POL00000688
POL00000688
THE POST OFFICE GROUP LITIGATION
Claim Nos. HQ16X01238, HQ17X02637, HQ17X04248
IN THE HIGH COURT OF JUSTICE
QUEEN'S BENCH DIVISION
BEFORE THE HONOURABLE MR. JUSTICE FRASER
BETWEEN:
ALAN BATES & OTHERS
Claimants
-AND-
POST OFFICE LIMITED
Defendant
CORRECTIONS TO DEFENDANT'S WITNESS STATEMENTS
In the course of preparing for the Horizon Issues Trial, the Defendant has identified a number of
errors in its Witness Statements. The table below sets out the corrections required.
Johnson 1, paragraph 47.3 The reference to POL-0171713 should be POL-0444009
Johnson 1, paragraph 48.5 The reference to POL-0171713 should be POL-0444009
Smith 1, paragraph 16 This paragraph should read:
“Post Office introduced a case management system in
September 2018 that records each individual challenge to a
TC in-September-2048 raised via the NBSC helpline and, if
the FSC product team is currently working via case
management, passed directly to the FSC team for action.
Individual challenges to TCs were not recorded prior to this
and therefore it is not possible to state what proportion of
TCs have been challenged historically (or what proportion of
the challenges were successful) definitively. However, I
have spoken to various Team Leaders within the business
in order to gain a sense of proportion of TCs or Error
Notices that have been challenged in their departments
historically and what proportion of those challenges were
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successful (i.e. preventing issue of a TC or leading to a
change in the TC before eventually being accepted or a
compensating TC being issued). The following sections of
this witness statement are based on information provided to
me by the Team Leaders identified in the headings or when
no Team Leader is identified from information within my
own knowledge."
Mather 1, paragraph 8 ‘Post Office” should be "my team"
Mather 1, paragraph 15 "Post Office was able to use Credence" should be "Post Office
initially used Credence"
An additional sentence at the end of the paragraph should
be added "However, page 2 of the Helen Rose report shows
that the reversal ‘was not an explicit reversal by the clerk"
Mather 1, paragraph 16 End of paragraph 16 continues
"because, I understand from my colleaque Tracy Middleton
that the branch confirmed that the bill had been paid for by
a Lloyds TSB cash withdrawal for £80.00 and that the
branch only gave the customer change of £3.91."
Bogerd 2, paragraph 30 complimented" should be "complemented"
Bogerd 2, paragraph 32.3 "Audit Request Query data" should be "Audit Recovery
Query data"
Bogerd 2, paragraph 47 “against a 'ZZAUD' user" should be "against a 'ZAUD' user"
Bogerd 2, paragraph 56 "Horizon Service" should be "Horizon Service Desk"
Bogerd 2, paragraph 62 The reference to POL-0444069 should be POL-0511427
Bogerd 2, paragraph 63 The reference to POL-0444059 should be POL-0444075
Bogerd 2, paragraph 69 "11 May 2018" should be "11 May 2016"
Bogerd 2, paragraph 71 The reference to POL-0444060 should be POL-0511400
Bogerd 2, paragraph 72 This paragraph should read:
"Mr Patny is correct that on 23 February 2016, he
processed a MoneyGram transaction for £3,100 and the
customer's debit card payment for the transaction was
declined by the customer's bank. At this point the
transaction was committed and could not be removed from
the stack, therefore Mr Patny had to settle to cash. Process
is that the MoneyGram transaction should have been
cancelled on Horizon followed by a reversal of the
transaction. The data shows that Mr Patny cancelled the
transaction, however did not complete the reversal. This
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would result in the £3100 loss. MrPatry-saysthathe
ig
t-nil-_value,the-effect being that the £3,100-t i il}
howed-in-th ts—}-do-netk hether-th
te actually_paid i h—+ tnotas-f 7
+P ics peop:
