1 Wednesday, 16 March 2022 2 (11.30 am) 3 MS HODGE: Good morning, sir, can you see and hear us? 4 SIR WYN WILLIAMS: I can, thank you very much. A little 5 while ago I introduced myself to Ms Beisner, so we've 6 already said hello, all right? 7 So over to you, Ms Hodge. 8 MS HODGE: Thank you, sir. Our witness today is 9 Julie Beisner who is appearing remotely. Ms Beisner, 10 I will ask Christine, the usher, to take you through 11 your oath. 12 JULIE MARIE BEISNER (sworn) 13 Questioned by MS HODGE 14 MS HODGE: Ms Beisner, my name is Catriona Hodge, as you 15 know, and I ask questions on behalf of the Inquiry. 16 Please state your full name. 17 A. Julie Marie Beisner. 18 Q. You made a statement, Ms Beisner, on 10 March this 19 year; is that correct? 20 A. That's correct, yes. 21 Q. Do you have a copy of your statement before you? 22 A. Yes, I have. 23 Q. Could I ask you please to turn to the final page? 24 A. Okay. 25 Q. Do you see your signature at the bottom of that page? 1 1 A. Yes, I see my signature. 2 Q. Have you had an opportunity to read your statement 3 again since it was first made? 4 A. Yes, I have. 5 Q. Is the content of the statement true to the best of 6 your knowledge and belief? 7 A. It is, yes. 8 Q. Is there anything you wish to correct in the 9 statement? 10 A. Yes. Paragraph 16 should read "Network Business 11 Support Centre" not "National". 12 Q. Thank you. 13 I'm going to begin by asking you some questions 14 about your background. Where are you from? 15 A. I'm from North Kilworth in Leicestershire. 16 Q. Where did you attend school? 17 A. Portland House school in Leicester. 18 Q. What qualifications did you obtain before leaving 19 school? 20 A. Seven O Levels, three A Levels. 21 Q. What did you do upon leaving school? 22 A. Upon leaving school, I was helping out in the 23 Post Office selling stamps but also, in my spare time, 24 I decided to study for a law degree. 25 Q. Who ran the Post Office where you were working? 2 1 A. The Post Office has been in my family going back for 2 a long time but, at that time, it was my grandmother 3 and my grandfather, and then it was my uncle after 4 that. 5 Q. Where was that Post Office located? 6 A. In North Kilworth, a small village. 7 Q. You've mentioned the Post Office being in your 8 family's ownership. For how long had they owned that 9 particular Post Office? 10 A. Since 1847. 11 Q. As a result of their ownership of that Post Office, 12 what role did your family play in their local 13 community? 14 A. Well, they were at the heart of the community. 15 I mean, anything that was going on, any village fêtes, 16 "Can you help out with this?" all sorts of things, you 17 know, "I've got a form to fill in, can you sign this 18 form for us?" et cetera. 19 Q. You've mentioned that you continued with your 20 education after leaving school. What qualifications 21 did you obtain? 22 A. I got an honours law degree from the University of 23 London. 24 Q. Did you pursue a career in the law? 25 A. I did become a tutor for the college that I studied 3 1 with and, at one point, I did think about pursuing 2 a law -- law as a career but then decided to carry on 3 the family tradition and take on the role of 4 subpostmaster. 5 Q. How old were you when you took over running the 6 Post Office? 7 A. I can remember I took it on in 1996. I can't remember 8 exactly how old I was but probably 20-something. 9 I can't remember, sorry. 10 Q. Not at all. 11 A. I'm a little bit nervous. I've not done anything like 12 this before. 13 Q. Please don't be nervous. 14 You've explained you took -- you were appointed 15 as the subpostmistress in 1996; is that right? 16 A. That's correct, yes. 17 Q. Did you employ anyone to assist you in running the 18 branch? 19 A. No. No, I didn't. 20 Q. Do you recall when the Horizon System was installed in 21 your branch in North Kilworth? 22 A. Around about 1999. 23 Q. Before the system was installed, how did you record 24 transactions and balance your accounts? 25 A. It was all paper-based transactions. So you always 4 1 had a copy of every document and, if there was 2 a discrepancy of some sort you could always trace it 3 because you'd got a copy. With Horizon it's all 4 computer-generated, so there's no paper copy you can 5 refer back to. 6 Q. You said it was approximately 1999 when the system was 7 installed. 8 A. Yes. 9 Q. What training did you receive from the Post Office 10 before the system was installed in your branch? 11 A. Not a great deal. It was one and a half days of 12 training at a hotel in Leicester. The first day was 13 on transactions, such as selling stamps. The second 14 day was on balancing. And I do recall at the end of 15 the first day my head was absolutely spinning with all 16 the information that we had to carry. I'd never used 17 a computer before and, yes, it was how am I going to 18 manage with all of this that I've never done before? 19 Q. What in-branch training did you receive from the 20 Post Office? 21 A. They sent out -- they were called Field Support 22 Officers and you had one Field Support Officer who 23 came to the office about three or four days during the 24 week when the Horizon System had been installed and 25 they shadowed you when you were doing transactions, 5 1 which, in theory, was quite a good idea but, of 2 course, it was dependent upon customers coming in and 3 doing, for example, pensions. 4 If a customer didn't come in and require 5 a pension to be paid, then you didn't get to 6 experience how you would do that transaction on the 7 computer system. 8 Q. What was your impression of the quality of the 9 training that you received? 10 A. Woefully inadequate. We had these huge binders of 11 information as well, which we were allowed to take 12 away with us and most of the information was 13 irrelevant and confusing. 14 Q. When did you first start experiencing problems in 15 using the Horizon System? 16 A. Around about 2006. 17 Q. What was the nature of the problems that you 18 experienced? 19 A. Shortfalls, you know, small shortfalls £10/£20, 20 something like that and then they gradually became 21 larger amounts. I've got two occasions that stand 22 out, one which was -- shall I explain? 23 Q. Please do. 24 A. One that was for £300, they said I owed them, for 25 an alleged shortfall and, at that time, I just 6 1 thought, well, I've got no option other than to pay it 2 so I paid it. Then another one occurred in 3 August 2007 and I decided to dispute that and I argued 4 I was not going to pay it and so they said, "Well, you 5 have to pay it, it's a shortfall in your accounts". 6 "No, I'm not going to pay it". So they said, 7 "If you don't pay it, we will take it out of your bank 8 account", and that's exactly what they did. And the 9 bank said that they should not have done that. It's 10 an unlawful and illegal act. You can't just take 11 money out of somebody's bank account like that. But 12 the Post Office could. 