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Stephen Dilley
From: Tom Beezer
Sent: 31 March 2006 11:53
To: Stephen Dilley
Subject: RE: Post Office -v- Castleton: IT info required
v helpful - I am digesting this and may revert to you
t
From: Stephen Dilley
Sent: 31 March 2006 11:45
To: Tom Beezer
Subject: Post Office -v- Castleton: IT info required
Dear Tom
In preparation for our telecon with Mandy next week, I have the following points:
(1) IT information we already have
(a) The info attached to Mandy's 29 March email. I've been through this and it is basically
helpline call logs relating to the period after Castleton was dismissed, so is of limited value.
However, there are some point in those entries that need discussion.
(b) The info exhibited to Cath Oglesby's statement dated 21 Jan 06. This includes NBSC and
HSH call logs, a copy of the Horizon System User Guide, Failure Sub-Sections 12 and 143,
an email from Andrew Price at NBSC to Cath Oglesby stating that Andrew Wise at NBSC had
been unable to find any errors and an email from Julie Welsh, Service Delivery Manager
HSH which stated that there was no evidence of any system problem.
{2) Information required in the IT report
(a) We need to explain to a Judge who will know nothing about Horizon exactly how it works.
What precisely happens when a customer goes into a Post Office to buy an item? How is this
recorded? Is it manually recorded into the Horizon system at the same time or later in the
day? Is the cash register linked to Horizon?
(b) Precisely what steps Fujitsu took to examine the Horizon system at the Marine Drive Post
Office in 2004 and what their conclusions were,
(c) Whether there have been any similar or serious problems with the Horizon system at the
Marine Drive Post Office since Mr Castleton’s suspension and dismissal.
(d) Whether Fujitsu believe that the suggestion put forward by Mr Castleton’s experts is likely
to be correct and their reasons, either way (if they are able to comment on this).
{e) If there have been human errors in recording the transactions, could an explanation be
that:
(a) There was nothing wrong with Horizon, because it simply reflected the information
entered on to it; but
(b) If staff entered the wrong numbers into Horizon there may have been no real loss (even
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though Horizon would show a loss), because there could be a human error in accurately
recording transactions.
If so, would that be a likely explanation?
6. Any other information that may be relevant.
(3) Who could provide the IT report and how are we going to get it
I sent the attached letter to Nick Samuel of the P.O on 18 November 2005. Nick was going to
‘orward it to Fujitsu. Nick has since left (he was part of Dave Hulbert's team) and Dave has
seen following up with Fujitsu, but apparently without success.
(a) We firstly need to understand exactly what steps the P.O have taken to get the info from
Fujitsu. Dave Hulbert should be patched in on our call next week to give an explanation.
(b) Then we need to establish precisely what roles Andrew Wise at NBSC and Julie Weish,
Service Delivery Manager HSH have, where they are based and what info they could provide.
(c) If they cannot help, Tony Utting at the P.O ought to be able to explain how Horizon works,
aut I don't think he had any contemporaneous dealings with the Castleton case, so Fujitsu
should be able to offer more value.
(d) 1 initially hoped that the attached letter produce the result, but it hasn't and we need to
-efine our strategy. Either the P.O need to meet Fujitsu and thrash this out with them or we
yeed to meet a someone who is in a position to help us face to face to take a proof of evidence.
We need to make it easy for them and if we meet them and do the drafting, this should do it.
(e) In addition to the above, we have permission to instruct an IT expert. We need to consider
whether we want to use an independent expert in addition to any Fujitsu witness. I think we
should. If you agree, we need to identify candidates.
(4) Timescale
(a) Mediation has to take place by 4 May. (Likely to be end of April early May).
(b) W/s of fact to be exchanged by 14 July (so this will probably include Fujitsu witnesses)
(c) Expert evidence to be served on 11 August
Tom - we need to consider with the P.O whether they either want us to:
(i) start interviewing people now in anticipation that the case will not settle at mediation; or
(ii) try to save cost by putting interviews on hold until after mediation.
We will also need to identify an accountancy expert, but it sounds as though Mandy's current
focus is on I.T issues.
I'm around all day if you want to discuss.
Kind regards.
Stephen Dilley
Solicitor
for and on behalf of Bond Pearce LLP
Main office phon
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