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Witness Name: Deborah Stapel
Statement No.: WITN08900100
Dated: 15'" October 2023
POST OFFICE HORIZON IT INQUIRY
FIRST WITNESS STATEMENT OF DEBORAH STAPEL
I, DEBORAH STAPEL, will say as follows
INTRODUCTION
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 the 8"
September 2023 (the “Request’).
BACKGROUND
1. I was called to the Bar in 1987. I worked for a short time as a legal assistant
at Hallett & Co prior to joining the Criminal Law Team in 1989.
2. I My main role as a senior lawyer in the Criminal Law team was to advise on
case papers submitted by the Security Team and where prosecution was
advised to conduct the case through to its conclusion. I would also deal with
any other matter allocated to me by the Head of the Criminal Law Team. In
November 1997 ! had a years matemity leave followed by a three year
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career break. I returned to work in the autumn of 2001. From that date to
2006 I advised on both ‘letter’ and “counter” cases. “Letter” cases related to
postmen and postal packets and “counter” cases to Crown Office employees
and SPMs and their assistants. From 2006, with the exception of the case of
Carl Page, I ceased dealing with “counter” cases and was responsible for all
“letter” cases in the geographical area covered by our Agents.
3. left Royal Mail in March 2013.
Policies / practices in place and the Criminal Law Team’s role relating to
relevant prosecutions
4. The Criminal Law Teams role relating to the prosecution of SPMs,
managers, assistants and Crown Office employees alleged to be responsible
for shortfalls shown by data from the Horizon IT System was to review,
advise on and to prosecute cases, where appropriate, based on the evidence
submitted by the investigation manager. All lawyers had a copy of the Code
for Crown Prosecutors. Prior to any decision being made lawyers would need
to be satisfied that they had all the information necessary to make a decision
and that the evidence was admissible, reliable and credible and where
appropriate case files would be returned for further information to be
obtained. Where it was considered that there was sufficient evidence to
afford a realistic prospect of conviction based upon the evidence and any
defence that had been put forward, lawyers would consider the public
interest test namely whether there were public interest factors tending
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against prosecution which outweighed those tending in favour. One of the
factors tending in favour of prosecution was the fact that suspects were
usually in a position of trust. Any advice on prosecution would be sent to the
Casework Manager who in turn would forward it to the decision maker within
POL to authorise the prosecution.
The rationale behind the practice of bringing private prosecutions
5. The rationale behind RMG and POL’s practice of bringing private
prosecutions against its agents/staff where they were suspected of financial
crime is historic. It had been doing so for centuries. In the present day, POL
investigators were familiar with most of the accounting systems in place and
the procedures that had to be followed on a daily and weekly basis. They
also knew where to source documentation from. On occasions the police
would contact POL after arresting a suspect with a request that POL assisted
at interview and took over the investigation. The CPS made similar requests.
6. POL did not cease the practice of bringing private prosecutions before I left.
Policies governing prosecution and charging decisions and the conduct of
prosecutions
7. I have been asked to consider documents POL00030659, POL00031012,
POL00039945, POL00039951, POL00039952, POL00030578,
POL00104812, POL00031011, POLONN3N5R0, POL00030579,
POL00026573, POLO0031008, POL00030598, POL00104853,
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POL00104855, POL00030685, POL00030800, POL00031034,
POL00104929 and POL00105226.
I can say that POL00039945, POL00039951 and POL00039952 were
policies that I reviewed. I would have been aware of the contents of the Post
Office internal Prosecution Policy (dishonesty) (December 1997)
(POL00030659) and paragraph 3.3 of the Investigation and Prosecution
Policy (March 2000) (POL00031012). The remaining documents came into
being after I stopped working on “counter” cases. The author of the Post
Office Internal Prosecution Policy (dishonesty) (December 1997)
(POL00030659) document was Andrew Wilson and I am not sure to whom
this document was circulated. In it, Andrew Wilson sets out the Post Office’s
Prosecution policy, namely that acts of dishonesty in relation to the illegally
acquiring of Post Office property or assets, or the property or assets of Post
Office customers and clients while in Post Office custody would normally be
prosecuted where this is deemed to serve the public interest. He
recommended that a single point within the Personnel Department of each
Business Unit should be the prosecution decision maker. In relation to
Paragraph 3.3 of the Investigation and Prosecution Policy document
(POL00031012). I would say that the reference to “in accordance with the
criminal law” would inciude The Code for Crown Prosecutors. The Code for
Crown Prosecutors was the key document followed when prosecution
decisions were made. The other documents were published after I stopped
doing “counters” cases.
In relation to POL00039945, POL00039951 and POL00039952 I would have
been provided with a draft policy document and asked to make any
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10.
11.
amendments necessary. I cannot now recall whether any such amendments
were necessary. These documents would have been reviewed annually,
usually by the Head of Criminal Law.
In my time working for POL, ! believe that in the main only theft or false
accounting charges were considered. The Fraud Act came in shortly before I
stopped doing “counters cases”. The appropriate charge(s) would reflect the
seriousness and extent of the offending as supported by the evidence. Rob
Wilson reinforced the fact on numerous occasions that it was inappropriate to
draft the charges in the alternative. I believe there was case law regarding
this. The Code for Crown Prosecutors also indicated that prosecutors should
not proceed with a more serious charge to encourage a Defendant to plead
guilty to a less serious one. !n relation to false accounting, I believe that there
was a policy that prosecution would not be considered when the sum
involved was less than £5000. This was on the basis that it was not in the
public interest for such cases to be prosecuted. I believe this conclusion was
reached following the courts imposing nominal penalties in such cases.
The Criminal Law Team was Ied by the Head of Criminal Law who would
allocate cases and any other work to the individual lawyers in the
department. Lawyers would hold the position of lawyer, senior lawyer or
principal lawyer. There were also two legal executives who would deal with
Crown Court work and two secretaries. Up until 2006 all lawyers would
undertake both “letters” and “counters” cases. In 2006 my role changed, and
I was responsible for dealing with all “letters” cases in the Agents area. The
remainder of the team advised on “counters” cases and “letters” cases in the
office area. I retained conduct of the case of Carl Page.
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12.
13.
14.
15.
16.
17.
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In general terms the Criminal Law Team would advise on evidence and
where appropriate draft charges. The decision to prosecute would be made
by a designated decision maker. The person making that decision changed
over the years. In the event that prosecution was authorised, summonses
would be issued and either Agents or Counsel would be instructed to appear
at the Magistrates court on behalf of POL. In an Agents area case, following
committal proceedings the case was handed over to our Agents who would
have conduct of the case. In office area cases Counsel! would be instructed
to draft the Indictment and advise on evidence. Conferences would be
routinely held with Counsel to discuss both evidential and disclosure matters.
Rob Wilson was responsible for supervising or reviewing the conduct of
Private prosecutions. Prior to Mr Wilson becoming Head of Criminal Law, Mr
Heath would have had that responsibility.
Mr Wilson would not have received any training but was an experienced
prosecuting solicitor who had worked for POL for many years. The same
applied to Mr Heath.
Mr Wilson would expect any issues on cases to be raised with him. He would
also see the post each morning and raise any concerns in correspondence
with the lawyer. He would also periodically check files.
There was no independent oversight exercised in relation to the conduct of
prosecutions.
! am not aware that Post Office policy regarding prosecution of Crown Office
employees differed from the policy and practice regarding prosecution of
SPMs and their managers/assistants. This did not change whilst I
conducted “counters” cases.
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Involvement of the Criminal Law Team in advising on investigations
18.
19.
I have considered The Casework Management document at POLOQ104747
and POLO0104777, POLO0118096, POLO0118108, POLO0118109,
POLO0118101, POLOO118102, POLOO118103, POLOO118104, POLO01181 05,
POLO0118106 and POLOO118107.
! can say that I was not working for POL in 2000 and therefore do not
believe that I have previously had sight of the Casework Management
document at POLO0104747. The 2002 version at POLO0104777 is not a
document that ! recognise as having previously seen and I did not
have any input into the document.
As stated I do not believe that I have previously had sight of either
POL00104747 or POLO0104777. Whilst working for POL I was unaware
that there were bugs, errors or defects in Horizon.
I was not working for POL in May 2011 and do not believe that I had
sight of the documents attached to Dave Posnett’s email.
I was not involved in the development, management or amendment
of the documents.
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20.
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V. I was not familiar with these documents.
Vi. Iwas not involved in the drafting of the document entitled
“Identification Codes" at POLO011804 nor have I seen that document
before. I was aware that Identification Codes were used by the
Security Team. in the preamble to the investigator's report there was a
heading, “Identification Code’.
Vil. I was not aware of the “Identification Codes” document.
Vill. My understanding was that in the event of a conviction certain
information was required by the police including the ethnicity of the
person convicted.
The Criminal Law Team did have input into the formulation of RMG/POL
policies and guidance in relation to the applicable statutory provisions, codes
of practice issued under statute, guidelines and guidance. This was normally
undertaken by the Head of Criminal Law. The Security Team had a database
that contained all their policies and I believe any new policy was either
circulated to the investigators or they were advised that it had been added to
the database. Policies on procedure e.g the conduct of tape recorded
interviews, the completion of notebook entries etc were reviewed ona
regular basis and the reviewing lawyers name would be on the document.
