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Witness Name: Brian Arthur Pinder
Statement No.: WITN04520100
Dated: 18 July 2023
POST OFFICE HORIZON IT INQUIRY
FIRST WITNESS STATEMENT OF BRIAN ARTHUR PINDER
I, MR BRIAN ARTHUR PINDER, will say as follows:
INTRODUCTION
1. I am a former employee of Fujitsu Services Limited (“Fujitsu”), having retired in
2018.
2. This witness statement is made to assist the Post Office Horizon IT Inquiry
(the “Inquiry”) with the matters put to me in a Rule 9 Request dated 7 June 2023
(the “Request”), to the extent I have or had direct knowledge of such matters.
Given the passage of time, I have limited recollection of the topics covered by the
Request. The content of this witness statement therefore focuses largely on the
content of various documents provided to me by the Inquiry. To the extent those
documents have assisted my recollection, I set out the URN of the relevant
document.
3. I was assisted in preparing this statement by Morrison Foerster, the recognised
legal representatives for Fujitsu in the Inquiry.
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PROFESSIONAL BACKGROUND
4. I joined ICL Sorbus (a Fujitsu group company) in November 1996 as a Security
Administrator, after 22 years in with the Royal Air Force Police. From this time, I
held various non-technical security-focused roles within the Fujitsu group,
including:
a. 1996 to 1998 / 1999: Security Administrator, employed on military sites
working within the Fujitsu team to carry out routine security administrative
duties;
b. 1998 / 1999 to 2003: Site Security Administrator, working within the
Department of Trade and Industry Account; and
c. 2003 to 2005: Security Administrator, working within the Fujitsu Security team
servicing all of Fujitsu’s central government security teams.
5. I joined Fujitsu’s Post Office Account (the “Account”) as a Security Manager in
around 2005 and left the Account in November 2009. After leaving the Account, I
took another role in Fujitsu in the Central Business Continuity team, where I
remained until I retired in 2018.
6. A summary of my (i) qualifications and accreditations, (ii) professional skills and
methodologies, and (iii) professional memberships are set out in Appendix 1 to this
statement.
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MY POSITIONS DEALING WITH SECURITY
7. As noted above, I became a Security Manager on the Account in 2005, having
been made aware of the role through conversations with other Security Managers
at Fujitsu. I was formally offered the position following interviews with the Security
and Service Managers on the Account at the time.
8. In terms of training and experience, by the time I joined the Account, I had gained
almost 10 years of security administrative experience through my employment with
the various security teams at Fujitsu. I had also gained knowledge of physical,
documentary, personal and IT security, including knowledge of the BS7799
standard, during my time with the RAF.
9. During my time as Security Manager, the Account worked towards compliance with
1S017799. My previous experience within Fujitsu involved co-ordinating (i) central
processes and policies, (ii) security documentation, (iii) awareness, and (iv)
standardisation, across all Fujitsu central government security teams. These teams
were also working within ISO compliance. My experience in these areas was
favourable for the Security Manager role on the Post Office Account.
10.As Security Manager, I performed a wide range of security-related activities that
(i) assisted the establishment and maintenance of an 1SO17799 compliant
infrastructure, (ii) supported legal and contractual obligations, and (iii) minimised
liabilities for the company. I was responsible for monitoring operations and
introducing specific security controls to maintain the integrity, availability and
confidentiality of the information used. This included arranging suitable “Pen
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Testing” with third party providers and managing issues found, in order to provide
a secure solution.
.My role also involved attending security meetings held by the Post Office Limited
(‘Post Office”) Security team to review, discuss and ultimately resolve any areas
of concern with regards to security. I was also involved in (i) the implementation
and maintenance of Fujitsu security policies and procedures, including those
relating to system and physical access controls, and Anti-Virus and malicious
software management, (ii) reporting security incidents, and (iii) problem
management.
In terms of reporting lines, all members of my team reported to me. This included
Peter Sewell (who was my deputy and also the deputy to my predecessor Bill
Mitchell), Andy Dunks, Penny Thomas and Neneh Lowther. Mr Dunks, Ms Thomas
and Ms Lowther also individually reported to Mr Sewell, who worked more closely
with them. As my deputy, Mr Sewell would manage any issues in my absence. I
then reported to the Service Director. I believe Dave Baldwin held this role at a
point, after which I reported to his replacements, although I cannot recall their
names. The role of Chief Information Security Officer (“CISO”) for the Account
Security team was introduced by the Account at some point during my tenure as
Security Manager, although I do not recall when, maybe around 2007. From that
point forwards, I reported to the CISO (Howard Pritchard), until I left the Account in
November 2009.
