WITN04450100 Stephen Bradshaw - 1st Witness Statement

Evidence on official site

WITN04450100
WITN04450100

Witness Name: Stephen Bradshaw
Statement No.: WITN04450100
Dated: 26 June 2023

POST OFFICE HORIZON IT INQUIRY

FIRST WITNESS STATEMENT OF STEPHEN BRADSHAW

I, STEPHEN BRADSHAW, will say as follows...
Introduction
This witness statement is made to assist the Post Office Horizon IT Inquiry

with the matters set out in the Rule 9 Request dated 19 May 2005.

Background
1. I have been employed by, Post Office Ltd (Formally known as GPO, Royal

Mail Group, The Post Office and Consignia) since 1978. During this period, I

have covered a number of roles as follows:
a. Telegraph Officer (Inland Telegram Service) 1978
b. Counter Clerk 1979 — 1984
c. Television Enquiry Officer 1984 — 1987
d. Royal Mail Transport Section 1987 — 2000 for all roles below

e. Royal Mail Collections

~

Royal Mail Distribution

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g. Post Office Investigations 2000 to date.

2. I applied for the position of Fraud Investigator as per the advertisement in the
Gazette.

a. I passed the selection process and undertook a two-week course at
Wolverton Mill College. On the successful completion of the course I
was assigned to Post Office Ltd. Other Successful candidates were
assigned to other parts of the business.

b. The role included the investigation of crimes committed against Post
Office Ltd by its staff, agents and agent’s employees.

c. I reported to my Line Manager (then renamed Team Leader).

d. I found my colleagues and managers to be both competent and
professional at all times.

3. I have been asked about my role as Security Manager. As above the initial
role has remained the same but the job title changed.
4. The following applied:

a. Disciplinary matters were dealt with by the Contracts Managers (also
known as Retail Network Managers — Retail Line Managers).

b. Anybody suspected of committing a criminal offence would be
interviewed in accordance with PACE.

c. Disclosure of the current available information regarding the enquiry
would be given to a solicitor prior to any interview. I do not recall
being party to any civil proceedings.

d. [do not recall being party to any Litigation case strategy.

e. Liaison with other Post Office departments would take place to request

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information to enable the facts to be gathered to ascertain if any criminal

offence had taken place.

5. I have been asked to describe the process of an investigation by the fraud
team. The process is as follows:

a. Any enquiry would go into the casework team, it would then be
assigned via the Line Manager in the first instance to an Investigator in
the area, depending on their current workload it could be assigned to
an Investigator in another area.

b. Contact made (either in person or via a telephone call) with the person
to be interviewed / suspect to arrange an interview, their legal rights
would be explained over the phone or in person together with the Post
Office agreement that a Post Office Friend (normally their Union Rep)
could also attend. A suitable time, place and date would be agreed for
an interview to take place. This would be confirmed in a letter to the
person who was to be interviewed.

c. All available information would be obtained for the interview.

d. The interview would take place, at the end of the interview they would
be given a form telling them what happens to the interview tapes /
discs, an offender's report would be submitted to the Criminal Law
Team (CLT) or Cartwright King when they took over to see if the
evidence was sufficient for a successful prosecution. If the advice was
for a prosecution, charging advice would be received, case would be
booked into the Magistrates, summons obtained, service and the
normal court process then takes place. If there was no plea or a not

guilty plea entered a committal bundle would be prepared. If any

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further evidence came to light this would be served on the defence by
the CLT or Cartwright King together with a statement formally

exhibiting the items.

6. All information would be passed to the Financial Investigator for confiscation,
if court case costs via prosecution barrister / solicitor would be applied for
and if interviewee / suspect had agreed to repay any monies details of
account for monies to be paid into would be provided and on occasions
person would send cheques directly and these paid into a Bank of Ireland
account.

Relationship with Fujitsu

7. Any information required from Fujitsu would be requested via the casework
team. Any contact with members of Fujitsu if they had provided a statement
would be as a matter of the court process in they may be required as a
witness. I do not recall any particular conversations or dialogue with members
of Fujitsu.

8. I do not recall having any direct contact with any Fujitsu engineers. I have
seen the documents listed (FUJ00122938 and FUJ00122939) and can only
assume contact was made as a result of advice form the Criminal Law Team.

a. I do know of any process in contacting any engineers.

b. I have been asked why it was “against process for investigators to
approach Fujitsu engineers direct”. As stated in paragraph ‘a’ I do not
know what is meant by “against process to approach engineers direct”.

c. Jane Owen was part of the casework team and I do not recall what her

specific role was in any due process.

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d. As far as I am aware any due process would always be followed.

e. As stated I do not recall having any direct contact with Fujitsu
engineers, there may have be occasions when I have attended court
and members of Fujitsu have been called.

9. I do not fully know what Gareth Jenkins’ role was within Fujitsu.

10.1 did not know that Gareth Jenkins was considered to be an expert witness.
My understanding of an expert witness is a person who has greater
knowledge in their particular field than the ordinary person. I may have
spoken with him when at the same court, but I do not recall having any
discussions with him regarding his role.

Relationship with others

11.Any contact with Cartwright King Solicitors would have been purely a working
relationship basis. I do not recall which lawyer I dealt with for each case.

12. Any involvement with the NFSP was on a working relationship basis.

Reports & Investigations

The case of Michael Mann

13. An enquiry concerning St Annes Post Office was assigned to me. The
amount of stock purported to have been returned to Swindon did not tally with
the amount of stock received in the pouch. The stock pouches would have

been checked by the stock centre.

14.Ms Helen Rose was a work colleague within the Security Team and

performed whatever role was necessary within the team.

15.Ms Rose always behaved in a competent, professional and impeccable

manner at all times.

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16. I am not aware of any involvement Ms Rose may have had.

17. I do not recall seeing or reading document FUJ00086811.

Second Sight

18.1 do not recall being involved with Second Sight.

19.1 have been asked if I am aware that allegations were made about my

conduct to Second Sight.

a.

