INQ00002021 - SSL0000104 version 2 - Conf Call with SC, Al and IRH re Paula briefing, as reviewed by Susan Crichton and Alwen Lyons (agreed corrections in green, disagreed in red)

Evidence on official site

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Conf Call with SC, Al and IRH re Paula briefing

SUSAN: ... had a chat with Paula earlier on and we had
a couple of chats this morning, Ron and Ian, and

then separately I've had chats with Alwen so I just
thought we should probably come back together and

try and to see if we can move this forward.

So Paula agrees that the original scope of the

investigation did not go as far as looking at

whether -- it was the miscarriage of justice point,
Ron and Ian. So that's -- that's not what she's
looking for. She's just -- she's looking for the
systematic -- or systemic, rather, not

systematic -- systemic weakness in the Horizon
System, but not -- as I said, didn't go on to that

next point around whether or not it's caused

a miscarriage of justice or a suspension of

a subpostmaster, because I think that's -- once you
have found it, then it's up for us to look for and see

what impact it might be if that happens.

RON WARMINGTON: Yeah.

SUSAN: Is that okay?

IAN HENDERSON: That makes a lot of sense.

SUSAN: Right. So that's the first thing.
The second thing, and Paula and I did get --
talk ourselves round in a complete circle on this,
despite me desperately trying to turn it into
a square, I think -- so two things, right, and this
is what I'd like us to focus on on this call.

Firstly, she's obviously got a call with James
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tomorrow at 10.30. I don't think either of us
actually know where James is. I think the one
thing that's probably come out of the conversation,
more so with Second Sight than anybody else, but
Alwen you can say whether it's -- from Janet as
well -- the need to somehow have a plan to close
down this process. I mean, even to the extent of

stopping MPs sending cases in now --

ALWEN LYONS: Yes.

SUSAN: So it's how do we close down the MPs' side of
the process and what would work for MPs and what
could we sell to MPs and how quickly can we do that
and what does that look like, in terms of both the
work you and Second Sight need to do and the

outcomes, and then --

IAN HENDERSON: Susan, sorry to interrupt but the other
element of that is what I might call work in

progress items where subpostmasters or former
subpostmasters have claimed that they've referred
cases to their MP but that MP has not yet forwarded
it to James' office and therefore we don't know

about it.

SUSAN: Yeah, so I think we almost need a sort of
policy which says: look, if they have not forwarded
it to the office, then obviously it can go through
the standard Post Office system; what it can't do is

go through the Second Sight system.

RON WARMINGTON: Yes.
ALWEN LYONS: Do we have any idea how many we're talking

about?

RON WARMINGTON: I think it's five new ones. So I put

that in an email yesterday. Let me just haul it

up.
There were -- Alan advised us of seven names,
I think, and two of them have just come in -- did

actually come in, they are the ones we were talking
about -- having just -- one was McQuillan and then
there's another one, Gail Ward, but there were five
other names on that list that we didn't know anything

about.

IAN HENDERSON: But a related element to that, of
course, is cases that have come in where we've just

got, you know, no submissions and no information.

SUSAN: So they were going to be my next, sort of,
tranche, is -- I think one thing that Paula needs
to explain to James is that we can't - sorry, do you mean

no information from them?

IAN HENDERSON: Yes.

SUSAN: We have no information because you've asked us.
RON WARMINGTON: We've got both situations. We've also
got the Seema Misra case where I can't get hold of
her, despite -- no matter how I try to get hold of

her.

SUSAN: Well ...

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ALWEN LYONS: So we've got cases where the MP has said,

"I've got a case" --

RON WARMINGTON: Yep.

ALWEN LYONS: -- but then we can get no evidence; is that

right?

SUSAN: Yes. Either from the subpostmaster or from us.

RON WARMINGTON: Not quite correct. We haven't gone
back to the subpostmasters to say, "You haven't
submitted anything of any quality or anything at
all other than, at kind of best, a handwritten
note," you know, to -- "do submit more." And the
reason we haven't done that is because we said we
would not make those approaches until we'd looked

at the documentation from the Post Office.

IAN HENDERSON: But, Ron, you are muddling various sort
of categories. What we did say to Janet -- we gave
Janet some months ago, as in February, the
specification agreed with the JFSA, which we regard
as the minimum necessary to, sort of, enter the

process. In other words --

RON WARMINGTON: Yep.

IAN HENDERSON: -- clearly set out, sort of, Statement

of Claim and, you know, what the issues are and so on.

RON WARMINGTON: Yep.

IAN HENDERSON: Janet agreed that, you know, she would
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ensure that MPs and SPMRs delivered that as their

input to the process.

RON WARMINGTON: Right. I've seen no evidence that that

has happened.

IAN HENDERSON: Yeah, we've not reached that standard in

a significant number of cases.

RON WARMINGTON: I don't think we've received it in any

case.

ALWEN LYONS: How many?

RON WARMINGTON: I don't think we received that in
any -- we haven't had any cases that have got --
where they've submitted documentation.

Well, perhaps Lee Castleton has submitted a huge
heap of data but it's -- there's no sort of
Statement of Case. It's just a kind of heap of
stuff. The only one that's articulated anything

sensibly is Alan, Alan Bates.

IAN HENDERSON: But, Ron, you came up with a number this

morning that was -- was it 17 or something? --

where we have in essence got virtually nothing.

RON WARMINGTON: Yes.

ALWEN LYONS: 17 out of 29?

RON WARMINGTON: I think it's 15 actually. 15 out of 29

where we've got effectively nothing.

Pardon?
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SUSAN: Have you got -- have you got the list of those

cases, the actual names?

RON WARMINGTON: Yep. Yeah, we've -- I'll send a fresh
version of the spreadsheet that we've sent to Simon

that's got that summary in it.

IAN HENDERSON: Ron, don't send the spreadsheet. It's
easier to deal with an email. You know, list the

people in an email.

RON WARMINGTON: All right, okay.

ALWEN LYONS: So we're saying that you would have liked to
have carried on that investigation but you were

unable to do so because there isn't enough

evidence. Is that what we're saying?

If I say this to James -- or Paula says this to

James tomorrow, it has to be factual, doesn't it?

RON WARMINGTON: I wouldn't say we'd like to. We --

we're as committed to --

ALWEN LYONS: You're unable to.

RON WARMINGTON: Yeah, we're as committed to wrapping

this up as you are.

ALWEN LYONS: Yeah, yeah.

RON WARMINGTON: Yeah, so we have been unable to, yeah.

SUSAN: I should have started off by saying I think we have
an aligned interest.

RON WARMINGTON: Yeah, good.

ALWEN LYONS: Yes. Yes, absolutely.

SUSAN: Sorry, Ron, I shouldn't have interrupted you.

RON WARMINGTON: No, all right. I will send -- getting

back to it again, I will send a list of names of

those where we've -- I'll give you a little summary

that says where we've received nothing at all from

the SPM and where we've received nothing at all

from POL, in some cases. Tick both boxes.

SUSAN: Okay.

RON WARMINGTON: Does that worry me? Not particularly

because --

IAN HENDERSON: But, Ron, we ought to look at it from

a James sort of perspective --

SUSAN: Yeah.

IAN HENDERSON: -- and not muddy the waters by
introducing POL issues. You know, let's deal, in

this category, with cases from SPMRs, you know,

where they/their MP have not delivered, you know, what

necessary.

RON WARMINGTON: Okay. Yeah.

SUSAN: So how many do you think those are?

is

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RON WARMINGTON: 15 probably.

SUSAN: Right. So that out of the 29?

RON WARMINGTON: Yes.

SUSAN: Or out of 20?

RON WARMINGTON: Out of what is now the

had two more added.

SUSAN: Yeah, okay.
Okay, so those two added were the ones

in yesterday?

RON WARMINGTON: Yes.