In terms of reporting issues or discussing actions to be taken, I conversed with my
team almost daily. From my recollection, I generally only had meetings with Mr
Baldwin and his Service Managers if they requested it.
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14. The Inquiry has asked me to comment on the competence and professionalism of
my colleagues and managers. In this regard, all my staff appeared very competent
in their work and worked hard to provide a good service for Post Office. All other
Account staff who I came into contact with also seemed to be very competent,
aware of their responsibilities, and again worked hard to achieve their goals for the
Account and Post Office.
MY INVOLVEMENT IN PROCEEDINGS AGAINST POSTMASTERS
15. Until reviewing the documents provided to me by Inquiry, I did not recall having any
involvement in Post Office disciplinary matters or proceedings against
postmasters. From the documents I have received, however, I can see that I was
in fact involved, albeit largely as a point of contact for Post Office legal
representatives in respect of certain subpostmaster proceedings.
16.In addition to the documents provided to me by the Inquiry in relation to Post
Office’s proceedings against Mr Lee Castleton, which are addressed in more detail
below, I have also been shown an email exchange between myself, Graham Ward
of Post Office, Gareth Jenkins and Neneh Lowther in relation to proceedings
relating to the Gaerwen branch (FUJ00152587). Unfortunately, however, this has
not assisted my recollection any further. Having reviewed the email exchange, I
believe my involvement would have been purely administrative as Ms Lowther’s
line manager.
17.I have also been asked by the Inquiry in which circumstances I would have had
contact with Mr Ward. I can see from the documents provided to me that Mr Ward
was a casework manager in the POL Investigation team. Beyond what is set out in
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18.
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the documents however, I have no recollection of Mr Ward. I would imagine that
any contact I did have with Mr Ward would have been for one-off specific reasons.
In order to help refresh my memory, I have also been provided with the Service
Description for the Security Management Service from March 2006
(FUJ00002000). Mr Ward is noted on the external distribution list for this Service
Description, I presume this was because he worked as a Case Manager for Post
Office.
I do not recall producing or signing any witness statements. Neither do I recall
undertaking the extraction of any audit data. During my tenure as Security
Manager, the extraction of audit data for the Post Office Investigation Team was
generally undertaken by Penny Thomas. This process was carried out from a
secure office which only Ms Thomas had access to. I was not personally aware of
the details of the process, but I am aware that it had to be carried out meticulously
so that the data contained the specific details the investigators required. The audit
data extraction process was in place prior to my arrival on the Account and, as far
as I was aware, was agreed between Fujitsu and the Post Office Investigations
Team as the acceptable process to be followed. I was not notified when Ms
Thomas was requested to extract data, nor did I expect to be provided with details
of such requests.
After the extraction process was complete, Ms Thomas would write a statement
presenting the audit data formally as evidence for the courts.
As far as I was aware, Ms Thomas was always very professional in her work, and
I never received any complaints about her or her work. In circumstances where Ms
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Thomas was away sick or on annual leave, she would have instructed her
colleagues Neneh Lowther or Andy Dunks to cover for her.
2
.To the extent that Ms Thomas was required to present any data obtained to the
court, as her line manager I would be asked if there was an issue with the court
date or whether the distance for her to travel was particularly extensive, but this
was the full extent of my involvement in the process. The process itself appeared
to me to be a straightforward one in that Ms Thomas would simply extract the data
requested and then present that data to the court.
22.The Inquiry has asked me to consider multiple documents in relation to the
provision of witness evidence in proceedings. I unfortunately do not have any
recollection of these documents. As explained further below, my involvement in
such matters would have been minimal or as an intermediary between the parties
involved.
MY INVOLVEMENT IN PROCEEDINGS AGAINST LEE CASTLETON
23.The Inquiry has asked me to consider around [35] documents relating to Post
Office’s proceedings against subpostmaster, Lee Castleton. The URNs for these
documents are listed in the index at the back of this statement. Unfortunately, I do
not have any recollection of the documents provided to me, of the case against Mr
Castleton, or of any other specific case or investigation carried out by the Post
Office. By way of background in this regard, this type of work did not form any part
of my day-to-day role on the Account. It was very much the exception.
