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lee castleton
From: “lee castleton" <~
Date: 18 December 207
Hi Tadge,
I have enclosed the transcripts of evidence given in my case by Andrew Wise and
Anne Chambers.
Andrew Wise is a Post Office Horizon Trainer. He has had various years of experience in
teaching people to use Horizon.
You will see that he states that it is Absolutely impossible to transact business without you
first logging on to Horizon.
This is because in order to reach the sales screen you have various secure checks te go
through to prove the person using the system is,
a, The person they say they are, by giving your user code and then a password only known to
that person to gain entry.
b, So the Horizon system can allow only access to the area's that are cleared to that person.
In the paperwork in my file held previously by Amanda Glover you will see the documents
that the questions and answers are drawn from.
You will see that £1300 worth is transacted on node one whilst { was not logged on to the
system. But as Andrew quite clearly states this is impossible.
Even though Post Office claim they have no access to the system themselves these
transactions cannot have been transacted by me at that time. Therefore there is either back
office access or the system itself has lost the transactions and then re-found them at a later
date. Or the transactions are not from my office at all.
Anne Chambers is a Horizon computer system specialist. You will see in her answers that
when asked about the contact of nodes in my office she explains that she needs to read up
on the system to answer a question on nodes and there contact. You will see in the
paperwork again left with Amanda Glover that the nodes are show as firstly losing contact
and then clearly stating contact has been regained. Nothing unusual in that. But whilst Anne
was quite happy to explain how and why contact is lost when ! asked her why further down
in the paperwork the document again clearly states contact to node 1 is lost but then as it
had done before stating contact with node 1 regained was not printed. The document goes
on to show contact with node 1 lost and a further contact with node 1 lost but again without
contact with node 1 being regained. Anne Chambers then could not answer. She explains to
the Judge that if she had known I was going to ask that question she would have read about
that in the system.
For me I have asked various computer people. Can a system show loss of contact and then
the resumption of contact in the first instance and then from then on just show repeated
loss of contact without any reference to the regaining of contact as in the first case. The
answer is always the same. NO.
A system when working correctly. Will always show the same reaction to the same instance.
It is not organic and therefore has no choices to make.
Lee Castleton
18/12/2011
a
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Q. So it would be quite a process to actually move through the numerous, is it three,
screens?
A. The navigation of the screens is quite quick. It may take a minute to log on to the
system but once you’re logged on the navigation is quite quick.
Q. But the initial log-on itself , how long would it take, depending on how --
It depends on how experienced the sub-Postmaster is. It can be a relatively quick
process. The less experienced ones might have to sit and think about it before they
begin to search for information.
Q. Obviously you have done this on numerous occasions and you teach people to do
that in your job?
A. Yes.
Q. Over that period of teaching, is it possible at any time to actually transact business
without being logged on to this computer?
A. You cannot enter anything on the system. Whether the sub-Postmaster chooses to
serve a customer while not being logged on then that’s --
Q. No, I mean on your -- sorry, I apologise. Let me understand what you are alluding
to there. You would mean under somebody else’s code?
A. No. You can still physically serve a customer without being logged on.
Q. The computer itself would not see that, would it?
A. You have to tell the computer what you’re doing.
Q. So you could not tell the computer that you are serving a customer if you are not
logged on to that system?
A. That's right. .
Q. It is absolutely imposstole? en,
A. Yes. :
Q. Could you take out book 1 1B, please.
JUDGE HAVERY: How much longer are you going to be with this witness,
Mr Castleton? I do not really want to make him stay (several inaudible words) if it
can be avoided. 1 am not hurrying you at all; I just want to know,
MR CASTLETON: It would depend, my Lord (I am sorry for not being specific) on how
far we can get through the questions.
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Mi
Wordwave International, « Merrill Communications Company
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JUDGE HAVERY: How many questions do you have, do you think, depending or
getting a quick answer to each question?
MR CASTLETON: Probably 16(?}, my Lard.
JUDGE HAVERY: I think we will go on.
MR CASTLETON: If you could turn to book 11B, tab 103, page 3705, Have you eve
seen one of those before?
A. I've seen one once oF twice. Is it (inaudible) transaction? Ive never looked at on
in depth to understand what information is on there.
