why is it going to be here? she says because it should have been my responsibility and a should have been something i dealt with at the beginning and i know that and that goes through my head every day and if i could answer for that sort of money i would answer. i know i can prove i have not stolen any money. i end a thief. —— i am not a thief and you ask how do we know you haven't stolen it and she says i know, i can sleep at night knowing i haven't and you say, we have got 59,000 point shortage in your account. you offer no explanation for that money has gone, you've got a moo point loss, everything is hunky—dory for 12 months and she says, no it isn't hunky—dory. i can force government to take the money that she did not have, could not force the money from the woman, she did not have it because that is all it is, i could

not force her, she did not have the money and she kept saying what she did not have the money and you say but you never did her by giving her the keys, to the office? she said yes. i know. 0nly because the customers were complaining i was arriving at work late. and you say get up earlier. your responsibility, he took the role of the sub—postmaster, diane will go through the rest, where up to £9,000 and we have another 50,000 to find. she says the restjust went missing through the year, i cannot explain it any other way, you can break it down into pounds and pennies but i cannot explain it, if i had an answer i would not be sat here. get up earlier, did you consider it yourjob to offer get up earlier, did you consider it your job to offer lifestyle get up earlier, did you consider it yourjob to offer lifestyle advice?

they had been contracted to open up the post office at a certain time. if you can't get up, fine. we all come from different parts of the country and we have ways of expression and i apologise if they don't like that sort of terminology, it wasn't meant to be detrimental towards the it's just, it wasn't meant to be detrimental towards the it'sjust, if towards the it's just, if you're forever arriving late for work people will say to you get up earlier to arrive on time. my question _ earlier to arrive on time. my question was _ earlier to arrive on time. my question was do you think it was appropriate to give lifestyle advice because your evidence yourself has been that you were carrying out an interview under the police and criminal evidence act, a very serious interview. do you think it's appropriate for someone who is questioning someone in relation to a criminal offence to tell them that they need to get up earlier. figs criminal offence to tell them that they need to get up earlier. $5 i they need to get up earlier. as i said, it's they need to get up earlier. as i said. it's my _ they need to get up earlier. " i said, it's my terminology and if it is not liked i apologise for that.

she's there for nine o'clock, she the person that she is suspected of stealing the money so to save her coming in she gave that person the keys. that is all that conversation is. when you read something it can sound better or worse then when it is actually spoken at the time. mr bradshaw, used to work for the post office. i bradshaw, used to work for the post office. ., in bradshaw, used to work for the post office-- in the — bradshaw, used to work for the post office. i do. in the security department. _ office. i do. in the security department. i— office. i do. in the security department. i do. - office. i do. in the security department. ido. do- office. i do. in the security department. i do. do you i office. i do. in the security - department. i do. do you consider that it is still — department. i cf do you consider that it is still appropriate to say to someone in an interview that it similar to a police interview that they should get up earlier? some --eole they should get up earlier? some peeple may _ they should get up earlier? some peeple may say — they should get up earlier? some peeple may say yes. _ they should get up earlier? some people may say yes, some - they should get up earlier? some | people may say yes, some people they should get up earlier? fin? people may say yes, some people may no. i can say that no, it's not appropriate. no. i can say that no, it's not appmpriate-_ no. i can say that no, it's not appropriate. no. i can say that no, it's not a...roriate. , appropriate. some people may say es, some appropriate. some people may say yes. some peeple _ appropriate. some people may say yes, some people may _ appropriate. some people may say yes, some people may say - appropriate. some people may say yes, some people may say no. - appropriate. some people may say. yes, some people may say no. what do you say? is it appropriate or not? in the context with the conversation goes. that's how it was at the time,

it appeared to be ok. if you can't get up and you are always late, you abuse the post office by opening too late. ii abuse the post office by opening too late. , ., , .. , abuse the post office by opening too late. , , ., late. if you were still carrying out this role and _ late. if you were still carrying out this role and interviewing - late. if you were still carrying out| this role and interviewing people, if you are interviewing somebody tomorrow, would you have any concerns about using that language? i'm a phrase at a different way. but ou ma i'm a phrase at a different way. but you may still _ i'm a phrase at a different way. but you may still give similar advice. it's a very difficult question, advice, it's not really advice. advice wise is, as i say, if you were always late, most people from being a small child in school say, you need to get up earlier to get in on time. is you need to get up earlier to get in on time. , ., ,, .,, ., you need to get up earlier to get in on time-— i - you need to get up earlier to get in on time._ i don't i on time. is it appropriate? i don't see a great— on time. is it appropriate? i don't see a great deal— on time. is it appropriate? i don't see a great deal wrong _ on time. is it appropriate? i don't see a great deal wrong with - on time. is it appropriate? i don't see a great deal wrong with it - on time. is it appropriate? i don't see a great deal wrong with it if. see a great deal wrong with it if you can't get it on time.- you can't get it on time. what --urose you can't get it on time. what purpose does _ you can't get it on time. what purpose does it _ you can't get it on time. what purpose does it serve - you can't get it on time. what purpose does it serve in - you can't get it on time. what purpose does it serve in an i purpose does it serve in an interview?—

