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Message
From: Andrew Parsons GRO
Sent: 04/10/2019 16; :
To: Ben Foat }Rodric Williams
ce: Lucy Bremner, . j]; Jonathan Gribbe Tom Beezer
Amy Prime ii
Subject: RE! KELs - query [WBDUK-AC.FID26896945]
Attachments: RE: KELs - query [WBDUK-AC.FID26896945]
FY! - Instruction to Fujitsu attached.
Kind regards
Andy
Andrew Parsons
Partner
Wombie Bond Dickinson (UK) LLP
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DICKINSON
From: Andrew Parsons
Sent: 04 October 2019 16:45
$ Emanuel, Catherine < Rodric Williams
Watts, Alan
‘enneth Garvey
jonathan Gribben Tom Beezer
KELs - query [WBDUK-AC.FID26896945]
Thanks Both — I will send the instruction to Fujitsu to begin the extraction now.
Kind regards
Andy
From: Ben Foat
_}; Rodric
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Agreed. Thanks Kate.
Let’s proceed in that basis. We should note this in the board update report that Ken and Rod are pulling together now to
be sent to me in about an hour.
Ben Foat
General Counsel
t Office Limited
From: Emanuel, Catherine
Sent: Friday, October 4, 2019 2:50 pm
To: Ben Foat; andrew.parsons; Rodric Williams; Watts, Alan
Ce: Lucy Bremner; Jonathan Gribben; Tom Beezer; Amy Prime
Subject: RE: KELs - query [WBDUK-AC.FID26896945]
Ben,
My view is that we should proceed expeditiously and, if a further "QA" process is required before we can be sure we
have provided everything, we need to make that clear in our communications with the Claimants.
The situation we want to avoid is where we say we have given full disclosure but in response to probing by the Claimants
we find ourselves having to reveal more.
Kate
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Andy
Thanks. How have we previously disclosed the KELs ~ did we have a forensic consultant design the process and assure it?
My view is that the disclosure needs to be made quickly and our obligation is to make the disclosure. It is then a
separate issue around the level of assurance, review and analysis (including having the experts consider) the additional
disclosure. There is already a significant risk that the delay that this issue creates is that it could cause the judgment and
settlement discussions to be delayed.
As HSF is instructed by the Board, I would like to have their view and be guided by that recommendation (and Im happy
for preliminary assessment to be challenge).
Kind regards
Ben
Ben Foat
General Counsel
Post Office Limited
From: Andrew Parsons + GRO
Sent: Friday, October 4, 2019 2:16:23 PM
To: Rodric Williams { GRO
Subject: RE: KELs - query [WBDUK-AC.FID26896945]
Sorry for the misunderstanding Red.
Ben — are you abie to provide instructions on the below or does this question need to go to the board / elsewhere?
Post Office has three principal options for the extraction:
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1. It can rely on Fulitsu to extract the documents, disciose them to the Cs and take no further action. This may leave
problems latent or to be discovered and raised by the Cs. I don't believe that this option is in line with the general
strategy of “owning the story" around this issue.
2. Itcan have Fujitsu extract the documents now, disclose them to the Cs and then ask a forensic consultant to
retrospectively assure the process (having told the Cs that the assurance is being conducted). If any issues are
found, these would need to be explained to the Court and the Claimants and, potentially, further / corrective
disclosure may be needed. This could further damage Fujitsu's / Post Office's credibility.
3. Itcan engage the forensic company upfront to design and assure the extraction process, but this could add days /
weeks to the extraction. We cannot give a firm time estimate for this until the forensic consultants have
commenced work (which could be started today).
Kind regards
Andy
Andrew Parsons
Partner
Womble Bond Dickinson (UK) LLP.
a:
m:
t
GRO
2
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From: Rodric Williams <f G RO
Sent: 04 October 2019 13:35
To: Andrew Parsons
Ce: Ben Foat 4 i Lucy Bremner
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} Tom Beezer
Thanks. I don’t agree with the final point —- we need instructions on whether quick extraction is preferred to assured but
slower extraction.
Rod
Lucy Bremner
Tom Beezer
All
See below. FJ are now content to proceed with the extraction without waiting for financial clearance.
In terms of the scope of the extraction, we intend to ask FJ for a copy of all previous versions of KELs up to January 2019,
being the last KEL extraction date. More KELs will have been created after that date (and the Cs know that already). The
concern with extracting all KELs up to today's date is that we will be adding more new KELs. A line has to be drawn
somewhere otherwise disclosure is a continuously moving target and we need to be consistent with our previous
approach to this. We are seeking Tony Robinson's views on this urgently before giving Fujitsu the final instruction to
proceed.
l understand from a conversation between Rod and Amy that we are to commission the extraction from Fujitsu now so to
get the documents out as quickly as possible, but we are then to retrospectively assure that process through using a third
party forensics firm. We will provide a list of options for this shortly.
Kind regards
Andy
Andrew Parsons
Partner
Wombie Bond Dickinson (UK) LLP.
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womblebonddickinson.com
=~
ww
From:ParkerS# GRO
Sent: 04 October 2019 12:27
To: Andrew Parsons + iMatthew.Lenton¢
ewsomel
‘VTorstein.
I’m unsure where the financial aspects have got in the FJ ~ POL commercial process, I'll defer to Pete / Matthew on that
one. Having said that, I now have internal approval to complete the work regardiess, once WBD ask us to start the
extract.
In stating earlier that “Given clearance now, we’d have the information to you tomorrow lunchtime” I had forgotten it
was Friday! In mitigation, this is just my second day back from leave. That statement should have been: Given clearance
now, we'd have the information to you lunchtime the following working day.