From the documents I have had sight of I reviewed POL00039945,
POL00039951 and POL00039952. ! may have reviewed other policy
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documents of a similar nature but after the time that has elapsed I cannot
give specifics.
21. I recall that as part of their training members of the Security Team took part
in a mock trial. The case papers would contain numerous errors to highlight
the importance of following the correct procedures. Junior counsel would be
instructed to act as prosecuting and defence counsel and a member of the
Criminal Law Team would play the part of the judge. Lawyers were also
expected to highlight any problems in case papers and further training would
be given by the Security Team to the investigators involved where this was
deemed necessary.
22. When case files were submitted prosecution decisions were made if the
lawyer considered the evidence contained therein was sufficient for such a
decision to be made. Where further enquiries were needed to enable that
decision to be made or for the public interest test to be properly assessed the
papers would be returned with a request for further evidence to be obtained
or lines of enquiry to be made.
Process for prosecution and charging decisions
23. Where the evidence was sufficient to afford a realistic prospect of success
and it was in the public interest for a prosecution to ensue the lawyer would
advise appropriate charges. The file would then be returned to the casework
manager who would in turn forward it to the relevant person for authorisation.
' can see from POL00030659 that in 1997 the recommendation was that a
single point within the Personnel Department of each business unit would
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24,
25.
26.
27.
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make that decision. From POL00031012 it would appear that in 2000 the
relevant person for authorising the prosecution was SIS. After the passage of
time I can no longer recall who that person was. The person authorising the
prosecution would be addressing the public interest test and would have had
a copy of the Code for Crown Prosecutors. I was not working for POL on the
dates that the remaining documents were published and can therefore not
assist with the contents of those documents.
Prosecution and charging decisions in respect of SPMs, managers,
assistants and Crown Office employees alleged to be responsible for
shortfalis shown by data from the Horizon IT system were made by the
lawyer who had conduct of the case. This did not change during the period
that I was employed within the Criminal Law Team.
Charging decisions were taken at the same time as prosecution decisions.
This did not change during the period that I was employed within the Criminal
Law Team.
The legal advice would be given by lawyers in the Criminal Law Team and
during the period I worked on POL cases I am unaware that this changed. A
very small percentage of cases were sent to Counsel to advise on the
Sufficiency of the evidence and whether it was in the public interest to
prosecute. These tended to be complex cases where it was considered that it
would be helpful to have Counsel's input from the beginning. I can not recall
this changing whilst I did POL cases.
All lawyers were either barristers or solicitors. In addition to their legal
training each lawyer, on joining the Criminal Law Team, would be supervised
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by other lawyers in the team for a period of up to two years fo ensure that
cases were properly advised on and that a consistent approach was taken.
Those involved in investigating a suspected offence would outline in the
offender report the charges that they believed were supported by the
evidence and any undermining material that existed. They would also
highlight any matters that might impact on the public interest test, for
example the ill health of the suspect. They did not have input into whether
the test for prosecution was met.
The test applied
29.
Prosecution decisions were made in accordance with the Code for Crown
Prosecutors namely whether the evidence was sufficient to afford a realistic
prospect of conviction of a suspect on a criminal charge. In reaching a
conclusion an assessment of the evidence would need to be made namely
whether the evidence submitted was reliable, credible and admissible. Any
evidence that undermined the prosecution case or assisted the Defence case
would also need to be considered. In the event that this test was made out a
decision would have to be made as to whether it was in the public interest for
@ prosecution to ensue. In the event that there were public interest factors
tending against prosecution which outweighed those in favour a decision
would be made that it was not in the public interest for a prosecution to be
brought. From memory cases where a decision was made that it was not in
the public interest to prosecute usually invoived the health of the suspect. I
recall that it was agreed that it was not in the public interest for cases of false
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30.
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accounting involving a shortfall of less than £5000 to be prosecuted. Of the
policy documents I have been asked to consider only POL00030659 had
been published whilst ! worked on “counters” cases. The author of this
document was Andrew Wilson and I am not sure to whom it was circulated.
From the content I would be surprised if it had been approved by a lawyer.
The document is titled “POST OFFICE INTERNAL PROSECUTION POLICY
(DISHONESTY)’ and I have been asked to consider paragraph 5. It appears
to be directed to the “letters” side of the business and despite its title,
reference is made to offences of wilful delay of mail, opening mail and
criminal damage, offences that do not involve dishonesty. It contains huge
generalisations. Paragraph 5 states that, “in order to provide a deterrent and
to serve the public interest it is clearly necessary to prosecute offenders in
the criminal category”. No reference is made to the public interest factors set
out in the Code for Crown Prosecutors. The conclusion that offenders in the
“itresponsibie” and “irrational” categories would not be prosecuted did not
reflect the position regarding the types of offences that were prosecuted on
the “letters” side of the business. This is not a document that lawyers took
into consideration in deciding whether a prosecution should take place.
POL00030578, POL0031011, POL00030580, POL00030598, POL00030685,
POL00030800 and POL00031034 were all published after I ceased doing
“counters” cases.
I do not consider that the guidance contained within the policy documents on
the test to be applied when making prosecution and charging decisions was
adequate. As stated at paragraph 29 ! do not consider that was the purpose
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31,
32.
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of POL00030659. The guidance in the Code for Crown Prosecutors was
followed at all times.
Whilst I was employed at POL advice was only sought from Counsel before a
decision to prosecute was made in complex cases. I cannot recall the
position changing during the period I advised on POL cases.
As a matter of policy it was the Criminal Law Team’s role to provide advice
on the public interest stage of the prosecution test. In considering this stage
of the prosecution test, the papers would on occasion be returned to the
investigator for further enquiries to be made. The prosecution decision maker
would have had a copy of the Code for Crown Prosecutors. The prosecution
decision maker was expected to consider the public interest test and would
have received training on how to do so. I was not involved in providing that
training nor did I participate in it. On rare occasions the prosecution decision
maker would return the papers to casework flagging up a public interest
factor that the Criminal Law team had been unaware of.
The conduct of prosecutions
33.
The following legisiation, codes and principles governed the conduct of POL
prosecutions:- the Code for Crown Prosecutors issued under section 10 of
the Prosecution of Offences Act 1985 gave guidance on the general
principles to be applied when making decisions about prosecutions, the
relevant statutes and case law set out the actus reus and mens rea of a
particular offence and how to prove it, the Police and Criminal Evidence Act
1984 dealt with police powers of investigation, the Criminal Procedure and
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Investigations Act 1996 set standards to regulate the investigation process
and the recording and retention of material found or generated during the
course of an investigation together with Codes of Practice. POLO0030659
sets out the fact that the usual course was to prosecute all breaches of the
criminal law by employees which affect the Post Office and which involve
dishonesty. POL00031012 refers to the fact that the prosecution guidelines
of the business will be used in making any decision to proceed under criminal
law. Where prosecution was advised this was in accordance with the Code
for Crown Prosecutors.
England and Wales were divided into office and Agent areas. With the
exception of a minority of office area cases Counsel were instructed by
lawyers in the Criminal Law team from the first hearing in the magistrates
Court to the conclusion of the case. In a minority of cases Counsel were
instructed to advise on the sufficiency of evidence and whether it was in the
Public interest for charges to be brought. in Agents cases, if my recollection
is correct, lawyers in the Criminal Law team would advise on charges and
evidence and would prepare the committal bundle. Agents would be
instructed from the first hearing in the magistrates court and after committal
Proceedings would take over the conduct of the case in the Crown court
which would include instructing counsel and drafting the Indictment. In
complex cases the Criminal Law team would retain Agent area cases and
use Agents to attend Magistrates court hearings only. I am not aware that
this changed.
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Disclosure
35.
36.
37.
I do not believe that the purpose of the prosecution policy documents at
paragraph 7 above were aimed at the disclosure obligations on the
Prosecution. The Intranet would have had policy documents on disclosure
and the completion of the forms. These documents would have been
reviewed by a lawyer.
I believe a policy document regarding disclosure from third parties would
have also been on the intranet.
My understanding of the disclosure obligation on POL as prosecutor was to
disclose to the accused any material which might reasonably be considered
capable of undermining the prosecution case or assisting the case for the
accused which had not previously been disclosed. The duty of disclosure
was an ongoing one throughout proceedings and involved the disclosure of
relevant material. The duty of disclosure imposed an obligation for
investigators to pursue all reasonable lines of enquiry whether they pointed
towards or away from the suspect. The disclosure officer would prepare
schedules of unused material which would be served on the Defence with the
committal papers. Copies of the material listed would be provided unless the
volume of the material was vast. Copies of any material that were considered
to undermine the prosecution case or assist the Defence would always be
copied. When a Defence statement was received a copy would be forwarded
to the disclosure officer and Counsel to ascertain whether further material
needed to be obtained. A conference would normally be held with Counsel to
discuss the Defence statement and disclosure.
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38.
39.
41.
42.
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I believe that in the majority of cases the lead investigator would hold the role
of disclosure officer in relation to private prosecutions brought by POL.
