POL00118249 - Email chain from Jim Cruise to Keith Baines, Nicholas Samuel, Jay O’Laogun, Adele Kilcoyne cc Susanne Helliwell re Cleveleys PO Mrs J Wolstenholme

Evidence on official site

POL00118249
POL00118249

Jim Cruise To: Keith K
: Samuel.
30/01/2004 09:32 O'Laogui
Kilcoyneé

cc: susanne.helliwel..
Subject: Cleveleys PO Mrs J Wolstenholme

You have previously had some involvement with this case in which losses at the above spo are being
blamed by the former spm on the Horizon computer system being faulty and causing the losses.

The case is before Blackpool County Court and a computer expert, Best Practice Group ple, is the
expert witness and they have produced an opinion which concludes that the system was defective and
the majority of errors noted in the fault logs could not be attributed to being Mrs W.’s fault. This is
clearly unhelpful to POL’s case.

Who would be the best person to see the opinion and comment on it please. Would it need to be
referred to Fujitsu itself? It may be that we can take up with the expert witness some of the matters
referred to in the report and clarify them or even persuade them that they are wrong - if this is possible.
POL00118249
POL00118249

ROYAL MAIL GROUP plc igoo1

02/02 ‘04 09:58 FAX

* Opinion ~
._ Re: Post Office Counters Ltd. —v- Mrs Julie Wolstenholme: Claim Number CR101947

T have been contacted by Weightman Vizards a law firm representing ‘Post Office Counters
LTD’ and Mrs Julie Wolstenholme, an individual, and requested to make i jal observations
that would be of value to the court in the matter of “Post Office Counters Ltd -v- Mrs Jutie
Wolstenholme” In the Blackpool County Court, Claim number CR101947,

My initial opinion, prior to examination of call logs provided, was that it would be difficult to
establish if the level and type of support calls made by Mrs Wolstenholme were ‘reasonable’ or
otherwise without having access to levels and type of support calls made by a comparable post
office branch. It was explained to me that this direct comparison was not possible, due to such
logs not being available and as a consequence I have been instructed to conduct a more
detailed review of the material already available.

In light of the above I do not consider that I am required at this stage to produce a full expert
witness report as such, and have therefore set out my initial opinions in the format below.

. This more detailed examination focused an the following documents provided to.me:-

Claim form dated 19 April 2001 and amended Particulars of Claim dated 17 February 2003.
Amended Defence and Counterclaim dated 14 Apri! 2003

Reply and Defence to Counterclaim

Order dated 6 October 2003

Claimant’s List of Documents

Defendant's List of Documents

Claimant's witness statement

Defendant's witness statement

Additional set of call logs disclosed by the Claimant to the Defendant.

My observations considering the documents are as follows:

The statement from Ms Elaine Tagg, the retail network manager of the Post Office Ltd, at para
11 stated that:

"Mrs Wolstenholme persisted in telephoning the Horizon System Help Desk in relation to
any problems which she had with the system generally, these problems related to the
use and general operation of the system and were not technical problems relating to
the system,”

This, in my opinion is not a true representation on the evidence that I have had access to. Of
the 90 or So fault logs that I have reviewed, 63 of these are without doubt system related
failures. Only 13 could be considered as Mrs Wolstenholme calling the wrong support help desk
requesting answers to “How do I ..?” type training questions.

The majority of the system issues were screen locks, freezes, and blue screen errors which are
clearly not a fault of Mrs Wolstenholme’s making, but most probably due to faulty computer
hardware software, interfaces or power. In fact, on a detailed view of call 11021413, dated 2
November 2000, Ms Tagg may have witnessed first hand the style of system problems that
Mrs Wolstenholme experienced in her operation of the system. This fault log notes that:
“Elaine reports that one of the counters has a blue screen with the message STOP 0x000000a”
and was advised by the operator to “reboot”.

Although not uncommon in my experience of support helpdesk’s, I find it disconcerting that
the helpdesk’s first line support consistently advised Mrs Wolstenholme to “reboot” the system
(ie. switch the equipment off and back on again), without trying to understand the cause of the
error. It can be noted that a re-boot was advised in 47 out of the 63 occasions where system
errors were logged. This instruction treats the effect and not the cause, leaving the actual fault
which caused the error intact, and with it a recurrence seems inevitable.

Best Practice Group rc

02/02 '04 09:58 TX/RX NO. 3432 Poi
POL00118249

POL00118249
. 02/02 '04 09:58 FAX: ROYAL MAIL GROUP plc @ooz

“Opinion

~The types of faults,-as reported in the faults logs were:-

“System Freezing” which is most probably due to either the hardware or interfaces crashing; or
alternatively fully saturated communication lines,

“System Halts displaying...” or “Blue Screen” which are almost certainly hardware faults.