13 If I can just read this to you, it was 14 a document that I have in my possession. Let me just 15 find that one for you. It was talking about the 16 changes to how shortfalls would be brought to account. 17 This is from 2003. Just to summarise, it says that: 18 "From November 2003 any error notices not 19 brought to account which resulted in a shortfall can 20 be deducted from subpostmasters' remuneration. This 21 new process has been made in consultation with the 22 National Federation of SubPostmasters." 23 Well, I think it's a pity individual postmasters 24 were not consulted before this new process was 25 implemented. 7 1 Q. Ms Beisner, the document to which you just referred 2 now describes a process by which the Post Office 3 proposed making deductions from a postmaster's salary. 4 Is that what you understood occurred on that occasion 5 or was it an actual deduction from the money in your 6 bank account? 7 A. They took the money from the bank account. So if you 8 were paid -- I don't know, you were paid a certain 9 amount for the remuneration, you'd have that money but 10 then the shortfall, in my case, was £333.58; they took 11 the £333.58 from my bank account. 12 Q. I think that covers the two incidents that you have 13 referred to in 2007; is that right? 14 A. Yes, that's correct. 15 Q. When you experienced discrepancies and shortfalls, 16 whom did you contact for advice and assistance? 17 A. You would contact the helpline and the advice that you 18 get would be very conflicting, and sometimes you'd be 19 sent ping-ponging from pillar to post because 20 sometimes it would be, "Well, this isn't a transaction 21 issue, this is an IT issue, you need to speak to IT". 22 And so sometimes you just didn't really get anywhere. 23 Occasionally, you got someone who would know 24 what they were talking about and they would help with 25 matters and I think I need to explain at this point 8 1 there was a difference between cash shortfalls and 2 stock shortfalls. 3 A stock shortfall, for example when Horizon 4 generated a figure, you could contest that and you 5 could argue that with them, and that's what I did. 6 Because I'd kept meticulous records, having been 7 brought up with a paper-based system, I knew what my 8 stock holding should be and, on one occasion, it was 9 May 2018, Horizon said I'd got 123 Songbird 10 presentation packs. I only ever had single figures of 11 those presentation packs that I could count on my 12 hand, and I argued with them. I said, "No, the system 13 is wrong, I haven't got that" and the advice was, 14 "Well, can you count them again?" And it took 15 an awful long time to convince them, "No, that's not 16 right, I've only got single figures". 17 Now, if you have come to the Post Office and not 18 been used to a paper-based system, you would probably 19 just assume Horizon says you should have X, and, 20 therefore, you've got X amount of stock. But I was 21 always on the look-out for these things. 22 If it was a cash shortfall, they just would not 23 entertain any discussion whatsoever. It was either 24 pay up or -- well, you know the rest of the story. 25 Q. You have mentioned the discrepancy in your stock 9 1 holding that was -- that showed on Horizon in 2 May 2018. 3 A. Yes. 4 Q. How was that ultimately resolved with the Post Office? 5 A. Because I stood my ground with them and I said, "No, 6 you know, this is not right, I can tell you what I had 7 last week and I can tell you I have not sold that 8 amount of presentation packs. I've never even had 9 that amount on hand". So I'd got all my records. 10 That's why the old paper-based system was so much 11 better, because you could refer back to paper copies 12 of things. 13 Q. You've described keeping your paper records and 14 comparing that against what the Horizon System was 15 showing your stock ought to be. 16 A. Yes. 17 Q. What did you believe at the time was causing these 18 discrepancies between what the Horizon System was 19 showing and your own paper records? 20 A. Well, probably the mixed information that you got 21 about the Horizon System because, as I explained, you 22 had problems with the equipment itself. You know, 23 you'd get power outages, you'd get the screen 24 freezing, you would get the PIN pad not working. And 25 you'd ring up and, eventually, you'd get through to -- 10 1 they called themselves Horizon System help desk or IT 2 desk, and they would say to you, "Oh, press buttons" 3 or, if that didn't work, "Reboot the system". 4 And I spoke to an engineer on one occasion who 5 had to come out and do bodge repairs on the system and 6 he said that it was very important with the Horizon 7 system that you switch things off in the right order, 8 that you log off from the screen and then you switch 9 the base unit off. If you do things in a different 10 order, then that can cause issues. So, quite 11 possibly, it could have been that, it could have been 12 a power surge. Those figures were definitely not 13 right. 14 Q. You have mentioned an engineer that you spoke to. Do 15 you know for whom that individual worked? 16 A. He would have come out from the IT desk. So he would 17 have been a Horizon engineer. Some of them are very 18 good. I did have some names of some of them, very 19 helpful, but some of them -- I asked people when 20 I spoke to them on the help desk, "Have you used the 21 Horizon System yourself?" and invariably it was, 22 "Well, no, no, I haven't used that". So how can they 23 give you advice when they don't even know the system 24 themselves? 25 Q. What happened when you received error notices issued 11 1 by the Post Office? 2 A. Error notices, you had to put them -- they had changed 3 the process but you had to put them into housekeeping. 4 After that, you had to put them in the suspense 5 account and you had to make sure that you'd put the 6 money in and accepted the error notice and followed 7 the instructions because you cannot balance up your 8 accounts if you have got outstanding discrepancies and 9 you can't balance up with negative figures either. 10 Q. You have already described the two particular 11 shortfalls that stand out for you in 2007. 12 A. Yes. 13 Q. You said, in the first instance, I think, you paid the 14 money into -- you paid the money to the Post Office. 15 A. Yes. 16 Q. You paid the money into the account. Why did you do 17 that if you didn't believe there was, in fact, 18 a shortfall in your accounts? 19 A. Because it was just that you work for the Post Office 20 and if they said the money was short, with 21 a paper-based system you could check the records and, 22 if they said it was short, you would pay the money. 23 But this, because I hadn't got any paper records, 24 I didn't think I'd got any other option. 25 Then when it happened a second time, that's when 12 1 I thought, "No, I'm not doing this; there's something 2 not right here". 3 Q. How much do you believe you have paid in total to make 4 good shortfalls shown by the Horizon System? 