24. That being said, I can see from the documents provided that, in the case against
Mr Castleton, I acted as a point of contact for Post Office’s legal representatives,
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25.
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Bond Pearce LLP (“Bond Pearce”). As the Security Manager at the time, I was
ideally placed in this regard to facilitate communication between Bond Pearce and
the many and varied colleagues on the Account. The communications provided
appear largely to have related to technical questions or the provision of information.
As with my previous security-related position, my role as Security Manager was
not a technical one and I did not therefore, have the requisite technical knowledge
to respond to Bond Pearce’s questions myself. From the documents provided, my
main contact at Bond Pearce appears to have been Stephen Dilley.
By way of example, the email chain at FUJ00122285 shows me acting as the
liaison between Bond Pearce and Anne Chambers; I am being requested to ask
Mrs Chambers to review her witness statement and respond accordingly. I then
forward the email onto Mrs Chambers, as directed. Similarly, the email chain at
FUJ00122283 shows me acting in the same capacity as intermediary between
Bond Pearce and Gareth Jenkins.
In relation to early discussions of the matter, the Inquiry has referred me to
document POL00071165, a note of a meeting between Post Office, Bond Pearce
and Fujitsu on 6 June 2006. Both myself and Mr Sewell, in addition to Mr Jenkins,
Mrs Chambers, Andy Dunks and Naomi Ellis are recorded as having attended the
meeting on behalf of Fujitsu (although I note that a Naomi Elliot appears on other
documents around this period). I do not recall this meeting but, having reviewed
my comments in the “How Horizon Works” section, I presume I would have
discussed the audit processes with various mainly technical people, including Ms
Thomas and maybe others, ahead of the meeting and then reported my findings
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as shown. I would then have known where to go to find technical people who had
the expertise to answer or explain the exact process if required.
27.With regards to the involvement of Mr Jenkins in the case against Mr Castleton, I
believe that Mr Jenkins was a senior technical person at Fujitsu with good
knowledge of the system. It is for this reason that I would have gone to him to
answer the various questions raised if need be. I would expect Mr Jenkins’
evidence to have been very technical and detailed (see for example
FUJ00122284).
28.I have also been asked about the involvement of Mrs Chambers in this case, but I
have limited recollection of Mrs Chambers or her role within the Account. I believe
she may have become involved in this matter as it concerned a call that she had
dealt with previously.
29.From the documents provided, it appears that a member of my team, Mr Dunks,
was also involved in this matter. Document FUJ00152297, for example,
demonstrates that Mr Dunks had retrieved Fujitsu helpdesk call logs for
proceedings in the past and was offering to do so again. I imagine that the reason
Mr Dunks became involved in this case was because he was in a position that
enabled him to gain access to the relevant call logs.
30.1 have been asked by the Inquiry to consider document FUJ00152290 and explain
why this matter was referred to as a “test case” and the implications of this. I do
not have any specific recollection of this email exchange, but I would presume that
what Graham Ward of Post Office meant by “test case” was that this was the first
case of this nature. On that basis, perhaps identifying someone who might (i) know
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31.
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and understand the requirements, where to look for the necessary information and
have the authority to examine those areas of the system, and (ii) be able to
document the information so it could be understood, would have been challenging
and time consuming.
I have also been asked by the Inquiry about my knowledge of the Horizon system's
ability to “lose” transactions, the existence of bugs, errors and defects or any
associated enquiries. In particular, I have been pointed to documents
POL0069404, POL00069835 and POL00069925. As my role was non-technical, I
do not recall having any direct experience of the system's ability to lose
transactions. However, I am aware that this was a very large system / network,
with thousands of terminals, and bugs, errors and defects were and are not
uncommon in any network. This is why IT technicians work on networks day and
night. In relation to the documents provided to me by the Inquiry, I do not have any
specific recollection of these discussions. Document POL00069835 is a further
example of my role as an intermediary between Mr Dilley of Bond Pearce and
technical experts within Fujitsu, whose responses are set out in my emails to
Mr Dilley.