purpose does it serve in an interview? , , , , interview? the purply purpose was there was that _ interview? the purply purpose was there was that she _ interview? the purply purpose was there was that she gave _ interview? the purply purpose was there was that she gave the - interview? the purply purpose was there was that she gave the keys l interview? the purply purpose was| there was that she gave the keys to somebody else to open and that is fine. she can do that but the keys were given to someone she suspected of stealing money which is a bit strange, to me is a bit strange. what does it matter to you whether she opens or someone else opens? you are carrying out a criminal investigation. you are not actually assisting her with the smooth running of her post office, are you? the smooth running is that if she was there to see what was happening. and run the post office from start to finish. is and run the post office from start to finish. . . and run the post office from start to finish. , , i. and run the post office from start to finish. . . ,, . to finish. is it still your evidence that ou to finish. is it still your evidence that you were — to finish. is it still your evidence that you were professional? - to finish. is it still your evidence | that you were professional? yes. to finish. is it still your evidence - that you were professional? yes. i'm auoin to that you were professional? yes. i'm going to move _ that you were professional? yes i'm going to move on to that you were professional? il:s i'm going to move on to the case that you were professional? ils i'm going to move on to the case of jacqueline mcdonald. can we still move on —— me please move on. thank

you very much. we are back again to the court of appeal. i would like to look at paragraph 179. i don't have the page number unfortunately. but if we can scroll down, scroll up a little bit more. thank you. jacqueline mcdonald on the 8th of november 2010 in the crown court she pleaded guilty to theft. 0n accounts of false accounting. 0n the 21st of january 2011 she was sentenced to a total term of imprisonment of 18 months. the confiscation order was made as a result of the proceeding against

her, she was false to file for bankruptcy. an audit of her post office had revealed a shortage of £94,000. in an interview she said that she had experienced problems with horizon and when she contacted the helpline she received no assistance. she denied theft but accepted that she had unintentionally made false accounts. her defence statement made reference to the problems experienced with horizon, the defence made a number of disclosure request but the prosecution made no disclosure in terms of any horizon difficulties. she had made 216 calls to the report centre about balancing problems and the pretense and report reported her saying that she had not stolen money but admitted to accepting that the system balances as correct in order to roll over into the next trading period. if we scroll down to the

bottom half of paragraph 182 and into 183. nevertheless, as the post office concedes this was a horizon 0ffice concedes this was a horizon case and the prosecution case was relying on data generated by horizon and yet there was nothing to indicate that any fidgets you audit data was obtained at the time of the criminal proceedings and there was no evidence to cooperate the horizon evidence, issues raised by miss mcdonald were not investigated and there was no proof of actual loss as approved to horizon generated shortage. the post office concedes that her prosecution was unfair but we conclude that the prosecution was an upfront to justice. i would like to look at her interview that can be found at uk gi 0001489. in this case, you were the interviewing officer. are we to assume that the

person who comes first is the main interviewer?— person who comes first is the main interviewer? yes. you are assisted there by a — interviewer? ils you are assisted there by a colleague suzanne winter. where you the officer in charge of the investigation of miss mcdonald? yes. ~ , :, the investigation of miss mcdonald? yes. ~ , ., ,. .,, the investigation of miss mcdonald? yes. were you the disclosure officer in that case — yes. were you the disclosure officer in that case as _ yes. were you the disclosure officer in that case as well? _ yes. were you the disclosure officer in that case as well? all— yes. were you the disclosure officer in that case as well? all papers - in that case as well? all papers that i in that case as well? all papers that i had _ in that case as well? all papers that i had would _ in that case as well? all papers that i had would have - in that case as well? all papers that i had would have been - in that case as well? all papers - that i had would have been disclosed who then discloses that the defence? i'm not asking about the quality of the disclosure but i'm talking about your role that was reported to a disclosure officer.— disclosure officer. guess i think that's a technical _ disclosure officer. guess i think that's a technical role _ disclosure officer. guess i think that's a technical role it's - disclosure officer. guess i think that's a technical role it's not . disclosure officer. guess i think| that's a technical role it's not an independent person.— that's a technical role it's not an independent person. thank you. if we can lease independent person. thank you. if we can please turn _ independent person. thank you. if we can please turn to _ independent person. thank you. if we can please turn to page _ independent person. thank you. if we can please turn to page five. - independent person. thank you. if we can please turn to page five. i'm - can please turn to page five. i'm going to read to you a section of her interview transcript. it begins,

