected to their evidence being given. At the time of the prosecutions it
seemed appropriate to obtain the evidence from Fujitsu employees.
15.3. I did not give any instructions to Mr Jenkins. I do not know whether Mr
Singh or anyone else within the CLT gave Mr Jenkins any instructions in
the Seema Misra prosecution.
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15.4. I considered that Mr Jenkins was acting as an expert. I had a minimal
involvement in the Seema Misra prosecution and do not believe I had any
contact with Mr Jenkins. I do not know whether anyone else explained to
him the nature of his duty as an expert but believe that, when giving
evidence, he would have been questioned about his qualifications,
experience, and the basis for his opinions, making it clear to the Court
and all parties involved why he was qualified to provide expert evidence
in the case.
15.5. During the course of the Seema Misra case I was notified of three
instances where "bugs, errors or defects" were present in the Horizon IT
system. The first related to an occurrence in December 2007 impacting
on one office where there was a financial imbalance (email
FUJ00155400). A software correction was applied to resolve the problem
in November 2008. The second concerned duplication of records
occurring under the New Horizon System. Ms McFarlane obtained a
statement from Gareth Jenkins covering the issue (emails 30 June 2010
FUJ00122903). The third was passed to me by an email from Alan
Simpson (POL00028838). This issue concerned discrepancies affecting
40 branches and occurred when moving discrepancies into the local
suspense account.
15.6. I do not recall speaking to Mr Jenkins about the Seema Misra case or, in
particular, any views expressed by Mr Jenkins in relation to disclosure
being sought by the Defence in the Seema Misra case.
16. I understand from reading the documents UKG100014898, POL00055100,
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17.
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POL00055150 and POL00055146 that the Defence were requesting access to
the system in the Midlands where it appears there were live reproducible errors.
The Defence also requested access to operations at Chesterfield to understand
how reconciliation and transaction corrections were dealt with and access to the
system change requests, known error logs and new release documents to
understand what problems had been fixed. I do not recall this request, or anything
to do with the response from POL, but believe from the documents supplied that
the requests were refused and the Defence were asked if they wished to proceed
with the request to make a Section 8 application to the Court. I understand from
the documents supplied that Mr Singh sought advice from Prosecution Counsel
on this point.
I have considered POL00055410, POL00028838 and FUJ00122995. At the time
I did not consider the issues discussed in the correspondence had a relevance to
the Seema Misra case and, accordingly, did not consider these issues to be
disclosable material in the prosecution. I understood that the Seema Misra case
was prosecuted under the Horizon System implemented from 1999. The issues
raised here I believe related to the New Horizon system which was installed from
January to September 2010 and did not have any relevance to the initial system
which had now been re-implemented as New Horizon (HNG-X). I now believe
that this was the wrong decision and that I should have disclosed this issue in
relation to all existing prosecutions.
I cannot recall what my view of the outcome of the case was at the time. I had
had very little input into the case but was aware of it and imagine that I was
content that a conviction had been achieved as the jury had determined the guilt
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of Mrs Misra. There were a number of individuals that the email of 21 October
was copied to who I did not know and I was surprised at the audience. I do not
believe that I was aware of the interest in the case and would not have expected
to see a report of this nature. The usual report would have simply described the
outcome and have been copied to a more limited audience. I did not share Jarnail
Singh’s hope that this would set a marker and believed that challenges to the
Horizon system would continue under New Horizon (HNG-X).
19. In so far as my reflections on the Seema Misra case are concerned, I was
shocked at the Judgement. I believed that the Horizon data was reliable and had
been properly disclosed. I understood that POL had dealt with its duties so far as
disclosure was concerned and ultimately seeking an order from the Judge dealing
with the prosecution when there was a challenge to the disclosure requests. I
believed that disclosure had been fully complied with. Clearly this view was not
correct.
The Prosecution of Alison Henderson
20. I must apologise to Mrs Alison Henderson as I have no recollection of her criminal
prosecution. My account is limited to the documents disclosed by the Inquiry and
any memories that they have engendered. Please note below a full account of
my dealings and recollection of the criminal prosecution of Alison Henderson.
