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From: Harvey Michael[/O=EXCHANGE/OU=ADMINGROUP1/CN=RECIPIENTS/CN=HARVEYM]
Sent: Fri 22/11/2013 4:32:19 PM (UTC)
To: Rodric Williams[i
Ce: Davidson JamesI _d; Newsome
Pet
Subject: I RE: Expert on the Horizon ‘System - Subject to Common Interest Privilege
Attachment: Horizon Integrity Independent expert TOR vO 3 mh.docx
Rodric,
Great, shall we say 10.30am at our Lon22 offices (22 Baker Street), James and Pete will be attending too. If you can
let me know who will be attending so I can notify reception. Should you want to meet at 148 instead then please let
me know.
In addition, as promised, please find attached Fujitsu’s view of the basis on which to instruct an expert to assist with
the Mediation process. You will note that it aligns with the postion previously agreed regarding the KPMG audit
which was later subsumed by the Second Sight process.
In addition, it will be Fujitsu’s position that we are allowing the expert to perform this audit solely for the purposes of
facilitating the Mediation Process and therefore we will be reserving our rights with respect to the outcome the
expert’s audit, in particular the right to challenge the validity/accuracy of the expert’s opinion. I suggest we
document this as part of an agreed project initiation document to address our involvement with the Mediation
Process.
Should 10.30am be inconvenient please let me know and we can find a more convenient time.
I hope you have a pleasant weekend.
Kind regards,
Michael Harvey
From: Rodric Williams :
Sent: 22 November 2013 14:58
To: Harvey Michael
Subject: RE: Expert on the Horizon System - Subject to Common Interest Privilege
Thanks Michael — next Friday 29 November 2013 works for us.
I’m assuming we will come to you. What time are you thinking?
Kind regards, Rodric
Rodric Williams I Litigation Lawyer
@® 148 Old Street, LONDON, EC1V 9HQ
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@ Post Office stories
®© @postofficenews
From: Harvey Michael :
Sent: 21 November 20.
To: Rodric Williams
Subject: RE: Expert on the Horizon System - Subject to Common Interest Privilege
Rodric,
I would like James Davidson to attend as he will be able to act as a conduit between the technical and commercial
elements. He is part time now so only works Thursdays and Fridays, therefore ideally I would like the meeting on
either 28" or 29". Are you team available then?
Please note I have had my meeting with the legal team and will be sending our view of the expert terms of reference
tomorrow for your review ahead of our meeting.
Kind regards,
Michael
From: Rodric William: nm GRO
Sent: 20 November 2013
To: Harvey Michael
Subject: FW: Expert on the Horizon System - Subject to Common Interest Privilege
Hi Michael — any thoughts on a new date?
Kind regards, Rodric
From: Rodric Williams
Sent: 08 November 2013 15:37
To: 'Harvey Michael’
Cc: Newsome Pete; Davidson James
Subject: RE: Expert on the Horizon System - Subject to Common Interest Privilege
Hi Michael,
Unfortunately we have a problem with 21 and 22 November. Can we do the following week?
I note your point about the draft scope, and it would be helpful if you could give us a sense of the issues you have in
advance of the meeting if at all possible.
Finally, thank you for making yourself aware of what’s going on with the Mediation Scheme. Andy Holt and I should
be able to give you an update of how that is progressing when we meet.
I hope you have a productive week on your MBA!
Kind regards, Rodric
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Rodric Williams I Litigation Lawyer
i) 148 Old Street, LONDON, EC1V 9HQ
© Post Office stories
© @postofficenews
From: Harvey Michae_ GRO
Sent: 06 November 2013 16:12
To: Rodric Williams
Cc: Newsome Pete; Davidson James
Subject: RE: Expert on the Horizon System - Subject to Common Interest Privilege
Rodric,
Thank you for your email.
Unfortunately I am not available on Friday and next week I am away studying for an MBA so I am not in the office.
Therefore, unfortunately it will need to be w/c 18" that we meet. I would like James Davidson and Pete Newsome to
attend with me so could we do either 21* or 22° November?
We have/are reviewing the Expert Terms of Reference and we have some concerns regarding the tone and scope of
the terms. A representative from the Fujitsu legal team has also asked to review it and I am meeting him on 19" to
go through his views and so by having the meeting 21/22 Nov I hope to have the comprehensive Fujitsu view so we
can make best use of everyones time.
I am also aware that Fujitsu’s Pete Newsome and Post Office’s Andy Holt are in dialogue regarding the type of issue,
volume and data requirements that are relevant to Fujitsu’s input into the Mediation Process. I have engaged with
Pete to ensure that these needs are fed into me and James so that the scope of the expert’s role is put into context
within Fujitsu.
I hope either of these days work with your (and your team’s availabilities).
Kind regards,
Michael
Michael Harvey
Commercial Director
Fujitsu
22 Baker Street, London W1U 3BW
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Web: hitp://uk.fujitsu.com
hwy Please consider the environment - do you really need to print this email?
From: Rodric Williams
Sent: 06 November 2013 14:55
To: Harvey Michael
Subject: FW: Expert on the Horizon System - Subject to Common Interest Privilege
Michael,
Further to my email below, in addition to me, my colleagues Jarnail Singh (in-house criminal law solicitor) and Andy
Holt (POL IT) will attend the meeting, along with Simon Clarke from Cartwright King (our external criminal law
solicitors).
The proposed agenda is:
1. Recap of Horizon/Second Sight situation.
2. Purpose of instructing independent experts.
a. Disclosure provisions
b. Independence
c. Firewall between POL/FSL and experts.
. Role of independent experts.