i'm going to begin with you who says, you just admitted that you falsified your balance because you impacted figures to enable you to balance. she says yes. you say, do you know that is a criminal offence? she says, no, i didn't. there is a summary that you said that you stated the accounts have possibly been falsified from either november or march. you produce sheets and asked her to state who had written the figures on the sheets. she said that some were hers and some were her colleagues and some were just her colleagues and some were just her colleagues. you asked if she had any time. she said she had two days off injune, her colleague was away in may. and then it says that you discussed the last she starting on 27th september and she confirmed that it was her writing and you asked her to explain what the figures are and she said that the figures are and she said that the figures were what was in the safe, the roller, cash in the tills. she

also stated that they were wrong and not worth the paper they were written on. she says asking where she would have got the figure of 65,000 she said it would have been the balance from the computer. then it stops summarising and goes into the actual word spoken. it says, would you like to tell me what happened to the money? she said, i don't know where the money is, i told you. she you said, you have told you. she you said, you have told me a pack of lies. she said, no, i haven't told you a pack of lies because i haven't stolen a penny. again, concentrating on words used in interview. pack of lies sounds somewhat like language you might see in a 1970s television detective show. was pack lies something that you would say. it’s a something that you would say. it's a ace something that you would say. it's a pace interview _ something that you would say. it's a pace interview and _ something that you would say. it's a pace interview and it's _ something that you would say. it's a pace interview and it's not _ something that you would say. it's a pace interview and it's not a - something that you would say. it�*s l pace interview and it's not a nice interview. before entering an

interview, the majority of times i speak to people and say to them, you know, it's not personal, the questions have to be asked. that's what it is. it is a criminal interview in accordance with pace. you have no difficulty with using those words. it you have no difficulty with using those words.— you have no difficulty with using those words. it went through the court system _ those words. it went through the court system afterwards - those words. it went through the court system afterwards and - those words. it went through the - court system afterwards and nothing was picked up by any defence team to say that that was oppressive or aggressive. so say that that was oppressive or aggressive-— aggressive. so because the defendant's _ aggressive. so because the| defendant's representatives aggressive. so because the - defendant's representatives didn't say that it was oppressive, you think that it is therefore appropriate language to use in an interview? is appropriate language to use in an interview? : . appropriate language to use in an interview? : , �* , appropriate language to use in an interview? a �*, ., interview? as i say, it's a difficult _ interview? as i say, it's a difficult interview. - interview? as i say, it's a difficult interview. with i interview? as i say, it's a i difficult interview. with the interview? as i say, it's a - difficult interview. with the same case can we _ difficult interview. with the same case can we look— difficult interview. with the same case can we look at _ difficult interview. with the same case can we look at another- difficult interview. with the same case can we look at another poll, j case can we look at another poll, please. we are now in november 2010. it's the same case. it's a memo to

you from phil taylor who is a legal executive in the criminal law division, could you score down, please. could you assist us with who phil taylor was. please. could you assist us with who philtaylorwas. i please. could you assist us with who phil taylor was.— phil taylor was. i think he was a leral phil taylor was. i think he was a legal executive _ phil taylor was. i think he was a legal executive who _ phil taylor was. i think he was a legal executive who works - phil taylor was. i think he was a legal executive who works in -- | legal executive who works in —— worked in the criminal law team. does that mean he was... he worked in the criminal law team. does that mean he was... he might be a paralegal- — does that mean he was... he might be a paralegal- does _ does that mean he was... he might be a paralegal. does it— does that mean he was... he might be a paralegal. does it sound _ does that mean he was... he might be a paralegal. does it sound a _ does that mean he was... he might be a paralegal. does it sound a bit - a paralegal. does it sound a bit like a paralegal— a paralegal. does it sound a bit like a paralegal or _ a paralegal. does it sound a bit like a paralegal or something i a paralegal. does it sound a bit l like a paralegal or something like that? , like a paralegal or something like that? . he like a paralegal or something like that? gas. he said that follows, the file has gone _ that? (1st he said that follows, the file has gone dead that? (lls he said that follows, the file has gone dead since that? ills he said that follows, the file has gone dead since the attendance note on the 15th ofjuly 2010. i have written to the defence but i have not mentioned another case to them, they can find out for themselves. what was your understanding of the duties of cross disclosure. the duty to disclose information from one case in another case? i information from one case in another case? :. . information from one case in another case? :, , , : information from one case in another case? ., , , . . ., case? i was expecting the criminal law division _ case? i was expecting the criminal law division to _ case? i was expecting the criminal law division to expose _ case? i was expecting the criminal law division to expose fully - case? i was expecting the criminal law division to expose fully what l law division to expose fully what was going on. 50.