SUSAN: So I think there are two policy

we need to be clear about. One is that

31, because we

that came

things, Alwen,

if claims

are now coming in, we don't believe they

should go to the Second Sight process,

expense, et cetera. We are absolutely,

because of

you know,

committed to investigate them through the POL

process.

ALWEN LYONS: Yeah.

SUSAN: And they go through our standard process, and

then we -- the response was vetted by senior

management.

ALWEN LYONS: Yeah.

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SUSAN: That's important.
Don't say "by legal", because I just think that we want
to defend ourselves, but it's (unclear)

senior management, so --

ALWEN LYONS: Yeah.

SUSAN: So the first policy is I think we need a bit of
history, because I'm really thinking about the briefing

paper for Paula here to talk --

ALWEN LYONS: Yeah, so am I.

SUSAN: So I'd like to just try to show James, we've
now got 31 cases that have come via your office,
two came only yesterday. We don't think that it's
right they should be included in the Second Sight
sample because too late. Happy -- obviously happy
to investigate them from the POL point of view, if
she can land that and say anything else that comes
in post whatever, the end of April or -- or from
today or tomorrow, doesn't go into the Second Sight

hopper.

ALWEN LYONS: Yeah.

SUSAN: Secondly, of those 29 --

ALWEN LYONS: Yeah.

SUSAN: -- 15 haven't supplied the information, so

Second Sight can't investigate them, so we believe

they should come off the list, which then takes you

down to, what, 14, is it, then, Ron?

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RON WARMINGTON: Yeah, about that. Yeah.

IAN HENDERSON: Susan, just to pick up what Second Sight
can't investigate, that's qualified by -- you know,
without a lot of extra work such as going out,
interviewing SPMRs and almost writing up their case

on their behalf.

SUSAN: I think that's really important. Alwen --

ALWEN LYONS: In your email, Ron, can you put a sentence
that you would be happy for me to say about

Second -- or Paula to say about Second Sight as to

why you couldn't take those forward, because

I don't want to put words in your mouth, I'd rather

you saying what you are happy that we can say.

RON WARMINGTON: Yep. Yep. Okay.

IAN HENDERSON: What we might do is refer to the

paragraph that was in the JFSA agreement which

actually set out the -- you know, the documentation
standard.
SUSAN: Well, I think that -- yeah, okay.

So that takes us to 14 cases then on the

(interference) James list. Of those 14, how far have you
got with those 14? Is that the summary that you

sent through to Simon -- oh, I don't know, because

I've been off -- three weeks ago now?

RON WARMINGTON: Yes. That's 14 cases where we've got

what we assess to be 70 or better per cent
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completion of the case, where we --

SUSAN: When you say "completion of the case", do you
just mean subpostmaster evidence, or do you mean

completion of the case?

RON WARMINGTON: I mean -- I mean that we've carried out
the investigation work based on what POL has

submitted as documentation, plus what the SPMRs
submitted, plus the interview but -- and where we

have got it, we've looked at the spot review

response and/or the Horizon data. But those last

two steps are thin on the ground. That's why we
haven't got anything higher than 90 per cent,

I think -- 85 per cent we've got, and 90 on one.

SUSAN: So just for my benefit here, if a case is at

90 per cent or even 70 per cent --

RON WARMINGTON: Yeah.

SUSAN: -- is it going to go any higher or than that or
is it just done now and we could actually -- we've

got to make a judgement on that 70 per cent?

RON WARMINGTON: No, it means that we have documented
what the SPMRs says -- asserts, and validated as
best we can without looking at the Horizon data,

and submitted it, but that we haven't yet got

a response from POL and/or we haven't got the
underlying data yet to validate or refute the

assertion.

SUSAN: So you're expecting -- before you could say yes
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or no or whatever's going on, that 70 has to go up

to 100?

RON WARMINGTON: Yes, yes.

SUSAN: Okay.

IAN HENDERSON: There's another element sort of in the
paths to completion, which is, you know, reviewing,
you know, responses from, sort of, POL. If it is
subject to a spot review, probably some, you know,
dialogue in terms of, you know, sort of dealing

with those responses, and then finally reaching

a conclusion and writing it all up in a mini sort

of report.

RON WARMINGTON: Now, all that was sort of laid down in
a -— the process that we said we were going to deploy from

several months ago, ages ago.

SUSAN: Yeah.

RON WARMINGTON: What was not mentioned and may have
upset Paula is the addition of what was entirely
logical and predictable but never was articulated,
which is to say it makes sense to get Alan Bates’
and Kay's approval -- you know, sort of at least
discuss -- get their input on those before we

absolutely lock in on our conclusion.

SUSAN: Okay. So I think that's -- I mean, that's
a separate point we need -- if I could, I would

just like to follow through --
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RON WARMINGTON: Yeah.

SUSAN: -- so that for Alwyn's benefit in drafting the
notes for Paula we can follow the waterfall of the
cases from James and to sort of get a very clear
understanding about how long you think it would

take to get you from the 90 or wherever you are on

each case, and that will be slightly different --

RON WARMINGTON: Yeah.

SUSAN: -- from there to 100 per cent, and then I think

we need to come back to the JFSA point.

RON WARMINGTON: Yes. And that is where we got to the
issue of the suggestion at one point that we drop
the 14 down to two or three. But that's forward

danger.

SUSAN: Can I just be clear about that suggestion. Did

that suggestion come from James Arbuthnot?

ALWEN LYONS: Yes. I mean, what I think -- I'll tell
you what I think and then other people can say what
they think, I think that was a suggestion made from
James to JFSA, and I've not seen any response from
JFSA. But the assumption is -- in James' head, is

that that is what now is happening.

SUSAN: Okay? So Ron and Ian, what do you think?

IAN HENDERSON: I think it was slightly more complicated

than that and it came up via sort of multiple

routes, and this is going back to 25th March
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meeting where my proposal, which wasn't accepted
sort of accepted subsequently, sort of by James, was to
go for this, sort of, thematic approach. Sort of tied
in with that was the, sort of, suggestion that

we -- you know, bearing in mind his wish for some
further report in July, we said we could either

look at the top two or three issues or the, sort

of, top two or three sort of cases. So we did

actually have that sort of discussion without

reaching any conclusion in March.

SUSAN: Did you have that with the big meeting then?

IAN HENDERSON: Um ...

RON WARMINGTON: Well, it was not suggested at the big
meeting that we dropped the MP-sourced cases. Had

it been there would have been -- I'm sure there
would have been an outcry from the MPs

representatives and their staff -- or their staff.

SUSAN: So would it be a correct as a summary to say that
If we exclude the new cases, the ones where we've got
insufficient evidence or lack of evidence, you've
looked at the 14 they've actually done quite -- we're
almost there on most of them. You've still got to

finish them off.

RON WARMINGTON: Yes.

SUSAN: It seems daft -- well, I say it seems daft. So my
other question was: how long -- what's your guesstimate
of how long it would take you to finish off those 14?

And is it delay on Fujitsu or our part that's stopping
you finishing up or is it just that we've fiffed and
faffed around for the last month, we just haven’t
known where to go. And if you were going to take two

or three, which -- presumably they would be in that 14?

RON WARMINGTON: Yeah, I think it would be it would --
I've never been a supporter of the idea of cutting
down to two or three, not least because, as I say,
I've already done 14. You know, looking at this,

I could -- it might even be 15. I'm not being

sloppy about it, I'm just -- I've got one --

SUSAN: How long do you reckon it would take you to

finish them?

RON WARMINGTON: So I've got it broken down to
50 per cent -- it probably could be higher --
however long to finish them.

