WITN04450200
WITN04450200
Witness Name: Stephen BRADSHAW
Statement No: WITN04450200 I
Dated: i 6 October 2023
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POST OFFICE HORIZON IT INQUIRY
SECOND WITNESS STATEMENT OF STEPHEN BRADSHAW
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I, STEPHEN BRADSHAW, will say as follows;
1. This witness statement is made to assist the Post Office Horizon IT Inquiry
with the matters set out in the Rule 9 meer dated 26 September 2023.
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Please provide a full account of your involvement in and recollection of the
criminal prosecution of Grant Allen. To assist you in providing this account,
please consider the documents referred to below. Your account should
address but is not limited to the questions set out below.
. This enquiry was assigned to myself and Mr Allen was interviewed in
accordance with PACE on 12 April 2012. He declined to have a solicitor or a
Post Office friend present during the interview (forms POLO01 — Legal rights
and POL003 — POL employees’ rights to a friend at interview were signed by
him). !
. During the interview he stated he was unsure if he needed a solicitor and the
interview was suspended. He then changed his mind and wished to continue
without a solicitor (Form POL002 — Agreement to continue without Legal
Advice was signed by him), before the interview recommenced authority was
obtained from David Pardoe Senior Security Manager. At the end of interview
Mr Allen was given a form (POL019 — notice to person whose interview has
been audio recorded), Forms NPAO01 (Notification of Proceedings to Police)
and POL033 (Antecedents) were completed.
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4. Mr Allen was informed a report would be submitted to the CLT / Cartwright
King for advice. The advice was received, and summons obtained and served
on Mr Allen.. Mr Allen would appear at the magistrates and further I
progression of the case would be managed by the CLT/CWK to the I
conclusion of the prosecution. The relationship of myself to CLT / CWK was I
similar to the police working with the cps. { I
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5. I have been asked to consider the followingidocuments: ]
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a) The Winsford Branch relocation timescale of events [POL00089655]; I
b) The NSBC call logs for Winsford Branch: [POL00089666];
c) The draft witness statement of Richard Cross [POL00089071];
d) The record of conversation with Mr Allen [POL00089080];
e) The final branch trading statement [POL00089089]; ! I
f) The Horizon Non Polling Report [POL00089563});
; g) The bundle of documents at [POLO0089486];
h) The letter from Stephen Bradshaw to Grant Allen, dated 8 February 2012 i
[POL00089238};
i) The letter from Stephen Bradshaw to Grant Allen, dated 21 March 2012
[POL00089124];
j) The letter from Stephen Bradshaw to Grant Allen, dated 5 April 2012
[POL00089243];
k) The record of the taped interview, dated'19 April 2012 [POL00089457];
1) The investigation report (legal), authored by Stephen Bradshaw, dated 1
May 2012 [POL00089464)]; : I
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m) The letter from Andrew Bolc, dated 4 July 2012 [POL00089454];
n) The PNC Record for Grant Allen (dated 12 July 2012) [POL00089145);
0) The letter from Stephen Bradshaw, dated 8 August 2012, enclosing the
summons [POL00089332]; I
p) The indictment [POL00089369];
q) The letter from Andrew Bolc to Maidments Solicitors Ltd, dated 22
November 2012 [POL00089376];
r) The letter from Simon Clarke to Maidments Solicitors Ltd, dated 25 July
2013 [POL00089682];
s) The emails, dated December 2012 [POL00089380];
t) The witness statement of Gareth Jenkins [POL00089077] and exhibits
GlJ/1 [POL00086089] and exhibit GlJ/2 [POL00089115);
u) The Notice of Additional Evidence, dated 18 December 2012
[POL00089063}; I
v) The brief for prosecution counsel [POL00089367];
w) The emails dated January 2013 [POL00089416];
x) The letter from Stephen Bradshaw, dated 30 January 2013
[POLO0089065);
y) The Final Result Sheet [POL00089446].
. I confirm I have considered these documents in the course of producing my
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witness statement but have no specific comments about individual I
documents.
How and when did you first become involved in the Grant Allen case?
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7. This enquiry for Winsford Post Office branch was allocated to me on or about I
the 7 February 2012.
Who authorised the prosecution of Grant Alien?
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8. The advice to prosecute would have been given by the CLT / Cartwright King.
David Pardoe Senior Security Manager was on behalf of POL, the Designated
Prosecution Authority Manager. The Designated Prosecution Authority
Manager would have sight of the file and give authority to proceed on the
advice given by CLT / Cartwright King. (
What evidence was obtained and relied upon by the Post Office in these
proceedings and what was it obtained to adiress?
9. At interview Mr Allen was shown the Record of the Conversation he had with
the auditors, the cash declaration, Branch Trading Statements, cash
declaration, auditors report. In addition to the above the tape transcripts would
have also been provided but the matter did not proceed to trial as Mr Allen
entered a plea at the PC&MH. ; I
Was any Horizon data (and in particular ARQ logs) requested from Fujitsu in
this case?
