WITNO08950100
WITNO08950100
Witness Name: Kevin Ryan
Statement No: WITN08950100
Dated: 16 November 2023
POST OFFICE HORIZON IT ENQUIRY
FIRST WITNESS STATEMENT OF KEVIN RYAN
I, Kevin Ryan, will say as follows —
1. I have made this witness statement to assist the Post Office Horizon Inquiry (the
“Inquiry”) with the matters set out to me in the Rule 9 Request dated 18 October
2023 (the “Request”). The Request contains 60 questions, which I have
considered and addressed within this statement. I would like to make the Inquiry
aware that I have received legal assistance to produce this statement from my
solicitor, Mr lan Manners of Ashfords LLP. When seeking to obtain assistance
from Ashfords LLP, I was assisted by the Post Office Limited (POL) with the initial
stage of confirming the availability of insurance coverage, to cover the associated
legal costs.
2. I confirm that everything that I include in this statement is to the best of my
recollection of matters. There have been instances where I have not been able to
recall something due to the amount of time that has passed and, therefore, I have
Page 1 of 59
WITNO08950100
WITNO08950100
had to rely on a document provided to me. Where this is the case, I have ensured
to indicate this clearly.
Background
3. 1am currently employed by POL as a Security Manager and I have worked within
the organisation for almost 40 years in many different roles. I would like to flag
to the Inquiry that the Request refers to me joining the POL Security Team in
2011 and being and Investigation Manger from 1998 to 2011, however, this is
incorrect.
4. I first joined POL in February 1985 as a Counter Clerk at a branch in Liverpool
and I stayed in this role for 5 years until August 1990. From this point until June
1991 I held various acting Branch Manager roles in a number of Post Offices on
Merseyside. I was then appointed to the Assistant Branch Manager role at
Prescot Post Office until March 1995. I was then a National Training Coordinator
for POL between March 1995 and August 1997, which involved the scheduling of
relevant classroom and in-branch training for new Subposmasters (SPMs). This
training was delivered to SPMs by POL National Field Trainers and would relate
to the role of a SPM. I then became a National Field Trainer myself in August
1997, and I would deliver this necessary training to SPMs in classrooms and at
branches all over the UK. I stayed in this position until March 2005, and then went
on to become an Area Intervention Manager for the North West Region. This was
for a period between April 2005 and August 2006 and it entailed working under a
Retail Line Manager and going in to branches to resolve issues such as balancing
difficulties and non-compliance to procedures. I cannot recall for certain, but I
Page 2 of 59
WITNO08950100
WITNO08950100
think that these issues would have been relayed to me by the Retail Line Manager
I was working under, who I believe would have obtained that information from
data analysis produced by Chesterfield (the POL central finance department),
customer complaints via the helpline, area managers, clerks or SPMs themselves
following self-reporting of issues via the POL helpline.
. In September 2006 I became a Business Development Manager for POL, initially
covering branches in the Mansfield and Nottingham areas before moving to the
Liverpool and Warrington areas. This role involved assisting SPMs with driving
sales of Post Office Products and services. I stayed in this position until March
2010 and then moved on to become a Horizon Migration Manager in April 2010
for a short period until early to mid-August 2010. During this role I worked on a
National POL project which involved the roll out of the new generation Horizon
software system. I would go out to branches on the day they were due to undergo
the relevant update of the Horizon system to ensure that the update ran smoothly.
This was an overnight download of software.
. Later in August 2010 I became a Transitional Manager within POL, when the
previous project ended. This was not a specified role as such - it was simply a
position whereby I remained employed by POL until a suitable role came up to
apply for internally. If a suitable role did not come around I was able to take
voluntary redundancy instead. After some time in this position I was initially going
to opt for redundancy, but around December 2010 vacancies were advertised on
the POL internal systems for Security Managers within the POL Security Team. I
recall that the job description set out that the role would entail a combination of
Page 3 of 59
WITNO08950100
WITNO08950100
Fraud Investigation and Physical Security. I decided to apply for the job and I
was invited to a question and answer style interview. Shortly after the interview I
was told I was successful in obtaining the role and I went on to start in late January
2011.
. I cannot recall if any specific pre-training or expertise was required in order to
apply for the role of a Security Manager, but I believe that my wide experience of
working in various POL roles by this time most likely went in my favour when
applying for the position. At the point I became a Security Manager I had been
with POL for 26 years but I had not gained any experience in investigations or
physical security.
. In terms of initial training for my role as a Security Manager, I recall going on a3
week course at some point in February 2011 which was delivered by Paul
Whitaker and Paul Southin (who were Security Managers for Royal Mail). I
remember that the course covered numerous topics including interviewing under
caution, the Police and Criminal Evidence Act 1984 (PACE), Conducting
Searches, taking statements, gathering evidence, writing investigation reports
and putting investigation case files together. There were likely more topics
covered, but these are the main ones that I can recall. I deal with this in further
detail later in this statement.
. I understood at the time that the investigation side of the Security Manager role
involved looking into potential fraud or crimes committed within POL I knew that
this entailed interviewing suspected offenders, conducting searches of premises
Page 4 of 59
WITNO08950100
WITNO08950100
(if necessary), gathering evidence and putting together case files for submission
to the POL Legal Team. In terms of the Physical Security side of the role, I
understood that this involved implementing necessary security measures
following robberies and burglaries at branches, as well as general equipment
deployment to ensure security in branches and cash in transit centres, such as
alarms, CCTV and any other security equipment available. I would like to flag to
the Inquiry that during the years that I have been a Security Manager for POL, I
have carried out much more physical security work than investigatory work.
10.When I first became a Security Manager, I reported to a Team Leader. The Team
Leader that I reported changed many times over the years and I cannot recall
every single Team Leader that I have had, nor when they changed. I do remember
at some point the following individuals have been my Team Leader - Leslie
Frankland, Keith Gilchrist, Simon Hutchinson, Helen Dickinson and Simon Talbot.
1
a
. At some point in July 2013 I temporarily stepped in to a Team Leader role, during
which I had to report to a Senior Security Manager, who I think was Andrew
Hayward at the time. I was asked to cover the role temporarily when the current
Team Leader (Keith Gilchrist) left until a permanent replacement was found.
During my short time as a Team Leader I think I had around 3 or 4 Security
Managers reporting to me, The ones I can recall are Mike Stanway, Steve
Bradshaw and Robert Daily. I do not recall providing any in-depth supervision to
those Security Managers, but I do remember doing some of their performance
reviews and conducting one-to-one meetings with them. I note that
[POL00129337] shows a one-to-one meeting I conducted with Robert Daily, and
Page 5 of 59
WITNO08950100
WITNO08950100
[POL00136728] shows a one-to-one meeting I conducted with Steve Bradshaw.
I stepped back down to the position of Security Manager at my own request after
6 or 7 weeks and I have not had anyone report to me since.
12. In all of my time working within POL’s Security Team, I have never had any reason
to doubt the competence or professionalism of any Team Leaders, Senior
Management or other colleagues. I have always believed that everyone has been
highly professional and competent throughout my career within POL.
13.When an investigation was carried out, Security Managers would be required to
complete disciplinary reports as part of the case file, which were then passed to
the Contract Manager dealing with the branch and SPM involved. It would then
be the Contract Manager who would make a decision as to whether the SPM
would be suspended or not if this had not already been done. Security Managers,
including myself, had no involvement in this disciplinary process other than
providing this report.
14. In terms of interviewing suspected offenders, this was part of my Security
Manager role, however, it would be the Lead Investigator who would ask the
majority of questions when interviewing a suspect. I was only a Lead Investigator
on a small number of cases before it was decided that POL would no longer
pursue any new prosecutions. I believe this change came in late 2013. I was a
2nd officer more often in cases, meaning that I would attend interviews to assist
the Lead Investigator. I would then have either no or minimal further involvement
Page 6 of 59
WITNO08950100
WITNO08950100
in that case. I deal with this in further detail when addressing questions on the
prosecutions of Mr Khayyam Ishaq, Angela Sefton and Anne Neild below.
15. As far as I can recall, it was Lead Investigators on cases who would have
assisted with disclosure in criminal proceedings. In the small number of cases
where I was a Lead investigator, I would have been involved in gathering
evidence for disclosure and providing it to POL’s Legal Team to be reviewed and
disclosed to the defence. I do not believe I had involvement in directly providing
disclosure the defence — it would be the POL legal team who would do this. In the
cases where I was a 2nd Officer, I would not have been involved in the disclosure
process at all.
16. I am not aware what litigation strategy is and I do not think it is something I would
have been involved in.
17.1 do not believe I would have had any liaison with other POL departments when I
was a 2nd Officer in respect of progressing cases. However, where I was a Lead
Investigator on a matter I would have liaised with the relevant Contract Manager
to let them know when it was decided whether a prosecution would be pursued
or not and to keep them updated on the progress. I would do this because the
Contract Manger would often want to know this information before making a
decision to terminate or reinstate a suspect. By this point the Contract Manager
would have likely already suspended the particular suspect. Unfortunately, I
Page 7 of 59
WITNO08950100
WITNO08950100
cannot remember any specific examples of me doing this but I do recall that it is
something I did.
18. I would also have liaised with POL’s Legal Team when my casefile had been
passed across to them. For example, I would have liaised with the Legal Team
when gathering disclosure which was included as part of the casefile or about
obtaining further evidence if they requested this. I do also remember occasionally
liaising with POL Financial Investigators, to inform them about the background of
a case if they were taking it on to progress from a recovery standpoint.
