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particular case, mr ishaq. and it is sent to you-— sent to you. she was part of the casework team. _ sent to you. she was part of the casework team. she _ sent to you. she was part of the casework team. she was - sent to you. she was part of the casework team. she was a i sent to you. she was part of the casework team. she was a case | casework team. she was a case worker, casework team. she was a case worker. you — casework team. she was a case worker. you are _ casework team. she was a case worker, you are an _ casework team. she was a case worker, you are an investigatorj casework team. she was a case i worker, you are an investigator and she gives an opinion as to sufficiency of evidence. ida. she gives an opinion as to sufficiency of evidence. no. not at all. what sufficiency of evidence. no. not at all- what she _ sufficiency of evidence. no. not at all. what she is _ sufficiency of evidence. no. not at all. what she is basically - sufficiency of evidence. no. not at all. what she is basically done i sufficiency of evidence. no. not at all. what she is basically done is l all. what she is basically done is forwarded on. that's been addressed from legal services because this is a round about the time of the crossover between the criminal law team and cartwright king taking over completely. so the legal services, as the royal mail group when the split came, all these royal mail letters they would then send it to the casework team and in this case maureen and they would be forwarded on and be attached to the files. tiara on and be attached to the files. two whose attention was this particular document. i5 whose attention was this particular document. . ., whose attention was this particular document. , ., , . , document. is to let the security team know- _

Khayyam-ishaq , Seema-misra-case , Case , Evidence , Team , Casework-team , Opinion , Part , Case-worker , Sufficiency , Investigator , You

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knowledge of that time people had told so i probably would have - knowledge of that time people had i told so i probably would have known. lets look at this. this is another case around a similar time, 2nd of march 2011. this is the case of damien owen. was this a case you will also the investigating officer? you are involved in that case? hat you are involved in that case? not at all. you are involved in that case? not at all- you — you are involved in that case? not at all. you didn't _ you are involved in that case? not at all. you didn't see _ you are involved in that case? not at all. you didn't see this - at all. you didn't see this dispensed _ at all. you didn't see this dispensed statement - at all. you didn't see this dispensed statement if . at all. you didn't see this | dispensed statement if we at all. you didn't see this - dispensed statement if we scroll down? 140 dispensed statement if we scroll down? ., ~ ., ., ., ., down? no knowledge of that. not damien owen. _ down? no knowledge of that. not damien owen. ok. _ down? no knowledge of that. not damien owen. ok. let's- down? no knowledge of that. not damien owen. ok. let's return i down? no knowledge of that. not damien owen. ok. let's return to kha�* am damien owen. ok. let's return to khayyam ishaq's _ damien owen. ok. let's return to khayyam ishaq's case, _ damien owen. ok. let's return to khayyam ishaq's case, then. - damien owen. ok. let's return to khayyam ishaq's case, then. we i damien owen. ok. let's return to - khayyam ishaq's case, then. we have the defence statement, we've just seen the defence statement of mr owen's case. let's look at the statement in khayyam ishaq's case. this is august 2012. can we please turn over the page? this is a document that you would have seen at

Seema-misra-case , Case , Knowledge , People , 2011 , 2nd-of-march-2011 , 2 , Witness-statement , Statement , Officer , Damien-owen , Hat

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example, i don't know what technical issues were investigated by the post office. i can't recall if any or what information i received concerning bugs, errors or defects in the horizon system. we had this morning that you are aware of those magazine articles in 2010 and there was an e—mail correspondence the same year where there was discussion about a number of challenges to horizon integrity. what investigation had you carried out in relation to product integrity? itrailien relation to product integrity? when the roduct relation to product integrity? when the product came _ relation to product integrity? when the product came around, - relation to product integrity? tween the product came around, you relation to product integrity? m�iez�i the product came around, you can relation to product integrity? “team the product came around, you can see in this particular case, it was the case of sheets and stamps had been reversed out of the system. that ou've reversed out of the system. that you've said _ reversed out of the system. that you've said here _ reversed out of the system. that you've said here on _ reversed out of the system. that you've said here on your- reversed out of the system. that you've said here on your report that there is... you can't see any failures in product integrity. what

Horizon-system , Issues , Post-office , Information , Defects , Bugs , Example , Errors , E-mail , Number , Investigation , Magazine-articles

