POL00041382 - Email from Rodric Williams to Shirley Hailstones and others re: Legally Privileged - Further Enquiry on Horizon Errors from Anobody

Evidence on official site

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Message

From: Rodric Williams E

Sent: 29/11/2016 14:26:56

To: Shirley Hailstones [7 3; Parsons, Andrew [/o=Exchange-Org/ou=Exchange
Administrative Group (FY! ndrew Pars];
Angela Van-Den-Bogerd I; FOITEAM

Subject: RE: Legally Privileged - Further Enquiry on Horizon Errors from Anobody [BD-4A.FI

Hi - that looks good to me thank you both.

Just one small typo in the last sentence of the first bullet point (“Event logs can also be produced which will provide
detail on who dene did what and at what time”).

Other than that, as far as I'm concerned this can go onto PO letterhead and sent by Angela.

Kind regards, Rod

From: Shirley Hailstones

Sent: 29 November 2016 10:51

To: Parsons, Andrew; Angela Van-Den-Bogerd; Rodric Williams; FOITEAM

Subject: RE: Legally Privileged - Further Enquiry on Horizon Errors from Anobody [BD-4A.FID26896945]

Hi Andy

Please see my additions: I’ve tracked changes.

Shirley Hailstones
> Support Services Resolution Manager
Post Office Limited

Guildhall, 57 Queen St
Glasgow

@

Confidential Information:
This email message is for the sole use of the intended recipient(s) and may contain confidential and privileged information. Any unauthorised review,
use, disclosure or distribution is prohibited.

If you are not the intended recipient please contact me by reply email and destroy all copies of the original message.

From: Parsons, Andrew [rm

Sent: 25 November 2016 18:18
To: Angela Van-Den-Bogerd; Rodric Williams; FOITEAM; Shirley Hailstones
Subject: RE: Legally Privileged - Further Enquiry on Horizon Errors from Anobody [BD-4A.FID26896945]

Angela

Please find attached a draft response to Mr Obody that Rod has already seen and commented on. Picking up a point in
one of the emails below, we've left space in the response to insert some guidance from Shirley on how to investigate

shortfalis.

Shirley — would you mind adding a few bullets to the draft response and then re-circulating?

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Thanks
Andy

Andrew Parsons
Partner
Bond &

www.bonddickinson.com

From: Angela Van-Den-Bogerd [mailt¢”
Sent: 24 November 2016 16:21

To: Rodric Williams; FOITEAM; Parsons, Andrew

Subject: RE: Legally Privileged - Further Enquiry on Horizon Errors from Anobody

Kerry
This is the latest on this.
Andy ~ I’ve not seen a draft response on this as requested by Rod. When do you anticipate I will?

Thanks,
Angela

~ Angela Van Den Bogerd
Director of Support Services

. 1% Floor, Ty Brwydran,
Atlantic Close, Llansamiet

Swansea SA7 9F3

Confidential Information:

This email message is for the sole use of the intended recipient(s) and may contain confidential and privileged
information. Any unauthorised review, use, disclosure or distribution is prohibited. If you are not the intended
recipient please contact me by reply email and destroy all copies of the original message.

From: Angela Van-Den-Bogerd
Sent: 16 November 2016 2:
To: Rodric Willi 7

Parsons, Andrew
er Enquiry on Horizon Errors from Anobody

Thanks Rod,

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I await the draft from Andy.
Kerry ~ would you amend the FO! response as per Rod’s suggestion please.

Thanks,
Angela

Angela Van Den Bogerd
Director of Support Services

1 Floor, Ty Brwydran,
Atlantic Close, Llansamlet
SA7 SF) _

Confidential Information:

This email message is for the sole use of the intended recipient(s) and may contain confidential and privileged
information, Any unauthorised review, use, disclosure or distribution is prohibited. If you are not the intended
recipient please contact me by reply email and destroy all copies of the original message.

From: Rodric Williams
Sent: 16 November 2016 19:16
To: Angela Van-Den-Bogerd
Cc: FOITEAM £
Subject: RE: Legally Pri

Parsons, Andrew
leged - Further Enquiry on Horizon Errors from Anobody

Hi Angela — I do not think this is a genuine request. It has all the hallmarks of Tim McCormack mischief, and indeed
these FOIA requests were recently cited in a blog which thanked Mr McCormack “for his work and help in relation to the
Horizon system”.

Nevertheless, we need to respond prudently, which I think we can do as follows:
1. Ewould use the FOIA response as drafted, concluding the letter as follows:

We deal with requests that do not fall under the FOIA through standard business enquiry processes
rather than as a formal request for information;
answer}. You will therefore receive a response from the relevant Post Office business. unit directly.

2. In terms of the BAU response, the point we want to get across is that asking for the Known Error Log to try to
identify whether anything in it impacted a branch’s accounts is to put the cart before the horse.

The KEL is a substantial electronic record, very little of which will have any bearing on an individual branch’s
accounts, and none of which (Fujitsu tells us} has ever affected the Core Audit Log, i.e. the record of transactions
as entered by the branch.

The PMR however is in the branch looking at his accounts all the time, and even if he can’t tell precisely wi
has gone wrong (though Kath and Shirley's guidance will help), he must at least know when things started to go
awry.

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Without even that most basic of information from the PMR, asking for the KEL is a bit like asking Sainsbury's for
a list of all prices ever charged for all products to work out why he’s spent more on his weekly shop, when really
he should start by looking at what he’s put in his basket.

Given that that is not the greatest analogy, but more importantly how central this allocation and sequencing of
responsibility for branch account anomalies is in the Freeths litigation (where we should assume this will end
up}, I have asked Bond Dickinson (Andy Parsons cc’ed)} to draft something setting this out, which we can then
dovetail with Kath and Shirley’s guidance for them to send.