law division to expose fully what was going on-— was going on. so, did you turn around on _ was going on. so, did you turn around on receiving _ was going on. so, did you turn around on receiving this - was going on. so, did you turn around on receiving this letter| around on receiving this letter and say, know that it's wrong it is disclosable. is say, know that it's wrong it is disclosable.— say, know that it's wrong it is disclosable. a ., ., ., disclosable. as far as i was aware, the were disclosable. as far as i was aware, they were notified _ disclosable. as far as i was aware, they were notified of _ disclosable. as far as i was aware, they were notified of the _ disclosable. as far as i was aware, they were notified of the other - disclosable. as far as i was aware, l they were notified of the other case at some stage. they were notified of the other case at some stage-— at some stage. that is not the ruestion at some stage. that is not the question i— at some stage. that is not the question i asked. _ at some stage. that is not the question i asked. at _ at some stage. that is not the question i asked. at some - at some stage. that is not the l question i asked. at some stage at some stage. that is not the - question i asked. at some stage they were informed _ question i asked. at some stage they were informed about _ question i asked. at some stage they were informed about the _ question i asked. at some stage they were informed about the other - question i asked. at some stage they were informed about the other case, | were informed about the other case, whether it was through me going back to them or another way. did whether it was through me going back to them or another way.— to them or another way. did that form of words _ to them or another way. did that form of words that _ to them or another way. did that form of words that was - to them or another way. did that form of words that was used - to them or another way. did that form of words that was used by i form of words that was used by someone from the criminal law team that they haven't mentioned another case and they can find out from themselves, did that cause you any concern? ~ �* . themselves, did that cause you any concern? ~ �* , ., , themselves, did that cause you any concern? ~ �*, ., , concern? well, it's not very good, is it, at all? _ concern? well, it's not very good, is it, at all? it's _ concern? well, it's not very good, is it, at all? it's like _ concern? well, it's not very good, is it, at all? it's like saying - concern? well, it's not very good, is it, at all? it's like saying go - is it, at all? it's like saying go and find it for yourself. it's not what i would expect from a set of lawyers. forthem what i would expect from a set of lawyers. for them to behave. this articular lawyers. for them to behave. this particular individual wasn't necessarily that.— particular individual wasn't

necessarily that. particular individual wasn't necessaril that. ., ., necessarily that. no, he was part of the division — necessarily that. no, he was part of the division and _ necessarily that. no, he was part of the division and acting _ necessarily that. no, he was part of the division and acting on _ necessarily that. no, he was part of the division and acting on behalf- necessarily that. no, he was part of the division and acting on behalf of| the division and acting on behalf of a lawyerfrom the the division and acting on behalf of a lawyer from the criminal law team. did this to send a memo back saying you got it wrong. is i did this to send a memo back saying you got it wrong-— you got it wrong. as i say, this is some 13 ago _ you got it wrong. as i say, this is some 13 ago now. _ you got it wrong. as i say, this is some 13 ago now. i _ you got it wrong. as i say, this is some 13 ago now. i know- you got it wrong. as i say, this is some 13 ago now. i know that - you got it wrong. as i say, this is some 13 ago now. i know that it i some 13 ago now. i know that it did come up when the defence team spoke about the other case i don't know when they were told. d0 about the other case i don't know when they were told.— about the other case i don't know when they were told. do you think full disclosure _ when they were told. do you think full disclosure was _ when they were told. do you think full disclosure was made - when they were told. do you think full disclosure was made about. full disclosure was made about expert reports in that case, for example?— expert reports in that case, for exam.le? ,, , m n :, expert reports in that case, for examle? ,,, a ., , example? yes because ms mcdonald put their own defence _ example? yes because ms mcdonald put their own defence expert _ example? yes because ms mcdonald put their own defence expert in. _ example? yes because ms mcdonald put their own defence expert in. they - their own defence expert in. they ut their their own defence expert in. they put their own _ their own defence expert in. they put their own expert _ their own defence expert in. they put their own expert in _ their own defence expert in. they put their own expert in that particular case?— put their own expert in that particular case? put their own expert in that articular case? , : ., particular case? yes. but from the -- but from _ particular case? yes. but from the -- but from the — particular case? yes. but from the -- but from the other— particular case? yes. but from the -- but from the other case - particular case? yes. but from the -- but from the other case do - particular case? yes. but from the -- but from the other case do you | -- but from the other case do you know what — -- but from the other case do you know what was _ -- but from the other case do you know what was disclose? - -- but from the other case do you know what was disclose? no. - -- but from the other case do you i know what was disclose? no. every look at know what was disclose? iiif?. every look at another —— if we look at another one. this is one month before that e—mail we have an e—mail

from someone else including some documents from the other case including the final technical experts report and it's that document that i would like to take you to that can be found at poll 00169420. thank you. could we please look at page 17 which are the conclusions in the expert report that was obtained. thank you very much. it says as follows, it is evident that trial balances and period balances showed discrepancies throughout the period for which transactions were provided. it appears that no action was taken by the post office to

investigate these discrepancies or to ensure that the subpostmaster was competent to prevent them from arising. instead they removed an employee on suspicion of theft. neither action appears to have resolved the issue. if we look at 3.3 it says is followed that the horizon system has had problems in the past as acknowledged by mr jenkins that is garethjenkins who in relation to calendar square. unfortunately, the post office has not given us the opportunity to assess the possible impact nor have they provided a list of known defects in horizon. the travellers cheque problem isn't illustration of the known defects that we independently identified, mrjenkins confirmed that fujitsu retained a full list has not been released. the horizon system is a component of the

full post office operating environment and elements of this environment and elements of this environment can result in changes to the cash balances recorded at the branch, transaction corrections and emittance is. mrjenkins was unable to provide any opinion as the integrity of these systems was provided with no opportunity to investigate them. so this is a report that you receive that contains quite clear criticisms of the horizon system. do you agree with that? , the horizon system. do you agree with that? yes. your evidence began toda not with that? ils your evidence began today not knowing about bugs or defects in the system. it does seem that you received at least a defence expert report that did identify these kinds of issues with horizon. people said about bugs or defects but if you asked me about what bugs or defects, i couldn't tell you.