The Security team’s role in relation to criminal investigations and prosecutions
19. I confirm that I have reviewed the following documents, but I would like to flag to
the Inquiry that the majority of them were produced before I joined the Security
Team in January 2011:
i) Casework Management Policy (version 1.0, March 2000)
([POL00104747)) and (version 4.0, October 2002) ([POL00104777));
il) Rules and Standards Policy (version 2.0, October 2000)
({[POL00104754)).
iii) “Investigation Procedures Policy (version 2.0, January 2001)
([POL00030687});
iv) Disclosure Of Unused Material, Criminal Procedures and
Investigations Act 1996 Codes of Practice Policy (version 1.0, May
2001) ([POL00104762});
Page 8 of 59
WITNO08950100
WITNO08950100
v) "Royal Mail Group Ltd Criminal Investigation and Prosecution Policy"
(1 December 2007) ({[POL00030578], which appears to be
substantially the same as the policy of the same date with a variation
on the title at [POL00104812)) (see, in particular, section 3);
vi) Royal Mail Group Security - Procedures & Standards - Standards of
Behaviour and Complaints Procedure" (version 2, October 2007)
([POL00104806));
vii) "Royal Mail Group Crime and Investigation Policy" (version 1.1, October
2009) ([POL00031003});
viii) "Post Office Ltd - Security Policy - Fraud Investigation and Prosecution
Policy" (version 2, 4 April 2010) ([POL00030580));
ix) "Post Office Ltd Financial Investigation Policy" (4 May 2010)
([POL00030579));
x) Royal Mail Group Security — Procedures & Standards: “Appendix 1 to
P&S 9.5 Disclosure of Unused Material & The Criminal Procedure &
Investigations Act 1996” (Version 1, July 2010) ([POL00104848));
xi) Royal Mail Group Security — Procedures & Standards: “Committal &
Summary Trial Papers & Processes” (Version 1, July 2010)
([POL00104837));
xii) "Royal Mail Group Security - Procedures & Standards - The Proceeds
of Crime Act 2002 & Financial Investigations" (version 1, September
2010) ([POL00026573));
xiii) "Royal Mail Group Security - Procedures & Standards - Initiating
Investigations" (September 2010) ([POL00104857]);
xiv) "Royal Mail Group Ltd Criminal Investigation and Prosecution Policy"
Page 9 of 59
xv)
xvi)
xvii)
xviii)
xix)
xx)
xxi)
xxii)
xxiii)
xxiv)
xxv)
WITNO08950100
WITNO08950100
(version 1.1, November 2010) ([POL00031008));
Post Office Ltd Financial Investigation Policy (version 2, February 2011)
([POL00104853));
Post Office Ltd Anti-Fraud Policy (February 2011) ([POL00104855)):
"Royal Mail Group Policy Crime and Investigation S2" (version 3.0, April
2011) ([POL00030786));
“Post Office Ltd PNC Security Operating Procedures” (August
2012) ([POL00105229));
"Post Office Limited: Internal Protocol for Criminal Investigation and
Enforcement (with flowchart)", (October 2012) ([POL00104929));
"Undated Appendix 1 - POL Criminal Investigations and Enforcement
Procedure (flowchart)", (October 2012) ([POL00105226));
The undated document entitled “POL — Enforcement & Prosecution
Policy’ ([POL00104968));
"Post Office Limited: Criminal Enforcement and Prosecution Policy"
(undated) ([POL00030602));
"Conduct of Criminal Investigations Policy" (version 0.2, 29 August
2013) ([POL00031005));
"Conduct of Criminal Investigations Policy" (version 3, 10 February
2014) ((POL00027863)).
"Conduct of Criminal Investigations Policy" (September 2018)
([POL00030902)).
Page 10 of 59
WITNO08950100
WITNO08950100
20.1 do not recall seeing any of the first 21 documents listed in paragraph 19 above,
prior to receiving these from the Inquiry. It may be that some of those 21
documents that were dated later (such as in 2009 and 2010) were provided to me
when I joined in 2011, however, due to the passage of time I cannot confirm this
for certain.
2
.I note that document [POL00105229] relates to Police National Computer Access
(PNC) access, which I believe allowed a user to see if a suspect had previous
convictions or pending prosecutions. PNC access was obtained by the Post
Office Security team not long after I joined and I do recall this document being
circulated at some point early on in my Security Manager career for reading.
However, I had no real use of this document other than as a guide for requesting
information because I did not personally have PNC access, as it was strictly
limited. Access to this was limited to the Post Office Security admin team based
in Chesterfield and if required we would request information from them that had
to be authorised. This would be authorised by a Security Operations Team Leader
or Senior Security Manager.
22. I do also recall the following documents being circulated, but I cannotremember
exactly when, nor who circulated them: [POL00104929], [POL00105226],
[POL00031005), [POL00027863), [POL00030902).
23. What I can confirm is that I had no involvement in the development of any of the
documents and polices listed in paragraph 19 above.
Page 11 of 59
WITNO08950100
WITNO08950100
24. I have been asked to describe the Organisational Structure of the Security Team.
I am aware that that the Physical Security Team and the Fraud and Crime
Investigation Team used to form two separate sections to the Security Team.
When I joined the Security Team in 2011 as a Security Manager, these roles
merged and became to be known as the Security Operations part of POL’s
Security Team. At this tine Security Operations consisted of three teams which
were responsible for geographical areas in the UK (North, Midlands and South).
Each of the teams had a Team Leader and approximately 18-20 Security
Managers based across the country for each geographical area. This has
changed as the years have gone by as the number of Security Managers has
gradually reduced to its current level of 8 Security Managers covering the whole
of the UK and only 1 Team leader. In terms of other sections to the Security Team,
I do recall that there was a Financial Investigation Team, a Commercial Security
Team and an Casework Team in the earlier years of my Security Manager career.
I cannot recall what any of the other sections of the POL Security Team were, but
I believe when I first started there were 4 or 5 different sections.
25. I believe that internal POL Investigation Policies governed the role and conduct
of Security Managers that were carrying out investigations. As mentioned above,
I believe that I have only seen later polices released around and after 2011. In
particular, I remember often referring to the flow charts in [POL00104929] and
[POL00105226] when I was still relatively new to the role, as I found them to be
a useful resource. I recall that there were changes over time to internal POL
procedures and policies, as the number of investigations carried out were
reduced over the years, however, I cannot recall what these changes were. In
Page 12 of 59
WITNO08950100
WITNO08950100
terms of legislation the main legal frame work that governed the conduct of
investigations was the Police and Criminal Evidence Act 1984 (PACE) and the
Regulation of Investigatory Powers Act 2000 (RIPA). There was likely other
legislation we were required to be aware of in addition to PACE and RIPA, but I
cannot recall what they were.
26.1 confirm that I have considered [POL00104900], [POL00105191],
[POL00123309] and the attachments at [POL00123310], [POL00123311] and
[POL00123312]. I cannot recall seeing these documents before they were
provided to me with the Request and I did not have any involvement in the
development of investigation policies within POL post-separation. I do not recall
separation having much of an impact on the way investigations were conducted,
however, I had only just been appointed as a Security Manager as separation
took place so I may not have noticed or realised any differences.
27. I do not recall ever having a complaint being raised about the conduct of an
investigation by the Security Team so I am not aware of what the process relating
to complaints would have been. I expect any complaint would have been raised
upwards to the Head of Security via Senior Security Managers.
28. Supervision was regularly provided through Team Leaders to Security Mangers
conducting criminal investigations. Team Leaders would check in with the
Security Managers and provide support if it was required and chase for updates
on matters. They would also double check case files before they were sent over
Page 13 of 59
WITNO08950100
WITNO08950100
to POL’s Legal Team to make sure they were in order and that all required steps
had been followed.
29.1 do also recall when I first started to take on my own investigations, I had a mentor
who would be my 2"¢ Officer at the interviews I conducted and provide guidance
and support with the next steps to take and with running the casefile in general. I
had this mentor until I was experienced enough to independently conduct
investigations as a Lead Investigator. My mentor was Steve Bradshaw.
30. I do not recall there ever being a difference to the policy and practice regarding
the investigation and prosecution of Crown Office employees in comparison to
SPMs, their managers and assistants.
Audit and investigation
31.1 have considered the document “Condensed Guide for Audit Attendance”
(version 2, October 2008) at [POL00104821]. After joining the Security Team in
2011 I only attended at a small number of POL audits. One reason for attending
was due to a significant shortage being reported during a routine audit at a
branch. If it was geographically feasible my Team Leader would ask me to attend
on the day to begin investigating the issue as an open enquiry. Sometimes the
location of the branch would make it impossible to attend at the time of the audit
and I would have to arrange attendance on an alternative date (most likely the
following day).
Page 14 of 59
WITNO08950100
WITNO08950100
32. There were also occasions where I was given pre notice to attend an audit which
was going to be raised due to suspicious activity being identified (for example,
Chesterfield spotting potential fraudulent activity via their data analysis of
transactions at a branch or customers (service users reported suspicions
activities in relation to their accounts).
33.In both of these examples, the role of the Security Manager when attending an
audit was to speak to the auditors to find out what had happened and if necessary,
request an interview with the SPM, request permission to carry out searches of
the SPM’s home address, and gather all available documents on the day that may
be relevant to the matter. This would include reports produced on Horizon by an
auditor as part of all audits. Interviews with a suspected offender would not always
be done on the day of the audit as sometimes the SPM would request a Post
Office friend or a solicitor to be present as was their right. If this was the case we
would arrange with the SPM a date to interview them in the near future.
34. Where a shortfall was identified following an audit of a Post Office branch, a
Team Leader would determine whether an investigation into potential criminality
was conducted by the Security Team or whether the case should be taken
forwards as a debt recovery matter by the Financial Services Centre, the Contract
Manager or the relevant legal team. If it was decided that a criminal investigation
would be pursued, the Team Leader would then allocate the investigation to a
Security Manager to run.
Page 15 of 59
WITNO08950100
WITNO08950100
35.1 believe that Contract Managers had no involvement in relation to the decision
on whether to pursue a criminal investigation or not. They dealt purely with
disciplinary and contract matters. They would make a decision on whether the
SPM would be suspended or not, and in the long term whether they would be
terminated or reinstated depending on the circumstances. This was the case
when I joined the Security Team in 2011 and it did not change.
36. I do not know what factors determined a Team Leader's decision to go down the
criminal investigation route when an audit shortage or suspected fraud was found
at a branch, but I imagine the severity of the loss faced by POL as a result would
be one factor. When I first joined the Security Team I recall that almost all
significant shortages were raised as a criminal investigation, but I cannot
remember if there was a minimum figure to determine this action. I believe the
level of loss required to trigger a criminal investigation did change over time but I
do not know the precise details of this. As time went on, less and less cases were
being taken down the criminal investigation route. I believe from late 2013 only a
few new investigations were raised. Any ongoing continued until the cases came
to a close.