The person who held the role of disclosure officer would also usually be the
lead investigator. They would have received training from the training
department. Where there were changes in legislation and guidelines, the
security department and training wing would be informed, policy documents
would be amended and circulated to all investigators.
Whilst I was employed by POL ! would have reviewed the disclosure in every
case from when the file was submitted to the conclusion of the case. If my
memory is correct in Agents cases, the Agents instructed would take over the
conduct of the case in the Crown Court. Up to the point that that happened
disclosure would be my responsibility.
The person(s) holding the roles of investigation officer, officer in charge
and/or disclosure officer did not make decisions about the conduct of
prosecutions.
After the passage of time it is difficult to recall advice that was given to
investigators about their disclosure obligations. Investigators certainly
understood that all material generated during the course of an investigation
needed to be retained and enquiries were needed to ensure that any material
that may undermine the Prosecution or assist the Defence was obtained. As
a matter of routine they would for example be asked to make enquiries from
the helpdesk if this had not already be done. When the Defence statement
was received it would be copied to the disclosure officer and Counsel so that
disciosure could be reviewed. Advice would be given regarding material that
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43.
45.
46.
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should be sought. In Crown court cases a conference would usually take
place where both evidence and disclosure would be discussed.
Wrere the integrity of the Horizon IT system was being challenged the
investigator would be asked to obtain any relevant data/ information from
Fujitsu. At the time I conducted POL cases I was unaware of any bugs or
defects in the system and believed that Horizon was a robust and reliable
system. Dr Jenkins, in his expert witness statement would have asserted that
and as an expert would have been under a duty to disclose any information
that undermined that position.
After committal proceedings or a transfer to the Crown Court Counsel would
be instructed to draft the Indictment and advise on evidence and disclosure.
In Agent area cases Counsel would have been instructed by our Agents.
Counsel who were instructed to prosecute were familiar with Horizon. When
Horizon was initially installed in offices, Counsel and Agents who were
regularly instructed on POL cases attended a training day where they were
shown how entries were physically made onto Horizon and how the system
worked. The witness bundle would have contained a statement regarding the
operation of Horizon.
Having reviewed the Defence statement, it would have been forwarded to
both the disclosure officer and Counsel. ! would have given advice regarding
the areas that needed to be addressed. A conference with Counsel would
usually take place to discuss the Defence statement. If further disclosure was
triggered a further schedule of unused material would be prepared and
served on ihe Defence.
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AT. Other than the case of Carl Page I cannot now recall any other case I dealt
with where a discrepancy was attributed to problems with the horizon IT
system in the Defence statement. Pension and Allowance order books were
still in existence up to 2003 and as such many of the cases up to that time
would have involved the wrongful encashment of orders from those books.
Cases solely involving a discrepancy between Horizon generated cash and
stock and the actual physical position determined following an audit
increased after order books were phased out. In such cases the Defence
statement would be forwarded to Dr Jenkins who would, if necessary, make
a further statement addressing the issues raised. Were Dr Jenkins aware of
any information which would undermine his evidence he had a duty to inform
the prosecutor who would in turn have to disclose such information to the
Defence. The disclosure officer would also be asked to look into any matter
raised and obtain any relevant material. I cannot now recall whether ARQ
logs were always requested from Fujitsu.
48. — Atno time that I dealt with POL cases was I aware of any potentially relevant
known bugs, errors or defects in the Horizon IT system. Had I known that any
such bugs, errors or defects existed then such an allegation in a Defence
Case Statement or Defence Statement would clearly have triggered an
obligation to disclose such information.
Experts
49. I do not know what information was provided to experts instructed by the
prosecution as to their role, including, in particular, their duty to the court and
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50.
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the meaning and importance of the expert's declaration. The statements
were obtained by the investigators. Dr Jenkins statement included the words
“L understand that my role is to assist the court rather than represent the
views of my employers or Post Office Ltd”. The words are self-explanatory.
My recollection is that when Horizon was rolled out the Head of the Criminal
Law team instructed Counsel to advise on the expert evidence that would be
required and what the statement needed to cover. I believe Fujitsu were then
asked who in their company would be able and willing to provide that expert
evidence. I do not know what instructions were given. As far as I recall only
Dr Jenkins provided an expert witness statement in cases I dealt with.
I cannot recall any policies or guidelines in place regarding the provision of
evidence by employees of Fujitsu whilst I worked in the Criminal Law Team.
At the time I believed that Dr Jenkins was the ultimate expert on Horizon. It
did not occur to me that there could be a potential conflict of interest. I do not
recall a challenge ever being made by the court or the Defence regarding the
use of Dr Jenkins as an expert witness. His role was to provide objective,
unbiased opinion on matters within his expertise to assist the court and not
the prosecution.
Criminal enforcement proceedings
52.
53.
! worked three days a week and as such was not required to deal with
criminal enforcement proceedings.
As above.
AS above.
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55.
As above. As I did not deal with criminal enforcement proceedings I am not
familiar with the Financial Investigation Unit process documentation
(POL00084988 and POL00084989) which was appended to the 2009
“Former Subpostmaster End to End Debt Review” (POL00084977), as well
as POL00051382
Audit data from Horizon to support investigation, prosecution and / or other
legal proceedings
56.
57.
{ cannot recall what the contractual requirements on Fujitsu were. I am aware
that there were limits on the number of ARQ requests which could be made
without additional costs being occurred. I do not know how any requests
above the limits were dealt with or charged but this would not have been a
factor taken into consideration in deciding whether such documentation
should be obtained. I was not working for POL when Horizon online was
introduced. I had no role in obtaining audit data. I do not know who
authorised an ARQ request. I cannot recall who from Fujitsu was responsible
for the provision of this data or how the data was presented. I do not know of
any additional prosecution support Fujitsu was contractually obliged to
provide.
The documents titied “Conducting Audit Data Extractions at CSR” dated 4
May 2000 at POL00029169 and “Conducting Audit Data Extractions at Live”
dated 27 November 2001 at FUJ00152176 are the only documents that
were published whilst I was conducting POL cases. ! do not recall having
seen them before. Ihe versions of the document entitled “Management of
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the Litigation Support Service” dated 27" October 2009 (FUJ00152212), 14%
February 2012 (FUJ00152220) and 23” April 2012 (FUJ00152225), as well
as the version marked “withdrawn” at FUJ00152235 were published after I
stopped doing POL cases. The same applies to the versions of the document
entitled “Audit Data Extraction Process” dated 13‘ September 2010
(FUJ00152216), 1% March 2011 (FUJ00152218) and 14" February 2012
(FUJ00152221) and the document entitled “Security Management Service:
Service Description” (SVM/SDM/SD/0017) dated 24" August 2006
(FUJ00002033), 31% December 2008 (FUJ00080107) and 15" October 2010
(FUJ00002264).
Your involvement in Criminal Prosecution Case Studies
R -v- Carl Page
58.
59.
I believe I first became involved in the case involving Carl Page and John
Whitehouse when the investigation file was submitted to the office. Mr Wilson
will have allocated the case to me to deal with. Unusually he made the
decision that he would be the second lawyer on the case.
I have considered the fax from Manish Patel to the Custody Sergeant at
Stafford Police Station at POLO00$3900,the email from me to Manish Patel
dated 7" April 2004 at POL00093930, the letter from Frisby & Co solicitors to
me dated 23" April 2004 at POL00093933, the intemal memo from Manish
Patel to me dated the 2" June 2004 and case conference note dated 6" July
2004 (final page) at POL00093910, the internal memo from Manish Patel to
me dated the 5t' July 2004 at POL00093931, the letter from me to Frisby &
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Co solicitors dated 23" September 2004 at POL00094100, letter from me to
Frisby & Co solicitors dated 7 October 2004 at POL00067072, the letter
from me to JMW solicitors dated 7" October 2004 at POL00067074, letter
from me to Frisby & Co solicitors dated 8"" November 2004 at POL00067082,
the internal memo from Manish Patel to me dated 8"" November 2004 at
POL00093928, the two electronic memos from Lisa Baddevithana to me
dated 16" November 2004 and my reply dated 19tt November 2004 at
POL00067116, the electronic memo from me to Lisa Baddevithana dated the
19" November 2004 at POL000671 14, the electronic memo from Lisa
Baddevithana to me dated 19" November 2004 and the electronic memo
from Manish Patel to Lisa Baddevithana with me cc’d of the same date at
POL00067085, the letter from me to Frisby & Co solicitors dated 23"
November 2004 at POL000670839, the letter from me to Frisby & Co solicitors
dated 25" November 2004 at POL00067090, the letter from Frisby & Co
solicitors to me dated the 29"" November 2004 at POL00067088, the letter
from me to Frisby & Co solicitors dated 1** December 2004 at POL00067087,
electronic memo from Lisa Baddevithana to me dated 2"? December 2004
and my reply dated 3 December 2004 at POL00067093, letter from Frisby &
Co solicitors to me dated 25" January 2005 at POL00067097, the letter from
me to Frisby & Co solicitors dated 17° March 2005 at POL00067099, the
electronic memo from Frisby & Co solicitors to me dated 16" May 2005 at
POL00067 104, letter from me to Frisby & Co solicitors dated 20°" May 2005
at POL00067 108, letter from Frisby & Co solicitors to me dated 20 May
2005 at POLN0067109, letter from Frisby & Co solicitors to me dated the 23
May 2005 at POLO00677110, letter from Frisby & Co solicitors to me dated
Page 22 of 50
61.