It seems that each time that the system halted, the screen would display an error code. From
this error code, it would have been possible for the helpdesk operatives to establish the detail
of these hardware faults, However, it seems that this type of analysis was not undertaken by
the helpdesk with a simple re-boot being the preferred method of dealing with the issue.

That said, on a number of occasions, certain elements of counter equipment were indeed
exchanged but without any real improvement in the situation until around the end of June
2000.

The number of fault logs reduces after the end of June 2000, this could be due to the system

. faults reducing in frequency i.e. being fixed, or simply-that Mrs Wolstenholme-tired of .the~
support department telling her to reboot the system (an activity which she could do herself). I
have no information to form an opinion either way.

It is interesting and certainly warrants further examination that in November 2000 the ‘system
freezing’ 's reported again with the support operator stating: “They all freeze, but if it gets bad
give us a call and we will investigate” (11084054 dated 8 November 2000]

From the 31° of October (starting at call log number 10253234) there seems to be a number
of logs which talk of ‘large discrepancies’ in stock figures, trial balances with “all sorts of
figures showing minus figures” [Call Log 10311359].

Referenced in call log 11012223 there is a comment noted by the support operative that the
“pm advised that this is an intermittent problem occurring since the counters were upgraded
on 23.10”, Although the documents do not list an upgrade taking place, it does seem that
these “large” reported discrepancies occur very frequently and shortly after this noted
upgrade. Again this should be investigated further as another six system errors were noted in”
November which seem to be a resurgence of the earlier, pre-July type errors,

Best Practice Group PLC 4

02/02 '04 09:58 TX/RX NO. 3432 P02
POL00118249
POL00118249

02/02 '04 09:59 FAX ROYAL MAIL GROUP plc @oo3

- Opinion

“In Summary:-

From a computer system installation perspective it Is my opinion that the technology installed
at the Cleveleys sub-post office was clearly defective in elements of its hardware, software or
interfaces. The majority of the errors as noted in the fault logs could not be attributed to being
of Mrs Wolstenholme’s making or operation of the system.

‘The helpdesk operated by the Post Office would seem to be more focused on ‘closing calls’
than attempting to get to the bottom of the continual recurrence. The Instruction to ‘re-boot’
would allow a call to be closed as the postmaster could continue to work once the system had
powered back up.

Without further examination, it is unclear whether the reduction of calls logged between July
and late October 2000 is attributable to a period of comparative system stability or merely
user disillusionment with the helpdesk. What is more clear is that from late October
recurrences of faults, which had been the subject of earlier logged calls, are reported once
again along with worrying ‘discrepancies’ In audits. This may, or may not be to do with an
- ‘upgrade’ of the counters which-seems ta have occurred.on-.or around-the-23 November 2000, ---- -
or may simply be an unconnected recurrence of the earlier faults.

Jason Coyne
20 January 2004

Best Practice Group PLC @

02/02 '04 09:58 TX/RX NO. 3432 P03
woos
POL00118249
POL00118249

02/02 ‘04 09:59

ROYAL MAIL GROUP plc

‘CPR35 Statement and CV

I confirm that I have made clear in my report those facts that are within my own knowledge
and which I believe to be true, and that the opinions I have expressed represent my tryg gnd
complete professional opinion. .

I have no known connection with any of the parties, witnesses or advisers involved in thig
case. . a)

Under the requirements of the Civil Procedure Rules 1999, as amended in January 2002 1

confirm that I fully understand my duty to the court and I have complied and will continue fo

comply with that duty. 7"

My business address is:

Best Practice Group PLC

106 Baker St

London . _. woo. _. . . __
“7 W1U 6TW" ve — ~ oe . ”

Law Society 2003 Accredited Expert Witness No. 229.

Iam a troubleshooting specialist in computer system procurement, implementation, design,

Infrastructure, hardware configuration and software development. My experience over the last

15 years is as follows: -

Hardware/infrastructure/operating systems:

Novell;

Windows NT, 3x, 95, 98, 2000,2003, ME, XP;

Unix (most variants), Solaris, Xenix, AIX, VMS;

IBM AS400, RS6000, Sun, Amdahl, DEC (now Compaq), Hewlett Packard and most PC based
equipment;

3COM, Cisco, Aircom;

Ethernet, Token Ring, SNA, CATS and various Fibre Optic configurations.
Server Centric Computing

Internet communications, MPLS, VoIP and VPN

Software development:

Languages - Dataflex, Powerflex, Oracle Forms, Delphi (Pascal), Visual Basic, Foxpro, Dbase,
Access, Informix and Progress;

Databases — Oracle, Informix, Sybase, Sequel, Dbase, Powerflex and Dataflex.
Application Systems design in Manufacturing, Distribution, Mail Order, CRM and Point of sale.
My experience spans the management of around 400 core business installations, of which

approximately 170 were described as failing prior to my engagement. My instructions are often
to provide advice to steer projects to completion

Best Practice Group PLC ¢

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