21. I have considered the following documents:
21.1. the final branch trading statement, dated 6 January 2010, at
POL00047227;
21.2. the investigation report (legal) dated 18 March 2010 at POL00047152;
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21.3.
21.4.
21.5.
21.6.
21.7.
21.8.
21.9.
21.10.
21.11.
21.12.
21.13.
21.14.
21.15.
21.16.
21.17.
21.18.
21.19.
21.20.
21.21.
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the interview transcript, dated 11 March 2010 at POL00129785;
the extract of the transaction report at POL00047183;
the ‘person not to be employed’ memo at POL00065009_011;
the memo dated 25 March 2010 at POL00047155;
the memo from Christopher Knight dated 20 April 2010 at POL00044501;
the memo dated 21 May 2010 at POL00047159;
the emails dated 25 and 26 May 2010 at POL00047161;
the memo from Maureen Moors dated 26 May 2010 at POL00047162:;
the email from Christopher Knight dated 12 July 2010 at
POL00065009_010;
the summons at POL00047193;
the letter from to Messrs Hugh A Cauthery at POL00054984;
the letter to the Norwich Magistrates Court at POL00055163:
the memo to Christopher Knight, dated 19 August 2010, at
POL00055189;
the Schedule of Non-Sensitive Unused Material, dated 24 September
2010, at POL00055495;
the committal bundle, dated 27 September 2010, at POL00125643;
the memo to Christopher Knight, dated 29 September 2010, at
UKGI00014627;
the letter from Hugh A Cauthery solicitors to you, dated 7 October 2010,
at POL00055388;
the advice on evidence, dated 14 October 2010, at POL00055542;
the summary of facts at POL00125641;
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21.22. the bundle of witness statements at POL00125644;
21.23. the list of exhibits at POL00125646;
21.24. the antecedents form at POL00125639;
21.25. the Defence Statement at POL00047195;
21.26. the letter from Belmores Solicitors dated 16 November 2010 at
POL00055787 and amended Defence Statement at POL00044503;
21.27. the emails dated 16 and 17 November 2010 at POL00055783;
21.28. the letter to Messrs. Belmore, dated 18 November 2010, at
POL00047168;
21.29. the memo dated 18 November 2010, at POL00047169;
21.30. the letter from Miss Andrews to Hugh A Cauthery Solicitors, dated 25
November 2010, at POL00055837;
21.31. the factual basis/application for a Goodyear indication at POL00046148;
21.32. the attendance note, dated 1 December 2010, at POL00055853;
21.33. the letter from Belmores Solicitors dated 1 December 2010 at
POL00055854;
21.34. the letter to Belmores Solicitors dated 7 December 2010 at
POL00055865;
21.35. the letter from Hugh A Cauthery Solicitors to myself, dated 15 December
2010, at POL00055890; and
21.36. the memo dated 16 December 2010, at POL00047170.
I believe that I first became involved in the Alison Henderson case when I
allocated the case to myself shortly after receiving the papers in March 2010 but
cannot recall doing so.
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23. I believe I will have received a copy of the Investigation Report and copy of the
Interview transcript conducted with Mrs Henderson. I may have received a copy
of the branch trading statement (POL00047227) and the transaction report
(POL00047183) but cannot recall this or the extent of the case papers.
24. I do not recall what advice I gave to the Security Team. I understand from the
documents copied to me that I asked for further clarification of assertions made
in the Investigation Report (memo 25th March 2010 POL00047155), receiving a
reply on 20th April 2010 (POL00044501) with a further memo being sent on 21
May 2010 (POL00047159).
25. Whilst I do not recall the advice, I believe that I would have asked for evidence
covering the audit of the Sub-Post Office, the interviews conducted with Mrs
Henderson, production of the branch trading statements, and transactional data
from the Horizon IT system.
26. The reasoning behind the advice would be to adduce sufficient evidence to
provide a reasonable prospect of conviction.
27. I believe that Mr Andy Hayward the DAM authorised the Prosecution of Mrs
Henderson on 26.05.2010 (POL00047161).
28. I drafted the single charge of theft and Mr Hayward made the decision to charge
Mrs Henderson.