Ian, that's more your bailiwick, because it's --
IAN HENDERSON: Sorry, just to be clear on the question,
Susan, the question is how long to finish the sort

of 14 or 15? Is --

SUSAN: Parking the let's go to two or three for a
minute, because I don't know -- I can't work out
whether that's a valid argument or not. So

we've --

IAN HENDERSON: Can I just --

SUSAN: -- got 14/15 MPs' cases --

IAN HENDERSON: Could I just pick up on the two or three

point?

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I think the only context that the two or three

has come up was as an interim sort of measure; in
other words, could we not so much report on the
totality but could we report on two or three by
July. And when that was first raised, I mean, that
was a possibility. But my point is that it was
only ever an interim proposal not a finite proposal
to only report on two or three, or at

least -- (unclear: simultaneous speakers) --

RON WARMINGTON: You're correct, Ian. It was sort of
mentioned in that context, and only in that
context, and I think it probably -- I think it
probably did come up from JFSA, because JFSA's
always made it clear that they don't particularly
care for the MP-sourced cases. They are "more
concerned" about the thematic or systemic issues,

as he calls them.

SUSAN: Okay.

So, sorry, Alwen, what were you going to say?

ALWEN LYONS: I was going to say, so could -- so can
you, even if we say that it's an interim bundle,
if you like, this two or three, have you got time
now to finish two or three and report by -- before

recess, which is halfway through July?

IAN HENDERSON: I think the question or the issue there
is which cases do we pick. We could pick two or

three completely rubbish cases that would add very
little, sort of, value, and -- and wrap those up,

but that's not really sort of dealing with the

bigger issue, which is --

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SUSAN: I'm afraid we might have to, though.

ALWEN LYONS: Are those rubbish cases in the 14?

RON WARMINGTON: Yes.

SUSAN: Yes.

ALWEN LYONS: So there's rubbish in the 14 as well?

SUSAN: Oh, yes.

IAN HENDERSON: Yes. I mean, the MP cases, generally

speaking, were far weaker and less value than the

JFSA cases.

SUSAN: I mean, some of them are really old as well.

IAN HENDERSON: Yes.

RON WARMINGTON: Having said that, we have -- of the

what we call high value cases, where we've been

able to assess it, there's only a couple where

we're not in the 70s or 80 per cent completed. So

they are mostly quite good cases but some are quite

simple. The Rudkin one is very, very simple. It

comprises one spot review. And, frankly, we've

probably got to bottom that out before and assess.

It is so important.

SUSAN: Not what we want to do.

ALWEN LYONS: Well, it might be, but we just don't know,

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do we, at the moment?
IAN HENDERSON: Probably the highest risk one, you know,
out of all of them at the moment.
RON WARMINGTON: It's probably got to be included.
SUSAN: I think it's got to be included. That's the
Bracknell one, Alwen.
ALWEN LYONS: Yes.
RON WARMINGTON: It's the Bracknell one, yeah.
ALWEN LYONS: So -- sorry, I'm sorry to push you on this, but I know

he's going to push us tomorrow. If we chose that one and three others

RON WARMINGTON: Yes.

ALWEN LYONS: -- could we get those done and a report before summer
recess?

IAN HENDERSON: We could produce some form of report.

How final it would be I think it's too early to

say.

ALWEN LYONS: Okay, okay.

SUSAN: Well, that's okay --

RON WARMINGTON: For example --

SUSAN: (unclear: simultaneous speakers) -- quite a lot of the spot

reviews as well.
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RON WARMINGTON: For example, the Tracey Ann Merritt case

might be included in one of those. We'd have to be

very selective about which ones we -- which ones we --

SUSAN: I think you have to have the choice.

RON WARMINGTON: Yes, we would.

SUSAN: Yes, (unclear).

RON WARMINGTON: But it would --

ALWEN LYONS: And the other thing is what we don't want is to choose,
you know, easy ones for the Post Office, if you like, is what I'm
saying, because (1) it might give the wrong answer first and then a
different answer later.

RON WARMINGTON: Yeah.

ALWEN LYONS: Or it might -- if someone realised, you know,

that we've chosen those, because JFSA will see that quite quickly I
think.

RON WARMINGTON: Yeah.

ALWEN LYONS: They'll just go: oh, well you just chose those three

because that was easy.

RON WARMINGTON: Yeah.

IAN HENDERSON: Rather than make a decision on who,

shall -- after this call, shall Ron and I come up

with a proposal that we think is doable --

SUSAN: Please.
IAN HENDERSON: -- by the middle of July?

SUSAN: I think if you can think about whether -- and
we should, I think, given the amount of work that's
gone in, we can also, for instance, include the

conclusion of the spot reviews.

RON WARMINGTON: Yes, we'd have to. We can't -- you
know, we couldn't professionally close out

a case --

SUSAN: So that's what I'm saying. I think you would

have to write it as an interim report anyway.

RON WARMINGTON: Yeah.

SUSAN: But could we include some of the spot reviews

as well as the cases maybe? Don't know.

RON WARMINGTON: Oh, I see what you mean, yeah.

IAN HENDERSON: But again, Susan, that's raising

a bigger question because the spot reviews were
aligned more with the thematic approach, putting

them into sort of categories, you know, which is

very different from reporting on cases which are,

you know, unique to an individual, and many --

SUSAN: Okay, okay, sorry, that's not a good idea then.

ALWEN LYONS: So that's the two or three.

SUSAN: Yeah.

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ALWEN LYONS: Then what sort of timeline are we looking at to finish

the whole thing, the 14, 15 whatever it is?

IAN HENDERSON: Probably another three months after

July.

SUSAN: September?

IAN HENDERSON: Yeah.

SUSAN: But won't we need to think about whether we can
speed stuff up, whether it's us that's delaying

things or --

RON WARMINGTON: Yeah, I mean, for example, we've said
that it would be a lot faster if we could pursue

a sort of iterative path on the spot review
responses rather than waiting for, you know,

a six-page answer that itself then requires deep

study and response.

SUSAN: Well, but --

RON WARMINGTON: Yeah, no, I know, (unclear) there's

Arguments the other way.

IAN HENDERSON: Also, frankly, we could be a lot more
aggressive in terms of bringing to your attention
sort of delays in the system, you know, when we've
bashed something out and it takes six weeks for,

you know, a substantive reply to come back.

SUSAN: Yeah, you need to be shouting to me quickly.

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RON WARMINGTON: Okay.

IAN HENDERSON: Yeah. And I think everybody involved in
the process needs to be told by -- from Paula, you
know, that sort of level, "This is a pariah -- a

priority, and we expect" --

SUSAN: No, it's a pariah, you were right the

first time.

RON WARMINGTON: Freudian slip.

IAN HENDERSON: -- you know, "a 48-hour turnaround."
SUSAN: Yeah, yeah, yeah.

ALWEN LYONS: So I don't --

SUSAN: Yeah, go on.

ALWEN LYONS: I don't want to suggest -- and I'm saying
October not September, because I've -- I don't want
to suggest that tomorrow and then us being beaten
up at the end of September. So, you know, is it in
your email? Can you just -- can you have a think
and just check that that is all right to say,

October.

SUSAN: I think Ian and Ron make it contingent

upon -- (unclear: simultaneous speakers) --

ALWEN LYONS: That's fine.

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SUSAN: - continuing and energetic support from POL.

ALWEN LYONS: Yeah, and support and everything. I think

that's fine. I just -- I just don't want to --

IAN HENDERSON: And of course another risk in the whole
process is Fujitsu getting nervous about the whole
thing and I am picking up some vibes along those

lines.

SUSAN: I think you should mention that actually, Ron,

in your email.

RON WARMINGTON: Okay.

SUSAN: Because we have got a difficult few years with

them, I think.

RON WARMINGTON: Yeah.

ALWEN LYONS: So has anybody told -- so this might be --
I'm thinking of that -- the James conversation now.
Has anybody told James that -- you know, that half

of these cases are basically it's not possible to

do anything with because the evidence is lacking?