37. Once a decision had been made to conduct a criminal investigation, the process
conducted by Security Managers during the initial investigation is contained in
the flow charts at [POL00104929] and [POL00105226]. I do recall that the
process differed slightly in some respect depending on the type of case. For
example, where there was pre-notice given of a potential shortage (for example,
a suspected fraud notified by Chesterfield, POL service users or branch
Page 16 of 59
WITNO08950100
WITNO08950100
employees) which resulted in an audit being scheduled, Security Managers would
speak to the necessary individuals and POL departments from the outset, such
as the relevant Contract Manger, Auditors and Chesterfield to establish as much
background information about what had been occurring at the branch. All relevant
data would be obtained such as Call Logs, Credence Data, Cash Holdings Data,
Transactional Correction data, and if an audit had already taken place, a copy of
the audit report and all relevant audit documentation. All of this information would
be studied ahead of any interview taking place with the suspected offender and
would be referred to during such interview. Any activity undertaken would also be
recorded on an event log.
38. Where a shortage was discovered following a routine audit and your Team Leader
allocated the case to you to investigate as Lead Investigator, a Security Manager
would attend the branch on the day if geographically possible, usually with at least
one other Security Manager to assist as 2™ officer. On arrival to the branch
Security Managers would speak to the Audit Team to get some background
information and would gather all the available information and documentation
available on the day such as Horizon reports obtained as part of the audit or any
documents that may help explain the shortage. Shortly after arrival Security
Managers would also speak to the SPM, assistant or staff member suspected of
an offence to inform them why they are there, explain their legal rights, request
permission to carry out a search if necessary, and arrange for an interview to take
place. Sometimes a suspected offender would request a Post Office Friend or
solicitor to be present at an interview, meaning the interview could not be carried
out on the same day. As mentioned above, in this scenario an interview would
Page 17 of 59
WITNO08950100
WITNO08950100
arranged in the near future. During an interview the Lead Investigator would ask
a suspected offender questions to try and establish what had happened to the
lost funds.
39.Security Mangers who were the Lead Investigator on a case would always write
up a report following the initial stages of any investigation being completed and
this would go on the casefile with all other evidence obtained. As explained earlier
in this statement, the Team Leader would review the case file before it was then
passed on to the POL Legal Team for consideration. At the end of the report there
was a conclusion section where a summary could be provided in relation to what
the facts pointed to (for example, potential theft or false accounting).
40. Once a casefile had been sent across to the POL Legal Team, they would come
back on occasion to suggest that further evidence was required. In these
circumstances, the Security Manager who was the Lead Investigator responsible
for the matter would have to gather this further evidence.
De ns about prosecution and criminal enforcement proceedings
41. So far as I can recall, the POL Legal Team would make a recommendation as to
whether or not a matter should proceed to prosecution after they reviewed the
casefile and this would then be passed to Cartwright King and they would put
forward the charges they believed to be relevant. I believe that this
recommendation would then be passed on to the Senior Security Manager to sign
off as the prosecuting officer. When I joined the Security Team in 2011 this was
Page 18 of 59
WITNO08950100
WITNO08950100
Dave Pardoe. They would make comment on the case file before it was returned
to the Lead Investigator. I believe that as things changed all case files were also
being sent to the Head of Security, John Scott.
42.1 do not believe that an SPM’s local Contract Manager had any input in relation
to decision of whether to prosecute or not. As explained above, they dealt purely
with disciplinary matters in the case.
43.1 do not know what test was applied by those making prosecution and charging
decisions — Security Managers had no involvement in this. I also do not know
what advice, legal or otherwise, was given to those making decisions around
prosecution and charging.
44. The steps taken to restrain a suspect's assets by criminal enforcement methods
such as confiscation proceedings was a matter dealt with by the POL Financial
Investigators. Security Managers also had no involvement in this other than
providing information gained as part of the investigation and interview, so I am
not aware what these steps might have been. I know that casefiles would be
handed over to the Financial Investigators to pursue in relation to recovery of
losses and sometimes we would discuss the background of the case with them,
but I do not have any knowledge in relation to the basis upon which they would
proceed with enforcement. I also do not know if it was the Financial Investigators
who would directly decide whether criminal enforcement proceedings should be
pursed or whether they liaised with the POL Legal Team to this regard. During
Page 19 of 59
WITNO08950100
WITNO08950100
my time in the POL Security Team, I believe the Financial Investigators were
Dave Posnett and Helen Dickinson.
Tra
45. As mentioned earlier in this statement, when I joined the Security Team in 2011
I went on a 3 week training course. This is course is mentioned in the feedback
document at [POL00129182]. I cannot recall every topic that was taught during
this course but I believe that we covered PACE, interviewing, taking witness
statements, conducting searches, obtaining evidence, drafting investigation
reports and putting casefiles together. My training continued immediately after
this through mentoring received from Steve Bradshaw and shadowing more
experienced Investigators on cases. I believe that my knowledge and skills in
relation to the abovementioned topics were further developed through receiving
mentorship and through shadowing colleagues. I also believe I would have
learned when to seek relevant evidence from third parties and what my disclosure
obligations were through mentorship and shadowing.
46.1 confirm that I have considered the following documents:
i) The feedback in respect of an investigation workshop, dated 2011 at
[POL00129182];
ii) The email from Tony Newman to me at [POL00126612];
iii) The email from Dave Posnett to me and others, dated 22 March 2013,
at [POL00129310] and invitation at [POL00129311];
Page 20 of 59
WITNO08950100
WITNO08950100
iv) The email from Rob King to me and others, dated 25 June 2013, at
[POL00122529] and attachment at [POL00122526];
v) The email from Rob King to me and others, dated 21 July 2013 at
[POL00122557] and the attachments at [POL00039970],
[POL00122559] and [POL00122560);
vi) The email from Rob King to me and others, dated 20 September
2013, at [POL00122897];
vii) The email chain including me at [POL00127081);
viili)The email from Andrew Wise to me and others, dated 11 November
2013, at [POL00123042];
ix) The email from Andrew Wise to me and others, dated 25 April 2014, at
[POL00123282]
47.As can be seen from [POL00126612], there was a development process in place
to provide ongoing refresher training to Security Managers on a range of topics.
Unfortunately, I cannot remember any precise details of this training.
48.[POL00129310] and [POL00129311] above relate to an invitation to a training
day run by Cartwright Kind Solicitors. I can recall that Cartwright King Solicitors
started to run and deliver useful training for the Security Managers in around
2013. [POL00122526] is a guidance document produced by Cartwright King for
Security Managers.
49.1 can see that [POL00122557] is an email from Rob King with attachments sent
to my personal email. The attachments [POL00122560] and [POL00039970]
appear to be case file review policy and guidance documents and
Page 21 of 59
WITNO08950100
WITNO08950100
[POL00122559] is a process map which shows the different modes by which
cases came into the Security Team. I cannot remember receiving this email, but
I do vaguely recall the attachments. At that time I may have forwarded Rob King’s
email to my personal account to enable me to print and review the documents
attached at home when working away from the office. So far as I can recall I
attended the meeting mentioned in the email and it was to go through the
documents attached to the email that were to be distributed to Security Managers.
50.1 can see that the email at [POL00122897] relates to the documents circulated
ahead of another training day delivered by Cartwright King Solicitors. I believe
that I did attend this training but I cannot recall the precise details of it.
51.The email chain including me at [POL00127081] was an invite to a training
workshop relating to Security Skills which I believe all Security Managers,
including myself, attended. I don’t recall the specific details of the training
provided in this workshop.
52.1 confirm that I have also considered the following documents:
i) The Casework Management document at [POL00104747] (version 1.0,
March 2000) and [POL00104777] (version 4.0, October 2002);
ii) Dave Posnett’s email dated 23 May 2011 at [POL00118096] and the
documents contained within the attached
ii) compliance zip file at [POL00118108], [POL00118109},
[POL00118101], [POL00118102], [POL00118103], [POL00118104],
[POL00118105), [POL00118106] and [POL00118107].
Page 22 of 59
WITNO08950100
WITNO08950100
53. I do not recall ever being provided with the 2000 or 2002 version of the Casework
Management Documents mentioned above. This is probably because I didn’t join
the Security Team until 2011 and by then the documents were quite old. I have
reviewed the guidance given in the second, third and fourth bullet points on page
2 of the 2000 version and the first, second and third bullet points on page 2 of the
2002 version, and my understanding of those points is that if Horizon Bugs or
errors were discovered or reported during the course of an investigation, this
should be disclosed. This point is also included in a 2013 guide introduced post-
separation, which I have seen previously - [POL00031005]. Even though this is
what I understood, I do not recall ever having any issues or errors with the Horizon
system being reported to me. We were always assured by POL and Fujitsu that
the Horizon system was robust.
54. Not long after I joined the Security Team in 2011 Security Managers were advised
that case files were going to be subjected to compliance checks to ensure
uniformity and that all the necessary steps in matters were being completed
correctly. I remember that there was a compliance checklist that was completed
by a Team Leader when your case file was passed over for review, Your Team
Leader would give you a score following the completion of each section of the
investigation/case file.
55. I did not play any role in relation to the development or the management of the
documents circulated in the email from David Posnett dated 23 May 2011 at
[POL00118096].
Page 23 of 59
WITNO08950100
WITNO08950100
56.1 have reviewed paragraph 2.15 of the document entitled “Guide to the
Preparation and Layout of Investigation Red Label Case Files — Offender reports
& Discipline reports” ([POL00118101]. I understood this to be an instruction to
record any failings discovered during an investigation (whether this be a security
issue such as theft, fraud, incompetence, lack of supervision by a SPM over staff
at the branch, or issues with a transactional process). If I had been aware of any
failings in relation to Horizon Bugs and Errors during my investigations then I
believe I would have reported this too, but I had never come across such failings
during an investigation. As well as making a Team Leader aware I would imagine
this would be entered into the Offender Report pre-amble that formed part of the
case file. If these were known I would understand them to be disclosable.
57.1 believe the Offender Report template at [POL00118102] was contained at the
front of a casefile, but due to the passage of time I cannot recall completing one
of these, but I expect that I would have done so.
