POL00058502
POL00058502
Jarnail A Singh To: Post Office Security
Sent by: Marilyn cc: »labo.Lonaman/elROSTOFFICE, Warwick Tatford
Benjamin GRO
Subject:
01/03/2010 14:30 GUILDFORD CROWN COURT
TRIAL - 15TH MARCH 2010
I now enclose a copy of the 4th and 5th Defence Expert Reports. I also enclose Gareth Jenkins latest
E-Mail dated 1st March 2010 for your information. The content does not appear to be very helpful.
4th interim technical expert's report to the Court 2010-02-12 v0 1.doc
Sth interim technical expert's report to the Court 2010-02-25 v0.1 [2).doc
Jarnail A Singh
Senior Lawyer
Criminal Law Team
Tel.No! ¢
Fax.No____
To:<jarnail.a.singh,
Subject:RE: REGINA VSEEMA MISRA GUILDFORD CROWN COURT TRIAL- 15TH MARC
01/03/2010 10:35
Jarnail,
Thanks for the information, which I've now read through.
I think I can summarise the situation as follows:
1. Ms Misera says initially identified that the sub post office was
short of cash by about £80 - £90K
2. She tried to cover this up while she repaid the loses which she
thought was due to staff theft
3. By the time of the audit in Jan 2008 she was £73K short suggesting
she had made good about £10K of the losses
4. When she went to court, she saw an article in Computer Weekly
indicating that Horizon was unreliable and decided to jump on the
bandwagon.
5. Note that there is no evidence to support any of the cases
referenced in the Computer Weekly articles and there is case law showing
the reliability of Horizon. (The case of Marine Drive which I think was
referred to in the Computer Weekly article.)
However I don't see how anything here changes the fact that she falsified
the accounts or that money was missing.
POL00058502
POL00058502
What I still don't understand is exactly what it is that the defence is
claiming in terms of where exactly Horizon might have "lost" this money
rather than her or her staff stealing it. Therefore unless we can get a
clear statement as to exactly what is being looked for and when the system
allegedly made mistakes, I don't think there is anything I can do. (I do
appreciate that it is up to the Prosecution to prove Horizon is reliable
rather than the defence to prove it isn't, but it is always difficult to
prove that there are no errors - particularly over such a long period of
time.)
Surely it is down to the Post Office investigators to get to the bottom of
exactly where there is anything in dispute. At that point I might be able
to assist with some technical knowledge to help interpret the various logs
to support such areas of dispute.
I'll leave Penny to continue the discussions she is currently having with
the Post Office investigators until there is something concrete for me to
investigate.
Regards
Gareth
Gareth Jenkins
Distinguished Engineer
Applications Architect
Royal Mail Group Account
FUJITSU
Lovelace Road, Bracknell, Berkshire, RG12 8SN
Tel: I GRO.
(Note new external number -
old number will not work after 31/12/2009)
Mobile: Internal:
email: Gareth. Jenking }
Web: http://uk.fujitsu.com
P Please consider the environment - do you really need to print this email?
Fujitsu Services Limited, Registered in England no 96056, Registered Office
22 Baker Street, London, W1U 3BW
This e-mail is only for the use of its intended recipient. Its contents
are subject to a duty of confidence and may be privileged. Fujitsu
Services does not guarantee that this e-mail has not been intercepted and
amended or that it is virus-free.
nooo Original Message----- _
From: marilyn. benjamii GRO
] On Behalf Of jarnail.a.singl.
Sent: 26 February 2010 16:38
To: Jenkins Gareth GI
Cc: Thomas
Penny
POL00058502
POL00058502
Subject: REGINA v SEEMA MISRA GUILDFORD CROWN COURT TRIAL - 15TH MARCH 2010
Thank you for your E-Mail of today. As per discussions I now enclose:-
1 copy
2 Copy
3 Copy
4 Copy
5 Copy
Case Summary.
Indictment
Defence Statement
of the interview
Defence Expert's name is Charles Alistair McLachlan, Staple
Hall, 87-90 Houndsditch, London, EC3A 7AD. Telephone number and mobile to
follow.
It is important that we are pro active on this and that you contact him as
soon as possible with a view to concluding this.
I appreciate all the help and assistance in this case.
I hope the
discuss in
above assists but if you require anything further or wish to
more detail please telephone me.
(See attached file: 258932AI.doc) (See attached file: 258932 IND.doc) (See
attached file: Defence Statement Scanned.pdf) (See attached file: Interview
- Scanned document .paf)
Jarnail A Singh
Senior Lawyer
Criminal Law Team
Tel.No:
Fax.No:}
FOI IOI OEIIEI ISIC IEICIEIGI CITC IIIS IOI III III i aE Ie
Royal Mail
Group Limited registered in England and Wales registered number
4138203 registered office 3rd Floor, 100 Victoria Embankment, London, EC4Y
OHO
This email and any attachments are confidential and intended for the
addressee only. If you are not the named recipient, you must not use,
POL00058502
POL00058502
disclose, reproduce, copy or distribute the contents of this communication.
If you have received this in error, please contact the sender and then
delete this email from your system.
FOI III IIIS III IOI IGS CSIG II IOC ICICI CII III IOI I seat
POL00058502
POL00058502
Jenkins Gareth
cc: "Thomas Penny"
‘Thomas Penny"
Subject: REGINA v SEEMA
01/03/2010 14:39 GUILDFORD CROWN COURT
TRIAL - 15TH MARCH 2010[5]
Jarnail A Singh
Sent by: Marilyn
Benjamin
Gareth,
Thank you for your E-Mail of 1st March 2010.
I now enclose Defence Expert's 4th and 5th reports after his conversation with you of the 12th
February 2010. As izon Expert you need to telephone Charles McLachlan, his mobile
telephone number i: ito arrange a meeting where you can discuss all his reports and
his concerns about the Horizon so you can deal with it and rebut it which you have done in your long
telephone conversation about his various hypothesis and then write a detailed report which would go
to someway of progressing and concluding this matter and importantly preserving the Horizon system.
May be the simplest and practical way of dealing with this whole question is to find a shortest span of
logs, analyse it, disprove or rebut what the Defence Expert is saying in his reports.
Just a reminder you are an Expert for Fujitsu, you will be giving evidence in Court, the Judge and Jury
will be listening to you very carefully and a lot will hang on the evidence.
The way forward is for you to arrange an immediate meeting with the Defence Expert and conclude
this matter once and for all.
Kind regards.
5th interim technical expert's report to the Court 2010-02-25 v0 1 (2).doc
Jarnail A Singh
Senior Lawyer
Criminal Law Team
Tel.No: 020 7881 4330
Fax.No: 020 7881 4:
"Jenkins Gareth Git_
Thomas Penny"
Subject: RE: REGINA v SEEMA MiSRA GUILDFORD CROWN COURT
TRIAL - 15TH MARCH 2010
Jarnail,
Thanks for the information, which I've now read through.
