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From: Andrew Parsons [/O=EXCHANGE-ORG/OU=EXCHANGE ADMINISTRATIVE GROUP
(FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=AD9ED344815E47E4AAA3COE7E17409 19-ANDREW PARS]
Sent: 11/02/2019 07:59:52
To: Angela Van-Den-Bogerd:
cc: Jonathan Gribben [/o=Exchange-Org/ou=Exchange Administrative Group
(FYDIBOHF23SPDLT)/cn=Recipients/cn=ea64a893cedd463ea82d76a4b08032dd-Gribben, Jo}; Katie Simmonds
[/o=Exchange-Org/ou=Exchange Administrative Group
(FYDIBOHF23SPDLT)/cn=Recipients/cn=38c83ff2d54f4e8daaafS 1c32c82b3dd-Katie Simmo]; Lucy Bremner
[/o=Exchange-Org/ou=Exchange Administrative Group
(FYDIBOHF23SPDLT)/cn=Recipients/cn=06e1b09e0d614ccd91d87a9323bd85c0-Bremner, Lu]; Dave Panaech
[/o=Exchange-Org/ou=Exchange Administrative Group
(FYDIBOHF23SPDLT)/cn=Recipients/cn=0310835f6adc435ab 1b160664f370de9-Dave Panaec]; Michael Wharton
[/o=Exchange-Org/ou=Exchange Administrative Group
ipi cn=cSd1fba922c540cba78e94f1f8ยข75b15-Wharton, Mi]; Rodric Williams
Mark Underwood! j _
Subject: 22 Bugs [(WBDUK-AC.FID27032497}
Attachments: _DOC_154190294(1)_3.27 Receipts and Payments.docx; _DOC_154189323(1)_3.78 Local Suspense Issue.docx;
_DOC_154189599(1)_3.43 Suspense Account Bug.docx; _DOC_154190043(1)_3.46 Dalmellington_ Branch Outreach
Issue.docx; _DOC_154188959(1)_3.140 Bureau discrepancies.docx; _DOC_154188831(1)_3.56 Remming In.docx;
_DOC_154166863(1)_3.67 Remming Out.docx; _DOC_154188942(1)_3.148 Phantom Transactions.docx;
_DOC_154174830(1)_3.99 Reversals.DOCX; FJ reports.zip
Angela
FJ have provided us with their initial comments on the 22 bugs cited by Coyne (attached). My team are now working
through these to convert FJ's comments into more comprehensive and user friendly notes for Counsel. Our first 9
summaries are attached - they are a little rough and ready at the moment.
I'd be grateful for your team's help in filling some gaps in our information.
First, some of these bugs take place in the context of a particular operating practice (eg. remming in). Would your team
be able to locate the relevant operating manual (or similar document) that describes the practice in question? This
document(s) would help us put the bug in context when presented in Court. Note โ we need the ops manual for the
correct time period of the bug which might be trickier.
Second, Fu's knowledge typically runs from identification of a possible problem through to fixing the underling bug. This
activity is tracked in their PEAK and KEL systems. Where there is a financial impact, FJ tell us (and indeed this is shown
in some of FJ's documents) that they will report to PO on the number of branches impacted so that PO can communicate
with the SPMs and correct any resulting shortfalls (typically by way of TC). We have asked FJ to search their records for
(i) lists of affected branches and (ii) communication of those lists to PO.
Would you mind trying to search for this same information from the PO side? Ideally we want to be able to show that
where there has been a bug, PO has identified and corrected all affected branches. In a perfect world, this would be a list
of a TCs issued to branches and covering letters to SPMs explaining what happened. This will obviously not be possible
in most cases, but even some internal emails that show this happening would be useful.
I appreciate that this is looking for a needle in a haystack but anything you can do to help would be appreciated. I would
suggest starting with the 9 summaries attached โ in particular, 3.46, 3.56, 3.67, 3.78 and 3.99.
Kind regards
Andy
Andrew Parsons
Partner
Womble Bond Dickinson (UK) LLP
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