. Suitability of proposed experts from Imperial.
. Scope.
. AOB.
Aunpw
It is probably a bit late for a meeting this week, but please let me know if we could still do something say on Friday, or
if not, how next week looks.
Thanks for your help, Rodric
Rodric Williams I Litigation Lawyer
(C) 148 Old Street, LONDON, EC1V 9HQ
a)
©
©
©
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®© @postofficenews
From: Rodric Williams
Sent: 27 October 2013 15:38
To: 'Harvey Michael’
Subject: RE: Expert on the Horizon System - Subject to Common Interest Privilege
Thanks Michael.
I am pulling together availability etc, and will circulate this so you can pick it up from your end when you get back to
the office w/c 4 November.
I hope you have a good week.
Kind regards, Rodric
Rodric Williams I Litigation Lawyer
© 148 Old Street, LONDON, EC1V 9HQ
@ Post Office stories
© @postofficenews
From: Harvey Michael} GRO ]
Sent: 24 October 20151216
To: Rodric Williams
Subject: RE: Expert on the Horizon System - Subject to Common Interest Privilege
Rodric,
Thank you for sending this through. I will have a chat with the team and get back to you.
1am out of the office next week so maybe we can try and arrange a meeting sometime for w/c 4°" November.
Kind regards,
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Michael
From: Rodric William:
Sent: 23 October 2013 19:17
To: Harvey Michael
Subject: Expert on the Horizon System - Subject to Common Interest Privilege
Michael,
Thank you for your time on the phone last week.
As we discussed, Post Office Limited is considering appointing an expert to prepare a report on the integrity of the
Horizon Online system. I attach the Draft Scope of the work which the expert may be asked to undertake, along with
the CVs of two potentially suitable experts, Professor Jeffrey Kramer and Dr. Naranker Dulay, both from the
Department of Computing at Imperial College London.
In order to progress this, it seems sensible to have a meeting to discuss how Fujitsu can work with Post Office Limited
to achieve the aims set out in the Draft Scope. This meeting would be attended by a member of the law firm we use
to prosecute alleged criminal conduct.
If you agree, could you please let me know when we could meet (ideally as soon as possible), and whether you think it
would be useful to have a technical person from Post Office at the meeting. I can then look to fix attendees, agenda
etc.
We also discussed the possibility of us sharing with you the advice we have received on the evidence which Gareth
Jenkins has previously provided in support of Post Office Limited criminal prosecutions. I hope to be able to provide
you with a substantive response on that request very shortly.
I look forward to hearing from you. Thanks for your support.
Kind regards, Rodric
Rodric Williams I Litigation Lawyer
® 148 Old Street, LONDON, EC1V 9HQ
Postline},
® Post Office stories
© @postofficenews
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POST OFFICE LIMITED is registered in England and Wales no 2154540. Registered Office: 148 OLD STREET,
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Unless otherwise stated, this email has been sent from Fujitsu Services Limited, from Fujitsu (FTS) Limited, or
from Fujitsu Telecommunications Europe Limited, together "Fujitsu".
This email is only for the use of its intended recipient. Its contents are subject to a duty of confidence and may
be privileged. Fujitsu does not guarantee that this email has not been intercepted and amended or that it is
virus-free.
Fujitsu Services Limited, registered in England No 96056, registered office 22 Baker Street, London W1U
3BW.
Fujitsu (FTS) Limited, registered in England No 03808613, registered office 22 Baker Street, London W1U
3BW.
PFU Imaging Solutions Europe Limited, registered in England No 1578652, registered office Hayes Park
Central, Hayes End Road, Hayes, Middlesex, UB4 8FE.
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Fujitsu Telecommunications Europe Limited, registered in England No 2548187, registered office Solihull
Parkway, Birmingham Business Park, Birmingham, B37 7YU.
This email and any attachments are confidential and intended for the addressee only. If you are not the named
recipient, you must not use, disclose, reproduce, copy or distribute the contents of this communication. If you have
received this in error, please contact the sender by reply email and then delete this email from your system. Any views
or opinions expressed within this email are solely those of the sender, unless otherwise specifically stated.
POST OFFICE LIMITED is registered in England and Wales no 2154540. Registered Office: 148 OLD STREET,
LONDON EC1V 9HQ.
Unless otherwise stated, this email has been sent from Fujitsu Services Limited, from Fujitsu (FTS) Limited, or
from Fujitsu Telecommunications Europe Limited, together "Fujitsu".
This email is only for the use of its intended recipient. Its contents are subject to a duty of confidence and may
be privileged. Fujitsu does not guarantee that this email has not been intercepted and amended or that it is
virus-free.
Fujitsu Services Limited, registered in England No 96056, registered office 22 Baker Street, London W1U
3BW.
Fujitsu (FTS) Limited, registered in England No 03808613, registered office 22 Baker Street, London W1U
3BW.
PFU Imaging Solutions Europe Limited, registered in England No 1578652, registered office Hayes Park
Central, Hayes End Road, Hayes, Middlesex, UB4 8FE.
Fujitsu Telecommunications Europe Limited, registered in England No 2548187, registered office Solihull
Parkway, Birmingham Business Park, Birmingham, B37 7YU.
This email and any attachments are confidential and intended for the addressee only. If you are not the named
recipient, you must not use, disclose, reproduce, copy or distribute the contents of this communication. If you have
received this in error, please contact the sender by reply email and then delete this email from your system. Any views
or opinions expressed within this email are solely those of the sender, unless otherwise specifically stated.
POST OFFICE LIMITED is registered in England and Wales no 2154540. Registered Office: 148 OLD STREET,
LONDON EC1V 9HQ.
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