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Witness Name: Jonathan Longman
Dated: 08 November 2023
POST OFFICE HORIZON IT ENQUIRY
FIRST WITNESS STATEMENT OF JONATHAN LONGMAN
I, Jonathan Longman, will say as follows —
1. This witness statement is made to assist the Post Office Horizon Inquiry (the
“Inquiry”) with the matters set out in the Rule 9 Request dated 13 October 2023
(the “Request’). The Request contains 64 questions, which I have addressed
below. I would like to make the Inquiry aware that I have received legal
assistance to produce this statement from my solicitor, Mr lan Manners of
Ashfords LLP. When seeking to obtain assistance from Ashfords LLP, I was
assisted by the Post Office with the initial stage of confirming the availability of
insurance coverage, to cover the associated legal costs.
2. The Request relates to matters that occurred many years ago and some of the
documents provided to me are over 20 years old. As such, I have sometimes
found it difficult to recall precise details. However, everything that I include in this
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statement is to the best of my recollection and where I cannot recall something or
I have had to rely on a document provided, I have ensured to state this clearly.
Background
3. 1am a former employee of Post Office Ltd (POL) and I worked within the business
for approximately 36 years. I first began working for POL in 1980 and I left in
2016. During this period I held a variety of roles. My first role was as a counter
clerk at a local Crown Office for around 2 to 3 years. I then transferred to the
local Head Office in Watford where I carried out a variety of roles in different POL
departments which included accounts work, processing wages, postcodes and
TV Licensing. I then joined the POL Security Team in 2000 as an Investigator
where I remained until around late 2012 or early 2013. I deal with what my
Investigator role entailed further below. I then worked in the POL Network
Transformation Team until I left the business in October 2016. This role involved
meeting subpostmasters (SPMs) who wanted to leave the business to discuss
their leaving package, as well as meeting SPMs who wished to stay in the
business to discuss how we would reinvest government funding POL had
received into the branch.
4. I confirm that the qualifications I hold are all those listed in my CV at
[POL00126360]. With specific reference to my Certificate in Management
Studies, Diploma in Management Studies and membership of the Association of
Accounting Technicians, I believe that I obtained these at some point between
1983 and 1990.
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5. I recall that at some point in the year 2000 POL advertised vacant roles for Post
Office Investigators in the Security Team. I cannot recall if the job listing required
any necessary qualifications to apply for the role, but I imagine some experience
working within the business was desired. I applied for the role internally, sat an
interview and was successful. I recall that I had to travel up to Birmingham for the
interview and stayed overnight. I believe it was a type of assessment day but
cannot recall what I did other than there was an interview during the process.
6. When I first started as an Investigator in the Security Team I remember being
given various work books to complete as part of my training for the role. I cannot
remember all the specific areas that these workbooks covered, but I think they
covered obligations under the Police and Criminal Evidence Act 1984 (PACE),
interviewing, conducting searches on premises, giving evidence in court,
disclosure and what our role entailed in general, including the duty placed on
Investigators to follow all lines of enquiry during an investigation.
7. I also attended a course very early on in the role which ran for about 5 weeks,
which again covered the areas I have mentioned above. I believe that I also went
on a separate searching course. Unfortunately I cannot remember the exact dates
that this would have been. There were two trainers running the course, one was
Mick Matthews but I cannot recall the other trainer. I don’t recall any formal exams
at the end of the training. We were being continually assessed and I think it was
the trainers decision as to whether we passed or not. I recall that I did pass.
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8. I also received further training as an Investigator in the Security Team by way of
shadowing. When I first became an Investigator I did not run any investigations
of my own. I would attend an investigation with a more experienced Investigator
or my Team Leader to assist and observe them until I built up enough knowledge
and experience to run an investigation myself. I cannot remember the point at
which it was determined that I was experienced enough to run an investigation of
my own. The Team Leader would have made the decision as to when I was ready
to carry out my own investigation as they would allocate the cases. I have tried
hard to recall how many weeks or months may have passed until I began my own
investigations and which was my first investigation to help establish the potential
timeframe, but unfortunately I cannot remember.
9. I provide further detail in relation to my training under the following section of this
statement - “Training, instructions and guidance to investigators within the
Security team”
10.1 have been asked to set out what I understood the role of an Investigator to
involve. I always considered the role to be one where I would be required to carry
out criminal investigations against any POL agents or staff who were involved in
potential criminal or fraudulent activity against the Post Office, for example, in
cases of theft of POL stock and money, false accounting, and pension benefit
fraud. I would be required to obtain evidence during the investigation, put together
a casefile and complete a suspect offenders report. Where I was a lead
investigator on the case I would usually see the case through to the end of a
prosecution if one was commenced.
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11.During my time as an Investigator I generally worked within a team of around 6
or 7 other Investigators who covered a geographical area and we would report to
a specific Team Leader. Over the years the geographical areas I covered
changed and I had various Team leaders during my time as an Investigator. The
main Team Leaders I can remember are Paul Dawkins, Manish Patel, Lester
Chine, Geoff Hall, David Posnett and Jason Collins.
12.I never had any concerns about the competence or professionalism of any of my
managers or colleagues during my time working within POL. Some naturally had
greater knowledge than others depending on their previous experience within the
POL (for example, some were ex-branch managers and had very good general
knowledge of Post Office processes and procedures) but overall I believe that all
of my managers or colleagues were professional and competent.
13. My role as an Investigator in the Security Team had no involvement in disciplinary
matters. I believe that disciplinary matters were dealt with by Contract Managers.
On some occasions I may have spoken to a Contract Manager to get further
background information on a matter I was investigating (although I cannot recall
a specific example of this), but I would have no further involvement in any
disciplinary matters that may be running alongside the investigation. I believe that
it would be the relevant Contract Manager for the area who would initiate a
suspension of an SPM following an incident involving potential criminal liability
and then finding a replacement SPM to enable the branch to continue operating
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if required. I have no further knowledge of how disciplinary matters were
progressed, managed or decided.
14.1 also had no involvement as an Investigator in litigation case strategy. I believe
it would have been the POL Legal Team who considered this.
15.1 was regularly involved in interviewing individuals who were identified as
potentially committing a criminal offence against POL during my role as an
Investigator. I would always carry out those interviews in accordance with the
duties set out in PACE.
16.I was also involved in assisting with the disclosure steps in criminal proceedings.
For example, in cases that were being prosecuted and I was the Investigator in
that matter, I would assist the POL Legal Team by compiling a committal bundle
of all the evidence in the matter which I think was used and referred to in court
hearings. I would also complete schedules of unused sensitive and non-sensitive
material. I would then send the committal bundle and schedules over to the POL
Legal Team for their review. Sometimes they would come back and make
requests to move things around in the committal bundle or to notify that a
document was on the wrong schedule. Unfortunately, I cannot recall any specific
case examples of this but I do vaguely recall that happening on a couple of
occasions. I believe that I only ever assisted with gathering disclosure in criminal
proceedings — I never made any final decision as to what should be disclosed to
the defence, and I do not recall ever disclosing anything to the defence directly.
The solicitors in the Legal Team would have been responsible for this.
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17. In terms of liaising with other Post Office departments in respect of the progress
of cases, I cannot recall all of the departments this may have included but I do
believe that I would have liaised with the POL Legal Team to this regard. As
explained above, on cases I investigated I would have been assisting the POL
Legal Team with gathering documents for disclosure and sending disclosure
schedules across to them. It was also not uncommon on cases being prosecuted
for the Legal Team to request Investigators to obtain further evidence such as
further witness statements, so I would sometimes liaise with them in these
circumstances. Another department I may have liaised with to progress a case is
Chesterfield (the Financial Division of POL). I would have liaised with Chesterfield
to see if there were any transaction corrections that might mitigate a cash
shortage. I would also contact the National Business Support Centre (NBSC) at
Chesterfield to see what requests for assistance or problems the subpostmaster
may have raised and whether it had any relevance to the loss under investigation.
The Security team’s role in relation to criminal investigations and prosecutions
18. I confirm that I have considered the following documents provided to me under
this heading:
i) Casework Management Policy (version 1.0, March 2000)
({POL00104747]) and (version 4.0, October 2002)
([POL00104777));
ii) Rules and Standards Policy (version 2.0, October 2000)
([POL00104754));
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iii)
iv)
v)
vi)
vii)
viii)
x)
xi)
xii)
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“Investigation Procedures Policy (version 2.0, January 2001)
([POL00030687)):
Disclosure Of Unused Material, Criminal Procedures and
Investigations Act 1996 Codes of Practice Policy (version 1.0, May
2001) ([POL00104762)});
"Royal Mail Group Ltd Criminal Investigation and Prosecution Policy"
(1 December 2007) ([POL00030578], which appears to be
substantially the same as the policy of the same date with a variation
on the title at [POL00104812)) (see, in particular, section 3);
"Royal Mail Group Security - Procedures & Standards - Standards of
Behaviour and Complaints Procedure” (version 2, October 2007)
([POL00104806)):
"Royal Mail Group Crime and Investigation Policy" (version 1.1, October
2009) ([POL00031003});
"Post Office Ltd - Security Policy - Fraud Investigation and
Prosecution Policy" (version 2, 4 April 2010) ([POL00030580));
"Post Office Ltd Financial Investigation Policy" (4 May 2010)
([POL00030579)});
Royal Mail Group Security —- Procedures & Standards: “Appendix 1
to P&S 9.5 Disclosure of Unused Material & The Criminal Procedure
& Investigations Act 1996” (Version 1, July 2010) ([POL00104848));
Royal Mail Group Security — Procedures & Standards: “Committal &
Summary Trial Papers & Processes” (Version 1, July 2010)
([POL00104837));
"Royal Mail Group Security - Procedures & Standards - The
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xiii)
xiv)
xv)
xvi)
xvii)
xviii)
xix)
Xx)
xxi)
xxii)
xxiii)
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Proceeds of Crime Act 2002 & Financial Investigations" (version 1,
September 2010) ([POL00026573));
"Royal Mail Group Security - Procedures & Standards - Initiating
Investigations" (September 2010) ([POL00104857]);
"Royal Mail Group Ltd Criminal Investigation and Prosecution Policy"
(version 1.1, November 2010) ([POL00031008));
Post Office Ltd Financial Investigation Policy (version 2, February 2011)
([POL00104853));
Post Office Ltd Anti-Fraud Policy (February 2011) ([POL00104855)):
"Royal Mail Group Policy Crime and Investigation S2" (version 3.0, April
2011) ([POL00030786));
“Post Office Ltd PNC Security Operating Procedures” (August 2012)
([POL00105229)).
