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Witness Name: Andrzej Konrad (Andrew) Bolc
Statement No.: WITN09670100
Dated: 28 November 2023
POST OFFICE HORIZON IT INQUIRY
FIRST WITNESS STATEMENT OF: ANDRZEJ KONRAD BOLC
1, ANDRZEJ KONRAD BOLC, will say as follows:
I make this statement in response to the Rule 9 Request dated 24" October 2023, in
relation to my role at Cartwright King Solicitors (the firm) in the criminal prosecutions
of Khayyam Ishaq, Grant Allen, Angela Sefton and Anne Nield, and working with
Fujitsu Services Ltd (Fujitsu).
Background
1. I graduated from the University of Manchester with a BA (Hons) Degree in
Economic and Social Studies. I completed the Common Professional
Examination and Law Society Finals at De Montfort University Leicester. I
qualified as a solicitor in October 1995, and was accepted onto the Duty Solicitor
Scheme in London several years later. I have maintained my Duty Solicitor status
since that time. In April 2008 I was granted Higher Rights of Audience (Criminal
Proceedings).
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2.
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I have worked continuously as a Solicitor since qualification. I initially remained
with the same criminal defence law firm in London at which I had been articled,
and was employed full time as an assistant solicitor in general crime for this legal
aid practice. I represented clients at the police station and magistrates court and
prepared their cases in the crown court. In November 2006 I joined Cartwright
King as an assistant solicitor in their Leicester office and was made a senior
associate shortly afterwards. Having gained my higher rights of audience in
2008, I spent several years in the firm’s Higher Courts Advocacy (HCA)
department, dealing primarily with plea and sentence hearings at the Crown
Court. The firm decided to set up a private prosecution department. One of the
directors of the firm had previously conducted prosecutions on behalf of amongst
others, the RSPCA, the Environment Agency (fishing licence prosecutions) and
the Royal Mail Group (the prosecution of postal workers). I was selected to join
this department. There was no separate training provided for this role as a
prosecutor, although I would have maintained my professional development
obligations to undertake 16 hours of training per year. With regard to the work for
POL I was told that I would be assisted by experienced investigators, and that
POL regularly instructed Counsel that were familiar with their prosecutions. Aside
from my involvement with Post Office Limited (POL), I subsequently also
undertook advocacy for the above organisations on a handful of occasions. I
have undertaken defence work for the police federation. Whilst at the firm I also
conducted some education law and ran a small practice in this field alongside my
criminal defence work. I left the firm in 2022.
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3. My understanding was that the Royal Mail and Post Office were to become
separate organisations on the 1% April 2012. That prosecutions for both had up
until that point been conducted by the Criminal Law Team, Royal Mail Group, but
upon separation the Post Office needed to create their own department. Rather
than continue to employ numerous agents around the country to conduct these
prosecutions, I understood it wanted to use a single firm as much as possible,
and employed Cartwright King, as Agents, to carry out this work for prosecutions
in England and Wales. This was to include, but not limited to advice on the
sufficiency of evidence in relation to charging decisions. Other arrangements
were to be put in place for Scotland and Northern Ireland. The first “Green jacket”
files containing cases prepared for prosecution that were sent to me began
arriving at my office in Leicester around March 2012. From July 2013, in light of
the publication of the Second Sight Report into the Horizon IT system, which
disclosed the existence of bugs within it, my involvement shifted towards a review
process of all previous Royal Mail / Post Office prosecutions. After a number of
months, as that process was gradually completed, I was moved onto other work,
and no longer had any involvement with the Post Office. I was aware that the
firm continued to have some involvement with the Post Office after that time, but I
do not know in what capacity, and I am unaware of when any arrangements
came to an end.
4. My recollection is that cases were referred to Cartwright King by Jarnail Singh. I
cannot recall if files were initially sent to him from the security team based in
Salford, or came directly to us.