I was not previously aware of any allegations made about my conduct.
I have now read document POL00099689 and I can categorically state
that I have never said to any person I have interviewed and definitely
not to Jacqueline McDonald that she was the only one in that position.
I refute the allegation that I am a liar, I do not know who she was

friends with or if they were involved with the JFSA.

I also refute the claim that Jacqueline McDonald was bullied, from the
moment we arrived, the auditor was already on site, conversations
were initially with Mr McDonald, the reason for our attendance was
explained, Mr and Mrs McDonald were kept updated as the day

progressed.

Ms Katie Noblet was not bullied and was spoken to as part of the
investigation to establish the facts of the discrepancy in the accounts. I
am not sure what Jacqueline McDonald means that she (Katie Noblet)
was running the Post Office under somebody's name and was bullied
about wage deductions or jail time. Post Office Ltd could not deduct

any monies from Katie Noblet wages as she was either paid by her

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employer (Jaqueline McDonald) or her new employer the person she

was allegedly running the Post Office for on their behalf.

d. Ms Katie Noblet was not being bullied but was being asked if she
would provide a statement as part of the on-going investigation. Ms
Richards would be seeing how she was coping in running the Post

Office branch when Mr McDonald asked us to leave the shop.

e. Ms Jacqueline McDonald is also incorrect in stating Post Office
Investigators behaved like Mafia Gangsters looking to collect their

bounty with the threats and lies.

f. I would be grateful if I could have a copy from Jacqueline McDonald of

her notes of when these threats and lies were made to her.

g. Ms McDonald made no mention or made any allegation or comments
against myself or my colleagues regarding our behaviour, either during
the investigation, at the interview stage (although she did bring a friend
who was present throughout the interview) or in court by her barrister
or solicitor to either the trial judge or the prosecution barrister. I am
also not aware of any complaint being received by POL from Ms

McDonald.
RV Janet Skinner

20.! have been asked to set out my recollection of these proceedings and been

referred to a number of documents’. I was second officer to the Lead

+ {POL.00044626}, [POL00047345], [POLO0047399), [POL00047427}, [POL.00044624), [POL00044632],
{POL00044633], [PO1L00044656], [POL00044624), [POL00044625], [POL00047427}, [POL00045329].

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2

22.

23.

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Investigator on this enquiry. The Lead Investigator would ask the questions
but if appropriate on occasions the second officer would also ask questions.
At the end of the interview as the second officer I would normally oversee the
signing of the tape seals and the sealing of the master copy. Any forms that
need completing including NPA1 (Non-Police Agencies) a Notification of
Proceedings to Police and Antecedents. The Lead Investigator would submit

the file.

. There were no concerns, the investigation was conducted in a professional

manner at all times.
I do not have any other reflections about this matter.

I have looked at INQ00001035 at p25 (internal pages 97 and 98) and I can
categorically state that I have never said to any person I have interviewed
and definitely not to Janet Skinner “we have dealt with people who have
stolen from Post Offices before and like you, we know you haven't done
anything’. I did not have the jurisdiction to say anything like this nor would I
ever make this type of comments to anybody. At the end of an interview the
person would be informed of the next stages, i.e. a report would be done, and
the file sent off for advice and any decision would be made by the Legal

Department.

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Rv Hughie Thomas

24.1 have been asked to set out my recollection of these proceedings and been
referred to a number of documents?. I was second officer to the Lead
Investigator on this enquiry. A telephone call was received concerning an
audit shortage at Gaerwen Post Office branch. I travelled to Anglesey with
the Lead Investigator. Advice was taken from the Team Leader at the time,
Mr Thomas was taken by North Wales Police Offices to Holyhead where he

was interviewed.

25. There were no concerns, the investigation was conducted in a professional

manner at all times.

26.1 have no other reflections about this matter.

Rv Ishaq

27.1 have been asked to set out my recollection of these proceedings and been
referred to a number of documents*. This enquiry was assigned to me and

concerned a discrepancy in the accounts.

2 [PoLo0044861], [POLO0044862], [POL00044864], [POLO0044862], [POLO0047894], [UKGI00012481].
3 [FUJ00124337], [POLO0045133], [POLO0045 134], [POLO0065003], [POLO0046224], [POLO0046228],
[POL00046231], [POL00046235], [POLO00S7543], [POL00046242], [POLO0046243}, [POLO0046244],
[POL00046248], [POL00046249], [POLO0046250], [POLO0046253], [POLO00S7582], [POLO00S8024],
[POL00058244], [POLO0046264], [POLO0059592], [POLO0059686], [POLO0046272], (POLO00S9887],
[POLO0059602], [POLO059308}, [POL00046313], [POLO0065000], [POLO0046342}, [(POLO0046349],
[POLO0056628], [POLO0046359}, [POLO0046361], [POLO0057985], [POLO0046394], (POLO0046363],
[POLO0046381], [POL00046393}, [POL00056375], [POLO0056476], [POLO00S6548}, (POLO00S6596),
[POLOO0S6600], [POLO0057078}, [POLO0057675], [POLO00S7702], [POLO00S7967], [POLO0058022],
[POLO0058024], [POLO0058025], [POLO0058027],[POLO0058028], [POLO00S8035], [POLO0058361],
[POLOO0S8194], [POL00046243}, [POLO0059308], [POLO0059338], [POLO005944 1], [POLO0059506],
[POL000S9517], [POLO00595511], [POLO0059618], [POLO0059617], [POLO0059652], [POLO0059675],
[UKGI00001549], [UKGI00001550] [POLO059692],[POL00059729}, [POLO0059811], [POLO00S9866],
[POL00059877}, [POLO0059927}, [POLO0060315},[POLO0060567], [POL00046223], [POLO0046229],
[POL00046236], [POL00046250}, [POLO0056752],[POLO00S 7584], [POLO00S7585], [POLO00S7697],
[POL00057723], [POLO0060315].

