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Horizons Issues - Alan Bates & Others v Post Office Limited
Day 3
March 13, 2019
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March 13, 2019 Horizons Issues - Alan Bates & Others v Post Office Limited Day 3
1 Wednesday, 13 March 2019 1 now.
2 (10.30 am) 2 MRJUSTICE FRASER: Yes please. If it hasn't been uploaded
3 Housekeeping 3 wean use it in the old fashioned way, that’s not
4 MRHENDERSON: My Lord, a couple of housekeeping points 4 a problem.
5 first of all. 1 reviewed my notes for cross-examination 5 MR HENDERSON: Yes of course and I will hand it to the
6 overnight, particularly in the light of your Lordship's 6 witness in due course.
7 final observation of the suggestion that various points 7 MRJUSTICE FRASER: All right, I will just put that to one
8 be put to Mr Patny junior as well and I have taken the 8 side.
9 view that I don’t need to continue my cross-examination 9 On the basis that we're dealing with housekeeping
10 of Mr Patny senior. 10 generally, I was going to deal with this point at the
11 MRJUSTICE FRASER: Understood. 11 end of today but I will deal with it now anda similar
12 MR HENDERSON: So I have notified my learned friend 12 point came up in the common issues trial, or two similar
13 yesterday evening, but apologies for that slight change. 13 points cameup, but I will just explain what they are
14 MRJUSTICE FRASER: No, it is not an apology. So you don't 14 If you're going to be putting -- and youare of course
15 have any re-examination? 15 perfectly entitled to put certain matters which might
16 MRGREEN: Idon't, my Lord. 16 suggest criminal conduct, at an appropriate point the
17 MR JUSTICE FRASER: Let me just check if I have any 17 witness has to have the warning against
18 questions for him. Just give me one second. 18 self-incrimination. If you can just bear that in
19 (Pause). 19 mind -- it doesn’t have to be done at the very beginning
20 There was one minor point but it’s not worth having 20 of their evidence, it can be done at the stage when you
21 him back to ask him. So we're going to start withanew 21 get to that cross-examination, but can you just bear
22 witness today. 22 that in mind so that the warning has to be administered.
23 MRHENDERSON: I'm grateful. And just for your Lordship’s 23 MRHENDERSON: My Lord, yes.
24 information, I think we're on track in terms of 24 MR JUSTICE FRASER: You don’thave to tell_me in advance,
25 timetable 25 but each witness is potentially, if that’s going to be
1 3
1 MRJUSTICE FRASER: Don't worry about that. I have been 1 put to them they have to be given that warning That's
2 keeping an eye on that. Right, so Mr Green -- sorry, 2 the first point
3 you had some more housekeeping? 3 ‘The second point is as far as what we have called in
4 MRHENDERSON: No. 4 the common issues trial a hard start in terms of trial
5 MRJUSTICE FRASER: Have you got housekeeping? 5 timetabling, if you find yourself going quicker than you
6 MRGREEN: Only one thing just in case your Lordship wants 6 expected, that is not a problem. I am working on the
7 to see it. MrRoll wanted to clarify more precisely 7 basis that we will be starting with the Post Office
8 some points in his witness statement overnight and in 8 witnesses on Monday morning in terms ofa hard start for
9 accordance with what we did in the common issues trial 9 week 2. I am notin any way going to become intemperate
10 we have incorporated it into his statement so 10 or get upset if for example on Thursday at 11.30 or
ii your Lordship can see how it fits in 11 early afternoon you effectively run out of questions to
12 MRJUSTICE FRASER: Ifyou could hand that up that would be 12 ask the Post Office witnesses and the same applies for
13 excellent. Thankyou. So he is being called on 13 the witness of fact. We're basically doing this trial
14 ‘Thursday. 14 in self-contained weeks.
15 MRGREEN: Heis going to be called this afternoon 15 ‘Then the final point, which is really a point for
16 I understand because we're going to -- I understand 16 Mr Draper: I reviewed the transcript overnight, it
17 we're going to get to him this afternoon. 17 appeared to me that I came across as an exceptionally
18 MRJUSTICE FRASER: All right, fine 18 abrupt in at least two occasions in respect of the way
19 MRHENDERSON: Actually there was one final matter I was 19 you were cross-examining Mr Latif, that was really in
20 going to deal with during cross-examination but perhaps 20 the sense that (a) 1 was aware of the time difference
21 it is more convenient to deal with it now. There is 21 and (b) I was aware of the fact that he was on
22 a further document which is on its way on to finding its 22 a videolink from Pakistan, which is why 1 was probably
23 way to the trial bundle but isn’t there yet. So I have 23 a little more-- or I might have come across a little
24 hard copies again, I have notified my learned friend, 24 more acerbic about how long you were going to be and
25 but could I perhaps hand a copy up just for convenience 25 I don’t want you to read anything into that
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Horizons Issues - Alan Bates & Others v Post Office Limited
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MR DRAPER: I understand.
MR JUSTICE FRASER: All right?
housekeeping.
MR HENDERSON: My Lord, yes. Dealing with the first point
first which is the relevant warning, Mr Aakash Patny is
coming in this morning and I think out of an abundance
of caution it may simply be sensible to make the warning
So is that all the
wyAnRone
since we are talking abouta lot of declarations
9 MRJUSTICE FRASER: Right, okay. Do you have it with you,
10 Mr Green?
11°) MRGREEN: My Lord, [haven't brought it with me and
12 1 should have done this morning because your Lordship
13 didn’t have the wording yesterday. I apologise
14 MRJUSTICE FRASER: It will be in the White Book.
15 MRGREEN: We can find it on the transcript of the common
16 issues trial which we've got on Opus.
17 MRJUSTICE FRASER: Orit will be in volume 2. So you do
18 Opus, I will do volume 2 and we will see who gets there
19 first
20 (Pause).
21. MRGREEN: My Lord, I’mafraid you are going to beat me
22 because I can’t get back in from this Opus to what
23 1 have in chambers.
24 MRJUSTICE FRASER: I wouldn't give up so quickly, you don't
25 know how longit is going to take me to do it this way.
5
1 Just remind me of the section?
2 MRGREEN: Is it C8.11in - have we got it? My learned
3 junior Mr Miletic has found it in the transcript
4 MRJUSTICE FRASER: Oh, he has found it in the transcript
5 All right, then just call it up because I've got to
6 MRGREEN: So in the documents bundle
7 MRJUSTICE FRASER: Ihave found it, it is 9B, 10.42.
8 “Privilege against incrimination”, section 14. So if
9 you call up what! said last I think
10 (Pause).
11 MRGREEN: My Lord, I've got it at the wording that is
12 shall I just read it out to your Lordship?
13 MRJUSTICE FRASER: Where are you looking?
14 MRGREEN: So this is the warning your Lordship gave
15 Mrs Stockdale
16 MRJUSTICE FRASER: Why can'tit just be called up on the
17 screen?
18 MRGREEN: Itcan be called up on the sereen
19 {C8.11/24/50} and it is on internal page 196 and it
20 begins at line 6.
21 MRJUSTICE FRASER: Or line 7.
22 MRGREEN: Anditis line 10 where your Lordship explains
23 it
24 MRJUSTICE FRASER: Yes. Now, last time I said to the
25 witness what the specific offence was.
So it is
I'mnot sure
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that necessarily is required, so instead of specifying
that false accounting was a criminal offence I am going
to be saying what? “Certain facts and matters in
relation to your making of cash declarations”?
MR HENDERSON: Yes, “making declarations of cash and stock’.
MR JUSTICE FRASER: "Making declarations to the Post Office
regarding the cash and stock.”
MR HENDERSON: My Lord, yes.
MR JUSTICE FRASER: Right, well, I will do that at the
beginning.
Is that everything?
MR HENDERSON: Yes.
MR JUSTICE FRASER: Yes? Are you about to call another
witness?
MR GREEN: Iam, my Lord.
MR JUSTICE FRASER: Right.
MR GREEN: My Lord, lam calling Mr Aakash Patny.
MR AAKASH PATNY (affirmed)
MR JUSTICE FRASER: Thank you very much, Mr Patny. Have
aseat. CanI firstly say that you have been referred
to once or twice as Mr Patny junior, That's not meant
to be patronising or anything like that, it was just to
differentiate you from your father
Secondly, I’m now going to give you a warning which
you have heard debated. I think you might have been in
court yesterday?
AL Yes.
MR JUSTICE FRASER: So you would have heard a similar form
of words to your father. But it is just to tell you,
Mr Henderson is going to ask you some questions and some
of those questions are going to relate to certain facts
and matters relating to the declarations that you made
to the Post Office regarding cash and stock. Under the
Civil Evidence Act 1968 you have the right to refuse to
answer any of his questions if it would tend to expose
you to proceedings for a criminal offence or the
recovery of a penalty. So you might choose to answer
his questions but it is correct that I should warn you
you don’t have to answer any of them if you don’t want
to. If he asks you a question and you want to decline
to answer it, just say "I decline to answer that
question”.
AL Yes.
MR JUSTICE FRASER: Thank you very much, Mr Patny. Over to
you, Mr Green.
Examination-in-chief by MR GREEN
MR GREEN: Mr Patny, hopefully there is a bundle in front of
you and if you turn to tab 2 please (E1/2/1}
see there "Amended witness statement of Aakash Patny"?
A. It has Adrees Latif on it.
Is that fairly clear?
You will
Sorry, wrong tab sorry.
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March 13, 2019 Horizons Issues - Alan Bates & Others v Post Office Limited Day 3
1 Q That's it, if you're in tab 2 do you have "Amended 1 A. Mostly, yes.
2 witness statement of Aakash Patny"? 2 Q. Cash and stamps particularly?
3 A. Yes 3 AL Yes.
4 Q. Andif youturn very kindly to the back of that 4 Q. Butit is also right, and your father explained
5 statement, page 4 {E1/2/4} 5 yesterday that you sometimes shared log in IDs, is that
6 A. Yes 6 right?
7 Q. Doyouhave that? Andis that your signature? 7A. Sometimes, yes.
8 A. It is, yes 8 So I hope! can take this reasonably quickly. I don't
9 Q. Anddoyoubelieve the contents of the statement to be 9 want to go through with you the events of the outage.
10 true? 10 I discussed that with your father yesterday as you will
11 A. Yes. 11 recall, but can we look at F/1507.1} and can you enable
12 Q. Thank you very much. Would you wait there. ‘There will 12 editing and remove filtering
13 be some questions. 13 MRJUSTICE FRASER: What document is this?
14 Cross-examination by MR HENDERSON 14 MRHENDERSON: This is the event data think for the
15 MR HENDERSON: Mr Patny, good morning. 15 relevant branch and it shows -- well, can we go to
16 A. Good morning 16 row it is the event data spreadsheet. Can we go to
17 Q. I assume that you were in court yesterday when your 17 row 13904. We looked at this yesterday.
18 father gave evidence, is that right? 18 Mr Patny, it would help me-- when your father was
19 A. Yes. 19 being cross-examined yesterday were you able to see the
20 Q AndI don’t wantto go through everything with you that 20 documents on the screen from somewhere?
21 I said to him, but there are a few points I would like 21 A. No
22 to deal with. 22 Not particularly , okay, fair enough.
23. A. Okay. 23 So this is the day of the outage and this is the
24 Q. In particular I want to deal with various allegations 24 cash declaration that you made at the end of that day at
25 that you make concerning a shortfall, which varies in 25 19.04, Doyousee thar?
9 u
1 amount but which during May 2016 comes and goes, in the 1 AL Yes.
2 value of about £17,000. Do you recall that? 2 And below it we can see that there is a variance for
3 A. Yes 3 minus £1,138.21, do you see that?
4 Q. Andeventually it is right, isn’t it, that a sumof 4A. Yes.
5 around that sum of money was required by the Post Office 5 Q. And that suggests that there is less cash than you were
6 to be settled centrally. Do you recall that? 6 expecting to the tune of that figure?
7 AL Yes 7 AL Yes.
8 Q. Although it hasn't actually been paid to the Post Office 8 So based on that, do you agree that it is very unlikely
9 1 think? 9 that the outage that had occurred during that day was
10 A. No, it hasn't. 10 responsible for the discrepancy of £17,000?
11° Q. And that was towards the end of May or the beginning 11 A. No.
12 of June, something like that? 12 Why not?
13 A. Around that time, yes. 13. A. Well, that's a big amount tobe missing, isn't it,
14 Q. AndasI understand the case put forward by you and your 14 £1,000?
15 father is that this was caused by a bug or bugs in 15 Q. Yes, but it’s not £17,000, that’s my point.
16 Horizon, is that right? 16 A. No, it’s not £17,000, no.
17 A. I believe so, yes. 17 My understanding of your evidence is that you believe
18 Q. Andyour evidence is that the outage on 9 May's the 18 that the outage on 9 May led to the discrepancy of
19 start of the problems, is that right? 19 £17,000 which you discovered on 11 May.
20 A. Yes. 20 A. Yes.
21 Q Okay. And again -- and 1 think this is just covering 21 And what I’m taking you to is the position on 9 May on
22 ‘common ground and you have dealt with it in your 22 the day of the outage itself and pointing out that there
23 statement -- I think you are responsible for the 23 wasn't a discrepancy of £17,000 on that day. Do you
24 declarations in the branch, or you were responsible for 24 accept that?
25 the declarations in the branch? 25 A. Ido, but it is after 7 o'clock as well so that’s after
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1 polling time, so I don’t know if that could have been an 1 AL Yes.
2 issue as well. 2 Q. Andi can't see anything else after that that is a fresh
3 Q. Why would that have been an issue? 3 declaration on that day.
4 A. I’mnottoo sure. 4 AL Yes.
5 Q. Youdiscovered, or you tell us you discovered the 5 And I wondered why that was. I understood from your
6 shortfall on 11 May. Can we havea look at {F/1522.1) 6 evidence that you had been told to carry out a fresh
7 This is the help desk log and could we go to row 136 7 declaration, that you had done so?
8 So this is your call on 11 May, we see that from 8 OAL Yes.
9 column D and if we could just scroll right a little way. 9 Q. But that’s not recorded there?
10 Just pause there. So column N is what the operator is 10 A. I’mnortoo sure why.
11 told by you and you are saying: 11 MR JUSTICE FRASER: We saw a document yesterday with two
12 “Doing BP.” 12 cash declarations on, did we not?
13 What's "BP" there? 13 MR HENDERSON: We did. We're coming to that one later,
14 A. Balance period. 14 my Lord. That's a different date.
15 Q. Balance period: 15 So you can’t help me with what happened then, but
16 and got a shortage in cash £17,000. Had a rem 16 your witness statement suggests that you were told to
17 in of [46,500] .." 17 recount?
18 There's a typo there: 18 A. Yes
19 *. cash 16,000 coin” 19 You did recount and you sorted the problem out. ‘That
20 ‘And it appears from this document that that’s what 20 was my understanding. Is that a fair understanding?
21 you told the operator, is that right? 21 A. I believe I did, yes.
22 A. I didn’t tell them 16,000 coin. 22 Okay. So what I would have expected to see is on the
23° Q Okay. And then if wecarry onto column V this is what 23 events data that there wasa discrepancy, you found the
24 they told you to do, or suggested that you do: 24 money and it was corrected?
25 “Asked the.” 25 A. Yes.
13 15
1 It_ must be postmaster: 1 Q But that’s not shown there.
2 ”.. to make sure only one cash declaration and make 2 A. I’mnottoo sure why that’s not shown there. I remember
3 sure rem was scanned in correctly ” 3 we went through quite a few steps, I had to readjust
4 So essentially what you were being told, I think, is 4 various things and then eventually it seemed okay and
5 that you need to check that you have counted the cash 5 I carried on.
6 properly, is that right? 6 Q. Okay.
7A. Yes ‘7 MRJUSTICE FRASER: When you said you found the money, does
8 Q. Now, if we go back to -- apologies for all the dotting 8 that mean after you did those steps, the physical amount
9 around, but if we go back to 1507.1 {F/1507.1} and if we 9 of money
10 could go to row 14515. 10 A. After I did the physical steps it seemed that everything
a1 Just while that is being brought up, Mr Patny, your 11 was in order so I carried on.
12 evidence in your witness statement is that what the 12 MRJUSTICE FRASER: So there was no longer a discrepancy of
13 helpline told you to do was to readjust the cash stock 13 17,0002
14 figure; do you remember that? 14. A. No.
15 A. Yes. 15 MRHENDERSON: When you say “the physical steps”, can I just
16 Q. Andby that I understand you to mean that you needed to 16 repeat his Lordship's question: do you mean that you
17 carry out a fresh declaration? 17 found the money?
18 =A. Yes. 18 A. I didn’t find no moneyassuch. It said it seemed to
19 Q. Andyou sayin your -- or at least I think you say in 19 me that everything was in order, there was no
20 paragraph 10 of your witness statement {E1/2/2} that 20 discrepancy, so I carried on.
21 that resolved the problem? 21 Q But! meanyouare carrying out a physical count of
22 A. I believe it did, yes. 22 money, aren't you?
23° Q. Okay. And1 just wanted to havea look at 1451Sbecause 23 A. Well, after the various adjustments that we did it
24 as far as -- if welook at 14515 that’s the discrepancy 24 seemed that everything was okay.
25 on 11 May for £17,000, do you see that? 25 Q. Whatadjustments were they then?
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A. [can’t remember. There were various things that they
made me go over the phone on
MR JUSTICE FRASER: Could you maybe keep your voice up,
Mr Patny.
A. Sorry,
MR JUSTICE FRASER: So whatever steps they told you to do
over the phone, you did them?
A. Yes.
MR JUSTICE FRASER: And were they steps to be taken on the
Horizon terminal?
A. It was, yes.
MR JUSTICE FRASER: Right, okay.
MR HENDERSON: But you didn’t make any fresh cash
declaration?
A. I can't remember.
Q. Let's look at the cash management report for your
branch, Again we looked at this yesterday with your
father, so I can hopefully take it reasonably quickly:
In (F/1514.1}- actually just before -- it might be
quicker if I take a further reference in this document
before we leave it, do you mind? Could we go to 15030
in this current document, just to speed things up.
MR JUSTICE FRASER: Where are we going now? 15030.
MR HENDERSON: 15030. And this, Mr Patny, is a cash
declaration on 13 May, a further declaration, and you
7
see in 15029, do you see that you declare cash for
a little over £80,000? Do you see that?
MR JUSTICE FRASER: Where?
MR HENDERSON: 15029, “Declare cash total 80,000"?
AL Yes.
Q. And then below that the variance check discrepancy is
plus 17,000-odd, do you see that?
AL Yes.
Q. So that appears to cancel out the previous discrepancy,
doesn't it?
A. It does. Yes.
Q. So just pausing at this point, as far as the branch is
concerned and as far as these records are concerned,
there is no longer a cash problem, is there?
A. Is this saying that it is £17,000 up now, or is it
saying that --
Q. I think that that is saying that whereas before you were
minus 17, you're now on this one plus 17 so you're
cancelling each other out?
‘A. Well, if it was cancelling it would be zero, wouldn't
it?
Q. Well, I think
MR JUSTICE FRASER: You might want to just take instructions
to be absolutely clear
MR HENDERSON: I'm told thatis right, whatI have said.
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MR GREEN: Sorry, what?
MR HENDERSON: So my understanding is that the discrepancy
that is shown here has the effect of cancelling out the
previous minus figure, effectively
A. But then that would be zero, wouldn't it, it wouldn't be
17-
Q. Well, the overall net position would be zero, yes.
A. But then that’s what that would show there.
I'm suggesting that it wouldn't, that what this is doing
is taking a later comparison on the information that was
available to it before, which will include the previous
cash declaration, and is saying that compared to that
position it’s £17,000 up?
‘A. But when you are doing the cash dees every day it tells
you a running total of whether you are up or down which
is what you're showing there, so if that in essence
would mean we are now £17,964 up, which is — well, that
means I've found £34,000 all of a sudden from the day
before
Q. Myunderstanding is that’s not the right position. I’m
sure you can keep a running view of it as well, but that
what this line demonstrates is as I have previously
said.
(Pause).
A clearer way of putting the point. You are 17,000
19
down onthe 11th, you roll the branch, that’s the
starting position, this is the result of the latest cash
declaration which is 17,000 up and the net position is
to balance broadly.
A. Okay. But like I said, the previous cash dec was after
7 o'clock so as far as I'm aware before 7 o'clock all
discrepancies or whatever would have been done before
7 o'clock would have rolled over. I” mnot 100% certain
on that but that’s what
MR JUSTICE FRASER: I'm not sure Mr Henderson necessarily is
to be honest.
When you say “roll the branch” would you like to put
to the witness exactly what you mean by that because we
had quite a lot of evidence about that before Christmas.
MR HENDERSON: Well, I believe the position is that the
position you have reached on the 11tha rolled
forward
A. Yes.
and then when you take the next declaration which we
are looking here on the 13th -- I can’t quite recall
what happened on the 12th, but anyway on the 13th-- it
takes that rolled forward position as the starting
position and it measures it against that?
A. Yes.
MR JUSTICE FRASER: And your case is that that line in 15030
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1 means there is no discrepancy, is that correct?
2 MR HENDERSON: Yes
3 MRJUSTICE FRASER: Right. That's what's being put to you,
4 Mr Patny, that as at the 13th there should be no
5 discrepancy.
6 A. Yes
7 MR HENDERSON: Cash has been found, in other words,
8 A. But like I say the previous day’s was done after
9 7 o'clock so whatever I declared before 7 o'clock would
10 have been taken, so if I had declared zero,
at for instance, before 7 o'clock, that’s -- from my
12 understanding that’s what would have showed the next
13 day. Because the minus 17,000 you have shown me has
14 happened at 19.04 which is after the polling time.
15 Q. Let’s have a look at what I’m suggesting may be the
16 explanation which was the document I was going to go to,
17 which was (F/1514.1}. And this has got some rows
18 highlighted. This is the cash management report for
19 your branch on various days and if we could just scroll
20 right until we can see the Mcolumn, you can see that on
21 10May-- do you see that, which is row 382, do you see
22 that?
23 A. Yes.
24 Q. There is £16,070 worth of £10 notes, do you see that?
25 A. Yes
21
1 Q. And then we know -- I don't need to take you through
2 that, but we know that there's £16,000 worth of £10
3 notes remmed in on 11 May, do you recall that?
4 A. 1 believe there was. I wasn't there when the remming in
5 happened.
6 Q. No, but that's your father’s evidence and we have looked
7 at that.
8 So what you would expect on the 11 May at the end of
9 the day is that there would be roughly £32,000 worth of
10 £10 notes, less any notes which you had paid out?
11 A. Yes.
12 Q In fact wecansee that there’s only 22,130, do you see
13 that?
14 A. Yes.
15 Q. Which seems strange?
16 A. Slightly, yes.
17° Q. Andagain I went through this with your father. We know
18 that there's no further £10 notes remmed in on the 12th
19 or the 13th, but if you look at those entries, on the
20 following day you have gone up by £15,000-odd, do you
21 see that?
22 A. Yes.
23 Q. Now, that suggests, doesn't it, that at around this time
24 there was some sort of problem with counting cash, but
25 it was resolved, you found the cash somewhere? Perhaps
22
it had been put in a safe
a. possibility ?
A. I'mnotsure.
Doyou think that's
It potentially could be, yes.
So doing the best that wecan at this stage, looking at
all the records that we've got, it doesn’t look as
though there is a problem with £17,000, does it? It
looks as though any problem with the cash has now been
resolved.
A. No, because the cash dec still shows £17,000 in plus,
doesn't it, so ..
Q. Okay, well, we have been through that.
Let me--
MR JUSTICE FRASER: Are you moving off that point?
MR HENDERSON: I'm moving off that.
MR JUSTICE FRASER: Right. I just want to be clear about an
important point that Mr Henderson has been exploring
with you round the edges and I just want to be
absolutely clear that I understand what your evidence
is.
A. Yes.
MR JUSTICE FRASER: When you thought you were £17,000 down
and you went through the steps on Horizon, did that lead
to you discovering physical cash of £17,000
A. No.
MR JUSTICE FRASER: -- elsewhere -- just wait for me to
23
finish -- which you hadn't counted before?
A. No.
MR JUSTICE FRASER: It didn’t.
A. No.
MR JUSTICE FRASER: So when you say in different places in
your evidence "It all looked okay” or “It all worked
out", whatis it that you mean please?
A. From whatI understand is when I did my
MR JUSTICE FRASER: From what you can remember.
A. Yes. When I did the various adjustments online at the
end of it there looked like there was no discrepancies
at all.
MR JUSTICE FRASER: In terms of information ona screen.
A. Yes, they had made me change various things and that
made it okay.
MR JUSTICE FRASER: All right
mean what?
And by "made it okay” you
A. The discrepancy wasn't something that -- well, wasn’t
alarming, as such.
MR JUSTICE FRASER: Right. Over to you.
MR HENDERSON: My Lord, just to be clear, the Post Office's
case is that there were various declarations and various
steps taken and at this period it resulted in no
problem.
MR JUSTICE FRASER: Well, it depends how you define
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“no problem”, Mr Henderson. The way you were putting it
seemed to suggest, in at least two questions, that money
had been discovered physically and that’s very important
and that’s why I needed to clarify what his evidence
was.
MR HENDERSON: I understand.
MR JUSTICE FRASER: Because if you roll them up in terms
that can be open to misunderstanding the evidence won't
wyAnRone
9 necessarily be very clear for me.
10 MR HENDERSON: I understand, my Lord,
11 MR JUSTICE FRASER: I know what the Post Office's case is,
12 1 think
13 MRHENDERSON: I understand.
14 I just wanted to ask you about something on document
15 {F/1834.3] and this is a separate point, I think, and
16 again I touched on it with your father, but let_me just
17 ask you. If you could go to sheet 1 and then row 2336
18 and this is the point your Lordship mentioned this
19 morning when there are two cash declarations one after
20 the other.
21 MRJUSTICE FRASER: And what are we calling this document?
22 MRHENDERSON: This is the events spreadsheet.
23 MRJUSTICE FRASER: The events data spreadsheet?
24° MRHENDERSON: Yes.
25 Do yousee that, MrPatny? Row 236?
25
1 AL Yes.
2 Q. Actually 2336. So this is 17 May 2016 and there's two
3 cash declarations only seven minutes apart but for
4 a significant difference , do you see?
5 AL Yes.
6 Q. About £16,000 difference. Now,I think -- do you accept
7 you made these declarations?
8 AL Yes.
9 Q Andagain -- and don’t need to turn this up I don't
10 think, unless you want me to, but we looked yesterday
11 with your father that the transaction data shows that
12 all that had happened between those two times was a
13 A. £300dee.
14 Q. -- £300declaration? Okay. Can you explain how that
15 can happen in that way, that there can be two
16 declarations so close to each other for such differing
17 figures?
18 A. FromwhatIcan see there that I must have been £16,000
19 up for some reason, I have entered in the wrong figure
20 and after when I have changed it it has come to the
21 secondone. I mean that was sometimes when you were
22 entering figures sometimes you could enter them in wrong
23 and, you know, you would end up with a massive gain or
24 a loss and then when you went through and re-entered
25 them again it would come toa more correct figure.
26
eIAHkYOnE
2
>
oropr
When you say you re-enter them again, would that involve
physically counting cash again
Sometimes.
-- or checking the piles of cash or whatever it is
you're doing?
Sometimes, but sometimes it could just genuinely be
a case of, you know, as you're rushing through pressing
tab keys -- you have to bear in mind we were serving
customers whilst we were doing this as well. It was
a fairly busy branch after closing times -- well,
general post office closing times are half past five;
because we were one of the very few in the city that
were open after 5.30 so we would get customers coming
from all around, other side of the city coming to us
because they knew there was a post office open, so as
you're rushing through sometimes you didn’t tab
correctly and you would end up instead of writing 20,000
£20 notes you could add the £10 notes of say 10,000
£10notes into that as well so you could end up with
40,000 in £20 notes. Just a minor mistake can cause
Okay. I just wanted to ask you a few questions about
the phone call you had from Debra Lambley, do you
remember this, from Chesterfield about stamps?
Yes.
Again, this wasa call that was prompted by a concern
27
that you had that you had declared a much higher value
of stamps than you could conceivably have been holding
onto, is that right?
Yes.
And that was a declaration that you made?
I never made the declaration of the stamps. I don’t
know how they got there.
Who made the declaration of stamps then?
I did the declaration of stamps, but I never put that
much in, I don't know what
I'msorry, I didn’t hear. You said you made the
declarations --
I declared the stamps but I never entered in that amount
on the £1.09 stamps or whatever that was that caused the
increase
Well, let's havea look at that this. Well, just before
I do that, you were the only one who declared the
stamps?
Yes.
The figure for the declared stamps was ~ we will come
to it, but it’s £18,000. Everyone agrees it is wrong.
Yes.
Can you explain how that came to be wrong?
No.
Isn't it possible that you just made the sort of error
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1 that you have just described to me? 1 AL Yes.
2 A. No. 2 Q. And it stays at that sort of level until 25 May, the
3 Q. Whyis that not possible? 3 following week, and it goes downto 1,551. So there has
4 A. Because you would - when you entered in the stamps - 4 obviously beena mistake here, hasn't there?
5 with cash decs, for example, you have to go through all 5 A. Not by me there's not
6 of it at the end and then see your variances. With 6 How can you be so sure it is not by you? Noone is
7 stamps are you literally just enter them in and then 7 saying it’s the worst mistake to have made, but there
8 a report is printed out saying "You have said this much 8 has been a declaration of stamps in the branch which has
9 is in there", so 1 would have seen at this point I'd put 9 been inaccurate.
10 in £18,000 worth of stamps. 10 A. Yes.
11 Q. But it’s still possible to make a mistake in that 11 Q. It has been picked up by Chesterfield and business as
12 process, isn't it? 12 usual, they have said "You need to sort it out”, you do
13 A. Sometimes, yes, if I didn’t check it correctly. 13 sort it out and that’s what happens. Why do you say
14 Q. Andisn’t it overwhelmingly likely that that’s what 14 that that’s a bug in Horizon?
15 happened here, you made a mistake in declaring the 15 A. Because after I've sorted it out, it’s stayed there.
16 stamps which was picked up and corrected? 16 I'msorry, I didn’t hear?
17 A. Okay, but then the same issue has came back, so 17 A. After I'd sorted it out, the issue has stayed there,
18 1 couldn't make the same mistake twice, could 12 18 hasn't it, it has gone back up to that many stamps up?
19 Q. Well, let’s look at it. Let’s look at the call log 19 So why would I change it down and then change it back
20 first of all at {F/1522.1}, row 138. If you just go 20 again? I'd understand you said that I'd made the
21 right to column N: 21 mistake the first time, but I couldn't make the mistake
22 “Call today from Chesterfield and £16,000 adjustment 2.2 again the second time, could 1?
23 now down in the office.” 23 Q. I don't quite understand the point you're making?
24 Not quite sure exactly what that means. 24 A. I’msaying you're saying I potentially could have made
25 “Activity: declarations and adjustments” and if you go 25 a mistake the first time. If 1 did make a mistake the
29 31
1 right a couple more, you were told to balance the stock 1 first time, fair enough, but I couldn't make the same
2 unit, weren't you? 2 mistake again, could 1?
3 A. Yes 3 Q. This just suggests that stamps are being declared at the
4 Q. Whichis essentially recount, isn’t it? 4 same sort of level for that week until 25 May andit is
5 A. It wasenter in all the figures again, that’s what 5 then corrected, isn't it?
6 I counted it as. 6 A. Yes, but the stamps issue came back.
7 Q. That's what! mean, yes. And if welook at the events 7 When?
8 data spreadsheet for the declaration of stamps, that's 8 A. The following week. After I adjusted them they still
9 at (F/1507.1}. This has been filtered and we can leave 9 went back up. Debra had to phone me twice.
10 the filtering on for present purposes because this is 10 MRJUSTICE FRASER: It might help if you did some of this by
11 what we need. 11 reference to his witness statement, Mr Henderson. We
12 MRJUSTICE FRASER: Whatisit filtered , just to show the 12 are having a lot of "I don’t understand”,
13 stamp declaration? 13 MR HENDERSON: 1 apologise, my Lord.
14 MR HENDERSON: The stamp declaration I believe, yes. 14 Well, I don’t understand and apologise for that if
15 MR JUSTICE FRASER: Well, that is how it has been filtered ? 15 it is myerror, but are you saying that you carried out
16 MRHENDERSON: Yes, itis, my Lord. 16 a declaration which took it down, took the value down
17 So the reason the rows aren't sequential is because 17 and it went back up again?
18 it has been filtered , Mr Patny, okay? But if you look 18 A. Well, yes. Debra-- sorry, I have forgotten her
19 at the dates you can see that there is reasonably 19 surname.
20 regular stamp declarations, generally once a week. If 20 Q. Lambley! think.
21 you look at the 11 May one, stamps are declared for 21 A. Debra Lambley phoned in the morning, spoke to my father.
22 1,633, do you see that? 22 When Icame inI spoketo her. She made me readjust
23° A. Yes. 23 them down and what she made me do was very complicated,
24 Q. And then they go up to £18,000, which we all agree is 24 she made me go into areas of Horizon I could never dream
25 wrong] think? 25 of going into andthen this issue of the extra stamps
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1 came back after I had done that, so then she’s had to 1A. Well, if she didn’t know what we had in the branch then
2 phone me again the following week and her words were 2 how did she know we were £18,000 up on stamps then?
3 “Why have you changed them back?” and I said 3 Q I think the point about that is it is just
4 “I haven't” 4 an extraordinarily high amount which everyone accepts
5 So in answer to your question I could have made 5 would not be the number of stamps ina branch of your
6 a mistake the first time, okay potentially I could have, 6 sort?
7 but then why would I make the same mistake a second 7A. Well, then you can’t have it in -- you're talking
8 time? 8 hypothetically in her defence but talking factually in
9 Q. So what you have said -- if you look at your witness 9 mine, aren't you?
10 statement in paragraph 13 (E1/2/3}, you say: 10 Q No, because! think it is agreed, isn’t it, that you
11 "She told me it was showing the branch had 11 didn’t have anything like £18,000 --
12 overdeclared the amount of stamp stock that was held.” 12 A. No.
13 ‘And we have gone through that? 13 Q. -- worth of stamps in your branch?
14 A. Yes. 14 A. No, wedidn't
15 Q. "Ms Lambley told mel had to adjust the stamp stock on 15 Q. Youdid have that number?
16 the system.” 16 A. Wedidn't.
17 ‘And you say that you did that 17 Q. Youdidn't, okay. So what happens isa process whereby
18 A. Yes. 18 it is adjusted froma high figure that’s been wrongly
19 Q. All right, that’s not shown in that declaration that we 19 declared to the correct figure?
20 just looked at? 20 A. Yes. And Debra has agreed at that point that everything
21 A. But she checked it on her side and said that everything 21 is okay.
22 was fine as well 22 Q. Okay. Well, I don’t think I can take that any further
23 Q. And then you say you rang the helpline and said that 23 for now.
24 they had given incorrect advice and you had to readjust 24 MRJUSTICE FRASER: Can I just check what was your
25 the stamp stock? 25 understanding of “everything is okay”, just in terms of
33 35
1 A. No, when I rang the helpline that night I was £16,000 1 what's shown and what your understanding was?
2 short and they made me do various adjustments to make it 2A it is. Debra has checked onher side that the
3 okay again and what this has done is somehow the stamps 3 correct amount of stamps are now in holding and
4 have gone back up and Debra has had to ring me again the 4 everything is fine with our branch, but if you have
5 next week. So then as I was answering your original 5 a look the stamps clearly wasn't reduced down but she
6 question, if 1 made the mistake of entering extra stamps 6 has verified that everything was okay and from my side
7 the first time, I haven't definitely done it the second 7 I verified everything was okay and followed what she
8 time, have I? 8 said.
9 Q Well, I accept it is unclear, Mr Patny, but what appears 9 MRHENDERSON: I want to ask you now, Mr Patny, about the
10 to have been the case according to the stamp 10 MoneyGram transaction. Do you remember this one?
11 declarations is that there was a problem which persisted 11 A. Yes.
12 for a week and then was corrected 12 And your complaint here is that you had a MoneyGram
13 A. But it hasn't corrected though. 13 transaction for money to be sent in the amount of
14 Q. Well, it was corrected on 25 May. 14 £3,100. That transaction didn’t go through, it was
15 A. Onthe day -- Debra rang methe first day, she has 15 cancelled and retried, didn't go through again
16 corrected it. Theissue has persisted, she has rang me 16 A. Yes. The actual transaction wasn't cancelled, just the
17 again a couple of weeks - well, a week anda half later 17 debit card.
18 and she has made me do the same thing again. 18 Q. Okay. Andyousay that youhada shortfall of exactly
19 Q. Andis it possible that you hadn't properly followed the 19 £6,200?
20 instructions that you were given by her over the phone 20 A. Yes.
21 at the time? 21 Q So just to understand what had happened, to make sure
22 A. No, because Debra checked it on her side and said that 22 I have understood this properly, presumably someone
23 everything was okay. 23 comes in, wants to carry out a MoneyGram transaction,
24 Q. But she wouldn’t know what stamps you had in the branch, 24 you put it onto the stack on the screen, you then try
25 would she? You would have to count it properly? 25 and clear the customer's card and it is declined?
34
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SIYIAHRONKE
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AL Yes.
Q. But by which stage you have already got it on your stack
and you have to do something with it in order to balance
the books, if I can just put it in that way?
AL Yes.
Q. Okay. So can we first of all look at the transaction
data which is at (F/1436.1) and if we goto sheet 1 at
the bottom please and enable editing and row 1067.
Thank you. So this is, I believe, the transaction. Do
you see that £3,100?
A. Yes, I do.
Q. And what we see is a -- we see two appearances of
£3,100, but that's a single transaction, yes?
AL Yes
Q. But what we don't see at around this time is a second
entry for £3,100. Wedonotsee that. Your evidence
effectively is that we should see that because you say
that this caused a problem of £6,200.
A. No, but from -- what we used to do with MoneyGram, the
procedure was you cash it through, so you cash -- say it
has gone through and then you cancel it at that point
I have done that correctly, but the Post Office had
changed the procedure in December which I wasn’taware
of that you had to cancel it on the back office as well
at that point, so I've never cancelled it there, so that
37
was still hanging.
Q. Okay. That's whatI wanted to come to. So you are
Could
this is the document
absolutely right, there is a two-stage process
I just hand this document to the
I handed up to your Lordship earlier. Apologies,
Mr Patny, for the paper. This is finding its way into
the electronic form.
This is the procedure which was online and this is
an operational update, as you will see, from
19 October 2015. Do you see that date in the top left?
A. Yes.
Q. And this is the procedure for dealing with the situation
that had arisen and if you look at page 4, and you have
just described it I think, it says:
“The refund cancella
ion process for MoneyGram has
changed ..”
MR JUSTICE FRASER: Whereabouts are we, sorry?
MR HENDERSON: I'm so sorry, my Lord,
this clip, the fourth page.
the top.
MR JUSTICE FRASER: It says "Page 4” on the top?
MR HENDERSON: 4 of 4 on the top left, yes
It says:
“If a customer wants to cancel their transaction and
“s the final page of
It says "Page 4 of 4” at
obtain a refund on the same day you must go through the
38
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WIAHRWNE
©
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
MoneyGram refund button to cancel the transaction. You
then need to use the back office reversals process to
reverse out the transaction.”
And that's the point you are just making, isn’t it?
>
Yes.
2
So you were supposed to follow a two-stage process which
is cancellation and reversal?