IAN HENDERSON: I have certainly told Janet the -- the
sort of the minimum standard that is necessary,

and -- and all of the submissions have come from
Janet, and therefore, you know, she ought to be
aware of the standard of documentation, or the lack
of it.

I don't think we've explicitly said, you know,

"Here is a list of, you know, 17 cases, you know,

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we need a lot more."

ALWEN LYONS: Is Paula going to raise that?

SUSAN: So who should raise that first with him? Should that be

guys or should that be Paula tomorrow?

IAN HENDERSON: I think it's perfectly appropriate to
raise tomorrow because, you know, he in his office

should be aware of that fact.

SUSAN: Also we've been giving people time, you know,

blah de blah de blah, haven't we?

IAN HENDERSON: There are -- sorry --

ALWEN LYONS: Let me just play devil's advocate, okay?
Because if I was James tomorrow, I would turn round
and say, "Well, why haven't Second Sight told me
that?"

IAN HENDERSON: Because we have only got what they have
submitted from his office and, therefore, you know,
that they have as much information as we do about

the submission.

SUSAN: But you are the expert. I'm just --

IAN HENDERSON: No, that's fair enough.

SUSAN: You are the expert, right? Janet isn't an

expert. She just sends you something across -- all

right, you have laid out what you want, but she

just sends you something across. And we, being

you

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silent, and going back and saying, "That's not good

enough, it can't stand as a case."

IAN HENDERSON: Yeah, no, you're right --

RON WARMINGTON: Yes, that is correct. We've got to
wear that hat. We have been silent to Janet.

We've realised that for a couple of months now that
we've been silent on this subject and it's itching
us, but the questions as to -- you know, the key
issue has been if we go back and ask for more, we
are further raising expectations and we've got to
do them all then. Okay? So the reason we haven't
done that is for that reason.

You know, the moment we should have done that

was when we created the JFSA agreement we should
have all slammed back to Janet and James a document
saying: right, the cases submitted so far do not
comply with this, they need to, you've got to go
back and get some level of documentation of every
case.

I mean --

IAN HENDERSON: Ron, we did do that, but without listing

the cases. I mean, I wrote to Janet, I think in

March --

SUSAN: Yeah.

IAN HENDERSON: -- saying this is the standard that we

require.

RON WARMINGTON: Yeah, and I might --

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SUSAN: (unclear: simultaneous speakers) -- phrased it,

Alwen, they probably had --

ALWEN LYONS: Yeah, okay.

SUSAN: -- (unclear: simultaneous speakers) -- and it

needs to be on these cases.

RON WARMINGTON: I might add --

SUSAN: -- (unclear: simultaneous speakers) --

listened.

RON WARMINGTON: I might add that of all the interviews
I've done, I haven't really found many people,
hardly any actually, that are capable of

documenting their own case, without external help.

SUSAN: Yeah, right. That's a different issue.

RON WARMINGTON: Well, that might account for why you

haven't got a response.

SUSAN: Sorry?

RON WARMINGTON: That might account for why we haven't

had any responses.

ALWEN LYONS: Yeah.

ALWEN LYONS: It might, but then, you know, they've called
their MPs, they can pick the phone up to you and just
say -- or email you and say, "Look, I really want to

talk to you about this, I can't explain it."

on

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RON WARMINGTON: Yeah. Yeah.

SUSAN: Okay.

RON WARMINGTON: I mean, the truth was we -- we diverted
some attention on to the more fertile, useful spot
reviews coming in or matters coming in from the

JFSA, and we had our work cut out with the 14 or so

cases on which we did have documentation.

SUSAN: Yeah, okay.

ALWEN LYONS: So I get the MP cases now. So then the

JFSA cases -~-

RON WARMINGTON: Yeah.

ALWEN LYONS: -- have they -- so we've got the -- so
we're talking about the 29 and I understand those.
How many cases have you had from -- direct from
JFSA? Or have they not sent cases like that? Have

they just sent thematic things?

RON WARMINGTON: Yeah, there's 19, and what they've sent
in are, you know, anything from emails to -- to

scanned documents, isolating in every case one or

two transactional issues. Tiny issues. You know,

very isolated, closely cropped, easy..relatively easy to
understand issues. They are much easier to deal

with than the MP-referred cases.

ALWEN LYONS: I'm just wondering how -- you know, how on

earth we shut these down as well, because --
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RON WARMINGTON: We have shut them down in the sense of
no more are coming in because after -- we've got

past the end of February.

ALWEN LYONS: Yes, yes. I meant more how do we get to
resolution, really, because we can do all these MP

cases --

RON WARMINGTON: Yeah.

ALWEN LYONS: -- some of which are rubbish, and then we'll go to the
MPs and we'll say we found this or we found that, and then JFSA will
stand at the sidelines going, "Yes, but you have answered the wrong

question. What about all this stuff?"

RON WARMINGTON: Yeah, well, exactly. The inference is
that -- my position, Alwen, is that trying not,
now, to review the JFSA-referred cases will be --

I just can't see how we could get away with that.

SUSAN: Okay, well, that then brings us on to

discussing the position with the JFSA.

RON WARMINGTON: Yeah.

SUSAN: So I'll say where I think we are, having
garnered that from Ron and Ian, and Alwyn can --
and you can all interrupt.

So Ron and Ian are working closely together with
Kay and Alan Bates -- Kay Linnell and Alan Bates.
This was an arrangement brokered by James because
it was one of the things he started off by saying

we need to take JFSA with us. So I reminded Paula,
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we all agreed, us at POL, that it was the right

thing to do --

ALWEN LYONS: Yeah.

SUSAN: -- and actually to get them on side would be
a remarkable achievement and something we should

aim for.

ALWEN LYONS: Yeah.

SUSAN: We even offered, and it was part of the sort of
independent agreement by Kay Linnell, which was

also part of -- wound -- so this was all wound up

in the James Arbuthnot piece.

Ron and Ian have agreed with JFSA that we would

take themes, hence the thematic reviews. A number

of themes have come out of cases. Some are

duplicated so run across one or two cases.

We have looked at a -- I don't know, about

a quarter of the thematic reviews and delivered

them back to you, Ron, Ian?

RON WARMINGTON: It would be about -- we've got nearly

six spot reviews back, Ian?

SUSAN: You have certainly got five back, haven't you?

RON WARMINGTON: Yeah, five I think. Yeah.

SUSAN: Is it going to be 20-ish?

RON WARMINGTON: We've got 27 spot reviews at the

moment.
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SUSAN: Okay, so a fifth, say --

RON WARMINGTON: Yeah.

SUSAN: -- (unclear: simultaneous speakers) --

ALWEN LYONS: Yeah.

SUSAN: I think there is something around the
process of the spot reviews where we, POL, have
assumed that we would get the allegations, for want

of a better word -- statement of facts --

RON WARMINGTON: Yeah.

SUSAN: -- from you, theJFSA and the subpostmasters. We

would then respond to them.

RON WARMINGTON: Yeah.

SUSAN: Then I think what we weren't expecting is sort
of an iterative process around discussions with

Kay Linnell and Alan Bates.

RON WARMINGTON: Yeah.

SUSAN: And I think we're not entirely sure how we stop
this process and it doesn't just go round and round
and round, because obviously they're not going to
like what we say, they're not going to believe what
we say, and we don't know how we could convince

them just, short of just telling them face to face,

and why would that work when they won't believe it
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in writing. So my one question is, how do we
actually -- having done all the work to answer the
questions in the spot reviews, in our honest
opinion having answered them properly, because
Alwen and I have both reviewed the documentation
and -- not been involved in all the investigative
work but we have at least reviewed it, as has
Angela, to make sure that it's -- and make sure of
we know about how we operate, so that sort of sense
check there -- can't say it would be absolutely
perfect but I think it would get there or
thereabouts, particularly with Angela and Alwen's

impact, not mine.