that is why i say i didn't know about bugs, errors or defects. nobody said that there was a particular bug or error or defect. that's what i am saying. no one has ever come or cascaded it down to see what particular book, error or defect was in the system. this kind of information _ defect was in the system. this kind of information is _ defect was in the system. this kind of information is presumably - defect was in the system. this kindj of information is presumably pretty pertinent to the case of ms mcdonald that you are charged with. prosecution, the criminal law team it was passed to them. you prosecution, the criminal law team it was passed to them.— it was passed to them. you say it would be. _ it was passed to them. you say it would be. you — it was passed to them. you say it would be, you didn't _ it was passed to them. you say it would be, you didn't say - it was passed to them. you say it would be, you didn't say it - it was passed to them. you say it would be, you didn't say it was. i it was passed to them. you say it| would be, you didn't say it was. it was. they would have had it because of the nature of their someone sent it to us for information and it would have been passed to the criminal law team at the time. for the case. ~ , ., criminal law team at the time. for the case. ~ . ., criminal law team at the time. for the case. ~ i. . ., ., the case. when you say criminal law team do you — the case. when you say criminal law team do you mean _ the case. when you say criminal law team do you mean the _ the case. when you say criminal law team do you mean the post - the case. when you say criminal law team do you mean the post office? | team do you mean the post office? the post office lawyers. they told me that mr singh came on board in

2012 when royal mail group became deformed and royal mail letters became independent as a private company that is when mr singh was attached to the post office. before that, in london in the criminal law decision. to that, in london in the criminal law decision. ., , decision. to somebody in the criminal law _ decision. to somebody in the criminal law division - decision. to somebody in the criminal law division would i decision. to somebody in the i criminal law division would have been aware of this and your expectation was that they would be responsible for disclosing that in another case?— responsible for disclosing that in another case? that is correct, yes. and that was _ another case? that is correct, yes. and that was not _ another case? that is correct, yes. and that was not something i another case? that is correct, yes. and that was not something that i another case? that is correct, yes. i and that was not something that you need to apply your own mind to? is i need to apply your own mind to? as i said, all need to apply your own mind to? as i said. all the — need to apply your own mind to? s i said, all the information i would have had would have been sent to our criminal law team and they may get to disclosure to the defence. did you expect the criminal law team themselves to take information and disclose it in another one of their cases? ~ . . : disclose it in another one of their cases? ~ , , . ., disclose it in another one of their cases? ,, . ., cases? with respect to something like this, i would _ cases? with respect to something like this, i would have _ cases? with respect to something like this, i would have expected i like this, i would have expected them as lawyers to let other people

know. ~ , ., them as lawyers to let other people know. ~ , :, :, them as lawyers to let other people know. ~ , ., ., , know. when you are signing the disclosure _ know. when you are signing the disclosure statements - know. when you are signing the disclosure statements of - know. when you are signing the i disclosure statements of schedule of a news material, schedule of use material, schedule a sensitive material, schedule a sensitive material, did you cast your mind to that issue as to whether there was information that didn't appear on your schedule but that was held in relation to another case? absolutely dead. -- relation to another case? absolutely dead- -- matt _ relation to another case? absolutely dead. -- matt can't _ relation to another case? absolutely dead. -- matt can't say _ relation to another case? absolutely dead. -- matt can't say i _ relation to another case? absolutely dead. -- matt can't say i did. - relation to another case? absolutely dead. -- matt can't say i did. if i i dead. —— matt can't say i did. if i put anything on it would have been filled in properly but if i haven't filled in properly but if i haven't filled in properly but if i haven't filled in properly i would have expected the lawyers to come back to me and say that i have filled the form incorrectly. iflan me and say that i have filled the form incorrectly.— me and say that i have filled the form incorrectly. can you not see a roblem form incorrectly. can you not see a problem with _ form incorrectly. can you not see a problem with signing _ form incorrectly. can you not see a problem with signing a _ form incorrectly. can you not see a problem with signing a disclosure i problem with signing a disclosure statement of schedule of disclosure and at the same time assuming that there is other information not on there is other information not on there that was going to be disclosed to a party? gi there that was going to be disclosed to a -a ? . ., , �* , to a party? of course. there's alwa s