A. Yes.
Q. And you just did cancellation
A. Yes.
Q. ~ not reversal?
A. No.
MR JUSTICE FRASER: “No” as in you agree you didn't do
reversal
A. Yes, I agree with what ..
MR HENDERSON: And that procedure, that was part of the
Horizon Online guidance at the time.
MR GREEN: Well, I’m sorry, my Lord, it should be pointed
out to the witness the date of the document that’s not
on Opus yet but we have just seen. The date of this
document is “Operational updates of 19 October 2015", so
it is fair to -- because you can put something in front
of someone and it may influence their confidence about
what they can remember.
MR HENDERSON: Okay. In any event you now accept that there
39
‘was a two-stage process
A. Yes.
that in an ideal world you would have followed, which
is cancellation and reversal
A. (Nods)
And you rang the help desk, didn't you, in relation to
this?
A. I did, yes
Q. Let’s have a look at {F/1522.1}. If we goto row 115.
MR JUSTICE FRASER: Is this the call log?
MR HENDERSON: Yes. Thisis your call -- do you see this ,
Mr Patny? This is 23 February 2016, at column D, and if
you go across and then just pause there at N, column N,
you said
“Debit card declined for MoneyGram, how to clear.”
So you had rung to ask what to do about this?
AL Yes.
And then you go across and the advice was” settle to
cash and then cancel and reverse”
AL Yes.
Q. So you were told you did need to reverse it but for
whatever reason you didn’t understand that or you didn’t
do it, but in any event you didn’t reverse it?
A. I didn’t reverse it at the time of the transaction but
I reversed it when the helpline helped me through it
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Q. Well, according to Post Office it was never reversed,
It was only cancelled, not reversed.
A. Sorry, are you on about the 7 o’clock phone call here or
the 12 0'clock phone call?
MR JUSTICE FRASER: This phone call is -- well, let's go
back to the left-hand side and we will see the time,
Could we go back to column A. This is at 12.50.
wyAnRone
A. Sorry, I was talking about when I rang them later on in
9 the day.
10 MR HENDERSON: You rang them later on in the day?
11 =sA. Yes.
12 Q Well, I had understood you to say before in your
13 evidence that you accepted that you had not reversed the
14 transaction?
15 A. No, I hadn’t reversed it in the back office, no.
16
17 A. I did after I spoke to the help desk, who they told me
2
Are you saying that you did reverse it in due course?
18 I had to reverse it at the back office.
19 Q. Okay. Soas far as the data is concerned and as far as
20 the Post Office is concerned you did not reverse it.
21 You did cancel it
22 A. Yes.
23. Q. Butyoudid no not reverse it?
24 A. No.
25 MRJUSTICE FRASER: At 12.50.
al
MR HENDERSON: Atall.
A. As the transaction took place I believe at midday,
I cancelled it, I never reversed it at that point.
I reversed it in the evening when I did my cash dec and
saw I was short and I reversed it after speaking to the
NSBC[sic] because at that point I was still unaware that
I had to reverse it on the back office. Reversals take
OYA HR YN
place on the back office, cancellations was on the front
9 office
10 Q. Mysuggestion to you, Mr Patny, is whether or not you
11 understood the process, as a matter of fact you didn’t
12 effectively reverse the transaction?
13. A. I didn’t reverse it when! should have, but I did later
14 on.
15 Q. Okay. I’mjust being clear, I am saying you didn’t
16 succeed in reversing the transaction at all?
17 A. Butwedid, we reversed it later on, didn't we?
18 Q. Well, as far as the evidence the Post Office can see
19 that didn’t happen. It did cancel, didn't reverse?
20 A. It did cancel and it did reverse but because that’s
21 after -- once again, after 7 o'clock, the issue was the
22 day's data had been polled so I have effectively it
23 doesn’t look like I have done it on that day, where in
24 terms of date I have but for business dates I haven't
25 done it on that date
42
eIAHkYOnE
MR JUSTICE FRASER: And you think there's a second phone
call, did you say?
A. Yes. That's here, this quarter past 7 one, that’s the
second phone call
MR JUSTICE FRASER: When you say “that's here”, what are you
pointing out?
A. 116is it? No, sorry I saw it -- if you scroll across.
There, 116, “Cash dec £6,000 short due to MoneyGram”.
That took place at quarter past 7.
MR HENDERSON: Okay and you say “Short due to MoneyGram
refund did not do the existing reversal ”
A. Yes.
Okay. And carry on across. Just look at 117 below
that, what does that involve, “Cancellation refund”?
Can we just go back to the beginning of 117. And can
you go across from 117. Here youare ringing again
saying:
“Asking if the discrepancy has been resolved yet
waiting for a TCto be issued - had failed to reverse
a [MoneyGram] for £6,000 that was cancelled on the same
day as having been sent”
A. So the next day when I rang up I have asked “Where's
the TC?"; I wasn't aware that a TC took several days to
come.
Q. Okay, but there is a single transaction here of £3,100?
43
AL Yes.
Q. Right. The process is it needs to be cancelled and
reversed?
A. Yes.
Q You only cancelled it?
AL Yes.
Q. You then think you may have reversed it?
A. I did reverse it, as youcan see there, quarter past 7
in the evening.
Q. Well, on 117 it says that it had failed to reverse
‘a MoneyGram for 6,000, which is not right, it’s
‘a MoneyGram for 3,100?
AL Yes.
And can we carry on going across on 117. Okay, so doing
the best we can, MrPatny, and I appreciate these things
are not as straightforward as they could be, it looks as
though there has been a transaction for £3,100
Yes.
-- which has not been reversed properly?
At the time
oPropr
In other words you need a transaction correction for
£3,100?
A. Wedo, yes.
Q. And just to be quick about it, you in fact receive
a transaction correction for £3,100, don't you?
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1 A. Wedb, several days later, yes 1 were accurate to the best of your knowledge?
2 Q. Yes, several days later. But your complaint is that you 2 A. I tried to, yes.
3 ‘were £6,200 out-of-pocket, is that right? 3 Q. Anda declaration of stamps -- you remember the £18,000
4 AL Yes. 4 declaration of stamps, was that an attempt by you to
5 Q. And what you say in paragraph 20 of your first witness 5 disguise a shortfall of cash?
6 statement (E1/2/4}. What you have said in paragraph 20 6 A. No.
7 is that you thought it was strange that it was exactly 7 I suggest it may have been. I suggest it was, Mr Patny.
8 double the amount of the problematic MoneyGram 8 You deny that?
9 transaction. Do you see that? 9 A. I do, yes.
10 A. Yes. 10 Q. I suggest finally, MrPatny, it is rather surprising,
11. =MRHENDERSON: My Lord, I just wondered -- this is going to 12 given that youdo all the balancing, or did all the
12 take a little while. 1 wonder if it mightbe sensible 12 balancing in the branch, that you don't understand that
13 to havea brief break now? 13 the effect of increasing the declaration of stamps is to
14 MR JUSTICE FRASER: Very good idea. 14 have a corresponding effect on the declaration of cash?
15 We're going to have a short break. Today it is 15 A. I wasn’t aware of that, no.
16 going to be seven minutes long. It is for the shorthand 16 Q. All right. So let’s go back to the MoneyGram
17 writers just to havea break from transcribing 17 transaction and just to remind you where we had got to
18 everything word for word. Because you are in the middle 18 with that, there’s a transaction for £3,100, you recall
19 of your evidence you're not allowed to talk to anyone 19 that?
20 about the case but you don’t have to stay in the witness 20 A. Yes.
21 box. Feel free to move, go out, stretch your legs. 21 Q. And you say you reversed it effectively ?
22 If everyone could be back in at quarter to. 22 A. At thar point, or ..2
23 (11.38 am) 23° Q. Well, my understanding is that your evidence was that
24 (Short Break) 24 you did reverse it properly?
25 (11.46 am) 25 A. Eventually I did, yes.
45 47
1 MRHENDERSON: Mr Patny, I want to just ask you a couple 1 Q. Separately from the transaction correction?
2 more questions about the stamp situation before I come 2 AL Yes.
3 back to the MoneyGram situation that we were dealing 3 So you both reversed it and you received a transaction
4 with before. 4 correction?
5 Do you agree with this, that if a declaration of 5 A. Yes.
6 stamps goes up, the cash position is automatically 6 That makes you £3,100 up, doesn’t it?
7 decreased, isn’t it? 7 A. No, because the reversal happened on the wrong
8 A. I'mnotsure. I don’t know that. As in do you mean for 8 day --well, on the wrong business day, because once
9 overall, or holding 9 again if you have a look at the call log, I spoke to
10 Q. It automatically happens, doesn’t it, that as the 10 them at quarter past 7 and they told me to do this,
a1 declaration of stamps goes up, the cash position will go 11 7 o'clock is polling. So it would have polled as the
12 down? 12 £6,200 short for the day.
13° A. I don’t see why that would, Thecash is going to remain 13 Q. MrPatny, it has nothing to do with the day. If you
14 the same, isn't it, if stamps go up? 14 have reversed the transaction with the effect that
15 Q. Let mepurit in a different way. If you were trying to 15 you're no longer losing that £3,100 and you're getting
16 disguise a shortfall of cash, one thing you could do is 16 a transaction correction for £3,100, you end up £3,100
17 to declare too much by way of stamps, isn’t it? 17 up, don’t you?
18 A. No. 18 A. No.
19 Q. You disagree with that? 19 Is that what you're saying happened?
20 A. Yes, because why would stock make a difference to cash? 20 A. No, wewere-- would it be easier if I explained from
21° Q. Because the more stock you've got, the less cash will 21 the start what's happened with this MoneyGram issue?
22 show, as a matter of balance? 22 Would that make it easier for my Lord, or ..2
23 A. Potentially, but I’mnot too sure of that: 23° Q By all means.
24 Q. Are you confirming that all of the declarations that you 24 MRJUSTICE FRASER: Go ahead.
25 made in relation to both cash and stamps at all times 25 A. Agentlemancame in. His MoneyGram has declined for
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3,100.
it at that point on the front office but I haven't done
anything on the back office which is what1 should have
His card has declined twice. I have cancelled
done, but I wasn't aware of that because it had changed
a couple of months earlier. Later on that night I’m
£6,200 short. I phoned up the helpline to ask why this
was and immediately “Look 6,200, you've got a £3,100
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short MoneyGram", that to me meant it doubled up
9 somewhere and overall there had been an issue there:
10 MoneyGram told me to reverse it on the back office , they
at made me do various things and they said --
12. MR JUSTICE FRASER: When you say MoneyGram told you?
13 A. NotMoneyGram, sorry, the helpline told me. They also
14 said a transaction correction would be sent to balance
15 out the losses.
16 So that’s what they made me do. Now, the issue is
17 on that day it would have polled as a £6,200 shortfall
18 because at 7 o'clock that’s when the polling happens and
19 the business day ceases as such, so I finished the day
20 as technically the business day I have not corrected it
21 onthe right day, but date-wise I have actually done it
22 on that day, because I have done it after 7 o'clock. So
23 the next day I phoned up to ask -- because we had never
24 had an issue like this before of where the TC was and
25 where the money was and they said it takes a few days to
49
1 generate and that’s what's happened.
2. MRJUSTICE FRASER: Just two questions from me about
3 MoneyGram so I can understand. MoneyGram is where
4 somebody wants to send some money overseas.
5 AL Yes.
6 MRJUSTICE FRASER: And itis done in a secure way.
7A. Yes
8 MRJUSTICE FRASER: So they come into your post office and
9 either give you cash or give youa debit card and you
10 take the money from them.
11 A. Yes.
12 MR JUSTICE FRASER: And then the recipient in another
13 country can use that MoneyGram account to withdraw that
14 money, is that correct?
15 A. Yes.
16 MRJUSTICE FRASER: So when the gentleman came in to try and
17 do this transfer and his debit card was declined, am
18 I right in concluding that that means you didn't take
19 any money off him for his MoneyGram, is that right?
20 A. No, his card declined twice.
21 MRJUSTICE FRASER: Which meant he could not then ~ or
22 whoever it was, his relative or friend in another
23 country could not have the benefit of the money that you
24 hadn't taken
25 A. Yes.
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AL Yes.
MR JUSTICE FRASER: Over to you, Mr Henderson.
MR HENDERSON: My Lord and just to be clear as to the
Post Office's position which I anticipate your Lordship
understands, it is accepted that the issue arose in
relation to 3,100 and there was a transaction correction
is that right?
in relation to it, which is accepted --
MR JUSTICE FRASER: The issue being .?
MR HENDERSON: The issue is whether there was a double
transaction for 6,200. And that’s what
MR JUSTICE FRASER: Because you did ~as I understand it,
and youcan correct me if I’m wrong and Mr Henderson you
can correct me if I'mwrong-- you did get a transaction
correction for £3,100.
A. Yes.
MR JUSTICE FRASER: And that took a number of days, is that
right?
A. Yes.
MR JUSTICE FRASER: Am I right?
MR HENDERSON: Correct.
MR JUSTICE FRASER: Over to you.
MR HENDERSON: But what I have been exploring with the
wimess is his suggestion, which I didn’t understand
from his witness evidence, that he had additionally
51
reversed the transaction and if he had effectively
reversed the transaction he wouldn't be entitled to
a transaction correction. But there is a single
transaction here and the data shows a single transaction
of £3,100
MR JUSTICE FRASER: When you say “the data’, are you talking
about
MR HENDERSON: The transaction data
MR JUSTICE FRASER: But not the call log.
MR HENDERSON: Not the call log, no, but the transaction
data. But the call log suggests, as we were looking at
before -- it might be sensible
MR JUSTICE FRASER: Well, let’s not go into the arena of you
explaining it to me because youare still in the middle
of cross-examining him.
MR HENDERSON: No, indeed.
So let’s explore the suggestion that I have put to
you just before the break, Mr Patny, that your loss was
exactly £6,200. Do you remember that?
AL Yes.
Q. So can we look at {F/1507.1}.
to take the filter off and go to row 1903. Now, this is
If we goto -- youneed
a bit fiddly, MrPatny, and I apologise for that but we
need just to take this in stages.
So the actual discrepancy that you experienced and
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declared at the end of 23 February was not for £6,200,
it was for £6,825.95. Do yousee that?
A. Yes.
Q. Soin itself that does not suggest that there is
a problem for £6,200, does it, in itself? I'm going to
go on.
A. No.
Q. But we need to look at the previous day and if we look
at -- it maybesensible if you just make a note
your Lordship may take the arithmetic from me, but we
have a declaration of 25,803.87. Let's look at the
previous declaration of cash
MR JUSTICE FRASER: Sorry, where? Oh, you are taking it
from the line above, 25,803, yes.
MR HENDERSON: My Lord, yes, 25,803.87, discrepancy of
6,825.95. And if you look at the previous day which is
row 1717, that is cash declaration for that day of
34,405.46. Do you see that?
AL Yes.
Q. So there is movement between the 22nd and the 23rd in
the cash declaration figure of £8,601.59. Perhaps you
would accept that from me. Your maths is probably
better but that’s fine.
So what I want to explore is whether we can see the
figure of 6,200 somewhere in that figure. Do you
53
understand?
AL Yes.
Q. Now, the first thing is we can havea look at what the
session data shows us for cash transactions over the
relevant period and this is to be found in document
{F/1436.1.1}. Sheet 1.
My Lord, I should just explain this, and Mr Patny
I should just explain this document. This is
transaction data filtered for trading date and cash
between the times of the two cash declarations that
I have just taken you to, MrPatny. Do you understand
that?
AL Yes.
Q. Now, this is a document that we have created for the
purposes of today in order to demonstrate this point
because otherwise it is just too painful to makeit.
I have explained it to MrGreen and Mr Green if you
Just go to the top of that document ~ sorry, before you
do so, just look at the figure of 1,806.71 which is in
row 216, That's the total of the decrease in cash in
the branch, okay?
A. Okay.
Q. And if we just go to the top of the document, it is
right to say that column U, “Calculation”, is one that
we have added, all right? That's not one that appears
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in the actual transaction log. So we have filtered this
in order to demonstrate the movement of cash of
1,806.71, Does that make sense?
Yes.
It is a figure that you will see in Ms van den Bogerd’s
witness statement in I think paragraph 74 (E2/5/20},
I think from memory.
So taking it in stages, we started with a figure of
1,806 as the movement in cash. We've got the MoneyGram
transaction for 3,100 which we know about which at this
stage the transaction correction hasn't been issued,
okay, so that’s another 3,100. So the total decrease
that wecan account for is 3,100 plus 1,806.71, which
leaves £3,694.88 of cash movement unaccounted for.
Do you agree with the approach I have taken at
least? I appreciate it’s very difficult for you to
agree with specific figures .
I'm trying to understand what you're saying, yes
Okay. ‘The point that I'm putting, clumsily and at great
length, is that there is not a discrepancy of £3,100.
It is a figure of over £3,600.
Right
So when you say that there was a shortfall of exactly
£6,200, that’s just not right, is it?
Well, according to your calculations there it's
55
different , yes, but that 6,200 -- when I’m saying
“exactly” it could be to the pence but I’m claiming that
3,100 times two which showed up as a shortfall on my
cash dec
Well, Ms van den Bogerd suggests that it is much more
likely to have been -- I mean the 3,100 for the
MoneyGram is one thing, but for the rest of it it’s much
more likely to be a cash handling problem ora user
error when making cash declarations, Can you say that
she is wrong in saying that?
Well, yes, I can.
On what basis?
On what basis can she say that that’s a cash user.
Because there's no indication in any of this data that
there were two lots of £3,100 that were processed in any
way, There is every indication that there was one lot
of £3,100 and the story that is told in relation to that
£3,100 makes entire sense. There is no indication of
the £6,200.
The only points I can raise to that is we spoke to our
area manager, Mark Irwin(?), we showed him all this
evidence and he agreed with us that it seemed like this
had doubled up and he is the one who put the block on
our behalf of Chesterfield asking for this money. So
Mark Irwin is obviously a Post Office employee and he
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1 said this and done this as well 1 column?
2 Then the second thing, I don't know if I’m being 2 MRGREEN: Yes. Actually we can go to the top right, little
3 obtuse here, but we have requested this data many times 3 down arrow.
4 from the Post Office and they have never gave it once. 4 MRJUSTICE FRASER: I think what you need to do is if you go
5 MRJUSTICE FRASER: The data that you are being shown, 5 to the very top where the letters for the columns are.
6 A. Yes, I believe this is what's the Credence report 6 Is that what you wanted?
7 1 might be wrong, but I believe this is the Credence ‘7 MR GREEN: I'm very grateful
8 report and we have requested on at least five to six 8 Now, let’s just look at the entry onthe 26th. You
9 occasions of this so we could try to go through it 9 will see there in row 140 "£17,000 shortage open.
10 ourselves on the behest of Mark Irwin. He is the one 10 postage” and then a reference to 09/05 "£17,000 loss
11 who told us to ask for this, as it Tony Sanghera, as did 11 £1.05"
12 the NBSC as well and they said this is where you could 12 Can we please go across one column to the right
13 work outand see if there are some difficulties with you 13 please. Just scroll to the right one column very
14 guys . 14 Kindly. And you will see Horizon Online "Stock",
15 MR HENDERSON: Mr Patny, I'm in some difficulty because 15 “Declarations and adjustments” and then could you please
16 1 can only go on what you've said in your witness 16 click on "Emailed ESG” and then perhaps go up to the top
17 statement and you haven't dealt with any of those 17 and do the same exercise
18 matters in your witness statement and I can only go on 18 It may be actually easier -- do you see in the
19 the data that I can show you and again my suggestion is, 19 formula bar at the top just underneath the ribbon
20 there is no possible basis for you asking for a further 20 there's a right little arrow pointing downwards, could
21 £3,100 when you have already had the transaction 21 you click on that arrow very kindly in the formula bar.
22 correction arising out of this transaction 22 You can just see the text there.
23 A. Without accusing Ms van den Bogerd, you said yourself 23 So this is the entry on helpline log, Mr Patny:
24 she has created this so we don’t know what she has 24 “Emailed ESG Thursday 26/05/2016 14.22 requesting
25 created, do we? She could have done anything on it. 25 Credence report. Please see attached documents advised
87 59
1 MR HENDERSON: My Lord, I have no further questions. 1 office of Credence info. Office adamant stamps are
2. MRJUSTICE FRASER: Re-examination, Mr Green? 2 declaring themselves and overriding [IS] figure referred
3 Re-examination by MR GREEN 3 to IT if believes system issue”
4 MRGREEN: Justa couple of points, if 1 may. 4 Now, you mentioned that you had requested a Credence
5 Could you please look at the helpline logs which are 5 report. Can you remember whether they told you they
6 at {F/1509.1} and could we please select A and B columns 6 were providing you with one or not?
7 just for the moment. Don’t worry, we will just do it 7 A. They said they would but we never received it
8 manually. We will do it manually. 8 Okay, well, let's follow that through. If you then go
9 Let's go down please to row 140 and could you just 9 down please, let's go down please six rows to row 147.
10 bring that a little bit higher up please. 10 Can we go to the left now please. If you look at 147
11 Now, you will see there that’s 26 May. Can you see 1 could we please click on the cell "Office state” in
12 that? 12 row 147. You can see up at the top we can see what that
13° A. Yes. 13 says
14 Q. And if we go across please you can see it is recorded 14 “Office state they were advised a Credence report
15 there 26 May, 12.33 the record is created, that's the 15 was being submitted for amount £17,200 but no report has
16 “Created” column. If we go across please you will see 16 been requested ..”
17 row 140 still, you see “Aakash” with one A but that is 17 Even though the prior entry suggests that an email
18 you though. You actually have two As? 18 was sent:
19 A. Yes. 19 ".. see previous references. Advised will request
20 Q. And then "17,000 shortage open postage”. Now, could the 20 report and ring office back 22/06 from 11/05, will then
21 operator very kindly click on "£17,000 shortage open 21 require an audit if cannot be found. No details on
22 postage”, that cell, and then please click "Wrap text” 22 previous calls. Need to call office back for further
23 if wecan see that. You might have to go -- I think you 23 details *
24 might have to go to the right top corner. 24 ‘Then if we go further down in that, so the bit you
25 MRJUSTICE FRASER: Do you want to show all the text in that 25 kindly did, can you scroll downatiny bit there, in the
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formula bar. Then:
“Have emailed ESG. The office are adjusting stamps
by a similar amount tothe discrepancy. ESG are
I have
investigating , called office .. spoke to Akash
also spoken to Sarah H who has been investigating the
office."
Can you go down a bit more.
MR JUSTICE FRASER: I'm sorry, I can’t see where you are
9 reading from.
10 MRGREEN: Inthe formula bar, my Lord, at the top.
11 MR JUSTICE FRASER: Which row is this?
12 MRGREEN: The row that's highlighted is 147.
13 MR JUSTICE FRASER: There are about eight highlighted which
14 is why I’masking,
15 MRGREEN: Sorry, the row that’s highlighted with the blue
16 round it
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It is row 147 and it is "Office state", the
17 bit your Lordship pointed out is in block capitals .
18 MRJUSTICE FRASER: So you are reading from the formula bar
19 which is a more full entry.
20 MRGREEN: Itis a full entry.
21 MRJUSTICE FRASER: Understood, okay.
22 MRGREEN: Soit says:
23 *1 have also spoken to Sarah Hwho has been
24 investigating this office activity through Horace.
25 There is no conclusive information relating to the loss
61
1 that has been found at this time. However the office
2 transactions are still being investigated and the office
3 hopefully should be contacted before the end of next
4 week 08/07. PM has been advised this information.”
5 Now, at this stage what did you understand was
6 happening?
7A. That they were going to be sorting out all these issues
8 that were prior really. ‘They would sort out a Credence
9 report and we would be told what was happening
10 Q Okay. Can we go down two further to 149, which has not
it been highlighted. And you can see “Previous call", Can
12 you click on that very kindly please. And you will see:
13 “Previous call... still waiting to hear back
14 regarding a requested Credence report.”
15 ‘Then can we go down please to 3 August which is,
16 I will just tell younow ... if we go down to 3 August
17 onthe left-hand side. It is row 155. So if you
18 actually just go just to 155there. It is not
19 highlighted. It says "ACKAH" is the person.
20 A. I assume that’s me.
21° Q. Butyouassume -- there’s no person called Ackah in the
22 branch?
23 A. No,
24 Q. Canyou just very kindly click on the cell starting
25 1895075 and then it says.
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“Branch still waiting a call back. Call closed,
Sarah ESG advised to assign to your stack to call the
office back. No details listed on the call regarding
how the incorrect cash rem is dealt with.”
Did you ever receive back the Credence report you
understood you were going to get?
A. No.
And did the sums that we have been looking at here,
stamps and cash, £17,000, feature in the special audit?
A. They did, yes.
MR GREEN: No further questions, my Lord.
Questions from MR JUSTICE FRASER
MR JUSTICE FRASER: I have two questions.
Can we go to {F/1507.1} please. Right, that doesn’t
appear to be the document I was expecting it to be.
Mr Henderson, you are going to have to help me with this
then because it was the document that showed the
discrepancies, do you remember? Row 1903 had the
discrepancy of 6,825 on 23 February 2016 and a total
cash figure of 25,803.87 and you were comparing that
with
MR HENDERSON: Yes, my Lord, that's 1507.1
filter off.
MR JUSTICE FRASER: Oh, I do beg your pardon. Could we take
the filter off. ‘Thank you very much. Right, if we can
If we take the
63
go to row 1903 please.
You were asked, Mr Patny, about the discrepancy on
23 February. Do you remember those questions?
A. Yes.
MR JUSTICE FRASER: And you were shown row 1903 which had
a discrepancy of £6,825.
of 25,803 and a discrepancy of 6,825.
AL Yes.
MR JUSTICE FRASER: And as I understand your answers, the
£6,200 is within or should be within the 6,825
discrepancy, is that correct?
It hada declare to cash total
A. Yes
MR JUSTICE FRASER: Is that a correct understanding?
AL Yes
MR JUSTICE FRASER: Ifyou go to the previous day which is
on 1717, you were asked about the cash declaration of
34,405. And that was the cash total I think for the
previous day, is that right?
A. Yes
MR JUSTICE FRASER: Which is 34,405. And you were then
taken to another document which I'm not going to take
you to, to examine the movement of cash from one day to
the next.
AL Yes.
MR JUSTICE FRASER: And that I think is the document which
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you said you had been asking for which you referred to
as a Credence report.
‘A. 1 believe that’s what the Credence report is.
MR JUSTICE FRASER: But if you look on 22 February there are
also two other entries. One is immediately above 1717
which shows a cash discrepancy I think of £781 and one
is a cash discrepancy in row 1718 which shows £31. Do
you see those two figures?
AL Yes
MR JUSTICE FRASER: If 1 want to go away and compare like
with like, should I be taking just the cash declaration
the day before, or should I taking the cash declaration
and the discrepancy the day before
A I'm
MR JUSTICE FRASER:
declaration and the discrepancy for the following day?
A. I think the second one would be more beneficial to you,
wouldn't it, because then you can see
MR JUSTICE FRASER: So therefore is it correct that as at
22 February whatever the discrepancy was on these
and comparing it with the cash
figures, that is not included in the 34,405 figure; is
that right? Or is it?
A. That £31.07 -- that 34,405 should be, to my
understanding, after that £31 discrepancy.
MR JUSTICE FRASER: That was my understanding. And does the
65
same point apply for the two figures the day before as
well?
AL Yes.
MR JUSTICE FRASER: So if ever you look at the cash figure
you have to look at the cash figure plus the
discrepancy, is that right?
AL Yes.
‘MR JUSTICE FRASER: Thank you very much.
That's all my questions. Thank you very much for
coming. You are now free to leave the witness box.
Right, Mr Green.
MR GREEN: My Lord, 1am calling Mrs Burke now.
MRS ANGELA BURKE (sworn)
MR JUSTICE FRASER: Have a seat.
‘A. Thank you.
Examination-in-chief by MR GREEN
MR GREEN: Mrs Burke, there will be a folder in front of
you. Move that sheet of paper away. You can put the
loose sheet away somewhere else because that was
separate and if you very kindly havea look in tab 4
{£1/4/1), you will see "Amended witness statement of
Angela Burke"?
A. Mm-hm, that’s right.
Q. And at paragraph 5 of that (£1/4/2} you deal with your
background.
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A. That's right
Q. It is right that you are no longer working as
a subpostmistress?
A. No.
And subject to that correction can we have a look at the
back page
A. I don’t workin the greetings card and stationary
business either now, that’s closed
Q. So you are no longer working there either
A. No. I've got no employment.
Q. And if you look at the final page of your witness
statement, which is page 6 (E1/4/6}
Yes.
You see a signature there.
Mm-hm.
Is that your signature?
That's my signature, that’s correct
And subject to those points about no longer working as
a subpostmistress or in the branch, are the contents of
OoPoPOoP
your statement true?
That's correct, yes. Everything else is fine
Thank you very much. Would you wait -- sorry?
Yes, everything else is fine
CoPOoP
Would you wait there, there will be some questions from
Mr Draper.
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Cross- examination by MR DRAPER
A. Hello.
MR DRAPER: Good afternoon, Mrs Burke. You just said you
were an assistant at Newport which was your husband's
branch.
A. That's correct, yes
I understand that before that you were also yourself
a subpostmistress, is that right?
A. Yes, that’s right.
In total then how long have you worked as either
a subpostmistress or an assistant?
A. I have worked with the Post Office since I was 16 on and
off, sometimes in sub-post offices , sometimes I had
three -- probably five years as subpostmaster and then
intermittently as an assistant
Q. Can you give any indication of the number of years
during which you were an assistant; are we talking five,
ten or more?
A. Let mejust think. Probably about 15.
I just want to ask you quickly about a change that you
recently made to your witness statement. If you have it
there in front of you, in paragraph 8 (£1/4/2] you say
that you and your husband never had any major issues
with unexplained shortfalls during your time running the
branch.
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1A. That's right
2 Q. You then say there was £1 here or there but never
3 anything more than that. In that paragraph the word
4 “unexplained” was added recently. I’m going to ask you
5 what you mean by that but I’m going to suggest what it
6 maybe. Is that clarification because you did have some
7 shortfalls that were over £1 but you were able to
8 investigate and resolve them?
9 A. That's correct, yes.
10 Q. Anddoyousay you were able to do that typically at the
11 end of the day when you carried out your cash,
12 declaration, you would identify the shortfall and then
13 look into it, is that right?
14 A. Usually, yes.
15 Q. If you identified a shortfall of a fairly substantial
16 size, say £50 or £100, much more than a pound, and you
17 were unable that evening to identify where it had come
18 from, was your practice to contact Post Office?
19 A. No.
20 Q. Did that situation not arise?
21 A. No~ normally if youhada shortfall and -- you would
22 try and investigate it yourself and try and find out
23 what the cause of it wasand if you didn’t know it, you
24 would hopefully -- I mean in days gone by it could have
25 been that it could be a transaction that had been sent
69
1 off and you had recorded it wrong and an error notice
2 in the old days -- would come. They have now been
3 replaced by transaction corrections .
4 Q. So you're saying sometimes where even if you had
5 a relatively substantial shortfall , for the time being
6 you might assume that a transaction correction would
7 come and correct it?
8 A. That's right, yes.
9 Q Is that right? Andin your experience is that what
10 happened in those circumstances where you had those kind
11 of shortfalls ?
12 A. Usually, yes.
13 Q. In your witness statement you describe a problem you had
14 with recovering transactions on 9 May 2016.
15 A. Right.
16 Q. Yougive the details of a number of transactions that
17 either didn’t go through at all or had to be recovered.
18 The only one I want to ask you about is the £150
19 withdrawal.
20 A. Okay.
21 Q Before I do that it would be helpful to take you to some
22 images of the Horizon screen so we can make sure that
23 we're talking about the same thing when I describe the
24 process. So if wecould call up please (E2/4/6} and
25 could we zoom in please on the first image on that page.
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oropr
eoPreo>r
PoP oP
This is obviously not a photograph, it is an image to
represent the front office home sereen on
Horizon Online. If you look towards the right of the
screen there, Mrs Burke, where it says British Gas in
blue
Yes
do you see that?
And then below it in red “Total due from custome!
Yes.
That section of the screen I suggest is what we will
refer to as the basket or stack?
Yes, that's correct
And products and services that you enter into the system
by using the buttons that we see on the rest of this
image then stack up in that section of the screen, is
that right?
Yes, that’s correct
‘And each one of those items when it goes into the stack
will show a price which may be negative or it might be
positive and that depends on whether that product or
service involves payment to or payment from the branch.
Yes.
That's right, isn’t it?
Yes.
Could you speak up please
Yes, that’s right.
7
And underneath the stack, as we have just established ,
in this image it says "Total due from customer” and it
is in red, but it might also, if the transactions were
different, say “Total due to customer” in which case it
would be green?
Yes, that’s correct
And whether you get a green or a red section there
depends on the net effect of all the transactions in the
stack, doesn't it?
Yes
So if we take, for example, this British Gas payment, if
the same customer in this transaction were then to ask
to withdraw £100 and you were to process that
withdrawal, it would then go into the stack and the net
effect would change, wouldn't
Yes
And that would be because there would then be cash due
, to be in green?
to the customer?
That's correct
‘Taking the two transactions together?
Yes, it would.
Going back then to the failed transaction on 9 May, in
your witness s
paragraph - and I will take youto it -
fement you seem to suggest in one
that once the
£150 withdrawal was authorised, Horizon then instructed
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1 you to pay that amount over to the customer.
2A. Yes, that's right
3 Q By that, when you use that kind of language, do you
4 simply mean that the withdrawal went into the stack that
5 we have just seen?
6 A. When the £150 withdrawal was done, the customer was
7 inserting a card into the PIN pad on his side of the
8 counter, He would put the card in, when the transaction
9 authorised it would bring “Authorised” on the PIN pad on
10 the customer's side of the screen. It would put the
at £150 onto the stack on my side of the screen and then it
12 would print off a receipt off the Horizon printer and
13 the receipt that came off there said “Authorised, £150"
14 and then that’s passed to the customer and then you pay
15 the customer. Press the “enter” button and pay the
16 customer.
17 Q Sorry, press the “enter” key and then pay the customer?
18 A. Yes
19 Q. That's the only point 1 wanted to clarify with you is
20 that ordinarily what you would do ~ I’m not talking
21 about 9 May whatyou actually did, but what you should
22 normally do is get all of the transactions, including
23 any withdrawals, into the stack that we have looked at
24 and then when the customer wants no more products or
25 services you close the stack, or we would say submit it,
73
1 by either pressing “enter” or “fast cash” or any other
2 way that closes the basket and ends the session; that’s
3 right, isn’t it?
4 A. If youdo that you can’t see what's actually - you've
5 got to then memorise then because as soon as you press
6 that button and it goes there’s no -- you've got no
7 reference as what you're actually paying the customer
8 because it will clear it, so you won't be able to see on
9 the screen what you're supposed to be paying and if the
10 customer then queries anything there will not be any
a1 information on your screen because it have gone.
12 Q. I see, so whatyou say is you would prepare whatever
13 money was due to the customer and then you may hand
14 money over once you had the money in your hand, or you
15 may click “enter” or "fast cash” and then hand it over,
16 but the twoare basically at the same time! think you
17 are saying on a normal transaction?
18 A. You would normally take the money out, you would say it
19 is £75 to pay or whatever -- like this case yousay 150.
20 You would have the 150, you count the 150, press the
21 “enter” and it would clear
22 Q. Andon 9 May, the situation we're talking about, on the
23 right-hand side of your screen here you would have had
24 three transactions stacked up; that’s right, isn’t it?
25 A. Yes.
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You would have had the two for the customer earlier, the
gentleman who was withdrawing money from two different
cards?
Yes.
And you would have had the 150 from the customer who was
presently before you?
Yes
Normally you wouldn't have two customers’
transactions at the stack on onetime. It was just the
circumstances on that day were exceptional. The systems
were slow, because they was connecting I had two
customers’ transactions on there, but I actually said
that in my statement, that there was two customers.
Yes, you have explained that you wouldn't ordinarily do
it
No.
it wasn’t the procedure you were supposed to
follow --
Yes.
but you were doing it in difficult circumstances?
That's right, that’s correct
Could I ask you to turn to the witness statement of
a Post Office witness, Ms van den Bogerd, which is at
{E2/5/25},
you seen this witness statement before, Mrs Burke?
It should come up onin your sereen. Have
75
Yes, I have seen that.
Can I ask you to read to yourself please paragraph 105,
It largely confirms what we have just discussed.
(Pause).
Yes.
Sorry, over the page as well please (E2/5/26}, just
finishing paragraph 108.
(Pause).
Right, yes.
Do you agree with what is said there?
I have read what she has said, but I have no idea of how
the back office procedures of Horizon work. We're
trained on transactions and how to process transactions,
we have no idea about how the system in the back
connects to Horizon, when it goes to a bank, how it
checks the bank or when it feeds things back.
Sure.
‘We're not
Sure. I'mnot trying to suggest that you're aware of
the technical data
No.
the data processing, everything that goes on within
the system. What I suggest you would have known is that
it is when youclose the stack that the transactions in
the stack go into your accounts?
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1 Yes, what should be in the stack, yes, should go into 1 customer had been in front of you; that’s fair,
2 our accounts. 2 isn’t it?
3 And that happens when you close the stack, because 3 But that would be the same if they were buying postal
4 that’s when those transactions are finally confirmed? 4 orders, stamps, et cetera, when-- you know, it could be
5 When you press the “enter” button and it clears the 5 the same time difference no matter what customer was
6 sereen, everything that’s in the stack should be in your 6 there.
7 accounts. 7 Mrs Burke, to be clear, it’s not the type of
8 ‘Thank you. 8 transaction. ‘The point I'm asking you about is the
9 On 9 May, you have explained that you were keeping 9 difference it makes that you were serving different
10 a single session open and were processing withdrawals 10 customers from the same session so had to keep the
at for two different customers from that single session a1 session open, even after the time when the first
12 because of the difficult circumstances. 12 customer may have left. Do you follow that?
13 Yes. 13 I don’t see whatyou're trying to get at there.
14 You would ultimately though, wouldn't you, have to close 14 Well, imagine a really extreme cireumstance where you
15 that stack and, as we have just described, it is at that 15 kept the session open for an hour and served ten
16 point that those transactions would go into the account? 16 customers from it. Do you follow?
17 Sorry, can you repeat that again please 17 Well, yes, but in a scenario you wouldn't do that. You
18 You had kept the session open because you were concerned 18 couldn't remember it.
19 about problems with the system. 19 That's taking it to extremes, Mrs Burke, but the point
20 Right. 20 is all I’m trying to suggest to you is that by not
21 But you would ultimately at some point, wouldn't you, 21 closing the stack as you go along after each customer
22 have to close the stack in order to put the transactions 22 session, what you're doing is increasing the gap in time
23 finally through? 23 between the authorisation and closing the stack and
24 Yes. 24 submitting the transactions.
25 And so not closing the stack between customers but 25 You are increasing the time, but that could be the same
77 79
1 keeping the session open increased the time between you 1 if it had been the same customer who had carried on.
2 obtaining authorisation for the withdrawals and dealing 2 I understand.
3 with the customer and when the transactions then were 3 If it had been the first it would have been the same.
4 submitted on the system; do you follow? 4 Your point is if you hada customer who said he wanted
5 Yes, I don't think that would have made any difference, 5 to process a withdrawal and then had seven other
6 because it could have been the one customer doing those 6 transactions, he may have been in front of you for
7 transactions himself anyway. One customer could have 7 ten minutes.