Bogerd 2, paragraph 74 "The Moneygram transaction" should be "The MoneyGram
transaction"
Bogerd 2, paragraph 77 The reference to Peak PC0214226 should include a
reference to POL-0383868
Bogerd 2, paragraph 78 The reference to POL- 200000366 should be POL-0156821
Bogerd 2, paragraph 83 “At that time, Mr Tank" should be "Atthattime; Mr Tank"
Bogerd 2, paragraph 90 "The transaction data" should be "The transaction and event
data"
Bogerd 2, paragraph 90 Following documents should also be referenced
POL-0511359, POL-0511363, POL-0511367
Bogerd 2, paragraph 91.2 Paragraph should read “/n July 2015 there were two
transfers of £2,000 from the AA stock unit to the SP1 stock
unit, both of which were successful" should be "In July 2015
there were two transfers of £2,000 from-between the AA
stock unit to and the SP1 stock unit, one from the AA stock
unit to the SP1 stock unit and one from the SP1 unit to the
AA stock unit, both of which were successful"
Bogerd 2, paragraph 91.3 Paragraph should read "/n total there were 5 4-separate
transfers of £2,000 in August 2015, 4 (on the 1st, 3rd, 5th,
26th) all-of which were successfully transferred into stock
unit SP1 and 1 (on the 3rd) which was successfully
transferred into stock unit AA."
Bogerd 2, paragraph 98 The reference to POL-0444076 should be POL-0511446
Bogerd 2, paragraph 104 After the words "From Horizon's perspective, this would
have looked like a set of transactions relevant to a single
customer” it should read "However this had no bearing on
the failed recovery of the £150 cash withdrawal"
Bogerd 2, paragraph 117 The reference to POL- 200000366 should be POL-0030977
Bogerd 2, paragraph 122 The reference to POL- 200000355 should be POL-0030979
Bogerd 2, paragraph 122 The reference to POL- 200000352 should be POL-0030982
Bogerd 2, paragraph 126 The reference to C-0714-0000005 should be C-0000332
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Bogerd 2, paragraph 126 ‘On this basis, I cannot see that this shortfall gives rise to
any evidence of their being a problem in Horizon" should be
"On this basis, I cannot see that this shortfall gives rise to
any evidence of there being a problem in Horizon."
Bogerd 2, paragraph 128 This paragraph should read:
"The FSC customer account (i.e. the record of all branch
discrepancies, TCs, credits and debits on the
Subpostmaster's account) confirms that Mrs Stubbs chese
te settled this shortfall centrally_and-se-this doesnot appear
thought-to-be-the
ig
Bogerd 2, paragraph 133 The reference to C-0019-0000014 should be C-0000014
Bogerd 2, paragraph 145 "The first two of the TCs were issued as a result of the
branch over-stating" should be "The first two of the TCs
were issued as a result of the branch everunder-stating"
Bogerd 2, paragraph 145 "Those TCs were followed by evidence of the relevant over-
stated transactions" should be "Those TCs were followed by
evidence of the relevant overunder-stated transactions"
Bogerd 2, paragraph 158.3 "This change went live to all counters on June 26 2015"
should be "This change went live to all counters in August
2015-0n-June-26-2015'
Godeseth 2, paragraph 15 'this bug affected thirty branches, resulting in mismatches at
twenty" should be "this bug affected twenty nine branches,
with one branch being affected twice, resulting in
mismatches at nineteen"
Godeseth 2, paragraph 42 "60" should be "62"
footnote to paragraph 26.3.6 'SVM/SDM/PRO/0020" should be "SVM/SDM/PRO/0012"
Parker 2, paragraph 29 From the results I can determine that this was only carried
out in the following circumstances while Mr Roll was
employed by Fujitsu" should be "From the results I can
determine that this was only carried out in the following
circumstances in Legacy Horizon"
Parker 2, footnote to paragraph 30 I "PC0112293 {POL-0283845}" is duplicated and should be
"PC0107043" {POL-0278647}"
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