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28. There were no concerns, the investigation was conducted in a professional

manner at all times.
29.1 have no other reflections about this matter.

30. I have been asked about the appropriateness of “placing the burden” on the
defendant to “fully particularise” any problems with Horizon before further
disclosure was made (POL00046234). I do not consider this to be a burden
on the Defendant as this enquiry concerned discrepancies due to the amount

of stock that should be on hand compared to the actual amount on hand.

3

.I have been asked about the appropriateness of the statement that POL “had
absolute confidence in the robustness and integrity of its Horizon system and
its branch accounting processes” (POL00059686). As far as I can recall this
additional statement would have been at the request of Cartwright King and
at this time the contents in the statement were considered appropriate. All
information from CLT, POL and Cartwright King was there were no issues

with the Horizon system.
R v Lisa Brennan

32.I have been asked to set out my recollection of these proceedings and
referred to a number of documents‘. This enquiry concerning the inflation of

P&A dockets.

33. There were no concerns, the investigation was conducted in a professional

manner at all times.

4 [P0L00047317], [POLO0047320], [POL00047322], [POLO0047324], [POLO0047325}, [POLO0047331],
[POL00047335], [POLO0047340], [POLO0047475}, [POLO0047491], [POLO0047492I, [POLOD047505],
[POL00047515], [POLO0047517], [POLO0047519}, [POLO0047529].

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34.1 have no other reflections about this matter.

R V Lynette Hutchings

35.1 have been asked to set out my recollection of these proceedings and
referred to a number of documents®. in this case was to report the findings of
the court case and the completion of the paperwork at the end of the enquiry

as the Investigators had left the team.
36. The only paperwork associated with me are the file completion papers.
37.1 could see no concerns about the conduct of this case.

38.1 have no other reflections about this matter.

R v Joan Bailey

39.I have been asked to set out my recollection of these proceedings and been
referred to a number of documents®. This enquiry was assigned to me
concerning a discrepancy in the accounts at the branch. Ms Bailey was
interviewed in accordance with pace and had legal representation present.

Ms Bailey received a caution.

40. There were no concerns, the investigation was conducted in a professional

manner at all times.

5 [POL00057528], [POLO00S7727], [POLO00S7750], [POLO00S7751], [POLO0057753}, [POLO0057997],
[POL000S8153], [POLO00S8334], [POLO0046635], [POLO0058350], [POLO0057597], [POLO0046712],
(POLO0057528}.

§ [POLO00S6003], [POLO00S6097], [POLO0056098}, [POLO056138], [POLO00S6144], [POLO0057198},
[POLO00S6387}, [POLO00S6388], [POLO0056389], [POLO0056477], [POLO0056629], [POLO00S7282],
{POL00060763}, [POLO00S6365].

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41.1 have no other reflections about this matter.

Rv Sefton

42.1 have been asked to set out my recollection of these proceedings and been
referred to a number of documents’. This enquiry concerning suppression of
deposit dockets was assigned to me. On the day of the audit a letter was
handed over which had been jointly prepared by both Ms Sefton and Ms
Nield stating they had been with holding customers deposits slips. The slips

had been kept in a cupboard behind the counter.

43. There were no concerns, the investigation was conducted in a professional

manner at all times.
44.1 have no other reflections about this matter.
Rv Anne Nield

45.1 have been asked to set out my recollection of these proceedings and been
referred to a number of documents (listed in items 172 to 186 of the index to
this statement). This enquiry concerning suppression of deposit dockets was
assigned to me. On the day of the audit a letter was handed over which had
been jointly prepared by both Ms Sefton and Ms Nield stating they had been
with holding customers deposits slips. The slips had been kept in a cupboard

behind the counter.

7 [POLO0043961], [POLO0044006], [POLO0044010}, [POLO0044014], [POL00044198}, [POLO0044206],
{POL00044052], [POL00057395], [POL00044006], [POLO0044198], [POLO0057435], [POLO00S 7495],
{POLO0057648}, [POLO00S7874], [POLO00S7876], [POLO0057944], [POLO0059752], [POL00060277],
[POL00044024}, [POL00044025), [POLO00S7374], [POLO0044159}, [POLO0044047], [POLO0060275).

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46. There were no concerns, the investigation was conducted in a professional

manner at all times.

47.1 have no other reflections about this matter.

Post Office v McKnight

48.1 have been asked to set out my recollection of these proceedings and
referred to a number of documents®. This enquiry concerning discrepancies
in the accounts was assigned to me. The PM did not take part in running the

branch and had installed her daughter as OIC. No prosecution took place.

49. There were no concerns, the investigation was conducted in a professional

manner at all times.

50.1 have no other reflections about this matter.

Response to Horizon Issues

51.1 have been asked to consider POL00096640 and explain why I am
mentioned in this meeting as having carried out an “independent
investigation”. It was assigned to me as an enquiry due to the branch having
a high volume of spoilt postage labels. Mr Walters (the Postmaster) was
interviewed in accordance with PACE. It was established they were unsure of
the procedures and what the difference is between a spoilt label (when
payment is expected) and a rejected label (when no payment is due). The
matter was dealt with by the Contracts team and no further action was taken

by the Security Team.

8 [POL00069229], [POLO0069249], [POLO0069265], [POLO0072167], [POLO0072294], [POLO0072295],
[POL00072296], [POLO0072291}, [POLO0095382], [POLO0069230], [POLO0072168], [POLO0073930).

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52. I was not involved with Lord Arbuthnot or attended any other meetings with

public officials relating to the response to Horizon issues.
General

53.1 have been asked to what extent I considered a challenge to the integrity of
Horizon in one case to be relevant to other ongoing or future cases. Each

and every case were treated on their own merits.
54.1 do not know what technical issues were investigated by POL.

55. Any technical issues would be dealt with by the relevant team at Fujitsu and

dealt with by them and POL.

56.1 cannot recall, if any, what information I received concerning bugs, errors

and defects in the Horizon system.