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10.1 do not recall any ARQ data being requested. Horizon data would be Cash '
declarations — Balance snapshots and Branth Trading Statements. If ARQ
data was required the investigating Officer viould submit a request to the
Casework team who would subsequently request the data from Fujitsu.
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Who was the disclosure officer in this case?
11.Any disclosure would be in the first instance by me as the Investigation Officer I
at interview, in this case no solicitor was present as Mr Allen declined legal I I
representation. If the matter proceeded to court then the following documents I
would be completed for any committal: Self disclosure of Investigators
disciplinary record; Non sensitive unused material; Sensitive unused material; I
Disclosure officers report (material that may:undermine the prosecution case
or assist the defence); Witness list including availability and contact details
and the Exhibits list . After the matter had been listed for court any further
evidence would be sent to the lawyers (CLT / Cartwright Wright King) with a
statement who would then serve the evidence to the defence.
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Who was the investigation manager in this case? I
12. The enquiry was assigned to me and Mr Andrew Wise was the 2" Officer.
Please explain your role in relation to disclosure in these proceedings. I
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13.Any material to be disclosed would be exhitited in a statement and passed to I
the CLT or Cartwright King. They as their ccntinuing.duty would disclose the
material to the defence. I
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Who was prosecution counsel in this case? Please provide details of your role i I
in instructing counsel.
14. Prosecution counsel was Mr John Gibson . Vr Gibson would have been
instructed by Cartwright King. I did not spec fically ask. for any particular
counsel and I had no input into this. I
Please describe any discussions you had with counsel instructed by POL to
prosecute this case. f
15. If required a case conference would take place at Chambers but I do not I
recall any conference taking place. Otherwi¢e any instructions would be via
the Royal Mail Group Criminal Law Team or Cartwright King.
Please describe any further involvement you had in this case.
16.1 do not recall any further involvement with this case after the court case
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concluded.
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What are your reflections now on the way the investigation and prosecution of
Grant Allen was conducted by the Post Offiée and the outcome of the case?
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17.The Investigation of Grant Allen was conducted in a professional manner at all
times. If any issues regarding bugs were declared by POL during this I
investigation, then any issues would have been looked at in depth to ascertain
if there was any impact on this enquiry.
18.1 believe that the facts contained in this witness statement are true.
Dated: 16 October 2023
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Index to Second Witness Statement of Stephen’ Bradshaw
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No. URN Document Descriptio. Control Number I
1. I POL00089655 II Winsford Branch relocation timescale of POL-0086630
events I i
2. _I POLO0089666 II NSBC call logs for Winsford Branch POL-0086641 I
3. _I POLO0089080 I Draft witness statement of Richard Cross I POL-0086055
4. _I POL00089080 I Record of conversation with Mr Allen POL-0086055
5. I POL00089089 II Final branch trading statement POL-0086064
6. _I POL00089563 II Horizon Non Polling Réeport POL-0086538 L
7. _I POL00089486 I bundle of documents ! POL-0086461 I
8. I POLO0089238 I Letter from Stephen Bradshaw to Grant POL-0086213 I
Allen dated 8 February. 2012
9. I POL00089124 I Letter from Stephen Bradshaw to Grant POL-0086099 \
Allen, dated 21 March 2012 I
10. I POL00089243 I letter from Stephen Bradshaw to Grant POL-0086218 I
‘I Allen, dated 5 April 2042 II
11. I POL00089457 I Record of the taped interview, dated 19 POL-0086432
April 2012 I
12. I POL00089464 II Investigation report (legal), authored by POL-0086439 I
Stephen Bradshaw dated 1 May 2012
13. I POL00089454 I Letter from Andrew Bolc, dated 4 July POL-0086429 I
2012
14. I POLO00089145 I PNC Record for Grant Allen dated 12 July I POL-0086120 I
2012 i
15. I POL00089332 I letter from Stephen Bradshaw, dated 8 POL-0086307
II August 2012, enclosing the summons
16. I POLO0089369 I Indictment z POL-0086344
17. I POL00089376 I Letter from Andrew Bolc to Maidments POL-0086351
Solicitors Ltd, dated 22 November 2012 I
18. I POL00089682 II The letter from Simon Clarke to POL-0086657
I Maidments Solicitors Ltd, dated 25 July
II. 2013
19. I POL00089380 I Emails, dated December 2012 POL-0086355
20. I POL00089077 II Witness statement of Gareth Jenkins and I POL-0086052
21. I POLO0086089 I Exhibit GlJ/1 POL-0083147
22. I POL00089115 I Exhibit GlJ/2 POL-0086090
23. I POLO0089063 II Notice of Additional Evidence, dated 18 POL-0086038
December 2012
24. I POL00089367 II Brief for prosecution counsel POL-0086342 l
25. I POL00089416 I Emails dated January 2013 POL-0086391
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26. I POL00089065 II Letter from Stephen Bradshaw, dated 30 I POL-0086040
January 2013
27. I POL00089446 I Final Result Sheet POL-0086421
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