Document POL00070126 is a Bond Pearce attendance note recording a phone
call that I was not a party to. The call seems to relate to an issue with Horizon at
the Falkirk branch and what actions needed to be taken in the case against Mr
Castleton as a result. The end of the note records that Mr Dilley stated he had
spoken with me about the issue and asked me to look into it. The note then records
that I forwarded the email to Mr Sewell. The Inquiry has asked what actions I took
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in response to this discussion. I do not recall this issue but would assume that Mr
Sewell progressed the matter as recorded in the note.
33.Document POL00069806 is an email exchange between myself and Mr Dilley
about (i) the availability of Mr Castleton’s cash declarations, and (ii) the “database”
from which data provided by Fujitsu had been collected. The Inquiry has asked
how I obtained the information set out in my response. Although I do not recall the
email exchange, I believe I would have acquired the information from various
people on the Account, both technical and otherwise, including Mr Sewell and my
own Security team.
34.1 am unable to comment on the content on the evidence provided by my Fujitsu
colleagues itself, as I do not have the technical knowledge or expertise necessary
to do so (nor did I have such knowledge at the relevant time).
35. In relation to how the matter developed after the conclusion of the trial, the Inquiry
has referred me to (i) an email exchange between myself and Mik Peach in relation
to whether an internal review of the case should take place (FUJ00152300), and
(ii) an “Afterthoughts” document prepared by Mrs Chambers (FUJ00152299). I
have no recollection of either of these documents but set out below my current
interpretation.
36. In relation to the email exchange at FUJ00152300, I have been asked by the Inquiry
why I did not consider a “mop up” following the case to be necessary. In the email
exchange with him, my response informs me that I sought advice from technical
people regarding the need for a wash up meeting and my response was the
conclusion of that, (i) as this was a rare occurrence and unusual case, involving
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specific areas, which had not occurred prior and would be highly unlikely to repeat
itself, and (ii) given all the routine procedures, despite being stretched, were
followed and served us well, no wash up meeting was considered necessary from
my perspective as Security Manager. So, provided the areas highlighted by Mrs
Chambers in her “Afterthoughts” document were picked up by those on the email
to the extent they were relevant to their specific areas, I as Security Manager did
not believe any mileage would be gained in holding a wash up meeting.
37.In relation to Mrs Chambers’ “Afterthoughts” document, Mrs Chambers had
obviously highlighted some areas of interest and written up her thoughts in relation
to the case. This document was attached to Mr Peach’s email, which was
addressed to both me and Ms Elliot to review / comment on / follow up on. I also
agreed to discuss the contents of Mrs Chambers’ document with Ms Elliot (Service
Manager) and to keep both Mr Peach and Mrs Chambers informed. I do not recall
any further action beyond this on my part, although it may have been brought up at
further meetings within the Service Management teams. My email would have been
to ensure that the Service Managers were aware. I was not specifically involved in
Customer Service Management.
38.In preparing this statement, I have also been provided with a copy of the transcript
of the evidence provided by Mr Peach to the Inquiry on 16 May 2023 and have the
following observations:
a. on pages 63 and 64 of this transcript, Mr Peach discusses an argument
he had in relation to Mrs Chambers’ participation in the proceedings
against Mr Castleton. I have no recollection of any arguments concerning
the presentation of evidence to court; and
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b. on pages 64 and 65 of the transcript, Mr Peach clarifies that it was not
me who was tasked with presenting data to court, but rather I managed
the team who undertook this exercise. I agree with Mr Peach's
clarification. As described above, the individual who presented extracted
data in any legal proceedings would have been the individual who
extracted the data. This extraction process was undertaken by certain
members of my team but not by myself.
MY RELATIONSHIP WITH POST OFFICE AND BOND PEARCE
39. The Inquiry has asked me to describe the circumstances in which I would have had
contact with Post Office in relation to issues concerning Horizon and who my
relevant contacts at Post Office were. If I ever needed to contact the Post Office,
my contact would have been Sue Lowther, who headed up the Security team. To
the best of my recollection, Ms Lowther was my primary point of contact at Post
Office.
