WITN08530100 Catherine Oglesby - Witness Statement

Evidence on official site

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Witness Name: CATHERINE OGLESBY
Statement No: WITN08530100

Dated: 4 June 2023

POST OFFICE HORIZON IT INQUIRY

FIRST WITNESS STATEMENT OF CATHERINE OGLESBY

I, Catherine Oglesby will say as follows:

1. I am providing this statement following a request for information pursuant
to Rule 9 of the Inquiry Rules 2006, regarding matters falling within Phase 4 of
the Inquiry: action taken by Post Office Ltd against Subpostmasters, dated 18

April 2023. The request contained 64 questions which I have addressed below.

2. I would like to flag that the questions are mainly centred around the case
of Lee Castleton, the events of which happened over 20 years ago. Due to the
passage of time, I have found it difficult at times to recall precise details.
However, this statement is made to the best of my recollection and where I
cannot remember something or have had to rely on a document provided, I

have made this clear.

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3. At the outset, I would like to offer my sympathy to all subpostmasters
who were affected by Horizon related issues and in particular, to Lee
Castleton. When the decision was made to terminate Mr Castleton’s contract,
this was based on an understanding that the Horizon system was working as
it should. I would like to express my sincere sympathy in how this affected
both Mr Castleton and his family and would like to express my support for the

Horizon Inquiry and to offer my full co-operation to Sir Wyn Williams.

Background

4. I have been asked to set out a summary of my professional
background. I started my career in the Post Office in February 1982, at the
age of 16, working on the Selby Post Office Counter in North Yorkshire. I
worked in this role for 5 years until 1987 when I gained a promotion to Selby
Branch Manager. I was then promoted in 1991 to Branch Manager of the main
Post Office in York. I also did a small secondment during this time to manage
the Post Office in Hull, as Branch Manager. In September 1992 I took
maternity leave for my first child and returned to work in April 1993. I then took
maternity leave for my second child in October 1994 until April 1995. Both

times I returned to the same role.

5. In July 1996 I went on maternity leave for my third child, returning to
work in January 1997. I recall that I moved roles when I returned to work but I
cannot recall whether my role was called ‘Retail Network Manager’ or ‘Area
Manager’. However, both of these roles are similar, with slightly different
names. I continued in this role until there was a general reorganisation within

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the Post Office in approximately 2005 at which point I was promoted to Area
Manager for the Directly Managed Branches from Selby to Sunderland. I
continued in this role until approximately 2010 and during this period, I did a
secondment to the ‘Service and Efficiency Team’ for about 8 months. In
approximately 2010, I gained a promotion to Regional Performance Manager,
running a team of Area Managers and customer service colleagues promoting
financial services in the Directly Managed Branches East England, Northern

Ireland and Yorkshire.

6. In approximately 2013, when the financial services were scaled down, I
became Regional Manager for the East Midlands Team. I then left the
business in 2015 and took time out until February 2016 when I started
working part-time at First Direct and Barlby and Osgodby Town Council. I
stopped working for First Direct in October 2017 but I still work around 9 hours
per week for Osgodby Town Council. In November 2017 I re-joined the Post
Office, working as an Area Manager for East and part of North Yorkshire. I am

still in this role today.

7. The Inquiry have asked specifically about my time as a Retail Line
Manager at the Post Office. To confirm, I have had several Retail Line
Manager roles with the titles of the role changing from ‘Retail Line Manager’ to
‘Retail Network Manager’ to ‘Area Sales Manager’ to ‘Area Manager’. As
detailed above, the dates of these roles were 1997 — 2005 in the Postmaster
Network, 2005 — 2010 in the Directly Managed Network and 2017 — present

day in the Postmaster Network.

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8. All of these roles have been similar, and involved the following:

a. to support a network of Postmasters and Strategic partner branches to
grow their business by coaching and supporting the Postmaster and
their staff on appropriate conversations with customers;

b. to build product knowledge and confidence on products to enable an
opportunity to be spotted and a conversation to take place;

c. to ensure all point of sale and literature is up to date and matches the
current campaigns;

d. to discuss the whole business including the retail sales, displays and
layout of the shop;

e. to enable a Postmaster to maximise their business potential;

f. to ensure that the Postmaster and staff are following the correct
security procedures and maintaining the Branch standards;

g. recruitment of new Postmasters, suspensions and termination of

contracts.

9. I would like to flag to the Inquiry that I understand that ‘g’ - suspensions
and terminations are now no long part of this role, but the responsibility of the

Contracts Team. However, it was within my role in 2003.

10. I would also like to flag that a Retail Line Manager (and all of its various
titles) did not have the responsibility to physically check the cash and stock of

a Branch or to try and find a loss or a gain if the Postmaster had not balanced

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their stock. The roles were to support the Postmaster and to signpost them to
the correct place to get support if needed, for example: Horizon Helpline,

Business Support Centre, Giro Bank, Savings Bank and the Cash Centre.

Early involvement in relation to Marine Drive Post Office

Initial contact with Mr Castleton

11. The Inquiry have provided me with the following documents:
POL00069622, POL00083604 and POL00107117. I can confirm that I have
reviewed these documents.

12. The Inquiry have asked me about my involvement with the Marine
Drive Post Office (“Marine Drive”) prior to Mr Castleton being appointed as its
Subpostmaster (SPM). Marine Drive was a Branch in my area when I was
Retail Line Manager for Hull and East Yorkshire and part of North Yorkshire.
Prior to Mr Castleton taking over the Branch in July 2003, I would visit the
previous Postmaster, whose name I cannot remember, and discuss the areas
listed in 8(a) — (g) above. The branch was one of about 85 branches that I

looked after and I cannot recall that there were any problems with it.

13. The Inquiry have asked me to describe the circumstances in which I
first had contact with Mr Castleton. Although I cannot remember the date, I
would have first met Mr Castleton at his Post Office interview for Marine Drive.
Based on the information provided to me by the Inquiry, I note that he took
over the branch in July of 2003. His interview would have been in
approximately April 2003, 3 months prior to taking over the branch. Once Mr

Castleton had taken over the branch, I would have visited him at least once

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every other month to see how he was getting on, although I do not have my

diaries going back to this year to check the exact dates.

