POL00053992
POL00053992
Amsphere Confidential and Privileged
On instruction of Coomber Rich Solicitors
Yard House, Basingstoke, RG21 7NX
Re: Seema Misra
3" Interim Technical expert’s report to the Court prepared by
Charles Alastair McLachlan, a Director of Amsphere Consulting
Ltd.
90 Fenchurch Street
London EC3M 4BY
England
This report contains 7 pages
POL00053992
POL00053992
Amsphere Confidential and Privileged
On instruction of Coomber Rich Solicitors
Yard House, Basingstoke, RG21 7NX
Contents
1 REVIEW OF EVIDENCE AVAILABLE AS OF 18" FEBRUARY 2010
2 APPENDIX 1 — INSTRUCTIONS ETC..........cessssssssssessesessesessseesseseseanes 2
3 APPENDIX 2 - MY DUTIES TO THE COURT..........::ssssssssssesesssssseeeeeeeeee 4
Charles McLachlan
1
POL00053992
POL00053992
Amsphere Confidential and Privileged
On instruction of Coomber Rich Solicitors
Yard House, Basingstoke, RG21 7NX’
1 Review of evidence available as of 1 February 2010
1.1
1.1
1.2
1.2.1
1.2.2
1.2.3
1.3.1
1.3.2
Hypothesis: The User Interface gives rise to incorrect data entry
Source of problem — training and support: full and complete training
materials and training records have yet to be provided. In addition a log
of calls and response to the NBSC would provide further evidence as to the
understanding of the users at the West Byfleet branch.
Source of problem — user interface: there has not been an opportunity to
conduct a usability review to date; in addition, the logs included in Andy Dunk
2". witness statement refer to problems with the touch screen which require
the screen to be calibrated. It has not been possible to test whether this
could give rise to incorrectly captured user actions.
Hypothesis: The Horizon system fails to properly process transactions
Source of problem — End to end EPOSS transaction flow: the equipment
failure user guide provided identifies at subsection 14 a process for identifying
lost EPOSS transactions. The implication is that EPOSS transactions can be
lost due to equipment failures. Without access to the sub post office data
records and the intermediate data records in the end to end process it will
not be possible to identify the extent to which this may explain the accounting
discrepancies.
Source of problem — Poor integration: the helpdesk reports provided in Andy
Dunks 2™ statement identify a series of problems with the network, printer
and the pin terminal. It has not been possible to test whether this could give
rise to inconsistent data capture and transmission at the sub post office.
Source of problem -— systems issues causing incomplete/inconsistent
processing of transactions between sub post office and central systems: the
reports provided in Andy Dunks 2™ statement identify a number of cases in
which the user was required to ‘re-boot’ the terminal. It has not been
possible to test whether this could give rise to inconsistent data records in the
sub post office.
Hypothesis: Errors in operator data entry are not properly reconciled by
the Post Office finance function or by the Horizon system: without access
to the system files it is not possible to determine whether this is the case.
Source of problem — lack of reconciliation of EPOSS transactions end to end:
without access to the system data files it is not possible to determine
whether this is the case.
Source of problem — lack of reconciliation of other transactions end to end:
without access to the system data files it is not possible to determine
whether this is the case.
Charles McLachlan
1
Amsphere
Charles McLachlan
2
POL00053992
POL00053992
Confidential and Privileged
On instruction of Coomber Rich Solicitors
Yard House, Basingstoke, RG21 7NX
POL00053992
POL00053992
Amsphere Confidential and Privileged
On instruction of Coomber Rich Solicitors
Yard House, Basingstoke, RG21 7NX
2 Appendix 1 — Instructions etc.
2.1 Instructions
2.1.1 Tam Charles Alastair McLachlan, a Director of Amsphere Consulting Limited,
London, England specialising in information technology consulting. I have
been instructed in this matter by Coomber Rich Solicitors, on behalf of their
client, Seema Misra, (“the Defendant”) to assist the court in this matter of
alleged fraudulent accounting in providing expert evidence on the questions
posed at 1.1.3 hereunder.