POL00058502
POL00058502
I think I can summarise the situation as follows:
1. Ms Misera says initially identified that the sub post office was
short of cash by about £80 - £90K
2. She tried to cover this up while she repaid the loses which she
thought was due to staff theft
3. By the time of the audit in Jan 2008 she was £73K short suggesting
she had made good about £10K of the losses
4. When she went to court, she saw an article in Computer Weekly
indicating that Horizon was unreliable and decided to jump on the
bandwagon.
5. Note that there is no evidence to support any of the cases
referenced in the Computer Weekly articles and there is case law showing
the reliability of Horizon. (The case of Marine Drive which I think was
referred to in the Computer Weekly article.)
However I don't see how anything here changes the fact that she falsified
the accounts or that money was missing.
What I still don't understand is exactly what it is that the defence is
claiming in terms of where exactly Horizonmight have "lost" this money
rather than her or her staff stealing it. Therefore unless we can get a
clear statement as to exactly what is being looked for and when the system
allegedly made mistakes, I don't think there is anything I can do. (I do
appreciate that it is up to the Prosecution to prove Horizon is reliable
vather than the defence to prove it isn't, but it is always difficult to
prove that there are no errors - particularly over such a long period of
time.)
Surely it is down to the Post Office investigators to get to the bottom of
exactly where there is anything in dispute. At that point I might be able
to assist with some technical knowledge to help interpret the various logs
to support such areas of dispute.
I'll leave Penny to continue the discussions she is currently having with
the Post Office investigators until there is something concrete for me to
investigate.
Regards
Gareth
Gareth Jenkins
Distinguished Engineer
Applications Architect
Royal Mail Group Account
FUJITSU
Lovelace Road, Bracknell, Berkshire, RG12 8SN
POL00058502
POL00058502
Tel: I GRO } Internal:
(Note new external number -
old number will not work after 31/12/2009)
Mobile: Internal:
email:
Web:
P Please consider the environment - do you really need to print this email?
Fujitsu Services Limited, Registered in England no 96056, Registered Office
22 Baker Street, London, W1U 3BW
This e-mail is only for the use of its intended recipient. Its contents
are subject to a duty of confidence and may be privileged. Fujitsu
Services does not guarantee that this e-mail has not been intercepted and
amended or that it is virus-free.
----- Original Message-
From: marilyn.benjamin{
] On Behalf Of jarnail a. singit
Sent: 26 February 2010 16:38
To: Jenkins Gareth GI
Cc: Thomas Penny
Subject: REGINA v SEEMA MISRA GUILDFORD CROWN COURT TRIAL - 15TH MARCH 2010
Thank you for your E-Mail of today. As per discussions I now enclose:-
1 Copy Case Summary.
2 Copy Indictment
3 Copy Defence Statement
4 Copy of the interview
5 Copy Defence Expert's name is Charles Alistair McLachlan, Staple
Hall, 87-90 Houndsditch, London, EC3A 7AD. Telephone number and mobile to
follow.
It is important that we are pro active on this and that you contact him as
soon as possible with a view to concluding this.
I appreciate all the help and assistance in this case.
I hope the above assists but if you require anything further or wish to
discuss in more detail please telephone me.
(See attached file: 258932AI.doc) (See attached file: 258932 IND.doc) (See
attached file: Defence Statement Scanned.pdf) (See attached file: Interview
- Scanned document .pd£)
Jarnail A Singh
Senior Lawyer
Criminal Law Team
JOS ISIS ISIS ISS IS IOS EIS IOS IS SI IGSIIO GIG ISO IE ISI IOS ISI III I Igor
Royal Mail Group Limited registered in England and Wales registered number
4138203 registered office 3rd Floor, 100 Victoria Embankment, London, EC4Y
OHQ
This email and any attachments are confidential and intended for the
addressee only. If you are not the named recipient, you must not use,
POL00058502
POL00058502
disclose, reproduce, copy or distribute the contents of this communication.
If you have received this in error, please contact the sender and then
delete this email from your system.
FEISS IS ISIS CICISIIIOSICISI SISSIES IIIS IOI I III ISI III I I IIE Fe ie vee
POL00058502
POL00058502
sMenkins.Gareth.GI."...... To: <jamail.a.singt,
i G RO ' cc: "Thomas Penny.
' I Subject: RE: REGINA v SEEMA MISRA GUILDFORD CROWN COURT
! TRIAL - 15TH MARCH 2010
Jarnail,
Thanks for the information, which I've now read through.
I think I can summarise the situation as follows:
1. Ms Misera says initially identified that the sub post office was
short of cash by about £80 - £90K
2. She tried to cover this up while she repaid the loses which she
thought was due to staff theft
3. By the time of the audit in Jan 2008 she was £73K short suggesting
she had made good about £10K of the losses
4. When she went to court, she saw an article in Computer Weekly
in@icating that Horizon was unreliable and decided to jump on the
bandwagon.
5. Note that there is no evidence to support any of the cases
referenced in the Computer Weekly articles and there is case law showing
the reliability of Horizon. (The case of Marine Drive which I think was
referred to in the Computer Weekly article.)
However I don't see how anything here changes the fact that she falsified
the accounts or that money was missing.
What I still don't understand is exactly what it is that the defence is
claiming in terms of where exactly Horizonmight have "lost" this money
rather than her or her staff stealing it. Therefore unless we can get a
clear statement as to exactly what is being looked for and when the system
allegedly made mistakes, I don't thinkthere is anything I can do. (I do
appreciate that it is up to the Prosecution to prove Horizon is reliable
rather than the defence to prove it isn't, but it is always difficult to
prove that there are no errors - particularly over such a long period of
time.)
Surely it is down to the Post Office investigators to get to the bottom of
exactly where there is anything in dispute. At that point I might be able
to assist with some technical knowledge to help interpret the various logs
to support such areas of dispute.
I'll leave Penny to continue the discussions she is currently having with
the Post Office investigators until there is something concrete for me to
investigate.
Regards
Gareth
Gareth Jenkins
POL00058502
POL00058502
Distinguished Engineer
Applications Architect
Royal Mail Group Account
FUJITSU
Lovelace Road, Bracknell, Berkshire, RG12 8SN
Tel: r Internal:
(Note new external number -
old number will not work after 31/12/2009)
Mobile: { : GRO I
email:
Web:
P Please consider the environment - do you really need to print this email?
Fujitsu Services Limited, Registered in England no 96056, Registered Office
22 Baker Street, London, W1U 3BW
This e-mail is only for the use of its intended recipient. Its contents
are subject to a duty of confidence and may be privileged. Fujitsu
Services does not guarantee that this e-mail has not been intercepted and
amended or that it is virus-free.
taal Original Message-
From: marilyn.benjamir,_
] On Behalf Of jarnail’a.singi! GRO }
Sent: 26 February 2010 16:38 ~ -
To: Jenkins Gareth GI
Cc: Thomas Penny
Subject: REGINA v SEEMA MISRA GUILDFORD CROWN COURT TRIAL - 15TH MARCH 2010
Thank you for your E-Mail of today. As per discussions I now enclose:-
1 Copy Case Summary.
2 Copy Indictment
3 Copy Defence Statement
4 Copy of the interview
5 Copy Defence Expert's name is Charles Alistair McLachlan, Staple
Hall, 87-90 Houndsditch, London, EC3A 7AD. Telephone number and mobile to
follow.