14. The Inquiry have provided me with document LCAS0000699 “Marine
Drive Post Office Summary of Events”. This gives a summary of the events at
Marine Drive Post Office when Mr Castleton was its SPM. I can confirm that I
wrote this document to capture a timeline of events and to keep a record of
what support had been given to try to find out why the branch was having
losses. If I was dealing with a situation which was complicated, I would often
make notes so that I could remember information if needed. As the situation
at Marine Drive was becoming so complicated, I took it upon myself to write
this narrative so that I would have a contemporaneous note to refer to. I was

not asked by anyone else to write it.

15. I have been asked to explain when Mr Castleton first reported a
shortfall at Marine Drive and the discussion that I had about it. I have
refreshed my memory from reading document LCAS0000699 and understand
that Mr Castleton contacted me between Christmas and New Year 2003 to
report a loss of £1,100.00. We discussed where that loss might be from. The
most common errors for losses were due to Giro bank or National Savings,
which are banking errors, for example a withdrawal entered as a deposit. I
therefore asked Mr Castleton to contact both Giro Bank and National Savings
to see if there were any outstanding errors. Another common error was for

cheques to be entered as cash, which would cause a loss. I did not think that

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this loss was unusual as it was common for branches to have a loss of this

amount due to an error.

16. When there was a loss, it was for the SPM to make that loss good. If
the SPM could not make the loss good than the usual procedure would be to
refer them to the Support Centre to obtain a hardship form. They could then
make an application to pay off the loss in smaller amounts on a monthly basis

and deductions would be made from their remuneration.

17. I therefore followed this procedure and asked Mr Castleton to make
good the loss. I did not ask him to do anything that I would not have asked
another SPM to do. As the loss was over £1,000 I would have checked with
him that he was able to pay it and have discussed options for repayments if

he said that he could not.

18. I When Mr Castleton confirmed that he was able to make the loss good,
I did not make any further enquiries. We assumed that in a few months’ time
he would get an error notice and get the amount back as was usual in this
kind of situation. It was common for SPMs to do their balance, make a loss
good and then the money would appear later on when the error was
discovered. I can see from my notes that I asked Mr Castleton to contact Giro
bank and National savings as these would be the most obvious places that a
loss could be that had left the Branch. If the loss was an error in counting
cash or stock, then he would find that himself the following week when he

balanced again.

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19. I have been asked to describe my visit to Marine Drive on 16 January
2004 and any enquiries that I made about the shortfall. I cannot recall the visit
and therefore this is taken from my summary document (LCAS0000699).
From reading my notes this looks like one of my routine visits and I have
written that nothing had come to light regarding the loss, so I am presuming
that I discussed the loss of £1,100 with Mr Castleton. Giro bank errors usually
took about 8 weeks to be returned at that point, so there was still a possibility
that the loss was a Giro bank error. I have noted that the three balances that
Mr Castleton had done between the initial loss of £1,100 and my visit of 16
January 2004 were all fine. As my visit was only 3 weeks after the initial loss,
there was still plenty of time for it to come to light and therefore, I would not

have made any other enquiries.

20. The Inquiry have asked me about what enquiries or investigations I
was involved with to determine the cause(s) of the shortfalls that Mr Castleton
reported between January 2004 and March 2004. I cannot recall this and
therefore this is all taken from my summary document (LCAS0000699). I
understand from reading my notes that the losses totalled £25,758.75 in

March 2004.

21. From reading my notes I can see that I asked Mr Castleton to repeat
the calls to Giro bank and National savings to see if any documentation that
had left the branch was incorrect and to see if any error notices were pending.

I asked him to complete a snapshot each evening to check the cash and to

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ensure that the branch was balancing. By doing this, he would be able to see
daily if the balancing was short or over. I also asked about how the cash was
being kept secure and if he thought any of the staff may have taken the
money. This is never something that a SPM likes to think about but
unfortunately it does happen and I have known occasions when staff
members have taken or borrowed money. I also suggested individual till
balancing which would put tighter controls in place and narrow down to a
person where the losses were happening. I offered to help Mr Castleton set

this up but as far as I recall, he did not action any of these suggestions.

22. In addition, I contacted the investigations team and, from reading my
note, I can see that I spoke to Paul Whitaker. I explained to Paul what had
happened over the last few weeks and asked for his advice. I was informed
that, as Mr Castleton had kept me informed of the losses, the investigations
team would not get involved. I would also have discussed the losses with my
line manager at the time, David Mellows-Facer, but I do not recall the
conversation after such a long time. I also completed an audit request to
assist Mr Castleton in finding the losses and to verify the cash and stock on

hand at the branch.

23. Many of these actions were above and beyond my role but because of
my previous experience within the Post Office, I was familiar with how to
check cash and stock and where to look if you had a loss and I was trying to
use this experience to help Mr Castleton as much as possible. A lot of other

Retail Line Managers would not have had the same background and

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experience as me and therefore would not have known to take these actions.
The usual role of a Retail Line Manager when a SPM reported a loss was

limited to telling the SPM to ring the business support centre for advice.

24. I have been asked to consider the following documents:
POL00069272, POL00071243, LCAS0000710 and POL00082391_025. I can

confirm that I have reviewed these documents.

25. I have been asked to describe my understanding of the frequency of Mr
Castleton’s contact with the Horizon System Helpline (“HSH”), the National
Business Support Centre (“NBSC”) and others in Post Office Ltd about the
issues he was experiencing. I can see from these documents that Mr
Castleton was having frequent calls to the NBSC, Horizon helpline and other
departments, seeking help and support to find the losses. The documents
also show that I was having contact with Chesterfield (the transaction
processing centre for the Post Office) and indirectly with Fujitsu, who were
saying that there was not a problem with the Horizon software or hardware.
My involvement was limited to signposting Mr Castleton to the most
appropriate people who I thought would be able to support him and to pass on

any information that I had received.