to a party? of course. there's always issues _ to a party? of course. there's always issues if _ to a party? of course. there's always issues if something i to a party? of course. there's| always issues if something has to a party? of course. there's i always issues if something has not been told but my understanding at the time was that i disclose everything that was available to me to them. do everything that was available to me to them. ,., ., everything that was available to me to them. ,:, :, , everything that was available to me to them. ., , ., , ., to them. do not see a problem though in ou to them. do not see a problem though in you creating — to them. do not see a problem though in you creating a _ to them. do not see a problem though in you creating a schedule _ to them. do not see a problem though in you creating a schedule of— in you creating a schedule of material that doesn't include material that doesn't include material that doesn't include material that you think for some reason is going to be disclosed to somebody else. iii reason is going to be disclosed to somebody else.— reason is going to be disclosed to somebody else. all the information i had in that file _ somebody else. all the information i had in that file was _ somebody else. all the information i had in that file was sent _ somebody else. all the information i had in that file was sent to _ somebody else. all the information i had in that file was sent to the i had in that file was sent to the criminal law team.— criminal law team. this wasn't enou:h criminal law team. this wasn't enough while _ criminal law team. this wasn't enough while it _ criminal law team. this wasn't enough while it was _ criminal law team. this wasn't enough while it was in - criminal law team. this wasn'tj enough while it was in another criminal law team. this wasn't i enough while it was in another case. it was held by the criminal law team, i would expect them to disclose it. so team, i would expect them to disclose it— disclose it. so were they the disclosure — disclose it. so were they the disclosure offices _ disclose it. so were they the disclosure offices in - disclose it. so were they the disclosure offices in the i disclose it. so were they the i disclosure offices in the case? ultimately they are the disclosure officers, it would be put in a statement and sent to them and sent to the defence was i did not disclose anything directly to the defence. :, :, disclose anything directly to the defence. ., ., ,., ., , defence. you are reporting to be the disclosure officer, _ defence. you are reporting to be the disclosure officer, are _ defence. you are reporting to be the disclosure officer, are you _ defence. you are reporting to be the disclosure officer, are you saying i disclosure officer, are you saying that you nevertheless assumed that there was some other disclosure officer? :. .

there was some other disclosure officer? ., , , , , there was some other disclosure officer? ., , , ,, ., officer? that is the process at the post office _ officer? that is the process at the post office put — officer? that is the process at the post office put in. _ officer? that is the process at the post office put in. all— officer? that is the process at the post office put in. all of- officer? that is the process at the post office put in. all of my i post office put in. all of my paperwork would be put there and the exhibits would be signed off in the committalfile and sent exhibits would be signed off in the committal file and sent to the criminal law team who would then disclose everything to the defence. can you see a problem with what is being made here.— being made here. there's always a roblem if being made here. there's always a problem if too _ being made here. there's always a problem if too many _ being made here. there's always a problem if too many people i being made here. there's always a problem if too many people are i problem if too many people are involved, they think somebody else may have done it. but i would have expected the criminal law team to be the full disclosure officers.— the full disclosure officers. saying that there is _ the full disclosure officers. saying that there is always _ the full disclosure officers. saying that there is always problems. i the full disclosure officers. saying| that there is always problems. are you not troubled by that in the context of criminal prosecution where somebody could go to prison? as i said, this inquiry is built on merit and what i had would have been sent to the criminal law team. do not reflect on and say, producing a schedule of the criminal proceedings where somebody could go to prison and not including all of the material on that schedule? i

produced a schedule of all the relevant information i had to hand concerning that inquiry. that relevant information i had to hand concerning that inquiry.— concerning that inquiry. that you are saying _ concerning that inquiry. that you are saying that — concerning that inquiry. that you are saying that there _ concerning that inquiry. that you are saying that there was - concerning that inquiry. that you are saying that there was otheri are saying that there was other material that you assumed was a disclose? ., , ., material that you assumed was a disclose? ., ., disclose? know you said was that other material _ disclose? know you said was that other material on _ disclose? know you said was that other material on the _ disclose? know you said was that other material on the criminal i disclose? know you said was that | other material on the criminal law team would have had that i expected them to do it. let team would have had that i expected them to do it— them to do it. let me look at the disclosure _ them to do it. let me look at the disclosure schedule _ them to do it. let me look at the disclosure schedule in _ them to do it. let me look at the disclosure schedule in this i disclosure schedule in this particular case that was signed by you. do you think we will find this particular report? i you. do you think we will find this particular report?— you. do you think we will find this particular report? i don't think so. i ma particular report? i don't think so. i may have — particular report? i don't think so. i may have done _ particular report? i don't think so. i may have done but _ particular report? i don't think so. i may have done but i _ particular report? i don't think so. i may have done but i don't i particular report? i don't think so. i may have done but i don't think. i may have done but i don't think so. �* ., i may have done but i don't think so. �* :, y :, ~ i may have done but i don't think so. �* ., i. ~ ., so. but do you think that the problem. — so. but do you think that the problem. i — so. but do you think that the problem, i think— so. but do you think that the problem, i think forget i so. but do you think that the | problem, i think forget about so. but do you think that the i problem, i think forget about the technicalities of that. the whole idea of— technicalities of that. the whole idea of having a disclosure statement signed by someone is to make _ statement signed by someone is to make that — statement signed by someone is to make that person responsible for its contents. _ make that person responsible for its contents, yes. make that person responsible for its contents. yes-— contents, yes. correct serve. but as isa contents, yes. correct serve. but as i say... invariably _ contents, yes. correct serve. but as i say... invariably as _ contents, yes. correct serve. but as i say... invariably as i _ contents, yes. correct serve. but as

