FUJ00121568 - Fujitsu Services Post Office Account - Response to J Coyne email dated 3rd March 2004

Evidence on official site

FUJITSU SERVICES POST OFFICE ACCOUNT
Response to The Expert’s Reply to Fujitsu Services’ Submission

Background

The Expert has responded to the letter we sent to Post Office dated 20'" February 2004 in
response to his Expert Report dated 20'" January 2004. Essentially he has not accepted any
of our explanations and has refused to change the original opinion expressed in his report.

The solicitors have advised Post Office that the matter will now be committed to trial and that
Post Office witnesses may be called. Post Office has in turn notified Post Office Account that
we may have to provide expert witness to testify against his opinions.

I have spoken to Jim Cruise (Post Office Case Manager) and we both feel that there is
probably another opportunity to influence the Expert's opinion by inviting him to Post Office
Account locations (FELO1, BRAO1, STE04) and providing him with access to data, records
and people who can deal with his observations directly.

Response
Using the headings as presented in his report :

Horizon System Helpdesk

Fujitsu does not agree with his assertion that this is a matter for the Post Office and Fujitsu
since he has made negative assertions about the HSH only dealing with symptoms and not
causes. The primary objective of the HSH, as explained in our original paper, is to provide
such assistance as is possible in the short term and to return the Outlet to normal business as
rapidly as possible. Advice to reboot is the most effective way of doing this. It is not the
function of the HSH to analyse crashdumps while on the ‘phone to Post Masters.

His statement that the HSH was not interested in getting to the ‘bottom of the continual
occurrence’ is flawed given that one of the calls that he has specifically referenced was
closed using a Known Error Log. The presence of a KEL clearly indicates that problems are
investigated and workarounds provided pending a permanent fix through a system upgrade.

He cannot dismiss our explanation in this way as it explains the modus operendi of the HSH
and challenges what is, in effect, his misunderstanding of the evidence put before him.

Transaction Handling on Reboot

What was offered in our reply was a statement of fact. We can, if allowed, demonstrate that
this happens but it would be for another Outlet, not Cleveleys, and the system build status
would not be as it was in 2000. Any supporting audit data has been deleted through normal
operating procedures.

Reasonabless of Calls

Data that is provided to Post Office in support of investigations and prosecutions is derived
from a controlled audit archive. HSH data from this source would indicate the numbers of calls
raised but not their content or final disposition. Under the contract this data would be deleted
18 months after it was originally written. It would be to this source that Fujitsu would turn to
service requests from Post Office Investigations.

However, the HSH call Powerhelp transcripts are maintained in an uncontrolled (in the sense
of evidentially admissible) archive and this can be made available to the Expert at our
Bracknell office, if he so wishes. From this archive he can obtain details of calls made by
similar profiled Outlets at the same time and draw his own conclusions as to whether
Cleveleys was unusual or not.

Similarly, the raw data for the analysis provided in our reply was derived from an uncontrolled
database. The Expert can have access to this database, again at Bracknell, and can make his
own analysis of the available data.

With regard to his specific comparisons of mean numbers he has selectively identified those
that show Cleveleys in a poor light and ignored those other Outlets whose results exceed

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those for Cleveleys. For example Darwen made more calls about hardware and Colwyn Bay
more about software.

Finally, we dispute whether a comparison with a mean has any relevance. Only the total
number of call made in the categories has value since all Outlets were running the same
system and would have been transacting similar profiles of business. As such, other factors
including, but not limited to, PM training, competence and capability and the PM's attitude
towards raising calls have a part to play.

Operator advice to Reboot

It will not be possible to provide the ‘crashdumps'’ that the Expert refers to since these will
have destroyed. Again, he can have access to the Horizon System Helpdesk in Stevenage
where he can talk to the relevant people and follow the support line from 1° to 4" line. Since
we cannot provide the absolute evidence relating to Cleveleys in 2000 we can at least assure
him of the support and problem resolution activity that goes on behind what could be
construed as a simplistic ‘reboot and continue’ piece of advice, and it would be wrong of him
to assume that that was the end of Fujitsu's responsibilities in resolving problems.

Defective Equipment

We would need to understand the basis for the opinion but as stated in our original response
the statement is subjective, not supported by evidence and we would reject it.

Worrying Discrepancies

We need to consider the specific calls that the Expert is referring to. It should be noted that in
all cases the Post Master was happy to close the call before it was closed by the HSH.

Call 10253234

Referenced by the Expert in respect of ‘large discrepancies’. A full review of the call shows
that on 25/10/00 the PM reported the problem and was provided with guidance to resolve the
problem within 45 minutes. The PM (male) agreed to call back when this advice had been
followed. On 31/10/00 the PM (female) rang wanting to know what was happening to the call.
On 01/11/00 the HSH called the PM who was too busy to talk but who later that day rang
back to say that the problem had been resolved the previous week when the transaction was
reversed through normal operational procedures.

Call 10311359

Referenced by the Expert in respect of ‘minus figures’. Again, advice on resolving the call was
given immediately and the call was closed after the PM had followed normal operational
procedures to resolve the problem.

Call 11084045

Referenced by the Expert in respect of ‘system freezing’. I suspect the Expert was pointing
out the poor response provided by the HSH in this instance.

Call 11012223

Referenced by the Expert in respect of ‘intermittent problem following system upgrade’. There
are two issues here. One was the unfortunate statement to the effect that the problem
occurred after the Counters were upgraded on 23/10/00 (Release CSR). The second was that
the problem was already known about and closed using a Known Error Log that would
challenge the Expert's opinion that POA does little to analyse and resolve problems other
than to recommend a reboot.

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