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FUJ00122334
Filed on behalf of the: Claimant
Witness: Andrew Paul
Dunks
Statement: 1
Exhibits: "API"
Date made: 27/9/06
IN THE HIGH COURT OF JUSTICE Claim No. HQO5X02706
QUEENS BENCH DIVISION
BETWEEN:
POST OFFICE LIMITED Claimant/Part 20
Defendant
- and -
LEE CASTLETON Defendant/Part
20 Claimant
WITNESS STATEMENT OF ANDREW PAUL DUNKS
I, ANDREW PAUL DUNKS of Fujitsu Services, Lovelace Road, Bracknell, Berkshire,
RG12 8SN WILL SAY AS FOLLOWS:
1. Ihave been employed by Fujitsu Services (Fujitsu), Post Office Account, since 11
March 2002 as an IT Security Analyst where I am involved in IT Security for the
Post Office Account. I am authorised by Fujitsu to undertake extractions of audit
data held on the Horizon system and to obtain information regarding system
transaction information processed on the Horizon system.
2. I make this Witness Statement from facts within my own knowledge unless
otherwise stated. References to page numbers in this Witness Statement are to
page numbers of Exhibit “AD1” to this Witness Statement. Any records to which I
refer in my statement form part of the records relating to the business of Fujitsu.
These were compiled during the ordinary course of business from information
supplied by persons who have or may reasonably be supposed to have personal
knowledge of the matter dealt with in the information supplied, but are unlikely to
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have any recollection of the information or cannot be traced, since the nature of
the helpdesk involves many engineers all at differing levels and any number could
be involved in a particular call. As part of my duties, I have access to these
records, but I was not involved with any of the technical aspects of these calls.
This area is not my particular area of expertise and I make this witness statement
simply to help clarify the call logs for the benefit of the Court.
3. An important element of the support provided to subpostmasters and Counter
Clerks is the Horizon System Helpdesk (HSH). The HSH is the Horizon user’s first
‘port of call’ in the event of their experiencing a problem with the Horizon system
or requiring advice and guidance. If the system were to malfunction, upon
discovery the Horizon users (i.e. the sub-postmaster or counter clerk) would raise
a call to the HSH seeking clarification or advice. HSH is a service run by Fujitsu
Services for the Post Office. I have been asked to provide details and information
on the calls for advice and guidance logged by HSH recorded during the period 1
December 2003 to 23 April 2004 for the 14 Marine Drive South, Bridlington Post
Office - FAD (Financial Accounting Division) Code 213337 (the Marine Drive
branch)
4. I have reviewed the HSH calls pertaining to the Marine Drive branch and during
the period 1 December 2003 to 23 April 2004 there were 23 calls from the Marine
Drive branch to HSH (5 of which occurred after 23 March 2004 when I am
informed that Mr Castleton was suspended). Details and an overview of the calls
are given in date order below:
HSH Call Logs
5. 9 December 2003, 9.54am, call reference e-0312090261 (page 1) The sub-
postmaster had a power blip following which, the keyboard was not accepting the
PMMC card, which is used by sub-postmasters to log onto their terminal. The Post
Master was advised to reboot his terminal. He rebooted, inserted his PMMC/pin
and was happy to continue. The call was then closed.
6. 20 January 2004, 2.05pm, call reference e-0401200574 (pages 2 to 3) -
this is a log simply to record that there was an upgrade to the network line
connection from dialup (Integrated Services Digital Network (ISDN)) to a
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broadband connection (Asymmetric Digital Subscriber Line (ADSL)). This was a
scheduled visit to the Marine Drive branch to install broadband. The upgrade was
completed, but the broadband was not turned on at that time.
7. 28 January 2004, 11.13am, call reference e-0401280325 (page 4) - the call
was taken by Dane Meah at HSH from the caller who stated that there were
discrepancies going through the system for three weeks in a row. The caller was
advised that the problem would need to be thoroughly investigated by the
National Business Support Centre (NBSC) before the issue could be investigated
as a software problem and the caller was transferred to the NBSC and the call
closed.