Q. But you can see generally what that is?
Yes.
Q. So we can actually look across and see in this 3705, this is actually a status repo
from my belief, and this would tell you who is logged on and who js not logged o
Is that correct?
A. Ittells you the user and what activity they've performed and the stock unit that th
were attached to, along with the time and date.
JUDGE HAVERY: By the user, you mean which terminal, do you?
A. The RSPOO}, that relates to an individual. Fach individual has a user name.
JUDGE HAVERY: Isee. I expect LC is you, is it, Mr Castleton?
A. My Lord.
JUDGE HAVERY: RSP, who is that?
A. It’s Ruth Stammer(?).
JUDGE HAVERY: Yes, I see.
MR CASTLETON: If we new just look back in that same book to 3703, 2 February.
we can follow through here from what the actual computer (several_inaud
words). Is that correct?
Yes.
And we can see who is logged on and who is not logged. Is that true?
Yes.
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Wordwave Intemational, a Merrill Communications Company
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_Q. If we continue back towards actually where we were in the original, so we can flick
through looking down and see whether (inaudible) are connected or various other
things, but one of the things that we can actually see is, at 14.24 ~
JUDGE HAVERY: What page?
MR CASTLETON: Sorry, my Lord, 3705, at 14.24.56.
JUDGE HAVERY: I see. Do you see that, Mr Wise, six lines from the bottom?
A. Ido, yes.
MR CASTLETON: That is myself, LCA00!, logged on to node 2, is that correct,
Mr Wise?
A. Yes.
Q. Then if we go back over to 11A, page 3501, under tab 101, in the other book. Do
you know what that document is?
I’ve never seen that one before.
Q. Okay. If you look in the first column, there is 1D and it is either a 1 or a 2. Do you
know what that number pertains to?
A. I would guess that’s the number of the terminal. If there were two Horizon
terminals, it’s either node I or node 2.
is that a guess though?
That’s a guess. [ don’t know that for sure.
Q. So you would not know anything that goes across this line? If we were to take the
top line where it says “IDI, LCAOOL, stock unit 88” would you know anything
from there?
A. From experience I can pick out what the information is referring to is the stock unit,
the date, the time. The session ID probably relates to the transaction that was
performed. I’m not sure about the next column. The mode is the type of
transaction (several inaudible words). The product, each product is assigned a
product number so that would relate to the product but I don’t know what product
that is. The quantity is the number of products. And the sale value would be the
sale of that particular transaction.
Q. So, basically, you can transpose every column.
A. The last five there I’m not quite sure what they would have been: the entry method,
state, IOOP, results and the last one there.
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Wordwave International, a Merrill Communications Company
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- Q. (several inaudible words} I could tell you what those are but to be honest, for the
purposes of the court, it is of no relevance to how things are inputted.
JUDGE HAVERY: Let us not worry about things that are not relevant.
MR CASTLETON: Could you tell me, in 3705, on the other book again, 11A, if you
look down to the time that I log on, LCAOO! logged on.
JUDGE HAVERY: It is (inaudible) 41.15. Is that it?
MR CASTLETON: That is actually into node 1, my Lord. If you look further down, I
actually move across into node 2 which is at 14.24.56.
JUDGE HAVERY: I see. Do you see that?
A. Yes.
MR CASTLETON: If you then look across into the other book, my Lord, and you look
across the seventh column down, you can see I appear there as LCAOQO! in node 2.
JUDGE HAVERY: Can you just repeat the aumbers of the two documents we are
comparing?
MR CASTLETON: Certainly, my Lord. It is bundle THB, tab 103, page 3705, and
bundle 11A, tab 101, document number 3501.
JUDGE HAVERY: I have those two, thank you.
MR CASTLETON: If you mark on 3705 on 2 February at 14.24.56, you will see that is
the time that I personally logged on to the system. If you then look across to the
other book, you will see the seventh transaction down from the top on 3501 was
placed at 14.21.12, some three minutes prior to me logging on.
JUDGE HAVERY: I see. No one was logged on at all before then, is that right?
MR CASTLETON: I was logged on to node 1, the other computer.
JUDGE HAVERY: No one was logged on to 2, is that right?
MR CASTLETON: That is right, my Lord.