It is important that we are pro active on this and that you contact him as
soon as possible with a view to concluding this.
I appreciate all the help and assistance in this case.
I hope the above assists but if you require anything further or wish to
POL00058502
POL00058502
discuss in more detail please telephone me.
(See attached file: 258932AI.doc) (See attached file: 258932 IND.doc) (See
attached file: Defence Statement Scanned.pdf) (See attached file: Interview
- Scanned document .pdf)
Jarnail A Singh
Senior Lawyer
Criminal Law Team
JOBS E EI ES IIS IIS SEE IESE SSSI ISS I ISO E II ISI IOS IISA IIe
Royal Mail Group Limited registered in England and Wales registered number
4138203 registered office 3rd Floor, 100 Victoria Embankment, London, EC4Y
oHQ
This email and any attachments are confidential and intended for the
addressee only. If you are not the named recipient, you must not use,
disclose, reproduce, copy or distribute the contents of this communication.
If you have received this in error, please contact the sender and then
delete this email from your system.
FESS SIIGIS IIS ICICI ISIS SII IIIS III III III I i i
POL00058502
POL00058502
To: <john.longmar,
cc: <mark.dinsdale..
larnaiLa.sinab...
01/03/2010 09:50 Subject: RE: West Byfleet - 126023
Jon/Mark
We are clearly not going to be able to provide the response requested by
POL Legal at this late stage and within the requested timeframe.
In POL Legal's urgent note of 8 February (attached) relevant timeframes
were identified - we will commence retrieving those transaction records
which fall within the current formal request. If there is a preferred
order for the remainder of the formal request please revert and we will
conform.
Please note that all other prosecution support activity will cease until
this request has been filled.
Also, you should note that I am warned for Court tomorrow, Tuesday 2
March, in Bolton for the case relating to Fishpool, one of Helen
Dickison's cases.
Kind regards
Penny
Penny Thomas
Security Analyst, Customer Services
Fujitsu Services Retail & Royal Mail Group Account
Lovelace Road, Bracknell, Berks RG12 8SN
penny . thomag.
http: //uk.£uj
tsu Services Limited, Registered in England no 96056, Registered
Office 22, Baker Street, London W1U 3BW
This E-mail is only for the use of its intended recipient. Its contents
are subject to a duty of confidence and may be privileged. Fujitsu
Services does not guarantee that this E-mail has not been intercepted
and amended or that it is virus-free.
oreo Original Message-
From: john.longmar.
[mailto:john. longmar.
Sent: 01 March 2010 08:53
To: Thomas Penny
Cc: mark.dinsdalé”
Subject: RE: West Byfleet - 126023
jarnail.a.singht
Hi Penny
The legal advice is that logs should be analysed for the whole of the
false
accounting period. I have been informed that this is from December 06
to
December 07.
(Embedded image moved to file: pic27027.jpg)
Mark/Jon
Of course, I'll help all I can.
Are you sure you need 12 months, Jon? It's not just the retrieving,
itt
the analysis that will take the time (by Gareth) and frankly, I don't
think
we will be able to achieve this in the time left.
Penny
Penny Thomas
Security Analyst, Customer Services
Fujitsu Services Retail & Royal Mail Group Account
Lovelace Road, Bracknell, Berks RG12 8SN
penny .thomag”
http://uk.fujitsu.com
Fujitsu Services Limited, Registered in England no 96056, Registered
Office
22, Baker Street, London W1U 3BW
This E-mail is only for the use of its intended recipient. Its contents
are subject to a duty of confidence and may be privileged. Fujitsu
Services
does not guarantee that this E-mail has not been intercepted and amended
or
that it is virus-free.
POL00058502
POL00058502
rom.s...mazk..dinedals..
To: Thomas Penny
Ce: maureen.moors,_
Subject: Fw: West
Importance: High
Penny, we need a massive favour that I'm sure will cost us quite a few
cream cakes.
Is there anything you can do to pull out the stops to provide what Jon
is
looking for within the timescales. Maureen will provide the necessary
paper work on Monday.
Thank you for considering this.
-->
Mark Dinsdale
Security Programme Manager
Security Team, Post Office Ltd
-- >>
I (Embedded image moved to file: pic00952.gif)Post Office Ltd, Security
Team, Royal I
Mail, 3rd Floor, Clippers House, Clippers Quay, Salford, M50 3NW
- - =>
I (Embedded image moved to file: pic08496.gif)0780 109 2486 Mobex: 5364
POL00058502
POL00058502
3436
(preferred contact method)
(Embedded image moved to file: pic05646.gif)0161 869 7205 Postline:
5831 7205
I (Embedded image moved to file
picl15183.gif)mark.dinsdald
(Embedded image moved to filé
picisss7 git)
(Embedded image moved to file: picl1554.gif)Post Office HR Help
- -->
- waren
Confidential Information:
This email message is for the sole use of the intended recipient(s) and
may
Jcontain confidential and privileged information. Any unauthorised
review, use,
[disclosure or distribution is prohibited. If you are not the intended
recipient I
Iplease contact me by reply email and destroy all copies of the original
message.
John Longman
To: Mark
Dinsdale/e/POSTOFFICE@POSTOFFICE
POL00058502
POL00058502
26/02/2010 16:38 ce: Jarnail A
Singh/e /POSTOFFICE
Subject: West Byfleet - 126023
Mark
Jarnail has just telephoned me and asked me to get transaction log data
for
the above PO from ist December 2006 to 31st December 2007. The logs
need
to be ordered through our current process and then given to Gareth
Jenkins
at Fujitsu to analyse and confirm by witness statement whether there
are
any errors within the Horizon system for the transaction log period.
Jarnail would like the statement by Friday 5th March 2010.
(Embedded image moved to file: picl8102.gif)
JERE SSSI SISSIES III IIIT III III IIIS EESTI III IIIT ISITE
Royal Mail Group Limited registered in England and Wales registered
number
4138203 registered office 3rd Floor, 100 Victoria Embankment, London,
ECc4y
oHQ
This email and any attachments are confidential and intended for the
addressee only. If you are not the named recipient, you must not use,
disclose, reproduce, copy or distribute the contents of this
communication.
If you have received this in error, please contact the sender and then
delete this email from your system.
JOSS SISSIES IOIIEISISI SI ISIS ISCAS IOI IOI III GIS I IO
----- Message from "Jones David M” r
-0000 -----
To:;
on Mon, 8 Feb 2010 12:00:03
Subject .