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5. I understood that once a case had been raised and was being investigated by a
security manager, they built a green jacket file containing their report, statements
and exhibits, including interview transcripts. As far as I can recall, in the cases
that I dealt with these files were then reviewed by the Business Unit who
recommended that prosecution should be pursued provided the evidence was
sufficient to do so (POL00044013). It was at this stage that the file was forwarded
to Cartwright King for that advice. The report from the investigator included the
potential offences that they were investigating, and on occasion the offence they
believed was most appropriate for charging purposes. Once an advice had been
prepared this was returned to the security team. If the advice was that the
evidence afforded a realistic prospect of conviction, the file would be forwarded to
the designated prosecution authority within Post Office Ltd for the authority to
proceed.
Working with Fujitsu Services Ltd (“Fujitsu”)
6. The circumstances in which I had contact with Fujitsu were limited to email
exchanges I had with Gareth Jenkins for the purpose of obtaining reports
prepared by him on behalf of Fujitsu with regard to the integrity of the Horizon
system. I do no recall any direct communication with Penny Thomas although I
can see from documentation provided to me that she was copied into email
exchanges between myself and Mr Jenkins, and that I have been copied into
emails between her and a Post Office security manager (FUJ00156539).
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7. Gareth Jenkins had previously been used by the Royal Mail Group pre separation
to give evidence in criminal prosecutions as an expert witness in cases where
losses had been attributed by the defence to the Horizon system. He had
prepared general reports on Horizon and Horizon Online Data Integrity, and had
also been used to prepare reports addressing defence expert reports in specific
cases. His email footer described him as a Business Applications Architect with
Fujitsu's Post Office account, so I understood him to have particular expertise in
relation to the Horizon system.
8. I believe that In-house Counsel had advised on the need for an expert report into
the integrity of the Horizon system and the urgency of this was raised in an email
exchange between Andy Cash, a director of the firm and Jarnail Singh on the 12'"
September 2012, to which I was copied in (POL00020489). Mr Singh explained
that he had used Gareth Jenkins of Fujitsu in the past for such a purpose but
raised the issue of his lack of independence. In-house Counsel who had also
been copied into this email exchange responded that someone entirely
independent would have been preferred. However, it seems that a decision to
use Gareth Jenkins was in due course taken in any event due to the
impracticality of obtaining an independent report in the timescale available in
court proceedings. I understood that Jarnail Singh was ultimately responsible for
instructing him and Rachel Panter within the firm had been given responsibility for
organising the delivery of the reports required as the cases progressed through
the courts (FUJ00156677).
Prosecution of Khayyam Ishaq
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9. I have no recollection of the criminal prosecution of Khayyam Ishaq. From the
documents provided to me’ I believe this file was allocated to my then colleague
Martin Smith and that he dealt with it.
10. As far as I can now see from these documents my involvement in this case
extends to being copied into a number of emails, including 26" July 2012, when
this was identified as a “Horizon” case (UKGI00001432), and 6"" March 2013
(FUJ00154128) when I was asked to arrange for hard copies of exhibit reports to
be printed out and passed onto colleagues attending court on this matter.
Prosecution of Angela Sefton and Anne Nield
11.At some point between the 3% February 2012 and 18 March 2012 I received a
“Green Jacket” file in relation to Angela Sefton and Anne Nield at my office in
Leicester. The file contained amongst other documents, which I cannot now
recall, an investigation report by Stephen Bradshaw, Security Manager (the
investigator), interview summaries, and a letter of instruction dated 2" February
2012 from the Fraud Team based in Salford and addressed to Royal Mail Group
Criminal Law Team, which I assumed was now for my attention (POL00044013).