58.1 have no knowledge of who drafted the “identification codes” document at
[POL00118104] and having reviewed it I consider it to be a disgrace. I do not
recall ever seeing this document before. Security Managers used identification
codes for reporting offences following prosecution and these were recorded using
the NPA0O1 at interview, and NPAO2 at conviction. If there was a conviction, I
believe this this information would be entered on to the Police databases. If no
conviction was obtained, the information would remain on the casefile.
Page 24 of 59
WITNO08950100
WITNO08950100
Analysing Horizon data, requesting ARQ data from Fujitsu and relationship
with Fujitsu
59. At some point in 2013, I recall that a new set of interview questions were provided
to Security Mangers to cover in an interview with SPMs, which related to whether
the SPM had faced any difficulties with Horizon and the training they had around
the system. I cannot remember if I ever worked on a case prior to 2013 where a
SPM had attributed a shortfall to issues with Horizon. When the new interview
questions were introduced in 2013, if the SPM did raise any issues with Horizon,
Investigators would have to report this in the case file and were required to
request ARQ data for the relevant period. ARQ data is provided by Fujitsu and it
reports every transaction or entry made on Horizon at the branch for the time
period requested. I do not recall doing this on many occasions.
60.1 do vaguely remember a case I worked on based in Newcastle where a SPM had
attributed a shortfall to issues with Horizon and I had to request 2 months’ worth
of ARQ data. I can remember going through this data to rebuild the balances to
see if I could identify any issues and I do not believe I found anything. I cannot
remember the precise details of this case, including who the SPM was or when
the case was. As far as I recall, Fujitsu would not have gone through this data in
this case, but I cannot confirm this for certain. I am also unsure if they did on other
cases.
Page 25 of 59
WITNO08950100
WITNO08950100
61.In any case, Security Managers would use a variety of data including Credence,
HORACE and ARQ data to investigate a shortfall whether an issue with Horizon
was raised or not. So far as I am aware, Credence and HORACE data is
transactional data pulled from Chesterfield data, reporting transactions and other
information entered onto Horizon such as transfers and cash declarations. I was
able to view Credence but had to request HORACE data from the PO Security
admin team. The type of data that Security Manager's requested was dealt with
on a case by case basis.
62.1 do not know if ARQ data was requested as a matter of course on all matters
where a shortfall was attributed to problems with Horizon. I did not have sight of
cases dealt with by other Security Managers and can only comment on my own.
I believe that I only had to request ARQ data for this specific reason on one
occasion, as detailed in paragraph 60 above.
63. I am not aware if ARQ data was provided to SPMs in cases where they had
attributed a shortfall to problems with the Horizon system. I do not recall this ever
happening in any of my cases, but it may have occurred on matters dealt with by
other Security Managers. I do not know for certain.
64. Whenever I did require ARQ data on a matter, I do not recall ever requesting this
data directly from Fujitsu — I believe that I always asked our admin team to request
it from Fujitsu for me. I do not think I ever spoke with Penny Thomas or Gareth
Jenkins from Fujitsu to this regard.
Page 26 of 59
WITNO08950100
WITNO08950100
65.1 understood that Gareth Jenkins was a subject matter expert from Fujitsu who
would provide evidence on whether the Horizon System was working as it should
in cases. I do not recall ever having any advice or assistance in relation to the
rules governing independent expert evidence. This is probably because Gareth
Jenkins was never required to give evidence in any of the cases I took on as Lead
Investigator.
Relati a
66. Other than attending a few training session at their offices in Birmingham around
2013, I had very little involvement or interaction with Cartwright King Solicitors.
They were the external lawyers that the POL Legal Team would instruct on
matters to provide advice and representation. Very few of my cases got to the
stage where Cartwright King’s involvement was required. Due to the passage of
time, I cannot remember which of my cases did get to that stage, nor who the
main contacts I would have liaised with. The two main contacts I remember from
attending training at Cartwright Kings is Martin Smith and Andrew Bolc.
Prosecution of Mr Khayyam Ishaq
67. I confirm that I have considered the following documents:
i) The Typed copy of Notebook Entry dated 7 April 2011 at
[POL00046313);
ii) The Record of Taped Interview of interview on 7 April 2011 (11.11 to
11.53) at[POL00046349]:
iii) The Record of Taped Interview of interview on 7 April 2011 (12.11 to
12.55) at[POL00045133]
Page 27 of 59
WITNO08950100
WITNO08950100
iv) The Investigation Report dated 13 May 2011 at [POL00046224]
v) The memo to the National Security Team dated 18 May 2011 at
[POL00046228);
vi) The memo to the National Security Team dated 5 July 2011 at
[POL00056596);
vii) The further memo to the National Security Team dated 5 July 2011 at
[POL00056600);
viii) The Typed copy of Notebook Entry dated 27 September 2011 at
[POL00065000);
ix) The Summary Record of Taped Interview of interview on
27 September 2011 at [POL00057985);
x) The Investigation Report dated 3 October 2011 at[POL00057078);
xi) The Advice and Draft Charge dated 23 March 2012 at[POL00057543];
xii) Your unsigned statement dated 4 April 2012 at [POL00057584);
xiii)The unsigned statement of Stephen Bradshaw dated 4 April 2012 at
[POL00057582];
xiv) The summons dated 13 April 2012 at [POL00046253];
xv) The email from Martin Smith, dated 31 May 2012, at [POL00119452];
xvi) The unsigned statement of Stephen Bradshaw dated 18 June 2012 at
[POL00058024),
xvii) The unsigned statement of Stephen Bradshaw dated 19 June 2012 at
[POL00058035);
xviii) The Defence Case Statement dated 29 August 2012 at
Page 28 of 59
WITNO08950100
WITNO08950100
[POL00046244);
xix) The email from Martin Smith dated 5 September 2012 at
[POL00046243};
xx) The undated Advice on Evidence at [POL00045134];
xxi) The unsigned statement of Stephen Bradshaw dated 27 January 2013
at [POL00046264];
xxii) The unsigned statement of Stephen Bradshaw dated 31 January 2013
at[POL00059592);
xxiii) The unsigned statement of Stephen Bradshaw dated 11
February 2013 at [POL00059686);
xxiv) The signed statement of Stephen Bradshaw dated 20 February
2013 at [POL00046272);
xxv) The addendum Defence Statement dated 20 February 2013 at
[POL00046278];
xxvi) The unsigned statement of Stephen Bradshaw dated 25
February 2013 at [POL00059887];
xxvii) The report dated 21 April 2013 at [POL00046249];
xxviii) The email chain from April 2013 at [POL00060315);
xxix) The Case Closure Reporting report emailed on 14 May 2013 at
[POL00046250).
68.1 would like to flag to the Inquiry that the request indicates that I am listed as the
designated prosecution authority in The Investigation Report dated 13 May 2011
Page 29 of 59
WITNO08950100
WITNO08950100
at [POL00046224]. This is incorrect - I was never the designated prosecution
authority in any case and the document shows that it was David Pardoe who held
this role for this specific case.
69.1 do not remember a great deal about the background of this case and I have had
to rely on the documents provided to help me recall specific details. In terms of
setting out my recollection of the background, I defer entirely to the facts set out
in the Investigation report completed by Steve Bradshaw and dated 3 October
2011 [POL00057078]. Other than my statement at [POL00057584] I had not
previously seen any of the other documents listed in paragraph 67 above as I was
not the Lead Investigator on the case. The Lead Investigator was Steve Bradshaw
— Mr Bradshaw would have requested me to make this statement as a matter of
standard practice, following me assisting him in a follow up interview held with Mr
Ishaq on the 27th September 2011. Such interview is evidenced in
[POL00065000] and [POL00057985].
70. My involvement in the prosecution of Khayyam Ishaq was minimal. I was only the
2"4 Officer at the follow up interview with Mr Ishaq. The role of the 2" Officer is
simply to set up the room for an interview and complete any administrative tasks
required by the Lead Investigator. A 2"? Officer can interject and ask questions if
relevant during an interview but on this occasion I asked no questions of Mr Ishaq.
I had no further involvement in the initial investigation or casefile preparation after
the follow up interview. I did attend court in this matter on one occasion as a
development and training opportunity as at the time I was a relatively new to the
Page 30 of 59
WITNO08950100
WITNO08950100
Security Manager role and I did not have much experience of hearing attendance.
I cannot recall which hearing this was.
71.1 believe that the decision to charge and prosecute Mr Ishaq would have been
made by the POL Legal Team and signed off by David Pardoe as the designated
prosecution authority. I had no involvement in this decision.
72. I have considered the statement in [POL00059686] that the Post Office had
“absolute confidence in the robustness and integrity of its Horizon system and its
branch accounting processes.” I do believe that at the time I would have
considered this statement to be accurate because I recall we were regularly
informed the same by POL in our team meetings.
73. Other than attending the follow up interview as 2™ Officer, providing a witness
statement and observing a court hearing for experience, I had no other
involvement in the case of Mr Ishaq.
74.1 have considered the judgment of the Court of Appeal in Josephine Hamilton &
Others v Post Office Limited [2021 EWCA Crim 577 at [POL00113278]. Due to
my minimal involvement in the case involving Khayyam Ishaq, I do not feel that I
am able to provide useful comment or reflection on the way the investigation and
prosecution was conducted by the Post Office, nor on the outcome of the case.
Page 31 of 59
WITNO08950100
WITNO08950100
Prosecution of Angela Sefton and Anne Neild
75.1 confirm that I have considered the following documents provided to me in
connection with this prosecution:
i) The Audit Report dated 5 September 2012 at [POL00044159];
ii) The notebook entry, dated 6 January 2012 at [POL00044052);
iii) The Record of Taped Interview Summary re interview of Angela Sefton
on 20 January 2012 at [POL00044010] and [POL00057435);
iv) The Record of Taped Interview Summary re interview of Anne Nield on
20 January 2012 at [POL00057389);
v) The handwritten statement from Anne Nield and Angela Sefton at
[POL00043958};
vi) The Investigation Report for Angela Sefton dated 1 February 2012 at
[POL00044198}];
vii) The memo from Maureen Moors dated 2 February 2012 at
[POL00044013]);
viii)The letter from Cartwright King to the Security Team dated 1 March
2012 at [POL00057495);
ix) The calllogs at [POL00118474].
