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Witness Name: David John Pardoe
Statement No.: WITN08170100
Dated: 24" October 2023
POST OFFICE HORIZON IT INQUIRY
FIRST WITNESS STATEMENT OF DAVID JOHN PARDOE
I, David John Pardoe, will say as follows...
1. This witness statement is made to assist the Post Office Horizon IT Inquiry
(the “Inquiry”) with the matters set out in the Rule 9 Request dated 17 August
2023 (the “Request’).
2. I come from a family of Postmasters; my late father owned and ran a Post
Office in the Northwest of England from the 1950s and his mother held the
position before that.
3. Given my family ties with the Post Office, then from a very young age I could
successfully perform Post Office transactions and I used to run my father’s
Post Office for him whilst he went away on holiday. I initially commenced my
career within the Civil Service, but as a young man, perhaps aged 19 or so, I
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applied for and was successful in securing a Post Office Crown Officer
counter clerk role in the Warrington area.
. I then quickly progressed from counter clerk and held several administrative
roles within the Liverpool District. One role was to design and deliver SPMR
onsite training. Prior to this initiative new or incoming SPMRs had been
trained by the outgoing. This was proving to be increasingly unsatisfactory as
any bad habits or flawed transactional processes were being immediately
inherited by the new SPMR. The revised training saw specialist training
delivered by one of two trainers. As such, I travelled across the Northwest of
England providing two-week training inductions and refresher courses.
. One day I was catching up on administrative work within the District Office in
Liverpool. I was approached by two individuals who I knew worked for the
Post Office Investigation Department - POID. This was the function that
provided investigation services to all elements of Post Office including Royal
Mail, Parceforce, Post Office Ltd and CASHCO (the cash carrying arm of Post
Office). The individuals asked me if I would consider working in an inner-city
branch that was under investigation for dishonesty. I agreed and I worked in
the Post Office branch for several months and supported a covert surveillance
operation. The operation was in connection to benefit payment book fraud.
. The operation concluded satisfactorily, and I received recognition for my
support. Shortly after I was offered the role of the Investigation Liaison Officer;
this role saw me act as the interface between the Liverpool Post Office District
and POID. The role involved taking reports of crime and suspected crime
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events, documenting them, and reporting them for intervention by POID. This
was very much an interface role and would not initially have led or supported
PACE investigative interviews or similar activity. I think that this would have
been around 1991.
7. I have asked the Post Office IT Inquiry team for detailed personnel print out of
the roles and role moves I held from around 1991. I genuinely do not wish to
appear evasive but do need support to aide my memory. I have held several
roles in the function and some will be of more interest to the Inquiry than
others.
8. There was minimal training given to discharge the POID interface role and
certainly nothing formal. I do seem to recall spending a week or two with my
predecessor, but the role was very much around reporting cases, providing
employee details obtained from HR, gathering witness information and so on.
In fairness, I didn’t feel ill-equipped to perform the role as the technical
elements were delivered outside of my pay grade.
9. Throughout this period the business was going through a sizeable number of
changes. In fact, change seemed a constant within the business, and this led
to the amalgamation of Post Office administrative structures for Liverpool,
North Wales and Manchester areas into one North West and North Wales
Region. The Regional office ended up in Salford.
10. Shortly after this, the Region started to encourage me and one other Liaison
Investigator to get closer involved in investigations that were being submitted
to POID. I don’t know the reason why. It was just a belief from some strong
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stakeholders that we should be closer to the conduct of our own
investigations. This started to see me conduct investigations in a supporting
role as second officer.
I do recall this was the start of formal training. I seem to recall that at this time
I received classroom training delivered by Royal Mail Group and access to
other training materials. I was also very heavily mentored by an experienced
and far more senior investigation manager, and this would see every element
of my work supervised. Again, I could do to reference with career details
surely held by the Post Office to provide dates with greater clarity. Given the
time that has elapsed I suspect that none of the training materials /
methodology will be available to the Inquiry.
12.The business continued into a state of flux. At the time, POID were being split
into the various Post Office business units. When this happened, I moved into
the newly formed Regional Security Department, had a substantive
investigator, as my line manager, and a Regional Head of Security. I seem to
recall that my job title also changed to that of Assistant Investigator.
13. This period saw me receive significantly more training both formally and
informally. It’s difficult to recall the timeline, but at various stages in an
operational role I received classroom investigative training, internally and
externally delivered courses around search awareness (using Metropolitan
Police facilities), interviewing course with Lancashire Constabulary, PACE
training, RIPA awareness and CPIA awareness. Elements such as PACE,
RIPA, HRA and CPIA were supplemented with various materials that were
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intended for retention. PACE and CPIA codes of practice would have been
available within every interview kit. I still recall having the codes in my
investigation kit. In my Post Office career, I also studied and passed my
Proceeds of Crime Act Senior Appropriate Officer. This was a pass fail one
week course delivered by the National Police Improvement Agency.
14. During my career in the function I also undertook other lines of role and
academic learning; I hold a certificate and diploma in management and am a
holder of an MSc in Security & Risk Management attained from Leicester
University. My MSc centered on organisational crime risk and was completed
in September 2000 by submission of an academic study on the reasons why
SPMRs committed offences of theft and wrongdoing and therefore rendered
themselves liable to prosecution. The work was entitled with complete irony
“There Must Be Some Mistake”; this referenced that SPMRs were shocked, in
the main, that their behavior led to suspension and prosecution. I’m struggling
to find a copy of the work and presume it's lost during a number of house
moves. I do recall that several subjects were citing unexplained losses as
being the cause of their downfall, but these were ordinarily attributed to sneak
thefts or a reluctance to provide full and frank explanations. This study would
have been completed pre-Horizon.
15.As an Assistant Investigator my role was to, predominantly, support field
investigation into allegations of dishonesty. I would not lead on interviews
under caution but would rather support with investigation questions around
the daily and weekly accounts.
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16. Again, I would need reference to Post Office HR details, but I then became a
substantive lead Investigator. This move was supported by additional training
and my lead work (first officer interviews, file preparation and so on) was
highly supervised to the extent that even grammatical errors within reports
would be returned for correction - that was the standard of supervision. Even
after this promotion to lead Investigator I remained in supervision for many,
many months and certainly longer than for any professional role I have held
subsequently. I don’t think that was any reflection on my ability to progress at
pace, it was just the way it was. There was a recognition that the role was
unique and required a high level of interpersonal skill and confidence to
deploy effectively.
17. There followed a further series of team restructures, building moves and
boundary moves. The function throughout the years if not decades always
struck me as an easy target to drive headcount reduction. Indeed, later in my
career I was performing the role of consultation manager for a long serving
colleague who had been subject to redundancy. I was to follow a party line
around change being a business necessity... when the colleague abruptly
stopped me and proceeded to produce a piece of paper and recount the 14
restructures they had been personally impacted by since joining the Post
Office — the majority in the security field. That was the regularity of structure
change.
18. Nevertheless, I seemed to escape the inevitable culling and received a
number of role moves and promotions. I was involved in a significant range of
operational activity within the Security function. Again, I need an aide to
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memory in terms of precise dates and durations, but roles included
Investigation team leader and further promotions to national roles and to
Senior Security Manager. The later saw me, at stages, involved in working as
a Commercial Security Manager with client managers to assure new and
existing products and services, a separate role dealing with physical crime
mitigation, a separate role dealing with operational investigations, a separate
role dealing with crime intelligence (under a basket of services called
Grapevine) and administration for the function, along with two or more
significant periods dealing with organisational design (headcount reduction)
and the move of Post Office Counters Ltd to Post Office Ltd in 2001. Some of
these periods would see removal and secondment from my substantive role
for periods of up to 12 months.
19. Throughout my career my reporting lines both up and down varied
significantly. From recollection I reported at periods into Susan TOMS (HR
lead NW Region), Jim McLeish, Tony UTTING, Duncan McFadyen and
latterly in my career John SCOTT (Head of Security). My span of control also
varied significantly, and I can recall working without any direct reports,
through to an operational Senior Security Manager leading a team of 15 or 20
via several team leaders and direct reports. In terms of competence and
professionalism of colleagues and managers, then given my varied roles and
length of service then that’s a difficult one. I worked with some fantastic
individuals who were highly capable and committed to doing their role to the
best of their ability. I worked with others who were less so and who would be
managed accordingly. Overall, the investigators were competent. We had, in
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the team, recent police officers and to be honest their application of the role
and understanding and use of impacting legislation was no better or worse
than incumbents who had progressed through a non-policing route, so I
suppose that must give some credit to Post Office grown talent and
incumbents.
I left the Post Office in 2014. I was tired of the London commute and living
away from home. I was also increasingly worn out by the prevailing Security
Team culture. I would say, from the outset, that I do have an issue with
several prosecution decision making activities and subsequent inputs I am
asked to comment on later in this statement; my memory is that I left the
operational Fraud Strand / Security Operations, to become the lead for crime
intelligence and administrative support under the generic term Grapevine.
Certainly, POL00091037 is attributed to me and clearly shows the prosecution
lead as lain MURPHY, but later in the life of the case I perform the
prosecution sign off. Mr. MURPHY was the Fraud Strand leader for a period (I
think he was my successor) and the case relates to late 2010. I think Mr.