"Post Office Limited: Internal Protocol for Criminal Investigation and
Enforcement (with flowchart)", (October 2012) ([POL00104929));
"Undated Appendix 1 - POL Criminal Investigations and Enforcement
Procedure (flowchart)", (October 2012) ([POL00105226));
The undated document entitled “POL — Enforcement & Prosecution
Policy” ([POL00104968)]);
"Post Office Limited: Criminal Enforcement and Prosecution Policy’
(undated) ([POL00030602));
"Conduct of Criminal Investigations Policy" (version 0.2, 29 August
2013) ((POL00031005));
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xxiv) "Conduct of Criminal Investigations Policy" (version 3, 10 February
2014) ([POL00027863});
xxv) Conduct of Criminal Investigations Policy" (September 2018)
([POL00030902)).
19. I cannot remember any of these documents from direct memory and I note that
some of them postdate my time working within the Security Team as an
Investigator. For those that were produced within the period I was an Investigator,
I imagine that I would have received them once circulated, but due to the passage
of time I am unable to recall.
20. The organisational structure of the Security Team changed many times during my
time as an Investigator. I cannot recall what all the changes were but I do recall
that in my geographical team there were normally 6 or 7 Investigators and we all
reported to a Team Leader (the names of which I have set out above). I believe
that our Team Leader would have reported to a Senior Manager in charge of the
Investigation/Fraud strand, who would in turn report to the Head of Security. I
cannot pinpoint from memory who would of held these specific roles and at which
point because those individuals also changed over the years. However I can
confirm that it did include Dave Pardoe who was the Senior Security Manager of
the Fraud strand who reported to John Scott who was the Head of Post Office
Security and managed all the other Senior Team leaders from other strands
relating to Post Office security.
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21. As well as the Investigatory/Fraud strand, I think there were also 4 or 5 other
strands in the Security Team. I cannot remember what all of these strands were
but I know that one related to physical security which dealt with alarms, locks and
security doors at branches. Later in my career a Financial Investigation Unit was
also introduced within the Security Team and they would deal with the recovery
of financial losses faced by POL when a crime was committed against the
business. I cannot remember when the Financial Investigation Unit was
introduced. I do also recall in my early days as an Investigator that there was a
Case Management team who were based in Croydon who dealt with
administrative matters, but they were later disbanded. Unfortunately I cannot
recall when this occurred.
22.Although there were various changes to the organisational structure of the
business, the crux of my role as a Criminal Investigator remained constant
throughout and the changes did not affect me. The only major change to my role
occurred around 2011 or 2012 when Criminal Investigators took on the additional
work of physical security at branches.
23. I cannot recall having any involvement in the development or management of
any of the policies listed in paragraph 18 above. I believe it is likely that these
policies would have been produced by someone more senior to me, but I do not
know who.
24. I am unable to recall all of the legislation, policies and / or guidance that governed
the conduct of investigations conducted by the Security Team during my time as
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an Investigator. The main legislation that I was trained to adhere to was PACE. I
also have a vague recollection of being required to understand duties under the
Regulation of Investigatory Powers Act 2000. I am sure that there were other Acts
that I was made aware of but I cannot recall these in detail. In terms of internal
POL policies, I imagine that those that were relevant to the role of Criminal
Investigators (including those listed in paragraph 18 above) were circulated, but
as explained above, I cannot directly remember when they were circulated. I
believe there would have been updates to policies and guidance over the years
but again, I am unable to recall when this would have been and what those
updates were. What I can confirm is that any time a policy was circulated to me I
would have read it and followed it.
25. I am unable to recall what the process was for dealing with complaints about the
conduct of an investigation by the Security Team. I do not believe I ever received
acomplaint against me personally, and I do not remember ever being involved in
any complaints that were raised against the Security Team as a whole. I note that
there is document provided to me titled "Royal Mail Group Security - Procedures
& Standards - Standards of Behaviour and Complaints Procedure"
(([POL00104806)). I cannot recall seeing this document. However, I can confirm
that for every Court Case where I or my colleagues gave witness statements, a
background check would always be made to see whether any individual had any
convictions.
26. In terms of receiving supervision, Criminal Investigators in the Security Team
could go to their Team Leaders for advice and support if they were unsure how
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to progress a matter or just needed to run something by them to ensure the
correct steps were being taken. All of the suspect offender case files that were
completed by Investigators would always be reviewed by our Team Leaders to
make sure all necessary steps had been followed. Our casefiles would also
undergo compliance checks to ensure that they were in order before they were
passed over to the POL Legal Team. I cannot recall who carried out these
compliance checks or who passed the casefiles on to the Legal Team. It may
have been the Case Management Team and then when they were disbanded,
our Team Leaders. However, I cannot say this for certain.
27. I do not ever recall having direct supervision from any of the individuals who were
Senior Management of the Investigation strand or the Head of Security Team
during my time as an Investigator. I am not sure if our Team Leaders may have
sought advice from these individuals when reviewing an Investigator’s casefile.
28. I do not recall that there was any Post Office policy that meant that Crown Office
employees who were investigated and/or prosecuted were treated any differently
to SPM’s, their managers or assistants. I think the policies and practices were the
same for both throughout my time as an Investigator.
Audit and investigation
29. I confirm that I have considered the document “Condensed Guide for Audit
Attendance” at [POL00104821]. There are two circumstances that I can recall
where an Investigator would attend an audit. Firstly, if an ongoing investigation
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(for example, relating to suspected pension benefit fraud) had identified a fraud
at a branch, then an Investigator would make a request for an auditor to attend a
branch to carry out an audit. The investigation team would also attend in that
scenario to inform the offender of the circumstances and to begin carrying out
any necessary investigations in accordance with PACE. Secondly, Investigators
would be called out to a branch if during a routine audit a large loss had been
discovered by the audit team. I cannot recall what the figure was to trigger the
need for Investigators to be called out to an audit shortage but I think it may have
been losses over £10k.
30. Where a shortfall was identified following an audit of a Post Office branch I
believe that it may have been Team Leaders for the geographic area that the
branch was in who would make the decision as to whether a criminal investigation
should be carried out and on what timescale. The reason I believe this is because
whenever I attended a branch in this scenario, the instruction to do so would
always come from my Team Leader, as did the allocation of the particular case. I
don't think Team Leaders had to first receive authority from Senior Management
or the Head of Security before allocating matters and instructing Investigators to
attend the audit.
31. I believe it would have been the Financial Investigators who would be responsible
for deciding whether a case was taken forward as a debt recovery matter. I do
not know what the exact criteria was to take it forward for this purpose. I only
know that it was the Financial Investigation Team who dealt with the recovery of
losses faced by POL as a result of a crime committed against the business, and
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their involvement came after the conviction of the individual who committed such
crime.
32. When an auditor discovered a discrepancy or large shortfall at a branch, I believe
that the Contracts Manager for the area would also be informed alongside the
Team Leader. I think it was common for Team Leaders to contact the Contract
Manager in these circumstances in order to gather as much information about the
Post Office branch in question and the SPM operating it. I do not think the
Contract Manager played any role in deciding whether a criminal investigation
should take place. As explained earlier in this statement, I believe that Contract
Managers only dealt with disciplinary issues relating to whether a suspension was
required and if a temporary SPM was needed to fill the role.
33.1 cannot recall what the triggers were for raising a fraud case following the
identification of a shortfall or discrepancy in a branch. I suspect that the amount
of shortfall or whether there was any evidence of false accounting may have had
some influence or formed part of the criteria. I cannot remember if the triggers
were different for raising a theft or false accounting case either or if the criteria
ever changed during my time as an Investigator.
34. In terms of the processes followed in an initial investigation, once an audit
shortage had been discovered and a decision had been made to conduct a
criminal investigation, generally the Lead Investigator would contact the Auditor
on site to establish the facts and obtain any relevant information surrounding the
shortage before attending. The Lead Investigator would then attend the branch
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with one or two other Investigators. Some of the Investigators would speak to the
audit team about the information they had obtained and would review the
printouts and balance sheets from the Horizon System. The Lead Investigator
would then speak with the identified suspect to inform them of the reason for the
investigation, to caution them and to go through and sign off various paper work.
I cannot remember what all the paperwork that we went through was but I do
recall that some of the documents related to the suspect's legal rights, whether
they wished to have a ‘Post Office Friend’ present, and seeking permission to
carry out a search if consensual searches were required. Following this, a taped
interview under caution would be conducted with the identified suspect in
accordance with PACE, during which evidence such as the Horizon printouts and
balance sheets would be referred to.
35. Following attendance at the branch the Lead Investigator would then be required
to complete a suspect offender report in line with the template pro-forma used by
the POL Security Team, and would put together a casefile with copies of all the
evidence obtained. As explained above, casefiles would be sent to Team Leaders
for review and eventually they would be passed over to the POL Legal Team. On
some occasions the POL Legal Team would send casefiles back to our Team
Leader if further information or enquiries were required, for example, extra
witness statements. It would then be up to the Lead Investigator on that matter to
obtain that extra evidence.