76. Prior to receiving the abovementioned documents I only had a vague recollection
of this case. I have therefore had to rely heavily on the documents provided to me
to remember specific details, and defer to my statement at [POL00044028] for
specific details of my involvement. I recall that Steve Bradshaw was the Lead
Investigator in this matter and I understand that on the evening of 5" January
Page 32 of 59
WITNO08950100
WITNO08950100
2012 Anne Neild had called up Steve and asked to speak with him outside of
work about a matter. Unbeknown to Ms Neild, there was already an audit
arranged to take place at the Fazakerley branch the following day due to
suspicious fraudulent activity being raised by a service user. Steve Bradshaw
called me ahead of the audit and asked me to go into the Fazakerley branch on
the day of the audit to assist him with an investigation. He explained the
background of the circumstances to me and I vaguely remember during this
conversation he informed me that there had been customer complaints about
deposits not being placed into their accounts in a timely manner. When I arrived
at the Fazakerley branch the Audit Team were already present and carrying out
an audit. As confirmed in my witness statement at [POL00044028], I witnessed
Anne Neild hand a letter to Mr Bradshaw which was prepared by both Ms Neild
and Ms Sefton. I learned that the letter stated that they had been supressing
Girobank deposits from customers. I was then directed to a number of Girobank
Deposit slips and cheque envelopes by one of the staff, which had been placed
in a cupboard. I think this was by Ms Sefton but I cannot be certain. There were
around 40 deposit slips and cheque envelopes and I passed these on to Steve
Bradshaw who was also present at the branch. Following the completion of the
audit, a consensual search was carried out at the homes of both Anne Neild and
Angela Sefton. I was present on both searches and I do not recall anything being
seized. I do not believe that any interviews were undertaken on this day.
77.I was then present as the 2"? Officer on 20" January 2012 when Anne Neild and
Angela Sefton voluntarily attended an interview under caution at Bootle Post
Office. As explained earlier in this statement, the role of the 2nd Officer is to set
Page 33 of 59
WITNO08950100
WITNO08950100
up the interview room and complete any administrative tasks required by the Lead
Investigator. A 2"¢ Officer can interject and ask questions if relevant and during
the interview with Angela Sefton I can see that I asked a single question about
whether she had reported shortages to anyone at all, to which she confirmed she
had not. It appears that I did not ask any questions during the interview with Anne
Neild.
78. Following the interviews on 20" January 2012, my only further involvement in this
case was to produce my unsigned witness statement at [POL00044028]. I cannot
recall if I ever produced a signed version of this statement though I would expect
I did. Mr Bradshaw would have requested me to make this statement as matter
of standard practice, to provide an account of me assisting him on the day of the
Audit on 6" January 2012 and with the interviews under caution held with Ms
Neild and Ms Sefton on 20" January 2012. I had no involvement after this in
relation to the casefile preparation, disclosure or seeing the case through the
prosecution.
79.1 confirm that I have reviewed the visit reports contained within [POL00044222]
and [POL00044223]. As indicated earlier in this statement, between April 2005
an August 2006 I was an Area Intervention Manager. I worked under a Retail Line
Manager (who I believe was Paul Williams at the time of these reports) and the
role involved conducting visits to branches to provide support. These visits were
based on requests for assistance logged by branches, or any other issues raised
from within POL such as mails integrity, Opening Hours and Complaints from
customers. As described earlier in this statement, I think that these issues would
Page 34 of 59
WITNO08950100
WITNO08950100
have been relayed to me by the Retail Line Manager I was working under, who I
believe would have obtained that information from a number of sources including
data analysis produced by Chesterfield, area managers, or clerks and SPMs
themselves following self-reporting of issues vial the POL helpline.
80.Due to the passage of time I cannot recall these visits I conducted from direct
memory — I can only rely in what the visit reports say. The visit report dated 14th
September 2005 shows that I conducted a visit following a shortage discovered
by SPMs which the branch believed was due to a change to the Horizon system
or an error in declaring cash. I note that [POL00118474] shows the call logs
where the cash shortage issues were raised, which then led to my visit. It appears
that when I visited the shortage had been corrected due to an error in entering
the ATM figures. Compensating errors can occur if a mistake is made during one
balance period and rectified in the next.
8
=
. The visit report dated 6th February 2006 illustrates that my visit related to a large
shortage reported by the branch. My role in visiting was to go through the balance
documents to see if I could identify if there were any errors in balancing that could
have explained the shortage. I note that there was no mention of Horizon failure
in this visit report.
82.1 would like to emphasise to the Inquiry that my Area Intervention Manager role
was not an investigatory role — I was only there to provide support. I had no
access to the systems and data that Investigators had. I would only go through
documentation in the branch and available on Horizon and information that was
Page 35 of 59
WITNO08950100
WITNO08950100
provided to me in relation to a query raised and I would report back my findings
to wherever the initial visit request was generated from.
83. Other than the above mentioned visits I conducted on 14th September 2005 and
6th February 2006 as an Area Intervention Manger, I have not had any other
previous involvement with interventions at the Fazakerley branch prior to the audit
on 5 September 2012.
84. In terms of the advice received from Cartwright King in relation to this case, I
note that various correspondence from the Cartwright King Team has been
provided with the Request. I would like to flag to the Inquiry that I had never had
sight of any of this correspondence previously and I was unaware of what advice
was given.
85.1 was also not aware of the actions taken by the Post Office following advice from
Cartwright King and what charges appeared on the final indictment in this case,
until I reviewed the following documents provided with the Request:
i) The Summons for Angela Sefton dated 15 March 2012 at
[POL00044030);
ii) The Summons for Anne Nield dated 15 March 2012 at [POL00044033];
iii) The Liverpool Crown Court list showing a PCMH in the case on 25 July
2012 at [POL00058146].
Page 36 of 59
WITNO08950100
WITNO08950100
86.1 note that these documents confirm that a charge of false accounting was brought
against both Anne Neild and Angela Sefton. I had not seen these official
documents before, but I do recall knowing at the time that Ms Neild and Ms Sefton
were being prosecuted. I was not aware of what the charges were but I would
have likely suspected false accounting because from my previous involvement in
the case as a 2" officer I knew they had delayed deposits.
87.1 confirm that I have also considered the following documents provided to me:
i) The list of witnesses relating to R -v- Angela Mary Sefton at
[POL00059525);
ii) The list of exhibits relating to R -v- Angela Mary Sefton at
[POL00059663);
iii) The list of witnesses relating to R -v- Anne Nield at [POL00058291];
iv) The list of exhibits relating to R -v- Anne Nield at [POL00059664];
v) My unsigned witness statement dated 21 March 2012 at
[POL00044028);
vi) The unsigned witness statement of Stephen Bradshaw dated 21 March
2012 at [POL00044027];
vii) The witness statement of Stephen Bradshaw dated 20 September 2012
at [POL00058307];
viii)The unsigned witness statement of Ali Askar dated 1 May 2012 at
[POL00057824];
ix) The Notice of Further Evidence dated 14 February 2013 at
[POL00043965);
Page 37 of 59
WITNO08950100
WITNO08950100
x) The witness statement of Stephen Bradshaw dated 20 December 2012
at [POL00044047] and exhibit SB/52 at [POL00044160);
xi) The unsigned witness statement of Frances Ann Ellis dated 31 August
2012 at [POL00044037];
xii) The unsigned witness statement of Christopher Dixon dated 18
September 2012 at [POL00044038);
xiii)The unsigned witness statement of Tim Gordon-Pounder dated 17
December 2012 at [POL00059459];
xiv) The unsigned witness statement of Stephen Bradshaw dated 10
April 2013 at [POL00060275].
88. As I had no further involvement in this case beyond the point that I provided my
unsigned witness statement dated 21 March 2012, I am unable to provide
comment on what witness evidence was obtained and relied upon by the Post
Office in these proceedings, nor what it was obtained to address. What I can
confirm is that I was never called to give evidence in the case.
89.1 have also considered the following documents:
i) The letter from Hogan Brown Solicitors to Stephen
Bradshaw dated 10 April 2012 at [POL00044206];
ii) The Disclosure Officer’s Report for Anne Nield dated 28 May 2012 at
[POL00057809);
iii) The Schedule of Non-Sensitive Unused Material for Anne
Nield dated 28 May 2012 at [POL00057812];
iv) The Schedule of Sensitive Material for Anne Nield dated 28 May 2012
Page 38 of 59
WITNO08950100
WITNO08950100
at [POL00057810);
v) The Schedule of Non-Sensitive Unused Material for Angela
Sefton dated 28 May 2012 at [POL00057876];
vi) The Schedule of Sensitive Material for Angela Sefton dated 28 May
2012 at[POL00057936);
vii) The Schedule of Non-Sensitive Unused Material for Anne
Nield dated 18 June 2012 at [POL00057350];
viii) The Schedule of Non-Sensitive Unused Material for Angela
Sefton dated 18 June 2012 at [POL00057944];
ix) The Schedule of Non-Sensitive Unused Material for Angela Sefton
and Anne Nield 18 June 2012 at [POL00057949];
x) The Defence Statement on behalf of Angela Sefton dated 18 July 2012
at [POL00044036);
xi) The unsigned and undated Defence Statement on behalf of Anne Nield
at[POL00044042};
xii) The emails dated July 2012 at [POL00058155] and [POL00058115).
xiii)The Application for Disclosure dated 12 September 2012 and
attachments at [POL00058294];
xiv) The emails dated 14 and 17 September 2012 at [POL00058303];
xv) The letter from Andrew Bolc to Laurence Lee & Co dated
18 September 2012 at [POL00058306];
xvi) The emails dated 19 and 20 September 2012 at [POL0005831 1];
xvii) The letter from Hogan Brown Solicitors to Cartwright King dated 7
November 2012 at [POL00059314];
Page 39 of 59
WITNO08950100
WITNO08950100
xviii) The letter from Rachael Panter to Jarnail Singh dated 8
November 2012 at [POL00059313];
xix) The letter from Laurence Lee & Co dated 5 February 2013 at
[POL00044023);
xx) The letter from Andrew Bolc to the representatives of Anne Nield
and Angela Sefton dated 15 February 2013 at [POL00059726];
xxi) The letter from Andrew Bolc to Stephen Bradshaw dated 18 February
2013 at[POL00044020);
xxii) The Schedule of Non-Sensitive Unused Material for Anne Nield
dated 18 February 2013 at [POL00059750];
xxiii) The Schedule of Non-Sensitive Unused Material for Angela
Sefton dated 18 February 2013 at [POL00059752];
xxiv) The letter from Andrew Bolc to Stephen Bradshaw dated 18
February 2013at [POL00044022).
xxv) The letter from Hogan Brown Solicitors dated 25 March 2013 at
[POL00044219);
xxvi) The letter from Laurence Lee & Co dated 2 April 2013 at
[POL00044218);
xxvii) The Direction from His Honour Judge Watson QC dated 4 April
2013 at [POL00044221]);
xxviii) The letter from Andrew Bolc to John Gibson dated 5 April 2013
at [POL00044217];
xxix) The letter from Andrew Bolc to Hogan Brown Solicitors dated 11
April 2013 at[POL00060277];
Page 40 of 59
WITNO08950100
WITNO08950100
xxx) The letter from Andrew Bolc to Laurence Lee & Co dated 11 April
2013 at[POL00060279);
Xxxi) The letter from Cartwright King to Hogan Brown
Solicitors dated 24 July 2013 at [POL00066798];
Xxxii) The letter from Cartwright King to Laurence Lee & Co dated 25
July 2013 at [POL00066799}.
