• Any telecommunications provider, bank, veterinarian, contractor or other person holding responsive records
1. Status and purpose
This document is issued under instructions as a coordinated request for official information, personal information, criminal disclosure, contractual and service records, preservation of evidence, and identification of statutory authority. Each recipient must treat it under every information-access and preservation regime applicable to that recipient.
It is not alleged as an established fact that all recipients colluded. The purpose is to determine, from primary records, whether the horse and cattle investigations were independent, whether information was improperly shared or repurposed, and whether inaccurate or incomplete system data was used to expose Michelle Francine Walker to criminal liability.
Nothing in this notice waives legal professional privilege, litigation privilege, confidentiality, privacy rights, property rights or any right to seek disclosure, exclusion, dismissal, damages, judicial review or other relief.
2. Immediate preservation requirement
Preserve all potentially responsive records, including:
No responsive record is to be deleted, overwritten, altered, destroyed or permitted to expire while the criminal proceeding and related disputes remain active.
3. Tuscan, title and Barrister Murray
• Identify Barrister Murray by full name and disclose all communications with him or his instructing representatives concerning Tuscan, title, custody, seizure, transfer or return.
• Produce the primary documents supporting the Crown’s assertion that it had “clear title” or lawful authority in relation to Tuscan.
• Produce all draft and final OIA responses, search records, legal reviews and internal communications relevant to that assertion, and explain any inconsistency between the assertion and the OIA material.
• Identify every person who made, approved, repeated or relied upon the assertion of clear title.
4. Authority to take or interfere with horses
• Produce every court order, warrant, statutory direction, application, affidavit, inventory, return, transport document and chain-of-custody record relied upon to take horses from Christine Barrett and Howard William Lee.
• Produce the equivalent records concerning Pete Verhoeven and Michelle Walker.
• Identify the statutory power relied upon where no court order or warrant existed, together with proof that each statutory precondition was met.
• Identify the current location, custodian, legal status and full movement history of Tuscan and every other horse affected.
5. Horse euthanasia and suspected poisoning
• Produce the original veterinary certificate and complete clinical record for the horse euthanised at the start of MPI’s intervention.
• Identify who authorised euthanasia, the legal basis, whether owner consent was sought, and what treatment alternatives were considered.
• Produce all toxicology, pathology, necropsy, blood, tissue or stomach-content testing. If none was performed, explain why potentially relevant evidence of poisoning or another external cause was not preserved.
• Produce all photographs, videos, drug records, disposal records and chain-of-custody records.
6. Troy Langley, gates, chains, locks and property damage
• Identify Troy Langley’s role, employer, instructions and authority.
• Produce every document authorising him to bolt, chain, lock, secure, alter or interfere with gates or access points.
• Identify the property, date, time, purpose, person directing the work, legal power relied upon and persons retaining keys or combinations.
• Produce all photographs, video, receipts, invoices, contractor records, damage assessments and repair records.
7. NAIT, LIC and the 119 cattle
• Produce raw scanner data for all 119 cattle and identify whether the disputed 14 tag reads were captured.
• Produce the complete tag-order, allocation and registration history for the 14 tags and explain why no effective exception or reconciliation prompt was provided.
• Produce LIC’s original and final files, all MINDA/NAIT/Gallagher logs, all error and exception reports, and the identity of each person who handled the transaction.
• Produce Gavin Jones’ receiving records and identify what he was required to confirm, what he did confirm, and when.
• Provide a complete animal-by-animal reconciliation and identify the evidence said to attribute any failure personally to Michelle.
8. Telephone, messages and private conversations
• State whether any telephone, email, text, social-media, subscriber, location, call-associated or stored-communication information was requested, obtained, monitored, recorded, analysed or shared.
• Identify the persons, numbers, devices and date ranges affected.
• Produce every production-order application and order, warrant, surveillance authority, provider request, return, analysis and dissemination record.
• Identify whether information obtained in relation to Tuscan or the horses was used to initiate, expand or support the NAIT investigation.
9. Banking and financial records
• State whether any banking, transaction, account-holder or financial information was sought or obtained concerning Michelle Walker, Pete Verhoeven, Christine Barrett, Howard William Lee, Tuscan, the cattle or associated operations.
• Produce every legal authority, request, response, statement, report, analysis and onward disclosure.
• Identify the purpose for which the information was obtained and whether it was used in more than one investigation.
10. Connection between investigations
• Identify the date, source and decision-maker responsible for opening the NAIT investigation.
• Disclose every record referring to both the Tuscan/horse matter and the NAIT/cattle matter.
• Identify all common officers, inspectors, lawyers, contractors and decision-makers.
• Disclose all instructions, intelligence, meetings or communications capable of showing coordination, prejudgment, improper purpose, retaliation or cross-use of information.
11. NorthSouth Livestock Whangārei proceeding
• Produce the judgment or transcript, if held, and every internal MPI review of the dismissed NorthSouth Livestock prosecution.
• Identify any changes to policy, evidence collection, NAIT reconciliation or prosecution practice following that case.
• Explain what additional evidence in Michelle Walker’s case is said to avoid the evidential deficiencies identified in the earlier matter.
12. Required form of response
• Provide native electronic files where practicable; do not flatten raw data or spreadsheets into screenshots.
• Provide a document schedule identifying each item held, disclosed, withheld, missing, destroyed or held by another person.
• For each withholding, identify the precise legal ground, decision-maker and reasons, and release the balance after redaction.
• Confirm in writing what preservation steps have been implemented and the systems searched.
• Provide a substantive response within 10 working days, or identify the statutory response period applicable to the recipient.
13. Notice of intended use
The responses and any failure to preserve, search for, identify or disclose responsive records may be placed before the District Court in CRI-2026-088-000136 and relied upon in applications for disclosure directions, exclusion of improperly obtained evidence, dismissal under s 147 of the Criminal Procedure Act 2011, judicial review, complaints, or other proceedings. No adverse conclusion is asserted merely from silence; however, an unexplained failure to answer particularised questions will be relied upon as demonstrating that the identified evidential and authority gaps remain unresolved.
Issued on: 4/08/2026
For the Private Trust Attorney’s Office Under instructions from the relevant trustees and affected persons
CRI-2026-088-000136 | MPI v Michelle Francine Walker
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