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Decisions about prosecution and criminal enforcement proceedings
36. Once a case file had been passed over to the POL Legal Team, I believe that the
solicitor who was allocated the matter would review it and make a decision as to
whether the SPM, their manager(s) and / or assistant(s) or a Crown Office
employee could be prosecuted by the POL. The solicitor would also state what
charges would be most appropriate to pursue. I do not know what considerations
determined whether a prosecution was brought other than there had to be
sufficient evidence and it had to be in the public interest. I believe the solicitor
would set out this decision and their reasoning to the Senior Security Manager of
the Investigation/Fraud strand for them to review the casefile and authorise the
decision to prosecute or not. I think ultimately it was the Legal Team who would
decide on the sufficiency of evidence in a case and draft charges, but it was the
Senior Security Manager of the Investigation/Fraud strand who would decide
whether a prosecution should be commenced. I believe this is how the decision
making process was implemented throughout my career as an Investigator.
37.1 do not recall Contract Managers ever being involved in deciding whether a
prosecution was brought or not. As explained earlier in this statement, Contract
Managers dealt with any disciplinary matters running alongside an incident. They
would deal with terminating the suspected individuals contract if deemed
necessary and would organise bringing in a new temporary SPM in to the branch
in question, so that services could continue.
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38.1 do not know what test was applied by those making prosecution and charging
decisions and therefore I cannot comment on what factors were considered at the
public interest stage.
39. I do not know what advice, legal or otherwise was given to those making
decisions about charging and prosecution. In a suspect offender report
Investigators could express an opinion as to whether they thought there was
sufficient evidence for a prosecution or not (based on their findings), but these
opinions did not dictate the next steps that were taken. As stated above, I believe
it was the POL Legal Team who would decide whether there was sufficient
evidence to pursue with a prosecution, with the Senior Security Manager of the
Investigation/Fraud strand approving that decision. I do not think that the Head
of Security would have got involved in this decision making process.
40.1 do not know the circumstances in which steps to restrain a suspect's assets by
criminal Enforcement methods such as confiscation proceedings were
considered. This was dealt with by the Financial Investigation Unit. Criminal
Investigators did not really overlap with this team as Financial Investigators
tended to get involved after a conviction was obtained and the prosecution case
had come to a close. I think sometimes Financial Investigators would contact
Criminal/Fraud Investigators to simply get some background information about
the case.
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41. As set out earlier in this statement, when I first became an Investigator I had to
complete various work books and attend a 5 week training course. In doing so I
believe that I did receive training and guidance on :
i) interviewing a SPM / SPM'’s assistant / Crown Office employee who
was suspected of a criminal offence;
ii) taking witness statements in the course of an investigation;
iii) conducting searches in the course of an investigation;
iv) the duty on an investigator to investigate a case fully;
v) obtaining evidence in the course of an investigation;
vi) an investigator's disclosure obligations;
vii) drafting investigation reports to enable a decision to be made about the
future conduct of a case.
42.1 also recall that I also attended Thames Valley Police HQ and carried out an
additional search awareness course.
43.In terms of obtaining third party evidence, I think I would have learnt about this as
I undertook different case types and from shadowing more Senior Investigators.
In terms of evidence from Fujitsu in particular, I cannot remember how training
and guidance on this was given to Investigators. I must have received some sort
of guidance on this as I do remember that if data from Fujitsu was required in an
investigation then the onus was on the Investigator to obtain this through the
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correct process. I remember that I would have to fill out a form requesting the
period of ARQ data that was required, and this would have to be signed off by a
Senior Manager in the Security Team, before being submitted to Fujitsu. ARQ
data (transaction log data) was very useful information to have for a variety of
Investigations. This data could show which user was logged onto the Horizon
system and what transactions they had conducted. Therefore, this data could
help with many types of Post Office fraud such as Post Office Card Account
Fraud, Postage Label Fraud, Green Giro Fraud, Benefit Fraud etc.
44. When it came to drafting investigation reports, as well as having initial training on
this through the 5 weeks course, we also had a pro-forma template to follow which
assisted Investigators with setting out their findings. The template was often
tweaked during my time with the Investigation Department. As mentioned earlier
in this statement, a completed report would be subject to review by compliance
checks to identify any failings.
45.With obtaining evidence, I believe that we would have been taught in initial
training about the general sort of evidence that would need to be acquired.
However, the necessary evidence to obtain would be slightly different depending
on the type of criminal investigation. For a new Investigator the evidence required
would probably also be relayed by working closely with a more experienced
Investigator and through advice from a Team Leader.
46.1 confirm I have considered the following documents provided in relation to this
subheading:
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i) The Casework Management document at [POL00104747] (version
1.0, March 2000) and [POL00104777] (version 4.0, October 2002);
ii) Dave Posnett’s email dated 23 May 2011 at [POL00118096] and the
documents contained within the attached compliance zip file at
[POL00118108],[POL00118109], [POL00118101], [POL00118102],
[POL00118103], [POL00118104], [POL00118105], [POL00118106]
and [POL00118107].
47. I cannot recall whether I received the 2000 or 2002 version of the Casework
Management document listed above. From my review, the guidance given in the
second, third and fourth bullet points on page 2 of the 2000 version and the first,
second and third bullet points on page 2 of the 2002 version suggest that any
procedural failures relating to products should appear on a separate report to the
suspect offender report in an investigation. I believe that if Horizon integrity was
offered as a reason for a shortfall during an initial investigation then I would have
thought that this this would have been included in the main suspect offender
report. This is because I considered the Horizon IT system to be an independent
operating system and not a POL product. I do not believe I ever experienced a
scenario where Horizon integrity was offered as a reason for a shortfall during an
initial suspect offender interview, but had I experienced this, I would have thought
it was something that the POL Legal Team should be aware of so I think I would
have included the information in the Suspect Offender report.
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48. Compliance checks of investigations were introduced to ensure that Investigators
were consistent in putting together their suspect offender file. I cannot recall who
carried out these checks but I would have thought it was likely to be the Team
Leader and early on possibly the Case Work Management department before
they got disbanded. I recall at one point a new form was introduced with a
compliance score system, so case files were critiqued. I cannot remember when
this was.
49.1 do not believe that I had any role in relation to the development, management
and any amendment of the suite of compliance documents attached to the email
from David Posnett dated 23 May 2011.
50.1 have reviewed paragraph 2.15 of the document entitled “Guide to the
Preparation and Layout of Investigation Red Label Case Files — Offender reports
& Discipline reports” [POL00118101]. The instructions/guidance given suggests
that any security, supervision, procedures and product integrity should be
highlighted in the offender report in bold text. As mentioned previously, if Horizon
Integrity issues were mentioned to me during the initial investigation I believe I
would have recorded this in the offender report as a matter of course. However I
don’t think I would have done it under this particular instruction because I did not
consider it to be a POL product. As stated above, I cannot recall any suspected
individual saying to me during an initial investigation interview that the Horizon IT
was at fault so it is difficult for me reflect on the relevance that paragraph 2.15
had in relation to POL’s disclosure relating to information about Horizon bugs,
errors and defects.
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51.1 do not know who drafted the document entitled Identification Codes” at
[POL00118104] and I do not recall ever seeing this form. I concur that it has been
drafted in an entirely inappropriate manner. I do recall that at the end of a suspect
offender interview an NPA form had to be completed which required the
identification code of the offender to be entered, but it did not look like this. I recall
there being references to IC1, IC2, IC3 etc, which I think related to a specific
identification code. I think the reason why Investigators had to complete
identification codes was so the suspect's details could be entered onto the police
national database if a successful conviction ensued.
52.1 have considered the email from Dave Pardoe, dated 30 August 2011 at
[POL00121772] and the attachment at [POL00121773]. I recall that ‘Project
Golden’ was a special investigation into our Financial Service Specialists (FSS)
who operated out of Crown Office Branches. I believe there was a concern held
that some of the FSS’s were manipulating their sales figures by signing up friends
and family to certain products and then cancelling those products. Investigators
were asked to conduct interviews with FSS’s and submit reports to the relevant
Post Office stakeholders. I cannot recall what training was given on this at the
time but I suspect it was to do with how FSS's carried out their role. During Project
Golden I only carried out the interviews, completed the reports and issued the
reports to whoever was dealing with the disciplinary side.
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Analysing Horizon data, requesting ARQ data from Fujitsu and relationship with
Fujitsu
53. When I was an Investigator I do not recall an SPM ever attributing a shortfall to
a problem with the Horizon System at interview or during the rest of the initial
investigation stages. In the Seema Misra case, this potential issue was not raised
until around a year later. As such, it is hard for me to say what analysis of ARQ
data would have been undertaking in such circumstances. As mentioned earlier
in this statement, ARQ or Transaction Log data supplied by Fujitsu gives an
Investigator information about who was logged onto the Horizon system and what
transactions they had carried out. I can only comment from a hypothetical
standpoint - had an SPM told me during an initial investigation that they thought
a shortfall discovered was due to an error with Horizon, I believe that it is likely I
would have asked the SPM when the discrepancies started to occur and whether
there was a specific transaction that they made that had not been accounted for
properly by the Horizon system. If a certain timeframe or specific transaction was
identified then ARQ data could have been requested. Just for clarification ARQ
data and transaction logs are one and the same. However, I think it would have
had to be Fujitsu who undertook a thorough analysis of any ARQ and other data
they may hold in this scenario as they were trained to understand the
programming and how the IT operating system worked, so they would be in a
much better position to understand where an error may have occurred and why.
54. As I never experienced a situation where a SPM attributed a shortfall to problems
with Horizon during the initial investigation stages, I do not know whether ARQ
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data was requested from Fujitsu as a matter of course in this situation, nor do I
know if such data was provided to that SPM. I know that in the case of Seema
Misra that the defence team were provided with ARQ data when a potential
problem with the Horizon system was later raised during the trial, but I had never
experienced a case previous to this where the integrity of Horizon was questioned
and ARQ data being required for that reason. Previous to this case, the reason I
would request ARQ data usually fell down to needing to know who logged on to
the system at certain times to see who carried out a specific transaction. For
example, with a suspected pension benefit fraud Investigators would want to look
at the transaction log data.