29. The charge of Theft was laid on 12 August 2010 (POL00047193). The charge
specified:
“FOR THAT YOU Alison Henderson on a day unknown between 2nd July 1997
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and 10th February 2010 at the Worstead Sub-Post Office stole £11957.78
belonging to Post Office Ltd. Contrary to S1 of the Theft Act 1968."
My memo of 21 May 2010 expressed the view that a single charge of theft was
the appropriate charge in this case against Mrs Henderson (POL00047159). I
have seen an email I wrote to Prosecuting Counsel (POL00055783) in which I
state that the Defence had indicated that Mrs Henderson may be willing to plead
to a charge of false accounting and pay the money back to PO Ltd. My email
goes on to say that “the matter is in defence counsel's hands”. I did not put any
pressure on anyone in the Defence team to offer a plea to false accounting or
suggest the same to anyone. I recall following a review of the documents that I
was expecting a trial in this prosecution. A letter was received from the Defence
solicitors dated 16th November 2010 enclosing an amended Defence Statement
(POL00055787 and POL00044503). The letter requested that the Defence would
require a further named witness to attend the trial of the matter. The Defence
Statement indicated that a "Goodyear" indication would be sought and whilst
denying theft, the Defendant would plead guilty to false accounting. I understand
that when the matter was next listed in Court which I believe was on ‘1st
December 2010 a count of false accounting was added to the Indictment. A
Goodyear indication was sought from the Judge however, he declined to give an
indication to allow the Defendant time to repay monies to POL. No pleas were
taken and the case was adjourned until 15th December 2010. I understand from
the documents that, at the hearing on 15th December, a plea to false accounting
was entered and the prosecution offered no evidence in relation to the charge of
theft. The Judge dismissed the charge of theft.
Page 20 of 35
31.
32.
33.
34.
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The disclosure officer was Christopher Knight.
My role in relation to disclosure in this case was to provide the Defence with initial
disclosure. This would include any unused evidence and any evidence that
undermined the prosecution case or assisted the Defence case. My duty of
disclosure would have continued throughout the course of the prosecution.
Following the receipt of the Defence Case Statement, in order to ensure
compliance with disclosure obligations I would first consider the statement and,
where any clarification of the content was required, I would write to the Defence
for clarification. I do note that a Defence statement was received in this case
where I questioned paragraph 2 which specified that further investigation by the
auditor could have discovered the whereabouts of the missing money
(POL00047168).
I believe after having reviewed the documents that the first time I became aware
that the integrity of the Horizon data was being questioned was upon receipt of
the amended Defence statement dated 16 November 2010. On the same date, I
received an indication that Mrs Henderson was highly likely to plead to false
accounting (POL00055783). The receipt ‘of the challenge complaining of the
malfunction of Horizon would have raised an obligation to serve on the Defence
any material that assisted the Defence or undermined the prosecution.
I do not believe that ARQ data was ever sought in this case. I understand that the
Sub-Post Office was situated in a village and had limited opening hours. Mrs
Henderson was the only person working at the office. She said that she did all of
the end of day work and branch trading statements herself. Further, she could
Page 21 of 35
35.
36.
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not recall problems with balancing and that the shortage discovered by the
auditors was a complete shock (POL00129785). As set out above, the Defence
on 16 November indicated that Mrs Henderson was highly likely to plead to false
accounting (POL00055783). This was the same date that the amended Defence
Statement was received (POL00044503). At that stage ARQ had not been sought
and advice from Prosecution Counsel had not requested ARQ data
(POL00055542). Had Mrs Henderson decided to continue to contest the
allegation of theft and had false accounting not been added to the indictment,
then I believe ARQ data would have been considered.
I understand from the documents that following Prosecuting Counsel's advice
dated 14th October 2010 (POL00055542), that daily cash figures and overnight
cash holdings (ONCH) would be obtained. I understand from the documents that
the information Counsel required together with the cash declarations would make
it obvious that money was missing.