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26" May 2005 at POL00067081, letter from me to Frisby & Co solicitors
dated 27" May 2005 at POL00067084, letter from me to Frisby & Co
solicitors dated 23" February 2006 at POL00066545, memo from me to the
Investigation Team Post Office Ltd at POL00053309 and memo from me to
the investigation Team Post Office Ltd dated 3% July 2014 at POL00066519.
I have considered the documents set out at i) to xii) namely The Case File
Events Log at POL00093908, the records of interview from 14‘ January
2003 at POL00093702 (commencing at 17:17) POLO0093701 (commencing
at 18:06) and 23" April 2003 at POL00093703 (commencing at 16:31),
POL00093760 (commencing at 17:18) and POL00093759 (commencing at
18:02) and POL00093758 (commencing at 18:54), the prosecution case
summary dated 34% June 2004 POL00065034, the witness statement of Andy
Dunks FUJ00122250, the witness statement of Glyn Burrows POL00093714,
the witness statement of Kevin Orgil! POL00093733, the witness statement
of Deborah Alison Edwards POLG0093897, the witness statements of Manish
Patel POL00093755 and POL00093868, the bundle of witness statements at
POL00066551, the expert accountant’s report of David Liddell, dated 16"
May 2005 POL00062201, the expert report of Mr Taylor, dated 7 April 2006
POL00061214 and the transcript of Mr Page's evidence at POL00067005
I first became involved in the case involving Carl Page and John Whitehouse
when the investigation file was submitted to the office. Mr Wilson will have
allocated the case to me to deal with. Unusually he made the decision that
he wouid be the second lawyer on the case. His role included being familiar
with the evidence, considering disclosure and attending conferences with
Counsel.
Page 23 of 50
62.
63.
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My knowledge and understanding of the initial investigation was that H.M
Customs & Excise suspected Mr Whitehouse of money laundering. I am
unaware whether any audits were carried out by H.M Customs & Excise
although I can say that an audit of the Post Office was not undertaken by
H.M Customs & Excise.
My Understanding is that Staffordshire Major Crime Unit were called in by
H.M Customs & Excise after officers from H.M Customs & Excise arrested Mr
Whitehouse as he attended a Bureau de Change facility. He had in his
possession 585000 euros and a receipt from Rugely Post Office dated that
day for a bureau transaction for £360000 worth of Euros at an exchange rate
of 1.62. Post Office investigators attended Staffordshire Police HQ facility to
liaise with DI Mark Abbotts and his team (POL00093908 Case File Events
Log). Mr Page was arrested by the police who conducted a search of the
Post Office and subsequently conducted a short interview with him that
evening. Post Office investigators were present at the search to point out
items that should be seized. A police officer was present at a second
interview, with Mr Patel being the lead interviewer. On the 14 January 2003,
at a meeting with officers from Staffordshire Major Crime Unit Post Office
investigators agreed that the Post Office would take charge of the
investigation and any resulting prosecution, with the police assisting with the
financial investigation and undertaking phone analysis.
I have considered POL00045921, a letter from Staffordshire Police to Mr
Whitehouse dated the 7" May 2003. I am unaware of any discussions that
took place with the police before a decision to charge Mr Page and Mr
Whitehouse was made. I was somewhat surprised by the conclusion of the
Page 24 of SO
65.
66.
67.
68.
69.
70.
police not to press charges on the basis that their enquiries had “not provided
any clear evidence of criminal conduct either by, or between, the two men”
given that the police had not conducted the investigation but had passed it to
the Post Office to do so. I do not know when I became aware of the
existence of this letter
Stephen John made the charging decision in this case. Mr Page and Mr
Whitehouse were jointly charged with conspiracy to defraud and Mr Page
was additionally charged with theft.
Stephen John was instructed to advise on whether there was sufficient
evidence so as to afford a realistic prospect of the conviction of Mr Page and
Mr Whitehouse and whether it was in the public interest for a prosecution to
take place. His advice was that a conspiracy to defraud charge should be
brought against Mr Page and Mr Whitehouse and a charge of theft against
Mr Page.
I can no longer recall who authorised the prosecution of Mr Page.
Mr Patel was the lead investigator in these proceedings. After 19 years I am
not able to describe any discussions that I had with him during the course of
this case. I can say that there were numerous conferences with Counsel
where both evidence and disclosure were discussed.
I cannot recollect whether any Horizon data was requested from Fujitsu in
this case.
I have been asked to consider the report of David Liddell at POL00045867
and his supplemental report at POL00045868. I would have become aware
of these reports when they were served on the Prosecution. I have been
asked to consider paragraph 2.7 of the first report. This was an extremely
Page 25 of 50
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71.
complicated case and I have little memory of it. My recollection is that the
Prosecution agreed that a surplus could not have physically built up in the
“AM" stock or elsewhere. Mr Patel’s schedules showed that all the euros sent
to the Rugeley Post Office were entered into the Forde Moneychanger and
were accounted for. I believe that this was the prosecution’s case and
therefore Mr Liddell’s conclusion would not have undermined the basis of the
theft charge against Mr Page. It was not considered that the timing
differences set out in paragraph 2.8 of the first report could account for the
alleged shortfall. The dates and times of the Euros deposited by Mr
Whitehouse refuted this. Glyn Burrows in his statement at POL00093714
outlines what he and his team did in conducting the audit. He explained that
he would request an “office snapshot” printout from Horizon which provided a
summary of all the cash and stock which should have been present at the
office at that time together with a summary of all receipts and payments in
relation to transactions conducted at the office since the beginning of
business on the 9" January 2003. He explains that the process was then to
verify the cash and stock actually on hand at the office to see if it agreed.
There is no suggestion in his statement that data was verified back to source
documentation.
Mr Wilson, Mr John, Mr Tatford, Mr Patel and I were all responsible for
ensuring primary and secondary disclosure was carried out. Stephen John
was clear throughout that the Prosecution were to carry out disclosure
correctly and not give blanket disclosure. He requested sight of all
correspondence relating to disclosure and after discussion would draft the
replies.
Page 26 of 50
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72.
73.
74,
75.
76.
77.
78.
As previously stated after 20 years I cannot recollect the evidence that was
relied upon by the Post Office.
Unfortunately, after the time that has elapsed, I cannot detail all the
disclosure requests that were made by the Defence or how those requests
were responded to. From the correspondence that I have had sight of it
appears that all requests were addressed, material obtained and
subsequently disclosed. The exception was material held by Customs which
is addressed at paragraph 80 below.
I have been asked to consider the case conference note dated the 6'" July
2004 at POL00093910. I can say that I am not the author of this note. It is not
my handwriting. I do not know whether I was present at the case conference,
who was present and what was discussed.
I would have had no involvement in drafting the witness statements. The
investigators obtained all the witness statements. I would have reviewed any
witness statement taken.
I have been asked to consider a letter to Frisby & Co solicitors dated the 25t”
November 2004 (POL00067090). I cannot assist regarding the conversation
on the 19 November 2004 referred to therein. It would logically relate to the
service of an additional list of witness statements and exhibits in relation to
the Notices of Additional Evidence previously served.
I have been asked to consider the letter that I sent to Frisby & Co solicitors
dated the 1* December 2004 (POL00067095). I cannot provide details of the
recent conversation referred to.
I have considered the letter from Frisby & Co solicitors dated the 25"
January 2005 (POLG60670397) and am asked whether I responded to this
Page 27 of 50
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79.
80.
81.
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letter and the details of my response. I have no recollection of the letter and
after some 18 years can not assist as to whether it was responded to. In the
unlikely event that it was not Frisby & Co solicitors would clearly have chased
a reply.
I have been asked to consider the letter from Frisby & Co solicitors dated the
23 May 2005 (POL00067110). I cannot recall details of any conversation
with Mr Cleary. I cannot recall the directions hearing and do not know
whether contact was made with Mr Cottier.
I have considered the letter from Frisby & Co dated the 26" May 2005
(POL00067081) and my response dated the 27 May 2005 (POL00067084).
I have no recollection of my letter dated the 24" May 2005 which preceded
these letters. I cannot now recall my reaction to the observation made by
Frisby & Co in the final paragraph but did not agree with their observation.
Although I have no recollection of the visit, Stephen John, Rob Wilson and
myself had attended H.M Customs & Excise headquarters and viewed the
material. I can no longer recall what that material was. We concluded that the
material did not fall for disclosure. Prior to the trial commencing the Defence
agreed that HHJ W Wood QC would examine the material and decide
whether it should have been disclosed. The material was brought to court
and HHJ W Wood QC concluded that it was not disclosable.
Stephen John was prosecution counsel. At some point, and ! can not recall
when, Mr John asked whether Warwick Tatford could be his junior. Mr
Tatford’s role was to assist Mr John in the preparation of the case. My role
was to ensure that Mr John was properly instructed so that he was abie to
conduct proceedings in a fair and objective manner. He was provided with all
Page 28 of 50
82.
