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Message
From: Thomas Penny [/O=EXCHANGE/OU=ADMINGROUP1/CN=RECIPIENTS/CN=THOMASP]
Sent: 14/12/2010 14:26:26
To: Jones David M [/O=EXCHANGE/OU=ADMINGROUP1/CN=RECIPIENTS/CN=DJ]
cc: Prenovost Jean-Philippe [/O=EXCHANGE/OU=ADMINGROUP1/CN=RECIPIENTS/CN=BRAJPREV]; Smith Jonathan
[/O=EXCHANGE/OU=ADMINGROUP1/CN=RECIPIENTS/CN=SMITHJ4]; Wilkerson Guy
[/O=EXCHANGE/OU=ADMINGROUP1/CN=RECIPIENTS/CN=WILKERSONG]; Jenkins Gareth GI
[/O=EXCHANGE/OU=ADMINGROUP1/CN=RECIPIENTS/CN=GARETH.JENKINS]; Williams Roger
[/O=EXCHANGE/OU=ADMINGROUP1/CN=RECIPIENTS/CN=WILLIAMSRQ]
Subject: RE: Standard Witness Statement - HNG-X
Attachments: HNGX Txn Data Witness Statement V 10.doc; Penny's Standard Fujitsu V9 Nov 09.doc
David
Please find attached the draft witness statement for HNG-X which was modelled on the Standard V9 Nov 09.
The original of V9 was reviewed and agreed with POL; some minor changes have been implemented without
further review.
Kind regards
Penny
Penny Thomas
Security Analyst, Customer Services
Fujitsu Services Retail & Royal Mail Group Account
Lovelace Road, Bracknell, Berks RG12 8SN
Tel:
Mob:
Fax:
E-mail: penny. thomas¢
web: http://uk.fujitsu.com <http://uk. fujitsu.com/>
Fujitsu Services Limited, Registered in England no 96056, Registered Office 22, Baker Street, London wiu
3BW
This E-mail is only for the use of its intended recipient. Its contents are subject to a duty of
confidence and may be privileged. Fujitsu Services does not guarantee that this E-mail has not been
intercepted and amended or that it is virus-free.
From: Jones David M
Sent: 14 December 2010 14:03
To: Thomas Penny
Cc: Prenovost Jean-Philippe; Smith Jonathan; wilkerson Guy; Jenkins Gareth GI; Williams Roger
Subject: RE: Standard Witness Statement - HNG-X
Penny
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Thanks. Please can you send me the latest draft so I can be certain I am reviewing the right starting
point?
Has this or an earlier version been reviewed and approved by Post office?
Best wishes
David
David M Jones, Head of Legal
UK Private Sector Division
FUJITSU.
Mob:
E-mai
david. jonesing. <mailto:david.jonesmt. GRO
From: Thomas Penny
Sent: 14 December 2010 14:01
To: Jones David M; Williams Roger
Cc: Prenovost Jean-Philippe; Smith Jonathan; wilkerson Guy; Jenkins Gareth GI
Subject: RE: Standard Witness Statement - HNG-X
David
Thank you for your note.
If your review of the document causes you concern then a meeting would be ideal for us to understand and
discuss those concerns; if it looks pretty straightforward we can work remotely.
be a party to any comments/discussions we may have, please.
I'm grateful for your offer of help.
Kind regards
Penny
Penny Thomas
Security Analyst, Customer Services
Fujitsu Services Retail & Royal Mail Group Account
Lovelace Road, Bracknell, Berks RG12 8SN
Tel:
Mob:
Fax:
E-Mail: penny. thomas@
Guy and Gareth should
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Web: http://uk.fujitsu.com <http://uk. fujitsu.com/>
Fujitsu Services Limited, Registered in England no 96056, Registered Office 22, Baker Street, London wlU
3BW
This E-mail is only for the use of its intended recipient. Its contents are subject to a duty of
confidence and may be privileged. Fujitsu Services does not guarantee that this E-mail has not been
intercepted and amended or that it is virus-free.
