POL00058443
POL00058443
THE QUEEN
v
SEEMA MISRA
TAKE NOTICE that, in addition to the evidence before the Magistrates’ Court, further evidence,
the effect of which is set out herein, may be given at the trial.
DATED this 12" day of April 2010
To: the Solicitors acting
for the Defendant
and to the Court
Signed J SINGH
for General Counsel to Royal Mail Group Limited
Legal Services
6a Eccleston Street
LONDON
SWIW SLT
Z:Acriminal work folders\singh jarnail - crm\258932 - misra\nae - 2.doc
POL00058443
POL00058443
Witness Statement
(CJ Act 1967, 9; MC Act 1980, ss 5A(3)(a)
and 5B, MC Rules 1981, r 70)
Statement of Andrew Paul Dunks
Age if under 18 over 18 (If over 18 insert ‘over 18')
This statement (consisting of 5 pages signed by me) is true to the best of my knowledge and
belief and I make it knowing that, if it is tendered in evidence, I shall be liable to prosecution if I
have wilfully stated in it anything which I know to be false or do not believe true.
Dated the 2010
Signature
Further to my Statement of 24" June 2009, I would now like to add the following.
I have been employed by Fujitsu Services (Fujitsu), Post Office Account, since 11 March 2002
as an IT Security Analyst where I am involved in IT Security for the Post Office Account. I
have a working knowledge of the computer system known as Horizon, which is a
computerised accounting system used by Post Office Ltd. I am authorised by Fujitsu to
undertake extractions of audit data held on the Horizon system and to obtain information
regarding system transaction information processed on the Horizon system.
I make this Witness Statement from facts within my own knowledge unless otherwise stated.
Any records to which I refer in my statement form part of the records relating to the business
of Fujitsu. These were compiled during the ordinary course of business from information
supplied by persons who have or may reasonably be supposed to have personal knowledge of
the matter dealt with in the information supplied, but are unlikely to have any recollection of
the information or cannot be traced, since the nature of the helpdesk involves many engineers
all at differing levels and any number could be involved in a particular call. As part of my
duties, I have access to these records, but I was not involved with any of the technical aspects
of these calls. This area is not my particular area of expertise and I make this witness
statement simply to help clarify the call logs for the benefit of the Court.
Signature
CSO11A (Side A) Version 4.0 07/06
POL00058443
POL00058443
Witness Statement
(CJ Act 1967, s9; MC Act 1980, ss 5A(3)(a) and 5B, MC Rules 1981, r 70)
Continuation of statement of Andy Dunks
An important element of the support provided to sub-postmasters and Counter Clerks is the
Horizon System Helpdesk (HSH). The HSH is the Horizon user's first ‘port of call’ in the event
of their experiencing a problem with the Horizon system or requiring advice and guidance. If
the system were to malfunction, Upon discovery the Horizon users (i.e. the sub-postmaster or
counter clerk) would raise a call to the HSH seeking clarification or advice. HSH is a service
run by Fujitsu Services for the Post Office. I have been asked to provide information pertaining
the working condition of the Horizon system. The following information constitutes the calls
logged by HSH recorded during the period January 1st 2005 to June 30th 2005 for the West
Byfleet Post Office - Branch Code 126023.
I have reviewed the HSH calls pertaining to the West Byfleet branch during the period
January 1st 2005 to June 30th 2005. There were 13 calls from branch Code 126023 to the
HSH. All the calls are of a routine nature and do not fall outside the normal working
parameters of the system or would affect the working order of the counters.
Call reference details and an overview of each call are given in date order below:
There are a many abbreviations that the HSH use in their call details, here are many
explained:
NBSC - Network Business Support Centre
PM - Post Master
CC — Counter Clerk
Bop — Back office printer
CP- Counter printer
ADSL - Asymmetric Digital Subscriber Line (network connection)
PWWDCTR - Wait While Desktop Connects To Riposte
BU — Base Unit (counter)
PMMC - Postmaster Memory Card
Ithaca — make of printer
MLP ~ mail label print
Signature I G RO I Signature witnessed by i GRO L
CS011A Version 4.0 07/06
POL00058443
POL00058443
Witness Statement
(CJ Act 1967, s9; MC Act 1980, ss 5A(3)(a) and 5B, MC Rules 1981, r 70)
Continuation of statement of Andy Dunks
OSP — One Shot Password
EOD — End of Day
BCR - Bar Code Reader
PMHTCC — Post master happy to close call
SSC - System Support Centre 3/4" line support
1. Mon 10 January 2005 10:10 Call E-0501100701
Engineer to swap pinpad ALWAYS even if it appears to be working due to HCP reporting as faulty. NODE ID: 3
Resolution: thu 10 February 2005 08:19
Call Closed by Emma Bradley: call closed
Outcome
PinPad replaced by engineer.