MURPHY held the position throughout 2010. To the best of my knowledge, I
had limited operational involvement in investigation cases from then (albeit I
seem to have returned to Security Operations in 2011 for a period). In my
Grapevine role I supported Fujitsu ARQ requests made by operational
Investigators (as one administrative part of my Grapevine role). Later in this
statement I talk about supporting an operational investigation when Mr.
Stephen BRADSHAW wished to obtain advice when an interviewee was
initially undecided whether they required the presence of a solicitor. Without
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the benefit of memory or documentation to the contrary, I suspect that this
was a period when I was the only immediate available Senior Security
Manager and not the substantive Security Operations lead — I will cover off
this specific instance later in this statement. To recap I suspect that the
Inquiry is labelling a small number of authorised prosecution activities
incorrectly to me.
.I suppose that I could best paraphrase my various roles and responsibilities
within my security career with Post Office as follows:
i) Investigation liaison was a District role acting as the interface between
the District and the Post Office Investigation Department. I received no
specific training save for a transfer of activity with the predecessor. I was
trained in elements such as DPA and the various headings (In Confidence)
and storage and transmission protocols required for personal data and
confidential papers.
ii) The Assistant Investigator was a Regional role. This was accompanied
by a mentorship with a far more experienced Investigator. I would have
started to receive training through this role using mediums from classroom,
through to electronic and paper handouts. I would also have met members of
the Criminal Law Team. I recall training sessions from both in and out of
house Lawyers and training staff from the Post Office Investigation
Department.
iii) The Investigator role was Regionally based. My training detailed above
was supplemented by significant levels of supervision and general oversight.
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In this role I was performing the role of lead investigator and discharging
activity from interviews under caution through to case paper and committal
preparation. To the best of my knowledge all my tenure in this capacity was
pre-Horizon.
iv) I don’t recall me holding National Investigator role (I thought this was a
title afforded to a former line manager Mr Tony UTTING). There was a period
when I was responsible for leading a small team of investigators, again a
Regional role. This role was leading on complex investigations and supporting
a team to ensure effective casework delivery. Again, this was mainly pre-
Horizon and was interspaced with a period supporting Tony UTTING as a
National Investigation Manager for Post Office Ltd; I also supported Mr.
UTTING at this time with the draft of policy documents and also was
seconded for a 12-month period as a project lead to the creation of Post
Office Ltd from Post Office Counters.
22.As a Senior Security Manager, I occupied several varied positions:
i) The Commercial Security Manager saw me support new and existing
products and services in terms of ensuring that they were deployed with
suitable levels of crime risk assurance. This was a national role and saw me
work with clients and Product Managers. This was a senior role in terms of
impact and decision making albeit with no operational investigative activities
or involvement in Horizon.
ii) The Fraud Strand Manager / Security Operations saw me support
investigation cases via Investigators and their respective Team Leaders. I
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can’t be specific around the numbers in terms of span of control but there
were regionally based Investigators covering events across the UK, along with
Team Leaders and I seem to recall Financial Investigators. There may have
also been a Casework Manager responsible for the timely and effective
conduct of investigations. My role here was to provide leadership to the crime
landscape and to support the identification of new and emerging crime trends.
During this period, I would have discharged the prosecution authority albeit
this is an area I will discuss later in this statement.
iii) Training through this period continued; I became the POCA Senior
Appropriate Officer and seem to recall undertaking other training courses in a
similar vein to those detailed earlier in the statement.
iv) From the role above I seem to recall leaving operational investigation (I
have already referenced that my successor was ultimately lain MURPHY) and
leading the crime intelligence and administrative support function under the
title Grapevine. Structure would have been broadly similar to the above in
terms of leading the function via direct reports and one full-time consultant.
There was no Horizon or operational investigations in this role save for
providing administration support for the conduit of Horizon and enabling Helen
ROSE as a team member to support ad-hoc analytical requests a number of
which related to Horizon. I’m unsure the dates to which I ebbed and flowed
between Security Operational roles, but I certainly became the substantive
Grapevine Senior Security Manager in 2012; this saw me hold responsibility
for the intelligence services provided by a third-party supplier in terms of risk
and potential risk / crime pattern analysis for Post Office branches utilising the
National Intelligence Model and crime risk management risk weightings. As
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I've detailed, at this time, I also had direct reports responsible for supporting
casework management and for liaising with Fujitsu in terms of receiving and
processing ARQ requests. To be honest, my primary focus at this time was
supporting the Grapevine product in terms of the external crime landscape.
v) Around 9 months or so before I left in late 2014, I was effectively being
removed from my role and asked to design a structure that would again
support a reduction in headcount as well as accommodate my departure. I
wasn't exactly placed on gardening leave, but my operational career with Post
Office was at an end and I was more or less omitted from all other activity.
23.1 want to address now how I understood my role in each of the following. For
simplicity I will model my answers around those organisational roles I held as
Investigation Manager, Investigation Team Manager and Senior Security
Manager Fraud and latterly in my Post Office career Grapevine.
24.For disciplinary matters I would have observed the relevant Codes of Conduct
appertaining to Post Office Ltd. As a line manager I would have applied these.
There were legacy Security team discipline conduct instructions, albeit my
recollection is that these were superseded by generic business unit standards
of behavior and particularly at separation from Royal Mail Group in 2012.
Irrespective of policy, it was recognised that conduct awards would be
potentially disclosable in future prosecution cases and that they would have a
significant impact on the recipient. I am aware of the award of conduct up to
and including termination of employment for members of the Security Team.
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25.For interviewing then my role was to comply with the impacting elements of
PACE when I was actively conducting investigations.
26. Disclosure I wish to cover in more detail later as I appreciate that it will form a
significant part of the Inquiry’s ask from me. All Investigators were expected
to comply with CPIA.
27.\n terms of my role in litigation, then I read this to be recovery under POCA;
for non POCA litigation, then my role would have simply to have been to
provide supporting case papers and potentially additional statements. I did not
make non POCA litigation decisions. In terms of POCA then I discharged the
role of Senior Appropriate Officer. This was around providing oversight to the
Financial Investigators and acting as signatory to the various authorisations
required to perform their role and the recovery objective. The Head of
Security, John SCOTT, had overarching responsibilities for the strategy
around recovery. I certainly recall conversations with him around the
calculations concerning recoverable amounts and defendant's benefit. I recall
that Mr. SCOTT was specifically challenged by the NFSP around the
calculation of recoverable amount in a particular case. We discussed the
case and whilst I don’t recall the specific outcome it was clear that he had
been challenged at a senior level.
28.In the context of liaising with other departments then communication was
predominantly between investigation function and Criminal Law Team. There
would be correspondence with the Criminal Law Team on a regular basis. In
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addition, stakeholders such as the Retail Line Management would be
appropriately apprised of charging decision and key elements of progression.
In terms of lessons learned and product weaknesses, then we would drive
liaison with product teams and financial departments within Chesterfield
Product and Branch Accounting. We would also undertake regular liaison with
Information Security in respect particularly about requesting Horizon logs.
The Security team’s role in relation to investigations and prosecutions.
29. The organisational structure of the Security team changed frequently and I
have detailed previously a number of the roles I myself occupied as a result of
restructures; broadly speaking and later in my career, there was a Fraud
Operations strand that led investigations against employees and SPMRs, a
Grapevine strand that led on crime intelligence and administrative support,
Physical Strand that led on supporting physical crime mitigation, Asset
Security that looked after physical security assets and the Commercial
Security strand that offered crime risk assurance to new and revised product
and services.
30. Function changes could be significant. I seem to recall organisational charts
with 80 or so colleagues, quickly depleted over the years. There were several
significant changes that led to sizeable redundancies, strand renaming and
functional job titles changing.
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31.1 have read though the suite of supplied policy documents. For Group policies
that would have been cascaded through the Security team, I would have been
a recipient as opposed to a contributor / author. On an aside POL00104968
has a comment that seems to have been attributed to me; this is incorrect, it is
a comment seemingly from Dave POSNETT who I believe is an Inquiry
witness.
32.1 would logically have had input into POL00105229 covering Post Office
authorised access to PNC. As I recall this was a highly regulated area and
subject to external audit. Again, logically, I would have oversight into several
of the POCA type investigation policies and specifically the policies that were
drafted post Group separation such as POL00104853.
33. Very early in my Security career I worked with Tony UTTING as National
Investigation Manager. I held for a very brief period a policy and standards
role. I do not recognise any of my work from this period in the supplied
documents. This would certainly have been a pre-Horizon role. Any of my
work from that time I suspect would predate materials available to be given to
the inquiry.
34. There were several impacting policies during the time that I occupied roles
within the Security function. Logically, these would have come across my
desk and whilst I don’t recall them specifically, they would have been
applicable to my team. These would include the Group policies including
those at POL00030578 / POL00104812, POL00031004, POL00031003.
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Other policies authored in 2010 and onwards I’m still unsure around my
precise roles within the function.
35. The function also had I seem to recall a suite of polices / procedural standards
covering PACE 1984 codes of practice, DPA, RIPA, HRA, CPIA and safe
ways of working.
36.Policies would be revised dependent on legislative changes. We would
ordinarily be advised of these changes by the Criminal Law team.