8 been doing two card withdrawals and then ultimately 8 Yes, it would have made no difference, it would still
9 a bank withdrawal, so that it was two customers doesn’t 9 have been the same. You would have still had that time
10 really make any difference 10 delay before you actually cleared your stack and then
at It would have the advantage that the single customer 11 they would have gone onto your log
12 would likely be there at the time you entered the 12 In that circumstance though it’s right, isn’t it, that
13 transactions into Horizon; that would be one advantage 13 you would not, following proper procedure, have passed
14 of doing it the proper way? 14 the money to the customer before you had gone through
15 No, because normally you have counted the cash out to 15 the rest of the transactions?
16 your customer, pressed the “enter” key and then it is 16 You would complete all the transactions that that
17 just onto the next customer -- the next customer comes 17 customer was wanting before you cleared.
18 forward then and you are serving then, so it would be 18 Yes. And on 9 May it was when you went to settle the
19 the same whether it was one or two. 19 basket and clear the screen that the system went down,
20 1 follow that, yes, Mrs Burke, but in relation to 20 wasn’t it?
21 thinking about the first customer, for whom the 21 Yes.
22 transactions actually were recovered, but thinking about 22 And Horizon then printed a disconnected session receipt
23 that customer, when you ultimately come to press “enter” 23 and we can see that at {F/1461} please. What that
24 and clear the stack, it might be several minutes sine 24 receipt shows is essentially what wasin your stack in
25 those withdrawals had been authorised and since the 25 that session when the system went down; that’s right,
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1 isn’t it?
2 A. That's correct, yes, but that took two minutes to come
3 upto after I had been serving the customer.
4 Q. Yes. And then what you next saw -- I'm just running you
5 through the documents. What you next saw is the
6 document at {F/1464}. This again, Mrs Burke, was a few
7 minutes later this receipt was printed; that’s right,
8 isn’t it?
9 A. Correct.
10 Q Andyou say in your witness statement that what you
at initially understood from this receipt was that the two
12 transactions listed on it had failed to recover; that’s
13 right, isn’t it?
14 A. Yes
15 Q Andyou inferred from that that the third transaction
16 for £150 had been successfully recovered?
17 A. Yes
18 Q Younow understand, it seems from your witness
19 statement, that what this receipt was intended to convey
20 was two things. 1, there had beena failure of recovery
21 for some transactions, one or more, but that these two
22 listed had been recovered?
23 A. Yes. I found that out when I went through my
24 transaction log and I started to tick off the
25 transactions, then I realised that the “recovery failed”
81
1 wasn't the fail -- the items it showed weren't the
2 failed transactions, they were the ones that had
3 actually gone through and it was the other transaction
4 that had failed .
5 Q Yes. Shall we look at the -- the transaction log is at
6 {F/1465}. So you printed this off within a matter of
7 minutes, as I understand it, is that right?
8 A. It wasafter I had closed the branch.
9 Q So approximately how long, do you think?
10 A. I did say in my statement. CanI just refer to it?
11. Q. Well, the "recovery failed” receipt was printed at 9.36.
12 We see that at paragraph 17 of your statement (E1/4/3).
13 You don’t actually say at paragraph 17
14 A. 9.36, yes.
15 MRJUSTICE FRASER: You phoned the helpline after you had
16 closed the branch?
17 A. Yes. I served another couple of customers and there
18 ‘were some problems with connection then and then
19 I decided to close the branch and then I went and ran
20 off the transaction log and that’s when I sat down,
21 closed the branch and worked through it.
22 MRJUSTICE FRASER: And at the end of paragraph 18, did you
23 then phone the helpline?
24 A. I phoned the helpline -- I think it was
25 MRJUSTICE FRASER: So we can work the time window out,
82
1 think,
MR DRAPER: Yes, my Lord.
Looking at this document that you have on screen at
the moment, Mrs Burke --
A. It would have been about 9.34. It would have been after
the -- because that’s -- when the 253 total came up.
Q. In any event, the precise time is --
A. About-- say 9.34.
Yes, so you printed off this transaction log that we can
see on screen and we can see from your handwritten
annotation on it the ticks on the transactions that you
expected to see and do see there and you have then
indicated between two transactions that the £150
withdrawal was missing.
A. Yes.
Q. So you were able to work out quite quickly from looking
at this transaction log that one of the transactions you
expected to see wasn't there?
Yes.
>
Q. It’s from that that you corrected what you had
understood from the “recovery failed” receipt?
Yes
You saw it was the other way round?
It was the other way round, yes.
oPrPoPr
So by this point, after you have sat down with the
83
transaction log, you knew you had had a system outage,
problem with the system, you knew that the session you
were in when the outage occurred had a problem, because
you had the discontinued session receipt?
A. Yes.
You knew that the recovery process on Horizon, the
automatic recovery process, had failed in some way; you
knew that from your "recovery failed” receipt?
A. Yes.
And you had been able to identify from this transaction
log which transaction it was that had not been
recovered?
A. Yes.
And that meant that in this fairly short space of time
you were able to work out that the £150 withdrawal for
which you had physically paid out had not gone into your
accounts?
A. Yes.
And you knew that the result of that was that unless you
obtained a transaction correction to put the transaction
into your accounts, you were going to have a £150
shortfall ?
AL Yes:
And you knew what would have caused that shortfall,
didn’t you, you knew it was the failed recovery for the
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1 1502 1 worked out that the £150 withdrawal hadn't made its way
2 A. Yes 2 to your account?
3 Q. CanI ask you to look at paragraph 19 of your witness 3 A. I did after studying all that paperwork, yes.
4 statement please (E1/4/4}, and can I ask you to look in 4 MRJUSTICE FRASER: Mr Draper, just so I understand, by the
5 particular, Mrs Burke, at the last sentence of that 5 discrepancy being shown on the Horizon system you mean
6 paragraph. 6 the receipt, do you, that was printed off, or do you
7 Have you read that? 7 mean something else?
8 A. I'mjust finishing it off 8 MR DRAPER: No, the point I was taking was "no means for the
9 Q. Okay. 9 discrepancy to be identified * and my point was that
10 A. Right. 10 Mrs Burke had identified the discrepancy.
11 Q. Whatl suggest to you, Mrs Burke, is that that sentence 11 MRJUSTICE FRASER: Well, you actually were putting the
12 isn’t accurate, is it? You had been able to ascertain 12 point on the last sentence which says “no means through
13 from the system what the discrepancy would be, the £150 13 the Horizon system for the discrepancy to be
14 shortfall , and you knew exactly what its cause was? 14 identified *
15 A. But it hadn’t been recorded on my transaction log, so it 15 MRDRAPER: Yes, that’s right.
16 had not shown thata transaction for that amount had 16 MRJUSTICE FRASER: So are you putting the point that it was
17 gone through on my accounts. 17 the receipt that demonstrated the discrepancy being
18 Q. Yes that’s right, but that actually was something that 18 identified in the Horizon system, or is it in some other
19 helped you understand what had happened, wasn't it? 19 way?
20 ‘That's what showed you that it hadn't got through to 20 MRDRAPER: Well, wo points, if I may.
21 your accounts. Do you follow? 21 First, Mrs Burke, you knew there would be
22 A. I just knew thatthe system -- it was missing off my log 22 a shortfall without even asking Horizon to tell you
23 and that it should have been there and then my accounts 23 that, didn’t you?
24 would have balanced, but as it was it wasn’t there, so 24 A. Because! had paid the customer the money.
25 my accounts didn’t balance. 25 Yes. So that’s the first point
85 87
1 Q. Yes, I appreciate that. I’m focusing quite closely, if 1 A. And it wasn’t recorded on my transaction log.
2 I may, on the wording of the last sentence of 2 And secondly, you could see that discrepancy, couldn't
3 paragraph 19 of your statement. It says there: 3 you, by running a balance snapshot?
4 “There was therefore no means through the Horizon 4 A. Because the transaction was missing on the snapshot.
5 system for the discrepancy to be identified.” 5 Q. Yes. And if you were -- we will come back to it,
6 Stopping there, I suggest to you that’s wrong 6 my Lord.
7 because you knew exactly what the discrepancy would be, 7 ‘The next step then, after whatwe have just gone
8 it would bea £150 shortfall. So that’s not correct, is 8 through, is that you call the helpline; that’s right,
9 it? 9 isn’t it?
10 MRJUSTICE FRASER: Well, Mr Draper -- well, I will wait for 10 A. That's right.
11 the answer and then 11 Q. Youcan see the transcript at {F/1466}. Before we look
12 A. Well, the Horizon system didn’t identify it; I knew it 12 at the detail of it, it’s this call to the helpline that
13 was the £150. Oh, I see what you mean, that I had the 13 makes you think that without your efforts in tracking
14 two receipts. Yes, I will agree with that 14 the customer and taking him to the bank and so on,
15 MR DRAPER: And focusing on the second half please of the 15 Post Office would not have resolved the problem for you,
16 sentence: 16 is that fair?
17 or for its cause to be established in [your] 17 A. That's fair, yes.
18 situation ” 18 Mrs Burke, I assume you are quite familiar with the
19 1 suggest that based on what we have just discussed, 19 transcript. Do you need an opportunity to read it, or
20 you knew what the cause of a £150 shortfall would be, 20 ‘would you be happy for me to ask you questions about it?
21 didn’t you? 21 A. I think I would be happy. There will be odd bits
22 A. Sorry, could you say that again? 22 T can always refer back to it if I’ mnot.
23 Q. Youknew that when a £150 shortfall arose -- 23 Q Youare the customer shown on this transcript, aren't
24 =A. Yes. 24 you? Mrs Burke?
25 Q. You knew what would have caused it, because you had 25 A. Sorry? Oh, yes, I'mthe customer.
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1 Q. And if we look to the bottom of this first page -- this 1 moment. If the transaction isn’t on your transaction
2 is you speaking -- you explain in that final entry on 2 Jog then the transaction hasn’t gone through”
3 the page that you know the £150 withdrawal hasn't gone 3 We see that you're not very pleased with that
4 through and you know that your branch therefore won't 4 answer. And then the supervisor says:
5 balance 5 “The only thing we can advise at this point, if you
6 A. Yes 6 want to discuss this further you would need to speak to
7 Q. If we flip over the page now please (F/1466/2}, you then 7 the IT help desk ... because they are the ones that are
8 explain there about the disconnected session. 1 think 8 running the invest.”
9 it is fair to say, just skipping forward, you didn’t 9 And suggest that would be“ investigation. Does
10 feel you were getting very far with the initial helpline 10 that accord with your recollection?
at operator so you asked to speak to a supervisor? a1 Yes.
12 A. Correct, yes 12 ‘Then towards the bottom of the page you see the third
13 Q. If wegothen to the conversation with the supervisor 13 entry:
14 and pick it up on the third page please {F/1466/3}, do 14 *Yeah but it is a nationwide issue at the moment and
15 you see four entries from the bottom there’s an entry 15 weare aware of it, So it maybe-- I can’t guarantee
16 starting “But the £150"; do you see that? 16 anything but it may be once we are aware of it and we
17 A. Yes 17 can sort something out. It may be we are looking into
18 Q. The supervisor says there: 18 it at a later date to try and recoup any losses but we
19 “But the £150 hasn't gone through, that’s why it’s 19 can’t guarantee anything at the moment until we are
20 not on your transaction log. If the £150 hasn't gone 20 aware of what is causing the issue.”
21 through and you have given the customer the £150 that 21 So two points I would like to take from what we see
22 will give you a discrepancy because there is no 22 from this transcript, Mrs Burke, The first is that you
23 transaction for it” 23 had been informed it was a nationwide problem that was
24 So that reflected your understanding, didn’t it? 24 being investigated?
25 A. That's right. But she is saying there's no transaction 25 Yes, it was a nationwide problem.
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1 for it, but it had already given me an authorised 1 And that it was being investigated?
2 receipt and the customer had had an “Authorised” message 2 But they were also saying that they can’t guarantee
3 on the sereen as well, on the PIN pad. 3 anything either
4 Q. Yes, we will be I think just several more minutes on 4 Yes. But you accept that you were told it was being
5 this transcript. 5 investigated and you understood that?
6 On page 4 6 I did, but never at any point did they say in the
7 MR JUSTICE FRASER: Sorry, do you mean you want to keep 7 conversation that they would come back to me and take
8 going past 1 o'clock or 8 a note of my problem and "We will come back to you and
9 MRDRAPER: Yes just the next three minutes. 9 make anote this is the problem you're having in your
10 MRJUSTICE FRASER: For how long? 10 branch”, which
11. MR DRAPER: Three minutes, my Lord. 11 Maybe! will try and summarise the position.
12 MRJUSTICE FRASER: Yes, of course. 12 Okay.
13 MR DRAPER: On page 4 though please {F/1466/4] in the middle 13 I appreciate that this call didn't give you the
14 do you see a long paragraph where the supervisor starts 14 certainty that you would have liked that you were going
15 by saying "No"? 15 to be taken care of and the problem resolved
16 A. Yes. 16 essentially .
17 Q. The supervisor there says: 17 Yes.
18 “When you're doing the transaction, at the very end 18 But it would be unfair, wouldn't it, to suggest that
19 of the transaction. When you're selecting * settle" 19 Post Office told you that it wasn’t going to resolve the
20 before you give the customer any money, because you 20 situation. It essentially said that that mightbe the
21 should never give the customer any money until the 21 case. Is that fair?
22 transaction has been settled, it’s at that point that 22 They are saying they couldn't guarantee and for meas
23 the transactions seem to be disconnecting. It’s 23 a branch, if they can’t guarantee, I would be losing --
24 a nationwide issue, Erm, we are aware of it and it’s 24 1 would be out-of pocket.
25 being dealt with by the Horizon service desk at the 25 Yes and you understood from what you had been told here
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that there were people other than the helpline operators
here, you were told about the IT service desk,
essentially this was being investigated by someone else
and they would get back to you with the results; that’s
fair, isn’t it?
A. They didn’t say they would get back to me. I can’t
recall them saying they would come back to me.
Q. If youlook at the third entry from the bottom,
Mrs Burke it is not precisely in those words ~ third
entry from the bottom, last sentence:
“It may be we are looking into it at a later date to
try and recoup any losses
That would be recoup losses for you, wouldn't it?
A. They are saying that they may be looking into it
‘That's not a guarantee of looking into it
Q. I understand
I think we can sense apply take a break there,
ny Lord.
MR JUSTICE FRASER: Right, we're going to have a break for
lunch, I would like you to come back at 2 0’clock
please. Because I say this to every witness so don't
read anything into it, but because you are in the middle
of giving your evidence don’t talk to anyone about the
case please and come back at 2 o'clock
Anything else? No, 2 o'clock. Thank you all very
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much.
(1.05 pm)
(The luncheon adjournment)
(2.00 pm)
MR DRAPER: Mrs Burke, we have just got through before the
break the helpline call, going through the transcript
‘The next step that you explain in your witness statement
is the things that you yourself did to track down the
customer and obtain records from him and from his bank.
A. That's correct, yes.
Q. And it’s right, isn’t it, that it was on 12 May that you
went with the customer to his bank to obtain
confirmation of the withdrawal?
A. That's right
Q. And it is one day after that, on 13 May, that your
husband spoke toa lady at Post Office and he was told
in that telephone call that your branch could expect to
receive a transaction correction?
AL Yes.
Q. Presumably it was in that call, onthe 13th, that you or
your husband told Post Office about everything that you
had done in the meantime?
‘A. Yes, we told them that we had seen -- that we had seen
the “authorised” receipt from the customer and that we
had also got the statement from the bank to show that
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the money had gone out of the customer's bank account,
even though it had not appeared on our system.
1 should make clear before moving on that Post Office
makes absolutely no criticism of you for doing all that
work yourself and for having tracked the customer down
and similarly I didn’t intend to criticise you earlier
about the impression you took from the telephone call .
You were understandably frustrated. I just wanted to
make that clear.
Fine
The point I do intend to challenge in your witness
statement is a relatively small one, which is your
suggestion that the shortfall in your branch would not
have been resolved if you hadn't done the work that you
did. Do you follow?
I understand what you're saying
It mighthelp to take it from your statement at
paragraph 27, which is {E1/4/5). It is the second
sentence in that paragraph, Mrs Burke, That’s the only
one I want to address with you at the moment. You say
there:
*Based upon my initial experience of the helpline,
I do not think that Post Office would have resolved this
if I had not had the clear proof that the £150
transaction had in fact been authorised and that the
95
money had left the customer's bank account”
No.
You of course were not aware at the time in May 2016, or
indeed when you prepared this witness statement, of the
steps that were going on in the background at
Post Office and at Fujitsu, were you?
No
What I intend to do is show you some documents produced
during that process that I will suggest show that
Post Office and Fujitsu were dealing with the problem
and would have been able to resolve it. Do you follow?
I follow
The first documentis at (F/1470.1}. This is what is
called a BIMS incident report which is a wonderfully
tautologous phrase because BIMS stands for business
incident management service, which is a function
performed by Fujitsu
You see at the bottom that this is a document
produced by Mr Andy Dunks. Do you see that in the
rectangle at the bottom of the page “Analyst” on the
right?
Yes.
You can take it from me that he is a Fujitsu employee.
This is a report that Fujitsu has generated to identify
branches affected by the outage on 9 May. Again, in the
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box at the bottom of the page do you see under “actions:
date and time”, the first entry there:
“On the 9th May 2016 there was a major outage at
branches that caused multiple transactions to fail
Transactions that require (Post Office Limited]
reconciliation have been identified anda spreadsheet
created”
Do you see that?
Yes.
And do you see that this document is dated 12 May,
that’s in the same box after “Actions: date and time”?
Yes
So am I right to say this is then the same dateas that
on which you went to the customer's bank with him?
Yes.
Going right to the bottom of this document, do you see
at the bottom it says:
“The resultant spreadsheet has been attached to the
same email that this BIMS has been sent”
Yes.
I can then show you that email quickly. It is at
(F/1470.1.1)
report that you have just seen, Mrs Burke, and you see
So this is the email that attaches the
from the top of the email that it is sent to various
recipients at Post Office
97
Yes
And it says in the last sentence of the email:
"I have attached a spreadsheet containing the list
of all transactions that require POL ..”
Which is Post Office Limited
*. fo manually reconcile as appropriate”
Yes
‘The next document, Mrs Burke, is a spreadsheet which is
at (F/1848.4}.
Mrs Burke, is the spreadsheet that we have just seen
It will just take a moment. Thi
described as having been attached to the email that went
to Post Office. If you could please look at row 12, if
the operator could sean down please. You recognise in
the first column, column A, where it identifies the
branch, the branch ID there 216321. Do you recognise
that branch ID?
Yes.
That's the Newport branch, isn’t it?
‘The Newport branch, yes.
Now can we move it over just slightly so we cansee all
of column H please. Whatit says there in this Fujitsu
documentis:
“The £150 cash withdrawal transaction was authorised
by the FI.”
Which I take to be financial institution
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and an authorised receipt was produced on the
counter. However, when the user attempted to settle the
transaction it failed due to the known data centre issue
at the time so disconnected session receipts were
produced and the user was logged off. ‘The user managed
to log back in but recovery also failed. As
an authorised receipt was produced the user should have
handed money over to the customer but we cannot be
certain that they actually did so. Assuming money was
handed over the customer account will be correet but the
branch will have a shortage given that the transaction
hasn’t been recorded on the system. ‘This will need to
be manually reconciled.”
So what I suggest is it looks, doesn’t it, like
whoever at Fujitsu wrote this didn’t know whether or not
you had paid money over the counter, is that right?
Yes, they have put they don’t know if it was handed over
even though I had already called in and said we had paid
the customer. So they knew on the 9th that I had paid
the customer.
Remember, Mrs Burke, this is a Fujitsu document rather
than a Post Office documento this is the people
managing the system and what I suggest is this is what
they have discerned from the data available to them on
the system, Do you follow?
99
Right.
And that they have essentially obtained data reports on
the thousands of branches that were affected and this is
what they can see from their data.
So do you see then that Fujitsu says, on the
assumption that the money was handed over,
reconciliation would be required?
Right. Yes, I can see what they're saying.
Continuing with this account of what's going on in the
background, Post Office then produces a spreadsheet to
show whatit is doing in response to this analysis from
Fujitsu and that’s at {F/1848.5}.
document that will take a moment to come up. Do you see
there, Mrs Burke, row 13 that’s been highlighted?
It is another
Yes
And we see in column A the branch code but helpfully the
branch name in column Bas well. Then if the screen can
be moved over a little please. Column His the same, it
is the statement we have already seen from Fujitsu. that
we just read. If we move further please to the right
When it says the transaction date and it says 9 May.
Forgive me, where are you looking? Can we move the
sereen back.
9 May. But it says the time 8.28. How can that be
8.28? My branch doesn’t open until 9.
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1 Q T'minstructed that these records will be an hour 1 the date at A, 16/05/2016. And then if the operator
2 different because of not accounting for savings time. 2 could move the sereen along a little please to the
3 So it's just every time you see a document like this 3 right, in column Lweseea description -- we see the
4 they will be an hour out. 4 text that accompanied the transaction correction and
5 A. Earlier? 5 that reads:
6 Q. Forgive me? 6 “To correct communications failure on 9.5.16 for in
7A. Anhour earlier? So how would they know Ihad done that 7 pounds 150
8 an hour earlier? 8 It gives a reference and it says then "so credit to
9 Q. No, the suggestion isn’t that the transaction occurred 9 office ", then provides the number for the financial
10 at 8.28, It did occur -- the session start date I think 10 services enquiry team. That's the transaction that you
11 that will show. No one is suggesting that it was at 11 received -- I think you say received and processed on
12 8.28, it’s just this time stamp doesn't take account of 12 the 17th, is that right?
13 changes in GMT, so it will be an hour off. ‘This time 13. A. Yes, 17May. Yes, it was 17 May when we gorit through.
14 stamp is an hour wrong 14 So the point I wantto take from these documents that
15 MRJUSTICE FRASER: I don't think GMT does change. 15 I have just taken you through, Mrs Burke, is nothing to
16 MR DRAPER: Forgive me. 16 do really with the impression that you took at the time
17 MRJUSTICE FRASER: I think what you meanis this is GMTand 17 or the impression that you set out in your witness
18 it would be daylight saving time in May. 18 statement -- as I say, wedon't criticise you for having
19 MR DRAPER: That’sright. I’m sure that’s whatI meant. 19 taken that view -- the point I’mtrying to establish is
20 MRJUSTICE FRASER: So it has GMT at the top of the 20 that having seen now, with the benefit of what you have
21 column under letter F. 21 seen here about what Post Office and Fujitsu were in
22 MRDRAPER: Yes,I think it is just unadjusted. 22 fact doing in the background, as it were, unknown to
23. A. Okay. 23 you, with the benefit of that knowledge would you accept
24 Q. If wecan move across then please. I think you 24 that it looks as though Post Office would have been able
25 confirmed that Hlooks like the same content we have 25 to resolve the problem in your branch even if you hadn't
101 103
1 already seen, Mrs Burke. If we go back just across 1 taken the steps that you did?
2 please. 2 A. Possibly, yes
3 A. Yes 3 ‘Thank you.
4 Q. That's whatwe have just already seen in the other 4 No further questions, my Lord.
5 spreadsheet. 5 MRJUSTICE FRASER: Mr Green?
6 A. Okay. 6 Re examination by MR GREEN
7 Q. But this is a document into which Post Office has added ‘7 MR GREEN: Only one question, my Lord.
8 further information and that’s over in columnJ. You 8 Mrs Burke, if you just have a very quick look on
9 see the heading to that column is "Action taken” and 9 page {F/1461/1}. Do you recognise that?
10 what Post Office has included in that box for your 10 A. Yes.
11 branch is 11 The transactions that we see on there, are they in
12 “Branch contacted. Shortage in branch so TC issued 12 chronological order going down, so 180 comes first,
13 to adjust cash” 13 73
14 So what I suggest is that's Post Office, with the 14 A. Then 73, then 150.
15 information it has about what actually happened in your 15 or are they going up in chronological order?
16 branch, information from you, confirming that it will 16 A. No, the 180 and then the 73 and the 150 was the last
17 issue a TC? 17 one.
18 AL Right. 18 Q. Right. And that's the one there was a problem with.
19 Q. AndI suggest that this coincides, Mrs Burke, with your 19 A. Yes
20 witness statement where you say that your husband was 20 Q. Thank you very much.
21 told on 13 May to expect a transaction correction. 21. MRJUSTICE FRASER: Thank you very much, no questions from
22 =A. Yes. 22 me. Youare free to go, thank you,
23 Q. Just to complete the picture, the transaction correction 23 MRGREEN: My Lord, there is a tiny possibility I mightneed
24 wasin fact produced on 16 May. We cansee that from 24 to ask your Lordship for just five minutes. There is
25 {F/1687.1}. If you look please at row 5 you will see 25 a PEAK that has been uploaded, a new one today, which
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1 don’t understand and the haste with which it has been
done suggests it might be going to be put to Mr Roll
MR JUSTICE FRASER: When you say uploaded you mean put in
the trial bundle?
MR GREEN: Yes. And so because I haven't hada chance to
discuss it with him, can I have five minutes?
MR JUSTICE FRASER: When did that appear, that document?
MR GREEN: During the course of today. It uploaded at 9.43
this morning but unfortunately I haven't managed to get
ontop of it
MR DE GARR ROBINSON: My Lord, I won't be asking any
questions on that PEAK.
MR JUSTICE FRASER: You're not? You are cross-examining
Mr Roll, are you?
MR DE GARR ROBINSON: 1am cross-examining Mr Roll and there
will be no questions about that PEAK. It is there for
an entirely separate, coincidental reason.
MR JUSTICE FRASER: Is Mr Roll going into tomorrow?
MR DE GARR ROBINSON: Yes, I would expect so.
MR JUSTICE FRASER: Are there going to be any questions on
that PEAK tomorrow?
MR DE GARR ROBINSON: No.
MR JUSTICE FRASER: No, all right.
Well then that means there won't be a situation
where you need to speak to Mr Roll overnight and he will
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be in purdah.
MR GREEN: My only anxiety, my Lord, is if it arises in the
evidence of someone else and I haven't dealt with it
I don’t want to be -- could I just have five minutes to
make sure?
MR JUSTICE FRASER: I'm not going to give you five minutes,
1 will actually give you ten minutes. That's the
easiest way of dealing with it. So we will come back in
at half past.
(2.20 pm)
(Short Break)
(2.30 pm)
MR GREEN: My Lord,I call Mr Roll if I may please.
MR RICHARD ROLL (affirmed)
MR JUSTICE FRASER: Thank you, Mr Roll
A. Thank you.
Examination-in-chief by MR GREEN
MR GREEN: Mr Roll, in front of you there should be
a folder, you can see.
Yes.
And if you turn please to tab 7 (E1/7/1}.
Yes.
Havea seat.
oPpop
You can see there's a witness statement with your name
on it
A. Yes.
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A.
a
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And at the back of that witness statement is
a signature.
Yes
Is that your signature?
It is
And are the contents of that witness statement true?
Yes, they are.
And if we go to tab 10 [E1/10/1}, have you got a copy of
the amended statement there?
Nothere, no. ‘Thank you.
Do you want to keep it in front of you
‘Thank you, yes.
Have a look at the back page of that if you would, very
kindly.
Yes.
And have you got your signature?
Yes.
On that one, or have you signed another one?
I have signed another one, yes.
And are the contents of that statement true?
Yes.
‘Thank you very much.
Cross-examination by MR DE GARR ROBINSON
MR DE GARR ROBINSON: Mr Roll, you say that between 2001 and
2004 you worked at Fujitsu. and you deseribe it in
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paragraph 2 of your first statement (E1/7/1} as working
in third/fourth line support.
1 would just like to ask you some general questions
about the support teams first of all and for that
purpose I would like to ask you to look at Mr Parker's
first witness statement, the reference is {E2/11/5}. It
will come up on the sereen for you. You will see that
Mr Parker says in paragraph 24:
“There were four lines of support for Horizon while
Mr Roll was employed by Fujitsu and they are described
in paragraph 26 below. Thereare still four lines of
support ..7
Stopping there actually there is a general question
I should ask which is that you know that Mr Parker has
made three witness statements, don’t you, in this
matter?
I know he has made some witness statements, I don't know
how many.
Have you read any of them?
I have looked at them briefly
Have you looked at all of them briefly or just some of
them briefly?
I don’t think I have read all of them.
Okay. His first witness statement, the witness
statement that we're now looking at, have you read that
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1 carefully or briefly?
2 A. Briefly.
3 Q. Paragraph 25, perhaps! could ask you to read that
4 paragraph very quickly to yourself
5 (Pause).
6 A. Yes
7 Q. That's true, isn't it, what's said there?
8 A. Yes.
9 Q. And thenhe describes in paragraph 26 the four lines of
10 support for Horizon. The first line involved several
11 different elements. This is in paragraph 26.1. First
12 of all he refers to the Horizon service desk, which was
13 a help desk operated by Fujitsu thar branches could
14 contact with issues relating to Horizon application or
15 hardware provided in branch. Then over the page
16 (£2/11/6}, in 26.1.2 he said
17 “There was also a Ist line communications management
18 team operated by Fujitstt which specifically focused on
19 ‘communication incidents
20 And then finally in 26.1.3 he says:
21 “Post Office also operated a Ist line help desk for
22 operational issues called the national business support
23 centre ..”
24 Are you able to confirm that all those facts are
25 true from your own knowledge?
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1 A. I don't remember.
2 Q. Youdo know that Post Office operateda first line help
3 desk for operational issues called the national business
4 support centre, don’t you?
5 A. Therewasa first line support desk and I believe it was
6 shared between Fujitsu and the Post Office, or ICL and
7 the Post Office as it was when I joined, but I don't
8 recall what the splits were or anything like that.
9 Q That's fair
10 Then if I could ask you to read the next unnumbered
11 paragraph underneath 26.1.3 to yourself please.
12 (Pause).
13° A. Yes.
14 Q. Are youable to agree with the points made in that
15 paragraph?
16 A. FromwhatI remember, yes.
17 Q. I'm grateful
18 Then the next unnumbered paragraph, Mr Parker says:
19 “If NBSC were unable to identify the cause of
20 a discrepancy they would often fall back ona default
21 statement along the lines of ‘this looks like a software
22 issue’ so that the SSC would investigate it. However,
23 Mr Roll's statement that "if an error was referred to us
24 then it was extremely unlikely to be due to a mistake
25 made bya postmaster’ is not correct. The vast majority
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of discrepancies investigated by the SSC as pseudo
"software issues’ were (and are) not caused by software
issues”
I would like to suggest to you, Mr Roll, that that’s
true, isn’t it?
A. Theway that I remember it, it was issues to do with the
software that were causing the problems. Whether that
‘was the programme that had been written or data
corruption, that’s what I remember as our problems
being.
Q. You remember there being problems with data corruption?
A. Yes.
I'mnotasking you about data corruption, Mr Roll, I'm
asking you about software issues.
like to put to you again is the last sentence of that
paragraph:
‘The claim 1 would
“The vast majority of discrepancies investigated by
the SSC as pseudo ‘software issues” were (and are) not
caused by software issues ”
Are you in a position to agree to that?
A, From my recollection I would disagree with that, but it
was a long time ago.
Q. I'm grateful.
Paragraph 26.2 (E2/11/7}, there's then a description
of the second line support:
i
"Second line support was provided by senior members
of the HSD and SMC ..”
MR JUSTICE FRASER: Hold on, the page hadn't changed.
MR DE GARR ROBINSON: I'm so sorry, it is page 7.
MR JUSTICE FRASER: It is all right.
Weare at 26.2, yes? Or
It has now, it just
takes a little while
whichever one it is on page 7.
MR DE GARR ROBINSON: Can I ask you to read paragraph 26.2
and its description of the second line of support.
AL Yes.
Q. Is that something that you can recall and can agree
with?
A. It’s not something I can definitely say yes or no to.
Your caution does you great credit, Mr Roll. What
I discern from you — and if I'm putting words in your
mouth do let me know -- you think it may well be right
but you don’t want to commit yourself --
AL Yes.
-- because it is a long time ago and you didn’t work in
second line?
AL Yes.
Q. That's very fair. But just to be clear, people who
worked in the second line included junior members of the
SSC team, yes?
A. Hm, That's not how1 remember it. Second line was
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1 a separate entity and we were third line in the SSC.
2 Q. Well, I put his evidence to you and I will move on,
3 Then we come to the third line, 26.3. He says:
4 “The SSC also provided 3rd line support. The staff
5 that provided 3rd line supporthad a detailed knowledge
6 of the Horizon application based on documentation and
7 some inspection of source code. They:
8 “Designed, tested and documented work rounds for the
9 Ast and 2nd lines of support;
10 *[They] applied analytical skills to the symptoms
11 and evidence gathered by the 1st and 2nd line functions
12 and undertook in-depth investigation into incidents
13 (incidents are the basic unit of work for the support
14 team and come from help desk calls and other Horizon
15 support teams);
16 *[They] undertook complex configuration
17 (configuration items can be used to alter the behaviour
18 of the application) and data fixes which might have
19 required the generation of special tooling;
20 “[They] designed, wrote and documented new support
21 tools... [they] undertook source code examination,
22 complex diagnosis and documentation (including methods
23 to recreate faults) of new application problems before
24 sending them to the 4th line support group for root
25 cause software fix; and (they] provided technical
13
1 support to other internal Fujitsu teams working on
2 Horizon”
3 Now, have read an awful lot to you, Mr Roll, and
4 1 have done that on the apprehension that none of this
5 is going to be controversial. Can ask you to indicate
6 whether you accept what Mr Parker says there in
7 paragraph 26.3?
8 AL Yes.
9 Q I'mgrateful. Then there is a description of the PEAK
10 and KEL system which I need not trouble you with.
11 Paragraph 26.4 on page 8 {E2/11/8}, there's
12 a description of the fourth line
13 “ath line support staff had an intimate knowledge of
14 narrow areas of the system and were (and are) ultimately
15 responsible for the production of permanent fixes to
16 repair the root cause of an incident or problem in the
17 live application. They had knowledge of computer
18 languages which they used to amend source code to fix
19 problem in the live application code. There was often
20 overlap between 4th line and developers, who added new
21 features into the application ”
22 Dol apprehend, Mr Roll, that you agree with that as
23 well?
24 A. Broadly speaking, yes.
25 Q. I'm grateful
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>
Now, you describe yourself in paragraph 2 of your
first statement (E1/7/1) as "third /fourth line support’
You in fact worked in third line support, didn’t you?
I worked in third line support, yes.
And it is fair to say that -- well, this is my language
and if you disagree with the nomenclature do let me
know, but would it be fair to say that third line
support was the elite, but the fourth line support, the
people that actually fixed software problems, they were
the super elite. Would thathe a fair thing to say?
1 would say there were some members of third line who
were super elite as well
And would you describe yourself as one of those people?
No.
Let’s talk about third line, The third line, they were
ona floor that even other Fujitsu staff members
couldn't generally access, is that right?
Yes.
And if we can pick it up at paragraph 28 of Mr Parker's
witness statement (E2/11/8}, you worked in third line
for between
“Between 1 January 2001 and 31 December 2014...”
And those are the years that you worked for Fujitsu
".. the SSC received a total of 27,005 calls ,
well
meaning that on average $63 calls per month were dealt
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with over this 4-year period”
And he refers to a spreadsheet setting that out and
he then analyses the data in that spreadsheet. Would
you accept that that is a fair reflection of the amount
of calls coming in, the amount of incidents coming in to
SSC when you were there, third line?
I can’t really remember. I know there were periods when
it was very busy and periods when it wasn't so busy.
Sometimes we had three or four jobs on the go at once,
other times we were given other work to do from the
manager.
And paragraph 29, Mr Parker says:
“Transferred calls (ie those not resolved by the
SSC) are of interest ”
He says:
“A very small proportion of calls transferred to
4th line support would have concerned software errors
requiring resolution
Stopping there, Mr Roll, that’s true, isn’t it?
Yes.
So he then says:
“.. it would be interesting [therefore] to know the
number of calls transferred to [fourth line }”
Would you agree to that? It would give some
indication of the extent to which incidents coming into
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the SSC properly, genuinely represented software areas
that required fixing? That would bea useful way of
a touchstone of trying to work out
Yes.
Thank you
He then says that, unfortunately:
while the SSC have records of the volume of
transferred calls , we do not retain records of where
they are transferred to and it is not the case that all
of these would have been transferred to 4th line
support. For example incidents would often arrive at
SSC from internal teams for routing back to help desks.”
Do you remember that?
1 don’t remember that particular ..
But would it be right to say that of the calls coming
into third line support, a significant proportion would
go -- of calls that would then be transferred out, would
go to places other than fourth line support? Would that
be fair? Does that accord with your recollection?
The way recollect it is that calls would come in and
we would work on them, either fix them, in which case
they would go back to the originator, or we would pass
them on,
To other people?
To other people.
Depending on the nature of the problem?
17
Yes
So if there was an infrastructure problem you would
probably pass the call on to the infrastructure team, it
wouldn't go to fourth line support, would it?
Probably.
And there are a number of other teams that calls coming
into third line would be passed to who would not be
fourth line support?
Probably.
I accept, it’s a long time ago
I can’t remember the full details .
If we could just look
at an analysis that Mr Parker has done of calls coming
in and calls coming out, could we go to (F/1839} please.
This is a series of spreadsheets which I have -- I'm
probably the least qualified person in court to be
talking about spreadsheets and I would like to go to the
tab which is “Live PEAKs into SSC” please, at the bottom
“RRP live PEAKs into SSC”, there
of the page. And you
will see that there is a calculation of from 2002 oh,
from 2002 all the way through to 2004-- actually, I'm
sorry, if you go up to the top of the page you will see
there is more. But it’s from January 2001 all the way
through to December 2004 and you will see at the bottom
there’s a figure of 27,005 calls. Mr Parker's evidence
is that’s the number of incidents/calls that came into
the third line support during the years that you were
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there. Are you in a position to dispute that?
I would say that’s probably the number of recorded calls
that came in, yes.
I'm grateful. If we could go to the next tab, which is
“RRP live PEAKs out of SSC", here is the calculation ,
again from January 2001 all the way through
to December 2004, of the total number of calls that were
passed out of third line support and we have already
established that a proportion of those calls would have
gone elsewhere?
Mm-hm.
Some of them would have gone to fourth line support and
I believe you have already accepted that a small
proportion of those going to fourth line support would
have gone to fourth line support because they required
software fixes?
Yes.
Very good.
Now, the total figure that Mr Parker has analysed
comes to 3,764 calls. Do you see that?
Yes.
‘Are you in a position to dispute that calculation?
I can’t dispute that, no.
No. AndI didn’t expect you to.
So what that means is that of the calls coming into
119
third line support while you were there, 14% of them
went elsewhere and of that 14% only a subset would have
gone to fourth line support.
Yes.
Do you accept that?
And of that subset only a small subset would have
represented calls relating to software errors requiring
fixing by fourth line support. Do you accept that?
Does this figure, 3,764
figure earlier on, is that calls that have come in, gone
is that -- and the other
out then come back to us and gone out again somewhere
else, or is it just ones that have come in, gone all
round the houses, as it were, and then gone out for
final resolution?
My understanding is it is the latter but I had better
check. Yes, Mr Parker is nodding. Are you in
a position to challenge that?
No.
Very good.
So what that indicates then is summarised by
Mr Parker in paragraph 32 on page (E2/11/9} and
Mr Parker says:
“From the SSC, only a tiny proportion of incidents
were escalated to the 4th line support team. It follows
that only a tiny fraction of incidents raised actually
needed to be looked at by the only team who might
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1 potentially effect changes in software.” 1 evidence. Would you accept that that might be the case?