i say... invariably as i understand i i say... invariably as i understand it, the i say. .. invariably as i understand it, the chief— i say... invariably as i understand it, the chief investigating - i say... invariably as i understand it, the chief investigating officer i it, the chief investigating officer becomes— it, the chief investigating officer becomes a disclosure officer and for the moment let's assume that's valid. _ the moment let's assume that's valid. 0k~ — the moment let's assume that's valid, ok. so the chief investigating officer has the responsibility for ensuring that all that should be disclosed in that statement is disclosed because he or she is— statement is disclosed because he or she is putting their name at the bottom — she is putting their name at the bottom. ., . she is putting their name at the bottom-- so _ she is putting their name at the bottom.- so at - she is putting their name at the bottom.- so at the i she is putting their name at the bottom.- so at the very| bottom. correct. so at the very least, before _ bottom. correct. so at the very least, before you _ bottom. correct. so at the very least, before you put _ bottom. correct. so at the very least, before you put your- bottom. correct. so at the very| least, before you put your name there _ least, before you put your name there at — least, before you put your name there at the bottom, if you are going — there at the bottom, if you are going to — there at the bottom, if you are going to assume that mr x, a lawyer in the _ going to assume that mr x, a lawyer in the criminal law department is going _ in the criminal law department is going to — in the criminal law department is going to provide some documentation to the _ going to provide some documentation to the defence, should you not liaise _ to the defence, should you not liaise with _ to the defence, should you not liaise with him to ensure that that is done? — liaise with him to ensure that that is done? i— liaise with him to ensure that that is done? , ., ., , ., ., is done? i understand what you are sa int is done? i understand what you are sa in: and is done? i understand what you are saying and what — is done? i understand what you are saying and what i _ is done? i understand what you are saying and what i have _ is done? i understand what you are saying and what i have said - is done? i understand what you are saying and what i have said that i is done? i understand what you are saying and what i have said that allj saying and what i have said that all the information i had to hand was sent to the lawyers.—

sent to the lawyers. putting it siml . sent to the lawyers. putting it simply- you — sent to the lawyers. putting it simply. you have _ sent to the lawyers. putting it simply. you have agreed i sent to the lawyers. putting it simply. you have agreed that| sent to the lawyers. putting it i simply. you have agreed that it was correct _ simply. you have agreed that it was correct for— simply. you have agreed that it was correct for the intonation in the seema — correct for the intonation in the seema misra case to be disclosed in subsequent cases because it was potentially helpful for the defence. therefore, in a case where the disclosure _ therefore, in a case where the disclosure officer was going to sign the disclosure form should he or she not ensure _ the disclosure form should he or she not ensure before the form is signed that the _ not ensure before the form is signed that the information in the seema misra _ that the information in the seema misra case — that the information in the seema misra case is there and ready for disclosure?— misra case is there and ready for i disclosure?_ thank disclosure? ultimately, yes. thank ou. just disclosure? ultimately, yes. thank you- just two _ disclosure? ultimately, yes. thank you. just two more _ disclosure? ultimately, yes. thank you. just two more documents i disclosure? ultimately, yes. thank. you. just two more documents before we take our mid—morning break. can we take our mid—morning break. can we look at file 0009859, please. we are sticking with the case of macdonald. this was a statement that miss mcdonald made in 2013, after her case can we please look at page

four? she says as follows, shortly after i have been audited and my post office was taken away from me, i read an article in a magazine that highlighted other people who had suffered or were about to suffer the same how i was coming through. i then got in touch with the writer of then got in touch with the writer of the article who then put me in touch with the justice for sub subpostmaster is alliance. this was a very big surprise to me because i was led to believe by the investigation for the post office, steve bradshaw that i was the only one in this position and this has never happened before. steve bradshaw is a liar and he knew the whole time as i am friends with another person here prosecuted he was a member of thejustice alliance for subpostmaster is. it was just unbelievable how i was going to feel like i was the only one and it made me isolated and paranoid about what was going on through the whole