37.Post Office split from RMG in April 2012. By this stage I do not believe I was
working within the investigation element of the Security team. Whilst I
supported John Scott on separation (I specifically recall discussing with the
Home Office our status in POCA legislation as well as agreeing a way of
working with Royal Mail should a Post Office employee or subpostmaster be
suspected of offences against Royal Mail) — actions and objectives are
reflected in POL00104900, POL00105191 and POL00105216, I do not recall
spending significant amounts of my time on the split but I may have attended
a number of senior meetings.
38.In terms of understanding the way that investigations were conducted post-
split, then I do not believe that I held a senior role in the investigation function
at the time. If I did, I’m not confident that it was for a sizeable duration. In
addressing how investigation conduct changed at this time, then save for the
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fact that we no longer received Group policy documents or Group training
support, then the mechanics of investigations remained the same.
39.In terms of complaints around conduct then I would have been expected to
follow the company policy around conduct. I certainly don’t recall a specific
policy that we applied outside of the standards expected by Post Office. I
know that pre 2012 split there was a Group policy, but conduct would have
followed the business unit protocols.
40. Irrespective of the successive structural changes, then Investigators would
report into a Team Leader and would overview their cases on a regular 121
basis. I think at one stage this was completed by both physical case files and
associated contents along with electronic case logs. Expectation would be
that the Team Leader would overview their direct report's cases on hand and
advise around quality and speed of progression. The Team Leader would also
intervene if a direct report was failing to progress inquiries in a timely manner.
I do recall that there was also a template around the construction of case files
to standardise casework.
4
.As previously detailed, this was a heavily mentored role, and my expectation
was that Team Leaders were highly visible and staying close to direct reports
in terms of casework supervision.
42. Crown Office investigations were relatively rare. The reason for this is that,
besides the smaller population in terms of physical numbers, Crown Office
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employees were subject to regular till checks and cash float and stock
exchanges between their peers. It just wasn’t possible or at least simple to
commit ongoing false account of a cash on hand figure providing, obviously,
that supervision was applied as it should be. We did however prosecute
employees including those who worked in a Crown Office. There was no
difference in approach or expectation of how a case would progress up to and
including prosecution. If anything, there was a lower appetite for loss within
the Crown environment. There was a time when Crown employees were
expected to produce weekly balances with no more than a £2 variance and
regular values above that could see investigation involvement.
43. There was also a period when resources would have been applied to
suspected thefts from SPMR assistants. By this I mean cash thefts and not
simply fraud against customers and / or clients. This ceased when I was new
in role and ended with the transition of Districts to Regions that I mention
earlier in the statement. On an aside, I do think that was a retrograde step as
it left SPMRs isolated and with the unenviable task of attempting to engender
police support to counter and evidence suspected employee theft.
Audit and investigation
44.I've read through POL00104821. I don’t think I have ever seen it before. I do
question who it is aimed at — I’d have thought it was aimed towards Auditors —
cash and stock checkers in effect. It’s not something, end to end, I'd envisage
the Investigator completing. In summary, then an Auditor would attend an
audit based on two broad scenarios; that is that a routine, unexpected, audit
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has produced evidence of wrongdoing either by virtue of a cash loss, other
anomaly or admissions made to the Auditor. This would see an Investigator
provide reactive audit attendance and would only be performed, on the same
day, if the Investigator was available and the journey was practicable. The
second reason for attendance would be in response to intelligence around the
likely result. Intelligence could be Product & Branch Accounting monitoring
cash movements in branch, or a client complaining about how customer
transactions were being dealt with.
45. Irrespective as to the catalyst for Investigator attendance, then the purpose for
attendance would be broadly similar, in terms of securing and examining
evidence and seeking to obtain an account from the person(s) responsible.
Whilst frequently, this would see voluntary interviews and searches on the
day, exceptional circumstances would see arrangements made to interview
later. Invariably, the Investigator would also have engaged with the retail line
in terms if future of office immediately post audit.
46.1 seem to recall that there was a triggers and timescale document that
covered the monetary loss value at which investigators would get involved,
coupled with prima facie evidence of wrongdoing. Unfortunately, I’ve not
recognised within the bundle of documents supplied to me. It was certainly at
around a £1K (one thousand pounds) before Investigators got involved and
even then, at that value, where other conditions existed, such as the value
disturbed a clear or obviously falsified balance. In terms of did this change
during my career with Post Office, then in the face of reductions in
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Investigator numbers, then lower-level cases would not have progressed.
There was no one person that was required to instigate an investigation; there
was an accepted case raise process and it certainly wouldn’t have needed my
involvement as a senior manager.
47. The Contract Manager was not in a position to ultimately unduly influence
whether a case was raised or not or as to whether a particular course of
action was followed. This had always been the case and I certainly don’t recall
this changing during my tenure.
48.As previously detailed, there was a trigger document. This would have been
reviewed during my tenure, but I'd expect that elements in the document
reflected an increased risk appetite, to reflect that resource had diminished.
Certainly, I recall undertaking investigations in the late 1990s and early 2000s
that would never have been conducted later in my career; one example was
the petty thefts of personal property in a Welsh Crown Office that was met
with electronic surveillance and early morning testing operations. That type of
case would never have been undertaken even in 2007 and certainly not in
2014 when I left.
The process followed by Security team investigators when conducting a
criminal investigation following the identification of a shortfall at audit.
49. Once a reportable audit discrepancy had been made, then the Investigator
would be expected to attend the branch and make introductions to the
personnel on site. Traditionally, two Investigators would have attended, with a
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lead Investigator making introductions and establishing from the Auditor(s) in
attendance the details of the variance and details of any pertinent comments
made by the SPMR. Once this was established then on the proviso that the
audit had been completed, then I would have expected the Investigator to
invite the SPMR / person responsible for completing the account to a formal
interview under caution.
50. Personally, I would have started to use my pocketbook from entering the
5
branch and would start to record key events and pertinent conversations. I
would also have asked the SPMR if they had any objection to the interview
taking place on site, dependent on suitability.
.I would then expect an interview to be prepared; this saw, in my time, a two-
tape recording machine utilised, and a set of paperwork completed and read
aloud by the Investigator. The paperwork would see the caution administered
and paperwork completed around whether legal representation was required.
There was also an offer made to have a Post Office friend witness the
interview. Obviously, if either of these conditions were required to be met,
then arrangements would be made.
52. The events of the day would then be outlined, and confirmation requested
around any pertinent conversations or verbal statements made prior to the
start of the recording.
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53.An account would then be sought from the SPMR. There would be a lead
Investigator and second. Towards interview conclusion a second caution
would be administered, and the interview closed. The Investigator would then
apprise the Contract Manager as to the outcome and traditionally you would
relay to the SPMR the requirement to speak to his Contract Manager around
the immediate future of the branch. At a suitable point the Investigators would
leave the branch, traditionally ensuring that cash and stock was secure.
54. From this stage, the case would enter the casework management system.
Decisions about prosecution and criminal enforcement proceedings
55. There was a period when I dealt with prosecution decisions, both as a conduit
between the Post Office Investigation Department and line managers making
the decision and then as a period myself as the nominated representative.
I'm unsure why the switch was made between line manager and Security as a
nominated representative, but it occurred.
56.A decision to prosecute would only ever be made in the face of supporting
advice from the Criminal Law Team (CLT). CLT would have seen all the facts
appertaining to the case including audit reports, Investigator report, supporting
evidence and interview precis. My expectation was that the CLT as an integral
part of Post Office security would have made all the due considerations in line
with Code for Crown Prosecutors and applied each necessary test in reaching
their decision. I took a stance that the decision will have been checked by
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CLT for fairness and objectivity. I saw my role to confirm their decision and
place the case into prosecution status via the Investigation Team Leader.
57.1 understand that documentation exists stating that the decision to prosecute
ultimately sat with the Head of Security (POL00104929). I’m genuinely not
sure where that originated. I do seem to recall that towards the end of my
tenure John SCOTT as Head of Security was personally signing off the
authorities. During my tenure I was advised that I was the nominated
representative. I guess that the Head of Security reference may have been a
post Group separation change.
58. The Contract Manager had no input into the decision-making process.
59. In terms of test around the correctness of prosecution and charging decisions,
then I firmly expected this to have been considered at the CLT stage. If they
had felt that public interest factors tended against prosecution, then my
expectation was that this would have been clearly stated. I’m genuinely not
attempting to be evasive, but I failed to see what additional input I was
providing around correctness when a Principal or Senior Lawyer had carefully
made the charging decision.
60. The question around charges was solely within CLT; whilst towards the end of
my tenure I'm aware that investigators would recommend charges when
submitting papers into the CLT, the ultimate recommendations sat with CLT.
Again, in terms of prosecution decision then my expectation was that all
elements had been considered by CLT in reaching a decision.
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61.Restraint and confiscation was enacted under POCA 2002 and under the
oversight of the National Police Improvement Agency (NPIA). There was a
prosecution financial trigger applied to engagement and I seem to recall this
was around £5K (five thousand pounds). The initiative was under the
oversight of the Head of Security and for a period as Senior Appropriate
Officer, I could provide the signatory for various elements of the Act.
Confiscation / restraint was very much the default position, and it was widely
recognised as being a key driver to recovering loss. I don’t recall a specific
sign off process to consider proceedings, but obviously the Financial
Investigators would keep me apprised and require my input as SAO signatory.
Training Instructions and guidance to investigators within the Security
team
62. Throughout my career in the Security team there were several approaches to
training; I may well reference courses that I personally attended that were
subsequently made obsolete or superseded by other training interventions.