POL00058502
POL00058502
_ FW: REGINA v SEEMA MISRA GUILDFORD CROWN COURT TRIAL - 15TH MARCH 201
FYI
David
David M Jones, Head of Legal
UK Private Sector Division
POL00058502
POL00058502
oeeee Original Message-----
From: Thomas Penny
Sent: 08 February 2010 11:20
To: Jones David M; Jenkins Gareth GI
Subject: FW: REGINA v SEEMA MISRA GUILDFORD CROWN COURT TRIAL - 15TH
MARCH 2010
David
We could have transaction data available by the end of this week/early
next week for the suggested timeframes; we need an ARQ request from Jane
Owens to proceed.
Penny
oo Original Message-
From: marilyn.benjamin GRO
[mailto :marilyn, benjat
jarnail.a.singt
Sent: 08 Februa:
To: Jones David M
Cc: Jenkins Gareth GI; Thomas Penny
Subject: REGINA v SEEMA MISRA GUILDFORD CROWN COURT TRIAL - 15TH MARCH
2010
On Behalf Of
URGENT
David,
Thank you. I would be grateful if Mr Jenkins is asked the following:-
1 In relation to the Eleanor Nixon statement, the information we
received that although Maureen Lyme states she cannot remember specific
Offices she has stated that pre August 2005 Offices were using a
separate
system for debit / credit card transactions called Streamline. Offices
would put debit / credit cards through this system and produce a
receipt,
which could be keyed into the Horizon terminals.
Some Postmaster / Clerks would key in the information into Horizon as
cash,
instead of debit / credit cards resulting in a shortage in Offices. If
Post Offices contacted Chesterfield at the time any Branch discrepancies
were dealt with, and sorted out with the individual Post Offices.
Therefore the problems were results of incorrect account produce and not
a
problem with the Horizon system. No information is available for any
Correction Notices pre August 2005. So the Nixon statement is unlikely
to
have any relevance for our present case of Misra.
2 The areas where Mr Jenkins says for POL to respond should be
deleted
from his statement.
Mr Jenkins needs to comment on the third interim report received from
the
Defence Expert.
The quality of training of SPMs is obviously outside Mr Jenkins
POL00058502
POL00058502
expertise.
However I wonder if he might be prepared to comment on how it might be
possible to examine the Horizon data to investigate mistakes.
We are keen that the Defence are given suggestions as to how they can
efficiently test their theories against the Horizon data. We do not
want
them to say that they will not have time before the Trial. we
anticipate
that it would not be very difficult to test their theories against a
short
but represented span of data example from the months when Mrs Misra has
admitted to false accounting. (15th November 2006 to 14th December
2006,
16th May 2007 to 16th June 2007, 14th November 2007 to 15th December
2007
and 9th January 2008. It would be helpful if Mr Jenkins could consider
practical and efficient ways in which the Defence might be able to test
their theories.
I also refer you to my E-Mail to you of Friday Sth February 2010 at
15.39
paragraphs 2, 3 and 4.
Thank you in anticipation of your help.
Kind regards.
Jarnail A Singh
Senior Lawyer
Criminal Law Team
Tel .No
Fax.No
FEES UI ISITE SISOS IIIS ISSO UIO IIS SIIIS ISIC IIIS III O It
Royal Mail Group Limited registered in England and Wales registered
number
4138203 registered office 3rd Floor, 100 Victoria Embankment, London,
EC4y
OHQ
This email and any attachments are confidential and intended for the
addressee only. If you are not the named recipient, you must not use,
disclose, reproduce, copy or distribute the contents of this
communication.
If you have received this in error, please contact the sender and then
delete this email from your system.
FEI ISS ISI II IEEIEIG I IOEIO GIG II IISIEICIEIISII IIE III it
POL00058502
POL00058502
John Longman To: “Thomas Penny"
cc: Mark Dinsdale/e! i
01/03/2010 08:52 Singh/e/POSTOFFICE GR
Subject: RE: West Byfleet - 126023[9
Hi Penny
The legal advice is that logs should be analysed for the whole of the false accounting period. I have
been informed that this is from December 06 to December 07.
Regards,
Jon Longman
Security Advisor,
Post Office Ltd, National Sequrity Tearn
OFFICE ADDRESS. Post Office Investigation Dept, Watford MLO, Ascot Road, Watford, WD18 BAA
LAND LINE PHONE: Spread the word.,
" (Pero!
MOBILE N fl Ay ri
Est
Confidential information: This e-mail message is for the sole use of the intended recipient (5) and may contain
confidentialand privileged information. Any unauthorised review, use, disclosure or distribution is prohibited,
If you are not the intended recipient, plea se contact me by reply e-mailand destroy all copies of the original message.
ee wl
Mark/Jon
Of course, I'll help all I can.
Are you sure you need 12 months, Jon? It's not just the retrieving, it’s the analysis that will take the
time (by Gareth) and frankly, I don’t think we will be able to achieve this in the time left.
Penny
Penny Thomas
Security Analyst, Customer Services
Fujitsu Services Retail & Royal Mail Group Account
Lovelace Road, Bracknell, Berks RG12 8SN
E-Mail: ‘penny.
Web: http://uk fujitsucorr
POL00058502
POL00058502
Fujitsu Services Limited, Registered in England no 96056, Registered Office 22, Baker Street, London W1U 3BW.
This E-mail is only for the use of its intended recipient. Its contents are subject to a duty of confidence and may be
privileged. Fujitsu Services does not guarantee that this E-mail has not been intercepted and amended or that it is
virus-free.
From: mark.dinsdal
Sent: 26 February 2010 f
To: Thomas Penny _
Ce: maureen.moors
Subject: Fw: West Byfleet - 126023
Importance: High
Penny, we need a massive favour that I'm sure will cost us quite a few cream cakes.
Is there anything you can do to pull out the stops to provide what Jon is looking for within the
timescales. Maureen will provide the necessary paper work on Monday.
Thank you for considering this.
Mark Dinsdale ee a
Security Programme Manager
Security Team, Post Office Ltd
* Post Office Ltd, Security Team, Royal Mail, 3rd Floor, Clippers House, Clippers Quay, Salford, M50 3NW
@%rane
Confidential Information:
This email message is for the sole use of the intended recipient(s) and may contain confidential and privileged information. Ar
recipient please contact me by reply email and destroy all copies of the original message.
~---- Forwarded by Mark Dinsdale/e/POSTOFFICE on 26/02/2010 16:48 -----
John Longman
To: Mark Dinsdale/e/POSTOFFIC
ce: Jarnail A Singh/e/POSTOFFICI,
26/02/2010 16:38 Subject! West Byfleet - 126023
Mark
Jarnail has just telephoned me and asked me to get transaction log data for the above PO from 1st
December 2006 to 31st December 2007. The logs need to be ordered through our current process
and then given to Gareth Jenkins at Fujitsu to analyse and confirm by witness statement whether
there are any errors within the Horizon system for the transaction log period. Jarnail would like the
statement by Friday 5th March 2010.