situation. had you mentioned the seema misra case, miss mcdonald might have realised that she wasn't the only one. i might have realised that she wasn't the only one-— the only one. i never said that to her, that is _ the only one. i never said that to her, that is incorrect _ the only one. i never said that to her, that is incorrect that - her, that is incorrect that statement.— her, that is incorrect that statement. ~ ., ., ~' her, that is incorrect that statement. ~ ., statement. well, we will look at that because — statement. well, we will look at that because we _ statement. well, we will look at that because we have _ statement. well, we will look at that because we have seen i statement. well, we will look at that because we have seen and| statement. well, we will look at i that because we have seen and that can come down thank you we have seen lisa brennan being told in her interview that nobody else's is making mistakes. i’sare interview that nobody else's is making mistakes. interview that nobody else's is makint mistakes. �* , ., ., making mistakes. i've explained that in that branch _ making mistakes. i've explained that in that branch she _ making mistakes. i've explained that in that branch she was _ making mistakes. i've explained that in that branch she was the _ making mistakes. i've explained that in that branch she was the only i in that branch she was the only person in that branch that was having that particular issue. we have seen _ having that particular issue. we have seen the letter from the lawyer of the post office taking a conscious decision not to tell jacqueline mcdonald about seema misra's case. you remember that document, don't you? that misra's case. you remember that document, don't you?— misra's case. you remember that document, don't you? that was after the interview- _ document, don't you? that was after the interview. so _ document, don't you? that was after the interview. so jacqueline - the interview. so jacqueline mcdonald's _ the interview. so jacqueline mcdonald's complaint i the interview. so jacqueline mcdonald's complaint that i the interview. so jacqueline i mcdonald's complaint that she the interview. so jacqueline - mcdonald's complaint that she was told she was the only one rings true, doesn't it?— told she was the only one rings true, doesn't it? that's not true. i never said — true, doesn't it? that's not true. i never said to _ true, doesn't it? that's not true. i never said to her _ true, doesn't it? that's not true. i never said to her that _

true, doesn't it? that's not true. i never said to her that she - true, doesn't it? that's not true. i never said to her that she was i true, doesn't it? that's not true. i never said to her that she was the only one. never said to her that she was the onl one. :. �* . never said to her that she was the onl one. ., �*, ,, ., only one. that's consistent with not raising seema _ only one. that's consistent with not raising seema misra's _ only one. that's consistent with not raising seema misra's case. - only one. that's consistent with not raising seema misra's case. in i only one. that's consistent with not raising seema misra's case. in the i raising seema misra's case. in the context of the _ raising seema misra's case. in the context of the interview _ raising seema misra's case. in the context of the interview at - raising seema misra's case. in the context of the interview at the i raising seema misra's case. in the. context of the interview at the time i have not said to jacqueline mcdonald that she was the only one. and also with that i don't know who she is friends with and i don't know whether she was a member of thejs essay. did whether she was a member of the js essa . , y :, ~ whether she was a member of the js essa . , i. ~ ., essay. did you think that jacqueline mcdonald was _ essay. did you think that jacqueline mcdonald was an _ essay. did you think that jacqueline mcdonald was an important - essay. did you think that jacqueline mcdonald was an important case i essay. did you think that jacqueline mcdonald was an important case to j mcdonald was an important case to when? ., mcdonald was an important case to when? :, �* , :, mcdonald was an important case to when? ., �*, ., , mcdonald was an important case to when? ., �*, ., , when? no. it's a case, each case is treated in — when? no. it's a case, each case is treated in its _ when? no. it's a case, each case is treated in its own _ when? no. it's a case, each case is treated in its own merit. _ when? no. it's a case, each case is treated in its own merit. said i when? no. it's a case, each case is treated in its own merit. said this i treated in its own merit. said this one isjust _ treated in its own merit. said this one isjust like _ treated in its own merit. said this one isjust like any _ treated in its own merit. said this one isjust like any other- treated in its own merit. said this one isjust like any other case? i treated in its own merit. said this| one isjust like any other case? all one is 'ust like any other case? all i did one is just like any other case? ill i did was interview, gather the information and send the file. ind information and send the file. and treat everyone _ information and send the file. and treat everyone fairly and equally? as far as i know i did. can we please look at paul 0016956, please.

this is, i think a self appraisal form for 2010—11, is that why? that form for 2010-11, is that why? that is correct- — form for 2010-11, is that why? that is correct. weight _ form for 2010-11, is that why? that is correct. weight if _ form for 2010—11, is that why? trilgt is correct. weight if we screw over to the next page... we is correct. weight if we screw over to the next page. . ._ is correct. weight if we screw over to the next page... we have at the bottom of that _ to the next page... we have at the bottom of that page, _ to the next page... we have at the bottom of that page, your - to the next page... we have at the bottom of that page, your position| bottom of that page, your position performance. it says i take ownership of the objectives, i agree for myself and my team that will help deliver the business goals, i regularly discuss my team's progress, i ensure that business goals and current team performance are highly visible to the whole team. i addressed are highly visible to the whole team. iaddressed poor are highly visible to the whole team. i addressed poor performance and recognise achievement. could be scroll down to the bottom of that page, please? it is numberfive, on the 5th ofjuly 2010, at preston crown court the offender pleaded guilty to false accounting but would

not accept theft.