2. Wed 12 January 2005 16:39 Call E-0501121046
Pm reports bop very hot and not feeding paper at all
Resolution: wed 12 January 2005 16:42
Call Close by Susanna Craske: Pm reports bop not feeding and very hot. advised Pm to order new image drum. ref
offered Outcome
Advised to replace printer part.
3. Tue 01 February 2005 09:33 Call E-0502010226
Pm states op receipt jams
Resolution: Tue 01 February 2005 09:37
Call Close by Philippa Sparrow: Pm states cp receipt jams. Adv clean sensor. pm states this has worked. pm htcc
Outcome
Advised to clean printer sensor.
4, Tue 08 February 2005 16:37 Call E-0502080765
Caller states that CP is not printing labels.
Resolution: wed 09 February 2005 18:19
Call Close by Sarah Hill: ** [No Remark entered.] Call closure code of FAILURE and repair code 821
Qutcome
Printer replaced.
SOTA Version 4.0 07/06
Signature} G RO I Signature witnessed by i GRO
POL00058443
POL00058443
Witness Statement
(CJ Act 1967, s9; MC Act 1980, ss 5A(3)(a) and 5B, MC Rules 1981, r 70)
Continuation of statement of Andy Dunks
5. Thu 10 February 2005 15:06 Call E-0502100784
clerk states that she had a replacement cp on node 1 but Is still having problems with the mail labels
Resolution: thu 10 February 2005 15:24
Call Close by Navdeep Uppal: clerk called as mail labels were jamming, advised clerk to perform a factory reset, cp
now operational call ref given, pmhtcc
Qutcome
Advised to reset printer.
6. Thu 10 February 2005 15:27 Call E-0502100802
pm states that mail labels get jammed in op
Resolution: Thu 10 February 2005 15:38
Call Close by Navdeep Uppal: pm called as mail labels are jamming, asked clerk to perform factory reset, pmhtcc call
ref given, cp now operational
Qutcome
Advised to reset printer.
7. Tue 15 February 2005 16:41 Call E-0502150867
Pm states cp keeps jamming labels, labels get stuck
Resolution: wed 16 February 2005 18:17
Call Close by Jordan Edgar: ** [No Remark entered.) Call closure code of FAILURE and repair code 821
Qutcome
Printer replaced.
8. Tue 22 March 2005 12:26 Call E-0503220459
pm states that the counter printer is not printing labels comes up with a red flashing light.
Resolution: Tue 22 March 2005 12:38
Call Close by Simon Hopperton: pm states that the counter printer is not printing labels comes up with a red flashing
light. advised pm to do a factory reset. pm states that the printer is now working and is happy to close call.
Qutcome
Advised to reset printer.
9. Tue 22 March 2005 15:26 Call E-0503220598
pm states cp is not printing postage labels
Resolution: wed 23 March 2005 08:05
Call Close by Martin Hammond: replaced printer Call closure code of and repair code 821
Qutcome
Printer replaced.
Signature I GRO I Signature witnessed by I GRO i
csot1A ~~" Version 4.0 07/08
POL00058443
POL00058443
Witness Statement
(CJ Act 1967, s9; MC Act 1980, ss 5A(3)(a) and 5B, MC Rules 1981, r 70)
Continuation of statement of Andy Dunks
10. Tue 29 March 2005 08:50 Call E-0503290102
pm states they have the error please wait while desktop connects to riposte
Resolution: tue 29 March 2005 08:53
Call Close by Adam Goldstein: pm states they have the error please wait while desktop conects to riposte ref no given
Outcome
PM advised to reboot counter...
11. Tue 29 March 2005 17:09 Call E-0503290872
caller states that the cp on 2 is not feeding correctly
Resolution: wed 30 March 2005 13:15
Call Close by Sarah Hill: Engineer replaced the counter printer. Call closure code of and repair code 821
Outcome
Printer replaced.
12. Fri 01 Aprit 2005 08:02 Call E-0504010050
PM states bop Is not printing and the message ‘unable to retrieve status of this device’ appears.
Resolution: Fri ot April 2005 08:11
Call Close by Elspeth Neilson: PM reporting bop not printing and red light flashing. Deleted print Q and advised to
change toner. Ref given.
Outcome
Advised to replace printer part.