26. The Inquiry have asked me whether I considered the issues that Mr
Castleton was reporting to be unusual and what I thought the cause might be.
I cannot remember my exact thoughts at the time, but this number of losses

and the amounts of money was unusual. It was normal for most branches to

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have small losses and gains each week and to even have a large loss or gain
from time to time when an error had occurred. These would usually show up
with a corresponding error notice several weeks later. Some errors, for
example where a staff member had given an incorrect amount of money to a
customer or miss-counted a deposit, may never come to light. These losses
are the responsibility of the SPM to make good. However, there were no other
offices that I dealt with which were experiencing this level of loss. Therefore
although the first loss did not seem unusual, it was completely unusual for Mr

Castleton to be experiencing such high losses week after week.

27. I did not know what the cause of the losses were and when I was trying
to assist Mr Castleton in finding the losses, I was just going on my experience
of what had happened in other branches over the years. There are a lot of
ways that a branch can make an error which would cause a loss or a gain and
it could have been caused by any number of different mistakes. I did not think
that the Horizon system could have been the cause of the issues and I had

never heard of this happening.

28. The Inquiry have asked me to explain my understanding of Mr
Castleton’s personal financial situation at the time and who was responsible
for considering any hardship form that he submitted. I cannot recall having a
conversation with Mr Castleton about his financial situation, although this
does not mean that I did not have one. I did ask if he was able to make the
losses good as was the procedure. When he said that he could not make the

losses good, we may have discussed his financial situation, but I cannot recall

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doing so. If a SPM said that they were unable to make the loss good, I would
signpost them to get a hardship form and make an application to pay the loss
in instalments. This was the usual process with any SPM who experienced a

loss.
Audit of 23 March 2003

29. I have been asked to consider the report of the audit of Marine Drive on
23 March 2023 at POL00082391_004. I can confirm that I have reviewed this
document. I can recall the day of the audit and being in Hull at another
branch, waiting for the call from the auditors at Marine Drive so that I would
know the outcome of their audit. I remember being contacted by the auditors, I
think in the afternoon, and making my way to Marine Drive to discuss their
findings. I cannot remember exactly what was said by them but we would
have discussed the findings of the audit. From reviewing the document, it
does not confirm the reason for the losses but finds that two of the losses

were put into the Suspense Account without authorisation.

30. In terms of what other enquiries were made to determine the cause of
the shortfalls, before the audit was undertaken, the Horizon helpdesk had
been contacted and asked for a system check and they had confirmed that
everything was fine. Giro bank and savings bank had also been contacted
and asked to check for errors and Chesterfield had been contacted and asked
about any pending errors. I had also contacted the investigation team, who
did not want to take on the case because there was no element of dishonesty

as Mr Castleton had openly declared the losses. I also understand that Mr

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Castleton had contacted the NBSC and sent off some of his cash accounts to

be looked at to see if they could spot any errors.

31. I was unable to contact Fujitsu directly myself but I asked for it to be
raised with them whether there were any issues with Horizon and the
message was passed back to me that nothing was wrong. I cannot recall who
it was that I raised it with or who passed back to me the message that nothing
was wrong. I can recall discussing the losses with my line manager, David
Mellows-Facer and felt that between us, we had exhausted all avenues of
where a usual loss or gain might occur and that no further enquiries were

necessary.

32. After the audit I visited Marine Drive and although I do not recall the
exact conversation, from reading my notes I can see that I spoke to Mr
Castleton and, as a precautionary measure, I suspended him. As Mr
Castleton had continually blamed the Horizon system for the losses, I asked
for his permission to put a temporary Postmaster in the branch to see how the
branch would balance. I wanted to make sure that the Horizon equipment was
kept exactly the same and only the people were replaced so that I could
check whether it was the Horizon equipment which was at fault. Therefore, Mr
Castleton and his staff were not allowed into the Post Office area during the

time the temporary SPMs were working there.

33. Mr Castleton did not provide any information as to how the losses had

occurred, except to say that it was a computer problem. I had made enquiries

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indirectly with Fujitsu, as well as with the Horizon helpline and it had been
confirmed that there were no issues and from my experience, I had never
heard of a computer changing amounts. All of the physical documentation
provided (for example, daily Giro bank deposits and withdrawals, pension
dockets and green giros) matched with the summaries produced to the weekly
balance and I could not see any evidence of a figure that had changed. Had
Mr Castleton shown me any evidence that a figure had changed from the daily
total to the weekly total, or that the summary of Giro bank work, Green Giros
or Pension Dockets was different on the balance compared to their individual

summaries, I would have taken this very seriously.

34. I have been asked to consider document POL00082391_002. I can
confirm that I have reviewed this document. I have been asked to describe
any involvement that I had in the decision to suspend Mr Castleton and what
alternative options were considered. I cannot remember doing so, but I am
confident that I would have discussed Mr Castleton’s suspension with the
Contracts Manager, Lesley Joyce and my Line Manager, David Mellows-
Facer. Following these discussions, I would have then sent the two letters

dated 23 March 2004 and 26 April 2004 (POL00082391_002).

35. As the amount of losses were increasing on a weekly basis, I would
have wanted to reduce the risk to Post Office funds of any more losses
occurring. Mr Castleton was upset and angry and I wanted to help and
support him as well. No errors had come to light to explain the losses but as

Mr Castleton was adamant that the losses were not down to anyone in the

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branch but to the computers, I thought that suspending him and putting in a
temporary SPM in the branch would provide a good opportunity to see how

the branch balanced with the same equipment but different people.

36. The only alternative to a temporary SPM was to either close the branch
or let Mr Castleton carry on. I did not want to close the branch and I did not
want to risk the losses increasing by letting Mr Castleton carry on without us
having found the source of the issue. My role was to reduce the risk to Post
Office funds and I was getting worried that the losses were ongoing week
after week and therefore I thought there was too much risk of losing even

more funds by letting Mr Castleton carry on.

37. I asked Mr Castleton for his permission to put a temporary Postmaster
into the branch and let him know my reasons for doing so and he agreed.
Reading my notes, this is when Mr Castleton said that he “couldn’t wait” until
the temporary Postmaster balanced thousands of pounds short. I therefore
think that in the circumstances he was pleased that we were able to get ina
temporary Postmaster to try and get to the root of the problem. Ultimately, the
decision to suspend Mr Castleton was mine, in conjunction with the Contracts
Manager and Line Manager. I would have discussed my proposal with my line

manager before implementing it.