The Defence Statement was served on 16 November 2010 which was the same
date that I wrote to Prosecuting Counsel informing her that the Defence had
indicated that Mrs Henderson was highly likely to plead to false accounting. I have
seen the emails dated 8 October 2010 at POL00055410 and documents at
POL00028838, as well as the email from Juliet McFarlane dated 16th September
2010 FUJ00122995 and can only believe that I had forgotten about the generic
statement that had been prepared for Ms McFarlane. So far as the bugs raised
in the emails referred to above, I believe they related to the New Horizon system
which was installed from January to September 2010 and did not have any
relevance to the initial Horizon system which had now been re-implemented as
Page 22 of 35
37.
38.
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New Horizon (HNG-X). As set out above, I now believe that this was the wrong
decision and I should have disclosed any issue concerning the New Horizon in
relation to the prosecution of Mrs Henderson.
I recall following a review of the documents that I was expecting a trial in relation
to the charge of Theft. I did not enter any negotiations with the Defence Solicitors.
So far as my stipulations in relation to the integrity of Horizon were concerned,
my view at the time in relation to the acceptance of the plea to false accounting
was that paragraph 10.4 of the Code for Crown Prosecutors 2010 applied to the
situation. Under paragraph 10.4 “Accepting Pleas” the code stated that:
“It must be made clear to the court on what basis any plea is advanced and
accepted. In cases where a defendant pleads guilty to the charges but on a basis
of facts that are different from the prosecution case, and where this may
significantly affect sentence, the court should be invited to hear evidence to
determine what happened, and then sentence on that basis”.
So far as my reflections on the way the investigation and prosecution of Alison
Henderson are concerned, I was of course shocked to read the criticism of the
conduct of the case. Whilst respecting the Judgement of the Court of Appeal in
Josephine Hamilton & Others v Post Office Limited (POL00113278), as set out
above, my view at the time and on reflection in relation to the acceptance of the
plea to false accounting was that paragraph 10.4 of the Code for Crown
Prosecutors 2010 applied to the situation. Under paragraph 10.4 “Accepting
Pleas’ it stated that “/t must be made clear to the court on what basis any plea is
advanced and accepted. In cases where a defendant pleads guilty to the charges
but on a basis of facts that are different from the prosecution case, and where
Page 23 of 35
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this may significantly affect sentence, the court should be invited to hear evidence
to determine what happened, and then sentence on that basis.” I did not consider
that I was acting improperly at the time as to accept a basis of plea that blamed
any deficit on the Horizon IT system was agreeing with the Defence that Horizon
was not working properly. This was not how I understood the position. I believed
that the Horizon IT system was working properly.
The Prosecution of Khayyam Ishaq
39. I must apologise to Mr Khayyam Ishaq as I have no recollection of his criminal
prosecution. My account is limited to the documents disclosed by the Inquiry and
any memories that they have engendered.
40. I have considered the following documents:
40.1. the Typed copy of Notebook Entry dated 7 April 2011 at POL00046313;
40.2. the Record of Taped Interview of interview on 7 April 2011 (11.11 to
11.53) at POL00046349;
40.3. the Record of Taped Interview of interview on 7 April 2011 (12.11 to
12.55) at POL00045133;
40.4. the Investigation Report dated 13 May 2011 at POL00046224;
40.5. the memo to the National Security Team dated 18 May 2011 at
POL00046228;
40.6. the memo to the National Security Team dated 5 July 2011 at
POL00056596;
40.7. the Summary Record of Taped Interview of interview on 27 September
2011 at POL00057985;
40.8. the Investigation Report dated 3 October 2011 at POL00057078;
Page 24 of 35
a1.
42.
40.9.
40.10.
40.11.
40.12.
40.13.
40.14.
40.15.
40.16.
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the memo to the National Security Team dated 11 October 2011 at
POL00046235;
the Advice and Draft Charge dated 23 March 2012 at POL00057543;
the unsigned statement of Stephen Bradshaw dated 4 April 2012 at
POL00057582;
the summons dated 13 April 2012 at POL00046253;
the unsigned statement of Stephen Bradshaw dated 18 June 2012 at
POL00058024;
the Schedule of Non-Sensitive Unused Material dated 18 June 2012 at
POL00058025;
the Schedule of Sensitive Unused Material dated 18 June 2012 at
POL00058027; and
the Disclosure Officers Report dated 18 June 2012 at POL00058028.
