POL00069609
POL00069609
Stephen Dilley
From: Pinder Brian [Brian.Pinder:
Sent: 07 September 2006 12:43
To: Stephen Dilley
Ce: Tom Beezer; Jenkins Gareth Gl; Dunks Andy
Subject: RE: WS Marine DriveDOC.DOC.
Stephen
1. As you say there is a possibility that Andy could be asked to answer
technical questions, but if cannot answer, he can always reply he does not know, or that its not within his
particular area of expertise etc.
2. Unfortunately Gareth, although technical, is not au-fait with the
helpdesk processes, procedures or terminology.
I would hope that the pre counsel meetings or any subsequesnt technical meetings between the PO expert and FJ
will identify where any technical issues may lie and address them as they develop.
Couple of comments on attached statement from Andy
Paras: Call Number Should read, 0401290358
Para 14: Comment to address
Para 17: Q. Is the person NBSC? Answer, Not known
Kind Regards
Brian
noon Original Message-----
From: Stephen Dilley [mailto:Stephen. Dilley:
Sent: 06 September 2006 18:33
To: Pinder Brian
Cc: Dunks Andy; Gareth.Jenkins{.
Subject: RE: WS Marine DriveDOC.DOC
“l, Tom Beezer
Dear Brian and Gareth,
I've been working on Andy's draft statement with him today (latest version attached). Andy didn't have any
contemporaneous involvement and essentially the statement is about putting the HSH call logs into plain English
for a judge who might not be too I.T savvy.
Andy has raised the valid point that he would not be able to answer any technical queries on the HSH calls, if he is
asked them at trial. He says you'd almost need a different engineer to explain all the different types of call,
(which may be true, but would of course, be impractical to have too many people involved).
There's two answers to Andy's concern:
1. We're not asking Andy to be the technical expert because both sides in this dispute have been given permission
to call an independent IT expert to give evidence. In due course, they'll probably need to meet Brian and Gareth
at Fujitsu to bounce off any technical queries with you. It is the independent IT expert who will have to deal with
technical points. As an expert, they can also give their opinion on sthg rather than simply sticking to the facts.
2. We've also tried to head off any technical questions being directed Andy's way by saying in his statement that
he's not a technical person.
However, I can't rule out the other side's barrister trying to stretch things and naughtily slipping in some technical
queries. This would not be fair on Andy.
Upon reflection, as Gareth has the real technical know how, I wonder whether he would be willing to give evidence
in place of Andy about the HSH call logs? That way, he'd be capable of dealing with most of what the other side's
barrister could throw at him and I imagine, they'd have a hard time of it. If so, then I could amend the attached
draft statement into Gareth's name.
POL00069609
POL00069609
Please let me know your views on this. (Gareth, either way, I confirm that you won't have to attend the
conference on Monday).
Kind regards.
Stephen Dilley
Solicitor
for and on behalf of Bond Pearce LLP
www.bondpearce.com
coool Original Message----- . nen
From: Dunks Andy [mailto:Andy.Dunkst GRO
Sent: 06 September 2006 16:30 —
To: Stephen Dilley
Subject: WS Marine DriveDOC.DOC.
Please see my comments in paragraph 14, I have tried to explain/answer your queries within the call descriptions
but I am unable to answer you question in paragraph 17 as the NBSC is a POL support team.
Hope this is OK..
Andy Dunks
CS Security
FUJITSU
Lovelace Road, Bracknell, Berkshire, RG12 8SN
Web: http://uk.fujitsu.com
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