The file contained no separate instructions to me, either identifying my specific
role, or anything else. I believed I was acting as an agent for POL in the
1POL00046313, POL00046349, POL00045133, POL00046224, POL00046228, POL00056596,
POL00056600, POL00065000, POL00057985, POL00057078, POL00046235, FUJ00154002,
POL00057543, POL00057582, POL00046253, POL00058024, POL00058035, UKGI00001432,
POL00046242, POL00046244, POL00046243, POL00045134, POL00059517, POL00046264,
POL00059592, POL00059652, POL00059686, POL00046272, POL00046278, POL00059887,
POL00046249, POL00060315, POL00046250, POL00089393, FUJ00124229, POL00052509,
POL00057580, POL00059602, POL00059874, FUJ00124337, POL00059927, FUJ00154128,
FUJ00154180 and POL00060113.
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prosecution. I was not supplied by way of introduction with any policy documents
in relation to the conduct of prosecutions by POL, disclosure or anything else. I
was not supplied with any information in relation to the Horizon system, the
details of any data it generated, issues relating to its reliability, any relevant
cases, or details regarding any civil actions or otherwise.
12. The letter stated, “It is the Business Unit recommendation that prosecution should
be pursued provided the evidence is sufficient to do so. Would you therefore
please advise on the sufficiency of the evidence in this matter. I was
immediately struck by the implication that considerations in relation to the
business of POL formed part of the decision-making process when deciding on
whether an individual should be prosecuted. It was also not clear to me whether I
was supposed to consider strictly the sufficiency of the evidence or employ the
wider test used by Crown prosecutors which required a realistic prospect of
conviction and consideration of the public interest. When I asked for clarification
regarding the public interest test, I was advised by Jarnail Singh that he
considered that this test was always met whenever there were losses to the
public purse (POL monies) and they were over a certain financial threshold akin
to DWP prosecutions for benefit fraud.
13. Going by the date of my letter of the 18‘ March 2012, POL00057495, I suspect
this was the first advice on charge that I prepared for POL, and was also
therefore the first charging advice I had ever given in relation to a criminal
prosecution. As far as I can recall, it was one of only two cases where I provided
charging advice and was involved where the integrity of Horizon became an
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issue. Prior to drafting the advice I recall making a telephone call to Stephen
Bradshaw to introduce myself. There would have been a discussion about the
case, but I cannot recall the details.
14. I stated in my opinion there was sufficient evidence to afford a realistic prospect
of conviction for false accounting based upon the admissions made in interview
to that effect. I did not believe charges of theft were made out, as I thought it
impossible to identify who was responsible to the criminal standard or rule out the
possibility of a third party being to blame. I would like to now add that in interview
both Angela Sefton and Anne Nield categorically denied stealing any money.
They acknowledged that the losses could have been down to human error, and
gave examples of how this had happened. I concluded that this was probably the
case.
15.1 returned my advice to Salford, I did not know who made the final decision to
proceed with the prosecution, although the investigation report cited the Senior
Security Manager as the Designated Prosecution Authority (DPA). I understand
from POL00105223, a Security Operations Casework Review dated 04/02/13 that
a file from that time would be forwarded to Jarnail Singh and then the DPA for a
final review and authority to proceed. I do not know what happened on this
occasion.
16.Summonses were issued by Liverpool Magistrates Court dated 15'" March 2012
(POLO00044030 and POL00044033) and proceed by way of committal to the
Crown Court with a plea and case management hearing listed for the 9"* August
2012 (POL00056146). I progressed the file by way of casework but did not attend
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any of the hearings or conferences throughout the proceedings. I think POL used
local agents for the advocacy in the Magistrates Court and John Gibson of
Counsel was instructed in relation to the Crown Court proceedings. I have not
seen the brief containing his instructions, so cannot recall what it now said.
17.Statements were obtained from the Sub-postmaster, the POL auditors and
security team who had attended the financial audit on the 6" January 2012; and a
trustee and book keeper from the charity whose cash flow had been affected
(POL00059459, POL00044037 and POL00044038) . Exhibits included the 40
suppressed giro deposit slips, the jointly signed letter by Angela Sefton and Anne
Nield and the interview tapes and transcripts. These were obtained to support the
charges of false accounting in the criminal proceedings.