JUDGE HAVERY: I see. It looks like it. There is not on 3703 and 3704.
MR CASTLETON: No, my Lord. They are all is all the way through to the start of
play, I am afraid.
JUDGE HAVERY: I think the question is fairly apparent now. How is it that page 3501,
Mr Wise, shows apparently Mr Castleton making some entry at terminal 2 at
2.21.12, whereas he only logs on, according to the other one at page 3705, at
2.24.56? .
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Wordwave Intemational, a Merrill Communications Company
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A. lean’t explain that.
JUDGE HAVERY: I assume it is precisely the same clock that is operating in both
x cases?
A. 1 don’t deal at all with the technical side of the system. I wouldn’t know, I’m sorry.
JUDGE HAVERY: Right. You are asking the wrong witness. There must be someone
B else to ask on this.
MR CASTLETON: You did say prior to this, I believe, that it is impossible to transact
business without being logged on.
A. 1 did, yes.
c Q. That is fine.
MR CASTLETON: I think that is fine, my Lord.
JUDGE HAVERY: I just have one or two questions for you, Mr Wise. If you could go
back to your own statement, volume3, behind tab 48. Would you look at
D paragraph 9 at page 302. Something I do not quite understand, it may even be a
typing error, but when you are describing what the Postmaster does, you say: “They
then complete a batch control voucher BCV i in heavy type.” Do you see that, about
halfway down in paragraph 9?
A. Yes.
E JUDGE HAVERY: “Paperclip”, which I assume means something that is attached to an
email, is that right?
A. No. So, the sub-Postmaster will complete the batch control voucher. We call it a
BCV. We always abbreviate things in the Post Office. And you paperclip that
batch control voucher, together with non-bar-coded and bar-coded TV licence
F forms, So for a TV licence transaction, they would have a physical slip that they’ ve
got in the office and they would paperclip that behind the batch control voucher and
they’ re despatched to Chesterfield.
JUDGE HAVERY: Thank you. And the other one, would you turn to page 305,
paragraph 22. Towards the bottom of the paragraph you say, “For example ...”. Do
you see that at line second from the bottom of the paragraph: :
G “For example, if the clerk records an item incorrectly on the system
they should pick this up on their daily or weekly report. However,
if they fail to do so this will be picked up at the processing centre.”
We are now back to Chesterfield, are we, or possibly Northem Ireland?
MS
Wordwave Intemational, a Merrill Communications Company
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“A. If it’s a Girobank transaction it could be Girobank ia Bootle; it could be National
Savings in Glasgow; it could be Chesterfield; it could be Northern Ireland, So it
“A would depend on the transaction type.
JUDGE HAVERY: I see, yes. Then you say here: “If an item has been wrongly
recorded, an error notice would be generated.” How does that happen? That must
be something that is done on the Horizon system, 1 assume?
A. Yes.
JUDGE HAVERY: So how does the Horizon system itself know that there is an error?
A. What happens, the transactions are input on to the Horizon system and the office
would have the documentation that should agree with that figure. If they’ve missed
something off (so for example they missed off a deposit and they’ve not put that
Cc through the system) when Girobank receive the dockets they check that figure
against what’s recorded on Horizon for that day and if it shows a discrepancy they
~ would generate that error notice.
JUDGE HAVERY: Does the Horizon system check that or does it take the word of the
recipient, Girobank or whoever it may be?
D A. Horizon just relies on what the sub-Postmasters input on there and then Girobank
check the physical work against what the sub-Postmasters put on the system.
JUDGE HAVERY: The Postmaster regularly sends off the documents in a bag or
something?
A. Yes. They’re despatched at the end of the day or week to different departments.
JUDGE HAVERY: So if there is an error, is it that what is in the bag is incorrect anc
your recipient finds that or what?
A. That’s right. What is physically there in documents is what has got to be correc
and if that disagrees with Horizon -- so it could be a sub-Postmaster has no
F recorded a document on Horizon, so the client would say, “Your system say:
you've done this number for this value but you’ve sent me documents for thi
value”. So they would say there’s a discrepancy of £100 bere and that woul:
generate the error notice.
JUDGE HAVERY: I see. Is the ultimate recipient checked by this at all or is jus
assumed that the ultimate recipient is right?