83.
85.
86.
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witness statements, exhibits, schedules and copies of material disclosed to
the Defence, documentation including memos from Mr Patel,
correspondence from the Defence solicitors, the Defence statements and
experts report.
As detailed at paragraph 66 above Stephen John was instructed prior to
charges being brought. There were numerous conferences at which
evidence, disclosure, the Defence statements and the expert report were
discussed.
I am not sure that I had a reaction. It was the jury’s role to decide on the
Defendants guilt or innocence.
POL has always followed the guidance given by prosecuting counsel.
Stephen John was of the view that it was in the public interest for a retrial to
take place and the business agreed. My recollection is that Mr John was of
the view that the prosecution case had come up to proof and in view of the
amount alleged to have been stolen that a retrial was the appropriate course
of action.
I believe that Stephen John advised on the further evidence that should be
obtained, transcripts of some of the evidence given in court were ordered,
and disclosure triggered by the first trial, the second Defence statement and
the expert report were considered.
I have considered the Defence statement in Mr Page's retrial at
UKG100012306. At the time that it was received I would have been fully
conversant with the evidence in this case. After the time that has elapsed I
have little independent memory of it. The Defence statement at Paragraph 2
suggests that in the original trial the theft charge was related to the
Page 29 of 50
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conspiracy to defraud charge. That was not and never was the prosecution
case. When the office was audited following the arrest of Mr Page a number
of cheques paid by Mr Whitehouse were found. Initially it appeared that they
related to Bureau transactions conducted by Mr Whitehouse. Mr Page later
admitted that Mr Whitehouse had given him a cheque in the sum of
£278 181.82 as three cheques used to purchase euros in December had not
been honoured. He was holding the cheque Pending error notices being
issued. The prosecution's case was and remained that the £282000 audit
shortage had been stolen over an unknown period of time by Mr Page. The
snapshot printout of Mr Page’s stock indicated that there should have been
£72159.03 in cash and £282000 in currency. Investigations made by Mr
Patel showed from accounting period week ending 28" August 2002 through
to week ending the 8" January 2002 the figure declared for currency in the
cash accounts had been inflated commencing with an inflated figure of
£188000 and by the date of the audit reaching £282000, the amount shown
as foreign currency in Mr Page's stock. The inflated figures relied on the data
from the Forde Money changer. I can no longer recall what steps were taken
upon receiving the Defence statement although clearly it would have been
forwarded to Counsel and the investigator and consideration would have
been given to whether any further evidence or disclosure were required. I
cannot recall whether Dr Jenkins made a further statement. The theft charge
relied on the Horizon shortfall and at the time I believed, as did Counsel and
Trevor Lockey (the investigation officer who took over from Mr Patel), that Dr
Jenkins statement regarding the robustness and integrity of Horizon was
factually correct and could be relied on. I believed that Dr Jenkins would
Page 30 of 50
87.
88.
89.
90.
91.
have disclosed any material which cast doubt on his opinion. I was also
unaware of any bugs or problems with the Horizon data that had come to
fight in any other case.
I have been asked to consider the expert report of Mr Taylor at
POL00061214. I can not comment on why Mr Page instructed a new expert.
I have been asked about my view of the conclusion reached by Mr Taylor in
his report. Had I believed his conclusions were correct, the prosecution of Mr
Page would not have continued.
I have considered the notification of disposal to police at POL00053308. I
was surprised at Mr Page’s guilty plea.
In relation to POLO0066519 I cannot explain why the memo was dated the
3° July 2014.
At the time I believed the case was fairly and competently conducted. I had
no knowledge that there were any issues with Horizon. Had I been aware
that there were bugs, errors and defects in the system that could, and did,
cause discrepancies and shortfalls in branch accounts then prior to
instructions being sent to Counse} enquiries would have been made to
ascertain whether these could be excluded in relation to the Horizon data
being relied on. Clearly were we not in a position to do this there would have
been no basis for the prosecution of Mr Page on the theft charge. I have
considered the Judgement of the Court of Appeal in Josephine Hamilton &
Others v Post Office Limited (2021) EWCA Crim 577 at POL00113278. Mr
Whitehouse was never charged with theft. The case against Mr Page at both
the first trial and the retrial was the same. In his case summary at the first
Page 31 of 50
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trial Stephen John states that “Page alone is charged with theft within the
same period of £282000, that being the deficiency found on audit”.
R -v- Oyeteju Adedayo
92.
93.
94,
95.
I have no independent recollection of the criminal prosecution of Oyeteju
Adedayo and my responses are based on the documents I have been
provided with.
{ have considered the documents POL00068926, POL00044360,
POL00066742, POL00066745, POL00064797, POL00044361,
POL00052904, POL00052916, POL00052910, POL00044363,
POL00644364, POL00044367, POL00052911, POL00044362,
POL00044362, POL00052588, POL00044365, POL00047897,
POL00044370, POL00047865, POL00052907, POL00044358,
POL00052902 and POL00052911.
I would have been allocated the case by Mr Wilson when it was sent to the
Criminal Law Team for advice.
I have not seen the case papers for 18 years and therefore cannot say with
certainty what exhibits and other documentation were enclosed with the
investigation file.
! can see from POL00044361 that I advised that the evidence was sufficient
to afford a realistic conviction of Mrs Adedayo on charges of false
accounting. In my view false accounting reflected the seriousness and extent
of the offending. Mrs Adedayo had advised the auditors who were already
present when she attended the office that the accounts would be about
£50000 short. Mrs Adedayo subsequently handed the auditors a note that
Page 32 of 50
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said “! have today 5"* September confessed to the auditor regarding the sum
of £50000 taken, with my mentioning it to my assistant that I was going to be
repossessed and, since I have equity, no mortgage on the Rainham Hill
property, I have already applied for a £50000 loan to pay back to the Post
Office, as this had not been my intention to take somebody else’s money.”
Mrs Adedayo attended a voluntary interview with Post Office investigators in
which she admitted to removing a total of £50000 on three separate
occasions from the Post Office to repay monies owed to friends and family
who were no longer prepared to wait for the monies to be repaid. She said
that they wanted their money or would start plastering, “repossession” on the
door. She was shown sample cash accounts and admitted that the cash on
hand figures had been inflated and included the monies that she had
removed. She accepted that she was aware that she was not allowed to use
Post Office money for her own use. Mrs Adedayo indicated that her assistant
ran the office and she would come in to do the balancing and cover when her
assistant was absent. She was asked if she was confident using the Horizon
system and said that she was. She said that her assistant was good with it
and they did the balancing together. Mrs Adedayo said that the investigators
could come to her house and she would give them the paperwork regarding
the applications for a remortgage. It was agreed that she would forward the
information by Special Delivery. Mrs Adedayo’s legal rights were explained at
the beginning of both taped interviews and she confirmed that she had not
been asked any questions in relation to the enquiry prior to the interview. My
view was that the admission made to the auditor and the interview itself were
admissible and reliable. In my view the public interest required the
Page 33 of 50
97.
98.
99.
100.
101.
102.
103.
104.
WITN08900100
WITNO8900100
prosecution of Mrs Adedayo given the seriousness of the offences. Mrs
Adedayo’s actions involved a serious breach of trust aggravated by the fact
that she involved her elderly assistant by informing her of what she was
doing.
{ made the charging decision in this case.
After the passage of time I do not know who authorised the prosecution of
Mrs Adedayo
Natasha Bernard was the lead investigator in this case.
As indicated at paragraph 95 above, after 18 years I cannot say for certain
what exhibits were contained in the file. The evidence relied upon would
have been the handwritten admission made to the auditors, the audit
shortage, the cash accounts and the admissions made at interview that Mrs
Adedayo had falsified the cash accounts to hide the fact that she had
borrowed money from the Post Office.
I do not believe that any Horizon data was requested from Fujitsu in this
case.
Natasha Bemard was the disclosure officer in this case.
My role would have been to ensure any material that may undermine the
prosecution case or assist the Defence case was disclosed. This was a
continuing duty.
I have no recollection of any disclosure requests being made by the Defence
in this case. I have not been provided with any correspondence from the
Defence solicitors. Had any request been made, it would have been replied
to.
Page 34 of 50
105.
106.
107.
108.
109.
WITNO8900100
WITNO8900100
I do not know who prosecuting counsel was in this case. Counse! was initially
instructed to conduct the hearing at the magistrates court. Mrs Adedayo
pleaded guilty at Chatham Magistrates Court on the 19" January 2006.
Jurisdiction was declined. I do not know whether I or one of the legal
executives instructed counsel to represent POL at the sentencing hearing.
I cannot recall having any discussions with Counsel.
I do not know who made the decision to commence confiscation proceedings
in respect of Mrs Adedayo.
I had no involvement in the confiscation proceedings. I see from the Financial
Investigation Events log (POL00047897) that I spoke to Michae! Matthews
regarding a prosecutors statement. I will have passed this to Mr Wilson to
deal with.