57.1 do not have any reflections on these matters or other matters relevant to the

TOR.
58.1 do not wish to bring any other matters to the attention to the Chair.

Statement of Truth

I believe the content of this statement to be true.

Dated: 26 June 2023

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Index to First Witness Statement of STEPHEN BRADSHAW

URN

Document Description

Control Number

FUJ00122938

Email from Penny Thomas to
Gareth Jenkins re: Report -
Rinkfield

POINQ0129152F

FUJ00122939

Gareth Jenkins comments
on Rinkfield Report

POINQ0129153F

FUJ00086811

Horizon data, Lepton
SPSO 191320, Draft
Report by Helen Rose

POINQ0092982F

POLOO099689

Post Office Limited
Application Form -
Jacqueline McDonald

POL-0099272

POL00096640

Post Office Pack for
meeting with James
Arbuthnot and other MPs
Meeting scheduled for
18th June 2012, 6pm,
Portcullis House.

POL-0096223

POL00046234

Memo from Maureen
Moors (Post Office Fraud
Team) to the Royal Mail
Group (Criminal law team)
re Khayyam Ishaq -
Requesting evidence be
reassessed in light of
further enquiries by Steve
Bradshaw, Fraud Advisor

POL-0042713

POLO0059686

Witness Statement of
Stephen Bradshaw re
Second Sight appointment

POL-0056165

POL00044626

Post Office Limited Interim
Report for Jane Louise
Skinner (North
Bransholme
branch/POLTD/0607/0108)

POL-0041105

POL00047345

Witness Statement of
Diane Sarah Matthews re
Janet Skinner case

POL-0043824

10.

POL00047399

Witness Statement of
Stephen Bradshaw
(unsigned) in relation to
the Janet Skinner matter

POL-0043878

11.

POL00047427

Janet Skinner case study:
Notebook Entry by
Stephen Bradshaw re
Janet Skinner

POL-0043906

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12.

I POL00044624

Post Office Ltd Interim
Report for Janet Skinner
(North Bransholme
branch)

‘I POL-0041103

13.

POL00044632

Interview Transcript -
Janet Louise Skinner

POL-0041111

14,

POL00044633

Summary of tape recorded
interview - Janet Louise
Skinner

POL-0041112

15.

POL00044656

Summary of tape recorded
interview - Janet Louise
Skinner

POL-0041135

16.

POL00044625

Investigation Report
(Personnel) by Diane
Matthews - Janet Louise
Skinner

~ I POL-0041104

17.

POL00045329

Notebook Entry from
Stephen Bradshaw re
Janet Skinner Interview

POL-0041808

18.

INQ00001035

Transcript (25/02/2022):
Post Office Horizon IT
Inquiry - Ms Stephanie
Reilly [WITNO318], Ms
Tracy Felstead
[WITN0319], Mrs Seema
Misra [WITNOO65], Ms
Janet Louise Skinner
[WITNO126].

INQ00001035

19.

POL00044861

Investigation Discipline
Report by Diane Matthews
- Hughie Noel Thomas

POL-0041340

20.

POL00044862

Investigation Offender
Report by Diane Matthews
~ Hughie Thomas

POL-0041341

21.

POL00044864

Summary of tape-
recorded interview of
Hughie Thomas -
conducted by Diane
Matthews and Stephen
Bradshaw.

POL-0041343

22.

POL00047894

Hughie Thomas case
study: Unsigned witness
Statement of Stephen
Bradshaw re Hughie Noel
Thomas

POL-0044373

23.

UKGI00012481

Noel Thomas Case Study:
Witness Statement of
Diane Sarah Matthews

UKG1I023277-001

24.

FUJ00124337

Comments on Defence
Expert's Report by Gareth
Jenkins - R v Khayyam
Ishaq

: POINQ0130551F

Page 16 of 31
25.

WITN04450100
WITN04450100

POL00045133

Khayyam Ishaq case
study: Interview of
Khayyau Ishaq -
conducted by Stephen
Bradshaw - Time
commenced - 12:11 and
Time Completed - 12:55
(undated)

POL-0041612

26.

POL00045134

Advice on Evidence in R v
Khayyam Ishaq

POL-0041613

27.

POL00065003

Stakeholder notification of
audit results following
audit at Bradford road PO.

POL-0061482

28.

POL00046224

Investigation (Legal)
Offender Report by
Stephen Bradshaw —
Khayyam Ishaq

POL-0042703

29.

POL00046228

Memo from Rob Wilson re
Ishaq case

POL-0042707

30.

POL00046231

Email from Stephen
Bradshaw to Paul Williams
re suspect offender
reporting - 2nd interview -
Khayyam Ishaq

~ I POL-0042710

31.

POL00046235

Memo from Rob Wilson to
Maureen Moors re Post
office LTD v Khayyam
Ishaq case
POLTD/1011/0186

32.

POL00057543

Khayyam Ishaq case
study: POL v Khayyam
Ishaq - Advice from
Counsel Martin Smith of
Cartwright King

POL-0054022

33.

POL00046242

Email from Martin Smith to
Sarah Porter regarding
Post Office Ltd - 24676 -
Prosecution of Ishaq

POL-0042721

34.

POL00046243

Email from Cartwright King
to Stephen Bradshaw re
Ishag case

POL-0042722

35.

POL00046244

Letter from Musa Patels
Solicitors to Cartwright

King solicitors regarding
Khayyam Ishaq Bradford
Crown Court 4th
September 2012

POL-0042723

36.

POL00046248

Letter from Musa Patel
Solicitors to Martin Smith
regarding Khayyam Ishaq
- trial at Bradford Crown
Court - 25th Feb 2013

I POL-0042727

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37.

POL00046249

Investigation Report by
Stephen Bradshaw re
Khayyam Ishag

POL-0042728

38.

POL00046250

Email from Stephen
Bradshaw to Paul X
Williams and John
Breeden re Case Closure
Reporting - Khayyam
Ishaq

POL-0042729

39.

