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To: ‘Jonathan Gribbe!
Ce: Defence Legal (Chris Ja
From: Godeseth, Torstein[/o=Fujitsu Exchange Organization/ou=Exchange Administrative Group
(FYDIBOHF23SPDLT )/cn=Recipients/cn=73367 f867463422895a4 1 1e49bd]
Sent: Fri 7/13/2018 3:11:49 PM (UTC)
Subject: RE: Dr Worden's Foundations Report [WBDUK-AC.FID27032497]
gij.Quantitative Approach to Horizon Bugs Final.docx
gij. DOC _150212853(1) Foundation Report v1tg.docx
IMPORTANT - This email or attached documents contains legal advice (or relates to litigation or anticipated litigation) and is being provided in circumstances for which
Legal Privilege may be claimed. Do not copy or forward this document without permission
Gareth and I have looked through the two documents and have added in comments.
I look forward to the session that Dave Ibbett is setting up for us to discuss further.
Regards etc
Torstein
From: Jonathan Gribben
Sent: Wednesday, July 4, 2018 8:52 AM
To: Newsome, Pete {_
Cc: Defence Legal (Chris Jay,
ob Godeseth, Torstein r
ir Worden's Foundations Report [WBDUK-AC.FID27032497]
Pete,
Privileged & Confidential — please do not forward other than to Gareth Jenkins
Further to my email below, Robert is very keen to get some feedback on his report which sets out some of the key lines of argument
that he intends to use in his expert's report as part of the Group Litigation (Foundations Report) and his short note summarising
two quantitative approaches to the core issue of the Horizon trial (i.e. have Subpostmasters been held liable for losses caused by
bugs in Horizon) that he has identified (Quantitative Approach). Both documents are attached.
Are Torstein and Gareth able to review the documents and provide some feedback early next week? The feedback can be in
writing or in a conference call.
Please feel free to give me a call if there is anything you'd like to discuss — I'm o1
Kind regards
Jonny
Jonathan Gribben
Managing Associate
Womble Bond Dickinson (UK) LLP.
e: jonathan aribben
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From: Jonathan Gribben t
Sent: 14 June 2018 19:29
To: Legal.Defencef” RO "~~~" pete.newsome:
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Cc: Mark Underwood1; Catherine Hamilton; Rodric Williams; Andrew Parsons
Subject: Update following 5 June CMC [WBDUK-AC.FID27032497]
Chris, Pete,
Privileged & Confidential — please do not forward
The purpose of this email is to update you following the CMC on 5 June. An unsealed copy of the Order is attached. The key
points that Post Office would like Fujitsu's assistance with are set out in the table below, with a note on their current status.
Order
Current Status
Post Office to use reasonable endeavours to arrange for the
parties' IT experts to be given two days access to inspect the
Peak and TFS systems at Bracknell.
Pete Newsome is currently arranging this.
Pete's view is that the inspection is likely to take one day only
and he would prefer not to tie up resource for two days. Pete's
preference is to offer one day initially with an agreement to
provide another day if required.
By 4pm on 26 June the parties’ IT experts are to produce a list
of error codes used in the Known Error Log and/or in the Peak
System or equivalent (Error Codes List) so that Fujitsu can
provide descriptions of what those error codes mean.
This flows from the fact that Fujitsu does not keep a list of error
codes.
By 4pm on 26 June the parties’ IT experts must compile a list of
information that either one or both of them considers they
require in order properly to opine on the Horizon Issues.
The Order does not provide for what is to be done with this list,
but Post Office has already agreed to use reasonable and
proportionate endeavours to provide some document references
and information to the Claimants' expert - Pete Newsome is
overseeing this.
The key dates are: (1) document references to be provided by
4pm on 17 July; and (2) information to be provided by 4pm on
14 August. However, from a tactical perspective it will assist
Post Office to provide the references and information in
tranches periodically (e.g. once a week). That should also
assist with the management of the exercise.
By 4pm on 14 September 2018 each party shall file and serve
witness statements of any witness of fact whose generic
evidence (in distinction to Claimant-specific evidence) they wish
to rely upon for the purposes of determining the Horizon Issues.
Post Office also has the right to serve responsive witness
evidence by 4pm on 16 October.
No decision has been made on the identity of Post Office's
witnesses, but it is likely that Post Office will request factual
evidence from a Fujitsu employee or employees.
As you will see from this table there is a lot going on at the moment and we anticipate that Mr Coyne will make further information
requests as he prepares his report, which is due on 28 September. Post Office's expert (Robert Worden) may also make some
requests, although they will be fewer (if any) and more focused.
There is also another round of disclosure underway that we have asked for your help with - Amy Prime has already contacted Pete
and Matthew about that.
In addition, Dr Worden has produced a report which sets out some of the key lines of argument that he intends to use in his expert's
report which focuses on the functionality, business uses and architecture of accounting systems, the checks built into such systems,
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the business applications in Horizon and the architecture of the original Horizon system and HNG (Foundations Report). The
Foundations Report is not written for the Court, but large parts of it will be used in Robert's expert's report. He and Post Office
would like Fujitsu to provide comments on it from a technical perspective and we think that is best done by Torstein and Gareth.
We'd appreciate your thoughts on that. Please note that the Foundations Report is privileged and, therefore, once we send it to you
please do not forward it to anyone without our prior written agreement.
Andy has already had a conversation with Garry Stewart about additional resources and it might be useful for us to set up a meeting
in London or Bracknell to discuss this and the above in more detail with you both and Garry. Please let me know if you think that
this would be useful and, if so, when you're free during the weeks commencing 25 June and 2 July. In the meantime, I have spoken
to Pete and he is going to check Gareth Jenkins' availability to assist for one or two days per week.
Please feel free to give me a call if there is anything you'd like to discuss
Kind regards
Jonny
Jonathan Gribben
Managing Associate
Womble Bond Dickinson (UK) LLP
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