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Message
From: Parsons, Andre’
Sent: 27/07/2016 10:
To:
+ Rob Houghton
cc: “} Mark Underwood:
GI Prime, Amy
Subject: FW: Horizon Group Litigation Update - Subject to Privilege [BD-4A.FID26859284]
dane, Rob
FYI below. FJ have finally got in touch about the LOR (Rob — if you prompted this ~ thank you!)
Despite Deioitte’s recent findings, you'll see that FU are still saying that FU cannot change transaction data (highlighted
below). There is clearly a disconnect in understanding between the parties but unfortunately we will not be able to resoive
this before tomorrow.
What we really need FJ to do is sign off on the other parts of the LOR (eg. the wording about the historic bugs). We don't
want the Remote Access point derailing the rest of the letter.
Let's discuss on our call and then I can speak to Mike
Kind regards
Andy
Andrew Parsons
Partner
www.bonddickinson.com
From: Parsons, Andrew
Sent: 27 July 201
To: 'Michael.Harve}.— F
Cc: Rodric Williams; Rob Houghton (i... ; Prime, Amy
Subject: RE: Horizon Group Litigation Update - Subject to Privilege [BD-4A.FID26859284]
Mike
We have a hard deadline (set by Court rules) of sending our Letter to the other side in the litigation by 4pm.
tomorrow. Any changes to the letter need approval by POL and so we need Fu's input by close today at the absolute
latest.
I'm around ail day so please call whenever good for you.
Kind regards
Andy
Andrew Parsons
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Partner
Direct: I
Mobile:
To: Parsons, Andrew ,
Cc: Rodric Williams; Rob Houghton (Rob.
Subject: RE: Horizon Group Litigation Update -
ject to Privilege [BD-4A.FID26859284]
Andy,
Apologies for the delay, unfortunately with holidays and a number of other things happening at once this one has
proven to be a struggle to get the right people to review in a timely manner. I will call you this afternoon after I have a
call with the team to get an update. We will provide you some interim views but our legal team have asked to get
involved given some of the inferences made in the document about Fujitsu and so please let me know what the absolute
deadline is and why this is key.
The primary issue we have at the moment is that we don’t believe the key element regarding the sanctity of the Core
Audit Process comes through in your proposed response and this remains the cornerstone of our inputs to date and the
presentations we’ve done on this point in the past to Post Office and Bond Dickinson. To say that Post Office has never
said the system is “error free” whilst correct fails to make the point that the system is built on the expectation that the
overarching system could have errors over time but the Core Audit Process captures every submitted “basket”
accurately and without error and cannot subsequently be changed but only added to {ail such additions include details
as to what created the addition etc. to create a full audit log). Numerous audits have proved this and it is the Core Audit
Process that forms the basis of the first level of analysis with respect to any suspect fraud or loss and hence why we
believe that Horizon is robust.
Kind regards,
Mike
From: Parsons, Andrew [mailto:af_ GRO _ i
Sent: 26 July 2016 1:
To: Harvey, Michael
Cc ic Willi
Rob Houghton
Subje Horizon Group Litigation Update - Subject to Privilege [BD-4A.FID26859284]
Mike
I think Rod tried fo calf you re the below and I left you a message earlier today. Have you got an ETA for your
comments? It's now extremely urgent.
if you could give me a call with an update that would be appreciated.
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Kind regards
Andy
Andrew Parsons
Partner
www.bonddickinson.com
From: Michael. Harvey. _[mailto:Michael Harvey _
Sent: 22 July 2016 09:07
To: Parsons, Andrew
Cc: Rodric Williams
Subject: RE: Horizon Group Litigation Update - Subject to Privilege [BD-4A.FID26859284]
Andrew,
Apologies for the delay in responding. I have forwarded the previous document to the relevant team members and I will
do the same without the document you attached to the below email. I will catch up with the tearn to understand
progress but we will not be responding today on either document. We will respond as soon as we can once we have had
chance to consolidate the responses and review them with our legal team.
Kind regards,
Mike
From: Parsons, Andrew [mailto!