Appointment of Temporary SPMs

38. I have been asked to describe any involvement that I had in the
appointment and management of temporary SPMs at Marine Drive following
Mr Castleton’s suspension. When a SPM is suspended, it isn’t easy to find

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someone to run a branch at short notice. Due to the problems Mr Castleton
had been having, I wanted an experienced individual who had a proven track
record of running a branch efficiently and with a good balancing record. It is
not common to appoint temporary SPMs and sometimes the Contract
Manager will offer names but at the time, I was managing approximately 85

branches and so I had all of those SPMs in my area to consider.

39. The first individual that I considered was a Postmaster in Bridlington
called David Earnshaw. However, he only had a small amount of staff and I
was also conscious that he was in the same town as Mr Castleton’s branch
and therefore I did not think that it was appropriate for him to get involved. I
therefore asked Ruth Simpson, who was an experienced Postmaster at First
Lane in Hull and she agreed to step in with a part-time member of staff to
support her. I would have discussed this appointment with the Contracts
Manager as well, as they would have to arrange remuneration payments to

her.

40. Myrecollection and understanding is I told Ms Simpson that she was
stepping in because Mr Castleton was experiencing unexplained losses. I
told her that that Mr Castleton thought that the Horizon system was to blame
for these losses. I therefore ensured that all of the same Horizon equipment
was used by Ms Simpson and no changes were made to it so that we could

have an accurate picture of how the branch balanced with a new SPM.

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41. I asked Ms Simpson to operate the Horizon system at Marine Drive in
the same way as she operated it at her own branch. She was responsible for
her own losses and gains while in the post. No independent analysis was
made of her accounting but an audit was conducted by Helen Rose before the
changeover from Mr Castleton to Ms Simpson to verify the cash and stock on
hand and to ensure that the cash and stock figures were accurate on the

transfer to the subsequent temps.

42. I cannot recall whether it was via a text message or phone call but I
remember asking Ms Simpson how her first day had gone and she let me
know that she was £2.14 short. I think that I was relieved that there had not

been a large loss.

43. Ms Simpson then reported a loss of £100 the following Monday.
However, she put this down to a part time member of staff who she had
brought with her making a common mistake which had also been made at Ms
Simpson’s branch at First Lane. I believe that the member of staff had left an
amount in the “stack” and paid this amount out again to the next customer.
From my notes (LCAS0000699), I can see that Ms Simpson was £19.38 over

and £10.76 short on the next two balances.

44. There isn’t a date for the call, but my notes tell me that I telephoned Mr
Castleton and from reading the notes, it looks like it was after Ms Simpson’s
first week, when she would have been £100 short, due to the staff error. Mr

Castleton had a few concerns, including queues out of the door and unhappy

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customers, as well as the £100 misbalance. He was also concerned that Ms

Simpson was not using both of the Horizon computers.

45. I spoke with Ms Simpson to address Mr Castleton’s concerns. She
confirmed that she was serving with two staff on Monday and therefore both
of the computers were being used. On the days when she was serving by
herself, she confirmed that she would log onto both computers with different
log-in details and perform different tasks on each. This was common and at
the time, individuals would often have two user IDs so that they could use
both computers at the same time according to service needs. I remember
stressing that the equipment and kit should not be changed at all. The only
difference was that Ms Simpson had a limited number of staff to run both her
own branch and Marine Driver and so unfortunately the staffing levels were
not as high as when Mr Castleton was running the branch. However, I
considered that it was better to have low staffing levels than to have to close

the branch.

46. Ms Simpson was only able to step in for a few weeks due to her own
commitments and therefore finished on 21 April. I told Mr Castleton that I
wanted more time and more balance results and with his agreement, Greg
Booth stepped in as the second temporary SPM from 21 April to takeover. Mr
Booth was the SPM at a small branch just outside of Scarborough. I cannot
recall the precise details but I think that his branch had closed, making him
available to step in as a temp. On Mr Booth’s first week, he reported a gain of

£14. I cannot recall the other amounts but I recall and also understand from

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my notes neither Ruth Simpson nor Greg Booth experienced any significant
gains or losses. The losses that were found were so small that they would not
have triggered an investigation and were within what a branch would normally

balance.

47. The Inquiry have also asked me about temporary SPM, Dorothy Day. I
cannot recall anything about her beyond recognising her name. I assume that
she was a temporary SMP at Marine Drive after Mr Booth but I am unable to
confirm. However, I can recall that no temporary SPMs experienced any

significant gains or losses.

48. The Inquiry have asked me about what investigations took place in
relation to the Suspense Account at Marine Drive Post Office. I have
refreshed my memory using my notes (LCAS0000699) which confirm that Mr
Castleton contacted me on 4 May 2004 to say that he had found £15,000 of
losses and that it was the suspense account that was doubling the figures. He
therefore asked for the Suspense Account software to be checked and so I
phoned the NBSC and requested that this was done. The request was
forwarded to Richard Benton in the Problem Management Department and he

sent the request on to Fujitsu.

49. Whilst we were waiting to hear back from Fujitsu, I thought that I would
ask the temporary SPM at the time, Mr Booth, to put a fictitious amount of
£100 into the Suspense Account to see how it affected the cash figure, and

then to balance. Once he had completed the balance, I asked him to remove

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the suspense account figure to see if it worked in the opposite way. The
notes I made at the time show that the Suspense Account worked in a way

that it should and was not doubling figures.