G
A. If an error notice comes through, the sub-Postmaster can challenge it and they ca
request for paperwork to be sent showing what the discrepancy is. So they woul
send copies of all the relevant paperwork and a copy of what was entered o
Horizon. So a sub-Postmaster can challenge it and ask for evidence to be ser
through.
H
JUDGE HAVERY: I see, thank you. Any other questions?
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Wordwave Intemational, a Merrill Communications Company
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Q: ‘Then moving down to 13.30, and even efter, there is no notice of node ?
being disconnected. Is that correct?
A: Node 2. was not doing anything at all Gnandible) until — the first thing
you have for node 2 is alog on at 14.24,
Qa Yes.
A sone it ot do myn otal prior © nt wich wa neues 2
Q: But it must have been disconnected, we have established --
A: se sould nat say it was disoonnecte if it was not WON
Q: Then would st not say that it had reconnected?
A: va, beceute was notever daconneted twas st COMICS
A No bei orm tomes ist ot Peron
Q com reconnection surely it would say it was reconnected:
A: io, because it hed nat ever been disconnected ‘You do not get that event
logged. Disconnected means that itis w' i ag it should be except it is not
ceernunicating with the other nodes. In this case it just was not working 5°
communicating it anand reson Xt wae SomEISny SY"
and then, yes, now it is working.
@ sn tia gift any pit node 2x Decomedcemness WOR
show on the log.
A: reseed een operon ah tinea hat had ez MNCS
jt would have said so, yes. Yes, {believe it would have said 0.
Q: So being not working but connected it would not show & disconnection.
A: No, because it cannot log anything because it is not working.
Q men you reboot the machine to pat bac online awl oT
that node 2 had reconnected? Booause surely it knows that it is di
evonnetion i A wou ig iit wa jus HE
Q@ seo tur to page 3705 at 12.41.51, midway trough ihe page —
A: Yes.
Pe LCAS0000252
LCAS0000252_’ ne 09
Wi
rd :
. ip
jg that node 1 disconnected?
. Then further down the page at 14.03.42.
}
I as. That appears pe node I disconnected.
Q
A
2 Node 1 has regained its connection
Q: So that js how it would be depicted.
Ay vat weet a ng operating normally but
the network between ope Tf that was
he eo DN net 8 and regained connection messages.
Q: So that would be the disconnection awe the counters or between
yourselves and the counter
A; Jamnot 100 per cent sure of this and itis something if Thad known}
was going to be as! Be would have made sure 12 SSI
Qa Just with it being part of Your =
A: This is not pert of my evidence. There is nothing to do with this in BY
witness statement.
Qi apologise, f My next question was going to be, if you would am pack to
3703, midway do ywn the ep 2029 cers 8 nes NOU? I
disconnection.
A: Yes.
@ sentence nt
until it disconnects again at 12.41.51. .
A {cannot tel just from this wi fay that would be.
Right. ‘To have it depicted in in one way between where WE SES HY.
fF reconnection ‘on further down ywn the pee F3, Lean appreciate obviOws)Y
that, as you have told me, this is ate vor area, it was obviously @ question
tha Pcs going 1 raise 10 YOUsE © ih reapect to ow it has 00
Tesonnected and how the syst sot seer 1 to know wheth node 2 has
AL ae ening sinensis
hk Whether senza he cogs ase oan NS
then jlaceeata them again -~
. 39
&
. Suggests that the communications between the gateway and the data centre
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Q: It does actually occur in other areas.
A: ~Ireally cannot explain thet, not from this information. If I looked at it
in conjunction with other things —
HIS HONOUR JUDGE HAVERY: What are these other entries after the
entry of 09.20.29 saying node 1 is completely disconnected? The next entry
is three minutes later and it says "IDI". That is node 1, is if?
A: Yes, node 1 was operational.
HIS HONOUR JUDGE HAVERY: If you have this entry for 09.23.23
saying: “Report APS receipt" and the report printed and all that, can that
happen if node 1 is discormected or what?
AD Yes, because node 1 was disconnected in that, I assume, it realised it
could no longer talk te node 2, but it was still operating properly in itself.
HIS HONOUR JUDGE HAVERY: It was still operating as 2 computer on its
own?
A: Yes.