8. 29 January 2004, 10.26am, call reference e-0401290358 (page 5) - a call
was taken by Mary Rainbow at HSH. The sub-postmaster reported that he was
having problems on his system connected to remittances (REMs). The Sub-
postmaster has to enter a remittance when he receives a delivery of new stock.
He stated that every time he entered in the new stock, it left him with a
discrepancy. The Sub Post master was transferred to the NBSC, since this was a
business issue and the call was closed.
9. 2 February 2004, 8.49am, call reference e-0402020111 (pages 6 to 7) -
Ben Horseman at HSH took a call from Cath at NBSC who stated that terminal
(node) 2 had failed to initialise and that he also has “operational integrity violation
has been detected” and “unable to connect to the repost service”. The sub-
postmaster was advised that he would be called back whilst the counter is
reviewed. Both counters had been upgraded with ADSL (Broadband). During the
night it is sometimes required that some of the services on the counters are
stopped and restarted, in this case it was unable to reconnect to the Repost
service after it was stopped. The Sub-postmaster called back at 9.18am and was
advised to reboot, which did not fix the problem. It was recommended that an
engineer swap or adjust the base unit on terminal 2. An engineer was sent out to
sort out the base unit. The engineer arrived on site at 1.30pm, replaced the node
and the call was closed.
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10.
11.
12.
13.
14.
13 February 2004, 10.41am, call reference e-0402130261 (page 8) - call
was taken by John Lockyear at HSH. The sub-postmaster had stated that he had
a rem issue and this was referred to NBSC. The call was then closed.
13 February 2004, 10.46am, call reference e-0402130267 (pages 9 to 10)
- this call was taken by Tony Law at HSH, referred from Marie at NBSC. The sub-
postmaster had stated that his system was doubling up cash declarations and
cutting off cheques, yet they still apparently appeared the next day. NBSC
advised that they had checked that he was cutting everything off properly and
that the catch figures were being done correctly. The sub-postmaster had
insisted on a system check being carried out. He said that the problem had been
happening for five weeks and that every time stock had been remmed in, they
had a loss that night. The sub-postmaster also stated that the cheques he had
recorded on the 10'» were showing on the 11" February as well.
The call was escalated to Heather Dryden at HSH. As a sub-postmaster is
supposed to send cheques to the EDS Processing Centre each evening, the next
day you would expect to see the cheque figures cleared to zero on the Horizon
system. The sub-postmaster, initially stated that this had happened more than
once, but when Heather went through his cheques, it had happened just the once.
It appears that the sub-postmaster forgot to cut off and the cheque listing had
two days worth of cheques in it. There is no option to cut off retrospectively ie if
the sub-postmaster reveals that he has not cut off the previous days cheques,
they will show up the next day and a failure to cut off previously cannot be
corrected later. However, the point is that the system will not put the cheques in
the balance and process them twice. It will reconcile each cheque against the
transaction.
16 February 2004, 8.32am, call reference e-0402160081 (page 11) - David
Lawrence at HSH took a call from Marie at NBSC. The sub-postmaster had called
NBSC to state that both his terminals were at Post Office Log On (POLO), but
were rebooting ok subsequently. The call was therefore closed.
16 February 2004, 11.12am, call reference e-0402160628 (page 12) - Tony
Law took a call from Pat at NBSC. The sub-postmaster had stated that he needed
an OBCS check. This is the bar code reader that each sub-postmaster has at their
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15.
terminal and was used for pension books. If the Pension book is not local to that
Post Office branch then a check is requested to ascertain if the book has been
stopped i.e whether they can pay out on that pension book. The OBCS was
checked and the results given. The call was then closed.