50. The Inquiry have asked whether the experience of the temporary SPMs
to Marine Drive influenced the Post Office's approach to action taken in
relation to Mr Castleton. I would say that it did because they did not have any
unexplained losses during their time at the Branch and this would have been
taken into consideration when the decision was made to terminate Mr

Castleton’s contract.
Dismissal

51. I have been asked to consider documents POL00082263 at pp.7-9 and
POL00082391_006. I can confirm that I have read both of these. The first
document (POL00082263), is a letter written from Mr Castleton to Mrs Joyce
and myself dated 28 April 2004 which requests 10 pieces of information. I
cannot recall what I sent Mr Castleton but based on the documents contained
in POL00082263, I sent all him all of the information that I was able to obtain

as follows:

a. Copy of — Suspension letter —- dated 23.03.04

b. Copy of — Reasons to urge letter — dated 26.04.04

c. Copy of e-mail from Fujitsu and logs of calls to Network Business
Support Centre and HSH

d. Copy of e-mail from Andrew Price

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e. Copy of Horizon System User Guide, Office Administration, System
failure Subsections 12 and 13

f. Copy of Audit report

52. With the benefit of hindsight, unfortunately I do not think that the
information that I provided addressed all of Mr Castleton’s concerns as his
primary concern was to obtain evidence that the Horizon system was causing
the losses which I was unable to give him. I tried to the best of my ability to
answer his questions and obtain the information that he asked for but I was
reliant on other people and could not physically get him all of the information

about Horizon.

53. On reflection, I do not think that we addressed all of Mr Castleton’s
concerns as we could not get hold of software checks and what updates had
been done to Horizon which he was asking for. This was not through want of
trying as I did ask for them but they were beyond my capacity to personally
obtain. I asked Richard Benton to ask Fujitsu to provide me with this
information and they just came back with a statement saying that everything

was okay and there were no problems which I passed on to Mr Castleton.

54. I have been asked to consider documents POL00082391_007 and
POL00082391_003. I can confirm that I have reviewed both of these
documents. The first document (POL00082391_ 007) is a letter from me to Mr
Castleton dated 14 May 2004. At the interview on 10" May, Mr Castleton

asked me to explain the discrepancies shown at the top of the snapshots

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which we were discussing. I told Mr Castleton in the interview that I would
provide an explanation of these discrepancies and so I asked Liz Morgan and
Davlyn Cumberland for an explanation and the letter dated 14 May 2004 is

that explanation.

55. The second document (POL00082391_003) is interview notes from the
interview with Mr Castleton on 10 May 2004. From this document, I can see
that Mr Castleton asked to see the cash accounts for weeks 1, 2, 3 and 4. I
can see that I provided these to him and also confirmed that he could have
copies. These would have been the cash accounts for while the temporary
SPMs were running the branch as, although the exact dates are not
mentioned, week 1 is the new financial year and so in late March or early April
which is when Ms Simpson started. Each cash account has the loss or gain
declared so Mr Castleton would have been able to see the discrepancies that
she and Mr Booth experienced. I can also recall that we discussed the losses
and gains that Ms Simpson and Mr Booth experienced at the time they were

running the branch.

56. At the end of the interview on 10 May 2004 the note says that I told Mr
Castleton that I was still waiting on a response from Horizon regarding the
checks on the software and, as soon as they were available, I would let him
know the outcome. From what I recall and as far as I can make out from my
notes at the time, I am referring here to the Horizon system checks that

Richard Benton was requesting from Fujitsu.

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57. I have been asked to consider POL00082391_ 002, POL00071234 and
POL00082391_009. I can confirm that I have reviewed these documents. I
have been asked to explain the decision-making process in relation to Mr
Castleton’s dismissal and the sources of information I considered in making
that decision. The normal procedure for dismissal would be for myself, as
Retail Line Manager to discuss the dismissal with the Contract Manager,
including discussing what happened at the interview and consider the reasons
put forward by the SPM as to why their contract should not be terminated.
This would have involved discussing the reasons that Mr Castleton put
forward for the losses, which were that there was a computer problem, but
discussing that this was not substantiated by any evidence besides his word. I
would have then discussed this, along with any investigations that we had
made, with my line manager and we would have decided to terminate his

contract.

58. The losses were very high by this point, over £25,000, and Mr
Castleton was unable to make them good or provide any explanation which
was supported by evidence as to why they were occurring. From what I recall,
this was my first termination of a contract for losses and so I would have taken

a lot of advice to make sure that I was doing everything correctly.

59. At paragraph 45 of my witness statement (_CAS0000609) I state “Mr
Castleton did not provide any evidence of a computer problem” and that...

“there was an actual loss, rather than a computer problem.” In terms of what

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evidence he could have provided, Mr Castleton was adamant that the
computer was changing his figures and therefore I wanted to see any
evidence that could prove this. For example, if he could show that his daily
Giro bank summaries did not reconcile with the weekly total, which would
have shown that the figure had been changed. Another example would be to
show where an item, such as a pension figure, had been entered into the
transaction logs which then didn’t follow through to the daily or weekly

accounting.

60. Mr Castleton was saying that the figures changed when he remmed in
stock. I therefore asked him to wait until the end of the day, declare the cash,
produce a snapshot and then rem in the stock and re-declare the snapshot.
By doing this, we would be able to see if the figures were correct or if they had
been changed. However, Mr Castleton said that he did not have the time to do
this. I was getting anxious as he said that he was looking through the
balances all night but he was not actioning any of my suggestions or providing
any evidence that he had attempted to do them. These were all normal things
that I asked other people to do and the fact that he was not doing them put

doubt in my mind as to whether we would find a reason for the losses.

61. I have been asked to consider POL00069523 and POL00071200. I can
confirm that I have reviewed these documents. I have been asked to describe
any involved I had in Mr Castleton’s appeal against his dismissal. From

reading these documents I can see that I was asked a number of questions by

John Jones who was to hear Mr Castleton’s appeal. Document POL00071200

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shows Mr Jones asking me three questions to which I responded but I cannot
recall anything beyond what is provided in these documents. I can recall that I
spoke to John on the phone about Mr Castleton’s appeal but I cannot

remember precisely what we spoke about.

62. The Inquiry have flagged page 6 of document POL00070516 where Mr
Castleton says that he received no support from me from the start of his
issues. I am really sorry that he feels this way as I tried my best to support Mr
Castleton both personally and through signposting him to be able to get the
help that he needed. It was not part of the role of Retail Line Manager to
check cash or stock or even get involved with misbalances, their role is limited
to supporting the SPM by directing them to the NBSC for help and assistance.
However, as I did have knowledge of running Directly Managed Branches and
balancing stock units, I was able to offer more practical help, such as give
suggestions to Mr Castleton as to ways he in which he could narrow down
who was making the losses, through individual balancing and daily snapshots.
As he did not implement anything I suggested it was a really difficult situation
and it was quite unnerving for me to have so many losses in a branch I was

responsible for with no explanation.