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Regards,
Jon Longman
Security Advisor,
Post Office Ltd, National Seaurity Team
~ OFFICE ADDRESS: Post Office Investigation Dept, Watford MLO, Ascot Road, Watford WO18 BAA
Spread the word...
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To: “jarnail.a.singh.
ce: Keith Hadrill
"khadil GI
"warwicktatfor( _ <warwicktatfort
01/03/2010 09:32 Subject: RE: REGINA v SEEMA MISRA GUILDFORD
TRIAL - 15TH MARCH 2010
Dear Jarnail,
Further to previous correspondence, I now attach my skeleton argument in
relation to our application for count 1 to be stayed for abuse, together
with our expert's 4th and 5th interim reports. As a result of these reports
and your email of 24th February I also attach my 4th request for
disclosure.
Regards
Issy
Issy Hogg
Coomber Rich Solicitors
Yard House, Basingstoke, RG21 7NX
SRA 308901
Tel.
Mobile
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oo Original Message-
From: jarnail.a.sing
Sent: 24 February 2010 14757
To: Issy Hogg
Subject: REGINA v SEEMA MISRA GUILDFORD CROWN COURT TRIAL - 15TH MARCH 2010
Dear Ms Hogg,
I have heard from Gareth Jenkins who informed me that he had a 90 minute
lengthy discussion with your Expert Charles McLachlan as long ago as Friday
12th February 2010.
In the meantime I now enclose the replies to the third disclosure request.
However if any of the items you have requested have not been dealt with if
you can give a reason wanting that item then of course the prosecution will
consider those. As always I am continuously and constantly keeping the
disclosure under review.
THIRD DISCLOSURE REQUEST
1 That was the contract in the form it was served.
2 We are well aware of our statutory duty of disclosure as you know the
prosecution have reviewed a large volume of material. The only material
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disclosable is Callender Place as we know Mr Jenkins is making full
investigations so the full position can be ascertained.
TRAINING
1 The training material is at West Byfleet Post Office. Presumably you
want simply an opportunity to inspect or view it on site.
2 We do not understand the relevance to dates to which your Client
received the documents. The real issue is did she steal the money or make
mistakes. This is an issue for the experts when they look at the Horizon
data.
3 See above.
4 —
5 The prosecution is under no obligation to provide witness statements.
You have full details of the witness and can contact him if you wish.
6(a) This statement is in the most useful format. The purpose of this
statement was to provide material in digestive form. Logs are impossible
to follow unless undertaken by an expert. We do not see the relevant calls
made prior to your Client's taking Office. We have provided the
information in the most useful form in the light of the data.
(b) The analysis data confirms that.
7(a) You have been provided with all available training material.
(b) What are the real issues in the case.
(c) Are we looking at the quality of the training but Mrs Misra made
mistakes which will be investigated by two experts. In fact the real issue
in this case, did she steal the money or deliberately attribute it to
mistakes by her and the training background is information only.
8 We believe we have complied with our disclosure obligation. Whether
any mistakes were made. Experts can examine them themselves.
9 We stand by our position. Our response is that there has been a
misunderstanding, there is no reason to put this in a statement form. If
it carries to trial it carries with it a risk that your expert and your
Miss Hogg will become witnesses in the case which is highly undesirable.
We suggest you re-consider.
10 We have already answered this request. There are no back up teams no
more than the Police Force investigating crime. Investigators consider all
reasonable explanations. Your Client did not give an explanation other than
other people were responsible. If your Client had made mistakes that will
be ascertained by two experts in their enquiries.
11 Costs is a consequence of Royal Mail contractual relationship with
Fujitsu. Our duty of disclosure is whether material which undermines the
prosecution case and supports your Client's defence. We hope if the
experts look at a short span of information ie the period where your Client
falsified her records as set out in our previous letter. We hope it will
not be necessary to examine records for 5 years. Your Client was inflating
figures over a long period. If this were as a result of mistakes over an
extended period we think analysis over shorter period of falsifying
accounting offences by your Client did not appear to remedy large loss.
There appears to be a long standing pattern of discrepancies which would
appear in a short period as it would be on the long extended period. If
mistakes are found in a short span of data the Crown will obviously review
its position as to acceptability of your Client's plea.
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(b) Our disclosure obligation do not require us to justify why data for a
5 year period is so expensive.
12 We anticipate the areas are for the experts to discuss.
13 The audit was not completed.
14, 15 We have disclosed all information in our possession. We are
not required to serve witness statements. It is clear that Steamline has
no relevance.
16 We are not prepared to make any promise in relation to criminal or
civil action. The issue is whether problems referred to was happening at
Byfleet is something for the experts to examine.
17 ‘The equipment is being updated. The original equipment is preserved
after updating has occurred.
18 Prosecution Counsel has reviewed the case of Hosi. There is no
material that requires disclosure.
19 Please refer to our answer to paragraph 8. Prosecution Counsel has
reviewed all material. We are still investigating Callender Place. We
recognise our duty of disclosure is a continuing one.
20 We repeat our answer in respect of Callender Place.
Yours sincerely,
Jarnail A Singh
Senior Lawyer
Criminal Law Team
JESSE ISIS SSI SISSIES SISO GIS G OGIO SI ISG IO GIST SSIS ISO I Ii
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Sth interim technical expert's report to the Court 2010-0225 v0 1 (2). doc Skeleton argument (ICH version).doc
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Amsphere Confidential and Privileged
On instruction of Coomber Rich Solicitors
Yard House, Basingstoke, RG21 7NX
Re: Seema Misra
4" 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 10 pages
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Amsphere Confidential and Privileged
On instruction of Coomber Rich Solicitors
Yard House, Basingstoke, RG21 7NX
Contents
4 REVIEW OF EVIDENCE AVAILABLE AS OF 12™ FEBRUARY 2010..1
2 APPENDIX 1 — INSTRUCTIONS ETC.....ccssssssssscsssesseseessseseeneseessnenreneenees 5
3 APPENDIX 2 - MY DUTIES TO THE COURT........:::eecseecseseseseteteseseneneee 7
Charles McLachlan 1
Amsphere Confidential and Privileged
On instruction of Coomber Rich Solicitors
Yard House, Basingstoke, RG21 7NX
1 Review of evidence available as of 12" February 2010
Introduction
This report has been updated to reflect the witness statements provided by Gareth
Jenkins and the telephone interview conducted with him on 12" February 2010.
Gareth Jenkins was asked to comment on the West Byfleet and the requests in
relation to Callender Place, Falkirk for the first time in the week commencing 1*
February 2010.
1.1 Hypothesis: The User Interface gives rise to incorrect data entry
1.1.1 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.