18.Stephen Bradshaw, as well as being the investigator was also the Disclosure
Officer in this case. He has identified himself as such in all of the relevant
schedules. This is common practice even amongst the police in routine
investigations. In addition I have seen that Jarnail Singh also appointed Helen
Rose as a disclosures officer for “Horizon” cases generally to deal with the
specific disclosure around previous challenges to the system.
19.Hogan Brown Solicitors requested disclosure papers in their letter of the 10" April
2012 to assist with plea and mode of trial prior to the first hearing in the
Magistrates Court (POL00044206). I can see from my letter of the 1%* March 2012
(POLO0057495) that I prepared a statement (summary) of facts for this purpose,
which would have been forwarded to both solicitors, although I have not seen a
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copy of this now. I can also see that I reviewed the committal disclosure
schedules before they were forwarded to the defence.
20.As far as I can recall my subsequent role in respect of disclosure requests and
2
applications in this case was to forward these onto Jarnail Singh for his
instructions and to relay these back to the defence. To request the investigator to
carry out more tasks related to disclosure requests, and to seek advice from
Counsel.
. The defence statement of Angela Sefton dated 18/7/12 (POL00044036) included
a request for details of complaints regarding the operation of the system from
2005, the steps taken to address these, and information regarding an ongoing
investigation of these complaints by POL. This was being considered by Jarnail
Singh in an email of the 23 July 2012 (POL00058115) and with a copy being
escalated within POL for a response to be prepared. The defence statement of
Anne Nield (POL00044042-) contained a similar request for details of complaints
and investigations into the Horizon computer system. This was followed up with a
S.8 application for the same disclosure dated 12" September 2012, this time
including a request for access to the Horizon computer system used by the
defendant for inspection (POL00058294).
22. Advice was sort from Prosecuting Counsel John Gibson in relation to this
application. Instructions to him from the firm were first reviewed by a Director
within the firm and also In-house counsel, who considered that the defence
should be offered the opportunity to test the system. Specific instructions were
sort from Jarnail Singh about direct access to the system and a timetable for
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service of the Fujitsu report. He responded by saying that defence experts had in
the past attended the relevant sub post offices in the past to be able to analyse
the relevant data etc. but asked to clarify the specifics (POL00058303). The
response from Mr Gibson is not included in the documentation I have seen, but a
letter to Anne Nield’s solicitors dated 18° September 2012 (POL00058306)
included reference to the ongoing 2™ Sight Investigation by Independent
Auditors, the pending report from Fujitsu, and the following passage: “Defence
experts have in the past attended the relevant Post Offices to be able to analyse
the relevant data. Access to the system beyond that would need to be specified
and approved by POL before being allowed”.
23.Mr Gibson provided advice regarding the disclosure of Stephen Bradshaw's
statement of the 20/9/12 and exhibit SB/51. Instructions regarding disclosure
were also sent to Prosecuting Counsel on the 5‘ April 2012, with regard to the
further evidence obtained by Stephen Bradshaw, and a further disclosure request
from solicitors on behalf of Anne Nield (POL00044217). My response which
would have been based on the advice provided is contained in POLO0060279.
24.1 also liaised with Mr Bradshaw to address specific disclosure requests made by
the defence. A further statement from him dated 20'" December 2012 addressed
his enquiries relating to call log information for the branch with the National
Business Support Centre (POL00044047, POL00044160). These showed that
calls had been made to the Centre starting 4 August 2005 over the following 3
weeks regarding a loss of £592.21 which was suspected to relate to the lottery.
He stated that the matter had been resolved in a call on the 25" August 2005.
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25.Further enquiries were conducted in respect of this loss and addressed in a
follow up statement of his dated 10‘ April 2013 (POLO0060275). Business
records indicated that Kevin Ryan, then the Branch Development Manager had
attended the branch on the 6" September 2005, to explore what had happened
and was told by the officer in charge, (possibly Anne Neild or Angela Sefton), that
it was something to do with the upgrade to Horizon online and that no errors
could be found. When Mr Ryan attended the loss had cleared and there was no
explanation. They also showed he had attended the branch on the 6 February
2006 regarding a shortage of £3959 in January 2006 and all documents,
transactions and event logs were checked and there was no indication what had
caused the loss. A history of audits undertaken at the branch was also set out as
requested.