40. Any contact with Ms Lowther would have been for Fujitsu Security-related reasons,
for example during routine meetings with the Post Office Security team, or if there
were technical issues (including software and hardware issues) or risk analysis that
needed to be discussed. These meetings, which I believe were minuted, were held
either bi-monthly or whenever required by Post Office and would be run by Ms
Lowther. At the meetings, Sue Lowther would have a technical advisor who worked
with her and I would often bring along someone who was technically savvy to
answer any queries.
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41.In relation to these meetings, I have been provided with the minutes of a Security
Liaison Meeting that took place on 26 June 2008 which was attended by myself,
Ms Lowther and another Post Office employee, Paul Halliden (FUJ00088340).
Having reviewed this document, I believe that Mr Halliden may have been Ms
Lowther's regular technical advisor. In most cases I attended meetings such as this
by myself; however, I can see on this occasion I was joined by others from Fujitsu.
This was likely to have been because there were particular technical issues to
discuss.
42.In order to refresh my memory, I have also been provided with the minutes of a
HNG-X Core Team Security meeting which took place on 25 May 2006
(FUJ00157865) and was attended by myself and Ms Lowther (amongst others).
Whilst I do not recall these meetings specifically, I note the inclusion of Bill
Membery’s name on the attendee list. This has caused me to remember that
Mr Membery accompanied me to meetings with Post Office on a few occasions in
order to provide appropriate technical input.
43. Apart from my interaction with Bond Pearce as a liaison between the solicitors and
other Fujitsu staff members (as detailed above), I do not recall having any other
involvement with Bond Pearce.
44. There are no other matters that I would like to draw to the attention of the Chair.
Statement of Truth
I believe the content of this statement to be true.
__GRO-
Signed: I
Dated: 18 July 2023
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APPENDIX 1
Professional Background
1. Qualifications & Accreditations:
a. NT Systems Administration & NT Core
b. BS7799 -2: 2002 Internal Lead Auditor
c. RSA 1 & 2 Computer Literacy
d. Integrated Certified Business Technology IBT2
e. Managing Safely with the Institute of Certified Occupational Safety &
Health.
2. Professional Skills / Methodologies:
a. City & Guilds Computer Maintenance
b. BS7799 Information Security
c. BS7799 Risk Analysis & Implementation
d. Windows NT 4 Basic Administration
3. Membership to Security Forums:
a. Member of the Information Security Steering Group
b. Representing Fujitsu at the Managed Service Providers Information
Exchange (MSPIE) Government Body
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INDEX TO FIRST WITNESS STATEMENT OF BRIAN ARTHUR PINDER
Exhibit
No.
Description
Control Number
URN
1.
Email chain between Graham
Ward, Brian Pinder, Neneh
Lowther and Gareth Jenkins with
subject “Gaerwen statement”,
dated 28 March 2006
POINQ0158782F
FUJ00152587
Fujitsu Service Description for the
Security Management Service,
Version 3.0, dated 6 March 2006
POINQ0008171F
FUJ00002000
Email from Andy Dunks to Stephen
Dilley, Graham C Ward and Peter
Sewell, with subject “First draft
witness statement of Ann
Chambers (PO v Lee Castleton)”,
dated 18 August 2006
POINQ0128499F
FUJ00122285
Email from Gareth Jenkins to Brian
Pinder and Pete Sewell, with
subject “to First statement of
Gareth Jenkins (PO V Lee
Castleton)”, dated 3 August 2006
POINQ0128497F
FUJ00122283
Womble Bond Dickinson personal
attendance meeting notes
concerning Lee Castleton, dated 6
June 2006
POL-0067728
POL00071165
Draft witness statement of Gareth
Jenkins, dated 2 August 2006
POINQ0128498F
FUJ00122284
Email chain between Anne
Chambers and Gareth Jenkins with
subject “Trial Date: Post Office
Limited -v- Mr L Castleton”, dated
20 November 2006
POINQ0158600F
FUJ00152297
Email from Anne Chambers to
Peter Sewell with subject “P.O v
Castleton: Transaction Logs”,
dated 7 August 2006
POINQ0158593F
FUJ00152290
Email from Stephen Dilley to Brian
Pinder, with subject “Post Office
Limited v Lee Castleton”, dated 31
October 2006
POL-0065967
POL00069404
10.
11.
Email Chain between Brian Pinder
and Stephen Dilly with subject
“Post Office Limited -v- Lee
Castleton”, dated 6 November
2011
Telephone Attendance Note by
Stephen Dilley regarding Lee
POL-0066398
POL-0066488
POL00069835
POLO00069925
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Exhibit
No.