Additionally: Gareth Jenkins during a telephone interview conducted on 12"
February confirmed his response in the witness statement dated. 2" February
relating to my 2" interim report at 2.1.3.10 “It is the responsibility of the
clerk to ensure that the Debit Card payment was successfully authorised by
the MA and to check the response received. Should they not do so and
assume it was processed and touch “Fast Cash” to clear the basket without
looking at the screen, then indeed the system might record a Cash
Transaction. (bold added).
1.1.2 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.
Additionally: Gareth Jenkins during a telephone interview conducted on 12
February confirmed that if the touch screen requires calibration it is possible
that the user could touch the screen to activate one button and a different
button would be activated. Gareth Jenkins asserted that the size of the buttons
makes such an event unlikely.
1.2 Hypothesis: The Horizon system fails to properly process transactions
Charles McLachlan 1
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Amsphere Confidential and Privileged
1.2.1
1.2.2
On instruction of Coomber Rich Solicitors
Yard House, Basingstoke, RG21 7NX
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.
Additionally: Gareth Jenkins, during a telephone interview conducted on 12"
February confirmed: that copies for the sub post office data records are
maintained by means of an message audit log for 7 years in the Fujitsu data
archive; that no request has been received by Fujitsu for any of the records
relating to West Byfleet; that such requests are routine and a Fujitsu employee
is engaged full-time in servicing such requests; that Fujitsu have an established
process for delivering the messages in the audit log into a readily interpretable
form accessible in an Excel spreadsheet. Further, Gareth Jenkins explained
that Fujitsu use an ORACLE database to load the messages and output both
consolidated branch data at the stock item level and raw data at the transaction
level that is sent to the Post Office Limited SAP accounting system and MIS
systems respectively. He explained that one of the functions of the SAP
system is to identify transaction errors. Gareth Jenkins advised that the Post
Office Product Branch Accounting department would be best placed to
comment on transaction corrections and ‘rems’ (remittances of stock to or from
branches).
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.
Additionally: Gareth Jenkins confirmed, in a telephone interview conducted
on 12" February, that if the printer failed to produce a readable document
because of ink or cylinder problems, then branch terminal would consider the
document to have been printed and if the operator acknowledged the printing
without examining the receipt then it was possible that the receipt could be a
“decline” or “refer” document for a card transaction which the operator then
over looked. Consistent use of the [Fast Cash] button to clear the stack would
Charles McLachlan 2
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Amsphere Confidential and Privileged
1.2.3
1.3
On instruction of Coomber Rich Solicitors
Yard House, Basingstoke, RG21 7NX
then result in the declined card transaction being treated as a cash receipt. It
is noted that such problems were reported in Andy Dunks 2" statement.
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.
Additionally: Gareth Jenkins asserted, in a telephone interview conducted on
12 February, that the treatment of messages would always ensure that there
was a matching set of credit and debit transactions maintained both at the
branch and centrally. However, he pointed out that the replication between the
branch and the centre relied on a 35 day retry cycle and, in the event of a flood
or other prolonged break down in branch access, inconsistencies between the
branch records and the central records could arise and would then have to be
resolved manually. Further, he explained that the audit log archive maintained
by Fujitsu would record when a terminal ‘re-boot’ occurred and it would be
possible to determine if this had given rise to any pattern of transaction
discrepancies.
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.
Additionally: Gareth Jenkins, in a telephone interview conducted on 12”
February, explained that these reconciliation processes are conducted by the
Post Office Product Branch Accounting function and the system data files
would have to be provided by this function. Fujitsu are not aware of any
request to provide this information.
1.3.2. 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 3
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Amsphere Confidential and Privileged
On instruction of Coomber Rich Solicitors
Yard House, Basingstoke, RG21 7NX
Additionally: Gareth Jenkins, in a telephone interview conducted on 12
February, explained that these reconciliation processes are conducted by the
Post Office Product Branch Accounting function and the system data files
would have to be provided by this function. Fujitsu are not aware of any
request to provide this information.
Charles McLachlan 4
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 I am Charles Alastair McLachlan, a Director of Amsphere Consulting
Limited, London, England specialising in information technology consulting.
T 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 I have been instructed to review the disclosures provided in electronic format
rh
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 5
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Amsphere Confidential and Privileged
On instruction of Coomber 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
2.7.1 I have 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.
2.7.2. Amsphere’s fees in this case are not dependent on the result of the
proceedings in this matter.
Charles McLachlan 6
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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
3.2
3.3
3.4
3.5
3.6
3.7
3.8
J 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.
T 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.
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.
I have drawn to the attention of the Court to all matters, of which I am aware,
which might adversely affect my opinion.
Wherever I have no personal knowledge, I have indicated the source of factual
information.
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.
Where in my view, there is a range of reasonable opinion, I have indicated the
extent of that range in the report.
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 7
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Amsphere Confidential and Privileged
On instruction of Coomber Rich Solicitors
Yard House, Basingstoke, RG21 7NX
3.9 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
Friday, 12 February 2010
Charles McLachlan 8
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Amsphere Confidential and Privileged
On instruction of Coomber Rich Solicitors
Yard House, Basingstoke, RG21 7NX
Re: Seema Misra
5" 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 13 pages
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Amsphere Confidential and Privileged
On instruction of Coomber Rich Solicitors
Yard House, Basingstoke, RG21 7NX
Contents
4 REVIEW OF PROGRESS AS OF 25 FEBRUARY 2010......sssccsssesseees 1
2 INSTRUCTIONS ETC.....ecsccssssssssssssecssseesseeesseccsnecentecnseessersueessneeenneecessees 8
3 MY DUTIES TO THE COURT ......csesesssssssssssstecsseceseseentecnsecsnseecanessaseetsne 10
Charles McLachlan 1
Amsphere Confidential and Privileged
On instruction of Coomber Rich Solicitors
Yard House, Basingstoke, RG21 7NX
1 Review of progress as of 25 February 2010
1.1 Introduction
This report has been prepared to describe the progress made by myself, the IT Expert
instructed by the Defence since first instructed in September 2009. This has been
offered as a simple table to provide clarity as to the development of hypotheses of
time, the work still required to conduct a proper investigation and the implications of
the witness statement of and interview with Gareth Jenkins in February 2010
Charles McLachlan 1
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Amsphere Confidential and Privileged
On instruction of Coomber Rich Solicitors
Yard House, Basingstoke, RG21 7NX
Hypothesis ist Raised Investigation Progress to date Expected time required to complete Implications of most recent
Required
investigation
information
The User Interface gives,
tise to incorrect data entry:
poor user experience design
can give rise to poor data
entry quality.
21 September
2009
User interface design
audit
Tthas not been possible to arrange for
access to a branch terminal system
under conditions that would permit a
user interface design audit or the
implications of a need for screen
recalibration
‘Six weeks from the time that a date is
offered for access to a branch system for
the purpose of a user interface design audit
Gareth Jenkins, in a telephone
interview on 12th February 2010
confirmed the evidence in his
witness statement dated 2nd
February that use of the Fast
Cash button could result in
ejected card payment being
treated as over the counter cash.