From: Jones David M
Sent: 14 December 2010 12:29
To: Williams Roger; Thomas Penny
Cc: Prenovost Jean-Philippe; Smith Jonathan
Subject: RE: Standard witness Statement - HNG-X
Roger
I will pick this up.
Penny
You will remember that we met earlier to discuss the issues on West Byfleet. Roger is leaving Fujitsu and
I am taking over in the new year as Head of Disputes. I am happy to work with you on putting in place
some standard wording.
what is the best way to do this? Can we do it remotely or shall I plan to visit Bracknell. who needs to
be involved?
Best wishes
David
David M Jones, Head of Legal
UK Private Sector Division
<mailto:david. jonesm
From: Williams Roger
Sent: 13 December 2010 12:53
To: Jones David M
Subject: FW: Standard Witness Statement - HNG-X Outlet
David,
I know that you have a particular interest in this area (!) having provided guidance to the team on the
West Byfleet case. As I am probably not going to have time to get involved, would you be able to pick
this up? I have to admit that it has slipped off my radar since October, so I am happy to accept
responsibility for the critical path delay. But I don't think there is really any particular deadline
‘involved.
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It probably needs someone to sit down with one of our experts to go through the Horizon system in detail
to make sure that we have captured it fully, and, just as importantly, explained it in a way that
Magistrates or a jury will understand. So we could get external lawyers involved if necessary. Chris
Breen from Pinsent Masons recently gave some general guidance to the team about giving evidence.
Best regards
Roger
Roger Q Williams
Legal Department
FUJITSU
Road, Slough, ire SL1 2eY
From: Prenovost Jean-Philippe
Sent: 13 December 2010 09:41
To: Williams Roger
Subject: RE: Standard witness Statement - HNG-X Outlet
Hi Roger,
Do you think you'll get a chance to review this before the holiday period?
Please let me know as the account is chasing.
Thanks in advance.
Kind regards
ap
From: Prenovost Jean-Philippe
Sent: 21 October 2010 11:59
To: Williams Roger
Subject: RE: Standard witness Statement - HNG-X Outlet
Hi Roger,
I now have more clarity around the timescales and it would appear as though there are no claims as such
on the horizon but the team wants to be in a position to agree a standard approach with PO to create
certainty and comfort around the litigation support obligations.
In summary, there are no firm timescales but if you could look at it as soon as convenient for you when
you do become available, it would allow the team to move forward in this process.
Thanks in advance.
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ap
From: Williams Roger
Sent: 20 October 2010 16:08
To: Prenovost Jean-Philippe
Cc: Maguire Dermot
Subject: FW: Standard Witness Statement - HNG-X Outlet
Hi JP.
The whole team is immersed in the NHS matter at present - we have a deadline of 29th to submit our claim
in the arbitration. But we could pick this up after that, assuming that there is no urgency.
The draft witness statement is a witness statement under the Criminal Justice Act to support a criminal
prosecution, so would need input from a criminal lawyer. As it happens, I do have criminal law
experience in the distant past (coincidentally, as a prosecution lawyer with the Post Office!). And I
suspect that Dermot has a hidden criminal past too.
But let me know the timescales.
Best regards
Roger
Roger Q Williams
Legal Department
FUJITSU
From: Prenovost Jean-Philippe
Sent: 20 October 2010 14:29
To: Williams Roger
Subject: FW: Standard Witness Statement - HNG-X Outlet
Hi Roger,
Following the litigation presentation a few weeks back, we reached the conclusion that the Post Office
team would benefit from having access to litigation expertise with a view to avoiding risks inherent in
the litigation process and in our interactions with the Post Office litigation team.
I'm certainly happy to act as the intermediary to manage engagement but I would like to officially open
up channels of communication on this account (perhaps with Katherine?) starting with a review of this
standard witness statement which is used to support Post Office litigation as explained below.
Let me know if this is workable.
Thanks
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ap
From: Thomas Penny
Sent: 20 October 2010 12:00
To: Prenovost Jean-Philippe
Subject: RE: Standard witness Statement - HNG-X Outlet
IP
we provide a litigation support service to POL. The basic deliverable is transaction data which the
investigator uses to identify exactly what transactions have been recorded at an outlet. Once we have
returned such ARQ (audit record query) transaction data and if the investigator wants to introduce that
data into court, then they will request a witness statement. We have a ‘standard’ return which
accommodates the specific detail of the ARQ request.