55.Whenever I did need to request ARQ data from Fujitsu, my main contact was
Penny Thomas. However, in the Seem Misra Case I also liaised with Andy Dunks
at Fujitsu when it was raised at trial that there was a potential error with the
Horizon IT system. I believe that Andy Dunks’ role was to analyse fault logs
where an SPM had reported issues with the Horizon system. I do not know if I
ever liaised with Andy Dunks before this case. I also think that my only contact
with Gareth Jenkins from Fujitsu was during the Seema Misra trial. Gareth
Jenkins provided a witness statement for the trial and also attended to give live
evidence. I comment further on the case of Seema Misra under the following
section of this statement — “Prosecution of Seema Misra.”
56. Following a review of the documents provided to me, I believe that I would have
understood at the time that Gareth Jenkins was an expert witness from Fujitsu
who would provide an expert opinion on the integrity of the Horizon IT system in
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criminal proceedings. The reason I believe I would of held this understanding is
because of the language used in the email chain at [FUJ00152889]. In my email
to Jane Owen and Andy Dunks dated 1 December 2012 in that chain I state “/
attach a report from the defence expert where he has highlighted a number of
problems with the Horizon system. Our barrister, Warwick Tatford has asked that
the problems with Horizon that he has raised in his report are replied to in a
witness statement form. I presume that an employee of fujitsu would have to
produce the witness statement”. As I used the words ‘defence expert,’ in this
email I believe that it is likely that I would have thought that any witness statement
produced in response (as was being requested by POL’s barrister Warwick
Tatford) would also be from an expert. The email illustrates that I presumed the
appropriate person to produce this witness statement in response was someone
from Fujitsu. I believe I would have said this because it needed to be someone
who could address the problems raised in the defence expert's report relating to
Horizon. I would have thought that someone from Fujitsu would have been best
placed to do this, as they would understand the Horizon system and
programming. I note that later in the chain at [FUJ00152889] on 17 December
2012 Penny Thomas also refers to Gareth Jenkins as “our expert” to Jane Owen,
and Jane forwards that email to me later that day. Although I think I would have
understood Gareth to be an expert witness, I was not aware of any specific rules
governing independent expert advice and I cannot recall if I was given any advice
or was assisted in this regard.
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Relationship with others
57.1 cannot recall any involvement that I may have had with Cartwright King
Solicitors. I note that one of the documents provided to me mentions Cartwright
King Solicitors, but this is dated 2013 and I had left the Security Team by then. I
think that all my prosecution cases were dealt with by the Post Office Legal Team.
Prosecution of Seema Misra
58. Prior to receiving the Request I did have a good general recollection of the
prosecution of Seema Misra, however, the documents provided to me in relation
to this case have helped me to recall the more specific details. In terms of my
involvement in the case, I was either asked by my Team Leader or the Lead
Investigator to attend West Byfleet Post Office on the 14th August 2008 to assist
with an audit shortage that had been reported. The Lead Investigator on the
matter was Adrian Morris, I was the 2"? Investigator and a 3" Investigator (Lisa
Allen) also attended. From direct memory I could remember that the shortage was
for an amount of around £77,000.
59. I arrived at the branch the same time as Lisa Allen. Adrian Morris was already
there, but I am not sure how long he had been there before we arrived. I believe
that prior to Lisa and I attending, Adrian Morris had already spoken to the Audit
Team to get background information on the shortage and had identified that the
suspect offender was Ms Seema Misra. Once Lisa and I had arrived, Adrian
Morris explained the amount of the shortage to Ms Misra, cautioned her and
explained the steps of the investigation that would happen during the rest of that
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day. Ms Misra was then taken through the necessary forms to be completed, for
example, the legal rights forms, search consent form, and the form relating to
whether she wanted to have a Post Office Friend present.
60. Following this, a search of the flat upstairs was undertaken on a consensual basis.
I then assisted Mr Morris with conducting a taped interview under caution with Ms
Misra. After the interview I then left the Post Office and the suspect offender
report and casefile was put together by Adrian Morris.
6
.I cannot recall the date but following along period of absence by Mr Morris I was
asked to take over the casefile relating to Ms Seema Misra. I think the decision
to charge Ms Misra had already been made by Post Office Legal Services by this
point. My role from then on was to arrange for summonses to be issued and
oversee the case through the court process. I recall that at the first hearing at
Guildford Crown Court, Ms Misra and her defence team informed the Post Office
Legal Team that a not guilty plea would be entered and that Ms Misra was
attributing the audit shortage amount to issues with the Horizon system. Following
this there were requests made by the defence for further documentation to be
produced relating to the Horizon system data. I was tasked with requesting all
the data that the defence were asking for from the relevant people and I made
sure to do so. This did not always mean that all data was provided without further
question, and I deal with this in further detail below. I also recall that I facilitated
a visit to West Byfleet Post Office so that Ms Misra and her defence team could
view the Horizon system and hardware at the branch.
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62. As indicated by the documents provided with the request, I did give evidence at
court in the prosecution of Seema Misra. However, I don’t remember being there
for very long.
63. I confirm that I have considered the following documents:
iii)
iv)
v)
vi)
vii)
viii)
ix)
x)
xi)
xii)
xiii)
xiv)
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 (legal) at [POL00044541];
The memo from Jarnail Singh to the Investigation Team dated 1 April
2008 at [POL00049658);
The emails from April 2008 at [POL00049716];
The email from Jarnail Singh dated 21 April 2008 at [POL00049717];
The memo from Jarnail Singh to the Fraud Team dated 18 November
2008 at [POL00044539);
The Schedule of Charges against Seema Misra at [POL00045010);
The Summary of Facts at [POL00044613];
The signed indictment at [POL00051149];
The witness statements of John Longman, dated 6 January 2009 at
[POL00045495], 5 February 2010 at [POL00054041] and 12 October
2010 at [POL00055530);
The email from Phil Taylor, dated 27 May 2009 at [POL00119335];
The financial investigation events log at [POL00119281];
The transcript of John Longman’s evidence, beginning at page 2
at [UKGI00014845].
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64. As described above, I first became involved in the Seema Misra case on the 14th
August 2008 when I was requested to attend West Byfleet Post Office to assist
with an investigation following the discovery of a cash shortfall by Post Office
Auditors. My initial involvement was to assist the Lead Investigator, Adrian
Morris, with the suspect offender interview with Ms Seema Misra on the 14th
August 2008. I remember that Ms Misra was very cooperative and pleasant
during the interview. At one point she did get upset during the questions asked,
but she confirmed that she was ok to carry on. I was also present when a search
was carried out of the flat above West Byfleet Post Office. Again, Ms Misra was
very pleasant and cooperative during this. The search was consensual and no
items were seized. I cannot recall anything further about the search.
65. As the 2"4 Investigator, I was only assisting Mr Morris as the Lead Investigator
during the interview conducted with Ms Misra. It was Mr Morris who would have
asked the majority of questions. My role was to ensure that Mr Morris completed
all the required legal forms and that all relevant questions were asked.
66. Unfortunately I cannot recall what pre-interview disclosure was provided to Ms
Misra.
67.At the time of the interview there was no mention made by Mrs Misra that the
Horizon IT system was responsible for the cash shortfall.
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68. It is my understanding that it was Mr Jarnail Singh (the solicitor who was in the
POL Legal Team dealing with the case of Ms Misra) in conjunction with the Senior
Security Manager of the Fraud/Investigation strand who made the charging
decision. This also seems to be indicated in the memo from Mr Singh at
[POL00049658]. I note that the email chain at [POL00119335] indicates that I
was spoken to by Warwick Tatford about whether the case for theft was strong
enough. I can’t remember that conversation but I believe it would have been
simply a conversation whereby Warwick set out his thoughts to me on the matter
and as per his email, asked me to make further enquiries into the individuals that
the defence say committed the thefts. I cannot remember who those individuals
were. I do vaguely recall that Dave Posnett said he lived near those individuals
and he went to see if they still resided at the specific address to see if they would
be contactable. However, they no longer lived there and no forwarding address
was available for them. I believe Dave Posnett told me this verbally, but it may
have been by email. The most recent email in the chain at [POL00119335] is
from Philip Taylor to me and indicates that Mr Singh agreed to Mr Warwick's
analysis that the case for theft was strong enough.
69.1 have no direct recollection of who authorised the prosecution of Ms Seema
Misra. However, I have reviewed the email chain at [POL00049716] and this
appears to confirm that it was Dave Pardoe. Whilst it was the POL Legal Team
who ultimately dealt with the prosecution, I believe it was standard practice to
liaise with a Senior Security Manager of the Fraud/Investigation strand for his/her
agreement to proceed with a prosecution.