2 Do you accept that conclusion? 2 Junior level seems to -- it doesn’t fully explain the
3A. Which paragraph are we looking at now, sorry? 3 complexity of the system or the knowledge of the system
4 Q. Paragraph 32, Mr Roll 4 required, but yes, 1 suppose
5 A. 32, sorry. 5 Well, let's agree on ordinary -- I’mnotsecking to cast
6 Q The first sentence is right, isn’t it? 6 any imputations and it is right that you should -- words
7A. When you take it as an average then yes I suppose so, 7 do have implications. So the ordinary level was your
8 but the system evolved from -- I started there in 2000 8 level --
9 I think it was and left in August 2004, The nature of 9 Base level .
10 the work changed over time and the ones that stick in my 10 ~ and there was this perhaps five or so people above
at mind are the ones where there was sort of the a1 the senior people above you and what did they do? Did
12 fire-fighting efforts where it was there were 12 they do the more challenging work?
13 difficult periods where there were software issues, 13 Their experience and knowledge was more focused, shall
14 $0 14 wesay. Some people had avery good -- even I suppose
15 Q Yes, Mr Roll. We could by all means go back to the 15 some of the junior level hada very in-depth knowledge
16 graphs because you will have seen from the live PEAKs 16 of the accounting side of things, so certain aspects
17 into and out of the SSC it actually gave monthly 17 would be passed over to them. A couple were very, very
18 figures, but what I’m suggesting to you, Mr Roll, is 18 clued up on UNIX and that side of things so the actual
19 that -- although you may well have been busy on all 19 servers, any problems with those, if it was involved
20 sorts of things, the fact of the matter is that software 20 problems would go over to them. So that was where their
21 problems requiring a software fix represented a tiny 21 knowledge lay in specific areas, very in-depth very
22 fraction of the work that was handled by the SSC third 22 specific knowledge of those particular areas. Does that
23 line support. 23 explain the question?
24 A. Yes. 24 I'm really trying to grope towards what the five true
25 Q I'mgrateful, Now, you don't say anything about your 25 specialists , whatkind of work they were doing. They
121 123
1 seniority , although you have already expressed some 1 were doing the more challenging kind of work, weren't
2 modesty in that respect. We have established that you 2 they?
3 weren't part of fourth line, Is it fair to say that you 3 I find it difficult to answer that from what I remember
4 were described as a SSC support consultant, was that 4 of the way we worked. There were some areas where some
5 your job title? 5 of the senior people where I would perhaps have been
6 A. I think I wasa product specialist . 6 more — had more experience because of previous work and
7 Q. Emsorry? 7 previous programming that I would have been better off
8 A. I believe my job title was product specialist . 8 and had more knowledge than they would have done, but in
9 Q. Youwerea product specialist and was that the junior 9 other areas then they would be far superior to me.
10 level of people working 10 Well, let me suggest one area where they would have been
11. A. It wasthe generic level. I believe most people there 11 far superior to you, Mr Roll, or at least it was
12 were product specialists . 12 perceived within the organisation -- I’mnot trying to
13° Q. Andi think we have established that is it 30 people 13 have a debate with you about your own perceptions of
14 worked in 14 yourself, that would be completely unfair, but the
15 A. Approximately. 15 perception at the SSC was that were there software
16 Q -- the SSC? OF that 30 people how many people were at 16 errors or potential software errors that required large
17 your level? 17 amounts of code to be examined, the people who would
18 A. WhenIworked there! -- it was two or three people were 18 generally do that examination would be those five
19 senior levels, I think Mr Parker was one, a couple of 19 people, people like Mr Parker. Would you accept that?
20 others, then there was Mik Peach and I believe the rest 20 Generally I suppose, yes, although
21 of us 25 or so. 21 And it would be relatively rare for someone outside that
22 Q. The figures I would like to ask suggest to you, Mr Roll, 22 core specialist team to be doing that kind of work
23 are about 25 people had the junior level and there were 23 not impossible but relatively rare, yes?
24 about five people who were true specialists. who I think 24 Several of us looked at the code on occasions. I was
25 you fairly described as specialist earlier on in your 25 a C programmer in that and other languages before
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1 1 moved to Fujitsu so there were areas of knowledge we
2 had from previous areas, but I suppose most of it would
3 then be passed on to those people
4 Q. Isee. So would you accept from me then that generally
5 it would be them that would look at lots of code but
6 occasionally there might be occasions when someone else
7 would look at lots of code?
8 A. Froma PINICL perspective yes, but some of us looked at
9 code more often, just out of interest.
10 Q. Well, 1 will ask you about that in a while.
aL Now, the last thing I’m going to be doing in this
12 cross-examination is suggesting that you didn’t have
13 a responsible position anda responsible job. You were
14 well trained, weren't you?
15 A. I waswell trained by Fujitsu, yes.
16 Q Is it the case that there was.a mandatory six month
17 training process you had to go through at Fujitsu before
18 you were allowed unsupervised access to the live system?
19 A. I don't fully recall that
20 Q. Andwouldit also be fair to say that the work that you
21 did involved tasks that were much easier and were much
22 more mundane --Idon’t mean tobe insulting -- than the
23 kind of tasks that the senior people within the third
24 line of support did?
25 A. I think one of the comments Mr Parker made in his
125
1 statement at some point was that some things stick in
2 the mind more than others and over time one tends to
3 forget the mundane aspects of the job and tends to
4 remember more the aspects that were not mundane, so my
5 recollection is that -- as I put in my statement
6 I spent sort of 70% of the time doing not mundane tasks,
7 as it were, and only 30%, but that could be wrong, it
8 could be my perception of events from 15/17 years ago.
9 Q. That's very fair, Mr Roll, and I’m grateful for that
10 Can we look at some PEAKs which indicate the kind of
it work that you were doing and I’m not suggesting, by the
12 way, that these PEAKs are representative of all the work
13 that you did. But if wecan go to {F/94.1} please.
14 That's a PEAK that’s dated 26 March 2001 soit is quite
15 early on in your tenure at the SSC. Could I ask you
16 just to -- well, let’s -- it’s halfway down the first
17 box we've got “Information: long calls detected on
18 Bootle ISDN66” and then there is a series of times
19 relating to particular branches, particular FADs. Are
20 you able to explain what that’s about? What that
21 problem was?
22 A. I think from what! remember calls were only supposed to
23 last a certain time. If they lasted more than so many
24 minutes then it would flag up an error. I think that’s
25 what that says but that’s
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I see, and then you will see several boxes down under
the heading “Graham Critchley”, do you see that?
Yes
And then the next box down:
*F response: lines checked, no longer up. All long
calls cleared. KEL updated”
And then there is a reference to a KEL.
Can you describe what you were doing in relation to
this?
No, I can't remember.
You can't remember.
‘Then you would have been -- it would have been your
final response. The fact that your nameis at the
bottom indicates that you are the final responder for
this PEAK, yes?
Yes.
And generally speaking would it be right to say that the
final responder is the person who has ownership of the
conclusion of the process?
Yes.
And the resolution and usually knows more about the
problem than anybody else, would that be fair?
Not necessarily knows more about the problem, no, but
would have ownership of the problem.
And its resolution?
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Yes.
And if we could move on to {F/164.01} please. This is
a PEAK
years into your tenure. It is dated 28 November 2003
it is now acouple of years, perhaps three
and at the top on the first box we've got at 15/10/03,
11.17 and then there is a long acronym. Could you tell
the court what OBC stands for?
I don't remember.
“Engineer to site 21/11/03 am to remove 2 counters and
pin pads from site and return to Triage Services.
Engineer to ensure EOD marker is received prior to
decommissioning”
So an engineer is going into a branch to remove some
counters.
Looks like the branch has closed
It looks like the branch is closing
Then if we go to the next box we've got
Barbara Longley -- who was Barbara Longley, do you
remember her?
I think she was the lady who was the administrative
person responsible for allocating calls
And then several lines down, "the call summary is now”
and there is a FAD number “check for marooned
transactions". Could you explain what the marooned
transactions are?
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1A. [can’t really remember but I think you had an end of
2 date marker and if anything had been -- any transactions
3 that were done after the last end of day marker so if
4 the branch had closed say at lunchtime, anything done in
5 the morning there wouldn't have been an end of data
6 marker left so I believe they may not have been
7 harvested properly and I think that was
8 Q. Well, can I suggest to you that what's happening here is
9 that there’s a basic kit removal operation and marooned
10 transactions are transactions that might be located on
11 the machines but are trapped in -- they are stuck in the
12 machines, possibly because of a hardware error. Would
13 that be right?
14 A. Possibly.
15 Q Isee. And you will see halfway down the same box:
16 *Pre-scan: assigning call to Richard Roll in EDSC”
17 Do you remember what EDSC stands for?
18 A. No, I don't
19 Q. Bur it is assigned to you and then if we go to the next
20 box down your response is:
21 “There are no marooned transactions; EODs and cash
22 accounts harvested okay.”
23 So what work would you have done there to result in
24 that report?
25 A. I don't know.
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1 Q. Youcan’t recall?
2 A. I don't remember.
3 Q Ise. Well, let's try the next one {F/193.1} please.
4 This is dated 26 February 2004. This is the year you
5 left and the first big box with big text in, another OBC
6 exercise of some sort, "planned short notice close”, so
7 it looks as if a branch is closing down:
8 “ROMEC Engineer to site 18/02/2004 AM to remove 1
9 counter and pin pad from site and return to triage
10 Services. Engineer to ensure EOD marker is received
11 prior to decommissioning”
12 So an engineer is going to a branch to close it down
13 and remove the equipment, so similar to what we saw
14 before.
15 And then the next box down, about a third of the way
16 down there's a line which reads:
17 “Attended site [18 February]. SMC John confirmed.
18 Synchronisation ..._ ROMEC work complete”
19 Who were ROMEC, do you remember?
20 A. No.
21 Q Andtwolines down:
22 “Information: please check for last CA and potential
23 marooned transactions.”
24 Do you know what “last CA” means?
25 A. Last cash account I think,
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And potential marooned transactions, again is someone
seeking to check whether there were any transactions
stuck ona machine that haven't been harvested and sent
elsewhere, is that right?
Yes.
And then if we go down the page to the bottom of the
page, right at the bottom it is assigned to you, so you
are still doing this kind of work amongst many other
kinds of work
Yes.
~ in 2004 and over the page (F/193.1/2} about halfway
down, 19 February at 11.8, user Richard Roll
“Final cash account harvested correctly, there are
no marooned transactions. No further action required.”
Now, is it fair to say that a significant portion of
your work did involve supporting engineers doing that
kind of work? Would that be right?
I can’t remember what percentage was what. It would
have varied over time. Certainly for the last year
after I had handed my notice in, I’ mnot -- I can’t
remember if there was.a change in my workload or not.
Well, let's go to your second witness statement that you
made in January of this year. It is at {1/10}. You
have already alluded to it. I would like to go to
page 8 (E1/10/8} which is paragraph 25. Perhaps you
131
could just read it quietly to yourself.
(Pause).
Yes.
Abouta third of the way down you say:
“However, if it is helpful to the court for meto at
least clarify my role, then I would add the following
short points: 1, whilst my workload did involve some
support to engineers opening and closing branches,
1 would estimate that this made up only 30% of my work,
and the majority of my workload (estimate 70%) involved
looking for faults on data stores, preparing reports for
the manager asa result of reports of problems with
Horizon experienced by the estate."
‘And then you say
“as part of this role, at least some of the time
I was involved in examining source code
Yes,
Now, first of all, when you say “looking for faults on
data stores”, what do you mean? Would that include
looking for marooned transactions on counters, on the
message stores?
It could do, yes
I see. And would it include checking to see whether
message - whether counters, whether the machines are
locked when they should be unlocked, that kind of,
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1 looking for problems in the configuration data for
2 example in machines which prevent them from working
3 properly? Would you include that as looking for faults
4 on data stores? Because it does seem to be what those
5 words mean, Mr Roll?
6 A. I find —- I can’t remember any specific details of that
7 sort of depth of work that I did. WhatI believe was
8 that I said most of my work was of a more technical
9 nature, not supporting the engineers, but that’s my
10 recollection and that’s the best I can give you.
11 Q Faults in data or data stores, that doesn’t mean looking
12 for bugs in software, does it?
13 A. It’s not technically looking for a bugin the code, more
14 a bugin the data, a corruption in the data
15 Q. Yes. So that’s a very useful distinction actually .
16 A difference between errors in code, bugs in -- what
17 layman would probably call bugs and then data
18 corruption?
19 A. Yes.
20 Q. And data corruption is a vast sort of panoply of
21 problems. It could include configuration problems, you
22 could have data which has some fields that are missing,
23 you could have machines that are locked because they've
24 got the wrong binary setting -. I’m not putting this
25 very technically, I hope you will forgive me. It would
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1 will include a vast array of problems, many of which
2 would be hardware related, would that be right?
3. A. No, not necessarily. Thedata ... it could -- it’s not
4 necessarily the hardware that’s corrupted it. The data
5 becomes corrupt. Data is not hardware or software, it’s
6 the data
7 Q Yes, when II say “many of which could be hardware
8 related” I’m actually trying to put that very point to
9 you, Mr Roll, which is that if you havea data
10 corruption, it maybe the result of a software bug
11 A. Yes.
12 Q. - but it maywellbe the result of something completely
13 different , there are a wide array of things, including
14 hardware issues, would you accept that?
15 A. Yes.
16 Q. So when you describe 70 per cent of your work as
17 including looking for faults on data stores, you are not
18 saying, are you, that that work was looking for software
19 bugs? That's not what you mean?
20 A. Not 70% of it, no.
21 Q. I’mgrateful. And then you say:
22 *... preparing reports for the manager asa result
23 of reports of problems with Horizon experienced by the
24 estate
25 First of all, whois the manager in that sentence?
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I see. So whatyou were doing, he would appoint you to
provide him with reports, would he?
He did, yes.
And those reports -- he would do that because he himself
had received reports of one kind or another, is that
right?
He -- Mik Peach was engaged to another lady who worked
in Fujitsu who was ofa similar or maybe senior level to
him and she occasionally asked him for favours and he
would ask me to write reports and generate reports to
give to her.
You describe them as being “as a result of reports of
problems with Horizon experienced by the estate". What
are these reports of problems with Horizon experienced
by the estate?
I don't remember the details.
Are we talking about standard routine reports that are
generated automatically?
No.
So we're talking about specific reports, what, by human
beings?
Specific reports where I would look at the various
reports that had already been generated, collate the
data and extract specific data for him.
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I see. So there were people producing reports and then
Mr Peach would then ask you to do reports collating the
information that wasin those underlying reports; is
that what you are describing?
Some of the reports were systems generated, some were
generated by other people.
And systems generated - 1 would like to investigate
that a little bit. This also applies to the looking for
faults on data stores that you describe. A lot of the
work you did in looking for faults on data stores was
related to system reports that -- there are a series,
avast series actually, of reports that are
automatically generated by the systemas to its own
performance just to make sure it is working, lots and
lots of automated reports, and when you were looking for
faults on data stores you would be using those reports
to look for problems which you would then be looking to
see whether you could see if there wasa problem and if
so what should be done about it?
Okay. Some of the reports were looking for
communications problems, so long calls. Others would be
looking for errors in the data stores. The data store
was harvested every day and the information would then
be processed overnight, so there would be all the
banking transactions from all the counters would be
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1 extracted and batched up and then sent off to different
2 banks and every process along there would generate
3 a report as well. So it wasn't just the data stores, it
4 ‘was the whole system was generating reports.
5 Q. There were an enormous
6 A. Wewould have access to all those reports, sorry.
7 Q Imsorry, I didn’t hear you that last -- that’s my
8 fault, 1 talked over you and now I'm saying I can’t hear
9 you. I’msorry, Mr Roll.
10 Yes, I see.
at So you would agree with me, would you, that there
12 were a large number of automatic reports that were
13 continually produced by the Horizon system
14 A. Yes
15 Q -- to monitor its performance and to look for problems?
16 A. Yes
17 Q And that when those reports generated some hits when
18 potential problems were identified, then people at your
19 level would go and look at them to see whether there was
20 anything that needed to be done about them?
21 A. Yes. As time progressed we wrote more and more reports
22 ourselves -- or programmes ourselves to monitor the
23 system, to alert us to any potential problems.
24 Q. And then perhaps I could ask you to go back to
25 Mr Parker's statement, (£2/11/9}. If I could pick it up
137,
1 at paragraph 34. Mr Parker says:
2 “As noted above, the SSC team provided both 2nd and
3 3rd line support. As with any mix of people, there are
4 {and were) various levels of talent within SSC. Mr Roll
5 was primarily used in operational business change (OBC),
6 which involved supporting the engineers who were opening
7 and closing branches and increasing and decreasing the
8 number of counters in branches.”
9 Stopping there, does that remind you as to what OBC
10 stands for?
11. A. It does, now.
12 Q. And would you agree that you were primarily involved in
13 that activity?
14 =A. That’s not howI remember it, no.
15 Q. Could suggest to you that it is quite possible that
16 because of the process you yourself described a few
17 minutes ago, that one tends to remember only the more
18 interesting things
19 A. It is, it is possible
20 Q. - it is actually possible that that did represent your
21 primary set of jobs?
22 A. Yes, it could be.
23° Q. I'mgrateful. He says
24 “Mr Roll would also have been regularly correcting
25 the application environment after engineers had replaced
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failed counter hardware and clearing temporary files to
increase disc space”
Is thar true?
A. It’s possible
“This could fairly be described as 2nd line work and it
was done by the SSC because it required a higher level
of access to the system than other support teams had.”
1 don't remember it, but it’s possible
Would you accept that?
A. It could be considered that.
Q. And then paragraph 35:
*Some members of the 3rd line support group
identified the need for software fixes via source code
examination and would pass this on to the 4th line team
for a code fix to be written. MrRoll did not play any
significant part in this and was not involved in any
extensive source code examination. An application code
fix would not be written by anyone in the 3rd line team
and he was not involved in the provision of 4th line
support”
Could I suggest to you, Mr Roll, that you did not
play any significant part -- I'm not saying you played
no part, but you did not play a significant part in that
process and you weren't generally involved in extensive
source code examination?
A. That is correct, not generally involved, but I was
139
involved in some source code examination.
Q. Onoceasion?
A. On occasion.
And then would you agree that an application code fix,
that’s a software fix to correct whatI would call
‘a bug, would not be written by anyone in the 3rd line
team; that's right, isn’t it?
A. Yes, we would identify a problem but the software
development team would write it
Q. It’s the fourth line people that fix them and! think
you would agree thar from Mr Parker says here is that
you were not involved in the provision of fourth line
support.
MR JUSTICE FRASER: Is that right?
A. Fourth line support, from that way
The way I was looking at fourth line
1 suppose yes, you
could say that
support was writing code that would monitor the systems
and generate errors -- generate alerts if there was
a potential error, so from the way that’s put then yes,
you could say that.
MR DE GARR ROBINSON: You weren't involved in the support
that was provided by the fourth line?
A. No
Q. Thank you.
So would it be fair to say that the reading of
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copious amounts of code was relatively rare for the
third line of supportand whenit did happen it was
generally done by the senior people that we have
discussed?
A. Yes, I would think so.
Q. And although you did it on occasion, it was even rarer
for you; would that be
A. Yes.
Q. I'm grateful
Then if we move on to paragraph 37 {E2/11/10}
Perhaps I could ask you to read paragraph 37.
A. Sorry, read out loud or .2
Q. No, no, just read it to yourself
(Pause).
Subject to one point which I’m about to raise with
I'mso sorry.
you, Mr Parker says here:
“Moreover, Mr Roll was not working at a level where
he would be required to review code.”
Mr Roll, I’m not suggesting that you never reviewed
code, sometimes you did, but subject to those occasional
times would you accept what Mr Parker says in
paragraph 372
A. It’s again what we said earlier. My recollection is
different to this but it’s possible that predominantly
I did do the workaround. It’s a long time ago.
41
MR JUSTICE FRASER: What about the sentences that say about
the role of the SSC, do you agree with them? The SSC
had access to view, but couldn't amend, source code?
A. Yes, I agree with that.
MR JUSTICE FRASER: That's correct.
then described in the second sentence was rarely used,
And the access which is
or do you not know?
‘A. I looked at the source code on several occasions, but
over a four year period that is rarely used, so ..
MR JUSTICE FRASER: Okay.
MR DE GARR ROBINSON: Well then, Mr Roll, if I could ask you
to go back to your first witness statement, it is E1,
tab 7. If wecould pick it up at paragraph 6 {E1/7/1}
you say:
“My role involved receiving issues or problems being
experienced by people working within Post Office
branches. In many cases, this involved me dealing
directly with subpostmasters and others employed in
Post Office branches”
And then in. paragraph 7 you say:
“By way of example of the type of issue that I would
deal with, if a financial discrepancy had arisen in
shortfall " of £5,000) then I would need
to work sequentially through all transactions over the
a branch (eg a
relevant period and also work through thousands of lines
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of computer coding. Software programmes were written by
us to strip out irrelevant data to enable us to more
easily locate the error.”
Given the discussion we have just been having,
Mr Roll, would you accept that perhaps with the benefit
of hindsight paragraph 7 might give a slightly
misleading impression, I’m sure unintentionally. It
gives, I would suggest, the impression that this is
something you did regularly, that when dealing with
problems arising in branches you would regularly work
through thousands of lines of computer coding, but
that’s not actually the case, is it?
That is not the ease, no, and that is
that is what that suggests.
That's fair. That wasn’t your intention to suggest that
Is that
1 must agree
and it may beI’m reading too much into it.
what you are saying?
My recollection was that I did work through computer
coding of the programmes, but now I'm not so sure.
I'mvery grateful, Mr Roll.
‘Then if we could go back to (E2/11}, Mr Parker's
statement. If we could pick it up at page 10
{E2/11/10}, in paragraph 39 Mr Parker describes how:
“When an incident is resolved, the SSC team member
(or technician as they are sometimes called) types
143
a summary of the incident (known asa final response)
and allocates a response code to the incident in order
to classify it.”
Pausing there, do you remember that that was how the
SSC worked?
No, I don’t remember that.
You do remember the fact that someone would be
responsible for producing the final response on any
PEAK, yes?
Yes.
And do you remember that that person would allocate
a code to the PEAK reflecting his or her judgment as to
the nature of the problem that had been dealt with?
I know that that’s what happened because I have seen the
documents here, but I don’t remember that.
Oh, well, it might be that the questions I was about to
ask you could go quicker but I will try anyway.
“While guidance is provided on when to use each
response code .. allocation is the subjective view of
the technician closing the incident and there is no
re-examination of the response codes later to ensure
consistency ”
Would I be right in thinking that you are not really
in a position to commentat this remove of time?
No.
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1 Q. Then Mr Parker says in paragraph 40: 1 Q Sohe also says this
2 “With that in mind, the final response codes that 2 does not provide any clarity on the
3 were allocated to incidents ... reported to SSC between 3 significance of the error corrected ”
4 1 January 2010 and 31 December 2004 were as follows: 4 I suppose that's a statement of the obvious,
5 “Known issue/workaround - 35.3%; 5 isn't it, you would accept that? The 8.3% could include
6 "Admin - 27.5%; 6 trivial problems, could involve major problems?
7 "Reconciliation - 15.7%; 7 AL Yes.
8 “Potential user error - 10.9%; 8 "Many software errors, particularly in a new product,
9 “Potential software error - 8.3%; and 9 were insignificant, such as correcting capitalisation in
10 “Hardware error - 1.2%." 10 printed ourput.”
11 Are those terms, those characterisations , known 11 Would you agree with that?
12 issue/workarounds, admin, reconciliation, are they 12 A. Yes, I assumeso. I don't know if anything that trivial
13 familiar to you? Would you be able to -- do you have 13 would have been passed through to us, or maybe it would,
14 a sense of what these things mean? 14 I can’t remember.
15 A. Notfrom my time there, I can’t remember them. 15 Q. Well, if we could look at your own -- my Lord, I see
16 Q. Youcan’t remember. Well, let_me ask you this then. 16 that it is 25 past 3. Therewasa break earlier, but
17 You will see in paragraph 40.5 he suggests that if you 17 would your Lordship
18 review the PEAKs for the relevant period the PEAKs that 18 MRJUSTICE FRASER: Well, I assume - are you going to go
19 qualified as potential software errors represented 8.3% 19 what until about quarter past 4, half past 4?
20 of the work that was done by the SSC. Would you be in 20 MRDEGARR ROBINSON: If could go to half past 4 I would
21 a position to challenge that or accept it? 21 be grateful .
22 A. No, neither. I wouldn't -- 22 MRJUSTICE FRASER: Let's have a break now for the shorthand
23 Q Neither? You just don’t know. Fair enough. 23 writers.
24 ‘Then Mr Parker says in paragraph 41: 24 Mr Roll, you are in the middle of giving your
25 “A major part of Ist line's raison d'etre is to deal 25 evidence. Please don’t talk to anyone in the short
14s 147
1 with user error and therefore the percentage of issues 1 break or indeed overnight about your evidence, because
2 attributable to user error would be much higher at 2 you are being cross-examined. We will have a break
3 Ist line * 3 until 25 to for the shorthand writers, and if everybody
4 Would you agree with that? 4 could come back for that time that would be good. Thank
5 AL Yes 5 you very much,
6 Q. And 41.2 {E2/11/11} 6 (3.28 pm)
7 “Very few hardware incidents reached the SSC because 7 (Short Break)
8 they were the preserve of the HSD (ie they were 8 (3.38 pm)
9 relatively easy to spot and therefore filtered out by 9 MRDEGARR ROBINSON: My Lord, thank you.
10 Ast line support).” 10 Could we go to {F/1839} please and once you've got
11 Would you agree with that? 1. it up I would like the "RRP live PEAK by category” tab
12 =A. Yes. 12 again, if that's possible.
13° Q 413: 13 MRJUSTICE FRASER: Do you want in or out?
14 "8.3% of calls to the SSC ... are attributed to 14 MR DE GARR ROBINSON: Could you keep going, I'm so sorry.
15 potential software errors over these four years. This 15 Yes, that’s the one.
16 includes duplicates 16 So, Mr Roll, can you see that there’s a table
17 Would that be right, do you recall? 17 here -- if you could perhaps bring the table up so we
18 A. No, 18 could see the whole of it because we are missing the
19 Q. Would yoube in a position to dispute that - 19 first nine rows, I think
20 A. No. 20 This is a table which Mr Parker describes in his
21 Q - the 8.3%-- the PEAK analysis would include PEAKs 21 witness statement. It is an analysis of the PEAKs that
22 that were essentially duplicates of other PEAKs? 22 were produced during the four years 2001 to 2004 and it
23 A. No, I couldn't -- I couldn't -- 23 is an analysis of the codes that were applied by the
24 Q. Youcouldn’t remember? 24 final responder to the relevant PEAKs and do you see,
25 A. No. 25 Mr Roll, that there are a number of-- there’s
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a column on A which is "Closure category” and these are
the codes, the codes that were used at the time that you
very fairly said you don't remember, it being so long
ago, and all the numbers going down from zero which is
"Deleted", all the way upto 200. Then there is a brief
description of these codes and then there is the
column C is the overall count of total number of PEAKs
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with these particular codes and you will see it comes to
9 27,002 and I should -- it is worth mentioning, my Lord,
10 Mr Parker says there are 27,005. This says 27,002,
11 there are three missing, I’m afraid I’m not in
12 a position to tell anyone why.
13. MRJUSTICE FRASER: They might be in cell C2 which has been
14 deleted. It might not count.
15 Can we just click on cell 34C-- I meanit is not
16 a big point so it is not worth .. no, sometimes it
17 shows the formula.
18 All right, it doesn’t matter.
19 MR DE GARR ROBINSON: I'm afraid it was posited only
20 a couple of hours ago and I'mnot in a position to
21 MR JUSTICE FRASER: I don’t think the difference between
22 27,002 and 27,005 is going to make any difference.
23 MR DE GARR ROBINSON: I don’t either.
24 So you will see, Mr Roll, just to explain it,
25 there's the overall analysis of the codes, the
149
1 distribution of the PEAKs between these different codes
2 and then there is a -- if yougo -- youcan skip D for
3 the moment, butE, F, G, H, I, J and, these are sort
4 of broader categories which are intended to encompass
5 different groups of code, so Mr Parker has chosen
6 “Potential software error” then "Potential user error”,
7 “Hardware”, "Admin", "Known isstte/work round”,
8 “Reconciliation” and "Documentation", do you see those
9 broad categories?
10 =A. Yes.
11 = Q. Just to explain how it works - it is not nearly as
12 complicated as it looks. If you look at "Potential
13 software error” you go down and you see there is a 1 on
14 row 12. That corresponds to closure category 59:
15 "Ref data fix available to call logger”
16 That's the official code, or rather a brief summary
17 of code 59 and it shows that there are some hits in that
18 code category during the four years that you are there.
19 Do you understand how it works?
20 A. Yes.
21 Q Thennext one down, another potential software error is
22 60:
23 “Software fix available to call logger”
24 And the third one down is 61 "Build fix available to
25 call logger”. Do these phrases, "Reference data fix
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16
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18
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20
21
22
23
24
25
available to call logger”, “Software fix available to
call logger*, "Build fix available to call logger”, do
those terms ring any bells?
No,
Or is it really just to
time trying to -
I'm afraid I can’t remember any of those.
‘would I be wasting valuable
‘That's fair andI won't -- and then just to complete the
picture, row 24 there's a code 74 which is also treated
as a potential software error and this is "Fixed at
future release” but given what you have just said
perhaps will leave it at the fact that you are not in
a position to challenge these categorisations, are you?
No.
And then we've got "Known issue/workround” in column
The first one, the first hit is at 64, “publish known
error’, that sounds quite logical, so if there’s a known
error log already in existence that’s just taking it and
saying "This is the KEL that applies to this problem’.
And the next one down is "Unpublished known error” and
the next one downis "Solicited known error” and the
next one down is “Avoidance action supplied". Again,
would I be right in thinking it is probably not
a valuable use of time to ask you about those
categories?
151
No.
Okay. Well, this is Mr Parker's categorisation and you
will see that he distinguishes between potential
software error and known issue/work-arounds and if we go
down to the bottom of the table, looking at the overall
figures of the 27,002, we have 2,252 which are treated
as potential software errors, that’s 8.3% andI think we
have already discussed that figure and I believe you
said you are not in a position to dispute that
calculation, is that right?
That's correct
And then if we go over to "Known issue/work round” there
are 9,545 of those which represents 35%, 35.3% of the
work being undertaken by the SSC while you were there.
Again, would I be right in thinking you are not in
a position to dispute that?
Yes.
Thank you.
Now, staying with this document I would like to go
to a different tab please. Could we goto the
“Final responses” tab. Now, this, Mr Roll, is an
analysis of the PEAKs for which you were the final
responder.
Right.
And you will recall that this is addressed in
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1 Mr Parker's witness statement. You will see that there 1 demanding that you accept them
2 are 915 PEAKs in which you are the final responder while 2 A I~ yes.
3 you were there in your 44 months when you were at 3 Q. If these figures are right, these just represent the
4 Fujitsu and there's a breakdown of which particular 4 PEAKs in relation to which you were the final responder,
5 categories you had applied to the relevant PEAKs when 5 you were the one who had ownership ~- if I can use that
6 you closed them. 6 horrible cliche -- of the resolution of the problem and
7 A. Right. 7 the closure of the PEAK. It’s true that you would have
8 Q Doyousee that? And if we could go back please to "RRP 8 worked on other PEAKs along the way, you would have
9 live PEAK by category” which I think is to the right, 9 been, you know, allocated the job and then it would pass
10 you will see that as well as an overall analysis of the 10 to someone else and so on, it would have passed through
11 work done by the SSC there’s also an analysis of the 11 your hands, but wouldn't it be right to say that the
12 would, that you did, "RR", this is in the pale -- is it 12 PEAKs where the music stopped -- the PEAKs that landed
13 beige? When Iwasa child I think I would have called 13 in your lap as the final responder would be a fair
14 it fawn but we have to say beige now. There is a beige 14 a representative reflection of the nature of the work
15 line and it has your 915 PEAKs and you will see 15 that you did as between different categories of work?
16 “Potential software error”, the total for the SSC is 16 A. Yes, I should think so. There were probably some that
17 8.3% but do you see that your total comes out at 3.2%? 17 I got to start with that I then passed on to, as you
18 A. Mm-hm. 18 said earlier on, more qualified personnel within the
19 Q. Would yoube in a position to challenge that percentage? 19 department.
20 A. No. 20 Q. Isee.
21 Q. Is it fair to say that it would reflect the nature of 21 MRJUSTICE FRASER: Mr De Garr Robinson, just so that I can
22 the work that you did because you weren't one of the 22 follow one of the tabs on this document can we go back
23 senior specialists ? 23 to the -- I just havea question for you about the
24 A. It’s possible, yes. 24 entry. Can we go back to the "Final responses” tab
25 Q. And if we go along to "Known issue/work round”, whichis = 25 please. Do you see there from row 21 downwards on the
153 155
1 column, as I say we have 35.3% for the SSC but we've 1 left -hand side the category is given but for some reason
2 got 61%, nearly 62% for you. Again, would you be in 2 there isn’t a description on the left-hand side. Is
3 a position to challenge that allocation? 3 that just because there isn’t enough room in that cell
4 A. Notonthe figures here. WhatI can say is that in some 4 and I should look across to column D for the
5 instances more than one person worked on a snag at 5 description?
6 a time, but their involvement may not be included in 6 MR DEGARR ROBINSON: Are we looking at column
7 this and also that over time my workload would have 7 MRJUSTICE FRASER: I mean look, for example, at row 21
8 shifted and ... well, I 8 which is "As category 70°, row 13 category 70 then says
9 Q Ise what you are saying. The point about this doesn’t 9 “Avoidance action supplied” but for some reason it
10 cover all the work you did because you would have worked 10 doesn’t on row 21. That might not be an issue because
11 on other PEAKs for which you were not the final 1 it has avoidance action in column D.
12 responder, could I just suggest to you that that may be 12 MR DEGARR ROBINSON: Let me take instructions. I hadn't
13 true, I'msure that is true, but it’s also true, 13 noticed that and will take instructions
14 isn’t it, that the PEAKs on which you are the final 14 MRJUSTICE FRASER: It is not important for now, just tell
15 responder are representative of how you spent your time, 15 mein the morning.
16 the proportion of the work that you did as allocated 16 MRDEGARR ROBINSON: Ican tell your Lordship one thing
17 between different -- it’s unlikely that you would be 17 your Lordship may find helpful is that there is
18 a final responder in categories which didn’t represent, 18 a document which gives an indication as to what these
19 you know, a fair allocation of the work you were 19 codes actually mean. It is froma later period in 2011
20 actually doing at any particular time, would it? 20 but I'minstructed that it is broadly accurate and for
21 A. It’s interesting because this isn’t how I remember it, 21 your Lordship’s note, if it your Lordship is interested
22 but that’s what the figures say so 22 ‘as to what these codes actually mean, it is (F/823} and
23° Q. But just if I could put my point again, it’s a small 23 the analysis of the codes starts at page 23 of that
24 point and will move on. You say, fairly, that these 24 {F/823/23}. I’m not suggesting -- there are some codes
25 are just -- assuming these figures are right and I'mnot 25 that are omitted but if your Lordship would like to know
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more about those codes, it is actually -- I was going to
take Mr Roll to them but given his --
MR JUSTICE FRASER: I imagined you probably would. 1 was
just curious about that column but it doesn’t matter,
please don't interrupt your flow.
MR DE GARR ROBINSON: I will take instructions overnight.
I'mso sorry to keep you waiting.
MRJUSTICE FRASER: It is my fault for interrupting
MR DE GARR ROBINSON: So, Mr Roll, with that analysis can we
go back to your first statement please. It is (E1/7/2}.
It is paragraph 11 that I’minterested in. You say:
“1 would estimate that there were over 30
individuals working on the same floor as me ... in the
Fujitsu building at Bracknell. My recollection is that
many of those individuals were involved in similar work
to myself, or were involved in other Horizon related IT
work. I would describe much of the work being carried
out as ‘fire - fighting * coding problems in the Horizon
system.”
For “coding problems” I take it you're talking about
software bugs. Onthe basis of the analysis of the
evidence that we have just been through at slightly
painful length, would you accept that it is possible
that you may have rather exaggerated the position, no
doubt unintentionally, in the last sentence of
187
paragraph 11?
A. Certainly the wayI remember it doesn’t agree with the
figures, so yes, it is possible that
Q. Much of your work was not fire- fighting coding problems
at all, was it, coding problems represented a tiny
amount of your work?
‘A. On the evidence you have just supplied, that’s correct.
Q. Nor did it occupy much of your colleagues’ work either,
if welook at the overall figures, 8.3% for software
errors, would you accept that? Even that -- it would be
unfair to describe the process that was undertaken
during that four-year period as fire fighting coding
errors by the SSC. It’s just not accurate, is it,
Mr Roll?
A. From volume perhaps not. Time-wise avoidance action
would obviously take much less time than trying to find
a software problem. But the figures certainly
contradict my recollections of it
Q. That's fair
If we could move back to paragraph 9 (E1/7/2} you
say:
“We regularly identified issues with the computer
coding in the Horizon system. We would then flag those
issues to the Fujitsu IT software developers.”
Mr Roll, you didn’t regularly identify issues with
158
computer coding that would be flagged for the fourth
line support, did you? That's just not consistent with
the figures we have been looking at?
A. The way I remembered it was that we were as a department
finding issues every week but I’m notsure if that is
the case now. That was my recollection
Q. I’m grateful. ‘Then paragraph 8-- this may have been
carefully drafted, or it may actually have been
carelessly drafted and I’m not attributing any motives
to you, I’m genuinely not, but if you look at the last
sentence of paragraph 8, you say:
“If an error was referred to us then it was
extremely unlikely to be due to a mistake made by
a postmaster; the vast majority of errors 1 dealt with
were due to coding errors or data corruption.”
Just to be clear, Mr Roll, you are not saying that
the vast majority of errors you dealt with were coding
errors, are you?
No.
>
Q. And when you say “or data corruption”, that includes all
sorts of problems
All sorts of problems ~
that had nothing to do with software bugs?
Yes.
oPrPoPr
I'm grateful. Now, I would like to ask you about
159
paragraph 10 of your witness statement (E1/7/2}.
I'msorry, Mr Roll, I'm told that the transcriber
hasn't got the last answer. Could I read my question
again and then you can answer it again. I think it may
be my fault for having talked over you. My question
was: and when you say “or data corruption” that includes
all sorts of problems that have nothing to do with
software bugs?
A. Yes.
I'm very grateful
Then paragraph 10 on page 2 {E1/7/2} of your witness
statement:
"My recollection is that the software issues we were
routinely encountering ..”
Do you think there’s a danger that by describing
yourself as “routinely encountering” software errors,
you may have unintentionally exaggerated the position?
A. I'mreferencing here the whole department, not myself
and it was my recollection that as a department we were
routinely encountering software errors, which, as we
have previously said, the figures don’t support that but
that was my recollection.
Q. That's very fair, MrRoll, thank you.
You say:
"My recollection is that the software issues we were
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1 routinely encountering could and did cause financial
2 discrepancies at branch level, including * shortfalls *
3 being incorrectly shown on the Horizon system.”
4 I think you will accept, won't you, that software
5 issues did not routinely cause branch discrepancies?
6 You are not saying that, are you?
7A. By “software” there I mean software and data issues,
8 corruption, et cetera
9 Q You're including data corruption issues and
10 A. The whole thing, yes.
11. Q Isee. So when you say “software issues” we should
12 would it be fair to say that whenever you refer to
13 “software issues” we should probably read in the
14 possibility of other data issues that aren't concerned
15 with software bugs?