5 A. I would say over the time that I had Horizon, if you 6 say, sort of, £10 here, £20 there, adding that up over 7 roughly 15 years, probably between £2,000 and £3,000 8 but then also, if you consider when the system was 9 down and you couldn't do any transactions, you were 10 placed on what they called limited services, you're 11 not being paid for that either. So, effectively, you 12 are losing out on that as well. 13 Q. Your appointment as an SPM came to an end last year; 14 is that right? 15 A. That's right, yes, February 2021. 16 Q. Was that a result of your decision to resign? 17 A. It was my decision because -- for lots of reasons but, 18 really, I'd had enough of it. I'd had enough of the 19 way the Horizon System was working. It was just so 20 much stress to be under every time it came to the 21 balance, you know, "What are the figures going to be 22 this time?" and seeing, of course, as time went on, 23 seeing what was happening to other subpostmasters, 24 I became quite scared. What's going to happen if 25 there's a shortage? You know, what's going to happen 13 1 to me? 2 Q. You have mentioned in your statement an event which 3 occurred before the final audit of your branch took 4 place that related to a surplus of cash. Can you 5 please explain what happened? 6 A. The surplus of cash that they wanted back? The 7 Post Office was closed -- just to put it into 8 perspective, the Post Office was closed in March 2020 9 because of Covid restrictions, et cetera, and I had 10 a call from my manager in the autumn of 2020 saying 11 that the Post Office wanted surplus cash back. 12 I point out at this point that, when I closed the 13 office in March, I obviously did a balance, a correct 14 balance, no negative values, no problems, locked the 15 premises, alarmed it and then, as I said, I had this 16 call could I send surplus cash back because they 17 wanted other offices to be able to use that. I said, 18 "Yes, of course I'll do that." 19 So I, you know, found out what I needed to do, 20 got in touch with the CRU, got in touch with Horizon 21 and went down to the office, unlocked it and I had to 22 get the computer system working again to be able to do 23 this, because you have to have the computer system 24 working to be able to send the money back to put 25 yourself in the correct balance period, et cetera, 14 1 et cetera. 2 So I rang the Horizon help desk and also the 3 NDSC, and I got all the instructions, all the 4 reference numbers, dates, times, what I needed to do, 5 because when I went down to the office, the computer 6 system -- presumably because it had been the office 7 had been closed for so long, the computer system was 8 down. So I had to get the computer system up and 9 running again to be able to send the money back which 10 I did. 11 My manager -- and I was in touch with my manager 12 throughout the whole of this process and he said, "All 13 you need to do is to open the office up for the CRU, 14 send the money back, lock the premises, alarm it, do 15 your balance, and that's it, that's all we want you to 16 do." I said, "Yes, of course I'll do that". 17 So that is what I did. I had to reboot the 18 system, do various compliances on it, do up the cash, 19 do a balance, which, again, was a correct balance, CRU 20 came, collected the cash, I closed the door, locked 21 the premises, alarmed it all, thought nothing more 22 about it. And then when it came to the final audit in 23 February 2021 -- would you like me to tell you about 24 that experience? 25 Q. Yes. Who attended your branch to carry out that 15 1 audit? 2 A. I'm still quite apprehensive about giving my full 3 evidence about giving names because of fear of the 4 Post Office coming after me, I mean the power that 5 they wield. I will give you the name of the auditor, 6 but the other two people who came with the auditor, 7 I don't feel comfortable giving their names. 8 The auditor's name was Gurmeet or Gurmet. 9 Auditors are not very nice people. They don't speak 10 to you. All they do is tot up the figures and then 11 they say, "Can you explain this?" The whole 12 experience is extremely stressful. It's like standing 13 in front of a steamroller and thinking, "At any 14 moment, I could be swept under the wheels". It's 15 just -- unless you have experienced that, you have no 16 idea just how horrendous it is. 17 The auditor went up the figures. "Can you 18 explain this?" There was a lot of negative values, 19 I couldn't believe it, all through my stock and I just 20 said, "Well, that's impossible". And what was also 21 upsetting was that my manager -- when the auditor was 22 going up the figures, my manager just said, "Oh, 23 I can't stay here, I'll step outside for a few 24 minutes". 25 So, basically, you are in there, you and the 16 1 auditor, and they are saying, "Can you explain this?" 2 "Well, no, I can't". You know, I run my office 3 deficiently. You can't balance up with negative 4 figures, it's impossible. So how does it get all 5 those figures? And the auditor gave me the stamps and 6 said, "For example, your self-adhesives. There's 7 eight books here, isn't there? Would you like to 8 count them?" Of course I counted them. There was 9 eight books. But there's all these negative figures 10 and I said, "Well, I'm not agreeing to that, you know, 11 this is wrong". I said, you know, "I'm just not going 12 to accept this". 13 They said, "If you don't accept this, you can't 14 close the office". It's just the whole thing was -- 15 it was just oppressive conduct. It was just extremely 16 distressing. They found a shortfall when they put all 17 the figures -- when he put the figures right, as he 18 said, of £1,970, after doing two correct balances. 19 How? The premises had been locked, the doors were 20 closed, it was all alarmed, no-one had been there, no 21 customers. How is that? It can't be. It just can't. 22 Q. I understand, Ms Beisner, you don't want to name 23 individuals but you have mentioned that your manager 24 was in attendance -- is that right -- at the audit? 25 A. That's correct, yes. 17 1 Q. There was one other employee of the Post Office, is 2 that correct? 3 A. That's correct, yes. 4 Q. Can you please describe the attitude of your manager 5 whilst the audit was being conducted? 6 A. Just, as soon as the audit started, the manager said, 7 "I can't be in here, I'll just step outside for a few 8 moments", and that was it. You know, there was no 9 support, there was no support from the helpline, 10 Horizon, no support from National Federation of 11 SubPostmasters, no-one. I was on my own. 12 And, you know, this £1,970, I'm still concerned 13 and worried about it. I know the Post Office are 14 watching this and I would like to have written 15 confirmation from them to be sent to my legal 16 representatives saying they will not be pursuing me 17 for this alleged shortfall of £1,970. I would like 18 that in writing. 19 Q. Just to be clear, this audit occurred on 17 February 20 of last year; is that right? 