RON WARMINGTON: Yeah.

SUSAN: What do I know? My question then is, how do we
actually put these to bed so that we can say those spot

reviews are now "agreed" by the JFSA?

IAN HENDERSON: Well, unfortunately, it may be that we
don't reach agreement with the JFSA. As almost

a natural justice point, I think we felt that it

was appropriate to have some input from the JFSA
before we reach a final sort of conclusion on the
whole matter but, I mean, that is a step and

a stage that -- that, you know, Ron and I have
introduced. We're in control of that and

ultimately Second Sight needs to make a decision

and come to a conclusion on each spot review,

which, you know, we're prepared to do.

RON WARMINGTON: Absolutely. Yeah, we're not -- we're

not going to be biased in favour of accepting Kay's
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or Alan's response.

SUSAN: Or our response.

RON WARMINGTON: Or yours, yeah. I mean, we'll look
at -- look at all of it. But in my judgement, and
Ian's I think too, it was better to disclose those
to them, and obviously once you disclose it to them
you're kind of inviting their response. I didn't
actually say to them, "Please -- you know, what do
you think of this? Please send us your response."

But you're bound to get it.

IAN HENDERSON: But that was the clear intention, Ron,

and I think we would welcome that.

RON WARMINGTON: Yeah.

IAN HENDERSON: You know, we have not -- you know, any
input from them that is, you know, of an informed
sort of basis potentially could be helpful, and

it's up to us to sort of decide whether to accept

or to reject that.

RON WARMINGTON: Exactly.

SUSAN: Okay, Alwen, does that make you feel -- because
Alwen and I a discussion, as indeed Paula and I had

a discussion, about how we get to the conclusion,

and we had internally agreed that it was up to

Second Sight at some point to get to the

conclusion, and you're right, they may never accept
it.

Alwen, are you okay with that as an answer?
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ALWEN LYONS: I suppose that, yes, I am okay with it.
I suppose -- I'm just worried that it's always
become ever decreasing circles, so, you know, you
said this, we said that, you said that. And my
expectation, and I think you have just confirmed
that that's what's going to happen, my expectation
is you're the experts and that -- and in the end
you will call it and you'll say the evidence shows
or that this is what we think happened and
therefore, you know, you need to do something about
it, either left-hand side or on the right-hand

side.

RON WARMINGTON: Yeah, that's --

ALWEN LYONS: I wasn't expecting it almost -- it just
feels as if -- and I absolutely understand why we
need to engage with JFSA and I think that's right,

I think we need to do it at a strategic level
rather than at a "You said this, we said that, you

said this" -- I don't think that will help anybody.

RON WARMINGTON: Yep.

IAN HENDERSON: Bear in mind, of course, that there are
some spot reviews where there is a conflict of
evidence, where, you know, POL, possibly via

Fujitsu, is saying one thing and where the SPMR is

saying something else.

ALWEN LYONS: Absolutely.
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IAN HENDERSON: And it may be that we're unable to

resolve that.

SUSAN: And it may be that you will have to come back
to us and say, "Show us the base data," or, "Ask us

more questions."

IAN HENDERSON: Yeah.

SUSAN: We completely understand that, don't we, Alwen?

ALWEN LYONS: Yes, absolutely.

SUSAN: Yeah, I mean, I would expect some -- you know,
I would expect that to be the case, because
otherwise -- if it was straightforward, we would

have sorted it out years ago.

IAN HENDERSON: Yeah.

SUSAN: Okay. So the next point then is your
commentary around what the JFSA's expectation is
and who needs to be managing them as stakeholders.
So they're expecting us and you to work through the

27 spot reviews. Is that right?

RON WARMINGTON: They haven't -- they never said that

but I think it's inferred, yeah.

SUSAN: I think that -- and what do they expect the

outcome to be then, Ron, do you think?

RON WARMINGTON: I think very much as Alwen described

it, which is that we would get POL's input -- well,
we've always said this. We would get POL's input,
try to validate or prove/disprove it with the
underlying data, bounce it off Kay and Alan, and
then reach a conclusion on each case. That's
always been the understanding of how we deal with

it.

SUSAN: Okay.

RON WARMINGTON: And I think they would be quite
surprised were we to sort of lop off a chunk of
spot reviews. I don't think -- I don't have any

problem with --

IAN HENDERSON: (unclear: simultaneous speakers) --

closed is it?
RON WARMINGTON: No, I don't see any problem with an
interim report based on some of them. Nothing

wrong with that at all.

IAN HENDERSON: Except it flies in the face of what

Arbuthnot wants or expects.

SUSAN: Yes.

RON WARMINGTON: It might do, yeah.

SUSAN: So --

ALWEN LYONS: So is there any way, and I'm thinking out

aloud here, is there any way of shutting down the
MP cases and making James and his friends happy so

they'll just go away basically, and then us finding

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a way forward with JFSA about how we look at the
thematic spot reviews and how -- in the future,
after you're no longer involved in all this, how we
have some sort of Horizon users group, which they
might be part of or lead on or whatever. I mean,

if we would -- I mean, that's the sort of
communication I think we need to have with JFSA,
which is around how can we make this better for
everyone, including the subpostmasters, and make

sure the system works properly.

RON WARMINGTON: Yeah.

ALWEN LYONS: But you know, I think we're just so far away

from that at the moment. That should be our goal

surely.

IAN HENDERSON: I think that's right. I just think it's
going to be difficult even to have that discussion
until we've reached something closer to finality on
the existing spot reviews, because the risk is JFSA
will feel we're just brushing the past under the
carpet and proposing something that hopefully will

be better in the future, and they want closure as

far as the past is concerned.

ALWEN LYONS: Okay.

RON WARMINGTON: But I don't think you'll get any
push-back on chopping some of the MP cases from
Alan, but we would get push-back on chopping some
of his 19 cases or the 26 spot reviews that relate

to his cases and the MP ones.

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IAN HENDERSON: Can I just say one thing on the spot
reviews? One thing that we have said from day one,
and explained to all the MPs, each spot review is
a mini case in itself, and as and when we reach

a sort of a conclusion on each spot review, there
will be the spot review form, there will be the
spot review response from POL, and then there will
be our sort of conclusion. We envisage packaging
those all together right at the end of the process,
and that would form the sort of appendix or

a number of appendices to our report. But what it
does mean is that over the next few months we will
be concluding on a number of spot reviews, we will
be sharing those conclusions with JFSA, and whilst
we won't be publishing them in the sense of, you
know, the world at large, it does represent a form
of conclusion on that particular sort of spot
review, and I'm just wondering if there's anything
we can do with that that, you know, will be of

benefit to the process.

ALWEN LYONS: So I think there's opportunity and risk
there, and I think the risk is around the media,
and I suppose it depends what conclusions you come
to, and it could go on in either way. If you keep
telling them, "There's no problem, there's no
problem, we've done this, we've done that, you
know, yes, they should do more training, they
should do better communications but actually the
system is sound," if we say that to them, then --
and you drip-feed that to them, saying there's a
big report coming, I think that -- I think there's
danger there that they will start disbelieving

stuff. If we give them an inkling that there is an

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issue, I think to make them sit on their hands for
three months for a report to arrive, I think

that's -- I don’t think that will happen.

RON WARMINGTON: Do you mean -- when you say "they", do

you mean the JFSA, Alwyn?

ALWEN LYONS: Yes.

RON WARMINGTON: I'm more confident than I suspect you
are because I'm probably closer to them. Alan and
Kay I think right now are not in the least bit
Minded to go to the press, but I accept what you're
saying, that were we to lose -- were they to lose
trust with us, then I think they will go to the

press pretty quickly.

ALWEN LYONS: Or if they thought they had a chink of a

story, I think that's --

RON WARMINGTON: No.