I do not recall when I first became involved in the Khayyam Ishaq case but believe
it will have been shortly after the Investigation Report dated 13 May 2011 was
prepared (POL00046224).
I do not recall the information I was provided with before I drafted advice to the
investigation manager. However, I believe I will have been in possession of the
Investigation Report dated 13 May 2011 (POL00046224), copies of the taped
interviews of 7 April 2011 (POL00046349 and POL00045133), and possibly the
audit report prior to my memo of 18 May 2011 (POL00046228). Following this
memo,
I will have received a copy of Mr Liquat’s statement, the Investigation
Report dated 3 October 2011 and a copy of the taped interview dated 27
Page 25 of 35
43.
44,
45.
46.
47.
48.
49.
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September 2011.
I provided advice dated 11 October 2011 (POL00057078) which requested the
obtaining of Horizon data to show a number of reversals relating to sales of
stamps and records in relation to a “relief who may have worked at the Sub-Post
Office at the time of the reversals.
My advice was given in order to establish who was making the reversals. I wanted
to know what user login was recorded in relation to the transactions that were
reversed and whether or not there was a “relief working at the Sub-Post Office.
I did not apply any test when advising the Security Team. I did not provide the
final advice or draft charges in this case. The advice and draft charge were
prepared by Martin Smith of Messrs Cartwright King on 23rd March 2012
(POL00057543). I believe that the case papers had been transferred to Messrs
Cartwright King in anticipation of the split between Royal Mail Group and POL. I
refer to paragraphs 24-26, 35 and 41 of my first witness statement in relation to
the role of Messrs Cartwright King.
I understand from the Investigation Report dated 13 May 2011 (POL00046224)
that David Pardoe, Senior Security Manager authorised the prosecution of
Khayyam Ishaq.
The charge was drafted by Martin Smith of Messrs Cartwright King.
The charge was theft of £21,168.64 contrary to Section 1(1) of the Theft Act 1968.
The disclosure officer was Stephen Bradshaw.
Page 26 of 35
50.
51.
52.
53.
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I did not have a role in relation to disclosure in this case.
I was not aware that Mr Ishaq had raised issues relating to the integrity of the
Horizon data during the course of the prosecution.
I had no involvement in the prosecution after I moved to the Royal Mail Group in
April 2012.
My reflections in relation to the investigation and prosecution of Mr Ishaq now are
limited on the basis that I ceased to be involved with the case prior to the issue
of summonses. I had however sought to clarify issues concerning a number of
reversals relating to sales of stamps and records in relation to a "relief" who may
have worked at the Sub-Post Office prior to handing the file to POL to prosecute.
I note that in the Judgement of the Court of Appeal the evidence fell short of that
required to prove an actual loss and in such circumstances I am surprised to see
that Mr Ishaq on the 7th of March 2013 pleaded guilty to the theft of £17863.
Statement of Truth
I believe the content of this statement to be true.
Signed:I G RO
Dated: SPR Noverbe 2022
Page 27 of 35
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Index to Second Witness Statement of ROBERT GEORGE WILSON
No. URN Document Description Control Number
1 POL00054303 Letter enclosing disc containing I POL-0050782
Horizon data on Miss Issy
Hogg dated 05.03.2010
2 POL00054999 Attendance note dated 15 July I POL-0051478
2010
3 POL00058550 Audit Report dated 16 January I POL-0055029
2008
4 POL00119329 Record of the interview of POL-0119248
Seema Misra (part 1)
5 POL00119330 Record of the interview of POL-0119249
Seema Misra (part 2)
6 POL00044541 The Investigation Report POL-0041020