Regards
Steve
From: Andrew Parsons <
Sent: Friday, October 4, 2019 12:09 PM
To: Parker, Steve <! >; Lenton, Matthew 1 5 Amy Prime
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; Godeseth,
Torstein{
Subject: RE: KELs - query [WBDUK-AC.FID26896945]
Steve — to be clear, please do not start the extract (even when you have financial clearance) until you get the go ahead
from WBD.
Thanks
Andy
Andrew Parsons
Partner
Wombie Bond Dickinson (UK) LLP
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DICKINSON
From: Andrew Parsons
Sent: 04 October 2019 11:31
Lucy Bremner
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Thanks. Where has the financial clearance got to? Is it with Post Office? If so who? I can then try to move it forward
from the Post Office end.
Kind regards
Andy
From:ParkerSP
Sent: 04 October 2019 10:55
To: Andrew Parsong ~~ ew. Lenton
GRO jLucy Bremner
en 4
RE: KELs - query [WBDUK-AC.FID26896945]
Andy,
Apologies for the TLA, yes, 1 MD = one man day. Given clearance now, we'd have the information to you tomorrow
lunchtime.
Regards
Steve
Steve Parker
Head of Post Office Application Support
Digital Technology Services
Fujitsu
Lovelace Road, Bracknell, Berkshire. RG12 8SN
Lenton, Matthew : Amy Prime
____GRO
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Torstein
Subject: RE: KELs - query [{WBDUK-AC.FID26896945]
Steve
Thanks. To be clear - does 1 MD mean one man day? If so, if you got financial clearance today, when would the
documents be passed to us?
Kind regards
Andy
Andrew Parsons
Partner
Womble Bond Dickinson (UK) LLP
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From:ParkerSP3
Sent: 04 October 20:
To: Andrew Parsons ¢
Laney
Subject: RE: KELs - query [WBDUK-AC.FID26896945]
Andy,
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Apologies, I didn’t realise that Matthew was on leave today.
While I still don’t have the internal confirmation of funding to do this activity I can say that the elapsed time to produce
the data for you would be 1 MD. Is that enough information for now?
Steve
Steve Parker
Head of Post Office Application Support
Digital Technology Services
Fujitsu
To: Lenton, Matthew Lucy Bremner
Cc: Newsome, Pete
; Godeseth,
Torstein
Subject: RE: KELs - query [WBDUK-AC.FID26896945]
Matthew
Please can you confirm as a matter of urgency (this morning) how long you believe it will take to extract the KELs? We
are expecting questions from the Claimants / the Court about this and need to be prepared to answer them immediately.
Thank you
Andy
Andrew Parsons
Partner
Womble Bond Dickinson (UK) LLP.
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womblebonddickinson.com
~
sae
Sent: 03 October 2019 15:22
GRO
To: Amy Pr img —_
We are just awaiting internal confirmation of funding before starting this activity.
Matthew Lenton
Document Manager
Post Office Account
Fujitsu
_Lovelace Road, Bracknell, Berkshire, R612 8SN
GRO I
Cc: Newsome, Pet Jonathan
Gribben }Parker, Steve
Subject: RE: KELs - query [WBDUK-AC.FID26896945]
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Matthew
Further to the below and our discussion yesterday, I understand that to extract the previous versions of the current or
deprecated KELS as HTML files it would be necessary to produce a new script. Please could Fujitsu proceed with
producing this script, butnot run the script until we provide further confirmation to do so?
if you could let me know and ETA for this script being ready it would be much appreciated.
Many thanks
Amy
Amy Prime
Associate
Womble Bond Dickinson (UK) LLP.
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Sent: 01 October 2019 10:15
To: Lucy Bremner}
“I Andrew Parsong "
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This part: “{t]he KEL only contains the current database entries’”— I’m not completely clear what that is intended to
mean, but it may be clarified by the following:
This is correct: “is constantly updated and so the current version will not necessarily reflect the version that was in place
at the relevant time”
The second sentence is not correct: “The previous entries / versions of the current entries are no longer available".
You may recall that there are three status categories of KEL: current, deprecated and deleted. For those that are current
or deprecated, they have been updated in such a way that previous content is not permanently overwritten, but instead
a new version is created, with the previous versions being retained and accessible. For those that have been deleted,
only the last version at the point of deletion has been retained.
Matthew Lenton
Document Manager
Post Office Account
Fujitsu
-bovelace. Road. Bracknell, Berkshire. R612 8SN
From: Lucy Bremner
Sent: Monday, September 30, 2019
To: Lenton, Matthew ¢
Cc: Newsome, Pete ¢ Andrew Parsons
Jonathan Gribben:
Subject: KELs - query [WBDUK-AC.FID27032497]
Matthew,
Post Office is seeking to quote from its Electronic Documents Questionnaire submitted back in 2017. It is seeking to rely
on the following quote in relation to KELs
“[t]he KEL only contains the current database entries and is constantly updated and so the current version will not
necessarily reflect the version that was in place at the relevant time. The previous entries / versions of the current entries
are no longer available".
Can you confirm that this is definitely the correct position (i.e. that previous entries are no longer available)? We need to
respond to Freeths by 10am tomorrow, so confirmation ASAP would be appreciated.
Kind regards,
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Lucy
Lucy Bremner
Associate
Wombie Bond Dickinson (UK) LLP.
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ral data is ia
s detestion software before
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This email is only for the use of its intended recipient. Its contents are subject to a duty of confidence and may
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Unless otherwise stated, this email has been sent from Fujitsu Services Limited (registered in England No
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