HIS HONOUR JUDGE HAVERY: I see.
THE DEFENDANT: So the disconnections of node 1 to node 2 is the only
thing that is depicted in there, it is not the connection to the network?
Ar Tam not 100 per cent sure whether it is also taking into account the
connection to the data centre.
Q So it could weil be that node 1 and node 2 at different points were
disconnected from the system completely?
A Except you appear to have been doing (inaudible).
Q: That is what I cannot understand.
HIS HONOUR JUDGE HAVERY: You are interrupting the answer, that is
the problem.
THE DEFENDANT: Sorry, my Lord, I apologise. ‘
HIS HONOUR JUDGE HAVERY: Would you mind finishing the answer,
Mrs Chambers?
A: Yes, I believe it looks like you have managed to carry on doing online
transactions during the morning from your gateway, your counter 1, which
were working as they should be and it was just counter 2 that was not
operating at all.
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WordWave Internetional, a Merrill Conmunications Company
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THE DEFENDANT: ‘Then would it not say that counter 2 hes disconnected
from the network?
A: No, because it is counter 2 itself that would report that and counter 2 was
not working so it could not report it.
Q: So why would it report node L was disconnected?
‘Az Because node 1 realised it could not see counter 2. It should be able
always to talk to counter 2 as well as to the data centre. ¥f counter 2 has been
. aire ie or whatever, then node 1 will say it as been disconnected from
the network. We are talking about the network within the branch.
Q Yes, the local network.
A: Certainly that, Tarn not sue if we are also talking about the network 'o
an dam cenbe, but certainly within the branch node 1 was up and running
nd you were using it but it could not talk to node 2 bocause node 2 was
down and not working.
Q@: Iam just going to turn back to your own statement now. It is under tab
51, page 58.
A: Yes.
Q: Are you happy with what it says?
A: Yes. °
Q: Could you just explain to me the fifth line down? What does that mean?
as What, no transaction date and time? i”
Q: Yes.
A
: ‘That s just something one of our other call Jogging systems shoves info
responses which have then been cut and pasted —
So this is a cut and paste?
z 2
Yes, it is completely irrelevant.
But it has been cut and pasted fiom another document then?
A: That information in there, yes. ‘That was the response that I gave to the
ean nad investigated, which we will be able to see somewhere in these
calls that were attached to my evidence. It would have been call
$50402251077, which appears to be tab 106, page 4141. If you look in there
{you will see that that precise same text is in there.
Qa Why would it appear as ano transaction date end time was Provided
for this action using current date and time?
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‘WordWeve International, a Merrill Cossmunications Company
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spac and I would be happier if I oould have some moze
formation on the background --
g
I Q: No, L appreciate that.
A vant sexs ighty likly att was problem which hs oo
very in’ seems hy years io date where fr some reason whe SY
very inte palace process on one count, OB COURS! OE
icating properly with cet, you do not get a disconnected node
commnitin bianing esd 00 8 Pn
problem. hangs ced up centrally berause itis rasing SRS TA)
poble To eid exon for ny ofthese es
a call raised. nd 30 I won rus if we have t ook any 9 9 7)
one of these. is also Wor So branch, iit was Calendar Square, WR
one ofthe oye probes with this ot of problem with {hea Ye"
Cl knew there were system
Q: Cnaudible) Calendar Square, that is not in Scotland, is it?
A: Yes, itis.
Q: Isit?
A: Yes, Falkirk.
Q: Cnaudible).
AS ves, tive his might be Calendar Sau bat Tomo eS
, fad code off the top of my head. “Yes, Ioan, itis 160848; believe, but I am
E}> not quite certain. Yes, eve are talking about this beach, they for SOR
easbn had this problem several weeks in 810% ‘As I said, it does happen
reason ly ba it is very rare frit to happen Tepeaedy ‘The first week it
latte of ec end ayes miamatced Bene 2
a transferring twice. ‘Jou can only do transfers, you may not be aware of this
a transtepelieve you are (inaudible) 2 single stock unit ~
F :
- Q: I That is true, yes.
A = paths wane problem only happens i you have mor MD O66 Sor
Ac, bat this nals om oe tote ott, The stl
unt an you te oe gine, that tha bee done an allowed 10 BE SONS
ae tpsond time, which should not be possible.