For example, I trained under Lancashire Constabulary in terms of
investigative interviewing but am aware that would have only applied to a
small number of investigators. Generically, the function saw comprehensive
training. This would traditionally have been a residential course held at a
management training facility. Whilst I do not recall the exact curriculum, it
certainly contained elements around interviewing of witnesses and suspects (I
seem to recall role playing was a mainstay) and would also have covered
search awareness. Again, my own search course was led by Group trainers at
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Metropolitan Police training college using their own search houses. I seem to
recall that the residential Post Office training course had a pass / fail
weighting with additional support given to weaker attendees.
63. All elements of case file construction would have been covered including
evidence gathering and committal preparation. I would have envisaged that
this included obtaining evidence from third parties, albeit I do not recall any
specific reference to Horizon data. All Investigators would have received
instruction in the use of Horizon and so logically I would have expected that
available evidence would have been covered then.
64. Formal training would have been supplemented with significant levels of
supervision in terms of operational activity and case paper construction and
submission. This was a role that traditionally had a longer lead in time given
the uniqueness of activity undertaken.
65. During formal training then attendees would have been provided with a range
of training materials including impacting policies and a copy of PACE and
CPIA codes of practice.
66.1 also seem to recall that representatives from the Criminal Law Team would
attend the residential training courses for guest slots. I'd be guessing at their
agenda slot, but the residential training was afforded, quite rightly, a certain
gravitas.
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67.1 don't recall specifically receiving the 2000 or 2002 Casework Management
document at POL00104747 / POL00104777 although logic says I would have
received the documents.
68.I've heard the Inquiry question previously the meaning of source documents
and policy that specifically highlight the removal from various reports of
content that indicate failures in security or operational procedures. Throughout
the various roles I held within the function I never, ever read this as being
applicable to Horizon bugs, errors or defects. I’d like to provide a clear
example of how I interpreted this; the Post Office conducted all their product
offers and services on behalf of third parties. A third party could be a private
entity, through to government departments such as DWP and DVLA. Each
product and service had a transactional process that the Post Office agent
was expected to follow and then some form of back-end reconciliation to
assure elements that were important to the particular client. Up to 2005, Post
Offices would pay many millions of pounds to benefit claimants using paper-
based pension & allowance payment books. This was a wholly flawed
proposition in terms of the design of the book and a weak reconciliation
process that saw <10% of work submitted subject to check. In essence, this
meant that a Crown employee or SPMR or his or her assistant could pay
benefit claimants £100K (one hundred thousand pounds) in a particular
accounting week and claim that actually £120K (one hundred and twenty
thousand pounds) was paid. The resultant cash surplus could be applied then
to personal use. The fraud in this respect was audacious and drew the
attention of organised crime groups (OCGs), who would target willing or
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unwilling SPMRs and Crown colleagues. In terms of the inherent weaknesses
in the design of the product, then Investigators were advised that under no
circumstances should the product weaknesses be supplied in any form of
disclosed discipline report but should sit within the offender reporting process.
69. There were similar weaknesses within a range of products. I seem to recall a
sizeable fraud through the poor treatment of Lottery payment cheques. Again,
there would have been a concerted effort to keep these failures out of a wider
public domain. I actually supported the approach.
70.As no time in my career was I aware of an implicit or explicit request, demand
or expectation that this approach was to be applied to Horizon failures.
71.My expectation is that ultimately every single document and Investigator
comment on organisational weakness should have been subject to review by
CLT and the disclosure test applied accordingly. I remember being
specifically advised, by CLT, that this would be the case.
72.1 do recall something of the compliance checks. I may be wrong, but I think
that every case due to be sent to CLT for their comment around a suspect
offender enquiry went through a series of compliance checks. I actually think
that this had originally been a minimum of two cases per annum, per
Investigator but had changed over the years. Their purpose was to
standardise the quality of casework, I don’t recall who specifically performed
the checks. This changed dependent on team structure and whichever role
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held that responsibility. I do recall that earlier structures had a substantive
Casework Manager that would have had overarching responsibility for
casework quality. The Casework Manager would have seen every case. I
seem to recall that this responsibility switched to team leaders for a period
post restructure and then back to a single point. I seem to recall that Dave
POSNETT conducted a number of the checks, but I may be wrong.
73.1n terms of development, then again, I don’t recall specifically being involved
in their design and deployment but logically I must have been.
74. Again, I never, ever read the requirement to, in any way, sanitise a report
required to be disclosed for conduct purposes to have been applicable to
Horizon. My take on this as I have previously detailed was that we were
absolutely required to treat issues around product and service reconciliation
and crime risk exposure with care and this certainly extended to placing within
the public domain. We had significant crime risks within a number of product
offerings predominantly around DWP type products. The situation was so bad,
that when the DWP benefit book contract was reaching obsolescence, we had
to recruit and train a team of submission checkers based in Chesterfield. This
was to shore up the collapse of weekly submission checking by the DWP.
75.At POL00118104 & PO00118128 I find the issue around “Identification
Codes” as utterly abhorrent. I certainly did not draft the document and have
no knowledge who did. I do not recall reviewing the document.
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76.We did instruct Investigators to record identification codes. My recollection
was that these were required to complete any submission into Police to have
details of subsequent convictions entered onto the PNC. These were referred
to as NIB type details. I certainly don’t recall the horrendous language on the
form or the obsolete country names.
Analysing Horizon data, requesting ARQ data from Fujitsu and
relationship with Fujitsu.
77.\ personally was not an operational Investigator from the inception of Horizon.
I don’t recall supporting or certainly leading a Horizon type investigation. I did
obviously lead the Fraud Strand and Security Operations function during
pertinent periods so will respond with that in mind.
78.1 appreciate that this is a view that will have been expressed previously, but
throughout my tenure the opinion firmly expressed at every turn, internally,
was that Horizon was fit for purpose. I recall with an element of clarity updates
from John SCOTT assuring the Security function that the system was reliable,
and we were to continue with BAU activity. I appreciate that there became a
more measured approach towards the end of my tenure, but I certainly don’t
recall being involved in those conversations. I also seem to recall an internal
Paula VENNELLS communication in response to the increasing noise around
Horizon; obviously I can’t recall word for word, but the thrust was that Post
Office were defending the system and refuted the claims. My point is that with
honesty the use of tools such as Credence data and ARQ logs were to my
mind used as much to evidence guilt than innocence and particularly utilised
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when false accounting was admitted but not theft. My understanding is the
Investigator would analyse logs to attempt to evidence theft and wrongdoing
particularly in terms of cash balance declarations and redeclarations; I’m not
even sure how the log would denote a bug, error, or defect. It’s certainly not
an area we had any training in, i.e., to spot a bug, error, or defect these are
the data patterns you should search for. The language at POL00055590 in
terms of Horizon bashing expressed by a Senior Lawyer was not uncommon.
79.My understanding is that Fujitsu was contracted to provide Audit Record
Query data, on demand, using an agreed secure process. I seem to recall that
the data provided a full log at key stroke levels for the period specified by the
Investigator and providing transactional and branch reporting detail. I’m
aware that this data could be used to identify singleton transactions (like the
use of a certain credit card) or a full and complete series of transactions using
a date range specified by the requester.
80.1 do recall limits in respect of ARQ requests. FUJ00080107 has refreshed my
memory and I recall that as a function we were capped, within contract, at 720
requests P.A. I seem to recall that this changed during mediation, but I wasn’t
involved in discussions around this and am not aware what the uplift was. I
seem to recall that additional requests were around £500. I don't specifically
remember being involved in uplift conversations that authorised these; it
certainly wasn’t a budget that I held, and I presume that John SCOTT would
have addressed this with the wider business.
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81.
82.
83.
84.
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I don’t recall specifically any changes between legacy Horizon and Horizon
online. I do not recall Investigator noise that this was proving to be
problematic.
There was a period towards the end of my career when I managed the crime
intelligence function under the heading Grapevine. This function acted as the
conduit between the operational Investigators and Fujitsu in terms of ARQ
requests. This was a stringent process and covered by a policy that
unfortunately hasn’t been presented to me within supplied documents. I didn’t
act as the gatekeeper to requests. I do recall that Dave POSNETT would get
involved in out of course requests in terms of size. As a Fraud Strand /
Investigation lead, then I can say that Investigators were empowered to
request ARQ data using a prescribed process. I don’t recall ever authorising a
request nor by the same token do I recall refusing one.
I don’t know who specifically received the ARQ requests within Fujitsu — I do
recall a Penny THOMAS being potentially involved. I do recall that these
requests were complied with by the return of password protected CD-ROMs.
In terms of additional prosecution support then I obviously recall that Fujitsu
would provide expert witness testimony presented by Gareth JENKINS. I’m
unsure what the contractual basis for this was.
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85.1 don’t recall any discussion I was privy to in 2003 / 2004 around limits on
Fujitsu requests. I’m not sure what role I undertook in 2003. It wasn’t Fujitsu
facing.
86.1 was not aware that 2003 had seen a decrease in contractually covered
requests (a question raised at 28.ii under Horizon data). I suspect this should
read increase as we were then preparing to shore DWP benefit book
reconciliation and investigation using internal resource.
87.1'm not aware of any impact on investigations in 2003 that the reduction in
requests within contract had.