Sent: 21 July 2016 19:55
To: Harvey, Michael {7
Ce: Rodric Williams <....
Subject: RE: Horizon Group Litigation Update - Subject to Privilege [BD-4A.FID26859284]
Mike
I should be grateful if you could confirm that the review below is underway and that you're on course for a response by
tomorrow.
Please could you also review the attached very short document, which addresses a very specific point around Post
Office's / Fujitsu's capability to change branch data (this overlaps with Deloitte's work).
Apologies for the short notice but please could you again come back with any comments by close tommorrow.
Kind regards
Andy
Andrew Parsons
Partner
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www.bonddickinson.com
From: Parsons, Andrew
Sent: 19 July 2016 17:52
To: ‘Michael.Harve'
Ce: 'Rodric William:
Subject: RE: Horizon Group Litigation Update - Subject to Privilege [BD-4A.FID26859284]
Mike
Further to below, please find attached relevant extracts in relation to Horizon from our draft Letter of Response.
I should be grateful if you (or someone suitably placed at Fujitsu) could review the attached and flag / amend any points
that you consider to be incorrect. If possible, please could you provide your feedback by the end of this
week. Amendments by way of track changes would be perfect.
I've also attached relevant extracts from the Letter of Claim for context (no need to comment on these but feel free to do
so if appropriate).
Please keep circulation of our draft Letter within Fujitsu to the absolute minimum necessary to undertake the above
task. This document has been prepared for litigation purposes and shouid it be circulated for any other purpose within
Fujitsu, then legai privilege over the docurnent may be lost.
Any questions, please do not hesitate to call.
Kind regards
Andy
Andrew Parsons
Partner
Follow Bond Dickinso:
www.bonddickinson.com
Sent: 18 July 2016 18:06.
To: 'Michael.Harvey,
Cc: Parsons, Andrew
Subject: RE: Horizon Group Litigation Update - Subject to Privilege
POL-0019907
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Mike — thanks for calling me back.
Andy Parsons (cc’ed) is the partner at Bond Dickinson leading our defence of the Group Litigation. The Bond Dickinson
team has been preparing a substantive response to the long Letter of Claim received from the claimants’ solicitors
Freeths, and I have asked Andy to contact you directly to get Fujitsu's input on the sections of the response which
concern the services Fujitsu supplies to Post Office.
Andy ~ can you please drop Mike a line or give him acalll. GRO 2 get this moving.
With thanks for your continued cooperation, Rodric
From: Rodric Williams
Sent: 18 July 2016 14:28
To: 'Michael.Harvey........
Subject: RE: Horizon Group Litigation Update - Subject to Privilege
Mike — I hope this finds you well.
I’ve just left a fairly long voicemail with you (apologies!), but Id be grateful if you could please give me a call when you
get a moment so I can give you an update on where we have got to in the Group Litigation, our next steps, and the input
we'd like from Fujitsu to help us advance our position.
The best number is my mobile —
With thanks and kind regards, Rodric
From: Rodric Williams
Sent: 15 April 2016 19:00
To: 'Michael.Harve\
Subject: Horizon Group Litigation Update - Subject to Privilege
Mike,
Just to let you know that earlier this week we received a letter from Freeths LLP (a firm of solicitors) advising that on 11
April 2016 they issued a Claim Form against Post Office in the High Court on behalf of some 91 claimants. They have not
as yet served the Claim Form or any Particulars of Claim on us, and did not send a Pre-Action Letter of Claim before
issuing, so we remain unsighted on the basis of the claim or who has brought it.
So we’re not really that much further forward, although Freeths did say they intend to send us a Letter of Claim by 26
April 2016 (which I’m sure you'll appreciate is rather putting the horse after the cart...).
Apologies for not being in touch sooner — I had intended to give you the courtesy of a call much sooner, but
unfortunately kept running out of time. I am in the office all week next week so will try to give you a call then (one of
the things we will need to discuss is document preservation), but please feel free give me a call any time.
Kind regards, Rodric
‘ Rodric Williams
Solicitor, Corporate Services
Post Office Ltd
20 Finsbury Street, London EC2Y 9AQ
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