G
Q: Gnaudible).
A: rat gave em otha oss and rout and payments misma)
‘That was picked up because ‘we monitored for receipts and payments
i . up boca eked up beoause there was ood of evens Ta
this site which we recognised. ‘They had the same thing the following woe
i: this sie wih ee ot nue tm any los or gan bess cy SSE
2 do the transferring twice. BE happened a third week and at that point I got
2 call about it which I passed on to our development teams. And also we
passed the information about the problem on to Post Office Limited so that
they could sort out the financial implications and I believe in this case the
problem was that (inaudible) information then did get sorted out at branch
level of Post Office Limited. But from the Horizon point of view, yes, they
had a system error which we were very well aware of snd I saw no evidence
of a similar system error at your branch. And I would have seen it had it
been there.
@ ‘You would have seen that?
A: Yes.
Q: ‘What evidence would that have produced?
A: In your system event log, which we do not have here, there would have
been hundreds, if not thousands, of the events, saying every few seconds that
i ible) is held. So that would have shown that, It also would have
shown in the message store because it would have potentially only included
transactions up to an earlier point than where you had actually gone to. But
because when you do a balancing it does draw a line under the transactions
which it has processed, the following week it would have included in here
what it would have missed in the first week. So in fact overall, as long as you
do not have this extra transfer problem, which you could not have hed, it
would give you some very confusing results as you belance, but it would then
sort it out subsequently. But I really do not think you hed that problem. ‘That
is one of the things I was looking for.
Q:. ‘Throughout the process we have heard various evidence ss to what 7
(inaudible) occurred and what has not occurred.
A: Yes.
Q: My question has always been: why when we produce snapshots on
Sundays we were way over in cash and other days we were under? tis not
the type of —
AS This is more a business issue, but the balance snapshot does not
recalculate your discrepancy.
Q: No, l appreciate thet. ‘What I am looking at is this system produces
obviously (inaudible) from the transactions that are placed. Is that correct?
A: ‘Yes, but I do not think T am going to be able to talk sensibly about the
snépshots because that is more of a business process than a system process
and I do not think I can talk off the cuff Gnaudibie).
Q: That is fine. Iwas saying my question was raised because of being, as
you say, over, under.
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AL st the cesh figure which is used is your last cass declaration ‘hat 38
made the last time you balanced.
Q: Absolutely, yes.
A: Adjusted by what you have recorded on the system since the eves! it
docs not then work out what the discrepancy is.
Q No, but obviously by checlcing the cash and cheque ~
A Yes, but I cannot see that because thet is not —
THE DEFENDANT: No, I appreciate that, but those calls were made. i
appreciate that you do not see that because that evidence is not Gnaudible).
‘That is fine, I am happy with that. Thank you.
RE-EXAMINATION BY MR MORGAN
MR MORGAN: Miss Chambers, three questions. ‘The first is something that
Lam not clear on and itis, I think, technical language: What is a Riposte
system?
A: ipo is the software that forms the bass of the Horizon syeion Wich
A: Riposte Oy a third party supplier, not by Fujitst, and which Hers
MS vi OY asf that has been put around the edge of, wt TS
is the system at the heart of it. When the system turns itself on after a reboot,
isthe system tytn you log out (audible) it says "Riposte” arose Se
front of it.
@ we looked at the document at page 2557AO and you thought it might
Calendar Square and you void that the particular discrepancy or difficulty thet
arose there only happened if there were multiple stock units and did not
happen with single stock units.
A: Yes.
Q How do you know that?
A Because you cannot do a transfer — 2 transfer is movement from one
stock unit to another stock unit. ‘That is what that function does.
2 low do you know that the error only ooeur in those circumstances?
A ‘The error does not, but the error that gave you a loss (inaudible) 1 ann!
e100 per cent sue, but I am just about certain that all the cases TBST So=t
oe ee Pesuber of years where this has happened, it has only been in tos!
westicular situation where they were able to do # transfer in C8, i
Pati have boon allowed, that actually resulted in both the receipts and
payments mismatch and a (inaudible).
Q: You talked about how it would be reflected in the events log.
46
WordWave International, a Merrill ‘Communications Company
LCAS0000252_109
LCAS0000252_1 09”