21 A. That's correct, yes. 22 Q. During that audit, a figure of £1,972 was said to be 23 a loss found in your account? 24 A. Yes, £1,977, and I forget how many pence. 25 Q. Am I right to understand that has not yet been 18 1 resolved as between you and the Post Office? 2 A. That's correct. They said I had to sign off the 3 accounts, otherwise I would not be able to retire. 4 They said that I needed to get in touch with 5 Chesterfield and Chesterfield would look into this and 6 tell me what they thought. I did have a phonecall 7 from someone from Chesterfield and they said, "Would 8 you like to speak to someone? We've decided that 9 we're not going to pursue that. Would you like to 10 speak to someone about it? 11 I said, "Yes, I'll speak to someone" and they 12 said, "Oh, they're not available at the moment". And 13 that is all that I've had. I've got nothing in 14 writing. If whoever it was who gave that verbal 15 assurance leaves that office, then what happens? 16 I think it's disgusting. I really do. You 17 know, they say they have changed and yet this is not 18 2007, (connection breaking up) this is 2021. 19 SIR WYN WILLIAMS: If I've got the sequence right, 20 Ms Beisner, apart from the time when you went into the 21 shop in order to arrange for surplus cash to be 22 returned, the premises had actually been closed for 23 about a year -- 24 A. Yes. 25 SIR WYN WILLIAMS: -- and, within that year, you had done 19 1 two balances which had both been correct? 2 A. That's correct, yes, and premises are alarmed, 3 Sir Wyn. No-one could walk in there. 4 SIR WYN WILLIAMS: Fine. Thank you. 5 MS HODGE: Please can you describe, Ms Beisner, how it 6 made you feel to experience this audit in 7 February 2021? 8 A. Well, to be honest, I still have nightmares about it 9 because, you know, I'm worried they are still going to 10 come after me for money. What good is a verbal 11 assurance from someone who doesn't come to the phone 12 to speak to you? My experience of using Horizon, it's 13 just been absolutely harrowing and, you know, I wish 14 I'd never become a subpostmaster. I just wish I'd 15 never decided to start to work for such a corrupt and 16 uncaring organisation who puts profits before people. 17 Q. I would like to ask you now a little bit more about 18 the impact that your experience of using Horizon has 19 had on you and your relationships with your family. 20 What effect did the shortfall shown by Horizon have on 21 your well-being? 22 A. Well, every time it came to doing a balance, you were 23 worried, you know, what were the shortfalls going to 24 be? And it's the lack of support. It's the feeling 25 of total isolation. It's just horrible. Of course, 20 1 living in a small village, if word had got out of 2 something like that, I mean, nobody's going to step 3 foot inside your Post Office, are they? It was just 4 awful. 5 I mean, I know my mother couldn't believe that 6 this was happening and she accused me of being 7 careless because she, like everybody else, thought 8 Horizon couldn't be wrong. 9 Q. What are you now doing for work since you resigned 10 your position as a subpostmistress? 11 A. I'm not -- I've been, sort of, just, sort of, 12 considering my options since then and, obviously, 13 helping the Inquiry, because I want to see justice 14 done. And I read that Horizon is not going to be 15 replaced until 2024. Well, how many more people are 16 going to suffer? 17 You know, a lot of people are afraid to speak 18 out about it. I was apprehensive but I feel I have to 19 do this because they say they've righted the wrongs of 20 the past, that things have changed. Even when I had 21 the auditor, I was told, "Oh, don't worry, they are 22 nice people, you know, it's all changed, they're all 23 pleasant people now". Well, not in my experience 24 they're not. In my experience, nothing's changed. 25 Q. Have you sought any compensation from the Post Office? 21 1 A. Yes, I did have offer of a small amount of 2 compensation under Historic Shortfall Scheme of just 3 under £500 but the problem is it comes with a gagging 4 clause. I decided that I'm going to decline because 5 I'm not going to be gagged. People need to hear just 6 how this system is, just how unreliable and how full 7 of flaws it is. 8 Q. By gagging clause, do you mean you would not be 9 permitted to disclose the details of the settlement? 10 A. That's correct, and probably not permitted to say 11 anything adverse about Horizon. 12 Q. How do you now feel about the way the Post Office 13 treated you and other subpostmasters? 14 A. To be honest, I can't believe it. When I look back to 15 the early days of running post offices -- I have 16 another note that I wish to tell you. I have 17 a brochure dated from the 1990s. It was a Post Office 18 brochure and they were asking for subpostmasters to 19 put themselves forward to become Magistrates because, 20 just like Magistrates, subpostmasters were considered 21 pillars of the community, just like Magistrates we 22 were able to sign and witness legal documents. 23 I mean, where's the irony in that? They're just 24 not nice people to work for. It's just completely 25 changed. They don't listen. They are threatening. 22 1 They use oppressive conduct. They just -- they're 2 just totally unreasonable. 3 Q. What do you think needs to be done to put right the 4 harm that has been done by Horizon and the actions of 5 the Post Office? 6 A. Well, what I want from the Post Office is an apology 7 for what they have done. I want justice and fair 8 recompense for all subpostmasters. I'd also like to 9 see full accountability, together with a duty of 10 candour from all those who have allowed this terrible 11 injustice to proliferate for so long. I'd certainly 12 like to see a swift end to the whole Horizon System, 13 a complete reorganisation overhaul and replacement of 14 the whole Post Office and its management. 15 I regret ever becoming a postmaster and, you 16 know, I wish I'd pursued my professional legal career 17 instead. 18 Q. Thank you, Ms Beisner. I have no further questions 19 for you. Is there anything else you would like to 20 say? 21 A. I'll just refer to my notes just very briefly. (Pause) 22 Yes, I think that's everything that I needed to 23 say. Yes, I think that's everything, thank you. 24 MS HODGE: Thank you. 25 Sir, do you have any questions for this witness? 23 1 SIR WYN WILLIAMS: No, I don't have any questions of you 2 but I would like to thank you for participating twice 3 in this Inquiry because you did participate quite 4 a long time ago, before we had statutory powers. So 5 you were one of the first people to try and help me 6 out. I'm very grateful that you did it then and I'm 7 very grateful that you've come today to give your 8 evidence in a formal setting. So thank you very much. 9 A. Thank you, Sir Wyn. 10 MS HODGE: Thank you, sir. 11 That concludes our oral evidence for today. We 12 have some witness summaries which Mr David Enright is 13 kindly going to read in. 14 SIR WYN WILLIAMS: Do we need to take a few minutes or is 15 Mr Enright ready to get going, so to speak? 