90.1 believe that the Disclosure Officer in this case would have been Steve
Bradshaw, as he was the Lead Investigator. I note that he is named as the
disclosure officer on a few of the abovementioned disclosure schedules. I do also
note that in the email chain at [POL00058303], Andy Bolc from Cartwright Kings
makes reference in a draft email to Helen Rose being appointed by POL as the
Disclosure Officer dealing with Horizon challenges in the case. I do not know any
details about this because as stated above, I did no further work in this matter
after providing a witness statement on 21 March 2012. What! can confirm is that
I had no involvement in the disclosure process whatsoever.
9
=
.As I did not play any role in the disclosure process, I do not know what disclosure
requests and applications were made by the Defence, how the Post Office
responded to any such requests, nor what advice was sought from and provided
by Counsel in relation to this. I defer entirely to the documents and
correspondence provided to me with the Request that relate to this.
92. I confirm that I have considered the following documents:
Page 41 of 59
WITNO08950100
WITNO08950100
i) The Application for Disclosure dated 12 September 2012 and
attachments at [POL00058294];
ii) The emails dated 14 and 17 September 2012 at [POL00058303);
iii) The emails dated 27 and 28 November 2012 at [POL00059421];
iv) The emails dated 30 November 2012, 3 December 2012 and 5
December 2012 at [POL00089394];
v) The Notice of Further Evidence dated 6 December 2012 at
[POL00044019);
vi) The witness statement of Gareth Jenkins dated 5 December 2012 at
[POL00059424);
vii) Exhibit GlJ/1 to Gareth Jenkins’ witness statement at [POL00044163];
viii)Exhibit GlJ/2 to Gareth Jenkins’ witness statement at [POL00044164].
93. I do not know how Gareth Jenkins came to be involved in this case and I was not
aware that he had any input until reading the documents produced to me from the
Inquiry. If I had been made aware at the time I believe I would have understood
that he was the subject matter expert witness from Fujitsu who would provide
evidence in relation to the robustness of the Horizon System.
94. At no point was any information given to me by anyone from Fujitsu (or the Post
Office) during the course of the criminal proceedings against Angela Sefton and
Anne Nield about known bugs, errors or defects in the Horizon IT system, past or
current.
95.1 confirm that I have considered the following documents:
Page 42 of 59
WITNO08950100
WITNO08950100
i) The Prosecution Opening dated 21 November 2012 at [POL00044050);
ii) The Agreed Facts for the cases of Angela Sefton and Anne Nield at
[POL00043964);
iii) The letter from Stephen Bradshaw to the Security Operations Casework
Team dated 10 May 2013 at [POL00044024);
iv) The Judgment of the Court of Appeal in Roger Allen & Others v Post
Office Limited [2021] EWCA Crim 1874 at [POL00113343]
96. Due to me having minimal involvement in only the initial investigation stages, I do
not feel that I am able to provide useful comment or reflection on the way the
investigation and prosecution was conducted by the Post Office on the whole, nor
on the outcome of the prosecution of Angela Sefton and Anne Neild. What I can
say is that where I assisted during the initial investigation, I believe that the correct
processes and procedures were followed and from reviewing Mr Bradshaw's
investigation report, it seems to be compliant.
General
97. Following the introduction of further questions to be asked to SPM’s in an
interview relating to the Horizon System, I believe that I would have considered a
challenge to the integrity of Horizon in one case to be relevant to others. We had
to ask them in all new cases going forwards. I cannot recall if I would have thought
the same from when I started in 2011 until the introduction of these further
interview questions in 2013. I do not recall ever being involved with a case where
a challenge to the integrity of Horizon was made during an investigation during
Page 43 of 59
WITNO08950100
WITNO08950100
this earlier period.
98. I am unsure what is meant by the following comment in [POL00124105] - “the
risk of testing a case in the criminal court prior to the civil hearing.” From reviewing
the rest of [POL00124105)], it appears that Senior Managers in the Security Team
were of the opinion that they were not prepared to risk initiating criminal
prosecutions in cases. It may have been the case that following a cease to
criminal prosecutions, Security Managers were querying whether they would ever
be reintroduced, and [POL00124105] was the response from Senior
Management that followed. However, this is just speculation and I cannot confirm
this for certain. I do not believe I held any opinion or view on this decision — I think
I would have just thought it was a decision for Senior Managers to make and I
was happy to just accept it.
99. Other than the matters I have already addressed in this statement, there are no
other matters which I consider to be relevant to the Inquiry’s Terms of Reference
that I would like to bring to the attention of the Chair.
Statement of truth
I believe the
his statement to be true.
Page 44 of 57
Index to First Witness Statement of Kevin Ryan
WITN08950100
WITNO08950100
No
URN
Document Description
Control Number
POL00126709
CV for Kevin Ryan.
Worked as Horizon
Migration Manager April-
October 2010 and as
Transitional manager after
Oct 2010
POL-0133173
POL00125273
Kevin James Ryan Profile
Form
POL-0131701
POL00127168
One to One Meeting
Record for Kevin Ryan
with Helen Dickinson.
Discusses Post Office
branch security incidents.
Discusses various case
updates in regards to
Fraud.
POL-0133387
POL00127137
One to One Meeting
Record with Kevin Ryan
and Simon Hutchinson -
Criminal Investigation
Case Closures
POL-0133362
POL00136728
One to One Meeting
Record between Steve
Bradshaw and Kevin Ryan
POL-0125542
POL00129337
One to One Meeting
Record of Robert Daily
with Kevin Ryan
POL-0135222
POL00104747
Investigation Policy:
Casework Management
(England & Wales) v1.0
POL-0080387
POL00104777
Investigation Policy:
Casework Management
(England & Wales) v4.0
POL-0080417
POL00104754
Investigation Policy: Rules
& Standards v2.0
POL-0080394
10.
POL00030687
Investigation Policy -
Investigation Procedures
v2 January 2001
POL-0027169
11.
POL00104762
Investigation Policy:
Disclosure of Unused
Material, Criminal
Procedures and
Investigations Act 1996
Codes of Practice" v0.1
POL-0080402
Page 45 of 59
WITN08950100
WITNO08950100
12.
POL00030578
$02 Royal Mail Group
Criminal Investigation and
Prosecution Policy
December 2007
POL-0027060
13.
POL00104812
Royal Mail Group Ltd
Criminal Investigation and
Prosecution Polic
POL-0080444
14.
POL00104806
Royal Mail Group Security
— Procedures and
Standards: Standards of
behaviour and complaints
procedure No.10-X v2
POL-0080438
15.
POL00031003
Royal Mail Group Crime
and Investigation Policy
v1.1 October 2009
POL-0027485
16.
POL00030580
Post Office Ltd - Security
Policy: Fraud Investigation
and Prosecution Policy v2
POL-0027062
17.
POL00030579
Post Office Ltd Financial
Investigation Policy, May
2010
POL-0027061
18.
POL00104848
Royal Mail Group Security
Procedures & Standards:
Appendix 1 to P&S 9.5
Disclosure of Unused
Material & The Criminal
Procedure &
Investigations Act 1996.
Version 1
POL-0080480
19.
POL00104837
Royal Mail Group Security
Procedures & Standards:
Committal & Summary
Trial Papers & Processes
P&S Doc 9.5 v1
POL-0080469
20.
POL00026573
RMG Proceedures &
Standards - Proceeds of
Crime Act 2002 &
Financial Investigations
doc 9.1 V1
POL-0023214
21.
POL00104857
Royal Mail Group Security
Procedures & Standards:
Initiating Investigations
doc 2.1
POL-0080489
22.
POL00031008
RMG Ltd Criminal
Investigation and
Prosecution Policy v1.1
November 2010
POL-0027490
23.
POL00104853
Post Office's Financial
Investigation Policy
POL-0080485
Page 46 of 59
WITN08950100
WITNO08950100
24.
POL00104855
Post Office Ltd. Anti-Fraud
Policy
POL-0080487
25.
POL00030786
Royal Mail Group Policy -
Crime and Investigation
(S2) v3 effective from
April 2011, owner Tony
March, Group Security
Director
POL-0027268
26.
POL00105229
Post Office Ltd PNC
Security Operating
Procedures
POL-0080854
27.
POL00104929
Post Office Limited:
Internal Protocol for
Criminal Investigation and
Enforcement (with
flowchart
POL-0080561
28.
POL00105226
Undated Appendix 1 -
POL Criminal
Investigations and
Enforcement Procedure
(flowchart)
POL-0080851
29.
POL00104968
POL - Enforcement and
Prosecution Policy (with
comments)
POL-0080600
30.
POL00030602
POL: Criminal
Enforcement and
Prosecution Policy
POL-0027084
31.
POL00031005
Conduct of Criminal
Investigation Policy for the
Post Office. (Version 0.2)
POL-0027487
32.
POL00027863
Conduct of Criminal
Investigations Policy v0.3
POL-0024504
33.
POL00030902
Final Draft of the Post
Office Conduct of Criminal
Investigation Policy
POL-0027384
34.