I have considered the transcript of Mrs Adedayo’s evidence to the Inquiry at
1NQ00001039. At the time I advised on evidence there would have been
nothing in the papers to indicate that anything untoward had happened on
the day of the audit and interview. I was not present on that day so do not
know what occurred and it would therefore be inappropriate to comment save
to say that on Mrs Adedayo’s evidence her interview would have been ruled
inadmissible. Her account of the impact that the prosecution had on herself
and her family are truly heartbreaking.
R -v- Susan Rudkin
Page 35 of 50
110.
111.
112.
113.
114.
115.
416,
117.
118.
119.
120.
WITNO8900100
WITNO8900100
My involvement in the Susan Rudkin case was limited to dealing with a letter
that would have been received from John Dove informing Mr Singh of the
outcome of the hearing on the 26'" March 2009.
I have considered POL00046550, POL00045243 and POL00045246,
POL00050026, POL00050123, POL00046485, POL00046576,
POL00046488, POL00045220, POL00050347, POL00046505,
POL00046506, POL00046537, POL00051256, POL00051248,
POL00051250 and POL00051252.
My first and only involvement with the Susan Rudkin case was dealing with a
letter notifying Mr Singh that Susan Rudkin had pleaded guilty, jurisdiction
had been declined and the case had been adjourned for sentence.
I was not involved in the prosecution of Susan Rudkin therefore would not
have had sight of POL00060416, POL00061521 or POLO0065265.
I did not give any advice on whether Susan Rudkin should be prosecuted.
I do not know who authorised the prosecution of Susan Rudkin.
I was not involved in the prosecution of Susan Rudkin and therefore do not
know what evidence was obtained and relied upon by the Post Office in
these proceedings.
I do not know whether any Horizon data was requested.
I have considered POL00051044, POL00059762, POL00044916 and
POL00060421.
I have not seen the correspondence at paragraph 118 above before.
As stated, save for notifying the relevant parties of the outcome of the
hearing on the 234 March 2009 I had no involvement in this case. ! therefore
have not previously seen the letter from Richard Nelson solicitors to Mike
Page 36 of 50
WITN08900100
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Wilcox dated the 7" April 2009 at POL00046524 and the enclosed letter from
Dr A T Peden dated 22"4 February 2009 at POL00050993.
121. 1 do not know who the disclosure officer was in this case.
122. I do not know who the investigation manager was in this case.
123. I had no role in relation to disclosure in this case.
124. Mr John Dove, Solicitor Advocate conducted the hearings. I had no role in
instructing him save for my letter to him on the 26" March 2009 at
POL00051250.
125. I did not have any discussions with Mr John Dove.
126. I had no involvement in the criminal enforcement proceedings taken against
Susan Rudkin. I have considered the documents POL00050242,
POL00051380, POL00052020, POL00052094, POL00055156,
POL00055203 and POL00057602. I have not had sight of these documents
before. Reference is made to my letter dated the 8" July 2009 at
POL00052029. This is in fact a letter from Mr Singh to Richard Nelson
solicitors.
127. As stated, I had no involvement in these proceedings so cannot reflect on the
way the investigation and prosecution of Susan Rudkin was conducted or the
outcome of the case.
General
128. Save for the prosecution of Carl Page I did not advise on POL cases from
2006 onwards. I was not aware of any issues impacting Horizon at the time
that I had conduct of POL cases. Had I been aware that there were bugs,
Page 37 of 50
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defects or any faults in Horizon then clearly a challenge to the integrity of
Horizon in one case would be relevant to other ongoing or future cases. It is
now clear that Horizon was not the robust system it was held out to be. In my
view no proceedings should have been started unless the Post Office were
able to prove that those bugs, defects or faults could not have impacted on
the operation of Horizon i.e that the evidence being relied on was reliable.
129. There are no other matters that I would like to draw to the attention of the
Chair.
Statement of Truth
I believe the content of this statement to be true.
Dated: St Der 225,
Page 38 of 50
Index to First Witness Statement of Deborah Stapel
WITN08900100
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INo. [URN [Document Description ‘ontrol
lumber
Ke IPOLO0030659 IPost Office Internal Prosecution PolicyPOL-0027141
(Dishonesty), Andrew Wilson
I December 1997
POLOOO31012 linvestigation Policy Appendix 16- POL-0027494
Investigation and prosecution policy
3 IPOLOO039945 Investigation Policy - Interview lPol-0036427
Recording, v.4.0
4 IPOLO0039951 investigation Policy - Notes of POL-0036433
Interview England & Wales v3 Nov 02.
lAppendix 2a.
IS [POLO0039952 investigation Policy: Notes of POL-0036434
Interview - Northern Ireland
6 IPOLO0030578 {S02 Royal Mail Group Criminal POL-0027060
Investigation and Prosecution Policy
[December 2007
7 POLOO104812 "Royal Mail Group Ltd Criminal POL-0080444
Investigation and Prosecution Policy”
iS IPOLO0031011 IRMG Prosecution Policy (undated) POL-0027493
2.1
9 POLO0030S80 Post Office Ltd - Security Policy: Fraud IPOL-C027062
investigation and Prosecution Policy
2
(10 IPOLO0030579 Post Office Ltd Financial Investigation POL-0027061
Policy, May 2010
11 JPOL00026573 IRMG Procedures & Standards - POL-0023214
Proceeds of Crime Act 2002 &
IFinancial investigations doc 9.1 V1.
a2 POLO0031008 IRMG Ltd Criminal Investigation and /POL-0027490
Prosecution Policy v1.1 November
2010
13 IPOLO0030598 Royal Mail Prosecution Decision POL-0027080
Procedure
Page 39 of 50
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[24
PoL00104853
[Post Office's Financial Investigation
Policy
OL-0080485
a5
IPOLOO104855
Post Office Ltd. Anti-Fraud Policy POL-0080487
IPOLOO030685
Wv3.0, April 2011 - Rob Wilson (Head ofI
{criminal Law Team)
[Royal mail Group Prosecution Policy, [POL-0027167
(7
IPOLOCO30800
3.0
IRMG Policy - Prosecution (S3) Version POL-0027282
18
POLO0031034
Post Office Prosecution Policy V1 POL-0027516
19
POLO0104929
for Criminal Investigation and
Enforcement (with flowchart)"
Post Office Limited: internal Protocol POL-0080561
20
POLOO10S226
Investigations and Enforcement
Procedure (flowchart)
\Undated Appendix 1-POL Criminal [POL-0080851
j21
IPOLO0104747
[Management (England & Wales) v1.0
investigation Policy: Casework IPOL-0080387
22
POLOO104777
iManagement (England & Wales) v4.0
investigation Policy: Casework POL-0080417
[23
POLOO118096
jEmail from Andrew Wise to Michael
Stanway forwarding an email re
(Casework Compliance
1S00012685
[24
IPOLOO118108
[Appendix 1 - Case Compliance
checklist. Undated (date taken from
parent email)
100012697
25
IPOLOO118109
lAppendix 2 - File construction and
\Appendixes A, B and C: "Compliance
Guide: Preparation and Layout of
investigation Red Label Case Files"
IUndated - date taken from parent
email
1$00012698
[26
POLOO118101
Appendix 3 - Offender reports and
Discipline reports: "Compliance Guide
ito the Preparation and Layout of
investigation Red Label Case Files" -
lundated (date taken from parent
jemail)
S00012690
Page 40 of 50
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27
IPOLOO118102
[Appendix 4 - Offender reports layout:
"POL template Offender Report (Legal
Investigation)" - undated (date taken
from parent email)
iS00012691
28
IPOLO0118103
IAppendix 5 - Discipline reports layout;
"POL template Offender Report
Personnel Investigation)" - undated
(date taken from parent email)
1S00012692
29
POLO0118104
[Appendix 6 - identification codes
(undated - date taken from parent
jemail)
1500012693
30
IPOLO0118105
Appendix 7 - Tape Interviews. "POL
Security Operations Team guide:
ummarising of Tape Recorded
interviews." Undated - date taken
from parent email
'S00012694
34,
POLOO118106
(Appendix 8 - Notebooks: Guidance on
jusing notebooks in investigations.
\Undated (date taken from parent
lemail)
1S00012695
32
POLOO118107
IAppendix 9 - Case Progression Toolkit.
\Undated (date taken from parent
jemail)
1S00012696
B3
IPOLO0029169
lExtractions at CSR Process (v1)
ICL Pathway Conducting Audit Data POL-0025651
i34
FUJO0152176
[Live - ICL Pathway Ltd - v2.0
(Conducting Audit Data Extractions at IPOINQ0158370F
35,
POLO0093300
Sergeant re John Whitehouse -
Release from bail on 2 June 2003.
Fax from Manish Patel to Custody POL-0094022
36
IPOLOG093930
\Deborah Helszajn to Manish Patel re
Relating to Carl Page
Icarl Page Case Study: Email from POL-0094052
[37
POLO0093933
IAndrew Broome to Debbie Helszajn re!
IR v Carl Page, Stafford Crown Court.