13. Fri 01 April 2005 08:49 Call E-0504010080
Pm states that the red light is still flashing and he has just changed the toner but the printer is still printing
Resolution: Fri 01 April 2005 08:52
Call Close by Sarah Dawe: Pm states that the red light is stil flashing and he has just changed the toner but the
printer is still printing advised pm if its printing everything will be ok and if he has any problems to call back pmhtcc ref
offered
Outcome
Advised and guidance given.
Signature Signature witnessed by
ry
iad
CSO11A Version 4.0 07/06
POL00058443
POL00058443
Witness Statement
(CJ Act 1967, s9; MC Act 1980, ss 54(3)(a)*
and 58, MC Rules 1981, r 70)
Statement of Andrew Paul Dunks
Age if under 18 over 18 (If over 18 insert 'over 18')
This statement (consisting of 1 page signed by me) is true to the best of my knowledge and
belief and I make it knowing that, if it is tendered in evidence, I shall be liable to prosecution if I
have wilfully stated in it anything which I know to be false or do not believe true.
Dated the 30th dayof March 2010
calls logged from West Byfleet Post Office to the Horizon System Helpdesk (HSH) between
January 1% 2005 to December 31° 2009.
I _GRO-
Signature
Version 4.0 07/06
CSO11A (Side A) ~~
POL00058443
POL00058443
Witness Statement
(CJ Act 1967, 89; MC Act 1980, ss 5A(3)(a)
and 5B, MC Rules 1981, r 70)
Statement of lan Venables
Age if under 18 Over 18 (If over 18 insert ‘over 18')
This statement (consisting of 2 pages each signed by me) is true to the best of my knowledge and belief
and I make it knowing that, if it is tendered in evidence, I shall be liable to prosecution if I have wilfully
stated in it anything which I know to be false or do not believe true.
Dated the 30 day of = March 2010
Signature ;
I have been employed by Fujitsu Services, Post Office Account since May 2005. I perform the
role of Service Delivery Manager and am responsible for service delivery of all Post Office
change. I have working knowledge of the computer system known as Horizon, which is a
computerised accounting system used by Post Office Ltd and knowledge of the processes
used when Horizon kit is uplifted from closing Post Office Branches.
Horizon’s documented procedures stipulate how the Horizon System operates, and while I am
not involved with any of the technical aspects of the Horizon System, these documented
processes allow me to provide a general overview.
The serial number of the Gateway PC base unit at West Byfleet Branch (FAD Code 126023) is
YBSHO011567 and I have documentation from Triage Services confirming repair and software
reload of this unit prior to its deployment to the West Byfleet Branch.
On arrival at Triage Services on the 23rd of January 2008 base unit YBSHO11567 was
subjected to a standard clean, test, and application reinstallation as per standard process,
Triage Services state that no malfunctions were found and as a result no repairs were carried
out to this unit and it was placed in storage awaiting redeployment.
All relevant data is held on Triages Services “MAX” system database.
The base unit with serial number YBSH011567 was finally redeployed to West Byfleet Office,
Branch Code 126023 on the 4th February 2008 and since its installation the Branch Manager
at this address has logged 29 Service Calls with the Fujitsu Services Horizon Help Desk. Once
redeployment has taken place all previous location history is overwritten on the Fujitsu
Signature i GRO i Signature witnessed by 4 GRO i
J Version 6.0 09/06
©S011A (Side Ap---~~
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POL00058443
POL00058443
Witness Statement
(CJ Act 1967, s9; MC Act 1980, ss 5A(3)(a) and 5B, MC Rules 1981, r 70)
Continuation of statement of Jan Venables
systems.
At the time of writing this statement the Gateway PC, serial number YBSH01 1567 is still on site
at the West Byfleet Branch 237405 and in the absence of service calls relative to this unit the
author believes it to be functioning correctly.
Any records to which I refer in my statement form part of the records relating to the business of
Fujitsu Services. These were compiled during the ordinary course of business from
information supplied by persons who have, or may reasonably be supposed to have, personal
knowledge of the matter dealt with in the information supplied, but are unlikely to have any
recollection of the information or cannot be traced. As part of my duties, I have access to
these records.
Signature!
Version 6.0 09/06
esata
POL00058443
POL00058443
GUILDFORD ;OURT
THE QUEEN
v
SEEMA MISRA
NOTICE OF ADDITIONAL EVIDENCE
General Counsel to Royal Mail Group Limited
Legal Services
6a Eccleston Street
Victoria
LONDON
SW1W 9LT
zAcriminal work folders\singh jarnail - crm\258932 - misra\nae - 2.doc