POL00104900
Undated ‘Separation
Project - Criminal
Investigations Policy for
Post Office Ltd!
POL-0080532
35.
POL00105191
Activity Plan for POL
separation project -
Criminal Investigations
Policy
POL-0080816
36.
POL00123309
Email from Dave Posnett
to Aftab Ali, Andrew
Daley, Andrew S McCabe
and others Re:
Investigation
Communication 6- 2014
Joint Investigation
POL-0129508
Page 47 of 59
WITN08950100
WITNO08950100
Protocols RMGS and PO
Ltd Security
37.
POL00123310
Royal Mail Group Security
Investigation
Communication-Joint
Investigation Protocols
RMGS And PO Ltd
Security
POL-0129509
38.
POL00123311
RMG: 2.2 Joint
Investigation Protocols -
RMGS and PO Ltd
Security - Version 1.0
Final
POL-0129510
39.
POL00123312
A Memorandum Of
Understanding On Joint
Investigation Protocols
Post Independence
Involving Royal Mail And
Post Office Ltd Security
POL-0129511
40.
POL00104821
Condensed Guide for
Audit Attendance v2
POL-0080453
41.
POL00129182
Investigations Workshop
Feedback for course dates
between 21st February to
11th March 2011 -
Feedback form for Kevin
Ryan
POL-0135110
42.
POL00126612
Email from Tony Newman
to Andrew J Scott and
Kevin Ryan, re: FW: Skills
Matrix
POL-0133146
43.
POL00129310
Emails from Dave Posnett
to Helen Dickinson,
Andrew Daley, Keith
Gilchrist and others. Re:
Cartwright King Training
Day (proposed topics of
training)
POL-0135204
a4,
POL00129311
Email from Dave Posnett
to Helen Dickinson,
Andrew Daley, Keith
Gilchrist and others.
Re:Cartwright Training
Day in Birmingham
change of start time
POL-0135205
45.
POL00122529
Email from Rob King To:
Andy Hayward CC: Darrell
Kennedy, Keith Gilchrist
and Others Re: notes
following meeting with
POL-0128766
Page 48 of 59
WITN08950100
WITNO08950100
Martin Smith: Cartwright
King
46.
POL00122526
Meeting Notes with Martin
Smith KC - Investigations
and Audit Policy
POL-0128764
47.
POL00122557
Email chain from Kevin
Ryan to Kev Ryan Re:
FW: Draft Case Review
policy and key points
document
POL-0128787
48.
POL00039970
Draft Case File Review:
Policy and Process
guidelines to complete a
successful investigation
(undated)
POL-0036452
49.
POL00122559
Flowchart of Case Source
Process
POL-0128789
50.
POL00122560
Security Operations
Casework Review
POL-0128790
51.
POL00122897
Email chain from Rob King
to Andrew Wise, Andy
Hayward, Simon I
Hutchinson and others
RE: Conduct Of criminal
Investigations Meeting -
25/9/13
POL-0129126
52.
POL00127081
Email from Andy Hayward
to Toni Sless re: Security
Skills Workshop 5 & 6
December 2013 - Agenda
and Delegate List
POL-0133340
53.
POL00123042
Email thread from Andrew
Wise to Rob King, Andy
Hayward, Dave Posnett
and others re: Conduct Of
Criminal Investigation
Workshop
POL-0129259
54.
POL00123282
Email from Andrew Wise
to Helen Dickinson,
Darnell Kennedy, Dave
Posnett and others RE
Criminal Investigation
Guidelines
POL-0129485
55.
POL00118096
Email from Andrew Wise
to Michael Stanway
forwarding an email re
Casework Compliance
VIS00012685
56.
POL00118108
Appendix 1 - Case
Compliance checklist.
VIS00012697
Page 49 of 59
WITN08950100
WITNO08950100
Undated (date taken from
parent email)
57.
POL00118109
Appendix 2 - File
construction and
Appendixes A, B and C:
"Compliance Guide:
Preparation and Layout of
Investigation Red Label
Case Files" Undated -
date taken from parent
email
VIS00012698
58.
POL00118101
Appendix 3 - Offender
reports and Discipline
reports: "Compliance
Guide to the Preparation
and Layout of
Investigation Red Label
Case Files" - undated
(date taken from parent
email)
VIS00012690
59.
POL00118102
Appendix 4 - Offender
reports layout: "POL
template Offender Report
(Legal Investigation)" -
undated (date taken from
parent email)
VIS00012691
60.
POL00118103
Appendix 5 - Discipline
reports layout: "POL
template Offender Report
(Personnel Investigation)"
- undated (date taken from
parent email)
VIS00012692
61.
POL00118104
Appendix 6 - Identification
codes (undated - date
taken from parent email)
VIS00012693
62.
POL00118105
Appendix 7 - Tape
Interviews. "POL Security
Operations Team guide:
Summarising of Tape
Recorded Interviews."
Undated - date taken from
parent email
ViS00012694
63.
POL00118106
Appendix 8 - Notebooks:
Guidance on using
notebooks in
investigations. Undated
(date taken from parent
email)
VIS00012695
64.
POL00118107
Appendix 9 - Case
Progression Toolkit.
VIS00012696
Page 50 of 59
WITN08950100
WITNO08950100
Undated (date taken from
parent email)
65.
POL00046313
Khayyam Ishaq Case
Study: Stephen Bradshaw
- Notebook Entry re Ishaq
interview
POL-0042792
66.
POL00046349
Interview of Khayyam
Ishaq - conducted by
Stephen Bradshaw - Time
commenced - 11:11 and
Time Completed - 11:53
POL-0042828
67.
POL00045133
Khayyam Ishaq case
study: Interview of
Khayyau Ishaq -
conducted by Stephen
Bradshaw
POL-0041612
68.
POL00046224
Investigation (Legal)
Offender Report by
Stephen Bradshaw —
Khayyam Ishaq
POL-0042703
69.
POL00046228
Memo from Rob Wilson re
Ishaq case
POL-0042707
70.
POLO0056596
Memo from Rob G Wilson
to Maureen Moors cc
Stephen Bradshaw re:
POSTVOFFICE LTD -v-
KHAYYAM ISHAQ
POL-0053075
71.
POLO0056600
Memo from Rob Wilson to
Maureen Moors re
Khayyam Ishaq further
interview
POL-0053079
72.
POLO0065000
Typed copy of Notebook
Entry from Post Office Ltd
Fraud Strand
POL-0061479
73.
POL00057985
Khayyam Ishaq case
study: Summary Record of
Taped Interview
POL-0054464
74.
POL00057078
Khayyam Ishaq case
study: Investigation
(Legal) report by Stephen
Bradshaw re Khayyam
Ishaq
POL-0053557
75.
POL00057543
Khayyam Ishaq case
study: POL v Khayyam
Ishaq - Advice from
Counsel Martin Smith of
Cartwright King
POL-0054022
76.
POL00057584
Khayyam Ishaq Case
Study: Witness Statement
POL-0054063
Page 51 of 59
WITN08950100
WITNO08950100
of Kevin Ryan re Khayyam
Ishaq case
77.
POL00057582
Witness Statement of
Stephen Bradshaw dated
2012
POL-0054061
78.
POL00046253
Khayyam Ishaq Summons,
4th April 2012
POL-0042732
79.
POL00119452
Email from Martin Smith to
Steve Bradshaw cc'ing
Jarnail Singh, Post Office
Security and others re:
CASE NO 24676 -
Prosecution of Ishaq -
Judgement
POL-0119371
80.
POL00058024
Witness Statement of
Stephen Bradshaw re
Khayyam Ishaq case
POL-0054503
81.
POL00058035
Witness Statement of
Stephen Bradshaw re
Khayyam Ishag case
POL-0054514
82.
POL00046244
Letter from Musa Patels
Solicitors to Cartwright
King solicitors regarding
Khayyam Ishaq Bradford
Crown Court 4th
September 2012
POL-0042723
83.
POL00046243
Email from Cartwright
King to Stephen Bradshaw
re Ishaq case
POL-0042722
84.
POL00045134
Advice on Evidence in R v
Khayyam Ishaq
POL-0041613
85.
POL00046264
Witness Statement of
Stephen Bradshaw -
Khayyam Ishaq case
POL-0042743
86.
POLO0059592
Witness Statement Post
Office Ltd Stephen
Bradshaw POL 011
Version April 2012
POL-0056071
87.
POLO0059686
Witness Statement of
Stephen Bradshaw re
Second Sight appointment
POL-0056165
88.
POL00046272
Witness Statement of
Stephen Bradshaw -
Khayyam Ishaq case
POL-0042751
89.
POL00046278
R v Khayyam Ishaq -
Addendum defence case
statement
POL-0042757
90.
POL00059887
Witness Statement of
Stephen Bradshaw
POL-0056366
Page 52 of 59
WITN08950100
WITNO08950100
91.
POL00046249
Investigation Report by
Stephen Bradshaw re
Khayyam Ishaq
POL-0042728
92.
POL00060315
Khayyam Ishaq case
study: Email from Martin
Smith to Mark Ford re. Rv
Ishaq
POL-0056794
93.
POL00046250
Email from Stephen
Bradshaw to Paul X
Williams and John
Breeden re Case Closure
Reporting - Khayyam
Ishaq
POL-0042729
94.
POL00113278
Approved Judgment
between Josephine
Hamilton & Others and
Post Office Limited
POL-0110657
95.
POL00044159
Email from Paul X
Williams to Tim Gordon-
Pounder re audit of
Fazakerley Branch
POL-0040638
96.
POL00044052
Typed copy of Notebook
Entry re Anne Nield and
Angela Sefton Clerks at
Fazakerley branch
POL-0040531
97.
POL00044010
Interview record - Angela
Sefton interviewed by
Stephen Bradshaw
POL-0040489
98.
POL00057435
Angela Sefton case study:
Record of Taped Interview
— Angela Sefton
POL-0053914
99.
POL00057389
Royal Mail Group, Record
of Taped Interview Anne
Nield
POL-0053868
100.
POL00043958
Angela Sefton and Anne
Nield case study -
statement signed by
Angela Sefton and Anne
POL-0040437
101.