Further, he said that there was a
possibility that when the touch
screen needed recalibrating a
user could believe they had
pressed one button while the
system recorded the pressing of a
different button (the call logs to
Fujistu identify that recalibration
was necessary on more than one
occasion).
The User interface gives
rise to incorrect data entry:
inadequately user
experience testing can give
rise to poor data entry
quality.
21 September
2009
Review of user
experience testing
conducted for Horizon
It has not been possible to review the
adequacy of the user experience
testing in the absence of any details of
the user experience testing process
and test results from the Post Office or
Fujistsu
Two weeks from the time that a complete
set of information relating to the user
experience testing activities has been
provided.
Gareth Jenkins, in a telephone
interview on 12th February 2010
confirmed the evidence in his
witness statement dated 2nd
February that use of the Fast
Cash button could result in
rejected card payment being
treated as over the counter cash.
In the absence of test information
it has not been possible to
determine whether other similar
issues were identified during user
experience testing.
Charles McLachlan
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Amsphere Confidential and Privileged
On instruction of Coomber Rich Solicitors
Yard House, Basingstoke, RG21 7NX
Hypothesis 1st Raised Investigation Progress to date Expected time required to complete Implications of most recent
Required
investigation
information
The User Interface gives
tise to incorrect data entry:
in cases that users are
working under pressure the
problems of data entry can
be exacerbated.
21 September
2009
Electronic Observation
of operational post
office where
discrepancies are
continuing to arise
A post office has been identified where
the sub post master is suffering from
continuing discrepancies, there is
currently no suggestion of theft or false
accounting and the sub postmaster is.
prepared to permit electronic
observation of the use of the Horizon
system. The use of a camera or
screen capture tool was proposed in
the report dated 19th November 2009.
Ithas not been possible to conduct
electronic observation of the use of the
Horizon system at the identified post
office because the Post Office has not
released the sub postmaster from their
contractual obligation of confidentiality
and the Post Office has not facilitated
any arrangements to install the
necessary monitoring tool.
‘Six weeks from the time that a date is
offered for access to a branch system for
the purpose of electronic monitoring
Gareth Jenkins, in a telephone
interview on 12th February 2010
confirmed the evidence in his
witness statement dated 2nd
February that use of the Fast
Cash button could result in
rejected card payment being
treated as over the counter cash.
The Post Office in the Midlands
reports that the level of
discrepancies appears to have
increased as the level of card
based transactions has increased.
The User interface gives
rise to incorrect data entry:
in cases that users are
insufficiently trained the
problems of data entry can
be exacerbated.
24 September
2009
Detailed review of
training both for
Seema Misra and,
more generally, the
training process and
outcomes for
individuals with a
similar profile of
experience and
English language
capability
Tthas not been possible to review full
and complete training records for
Seema Misra. It has not been possible
to review a complete set of training
materials. No log of the calls to the
National Business Support Centre has
been provided, the original log of calls
to the Fujitsu help line has not been
provided - such a lag of calls would
provide evidence as to the extent to
which Seema Misra had been
sufficiently trained to operate the
branch system. Finally, there has been
no opportunity to observe the training
process for a sub postmaster with a
similar level of English capability as
Seema Misra.
‘Two weeks from the time that a complete
set of information has been provided and
the training process has been observed for
an individual with a similar level of English
language capability
We have been provided with part
of a guide that explains the
process for manually dealing with
a card payment that fails to be
properly recorded due to a system
problem. It has not been possible
to establish whether the training
‘Seema Misra received ensured
that she was competent to deal
with this kind of problem.
Charles McLachlan
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Amsphere Confidential and Privileged
On instruction of Coomber Rich Solicitors
Yard House, Basingstoke, RG21 7NX
Hypothesis Ist Raised Investigation Progress to date Expected time required to complete Implications of most recent
Required investigation information
The User Interface gives ‘21 September Detailed review of It has not been possible to review full ‘Two weeks from the time that a complete We have been provided with part
rise to incorrect data entry: 2009 training both for and complete training records for set of information has been provided and of a guide that explains the
in cases that users are
using a system presented in
a language different from
their first language the
problems of data entry can
be exacerbated.
Seema Misra and,
more generally, the
training process and
outcomes for
individuals with a
similar profile of
experience and
Seema Misra. Nor has it been possible
to review a complete set of training
materials. Finally, to observe the
training process for a sub postmaster
with a similar level of English capability
as Seema Misra.
the training process has been observed for_I process for manually dealing with
an individual with a similar level of English I a card payment that fails to be
language capability properly recorded due to a system
problem. It has not been possible
to establish whether the training
Seema Misra received ensured
that she was competent to deal
English language with this kind of problem.
capability
The Horizon System fails to I 21 September _ I In order to identify K post office has been identified where I Six weeks from the time that a date is Gareth Jenkins, in a telephone
properly process 2009 whether this is a the sub post master is suffering from I offered for access to a branch system for _I interview on 12th February 2010
transactions possible cause, it continuing discrepancies, there is the purpose of electronic monitoring explained that the Horizon system
would be necessary in
the first instance
examine the
operations in normal
Post Office conditions
where there is an
experience by the
branch manager of
what they believe to be
incorrect transaction
processing.
currently no suggestion of theft or false
accounting and the sub postmaster is
prepared to permit electronic
‘observation of the use of the Horizon
system. The use of a camera or
screen capture too! was proposed in
the report dated 19th November 2009.
Ithas not been possible to conduct
electronic observation of the use of the
Horizon system at the identified post
office because the Post Office has not
released the sub postmaster from their
contractual obligation of confidentiality
and the Post Office has not facilitated
any arrangements to install the
necessary monitoring tool.
managed by Fujitsu is only part of
a much larger of integrated
systems used by the Post Office
to manage their counters
business. In particular, SAP, a
data warehouse and technology
connecting to a merchant service
provider for card payment
services is involved. The scope of
any systems audit will need to
ensure that any issue relating to
these other systems can be
excluded.
Charles McLachlan
POL00058502
POL00058502
Amsphere Confidential and Privileged
On instruction of Coomber Rich Solicitors
Yard House, Basingstoke, RG21 7NX
Hypothesis ist Raised Investigation Progress to date Expected time required to complete Implications of most recent
Required investigation information
The Horizon System failsto [21 September I Ifthere is primafacie I Ithas not been possible to conduct a_I Two weeks from the time that the interviews I Gareth Jenkins, in a telephone
properly process 2009 evidence of incorrect I detailed interviews with members of are completed interview on 12th February 2010
transactions transaction processing, I the Fujitsu team although a prelimary explained that the Horizon system
it would be necessary
to review the technical
documentation of the
Horizon system and
interview key
individuals responsible
for the system within
the Fujitsu team in
order to understand
the potential source of
the incorrect
transaction processing.
conversation with Gareth Jenkins
occurred on 12th February 2010
managed by Fujitsu is only part of
a much larger of integrated
systems used by the Post Office
to manage their counters
business. In particular, SAP, a
data warehouse and technology
connecting to a merchant service
provider for card payment
services is involved. The scope of
the interviews will need to engage
managers and technical experts
so that any possible issues
relating to these other systems
can be understood.