POL00046253

Khayyam Ishaq Summons,
4th April 2012

POL-0042732

40.

POL00057582

Witness Statement of
Stephen Bradshaw dated
2012

POL-0054061

41.

POL00058024

Witness Statement of
Stephen Bradshaw re
Khayyam Ishaq case

POL-0054503

42.

POL00058244

Defence Case Statement
in the case of Rv
Khayyam Ishaq

POL-0054723

43.

POL00046264

Witness Statement of
Stephen Bradshaw -
Khayyam Ishag case

POL-0042743

44,

POL00059592

Witness Statement Post
Office Ltd Stephen
Bradshaw POL 011
Version April 2012

POL-0056071

45.

POLO0059686

Witness Statement of
Stephen Bradshaw re
Second Sight appointment

POL-0056165

46.

POL00046272

Witness Statement of
Stephen Bradshaw -
Khayyam Ishag case

POL-0042751

47.

POL00059887

Witness Statement of
Stephen Bradshaw

POL-0056366

48.

POLO0059602

Comments on Ishaq Docs
by Gareth Jenkins

POL-0056081

49.

POL00059308

Advice on Evidence -
Khayyam Ishaq (amended)
- Rachel Panter

POL-0055787

50.

POL00046313

Khayyam Ishaq Case
Study: Stephen Bradshaw
- Notebook Entry re Ishaq
interview

POL-0042792

51.

POLO0065000

Typed copy of Notebook
Entry from Post Office Ltd
Fraud Strand

POL-0061479

52.

POL00046342

Letter from Stephen
Bradshaw to Khayyam
Ishaq in re to Birkenshaw
post office branch.

POL-0042821

Page 18 of 31
WITN04450100
WITN04450100

53.

POL00046349

Interview of Khayyam
Ishaq - conducted by
Stephen Bradshaw -

POL-0042828

54,

POL00056628

Letter from Stephen
Bradshaw to Khayyam
Ishaq re: Birkenshaw Post
office Branch

POL-0053107

55.

POL00046359

Typed copy of notebook
entry from Steve
Bradshaw's notebook
regarding the Khayyam
Ishag matter

POL00046359

56.

POL00046361

Email from Stephen
Bradshaw to Khayyam
Ishaq re letter of
undertaking and second
interview

POL-0042840

57.

POL00057985

Khayyam Ishaq case
study: Summary Record of
Taped Interview

POL-0054464

58.

POL00046394

Email chain between
Stephen Bradshaw and
Khayyam Ishaq re letter of
undertaking

POL-0042873

59.

POL00046363

Email from Stephen
Bradshaw to Khayyam
Ishaq re letter of
undertaking.

POL-0042842

60.

POL00046381

Email from Stephen
Bradshaw to Helen
Dickson re FES - Case
Number:
POLTD/1011/0186 -
Branch - Birkenshaw -
Branch Code - 163 306 -
Interview of Khayyam
Ishaq

POL-0042860

61.

POL00046393

Email from Stephen
Bradshaw to Khayyam
Ishaq re outstanding debt

POL-0042872

62.

POL00056375

Email from Stephen
Bradshaw to Paul X
Williams re: Fraud -
suspect offender
reporting, Khayyam Ishaq

POL-0052854

63.

POL00056476

Financial Investigation
Sheet - Khayyam Ishag

POL00056476

Page 19 of 31
WITN04450100
WITN04450100

64,

POL00056548

Khayyam Ishaq case
study: Memo from Rob
Wilson to Maureen Moors,
Stephen Bradshaw re Post
Office Ltd v Khayyam
Ishaq

POL-0053027

65.

66.

POLO0056596

Memo from Rob G Wilson
to Maureen Moors cc
Stephen Bradshaw re:
POSTVOFFICE LTD -v-
KHAYYAM ISHAQ

POL-0053075

POL00056600

Memo from Rob Wilson to
Maureen Moors re
Khayyam Ishaq further
interview

POL-0053079

67.

POL00057078

Khayyam Ishaq case
study: Investigation
(Legal) report by Stephen
Bradshaw re Khayyam
Ishaq

POL-0053557

68.

POL00057675

Khayyam Ishaq case
study: Email from Martin
Smith to Stephen
Bradshaw re disclosure
bundle for Ishaq case

POL-0054154

POL00057702

Email from Stephen
Bradshaw to Helen
Dickinson re: Birkenshaw/
Khayyam Ishaq case

POL-0054181

70.

POLO0057967

Email from Martin Smith to
Steve Bradshaw re: Case
no. 246767 - Prosecution
of Ishaq

POL-0054446

71.

POL00058022

Note for Case 24676, re:
Prosecution of Ishaq.

POL-0054501

72.

POL00058024

Witness Statement of
Stephen Bradshaw re
Khayyam Ishaq case

POL-0054503

73.

POL00058025

Schedule of Non Sensitive
Unused material -
Khayyam Ishag case

POL-0054504

74,

POL00058027

Schedule of Sensitive
Unused Material by the
Post Office Ltd -
Confidential in the case of
R v Ishag.

POL-0054506

75.

POL00058028

Disclosure Officer's Report
by the Post Office Ltd -
Confidential in the case of

POL-0054507

Page 20 of 31
WITN04450100
WITN04450100

76.

POLO0058035

Witness Statement of
Stephen Bradshaw re
Khayyam Ishag case

POL-0054514

77.

POL00058361

Khayyam Ishaq case
study: Brief for the
Prosecution (In the case
of R v Khayyam Ishaq)

POL-0054840

78.

POL00058194

Email from Martin Smith to
Stephen Bradshaw re:
Prosecution of Khayyam
Ishaq

POL-0054673

79,

POL00046243

Email from Cartwright King
to Stephen Bradshaw re
Ishag case

POL-0042722

80.

POL00059308

Advice on Evidence -
Khayyam Ishaq (amended)
- Rachel Panter

POL-0055787

81.

POL00059338

Email from Martin Smith to
Steve Bradshaw re
prosecution case -
Khayyan Ishaq

POL-0055817

82.