88.2004 saw an increase in pre-paid requests through to the DWP inhouse
activity previously detailed.
89.1 do seem to recall some conversation around direct access to data. I’m not
aware that this was achieved in my tenure and certainly not for historic data. I
think that Credence access provided 90 days.
90.In my employment post the Post Office I have yet to work for an employer
who cannot access, on demand, their own EPoS data and usually via their
own propriety data warehouse. There would be a question around the
granularity of data held, but my experience is that these can be overcome with
system changes. I am aware that several retail organisations will exercise
independent data harvesting and storage solely for the investigation of
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anomalies, leaving an independent warehouse to capture transactional sales
and performance details.
91.In line with my response at 78, my belief is that there was a cynicism in terms
of the steps that were taken to support any assertion that Horizon was the
root cause of discrepancies. Horizon data from my perspective was primarily
a tool to either evidence how false accounting took place or to support a
charge of theft and particularly when theft was denied at interview. I’m
struggling to understand how the ARQs would identify a bug, error, or defect
and particularly if their presence was subtle and sat beneath obvious key
stroke data.
92.1'm not aware of circumstances where an ARQ was provided to a SPMR, save
for prosecution cases when I would have expected the data to be disclosed.
93.I've considered POL00114566. At the time I suspect that I was supporting our
internal response to the withdrawal of the DWP benefit book as a method of
payment for claimants. I know that this is one of the reasons cited why we
were seeing an uplift in requests, along with the fact that paper-based records
were disappearing from branch and that cases needed to be supported by
Fujitsu.
94.In terms of POL00114566 whilst I can’t recall my response at the time, I would
have been disappointed by the omission and particularly of end of day activity.
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95.1 don’t recall my thoughts around the prevalence highlighted in POL00114566
at the time. I would now read it as a system weakness in terms of capacity,
exasperated with human error.
96.1 don’t recall that the information in POL00114566 impacted on investigations
and prosecutions. I see that Tony UTTING was detailed as Head of Security
in the period. Mr. UTTING may well be closer to response and steps taken.
97.Whether the fact that requests had been returned incomplete was identified
and communicated in other case then that I’m not aware of. Again, I would
have. expected that CLT and the Head of Security would have assured this.
98.1 have no knowledge of what happened to that particular case impacted by
POL00114566.
99. Other than acting in a role that had team members who acted as the conduit
between Post Office Investigators and Fujitsu then I can’t recall any regular
contact with them. Contact historically was via the Information Security Team.
100. I understood Gareth JENKINS to be the expert witness for Horizon. His
role, remit and purported status was presumably decided between Post Office
Ltd and CLT. I had no dealings direct or otherwise in this. In matters of
independence, then my expectation would be that this test around the validity
of his status would have been applied by CLT.
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Relationship with others
101. I had very little contact with Cartwright King Solicitors. I seem to recall
having one meeting with them at one of their offices, but don’t recall the
context or content. I understand that they commenced offering the initial
charging advice in cases, but I don’t recall how that came about. I’m assuming
that this was post Group separation.
102. In the early stages of my career and particularly when I had District
facing roles as opposed to National, then I had ad-hoc relationships with
NFSP Representatives. We would often see a Representative performing the
official friend at interview role and would get to know one another via that
contact. We also attended NFSP events and roadshows to provide personal
security advice and to show a presence. As my role progressed Regionally
and latterly Nationally, then contact became less frequent. I do seem to recall
that John SCOTT as Head of Security would meet them on a formal and
presumably structured basis.
Involvement in Criminal Prosecution Studies
Prosecution of Josephine Hamilton
103. I have no recollection of this case and note from POL00047955 that
Tony UTTING was detailed as prosecution authority. I have read and noted y,
POL00118877 and POL00118990 with POL0018990 unfortunately being
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unreadable. Again, I cannot be sure what role I played in this investigation. I
was not the lead Investigator, nor second officer. Potentially, I would have
discussed case progression at 121s with team leaders as I recognise the
inclusion of Paul DAWKINS as holding this position, but I really am
speculating. I clearly became involved later in the prosecution as evidenced
by POL00049083.
104. I was aware of the allegations around Horizon IT issues. At the time
and as previously detailed, these would have been treated in line with the
business advice. I see that at POL00044388 this sentiment is reiterated by
Juliet MCFARLANE as Principal Lawyer.
105. I do not recall specific communications in terms of plea, other than
those supplied to me as part of the Inquiry. I would expect that the managing
agent / counsel would be involved along with CLT and the Investigator in the
case. I see that this case came to me for authority to proceed with the
proposal, I’m not sure how often this would take place. Very often a basis for
plea would be agreed on the day and without my availability and therefore
input. I would be guided on the appropriateness of acceptance by CLT.
106. I'm not aware of any conditions required to accept the plea. I don’t
recall ever being privy to discussions that a plea came with caveats around
Horizon.
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107. I’m not aware of the circumstances of why the theft count was left on
file. I'd presume that this was to enable reinstatement should it be required at
a later date. I’d really have expected CLT to have led on this.
108. I would likely have read POL00047955. There must surely be a
connection between agreeing to treat the theft charge and the lack of theft
evidence. I read the observation by Mr. BRANDER around evidence of cash
inflation (lack of) to mean that he did not find a series of inflated cash
declarations succeeding lower declared values. I wouldn’t have thought this
was unique as there were ways to overstate cash values without leaving an
audit trail.
109. I have considered POL00049071 and POL00049535. I would have
been supervising Ged HARBINSON. I had qualified under the National Police
Improvement Agency as the POCA Senior Appropriate Officer. I would have
had oversight of the financial investigation using 121 discussions with Mr.
HARBINSON as Financial Investigator and his case notes. This was a period
when we were heavily supervised by the NPIA.
110. I do not have the benefit of successive POCA file notes that illustrate
how the loss was recovered. I presume form POL00049083 that the amount
was repaid prior to sentencing.
111. I have read the relevant paragraphs of POL00113278. Clearly, the
prosecution was wholly wrong as was the continual Post Office refutes that
the system was not at fault. Had I been aware that there was knowledge of
bugs, errors and defects that could ultimately and significantly affect the cash
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values required to perform an acceptable balance and I was expected to
remain mute around these and continue any form of role within the Security
function, then I would have considered my position untenable.
Prosecution of Susan Rudkin
112. I have read and noted the available documents in relation to the above
named. I would have had no role in the initial investigation but would have
been privy to the upward report at POL00050123. As previously stated, this
was a period when I discharged the role of nominated representative in terms
of prosecution decision. I have previously outlined my role and would have
taken the proposed CLT charges and at POL00050347 and advise that
prosecution should ensue as per the CLT advice. I was not involved in the
decision to charge or the offence construction.
113. I first became aware of the case when I would have received the report
cascade at POL00050026. My role at the time would have been Strand
Leader and would have been to work through the Investigation Team Leader
to ensure appropriate case progression. I discharged the nominated
representative role and would have performed my SAO role in terms of any
POCA engagement. Because of the relationship with the NFSP, I would have
likely kept John SCOTT apprised as Head of Security.
114. I had no role in the initial investigation.
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115. My role in relation to charge and prosecution remains that at 112/
above.
116. I have considered POL00050244, POL00050040, POL00061322,
POL00046450, POL00056762 and POL00094295. I would have been
supervising Ged HARBINSON. I had qualified under the National Police
Improvement Agency as the POCA Senior Appropriate Officer. I would have
had oversight of the financial investigation using 121 discussions with Mr.
HARBINSON as Financial Investigator and his case notes. This again would
have likely been a case conducted with the knowledge of the NPIA.
117. Recovery decisions were made in line with POCA and after
consultation with John SCOTT as Head of Security given the gravitas of the
investigation in terms of NFSP relationship.
118. I understand from POL00056762 that the amount outstanding was paid
by way of Compensation Order.
119. I have examined POL00051044, POL00059762, POL00044916 and
POL00060421. I’m not certain if I was aware of the correspondence at the
time. Saying that I would have been surprised if I hadn't been. However, I
certainly wouldn’t have thought the content would have influenced the
decisions made.
120. I have read POL00046524 and POL00050993. I don’t recall whether I
was aware of these issues at the time. However, I have dealt with similar
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issues and would have expected that the correspondence was sent to CLT for
their notice.
121. I do not recall reviewing the prosecution or indictment decisions.
122. Clearly, the prosecution was wholly wrong as was the continual Post
Office refutes that the system was not at fault. Had I been aware that there
was knowledge of bugs, errors and defects that could ultimately and
significantly affect the cash values required to perform an acceptable balance
and I was expected to remain mute around these and continue any form of
role within the Security function, then I would have considered my position
untenable.
Prosecution of Julian Wilson
123. I note that at POL00044692 that I am the nominated representative in
terms of prosecution. This likely would have been the first time I was aware of
the case. The case would have, traditionally, been sent to me and the been
forwarded to CLT.
124. I had absolutely no role in the initial investigation.
125. I had no role in the charging decision and my prosecution role is as
previously detailed.
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126. Unfortunately, POL00052183 is omitted from my papers. I am therefore
unaware of the context and the role I played in it.
127. I would have read at the time the report at POL00044692 was
submitted and been aware of the assertion that Horizon was cited as being
one of the causes for deficiencies as well as the supporting precis at
POL00050140 and POL00050128 and the comments made by Mr. Rob
WILSON. At the time these would have been dismissed given the repeated
assurances being presented by the business around the system reliability.