3. On the false accounting point, it is in PMR’s interest (and arguably also his duty} to raise with us anomalies in his
branch accounts. if he has instead acted in a way which he is concerned gives rise to criminal liability, he should
seek independent legal advice.

I hope that helps. Please let me know if you would like to discuss.
Kind regards, Rod

From: Angela Van-Den-Bogerd

Sent: 14 November 2016 20:13

To: Rodric Williams

Cc: FOITEAM

Subject: FW: Legally Privileged - Further Enquiry on Horizon Errors from Anobody
Importance: High

Rodric,

Could you respond to me email of 3° November so that we can formally respond to the follow up request from this
postmaster.

Thanks,
Angela

# Angela Van Den Bogerd
Director of Support Services

. 1% Floor, Ty Brwydran,
Atlantic Close, Llansamiet

Swansea SA7 9FI

Confidential Information:

This email message is for the sole use of the intended recipient(s) and may contain confidential and privileged
information. Any unauthorised review, use, disclosure or distribution is prohibited. If you are not the intended
recipient please contact me by reply email and destroy all copies of the original message.

From: FOITEAM.
Sent: 14 November 2016 17:33
To: Angela Van-Den-Bogerd ¢ GRO na

Subject: FW: Legally Privileged - Further Enquiry on Horizon Errors from Anobody
Importance: High

Hi Angela,

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Do you have the response ready you were working on in relation to this request?

Many thanks,
“ Kerry Moodie
Information Rights Manager
1% Floor
Finsbury Dials

20 Finsbury Street

From: Angela Van-Den-Bogerd

Sent: 03 November 2016 08:30

To: Rodric Williams; Patrick Bourke; Melanie Corfield; Mark R Davies
Ce: FOITEAM
Subject: Legally Pri
Importance: High

leged - Further Enquiry on Horizon Errors from Anobody

Rod,

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This postmaster clearly thinks that the answer to their problem is in this list of errors and in all likelihood is therefore not
looking/or does not know how to look for any discrepancies in branch. I really want to try and help this postmaster but
clearly we cannot say that we will not address what they have confirmed to us je that they have falsified their account.

My preference would be to explain to this postmaster what the errors to which he refers are and that if these were
affecting his branch we would be able to identify that. And as per my request to Shirley below offer some guidance on
how to look for discrepancies and accounting irregularities and importantly how to control the balancing of their branch.

On the false accounting point could we say something along the lines of “each case is treated on its merit and therefore
we could not say until we were aware of the facts of the situation what action if any would be taken contractually or
legally. But it could be possible that an error or errors within the branch could have contributed to any loss and there is a

possibility that with proper scrutiny of the Horizon data we could establish what had happened in branch”

What’s your view?
Patrick, Mel, Mark - any thoughts welcome.
Thanks,

Angela

Angela Van Den Bogerd
Director of Support Services

1% Floor, Ty Brwydran,
Atlantic Close, Llansamlet
Swansea SA7 9FJ

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Confidential Information:

This email message is for the sole use of the intended recipient(s) and may contain confidential and privileged
information. Any unauthorised review, use, disclosure or distribution is prohibited. If you are not the intended
recipient please contact me by reply email and destroy all copies of the original message.

From: Angela Van-Den-Bogerd

Sent: 03 November 2016 08:07

To: Shirley Hailstones <¢~ >
Subject: FW: Further Enquiry on Horizon Errors from Anobody
Importance: High

Shirley

Would you pull some pointers together for me to send to this postmaster. I have no idea what the size of this loss is or
over what period it has built up but in the absence of them talking to us I want to offer some guidance on how to look
for discrepancies and perhaps staff theft/manipulation of transactions. Also guidance on how to run a tight ship eg
accurate cash declarations; weekly balancing etc. I know you'll get my drift.

Could you do this today please as this postmaster is sounding desperate and making references to taking their own life.

Thanks,
Angela

. Angela Van Den Bogerd
Director of Support Services

. 1st Floor, Ty Brwydran,
Atlantic Close, Llansamiet

Swansea SA7 9F3

Confidential Information:

This email message is for the sole use of the intended recipient(s) and may contain confidential and privileged
information. Any unauthorised review, use, disclosure or distribution is prohibited. If you are not the intended
recipient please contact me by reply email and destroy all copies of the original message.

From: FOITEAM.
Sent: 01 November 2016 11:01
To: Angela Van-Den-Bogerd

“>; Melanie Corfield
'>; Patrick Bourke

>; Mark R Davies <i
Q Rodric Williams ¢__
Subject: Further Enquiry on Horizon Errors from Anobody
Importance: High

Good Morning All,

Please see the reply received from Mr Obody below.

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In light of the Court Action I think legal should draft the response to this, we have provided the 'anonymous' person
options to resolve the alleged issue pursue and cannot do much else in this public arena and advised what they should
do if they want an internal review.

I think the response should be based on the fact that this is not a request for recorded information and whatever
context are felt to be required — therefore I have attached the basic response to this for amendment.

I will acknowledge the request and await further instructions.
Regards,

Kerry Moodie
Information Rights Manager

20 Finsbury Street
London EC2Y 94Q

Dear Post Office Limited,
I thought i sent a reply to you but it doesn't seem to have got through.

I cannot talk to anyone about this because I have signed off my branch accounts with the wrong figures and I can go to
prison for doing that. I haven't taken any money. I want to know what errors to look for. I read all this talk about
errors in horizon on the internet I want to know what they are. YOu say you have that information but you won't give
me it so what is my alternative. I don't have that sort of money to give to you. Will you prosecute me for my accounts
if I talk to mrs Bogard? Please tell me, surely you have to tell me what these errors are?

Yours faithfully,

A.N. Obody

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