26. Gareth Jenkins had previously received instructions to prepare a report regarding
the integrity of Horizon as it related to this case, and had been sent case
summaries and defence statements for this purpose. I had chased this report on
the 27" November 2012 as it was still outstanding and the trial was due to take
place in January at that time. Rachel Panter was due to speak to him the
following day and would raise it then. I received an email from Mr Jenkins on the
3 December 2012 seeking clarification with regard to the content
(POL00089394). He proposed to clarify that installation of Horizon occurred
between 1999 and 2002, which did not accord with the start of losses at the
branch from 2005, and refer to the migration from the original Horizon system to
the new Horizon online system in 2010. He stated that it has already been
established that it is not possible to examine the original Horizon system that was
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operational until 2010. I took this to mean that this would have been self evident,
as the counter terminals would have all been replaced in 2010 when the new
system was installed.
27.There then appears to have been further discussion around events in 2005
regarding an update to the system to the weekly cash account. This was
subsequently addressed in his report.
28.Mr Jenkins also makes reference to having not been presented with any audit
data. By my response in an email at 14:20 that day it would appear that I had
misunderstood him to be referring to the Horizon print outs obtained for the
financial audit of the 6"" January 2012 and had not understood the wider
significance of what he was referring to (FUJ00153872).
29.1 received no information by anyone from Fujitsu (or the Post Office) during the
course of the criminal proceedings against Angela Sefton and Anne Nield with
regard to known bugs, errors or defects in the Horizon IT system, past or current.
30.1 would like to offer my apology to both Angela Sefton and Anne Nield for my part
in the injustice they suffered and the awful impact this had upon them.
Prosecution of Grant Allen
31. Agreen jacket investigation file would have been sent to my office sometime in
May or June 2012. My recollection is that my role in this case was to act as agent
on behalf of POL, to include advice on the sufficiency of evidence and carry out
case work as the file progressed through the prosecution.
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32.When considering the file I read that a financial audit conducted on the 8"
February 2012 had shown a cash shortage of £11,705 against his stock unit. Mr
Allen admitted in interview inflating his cash on hand to achieve a balance,
putting the approximate amount on the unusable notes line from April 2010 to
February 2012. However, he had raised an issue with regard to data transfer
following a relocation of his Post Office. My advice on charge in this matter is set
out in full at POLO0089057. In particular, at paragraph 4.iii) in the first 4 weeks
there were wiring problems with the terminals, which he believed meant Horizon
was not sending out (Polling) data. iv) in that period a £3,000 discrepancy arose
in the accounts which could not otherwise be explained. At para 5 i) the Non
polled report following the branch relocation showed that an engineer attended
on the 16" and 17" March 2010 to complete a base unit build and that BT fixed a
fault. However as of the 17" March 2010 the number of days Not Polled is shown
as 12.
33.At para 7, “I would advise that an additional statement be provided by, I assume
Mr Bradshaw, into the enquiries conducted after the interview with regard to the
non polled report, and lack of calls to the Branch Conformation team and National
Business Support Centre. With regard to the non polled report, a separate
statement will be required explaining in lay man’s terms, why this not show that
data could have been lost during the 12 day period identified thus generating the
£3000 loss as claimed by the defendant.”
34.At para 8, “Subject to a satisfactory answer to the above query about the
possibility of lost data then I would advise that a charge of fraud by false
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representation would suit the circumstances described for the period covering Mr
Allen’s admissions in interview with regard to inflated cash declarations.... There
is insufficient evidence to prove to the criminal standard who if anyone, actually
stole money from the Post Office”.
35. The advice with covering letter, and draft charge were emailed to Post Office
security on the 4‘ July 2012, and copied to Stephen Bradshaw, Jarnail Singh,
and members of the prosecution team within the firm.