2.1.2 [have been instructed to review the disclosures provided in electronic format
by the prosecution up to 1* February 2010 and consider to what extent they
will enable me to provide an opinion in relation to the alternate hypotheses for
the discrepancies that have given rise to charges of fraudulent accounting.
2.2 My qualifications have been itemised in the previous two interim reports.
2.3 Confidentiality
2.3.1 This report is strictly private and confidential and has been prepared at the
request of Coomber Rich Solicitors on behalf of their client, for the Court.
2.4 Legal and factual issues
2.4.1 This report should not be read as expressing any opinion on factual matters
which depend on disputed testimony of the witnesses of fact, or legal issues.
It, however, inevitably reflects my understanding of the position.
2.5 Sources of information
Charles McLachlan
3
POL00053992
POL00053992
Amsphere Confidential and Privileged
On instruction of Comber Rich Solicitors
Yard House, Basingstoke, RG21 7NX
2.5.1 In preparing my report, I have considered the documents used for my previous
reports and in addition:
a. The ‘Further Disclosure Request’ submitted by the Defence
b. The responses by e-mail from Marilyn Benjamin, Royal Mail 29" January
2010
c. Horizon System User Guide - Equipment information and system failure
Version 8.0 August 1999
d. The 2™ Witness statement of Andrew Paul Dunks 29" January 2010
e. The Audit of Post Office ® West Byfleet branch, Excel Workbook
2.6 The scope of my work
2.6.1 I report as an expert witness, not as a witness of fact. I have reviewed the
documentation provided to me.
2.7 Independence
2.1.1 Ihave prepared an independent and objective report addressed to the Court. I
have had no previous involvement with the Defendant. I have no previous
involvement with Coomber Rich Solicitors.
2.1.2 Amsphere’s fees in this case are not dependent on the result of the
proceedings in this matter.
Charles McLachlan
4
POL00053992
POL00053992
Amsphere Confidential and Privileged
On instruction of Coomber Rich Solicitors
Yard House, Basingstoke, RG21 7NX
3 Appendix 2 - My duties to the Court
3.1 IT understand that my overriding duty is to the Court, both in preparing reports
and in giving oral evidence. I have complied and will continue to comply with
that duty.
3.2 I have set out in my report what I understand from those instructing me to be
the questions in respect of which my opinions as an expert are required.
3.3. I have done my best, in preparing this report, to be accurate and complete. I
have mentioned all matters that I regard as relevant to the opinions I have
expressed. All of the matters on which I have expressed an opinion lie within
my field of expertise.
3.4 I have drawn to the attention of the Court to all matters, of which I am aware,
which might adversely affect my opinion.
3.5 Wherever I have no personal knowledge, I have indicated the source of factual
information.
3.6 I have not included anything in this report that has been suggested to me by
anyone, including the lawyers instructing me, without forming my own
independent view of the matter.
3.7 Where in my view, there is a range of reasonable opinion, I have indicated the
extent of that range in the report.
3.8 At the time of signing the report I consider it to be complete and accurate. I will
notify those instructing me if, for any reason, I subsequently consider that the
report requires any correction or qualification.
Charles McLachlan
5
POL00053992
POL00053992
Amsphere Confidential and Privileged
On instruction of Coomber Rich Solicitors
Yard House, Basingstoke, RG21 7NX
3.9 I understand that this report will be the evidence that I will give under oath,
subject to any correction or qualification I may make before swearing to its
veracity.
3.10 I have included in this report a statement setting out the substance of all facts
and instructions given to me, which are material to the opinions expressed in
this report or upon which those opinions are based.
3.11 I confirm that insofar as the facts stated in my report are within my own
knowledge I have made clear which they are, and I believe them to be true, and
the opinions that I have expressed represent my true and complete professional
opinion.
Charles McLachlan
Amsphere Consulting Ltd
90 Fenchurch Street
London, EC3M 4BY
England
Wednesday, 3“ February 2010
Charles McLachlan
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