16 MS HODGE: I think he's ready to go. 17 SIR WYN WILLIAMS: If you want to, you can stay listening 18 to this, Ms Beisner, but if you don't want to, feel 19 free to disconnect yourself. 20 A. I will listen. It will be quite interesting, thank 21 you. 22 MR ENRIGHT: Thank you for inviting me to read in the 23 summaries of the detailed statements and exhibits that 24 you have before you. 25 Summary of witness statement of CHHAYA PATEL (read) 24 1 MR ENRIGHT: Mrs Chhaya Patel was subpostmistress in 2 Burgess Hill between 2014 and 2016. Prior to this, 3 she was an accountant at the TSB. Her family have 4 a long history of running post offices. Mrs Patel 5 received five days of in-branch training on the 6 Horizon system. She found the training to be basic. 7 In fact, a shortfall occurred whilst the trainer was 8 conducting the first balance. The trainer wrote the 9 shortfall off without explanation. 10 Further shortfalls appeared within four to 11 five months of her taking over the branch. Mrs Patel 12 would constantly call the helpline for advice but none 13 was ever forthcoming. 14 She was forced to put her own money in to 15 balance the system to be able to trade the following 16 day. 17 Mrs Patel's branch was audited and an alleged 18 shortfall of £33,000 was discovered. She was 19 immediately suspended. This was despite the fact that 20 Mrs Patel told the Post Office of the discrepancies in 21 advance and asked them for assistance. Mrs Patel 22 resigned following her suspension. She believes that, 23 in total, she paid in excess of £50,000 to the 24 Post Office. Paying the shortfalls placed an immense 25 stress on her and her family. They became homeless 25 1 and were forced to live in rented accommodation. 2 Her husband was hospitalised for over a year 3 with epileptic fits and seizures. He had to be 4 resuscitated on two occasions. The doctors could not 5 explain why he was so ill, other than it was a direct 6 consequence of stress. 7 Mrs Patel describes living on the poverty line. 8 Her sons were forced to look for employment to help to 9 pay off the debt. She lived in constant fear she 10 would be prosecuted by the Post Office. She felt 11 blacklisted in the community and considered that she 12 had no option but to move away from the area because 13 she felt the whole family had been labelled as 14 thieves. 15 Mrs Patel now despises the Post Office. She 16 says: 17 "We were in our late 50s and having to suffer 18 like this became so unbearable that, at times, we 19 wanted to end our lives, to commit suicide, just to 20 get out of this." 21 Mrs Patel now lives in affordable housing for 22 the elderly with her husband, who is housebound. She 23 is still forced to work full time although now aged 24 65, as they still owe money to family members who they 25 borrowed to pay the debt to the Post Office. She 26 1 concludes: 2 "I want this whole part of my life to be over. 3 It has gone on for too many years but, most of all, 4 I just want peace." 5 Summary of witness statement of ELIZABETH STOCKDALE (read) 6 MR ENRIGHT: Sir, Ms Elizabeth Stockdale was 7 a subpostmistress in Bridlington between 2014 and 8 2017. Prior to this, she worked in an employment 9 agency. She ran the Post Office with her son, Luke, 10 who was already employed as an assistant at the 11 branch. Ms Stockdale and her son attended a three-day 12 training course on the Horizon System. She was then 13 shadowed in branch by trainers for a week. 14 Elizabeth found the training to be basic and 15 only provided an overview of the Horizon System. The 16 first balance she did, under supervision, showed 17 a shortfall. The trainer printed off some paperwork 18 and said she would investigate the shortfall. He did 19 not and four weeks later she had to pay the shortfall. 20 Ms Stockdale regularly experienced shortfalls 21 and would call the helpline for assistance. Their 22 advice was unhelpful. Usually, she was simply told to 23 pay the shortfalls. She was also told that she was 24 the only one who was experiencing problems with the 25 Horizon System. 27 1 Ms Stockdale estimates that she paid or had 2 deducted from her salary in excess of £10,000 as 3 a result of shortages. Elizabeth describes working 4 full time but barely earning a living. 5 In 2016 Ms Stockdale's branch was audited and 6 an alleged shortfall of £5,000 was found. She was 7 immediately suspended. She was shocked and shaken. 8 Elizabeth asked that she be allowed to try to 9 understand how the shortfalls had occurred, as she was 10 shown no evidence. She was not provided with 11 evidence. The Post Office simply confirmed that there 12 were no anomalies in the system and Elizabeth had to 13 make good the loss. 14 Ms Stockdale's Post Office contract was 15 subsequently terminated. She lost her livelihood and 16 the value of her business. She also suffered stigma 17 and reputational damage. There were rumours that she 18 had been stealing from the Post Office. She struggled 19 with the stress of the shortfalls and turned to 20 alcohol. This put a tremendous strain on her 21 marriage. 22 Ms Stockdale describes suffering with a loss of 23 self-esteem, paranoia and undergoing a complete 24 character change. On one occasion, she says: 25 "My paranoia had gotten so bad that I did not 28 1 even trust my own son and, on one occasion, 2 I physically pinned by son, Luke, down on the bed and 3 asked him what he had done and swear that he was not 4 stealing from me. I was totally confused." 5 Ms Stockdale now works as a carer, working night 6 shifts. She has many regrets about taking on the 7 Post Office and believes that, if the Post Office had 8 admitted to the failings in the Horizon System, her 9 life would be much different. She would still be 10 running a successful, thriving business. 11 One of Ms Stockdale's biggest regrets is that 12 her father passed away not knowing it was not her 13 fault. Elizabeth concludes: 14 "I want an apology from the Post Office. 15 I really wish the Post Office would write in big 16 letters in every newspaper 'I'm sorry, They never did 17 it. Leave them alone'. I want justice for everyone. 18 I want vindication." 19 Summary of witness statement of GILLIAN BLAKEY (read) 20 MR ENRIGHT: Sir, Mrs Gillian Blakey was a subpostmistress 21 in Grimsby from 1996 to 2004. Mrs Blakey ran the 22 Post Office along with her husband, having used a bank 23 loan to finance the purchase. Mrs Blakey managed the 24 Post Office branch using a paper-based system before 25 Horizon was introduced. She recalls that the paper 29 1 accounting system gave her the chance to check and 2 correct discrepancies if they occurred. This was not 3 possible using Horizon. 4 Mrs Blakey states that she received inadequate 5 and insufficient training on the Horizon System and 6 struggled with the weekly balancing procedure, despite 7 Post Office staff occasionally coming in to assist at 8 her request. 