(Carl Page case study: Letter from POL-0094055
38
IPCLOO0S3916
[Patel to Deborah Helszajn re: POST
IOFFICE Ltd v PAGE & WHITEHOUSE
Internal POL memo from Manish POL-0094032
Page 41 of SO
WITN08900100
WITNO8900100
B9
IPOLO0093931
Deborah Helszajn re Post Office Ltd v
Page & Whitehouse - Further
documentation
internal memo from Manish Patel to jPOL-0094053
40
POLO0094100
1& Co Solicitors re H M Customs &
[Excise investigation
iLetter from Debbie Helszajn to Frisby POL-0094222
41
IPOLO0067072
IFrisby & Co Solicitors for the attention]
lof Andrew W Broome re: Regina v
(Carl Adrian Page Stafford Crown
(Court - Trial - 4 January 2005
Letter from Debbie Helszajn to MessrsPOL-0063551
A2
IPOLO0067074
IMessers JMW Solicitors. Re: Regina v
[Carl Adrian Page Stafford Crown
(Court - Trial - 4th Jan 2005
Letter from Debbie Helszajn to POL-0063553
43
IPOLO0067082
Letter from Debbie Helszajn to MessrsI
Frisby & Co re: Regina v Carl Page
Stafford Crown Court Trial - 4th
january 2005
POL-0063561
laa
IPOLO0093928
Patel to Deborah Helszajn re Post
Office Ltd v Page & Whitehouse.
ISIMS/6299.
internal memos between Manish POL-0094050
45
IPOLO0067116
ito Lisa Baddevithana Re R v Page
IMemo chain from Deborah Helszajn /POL-0063595
46
POLOO067114
fai to Lisa Baddevithana Re
isclosure in R v Page
IMemo from Deborah Helszajn (Royal IPOL-0063593.
47
IPOLOO067085,
ifrom Lisa Baddevithana to Deborah
lHetszajn RE: Request for updated
schedules for statements and exhibits
(Carl Page)
Electronic Memo and email chain POL-0063564
4g
IPOLO0067089
lof tegal services to Frisby & Co
jsolicitors Re R v Cart Page
Letter from Debbie Helszajn on behalf /POL-0063568
49
IPOLO00670S0
I& Co solicitors Re R v Carl Page
ILetter from Debbie Helszajn to Frisby IPOL-0063569
Page 42 of 50
WITN08900100
WITNO8900100
iSO
IPOLOOO67088
Letter from Andrew Broome to ‘OL-0063567
Debbie Helszajn re: R v Carl Page
IStafford Crown Court
jo
IPOLOO067087
lLetter from Debbie Helszajn to MessrsIPOL-0063566
Frisby & Co Solicitors for the attention!
lof Andrew W Broome re: Regina v
(Carl Adrian Page Stafford Crown
(Court - Trial - 4 January 2005
2
IPOLOO067095
ILetter from Debbie Helszajn (Royal [POL-0063574
jail) to Andrew W Broome of Frisby
I& Co Solicitors enquiring about expertI
report, proposed jury bundle and
jamendments to the interviews - Rv
[carl Edward Page
53
IPOLO0067093
lemo from Deborah Helszajn to Lisa POL-0063572
Baddevithana Re R v Carl Page
4
IPOLO0067097
lLetter from Andrew Broome of Frisby POL-0063576
I& Co Solicitors to Debbie Helszajn Re
IR v Carl Page
5S
IPOLOO067099
Letter from Debbie Helszajn to POL-0063578
iAndrew W Broome of Frisby & Co
Solicitors Re R v Carl Adrian Page
56
POLOG067104
IMemo from Tom Cleary to Debbie POL-0063583
Helszajn, RE: Interview Tapes and
[Transcripts (R v. Page)
S7
IPOLO0067108
ILetter from Debbie Helszajn to Frisby POL-0063587
I& Co Solicitors Re R v Carl Adrian PageI
jand John Edward Whitehouse
58
IPOLOO067109
Letter from Tom Cleary of Frisby & Co IPOL-0063588
ISolicitors to Debbie Helszajn Re R v
Carl Page
[59
IPOLO0067110
lLetter from Tom Cleary of Frisby & Co IPOL-0063589
Solicitors to Debbie Helszajn of Royal
(Mail Re R v Carl Page
IPOLO0067081
\Letter from Andrew Broome to jPOL-0063560
[Debbie Helszajn re: R v Carl Page
Stafford Crown Court
61
IPOLO0067084
ICarl Page case study: Letter from POL-0063563
[Debbie Helszajn to Messrs Frisby & Co]
ffor the attention of Andrew W i
Page 43 of 50
WITN08900100
WITNO8900100
Broome re: Regina v Carl Page Dudley
{Crown Court
62
IPOLOO066545,
(Carl Page Study: Letter from Post IPOL-0063024
lOffice to Messrs Frisby & Co
kontaining Mr Page Evidence
transcript.
63
IPOLOO0S3309
(Carl Page case study: Memo from IPOL-0049788
\Debbie Helszajn to POL Investigation
\Team re: Regina v Carl Adrian Page ~
iReport on Final Result
4
IPOLO0066519
{Memo from Debbie Helszajn to IPOL-0062998
linvestigation Team Post Office re:
IRegina v Carl Adrian Page report on
final result Case 6299
65,
IPOLO0093908
Icase File Events Log - Rugeley MPSO, IPOL-0094030
SPM Mr Carl Page
66
IPOLO0093702
[Transcript of Police Station Interview IPOL-0093824
jof Carl Adrian Page on 14/01/2003.
Tape 2
67
IPOLO0093701
[Transcript of Police Station Interview IPOL-0093823
jof Carl Adrian Page on 14/01/2003,
[Tape 3
IPOLO0093703
Record of Tape Recorded Interview of IPOL-0093825
\Carl Adrian Page
\69
IPOLOO093760
[Transcript of tape recorded interview IPOL-0093882
lof Carl Page. Interviewed by Manish
Patel and Colin Price (17:18 start
itime)
70
[POLOO093759
(Carl Page Case Study: Transcript of — [POL-0093881
tape recorded interview of Carl Page.
Interviewed by Manish Patel and
[Colin Price.
71
IPOLOG093758
Transcript of tape recorded interview IPOL-0093880
lof Carl Page. Interviewed by Manish
Patel and Colin Price.
72
IPOLOO065034
(Case Summary - R -v- Carl Adrian PageiPOL-0061513
and John Edward Whitehouse in the
(Crown Court at Stafford
Page 44 of 50
73
IFus00122250
lv.3)
Andy Paul Dunks' witness statement JPOINQO128464F I
WITN08900100
WITNO8900100
74,
IPOLO0093714
Istatement of Glyn Burrows (Audit
Manager), version 3.0 11/02
ICarl Page Case Study - Witness IPOL-0093836
75
IPOLO0093733
itness Statement of Mr Kevin Orgill
IRE: Rugeley PO branch
investigations.
\Carl Page (WITNO151) case study. POL-009385S
76
IPOLO0093897
Edwards.
IWitness statement of Deborah POL-0094019
77
IPOLOO09375S
itness Statement of Manish Patel. IPOL-0093877
(78
POLO0093868
Whitehouse - Notice of Additional
Evidence.
IThe Queen v Carl Page and John POL-0093990
79
IPOLOOO66551
Statement of Sarah Jane Boardman,
Mrs Elaine Lievesley, Mark irvin,
jMichael Joseph Cooksey, Mr Steve
IGeraty, James Gerard Coney, Mrs
Shirely Brocklehurst, Mrs Mary
Elizabeth Peet, Mr Douglas Paul
IBrown, Mr Stephen Charles
(Cartwright, Mrs Gwen Talbot, Pippa
Barker, Andrew Wood, Barry
jamieson, Colin Richard Price and
{Manish Patel.
(Carl Page Case Study: Witness POL-0063030
80
IPOLOG062201
Liddell 2005, R-V-Carl Adrian Page
Expert Accountant's Report of David {POL-0058680
81
IPOLO0061214
Report to the Court prepared by T
Taylor, a Director in KPMG LLP.
[Between Regina and Carl Adrian Page /POL-0057693
82
IPOLO0067005
Adrien Page ( R v Page and another)
lbefore Judge W Wood
(Carl Page case study: Evidence of Kart POL-0063484
83
IPOLO0045921
lpolice regarding John Whitehouse
ated 7/5/2003.
ILetter from DC Deans to Staffordshire IPOL-0042400
Page 45 of SO
WITN08900100
WITNO8900100
IPOLO0045867
Liddell In the Crown Court at Dudley -
R v Carl Adrian Page
Expert Accountant's Report of David /POL-0042346
5
IPOLO0045868
IR v Carl Adrian Page, Expert
Accountant's Report of David Liddel!
POL-0042347
86
IUKG100012306
(Carl Page case study: Regina and Car!