36.A decision was taken to authorise prosecution and a summons dated 19" July
2012 was issued for Mr Allen to attend on the 30" August 2012. I prepared a
summary of facts for the hearing set out in full at POLO0089562, which included
Mr Allen’s account of the £3,000 discrepancy.
37. The case was subsequently listed for committal to the Crown Court on the 25"
October 2012. Stephen Bradshaw is named as the investigator on the disclosure
schedules, and I believe he would have been acting as the disclosure officer in
this case. The case was then initially listed for a plea and case management
hearing on the 10'* December 2012.
38.Mr Allen was represented by Maidments Solicitors. I do not recall the contents of
their letter from the 2.4 November 2012, but I have responded to them on the
22°4 November in relation to the Second Sight Report that was still pending at
that time (POL00089376). I suspect that this response would have been drafted
by POL. I do not know what considerations, if any were made by POL to either
stay or adjourn the proceedings pending the publication of the report. I would
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have thought that such a decision could only have been made at a much higher
level within the organisation.
39.An entry in the investigation report (POL00089426) indicated that a telephone call
had been made to the Branch Confirmation Team and they reported that they had
not been contacted in relation to any £3,000 discrepancy. The call logs were also
requested from the National Business Support Centre (NBSC) for the period of
March 2010 to 23 April 2012. No calls were listed with any discrepancies at the
branch. A request for Help Desk Calls was made in an email to Gareth Jenkins at
POL00089378.
40.Mr Jenkins was instructed to prepare reports in cases involving “Horizon” cases
as already described in paragraphs 7 and 8 above. Case summaries and other
relevant material was forwarded to him to be able to provide comment on specific
cases to add to the general reports he had already prepared with regard to the
different iterations of Horizon. Fujitsu made it clear that POL would have to pay
for his time in preparing such reports. This was reiterated to the firm in an email
from Jarnail Singh dated 19'" November 2012 at POL00089374, which reads “the
cost of obtaining data, statements is very expensive... legal, compliance and
budgetary obligations puts further restraints on obtaining such data from Fujitsu.
It is very important due process is strictly followed. I need to be notified if
anything is required from Fujitsu”. I suspect that this email may have been
forwarded onto me or the general message relayed back.
4
.Mr Jenkins would have been initially instructed by Rachel Panter from the firm to
prepare these reports. I was not involved in that process. I contacted him on the
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4 December 2012 to inform him that I had just spoken to Mr Allen’s solicitor as
she was going to ask the court to relist the case from the 10'" December 2012
until the following January (POL00089378). I took the opportunity to ask him if he
was able to comment specifically on the non polling data issue that Mr Allen had
raised in interview and provided him with an extract, in addition to the case
summary he had already been sent.
42.Mr Jenkins responded by email the following day. He believed he understood the
issue being raised in relation to the initial loss. He stated any missing data would
normally be recovered if communication issues were resolved within 35 days. He
could make a general statement to that effect or carry out an analysis of the
specific data to see exactly what had happened. He pointed out data retrieval
was part of the standard service but his analysis would be chargeable to POL. He
would not be able to carry out analysis until the new year.
43.1 invited him to add his general comments at that stage regarding the safeguards
in place for comms problems whilst I referred back to POL before incurring any
expense as per instructions. I attached a copy of the non polling report previously
obtained as I now understood its relevance. Mr Jenkins responded, “A look at the
non — poll report shows that the branch was offline for 12 days, assuming it was
OK after the last entry. The data should have been fully recovered assuming base
units were swapped correctly and I'll cover that in what I say.”
44. At page 3 of Mr Jenkin’s report FUJ00124200 he stated, “(Data is held at the
counter for a period of at least 35 days, so provide a comms outage is less than
35 days and operational processes regarding replacement hardware are followed
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correctly, then no data should be lost.) I have not had an opportunity to examine
the detailed logs from this period to see whether there were any issues, and any
justifications in the claim that this resulted in apparent losses of £3,000 as
claimed.”