7 POL00049658 Jarnail Singh’s memo to the POL-0046137
Investigation Team dated 1
April 2008
8 POL00049716 The emails from April 2008 POL-0046195
9 POL00044539 Jarnail Singh’s memo to the POL-0041018
Fraud Team dated 18
November 2008
10 POL00045010 The draft Schedule of Charges_I POL-0041489
11 POL00051441 The letter dated 13 May 2009 POL-0047920
12 POL00119335 The emails dated 22 and 27 POL-0119254
May 2009
13 POL00044613 The Summary of Facts POL-0041092
14 POL00050750 The Schedule of Non-Sensitive I POL-0047229
Unused Material dated 23
January 2009
15 POL00050751 The Schedule of Sensitive POL-0047230
Material dated 23 January
2009
16 POL00044585 The draft instructions to POL-0041064
Counsel to settle indictment
and advise on evidence and
brief for the Prosecution dated
February 2009
17 POL00050950 The letter to Counsel’s clerk POL-0047429
dated 17 February 2009
18 POL00051092 Counsel's email dated 10 POL-0047571
March 2009
19 POL00050942 The letter from Jarnail Singh to I POL-0047421
the Castle Partnership dated
17 February 2009
20 POL00051045 The letter from Jarnail Singh to I POL-0047524
the Castle Partnership dated 17
February 2009
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21 POL00051149 The signed indictment dated 16 I POL-0047628
March 2009
22 POL00051773 The attendance note dated 3 POL-0048252
June 2009
23 POL00052487 The letter from Coomber Rich I POL-0048966
dated 1 October 2009
24 POL00052462 The enclosed application for POL-0048941
disclosure
25 POL00058503 Request for disclosure POL-0054982
26 POL00053723 The email from Mark Dinsdale I POL-0050202
to me, copied to others, dated
11 December 2009
27 POL00044557 Counsel’s Advice dated 5 POL-0041036
January 2010
28 POL00053746 The letter from Jarnail Singh to I POL-0050225
Messrs Coomber Rich dated
11 January 2010
29 POL00044553 Jarnail Singh’s letter to Messrs I POL-0041032
Coomber Rich dated 27
January 2010
30 POL00053849 The attendance note dated 27 I POL-0050328
January 2010
31 POL00053880 Jon Longman’s email dated 29 I POL-0050359
January 2010
32 POL00093865 The audit report dated 14 POL-0093987
October 2005
33 UKGI00014903 The attendance note dated 1 UKGI025696-001
February 2010
34 POL00053938 The emails dated January and I POL-0050417
February 2010
35 POL00053954 The letter from Juliet POL-0050433
MacFarlane to Counsel’s clerk
dated 2 February 2010
36 POL00114272 The email from Juliet POL-0113199
MacFarlane dated 5 February
2010 at page 3
37 UKGI00014895 The email dated 3 February UKGI025688-001
2010
38 POL00054010 The emails dated 5 February POL-0050489
2010
39 POL00054185 The email dated 24 February POL-0050664
2010
40 POL00054254 The emails from February and
March 2010 POL-0050733
41 POL00054335 The email dated 8 March 2010 I POL-0050814
and attachment to that email
42 POL00054346 Draft skeleton argument POL-0050825
43 POL00045565 The attendance note relating to I POL-0042044
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a hearing on 7 May 2010
44 POL00055217 The Schedule of Non-Sensitive I POL-0051696
Unused Material dated 8
September 2010
45 POL00055236 Cover of a letter dated 15 POL-0051715
September 2010
46 POL00055421 The emails dated 6 and 8 POL-0051900
October 2010
47 POL00054248 Email from Issy Hogg dated 1 POL-0050727
March 2010
48 POL00054275 Notification of fixture dated 2 POL-0050754
March 2010
49 POL00054430 Emails dated 11 and 16 March I POL-0050909
2010
50 UKG100014994 Transcript from the 11 October I UKGI025787-001
51 UKG100014845 Transcript from the 18 October I UKGI025638-001
52 POL00093689 The report of Charles POL-0093811
McLachlan dated 21
September 2009
53 POL00094101 The 2nd interim report of POL-0094223
Charles McLachlan dated 19
November 2009
54 POL00053930 The emails dated 1 February POL-0050409
2010
55 POL00053937 The witness statement of POL-0050416
Gareth Jenkins dated 2
February 2010