128. I have considered POL00051920, UKG100012555, POL00044751,
POL00044809, POL00051720, POL00051459, POL00044800 and
POL00051936. I don't recall seeing these documents previously. I do not
recall any review of the prosecution decision albeit any proposed change in
the indictment would, time permitting, ordinarily come back into the Security
function.
129. Clearly, the prosecution was wholly wrong as was the continual Post
Office refutes that the system was not at fault. Had I been aware that there
was knowledge of bugs, errors and defects that could ultimately and
significantly affect the cash values required to perform an acceptable balance
and I was expected to remain mute around these and continue any form of
role within the Security function, then I would have considered my position
untenable.
Prosecution of Peter Holmes
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130. I have been asked to comment on the above using the initial report
POL00050832 and interview precis POL00066743.
131. In terms of prosecution, I can see I was detailed as the nominated
representative. I would have acted in respect of the CLT decision as
previously stated. I would have played no active operational role in the initial
investigation.
132. I have read the interview precis at POL00050561. I can indeed see that
Horizon difficulties have been cited. Again, these assertions would have been
transacted with the fact that a steady stream of denials were being issued by
Post Office.
133. I do not recall any review of the prosecution decision albeit any
proposed change in the indictment would, time permitting, ordinarily come
back into the Security function. By time permitting, I mean that occasionally a
change of plea in Court may have been discussed directly with CLT, by the
agent, and agreed.
134. Clearly, the prosecution was wholly wrong as was the continual Post
Office refutes that the system was not at fault. Had I been aware that there
was knowledge of bugs, errors and defects that could ultimately and
significantly affect the cash values required to perform an acceptable balance
and I was expected to remain mute around these and continue any form of
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role within the Security function, then I would have considered my position
untenable.
Prosecution of Seema Misra
135. I have read and noted the available documents in relation to the above
named. I would have had no role in the initial investigation but would have
been privy to the upward report at POL00044541. As previously stated, this
was a period when I discharged the role of nominated representative in terms
of prosecution decision. I have previously outlined my role in this matter and
would have taken the proposed CLT charges and ensured that prosecution
commenced. Could I immediately add please that during late 2009 / early
2010 I had no Fraud Strand ownership. This sat instead with lain Murphy.
Whilst I would have been in role for the inception of the investigation, matters
during 2010 I would assume were handled or occurred with the knowledge of
lain MURPHY Senior Security Manager.
136. I have outlined on a number of occasions my thought process around
discharging the role around prosecution. I saw myself enacting a charging
decision from CLT. At POL00049716 I would presumably have been agreeing
with the CLT proposed schedule of charge(s).
137. At POL00049716 I was enquiring from the CLT Lawyer Mr. Jarnail
SINGH as to whether there should not be consideration of charges under the
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Fraud Act. At that stage I was aware that the relatively new Act was
increasingly being used in charging decisions for cases such as this.
138. I have examined POL00051441 and POL00051539. On
POL00051441, then in the absence of the committal bundle or page stated,
then I am unsure why the Investigator would question prosecution
continuance. I don’t recall the specifics of this case. I can say that dropping
the theft charge in relation to acceptance of falsification of accounts was
certainly not unheard of. Again, these matters would have been deferred back
to CLT and discussed between CLT and nominated agents.
139. I have read through POL00051773. When transacted with
POL00044541 I can see that the challenge to Horizon integrity occurred in
around June 2009.
140. I have noted the contents of POL00052202. I can see that there is
some push back on the volume of ARQs requested. The challenge would
have been around exhausting contractual limits and incurring additional costs.
I don’t read the document as an absolute denial to supply, rather and quite
rightly a request for further discussion, led by the Investigator to CLT.
141. I have read through a significant volume of documents in respect to the
cut and thrust of disclosure requests. I have no knowledge of these requests
or the CLT counters. At POL00053849 then I have no idea what this relates
to. I can see no evidence that this was escalated to me, although obviously it
may have been at Team Leader 121 or similar.
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142. I can offer no comment as to position offered to the Defence by Post
Office around disclosure demands. I can clearly see from the various counters
that Post Office felt this was unacceptable, but perhaps a fuller answer would
be available from the decision makers in this respect. But simply, as an
Investigator, Investigation Team Leader or Senior Security Manager then we
would have attempted to meet every disclosure request. It was not for us to
apply a reasonableness test, but rather would expect that to be performed
through CLT.
143. I do not recall how Penny THOMAS and Gareth JENKINS became
involved. I seem to recall that Gareth JENKINS was involved in individual
cases via CLT. I can’t see a logical involvement point within the various
documents save for the statements form Gareth JENKINS at POL00110275,
POL00001643 and FUJ00122906. I would have considered Mr. JENKINS to
have been acting as an expert witness.
144. At the time of this investigation, I recall no explanation given to me
internally around a bug, error, or defect within the Horizon system.
145. I have no view on the material sought by the Defence. Clearly, at
instances such as POL00053723, POL00044557, POL00053746,
POL00054010 and POL00044553, requests were being challenged.
146. In respect of POL00055418 I presume that this was under the watch of
lain MURPHY as previously detailed. Likewise, I would have expected any
changes in prosecution or charge amendment to be within his knowledge if
applicable.
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147. Clearly, the prosecution was wholly wrong as was the continual Post
Office refutes that the system was not at fault. Had I been aware that there
was knowledge of bugs, errors and defects that could ultimately and
significantly affect the cash values required to perform an acceptable balance
and I was expected to remain mute around these and continue any form of
role within the Security function, then I would have considered my position
untenable.
Prosecution of Alison Hall
148. I note that the nominated representative for the prosecution for this
case was lain MURPHY as at POL00091037 but that at POL00091300 I act
as the nominated representative in providing this. I have covered my thought
process around this previously.
149. I had no role in the initial investigation. I had no role in any charging
decision.
150. I would have read the case papers commencing with the report at
POL00091037 and precis at POL00021252. The case seems centered
around lottery scratch cards which I seem to recall was a stand-alone entity to
the Horizon system in terms of selling cards, but I also see transaction
corrections mentioned that are obviously connected with Horizon. I would
therefore have been aware of the connection and again relied on the business
assertions.
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151. I don’t recall any involvement or request to review the prosecution
decision or involvement in changing the indictment. I don’t recall any
involvement in agreeing the eventual plea basis.
152. Clearly, the prosecution was wholly wrong as was the continual Post
Office refutes that the system was not at fault. Had I been aware that there
was knowledge of bugs, errors and defects that could ultimately and
significantly affect the cash values required to perform an acceptable balance
and I was expected to remain mute around these and continue any form of
role within the Security function, then I would have considered my position
untenable.
Prosecution of Lynette Hutchings
153. I note that it is alleged I was the nominated representative for the
prosecution as per POL00056478. I have covered my thought process around
this discharge of responsibility previously.
154. I had no role in the initial investigation. I had no role in any charging
decision.
155. I would have read the case papers commencing with the report at
POL00056478 and precis at POL00056532, POL00044505, POL00046625. I
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note that Horizon was immediately cited. I would therefore have been aware
of the connection and again relied on the business assertions.
156. I don’t recall any involvement or request to review the prosecution
decision or involvement in changing the indictment. I don’t recall any
involvement in agreeing the eventual plea basis. Indeed, I suspect that a
number of these discussions and decisions took place and were made when I
had no responsibility for investigations.
157. Clearly, the prosecution was wholly wrong as was the continual Post
Office refutes that the system was not at fault. Had I been aware that there
was knowledge of bugs, errors or defects that could ultimately and
significantly affect the cash values required to perform an acceptable balance
and I was expected to remain mute around these and continue any form of
role within the Security function, then I would have considered my position
untenable.
Prosecution of Grant Allen
158. I note from POL00089436 that I was the nominated representative for
the prosecution. I do not believe I was at that stage working in the fraud
function and that this is an error on the template. I would like this clarified
please before I can make further comment.
159. I have examined POL00089560, POL00089110 and POL00089111. I
don’t recall the discussions I had with Mr. BRADSHAW. Contextually, I do
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recall that Investigators were to really explore when an individual showed
uncertainty around the need for a legal representative and particularly when
uncertainty was around cost or convenience. Mr. BRADSHAW did exactly
what was expected of him. If I’m reading the events correctly, the Mr. ALLEN
showed initial uncertainty around whether legal representation was required,
but this shifted to one of him taking advice post interview and being content to
continue.
160. Clearly, the prosecution was wholly wrong as was the continual Post
Office refutes that the system was not at fault. Had I been aware that there
was knowledge of bugs, errors and defects that could ultimately and
significantly affect the cash values required to perform an acceptable balance
and I was expected to remain mute around these and continue any form of
role within the Security function, then I would have considered my position
untenable.
Prosecution of Mr Khayyam Ishaq
161. I note that the nominated representative for the prosecution for this
case as detailed at POL00046224 and at POL00057078. I have covered my
thought process around this previously.
162. I had no role in the initial investigation. I had no role in any charging
decision.
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163. I do not recall how Penny THOMAS and Gareth JENKINS became
involved. I seem to recall that Gareth JENKINS was involved in individual
cases via CLT. I would have considered Mr. JENKINS to have been acting as
an expert witness.
164. At the time of this investigation, I recall no explanation given to me
internally around a bug, error, or defect within the Horizon system.