25 February 2004, 11.03am, call reference e-0402250454 (pages 13 and
14) - A call was taken by Mary Rainbow. The clerk reported that they had been
having problems on the system with balancing that week, which seemed to be
related to stock being remmed in through the week. The clerk reported that over
the past 7 weeks, they have had losses every week and at one point they had a
problem with cash on hand, but they found that this was an issue with ID
numbers that had been resolved. The clerk also reported that last week when
they rolled over they put a loss into the suspense account and then took the
computer terminal back to the trial balance which came out with a zero net
discrepancy to start the new week with. The clerk reported that she had printed
out a balance snapshot on Monday and that looked OK, but since then they had
remmed in some stock which appears to have given them a loss.
16. The clerk was advised that she would need to check her stock position for last
17.
week and then check her rems in summary. This would show the stock that she
should be holding and that figure could be compared with the stock showing in
the adjust stock (Stock Check) and this would highlight any problems with the
stock on hand. The clerk was advised that we would need her to take her
computer terminal to trial balance this evening and come back to us before she
rolls over so that we can take down any details she can give us. The clerk
confirmed that they are working on a shared stock unit and would call back if
further assistance was required. The balance sheet would show the old
discrepancy until they can do a trial balance. The call was then closed.
25 February 2004, 12.03pm, call reference e-0402250553 (page 15) - the
call log states that the call was taken by Robert Congerton. The clerk had told the
NBSC she had problems regarding the balance. The NBSC were advised that HSH
had told the PM to call back tonight when they had a net discrepancy on the cash
account. The call was then closed.
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18. 25 February 2004, 12.12pm, call reference e-0402250565 (page 16) - Call
was taken by Nicola Goodson at HSH. Jane at the NBSC had a call in relation toa
call that had been closed.
19. 25 February 2004, 4.56pm, call reference e-0402251011 (pages 17 to 18) -
Call was taken by Niall Vincent, because a critical event was seen stating “error
message. An error has occurred = see the audit log”. This call was not generated
by the sub-postmaster calling the help desk, but by the System Management
Centre (SMC) which automatically triggers a call when there is an unusual event.
The call was referred to the System Support Centre (SSC), so the SMC closed
their call. The term critical is the comparative level of attention required to
generate remedial action. It refers to the level of attention required on a grading
system for example critical high level of attention or warning would be medium
level of attention.
20. 25 February 2004, 5.33pm, call reference e-0402251077 (pages 19 to 20) -
21.
Call was taken by Kuljinder Bhachu at HSH. The sub-postmaster reported that
the branch was getting large discrepancies for the past few weeks. The closed
calls were reviewed and it was noted that a number of calls had been logged
regarding discrepancies and that the NBSC had been in contact with the sub-
postmaster could not find any user error. Kuljinder spoke to Sandra at NBSC.
They checked the Tivoli events and the system appeared to be OK. Given that a
critical event had been noted earlier that day, the event logs were downloaded for
review. The sub-postmaster advised that the problem had started ever since the
BT engineer came to move the BT box for preparation for the installation of the
ADSL. Kuljinder recommended that SSC investigate why the sub-postmaster is
experiencing large discrepancies. A known error log (KEL) reference was given
and the problem was re-assigned within HSH to group EDSC1 (European
Development and Support Centre) which is the helpdesk group name for the SSC
and call PC0099954 was logged to enable them to look at the call. At this point
Anne Chambers of SSC investigated the matter. She found that there was no
evidence whatsoever of any system problem.
4 March 2004, 8.42am, call reference e-0403040165 (page 21) - A call was
taken by Hayley Minnis, a HSH retail line manager. The caller reported
discrepancies in the office and was advised to speak to NBSC about this, since it
was not a HSH issue. The call was then closed.
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22.
23.
24,
25.
26.
27.
4 March 2004, 11.28am, call reference e-0403040524 (page 22) - A call was
taken by Elspeth Neilson. The sub-postmaster’s line manager stated that the sub-
postmaster was getting large discrepancies. They were advised that the
discrepancies are caused by the difference between the transactions they have
recorded on the system and the cash they have declared and are not being
caused by the software or hardware. The call was then closed.