9 Mrs Blakey's husband took over the balancing but 10 also experienced regular shortfalls. The first 11 significant shortfall was approximately £5,000 but the 12 shortfalls continued to grow. Mr Blakey did not tell 13 Gillian about the shortfalls as he knew the negative 14 impact it would have on her health. When auditors 15 arrived on 13 May 2004, Mr Blakey informed the auditor 16 that the branch would be approximately £65,000 short. 17 This was a shock to Mrs Blakey who until this time had 18 had no idea any significant shortfalls had occurred. 19 Following the audit, Paul Whittaker, 20 a post office investigator, interviewed Mr and 21 Mrs Blakey separately and accused Mr Blakey of 22 stealing money from the Post Office. Mr Whitaker 23 suggested to Mrs Blakey that her husband may have been 24 leading a secret life behind her back, gambling their 25 money without her knowledge, and suggested that 30 1 Mr Blakey may have been unfaithful. 2 These ignoble allegations were untrue. 3 Mrs Blakey suggests that the shortfall was due to 4 a problem with the Horizon System but Mr Whittaker of 5 the Post Office rejected her observation out of hand, 6 telling her that, "No, someone has stolen it". 7 Mrs Blakey's husband lost his job and was 8 subsequently declared bankrupt. The Post Office 9 prevented Mrs Blakey from selling the branch to 10 a preferred purchaser, preventing them from recouping 11 some of their investment and alleviating some of the 12 financial hardship. The family home had to be sold. 13 The proceeds went towards the mortgage on the house 14 and the business loan that had been used to finance 15 the purchase of the Post Office. The couple moved 16 into rented accommodation, yet Post Office still 17 attempted to pursue the couple for the alleged 18 shortfall. 19 Post Office took away Mrs Blakey's business, her 20 livelihood and her home. She considers that they 21 robbed her of the chance of a peaceful and happy 22 retirement and devastated her husband and family with 23 her husband's prosecution. The couple still live in 24 the shadow of those events more than 18 years later. 25 Mrs Blakey says: 31 1 "I regret the decision to become a subpostmaster 2 very much and very deeply. I hate the Post Office. 3 I do not trust them. I do not think they have learned 4 any lessons. I'd like the Inquiry to put this right 5 and to show where the blame really belongs and to put 6 us in the position we would have been in if none of 7 this had ever happened." 8 Summary of witness statement of KEITH LOFTHOUSE (read) 9 MR ENRIGHT: Sir, Keith Lofthouse was the subpostmaster of 10 the Wyverstone Road Post Office in Stowmarket from 11 December 1977 to May 1980. He then purchased a larger 12 Post Office at Humberston in Grimsby, where he was 13 subpostmaster from September 1980 to February 2009. 14 In the 14 years prior to the introduction of the 15 Horizon system, Mr Lofthouse experienced no 16 discrepancies. After the Horizon System was 17 introduced in 2001, Mr Lofthouse recounts that he 18 paid, or the Post Office deducted, in excess of 19 £22,000, in relation to alleged shortfalls between the 20 period 2001 to 2009. 21 The shortfalls were continuous, ranging from £50 22 to in excess of £1,000, throughout this his time in 23 post. Mr Lofthouse felt compelled to retire and sell 24 his business because the shortfalls became too much to 25 sustain. 32 1 Mr Lofthouse says that he knew there was a fault 2 with the Horizon System because the screen would alter 3 of its own accord and totals would just suddenly 4 double. The Post Office eventually replaced all the 5 Horizon hardware in Mr Lofthouse's branch but this did 6 not resolve the problem. Mr Lofthouse says he and his 7 wife lost out on a comfortable retirement and their 8 plans to enjoy a more relaxed lifestyle because they 9 were constantly having to dip into their pensions to 10 cover the Horizon losses. 11 Mr Lofthouse says: 12 "I would like to see the people that introduced 13 the Horizon System to be held responsible for the 14 faulty system. Paula Vennells only came into office 15 in the Post Office in 2007. She inherited Horizon. 16 She did not introduce it. I believe those who 17 introduced the faulty Horizon System should be held 18 accountable for the damage it caused so many 19 subpostmasters." 20 Summary of witness statement of MOHAMMED KHALIL (read) 21 MR ENRIGHT: Sir, Mr Mohammed Khalil was the subpostmaster 22 in Norwood from 2004 until 2015. He remortgaged his 23 house and took out a bank loan to finance the 24 business. Prior to this, he had worked as an accounts 25 manager. 33 1 Mr Khalil received some training on the Horizon 2 System and was left with a manual to refer to if any 3 problems arose. When he did call the Post Office 4 helpline seeking assistance they would usually refer 5 him to the training manual. 6 Shortfalls in the Horizon System arose from the 7 beginning. Initially they were small and manageable. 8 Mr Khalil used his own money to make them good to 9 continue trading. However, the shortfalls increased 10 over time. Mr Khalil estimates that in the ten years 11 he was a subpostmaster he paid in excess of £85,000 in 12 shortfalls. To cover this, he initially used his 13 savings, then borrowed from family, then used bank 14 loans and credit cards. He also resorted to selling 15 his wife's jewellery to raise money. 16 Mr Khalil describes the stress as being intense 17 and he collapsed on two occasions whilst he was 18 working in his own Post Office. Mr Khalil could no 19 longer afford to continue to pay the ever-increasing 20 shortfalls and made the decision to sell his business. 21 He was suffering with stress, sleeplessness and 22 diabetes. He fell into depression and estimates his 23 losses to be in the region of £200,000. 24 Mr Khalil is now 70 years of age. He still has 25 a mortgage and relies on credit cards and handouts 34 1 from his children to survive. He blames Post Office 2 Limited for this. He avoided the potential accusation 3 of theft by paying a crippling amount of money to the 4 Post Office that he believes he was not responsible 5 for. 6 He did everything he could to avoid becoming 7 bankrupt, living what he describes as a deprived life 8 for many years. 9 He did this also to preserve his reputation 10 within the community. Mr Khalil blames Post Office 11 Limited for arguments caused within the family that 12 led to his son's divorce. His son left the country 13 and they now have little contact. 14 Mr Khalil says that he wants an apology from the 15 Post Office: 16 "I want them to hold their hands up and accept 17 responsibility. The public should know that 18 subpostmasters are not and were not dishonest. They 19 were, in fact, failed by the system that was put in 20 place by the Post Office and the Government." 