16 A. Yes
17° Q I'm grateful
18 MR JUSTICE FRASER: By “software bugs" I think
19 Mr De Garr Robinson is talking about code issues.
20 A. Yes.
21 MRJUSTICE FRASER: That's how you are putting it. You are
22 using in your statement, as far as I can tell,
23 “software” in a rather more generic way, is that
24 correct?
25 A. I'matraid so, yes. I should have - it has beena long
161
1 time.
2. MRJUSTICE FRASER: That’s my understanding from both other
3 cases and today. Coding is whatin the computer
4 industry they would describe as software issues, I think
5 and that’s the way you are putting your questions.
6 MRDEGARR ROBINSON: Yes and I'm suggesting that the fact
7 that you have a data problem
8 MRJUSTICE FRASER: I understand that.
9 MR DE GARR ROBINSON: -- bears no necessary relation to
10 MRJUSTICE FRASER: I entirely understand all of those
it points. Just so that you, MrRoll, if you could specify
12 in any of your answers when you are referring to coding
13 using the word "code" then I will understand and
14 Mr De Garr Robinson will understand what your answer
15 relates to.
16 A. Yes, my Lord.
17 ~~ MRJUSTICE FRASER: All right.
18 MR DEGARR ROBINSON: So back to paragraph 10, I think you
19 have -- I hope I’m not putting words into your mouth.
20 Well, let me the software issues properly
21 so-called -- that’s unfair, that’s suggesting I'm
22 pulling rank on you or something, that’s not my
23 intention
24 Software issues in my definition, bugs.
25 A. Bugs.
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Coding issues. You are not saying that even the whole
group of you, not just you, routinely encountered issues
of that sort? You're not saying that, are you?
We would --a call would come into us with an error in
the accounts or something like that basically. We would
then look for a cause, And so unfortunately my
terminology -- it has beena long time since I was in
the industry. So it could be the code or it could be
the data corruption and we would have to try and find
out which one it was.
So you are not saying that you were routinely
encountering coding issues, are you?
Bugs, no.
I'm grateful. And then you said these issues could and
did cause financial discrepancies at branch level ,
“these issues” being both software issues and data
Data,
-- more generally data issues. You are not
suggesting -- actually let me break it down so we can be
completely clear about what we're talking about. You've
got -- it is not a venn diagram, in fact it is the
opposite of a venn diagram, We've got a category of
whatI would call -- let's call them coding issues so we
know exactly what we're talking about, and then we have
a category of data issues. Would! be right in thinking
163
that the data issues that you encountered were far more
frequent than the coding issues, the coding issues
actually were quite rare?
We would always encounter data issues. Those data
issues could be caused by a coding issue, or they could
be caused by something else and I would say they were
usually caused by something else.
I'm grateful. So data issues that were the result of
coding issues represented a very small proportion of the
total world of data issues, yes?
Yes.
I'm grateful. And then of that -- we then look at data
issues and we have data issues that result in
discrepancies at branch level
Yes.
Would Ibe right in thinking that the number of data
issues that cause discrepancies at branch level were
very small compared with the total number of data issues
with which you were wrestling?
My recollection is that the data issues we were dealing
with were generally -- that it was quite a high
percentage of
1 will
You say causing problems at branches, there are all
they were causing problems at the
branches,
sorts of problems that would be caused at a branch. For
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1 example you could have a configuration problem which
2 means the machine isn’t working properly. ‘That's a data
3 issue, isn’t it?
4A. Yes, yes.
5 Q. That would bea problem at the branch but it wouldn't be
6 a problem that would cause a discrepancy, would it?
7A. So what! meanis from what I remember, alot of the
8 data issues that came in, we got them because there was
9 a problem with the accounts, a balance mismatch.
10 somewhere. This is how] remember it. And if we could
11 find a problem-- if you could pinpoint it to the data
12 itself then you could perhaps find the problem and fix
13 it. If youcouldn’t find where the problem was in the
14 data, or you couldn't understand why it had happened
15 then there was the potential for it to bea software
16 problem, so then you would pass it over. It didn’t mean
17 there was a software problem, it meant there was
18 a potential for it.
19 Q. Well, I'm grateful for that and actually I think you may
20 have just agreed with what I'm about to put to you.
21 Could I ask you to go to Mr Parker's first statement
22 please. It is at {E2/11/11). This is where Mr Parker
23 says this:
24 "Classifying an incident as a ’ potential’ software
25 error does not necessarily mean that there was
165
1 a software error ..”
2 I believe that’s the point you just made to me,
3 isn’t it?
4A. Mmhm.
5 Q “and, even if there was, it does not mean that the
6 error was one that could have caused a financial impact
7 in a branch's accounts ..”
8 Would you agree with that?
9 AL Yes.
10 Q. Andthen he says in brackets
11 *.. (a large proportion of these would be errors in
12 numerous data centre resident systems that the
13 subpostmaster never sees - errors were often as_ trivial
14 as the use of "Kg’ instead of *kg’ on receipts ).”
15 Would you agree with that?
16 A. [can't remember.
17 Q. Well, I do suggest to you, Mr Roll, that even when you
18 had a coding error that created a data problem in
19 a branch, the number of data errors that actually
20 created a branch shortfall was a vanishingly small
2 proportion?
22 A. My recollection is that it wasa big part of our job, so
23 for me working there it didn’t seem like a small
24 proportion, a vanishingly small proportion. Also
25 just -- if there wasa potential software issue and we
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passed it over for investigation, if they couldn't find
a problem it didn’t necessarily mean there wasn't
a problem, it just meant they couldn't find it. $0.
I can’t agree fully with what you have just said
Well, let me continue with what Mr Parker says:
“As stated in paragraph 16 above, such errors were
extremely rare”
‘That's coding errors which caused a financial impact
on branch accounts. As a proportion of the work coming
into the SSC, coding errors causing financial impact on
branch accounts was extremely rare, would you agree?
Yes.
Thank you. And you say that problems would come in
because there were discrepancies in branch accounts and
that’s how you would often see a problem, but of course
there’s a large number of possible causes,
Yes.
-- for those problems, including user error, would you
agree?
Yes.
‘And would you agree that a significant proportion,
a large proportion of even the problems that got through
to the SSC, to third line, they were due-- probably due
to user error?
My recollection is that maybe 50% ~ I'm trying to
167
remember now. [can’t remember it fully. But my
recollection is that it wasa pretty balanced mixas to
cither user error or maybe data corruption,
So let_mesee if I understand your answer, So what you
are suggesting is of the problems that came in that were
concerned with branch account discrepancies, you say
your recollection is 50% you would have put down to user
error?
Yes, I’m-- I’mtrying to just think of it now and maybe
50% wasuser error. Certainly -- 1 wouldn't have liked
to have said that the majority, or a vast majority was
user error, but it is possible
Then let's move on to paragraph 42:
"Mr Roll’s suggestion in paragraph 10 that software
issues in Horizon ‘routinely’ caused discrepancies in
branch accounts is misleading. In the vast majority of
cases such an occurrence would cause a receipts and
payments ... mismatch that would be flagged by the
branch system as part of the balancing process
Is that right?
I think -- I'm
‘There were instances -- no, I can't
not sure. I think that’s right
“In the vast majority of cases such an occurrence would
cause a receipts and payments .. mismatch that would be
flagged
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1 That's true, isn’t it?
2 A. In the vast majority, yes.
3 Q. Then he adds:
4 "... (the Horizon system carries out
5 self -consistency checks which generate alerts in the
6 event of a receipts and payments mismatch that are
7 picked up by SMC and incidents raised for the SSC) ..°
8 Do you remember that?
9 A. In the vast majority of cases, yes.
10 Q. And it appears on MSU reporting. Do you remember what
aL MSU reporting is?
12 A. No.
13. Q. “These would then be investigated and resolved by the
14 ssc.”
15 Is that right?
16 A. I can't remember
17 Q. Andthenin 42.1 he says
18 “Since the introduction of Horizon in 1999 there
19 have been 735 live incidents which refer to ‘payments
20 and receipt mismatch’ (ie incidents recorded against
21 ‘components of the system providing Horizon service to
22 Post Office rather than incidents raised against test
23 systems)”
24 Stopping there, would! take it that you are not in
25 a position to challenge that figure?
169
1 A. No.
2 Q. "This figure has been obtained using a textual search
3 across all incidents where the title or one of the
4 incident updates contains all of the words ‘receipts ’,
5 "payments’, ‘mismatch””
6 Would you agree that there would bea fair way of
7 trying to find the relevant PEAKs in this respect?
8 A. If you're looking for receipts and payments or mismatch
9 then yes.
10 Q. I'm grateful:
11 "It should be noted that this is not 735 unique
12 incidents; there will be a lot of duplicates with the
13 same root cause”
14 Would you agree with that?
15 A. [can’t disagree with it.
16 Q. “The only way to determine how many unique incidents
17 there were would be to manually review all of the
18 incidents ”
19 I take it you would agree with that?
20 A. Yes.
21 Q “All of them were resolved.”
22 Do you accept that?
23 A. [can’t comment.
24 MRJUSTICE FRASER: I don't think he would bein a position
25 to -- I meana question would be I suppose: from your
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time there do you remember any that were not resolved?
MR DE GARR ROBINSON: Yes, thank you.
A. 1 -- only vague memories of some things that may have
not been -- we couldn't pin anything down specifically
to code, or we couldn't find a problem, so it was
assumed that the postmaster must have made a mistake.
Q. Well, you say “assumed”, Mr Roll, wouldn't it be fair to
say that when you're looking at -- we're now looking at
software coding issues, you're looking for coding issues
that may have caused a problem, would you agree that an
enormously thorough amount of analysis is done to try
and figure out how a coding problem may have caused this
particular symptom; would you accept that?
A. Yes.
Q. And the SSC would keep going, people like the five
specialists and indeed you when you were involved on
those occasions, you would keep going until you had
satisfied yourself, as far as any human being could,
that it wasn't down toa coding error; would you accept
that?
A. Sometimes there were times ~ well, sometimes there were
time constraints from what I remember, so you had a few
days to find a problem and produce an answer.
"Sometimes". How often did that occur?
A. I-couldn’t say, but that’s one of the things that sticks
171
in my mind that there were occasions. Very
infrequently.
Q. I'm grateful.
{62/11/12}:
"These incidents
Let's move on to page 12 please
We are now talking about receipts and payments
mismatches:
‘These incidents are reported as a result of
self consistency checks carried out by Horizon. It
should be noted that a R&P mismatch is not only caused
by a software error, It can also be caused by
product reference .. data
That's right, isn’t it?
AL Yes.
Then 42.3
“Receipts and payments mismatches happened more
often during the early life of Horizon
And there is a reference to a tab which I will go to
in a moment:
“My analysis of that data shows that there were
around 8.6 such incidents per month on average between
1 January 2001 and 31 December 2014 (417 out of a total
of 27,005 incidents into SSC, or 1.5% of SSC incidents
during that period)”
We can goto the table if you like but I apprehend
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1 that you would probably give me the same answer that 1 Now, if you encountered a software error causing
2 you're going to give me now which is that you are not in 2 a branch -- well, actually, I’mso sorry, let's go back
3 a position to challenge that analysis? 3 to paragraph 19 of your first statement which is at
4A. T'mnot. 4 page 3 {E1/7/3)
5 Q. Sowhatwe're talking about, if this analysis is right, 5 Could I suggest a way of rewriting paragraph 19 that
6 is 1.5% of incidents going to third level, going to the 6 would make it if not more accurate, at least read more
7 third line which consist of payments and receipts 7 fairly. You start by sayin;
8 mismatches and that means that less than 1.5% of 8 “In summary, the issues with coding in the Horizon
9 incidents going into SSC would have been discrepancies 9 system were extensive”
10 in branch accounts caused by software issues, by coding 10 But it would be fair to say "but represented a tiny
11 issues. Do you accept 11 proportion of the work coming into the SSC”, would you
12 A. Yes: 12 accept that?
13. Q. -- the logic of what Mr Parker is saying? 13 A. Sorry, which one are we looking at now?
14 A. I don’t knowif the receipts payments mismatch would 14 I'mso sorry, paragraph 19 on page 3 of your first
15 include other balancing problems or not. 15 witness statement.
16 Q. Burl think you have already agreed that in the vast 16 MRJUSTICE FRASER: I don't think the witness has reached it
17 majority of cases such an occurrence would cause 17 yet. Heis using the hard copy.
18 a receipts and payments mismatch? 18 Look under tab 7 and then look at the penultimate
19 A. 1 believe so. 19 page of your witness statement which should have
20 Q I'mgrateful. On the basis of that evidence -- would 20 {E1/7/3} in the bottom right-hand corner. Do you see
21 you give mea moment, Mr Roll, I do apologise. One of 21 thar?
22 my questions is being corrected by a junior whois far 22 A. Yes, thank you, my Lord.
23 too able for his own good. 23 MR JUSTICE FRASER: It has paragraph 19,
24 At page 1721 think I did what is conventionally 24 MR DEGARR ROBINSON: Mr Roll, I should have done that and
25 called an American misspeaking. My question was "1.5% 25 I do apologise for not having seen your predicament.
173 175
1 of incidents going to third level which consist of 1 You start by saying:
2 payments and receipts mismatches and that means less 2 “In summary, the issues with coding in the Horizon
3 than 1.5% of incidents going into SSC would have been 3 system were extensive”
4 discrepancies in branch accounts caused by software 4 Would it be fairer to say that the issues with
5 issues” and I’mecorrected, I should have said: 5 coding in the Horizon system represented a very, very
6 potentially caused by software issues. 6 small proportion of the issues that the SSC dealt with?
‘7 MRJUSTICE FRASER: I think you meant potentially caused by 7 A. From the evidence you have shown me just then I would
8 coding issues. 8 agree with that.
9 MR DE GARR ROBINSON: I really do mean that. 9 Q And then you say:
10 MRJUSTICE FRASER: But you then did go on to say “by coding 10 “Furthermore, the coding issues impacted on
11 issues” after software issues 1 transaction data and caused financial discrepancies on
12 MR DE GARR ROBINSON: But the key word is “potential” 12 the Horizon system at branch level ”
13 1 wasn’t seeking to suggest to you -- I was seeking to 13 Would you accept that the proportion of coding
14 suggest to you there is a wider category. You recognise 14 issues that had that effect was even smaller?
15 of course there are potential coding issues and then 15 A. Yes.
16 there are actual coding issues and the former is 16 And the next sentence:
17 a larger class than the latter. We have lots of ven 17 "It was those issues that I, and other colleagues at
18 diagrams today and what I was suggesting to you there 18 Fujitsu, were routinely working on daily ”
19 was I was talking about the larger class 19 Well, that’s not really right, is it, Mr Roll? You
20 A. Yes. 20 and others were not working on these issues daily, were
21 Q That is what must be less than 1.5% 21 you, they werea very small proportion of the work that
22 A. Yes. 22 was being done?
23° Q. -- would you accept that logic? 23 A. From the bugs then yes.
24 =A. Yes. 24 Q. Thank you.
25° Q. Thank you, Mr Roll. 25 MRJUSTICE FRASER: By bugs you mean coding?
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1 MRDEGARR ROBINSON: Coding.
2 MRJUSTICE FRASER: I seem to be the only person who cares
3 about what words are used.
4 MR DEGARR ROBINSON: So if we could go back to paragraph 10
5 please on page 2 of the same document (E1/7/2}. You say
6 that -- you refer to software issues, which we now know
7 is a wider category, it’s both coding issues and data
8 issues
9 *.. could and did cause financial discrepancies
10 if wewere unable to find the cause of the discrepancy
at then this was reported up the chain and it was assumed
12 that the postmaster was to blame”
13 When you say “reported up the chain”, to whom was it
14 reported?
15 A. To our manager and that’s as far as I knew. I don’t
16 know where it went after that
17 Q Andwhy would you reportit up the chain? Why wouldn't
18 you just complete the PEAK in the normal way? There
19 seems to be some significance attached to a process of
20 reporting?
21 A. Usually, from wharI remember, there was some pressure
22 onus to come toa resolution, a solution
23 Q. Oh, youmean~ I see, so do I understand this, that it
24 wasn’t -- the management didn’t want you to close your
25 eyes to issues of that sort, management wanted you to
7
1 figure out what the problem was?
2 A. Quickly.
3 Q. That was the encouragement that
4 A. They wanted a quick answer, yes
5 Q. No, let's take this in stages. They wanted you to
6 figure out what the problem was, is that right?
7A. Yes
8 Q. And now you have added the word “quick”. Why do you say
9 quick
10 A. “Quick” was perhaps the wrong word.
11 Q. -- doyouthink that’s entirely fair?
12. A. AsI recall, sometimes we felt under pressure to
13 provide -- to examine the data and give an answer within
14 the timescale.
15 Q So sometimes the SSC was busier than other times and
16 when the SSC was busy then sometimes you would say,
17 what, you didn’t have as much time as you would have
18 liked to have got to the bottom of the problem?
19 A. Yes.
20 Q Andin that situation where you hadn't done enough you
21 would report that situation up to your manager, would
22 you?
23 A. Yes
24 Q. And that would be Mr Peach, would it?
25 A. Yes.
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13
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16
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18
19
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22
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And what would Mr Peach say?
I don't know what he said to his -- to the management
above that, I"ve got no idea
But it would be fair to say -- I think I’m-- I hopeI'’m
drawing the right inference from whatyou said a minute
ago -- it would be fair to say that Mr Peach would want
you to bottom out the issue, to get to the bottom -
Yes.
of that issue that was reported to you. He didn’t
want you to close your eyes to a problem, did he?
No.
I'm very grateful, Mr Roll
When you encountered a coding issue which had
well, did you ever encounter a coding issue which had
a financial impact on the branch account?
I can’t remember. There were times when I suspected
something like that and passed it on, from what I do
remember, to one of the other
To seek more senior people
Yes.
who might be able to look at it in more greater
depth?
Yes.
But you don’t recall ever having encountered, in all the
PEAKs that you worked on, a coding issue that definitely
179
caused a financial impact?
I don't recall discovering one, no.
I'm grateful.
So my next question was going to be when you were in
that position, what would you do, but I apprehend that
you won't be able to answer that question?
I can’t remember.
I was going to ask you about identifying all the
branches that were affected by that coding issue but
I apprehend that it’s just not something you can speak
to, is that right?
No.
Isee. Can you just give mea moment. I'm sorry to
keep you waiting.
So if we could go to {E2/11/3]. Paragraph 17,
Mr Parker says:
“On the very rare occasion that a software problem
which could cause a financial impact in branch accounts
arose, it would be investigated and resolved and Fujitsu
‘would determine its impact on the Horizon estate and
inform Post Office of any financial impact on branches
so that they could be resolved”
Would I be right in thinking that’s just not
something that’s within your experience because you were
never in that situation?
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1A. Yes.
2 Q. Then! don’t need to go there.
3 My Lord, it occurs to me that now might be
4 a convenient moment.
5 MRJUSTICE FRASER: All right.
6 Mr Roll, I said at the break you were going to go
7 overnight, so if you could come back tomorrow please,
8 10.30.
9 AL Yes
10 MRJUSTICE FRASER: And remember what I said about not
11 talking to anyone about your evidence. ‘That doesn’t
12 mean that you can’t talk to anyone about anything, but
13 you can’t talk to anyone about your case or your
14 evidence.
15 Housekeeping
16 MRJUSTICE FRASER: Couple of housekeeping things, we may as
17 ‘well deal with them now. I don’t think I have had
18 a file next of your witness statements for next week
19 MR DE GARR ROBINSON: No, that's in hand, my Lord.
20 MRJUSTICE FRASER: I would also like a single -- and this
21 can be doneas a running file. The PEAKs thatare being
22 used in cross-examination -- and I think there have only
23 been two or three of them so far -- if I can just have
24 a hard copy of whichever ones are in fact used and those
25 just put in a file and that file can be updated each
181
1 day.
2 MR DEGARR ROBINSON: My Lord, we can prepare that. That
3 would be helpful
4 MRJUSTICE FRASER: At the moment! think there is just the
5 ones used in opening plus the three from today, so it’s
6 not going to be very difficult
7 MR GREEN: My Lord, would you like as we go along to have
8 a second section with the associated KELs?
9 MRJUSTICE FRASER: Yes, if that's going to be useful.
10 MRGREEN: I think typically you may see both.
11° MRJUSTICE FRASER: Allright. So that’s that
12 You were going to tell me how many documents had had
13 to be disclosed result of your recollection , or the
14 redaction review.
15 MR DEGARR ROBINSON: I was. My Lord, may we do it tomorrow
16 morning?
17 MRJUSTICE FRASER: Do it tomorrow, yes, we will do it at
18 the end of tomorrow.
19 1 would like both your openings in Word but not the
20 appendices. And then I thought I would just give you an
21 outline on the current plan on the judgment in common
22 issues. I've hada list of typos from the claimants.
23 That has not affected the intended timetable to hand it
24 down on Friday. I imagine I will have some-- I think
25 the time I asked for them was 5 o'clock, so I know it is
182
a different team,
MR DE GARR ROBINSON: I'm afraid I know nothing about ~
MR JUSTICE FRASER: No, it is just on the basis that it is
the Post Office here, I thought I would just say.
Assuming they are in the normal scope of typographical
errors, et cetera, I’m still on track to be able to hand
it down finally on Friday at 12 o’clock, but if thar
changes I will tell _you tomorrow.
‘Then one grammatical point which you may or may not
find amusing, I do, but I thought I would ask you.
“Subpostmasters” in the draft judgment you will see
I abbreviated to a three letter abbreviation, or TLA, of
SPM. I have put it as the indefinite article “an SPM”.
Mr Warwick's helpful corrections have suggested that
throughout it should be changed to "a SPM’.
mind because it takes a single keystroke, but in terms
of grammar I thought it should be “an” SPM but thought
1 would explore your views before I hand down a 180,000
word judgment riddled with a potential grammatical
1 don't
inaccuracy. So Mr De Garr Robinson?
MR DE GARR ROBINSON: Your Lordship will have seen from our
submissions we say “an” SPM.
MR GREEN: My Lord, I have no problem with “an” SPM at all .
MR JUSTICE FRASER: You hadn't spotted that.
I actually know with absolute precision what the rule is
I'mnotsure
183
for abbreviations, but we will probably stay with “an”.
Anything else?
MR GREEN: No, my Lord.
MR JUSTICE FRASER: 10.30 tomorrow.
See you tomorrow, Mr Roll. Thank you all very much.
(4.30 pm)
(The court adjourned until 10.30 am on Thursday,
14 March 2019)
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2
Housekeeping
3
MR AAKASH PATNY (affirmed) sensed
4
Examination-in-chief by MR GREEN 8
5
Cross-examination by MR HENDERSON rssoon9
6
Re-examination by MR GREEN ene.
7
Questions from MR JUSTICE FRASER ssosn63
8
MRS ANGELA BURKE (sworn) nena I)
9
Examination-in-chief by MR GREEN
10
Cross-examination by MR DRAPER 68
at
Re-examination by MR GREEN rsesnovon 104
12
MR RICHARD ROLL (affirmed)
13
Examination-in-chief by MR GREEN
14
Cross-examination by MR DE GARR ROBINSON ......107
15
Housekeeping 1 81
16
17
18
19
20
21
22
23
24
25
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aakash (7) 6:5 7:17.18
8:24 9:2 58:17 185:3
abbreviated (1) 16312
abbreviation (1) 183:22
abbreviations (1) 1841
able (18) 11:19 697.10
748 83:16 8410.15
85:12 96:11 10324
109.24 110.14 126:20
145:13 173.23 179:21
190.6 1836
above (7) 53:14 65:5
123:10,11 1362 167.6
1793
abrupt (1) 4:18
absolute (1) 183.25
absolutely (4) 18:24
23:18 36:3 95:4
abundance (1) 5:6
accept (33) 1224 26:6
34:9 39:25 83:29 924
10323 1146 1164
11610 12037 112
1231 12429 1254
134.14 1398 141.21
1435 145:21 1475
155 15723 15810
1614 170.22
y71a3.39 17341
174.23 175.2 176:13
accepted (4) 41:13
5168 119.13,
accepts (1) 35:4
access (6) 115.17
125.18 1376 139.7
423.5
‘accompanied (1) 103:4
accord (2) 91:10 11718
accordance (1) 2:9
according (3) 34:10
41.2 55:25
account (13) 50:13,
35:13 77.26 87:2 95:21
96:1 99:10 100.9
yo112 13025 151:13
168:6 17915
accounting (3) 7:2
1012 12336
accounts (20) 76:25
7727 6417.21
85:17,21,28.25 129.22
1635 1659 1667
167.9,11,14 16816
17310 1744 16018
accurate (5) 47:1 85.12
156:20 158.13 175:6
accusing (1) 57:23
acerbic (1) 4:24
‘ackah (2) 62:19,21
acronym (1) 1286
‘across (15) 4:17.23
40:13,18 43:7,13,16
44:14 58:14,16 59:12
101.24 102.1 156-4
1703
action (6) 102.9 131.14
151.22 1569.11
158.15
actions (2) 97:1,11
activity (3) 29:25 61:24
13613
actual (5) 36:16 52:25,
551 12318 17416
actually (43) 2:29 10:8
17:19 262 49:21
56:16 592,16 62:18
73:21 74:47 75:12
76:22 80:10 623,13
85:18 87:11 999,
102.15 106.7 108.13,
1159 11819 120:24
1217 133.15 1348
136:12 13820 143:12
154:20 156:19,22
15721 1598 163:19
16433 165:19 166:19
1752 168:25
adamant (1) 6021
add (2) 27:18 1326
added (5) 5425 694
1027 116.20 1788
additionally (1) 51:25
address (1) 95:20
addressed (1) 152.25
adds (1) 169:3,
adjourned (1) 184.7
adjournment (1) 94:3
adjust (2) 33:15 10213
adjusted (2) 32:8 35:18
adjusting (1) 61:2
adjustment (1) 29:22
adjustments (6)
1623.25 24:10 29.25
342 59:15
admin (3) 145:6,12
1507
administered (1) 3:22
administrative (1)
12820
adrees (1) 8:25
advance (1) 3:24
advantage (2) 78:11,13
advice (2) 33:24 40:18
advise (1) 91:5
advised (5) 59:25
60:14,19 62:4 632
affected (4) 96:25
1003 1809 182:23
affirmed (4) 7:18
106.14 185:3.12
afraid (6) 5:21
149:11,19 1517
161.25 1832
after (39) 12:25,25 152
168,10,23 205
21.8.14 25:19 26:20
27:03 31:15.17
328 33: 41:17
425,21,21 49:22
65:24 79:11,21 613
828.15 035.25 87:3
88:7 94:15 97:11
1293 131.20 138.25,
17411176
afternoon (4) 2:15.17
421 683
again (41) 2:24 10:21
17.17 227 25:6
26:9,25 27:1.2.25 305
31:20,22 32:2,17 33:2
343,417.18 36:15
4221 43:16 489
5719717 816
96:22 96.25 12:15
13946 10:10 2312
14:28 14852 151.22
152115 1542.23
16044
‘against (5) 3:17 68
20:23 169:20.22
‘ago (9) 111.22 11219
128,10 126.8 138:17
14125 149420 1796
‘agree (37) 12:8 30:24
3913.15 465
55:15,17 7610 @614
ui0-14 11120 1121
114.22 116.26 1235
1371 13832
40-411 1422.4
14313 1464.11
347-11 1582 166:8,15
167.411.1921
170614,19 171.10
1768
‘agreed (5) 36:10,20
56:22 165:20 173:16
‘agrees (1) 28:21
‘ahead (1) 48:24
‘kash (1) 61:4
‘alarming (1) 24:19
‘alert (1) 137.23
alerts (2) 140:18 1695
allegations (1) 9:24
allocate (1) 144.12
allocated (3) 145:3,
15416 155.9
allocates (1) 1442
allocating (1) 126-22,
allocation (3) 14429
154:3:9
allowed (2) 45:19
125118,
alluded (1) 132.24
along (7) 79:21 103:2
110.21 1372 153:25
1558 162.7
‘already (15) 37.2 57-21
90: 99:18 10:19
1021.4 198,13,
122.1 131-24 135:24
15118 152.8 173.16
‘also (25) 11:4 49:13
615,23 65.5 68:7 723
92:2 94.25 99:6
109:17.21 1134
125,20 136.8 138:24
142425 147: 151:9
158411 1547.3
166:24 172:11 18120
‘ater (1) 12327
atthough (5) 10.8
12119 122: 124:20
1416
aways (2) 88:22 164.4
amend (2) 114.18 142.3,
amended (4) 8:24 91
6621 1079
‘american (1) 173:25
‘amongst (1) 1318
‘amount (17) 10:1 12:13
168 2613 33:12 354
363.13 45:8 6015,
613 731 85.36
116.45 1586 17111
‘amounts (2) 12417
prey
amusing (1) 1830
analysed (1) 119:19
analyses (1) 116:3
analysis (16) 100.11
nea 14621,
149:21,28 149.25,
152.22 1530.11
156.23 157:9.21
1711 17220 17335
analyst (1) 96:20
analytical (1) 113:10
andy (1) 9619
angela (3) 66:13.22
1858
annotation (1) 63:12
another (13) 723,
50:12.22 55:12 64:21
8227 10022
107:18,19 1305
13568 15021
answer (18)
8:10,1214,16.16 335
e622 91:4 12433
1603.4 16224 168-4
171.28 1732178413
1606
answering (1) 345
answers (2) 64:9 162:12
anticipate (1) 51:5
anxiety (1) 1062
anybody (1) 127:22
anyone (9) 45:19 93:23
139.17 140.6 147.25
149:12 161:11,12,13
anything (22) 4.25 7:22
15:2 35.11 493 57:25
693 7420 912639
90:3 992225 1108
121.25 129:2,4 137.20
1472 1714 18142
1042
anyway (3) 20:21 78:7
uaa7
apart (1) 263
apologies (3) 113 14:8
235
apologise (6) 5:13
3993,14 5223 17321
17525
apology (1) 1.14
appear (2) 63:25 1057
appearances (1) 37:12
appeared (2) 4:17 95.2
appears (5) 13:20 16:9
34:9 54.25 169.10
appendices (1) 182:20
application (10) 109:24
11361823
124:17,19.21 138.25
139.16 140:4
applied (3) 113:10
149.28 1535
applies (3) 4:12 136:8
15119
apply (2) 66:1 93:17
appoint (1) 135:2
appreciate (4) 44:25
55:6 663 9233
‘apprehend (4) 114.22
17225 180510
apprehension (1) 114-4
approach (1) 55:15
appropriate (2) 3:16
986
approximately (2) 62:9
1225
area (2) 56:21 126:10
areas (9) 32:28 116.14
a7 123.21,22
124.49 125:1.2
arena (1) 52:13
arent (8) 16.22 30:7
35:9 86.28 16114
arise (1) 69:20
arisen (2) 38:13 142.22
arises (1) 106:2
arising (2) 57:22 143:0
arithmetic (1) 53:10
arose (3) 51:6 66.23
18019
around (7) 105,13 149
22.23 2714 37:5
pire
array (2) 134313
arrive (1) 117:10
arrow (3) 59:3,20,21
article (1) 183:13
ascertain (1) 8512
ask (44) 121 412 85
25:14,17 27:21 36-9
40:26 46:1 49:6,23
57:11 68:20 69:4
To8 72:12 75:22
762 85.3.4 88:20
104.24 1083,5,14
1093 110.10 1128
1145 12222 12520
126:15 135.1 136.2
337.24 14191 1a2a1
14427 145.26 151.24
159.25 165.21 1808
183110
asked (7) 13:25 43:22
642,16 99:11 13510
182.25
asking (10) 43:18 56:24
57.20 61:14 65:1 79:8
07:22 10541
a1a3.14
asks (1) 815
aspects (3) 12316
1263.4
assign (1) 63:2
assigned (2) 129:19
peed
igning (2) 129.16
assistant (4)
684,11,15,17
associated (1) 1928
assume (7) 9:27
6220.21 70:6 88:18
1472.18
assumed (3) 171:67
wrat
assuming (3) 99:9
154.25 1885
assumption (1) 1006
attached (5) 59:25
97.18 98:3,11 177.19
attaches (1) 97:22
attempt (1) 47:4
attempted (1) 992
attended (1) 130.17
attributable (1) 146:2
attributed (1) 14614
ting (1) 259.9
‘audit (2) 60:21 63:9
august (3) 62:25,16
1219
‘authorisation (2) 78:2
79:23
‘authorised (12) 72:25
73:9,9,13 78:25 90:1,2
98:24 95:25 98:23
99,7
automated (1) 136.15
‘automatic (2) 84:7
13742
‘automatically (4)
46:6,10 135:19 1363,
available (8) 19:12
99:24 150:15,23,24
151112
average (3) 115:25
1217 17221,
avoidance (4) 151:22
1569,11 158:15
aware (13) 4:20.21 20:6
37:23 43:3 47:15
49:4 76:19 90:24
91:15,16.20 96:3
away (3) 65:10 66.18.19
‘awful (1) 124-3,
b (3) 421 586 10017
back (72) 1:21 5:22 9:4
14:8,9 29.17 31:18,19
32:6,9,17 33:,3 34:4
37:24 392
41:6,7.15,18 42.7.8
43:15 45.22 46:3
47:36 493,10
60:20,22 62:13
63:1,3,5 67:6 72.