ALWEN LYONS: I mean, we're hearing, you know -- we're

being quoted that, you know, they've got

Private Eye waiting, they've got the BBC --

RON WARMINGTON: That's me. I'm saying that. No, it's

all quite contained, Alwen.

ALWEN LYONS: That's not from them, then?

RON WARMINGTON: No, they're not -- they're not

threatening us with that at all.
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ALWEN LYONS: Okay, sorry --

RON WARMINGTON: I think you -- I want to reassure --

IAN HENDERSON: What they did do, of course, was write

to the MP, you know, with responsibility for the

Post Office --

RON WARMINGTON: Yes.

IAN HENDERSON: -- and so, you know, that -- (unclear:

simultaneous speakers) --

ALWEN LYONS: (unclear: simultaneous speakers) --

RON WARMINGTON: Yeah, in fact, Alan also told me today
he'd written to Paula seeking to meet with her, not
least to make sure, he told me today, that there

are -- that the messages are getting through to her
that should be getting through to her. That's what

he said to me just a short while ago.

SUSAN: That's funny because I said I wasn't sure

he and Paula should meet. I thought it would be

Alwyn and I who should meet him, but anyway.

RON WARMINGTON: Yeah, okay. Right.

SUSAN: If we go back to the briefing with James for

tomorrow, which is Alwen's most immediate problem.

ALWEN LYONS: Yeah.

RON WARMINGTON: Yes, exactly.
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SUSAN: Alwen, have you got enough now and is there
a remaining issue round convincing Paula and Alice

that we need to keep going with the JFSA reviews?

ALWEN LYONS: I think it is. I think -- and I think the
issue there will be -- cost will be the issue

there, because, in fact, if (unclear) is saying

that we can do the MPs and everybody by the end of
October, how long is it going to take beyond that

to do all the JFSA spot reviews?

SUSAN: I thought we'd get everything done by the end

of October --

RON WARMINGTON: Yeah, I don't think --

IAN HENDERSON: When I said three months, I included or

had in mind --

SUSAN: Oh, right, okay. That's helpful.

IAN HENDERSON: I see this all wrapped up by October.

SUSAN: Okay. That's helpful.

RON WARMINGTON: I bloody well hope so, because I'm

getting married on September 14th and I'm not going

to be doing this as I walk down the aisle. I've

already got --

SUSAN: (unclear: simultaneous speakers) -- the day

before Trevor's birthday, and I do a 50K walk.
RON WARMINGTON: Right, that sounds like a good closure

(unclear: simultaneous speakers) --

IAN HENDERSON: (unclear: simultaneous speakers) -- you

walk?

SUSAN: Yes, so I've got to be better, obviously, by

then.

RON WARMINGTON: Not half, yeah. Okay.

SUSAN: (unclear) Thames Path, so I reckon it's flat,

unlike Glencoe last year.

IAN HENDERSON: That's about 30 miles or something.

RON WARMINGTON: I could give you a lift, actually, in

the boat.

SUSAN: You could?

RON WARMINGTON: Yeah, I could quietly pick you up.

SUSAN: Alwen, I injected an air of frivolity (unclear).

RON WARMINGTON: It doesn't do any harm.

IAN HENDERSON: Can I just mention one practical point

in case you get any push-back on JFSA issues?

SUSAN: Yeah.

IAN HENDERSON: The totality of the JFSA agreement is

published on the internet, you know, and is

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available to the world and its dog, and I don't
think, in any practical sense, there's any scope to

renege on any of that.

ALWEN LYONS: Okay.

SUSAN: Well, I did bring this up with Paula
today, and she said, "Oh, yes, I assumed we'd keep

on doing those."

RON WARMINGTON: Yeah.

ALWEN LYONS: Okay.

ALWEN LYONS: Whether that's true or not, but that's

what she said to me when I spoke to her at lunch --

SUSAN: So that's helpful. It's helpful.

RON WARMINGTON: Well, what we're getting to then is the
culling of some of those low value, undocumented,
disinterested MP cases. You're not getting

push-back from us, that's for sure, and I don't

think you're going to get push-back from JFSA, and
actually neither from Arbuthnot. The only people

that might --

IAN HENDERSON: No, Ron, can I just pick up on

Arbuthnot? I mean, I raised that with Arbuthnot.

RON WARMINGTON: Yeah?

IAN HENDERSON: And he specifically said, "I don't think

I've got the power, you know, to involve individual

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cases" --

SUSAN: Well, the other option --

RON WARMINGTON: No --

SUSAN: The other option, Ian, if we could offer --

so -- because it's the -- it's not only those but
it's the new cases that are coming in. The other
option is we could say is that we will offer those MPs
the POL reviews. And frankly, given how much
attention they've paid so far, the MPs that is,

that may be enough.

IAN HENDERSON: Well, can I just read something out,
because I've been looking at my emails with Janet
whilst we've been talking. I had an email from
Janet on 21st March, which is obviously four days
before the MP meeting, and the relevant sentence
is:

"Dear Ron and Ian, I am sending these two [as in
cases] in some trepidation from discussions

with ..."

RON WARMINGTON: Exactly.

IAN HENDERSON: "... earlier this week. I gather that
there has been a deadline for new cases to be
accepted."

In other words, she's implying or accepting that

the drawbridge had come down probably on 28th February
and that we would be getting no more MP cases from that

date --
SUSAN: That's what we agreed, I think.

IAN HENDERSON: Yes.

RON WARMINGTON: I just found the same email, Ian.

SUSAN: (Unclear) was that from the JFSA?

RON WARMINGTON: Yes, this was -- would have been

Rabeena Shaheen and Robinson come in, and yeah, you're

right, the conversations we had with her, I
remember, she called me, she said, "Oh, look, I'm
really embarrassed, I think these have been sitting

on my desk."

IAN HENDERSON: Ron, can I just finish reading this out?

Second sentence from Janet:

"I'm afraid I didn't know about the deadline
until it was mentioned this week, so it might be
worth mentioning to MPs obviously, i.e. no new
cases to be taken on from now, but I would be very

grateful if you'd consider taking these two on."

RON WARMINGTON: Exactly.

IAN HENDERSON: So I think that, you know, we had in
effect reached agreement that after the date of
this email that we would definitely be getting no

new cases via the MP route.

SUSAN: I think there are two things we can say:
firstly that, "And there's the evidence"; secondly,
if there are cases where you have not been able to

find evidence and not -and the subpostmaster has not

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been forthcoming, that we, POL, again subject to
senior management review and intervention, will
contact those subpostmasters and invite them to
come forward.

I mean, we could offer that, Alwen. I don't

know whether she will want to offer it tomorrow with James.

ALWEN LYONS: Yeah.

SUSAN: Or she could say, of course, it's always up to
the subpostmasters to come directly to -- and

I think we should give them a separate email

address or something, not -- that they don't go
through the normal route in the network. Even

maybe come to you as the company secretary or

something.

ALWEN LYONS: Yeah, yeah, could do that. I have my own

email address now.

SUSAN: Well, I was thinking that it was possible that
for subpostmaster complaints and queries, in order
to get them out of the network

loop, we should --

ALWEN LYONS: Yeah.

SUSAN: -- you should actually do sort of -- I know we
didn't provide another appeal to it, but they can
come to you and at least get a hopefully more,

maybe -- maybe -- more fair hearing.

ALWEN LYONS: Yeah.

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SUSAN: Or at least a hearing.

ALWEN LYONS: Yes, yeah. Okay, I have that.

SUSAN: (unclear: simultaneous speakers) -- a little

way --

ALWEN LYONS: Yeah.

SUSAN: -- from that, but it's part -- and it's part of
what I need to put in place as part of the "let's

change the investigation" structure.

ALWEN LYONS: Yes, absolutely. Okay.

SUSAN: So I think the one issue we have then is
whether Paula is prepared to wear us taking until
the end of October, worst case, to get to all the

other -- the JFSA.