Description
Castleton Litigation, dated 30
November 2006
Control Number
URN
12.
13.
14.
Telephone attendance note of
Thomas Bourne, SDJ3, Richard
Morgan and Mandy Talbot
regarding “Lee Castleton and
problems with Horizon system at
Falkirk Branch”, dated 6 December
2006
Email from Brian Pinder to
Stephen Dilley, Graham Ward,
Tom Beezer and others with
subject “PO Ltd v Lee Castleton”,
dated 8 November 2005
Email from Pinder Brian to Mik
Peach and Anne Chamber with
subject “"Mop up" on the Castleton
case”, dated 28 February 2007
POL-0066689
POL-0066369
POINQ0158603F
POL00070126
POLO0069806
FUJ00152300
15.
Afterthoughts on the Castleton
case authored by Anne Chambers,
dated 29 January 2007
POINQ0158602F
FUJ00152299
16.
Post Office / Fujitsu Review
Meeting Minutes (Security Liaison),
dated 26 June 2008
POINQ0094511F
FUJ00088340
17.
HNG-x Core Team Security
Meeting Minutes, dated 25 May
2006
POINQ0173632F
FUJ00157865
18.
Email chain between Stephen
Dilley and Andrew Wise and others
with subject “Post Office Limited v
Mr L Castleton”, dated 6 June
2006
POL-0067727
POL00071164
19.
Email from Brian Pinder to Anne
Chambers with subject “Update on
trial, P.O -v- Castleton”, dated 23
November 2006
POINQ0158601F
FUJ00152298
20.
21.
Email chain between Stephen
Dilley, Tom Beezer, Brian Pinder
and others with subject “Post
Office Limited -v- Mr L Castleton”,
dated 6 November 2006
Email from Stephen Dilley to Brian
Pinder, Gareth Jenkins, Tom
Beezer and others with subject
“Post Office Limited v Lee
Castleton”, dated 7 November
2006
POL-0070306
POL-0070307
POL00073743
POL00073744
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Exhibit
No.
22.
Description
Email from Stephen Dilley to Brian
Pinder with subject “Post Office
Limited v Lee Castleton”, dated 7
November 2006
Control Number
POL-0070308
URN
POL00073745
23.
24.
Email from Brian Pinder to Gareth
Jenkins and Peter Sewell with
subject “First draft statement of
Gareth Jenkins (PO V Lee
Castleton)” dated 2 August 2006
Draft witness statement of Gareth
Jenkins (Post Office Limited v
Castleton - High Court), dated 2
August 2006
POINQ0128493F
POINQ0128494F
FUJ00122279
FUJ00122280
25.
26.
Receipt and suspense account for
Marine Drive, dated 3 March 2004
Transaction log dated 28 April
2004
POINQ0128495F
POINQ0128496F
FUJ00122281
FUJ00122282
27.
Email from Richard Morgan to
Stephen Dilley with subject “Post
Office Limited v Lee Castleton”,
dated 13 October 2006
POL-0066035
POL00069472
28.
29.
Email from Stephen Dilley to John
Jones and others with subject “trial
date - POL v Castleton”, dated 20
November 2006
Email from Stephen Dilley to
Pinder Brian with subject “trial date
- POL v Castleton”, dated 20
November 2006
POL-0066304
POL-0066302
POL00069741
POL00069739
30.
Email from Stephen Dilley to Liz
Morgan, Davlyn Cumberland, Tom
Beezer and others with subject
“Post Office Limited v Lee
Castleton”, dated 24 August 2006
POL-0070297
POL00073734
31.
Email from Brian Pinder to
Stephen Dilley, copying Peter
Sewell with subject “P.O —
Castleton”, dated 1 December
2006
POL-0066456
POLO0069893
32.
Email chain between Anne
Chambers and Stephen Dilley with
subject “Urgent Post Office Limited
v Lee Castleton”, dated 16
December 2006
POL-0066668
POL00070105
33.
Email from Stephen Dilley to Brian
Pinder, Graham Ward, Peter
Sewell with subject “Post Office
POL-0067384
POL00070821
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Exhibit
No.
