POL00069472 - Email from Richard Morgan to Stephen Dilley re whether software updates interfered with system whilst Mr L Castleton was using it.

Evidence on official site

POL00069472
POL00069472

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S$ hen Dilley

From: Richard Morgan,
Sent: 13 October 2006 17:48

To: Stephen Dilley

Subject: RE: Post Office Limited v Mr L Castleton

I think leave it to an IT expert or possibly deal with it in a supplemental
Richard

none Original Message:
From: Stephen Dilley!
Sent: 13 October 2006
To: Richard Morgan
Cc: Tom Beezer
Subject: FW: Post Office Limited v Mr L Castleton

Dear Richard,

Castleton's solicitors have previously said that software updates interfered with the
system whilst he was using it. I attach 2 excel spreadsheets:

1. For the period January to April 2004 - we disclosed this on 21 June. This was
disclosed after exchange of lists, so it is not on our list (and for that reason may not
be in your bundles). It shows that there for counter 1 there were no updates
between 8.30am and 5.30pm during this period. For counter 2 it shows that (with
1 exception on 2 Feb 2004 explained in the email below) there were no updates
between 8.58am and 10.06pm for this period.

2. For the period November 2003 to date. I have not disclosed this just because I
don't see how it could help/hinder us given that we've disclosed 1.

My question is whether we should deal with spreadsheet 1. in a witness statement
of fact just to get it in, as we don't at the moment. (e.g I could ask Andy Dunks
who deals with the HSH call logs whether he could say sthg about this). The
alternative I guess is to leave it to an I.T expert report, if we bother getting one.
What do you think?

I look forward to hearing from you.

Kind regards. Stephen

From: Pinder Bria
Sent: 16 June 200!
To: Stephen Dilley _

Cc: graham.c.ward.... Thomas Penny; Dunks Andy
Subject: RE: Post Office Limited v Mr L Castleton

Stephen

I am advised that it is correct, we do update the software remotely and that a software update
could result in the desktop being closed and restarted, however even then, we don’t see how it
would result in losses as is being claimed. We do hold records of all updates and I have
attached an extract of updates for the period Jan - Apr 04 for your perusal. Software updates
are relatively rare and (unless prior agreement is made with the postmaster) they only take
place outside of office hours with occasional extensions at the weekends, which places them

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outside the normal operational hours of Horizon,

1. Attached is a copy of all updates for both counters (1 & 2) for Marine Drive between Jan -
Apr 04 (incl).

2. In the Product column is shown an I, U, oraD; I = Install D=Delete U = Update.
3. Counter 1 shows there were no updates between 0830 & 1730 hrs over the period

4. Counter 2 shows (with exception to 2nd Feb) there were no updates between 0858 & 2206
hrs over the period

The 2nd Feb shows 24 instances of (I,U,D,) at 1409 and 1 instance at 1410 hrs, which indicates
that a process (lasting one minute) started at 1409 and completed at 1410. I am advised that
this was due probably due to a counter installation and would have been with the postmasters
knowledge and approval. Details of the exact reasoning could be found if required.

I hope this is helpful to you,

Kind Regards Brian

To: Pinder Brian
Ce: graham.c.war
Subject: Post Offi

tmandy. talbott,
astleton

Dear Brian

Firstly, I would like to thank you and your team for finding the time to meet us on
Tuesday. We found the meeting to be really worthwhile, helpful and productive.
We will circulate a note of the meeting shortly, just for everybody's record.

In the meantime, I attach a letter received on 7 June from Mr Castleton's solicitors.
I have highlighted the two paragraphs that I would like you to have a quick look at.
Basically they state the Horizon system is equipped with a facility via which its
operating software can be updated remotely via the connection to the PO's head
office and that the system sometimes went off line when there are software
updates. They have therefore asked for documents relating to the updating of the
software of the system. My view is that they are making a stab in the dark, but
please could you ask your team whether they would have or could obtain any
records of software updates?

I look forward to hearing from you as soon as possible.

Kind regards.

Stephen Dilley
Solicitor
for and on behalf of Bond Pearce LLP

Please note our new contact details from 8 May 2006 as set out above.

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