ALWEN LYONS: I think she's going to want to run that

past Alice.

SUSAN: That's fine. I thought she remembered -- you
know, but I think she needs a timeline, Alwen,

which we can probably get from Simon.

ALWEN LYONS: Yes. Yeah, okay.

SUSAN: Otherwise, it will just -- I mean, I know it's long
and it's taking too long and everything else, but this

stuff --

ALWEN LYONS: I think if we can promise them something,
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an interim report, by before the end of July -- we

can call it a report, wouldn't that be --

SUSAN: Yes, yes.

ALWEN LYONS: -- then I think she, they'll be happier.

SUSAN: Okay.

ALWEN LYONS: Then if we can say, you know, and -- and

then within three months or by the end of -- let's

say end of October, let's not push it -- or are we

saying end of September? If you are all going off

doing something --

IAN HENDERSON: I think, to be safe, it ought to be

October.

ALWEN LYONS: Okay, okay.

ALWEN LYONS: (unclear) so it will be a good honeymoon, then?

RON WARMINGTON: No, we're not going anywhere, so I will

be spending my honeymoon in my office.

ALWEN LYONS: Oh, you're joking.

RON WARMINGTON: I'm too old for honeymoons. Right --

SUSAN: When Ron sends his email in, he has to make

that subject to adequate levels --

ALWEN LYONS: Yes, if you could -- if you could get

a form of words for me and -- so that I can include
that in the report with Paula, so she's got that in front

of her tomorrow.

RON WARMINGTON: Yeah, yeah.

SUSAN: That would be really helpful.

RON WARMINGTON: Okay. Okay, right, we'll do that.
The other thing that's -- I don't know, Ian,
before this meeting we were discussing this bloody
Bracknell issue. Are we right in thinking that

Paula isn't aware of that?

SUSAN: Yes, she's not aware of it -- or, no, she's not

aware of it.
RON WARMINGTON: I don't think Arbuthnot is aware of it
either -- or maybe he is. Oh, actually he is,

because it's --

IAN HENDERSON: He's aware that it's something we're

looking at.

RON WARMINGTON: He is aware of it.

IAN HENDERSON: He's aware of some of the, you know,

evidence that is -- that is coming up.

RON WARMINGTON: Yes, he's not aware of how it's panned

out over the last -- more recently.

SUSAN: Yes, my view on that is I would

really like to understand and I have been out of

the loop so apologies, and it probably should be

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me -- Ian, you and I probably need to sit down and
go through the evidence and work out what the next

steps are with it, or Alwen and

RON WARMINGTON: Yeah.

SUSAN: You've obviously got an enormous download of data

from CSP. I saw that.

IAN HENDERSON: Yeah.

SUSAN: Maybe we don't need to take Alwen's time on

this but you have been through the emails.

IAN HENDERSON: Yes.

SUSAN: You've found this one email. We don't need to
say, "Right, well, what does that mean?" I need
probably to get Lesley involved as well, or I need

to ask Lesley for consistent help.

RON WARMINGTON: It's more than one email but --

SUSAN: Yeah, okay. But there is evidence, let's put

it that way.

RON WARMINGTON: There is something.

IAN HENDERSON: Simon also -- and before I say this, we
also need to decide whether we're sticking with the
discussion of a few weeks ago, which was to keep
Simon completely clear of this, because Simon
mentioned it in a call to Ron and I earlier today

and he has, in the last couple of days, got some
new information that pretty well confirms at least

part of what we have found.

SUSAN: Right, okay. I think we are going to have
to put some -- somebody else on this. I don't
know. We haven't found somebody yet, have we,

Alwen?

ALWEN LYONS: No, but I think we'll have to.

SUSAN: Shall I text Lesley and ask her to give me

a call --

RON WARMINGTON: You can't really delegate this to

Fujitsu because --

ALWEN LYONS: No, no, no, we wouldn't do that.

RON WARMINGTON: Okay. Now, who's mentioned it, Simon
told me shortly before this call that he'd
questioned Rod Ismay and Andy Winn as to whether
they knew about that process, and he said that they

said they didn't know anything about it.

SUSAN: Right.

RON WARMINGTON: So one of them might be a civil person.

IAN HENDERSON: No Ron, we need somebody unconnected with

the process.

SUSAN: To be honest, I think we need somebody out of the

line.

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RON WARMINGTON: Mmm.

IAN HENDERSON: Who is -- who -- you know, who's got

a brain and has got some good IT knowledge.

RON WARMINGTON: Got an internal auditor there?

SUSAN: I almost wonder if it's our new head of

internal -- there's an IT auditor who has just

started.

ALWEN LYONS: Yeah, that might work.

SUSAN: I haven't dragged him into it yet. I could do.

RON WARMINGTON: The sort of thing an IT auditor would

routinely do.

SUSAN: It is.

RON WARMINGTON: Yeah.

SUSAN: It might be quicker to get him. It would be good

for him because it would get him up to speed quicker as

well with stuff.

RON WARMINGTON: Yeah.

SUSAN: But I'd have to get Chris to agree to it.

Are you happy, because of where we are on the

Bracknell piece, that we don't -- it's not -- we

have suspicions. We need to work them through.

IAN HENDERSON: I think it's dangerous not to brief
Paula.

RON WARMINGTON: Yes, so do I. I would brief her on it.

SUSAN: But what do we say, though?

RON WARMINGTON: How's it going to be, for example,
if -- if, for all I know, Arbuthnot asks her
a question about it tomorrow? She's going to be

blind-sided on it.

SUSAN: Well, what does he know? He only knows the

allegations that Rudkin's made, doesn't he?

RON WARMINGTON: Yes.

IAN HENDERSON: Yeah, but what we're getting, Susan,
know, not putting too fine a point on it, is
confirmation that the sort of facility that was
described was at the sort of capability that was
described does exist. You know, the issue, the
outstanding issue, is what are the consequences of

that and have we got a reliable record --

SUSAN: A robust audit.

IAN HENDERSON: Yes.

ALWEN LYONS: Yes, but it's very different saying to
Paula that we found this way that you can fiddle
with the system, right, or them saying to her there
is (unclear) process because he would have to use
it for this, this and this. However, here are the

records of the robust audit. That's a very

you

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different message.

SUSAN: And she has -- Simon has been through with her

the recent incidences.

ALWEN LYONS: Yes.

SUSAN: So she has all that.

RON WARMINGTON: Yes.

ALWEN LYONS: Yes.

RON WARMINGTON: Yes. Yeah. Well. That's good.

ALWEN LYONS: Yes, she's got everything. The way that

I've tried to brief Paula is as soon as I have

evidence that, you know, there is a problem she

knows about it the next minute and so does Alice.

So, you know -- so we have talked through the bugs

and we have done and so we've done that.

RON WARMINGTON: But the context of this --

IAN HENDERSON: I wouldn’t say that Bracknell is in the

category.

RON WARMINGTON: Yeah, the context of this is --

SUSAN: The thing is, Ron, we don't have the end

solution.

RON WARMINGTON: Well, no but -- well, that's true of

lots of things, isn't it? In my mind, that doesn't

same

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mean -- if I was in her shoes and I was not told
about it because you didn't have the end solution,

I wouldn't be very happy about it.

IAN HENDERSON: I mean, why don't we just say it does
look as if there was the sort of capability
available that has been sort of described. What we
don't yet know is the consequences or the impact of
that and that is something that we are urgently

working on.

ALWEN LYONS: Do we know that the capability's there?

We need to -- I'd like to --

RON WARMINGTON: Simon has told me that it is true the

facility does exist, but --

ALWEN LYONS: So where's he getting that from because

I haven't seen that anywhere?

RON WARMINGTON: He said he found out.

IAN HENDERSON: He found out --

RON WARMINGTON: Yeah, he's found out a lot in the last

half day or so.