Description
Limited v Mr L Castleton”, dated 26
August 2006
Control Number
URN
34.
Email from Stephen Dilley to Anne
Chambers and Brian Pinder with
subject “First draft Witness
Statement of Anne Chambers
(Post Office Limited v Lee
Castleton)’, dated 17 August 2006
POL-0067656
POL00071093
35.
36.
Email from Brian Pinder to
Stephen Dilley, Mandy Talbot, Tom
Beezer and others with subject
“First Draft Statement of Gareth
Jenkins (Post Office Limited v Lee
Castleton)”, dated 2 August 2006
Email chain between Brian Pinder
and Stephen Dilley copied to
others with subject “Post Office
Limited v Mr L Castleton”, dated 16
June 2006
POL-0067672
POL-0067713
POL00071109
POL00071150
37.
Stephen Dilley’s attendance note
summarising preparatory work and
telephone conference with Brian
Pinder (Lee Castleton), dated 21
December 2006
POL-0069271
POL00072708
38.
Email from Jennifer Robson to
Carol King and Cheryl Woodward
with subject “Lee Castleton, Marine
Drive Post Office, Bridlington”,
dated 25 October 2006
POL-0106089
POL00107851
39.
40.
Letter from Bond Pearce to Lee
Castleton with subject “Post Office
Limitec -v- Yourslef’ enclosing
Post Office’s supplemental
disclosure list, dated 22 November
2006
Email from Brian Pinder to Gareth
Jenkins with subject “WS for Rvs
Teja”, dated 4 November 2005
VIS00010644
POINQ0128338F
LCAS0000404
FUJ00122124
41.
Witness statement of Beatrice
Neneh Lowther, dated 3 October
2005
POINQ0128339F
FUJ00122125
42.
Email to Gareth Jenkins and
Neneh Lowther from Penny
Thomas with subject “CS Witness
Statement Amendment”, dated 24
November 2005
POINQ0128344F
FUJ00122130
43.
Witness statement of Gareth Idris
Jenkins, dated 3 October 2005
POINQ0128345F
FUJ00122131
Page 19 of 20
WITNO04520100
WITNO04520100
Exhibit
No.
44.
Description
Email from Gareth Jenkins to
Penny Thomas, Neneh Lowther
with subject “CS Witness
Statement”, dated 28 November
2005
Control Number
POINQ0128348F
URN
FUJ00122134
45.
46.
Email to Peter Sewell and Gareth
Jenkins from Penny Thomas with
subject “Witness Statement
Review’, dated 7 December 2005
Witness statement of Penelope
Anne Thomas (undated)
POINQ0128365F
POINQ0128366F
FUJ00122151
FUJ00122152
47.
48.
Email to Peter Sewell and Gareth
Jenkins from Penny Thomas with
subject “Witness Statement
Review’, dated 7 December 2005
Witness statement of Penelope
Anne Thomas (Undated)
POINQ0128367F
POINQ0128368F
FUJ00122153
FUJ00122154
49.
Email to Andy Dunks and Peter
Sewell from Brian Pinder with
subject “Gaerwen Witness
Statement”, dated 22 March 2006
POINQ0128403F
FUJ00122189
50.
Witness Statement of William
Leslie Mitchell (Version 3.0), dated
22 March 2006
POINQ0128404F
FUJ00122190
51.
Email chain between Neneh
Lowther, Gareth Jenkins, Penny
Thomas, Graham Ward and Brian
Pinder with subject “Gaerwen
branch”, dated 23 March 2006
POINQ0128411F
FUJ00122197
52.
Witness Statement of Gareth Idris
Jenkins, dated 23 March 2006
POINQ0128412F
FUJ00122198
53.
Email to Neneh Lowther and Brian
Pinder from Gareth Jenkins with
subject “Gaerwen”, dated 23
March 2006
POINQ0128417F
FUJ00122203
54.
Witness Statement of Gareth Idris
Jenkins, dated 23 March 2006
POINQ0128418F
FUJ00122204
55.
Email to Graham C Ward and
Neneh Lowther from Gareth
Jenkins with subject “Gaerwen’,
dated 28 March 2006
POINQ0128431F
FUJ00122217
56.
Witness statement of Gareth
Jenkins, dated 24 March 2006
POINQ0128432F
FUJ00122218
Page 20 of 20