POL00059441

Witness Statement of Lee
Heil - Khayyam Ishag case

POL-0055920

83.

POLO00059506

Khayyam Ishaq case
study: Email from Martin
Smith to Mark Ford RE:
Post Office Ltd- 24676-
Prosecution of Ishaq

POL-0055985

84.

POLO0059517

Letter from Cartwright
King to Ishaq Defence
Solicitors re response to
letter concerning problems
with Horizon system

POL-0055996

85.

POL00059551

Khayyam Ishaq Case
Studies - Email from
Martin Smith (Cartwright
King) to Stephen
Bradshaw re Post Office
Ltd - 2476 - Prosecution of
Ishag

POL-0056030

86.

POLO0059618

Email from Martin Smith to
Stephen Bradshaw re
letter from Defence
Solicitors in Ishaq case

POL-0056097

87.

POL00059617

Notice of Additional
Evidence - Khayyam Ishag

POL-0056096

88.

POL00059652

Email from Martin Smith to
Stephen Bradshaw re
Ishaq mention hearing

POL-0056131

Page 21 of 31
89.

POL00059675

Letter from Musa Patels
LLP Solicitors to Martin
Smith , Re: Khayyam
Ishaq Trial at Bradford
Crown Court 25 February
2013

POL-0056154

WITN04450100
WITN04450100

90.

UKGI00001549

Email from Martin Smith to
Stephen Bradshaw & Mark
Ford re Sharron Jenning
statement - Ishaq case
(date taken from
attachment)

UKGI012363-001

91.

UKGI00001550

_Post Office Review

Witness Statement of
Sharron Lisa Jennings -

UKGI012364-001

92.

POLO0059692

Khayyam Ishaq Case
Study: Email from Martin
Smith to Mark Ford re
Post Office Ltd - 24676 -
Prosecution of Ishaq

POL-0056171

93.

POL00059729

Email from Cartwright King
to Defence Solicitors re
additional evidence -R v
Khayyam Ishaq re.
disclosure and asking for
evidence of malfunctions.

POL-0056208

94.

POL00059811

Email from Martin Smith to
Steve Bradshaw re. Post
Office - 24676 -
Prosecution of Ishaq

POL-0056290

95.

POLO0059866

Email from Martin Smith to
Steve Bradshaw re. FW:
Ishag

POL-0056345

96.

POL00059877

Khayyam Ishaq Case
Study: Email from Martin
Smith to Mark Ford re.
Post Office - 24676 -
Prosecution of Ishaq

POL-0056356

97.

POL00059927

Expert Report of Beverley
Ibbotson & joint statement
of Beverley Ibbotson and
Gareth Jenkins rerv
Ishag

POL-0056406

98.

POL00060315

Khayyam Ishaq case
study: Email from Martin
Smith to Mark Ford re. Rv

Ishaq

POL-0056794

Page 22 of 31

99.

POLO0060567

Witness Statement of
Stephen Bradshaw re:
Khayyam Ishaq relating to
horizon balances from
new submaster being
found in the bin and
supporting Ishaq's case

POL-0057046

WITN04450100
WITN04450100

100.

POL00046223

Email from Steve
Bradshaw to Paul X
Williams in re : Fraud
Suspect Offender
Reporting Khayyam Ishaq

POL-0042702

101.

POL00046229

Khayyam Ishaq case study
- Memo from Stephen
Bradshaw to Legal
services in re to Mr
Liaquat

POL-0042708

102.

POL00046236

Memo from Stephen
Bradshaw to Rob Wilson
in re to Ishag case

I POL-0042715

103.

104. I

POL00046250

Email from Stephen
Bradshaw to Paul X
Williams and John
Breeden re Case Closure
Reporting - Khayyam
Ishaq

POL-0042729

I POLO0056752

Email from Steve
Bradshaw to Helen
Dickinson re: Fl Update

POL-0053231

105.

POL00057584

Khayyam Ishaq Case
Study: Witness Statement
of Kevin Ryan re Khayyam
Ishaq case

POL-0054063

106.

POL00057585

Khayyam Ishaq Case
Study: Witness Statement
of Andrew Wise re
Khayyam Ishag case

POL-0054064

107.

POL00057697

Email from Steve
Bradshaw to Martin Smith,
RE: Birkenshaw
statements - Khayyam
Ishaq

POL-0054176

108.

POL00057723

Email from Steve
Bradshaw to Martin Smith,
RE: Birkenshaw Brnch
Statements - Khayyam
Ishaq

POL-0054202

109.

POL00047317

Transcript of tape
recorded interview under
caution of Lisa Brennan

POL-0043796

Page 23 of 31
WITN04450100
WITN04450100

110.

POL00047320

Lisa Brennan case study:
Record of tape recorded
interview in re to Lisa
Brennan.

POL-0043799

a

POL00047322

Summary Record of Tape
Recorded Interview for
Lisa Margaret Brennan.

POL-0043801

112.

POL00047324

Report from S Bradshaw
to Jan Mullin re audit
investigation and
suspension of Lisa
Brennan

POL-0043803

113.

POL00047325

Investigation - Pension
and allowance Fraud -
Lisa Margaret Brennan.

POL-0043804

114.

POL00047331-

Internal memo from
Teresa Berridge to
Prosecution Support
Office, Leeds re: Lisa
Margaret Brennan

POL-0043810

115.

POL00047335

Lisa Brennan case study:
Interoffice Memorandum
from Steven Bradshaw to
Teresa Berridge re: Lisa
Margaret Brennan.

POL-0043814

116.

POL00047340

Lisa Brennan case study:
Interoffice memorandum

from Steve Bradshaw to

Teresa Berridge re: Lisa

Margaret Brennan

POL-0043819

117.

POL00047475

Lisa Brennan case study:
Interoffice Memorandum
From Steve Bradshaw to
Teresa Berridge re: Lisa
Margaret Brennan Paper
NOS: 7746/3415

POL00047475

118.