165. In respect of POL00046243 then my expectation would be that the
disclosure test would have been attended to via CLT.
166. POL00059686 has been examined. I have no reason to believe that
Mr. BRADSHAW was doing anything other than tow the party line. Mr.
BRADSHAW will need to comment himself on whether he would have made
such a bold assertion had he been in possession of all the facts.
167. I don’t recall any involvement or request to review the prosecution
decision or involvement in changing the indictment. I don’t recall any
involvement in agreeing the eventual plea basis.
168. Clearly, the prosecution was wholly wrong as was the continual Post
Office refutes that the system was not at fault. Had I been aware that there
was knowledge of bugs, errors and defects that could ultimately and
significantly affect the cash values required to perform an acceptable balance
and I was expected to remain mute around these and continue any form of
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role within the Security function, then I would have considered my position
untenable.
Prosecution of Angela Sefton and Anna Nield
169. I note from POL00044017 that I appeared as the nominated
representative for the prosecution for this case. I have covered my thought
process around this previously.
170. Logically, my belief is that this case was a matter of a short few weeks
before I left Fraud Strand / Security Operations to take up the Grapevine
Intelligence role. Decisions made or not made after this time should be
addressed to my successor.
171. I had no role in the initial investigation. I had no role in any charging
decision.
172. At the time of this investigation, I recall no explanation given to me by
the business around a bug, error or defect within the Horizon system.
173. Clearly, the prosecution was wholly wrong as was the continual Post
Office refutes that the system was not at fault. Had I been aware that there
was knowledge of bugs, errors and defects that could ultimately and
significantly affect the cash values required to perform an acceptable balance
and I was expected to remain mute around these and continue any form of
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role within the Security function, then I would have considered my position
untenable.
Review of challenges to Horizon Integrity / Post Office
Investigations
174. I am struggling with any clarity to recall the involvement I may have had
regarding investigations into the integrity of Horizon. I have been asked to
refer to several emails including POL00120471 and POL00120479. Cleary at
POL00120471, I as being asked to input into case number details concerning
pre and post Horizon online migration. It seems that cash checks on migration
were producing shortages; I really can’t be more specific or recall why the
input was required. Likewise, at POL00120471, I can see I am cc into a Rod
ISMAY email around Horizon integrity. Obviously, I’m aware that Mr. ISMAY
was a key contributor to the defence of Horizon integrity, but I can’t remember
the specifics, other than the continued stance that Horizon was fit for purpose.
I do recall Helen ROSE playing a supporting role in terms of analysis. Whilst
ostensibly Helen worked in my strand, I am aware that Helen was supporting
other Strand leads with Horizon type issues. At that point my remit was firmly
around external crime management and maturing the Grapevine service
175. I genuinely don't recall any sizeable levels of engagement with the
other bodies or individuals named.
General
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176. It's clear that operationally there was cynical group think around in
integrity challenges and this has been highlighted previously in this statement
when you consider some of the language used and assertions made around
disclosure demands.
177. I did not seek further information when giving consideration to
discharging my nominated representative role in terms of prosecution. I was
confident that cases submitted to CLT contained prima facie evidence of
criminality, contained all the facts and circumstances and accordingly the
charging advice returned never shook me enough to question the
recommendation.
178. Yes, I did support the refusal of a prosecution. I worked in the Liverpool
District and along with the Head of Services declined a prosecution in relation
to a SPMR who had suffered several physical assaults by the local community
and whose partner and small child had narrowly escaped serious injury when
the rear yard entrance to the Post Office was effectively boobytrapped with
concrete blocks designed to fall from a height on anyone accessing the yard.
As I recall the SPMR was effectively forced to rehouse his family and
committed offences in terms of applying official cash to personal use given
increased expenditure, when faced with additional costs this rehousing had
incurred. The District argued that prosecution was not the correct route to
take. I do recall having a ticking off from a Senior Lawyer for failing to ensure
that the District effectively engaged back with CLT when making the decision.
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179. I have also been highly critical and challenging when as an Investigator
I was forced to deal with branches that clearly lacked financial viability. I recall
a Shropshire branch had, I seem to remember, three quickly successive
SPMRs that failed to make a viable business with the third incumbent
prosecuted. I went past the former branch the other month — it was now
permanently closed. I recall vocally criticising a Retail Line decision at the
time to continue services. I did similar at other branches and particularly
when suspensions were met with family transfers that effectively exasperated
financial troubles.
180. The more I see and hear from the Inquiry, then the further I despair. It
strikes me that no one, at a suitable level of seniority, had the conviction and
gumption to say enough is enough and to drive a timely, truly independent
review whilst ceasing all prosecution activity and having the courage to be
prepared to support the application and lessons of a truly independent
Horizon review, to both historic prosecutions and non-prosecuted repayment
of accounting shortfalls. As someone that held several investigatory roles in
the Post Office, I feel utterly deceived.
181. With hindsight there should have been a team of skilled analysts
working on behalf of branch errors, conducting full error analysis using
complete and unabridged Fujitsu data including all reversals. This level of
transparency would have supported SPMRs to come forward at low level loss
stage, rather than being pushed into systematic false accounting series.
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182. I genuinely don't feel well informed enough to comment on Fujitsu’s
role in escalating bugs, errors, and defects.
Statement of Truth
I believe the content of this statement to be true.
Page 55 of 62
Index to First Witness Statement of David John Pardoe
WITNO08170100
WITNO08170100
URN
Document Description
Control
Number
POL00091037
Post Office Ltd Investigation - Alison
Loraine Hall
POL-0090681
IN
POL00104968
POL - Enforcement and Prosecution
POL-0080600
Policy (with comments)
loo
POL00105229
Post Office Ltd PNC Security
POL-0080854
Operating Procedures
rs
POL00104853
Post Office's Financial Investigation
POL-0080485
Policy
Ion
POL00030578
S02 Royal Mail Group Criminal
POL-0027060
Investigation and Prosecution Policy
December 2007
ID
POL00104812
“Royal Mail Group Ltd Criminal
POL-0080444
Investigation and Prosecution Policy"
IN
POL00031004
RMG Policy - Crime and Investigation
POL-0027486
(S2) - version 3.0
100
POL00031003
Royal Mail Group Crime and
POL-0027485
Investigation Policy v1.1 October
2009
Io
POL00104900
Undated 'Separation Project -
POL-0080532
Criminal Investigations Policy for Post
Office Ltd’
POL00105191
Activity Plan for POL separation
POL-0080816
project - Criminal Investigations Policy
POL00105216
Post Office Ltd Security Operations
POL-0080841
Team — Compliance — Guide to the
Preparation and Layout of
Investigation Red Label Case Files:
Offender reports and Discipline
Reports - undated
POL00104821
Condensed Guide for Audit
POL-0080453
Attendance v2
POL00104929
"Post Office Limited: Internal Protocol
POL-0080561
for Criminal Investigation and
Enforcement (with flowchart)"
POL00104747
Investigation Policy: Casework
POL-0080387
Management (England & Wales) v1.0
POL00104777
Investigation Policy: Casework
POL-0080417
Management (England & Wales) v4.0
POL00118104
Appendix 6 - Identification codes
VIS00012693
(undated - date taken from parent
email)
POL00118128
Race Identification Codes, numbers 1-
VIS00012717
Zz
Page 56 of 62
POL00055590
Email from Marilyn Benjamin on
WITNO08170100
WITNO08170100
POL-0052069
behalf of Jarnail A Singh to Mandy
Talbot, Hugh Flemington, Jacqueline
Whitham, Re: Regina v Seema Misra-
Guildford Crown Court-Trial-Attack on
Horizon
FUJ00080107
Fujitsu's Guidance on Security
POINQ0086278
management service: Service
Description (v.2)
F
POL00114566
Audit Record Requests (Increase In
POL-0113672
Limits)
POL00047955
Josephine Hamilton Offences Report
POL-0044434
POL00118877
Antecedents of Josephine Hamilton -
POL-0118796
Officer in Case Graham Brander,
Supervising Officer Dave Posnett
POL00118990
Josephine Hamilton criminal case
POL-0118909
study - Suspect offender reporting
form to be emailed to Casework team
case file no. POLTD 0506/068.
Josephine Hamilton
POL00049083
Email from Graham Brander to
POL-0045562
Jennifer Andrews, Juliet McFarlane
Dave Pardoe and others re: Fw:
Hamilton
POL00044388
Josephine Hamilton case study:
Memorandum from Miss J A
McFarlane to Investigation Team Post
Office Limited, cc Graham Brander,
Ged Harbinson and Dave Pardoe RE:
R v Josephine Hamilton mentions
hearing 19/11/2007 - update after
hearing
POL-0040867
POL00049071
Josephine Hamilton Case Study:
POL-0045550
Financial Investigation Policy Log -
Josephine Hamilton.
POLTD/0506/0685.
POL00049535
Josephine Hamilton case study:
POL-0046014
{Internal Memo from Ged Harbinson
to Dave Pardoe re: Investigation Ref: -
POLTD/506/0685 - OFFICE South
Warnborough / SUSPECT NAME
Josephine Hamilton]
POL00113278
Approved Judgment between
POL-0110657
Josephine Hamilton & Others and
Post Office Limited
Page 57 of 62
POL00050123
Email from Mike Wilcox to Williamson
POL-0046602
and finance investigation in re to
Susan Rudkin
WITNO08170100
WITNO08170100
POL00050347
Email from David Pardoe to Fraud
POL-0046826
Team Post Office, RE: DAM Authority-
Susan Jane Rudkin Ibstock
POL00050026
Record of tape recorded interview of
POL-0046505
Susan Jane Rudkin dated 20/8/08.