21 Summary of witness statement of PAMELA STUBBS (read) 22 MR ENRIGHT: Sir, Ms Pamela Stubbs was the subpostmistress 23 of Barkham Post Office in Berkshire from 4 August 1999 24 to 8 June 2010. She and her husband sold their homes 25 to buy the Post Office at a cost of £186,000. 35 1 Ms Stubbs received a single day's training on the 2 Post Office's Horizon System when it was introduced. 3 Prior to the introduction of the Horizon System she 4 had no major problems. Ms Stubbs describes the 5 Horizon training as being very poor and she 6 experienced repeated problems with the Horizon System 7 from the outset. 8 She sought help from the Post Office helpline 9 but no help was provided. Shortfalls were repeatedly 10 reported to the Horizon System. When Pamela 11 complained about the discrepancies to her network 12 business manager, he responded, "Well, a lot of SPMs 13 have said that Horizon has problems but nobody has 14 been able to prove it". 15 The Post Office demanded that Ms Stubbs pay them 16 £28,829.05 in respect of a series of alleged 17 shortfalls. Ms Stubbs was threatened with 18 prosecution, suspended by the Post Office and locked 19 out of her own Post Office. She undertook her own 20 research into the Horizon System and threatened to 21 expose the Post Office in court. Consequently, the 22 Post Office decided not to pursue a prosecution. 23 However, she was forced to sell her Post Office 24 at a huge loss, thereby losing the value of the 25 business and her future income. From being respected 36 1 and trusted, she says, she lost her reputation and was 2 aware of gossip about her. She felt compelled to give 3 up her position as a district councillor, due to the 4 unfounded rumours that she had stolen money from the 5 Post Office. Ms Stubbs says that: 6 "The Post Office might have well have just held 7 us up at gunpoint on the street and said 'Give us your 8 money', knowing full well they would never have to 9 give it back." 10 She says that the experiences with the 11 Post Office took its toll on her mentally, physically 12 and that she suffered from anxiety, depression, 13 insomnia because of the stress she was put under by 14 Post Office in trying to prove that she did not take 15 any money from them. Ms Stubbs says: 16 "I used to be a PE teacher. As such, I have 17 always been fit and healthy. And now, suddenly, I am 18 not, because of the stress the Post Office caused me 19 and I am still on tablets to this day. I was also 20 diagnosed with a heart condition caused by stress. 21 I had been put under and I am no longer able to work 22 as a result." 23 Pamela is left feeling very angry and breaks 24 down in tears when she thinks about what happened. 25 She feels the retirement years she looked forward to 37 1 have been taken away from her as has her good health. 2 Summary of witness statement of PAULINE COATES (read) 3 MR ENRIGHT: Sir, Pauline Coates was the subpostmistress 4 of two post offices, West Tisted Post Office and later 5 Ropley Post Office, until March 2009. She began her 6 career with the Post Office in March 1988. 7 From the instruction of the Horizon System, 8 Pauline regularly experienced small shortfalls. When 9 she would call the helpline seeking help, she was 10 usually told to consult the training manual. An audit 11 was conducted on 5 January 2009 and a huge shortfall 12 of £9,953.86 was allegedly found, supposedly 13 a combination of cash and stock. 14 Consequently, Ms Coates was suspended and her 15 contract was later terminated. Ms Coates was required 16 to repay the alleged shortfalls in instalments for 17 ten years. She made her final payment in 18 December 2019. 19 The Post Office's fraud investigators accused 20 her of theft. A Post Office investigator came to 21 Pauline's home. He told her that he would issue 22 Pauline with what he described as a simple adult 23 caution. Pauline was told if she accepted this that 24 the matter would be concluded. Pauline had no idea 25 what this was. She accepted it as she was so upset 38 1 and afraid. Pauline says: 2 "I didn't even think of making any kind of 3 appeal because they, the Post Office, were just so 4 convinced I had taken the money and I could not prove 5 otherwise. To be completely honest, my spirit was 6 broken and I would not have wanted to remain being 7 employed by such a heartless organisation. 8 "In October 2009, Graham Brander, a Post Office 9 fraud investigator, came to my home and advised me 10 that I would be issued with what he described as 11 a 'simple adult caution', whatever that means, and the 12 matter would be concluded. I do not know whether 13 I have a criminal record or not. If this is the case, 14 I want this removed." 15 Summary of witness statement of SHARON BENNETT (read) 16 MR ENRIGHT: Sir, Mrs Sharon Bennett became 17 a subpostmistress of Whinney Lane branch in Pontefract 18 in 2005, after working there as a counter assistant. 19 She took over the branch with the intention of running 20 it as a family business. 21 As Ms Bennett had been working as a counter 22 assistant, the Post Office assumed she did not need 23 training on the Horizon System and none was offered to 24 her. Following a back injury, Ms Bennett took 25 a month's sick leave from the branch. On her return, 39 1 Sharon was made aware that there was a shortfall of 2 some £3,000. 3 Sharon contacted the Post Office helpline and 4 requested that they send a trainer into the branch as 5 a matter of urgency to carry out an audit. Sharon 6 also contacted the previous subpostmistress who came 7 to the branch and confirmed that Mrs Bennett had done 8 the transactions correctly and could not explain the 9 discrepancy. 10 Mrs Bennett paid in excess of £5,000 of her own 11 money to cover the supposed shortfalls after borrowing 12 money to do so. This caused tension between her and 13 her husband. In early 2006, Mrs Bennett's branch was 14 audited and an alleged shortfall of over £500 was 15 discovered. Sharon was immediately suspended and 16 questioned in an aggressive manner by her area 17 manager, who implied she had stolen the money. 18 Mrs Bennett's contract was subsequently 19 terminated on basis that the Post Office had lost 20 faith in her ability to run the Post Office. 21 Sharon says: 22 "I have tried to give an indication of the 23 consequences of the Post Office action against me but 24 it is impossible to give a full account of the nights 25 and days when you can see no way ahead. I was treated 40 1 as a criminal, my business was destroyed, my finances 2 were ruined. We lost our home and I had to stop 3 working due to my illness being exacerbated by the 4 stress I was placed under. The Horizon system has 5 been shown to be deeply flawed and that the 6 Post Office knew that it was. I would like the full 7 truth to come out. I want the world to know that 8 I and other ordinary, hard-working, decent people like 9 me had their lives ruined by Post Office Limited. 10 I would like it to be publicly shown that the 11 Post Office knew its computer system, Horizon, was 12 completely flawed and unreliable and that, despite 13 this, Post Office pursued subpostmasters and ruined 14 their lives for money that never existed." 