POL00029707 - Email from Andrew Parsons to Belinda Crowe, Angela Van-Den-Bogerd, Andy Holt and Rodric Williams and others, re: Post Office Mediation Claims.

Evidence on official site

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Message

From: Parsons, Andrew!

on behalf of — Parsons, Andrew:

Sent: 08/04/2014 20:

To: Belinda Crowe!

cc:

Subject: RE: Post Office Mediation Claims. [BD-4A.FID20472253]
Belinda

I've spoken to both Rodric and Simon Clarke at CK about the email from Priti Singh at Howe and ail three of us have
similar thoughts on the way to proceed.

The only redactions made to the copies of the reports sent to SPMRs was to remove:

1. the personal information of some of the individuals named in the report (eg. names, telephone numbers, etc.)
2. aheader in the document that said that the document was subject to legal privilege when it clearly was not. This
was done to avoid any confusion over the privilege status of the document.

In light of this, I do not understand Howe & Co's compiaint that there is substantial missing material. It is not suggested
that POL provides an un-redacted version of the report as (i) this is not necessary and (ji) we do owe some duty of privacy
to the individuals in involved. Instead, it is recommended that POL maintains its current position and simply explains the
redactions to the report.

in this vein, I've set out below a possible response to Howe to go from Chris. This response is purposefully short in order
to avoid any dialogue with Howe on this matter. I do not believe that this matter need go through the WG as this is about
POL's prosecution duties and not Scheme business. This response could, and in my view should, be sent regardless of
Steve Darlington's email below as it is important that POL's position is clearly stated before Ron's begins to escalate
Steve's views to the Working Group.

dust for background information, the material part of the Helen Rose report has nothing to do with her comments about
reversal data. SS and Howe are taking this point as evidence of a problem with the integrity of Horizon. in fact, Helen's
issue was that the credence data, although accurate, did not on its face clearly distinguish between automated reversals
and user generated reversals. This information is available but in a different report. The concern was not with the data's
accuracy but that the presentation of the data could be misleading if its limitation were not fully understood. Putting this
issue aside, the real (and confidential) reason that the report was disclosed was because Helen’s comment at the bottom
of page 3 suggests that it was widely known that there were problems with Horizon. This statement (regardiess of
whether it is correct) could have been used to attack Gareth Jenkin's credibility as POL's Horizon expert as he had
previously stated that there were no problems with Horizon.

As a side point - in Steve's email he refers to an “Andy Winn / Andy Lusher email”. I don't know anything about this
document — does this mean anything to anyone else?

Kind regards
Andy

Dear Ms Maru-Singh

I refer to your email of 7 April 2014.

The version of the report sent to Ms Robinson was redacted to protect the privacy and personal information of the
individuais named in the report. This was done to ensure compliance with the Data Protection Act 1998. Ail material

information in the report has been provided to your client in full compliance with Post Office's legal duties. We will
therefore not be providing an unredacted copy of the report..

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For the sake of good order, I note that Post Office disagrees with the statements in your email about the integrity of data
on Horizon and the safety of convictions.

I do not believe that this matter should delay the submission of your clients’ CQRs. However, should you require further
time on any particular case you may of course apply in thi ual way to the Working Group for an extension — please

Yours sincerely

Chris Aujard

Andrew Parsons
Senior Associate
for and on behaif of Bond Dickinson LLP

To: Angela Van-Den-Bogerd; Parsons, Andrew; Andy Holt; Rodric Williams
Cc: Chris Aujard; David Oliver1
Subject: Fwd: Post Office Mediation Claims.

Please see below. Not yet decided about whether to postpone this week's WG call but does anyone know anything
about the email being quoted below about remote alteration of figures in branch? I think that this is a new one on me.

Andy P, can we please chase CK for a response on the Rose report point.

Best wishes
Belinda

Belinda Crowe
48 Old Street, LONDON, EC1V 9H

Begin forwarded message:

From: Ron Warmington
Date: 8 April 2014 17:30:57 BST
To: ‘Belinda Crowe’

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Subject: FW: Post Office Mediation Claims.

Agenda item for this week's WG call perhaps?

Regards, Ron.

From: Steve Darlington!
Sent: Tuesday, April 08, 2014
To: 'Ron Warmington’
Cc: Post Office Group
Subject: FW: Post Office Mediation Claims.

Importance: High

Dear Ron,

As Priti has stated in her last sentence we are seeking a stay on the time limits on all cases under review due to the
implications of POL’s non-disclosure of system-generated transactions and Horizon’s integrity issues.

The ‘Helen Rose Report’ is of critical significance to all cases. The information contained within it is a compelling case for
such a stay in its own right. When combined with the Andy Winn/Alan Lusher email in the case of Ward which explicitly
states that Fujitsu can remotely change the figures in the branches without the SPMs’ knowledge or authority, the case
for a general stay is overwhelming.

We ask that the Working Party considers this request as a matter of urgency In order that we do not prejudice our
clients’ cases by omitting what is clearly information of the utmost general significance,.

We also request that the Working Party demands that POL acts quickly to provide the information requested in Priti’s
email immediately so that the mediation process is not hindered further.

Regards

Steve Darlington BA (Hons) ACA
Finance Director

1016 Great West Road, Brentford, TW8 9BA
www.howe.co.uk

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