POL00044198
Angela Sefton and Anne
Nield case study: List of
Offences Report by
Stephen Bradshaw re:
Fazakerley Branch
POL-0040677
102.
POL00044013
Internal Memo from
Maureen Moors (POL
Fraud Team) to RUG
Criminal Law Team re
Fazakerley Branch -
Prosecution
recommended
POL-0040492
Page 53 of 59
WITN08950100
WITNO08950100
103.
POL00057495
Angela Sefton and Ann
Nield Case Study: Letter
from Andrew Bolc to Post
Office Ltd, RE: POL v
Angela Marty Sefton and
Anne Nield
POL-0053974
104.
POL00118474
Fazakerley Call Logs.
Case study of Angela
Sefton.
POL-0118427
105.
POL00044222
Area intervention manager
visit log report -
Fazakerley branch
14/09/2005
POL-0040701
106.
POL00044223
Area intervention manager
visit log report -
Fazakerley branch
POL-0040702
107.
POL00044030
Magistrates Court
Summons for Angela Mary
Sefton
POL-0040509
108.
POL00044033
Summons letter
(Magistrates Court 2267)
addressed to Ms Anne
Nield.
POL-0040512
109.
POL00058146
Criminal Form List for
week commencing
06/08/2012
POL-0054625
110.
POL00059525
List of Witnesses - Post
Office The Queen v Anne
Nield
POL-0056004
111.
POLO0059663
Post Office, List of
Exhibits, The Queen v
Angela Mary Sefton
POL-0056142
112.
POL00058291
Post Office Ltd, List of
Witnesses CROWN v
ANNE NIELD
POL-0054770
113.
POLO0059664
CROWN v ANNE NIELD,
POL List of Exhibits
POL-0056143
114.
POL00044028
Witness Statement of
Kevin Ryan - Fazakerley
Branch.
POL-0040507
115.
POL00044027
Witness Statement of
Stephen Bradshaw -
Fazakerley Branch
POL-0040506
116.
POL00058307
Witness Statement of
Stephen Bradshaw
(signed) - Ann Nield /
Angela Sefton case
POL-0054786
Page 54 of 59
WITN08950100
WITNO08950100
117.
POL00057824
Witness statement of Ali
Askar re Angela Sefton
and Ann Nield
POL-0054303
118.
POL00043965
Court Order allowing
further evidence in case of
R v Angela Mary Sefton &
Anne Nield
POL-0040444
119.
POL00044047
Unsigned Witness
statement of Stephen
Bradshaw - Fazakerley
Branch.
POL-0040526
120.
POL00044160
Extract of NBSC Call Log
from Fazakerley branch
POL-0040639
121.
POL00044037
Witness Statement of
Frances Ann Ellis
POL-0040516
122.
POL00044038
Witness Statement of
Christopher William Dixon
POL-0040517
123.
POL00059459
Witness Statement of Tim
Gordon-Pounder Post
Office Ltd re Angela
Sefton and Ann Nield case
studies
POL-0055938
124.
POL00060275
Witness Statement of
Stephen Bradshaw -
Fazakerley Post Office —
Nield & Sefton
POL-0056754
125.
POL00044206
Letter from Hogan Brown
Solicitors to Mr S
Bradshaw, Re Post office
v Mrs Angela Sefton.
POL-0040685
126.
POL00057809
Anne Nield case study:
Disclosure Officer's report
POL-0054288
127.
POL00057812
Investigation Schedule,
Schedule of non sensitive
Unused material - Anne
Nield
POL-0054291
128.
POL00057810
Investigation Schedule,
Schedule of non sensitive
Unused material - Anne
Nield
POL-0054291
129.
POL00057876
Angela Sefton case study:
Schedule of non sensitive
unused material-
investigation
commencement date form
- Rv Angela Mary Sefton
POL-0054355
130.
POL00057936
Schedule of Sensitive
Material re: Angela Mary
Sefton
POL-0054415
Page 55 of 59
WITN08950100
WITNO08950100
131.
POL00057350
Schedule of Non Sensitive
Unused Material, R v
Anne Nield
POL-0053829
132.
POL00057944
Schedule of non-sensitive
unused material- R v
Angela Mary Sefton
POL-0054423
133.
POL00057949
Schedule of non sensitive
unused material, R v
Angela Mary Sefton
POL-0054428
134.
POL00044036
Defence Statement re
Angela Mary Sefton - Rv
Angela Mary Sefton
POL-0040515
135.
POL00044042
Regina v Anne Nield
Defence Statement
POL-0040521
136.
POL00058155
Email from Jarnail A Singh
to Hugh Flemington,
Susan Crichton and Alwen
Lyon re: 2nd Sight Review
draft
POL-0054634
137.
POL00058115
Email from Jarnail A Singh
to Simon Baker; Hugh
Flemington, re: Horizon
Challenge.
POL-0054594
138.
POL00058294
Letter from Laurence Lee
& Co Solicitors to Miss
Waters re: Regina v Anne
Neild
POL-0054773
139.
POL00058303
Email chain from Jarnail A
Singh to Hugh Flemington
re: FW: R v Sefton & Nield
Liverpool Crown Court
17th October 2012
POL-0054782
140.
POL00058306
Letter from Andrew Bale
to Laurence Lee & Co re:
R v Anne Nield & another,
Liverpool Grown Court
regarding appointment of
second sight.
POL-0054785
141.
POL00058311
Letter from Jarnail A
Singh to Andrew Bloc re:
Angela Sefton and Anne
Nield - 24040 - Theft /
Fraud
POL-0054790
142.
POL00059314
Letter from Hogan Brown
Solicitors to Cartwright
King solicitors re: Rv
Angela Sefton -
Disclosure of reports
POL-0055793
Page 56 of 59
WITN08950100
WITNO08950100
143.
POL00059313
Email from Rachael Paner
to Jarnail A Singh re:
Insight 2
POL-0055792
144.
POL00044023
Letter to Cartwright King
Solicitors from Ms Brigitte
Waters (Laurence Lee &
Co Solicitors) regarding 'R
v Anne Nield', and asking
for documentation relating
to an audit conducted in
2005.
POL-0040502
145.
POL00059726
Angela Sefton and Ann
Nield case studies: Letter
from Andrew Bole on
behalf of Cartwright King
Solicitors to the
representatives of Angela
Sefton and Anne Nield Re
Material to disclose -
ongoing disclosure.
POL-0056205
146.
POL00044020
Letter from Mr Andrew
Bolc to Mr Steve
Bradshaw regarding 'R v
Sefton & Nield' and
preparation for court
documents.
POL-0040499
147.
POL00059750
Schedule of Non-Sensitive
Unused Material - Anne
Nield
POL-0056229
148.
POL00059752
Schedule of non-sensitive
unused material - Angela
Sefton investigation
POL-0056231
149.
POL00044022
Cover letter from Mr
Andrew Bolc to Mr
Stephen Bradshaw in'R v
Sefton & Nield' regarding
an audit conducted in
2005.
POL-0040501
150.
POL00044219
Letter from Hogan Brown
Solicitors to Cartwright
King Solicitors Re Future
hearing of Mrs Angela
Sefton, request for
evidence.
POL-0040698
151.
POL00044218
Letter from Laurence Lee
& Co Solicitors to
Catwright King ISolicitors
Re Regina v Anne Neild
POL-0040697
152.
POL00044221
Prosecution Certificate of
readiness from Judge
POL-0040700
Page 57 of 59
WITN08950100
WITNO08950100
Watson QC for R v Anne
Nield& Angela Sefton.
153.
POL00044217
Letter from Mr Andrew
Bolc (Cartwright King
Solicitors) to John Gibson
regarding 'R v Angela
Sefton & Anne Nield',
enclosing letters from the
defence.
POL-0040696
154.
POL00060277
Letter to Hogan Brown
Solicitors from Andrew
Bolc re. Letter to Defence
where there is material to
disclose - ongoing
disclosure (defence case
statement) R v Angela
Sefton & another
POL-0056756
155.
POL00060279
Ann Nield case study:
Letter to Laurence Lee &
Co to Andrew Bolc re.
Letter to defence where
there is material to
disclose - ongoing
disclosure (defence case
statement) R v Anne Nield
& another Court and Next
Hearing Date:
POL-0056758
156.
POL00066798
Angela Sefton Case study.
Letter from Simon Clarke
to Hogan Brown Solicitors
re: Angela Sefton outcome
and potential grounds to
appeal
POL-0063277
157.
POL00066799
Ann Nield Case Study:
Letter from Simon Clarke
to Laurence Lee& Co
Solicitors Re Anne Nield
Liverpool Crown Court
POL-0063278
158.
POL00059421
Email from Andrew Bolc to
Jarnail A Singh re: Sefton
and Niled
POL-0055900
159.
POL00089394
Email from Gareth Jenkins
to Andrew Bolc, re: Sefton
& Nield
POL-0086369
160.
POL00044019
Notice of further evidence
-Rv Anne Nield & Angela
Sefton
POL-0040498
161.
POL00059424
Witness Statement of
Gareth Idris Jenkins
POL-0055903
Page 58 of 59
WITN08950100
WITNO08950100
162.
POL00044163
Horizon Data Integrity -
This document describes
the measures that are
built into Horizon to
ensure data integrity
POL-0040642
163.
POL00044164
Horizon Data Integrity for
POL - This document
describes the measures
that are built into Horizon
to ensure data integrity
POL-0040643
164.
POL00044050
Case Report - Opening for
Regina v Angela Sefton
and Anne Neild - In the
Crown Court at Liverpool
POL-0040529
165.
POL00043964
Angela Sefton and Anne
Neild case studies:
Agreed Facts forR v
Angela Sefton and Anne
Neild
POL-0040443
166.
POL00044024
Report outlining Anne
Nield and Angela Sefton's
prosecutions - Fazakerley
Branch
POL-0040503
167.
POL00113343
Roger Allen & ors v. Post
Office Limited and Crown
Prosecution Service
[2021] EWCA Crim 1874 -
Approved Judgment.
POL-0110721
168.
POL00124105
Email chain from Sharron
Logan to Jim Coney,
Andrew S McCabe, Matt
Mowbraw and others,
titled "FW: Prosecution
meeting outcome"-
discussing the group
litigation, CCRC and
criminal prosecutions
POL-0130247
Page 59 of 59