POL00050244
Financial investigation policy log in re
POL-0046723
to Susan Rudkin dated 21/08/2008
POL00050040
Susan Rudkin case study: [Witness
POL-0046519
statement of Gerald Harbinson in
support of an application for a
restraint order]
POL00061322
Email chain from Ged Harbinson to
POL-0057801
Mike Wilcox cc Graham Brander re:
Fw: lbstock Sub Post Office (re
Restraint)
POL00046450
Witness statement of Gerald
POL-0042929
Harbinson
POL00056762
Financial Investigation Events Log
POL-0053241
Susan Rudkin csae no:
POLTD/0809/0101
POL00094295
Susan Rudkin Case Study - Email
from Tahira Rasool to Ged Harbinson
re: Michael and Susan Rudkin
(Ibstock PO, 2232170) - Email chain
provides background to the
prosecution and discusses repayment
of debt
POL-0093241
POL00051044
Email from Jarnail A Singh to Tahira
POL-0047523
Rasool in re to Michael and Susan
Rudkin (lbstock) Leicester post office.
POL00059762
Email from Glenn Chester to Sarah
POL-0056241
Howards, Re: Urgent Advice needed-
Flag Case FCT728
40
POL00044916
Letter from Mr Michael Rudkin to POL
POL-0041395
re: Requesting withdrawal of
suspension & prosecution
POL00060421
Letter from E M Rudkin to Mr Goerge
POL-0056900
Thomson re: Private, In the Strictest
Confidence and without Prejudice.
POL00046524
Letter from Marie Dancer to Mike
POL-0043003
Wilcox in re to Susan Rudkin
POL00050993
Letter from Dr A T Peden Richard
POL-0047472
Nelson Solicitors in re to Susan
Rudkin's mental health.
Page 58 of 62
POL00044692
Post Office Ltd investigation report for
POL-0041171
Julian Wilson (Astwood Bank office)
WITNO08170100
WITNO08170100
POL00047029
Memo from Miss J S Andrews to Post
POL-0043508
Office Security re: Regina v Julian
Wilson Worcester Crown Court
Confiscation Hearing - W/L WIC 16th
November 2009 Case No:
POLTD/0809/0126
POL00050140
Transcript: Record of tape interview in
POL-0046619
re to Julian Wilson dated 15/09/2008
POL00050128
Transcript: Record of tape recorded
POL-0046607
interview in re to Julian Wilson.
POL00051920
Julian Wilson case study: Letter from
POL-0048399
J. Canlin to Mr J Singh RE: Julian
Wilson - Worcester Crown Court. 15th
June 2009 - PCIVIH
UKGI00012555
Letter pertaining to Plea and Case
UKGI023351-
Management hearing R v Julian
001
Wilson from Jarnail Singh to Jolyon
Canlin
POL00044751
In The Crown Court at Worcester.
POL-0041230
Advice statement re: R v Julian
Wilson
POL00044809
Indictment, Draft Case Summary from
POL-0041288
Anthony Vines, Civitas Law - Rv
Julian Wilson
POL00051720
Letter from Jarnail Singh to Fraud
Team Post Office Limited c.c. Gary
Thomas and others re: REGINA v
JULIAN WILSON
POL-0048199
POL00051459
Instructions to Counsel (Mr Anthony
POL-0047938
Vines of Civitas Law) drafted by Rob
G Wilson to settle indictment and
advise on evidence and brief for the
prosecution in the matter of The
Queen v Julian Wilson (Backsheet
endorsed by Counsel (Richard Cole
with various dates)
POL00044800
Indictment, Statements of Offences -
POL-0041279
R v Julian Wilson
POL00051936
Letter from John H. Dove. to Mr. J.
POL-0048415
Singh re: Regina - v - Julian Wilson -
Worcester Crown Court
Page 59 of 62
POL00050832
Peter Holmes Case Study: POST
WITNO08170100
WITNO08170100
POL-0047311
OFFICE LTD CONFIDENTIAL:
INVESTIGATION LEGAL
POLTD/0809/0128, OFFENCE.
Theft/False Accounting re: Peter
Anthony HOLMES
POL00066743
Note on Peter Holmes Interview
POL-0063222
POL00050561
Record of tape interview in re to Peter
POL-0047040
Anthony Holmes dated 19/09/08.
POL00044541
POL Investigation Report for Seema
POL-0041020
Misra (POLTD/0708/ 0249
POL00049716
Email from Jason G Collins to Jarnall
POL-0046195
A Singh re: DAM Authority Seema
Misra West Byfleet
POL00051441
Letter from Phil Taylor to Mr Wawick
POL-0047920
Tatford. Re: Counsel's advice on
criminal prosecution of Seema Misra
for theft
POL00051539
Seema Misra Case Study - Email from
POL-0048018
Warwick Tatford to Phil Taylor re
Seema misrta Guildford Crown Court
Trail - W/L 1st -12th June 2009.
POL00051773
Seema Misra Case Study: Attendance
POL-0048252
Note by Jarnail Singh re: Seema
Misra at Guildford Crown
Court(CRM/258932/JSX)
POL00052202
Email from John Longman to Phil
Taylor Fw: Trial of Seema Misra -
West Byfleet SPSO - Branch Code
126023 - Guildford Crown Court 30th
November 2009 (Four day trial)
POL-0048681
POL00053849
Attendance note from Jarnail Singh
POL-0050328
for Seema Misra dated 27/01/10.
POL00110275
Witness Statement of Gareth Idris
POL-0108082
Jenkins Version 3.0 11/02
POL00001643
Witness statement of Gareth Jenkins
VIS00002657
FUJ00122906
Witness statement of Gareth Idris
POINQ0129120
Jenkins; Re: Seema Misra
F
POL00053723
Email from Jarnail Singh to Warwick
POL-0050202
Tatford incl em chain from Mark
Dinsdale to Rob Wilson re: advice
requested on disclosure request in
MISRA case
POL00044557
Advice on requests for disclosure in
POL-004 1036
Seema Misra case
Page 60 of 62
POL00053746
Seema Misra case study - Letter from
POL-0050225
Jarnail Singh to Coomber Rich
Solicitors, RE: R v Seema Misra
Guildford Crown Court, Trial 15 March
2010
WITNO08170100
WITNO08170100
POL00054010
Email from Issy Hogg to Jarnail Singh
POL-0050489
RE: FW: R v Seema Misra Guildford
Crown Court Trial 15th March 2010 -
disclosure
POL00044553
Letter Jarnail to Singh to Seema
POL-004 1032
Misra's lawyers regarding Regina v
Seema Misra Guilford crown court
POL00055418
Email exchange between Mandy
POL-0051897
Talbot, Jarnail Singh, Rod Ismay and
Mike Granville
POL00091300
Email from David Pardoe to Post
POL-0090944
Office Security, RE: DAM Authority.
Hightown
POL00021252
Alison Hall, POLTD-1011-0095.
POL-0014444
Record of interview with Post Office
investigation department
POL00056478
Post Office Confidential: Investigation
POL-0052957
Legal - report of Lynette Hutchings
investigation
POL00056532
Lynette Hutchings Case Study :
POL-0053011
Record of Taped Interview of Lynette
Hutchings dated 20/04/2011
POL00044505
Record of Taped Interview with
POL-0040984
Lynette Hutchings
POL00046625
Transcript: Record of taped interview
POL-0043104
re Lynette Hutchings dated
20/04/2011.
POL00089436
Email from Jarnail Singh to Hugh
POL-0086411
Flemington re: Horizon cases
POL00089560
Post Office Limited - Witness
POL-0086535
Statement of Stephen Bradshaw
POL00089110
Post Office Ltd Security Operations
POL-0086085
Typed Copy of Notebook Entry
POL00089111
Agreement to Continue without Legal
POL-0086086
Advice: Interviewer (Grant lan Allen)
and Investigator (Stephen Bradshaw)
POL00046224
Investigation (Legal) Offender Report
by Stephen Bradshaw — Khayyam
Ishaq
POL-0042703
Page 61 of 62
POL00057078
Khayyam Ishag case study:
POL-0053557
Investigation (Legal) report by
Stephen Bradshaw re Khayyam Ishaq
WITNO08170100
WITNO08170100
POL00046243
Email from Cartwright King to Stephen
POL-0042722
Bradshaw re Ishaq case
POL00059686
Witness Statement of Stephen
POL-0056165
Bradshaw re Second Sight
appointment
POL00044017
Hand written note about
subpostmaster's contractual obligation
to make good discrepancies / Angela
Sefton, Ann Nield case
POL-0040496
POL00120471
Emails chain from Lynn Hobbs t To
POL-0126165
Sue Huggins, Nick Beal, Philippa
Wright and others. Re: Horizon -
Urgent Please
POL00120479
Email chain from Rod Ismay to Rod
POL-0126171
Mark Burley, lan Trundell, Dave
Pardoe and others Re: Horizon
Challenges - Draft report with
attachments
Page 62 of 62