POL00047491

Disclosure Officer's Report
- Lisa Margaret Brennan

POL-0043970

119.

POL00047492

Schedule of sensitive
material in relation to Lisa
Margaret Brennan's
prosecution

POL-0043971

120.

POL00047505

Internal Memo from
Teresa Berridge to
Stephen Bradshaw re Lisa
Margaret Brennand

POL-0043984 I

121.

POL00047515

Memo from Steve
Bradshaw to John Gibson

re: Lisa Margaret Brennan

POL-0043994

Page 24 of 31
WITN04450100
WITN04450100

122.

POL00047517

Schedule of Non-
Sensitive, unused Material
in re to Lisa Margaret
Brennan. - Version 3.0
11/02.

POL-0043996

123.

POL00047519

Lisa Brennan Case Study:
Internal Memo from
Stephen Bradshaw to Miss
JS Andrews re Lisa
Margaret Brennan

POL-0043998

124,

POL00047529

100057528

Post Office Report of
prosecution — Lisa
Brennan written by S
Bradshaw

POL-0044008

“Interim/Current Status
Report - Lynette Hutchings
2012

‘I POL-0054007

POL00057727

Schedule of Sensitive
Material, R v Lynette Jane
Hutchings, Investigation
Schedule

POL-0054206

127.

POL00057750

Letter from Mr Steve
Bradshaw to Miss Rachel
Panter re: Committal
bundle for R v Lynette
Hutchings

POL-0054229

128.

POL00057751

Investigation Schedule
non-sensitive - Lynette
Jane Hutchings

POL-0054230

129.

POL00057753

Disclosure Officer's report
- Lynette Jane Hutchings
case study

POL-0054232

130.

POL00057997

Email from Martin Smith to
Steve Bradshaw re: Case
No. 22796 - Prosecution of
Lynette Jane Hutchings

POL-0054476

131.

POL00058153

Lynette Hutchings case
study: Email from Martin
Smith to Stephen
Bradshaw re attendance
note for Lynette Hutchings
case and costs

POL-0054632

132.

POL00058334

Internal Memo re Lynette
Hutchings

POL-0054813

133.

POL00046635

Report: Case Closure
reporting in re to
Rowlands castle dated
26/09/2012.

POL-0043114

Page 25 of 31
134.

POL00058350

WITN04450100
WITN04450100

Lynette Hutchings Case
Study: Case Closure
Reporting re: Lynette
Hutchings (Rowlands
Castle branch)

POL-0054829

135.

POL00057597

Lynette Hutchings case
study: Note for case
22796-Prosecution of
Hutchings

POL-0054076

136.

POL00046712

Case file event log report
in relation to Rowlands
Castle Post Office
(Lynette Hutchings case
study)

POL-0043191

137.

POL00057528

Interim/Current Status
Report - Lynette Hutchings
2012

POL-0054007

138.

POLO00056003

Letter from Stephen
Bradshaw to Joan Bailey
re interview following audit

POL-0052482

139.

POL00056097

Letter from Stephen
Bradshaw to Andrew
Tench re arrangement of
Joan Bailey interview.

140.

POLO005S6098

Letter from Stephen
Bradshaw to Joan Bailey
re arrangement of
interview.

POL-0052577

141.

POL00056138

Email from Stephen
Bradshaw to Colin Burston
re Joan Bailey re suspect
offender reporting

POL-0052617

142.

POLO00056141

Notebook Entry from
Stephen Bradshaw re
Joan Bailey interview

POL-0052620

143.

POL00057198

Post Office Ltd
investigation report for
Joan Bailey

POL-0053677

144.

POL00056387

Joan Bailey - Record of
Taped Interview, Date of
Interview: 9.3.11

POL-0052866

145.

POLO0056388

Joan Bailey - Record of
Taped Interview, Time
commenced: 13.14, Time
concluded

POL-0052867

146.

POL00056389

Joan Bailey - Record of
Taped Interview

POL-0052868

147.

POL00056477

Memo from Jarnail Singh
to Post Office Security re:
Post Office Limited v Joan
Francis Bailey

POL-0052956

Page 26 of 31
WITN04450100
WITN04450100

148.

POLO0056629

Letter from Stephen
Bradshaw, Fraud
Investigator to Mrs Joan
Bailey Re: Howey Post
Office Branch

POL-0053108

149.

POL00057282

Letter from Steve
Bradshaw to Colin
Burston, RE: Case closure

POL-0053761

150.

POL00060763

Outcome report to Joan
Francis Bailey

POL-0057242

151.

POL00056365

Post Office - Record of
Forms / exhibits shown at
Interview - Joan Bailey

POL-0052844

152.

POL00043961

Record of Taped Interview
- Angela Sefton
interviewed by Stephen
Bradshaw and Kevin Ryan

POL-0040440

153.

POL00044006

Email from Stephen
Bradshaw to Paul Williams
and John Breeden re
offender reporting
Fazakerley Branch-
Angela Sefton

POL-0040485

154.

POL00044010 —

Interview record - Angela
Sefton interviewed by
Stephen Bradshaw

POL-0040489

155.

POL00044014

Angela Sefton and Anne
Nield case study: Letter
from Cartwright King to
Security Team re POL v
Angela Mary Sefton and
Anne Nield

POL-0040493

156.

POL00044198

Angela Sefton and Anne
Nield case study: List of
Offences Report by
Stephen Bradshaw re:
Fazakerley Branch

POL-0040677

157.

POL00044206

Letter from Hogan Brown
Solicitors to Mr S
Bradshaw, Re Post office
v Mrs Angela Sefton.

POL-0040685

158.

POL00044052

Typed copy of Notebook
Entry re Anne Nield and
Angela Sefton Clerks at
Fazakerley branch

POL-0040531

159.

POL00057395

Notebook Entry by Steve
Bradshaw re: Angela
Sefton

POL-0053874

160.