63. I wasn’t able to investigate the Hardware or Software myself so I
contacted all the available help that I could get to gain the information that Mr
Castleton was requesting. This included asking Richard Benton, Paul

Whitaker, Lesley Joyce, the audit team, my line manager David Mellows-

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Facer, Davlyn Cumberland, Liz Morgan and the Chesterfield error notice
department.
64. I also brought in temporary SPMs to see if they could find the source of

the problem and whether the losses continued or stopped when new people
were brought in using the same equipment. When Mr Castleton said that it
was the suspense account which was changing the figures, I asked Mr Booth
to run checks so that I could verify whether this was correct. I thought that I
had exhausted all avenues to help Mr Castleton and I tried to work with him
and offer advice. I feel really sorry that he did not feel like I supported him as I

felt like I was doing as much as I could.

65. _I was asking and being reassured that there was nothing wrong with
Horizon and so I was coming from that standpoint, whereas he was saying
that there was something wrong with the computer but providing me with no
evidence to support that statement or actioning any of my suggestions with

how he could go about providing evidence.

66. _I can’t recall what involvement I had with Mr Castleton’s case after he
was dismissed but before proceedings were commenced against him by the
Post Office. I also think that at that point, I had moved roles and therefore

would not have had any involvement.

67. Throughout the situation I was concerned about the wellbeing of Mr

Castleton and Chrissie as I could see how angry and upset they both were

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which is why I tried to do everything I could. I know that now there is a
process where an individual is concerned about the wellbeing of a SPM, for
example being able to direct them to counselling services, but I do not think

that this was available at the time.

Post Office Ltd v Lee Castleton

68. Besides this case, I have not been involved in any proceedings against

SPMs involving the Horizon IT system.

69. I provided a witness statement for this case (POL00070760) but I

cannot recall who asked me to provide it.

70. Atthe time, my understanding of the case against Mr Castleton was
that the Post Office were trying to get the unexplained losses recovered from

him.

71. The Inquiry have asked me about document LCAS0000699. I have
explained this document at paragraph 14 above. I can confirm that I wrote the
document to capture the timeline of events and to keep a record of the losses

at the branch and what support had been given.

72. I have been asked to consider documents POL00069524,
POL00070727 and POL00071011. I can confirm that I have reviewed these
documents. I have been asked to set out the individuals that I had contact
with during the drafting of my witness statement and the nature of any
discussions I had with them. Looking at these documents, I dealt with

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Stephen Dilley (Solicitor at Bond Pearce LLP) who supported me in the
drafting of my witness statement. I could not recall him before this document
prompted me but I recall going down to London and discussing the case with

him and Counsel.

73. I have been asked to consider POL00069608. I can see from this
email that I had a meeting with Counsel to discuss my witness statement. This
was the trip to London referred to at paragraph 72 above. I can remember
going through questions but I cannot recall whether this was before or after I
signed by witness statement. My understanding of my role was that I was a
witness in the case that the Post Office was bringing against Mr Castleton and
therefore I needed to provide facts and explain from my point of view what

had happened.

74. I have been asked to consider POL00070841 and POL00070477. I
cannot recall if I was made aware of Mr Castleton’s defence and counterclaim
at the time and cannot remember any discussions about it. My role was

limited to being a witness and therefore I cannot recall what my view of it was.

75. I have been asked to consider document LCAS0000945. This contains
correspondence between Mr Castleton’s and The Post Office’s solicitors,
enclosing the expert opinion of Mr Hine of Bentley Jennison as to whether the
alleged shortfalls were, at least in part, attributable to problems with the
Horizon system. I may or may not have seen this before but I cannot recall

having done so. I have been asked for my opinion of the views expressed in

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the report and, although I am unable to comment on the technical aspects of
it, I understand that the report concluded that Mr Castleton would benefit from
receiving daily balance snapshots which were not yet disclosed. I do not know
what these snapshots are that he is referring to. As far as I recall, all
snapshots taken were discussed with Mr Castleton at the meeting on 10 May
2004 and he received copies of them. It should be noted that snapshots may
not be available for every day unless they are taken at that time. You cannot
take a snapshot of a day or time retrospectively and so there may be gaps in
the snapshots. For example, there may be several for one day and none for
the next week. All of the snapshots which I held, I had given to the Post Office

for Mr Castleton’s appeal against his dismissal.

76. I have been asked to consider document POL00069955. The is a draft
report dated 29 November 2006, written by expert Geoffrey Porter of Stoy
Hayward LLP who I understand was instructed by the Post Office to
investigate Mr Castleton’s losses. Again, I cannot recall whether or not I have

seen this document before.

77. I have been asked for my opinion of the views expressed in the report.
I found it difficult to follow as I am not technically minded but from my
understanding, the report seems to conclude that there is no indication of
computer problems which would cause the large amounts of losses that Mr
Castleton experienced but that these were most likely caused by human error,

such as cash not being input correctly.

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78. I have been asked to consider documents POL00071137 and
POL00071145. I can confirm that I have reviewed these documents. I have
been asked to explain any involvement I had in the disclosure process during
the proceedings. I cannot recall specifically being involved in the disclosure
process but before the case went to Court, I handed all of the documents that
I held to John Jones at the Post Office who was reviewing Mr Castleton’s

internal appeal against his termination.

79. I have been asked to consider documents POL00070518,
LCAS0000441, POL00070520, POL00107420, POL00070746 and
POL00071158. I can confirm that I have reviewed these. I have been asked to
confirm what documents I removed from Marine Drive when Mr Castleton was

suspended.