45.1 forwarded a copy of the draft report onto Mr Bradshaw for his consideration. In
my email to Mr Bradshaw (POL00089380) I thought that the report had dealt with
the non polling issue adequately but pointed out that “it is in fact possible for him
(Mr Jenkins) to retrieve the actual data from this time to see what actually
occurred at this branch.” That Mr Jenkins had stated the cost of the data was
free to POL but that the analysis was chargeable. My email continues that I had
told Mr Jenkins that we did not wish to incur additional costs unless unavoidable,
although I hadn't in fact said this to him. I cannot now recall why I added this
comment. I asked Mr Bradshaw for his instructions. I emailed Mr Jenkins later
on the 12 December 2012, to say “the investigator is happy with the report as it
stands. Please could you proceed as before” (FUJ00153905). I do not know if Mr
Jenkins ever conducted any analysis of the data specific to the case. Upon
conclusion of the proceedings there seems to have been concern by Fujitsu that
the case “might set a precedent” for comms issues to be a reason for losses.
46.1 received no information by anyone from Fujitsu (or the Post Office) during the
course of the criminal proceedings against Grant Allen with regard to known
bugs, errors or defects in the Horizon IT system, past or current.
47.1 would like to offer Mr Allen my apology for my part in the injustice he suffered
and the awful impact this had upon him.
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Statement of Truth
I believe the content of this statement to be true.
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Exhibits to First Witness Statement of Andrzej Konrad Bolc
WITNO9670100
WITNO9670100
No.
URN
Reviewer Document Descrip-
tion
Control Number
POL00133265
Voucher Migration (via an OBC.
change).
POL-0137718
POL00044013
Internal Memo from Maureen
Moors (POL Fraud Team) to
RMG Criminal Law Team re
Fazakerley Branch - Prosecution
recommended (Sefton and Nield
case study)
POL-0040492
FUJ00156539
Email chain with James Da-
vidson, Penny Thomas, Peter
Thompson and others - Re: RM v
Bramwell Specifically - Horizon
Integrity in general
POINQ0162733F
POL00020489
Email chain between Harry Bow-
yer, Jarnail Singh, Andy Cash
and Helen Rose re Helen Rose
disclosures report (defence ex-
pert reports & disclosure re-
quests)
POL-0013681
FUJ00156677
Khayyam Ishaq, Ann Nield, An-
gela Sefton, Grant Allen case
studies: Email from Rachael
Panter to Gareth Jenkins, An-
drew Bolc, Andy Cash and others
Re: FW: POL cases raising Hori-
zon - also regarding Kim Wylie
and Jamie Dixon
POINQ0162871F
UKGI00001432
Khayyam Ishaq Case Study:
Email from Martin Smith to
Rachael Panter and Andy Cash
RE: CASE no 24676- Prosecu-
tion of Ishaq
UKGI012246-001
FUJ00154128
Khayyam Ishaq criminal case
study - Email chain with Jenkins
Gareth, Andrew Bolc and Martin
Smith - Re: R v Khayyam Ishaq
[PKF-UK.FID2678503]
POINQ0160323F
POL00044013
Internal Memo from Maureen
Moors (POL Fraud Team) to
RMG Criminal Law Team re
Fazakerley Branch - Prosecution
recommended (Sefton and Nield
case study)
POL-0040492
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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
WITNO9670100
WITNO9670100
10
POL00105223
Security Operations Casework
Review®
POL-0080848
11
POL00044030
Magistrates Court Summons for
Angela Mary Sefton
POL-0040509
12
POL00044033
Summons letter (Magistrates
Court 2267) addressed to Ms
Anne Nield.