15 Summary of witness statement of TRACY McFADDEN (read) 16 MR ENRIGHT: Sir, Tracy McFadden was a subpostmistress of 17 the Sandiacre Post Office, Nottingham from 18 approximately 17 June 2002 to August 2016. She also 19 ran the Chaddesden Post Office in Derby from 2006 to 20 2008. 21 It will be recalled that Ms McFadden gave 22 evidence to you when the Inquiry was in its 23 non-statutory phase. 24 Tracy worked in the insurance industry for 25 20 years in the UK and internationally prior to 41 1 becoming a subpostmaster. She says that the training 2 she received on Horizon was inadequate. Tracy began 3 to experience shortfalls and regularly contacted the 4 helpline. 5 On one occasion, she contacted the helpline for 6 advice and carried out their instructions which then 7 doubled the shortfall, then doubled it again and again 8 until, before she knew it, the supposed shortfall had 9 grown to £16,000. Tracy naturally refused to pay this 10 sum and eventually the Post Office reduced the 11 shortfall to £800. Tracy estimates that she paid 12 £24,000 in respect of shortfalls from both of her 13 branches. 14 Tracy's contract was terminated by Post Office 15 against her will under the Network Transformation 16 scheme. Ms McFadden feels that the events related to 17 the Post Office branch have ruined her life and her 18 reputation. Tracy's reputation suffered. She has 19 been called a "wicked witch" to her face after having 20 served the community for over 14 years. The 21 Post Office's defective Horizon System damaged her 22 confidence in her abilities, her confidence in her 23 staff, and their confidence in each other. Tracy 24 says: 25 "My mental and physical health are completely 42 1 wrecked. I hate everything my life has turned out to 2 be. Becoming a subpostmaster now seems to have been 3 the worst decision I could have made as the 4 Post Office stole everything from me." 5 Ms McFadden says: 6 "I would like the Post Office to truly 7 understand the impact that their actions had upon me 8 and people like me, good, decent, hard-working people 9 who were committed to their local communities. 10 Instead, I and others are reduced to poverty with our 11 reputations in tatters." 12 Summary of witness statement of SHAZIA SADDIQ (read) 13 MR ENRIGHT: Finally, sir, Ms Shazia Saddiq. Ms Saddiq 14 overcame a very difficult young life to have a 15 successful career with a major bank before becoming a 16 subpostmistress in 2009. She ran three post offices 17 in the Newcastle-upon-Tyne area. She says that she 18 poured all of her energies and efforts into making 19 these post offices a success to create security for 20 herself but particularly for her two children. These 21 post offices were not businesses to Ms Saddiq; they 22 were her hopes and dreams for a safe and secure and 23 happy life. 24 Ms Saddiq suffered constant shortfalls and 25 discrepancies with the Horizon System. The 43 1 Post Office demanded £39,269.97, which later rose to 2 £41,097.37. However, the Post Office provided no 3 explanation as to how that figure had been arrived at. 4 Ms Saddiq was suspended by the Post Office, her 5 branches were closed in October 2016 and the keys 6 taken away from her. She was the subject of an 7 investigation during which the Post Office threatened 8 to place a charging order on her property. 9 Ms Saddiq says because her Post Office was 10 closed, local people were unable to access services, 11 including benefit payments. As a result, there was 12 a lot of anger directed towards her by local people. 13 On one occasion, Ms Saddiq was approaching her home 14 with her children when a group of men began shouting 15 at her, threatening her and calling her a thief. On 16 another occasion, a crowd through eggs, flour and 17 stones at Ms Saddiq and her children. She fled her 18 home with her children that night with a handful of 19 belongings. 20 Sir, you will have seen the exhibit to 21 Ms Saddiq's statement which shows the few things they 22 were able to carry with her. They have never returned 23 to their home. These attacks were a direct result of 24 the action taken against Ms Saddiq by Post Office 25 Limited. 44 1 Ms Saddiq's health was affected. She suffered 2 a total breakdown, an irregular heart beat, headaches, 3 insomnia, stress-related hair loss, and extreme 4 anxiety. 5 Ms Saddiq received threatening calls from 6 Post Office investigators. She says that the 7 Post Office stole her life and the dreams that she had 8 for herself and her children. She says that the 9 Post Office treated her like a criminal when, in fact, 10 any criminal behaviour was committed by the 11 Post Office. 12 Ms Saddiq says: 13 "I am an ordinary, honest and very hard-working 14 woman. I have always tried to be a good mother and 15 a good person. I feel like I was raped in public by 16 the Post Office and no-one in authority has done 17 anything about it." 18 Thank you very much, Sir Wyn. 19 MS HODGE: Sorry, sir, I think you are on mute. We 20 couldn't hear what you said just then. 21 SIR WYN WILLIAMS: Sorry, I was simply observing that 22 I actually have one more summary from Isabella 23 Armstrong Wall and I was just wondering whether that 24 was to be read on some different occasion. That's 25 all. 45 1 MR ENRIGHT: If I may explain, sir, your legal team 2 advised me that the statement of Ms Wall has not been 3 uploaded yet and, as such, the summary cannot be read 4 today. 5 SIR WYN WILLIAMS: Thank you, Mr Enright. That's fine. 6 MS HODGE: Thank you, sir. That concludes our proceedings 7 for today. We are due to resume tomorrow at 11.30 am 8 if that remains convenient for you. 9 SIR WYN WILLIAMS: Yes, certainly. And I think tomorrow 10 we have three witnesses and roughly a similar number 11 of summaries to read; is that the programme? 12 MS HODGE: That is correct, yes. 13 SIR WYN WILLIAMS: Thank you. Then I will see you 14 tomorrow, Ms Hodge. 15 MS HODGE: Thank you, sir. Good afternoon. 16 (12.38 pm) 17 (Adjourned until 11.30 am the following day) 18 19 20 21 22 23 24 25 46 1 I N D E X 2 3 JULIE MARIE BEISNER (sworn) ......................1 4 Questioned by MS HODGE ...........................1 5 Summary of witness statement of CHHAYA ..........24 6 PATEL (read) 7 Summary of witness statement of ELIZABETH .......27 8 STOCKDALE (read) 9 Summary of witness statement of GILLIAN .........29 10 BLAKEY (read) 11 Summary of witness statement of KEITH ...........32 12 LOFTHOUSE (read) 13 Summary of witness statement of MOHAMMED ........33 14 KHALIL (read) 15 Summary of witness statement of PAMELA ..........35 16 STUBBS (read) 17 Summary of witness statement of PAULINE .........38 18 COATES (read) 19 Summary of witness statement of SHARON ..........39 20 BENNETT (read) 21 Summary of witness statement of TRACY ...........41 22 McFADDEN (read) 23 Summary of witness statement of SHAZIA ..........43 24 SADDIQ (read) 25 47