76:12,14,16 88:5,22
92.7.8 93:4.6,7,20.24
99:6 100.28 102.1
1068 107:1,23 10:20
117.:11,21 12010
3215 137.24 142.12
143.21 1484 153:8
195:22,24 187.10
15820 162:18 175:2
A774 187
background (4) 66:25
96:5 10010 103:22
balance (11) 13.14.25
20:4 30:1 37:3 46:22
49:14 05:25 68:3 89:5,
1659
balanced (2) 85:24
1682
balancing (4) 47:11,12
168.19 173515
bank (10) 76:15.16 78:9
88:14 94:9,12,25 95:1
96:1 97:14
banking (1) 136.25
banks (1) 137:2
bar (5) 59.19.21
61,1018
barbara (2) 126:28,18
base (1) 123:9
based (4) 12:8 86:19
95:22 1136
basic (2) 113:13 1299
basicaly (3) 4:13 74:16
1635,
basis (8) 3947
562,13 57:20 157.21
17320 1833
basket (3) 71:10 74:2
so
batched (1) 137:1
bear (3) 318.21 278
bears (1) 1629
beat (1) 5:22
become (1) 49
becomes (1) 134°5
before (39) 17.19.21
aga? 19:11,9
206,716 21:9. 2621
2636 41:12 462.4
49.24 521218 54:18
623 6512.13 66
68:7 7021 75:6,25
800,14,17 88:11
90:20 94:5 95:3,
113.28 126.25 125.17
130:14 183:18
beg (1) 63:24
beginning (4) 3:19 710
yoat 43:15
begins (1) 6:20
behalf (1) 56:24
behaviour (1) 1237
behest (1) 57:10
beige (3) 153:13.14,14
being (34) 223 12:19
144,11 21:3 323,
4225 51:9 57.2.5
6035 622 705
875,17 90:25 91:24
92.1.4 93:3 111.10,11
13513 14235 148.2
9:3 152514 157.17
3613 163.6 17118
17322 17622 181.21
beings (1) 135:22
believe (23) 9:9 10:17
a2a7 14:22 15.22
20:5 22:4 30:14 37.9
42.2 57.6.7 65:3 1105
419.13 122:8,11,20
1296 1337 1528
3662 17319
believes (1) 60:3
bells (1) 1513
below (5) 12.2 18:6
433 71:7 10842
Deneicial (1) 65:27
benefit (4) 50:23
103:20,23 143:5
best (4) 23:4 4415 47:2
13320
better (3) 53:23 220.14
3247
between (20) 26:12
53:20 54:10 77:25
7a 7923 6313
107.24 110:6 11420
115.21,22 138.16
1453 149.21 1501
1523 15417 155.15
aa
big (5) 12:13 1305.5,
149:16 166:22
bims (3) 96:14.15 97:19
binary (1) 133.24
bit (7) 52:23 58:10
6024.25 61:7.17
Opus 2 International
Official Court Reporters
transcripts@opus2.com
203 F
B10.1/3/49
POL00004075
POL00004075
March 13, 2019 Horizons Issues - Alan Bates & Others v Post Office Limited Day 3
1368 bug (6) 10:25 3126 I came (16) 31213417 I 15525 choose (1) 8:12 1631.12.28 1591 1623
bits (1) 88.21 1331314 13610 2623 29:17 52.622 I categorisation (1) 152.2 I chosen (1) 1505 168:2.25,916618 I conceivably (1) 282
blame (1) 17712 1406 33:1 48:25 50:16 categorisations (1) ctristmas (1) 20:14 1678.10 concer (1) 27:25
block (2) 56:23 61:17
blue (2) 61:15 715
bogerd (3) 565 57.23
75.28
bogerds (1) 55:5
book (1) 5:24
books (1) 37:4
bootle (1) 12638
both (8) 46:25 48:3
136-2 1622 163:16
1777 182109
bottom (21) 37:6,
89:1.15 91:12 93:8,10
96:18,20 97:1.16.17
118:16,22 127.14
131.6,7 152.5 175:20
176.18 179:7,7
box (13) 45:21 66:10
971,11 102:10 126.17
127.4 1285,17
129:15,20 1305.15
boxes (1) 1272
bp (2) 132.23
brackets (1) 16:10
bracknelt (1) 157:14
branch (76) 10:24,25
11s 17:7 1812
202,12 21:19 27:10
31:8 33:11 34:24
35:15,13 364 47:22
54:21 62:22 63:1
67.19 66:5,25 71:20
828,169.21 894
92:10,23 94:17 95:13
96:15,15,16.18,19
99:11 100.16,17.25
302.11,12,12,16
103:25 109.15
128:13,15,16 1294
1307.12 142.23,
161.2.5 163:15
164:14,17.25 1655
166:19.20 167:9,11,14
168:6.16,19 173.10
1744 1752 17612
179.15 18018
branches (15) 96:25
97:4 100:3 109:13
126-19 1328 1387.8
142:17,19 43:10
164:23,24 180:9,21
branchs (1) 1667
break (16)
4513,15,17,24 5218
93.17.29 96:6 106.21
147:16.22 148:1.27
163:19 1616
breakdown (1) 1534
brief (3) 45:13 1495
150:16
briefly (5) 108:20,21.22
1091.2
bing (3) 58:10 73:9
ue:i7
british (2) 724-72:
broad (1) 150:9
broader (1) 150:4
broadly (3) 20:4 114:24
15620
brought (2) 5:12 14:11
bugs (25) 10:15
133:12,16,17 134.19
157-21 159:28 1608
1615.18 162:28,25
168.13 176:23,25
build (2) 150.24 151:2
building (1) 15714
bundle (4) 223 66
8:22 1054
burke (32)
66:12,13,17,22 68:3
71:4 75:25 78:20
797,19 81:6 83:4
855,11 87:10,21
8818.24 91:22 939
945 95:19 97:23
964,30 99:21 100.24
1022.29 1035 1048
1858
busier (1) 178.5
business (10) 31:11
42:24 48:8 49:19,20
67.8 9615 10922
1103 1385
busy (5) 27:10 116.88
121.9 176:16
button (4) 39:1 73:5
746775
buttons (1) 71:13,
buying (1) 79:3
€ (2) 124.25 149.7
2 (1) 14913
81h (1) 62
8112450 (1) 619
ca (2) 130:22,24
caleulation (5) 54:24
11816 1195.22
15210
calculations (1) 55:25
cal (49) 65,9 713 138
27.22.28 29:19,22
4010.11 413,45
43.2.4 48.9 529,101
60.22 621,13
631,123 70:24
886,12 92:13
94:6,17,20 95:7
106:13 116-3 128:22
12936 1387 1405
1505.25.25
1511.2,2 1684.23.28,
called (14) 2:13.15 4:3
6:16.18 61:4 62:21
96:14 99:18 109:22
1103 143:25 153:13
17325
calling (3) 737 25.21
6612
calls (29) 60:22 113:14
1152435
1165,13,16.28,
11777.24,16.19
1166,11,12.28,
11927,9,20.25
1206.9 126:17,22
127.6 12821 136:21
14614
73:23 63:6 118:24
119:3 165-8 1685
cancel (9) 189
37:21,28 38:24 39:3
40:9 41:21 42:19.20
cancellation (5) 3815
3917.9 404 43.18
cancellations (1) 42:8
cancelled (9) 36:15,16
37.25 41:2 42:3 43:20
44:25 4921
cancelling (3) 18:19:20
193
cannot (2) 60:21 99:6
cant (41) 522 616
152,15 17.1,15 2020
35:7 61:8 744
91:25,19 92:2,23 93:6
1167 1189 119:23
127:10,11 129: 1301
13116,20 133.6 137:8
145.1516 147.14
151:7 166.16 167:4
168:1,21 169.16
170:15,23 179.16,
100:7 161:12.13
capitalisation (1) 1479
capitals (1) 61:17
card (11) 36:17,25
40:5 49:1 50:9.17.20
617 737.8 788
cards (1) 75:3,
care (1) 9215
carefully (2) 209.1
1598
carelessly (1) 159:9
cares (1) 177:2
carried (8) 16:5,11,20
3235 6911 80:1
187:17 1729
carves (1) 160:4
carry (6) 1323 14:17
156 3623 43:13
aaa
carrying (1) 16:21
cases (6) 142.17 1623
1687.23 1699
yaar
cash (88) 7.45.7 68
11:2,28 125 13.16.19
142.5,13 15:2
1713.16.24 18:1,4,14
191214 2025
217.18 22:24,25
237,9,23 25:19 26:3
27:2,4 29:5 37:2020
4039 42:4 43:8
466.11,13,16 20.21.25
475.4509
5327.21
54:4,9,10,20 552.9.14
56:48,9,13 634,920
646.16,17.22
656,7,11,12.15 66:45
69a 7247 74:15
76:5 98:23 102:13
129.21 130.35 13113
cast (1) 1235
categories (6) 150:4,9
151:25 15335 15418
51:13
category (12) 148:11
149:1 150:14.18 153.9
156:1.8,8 163.22.25
174.14 1777
cause (21) 27:20 69:23
85:14 86:17,20 110.19
113.25 11416 1615
163:6.15 164.17 165.6
168:17,24 170.13
17317 1779.10
180:18
caused (25) 10:15 28:14
37:18 84:24 86:25,
97:4 112.29
1645, 6.7.25 166.6
167:8 168:15
171:10,12 172:10,11
173:10 1744.67
176:11 1601
causes (1) 167:16
‘cousing (6) 91:20 1117
1642.24 167.20
175
caution (2) 5:7 1124
ceases (1) 49:19
cell (6) 58:22 60:11
62:24 149:13,15 1563
cent (1) 134.16,
centrally (1) 106
centre (4) 99:3 109.23,
110-4 16:12
certain (7) 325 73.86
20:8 99:9 123:16
126.23
certainty (1) 92:14
cetera (3) 79:4 1618
1636
chain (3) 172,237
challenge (8) 95:11
120:16 145.21 151:13
153:19 1543 169:25,
1733
challenging (2) 123:12
1242
chambers (1) 5:23
chance (1) 1055
change (9) 113 2414
31:19,19 68:20 72:15
101.15 131.21 1385,
changed (8) 26:20 33:3
37:23 36:16 49:4
112:3 121,10 18315
changes (3) 10113
1212 1638
characterisations (1)
145.11
check (9) 1:37 145
18:6 29.13 35:24
120:15 128.23 130.22
1312
checked (4) 33:21 34:22
36:2 127.5
checking (2) 27:4
132.23
checks (3) 76:16 1695
172.9
chesterfield (4) 27:23
29:22 31:11 56:24
child (1) 153513
chronological (2)
104:12.15,
circumstance (2) 79:24
aon2
circumstances (4) 70.10
750,20 77:12
city (2) 2712.14
evil (1) 89
claimants (1) 162:22
claiming (1) 56:2
73:9 1326
larity (1) 147.2
class (2) 17417,39
classify (1) 1443,
classifying (1) 165:24
clear (21) 6:17 18.28
23:15,18 24:21 25:9
36:25 40:15 42.15
51:4 748.21 78:24
79:7 8019 95:3.9.28
112.22 159:16 163.20
cleared (3) 80:10,17
276
clearer (1) 19:25
clearing (1) 139:1
clearly (1) 36:5
elears (1) 77:5
cliche (1) 155.6
cick (9) 58:21,22
59:16,22 60:11
6212.24 74:15 149.15
clip (1) 38:19
close (11) 26:16 73:25
16:24 77:3,14,22
82:19 1306.12 177.24
179.10
closed (8) 63:1 67.8
62:8,1621 12815
1294 1536
closely (1) 26:1
closes (1) 742
losing (10) 27-10.12
77.28 79:21,23 128.16
130.7 1328 1387
14420
closure (3) 14921
150:16 155:7
clued (1) 123218,
clumsily (1) 55:19
code (38) 100:16
113721 114:18,19
326:17,24 155,79
132.16 1333.6
139:12,14,16,16.24
140:1,6.37
141:1,18,20 14238
14421219
15055,16,17,18 1519
161.19 162.13 1638
ms
codes (14) 144.21,
145:2 148.23
149:2,2.6,8.25 150:1
156:19,22,28,24 15731
coding (45) 143:1,11.19
157:18,20
1584,5.12.23
359:1,15.17 1623.2
371:99,2,19 17330
1748,10.15,16 1758
1762510,13.25,
377.7 1793.14.25
1809
coin (2) 13.19.22
coincidental (1) 105:17
«coincides (1) 10219
collate (1) 135:24
collating (1) 136:2
colleagues (2) 1588
17637
column (31) 13°9,10.23
21:20 2921 4012.13
41:7 54:24 58:16
soa3233
98.14.1421
300:16,17,18 101.21
1028.9 1033 149.17
15125 1541
156:4.6.1 157:4
columns (2) 58.6 59°5
‘come (34) 4:23
26:20,25 28:20 382
43:24 46:2 50:8 69:17
702,7 75:24 76:23
812 885 9278
93:7,20,24 100:13
1068 1067 113314
17:19 1209,10,11
13:4 163-4 16713
37722 181.7
comes (7) 101 36.23
Tea? 10412 119:20
149 153.7
coming (15) 5:6 15:23
27:23,14 66:10
1165, 5,25 117.14
1186.12.12 119.25
1679 17531
‘comment (2) 148-24
37023
comments (1) 125-25
‘commit (1) 11217
‘common (6) 2:9 3:22
4:4 5:15 1022 182.21
‘communication (1)
109.19
‘communications (3)
1036 1097 136:21
‘compare (1) 65:10
compared (2) 19:12
168318
comparing (2) 63:20
655
‘comparison (1) 19:10
complaint (2) 36:12
452
‘complete (5) 80:16
102.23 130:18 151.6
anaes
completely (3) 124:14
134:12 163:20
‘complex (2) 113:16,22
‘complexity (1) 123:3
complicated (2) 32:23
35012
‘components (1) 169:21
‘computer (7) 114.17
1431.11.18 158:22
concemed (8) 1813.13
41:19,20 77:18 116.17
161.14 1686
conceming (1) 9:25
concluding (1) 50:18
conclusion (2) 121:2
ars
conclusive (1) 61:25
conduct (1) 3:16
confidence (1) 39:23
configuration (5)
113:16,17 133:1,21
1651
confirm (1) 109:24
confirmation (1) 94:13
confirmed (3) 77:4
101:25 130.17
confirming (2) 46:24
30216
confirms (1) 76:3
connecting (1) 75:11
connection (1) 6218
connects (1) 76.5
considered (1) 139.9
consist (2) 1737 1741
consistency (1) 144.22
consistent (1) 159.2
s (1) 171.22
consultant (1) 122°4
contact (2) 69:18
yo934
contacted (2) 62:3
30232
containing (1) 96:3,
contains (1) 170:4
content (1) 101:25
contents (4) 9:9 67:19
1076.20
continually (1) 137.23
continue (2) 1:9 167:5
continuing (1) 100:9
contradict (1) 158.18
controversial (1) 1145
convenience (1) 2:25
convenient (2) 2:21
yea
conventionally (1)
17324
conversation (2) 89:13
927
convey (1) 81:19
copies (1) 2:24
copious (1) 141.2
copy (4) 2:25 1078
175.17 161:24
core (1) 124:22
comer (2) 58:24 175.20
conrect (36) 8:13 21:1
2625 35.19 363
504 51:13,14,21
641,13 65:19
67.27.22 68:6 69:9
707 71:11,16 726.19
7521 81.2.9 86:8
89:12 94:10 99:10
103:6 110:25 139.25
140:5 14255 15221
158.7 161:24
corrected (12) 15:24
2936 325,
consti
Opus 2 International
Official Court Reporters
transcripts@opus2.com
203 F
B10.1/3/50
March 13, 2019
Horizons Issues - Alan Bates & Others v Post Office Limited
POL00004075
POL00004075
Day 3
34:12,13,14.16 49:20
83:20 1473 173.22
1745
correcting (2) 138.28
1479
correction (18)
44.21.25 48:1.4,16
49:14 51:7.15 52.3
55:1 57:22 67.5 706
84:20 94:18 102:21.23
1034
corrections (2) 70:3
1314
correctly (5) 14:3 27:27
29:3 37:22 13113
corresponding (1) 47:14
corresponds (1) 150:14
corrupt (1) 1345
corrupted (1) 1344
corruption (14)
119,113,
133:14,18,20 138-20
159:15,20 1606
1618.9 163.9 1683
couldnt (18) 29.18
31:21 32:1 79.18 682
92.22 115.7 1423
14623,23,24
165:13,16 1673.3
1714525
count (5) 16:21 34:25
74:20 1497.34
counted (4) 145.241
306 78.15,
counter (5) 738
992.16 130:9 1392
counters (6) 128:9,14
152.20,28 136.25
1388
counting (2) 22:24 27:2
country (2) 50.13.23
couple (12) 1:4 302
34:17 46:1 49:5 58:4
e2.7 12239 12317
126:3 149:20 181.16
course (9) 35,6,14
41:16 90:12 96:3
1058 167:15 17435
cover (1) 154:10
covering (1) 10:2
created (8) 5414
57.24.25 56:15,16
97.7 166:18,20
credence (11) 57:67
59:25 60:1,4.14
628,14 635 652.3,
credit (2) 1038 12214
criminal (3) 326 7:2
ear
critehley (1) 1272
criticise (2) 95:6 103:18
criticism (1) 95:4
crossexamination (12)
159220 3.21 9:16
68:1 107:23 12512
1812 1855,1014
crossexamined (2)
1191432
crossexamining (4) 4:19
52:5 105:13,15
curous (1) 157:4
‘current (2) 17:22
16221
customer (52) 38:24
717 722,412.18
733,6,14,15,16,17.24
747,10,13 75:5
783.67.11,16177 214
791,512.21
80:1,4.14,17 81:3
87:24 88:14,23,25
89:21 90:2.20,21
94:9,12,24 95:5
998,10,19.20
customers (16) 27:9,13
36:25 73:10
75:8,12,13 77:1,25
789 79:10,16 62:17
95:1 961 97:14
4 (6) 139 4032 1502
1564.1
daily (2) 176:18,20
danger (1) 16015
data (94) 12:14,16
15:23 25:25 26:11
308 37:7 41:19 42:22
52:4,6,8.11 54:49
5614 573.519
7620.22 99:3,24
1002.4 111.6,11,13
11318 1163 129:5
13212,19
133:1,4.11.114.1427,
1343,4,56.9.17
13525.25,
1369,20,16,22.22
1373 1432 150:15.25
159:25,20 1606
1617.9.14 1627
1639,16,17,10.25
164:1.4,48,10.1
1652.8,11.14
166:12.18,19 168:3
1722.20 1761
177717813
date (16) 15:14 38:20
39:19,20 42:24,25
549 91:18 93:11
97:2.1,18 100.21
101510 103: 129:2
dated (4) 97:10 126.14
126.4 130:4
dates (2) 30:19 42:24
datewise (1) 49:21
day (46) 11:23,24
129,22,23 15:3
1914,38 21:13
229,20 34:15,15
36:25 41:9,10 42:23
43.21.22 48:8,8,12.13
49:7,19,19,20,21,22.23
5381617
64:25,18,22
65:12.13,16 66:1
69:11 75:10 96:15
12933 136:23 1821
daylight (1) 201.28
days (11) 21:8,19 42:22
43:23 45:21,2 49.25
51:7 69:24 702
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1072328 11248
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157.69 16119
162:69,14,18 171.2
8 174:9,12 175.24
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1822.15 183:2.20,21
185.14
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3:10.11 9:22,24 66:24
142.22 145,25 18117
dealing (10) 39 5:4
36:12 46:3 78:2 96:10
106:8 142:17 143:9
164:20
dealt (10) 10:22 57:17
63:4 90:25 106:3
11525 14413
159:14.17 1766
bate (1) 12613,
debated (1) 7:25
debit (4) 36:17 405
50947
debra (9) 27:22
329,18,21 34:4,15,22
35:20 362
doc (6) 20:5 25:9 26:13
42:4 43.8 56:4
december (6) 37:23
125:22 118.22 119.7
145.4 172:22
decided (1) 82:19
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142,17 153.7
1724.25.25 19:12
203,19 26:18
285,6,89 30,1314
31:8 32:16 33:19
465.1 473,413.14
5321,12,17,21 64.16
2095:11,12,16 69:12
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745.6 8:7 10:24,25
1522 2422 25:19
26:3,7.16 26:12 29:25
30:20 34:11 46:28
54:10 569 59:15
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46
declared (10) 22.9.10
26:1,13,27,20 30:21
323 35:19 53,
declaring (2) 29:15 60:2
decline (2) 8:15,16
declined (6) 36:25
40:25 48:25 49:1
50.17.20
decommissioning (2)
126:12 130311
decrease (2) 54:20
5512
decreased (1) 46.7
decreasing (1) 138.7
decs (2) 19:14 295
default (1) 110.20
define (1) 24.25
definitely (3) 34:7
13283 179.25
definition (1) 162:24
delay (1) 80:20
deleted (2) 149:5.14
‘demanding (1) 155.1
demonstrate (2) 54:25
55:2
demonstrated (1) 87:17
demonstrates (1) 19:22
den (4) 55:5 56:5 57:23
75:28
deny (1) 47:8
department (4) 15:19
159:4 1608.19
depending (1) 117.25
depends (3) 24:25
7119 728
depth (2) 1337 179.22
describe (12) 70.13.23,
107.25 115,13 1278
134:16 13513 1369
157:17 15811 1624
described (10) 29:1
38:14 77:35 98:11
108.10 122:4,25,
138:16 1395 1426
describes (3) 109.9
143:23 14820
describing (2) 136:4
160:15
‘description (8) 103:3
311241129 1149.12
149.6 156:2.5
designed (2) 113,20
desk (12) 13:7 40:6
41:17 90.25 91:7 93:2
109:12,13,21 11035
u3.14
desks (1) 117.11
detail (1) 88:12
detailed (1) 1135
details (7) 60.21.23
63:3 7016 118.9
133.6 135.17
detected (1) 126:17
determine (2) 170:16
180:20
dette (1) 145:25
developers (2) 114:20
158:24
development (1) 1409
diagnosis (1) 113.22
diagram (2) 16323,22
dliograms (1) 174:18
didnt (56) 5:13 13.22
16:18 17.13 243
27:16 26:11 29:13
31:16
35:1.11,14,16.17
36:14,15 39:13
40:6.22,22,23.28
42:11,13,5,17.19,19
50:18 51:24 69:23
70:17 84:25 85:25
86:12,21 87:23,
89:9.24 92:13 936
95:6 9915 112.19
115:3 11924 12512
137-7 154.18 15825,
165:16 166.23 1672
17:24 17817 1799
difference (12) 4:20
26:4,6 46:20 78:5,10
79559 60:8 133:16
149:21,22
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24:5 46.15 56:1 72:4
75:2 7711 79:9 1012
209;12 13413 1372
141.24 150:1,5 152:20
154.17 155.5 183:
differentiate (1) 7:23
difering (1) 26:26
dlificute (6) 55:16 75:20
rag 12113 1243
1626
dificutties (1) 57:23
alificutty (1) 57.25
directly (1) 142.18
lisagree (8) 46.19
111.21 1156 17025
dise (1) 139:2
discern (1) 11215
dliscemed (1) 99:24
disclosed (1) 182:13
disconnected (3) 80:22
89:8 99:4
sisconnecting (1) 9023
discontinued (1) 84:4
discovered (4) 12:19
1355 253
discovering (2) 23:23
1802
discrepancies (17) 20:7
2411 63:18 112,17
161.25 168.15
164:14,17 167.14
168:6,15 173:9 174-4
376.11 1779
discrepancy (44)
12:10,18,23 16:24
15:23 16.12.20 186.9
19:2 2115 2418
43:10 52:25 53:15
55:20 61:3 63:19
64:26,7,12
65:6,7.13,16,20.28
66.6 85:13 86:5,7
87:5,9.10,13,17 88:2
99.22 11020 14222
165.6 17:10
discuss (2) 91:6 105:6
discussed (5) 11:10 763
26:19 14141528
discussion (1) 143:4
disguise (2) 46:16 47:5
dispute (6) 119:1,22.23
146.19 1529.26
distinction (1) 133.15
istinguishes (1) 152:3
distribution (1) 150:1
document (40) 2:22
11:43 13:20 15:11
17:20,22 21:16
25:14.21 38:44
39:29,21
545,8,14,18,23
63:25,17 64:21.25
01:6 63:3 9613.18
97:10,16 98:8,22
99,21,22 100.13 101:3
202.7 1057 15219
155.22 15618 175
documentation (3)
1136.22 1508
documented (2)
1136.20
documents (8) 66
11:20 59:5 81:5 96:8
103.4 1445 18212
does (21) 16:7 1613
23:6 43:14 53:6,5 553
65:25 91:9 1015
zag 11738 1208
123.22 133:4,12
138:9,11 14722 16525
1665
doesnt (22) 3:19 18:10
22:23 23:5,10 42:23
46:10 486 63:14 72.9
78:9 99:14 100.25
O12 123:2 138:11
14918 1549 156:10
157-4 1562 1@111
doing (28) 4:13 13:12
199,14 23:4 27:59
44:14 75:20 78:6,8,14
79:22 90:18 95:4
00:12 103:22 123.25
324:1,22 1251
126611 1278
1318.16 135:2 154.20
done (41) 3:19,20 5:12
15:7 20:7 21:6 33:1
34:3,7 37:22 42:28,25
49:2,4,21,22 50:6
57:1,25 73.6 94:22
95:14 101.7 105
1144 116-11 126:8
129:3,4.23 136:19
137.20 1396 141:3
14520 153-11 171-12
17524 176:22 178:20
36121
dont (79) 1.9,14.16 2:1
3:24 4.25 5:24 81414
9:20 11:8 13.1 22:1
26:9,9 28:6,10 31:23,
32:12,14 35:22 37.15
44:25 45:20 46:8,13,
47:32 4817 872,24
58:7 67:7 78:5 79:13
82:13 93.21.23 99:17
101.15 10318 105:1
106-4 106:15,17,23
03.47 11237
117.43 121:25
125:19,22 1288
129:18,25 1302
13517 139-4 144.615,
145.23 147:12,25
149,3,21,23 1575
160.21 170:28 173-14
175.6 17:15
1792.24 180.2
181:2,17 1635
dotting (1) 148
double (2) 45:8 51:10
doubled (2) 49:8 56:23
doubt (1) 157.25
down (58) 19-15 20:1
23:21 2928 313,19
32:26,16,23 36.5
46:12 589 59.3,
60:9,9,24.25 61:7
62:10,15.16 80.19.25
82:20 83:25 94:8 95.5
98:13 104-12 126:16
127.4 128.22
129:15,20
130:7,12,25,16.21
1316.12 132-4 1494
151-20.21,22 1525
163.19 1687 171:4,19
162:24 183°7.18
downwards (2) 59:20
155.25,
draft (1) 163.11
drafted (2) 15989
draper (20) 4:16 5:1
67:25 68:1,3 83:2
8610.15 87:4,8.15,20
909,12,13 94:5
101:16,19.22 185.10
drawing (1) 1795
dream (1) 32.24
due (15) 3.6 41:16
438,10 71:7 72247
74:33 993 110.24
159:13,15 167:23,23,
dunks (1) 9629
duplicates (3)
146:16,22 170.22
during (13) 220 101
129 68:17,24 969
105:8 118:25 148.22
10:18 158:12
72.47.24
© (1) 1503
et (1) 14222
e110 (1) 131.23
e1101 (1) 1078
co1408 (1) 131.25
e12t (1) 823
e122 (1) 14:20
0123 (1) 35:20
e124 (2) 95 456
e141 (1) 66:21
e142 (2) 66:24 68:22
e143 (1) 6212
e144 (1) 85:4
e145 (1) 95:18
e146 (1) 6712
e171 (4) 106.21 108:
1152 14213
172 (5) 187.10 158:20
360:21.11 175
e173 (2) 175:4,20
e214 (1) 143-21
21110 (2) 141:10
143.28
e211 (2) 1406
165.22
21112 (1) 1724
2113 (1) 160.25
e215 (1) 1086
©2116 (1) 109.16
e217 (1) 122.28
e218 (2) 11821
11520
2119 (2) 120.20
13725
£246 (1) 70:24
£2520 (1) 556
£2525 (1) 75.24
£2526 (1) 766
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752 956 1015.78
3209 122:25 141:23
14716 15:18
carly (3) 411 12635
aa7
easier (4) 48.20.22
59.28 125.21
easiest (1) 1068
Opus 2 International
Official Court Reporters
transcripts@opus2.com
203 F
B10.1/3/51
March 13, 2019
Horizons Issues - Alan Bates & Others v Post Office Limited
POL00004075
POL00004075
Day 3
easily (1) 143:3
easy (1) 1469
edges (1) 23:17
editing (2) 11:12 57:8
cedse (2) 1296.17
effect (8) 19:3 4713.14
48:14 728,15 1211
17614
effectively (7) 41 19.4
377 42:12,22 47.21
52a
efforts (2) 88:13 121:12
eg (1) 142.23
eight (1) 61:13
either (11) 509 678.9
68:10 70:17 74:1 92:3
11720 149.23 158:8,
1683
electronic (1) 38.7
clements (1) 109.11
elite (3) 115:8,10.12
cise (15) 15:2 66:19
67.21.23 67:7 98:3.25,
106:3 120.11 1256
127:22 155110 164:6.7
1842
elsewhere (4) 23:25
119.10 120.2 131-4
email (7) 60:17
97:19,21,22.24
982.12
emailed (3) 59.16.24
a2
employed (2) 108:10
44218
employee (2) 56.25
96:28
employment (1) 67:10
enable (3) 11:11 37:8
14032
encompass (1) 150:4
encounter (2) 164:4
934
encountered (5) 163:2
166:1 175:1 179:13,24
encountering (5)
160:14,16,20 161:1
16312
encouragement (1)
1783
end (19) 3:11 10:12
11:24 228 26:11
26:23 27:17,19 296
48:16 53:1 62:3 69:11
82:22 90:18 1291.35
16218
ends (1) 74:2
engaged (1) 1358
engineer (6)
1289,11,13,
1308.10.12
engineers (5) 13116
1328 1339 1366.25
enormous (1) 1375
enormously (1) 17122
enough (5) 11:22 32:1
145.23 1563 17820
enquiry (1) 103:10
ensure (3) 126:11
13010 14421
enter (12) 26:22 29:7
305 71:12 73.15.17
741.1521 775
7816.28,
entered (4) 269 26:13,
294 78:2
entering (2) 26:22 346
entire (1) 56:18
entirly (3) 105:17
16210 1782
entitied (2) 3:25 52:2
entity (1) 1132
entries (3) 22:19 655
3015,
entry (13) 37.26
596,23 60.17
61:19:20 09:2.15
91:3 93:8,10 97:2
15524
environment (1) 138.25
end (2) 128.11 130330
ods (1) 129.21
equipment (1) 130:23
exm (1) 90:28
ror (41) 28:25 32:35
569 70:1 110:23
12624 129:2 14019
1433 1458.9,10
1461.2 1473
1506.6,13,21
15110.17,18,20,21
1524 153:16 159:12
168-4 165.25
1661.6,18 167:18,24
1663,8,10,12 171.19
17201 175.1
errors (26) 1367
1206 124:16,16
13316 13622 14018,
14519 146:15 147.8
1527 158:10,13
159:14,15,17,18
160:16,20
166:11.13,19
1676,8,10 1836
escalated (1) 120:23
sg (5) 59.16.28 612.3,
632
essence (1) 19:16
essentially (8) 14:4 304
80.24 92:16,20 93:3
1002 146:22
establish (1) 10319
established (5) 72:1
8627 1199 122213
estate (5) 152.13
134.24 135:16,16
18020
estimate (3) 152:9.10
15712
ot (3) 794 1618 1836
even (16) 60:17 70:4
79: 67:22 95:2
99:8 103.25 11516
123.14 1416 158:10
168: 166:5,17 167.22
17614
evening (4) 113 424
449 6937
event (6) 1124.16
39:25 40:23 83:7
1696
events (6) 11:9 15:23
2522.28 30:7 1268
eventually (3) 10.4 16-4
4725
ever (4) 63:5 66:4
179.1424
every (7) 19114 56.16
93:21 101:3 136:23
137.2 1595
everybody (1) 1483
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45:22
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35:21 34:23 35:20,25
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67.21.23 7622 776
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918 1038 12:17
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25:18 246 254.8
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113.21 11623 1932
147.25 48:1 157.22
158:7 173.20 1767
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evolved (1) 121:8
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52.19 55:23 56:2
25:14 867 163:28
exaggerated (2) 157:24
160:17
examination (6) 113:21
124.16 1393.16.24
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8.21 66:16 106:17
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‘examined (1) 12417
‘examining (1) 13216
‘example (8) 4:10 295
721 117.10 1332
142.21 156:7 1651
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‘exceptional (1) 75:10
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‘exercise (2) 59:17 1306
existence (1) 15118
existing (1) 43:12
expect (5) 22:8 94:17
102:21 105.19 119:24
expected (4) 4.6 15:22
83:12.18
‘expecting (2) 12:6
6335
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95:22 123:13 124.6
180:24
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132.13 13423,
135:14.15 142.16
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28:23 54:7,8 89.2.8
94:7 1282.28 126:20
12:24 149.24 15011
‘explained (5) 11:4
48:20 54:17 75:14
79
‘explaining (1) 52:14
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‘explanation (1) 21:26
explore (3) 52:17 53:24
13:18
exploring (2) 23:26
51:23
‘expose (1) 6:10
‘expressed (1) 1221
extensive (4) 139:16,23,
175:9 1763
extent (1) 116.25
extra (2) 32.25 346
extract (1) 135.25
extracted (1) 1371
extraordinarily (1) 35:4
extreme (1) 79:14
extremely (4) 110.24
159:13 167:7,12
extremes (1) 79:19
eye (1) 2:2
eyes (2) 17:25 179.10
£ (3) 101.21 1275 1503,
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£1464 (1) 81:6
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#14663 (1) 69:14
14664 (1) 90:13
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f1a7oit (1) 97:22
f1S071 (5) 11:11 14.9
30,9 52:21 63:14
£15091 (1) 58:6
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£15221 (3) 13:6 29:20
409
FIG401 (1) 128-2
46871 (1) 102.25,
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£1839 (2) 118:12 148:10
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F941 (1) 126.13
factually (1) 35:6
fad (1) 128:23
fads (1) 12619
fail (2) 82: 97:4
failed (15) 43:19 44:10
72:22 81:12.25
82:2,4,11 63:21
24:7,8,25 99:36 1302
failure (2) 81:20 103:6
fair (38) 11:22 15:20
32:1 3922 79
98:16.17 89:9 9221
935 110:9 112.22
1155720 1164
117.18 1223 125:20
1269 127:22 131.15
140,25 14335 14523,
1518 153:21 15419
155;13 158.9 160.23,
161:12 1706 171:7
175:10 178: 1794.6
faleer (1) 1764
fairly (9) 8:17 27:10
69:15 84:14 12225
139.5 149:3 154.24
187
fall (1) 110:20
false (1) 72
famitir (2) 88:28,
145:13
far (17) 4:3 14:24
18:12,13 206
41:19,19 42:18 89:10
124:9,11 161:22 1641
ais 173.22 177.15
181:23,
fashioned (1) 33
fast (2) 741.15
father (12) 723 8:4
9:28 10:25 11:42018
17:28 227 25:16
261 32.01
fathers (1) 226
fault (3) 1378 1578
1605
faults (9) 123:23,
132:11,18 133311
134.17 136:9,10.26
favours (1) 135-10
fawn (1) 153:24
feature (1) 63:9
features (1) 11421
february (9) 40:12 53:2
63:19 64:3 65:4.20
130:4,17 131:12
foods (1) 76:26
feel (2) 45.21 69:10
felt (1) 1782
few (9) 921 16:3,
27:12,21 49:25 61:6
136:16 1467 171:22
111) 96:24
fiddly (1) 52:23,
fields (1) 133:22
figure (30) 12:6 14:14
19:4 26:19,25 28:20
35:18,19 53:21,25,25
54:19 55:5,8.21 602
63:20 65:21 66:45
38:23 119.19 12089
152.8 169.25 1702
y71a2 1781.6
figures (19) 26.17.22
30:5 55:17 65:6,21
66:1 121.18 12222
152.6 154:4,22.25
155:3 158:3.9.17
159:3 16021
file (4) 162:18,21,25,25
files (1) 1392
filter (3) 52.22 63:23,25
filtered (7)
30:9,12.15.16 54:9
55:1 1469
fitering (2) 11212 3010
final (24) 1:7 219 425
38:18 67.11 892
320:18 1273.14.18
13113 1441.8 1452
148:24 152.21,
153.2 154:11,14,18
155:4,13.24
finally (5) 47:30 77:4,23
109:20 183:7
financial (14) 98:25
103:9 142.22 161:1
163:15 16:6 167:6,10
37631 17:9 179.15
360:1,18.21
find (19) 45 515 16:8
69:22 1243 1336
156.17 156:16 1639
165:11,12,13 16713
1707 1715.23 17:10
39310
finding (3) 2:22 36:6
1595
fine (7) 2:18 38:22 36:4
53:28 67:21,23 95:10
finish (1) 24:2
finished (1) 49:19
finishing (2) 70:7 85:8
firefighting (4) 121-12
157.18 158:412
first (50) 1:5 4:2
5:45.19 29:20
31.21.25 32:1 336
3457.15 3766 45:5 543
7025 78.21 79:11
80:3 87.21.25 89:1
91:22 9613 972
98:16 10412
108:1,46,24
109:10,11 1102.5,
1152 121.6 126:16
3285 1305 13218
134.25 142:12 148.19
151:16,16 15710
165.21 1753.14
firstly (1) 720
fits (1) 221
five (13) 27:11 57:8
68:14,17 104.28 105:6
106:4.6 122:24
323:10,24 12418
qa
fix (16) 11325 12418
117.20 121.21
130:14,17 140:4,5,10
150:15,28,24,25
351:1.2 165:12
fixed (2) 1259 15110
fines (4) 113.18 12415
ag.a6 139.12
fixing (2) 117:2 120.7
fog (2) 126:24 158.23
flagged (3) 159:
168:18,25
ip (1) 89:7
floor (2) 115:16 157.13,
flow (1) 1575
focused (2) 10938
32313
focusing (2) 861.15
folder (2) 66:17 106:19
follow (13) 39:6 60.8
75:18 784.20
79:12.16 65:21 95:15
96:11,12 99:25 155.22
followed (3) 34:19 36:7
403
following (7) 22:20 31:3
32:6 33:2 65:16 80:13
1326
follows (2) 120:23 145:4
forget (1) 126:3,
forgive (4) 10022
101.6,16 13325,
forgotten (1) 32:18
form (2) 8:3 387
former (1) 174:26
formula (6) 59:19,21
61:1,10.18 149.17
forward (8) 10:14
2017.22 7818 699
found (13) 63.47
1523 167,37 19:18
21:7 22.25 54:5 60:21
621 8123
four (9) 89:25 1089.11
1099 116.9 1429
146.15 14822 150.18
fourth (19) 38:19
11412 1156 11623
1177 18:48
31912,14.35 1203.7
3223
140:10,12,5,16.22
1592
fouryear (1) 158:12
fraction (2) 120:24
aan22
fraser (180) 111.2417
2:2,5:12,18 327.24
5:2,9.14,17,28
6:4,7,13,16,21,24
7:6,9,13,16,19 6:3,19
a3 15:11 167,12
173,6.9,12,23 183,23
2010.25 213
223,15,21,25
2413,5.9,13,16,20.25
25:7,41,21.23,
30122,15 32:10 35:24
387.21 39:13 40:10
415,25 43:15 4518
4824 49:12
502,6.8,12,16.21
511,3.9,12,17,20.22
5269.13 5313 575
582,25 59:4
618,11.13,16.21
6332.13.28
645,9,13,15,20.5,
654,10.15,19.25,
664,8,14 £2:15,22.25
860 67:4,11,16
907,10,12 93:19
101.15,17,20 1045.21
1053,7.13.18.20.23
1066.15 11235
140.14 142:15,10
147:18,22 148.13
149:13,21 155:21
1567.14 1573.8
16138,21
162:2.8,10.17 170.24
1747101751623,
176.25 17:2
181.5,10.26,20
38249,1117
1833.24 184-4 1657
free (3) 45:23 66.10
108.22
frequent (1) 164:2
fresh (8) 14:17 15:26
a7a3
friday (2) 162.24 1837
front (11) 822 39:22
428 49:2 66:17 68:22
712 791 806 106:18
Opus 2 International
Official Court Reporters
transcripts@opus2.com
203 F
B10.1/3/52
March 13, 2019
Horizons Issues - Alan Bates & Others v Post Office Limited
POL00004075
POL00004075
Day 3
woray
frustrated (1) 95:8
fujitsu (29)
96:6,10,17.28,24
96:21 99:15,21
100:5,12,19 108.21
107.25 108.10
109:13,18 1106 1141
115:16.23 125:1.15,17
1359 1534 15714
15824 176.18 160.19
full (3) 61:19,20 1189
fully (4) 123.2 12519
1674 1682
funetion (1) 96:16
fonctions (1) 123.12
further (16) 2:22
17.20.25 22:18 35:22
57:20 58:1 60:22.24
6210 63:11 91:6
100:20 1028 1044
x34
furthermore (1) 176:10
future (1) 22:12
g (1) 150:3
gain (1) 26:23
wap (1) 79.22
gare (39)
10511,15,19,22
1072324 1248
140.21 142,11 147:20
148.9,16 149.19,23
15521 1566.12.16
1576.9 16119
1626,9,1418 1712
1749.12 175.24
177.4 18129
1922.15 1832.20.21
10514
gas (2) 71:4 72:11
gathered (1) 113.11
gave (4) 614 9:18 57:4
uit
general (3) 27:11
1083.13
generally (12) 310
3020 11517
124:18,20 1254
127.17 139:23.5,
1413 16318 164.21
generate (6) 50:1
135111372
woae.te 1695
enerated (8) 96:24
1351924
13656713 13727
‘generating (1) 137-4
generation (1) 113:19
generic (2) 1221
161.23
gentleman (3) 46.25
50:16 752
genuinely (3) 27:6
117.1 1590
get (14) 2:17 3.21 4.10
5002 27-13 51:14 63:6
797 73:22 79:3
93:46 105:9 1797
gets (1) 5:18
getting (2) 48:15 69.10
sive (23) 2:28 5:24 7:24
5099 68:16 70.16
99:22 90.20.21 92:3
106:6,7 116.24 1330
13512 143.6
1734221 17833
160:13 1€2:20
given (12) 4:1 33.24
3420 4701 69.21
902 991 11610
1434 151.11 15621
1572
gives (9) 1038 1438
15618
aiving (2) 9323 147.24
amt (4)
101:13,5,27.20
goes (8) 10:1 31:3
466.1 71:17 746
7615.22
ving (72) 123
2:15,16,17,20
310.1425 459.28
521.25 7.2.24 856
17:23 21:6 3225
4414 4511,15.16
4613 535 627
636.16 64:21 69455
72.22 64.21 908
914,19 93:9 946
965 97:16 1009
1041215 1052.16.20
1066 1145 119.14
12521 12813 13012
uarae 48.24
1494.22 157
1711527 1732669
1741.3 1004.8 161.6
1826912
gone (26) 22:20 31:18.