56 POL00053992 The 3rd interim report of POL-0050471
Charles McLachlan dated 3
February 2010
57 POL00054085 The emails dated 3 February POL-0050564
2010
58 FUJ00122804 The emails dated January and I POINQ0129018F
February 2010
59 FUJ00122729 The email sent dated 5 POINQ0128943F
February 2010
60 FUJ00122808 The email dated 8 February POINQ0129022F
2010 and attached witness
statement from Gareth Jenkins
61 POL00054095 The emails dated 8 and 9 POL-0050574
February 2010
62 POL00054183 The emails dated 22 and 23 POL-0050662
February 2010
63 POL00054198 The emails dated 25 February I POL-0050677
2010
64 POL00058450 The notice of additional POL-0054929
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evidence and attached witness
statements dated 26 February
2010
65
POL00054220
The emails dated 25 and 26
February 2010
POL-0050699
66
POL00054252
The emails dated 26 February
and 1 March 2010
POL-0050731
67
POL00054267
Jarnail Singh’s email dated 1
March 2010
POL-0050746
68
POL00054126
Jarnail Singh’s email dated 1
March 2010
POL-0050605
69
POL00054257
Jarnail Singh’s email dated 1
March 2010 (and what appear
to be the attachments — the 4th
and 5th Interim Technical
Expert's reports prepared by
Charles McLachlan - at and)
POL-0050736
70
POL00054250
Jarnail Singh’s email to Jon
Longman dated 1 March 2010
POL-0050729
71
POL00054282
Jarnail Singh’s email to Penny
Thomas dated 3 March 2010
POL-0050761
72
POL00054311
The emails dated 4 and 5
March 2010
POL-0050790
73
POL00054326
The letter dated 5 March 2010
to Messrs Coomber Rich
POL-0050805
74
POL00001643
Gareth Jenkins’ witness
statement dated 9 March 2010
ViIS00002657
75
POL00058440
The notice of additional
evidence and attached witness
statements dated 18 March
2010
POL-0054919
76
POL00001759
Gareth Jenkins’ witness
statement dated 8 July 2010
ViS00002773
7
POL00055018
The emails of 15 and 16 July
2010
POL-0051497
78
POL00055059
The email dated 22 July 2010
POL-0051538
POL00055100
The emails dated 27 July 2010
POL-0051579
80
POL00055150
The email dated 11 August
2010
POL-0051629
81
POL00055146
The memo from Jarnail Singh
to Post Office Security dated
11 August 2010
POL-0051625
82
POL00055356
The emails dated 1 and 4
October 2010
POL-0051835
83
FUJ00083736
The report of Charles
McLachlan dated 4 October
2010
POINQ0089907F
84
FUJ00123031
The emails dated 7 October
POINQ0129245F
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2010
85 FUJ00123050 The emails dated 8 October POINQ0129264F
2010
86 POL00110275 The draft statement of Gareth I POL-0108082
Jenkins
87 POL00030298 The addendum report from POL-0026780
Charles McLachlan dated 11
October 2010
88 POL00001882 The Joint Statement to the VIS00002896
Court by Gareth Jenkins and
Charles McLachlan dated 11
October 2010
89 POL00029406 The transcript of 14 October POL-0025888
2010
90 POL00001856 The transcript of 15 October VIS00002870
2010
91 POL00065708 The transcript of submissions, I POL-0062187
closing speeches and the
Judge’s directions on 19
October 2010
92 FUJ00122670 Email from Penny Thomas to POINQ0128884F
Gareth Jenkins dated 28
January 2010
93 UKG100014898 Requests for access made by I UKGI025691-001
the Defence on 22 July 2010
94 POL00055410 Emails dated 8 October 2010 POL-0051889
95 POL00028838 Attachments to emails dated 8 I POL-0025320
October 2010
96 FUJ00122995 Email from Juliet McFarlane POINQ0129209F
dated 16th September 2010
97 POL00047227 Final branch trading statement, I POL-0043706
dated 6 January 2010
98 POL00047152 The investigation report (legal) I POL-0043631
dated 18 March 2010
99 POL00129785 The interview transcript dated POL-0123811
11 March 2010
100 POL00047183 The extract of the transaction POL-0043662
report
101 POL00065009_011 I The ‘person not to be POL-
employed’ memo 0061488 011
102 POL00047155 The memo dated 25 March POL-0043634
2010
103 POL00044501 The memo from Christopher POL-0040980
Knight dated 20 April 2010