POL-0040512
13
POL00056146
Rowlands Castle Final branch
Trading Statement from
16/02/2011 to 16/03/2011 re
Lynette Hutchings case study
POL-0052625
14
POL00059459
Witness Statement of Tim Gor-
don-Pounder®Post Office Ltd re
Angela Sefton and Ann Nield
case studies®
POL-0055938
15
POL00044037
Witness Statement of Frances
Ann Ellis
POL-0040516
16
POL00044038
Witness Statement of Christo-
pher William Dixon
POL-0040517
17
POL00044206
Letter from Hogan Brown Solici-
tors to Mr S Bradshaw, Re Post
office v Mrs Angela Sefton.
POL-0040685
18
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
19
POL00044036
Defence Statement re Angela
Mary Sefton - R v Angela Mary
Sefton
POL-0040515
20
POL00058115
Email from Jarnail A Singh to Si-
mon Baker; Hugh Flemington, re:
Horizon Challenge.
POL-0054594
21
POL00044042
Regina v Anne Nield Defence
Statement
POL-0040521
22
POL00058294
Letter from Laurence Lee & Co
Solicitors to Miss Waters re: Re-
gina v Anne Neild
POL-0054773
23
POL00058303
Email chain from Jarnail A Singh
to Hugh Flemington re: FW: Rv
Sefton & Nield Liverpool Crown
Court 17th October 2012
POL-0054782
Page 21 of 23
24
POL00058306
Letter from Andrew Bale to Lau-
rence Lee & Core: Rv Anne
Nield & another, Liverpool Grown
Court regarding appointment of
second sight.
POL-0054785
WITNO9670100
WITNO9670100
25
POL00044217
Letter from Mr Andrew Bolc
(Cartwright King Solicitors) to
John Gibson regarding 'R v An-
gela Sefton & Anne Nield’, en-
closing letters from the defence.
POL-0040696
26
POL00060279
Ann Nield case study: Letter to
Laurence Lee & Co to Andrew
Bolc re. Letter to defence where
there is material to disclose - on-
going disclosure (defence case
statement) R v Anne Nield & an-
other Court and Next Hearing
Date: Liverpool Crown Court -
wic 15/04.2013
POL-0056758
27
POL00044047
Unsigned Witness statement of
Stephen Bradshaw - Fazakerley
Branch.
POL-0040526
28
POL00044160
Extract of NBSC Call Log from
Fazakerley branch
POL-0040639
29
POL00060275
Witness Statement of Stephen
Bradshaw - Fazakerley Post Of-
fice — Nield & Sefton
POL-0056754
30
POL00089394
Email from Gareth Jenkins to An-
drew Bolc, re: Sefton & Nield
POL-0086369
31
FUJ00153872
Email from Andrew Bolc to
Gareth Jenkins re: Sefton and
Nield.
POINQ0160067F
32
POL00089057
Post Office Limited Regina v
Grant lan Allen - Charging Ad-
vice
POL-0086032
33
POL00089562
Summary of facts - Post office
Limited v Grant lan Allen
POL-0086537
34
POL00089376
Letter from Andrew Bolc to Mar-
tin Bloor, RE: R v Grant Allen
POL-0086351
35
POL00089426
Post Office Ltd: Legal Investiga-
tion - Offences report
POL-0086401
36
POL00089378
Email from Andrew Bolc to
Gareth Jenkins, RE: Post Office
Ltd v Grant Allen
POL-0086353
37
POL00089374
Email chain from Jarnail A Singh
to Rachael Panter, Andy Cash,
POL-0086349
Page 22 of 23
Martin Smith RE: POL cases
raising Horizon
WITNO9670100
WITNO9670100
38
POL00089378
Email from Andrew Bolc to
Gareth Jenkins, RE: Post Office
Ltd v Grant Allen
POL-0086353
39
FUJ00124200
Witness statement of Gareth
Jenkins.
POINQ0130414F
40
POL00089380
Email chain from Gareth Jenkins
to Steve Bradshaw, RE: FW:
Post Office Limited v Grant Allen.
POL-0086355
a
FUJ00153905
Grant Allen Case Study: Email
from Andrew Bolc to Gareth Jen-
kins re POL v Grant Allen - report
POINQ0160100F
Page 23 of 23