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70. I confirm that I have considered the following documents:
i) The Schedule of Non-Sensitive Unused Material dated 23 January 2009
at[POL00050750);
ii) The Schedule of Sensitive Material dated 23 January 2009 at
[POL00050751);
iii) The Audit Record Query (“ARQ”) dated 9 June 2009 at
[POL00051793);
iv) The emails dated 22 June 2009 at [FUJ00122608);
v) I The email from you to Andy Dunks, dated 23 June 2009 [FUJ00152816];
vi) I The email from you to Andy Dunks, dated 24 June 2009 [FUJ00152817];
vii) The emails dated June and August 2009 at [POL00052222);
viii) The emails dated August 2009 at [POL00107662];
ix) The report of Charles McLachlan dated 21 September 2009 at
[POL00093689] and the 24 interim report of Charles McLachlan
dated 19 November 2009 at [POL00094101] and the 3rd interim
report of Charles McLachlan dated 3 February 2010 at
[POL00053992);
x) 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);
xi) The email from me to Andy Dunks, dated 16 November 2009
[FUJ00152838];
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xii) The email from me, dated 18 November 2009 [FUJ00152841];
xiii) The email from me, dated 26 November 2009 at
[FUJ00152843] and attachments at [FUJ00152844] and
[FUJ00152845]:
xiv) The further request for disclosure, dated 30 November 2009 at
[POL00124857];
xv) The email from me dated 2 December 2009 at [FUJ00152851];
xvi) The email from Penny Thomas, dated 17 December 2009 at
[FUJ00152871];
xvii) The email from me, dated 24 December 2009 at [FUJ00152876];
xviii) Counsel’s Advice dated 5 January 2010 at [POL00044557];
xix) The letter from Jarnail Singh to Messrs Coomber Rich
dated 11 January 2010 at [POL00053746);
xx) The email from me, dated 27 January 2010 at
[FUJ00152889] and attachment at [FUJ00152890];
xxi) The letter from Jarnail Singh to Messrs Coomber Rich
dated 27 January 2010 at [POL00044553];
xxii) The email from me, dated 28 January 2010, at [FUJ00152897] (page
2);
xxiii) The attendance note, dated 27 January 2010 at [POL00053849];
xxiv) The letter to Messrs Coomber Rich dated 27 January 2010 at
[POL00044553};
xxv) My email dated 29 January 2010 at [POL00053880] and the audit report
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dated 14 October 2005 at [POL00093865];
xxvi) The attendance note dated 1 February 2010 at[UKGI00014903];
xxvii) The email from me, dated 1 February 2010, at [FUJ00152896];
xxvili)The email from me, dated 2 February 2010 at[FUJ00152901);
xxix) The witness statement of Gareth Jenkins dated 2 February 2010 at
[POL00053937];
Xxx) The email from Penny Thomas to me, dated 3 February 2010 at
[FUJ00152905];
xxxi) The email from me, dated 12 February 2010 at [FUJ00154881];
xxxii) The ARQ Request, dated 26 February 2010 at [FUJ00155189];
xxxiii) The notice of additional evidence and attached witness statements
dated 26 February 2010 at [POL00058450);
xxxiv)The email from me, dated 1 March 2010 at [FUJ00153007];
xxxv) The 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));
xxxvi)The email from Penny Thomas to me, dated 5 March 2010 at
[FUJ00153029}:
Xxxvii) The email from me to Penny Thomas, dated 9 March 2010 at
[FUJ00153039);
xxxvilil)The notice of additional evidence and attached witness
statements dated 18 March 2010 at [POL00058440];
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xxxix)The email from Jarnail Singh to me, dated 6 April
2010 at [POL00054557];
xl) The email from Penny Thomas, dated 6 April 2010
at [FUJ00153068);
xli) The email from Penny Thomas, dated 8 April 2010
at [FUJ00153073];
xlil) The email from me, dated 8 April 2010 at
[FUJ00153074] (at page 2);
xliii) The email from me, dated 9 April 2010 at
[FUJ00153075];
xliv) The email from me to Gareth Jenkins, dated 6 May
2010 at [FUJ00153094];
xlv) Gareth Jenkins’ witness statement dated 8 July
2010 at [FUJ00122906];
xlvi) The email from you to the Fraud team, dated 14 July
2009 at [FUJ00152818];
xlvii) The email from Jarnail Singh to John Longman,
dated 15 July 2010 at [FUJ00153131] (page 4);
xlviii) The email from me to Penny Thomas, dated 15 July
2010 at [FUJ00153132] (page 2):
xlix) The email from Penny Thomas to me, dated 27 July
2010 at [FUJ00153159];
i) The email from me, dated 27 July 2010 at
[UKG100014898};
li) The email from me, dated 20 August 2010 at
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[FUJ00153230];
li) I The Schedule of Non-Sensitive Unused Material
dated 8 September 2010 at [POL00055217] (the covering
letter from Rob Wilson sending this to the Defence is
dated 15 September 2010 and is at [POL00055236));
lili) The email from Andy Bayfield to me, dated 9
September 2010 at [FUJ00153279];
liv) The email from you, dated 15 September 2010 at
[POL00093841];
lv) I The email from Marilyn Benjamin, dated 4 October
2010, at [FUJ00153345);
lvi) I The report of Charles McLachlan dated 4 October 2010
at [FUJ00083736);
\viil) The email from me to Gareth Jenkins, dated 6 October
2010, at [FUJ00153358] and the attachments at
[FUJ00153359], [FUJ00153360], [FUJ00153361],
[FUJ00153362],[FUJ00153363], [FUJ00153364] and
[FUJ00153365);
\viii) The emails between Warwick Tatford and Gareth
Jenkins, dated October 2010, at [FUJ00153368];
lx) I The email from me to Warwick Tatford and Jarnail Singh,
dated 7 October 2010, at [FUJ00153371]
[FUJ00154958);
kx) I The emails with Gareth Jenkins, dated October 2010
at [FUJ00224966);
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Ixi)
Ixii)
\xiii)
Ixiv)
Ixv)
Ixvi)
The emails with Gareth Jenkins, dated 8 October
2010 at [FUJ00224967] and attachments at
[FUJ00224968], [FUJ00224969], [FUJ00224970],
[FUJ00224971];
The draft statement of Gareth Jenkins at
[POL00110275):
The addendum report from Charles McLachlan dated 11
October 2010 at [POL00030298);
The Joint Statement to the Court by Gareth Jenkins and
Charles McLachlan dated 11 October 2010 at
[POL00001882];
The email from Gareth Jenkins to Charles MacLachlan,
dated 11 October 2010 at [FUJ00153390];
The email from me, dated 11 November 2010 at
[FUJ00153425].
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71. As indicated by the schedules of material signed off by me at [POL00050750]
and [POL00050751], it is clear that I gathered and organised the necessary
disclosure schedules for the committal bundle in this matter, which I can only
assume means that I was the Disclosure Officer. However, I would like to point
out to the Inquiry that I did not realise at the time that I had this official title. I would
have provided the committal bundle, copies of witness statements, copies of
exhibits and disclosure schedules to the POL Legal Team to review and they
would have dealt with providing disclosure to the defence team. I would not have
had any involvement in providing disclosure to the defence team.
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72. Once the defence had attributed the shortfall discovered to a problem with the
Horizon system, ARQ data was then requested in the case of Ms Seema Misra.
The emails at [FUJ00153007] indicate that data for the period 1st December 2006
to 31st December 2007 was retrieved from the Horizon system, and I made the
request for this data based on advice from the POL Legal Team.
73. I believe I was the only person responsible for collating disclosure for the
committal bundle in this matter and it was me who actioned all further disclosure
request made by the defence to the relevant departments. The documents
produced to me in relation to the case of Seema Misra confirm this. As explained
above, some requested disclosure was provided and some was not. If requests
were not forthcoming then I would have reported this back to the POL Legal Team
for advice. I don’t have a view on the merits of the disclosure requested.
74. It is my understanding that that the amount of ARQ requests that the defence
wanted was deemed excessive as the defence wanted to see around 3 years’
worth of data — I requested this data but as seen in the email from Dave Posnett
in the chain at [POL00107662], there were concerns held in relation to how much
of the POL’s data request quota would be used up. I cannot recall my reaction to
this email from Dave Posnett. From hindsight I imagine I would have thought it
was a larger than usual request as I was aware that POL had a contract with
Fujitsu where only a certain number of ARQ requests would be provided without
further costs being incurred by POL. As you can see in the email chain, I simply
referred to the Legal Team for advice.
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75. I cannot recall how Penny Thomas’ involvement came about in the case of
Seema Misra, but I do recall that she provided ARQ data together with a witness
statement. Gareth Jenkins became involved so that he could produce a witness
statement in response to the defence expert's report and be called to give
evidence in relation to the integrity of Horizon. My understanding is that Penny
Thomas was more junior to Gareth Jenkins in that she carried out more of the
administrative roles for Fujitsu. For example, she was the key point of contact to
request ARQ data when required and her statements would provide an account
about the provision of such data requests in cases. I believe that Gareth on the
other hand would not have dealt with these administrative matters. I understood
him to be a Senior Manager within Fujitsu as he provided more technical witness
evidence on issues raised about the Horizon system. In the case of Seema Misra
I was asked to go to the Fujitsu Head Office (which I believe was near
Maidenhead) to take a witness statement from Gareth Jenkins. I cannot
remember who asked me to go and take this statement — I imagine it was the
Legal Team. When I arrived Gareth told me to leave it with him and that he would
produce a written statement and send it over. I vaguely recall further down the
line going to a meeting at Chambers. Document [FUJ00153368] suggests that
the meeting took place on the 5' October 2010 and that Gareth Jenkins, Jarnail
Singh, Warwick Tatford and myself were the attendees. I cannot recall if anybody
else was present.
76. 1 cannot recall giving any direct instructions to Mr Jenkins. I imagine his
instructions came from the POL Legal Team and Counsel, Warwick Tatford. As
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stated above, I was asked to go and take a statement from Mr Jenkins, but in the
end he produced it himself. I am sure that I probably read through Mr Jenkins’
statement once provided, but I cannot recall having any views on it, nor providing
any comments on it. I think it would have been Counsel who would have reviewed
and critiqued Mr Jenkins’ statement. The email chain at [FUJ00153371] seems
to indicate this as it shows Warwick emailing Mr Jenkins on 7 October 2012 which
says “Please find attached your draft with my comments in red.” Mr Jenkins then
replies to Warwick on the same day and says “Thanks for the feedback. I'll try
and amend as suggested once I've finished my further analysis.”
77. The emails produced to me in relation to this prosecution do refer to Mr Jenkins
as being an expert witness in this case, examples being [FUJ00152871],
[FUJ00152889], [FUJ 00152897] etc. As he was referred to by others as an
expert then I would have considered him to be one. I am unaware of what the
difference would have been between an expert or lay witness. I do not recall any
information that was given to him by me in relation to the role of an expert witness
and the duties he owed to the court if he was an expert witness. I don’t think it
would have been my role to give him this information. I am not sure who would
have had that role.
78. I cannot recall anyone from Fujitsu or POL explaining to me that there were bugs,
errors or defects in the Horizon system that would make the system unreliable,
during the Seema Misra case or at any other time. I always thought the system
functioned correctly. Had I been told otherwise I would have raised my concerns
during an investigation.
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79.1 cannot recall whether Mr Jenkins expressed any views in relation to the
disclosure being sought by the Defence and the relevance of the material sought
to the case.
80. I confirm that I have considered the document [FUJ00153132] which refers to
the duplication of the ARQ records found in this matter. I had no understanding
about the duplication of the ARQ records other that it was said to have had no
bearing on the accuracy of the Horizon data. As such, I do not think I would have
held a view as to the impact of this had on the case.