104 POL00047159 The memo dated 21 May 2010 I POL-0043638
105 POL00047161 The emails dated 25 and 26 POL-0043640
May 2010
106 POL00047162 The memo from Maureen POL-0043641
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Moors dated 26 May 2010
107 POL00065009_010 I The email from Christopher POL-
Knight dated 12 July 2010 0061488 010
108 POL00047193 The Christopher G. Knight POL-0043672
summons
109 POL00054984 The letter from to Messrs Hugh I POL-0051463
A Cauthery
110 POL00055163 The letter to the Norwich POL-0051642
Magistrates Court
111 POL00055189 The memo to Christopher POL-0051668
Knight, dated 19 August 2010
112 POL00055495 The Schedule of Non-Sensitive I POL-0051974
Unused Material, dated 24
September 2010
113 POL00125643 The committal bundle dated 27 I POL-0131312
September 2010
114 UKGI00014627 The memo to Christopher UKGI025420-001
Knight dated 29 September
2010
115 POL00055388 The letter from Hugh A POL-0051867
Cauthery solicitors to you dated
7 October 2010
116 POL00055542 Prosecuting Counsel’s advice I POL-0052021
dated 14th October 2010
117 POL00125641 The summary of facts POL-0131310
118 POL00125644 The bundle of witness POL-0131313
statements
119 POL00125646 The list of exhibits POL-0131315
120 POL00125639 The antecedents form POL-0131308
121 POL00047195 The Defence Statement POL-0043674
122 POL00055787 The letter from Belmores POL-0052266
Solicitors dated 16 November
2010
123 POL00044503 Amended Defence Statement I POL-0040982
124 POL00055783 The emails dated 16 and 17 POL-0052262
November 2010
125 POL00047168 Letter to Messrs. Belmore POL-0043647
dated 18 November 2010
126 POL00047169 Memo dated 18 November POL-0043648
2010
127 POL00055837 Letter from Miss Andrews to POL-0052316
Hugh A Cauthery Solicitors
dated 25 November 2010
128 POL00046148 The factual basis/application POL-0042627
for a Goodyear indication
129 POL00055853 The attendance note dated 1 POL-0052332
December 2010
130 POL00055854 The letter from Belmores POL-0052333
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Solicitors dated 1 December
2010
131
POL00055865
The letter to Belmores
Solicitors dated 7 December
2010
POL-0052344
132
POL00055890
The letter from Hugh A
Cauthery Solicitors to myself
dated 15 December 2010
POL-0052369
133
POL00047170
The memo dated 16 December
2010
POL-0043649
134
POL00113278
Judgement of the Court of
Appeal in Josephine Hamilton
& Others v Post Office Limited
[2021] EWCA Crim 577
POL-0110657
135
POL00046313
The Typed copy of Notebook
Entry dated 7 April 2011
POL-0042792
136
POL00046349
The Record of Taped Interview
of interview on 7 April 2011
(11.11 to 11.53)
POL-0042828
137
POL00045133
The Record of Taped Interview
of interview on 7 April 2011
(12.11 to 12.55)
POL-0041612
138
POL00046224
The Investigation Report dated
13 May 2011
POL-0042703
139
POL00046228
The memo to the National
Security Team dated 18 May
2011
POL-0042707
140
POL00056596
The memo to the National
Security Team dated 5 July
2011
POL-0053075
141
POL00057985
The Summary Record of Taped
Interview of interview on 27
September 2011
POL-0054464
142
POL00057078
The Investigation Report dated
3 October 2011
POL-0053557
143
POL00046235
The memo to the National
Security Team dated 11
October 2011
POL-0042714
144
POL00057543
The Advice and Draft Charge
dated 23 March 2012
POL-0054022
145
POL00057582
The unsigned statement of
Stephen Bradshaw dated 4
April 2012
POL-0054061
146
POL00046253
The summons dated 13 April
2012
POL-0042732
147
POL00058024
The unsigned statement of
Stephen Bradshaw dated 18
June 2012
POL-0054503
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148
POL00058025
The Schedule of Non-Sensitive
Unused Material dated 18 June
2012
POL-0054504
149
POL00058027
The Schedule of Sensitive
Unused Material dated 18 June
2012
POL-0054506
150
POL00058028
The Disclosure Officers Report
dated 18 June 2012
POL-0054507
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