23 March 2004, 11.44pm, call reference e-0403230583 (page 23) - Call
was taken by Jacqueline Wilcock at HSH. The auditor wanted to know when the
base unit had been exchanged at the Marine Drive branch. They were advised
that it was exchanged on 2 February 2004. The call was then closed.
23 March 2004, 2.20pm, call reference e-0403230628 (page 24) - Call was
taken by David Dawe at HSH. Brett from the NBSC asked for a One Shot
Password (OSP) for the auditor. An OSP is issued so that the auditor can log on
to the sub-postmaster’s system. An OSP was given and the call was closed.
1 April 2004, 12.45pm, call reference e-0404010718 (page 25) - A call was
taken by Adam Goldstein at HSH. The new sub-postmaster stated that the screen
had frozen. A check of the events log for this counter was carried out which
showed there to be no faults and the sub-postmaster was advised to reboot. The
call was then closed.
19 April 2004, 9.57am, call reference e-0404190387 (page 26) - A call was
taken by Elspeth Neilson at HSH. The Retail Line Manager (RLM) stated that
there had been discrepancies on the system since the base unit was swapped in
February and wanted to know why. The RLM was advised that events appeared to
be normal and that a health check had been passed. The sub-postmaster was
happy to continue unassisted. The RLM stated that the new sub-postmaster had
been in the office and there had not been any discrepancies in the balance. The
RLM was advised to contact NBSC for advice on balancing. The call was closed.
21 April 2004, 9.10am, call reference e-0404210187 (page 27) - A call was
taken by David Dawe. The sub-postmaster stated that the gateway was saying to
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28.
29.
enter the PMMC and that the screen had been blue for 10 minutes. The sub-
postmaster had to wait for the screen to clear. The sub-postmaster was told to
wait for 20 minutes as that screen was normal and the sub-postmaster was told
to call back if this had not changed within the next 20 minutes. The call was then
closed.
21 April 2004, 1.32pm, call reference e-0404210701 (pages 28 to 29) - A
call was taken from Bernard Michael at SMC. This was an SMC call and related to
a software upgrade. It was when ADSL (broadband), that had been installed in
20 January 2004, was actually switched on. The call was then closed once the
switch over to ADSL had been successful.
23 April 2004, 3pm, call reference e-0404230660 (page 30) - A call was
taken by Jason Lockyear. The sub-postmaster wanted to know if he could get a
list of his calls and of software. The sub-postmaster was advised to contact NBSC
for a full list and the call was then closed,
I believe that the facts stated in this witness statement are true.
SIQNEW 0... ceesseeceeeeeee
Date
1A_121
ANDREW PAUL DUNKS
109986_2
FUJ00122334
FUJ00122334
FUJ00122334
FUJ00122334
Claim No. HQO5X02706
IN THE HIGH COURT OF JUSTICE
QUEENS BENCH DIVISION
BETWEEN:
POST OFFICE LIMITED Claimant/Part 20
Defendant
- and -
LEE CASTLETON Defendant/Part 20
Claimant
WITNESS STATEMENT OF ANDREW
PAUL DUNKS
BOND PEARCE LLP
Ballard House
West Hoe Road
Pl mouth PL1 3AE
“BX 8257 Plymouth
Ref: SID3.348035.134
Solicitors for the Claimant/Part 20
Defendant
1A_1209986_2
Filed on behalf of the Claimant
Witness AP Dunks
Statement: 1
Exhibits: "ADI"
Date made: 27/9/06
IN THE HIGH COURT OF JUSTICE Claim No.
QUEENS BENCH DIVISION
BETWEEN:
POST OFFICE LIMITED Claimant/Part 20
Defendant
- and -
LEE CASTLETON Defendant/Part
20 Claimant
EXHIBIT "APD1"
This is the Exhibit marked “AD1” referred to in the Witness Statement of Andrew Paul
Dunks dated September 2006.
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