8
=
. I have reviewed the attendance note at [POL00053849] dated 27 January 2010
and the comment within it that states “Jon Longman has been chased on Horizon
but this has not been in hand at the moment”. Unfortunately due to the passage
of time I cannot recall what this is in reference to. I can only assume that I was
still waiting for some information I had requested from Fujitsu, but I cannot say
this for certain.
82. I cannot provide an account from direct memory of the requests for access made
by the Defence on 22 July 2010 and the response provided by POL, Therefore I
am relying entirely on the documents produced to me with the Request.
Document [UKGI00014898] illustrates that I requested the said information
sought by the defence but this seems to have been deemed unnecessary by
Chesterfield and the POL Legal Team. It appears that I was told that the Defence
would have to make a Section 8 application to the court for this information. I do
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not think I was entirely sure what a section 8 application was, I was simply
following the advice given to me.
83. I cannot recall what criminal enforcement proceedings were taken against Ms
Seema Misra. As explained above, Recovery of losses faced by the POL as result
of crime committed by an SPM was something that Financial Investigators in the
Security Team dealt with.
84. Other than my involvement described above, I had no further involvement in the
prosecution of Ms Seem Misra. I believe that by the time sentencing took place,
Adrian Morris had returned to work and he attended the sentencing hearing.
85. I have considered [POL00055759] and [POL00055590]. Unfortunately I cannot
recall what my view of the outcome of this case was at the time.
86. I have reviewed the Judgment of the Court of Appeal in Josephine Hamilton &
Others v Post Office Limited [2021 EWCA Crim 577 at [POL00113278]. Upon
reflection on this case, I do not think that I would have done anything differently.
The initial investigation and interview under caution where I assisted was all
carried out in accordance with PACE and I believe we acted in accordance with
how we had been trained to conduct investigations. Following my review of the
offender report completed by Mr Morris during the initial investigation, it all seems
compliant.
Page 42 of 58
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87. The record of interview with Ms Misra illustrates that she had admitted to entering
incorrect data on to the Horizon system (which is false accounting) and she
explains that there had been theft committed at the branch by past employees. A
year had gone by before any issues were raised by Ms Misra’s Defence team in
relation to the integrity of the Horizon system — had any issues in relation to the
reliability and integrity of the Horizon System been raised from the outset then I
believe the direction of the investigation would have been different. I believe that
it would have been a concern and a line of Inquiry that needed to be addressed
before any decision in relation to charges and whether to prosecute was reached
by the Legal Team.
Prosecution of Julian Wilson
88. I confirm that I have reviewed the following documents in relation to this case:
i) The audit report, dated 11 September 2008 at [POL00050062];
ii) The record of the interview at [POL00044804] and [POL00050138);
iii) The stakeholder notification at [POL00047065);
iv) The suspect offender report at [POL00044695);
v) The investigation report at [POL00044692);
vi) The case closure report at [POL00065047].
89. I would like to flag to the Inquiry that I played no role the initial investigation or
the criminal proceedings that followed against Mr Julian Wilson. From a review of
the documents provided to me in, I can see that this matter was allocated to Gary
Page 43 of 58
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Thomas and Graham Brander, who were other Investigators within the Security
Team.
90. I have also reviewed the following documents:
i) The emails from me and various individuals at Fujitsu at
[FUJ00155018)], [FUJ00155021], [FUJ00155050);
ii) The email from Pat Davies, dated 31 August 2011 at [POL00114736];
iii) The email from Pat Davies, dated 1 September 2011 at
[POL00114717] and [POL00114722):
iv) The email from Pat Davies, dated 5 September 2011 at
[POL00114697];
v) The email from Pat Davies, dated 9 September 2011 at
[POL00114706);
vi) The email from Penny Thomas, dated 15 September 2011 at
[FUJ00225264];
vii) The email from me to Penny Thomas at 28 September 2011 at
[FUJ00155051];
viii)The email from me at [FUJ00155070] (page 1);
ix) The email from me, dated 27 October 2011 at [POL00114698].
91. It appears that after the conviction of Julian Wilson was already obtained, I was
called to a meeting with solicitors dealing with the enforcement proceedings and
I was asked if I could obtain ARQ data costings from Fujitsu where SPMs were
not repaying money to POL for the loss suffered. I think that the reason they were
Page 44 of 58
WITNO04670100
WITN04670100
not paying back the losses was because they were attributing the losses to issues
with the Horizon IT system. I believe the ARQ data was requested by their
defence teams. In total there were four Post Offices for which ARQ data costings
were requested. They were, Alderley Edge, Astwood Bank, Hockley and Splott
Road.
92.1 cannot recall that I was aware of any allegations made by Mr Wilson about the
reliability of the Horizon IT system until I was requested to deal with defence
disclosure requests relating to ARQ data, as described above. I cannot recall who
or why I was asked in particular to assist with obtaining these Defence data
requests. All I can say is that the above emails illustrate me making those
requests to Fujitsu, so I was clearly asked to do this
93. I cannot recall who was present at the meeting I had with solicitors, nor what was
discussed. I can only rely on what I have included in my email at [FUJ00155051].
I have been asked to explain what I meant when I said in this email that the feeling
from the meeting was that a lot of the requests for information were unnecessary
and should be challenged. I cannot recall directly what I meant by this and I do
not know who raised this concern in particular. I can only assume that the concern
related to the fact the requests being made by the Defence were large and as
explained above, POL had a contract with Fujitsu where only a certain number of
ARQ requests would be provided without further costs being incurred by POL.
Page 45 of 58
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94.1 do not know who made the decision to request an undertaking from Defence
solicitors to pay the costs of retrieving data from Fujitsu and cannot recall what
my view was of this.
95. I confirm that I have reviewed [FUJ00225264]. It is clear from my emails in this
chain that I was asked to obtain further horizon data, but I needed to get a costing
estimate for such information. I cannot recall being aware of any of the email
discussions in the chain after my initial two. The remainder of the emails appear
to be internal ones between Fujitsu employees. I cannot recall if I was made
aware by Fujitsu employees of the concerns being discussed in such emails.
96. Other than my minimal involvement post-conviction (as described above) I had
no further involvement in the case of Julian Wilson.
General
97. At the time, I do not believe that I considered a challenge to the Horizon system
in one case to be relevant to other cases. As explained earlier in this statement,
it was never confirmed to me that there was a definite fault with the Horizon
System. As such, I was under the impression that the system was operating as
expected.
98. Other than the matters referred to above, I do not wish to bring any other matters
to the attention of the Chair of the Inquiry.
Page 46 of 58
Statement of truth
I believe the content of this statement to be true
Dated: 08 November 2023
Page 47 of 58
WITNO04670100
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Index to First Witness Statement of Jonathan Longman
WITNO04670100
WITN04670100
No
URN
Document Description
Control Number
POL00126360
Curriculum Vitae of Jon Longman
POL-0132918
POL00104747
Investigation Policy: Casework
Management (England & Wales) v1.0
POL-0080387
POL00104777
Casework Management Policy version
4.0, October 2002
POL-0080417
POL00104754
Rules and Standards Policy (version
2.0, October 2000
POL-0080394
POL00030687
Investigation Policy - Investigation
Procedures v2 January 2001
POL-0027169
POL00104762
Disclosure Of Unused Material, Criminal
Procedures and Investigations Act 1996
Codes of
Practice Policy (version 1.0, May 2001)
POL-0080402
POL00030578
Royal Mail Group Ltd Criminal
Investigation and Prosecution Policy", 1
December 2007
POL-0027060
POL00104812
"Royal Mail Group Ltd Criminal
Investigation and Prosecution Policy", 1
December 2007
POL-0080444
POL00104806
"Royal Mail Group Security - Procedures
& Standards - Standards of Behaviour
and Complaints Procedure" , Version 2,
October 2007
POL-0080438
10.
POL00031003
"Royal Mail Group Crime and
Investigation Policy", Version 1.1,
October 2009
POL-0027485
11.
POL00030580
"Post Office Ltd - Security Policy - Fraud
Investigation and Prosecution Policy"
(version 2, 4 April
2010)
POL-0027062
12.
POL00030579
"Post Office Ltd Financial Investigation
Policy" (4 May 2010)
POL-0027061
13.
POL00104848
Royal Mail Group Security — Procedures
& Standards: “Appendix 1 to P&S 9.5
Disclosure of Unused Material & The
Criminal Procedure & Investigations Act
1996” (Version 1, July 2010)
POL-0080480
14.
POL00104837
Royal Mail Group Security —- Procedures
& Standards: “Committal & Summary
POL-0080469
Page 48 of 58
WITNO04670100
WITN04670100
Trial Papers & Processes” (Version 1,
July 2010)
15.
POL00026573
“Royal Mail Group Security - Procedures
& Standards - The Proceeds of Crime
Act 2002 & Financial Investigations"
(version 1, September 2010)
POL-0023214
16.
POL00104857
“Royal Mail Group Security - Procedures
& Standards - Initiating Investigations"
(September 2010)
POL-0080489
17.
POL00031008
"Royal Mail Group Ltd Criminal
Investigation and Prosecution Policy"
(version 1.1, November 2010)
POL-0027490
18.
POL00104853
Post Office Ltd Financial Investigation
Policy (version 2, February 2011)
POL-0080485
19.
POL00104855
Post Office Ltd Anti-Fraud Policy
(February 2011)
POL-0080487
20.
POL00030786
"Royal Mail Group Policy Crime and
Investigation S2" (version 3.0, April
2011)
POL-0027268
21.
POL00105229
“Post Office Ltd PNC Security Operating
Procedures” (August 2012)
POL-0080854
22.
POL00104929
Post Office Limited: Internal Protocol for
Criminal Investigation and Enforcement
(with flowchart)", (October 2012)
POL-0080561
23.
POL00105226
"Undated Appendix 1 - POL Criminal
Investigations and Enforcement
Procedure (flowchart), (October 2012)
POL-0080851
24.
