IN THE CROWN COURT CASE No: T20107219

AT SOUTHWARK

REGINA

V

JASON PLACE

ADDENDUM TO DEFENCE STATEMENT

1. This Addendum is intended to supplement the Defence Statement ofthe Accused

dated 23 November 2011.

2. This Addendum supplements, and is not intended to alter nor detract from anything

contained within the Defence Statement of23 November last. It provides additional

information as to the Accused ' s dealings with Confidential Access ('CA' ) from

August 2005 onwards.

Additional Information

(i) Potential Sale to Barclays and Extradition to UK

3. In May 2008, the Metropolitan Police made arrests in the UK which were related to

the activities of CA. Because of his previous association with CA, the Accused

sought and received legal advice from Mr. Fred Bunn of Bark and Co. Solicitors. Mr

Bunn met the Accused in Spain.

4. Mr. Bunn and Giles Bark Jones, Senior Partner of Bark and Co. subsequently

suggested a meeting between the Accused and a man named Steve Young. The

Accused understood Steve Young to be Head of Security for Barclays plc. The

Accused was told by Mr. Bunn and Mr. Bark-Jones that the purpose they could

facilitate a meeting in Spain between representatives of CA and Steve Young. Mr.

Bunn and Mr. Bark-Jones indicated to the Accused that there was potential for a

multimillion pound purchase of CA by Barclays.

5. As was set out in the Defence Statement, the Accused moved to Spain in August

2005. He sold CA to Joanne Colomvakos aka Joanne Tragas for a sum of £100,000

which was to be paid to the Accused as and when funds were available to enable

payment to be made. At the time of the sale, there was an oral agreement between the

Accused, Sales and Colomvakos to the effect that if the database and business of CA

were later to be sold on to a major financial institution then the Accused would take

the lead in the negotiations for such a sale. The Accused, Sales and Colomvakos

would then each receive a third of the proceeds.

6. In pursuit of that oral agreement, a meeting between the Accused, Sales, Mr. Bunn

and Mr. Young took place on 12 November 2008. The meeting was held in the

Guarda Corte Hotel, La Ligna, Spain and lasted some three hours between four and

seven in the evening. At the meeting Mr. Young was provided with infonnation about

the workings of CA and the location of its servers. The meeting was conducted as if it

was the early stages of a buy-out by the bank. It was left on the basis that Mr. Young

would get back to Mr. Bunn concerning the next stage of the purchase.

7. The proposed deal between CA and Barclays came to nothing.

8. The Accused now believes that Mr. Young spoke to officers in this country about his

meeting the Accused in Spain.

9. On 3 December 2008, less than a month after the meeting with Mr. Young, the Hong

Kong server for CA was taken down.

10. Following the arrest ofthe Accused in Gibraltar, he was remanded in custody pending

extradition. He challenged the extradition proceedings initiated against him being

represented by specialist extradition solicitors based in Gibraltar. Whilst that

challenge was pending, he was visited in custody by a representative of Bark and Co,

Mr. Chris Finch. Mr. Finch persuaded the Accused to abandon his attempt to resist

extradition. The Accused was subsequently returned to the UK on 17 March 2010.

(ii) Possession of material found at the premises belonging to J a son Place in Alicante

11. The Accused asserts that computers and other incriminating material found at a

property owned by him in Alicante was not put there by him.

12. The Accused does not know who it was who put the material there, but suspects it

could have been Joanne Colomvakos, Paul Payne and/or Linda Smith. The Accused

believes that all three of those persons were living near to the Alicante property at the

time of the raids.

13. The Accused believes that it is possible that Joanne Colomvakos had reason to

implicate him in order to avoid proceedings being taken against her. She has been

convicted of offences relating to CA in the USA.

14. The Accused further asserts that Paul Payne and Linda Smith held a hostile animus

towards him. They may have sought to implicate the Accused in order to avoid any

proceedings being taken against them. The Accused believes that they were the

subject of arrest warrants issued in the Republic of Ireland.

Disclosure

(i) Potential Sale to Barclays and Extradition to UK

15. Pursuant to this Addendum to the Defence Statement dated 23 November 2011, the

Accused seeks disclosure of:

(i) All records of any contact between any officer and Steve Young in connection

with this investigation and/or these proceedings;

(ii) Details of all information provided to the UK authorities by Steve Young;

(iii) All records of any contact between any officer and Fred Bunn in connection

with this investigation and/or proceedings prior to the return of the Accused to

theUK;

(iv) All records of any contact between any officer or prosecution lawyer and Bark

and Co. in connection with the extradition of the Accused;

(v) All records of any contact between any officer and Fred Bunn in connection

with the Accused following the return of the Accused to the UK.

16. The reason the Accused seeks disclosure ofthis material is because he believes

that he may have been tricked by Mr. Bunn into providing information to Mr. Young,

who then provided the information to the authorities. If that was the case, then the

continuation of these proceedings would arguably constitute an abuse of the process

of the Court. Any material of the type identified in paragraph 12 above might

reasonably assist the defence.

17. In addition, the Accused believes he may have been tricked into abandoning his

challenge to the extradition proceedings initiated against him. If that was the case and

the authorities had any role in that process, the continuation of these proceedings

would arguably constitute an abuse of the process of the Court. Any material of the

type identified in paragraph 12 above might reasonably assist the defence.

(ii) Possession of material found at the premises belonging to Jason Place in Alicante

18. The Accused requests disclosure of:

(i) Details of any and all contact between officers involved in this investigation

and/or proceedings and Paul Payne. Such details should include all

information provided to officers which touches upon these proceedings;

(ii) Details of any and all contact between officers involved in this investigation

and/or proceedings and Linda Smith. Such detail should include all

information provided to officers which touches upon these proceedings;

(iii) Details of any and all contact between officers involved in this investigation

and/or proceedings and Joanne Colomvakos aka Tragas. Such detail should

include all information provided to officers which touches upon these

proceedings;

(iv) The place of residence of Joanne Colomvakos aka Tragas at the time of the

Alicante search;

(v) All details known by the prosecuting authorities of the prosecution of Joanne

Colomvakos aka Tragas in the USA.

(vi) Details of outstanding proceedings in the Republic oflreland against Paul

Payne and/or Linda Smith

19. The reason the Accused seeks disclosure of this material is that it may reasonably

assist his defence as set out in his Defence Statement of23 November last and this

Addendum.

Jason Place

6 March 2012