[Adrian Page Defence Statement
IUKGI023102-001
87
\PoLo0113278
josephine Hamilton & Others and
Post Office Limited
Approved Judgment between POL-0110657
88
IPOLO0063926
[Office (FAD098941X) by Deepak
alani
Audit report of Rainham Road Post —/POL-0065405
89
\POLO0044360
JOyeteju Adedayo
\Theft/False Accounting report - JPOL-0040839
90
IPOLO0066742
[Transcribed note on Oyeteju Adedayo
interview
POL-0063221
jot
IPOLOO066745
Interview - Tape 2
[Transcript of Oyeteju Adedayo POL-0063224
92
IPOLO0064797
(Criminal Law team recommending
Iprosecution be pursued (Oyeteju
(Adedayo)
internal Memo from Darryl Owen to IPOL-0061276
[93
IPOLO0044361
\Natasha Bernard regarding prospect.
pf conviction in Post Office itd v
(Oyetehu Adedayo case
IMemo from Debbie Helszajnto Ms POL-0040840
POLOC0S2904
internal memo from Terry Crowther
to Natasha Bernard, RE: Solicitors
Advice on Prosecution and Schedule
lof Charges (Oyeteju Adedayo}
POL-0049383
js
IPOLOG052916
Debbie Helszajn, RE: Oyeteju Adedayo!
[summons
Letter from Natasha Bernard to IPOL-0049395
96
IPOLO0052910
lemo letter from Debbie Helszajn to
INatasha Bernard Re Post Office Ltd v
jOyeteju Adedayo Case
IPOLTD/0506/0336
POL-0049389
Page 46 of 50
WITN08900100
WITNO8900100
97
10100044363
lOyeteju Adedayo - False accounting
lotification of proceedings to police - IPOL-0040842
98
IPOL00044364
[Oyeteju Adedayo - False accounting
Notification of proceedings to Police - IPOL-0040843
POLOG044367
IAdedayo in Post Office Ltd v Oyeteju
Adedayo
Schedule of charges for Oyeteju Pot-o040846
{100
POL00052911
Mail) to Investigation Team Post
(Office Ltd Re Post Office Ltd v Oyeteju!
\Adedayo - Pleaded guilty, on notice of
compensation
(Memo from Debbie Helszajn (Royat IPOL-0049390
(101
IPOLO0044362
rom Phil Taylor to the Post Office
investigation Team regarding Regina v
lOyeteju Adedayo
lOyeteju Adedayo case study- Memo [POL-0040841
1102
POLO00S2588
{Stephens and Sons Solicitors, RE: Mrs
lOyeteju Adedayo
Letter from Michael F Matthews to —POL-0049067
103
IPOLO0044365
Hlisposal to police - Oyeteju Adedayo
[Form NPA 03 1/97 - Notification of — POL-0040844
(104
IPOLOG047897
Financial Investigation Events Log,
se Number: Fl 0506 0336
lOyeteju Adedayo Case Study - POL-0044376
1105
POLO0044370
jaccordance with section 16 (6) of the
proceeds of Crime Act 2002 Regina v
Oyeteju Adedayo
Statement of information relevant in IPOL-0040849
106
IPOLO0047865
Schedule Fl 0506 0336
Financial Investigation Document POL-0044344
\L07
IPOLOGOS2907
investigation Team Post Office Ltd,
IRE: R v Oyeteju Adedayo, Maidstone
[Crown Court
Memo from Phil Taylor to IPOL-0049386
1108
IPOLO0044358
the accused - Oyeteju Adedayo
[Memorandum for the information of POL-0040837
109
IPOLGO052902
lAdedayo
jAntecedents form tor Oyeteju POL-0049381
Page 47 of 50
WITN08900100
WITNO8900100
1110
INQ00001039
Horizon IT Inquiry - John Dickson
IfWITNO166}, Pauline Thomson
(WITNO258}, Timothy Burgess
[WITNO187], Siobhan Sayer
[WITNO183] and Oyeteju Adedayo
l[wiTNot7a]
[Transcript (21/02/2022): Post Office IINQo00001039
(141
POLOGO46550
{Chester re Audit of Post Office
ltbstock, Branch Code 223217
Audit report from Paul Field to Glenn IPOL-0043029
IPOLO0045243
subpostraster debt recovery
{undated - date estimated from audit
date) Susan Rudkin
(Handwritten statement in re to POL-0041722
413
POLO0045246
libstock Post Office
[Handwritten note re: Interview at POL-0041725
114
IPOLOO050026
Susan Jane Rudkin dated 20/8/08,
Record of tape recorded interview of IPOL-0046505
215
IPOLO0050123
jand finance investigation in re to
Susan Rudkin
Email from Mike Wilcox to WilliamsonIPOL-0046602
(116
POLOQ046485,
itheft/money laundering in re to SusanI
jane Rudkin
Investigation report in re to jPOL-0042964
[117
IPOLOO046576
Rudkin
IAntecedents in re to Susan Jane IPOL-0043055
(118
IPOLoo046488
[to Jarnait Singh to Fraud team post
foffice limited and Mole Willcox in re
[to ' Post office limited v Susan Jane
Rudkin dated 3/10/2008.
Susan Rudkin case study: Memo in re POL-0042967
(119
jPOLO0045220
[Limited v Susan Jane Rudkin
[Schedule of charges - Post Office IPOL-0041699
120
POL.00050347
[Team Post Office, RE: DAM Authority-
Susan Jane Rudkin Ibstock
{Email from David Pardoe to Fraud POL-0046826
424
IPOL00046505
[Singh in re to Susan Jane Rudkin
Letter from Mike Wilcox to Jarnail IPOL-0042984
Page 48 of 50
WITN08900100
WITNO8900100
22
POLOGO46506,
jteam post office in re to Susan Jane
(Rudkin
{Memo from Jarnail Singh to Fraud IPOL-0042985
123
IPOLO0046537
lHinckley magistrates court in re to
[Susan Jane Rudkin.
[Susan Rudkin case study: Summons, /POL-0043016
(124
IPOLO00S1256
[Team Post Office Limited c.c. Mike
filcox re: REGINA v SUSAN JANE
IRUDKIN
[Letter from Debbie Helszajn to Fraud jPOL-0047735
425
IPOLOO0S51248
\Team Post Office Limited c.c. Mike
Wilcox, Ged Harbison and Press OfficeI
RE: R v Rudkin (Guilty Plea to theft on
[23 March 2009)
[Memo from Debbie Helszajn to Fraud IPOL-0047727
126
POLO0051250
john Dove re: REGINA v SUSAN JANE
IRUDKIN
[Memo from Debbie Helszajnto Mr —_IPOL-0047729
(127
POLO00S1252
(Chief Clerk re: REGINA v SUSAN JANE
IRUDKIN
Letter from Debbie Helszajn to The — IPOL-0047731
128
POLOOO060416
IMr EM Rudkin to Paul Hemley Re:
Isuspense account
Susan Rudkin case study: Letter from IPOL-0056895
129
POLO0061521
[Rudkin re: Suspense account query
Letter from Paul Hemley to EM iPOL-0058000
1130
IPOLO0065265
Report for Ibstock Post Office Branch
[Susan Rudkin case study: incident IPOL-0061744
132,
IPOLO0051044.
Rasool in re to Michael and Susan
Rudkin {Ibstock) Leicester post
loffice.
[Email from Jarnail A Singh to Tahira IPOL-0047523
132
IPOLO00S9762
IHowards, Re: Urgent Advice needed-
Flag Case FCT728
Email from Glenn Chester to Sarah —_[POL-0056241
133
IPOLO0044916
Ire: Requesting withdrawal of
suspension & prosecution
jLetter from Mr Michael Rudkin to POLIPOL-0041395,
Page 49 of 50
WITN08900100
WITNO8900100
134 IpoLooo60421 lLetter from E M Rudkin to Mr Goerge IPOL-0056900
[Thomson re: Private, In the Strictest
(Confidence and without Prejudice.
(435 IPOLO00S0242 7 Restraint Order Prohibiting Disposal IPOL-0046721
lof Assets - Susan Jane Rudkin
1136 IPoLo00s1380 lsusan Rudkin case study: Memo from IPOL-0047859
Rob Wilson to Fraud Team cc Mike
Wilcox, Ged Harbinson and Press
[Office re: Rv Susan Jane RUDKIN -
report on final result
1137 jPOLO0052020 STATEMENT OF INFORMATION IPOL-0048499
IRELEVANT IN ACCORDANCE WITH
SECTION 16 (3) OF THE PROCEEDS OF
(CRIME ACT 2002, REGINA V SUSAN
JANE RUDKIN-
138 IPOLO00S2094 STAFFORD CROWN COURT - POL-0048573
(CONFISCATION HEARING - 21st
AUGUST 2009, THE QUEEN v SUSAN
JANE RUDKIN, BRIEF TO COUNSEL
IFOR THE PROSECUTION
1139 IPOLOOOSS156 lLetter from Charlotte Knight to Mr _[POL-0051635
‘Singh, Re: R v Susan Jane Rudkin-
IOutstanding Confiscation Order-
129.894.15 Deadline for payment
ednesday 18 August 2010
(1440 IPOLOG0SS203 Letter from Jarnail Singh to Charlotte IPOL-0051682
Knight, re: Regina v Susan Jane RudkinI
lOutstanding Confiscation Order
1441 {POLOO057602 Financial Investigation Events Log, IPOL-0054081
POLTD/0809/0101 Susan Rudkin
442 IPOL00052029 Letter from Jarnail Singh to Messrs [POL-0048508
Richard Nelson Solicitors re: Regina v
Susan Jane Rudin Stafford Crown
{Court Confiscation Hearing - 21st
August 2009
Page 50 of 50