3343 344 3721,
69.24 7411 e0a124
923 04.6 85.7 867
89:3,19,20 91:2 952
1391032.35
120391032,
g00d (9) 9:15.16 45:16
683 11928 12018
123.14 148:4 173.23
graham (1) 1272
grammar (1) 18837
grammatical (2)
16399
graphs (1) 121.6
arateful (27) 1.23 59:7
11037 111.23
114925 11946 12125
12659 134.21 138.23
1419 14320 147.21
1597725 1600
16127 163.14
164612 165119
170.10 172:3 173:20
17912 1803
arcat (2) 85.19 11234
arater (1) 179:21
arcon (60) 2:36
2265 5021,15.21
62.611,141822
715.17 82021.22
193 3918 541737
582345927
61103215.2022
63:1 66:1,12.16.17
725,715 108:5,6,7.23
10558
106:213,17,18
1827.10 18323 1643
105:46,9,11,13
srectings (1) 67:7
‘rope (1) 123:24
sound (1) 10:22
ssroup (3) 113-24
339111 1632
‘groups (1) 1505
guarantee (6) 91:15.19
92.2.20,23 98:5
suidance (2) 39:17
was
suys (1) 5714
th (6) 615,23 98.22
100:18 101:25 1503,
hnadat (13) 24:1 34:19
41:15 5024 85:15,20
87:1 95:14 108:25
12:3 156:12 178:20
163:24
half (6) 27:21 347
86:15 1069 147:19,20
halfway (3) 12626
129.15 13101
hhand (11) 22.25 35
384 74:13,14,15
yar-19 182.23,
183.618
handed (6) 38:5
99:8,10.17 1006
331:20
hhandled (1) 121.2
handling (1) 56:8
hhands (1) 155.12
handwritten (1) 83:10
hanging (1) 38.1
hhappen (3) 265 42.19
1412
happened (17) 15:15
2021 21:14 22:5
26:12 29:15 36:21
48:7 19,21 50:1 70.10
95.19 10215 144.14
165.14 1726
happening (3) 626.9
1298
happens (5) 31:13
36:27 46:10 49:18
73
happy (2) 88:20.21
hhard (5) 2:28 44.8,
75:17 161.24
hnardware (11) 109.15
19:12 134.245.7214
139:1 145:10 146:7
150.7
hnarvested (5) 129:7.22
131:3,13 136.23,
hasnt (13) 3:2 10:8.10
314,18 34:23 55:21
89:3,19,20 91:2 99:12
1603
hhaste (1) 105:1
hhavent (10) 5.12 33-4
347 4224 492.5717
105:5.9 106:3 1313,
hhaving (12) 1:20 32:12
43:21 92.9 95:5 98:11
103:18,20 143:4 1605
175:25 179.24
heading (2) 102.9 1972
hhear (5) 26:11 31:26
6213 13778
heard (2) 7:25 8:3
theld (1) 33:12
hello (1) 68:2
help (14) 1:18 13:7
15:18 32:10 40:6
41:17 68:16 91.7
95:17 109:13,21 1102
nga417an
helped (2) 40:25 85:19
helpful (5) 70:21 1325
156:17 162:3 183:24
frejpfully (1) 100.26
hhelpine (17) 14:13
33:23 34:1 40:25
49:6.13 585 59:23
82:15,23,24 868,12
89:10 98:1 94:6 95:22
henderson (65)
2412.23 2.49
35,23 5:4 758,12
95 914,15 1114
15:13 16.35 17:13,24
184,25 19:2 20:10.15
21.2.7 23:14,16 24.21
25:1.6.10,13,22.28
3014.16 3221.13,
36:9 38:18,22
39:16,25 40:11 41:10
42:1 43.10 45:21 462
51:3,4.10,13.21,23,
52:8,10,16 53:15
57:15 58:1 6316.22
1855
hhere (28) 19:3 20:20
29:35 31:4 36:12 41:3
45:3.5,16,25 52:4 57:3
63:6 69:2 74:23 92.95
93:2 108:21 107:10
1195 198 14011
141.16 14415 148:17
154:4 160.18 183-4
high (3) 35:4.18 16421
higher (4) 28:1 58.10
1396 146.2
hightighted (7) 21:18,
61:12,13,15 6211.19
100:14
himsetf (2) 78:7 1355
hindsight (1) 143.6
hit (1) 151.26
hits (2) 13727 15017
fhm (1) 112.25
hold (1) 1223
holding (3) 28:2 36:3,
469
hhome (1) 71:2
honest (1) 20:22
hhope (4) 11:8 13325,
162.19 1794
hopefully (4) 8:22 27:18
62:3 69:24
hhorace (1) 61:24
hnorizon (50) 10:16
Y7:20 23:22 31:14
32:24 39:17 59:14
70:22 71:3 72:25
7:12 76:12,15 78:13
20.22 88:6 86:4,12
87:5,13,18,22 90.25
108:9 109:10,22,14
1136.14 1142 152.13
134.23 135:14,35
13713 157.1618
158.23 161:3 168.15
369:4,18,21 172917
1758 176:2.5.12
180.20
horrible (1) 155:6
thour (7) 79:5
1011,47,81314
hours (1) 149:20
housekeeping (10) 13.4
2353953
381:15,16 185:2,15
houses (1) 1202
however (4) 62:1 99:2
110.22 1325
hhsd (2) 112.2 146:8
thurman (2) 135-22
ans
husband (4) 68:23
94:16,21 102:20
husbands (1) 68:6
frypotheticaly (1) 35:8
fel (1) 1206
1 (6) 29:9 31:17,20.20
98:25,16
Idea (4) 45:14 76:11,14
1793
‘ideal (1) 40:3
identified (10) 69:15
865 87:9,10.14.18,
97.6 137:18 130:12
158.22
identifies (1) 98:14
Identity (8) 69:12.17
84:10 86:12 96:24
310.19 1408 15825
Identifying (1) 180:8
fds (1) 105
fe (3) 11613 146:8
369.20
‘im (142) 1:23 5:21 6.25
7:28 1221 134 15:10
16:2 18:25 199.20
2068.10 21:5
23:34 2621
3:16.28 38:18 39:18
42:15 46:0,23 49:5
51:13,14 53:5
55:18,19 56.1.2
57.215 59:7 618,14
64:21 65:14 69:45
73:20 76:19 798,20
e1:4 858 662
88:20,25 101:1,19
103:19 1066 110.17
111:13,18,28 112-45
114:9,25 116:13,19
119.4 121:18,25 1227
123:5,28 124312
12511 1269.11
131:20 133.24
1348.21 137:7,8.9
336-23 139.21
141,9,13.15,19
143:7,26,19,20 148.14
349:11,11,19,20 151.7
154:13,25 156:20,24
77.
15955,7,9,10,25
160:2,2.10,18
161:17,25 1626.19.21
163:14 164:8,12
165:19,20 167.25
1689.9.23 170.10
3723 173:4,20 1745
1752.4 1794412
180:3.13 183:2,6.24
image (4) 70:25 71:1.14
m2
images (1) 70:22
imagine (2) 79:14
18224
imagined (1) 1573
immediately (2) 49:7
655
impact (8) 16:6
1678.10 1795,
180:1,18,20.21
Impacted (1) 176.10
implications (1) 1237
important (3) 23:16
25:3 15614
impossible (1) 124:23
impression (5) 95:7
103:16,17 1437.8
imputations (1) 1236
Inaccuracy (1) 163:20
Inaccurate (1) 319
incident (9) 96.14.26,
114.16 143.24
144:1,2,20 165.24
04
Incidents (27) 109.19
1131213 1165.25
11720 120.2224
1453 1467
169:7,19,20,22
1703,12,16,18
1725,8,21,23,28
1736917413
Incidentscalls (1)
1824
include (9) 19:23
132:19,28 1333.21
1341 146.23 147.5
17315
included (4) 65:23
302.10 112.23 1546
includes (3) 146:16
15920 160.6
including (7) 73:22
31322 134.1317
161.29 167:18
incorporated (1) 2:10
incorrect (3) 33:24 63-4
ara
incorrectly (1) 161:3
Increase (2) 28:15 139.2
increased (1) 78:2
Increasing (4) 47:13,
79:22,25 1387
incrimination (1) 68
indefinite (1) 163:13
indepth (3) 113:12
323:15,21
Indicate (2) 114:5
32610
indicated (1) 83:13
Indicates (2) 12019
az7ra4
indication (6)
56:14,16,18 68:16
116.25 156:18
Industry (2) 162:4 163:8
inference (1) 1795
inferred (1) 81:25
influence (1) 39:23,
info (1) 602
inform (1) 180-21
information (13) 1:24
19:20 24:13 61.25
624 7411
1028.15.16 126.17
130:22 136:3.23
informed (1) 91:23
infrastructure (2)
11823
infrequently (1) 172.2
initial (2) 89:20 95:22
initony (1) 82:22
inserting (1) 73:7
insignificant (1) 147.9
inspection (1) 1137
instance (1) 2:22
instances (2) 154°5,
168:21
instead (3) 7:1 27.7
166.14
institution (1) 98:25
instructed (3) 72:25
301.1 156:20
instructions (5) 18:23
34:20 156.1213 1576
insulting (1) 125:22
intemperate (1) 4:9
intend (3) 95.6.12 968
intended (3) 61:19
150:4 12:23
intention (2) 14325
16223,
interest (2) 116.14
1259
Interested (2) 156:21
as7aa
Interesting (3) 116:22
138.18 154.21
intermittently (1) 68:15
intemal (3) 619 1141
ua
interrupt (1) 1575
interrupting (1) 157:8
intimate (1) 114.13
into (48) 220 4:25
27:19 32.24.25 366
50:8 52:13 69:13
732,17 72:14
73:47.23 7625
77,16 78:33
84:16,21 91:17
93:1,14,15,22 1027
305:28 11312 114.22
116.25 117.15
118:7,16,17,24 119:25
321.17 128-43
143:16 162.19 163:4
167.10 172.23 173:9
3743 17531
introduction (1) 16918
invest (1) 91:8
Opus 2 International
Official Court Reporters
transcripts@opus2.com
203 F
B10.1/3/53
POL00004075
POL00004075
March 13, 2019 Horizons Issues - Alan Bates & Others v Post Office Limited Day 3
Investigate (4) 69:8,22 118:10,21 126.16 154:19 155:9 156.25 145:16 156:12 16220 I 118:16,17 1195 38:5 51:5 53:10 61:17 I mean (42) 14:16
11022 1367
investigated (9) 622
91:24 92:1,5 93:3,
1111.17 1693
18019
Investigating (3)
6145.24
investigation (3) 91.9
nng2 167
involve (5) 27:1 43:14
13116 1327 1476
involved (19) 109:10
123.9 125.21
152:10,16 136612
13915 18,23,25
140.1,12,21 142:15,17
1575.16 171.16
involvement (1) 1546
involves (1) 71:20
irrelevant (1) 143:2
lewin (3) 56:21,25 67:10
ikdn66 (1) 126-38
Isnt (43) 2.28 10:4
1243 28:25 29:12.14
30:4 32:5 35:10 39:4
46-7437 71:22
143,24 79:2 80:12
01:1,8,13 85:2 68:9
9:1 98:5 96:11 98:8
1019 109:7 1115
116.9 1216 140.7
1475 154:14.21
1562,3 165:2.3 1663
169117243
issued (3) 4329 5521
10212
Issues (83) 2:9 3:2 4:4
5:16 62:7 68:28,
109:14,22 1103
1112,36.14.18,19
12113 13414 14215
146.1 15822,24,25
1595 160:13,25
1615,79.11,13,419
1624.20.24
163.1,2.12.14.16.16.18,
1641.22.45,89.10.13,
165.8 16815 1719.9
1730.11
1745,68.11,11,1546
1758
1762,46,10,14,17.20
177.6,78,25 16222
Issuework (3) 150.7
15212 15325
issueworkaround (1)
1455
‘ssueworkarounds (2)
1452 1524
Issueworkround (1)
15115
items (3) 71:37 82:1
n3a7
its (68) 1:20 2.22.22
12:5,16 19:13 2621
29:1 31:7,15 386,18
44:11 55:16,25 56.7
797 80:12 83:20
85:14 86:17 87:1
88:12 69:19
90:22,23,24 94:1
101312 1129,13
127.25 133:13 134:3,5
16:13 137:15 139:4,4
140:10 141:23,24,25
15324
156:13,17,21,23 1557
18:13 177.7
160:10,20 182.5
itself (4) 12.22 53:4.5
16512
ive (8) 65,11 19.18
3145 37.25 67:0
1793 182.22
J (2) 102:8 150:3
January (6) 125:22
12821 1196 131:23
1454 172.22
job (6) 12258 12513
1263 1559 16:22
jobs (2) 1269 13621
jobn (1) 1307
joined (1) 110:7
judgment (4) 146.12
16221 163:12,19
june (1) 10:12
junior (9) 1:8 63 7.21
11223 122.923
1232.5 17322
K
(1) 1503
keep (10) 17:3 19:21
7920 907 10721
14816 1577
757 16024
teeping (3) 22779
701
kel (4) 114:10 127:6,7
15129
kkels (1) 182:8
kept (2) 77:18 7915
hey (3) 7317 7816
agi
tne 278
heystoke (1) 18316
kg (2) 166:14,14
kind (11) 70:10 73:3
12325 1941.22
12523 12610
151617 15225 1356
kindly (9) 9:4 582.
5934.21 6025,
6232.24 6620 10714
kinds (1) 1319
kit (1) 129:9
now (18) 2725
961.26.819.2425
516.22
06712202325
8721 9019 17715
now (49) 5.25133
221.247 2531 2623
277 267.20 3424
35:12 468 5510
572.24 6923 704
893.490:16.7 1017
10816.17,37 1102
1216 115.7 1167.22
12925 13024 1427
14414 145.28 1472
163:24 1734
177616 179:2 182.25
103:225,
knowledge (13) 47:1
103:23 109:25 1135
116:13,17
123:3.13,15,21,22
124:8 125.1
known (14) 76:23 993
146:1 145,5,11 150.7
351:15,16,17,20,21
152:4,12 15325
knows (2) 127:21,23
11) 1033
lady (3) 94:16 128.20
1358
lambley (4) 27:22
322021 3315
landed (1) 25:12
language (2) 73:3 1155
languages (2) 114.18
12425
lap (a) 15523,
large (5) 12416 137:12
16611 167:16,22
largely (1) 76:3
larger (2) 178:17.29
last (20) 69,24 85:5
862 87:12 93:10 98.2
10416 111.5 125.1
126.28 129.3
130:22.24,25 131.19
1377 157-25 159:20
160:3
lasted (1) 126.23,
later (45) 15:13 19:10
3427 41:8,10
423,17 45:1,2 49:5
1:7 91:18 93:11
144.21 1569
latest (1) 20:2
lati (2) 4:19 8.25
latter (2) 120514 174.17
lay (2) 123:20
layman (1) 138.17
lead (1) 23:22
learned (3) 1:12 2:24
62
least (10) 4:18 24:19
252 55:16 57:8
11:14 12432
1326615 1756
leave (8) 17:21 30:9
6620 151.12
leaves (1) 55:14
ted (1) 1218
left (8) 38.10.22 60.10
79:32 96:1 121:9
1296 1305
lefthand (4) 41:6 62:17
156:1.2
legs (1) 45:21
length (2) 55:20 157:23
tess (7) 325 2210
46:21 158:16 173:8
1742.21
let (14) 1:7 25:12
25:6 46:15 68:19
11216 1156 124:10
163:19 1675 168:4
lets (26) 17:16 22:15,
28:16 29:19,19 40.9
415 47:16 523,17
53:11 58.9 59:8 608.9
11515 1235 126.16
130.3 131.22 147:22
163:23 1683 1723
17521785
letter (2) 101-21 163:12
letters (1) 59:5,
level (22) 31:2 324
122:10,12,17,28
123:278,9.15 1359
137.19 1396 141.17
161:2 16315
164:14,17 173.6 1741
17612
levels (2) 122:19 1384
life (1) 17237
tight (1) 2.6
like (44) 7:22 9:21
10:12 205,22 21:8,
2411 35:11 42.28
49:24 56:22 65:10,11
74:19 91:21 93:20
9914 101:3,25
10835 1108.21
111415 11835
122.22 12439
128.15,16 131.24
1367 148:11 15239
15625 159.25 1635
166.28 171.5 172.25
179.17 18120
1827.19
liked (3) 92:14 16810
17818
likely (4) 29:14 5668
7ea2
limited (2) 97:5 98:5
line (77) 6:20,21,22
19:22 20:25 53:14
1082 109:10.17,21
10:25 111.25
122:1,9,20,23.25
1131,3,4,5.11.28
11412,13.20
12523.4,7.8.15.5,
1166.17.23
1179.15.17
11847825
119:8.12.14,15,
120:1,37,23 101.23
1223 125:24 130.16
1383
139:52,3,7.18
140'6,10,12,15,16,22
141:2 146:3,10 15315
159.2 167.23 173:7
tines (11) 106:9.11
1099 110.21 113:9
127.5 128:22 130:21
142.25 14321 145,25,
list (2) 98:3 162.22
sted (3) 68:3 61:12,22
lterally (1) 29:7,
little (12) 423,28 139
18:2 45:12 58:10
59:2.20 100.18 103.2
1126 1368
tive (10) 114:17.29
121.16 125.8 148.11
1539 16919
locate (1) 1433,
located (1) 129:10
locked (2) 12:25
13323,
Jog (25) 11:5 137 29.19
40,10 48:9 52:9,10.11
55:1 69.28 80:11
81:24 625,20 839.17
41,21 65:15,22 88
89:20 91:2 99:6
a5138
logged (1) 99:5
logger (6) 150:15,23,25
15111,
logic (2) 173:13 174:23
logical (1) 151.7
fogs (1) 585
long (18) 4:24 5:25
45:16 68:10 82:9
9o:t0.14 11:22
auz19 11810 226.17
127.5 1286 13621
141.25 1493 16225,
1637
longer (7) 16:12 2814
48:15 67:2.9,16 1275
longley (2) 126:18.18
look (71) 12:11 136
14:23,24 17:16 21:15
22:19 23:5 28:16
29:29,19 30:7,18.21
33:9 3655 37.6 38:13
40,9 42.23 43:13 48.9
4o7 52.00
53:8.8,11,16 54:39
58:5 59.8 60:10 654
6645.20 675,11
69113 71:3 62:5 85:34
8811 89:1 93:8 98:12
10225 1048 10723
108:5 118.10 12557
126:10 15:23 136:17
337.1519 147.35
150.12 1564,7 158.9
159:10 1636 16432
17518,18 179.21
looked (14) 2117 37:37
226 24.6.1 26:10
33:20 73.23 108:20.21
120.25 124.24 1258
ae
looking (38) 613 20:20
23:4 62:11 63:8
833,16 9117
9311,14,15 100:22
10825 1213
13212,16,20
1331.31.13
1341718,
136:8,10,15,17,20,22
140,16 1525 156:6
1593 1708 1728,89
375.13
looks (10) 23:7 44:16
9914 101:25 103.24
11021 1261516
13007 15012
loose (1) 66:19
lordship (18) 26.21
5:12 61,1422 25:18
108.24 14737
1563617.21,25
183.21
lordships (4) 16,23
16.36 15623
losing (2) 48:15 92:23,
loss (4) 2624 52:18
59120 61.25
losses (4) 49:15 91:18,
932.13,
lot (8) 5:8 20:16 32:2
56:6 1143 1369
1657 17032
lots (6) 56:15 125:5,7
136245 17417
loud (1) 141:12
lunch (1) 98:20
luncheon (1) 943
lunchtime (1) 129:4
M
m (1) 21:20
‘machine (2) 131:3
165.2
machines (5) 129:11,12
132.24 1332.23
major (4) 68:23 97:3
14525 147.6
‘majority (12) 110.25
34117 132:10
159.1417
168:11,11,16,23
1692.9 173.17
makes (5) 48:6 56:18
79:9 88:13 95:4
making (6) 7.4.5.6
31:23 39-4 56:9
‘managed (2) 99:5 105.9
‘management (7) 17:16
21:48 96:16 109:17
177.24,25 179.2
‘manager (7) 56:22
aa6a1 132:12
134.2225 17715
7821
‘managing (1) 99:23
mandatory (1) 125:16
‘manually (5) 588.8
98:6 99:13 170.17
‘many (13) 31:18 57:3
08:18 122-16 126:23
1318 136:1,7 14217
1478 157.15 17016
8212
march (3) 1:1 126-14
1848
‘mark (3) 56:21,25 57:10
‘marker (5) 12811
1292.36 13010
‘marooned (8) 128.23,24
1299.21 13023
3311.14 132:20
‘massive (1) 26:23
‘maths (1) 53:22
matter (9) 2:19 42:11
46:22 795 82.6
10816 121:20 149.18
1674
matters (4) 315 7:3 87
sre
‘maybe (7) 17:3 92:11
1359 14713 167:25,
168:3.9
168,16,21 19:17
2033 247,17 26.21
30:7 46:8 56:6 69:5,24
73:4 86:13 67:5,7 90:7
01:17 105:3 125:22
15219 1335.11
14:19 145:14 149.15
1567.19.22 1617
1657.16.25 1665
1672 170.25 1749
176.25 177-23 161:12
meaning (1) 115:25
means (15) 19:16 21:1
29:26 48.23 50:18
86:4 87:8,12 105.24
19:25 121:15 130:24
3652 17318 174:2
‘meant (8) 7.21. 49.6
50:21 84.14 101:19
165:17 167.3 174.7
‘meantime (1) 94:22
measures (1) 20:23
member (1) 143.24
members (5) 1221.23
31521,16 139.3
memories (1) 1713
memorise (1) 745
memory (1) 55:7
mentioned (2) 25:18
604
‘mentioning (1) 149.9
message (3) 902
13221,24
methods (1) 11322
midday (1) 422
middle (5) 45:18 52:14
90:13 93:22 147:24
might (32) 3:15 4:23
7:25 8:12 17:19 18.23
32:0 45:12 52:12
57.7 58.23.26 706
71:38 72:3 78:24
92.20 95:17 104:23,
105:2 13:28 120:25
123:1 125:6 120:10
1436 144.16
149:13,14 256.10
179.21 161:3
nik (3) 122.20 1358
imiletic (1) 6:3
mind (9) 319,22 17.21
278 121-11 1262
145:2 172:1 13:16
mine (1) 359
minor (2) 1:20 27:20
‘minus (4) 123 1828
3942133
minute (1) 179:5
minutes (17) 26:3 45.16
78:26 80:7 81:2,7 82:7
90:4,9,11 104:24
105:6 106.4.6,7
126.24 138:17
misleading (2) 143:7
168.16
mismatch (10) 165.9
168:18,26 169:6,20
1705.8 17210
1731418
mismatches (4)
1727.16 1738 1742
missing (7) 12:13 63:14
Opus 2 International
Official Court Reporters
transcripts@opus2.com
203 F
B10.1/3/54
March 13, 2019
Horizons Issues - Alan Bates & Others v Post Office Limited
POL00004075
POL00004075
Day 3
95.22 88:4 133.2
14616 149.1
mmisspeaking (1) 173.25
mistake (17) 27:20
291,15,18
51:47,21,21,25,25
32.2 3867 346
11024 15913 1716
misunderstanding (1)
258
imix (2) 138.3 168.2
anuntim (5) 66:23 67:25
119.1 153.18 16:4
modesty (1) 122:2
moment (14) 58:7 83:4
91:1,14,19 95:20 98:9
10013 1503 17239
17321 186013 161-4
1824
monday (1) 48
money (31) 10:5 15:24
16:79,17,18,22 25:2
36:13 49:25
50:4.10.14.19.23,
56.24 743,144.18
75:2 8014 87:24
90:20.21 95:1 96:2
9989.16 1006
smoneygram (27)
36:10,12,23 37:19
38:5 39:1 40:15
43:810.20 48:11,12
45.8 46:3 47:16
49.21.25,
498101213
50:3.3,13.19 55:9 56.7
monitor (3) 1371522
44017
month (3) 125:25
12516 172.21
‘monthly (1) 12137
months (2) 4955 1533
more (51) 2:37.21
4:23,24 26:25 30:1
462.21 5658 617,19
65.17 66.18 69:3.16
73:24 61:21 90:4
11821 12312,13
1241,66.8 125922
1262,4,23 127:21.23
1338.13 1372121
13617 1432 1545
155.16 157:1 161.23
168:16 164:1 17216
17566 179:19,21
‘moreover (1) 161:17
1 (11) 48 56.12
9:18.16 25:19 32.21
1059 12955 15615
18216
most (3) 12211 1252
1338
mostly (1) 103
motives (1) 1599
mouth (2) 112.16
16219
move (14) 45:21 66:18
98:20 100:20,22
101-24 1082 1132
1282 141:10 154.24
158.20 168:13 172:3
moved (2) 100:38 1251
movement (5) 53:20
55:2.9,14 64.2:
moving (3) 25:13,14
953
ims (5) 33:15 55:5 56:5
57.23 75:23
mau (2) 169-10,12,
much (29) 7:19 8:19
9:12 26:1,10 29.8
46:17 565.7 63:25
66:8.9 67:22 69:16
94:1 104:20,21 107.22
125:21,21 14336
1462 1485 15717
1584,8,16 178.17
10465
multiple (1) 97:4
‘mundane (4) 125:22
1263.46
‘music (1) 15512
must (6) 14:1 2618
38.25 143:13 171.6
17421,
myself (2) 157-16
16018
n (4) 13:10 29.21
4013.13
name (3) 100.17 106.23
12713
narrow (1) 12414
national (2) 109:22
1103,
nationwide (4) 90.24
91:24.23,25
nature (6) 117-25 1219
1339 144.13 153:21
15514
nibsc (2) 57:12 11019
nearly (2) 150:11 154.2
necessarily (8) 7:
20:10 259 127.23
136:3,4 165.25 1672
necessary (1) 1629
need (23) 1.9 145 22:2
26:9 30:11 31:12 392
40:21 44:21 52:21,24
53:6 59:4 60:22 66:19
91:6 99:12 106:23
105.25 11410 139:12
142.23 181:2
needed (4) 14:16 25:4
12025 137:20
needs (1) 44:2
negative (1) 71:18
neither (2) 145:
net (4) 19:7 20:3,
728.14
never (17) 2669.13,
32:04 37:25 41:1 423
49:23 57:4 60:7 68:23
69:2 90.21 926
141-19 166.13 180:25
newport (3) 68:4
96:18,19
next (31) 20:19 21:12
3455 43:22 49:23 623
6423 78:17,17 8145
88:7 90:9 94:7 96:8
110:10.18 119:4 127.4
128.17 129.19
1303.15 15021
151:20,21,22 176.16
180-4 181:18,18
23
fight (2) 34:1 49:5,
sine (1) 14829
rpodding (1) 12015
nods (1) 40:5
nomenclature (1) 115:6
rrone (1) 1144
thor (1) 158:8
‘normal (3) 74:17
37718 1835
‘normaly (5) 69:21
7322 74:18 7518
7ea5
note (4) 53:9 92,9
356.21
rroted (3) 1382 170.11
yao
notes (10) 15 21:24
223,10,10,18
27.28,18.19,20
nothing (5) 48:13
108:15 159.28 160:7
1832
notice (3) 70:1 130:6
131:20
‘noticed (1) 156.13
notified (2) 1:12 2:24
november (1) 128:4
rnsbesic (1) 426
number (20) 35:5.15
517 66:16 70:16
103:9 11623 118:6,24
11927 128.23 1372
138.8 148.25 149:7
164'16.18 16:19
16716
‘oumbers (1) 149.4
ssumerous (1) 16:12
‘obe (4) 128:7 1305
13859
‘observation (1) 17
obtain (3) 38:25 94:9.12
‘obtained (3) 84:20
100:2 170:2
obtaining (1) 78:2
‘obtuse (1) 57:3
‘obvious (1) 147:4
‘obviously (4) 31:4
56.25 711 158:16
occasion (4) 140:2,3
1416 160:17
‘occasional (1) 141:20
‘occasionally (2) 125:6
135:10
‘occasions (7) 4:18 57:9
124.24 125.6 142.8
yar ia
‘ccupy (1) 1586
‘oceur (2) 101.10 171.24
‘occurred (3) 12:9 84:3
1019
168:17,23 173.17
‘occurs (1) 1813
‘clock (19) 12:25
206.6.8219.9,12
41:3,4 42:21 48:11
49:18,22 908
98:20,24.25 162.25
1637
‘october (2) 38:10 39:21
odd (1) 88:23
offence (3) 6.25 72
eal
office (74) 47.32 7:6
881056271115
29:28 37:22,24 39:2
41:1:15,18,20
42:7.8.9,16 49.2,3,10
50:8 56.25 57:4
60:,1.11,14,20.22
61:2.4.6.16.24 62:2
63:3 6812 69:18 71:2
75:28 76:12 68:15,
92:19 94:16,21
95:3.28 96:6,10
97:5.25 985,12 99:29
100:10 1027.10.14
103:9,21,24 109.21
110:2.6,7 142:16,19
169.22 160.21 183:4
offices (4) 2421 25:11
51:5 68:13
official (1) 15036
often (8) 110:20 114.19
117-10 1259 166:13,
167.15 171:24 172.37
oh (8) 6-4 53:13 63:24
86:13 86.25 118.16
14416 17.23
okay (56) 5:9 9:23
1021 11:22 13:23,
14:23 15:22 164.6.24
17:12 205 23:11
24:6.15.16 26.14
27:21 2927 30:18
33:6 343.23
35:17,21.22.25
36:6,7.18 37:6 38:2
39:25 1-19 42:15
43:10.13,25 4414
54:21,22 55.12.19
60:8 61:21 62:10
70:20 85:9 92:12
101:23 1026 108:24
129:20 136.20 142:10
152.2
old (2) 3:3.70:2
‘omitted (1) 156.25
‘once (10) 7:21 30:20
42:21 48:8 57:4 72.24
7414 91:16 1169
14:10
cones (7) 62:2 91:7
120.11 121:10,11
191.24 1625
ontine (5) 24:10 388
39:17 59:14 71:3
onto (3) 36:24 73:1
eo.
open (12) 25:8 27:13,15
58:20.21 599
7:10.18 78.1
79:11,15 10:25,
‘opening (3) 132:8 138:6
1925
‘openings (1) 162.19
operated (4)
109:13,18,21 10:2
‘operation (1) 129.9
operational (5) 38.9
39:21 109:22 1103
1385
‘operator (6) 13.10.21
59:21 69:21 98:13
103
‘operators (1) 93:1
‘opportunity (1) 88:19
opposite (1) 163:22
opus (4) 5:16,18,22
39:20
order (9) 16:11,19 37:3
54:15 55:2 77:22
308:12.15 1442
orders (1) 79:4
‘ordinarily (2) 73:20
75:34
ordinary (2) 123:5,7
orgonisation (1) 124.12
original (1) 34:5
originator (1) 117.21
others (5) 122:20 126:2
336:21 14218 176:20
otherwise (1) 54:16
ourselves (3) 57:10
137.22,22
outage (10) 10:18,
11:9,23 129,18,22
84:1,3 9625 973,
outline (1) 182:21
outofpocket (2) 45:3
928
output (1) 147,10
outside (1) 124.21
over (43) 8:19 17.27
18:2 20:8 2420 34:20
51:3,22 54:4 55.21
697 731 7424.15
76:6 69:7 96:20
99810,6.17
1006.18 1028 109:15
116: 121.0
123:17,20 1262
13h1L,19 1378
142,9,24 146:15
152.12 1547 15722
160'5 16516 167.1
overall (8) 19:7 46:9
49:9 149:7.25 1525
153:10 1589
overdeclared (1) 38:12
overlap (1) 114.20
overnight (8) 1:6 2:8
4:26 105:25 136.24
1481 1576 1817
(1) 602
overseas (1) 50:4
overwhelmingly (1)
roa
‘own (5) 109:25 124:13
136.3 147.15 173.23,
ownership (3)
127:18,24 1555
pad (4) 73:7,9 90:3
130.9
pads (1) 128:10
paid (7) 10:6 22:10
8416 67:24
99:26,18.19
painful (2) 54:16 257-23
pakistan (1) 4:22
pale (1) 153:12
panoply (1) 133.20
paper (2) 36:6 66.18,
paperwork (1) 87:3
parageaph (71) 14:20
33:10 45.5.6 55:6
66:24 68.22 69:3
72:24 762.7
62:12,13,22 85:36
26:3 90:14 95:18,19
108:1.8.12
1093,49,11
11011,15,18
1111624 1128
1147.11 113,19
116.12 120:20 121:3.4
131.25 138-1 139:10
ag110,1
142:13,20 143:6,23,
1451.17.24 15731
1581.20 197,11
1602.11 162:18 167.6
168.1314
175351423 1774
180.15
pardon (1) 63:24
parker (27) 108:8,24
9s 1146 11612
11.1 119.19
120:15,20,21 122.19
124.19 125-25 138-1
dona 141:16,21
143.23 145-1,28
148.20 149:10 150:5
165,22 167:5 173:13
180.16
Parkers (8) 108:5
115.19 118.23 137.25
143.21 152:2 153:
165.21
part (10) 39:16 122.3
1325
139:15,21,22,22
145,25 166:22 168:19
particular (10) 9:24
85:5 11713 123.22
126:19,19 149:8 153-4
15420 171:13
particularly (4) 1:6
112,22 1478
pass (5) 127:21 1183
13913 15:9 165:16
passed (11) 73:14 80.13
1187 1198 12317
1253 14743,
395:10,17 1671
a79a7
past (11) 27:11 43:39
44:8 48:10 90:8 106.9
147.16,19,19,20
patny (37) 18,10 5:5
7.17,18,19,21
8:19,22.24 9.2.15
ange 1421 174,24
21:4 25:25 30:18 34.9
36.9 38:6 40:12 42:10
44:35 46: 47:7,10
48:13 5218.23
54:7,21 57-15 59:23,
64:2 1053
patronising (1) 7:22
pause (12) 1:19 5:20
6:0 13:10 19:24
40:13 76.4.8 1095
0.2 1322 141.14
pausing (2) 18.12 144.4
pay (5) 73:2,14,15,17
raa9
paying (2) 747.9
payment (3) 71:20,20
Ta
payments (12)
168:18,24 169:6,19
1705.8 1726.16
1737.14.18 1742
peach (7) 12220
1351.8 1362 17624
17916
peak (25) 104.25,
105:12,16,21 1149
32614 1975 1283
148:9,12 146.21
18:11 153:9 155.7
a7as
peaks (27) 1186.17
119s 12:16
1261012 145.1818
146:21,22 148:21,24
4497 150.1 152:22
1532.5.15 154:11,14
155:4.812.12 1707
17925 161-21
penalty (1) 8:12
pence (1) 56.2
penultimate (1) 175:18
people (33) 93:1 99:22
112.22 115:9.13
117:23,24
322:0,11,13,16,16,16,23,24
32310.11,8
3285,17,19,19
1253.23 1361,6
1378 138:3 140.10
aan 1426 17115
37919
per (3) 115:25 134.16
ya
perceived (1) 124:12
percentage (4) 152.18,
146:1 153:19 16422
perception (2) 124:15
1268
perceptions (1) 128:23
perfectly (1) 3:5
performance (2) 136.14
13735
performed (1) 96:17
perhaps (18) 2:20,25
22:25 53:21 59:16
209:3 123:10 1245
12833 131:25 137-24
ana 1435 14827
15112 158:15 165:12
37810
period (11) 33:24,35
2423 54:5 1162
142.9,25 145.8
156:19 156:12 172.28
periods (3) 116:7.8
amas
permanent (1) 11435
persisted (2) 34.11.26
person (8) 6219.21
ae4 127:18 126.21,
a4g:12 15435 177.2
personnel (1) 155:18
perspective (1) 1258
phone (12) 17.2.7 27:22
329 332 34.20
413,45 43:1,4 62:23
Opus 2 International
Official Court Reporters
transcripts@opus2.com
203 F
B10.1/3/55
March 13, 2019
Horizons Issues - Alan Bates & Others v Post Office Limited
POL00004075
POL00004075
Day 3
phoned (5) 32:21
49:6,23 82.15.24
photograph (1) 71:1
phrase (1) 96:15
phrases (1) 150:25
physical (5)
168,10,15,21 2323,
physically (3) 25:3 27.2
84:16
pick (5) 89:14 11519
137-25 14213 143:22
picked (3) 29:16 31:11
1697
picture (2) 102.23 151:9
piles (1) 27:4
pin (6) 73:7.9 90:3,
128:10 1309 1714
piniel (1) 125:8
pinpoint (1) 165:11
place (3) 42.2.8 43.9
places (2) 24:5 117.17
plan (1) 182:2
planned (1) 130-6
play (3) 139:14,21,22
played (1) 139:21
please (66) 32 6:23,
26:7 37:8
58)5,6,9,10,14,16,22
59:12,13,16,25
60:9.9,10,11 62:12,15
63:14 64:1 70:24,25
71:24 76.2.6 777
80:23 85:4 86:15
89:7.14 90:13
93:21,24 98:12,13,21
100:18,20 101:24
102:2,25 103:2
106:13,21 110:11
118:12,26 12613,
1282 130:3,22 147.25
148:20 152:20 153:8
155:25 157:5,10
16522 1723 17:5
1817
pleased (1) 91:3
plus (6) 16:7,18 23:9
55:13 66:5 182.5
ppm (8) 62:4 94:2.4
106:10,12 1486.8
1846
pointed (2) 39:18 61:17
pointing (3) 12:22 43:6
59:20
points (13) 14,7 26
3:13 9121 56:20 58:4
67.18 87:20 91:21
310.14 1327 16221
pol (1) 96:4
polled (3) 42:22 49:11
4937
polling (4) 15:1 21:14
48:11 49:18
portion (1) 131:15
posited (1) 149:19
position (35) 1222
197.1320
20:2,3,28,16,22,23,
46:6,11 51:5 9211
111.20 119,22
120.16 125:13 144:24
145:21 146:19
149:12,20 15113,
1529,16 153:19 1543
157.24 160.17 169:25
170.24 173:3 18035
positive (1) 72:19
possibilty (3) 23:2
108-23 16114
possible (17) 26:25
293,11 34:19 57:20
138:15,19,20 139:4,4
141.24 148,12 153:24
157.23 158:3 167.16
16812
possibly (3) 104.2
1291214
post (49) 4:7.127:6 88
105,8 24:21 25:11
2rai.as 37:22
42:.20 42:18 508
525 56:25 57:4 68:12
69:18 75:23 88:15
92:19 96:16,21
95:3.23 96:6.10
975,25 985,12 99.22
100:10 102:7,10,14
108:21,24 109.21
110.2.6,7 42.16.19
16922 180,21 163:4
postage (3) 58:20,22
5910
postal (1) 79:3
postmaster (5) 14:1
110.25 159:14 171.6
a7ra2
Potentiat (25) 124.16
130221311
1371823 14019
1458.9,19 146.15
150:6,6,12.21 151:10
1523.7 153:16
165:15.18,24 166:25
17412,15 18339
potentially (8) 3:25
23:3 31:24 33:6 46:23
1212 17467
pound (1) 69:26
pounds (1) 103:7
practice (1) 69:16
Precise (1) 63.7
precisely (2) 2:7 93:9
precision (1) 183:25,
predicament (1) 175.25
predominantly (1)
1ai.24
prepare (2) 74:12 1822
prepared (1) 96:4
preparing (2) 132:12
13422
prescan (1) 129.16
resent (1) 30:10
presently (1) 75:6
preserve (1) 146:8
press (6) 73:15.17
745,20 77'5 78:23
pressed (1) 78:16
pressing (2) 27°7 74.1
pressure (2) 17:22
17812
presumably (2) 36:22
9420
pretty (1) 168:2
Prevent (1) 133:2
previous (17) 189
194,11 20:5 21:8
53:8.12,26 60:19,22
62.11.13 64:25,18
12667 1252
previously (2) 19:22
160:21
price (1) 72:8
primarily (2) 138:5,12
primary (1) 138-21
prin (1) 73:2
printed (8) 298 60:22
#17 62.6.1 839 87.6
x70
printer (1) 73:2
prlor (8) 60:17 62:8
126: 13032
privilege (1) 6:8
probably (17) 422
53:22 65:14,19
11835,9,14 1192
133,17 151.23 1556
1573 161:13 167:23
73 1641
problem (64) 3:4 46
1421 15:9 18:14
22:24 236,7 24.28
25: 34.11 37:18 535
568 7013 84.2.3
(88:5 91:23,25
928,9.15 9610
10325 104.18
114:16,19 117.25
1282 126.21
127:22,23,24 13618
1408 144.13 151:19
155.6 158:17 162:7
165:15,6.9,12,12,13.16,
166.18 167:2.3.15
171'510,2.28,
178:1.6,18 179.10
180:17 183.23
problematic (1) 458
problems (43) 10:19
7ra9 8218
111:7,9,11 113.23
1159 121-21
123:19.20 132.12
13851,21,21 134,23
135.145 1367.22
1375.18.23 14215
14310 1476.6
187:18.20 158:45
159:21.22 160:7
164:22.26,25
167:13.18.22 1685
a3
procedure (7) 37:20.23
388,12 3916 75:17
8013,
procedures (1) 76:12
proceedings (1) @:12
process (28) 29:12
35:7 38:3,15 392.6
40a 42:11 442 70.24
72:3 76:13 80:5
£46,7 96912517
127-19 1372 138:16
139.28 158.2 16619
aia
processed (3) 56:15
103: 136.24
processing (2) 76:22
70
produce (1) 171:23
produced (8) 96,19
7
99:15,7 102.24
137.13 148.22
produces (1) 100:10
producing (2) 136:1
14:8
produet (7) 71:19
122:689,12 1478
y2312
production (1) 11415
products (2) 72:12
73:24
programme (1) 1118
programmer (1) 124:25
programmes (3) 137:
143:1:19
Programming (1) 124:7
progressed (1) 137:21
Prompted (1) 27:25
proof (1) 95:24
proper (2) 78:14 60:13
properly (11) 146
34:19.25 36:22 44:19
47.24.1171 1297
135:3 162.20 1652
Proportion (18) 116.16
ni75 1199.14
120:22 15416 164.9,
266:12,21,24,24
167:9.21,22 17511
176:6.13,21
provide (3) 135:3 147-2
178.13
Provided (8) 109:15
221:113:45,25
136:2 140.22 144.18
Provides (1) 103:9
providing (2) 60:6
169.21
provision (2) 139.18
140.12
pseudo (2) 1121.18
publish (1) 15116
pulling (1) 162:22
purdah (1) 1061
purpose (1) 108:5
purposes (2) 30:10
5415
putting (11) 3:14 19:25
25:1 56:19 87.11.16
112.15 13324 161.21
1625.19
4 (667)
914792872024
1040.11,1418.21
11:24.822
122501215721
1335.15.23
14:816,19.28
152591922
16:1.6.21.25 17:36
1869.12.17.22
1979.20 20:19
25.24
221612151723
234.11 262.69.16
271.4,21.95
2858.11.16 2023.25
293212819
3047.28
3126.16.23
3237.20
339,159.23,
349,149.24
35:3,10,13,15,17.22
36:12,18,21
37:2,6.12,15 38:2,12
39:6,9,11
40:3,69,18.21
41:1,12,16,19,23
42:30,15,18 43.13.25
44:2,5,7,10,14,19.21,24
45.25
46:10,15,19,21,24
47:3,7,20,16,21,23
48:1,3,613,19,23
52:21 53:4,8,20
54:3,1423 555,19,23
56:5,12,18 58:14,20
08
62:10,21,28 63:8 66.24
67:2,5,9,11,14,36 18,22,
68:7,10,16,20
69:2,10,15,20
70:4,9,13,16,21
72:7,9.12,17,22,24
72:1,7.11,17,20.22
73:3,17,19 7412.22
75:1,5,34,17,20.22
76:2,6,30,17,19,22
77:3,8,14,18,21,25
78:11,20 79:7,14,19
80:2,4.12,18,22
91:4,10,15,18
9259.1
83:7,9,26,20,23,25
4:6,10,14,19,24
95:3.9.11,18
26:1,23.25 87.25,
98:2,5,11,18,23,
89:1,7,13,18 90:4,17
er
92:1,4.11,13,18,25
93:8,16 94:11,15,20
95:3,11,7
96:3,8,13,23
97:10,13.16,21
98:2,8,18,20 99:21
100:2,9.16,22
101',6.9,24
102:4,7,19,23 103:14
104:3,11,18,18,20
106.23,23,
107-1,46,8.11,13,16.18,
108:19,21,24
109:3,7.9
110.2,9.14,17
111:11,13,23
312:11,14,10,22 1132
114:9,25
115:5,13,15,19
116:12,21
117'5,14,23,25
118.2610
119-4,12,18,22,24
120:5,14,18
121:4,6,15,25
122:7,9,13,16,22
12318,10,24 1241021
125:4,10,16,20 1269
197:1,4.11,17,21,25
128:2,9,16,22
129:8,15,19
1301321
1311,6,11,22
1324.18.23
133:11,15,20
1347,12,1621
135:2.5,13,18,21
1361.7
137:5,7.15,17 24
138:12,15 20,23
139510
1402.4.10,24
141.6,9,13 143:15,20
1047.11.16
145:1,16.23
1466,13,10,21,24
147-2,8.15 150:11,21
1515815
1522,12.18,25
1538,19,21,25
1549,23 155:3,20
4
360:10.23 1619.11.17
163:1,11,18,18
1648,12.16,24
1655.19 1665.10.17
1675,13.18,21
168:4.13.23
1693,10.13,17
3702,10,16,21
1717.15.24 17235
1735,13,16,20
17421,23,25 175.14
1769.16.26 177:17.23
178:358,11,15,20.28
179.1.49.12,19,.21.24
1803,8.13 1812
‘walified (3) 116.14
145.19 15:28
quarter (6) 43:3,9 448
45.22 48:10 14719
‘queries (1) 74:10
‘question (15) 835,17
16.26 335 34:6 104.7
108:13 123:23 155.23
1603.5 170.25 17325
18046
‘questions (29) 1:18
411 856,10,13 913
25:2 27:21 46:2 50:2
58 63:11,12.13 643
66.9 67:24 88:20
104,21 105:12,16,20
o.2208:3 144.16 1625
17322 1857
‘quick (6) 44:24 104:8
1784,89,10
‘quicker (3) 4:5 17:20
aaa?