The Horizon System fails to
properly process
transactions
21 September
2009
If the potential source
of the incorrect
transaction processing
can be identified then it
would be helpful to be
able to reproduce the
problems under
controlled test
conditions in a
consistent and
reproducible manner.
This would require the
assistance of Fujitsu in
providing access to the
test environments
maintained in support
of the Horizon system.
A number of hypotheses relating to
incorrect transaction processing have
been identified but it has not been
possible to conduct any testing in a
controlled environment.
‘Six to twelve weeks from the time that a test
environment is made available.
Gareth Jenkins, in a telephone
interview on 12th February 2010
explained that the Horizon system
managed by Fujitsu is only part of
a much larger of integrated
systems used by the Post Office
to manage their counters
business. in particular, SAP, 2
data warehouse and technology
connecting to a merchant service
provider for card payment
services is involved. The scope of
testing process will need to
ensure that end to end testing
across these other environments:
is possible if the problems cannot
be reproduced in the Fujitsu
environment alone.
Charles McLachlan
POL00058502
POL00058502
Amsphere Confidential and Privileged
On instruction of Coomber Rich Solicitors
Yard House, Basingstoke, RG21 7NX
Hypothesis ‘st Raised Investigation Progress to date Expected time required to complete Implications of most recent
Required investigation information
Incorrect data entry is not__I 19 November I System audit of branch I Ithas not been possible to conduct a__I Six to twelve weeks from the time the Gareth Jenkins, in a telephone
resolved by sub post office } 2009 transaction logs and I systems audit - indeed no branch system audit commences interview on 12th February 2010
reconciliation and relies on the Post Office transaction logs have been provided explained that branch transaction
the consistent, accurate and reconciliation system logs are extremely detailed
timely resolution of records of all branch actions as
discrepancies by the Post well as any branch system
Office and operators of the exceptions (e.g. network failure).
Horizon system They are routinely archived for 7
years and a Fujitsu employee is
engaged fulltime to provide
recovery of logs from the archive
in a routine batch process which,
he said, has been forensically
examined to demonstrate a full
chain of evidence necessary for
the logs to be used in court. In
addition, he explained that
software is provided by Fujitsu for
converting the logs into a readily
accessible spreadsheet format for
system and accounting audit
purposes.
The Horizon system does I 19November I System audit of branch I Ithas not been possible to conduct a__I Six to twelve weeks from the time the Gareth Jenkins, in a telephone
not appear tobe asingle I 2009 transaction logs and I ‘systems audit - indeed no branch system audit commences interview on 12th February 2010
monolithic mainframe based the Post Office transaction logs have been provided explained that the Horizon system
system with computer reconciliation system managed by Fujitsu is only part of
terminals with no a much larger set of integrated
independent processing systems used by the Post Office
capability: each of these to manage their counters
‘components could give rise business. In particular, SAP, a
to faults that result in data warehouse and technology
discrepancies. connecting to a merchant service
provider for card payment
services is involved. The scope of
systems audit process will need to
ensure that end to end audit of
transaction records is conducted if
the issue cannot be identified in
the Fujitsu systems alone.
Charles McLachlan
POL00058502
POL00058502
Amsphere Confidential and Privileged
On instruction of Coomber Rich Solicitors
Yard House, Basingstoke, RG21 7NX
Hypothesis st Raised Investigation Progress to date Expected time required to complete Implications of most recent
Required investigation information
The end to end dialogue 19 November I System audit of branch I Ithas not been possible to conduct a__I Six to twelve weeks from the time the Gareth Jenkins, in a telephone
between the counter 2009 transaction logs and I systems audit - indeed no branch system audit commences interview on 12th February 2010
terminal, the card the Post Office transaction logs have been provided explained that the Horizon system
authorisation terminal, the reconciliation system managed by Fujitsu is only part of
network, the core Horizon a much larger set of integrated
system, the electronic funds systems used by the Post Office
transfer component, the to manage their counters
authorising merchant business. in particular, SAP, a
service and the central post data warehouse and technology
office branch accounting connecting to a merchant service
system is a long running provider for card payment
transaction with multiple services is involved. The scope of
points of possible failure. systems audit process will need to
ensure that end to end audit of
transaction records is conducted if
the issue cannot be identified in
the Fujitsu systems alone.
‘Complex systems rarely 19 November I Based on the review of I It has not been possible to proceed Six to ten weeks from the time the technical I Gareth Jenkins, in a telephone
have sufficient capability 2009 the technical with this review because no technical I documentation is provided interview on 12th February 2010
builtin to deal with all
possible failure points and
discrepancies are very likely
to arise which require
manual intervention based
on the reconciliation of
paper and electronic logs at
different points in the
system.
documentation, it
should be possible to
identify and examine
the various electronic
log files maintained by
different components
of the systems
architecture that are
required by the
Electronic Mastercard
Visa (EMV) standard
or for Payment Card
Industry (PCI)
compliance
documentation has been provided
explained that the Horizon system
managed by Fujitsu is only part of
a much larger set of integrated
systems used by the Post Office
to manage their counters
business. In particular, SAP, a
data warehouse and technology
connecting to a merchant service
provider for card payment
services is involved. The scope of
the technical documentation will
need to cover all of these
systems.
Charles McLachlan
POL00058502
POL00058502
Amsphere Confidential and Privileged
On instruction of Coomber Rich Solicitors
Yard House, Basingstoke, RG21 7NX
2 Instructions etc.
2.1 Instructions
2.1.1 I am Charles Alastair McLachlan, a Director of Amsphere Consulting
Limited, London, England specialising in information technology consulting.
Thave 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 progress on my investigation to date and the
expected time required to complete a full report.
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 8
Amsphere Confidential and Privileged
On instruction of Coomber Rich Solicitors
Yard House, Basingstoke, RG21 7NX
2.5.1 In preparing my report, I have considered the documents used for my
previous reports
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
2.7.1 I have 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.
2.7.2. Amsphere’s fees in this case are not dependent on the result of the
proceedings in this matter.
Charles McLachlan 9
POL00058502
POL00058502
Amsphere Confidential and Privileged
On instruction of Coomber Rich Solicitors
Yard House, Basingstoke, RG21 7NX
3 My duties to the Court
3.1
3.2
3.3
3.4
3.5
3.6
3.7
3.8
I 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.
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.
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.
I have drawn to the attention of the Court to all matters, of which I am aware,
which might adversely affect my opinion.
Wherever I have no personal knowledge, I have indicated the source of factual
information.
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.
Where in my view, there is a range of reasonable opinion, I have indicated the
extent of that range in the report.
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 10
POL00058502
POL00058502
POL00058502
POL00058502
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
Thursday, 25 February 2010
Charles McLachlan ll