Let me know if you need more.
Kind regards
Penny
Penny Thomas
Security Analyst, Customer Services
Fujitsu Services Retail & Royal Mail Group Account
Lovelace Road, Bracknell, Berks RG12 8SN
Tel:
Mob:
Fax:
<mai]to: penny. thomas:
E-Mail: penny. thomag
web: http://uk.fujitsu.com <http://uk. fujitsu.com/>
Fujitsu Services Limited, Registered in England no 96056, Registered Office 22, Baker Street, London wW1U
3BW
This E-mail is only for the use of its intended recipient. Its contents are subject to a duty of
confidence and may be privileged. Fujitsu Services does not guarantee that this E-mail has not been
intercepted and amended or that it is virus-free.
From: Prenovost Jean-Philippe
sent: 20 October 2010 11:51
To: Thomas Penny
Subject: RE: Standard witness Statement - HNG-X Outlet
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Hi Penny,
Could you please provide me with a brief paragraph explaining when this is used and I will involve the
litigation team as discussed.
Thanks
ap
From: Thomas Penny
Sent: 20 October 2010 11:49
To: Wilkerson Guy; Prenovost Jean-Philippe
Subject: FW: Standard Witness Statement - HNG-X Outlet
Guy / 3P
Have some comments from Tom - would you please be kind enough to provide your comments.
Many thanks
Penny
Penny Thomas
Security Analyst, Customer Services
Fujitsu Services Retail & Royal Mail Group Account
Lovelace Road, Bracknell, Berks RG12 8SN
Tel:
Mob:
Fax:
E-Mail: penny. thomas <maj1to: penny. thoma
web: http: //uk. fu tsu.com <http: //uk. fujitsu.com/>
Fujitsu Services Limited, Registered in England no 96056, Registered Office 22, Baker Street, London wlu
3BW
This E-mail is only for the use of its intended recipient. Its contents are subject to a duty of
confidence and may be privileged. Fujitsu Services does not guarantee that this E-mail has not been
intercepted and amended or that it is virus-free.
From: Thomas Penny
Sent: 06 October 2010 08:25
To: Wilkerson Guy
Subject: FW: Standard witness Statement - HNG-X Outlet
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Guy
Could I please nudge you for your comments?
Kind regards
Penny
Penny Thomas
Security Analyst, Customer Services
Fujitsu Services Retail & Royal Mail Group Account
Lovelace Road, Bracknell, Berks RG12 8SN
Tel:
Mob:
Fax:
)
A
O
E-Mail: penny. thomas
web: http://uk.fujitsu.com <http://uk. fujitsu.com/>
Fujitsu Services Limited, Registered in England no 96056, Registered Office 22, Baker Street, London wiu
3BW
This E-mail is only for the use of its intended recipient. Its contents are subject to a duty of
confidence and may be privileged. Fujitsu Services does not guarantee that this E-mail has not been
intercepted and amended or that it is virus-free.
From: Thomas Penny
Sent: 16 September 2010 16:11
To: Lillywhite Tom; Wilkerson Guy; Prenovost Jean-Philippe
Subject: Standard witness Statement - HNG-X Outlet
All
In preparation for litigation support of an HNG-X outlet I have prepared the attached standard witness
statement.
Could you please review and let me have any comments you may have?
Kind regards
Penny
Penny Thomas
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Security Analyst, Customer Services
Fujitsu Services Retail & Royal Mail Group Account
Lovelace Road, Bracknell, Berks RG12 8SN
Tel:
Mob:
Fax:
!
E-Mail: penny. thoma:
Web: http://uk.fujitsu.com <http://uk. fujitsu.com/>
Fujitsu Services Limited, Registered in England no 96056, Registered Office 22, Baker Street, London wiu
3BW
This E-mail is only for the use of its intended recipient. Its contents are subject to a duty of
confidence and may be privileged. Fujitsu Services does not guarantee that this E-mail has not been
intercepted and amended or that it is virus-free.