‘quickly (8) 5:24 118
17.28 68:20 63:6
97.21 1094 1782
quietly (1) 232
quite (13) 163,
2014.20 29:24 51.28
85:16 86:1 66:18
32614 13615 151.7
1643.21
®
raise (2) 56:20 141.15
raised (3) 120:24
1697.22
raison (1) 145.25
ran (1) 82:39
rang (8) 35:23
34:,15.16 40:6
418,10 43:22
rank (1) 162:22
rare (7) 124:21,23 14151
164:3 167:7.11 16017
rarely (2) 1426.9
rarer (1) 141:6
rather (6) 47:30 99:21,
150:16 157.26 161:23,
16922
reached (3) 20:16 1467
17516
read (22) 4:25 6:12
762,11 85:7 68:19
93:22 100:20
108:19,23,25 1093
31020 1128 1143
apa 141311213
160:3 161.13 175:6
reading (4) 62:9.18
140:25 143.16
readjust (4) 1415 163
3222 33.24
reads (2) 1035 13016
realised (1) 61:25
really (13) 4:15.19 62:8
7830 79:14 103:16
116.7 123:24 129:1
144-23 1515 1749
17619
reason (6) 26:19 30:17
40:22 105:17 156:1,9
reasonably (3) 11:8
1738 3019
recall (16) 10:2.6 21:12,
20:20 22:3 47:18 93:7
1108 11211 125:19
1301 146.27 152.25
17812 179.26 1802
receipt (18) 73:12,13
8022.24 81:7,11.19
e201 63.21 84:48
876,17 90.2 94:24
93,7 169.20
receipts (14) 86:14 99.4
166:14 168:17.24
1696 1704.8
1726.16 1737.14.18
i742
receive (3) 44:24 635
948
received (8) 48:3 60:7
103:12,11 115:24
328.11 130:10 135:6
receiving (1) 1425
recently (2) 68:21 69:4
recipient (1) 50:12
recipients (1) 97:25
recognise (4) 98:13,15
1049 174.14
recollect (1) 117.19
recollection (19) 91:20
311.21 117.18 1265
13320 141.23 143.18,
157.14 1596
160:13,19.22.25
164:20 166.22 167:25
168:2,7 182.13
recollections (1) 158.18
reconcile (1) 96:6
reconciled (1) 993,
ition (8) 976
Opus 2 International
Official Court Reporters
transcripts@opus2.com
203 F
B10.1/3/56
March 13, 2019
Horizons Issues - Alan Bates & Others v Post Office Limited
POL00004075
POL00004075
Day 3
1007 145:7,12 150.8
record (1) 58:15
recorded (8) 15:9 58.14
To 85:15 88:1 99:12
1192 169:20
records (6) 18:13 23:5
94:9 101:1 117.67
recount (3) 15.17.19
304
recoup (3) 91:18
9312.13,
recover (1) 81:12
recovered (5) 70:17
78:22 €1:16,22 64:12
recovering (1) 70:14
recovery (10) 8:12
81:20,25 62:11 83:21
8467.8,25 996
recreate (1) 113.28,
rectangle (1) 96:20
red (3) 71:7 72:37
redaction (1) 162.14
reduced (1) 36:5
reenter (1) 27:1
reentered (1) 26:24
reexamination (7) 115
58:2,3 104.6 148-21
1856.1
ref (2) 150:25
refer (6) 71:10 62:10
98:22 161:12 169.19
1776
reference (10) 17:20
32:11 59:10 74:7
1038 108:6 127.7
15025 17212,18
references (1) 60:19
referencing (1) 160-18
referred (5) 7:20 60:2
65:1 110.23 15912
referring (1) 16212
refers (2) 109.12 1162
reflect (1) 153:21
reflected (1) 69:24
reflecting (1) 14:12
reflection (2) 1164
1554
refund (5) 38:25,25
390 431,14
refuse (1) 6:9
regarding (4) 7.7.88
624 63:3
regular (1) 30:20
regularly (5) 136:24
143:9,10 158:22,25
relate (1) 8:6
related (4) 13428
13611 15716
relates (1) 162.15
relating (5) 6:7 61:25
109:14 1206 12619
relation (10) 7:4 406
46:25 51.7.8 56:17
7820 1278 1554
1629
relative (1) 50:22
relatively (6) 70:5 95:22
124:21,28 141 1469
release (1) 151:11
relevant (8) 5:5 11:15
54:5 142.25 145.18
148.24 1535 1707
rom (3) 13:16 143 63:4
remain (1) 46:23
remember (71) 14:14
162 172,15 24:9
27:23 36:10 39:24
47:3 52:19 60:5 63:18
643 79:18 99:21
110,16 1116,9.11
11225 1167
1172.13 1189 1243
1264.22 127:10,11
1288.19 129,17
1302.19 131:18,21
1336 13517
136:14,17 1394
146:4,6,7.11.15
145:15.16 146.24
147.14 149.3 151:7
154:21 158:2 165:7.10
166.16 1681.1
169:8,10,16 171:.22
17721 1791618
1807 181:10
remembered (1) 159:4
remind (3) 61 47:17
1389
remmed (2) 223.18
remening (1) 22:4
removal (1) 1299
remove (6) 11:12
1289.13 130:8,13
144.24
repair (1) 11416
repeat (2) 16:6 77:17
replaced (2) 70:3
136.25
report (22) 17:16 21:18
2958 57:6,8 5925
6055,14,15,20 629.14
635 65:2,3 9614.24
97:23 12924 137:3,
y77a7 17821
reported (6) 1453
1726 17711,13,14
1799
reporting (3) 169:10,11
17720
reports (30) 100°2
13211,12 134:22,23
1353.5,6.11.11,13.15.1
136:1,2,35.12,12,15,16.
1374612721
represent (4) 71:2
138.20 15416 155:3,
representative (3)
126:12 15415 155:14
represented (8) 117.1
1206 121.21 145.29
1585 1649 175.10
1765
represents (1) 152.13
request (1) 60:19
requested (5) 57.3.8
60:4.16 62:14
requesting (1) 59.26
require (3) 60:21 97:5
984
required (11) 7:1 105
1007 11319 1172
119.15 123:4 12416
132.14 1396 14:18
requiring (3) 1168,
1206 121.21
resident (1) 16612
resolution (6) 116:18
320.13 127:21.25
355:6 17:22
resolve (4) 69:8 92:19
96:11 103:25
resolved (15) 14:21
22.25 238 43:18
88:15 92:15 95:14.23
16:13 143:24 169.13
y70.21 71a
190:19.22
respect (3) 4:18 122.2
107
responder (10)
107:14,18 148.24
152:23 1532
154:12,15,18 155:4,13
response (10) 100:11
127:5.13 12920
144:1.2.8,19.21 1452
responses (2) 152:21
155:24
responsible (8) 10:23,24
3220 114.15
1251313 128.21
uae
rest (4) 56:7 71:13
80:15 122:20
result (12) 20:2 64:19
129:23 132.12
134:10,12,22 13513
164:8.13 1728 16213
resultant (1) 97:18
resulted (1) 2423
results (1) 93:4
retain (1) 1377
retried (1) 3615
return (2) 128:10 1309
reversal (6) 397,11.14
40-4 43:11 48:7
reversals (2) 39:2 427
reverse (19) 39:3
40:19,21,23,24
41:16,18 20,28,
427,12,13,19.20
48:19 44:8,10 47:24
49:20
reversed (17) 40.25
21 2942.13.15
0423.45.17 443,7.19
4721 483,16 521.2
reversing (1) 42.16
review (4) 141.16
145:18 170.7 162.14
reviewed (3) 15 416
yaias
rewriting (1) 17535
ribbon (1) 59:19
richard (4) 10604
109:16 131.12 185:12
riddled (1) 183.19
Fighthand (2) 74:23
175:20
ring (3) 34:4 60:20
1513
Finging (1) 43:16
robinson (39)
105:11,15,19.22
107:23,24 112.48
40:21 1421 147:20
148:9,14 149:19,23
155:21 1566.12.16
157,69 161.19
162:6.9,14,18 1712
174:9,12 175:24
171.4 181.19
162:2.15 183:2,20.21
185.14
role (4) 1326.15
1422.15
roll (68) 27 201.12
25:7
105:2.14.15,18.25
106:13,14,15.18
107:24 108.10
11433 12:14
114:3.22 11619
121:4,15,18 122.22
124:11 1269 129.16
13112 1335 1349
137.9 138:4.24
139:14,20 141:17,19
142:11 1435.20
147:24 148.1625
149:24 15221 1572.9
158:14,25 159.16
160:2.23 162:11
166.17 171.7 173121
17425 175.24 17619
179:12 161:6 1845
105:12
rolled (3) 20:8,16.22
rolls (2) 110.23 168:14
romec (3) 130:8.18,19
room (1) 1563,
root (3) 113:24 11416
170.13
roughly (1) 229
round (8) 23:17 61:16
83:23,24 120:12 1507
152.12 153.25,
rounds (1) 113:
routine (1) 13528,
routinely (9)
160:14,26,20 161.15
168:2.11 168:15,
176:18
routing (1) 1271
row (36) 11:16.17 137
14:10 21:21 25:17,25
29:20 37:8 40:9 62.22
53:17 54:20 589.17
59:9 609.12
62:11,12,15,16 6227
63:18 64:15 65:7
98:12 100:14 102:25
150:14 151.9 155:25,
156:7.8,10
rows (4) 21:17 30:17
60:9 148.19
rp (1) 17220
vr (1) 153.12
rip (4) 118:17 1195
148:11 1538
run (1) 411
rung (1) 40:26
running (7) 2925.21
68:24 81:4 88:3 918
e121
rushing (2) 27°7.16
safe (1) 23:1
same (33) 4:12
29.17.18 32.1.4 33:7
34:18 38:25 43:20
46:16 597 66
70:23 7212 74:6
78:19 7935.10.25
8013.9 971,339
100:18 101.25 129:15,
357.3 17013373
W115
sanghera (1) 57:11
sarah (3) 615,23 63.2
‘sat (2) 62:20 83:25
satisfied (1) 17116
saving (1) 10228
savings (1) 101.2
saw (7) 15:1 42:5 63.7
e145 63:25 13013
saying (42) 73 13.21
16:5,1617 1912
29:6 22°7.24.28 3225
416 4215 43:17
48,19 55:18 56:1,10
Toa 74:17 89:25
90:15 92.222 93:74
95:16 1008 13418
3978 139.21 14337
151:19 1549 150.16
1616 1632311
17333 1757 1763
scan (1) 98:13
scanned (1) 14:3
scenario (1) 79:7
scope (1) 183:5
sereon (25) 6:17.28
11:20 26:13 36:24
70.22 71:24916
73:40,11 74911,28
75:24 776 80:19
#3310 903
100:17,28 103:2 108.7
scroll (5) 13:9 21:19
43:7 59:13 60:25
search (1) 170:2
seat (3) 7:20 66:14
106.15,
second (22) 1:10 4:3
26:21 31.22 33:7 347
37:35 43:14 572
65:17 06:15 95:18
3125
112:1,9.20,23.25,
13122 1426 1828
secondly (2) 7:24 88:2
section (6) 6:1,8
79,4 72:7 1828
secure (1) 50:6
see (161) 27.11 5:38
8:24 1119.25 1223
13:8 1425 15:2.22
1811.27
21:20,20,28,21,24
22:12,12.21 25:25
26:4,18 29:6 3019.22
37.20,12.12,15.26.17
38:9,10 40.11 41:6
42.18 48:8 45:9 46.13
5321824 55:5 57:13
58:11,11,14,16.17,23
59,9,14,18,22.25
60:12,12.19 61:8
62:11,12 65:8,18
66.21 67:24 71:53
74:4.8,12 79:13 60:23
e212
83:10,10.12,12.18
86:13 882.11
89:15,16 90:14
91:3,12,21 961819
97:2,8,10,16,23 98:20
100:4,5,6,13,16 101:3,
102:9,24.25 1033.3,
04:11 106:19,23,
1087 118:18,20,22
11920 125.4
3271.12 1291515
10:3 132.23,28 1352
136:1,18,18 137:10,19
14517 147-15
148:16,16,24 149.8,24
150:8,13 152:3
153:1,8,10,15.17
1549 155:20.25,
36111 167-15 168:4
17520 17:23 10:13,
182:10 188:11 184:5
seek (1) 179.19
secking (4) 1235 131.2
17413,13
seem (5) 72:28 90:23
133:4 16623 17:2
seemed (6)
16:4,10,18,24 25.2
56:22
seems (4) 22:15 81:18
3232 17739
seen (18) 29:9 39:20
735 75:25 761
94:23.23 97:23 98:10
20:29 102:1.4
103:20,21 121.16
144:24 175.25 183:21
sees (1) 166:13
select (1) 58:6
selecting (1) 90:19
selfconsistency (2)
1695 1729
selfcontained (1) 4:14
selfinerimination (1)
3:18
send (1) 504
sending (1) 123:24
senior (10) 2:20 132.1
32229 12311 1245
125.23 1359 141:3,
15323 179.19
seniority (1) 122:1
sense (5) 4:20 55:3,
56:18 93:17 145.14
sensible (4) 5:7 45:12
52:12 539
sent (9) 36:13 43:21
49:14 60.18 69:25,
97:19,24 1313 1371
sentence (15) 85:5,11
86:2,16 67:12 93:10
95:19 98.2 11195,
1216 13425 142.6
157.25 159:11 176.16
sentences (1) 142:1
separate (4) 25:15
66:20 10517 113:1
separately (1) 48:1
sequential (1) 30:37
sequentially (1) 142:24
series (4) 118-23 12618
136:11,12
served (2) 79:15 62:17
servers (1) 12319
service (6) 71:20 90:25
932 96.16 10912
169.2
services (8) 71:12 73:25
103:10 126-10 130:10
serving (4) 27:6 78:18
799813
session (17) 54:4 742
7730.11.38 78:1
79:10,11,15,22
80.22.25 64:2,4 098
994 101:10
set (2) 103:17 138.21
setting (2) 116:2 133.24
settle (4) 40:16 80:18
90:19 99:2
settled (2) 10:6 90:2:
seven (3) 26:3 45:16
805
several (10) 43:23
45:2,2 76:24 90:4
09:10 124.26 127
128.22 1428
shall (3) 6:12 82.5
32313
shared (2) 11:5 1106
sheet (5) 25:17 37:7
546 6618.19
shes (1) 33:1
shifted (1) 154.8
short (15) 34:2 42:5,
438,10 45,35,24
48:12 4969 64:14
306:11 130:6 1327
147.25 1487
shortage (6) 13:16
58:20,21 59:9 99:11
302.12
shortfall (22) 925 13:6
36:18 46:16 475
497 55:23 563
6932,15,23 70
£4:22,24 85:14
86:8,20,23 67:22
95:13 142:23 166:20
shortfalls (4) 68:24 69:7
Toi 1612
shorthand (3) 45:16
14722 148.3
should (41) 5:12 8:13
21.4 37.17 39:18
42:13 49:3 54:78 62:3
64:10 65:11.12,23,
73:21 75:24 77:1,1.6
85:23 9021 95:3 99:7
106:18 108:14 123:6
122:25 136.19 149:9
155.16 156-4
361:11,13,35 17011
172.10 1745
1751924 183.1517
show (12) 19:8 30:12
4622 57:19 58.25
71s 9425 968.9
97:21 100.22 10:12
showed (6) 21:12
56:3,21 63:17 821
85:20
showing (2) 19:16 33:11
shown (13) 161,2 19:3
21:13 33:19 36:1 575
6455 85:16 87:5 88:23
1613 1767
Opus 2 International
Official Court Reporters
transcripts@opus2.com
203 F
B10.1/3/57
March 13, 2019
Horizons Issues - Alan Bates & Others v Post Office Limited
POL00004075
POL00004075
Day 3
shows (11) 11:15 239
26:11 52:4 54:4 65:67
90:24 149.37 150.17
17220
side (16) 38 27:14
33:21 34:22 36.2.6
41.6 62:17 73:710,11
74:23 1236.18
1561.2
signature (7) 9:7
6714.26.17
1072.46
signed (2) 107:16,19
significance (2) 1473
w77a9
significant (7) 26:4
N75 13115
139.15,21,22 167.21
similar (7) 3:12.12 83
613 13013 1359
15715
similarly (1) 95:6
since (6) 5:8 68:12
78.24.25 163°7 169.18
single (9) 37:13 43:25
52:34 774021 7821
181.20 18316
site (5) 1289.20
1308.97
situation (11) 38:12
46.2.3 69:20 74:22
86:18 92:20 105.24
178:20.21 180.25
six (3) 57:8 609 125:16
size (1) 69:16
skills (1) 11320
skip (1) 150:2
skipping (1) 89.9
slight (1) 123,
slightly (4) 22.16 98:20
143.6 15722
slow (1) 75:22
small (12) 95:12 11616,
119.13 1205 15423,
164:9,18 166:20,23,24
1766.21
smaller (1) 176.14
sme (3) 1122 130.17
1697
snag (1) 1545
snapshot (2) 88:3,4
socalled (1) 162.21
software (77) 110:21
111.2.27.14,18,19
11325 1159 11617
1171 19:16 1206
122:2.13,20.21
126.15,16 13312
13455,10,18 139.12
1405.8 143:1
145:9,19 146-15 1478
150:6.13,21.23,
1511.10 15247
15316 157-21
158.9,17,24 159.23
160:8,13,16,20.25
161:4,7,7.11,13,15,18.2
162:4,20,24 168.16
165:15,17,26 166:1,25
168:14 171917211
17310 1744.6.11
1751 1776 180.17
solicited (1) 15:22,
solution (1) 17:22
somebody (1) 50:4
somehow (1) 34:3
someone (9) 36:22
39:23 93:3 1063,
126-21 1256 1311
1447 15510
something (19) 10:12
2438 25:14 37:3,
39:22 85:18 877
91a7 12221,13
134:12 143:9 162:22
16855 1646.7 179.17
180:10,24
sometimes (22) 115.7
2621.22 27:3.6.6.16
29:13 6813.13 704
2169 141.20 143:25,
149.16 171:21,21,24
176121516
somewhere (7) 12:20
22:25 49:9 53:25,
66:19 12010 165:10
soon (1) 745
sort (17) 22:24 28:25
322,123 32:4 356
626 91.17 121.11
12636 13056 133:7.20
150:3 163:3 17:25
sorted (3) 15:19
315.7
sorting (1) 62:7
sorts (5) 121:20
159:21,22 1607
164.25
sounds (1) 15117
source (10) 113:7,21
114.18 13216
13912,16,24 1401
14238
space (2) 84:14 1392
speak (5) 71:24 89:11
91:6 105:25 160:10
speaking (4) 42:5 89:2
11424 12737
special (2) 63:9 113:19
specialist (5)
122:6,8,9.25 12422
specialists (5)
122:12,24 12325
15323 17116
specific (8) 6:25 85:17
123:21,22 1336
135:21,23,25
specifically (2) 109:18
ya
specify (1) 16222
specifying (1) 7:1
speed (1) 17.22
spent (2) 126.6 154.15
splits (1) 110.8
spm (6)
168:13,13,15,17,22.23
spoke (7) 32:21,22
4117 48:9 56:20 614
94:36
spoken (2) 61:5.23
spot (1) 146:9
spotted (1) 163:24
spreadsheet (13) 11.16
25:22,23 30:8 97:6.18
98:3,8,10 100:10
1025 1162.3,
spreadsheets (2)
11811315,
se (51) 11022
uuni.ge 11224
uug.¢ 11528
1166,14.1171,6.11
138:16.17 1195
120.22 121:17,22
122.416 12415
12615 138:2.6 1396
14222 143.24 1445
145:3,20 1467.14
152-14 153:11,16
154:1 18:13
167:10,23 169.714
17115 172:28,23
1739 174:3 175:11
1766 178:15,36
stack (27) 36:26 37:2
632 71:10,16,7
724.9,16
734,11,23,25 75:9
7624.25
77,3.6.18,22,25
78:24 79.21.28
8010.28
stacked (1) 74:24
staff (3) 113-4 12423
15:6
stage (5) 320 25:4 37:2
55:1 625
stages (3) 52:24 55.8
1785
stamp (10) 3013.14.20
33:2,15,25 34:10
462 10112,14
stamps (41) 11:2 27:23
28:2.6,89,13.14.18,20
29:4,7,10,16 308,21
318.18 32:3.6.25
34:3.6,28 95:2.5,13
3635
46611,1417.25
47:3.4,13 60:1 61:2
639794
standard (1) 1358
stands (4) 9615 1267
329:17 1380
start (9) 1:21 4:48
30.19 48:21 102:10
185,17 175:7 2762
started (3) 55:8 81:24
118
starting (5) 47 20:2.22
6224 89:16
starts (2) 90:14 156.23
stated (1) 167.6
statement (69) 2.8.10
824 9.2.5.9 10:23
14:12,20 15:6 321
33:0 45:6 55:6
5737.28 66.21
67.12.20 6821 70:13
7223 7513.22.25
81:10,19 62:10.12
854 86:3 98:7.25,
95:12,7 96:4 100.19
102:20 10318 106.23,
107:1.6.9,20
108:1.6,24,25
110:21,23 1152.20
126:15 131.22 137.25
M412 143:22 1474
148:21 1531 157:10
160:1,12 161:22
165:21 1753.15.19
statements (3)
108:15,17 181.18
stationary (1) 67:7
stay (2) 45:20 186-1
stayed (2) 31:15,17
staying (1) 1529
stays (1) 31:2
step (2) 88:7 94:7
steps (10) 16:3.8,10.15
17.69 23:22 24.23
96:5 104-2
stick (2) 121:10 126-1
sticks (1) 171:25
still (15) 23:9 29:1
32:8 381 42:6 52.14
59:17 622,13 631
80:8.9 10821 1318
1836
stock (11) 75,7 88
14:13 30:1
33:12,15,25 4620.21
sana
stockdale (1) 625
stopped (1) 155:12
stopping (5) 86:6
108:13 11619 138.9
169:24
store (1) 136:22
stores (11)
332:11,1921 133:4,11
134:17 1369.20,16,22
1373
story (1) 56:17
straightforward (1)
44:16
strange (2) 22:15 45:7
stretch (1) 45:21
strip (1) 1432
stuck (2) 12932 1323
studying (1) 87:3
subject (4) 67:5.18
141:15,20
subjective (1) 14:19
submit (1) 73:25
submitted (2) 60:15
Tea
submitting (1) 79.24
subpost (1) 6813,
subpostmaster (2)
68:14 16613
subpostmasters (2)
142.18 16311
subpostmistress (4)
67:39 688,11
subset (3) 120.2.5.5,
substantial (2) 69:15
705
succeed (1) 42.16
successfully (1) 61:16
sudden (1) 19.18
suggest (35) 316 25:2
477,720 53:4 695
71:9 72.23 7619.23
79:20 85:11 86:6.19
92:9 92.18 969
9:14.23 102:14,19
114 122.22 12410
129.6 136:15 130:20
143:8.15 15412
166.17 1743.14
1755
suggested (2) 13.24
183.14
suggesting (13) 19:9
2:5 101-1 12138
325:12 12611 142-19
156.26 1626,21
16319 1685 178.18
suggestion (8) 17
42.10 51:24 52.17
57:19 95:13 1019
16814
suggests (10) 12:5
15:16 22:23 32:3
52:1 56:5 60:17
105.2 143:14 1457
sum (2) 104.5
se (1) 92:01
summarised (1) 120.19
summary (5) 128:22
148:1 150:16 175.8
1762
sums (1) 638
super (2) 115:10.12
superior (2) 1249.22
supervisor (6)
99:1,13,18 901417
ona
supplied (3) 151:22
156.9 158.7
support (56)
1082.49.12
109:10,22 11045
11125 11219
1134,5,9,13,15,20.24
114.113 115234.88
116.17 1170.15.17
1184,8,25
1198121415
1201,3,7,23 121.28,
1224 125:24 1328
138:3 1397.11.19
140/13,15,17,21 141-2
146:10 159.2 160:21
supporting (3) 131:16
135.9 1386
suppose (8) 121.7
1323:4,14 124.20 1252
140.15 147-4 170.25
supposed (4) 39:6 749
75:7 12622
sure (26) 6.25 134
14:2,3 15:10 162
19:21 20:10 23:3
29:24 31:6 36:21
46823 7022
76.:27,19 101:19 1065
13614 1437.29
15413 1595 168:22
163.24
surname (1) 32:19
surprising (1) 47:10
suspected (1) 279.16
sworn (2) 66:13 185:8
symptom (1) 172.13
symptoms (1) 113:10
synchronisation (1)
130.18
system (44) 38:16 60:3
7122 76:314,23 77:19
7a 80.19.25 841.2
85,13,22 86:5,12
8751338 952
99:12,23,25 114:10,14
1218 1233,3 12518
136:11,13 137:4,13,23
139:7 157.19 158:23,
161:3 168:19 169:4,21
1759 1763.5,12
systems (6) 75:10
13657 140:17 16612
169.23
tab (17) 8:23.25 9:1
278,16 66:20 106:21
1078 11616 119:4
14213 148-11
15220.21 15:24
17216 175.18
table (5) 148:16,17.20
1525 172.25
tabs (1) 15522
taken (13) 18 179
21:10 24.23 50.26
54:11 55:5 64:21,
92:15 1029 103:15,19
1081
takes (4) 20.22 49.25
1126 16316
‘aking (11) 12:22 19:20
53:13 5598 65:11,12
72:20 79:19 878
68:14 15118
talent (1) 138-4
talk (6) 45.19 93:23,
15:15 147-25
3811213
talked (2) 137.8 1605
talking (20) 5:8 357.8,
418 526 68:17 70:23
73:20 74:22 11615
335:16,21 15720
161:19 163:20.24
1726 1735 17419
yeni
tasks (3) 125:21.23
1266
tautologous (1) 96:25
te (6) 43:19,23,23 49.24
30212,17
team (15) 103:10
jo9.28 1122611314
1183 1202325,
12422 1382
139:13,17 1407.9
14324 183-1
teams (6) 108:4 113:15
314 11741 1186
197
technical (3) 76:20
113.25 1338
technically (3) 49:20
133:13.25
technician (2) 143:25
144.20
telephone (2) 94:17
957
tells (1) 19:14
temporary (1) 139:2
ten (4) 68:18 795
80:7 1067
tend (1) 8:10
tends (3) 1262.3
13817
tenure (2) 12615 128-4
terminal (1) 17:20
terminology (1) 163:7
terms (10) 124 44.8
24:33 25:7 35:25
42:24 145: 151:3
18336
test (1) 169.22
tested (1) 1138
teat (5) 58.22.25 59.22
1084 1305
textual (1) 170:2
thank (33) 213 719
8:19 9:12 37:9 63:25
668,915 67:22 77:8
93:25 104:320,21,22
106:15.16
307:210,12,22 1175
140.24 148:49 15218
160.23 167:13 171.2
174.25 175:22 176.28
1385
thats (185) 33,25 4.1
72191 1213,1525
15:20 14:26 15:9,14
161.2 198,20 2019
213,11,12 226 23:1
25:3,4 20:14 3057.8
3123.14 33:19 3538
37.13 38:2 39:4,19
42.20 433,35
49.26.18 501 51:21
5323 54:20.25
5522.24 5613
591,15 61:12,15
62:20 63:22 65:3
669,23
673,817,1721 6869
69,9 708
7121,16,22.25
72649 732419
742,24 75:21,21
7746 79:9 8025
81:2,7.2 6220 63:6
85:18.20 866.8,
07.35,25 68:8,10.7
89:29,25 93:4,15
9410.14 95.19 9711
9818 1002.14
3011919 102:48,14
103:10 104:18 106.7
1097 110911149
112:22,25 116.19
11824 1192
126:9,14,16,20,24,25
1539.10.15 1344.19
1377 13834
1M055,7,19 1425
1431215 144.14
1474 1482.15
150.16 151:6.18
3527.11 15422
1587.19 1592 160.23,
yeaa
16225.21.21.22
1652 166.2 1678.15
168:22 169:1 171:25
37243 17619 177.15,
178:11 160:23,24
ae1a9 162.9,1
themselves (1) 602
therefore (6) 65:19 86:4
89.4 116.22 146:1.9
theres (29) 13:8
Opus 2 International
Official Court Reporters
transcripts@opus2.com
203 F
B10.1/3/58
March 13, 2019
Horizons Issues - Alan Bates & Others v Post Office Limited
POL00004075
POL00004075
Day 3
22:2:2,18 26:2 31:5
43: 47:18 56:14
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Opus 2 International
Official Court Reporters
transcripts@opus2.com
203 F
B10.1/3/59
March 13, 2019
Horizons Issues - Alan Bates & Others v Post Office Limited
POL00004075
POL00004075
Day 3
66:10 171.7 177.7
wrap (1) 58:22
wresting (1) 164.19
write (2) 13511 140.9
writers (3) 45:17 147-28,
1403
writing (2) 27:17 140.17
written (5) 111.8
1391417 1406 1432
wrong (18) 8:25,
26:19,22 26.21.23
30:25 40:7,8 51:13,16
56:10 57:7 70:1 86:6
10114 126:7 13324
17610
wrongly (1) 35:18
wrote (3) 99:15 123:20
137.21
yeah (1) 92:14
year (8) 1304
13119.23 1429
years (10) 68.14.16
11523 11025 1268
1283.4 146:5 148.22
15018
yesterday (11) 1:13
52361 937
115,027.19 151
17:7 2630
yet (a) 223 3920 43:18
W537
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49.15,15,19 55:18
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79.13.22 90:18,19
913.929 95:16
10513 157:20 161:9
1633 1708 1718.9
1732
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69:7 69:22 762 94.8
955 1094 110.11
12247 1151.3
12414 132213816
14113 16016 17108
youve (7) 46:21 49:7
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16320
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210 1494
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69:2,7 81:20 908
15:22 130:8 1327
145.4 150.13 172.22
1852
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27:18,19 1078 14322
160:1,11 16218
166.14 174
100 (3) 20:8 69:16
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10000 (1) 27:18
1030 (4) 121818
194:47
104 (1) 18511
1082 (1) 67
108 (4) 59:11 76:27
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106 (2) 185:12.13
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107 (1) 185:14
209 (2) 28:14 145.8
11 (9) 12:19 13:68
1425 2238 30.21
15721 1581
1105 (1) 60:20
17 (1) 1286
1130 (1) 410
1138 (1) 45:23
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1146 (1) 45:25
115 (1) 40:9
16 (2) 437.8
117 (5) 4313.15.16
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1250 (2) 417.25
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33 (1) 11.1725 33:10
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136 (1) 137
138 (1) 29:20
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40 (3) 589.17 599
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173:6.8.25 1743.21
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5820.21 599,10 63:9
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172 (1) 173.28
17200 (1) 60:5
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17th (1) 1032
16 (2) 82:22 130.17
100 (2) 104:12.16
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30:24 36:2,11 47:3
160000 (1) 183:18
10022008 (1) 130.8
1806 (1) 55:9
100671 (3) 54:19
353.13
101 (1) 185.5
1095075 (1) 62.25
19 (9) 36:10 39.21 85:3,
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1903 (4) 52.22 63:18
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1904 (2) 12:25 21:14
196 (1) 6:19
1968 (1) 69
1999 (1) 16918
Ast (7) 1097.21
113:9,11 145.25,
146:3.10
2 (13) 49 57.18 623
9:1 93:20,26,25 1081
12511 128-9 16011
17s
20 (4) 27:18,20 45:5.6
200 (2) 94:4 149:5
2000 (1) 121:8
20000 {1) 27:17
2001 (7) 107:24 115:22
118:21 1196 126.14
148.22 172.22
2002 (2) 116:18,19
2003 (1) 128:4
2004 (9) 107:25
118:19.22 119:7 1219
130-4 181-11 145:4
148.22
2010 (1) 145:4
2011 (1) 15619
2014 (2) 115.22 172:22
2015 (2) 38:10 39:21
2016 (7) 10:1 26:2
40,32 68:9 70:14
96:3 973
2019 (2) 1 1248
21 (3) 155:25 1567.10
211103 (1) 1289
216 (1) 5420
216321 (1) 98:15
22 (2) 654.20
220 (1) 106:10
2206 (1) 60:20
22130 (1) 2212
2252 (1) 152.6
22nd (1) 53:20
23 (6) 40,2 53:1 63:9
64:3 156.23
230 (1) 106:12
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236 (1) 25:25
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24 (2) 106:8 151.9
25 (9) 31:2 324 34:16
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109:9 126.14 1304
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261 (1) 10911
2612 (1) 109:16
2613 (2) 109:20 110:11
262 (3) 111.24 11268
263 (2) 113:3 114:7
264 (1) 32432
26th (1) 598
27 (1) 95:18
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1526
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20 (2) 11519 1264
29 (1) 16:12
2nd (4) 113:9,11 138:2
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3 (8) 6215.16 147.16
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30 (6) 122:13,16 126.7
132.9 1572
300 (2) 26.13.34
31 (6) 657.24 11522
145;4 1722
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3107 (1) 65:23
32 (4) 120.20 121.45
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32000 (1) 229
328 (1) 148:6
330 (1) 1488
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3c (1) 149.15
35 (2) 139:10 15213
353 (3) 145:5 152-13
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37 (3) 141:10,11.22
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139:11,17 1406
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41 (1) 145.24
412 (1) 1466
413 (1) 146:23
47 (a) 17222
42 (1) 168:13
421 (1) 16917
423 (1) 17235
430 (1) 1046
44 (1) 1533
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5 (3) 66:24 10225,
182.25,
50 (8) 69:26 167:25
1687.10
5000 (1) 142.23,
530 (1) 27:13
563 (1) 125:25
56 (1) 1056
59 (2) 150:16,17
6 (3) 6:20 67:12 142.23
60 (1) 150:22
6000 (3) 43:8,20 44:12
61 (2) 150.24 1542
62 (1) 154.2
6200 (16) 36.19 37:18
45:3 48.12 49:6,7.17
51:11 5219 53:1,5.25
55:24 56:1,19 64:10
63 (1) 185.7
64 (1) 151.16
66 (2) 18589
68 (1) 18510
6825 (4) 63:19
64:6,7,10
682595 (2) 532.16
7 (25) 6:21 12.25
20:6,6.8 21:9,9,11
41:3: 42:21 433.9 46:8
48:10,11 49:10,22
06:21 112-47
142:13,20 1436
175.18 185-3,
70 (6) 126:6 132.10
134:16,20 156.8,8
73 (3) 104:13,14,16
735 (2) 169.19 170.11
74 (2) 55:6 151:9
75 (1) 74:19
781 (1) 65:6
8 (6) 68:22 11411
131.25 159-7,11 1854
‘80000 (2) 18:2.4
1828 (4) 100:24,25
1011012
83 (8) 145:9,19
146 14,21 1475 152.7
153.17 158.9
86 (1) 172.23,
1960159 (1) 53:22
9 (15) 10:28 1236.22
roe 7222 73:21
7422 779 8038
96:25 100:21,24.25
15620 1855
915 (2) 153.215
934 (2) 835.8
936 (2) 82:11,14
943 (1) 1058
9516 (1) 103.6
9545 (1) 15233
9 (1) 67
‘9th (2) 97:3 99:19
Opus 2 International
Official Court Reporters
transcripts@opus2.com
020:
30
B10.1/3/60