POL00104968
Undated document entitled “POL —
Enforcement & Prosecution Policy”
POL-0080600
25.
POL00030602
"Post Office Limited: Criminal
Enforcement and Prosecution Policy"
(undated)
POL-0027084
26.
POL00031005
"Conduct of Criminal Investigations
Policy" (version 0.2, 29 August 2013)
POL-0027487
27.
POL00027863
"Conduct of Criminal Investigations
Policy" (version 3, 10 February 2014
POL-0024504
28.
POL00030902
"Conduct of Criminal Investigations
Policy" (September 2018)
POL-0027384
29.
POL00104821
“Condensed Guide for Audit
Attendance” (version 2, October 2008)
POL-0080453
30.
POL00118096
Dave Posnett’s email dated 23 May
2011
VIS00012685
Page 49 of 58
WITNO04670100
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31.
POL00118108
Appendix 1 - Case Compliance
checklist
VIS00012697
32.
POL00118109
Appendix 2 - File construction and
Appendixes A, B and C: "Compliance
Guide: Preparation and Layout of
Investigation Red Label Case Files"
VIS00012698
33.
POL00118101
Appendix 3 - Offender reports and
Discipline reports: "Compliance
Guide to the Preparation and Layout
of Investigation Red Label Case
Files"
VIS00012690
34.
POL00118102
Appendix 4 - Offender reports layout:
"POL template Offender Report
(Legal Investigation)"
ViS00012691
35.
POL00118103
Appendix 5 - Discipline reports
layout: "POL template Offender
Report (Personnel Investigation)"
VIS00012692
36.
POL00118104
Appendix 6 - Identification codes
VIS00012693
37.
POL00118105
Appendix 7 - Tape Interviews. "POL
Security Operations Team guide:
Summarising of Tape Recorded
Interviews."
VIS00012694
38.
POL00118106
Appendix 8 - Notebooks: Guidance
on using notebooks in investigations
VIS00012695
39.
POL00118107
Appendix 9 - Case Progression
Toolkit.
VIS00012696
40.
POL00121772
Email chain from Dave Pardoe to
Allison Drake, Andrew Wise, Dave
Posnett and others Re: FW: Project
Golden - process/issues arising from
security training
POL-0128032
41,
POL00121773
Appendix 4 - Offender reports layout:
"POL template Offender Report
(Legal Investigation)"
POL-0128033
42.
POL00058550
The Audit Report dated 16 January
2008
POL-0055029
43.
POL00119329
Record of Tape Recorded Interview
of Seema Misra - Tape Reference
Number: 060341
POL-0119248
44.
POL00119330
Record of Tape Recorded interview
of Seema Misra -Tape ref: 060342 -
Interviewing officer Adrian Morris and
John Longman
POL-0119249
45.
POL00044541
POL Investigation Report for Seema
Misra (POLTD/0708/ 0249)
POL-0041020
Page 50 of 58
WITNO04670100
WITN04670100
46.
POL00049658
Memo from Jarnail Singh to
Investigation Team Post Office Limited
and Adrian Morris re Post Office Limited
v Seema Misra. POLTD/0708/0249.
Opinion that there is sufficient evidence
to prosecute, and in the Crown Court.
POL-0046137
47.
POL00049716
Email from Jason G Collins to Jarnail A
Singh re: DAM Authority Seema Misra
West Byfleet
POL-0046195
48.
POL00049717
Email from Jarnail Singh dated 21 April
2008
POL-0046196
49.
POL00044539
Memo from Jarnail Singh to the Fraud
Team dated 18 November 2008
POL-0041018
50.
POL00045010
Schedule of Charges against Seema
Misra
POL-0041489
51.
POL00044613
Summary of facts (POL v Seema Misra)
POL-0041092
52.
POL00051149
Signed indictment
POL-0047628
53.
POL00045495
Witness statements of John Longman,
dated 6 January 2009
POL-0041974
54.
POL00054041
Witness statements of John Longman,
dated February 2010
POL-0050520
55.
POL00055530
Witness statements of John Longman,
dated 12 October 2010
POL-0052009
56.
POL00119335
Seema Misra Case Study: Email chain
from Phil Taylor to Fraud Team and
John Longman. Re: Regina v Seema
Misra Guildford Crown Court Trial
between the dates of 1 - 12 June 2009
POL-0119254
57.
POL00119281
POL Financial Investigation Events Log
for Case Number POLTD/0708/0249
(West Byfleet Branch - Seema Misra)
POL-0119200
58.
UKGI00014845
Transcript of John Longman’s evidence
UKGI025638-001
59.
POL00050750
Schedule of Non-Sensitive Unused
Material dated 23 January 2009
POL-0047229
60.
POL00050751
Schedule of Sensitive Material dated 23
January 2009
POL-0047230
61.
POL00051793
Audit Record Query (“ARQ”) dated 9
June 2009
POL-0048272
62.
FUJ00122608
Email from Dave Posnett to Andy Dunks
re: WS for West Byfleet HSH calls
POINQ0128822F
63.
FUJ00152816
Email from Andy Dunks to John
Longman re WS for West Byfleet HSH
calls.
POINQ0159011F
Page 51 of 58
WITNO04670100
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64.
FUJ00152817
Email to Andy Dunks, dated 24 June
2009
POINQ0159012F
65.
POL00052222
Emails dated June and August 2009
POL-0048701
66.
POL00107662
Emails dated August 2009
POL-0105957
67.
POL00093689
Report of Charles McLachlan dated 21
September 2009
POL-0093811
68.
POL00094101
2°¢ Interim report of Charles McLachlan
dated 19 November 2009
POL-0094223
69.
POL00053992
34 Interim report of Charles McLachlan
dated 3 February 2010
POL-0050471
70.
POL00052487
Letter from Coomber Rich dated 1
October 2009
POL-0048966
71.
POL00052462
Application by the defence pursuant to
s8 of the criminal procedure and
investigations act for disclosure of
relevant material
POL-0048941
72.
POL00058503
Email from Warwick Tatford to John
Longman, Re: Misra further disclosure
request from the defence.
POL-0054982
73.
FUJ00152838
Email from Andy Dunks to Leighton
Machin Re WS for West Byfleet -
Additional Information Requested
POINQ0159033F
74.
FUJ00152841
Email from Andy Dunks to Tom
Lillywhite, cc'iing Penny Thomas, re Trial
of Seema Misra - Guildford Crown Court
WIC 30th November 2009
POINQ0159036F
75.
FUJ00152843
Email from John Longman to Jane
Owen cc Andy Dunks re Seema Misra
Trial (West Byfleet PO) - Interim
technical expert's report and request
from the defence regarding hardware
installed at West Byfleet
POINQ0159038F
76.
POL00046162
(updated URN
FUJ00152844
the Request)
for
2nd Interim Technical expert's report to
the Court prepared by Charles Alastair
McLachlan, a Director of Amsphere
Consulting Ltd - R v Seema Misra
POINQ0159039F
77.
FUJ00152845
Card Information Flow OVerview
RePOS/EFT - Misra - Electronic Funds
Transfer PCI Schedule
POINQ0159040F
78.
POL00124857
Further Request for Disclosure from Issy
Hogg to Phil Taylor, dated 30 November
2009
POL-0131691
79.
FUJ00152851
Email from Jane Owen to Penny
Thomas re Seema Misra West Byfleet
branch, dated 2 December 2009
POINQ0159046F
Page 52 of 58
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80. FUJ00152871 Email from Penny Thomas to Jane POINQ0159066F
Owen re Seema Misra trial - Guildford
Crown Court., dated 17 December 2009
81. FUJ00152876 Email re Regina V Seema Misra, dated I POINQ0159071F
24 December 2009
82. POL00044557 Counsel's Advice dated 5 January 2010 I POL-0041036
83. POL00053746 letter from Jarnail Singh to Messrs POL-0050225
Coomber Rich dated 11 January 2010
84. FUJ00152889 Email from Thomas Penny to Gareth
Jenkins attaching expert report in case I POINQ0159084F
of Seema Misra, dated 27 January 2010
85. FUJ00122678 Seema Misra's case study: 2nd POINQ0159085F
(updated URN for I Interim Technical expert's report to
FUJ00152890 inI the Court prepared by Charles
the Request) Alastair McLachlan, a Director of
Amsphere Consulting Ltd.
86. POL00044553 Letter from Jarnail Singh to Messrs
Coomber Rich dated 27 January 2010 POL-0041032
87. FUJ00152897 Email from Thomas Pnny to Tom POINQ0159092F
Lillywhite and Gareth Jenkins re West
Byfleet Issues, dated 28 January 2010,
88. POL00053849 Attendance note, dated 27 January
2010 POL-0050328
89. POL00053880 Email re West Byfleet- Latest Defence
Request for Disclosure dated 29 POL-0050359
January 2010
90. I POL00093865 Audit report dated 14 October POL-0093987
2005
91. UKGI00014903 Attendance note dated 1 February 2010
UKGI025696-001
92. IFUJ00152896 Email dated 1 February 2010. POINQ0159091F
93. FUJ00152901 Email dated 2 February 2010
POINQ0159096F
94. I POL00053937 Witness statement of Gareth Jenkins
dated 2 February 2010 at POL-0050416
95. FUJ00152905 Email from Penny Thomas to you, dated I POINQ0159100F
3 February 2010
Page 53 of 58
WITNO04670100
WITN04670100
96.
FUJ00154881
Email re West Byfleet- Horizon Service
Helpdesk Calls dated 12 February 2010
POINQ0161076F
97.
FUJ00155189
ARQ Request, dated 26 February 2010
POINQ0161384F
98.
POL00058450
Notice of additional evidence and
attached witness statements dated 26
February 2010
POL-0054929
99.
FUJ00153007
Email re West Byfleet- 162023, dated 1
March 2010
POINQ0159202F
100.
POL00054267
Memo from Jarnail A Singh to Gareth
Jenkins re. Regina v Seema Misra
Guildford Crown Court Trial - 15th
March 2010
POL-0050746
101.