80. Document POL00070520 refers to a request for documents that were
removed from Marine Drive when I attended, after the audit. From reviewing
document POL00071158, I can see that I stated “all the cash accounts and
any snapshots that I removed from Marine Drive were kept together in the
folder that I believe you have, I did not make a list of the snapshots that I took,
so cannot say for sure which are there now, but I have not done anything else
with the documents. I have nothing more.” I removed them to ensure that they
were kept safe and not destroyed as some had handwritten notes on them by
either Mr Castleton or his staff. These notes were regarding the cash
declarations and looked to show that they were maybe not recording their

cash accurately. It looked as though the branch had a gain on one of the

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weeks up until the balance day and then the gain disappeared and so I
wanted to preserve this and ask Mr Castleton about it at interview. I can see
from the interview notes of 10" May (POL00082391_003) that we discussed
balances, error notices, losses etc. with Mr Castleton and provided him with
snapshots and declared cash. I understand that the evidence provided
included the documents which I removed and I can see from the interview

notes that copies of these were given to Mr Castleton.

81. All of the documents that were removed were kept safely in a file until
after Mr Castleton had had his contract for services terminated. When Mr
Castleton appealed against that decision, all of the documents were passed to

the appeal manager.

82. I have been asked to consider the transcript of my evidence given at
the trial in the Castleton case at page 39 of document POL00070183. I can
confirm that I have reviewed this document. In this transcript I make the
statement “/ don’t know the working of the Horizon system”. I have re-read the
transcript and understand that I was referring to the balancing procedure and
sequence of events when balancing at a branch. I had not performed this
myself for several years at this point and so I was not familiar with the
systems. I was also not familiar with the figures at the top of the snapshots
and final balances, which is why I asked others to explain them before

providing an explanation to Mr Castleton (POL00082391_007).

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83. I had never been to a court case before and so this was my first
experience of being a witness. From my point of view, the Post Office were
following their due process and wanted to recover their losses. My role was
limited to that of a witness and as a witness, I was not able to watch most of

the proceedings. Mr Castleton cross-examined me himself.

84. With hindsight, I still do not feel able to comment as to whether
anything should have been done differently in relation to how the proceedings
were conducted as this was the only time that I have ever been involved in a
court case and I do not know how proceedings are meant to be conducted. I
do, however, extend my deepest sympathies to all SPMs who were affected
by Horizon. I had no idea at the time that there was anything wrong with it and

was not aware that any other SPMs were having problems with balancing.

Subsequent Events

85. I have been asked to consider POL00082391_ 051. I can confirm that I
have reviewed this. I have been asked to describe my involvement in the
advertisement for sale of Marine Drive Post Office. I was not involved in the
actual advertisement, it would have just been my job to send out the chaser
letter to the SPM to sell the business. This document is a templated letter and
I cannot recall sending it. I would have just been following the process. If a
SPM has had his contract terminated then there is only a limited amount of
time that a temporary SPM can step in and so there is a need to sell it ina
reasonable amount of time. I should note that the SPM does not have to sell

his business, he can choose to sell the whole business or keep the retail

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business and the Post Office will look for other premises and a different

operator to run the Post Office.

86. Beyond this letter, I cannot recall any discussion with Mr Castleton
about selling the Post Office or anything about the sale of the branch at all
and so I do not feel that I am able to comment the circumstances around the

sale of the branch or the property.

87. I have been asked to consider document POL00069976 and asked
about what my reaction was when I was informed of the outcome of the case.
I have reviewed this document and do not think that it is relevant to the
question. In terms of my reaction as to when I was informed of the outcome of
the case, I think that I was probably pleased as I had spent over 3 hours
giving evidence and I was relieved that the judge had found me a credible
witness. I also found it reassuring as, at the time, it confirmed that my
decisions were correct and I had not made a mistake and that the Court had
come to the same conclusions as I did when presented with the same

evidence.

Other civil and criminal cases

88. I have been asked about what (if any) recollections I have of the

following criminal cases:

a. Nichola Arch
b. Susan Hazzleton
c. Lisa Brennan

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d. David Yates

e. Carl Page

f. David Blakey

g. Tahir Mahmood
h. Oyeteju Adedayo
i. Hughie Thomas
j. Suzanne Palmer
k. Janet Skinner

I. Jo Hamilton

m. Pauline Stonehouse
n. Susan Rudkin

o. Julian Wilson

p. Peter Holmes

q. Seema Misra

r. Allison Henderson
s. Alison Hall

t. Lynette Hutchings
u. Grant Allen

v. Khayyam Ishaq

w. Angela Sefton and Ann Neild

89. I donot have any recollection of any of these cases although I
recognise the name ‘K. Janet Skinner’. She was a lady who used to work in a
branch in Hull when I was Area Manager there but her case was not ongoing

when I was there and I had nothing to do with her criminal proceedings.

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90. I can confirm that I was not involved in any prosecutions / criminal

cases.

91. I have been asked what (if any) recollections I have of the following

civil cases:

a. Aslam Ramtoola

b. I Anonymity Order ;
c. Kevin Palmer

d. Rachel Williams

e. Frank Holt

f. Susan McKnight

g. Tracey Etheridge
h. Katherine Mc Alerny
i. Keith Macaldowie

j. Julie Wolstenhome

92. I donot recognise any of these names and have no recollection of any

of the civil cases.

93. I can confirm that I was not involved in any civil actions besides Mr

Castleton’s case.

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Knowledge of bugs, errors and defects in the Horizon system

94. I did not have, and was not aware of, any concerns regarding the
robustness of the Horizon IT system during my time working for the Post
Office. I was reassured that it was robust and properly working and the only
individual I came across who suggested that it was not robust was Mr
Castleton but he was unable to provide me with any evidence to substantiate

this claim.

Other matters

95. ‘There are no other matters that I wish to bring to the attention of the Chair of

the Inquiry but I would like to reiterate my sympathies to Mr Castleton and his family.