SUSAN: Okay, so we need --

RON WARMINGTON: He is the centre of knowledge on that

at the moment.

SUSAN: Okay. Okay. Well, we'll catch up with Simon

on that.
RON WARMINGTON: Yeah. I think, I mean, having said
that, he relayed something that Gareth is saying it
more or less doesn't exist or it's misunderstood
but, you know, that's -- I don't know. I don't

know the answer to that yet.

SUSAN: I see, I don't think we know the answer.
I suppose it's -- there are allegations made
about the facility, a Post Office testing
facility at the Fujitsu. Maybe, you know, it is

the case that that exists.

IAN HENDERSON: Well, remember it was POL employees.
They just happened to be located in a Fujitsu
building. I don't think we can sort of pass the

blame on to Fujitsu.

SUSAN: No, no, I'm not saying that but I don't --
they're testers, aren't they? That's who they are.

It's a test environment.

RON WARMINGTON: Well --

IAN HENDERSON: What we're seeing from the emails is
they were getting instructions, in effect, directly
from the Helpdesk saying, "Look, we need this
fixed. You know, can you work your magic?" and,

you know, the responses are going back, "Yeah, it
will be done in the overnight run tonight. We will

change the balances or whatever".

SUSAN: Okay. Well -- we need to talk to Simon.

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RON WARMINGTON: Yeah.

SUSAN: Have you got the email? Are you the only

one with the email?

IAN HENDERSON: And, Susan, I'm coming back to the
question a few moments ago. I haven't sent that to
Simon and I suggest that we don't because I really

think they --

SUSAN: No, you're right. You're right. We can't

really go to Simon --

ALWEN LYONS: No, no, okay. But then he's obviously

been doing stuff.

IAN HENDERSON: I think he's doing it as much to protect

his back. I mean, you know --

ALWEN LYONS: Well, I don't think -- I think he was just

trying to be helpful --

RON WARMINGTON: Yeah. I think he was, Ian. I think he

was genuinely trying to be helpful on it.

ALWEN LYONS: I don't think he was trying -- you know,
I think I know him well enough that if he’d found

something --

RON WARMINGTON: He really is curious as to what on
earth was the truth in this and he's actively
trying to get to the bottom of it. So I'm -- but

I agree. I don't disagree with your position

there. But it does require some urgent action

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because it's just such a big issue that could be

nothing, that's just -(unclear)- it's just a big X factor.

SUSAN: And whether we can get to it and how we
can get to it and who we can get to help us with

it.

RON WARMINGTON: I'm pretty sure you won't be able to

resolve it before tomorrow.

SUSAN: No, no, no. No, I'm not saying resolve

RON WARMINGTON: Get to the bottom of it --

ALWEN LYONS: -- what Paula needs to know before she

talks to James, that's all.

RON WARMINGTON: Yeah.

SUSAN: I'm not sure whether it's going to --

I think it will just confuse things.

RON WARMINGTON: If James says something like "and where
are you on this assertion about the Bracknell

covert operations team" as it was referred to by
Rudkin and, remember, he's got a direct line to
Shoosmiths. They're chummy apparently. So they

will have told him about this, for sure. So, you

know, if he challenges her on it --

SUSAN: -- (unclear) say, well, look that's a

specific case --

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RON WARMINGTON: (Unclear).

SUSAN: Come back to -- when we've finished the investigation.

RON WARMINGTON: Yeah, as long as she doesn't come back

and say, “Well, he mentioned this Bracknell issue.

What is he talking about?" "Oh, we've known about

that for, you know, two months."

SUSAN: No, she knows about the allegation.

RON WARMINGTON: Oh okay.

SUSAN: She knows we're working on it.

RON WARMINGTON: That's all right then. Okay. Good,

good, good.

SUSAN: So we mentioned it to her.

RON WARMINGTON: Okay.

SUSAN: We’ve all been going, well that is all very odd.

IAN HENDERSON: But I think she needs to be prepared for

the, you know, the journalist-type question, you

know.

SUSAN: "When did you last beat your wife?"

IAN HENDERSON: Yes, and in relation to, sort of

Bracknell, can you assure me that there is not

some, you know, back door, some remote capability,

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you know, at Bracknell or elsewhere, you know, that

has been used to the detriment of SPMRs.

SUSAN: She won't. I mean --

ALWEN LYONS: I don't think James will ask her -- you
know, if he did, I think she could quite rightly

say, "My understanding is that that's one of the

things in the spot reviews that we're looking at;

so, you know, we'll get to it when we've gone and looked
at the evidence James". I think, you know, that's

where I would push her in that.

IAN HENDERSON: Okay.

ALWEN LYONS: I don't think she's going to start talking

about cases, to be honest.

RON WARMINGTON: Okay.

SUSAN: She's just desperate to try and get some

structure round it.

ALWEN LYONS: Yeah, yeah.

SUSAN: Alwyn, is there anything else you need from us

because I'm conscious --
ALWEN LYONS: No, I don't think so. I'm going to try
and put this together now and then get that over to

you, Susan.

SUSAN: Okay. That's fine.
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IAN HENDERSON: What time is the call?

ALWEN LYONS: 10.30.

IAN HENDERSON: Fine, okay. Well, if anything else

springs to mind, I mean, you know, contact either

Ron or I direct.

RON WARMINGTON: And we'll contribute our pieces of that

stuff to you tonight, Alwen.

ALWEN LYONS: Excellent, okay.

SUSAN: Okay. Thanks you for your help. Thank you

very much.

ALWEN LYONS: Bye.

RON WARMINGTON: Bye.

IAN HENDERSON: Bye.

(The call concluded)
FEMALE SPEAKER: There weren't lithium batteries in.
RON WARMINGTON: Okay.

FEMALE SPEAKER: Or Adrian's or the chemist or --
RON WARMINGTON: No, it's only Tesco's that do them,
I think. Not to worry, can we --

FEMALE SPEAKER: Have you met Becky's partner --

RON WARMINGTON: You met Becky?

FEMALE SPEAKER: -- from Winston, yes. I was coming out

RON WARMINGTON: Oh, that Becky.

FEMALE SPEAKER: Yeah, yeah. I was coming that
chemist --

RON WARMINGTON: That Becky, yeah, yeah, right.
FEMALE SPEAKER: And he said, "Oh, you don't want
another one of those dogs, do you?" I said no

but -- are you Winston's -- are you Becky's
partner?

RON WARMINGTON: Yes.

FEMALE SPEAKER: I said I've got one at home.

RON WARMINGTON: We know. We met him.

FEMALE SPEAKER: Oh, that's Harry.

RON WARMINGTON: Yeah, funny.

FEMALE SPEAKER: Then I went into the crop shop, "Oh,
saw one of these the other day, a lot younger than
him, white. We've looked for a tan". I said,

"yes, I think that's Winston".

RON WARMINGTON: That's Winston. How funny. Yeah.
Yeah. No, we're on the trail of Winston, eh?
(Descriptive noise) Laying in the sun there, look.
Okay, I've got to do some more work on the Post

Office now.

we

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FEMALE SPEAKER: All right. Shovel some dirt?

RON WARMINGTON: Mmm?

FEMALE SPEAKER: (unclear) dirt shovelling.

RON WARMINGTON: Dirt shovelling, yeah. Ian will call
in a minute. The whole bloody -- I spent the whole
bloody -- I had one more spot review but spelt the
whole day on the bloody phone dealing with the
management of the case. They want to get some
structure around it.

FEMALE SPEAKER: Bit late for that, isn't it?

RON WARMINGTON: As if it's unstructured.

FEMALE SPEAKER: What, who wants to control the Post
Office?

RON WARMINGTON: Yeah, they want to rein the costs in.
I mean, it's costing so much. Right, okay.

(Recording ends)