POL00054126
Attachment — the 4th Interim Technical
Expert's reports prepared by Charles
McLachlan
POL-0050605
102.
POL00054257
Attachment — the Sth Interim Technical
Expert's reports prepared by Charles
McLachlan
POL-0050736
103.
FUJ00153029
Email chain from Penny Thomas to
John Longman cc Jane M Owen re:
REGINA v SEEMA MISRA
GUILDFORD CROWN COURT TRIAL -
15TH MARCH 2010
POINQ0159224F
104.
FUJ00153039
Email to Penny Thomas re West Bufleet
(126023)- Witness Statement from
Fujitsu, dated 9 March 2010
POINQ0159234F
105.
POL00058440
The notice of additional evidence and
attached witness statements dated 18
March 2010
POL-0054919
106.
POL00054557
Email from Jarnail Singh re Mrs Seema
Misra - POLtd 0708/0249, dated 6 April
2010
POL-0051036
107.
FUJ00153068
Email from Penny Thomas re West
Byfleet- 126023- Witness statement
from lan Venables, dated 6 April 2010
POINQ0159263F
108.
FUJ00153073
Email from Penny Thomas re West
Byfleet: Seema Misra Case Study,
dated 8 April 2010
POINQ0159268F
109.
FUJ00153074
Email from Thomas Penny to lan
Venables re West Byfleet — 126023,
dated 8 April 2010
POINQ0159269F
110.
FUJ00153075
Email re West Byfleet- Trial of Seema
Misra, dated 9 April 2010
POINQ0159270F
111.
FUJ00153094
Seema Misra Criminal Case Study:
Email with attachment from Gareth
POINQ0159289F
Page 54 of 58
WITNO04670100
WITN04670100
Jenkins to Penny Thomas re:
Transaction Errors West-Byfleet
112.
FUJ00122906
Gareth Jenkins’ witness statement
dated 8 July 2010
POINQ0129120F
113.
FUJ00152818
Email to the Fraud team, dated 14 July
2009
POINQ0159013F
114.
FUJ00153131
Email re Regina v Seema Misra-
Experts, dated 15 July 2010
POINQ0159326F
115.
FUJ00153132
Email re Duplication of Transaction
Records in ARQ Returns, dated 15 July
2010
POINQ0159327F
116.
FUJ00153159
Email from Penny Thomas re requests
following experts meeting- R V Seema
Misra, dated 27 July 2010
POINQ0159354F
117.
UKGI00014898
Email re Seema Misra Case Study,
dated 27 July 2010
UKGI025691-001
118.
FUJ00153230
Email re Seema Misra Trial, dated 20
August 2010
POINQ0159425F
119.
POL00055217
Schedule of Non-Sensitive Unused
Material dated 8 September 2010
POL-0051696
120.
POL00055236
Covering letter from Rob Wilson sending
this to the Defence is, dated 15
September 2010
POL-0051715
121.
FUJ00153279
Email from Andy Bayfield re West
Byfleet- Trial date- 11 October 2010,
dated 9 September 2010
POINQ0159474F
122.
POL00093841
Email re West Byfleet- Seema Misra,
dated 15 September 2010
POL-0093963
123.
FUJ00153345
Email from Marilyn Benjamin, dated 4
October 2010
POINQ0159540F
124.
FUJ00083736
Report of Charles McLachlan dated 4
October 2010
POINQ0089907F
125.
FUJ00153358
Email to Gareth Jenkins, dated 6
October 2010
POINQ0159553F
126.
FUJ00153359
Seema Misra Criminal Case Study:
Final Branch Statement from
11/10/2006 - 21/11/2006 at West
Byfleet PO branch
POINQ0159554F
127.
FUJ00153360
Seema Misra Criminal Case Study:
Final Branch Trading Statement from
12/07/2006 - 18/08/2006
POINQ0159555F
128.
FUJ00153361
Final Branch Trading Statement for
West Byfleet branch (1260235) for
period 10/1/2007 to 13/02/2007
POINQ0159556F
Page 55 of 58
WITNO04670100
WITN04670100
129.
FUJ00153362
Final Branch Trading Statement
POINQ0159557F
130.
FUJ00153363
Final Branch Trading Statement
POINQ0159558F
131.
FUJ00153364
Final Branch Trading Statement
POINQ0159559F
132.
FUJ00153365
Seema Misra Criminal Case Study -
Final Branch Trading Statement for
West Byfleet
POINQ0159560F
133.
FUJ00153368
Emails between between Warwick
Tatford and Gareth Jenkins, dated
October 2010
POINQ0159563F
134.
FUJ00153371
Emails to Warwick Tatford and Jarnail
Singh, dated 7 October 2010
POINQ0159566F
135.
FUJ00154958
Seema Misra case study: Email from
Wariwick tatford to Gareth Jenkins re:
Draft Witness Statement
POINQ0161153F
136.
FUJ00224966
Emails with Gareth Jenkins, dated
October 2010
POINQ0231081F
137.
FUJ00224967
Emails with Gareth Jenkins re Witness
Statement v3, dated 8 October 2010
POINQ0231082F
138.
FUJ00224968
Table showing Total value of
Transactions that can potentially be
associated with Transaction Corrections
with further comments from Gareth
Jenkins
POINQ0231083F
139.
FUJ00224969
Fujitsu Services - Horizon Office
Platform Service Style Guide - Desktop
Layout - (Version 10.0)
POINQ0231084F
140.
FUJ00224970
Fujitsu Services - Hoirzon Office
Platform Service Style Guide Desktop
Components - (Version 10.0)
POINQ0231085F
141.
FUJ00224971
Fujitsu Services - Horizon Office
Platform Service Style Guide Human
Computer Interface Specification -
(Version 10.0)
POINQ0231086F
142.
POL00110275
Witness Statement of Gareth Idris
Jenkins®Version 3.0 11/02
POL-0108082
143.
POL00030298
Addendum report from Charles
McLachlan dated 11 October 2010
POL-0026780
144.
POL00001882
Joint Statement to the Court by Gareth
Jenkins and Charles McLachlan dated
11 October
2010
VIS00002896
145.
FUJ00153390
Email from Gareth Jenkins to Charles
MacLachlan, dated 11 October 2010
POINQ0159585F
Page 56 of 58
WITNO04670100
WITN04670100
146.
FUJ00153425
Email re sentencing of Seema Misra,
dated 11 November 2010
POINQ0159620F
147.
POL00055100
Emails between John Longman, Jarnail
A Singh and others, re. Regina V
Seema Misra - Guilford Crown Court -
Trial
POL-0051579
148.
POL00055150
Email to Jarnail A Singh, Re: West
Byfleet-Misra
POL-0051629
149.
POL00055146
Letter from Jamail Singh Re: Regina v
Seema Misra Guildford Crown Court
Trial Case No: POLTD/07/08/0249
POL-0051625
150.
POL00055759
Memo re Regina v Seema Misra Case
No: POLTD/0708/0249
POL-0052238
151.
POL00055590
Email from Marilyn Benjamin on behalf
of Jarnail A Singh to Mandy Talbot,
Hugh Flemington, Jacqueline Whitham,
Re: Regina v Seema Misra-Guildford
Crown Court-Trial-Attack on Horizon
POL-0052069
152.
POL00113278
Judgment of the Court of
Appeal in Josephine Hamilton & Others
v Post Office Limited [2021 EWCA Crim
577
POL-0110657
153.
POL00050062
Audit report, dated 11 September 2008
POL-0046541
154.
POL00044804
Royal Mail Record of Tape Recorded
Interview with Julian Wilson
POL-0041283
155.
POL00050138
Julian Wilson Case Study: Royal Mail
Group "Record of Tape Recorded
Interview" of Julian Wilson transcript.
POL-0046617
156.
POL00047065
Julian Wilson: Email from Gary R
Thomas to Glenn Chester and Graham
Brander re: Stakeholder Notification
POL-0043544
157.
POL00044695
Email from Gary Thomas to Graham
Brander re: Offender Reporting (Report
for Mr Julian Wilson)
POL-0041174
158.
POL00044692
Post Office Ltd investigation report for
Julian Wilson (Astwood Bank office)
POL-0041171
159.
POL00065047
Case closure report
POL-0061526
160.
FUJ00155018
Email to Penny Thomas re: FW: Horizon
Integrity Challenges - Alderley Edge
Post Office (Scott Darlington) &
Astwood Bank Post Office (Julian
Wilson)
POINQ0161213F
161.
FUJ00155021
Email to Penny Thomas re: FW: Horizon
Integrity Challenges - Alderley Edge
Post Office (Scott Darlington) &
POINQ0161216F
Page 57 of 58
WITNO04670100
WITN04670100
Astwood Bank Post Office (Julian
Wilson)
162.
FUJ00155050
Email from Jane M Owen to Penny
Thomas, including John Longman and
CC'ing Jason G Collins (on separate
emails), re Horizon Integrity Challenges
- Alderley Edge Post Office (Scott
Darlington) & Astwood Bank Post Office
(Julian Wilson)
POINQ0161245F
163.
POL00114736
Email from Pat Davies, dated 31 August
2011
POL-0113837
164.
POL00114717
Email from Pat Davies, dated 1
September 2011
POL-0113818
165.
POL00114722
Email from Pat Davies, dated 1
September 2011
POL-0113823
166.
POL00114697
Email from Pat Davies, dated 5
September 2011
POL-0113798
167.
POL00114706
Email from Pat Davies, dated 9
September 2011
POL-0113807
168.
FUJ00225264
Email from Penny Thomas, dated 15
September 2011
POINQ0231381F
169.
FUJ00155051
Email to Penny Thomas at 28
September 2011 at
POINQ0161246F
170.
FUJ00155070
Karen Wilson Case Study - Email chain
from Jane M Owen to Penny Thomas cc
John Longman RE: Horizon Integrity
Cases with handwritten notes
POINQ0161265F
171.
POL00114698
Email to Pat Davies RE: Darlington-
Alderley Edge- Wilson Astwood Bank
POL-0113799
Page 58 of 58