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from them so this predates that statement. from them so this predates that statement-— from them so this predates that statement. ., �* , �* , ., ,~ statement. that's when he's asking me to no statement. that's when he's asking me to go down and _ statement. that's when he's asking me to go down and take _ statement. that's when he's asking me to go down and take the - me to go down and take the statement. br; me to go down and take the statement.— me to go down and take the statement. �* , ., , ., , ., ., statement. by that stage you would already said — statement. by that stage you would already said in _ statement. by that stage you would already said in a _ statement. by that stage you would already said in a witness _ statement. by that stage you would already said in a witness statement | already said in a witness statement no problems or discrepancies had been reported subsequent to mr ishaq. my question is how did you form the opinion? it ishaq. my question is how did you form the opinion?— ishaq. my question is how did you form the opinion? it would have been at the time we _ form the opinion? it would have been at the time we had _ form the opinion? it would have been at the time we had not found - form the opinion? it would have been at the time we had not found any i at the time we had not found any issues there had been reported any issues there had been reported any issues with the horizon. i5 issues there had been reported any issues with the horizon. is an assumption- _ issues with the horizon. is an assumption. no. _ issues with the horizon. is an assumption. no. again, i issues with the horizon. is an i assumption. no. again, without havinu assumption. no. again, without having the _ assumption. no. again, without having the case _ assumption. no. again, without having the case file _ assumption. no. again, without having the case file and - assumption. no. again, withoutj having the case file and whether assumption. no. again, without i having the case file and whether the call logs had been obtained from horizon. but there was nothing at the time to indicate any issues. you said no problems or discrepancies had been reported. really, what i am asking you is to are we to read that very carefully that you had referred

Witness-statement , Statement , Stage , Problems , Discrepancies , Witness , Statement-me , Br , Khayyam-ishaq , Issues , Question , Opinion

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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

It , Defence , Lawyers , Cases , Intonation , Seema , Siml , Seema-misra-case , Information , I-disclosure , Form , Officer

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fishing expedition isjust throwing anything around to see what comes out from it. we have seen a number of request for disclosure, did you seek and obtain the information that was sought. either by sarah porter or from either by sarah porter orfrom our prosecution agency can't write king didn't do it if they had asked me for anything i would have... you would have _ for anything i would have... you would have done _ for anything i would have... you would have done whatever they requested? we spoke earlier about the reliance of legal teams to cross disclose from other cases. here we have cartwright king, an external firm perhaps the lawyers for the case and you also have sarah porter who is potentially yet another external firm.— external firm. cartwright king became the —

Ijy-disclosure , Number , Information , Anything , Request , Fishing-expedition-isjust , In-particular-inquiry-didn-t , Sarah-porter , King , Prosecution-agency , Orfrom , Cases

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place because front and centre for their defence is the horizon system and the reliability of the horizon system. in what sense are we to understand that mr smith has any idea whether obtaining data for that period would have or would not have assisted or undermined at the crowds case? m assisted or undermined at the crowds case? ~ ~ assisted or undermined at the crowds case? ~' ~ ,, , ., case? i think mr smith is going, based on the — case? i think mr smith is going, based on the question _ case? i think mr smith is going, based on the question that - case? i think mr smith is going, based on the question that the l based on the question that the postmaster at the time was at balance each and every week and each and every month sol balance each and every week and each and every month so i think that mr smith has made the decision where that, you know, there was no issues showing, no data would show any loss. ., ., , ., showing, no data would show any loss. ., ., ~ ., . loss. how would you know that? because the _ loss. how would you know that? because the data _ loss. how would you know that? because the data has _ loss. how would you know that? because the data has got - loss. how would you know that? because the data has got the . because the data has got the transactions, if you've got the data it would show all the transactions that were taken in so what payments you made and if it's balancing, everything is balanced out, the left

Horizon-system , Defence , Martin-smith , Place , National-business-support-centre , Reliability , Front , Sense , Seema-misra-case , Case , Postmaster , Question

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subpostmaster is is not a reasonable thing to disclose? ii subpostmaster is is not a reasonable thing to disclose?— thing to disclose? if there was issues there _ thing to disclose? if there was issues there than _ thing to disclose? if there was issues there than the - thing to disclose? if there was issues there than the lawyersl thing to disclose? if there was i issues there than the lawyers knew about it they should disclose it. but you know about it. the lawyers. as i said, but you know about it. the lawyers. as i said. i — but you know about it. the lawyers. as i said, i expect _ but you know about it. the lawyers. as i said, i expect the _ but you know about it. the lawyers. as i said, i expect the lawyers i but you know about it. the lawyers. as i said, i expect the lawyers to i as i said, i expect the lawyers to do it, not me. i had disclosed all relevant work i had pertaining to the case and the lawyers should deal with the defence lawyers. flan the case and the lawyers should deal with the defence lawyers.— with the defence lawyers. can we lease with the defence lawyers. can we please look _ with the defence lawyers. can we please look at — with the defence lawyers. can we please look at paul _ with the defence lawyers. can we please look at paul 0005962. i with the defence lawyers. can we| please look at paul 0005962. we with the defence lawyers. can we i please look at paul 0005962. we are in the 6th of february now. we have an e—mailfrom martin smith from cartwright king to yourself. i am going to just read from this e—mail. it says the defence were unable to persuade the judge to order any further disclosure. the defence solicitor told me that the defendant still operate the store in which the post office is situated. the defendant hadn't instructed them

Issues , Lawyers , Thing , Subpostmaster , Lawyersl , Ii-subpostmaster , Seema-misra-case , It , Case , Defence , Work , Defence-lawyers

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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

I-disclosure , Lawyers , Disclosure-schedule , Material , People , Mind , Issue , Disclosure-statements , Statements , News-material , Disclosure-statements-know , Information

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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

Defects , Defect , Nobody , Bugs , Error , No-one , Errors , Bug , Book , One , Information , Criminal-law-team