POL00057435

Angela Sefton case study:
Record of Taped Interview
— Angela Sefton

POL-0053914

Page 27 of 31
WITN04450100
WITN04450100

161.

POL00057495

Angela Sefton and Ann
Nield Case Study: Letter
from Andrew Bolc to Post
Office Ltd, RE: POL v
Angela Marty Sefton and
Anne Nield

POL-0053974

162.

POL00057648

Post Office Ltd, Record of
forms/exhibits shown at
interview. Persons
interviewed- Anne Nield,
Angela Sefton _

163.

POL00057874

Disclosure Officer's report I

Angela Sefton (no entries)

POL-0054127

I POL-0054353

164.

POL00057876

Angela Sefton case study:
Schedule of non sensitive
unused material-
investigation
commencement date form
- Rv Angela Mary Sefton

POL-0054355

165.

POL00057944

Schedule of non-sensitive
unused material- R v
Angela Mary Sefton

POL-0054423

166.

POLO0059752

Schedule of non-sensitive
unused material - Angela
Sefton investigation

POL-0056231

167.

POL00060277

Letter to Hogan Brown
Solicitors from Andrew
Bolc re. Letter to Defence
where there is material to
disclose - ongoing
disclosure (defence case
statement) R v Angela
Sefton & another

POL-0056756

168.

POL00044024

Report outlining Anne
Nield and Angela Sefton's
prosecutions - Fazakerley
Branch

POL-0040503

169.

POL00044025

Email from Stephen
Bradshaw to Paul Williams
and John Breeden re case
closure -
POLTD/1112/0208 -
Fazakerley Branch/
Angela Sefton

POL-0040504

170.

POL00057374

Field Support Team-
Event Capture Form
Fazakerley - Sefton &
Nield

POL-0053853

171.

POL00044159

Email from Paul X
Williams to Tim Gordon-
Pounder re audit of
Fazakerley Branch

POL-0040638

Page 28 of 31
WITN04450100
WITN04450100

172.

POL00044047

Unsigned Witness
statement of Stephen
Bradshaw - Fazakerley
Branch.

POL-0040526

173.

POL00060275

Witness Statement of
Stephen Bradshaw -
Fazakerley Post Office —
Nield & Sefton

POL-0056754

174.

I POL00057413 I

Email from Stephen
Bradshaw to Paul Williams
and John Breeden re
Offender Reporting
Fazakerley Branch - Anne
Nield

175.

POL00044009

Investigation Report by
Stephen Bradshaw re
Fazakerley Branch - Anne
Nield

POL-0040488

176.

POL00057389

Royal Mail Group, Record
of Taped Interview Anne
Nield

POL-0053868

177.

POL00057350

Schedule of Non Sensitive
Unused Material, R v
Anne Nield

POL-0053829

178.

POL00057396

Steven Bradshaw
Notebook Entry, RE:
Fazakerley PO (Anne
Nield)

POL-0053875

179.

POL00057413

Email from Steve
Bradshaw to Paul X
Williams, John Breeden,
RE: Offender Reporting-
POLTD- Branch-
Fazakerley- Suspects
name- Nield

POL-0053892

180.

POL00044028

Witness Statement of
Kevin Ryan - Fazakerley
Branch.

POL-0040507

181.

POL00044027

Witness Statement of
Stephen Bradshaw -
Fazakerley Branch

POL-0040506

182.

POL00057806

Anne Nield case study:
Letter enclosing committal
bundle for Anne Nield from
Stephen Bradshaw to
Cartwright King

POL-0054285

183.

POL00057809

Anne Nield case study:
Disclosure Officer's report

POL-0054288

184.

POL00057810

Schedule of sensitive
material - Anne Nield

POL-0054289

Page 29 of 31
WITN04450100
WITN04450100

185.

POL00058307

Witness Statement of
Stephen Bradshaw
(signed) - Ann Nield /
Angela Sefton case

POL-0054786

186.

POL00059750

Schedule of Non-Sensitive
Unused Material - Anne
Nield

POL-0056229

187.

POL00060246

Email from Defence
Solicitors (Laurence Lee &
Co) to Cartwright King re
Anne Nield

POL-0056725

188.

POLO0057812

Investigation Schedule,
Schedule of non sensitive
Unused material - Anne
Nield

POL-0054291

189.

POL00069229

Investigation (personnel)
Report by Stephen
Bradshaw re Suzanne

McKnight

POL-0065792

190.

POL00069249

Email from Kathryn
Alexander to Steve
Bradshaw re investigation
of Susan McKnight

~ I POL-0065812

191.

POLO0069265

Financial Investigation
Events Log - Suzanne
McKnight

POL-0065828

192.

POL00072167

Interview record of
Suzanne McKnight

POL-0068730

193.

POL00072294

Internal Memo from Terry
Crowther to Stephen
Bradshaw re Suzanne
McKnight file

POL00072294

194.

POL00072295

Memo from Rob Wilson to
Fraud Team cc Stephen
Bradshaw Re: POL v
Suzanne Elizabeth
McKNIGHT - further
inquiries

POL-0068858

195.

POL00072296

Email from Stephen
Bradshaw to Paul X
Williams re Stakeholder
Notification on Suzanne
McKnight

POL-0068859

196.

POL00072291

Email from Stephen
Bradshaw to Paul X
Williams re Case Closure
Reporting -
POLTD/0809/0102 —
Suzanne McKnight

POL-0068854

197.

POL00095382

Spreadsheet of SPMs in
debt to Post Office
(c.2002-2010)

POL-0094965

Page 30 of 31
WITN04450100
WITN04450100

198.

POL00069230

Investigation (Legal)
report by Stephen
Bradshaw regarding
Suzanne Elizabeth
McKnight

POL-0065793

199.

POL00072168

Interview record of
Suzanne McKnight

POL-0068731

200.

POL00073930

Email from Paul Williams
to Joanne
Shelton/Stephen
Bradshaw re termination
of Susan McKnight
contract

POL-0070493

Page 31 of 31