Statement of Truth

I believe the content of this statement to be true

Page 36 of 40
Index to First Witness Statement of Cath Oglesby

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No

URN

Document Description

Control Number

POL00069622

Stephen Dilley Personal
attendance note re Lee Castleton
case, 11.09.06. Attending: Richard
Morgan and Tom Beezer re
meeting four key witnesses (Cath
Ogelsby, John Jones, Andrew
Wise and Mandy Talbot)

POL-0066185

POLO0107117

Witness statement of Catherine
Oglesby re: Post Office Ltd v Lee
Castleton signed 19.10.2006

POL-0105425

POL00083604

Exhibits of witness statement of
Catherine Oglesby in Office
Limited v Lee Castleton

POL-0080167

LCAS0000699

Catherine Oglesby's Summary of
events (01.01.2006)

VIS00010939

POL00069272

LC Calls from 28/01/04 to
26/04/04 (27.04.2004)

POL-0065835

POL00071243

Email chain from Richard to Cath
Oglesby re: Horizon system
(Marine Drive branch)
(31.10.2005)

POL-0067806

LCAS0000710

Marine Drive branch - various
records of Giro Deposits
withdrawals, miscellaneous
transaction and sales report
between 19/02/2004 - 25/02/2004
(25.04.2004)

VIS00010950

POL00082391_025

Un-dated copy of email from
Andrew Price to Cath Oglesby re
errors at Marine Drive
(01.04.2004)

POL-0078954_193

POL00082391_004

Marine Drive - audit report
(25.03.2004)

POL-0078954_172

10.

POL00082391_002

1. 23.03.04 Letter from Lesley
Joyce to Lee Castleton -
suspension. 2. 26.04.04 Letter
from Cath Oglesby to Lee
Castleton - considering
termination (23.03.2004)

POL-0078954_170

POL00082263

Exhibit to first witness statement
of Catherine Oglesby - Post Office
Limited v Lee Castleton
(21.01.2006)

POL-0078826

12.

POL00082391_006

Letter from Cath Oglesby to Lee

POL-0078954_174

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Castleton re suspension
documents (06.05.2004)

13.

POL00082391_007

Letter from Cath Oglesby to Lee
Castleton re final balance entries
(14.05.2004)

POL-0078954_175

POL00082391_003

Note of interview of Lee Castleton
by Cath Oglesby & Lesley Joyce,
Christine Train also present
(10.05.2004)

POL-0078954_171

15.

POL00071234

Agent Case Summary: Appeal
against summary termination of
contract, Mr Lee Castleton
(07.06.2004)

POL-0067797

16.

POL00082391_009

Letter from Cath Oglesby to Lee
Castleton re summary termination
of contract (17.05.2004)

POL-0078954_177

17.

LCAS0000609

First Witness Statement of
Catherine Oglesby (21.01.2006)

VIS00010849

POL00069523

Email from Cath Oglesby to
Stephen Dilley re Marine Drive
Appeal (01.10.2006)

POL-0066086

19.

POL00071200

Email chain between John J Jones
and Cath Oglesby Re: Marine
Drive Appeal (25.06.2004)

POL-0067763

20.

POL00070516

POL Note - Appeal against
Summary Termination of Contract
- Lee Castleton (01.07.2004)

POL-0067079

21.

POL00070760

Draft witness statement of
Catherine Oglesby in POL v Lee
Castleton Claim No: HQ05X02706
(06.12.2005)

POL-0067323

22.

POL00069524

Email from Cath Oglesby to
Stephen Dilley re Re-revised
second statement (01.10.2006)

POL-0066087

23.

POL00070727

Email from Stephen Dilley to
Mandy Talbot & others re Post
Office v Lee Castleton - re
changes to Cath Oglesby
statement (07.12.2005)

POL-0067290

24.

POL00071011

Email from Julian Summerhayes to
Mandy Talbot re: Post Office v
Castleton (21.12.2005)

POL-0067574

25.

POL00069608

Castleton: E-mail trail between
Oglesby and Dilley concerning
witness timetable (07.09.2006)

POL-0066171

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26.

POL00070841

Email from Stephen Dilley to
Mandy Talbot, Tony Utting, John
Jones, RE: Post Office Ltd v Mr L
Castleton (13.04.2006)

POL-0067404

27.

POL00070477

Email from Julian Summerhayes to
Stephen Dilley regarding the Post
office v Lee Castleton (Marine
Drive Post Office, Bridlington)
(24.11.2005)

POL-0067040

28.

LCAS0000945

Letter from Rowe Cohen to Bond
Pearce enclosing the report from
their expert accounting witness on
a without prejudice basis (includes
enclosures) (30.09.2005)

VIS00011185

29.

POLO00069955

Draft Expert Report by Geoffrey W
Porter from BDO Stoy Hayward
LLP in the case of Post Office v
Lee Castleton (29.11.2006)

POL-0066518

30.

POL0007 1137

Email from Stephen Dilley to
Mandy Talbot re: Post Office -v-
Castleton: Disclosure (27.06.2006)

POL-0067700

31.

POL00071145

Email from Stephen Dilley to
Mandy Talbot re: Post Office -v-
Castleton: Disclosure (21.06.2006)

POL-0067708

32.

POL00070518

Fax Cover Letter from Mark Turner
to Stephen Dilley - Bond Pearce
re: The Post Office/Lee Castleton
(17.11.2005)

POL-0067081

33.

LCAS0000441

Letter Bond Pearce to Rowe
Cohen in preparation for civil
proceedings. (21.04.2005)

VIS00010681

34.

POL00070520

Email from Stephen Dilley to Cath
Oglesby re Castleton (17.11.2005)

POL-0067083

35.

POL00107420

Letter from Rowe Cohen to Cheryl
Woodward, Re: Lee Castleton
(10.05.2005)

POL-0105728

36.

POL00070746

Email from Vicky Harrison to
Stephen Dilley re the Post Office v
Lee Castleton, Marine Drive Post
Office, Bridlington (07.12.2005)

POL-0067309

37.

POL00071158

Email from Cath Oglesby to
Stephen Dilley re: Post Office Ltd
v Mr L Castleton (11.06.2006)

POL-0067721

38.

POL00070183

Official Transcript of Evidence of
Helen Rose and others in The
Post Office v Lee Castleton
(11.12.2006)

POL-0066746

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39. I POL00082391_051 I Letter from Cath Oglesby to Lee POL-0078954_219
Castleton re sale of Marine Drive
(21.02.2005)

40. I POLO0069976 Castleton: Email trail between POL-0066539

Stephen Dilley and others
concerning witness requirements
and updates (28.11.2006)

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