POL00083319_033 - Email chain between Stephen Dilley and Anne Chambers - Post Office v Castleton - Revised Copy of Anne Chambers’ Witness Statement

Evidence on official site

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Stephen Dilley

From: Chambers Anne O [Anne.Chambers)
Sent: 23 August 2006 17:15

To: Stephen Dilley

Ce: Pinder Brian

Subject: RE: Post Office -v- Castleton

Follow Up Flag: Follow up
Flag Status: Red
Attachments: DOC_1203719_update.DOC

Stephen,

I have added the references as requested. The additional call which you have not yet seen, which was not
raised specifically for this branch, is e-0402180803.

Brian, can you retrieve this from your official Powerhelp archive?

I noticed there were still two "Ann's on the penultimate and last pages, these need correcting too. Otherwise I
am happy with the content.

Call e-0403040165 is attached as part of the exhibit and I don't think it should be.

Regards,

Anne

Anne Chambers
‘Systems Support Centre, Post Office Account

FUJITSU
Lovelace Road, Bracknell, Berkshire RG12 8SN_
Telf, Internally

Fax. GRO,
E-mail
Web: 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.

From: Stephen Dilley [mailto:Stephen. Dilley:
Sent: 22 August 2006 18:34

To: Chambers Anne O

Cc: Pinder Brian; Tom Beezer

Subject: Post Office -v- Castleton

Dear Anne,

Thanks for your email of 18 August. I attach a slightly revised copy of your statement with
questions in underlined bold italics and Exhibit (the Exhibit will increase when you respond to
the questions on call logs).

Once you've approved it, I'll send it to Counsel to review before sending you an amended
version for approval and signature.

25/08/2006
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I look forward to hearing from you as soon as possible.

Kind regards.

Stephen Dilley
Solicitor
for an

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25/08/2006
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Filed on behalf of the: Claimant

Witness: Ann Chambers
Statement: 1
Exhibits: "ac"
Date made: 22/8/06
IN THE HIGH COURT OF JUSTICE Claim No. HQ05X02706
QUEENS BENCH DIVISION
BETWEEN:
POST OFFICE LIMITED Claimant/Part 20
Defendant
- and -
LEE CASTLETON Defendant/Part

20 Claimant

WITNESS STATEMENT OF ANNE CHAMBERS

I, ANNE CHAMBERS of Fujitsu Services, Lovelace Road, Bracknell, Berkshire, RG12
8SN WILL SAY AS FOLLOWS:

1. I am a System Specialist employed by Fujitsu... 1 have worked for Fujitsu
(previously ICL) since 1978. I have a working knowledge of the computer system
known as Horizon, which is a computerised accounting system used by Post Office
Limited (Post Office). I am responsible for investigation of problems which are,
or are suspected to be, caused by software or hardware errors anywhere in the
Horizon system. I am authorised by Fujitsu Services to view extractions of audit
data held on the Horizon:system. and to obtain system transaction information
from the live Horizon system.

2. I make this Witness Statement from facts within my own knowledge unless
otherwise stated. References to page numbers in this Witness Statement are to
page numbers of Exhibit “AC1” to this Witness Statement.

3. 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

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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.

System Support Centre

4. Calls from Post Masters relating to potential system problems are initially taken
and logged by the Horizon System Helpdesk (HSH). Business issues, which
include problems with discrepancies when balancing the branch accounts, are
expected to be handled in the first instance by the National Business Support
Centre (NBSC), run by the Post Office. If these helpdesks are unable to resolve
the problem, calls may be passed to the System Support Centre (SSC), the unit in
which I work. I have access to much more detailed system information than do
the other units.

5, My initial involvement with the investigation was on 26" February 2004, when call
reference e-0402251077 was assigned to SSC (pages _). The call cross-referred
several other closed calls at pages, {do they need to be included explicitly
here? - We should exhibit them but Andy Dunks can explain them in his
statement. Please can you tell me what the calls were you read so we
can_exhibit them} e¢-0401280325, e-0401290358, e-0402130267, e-e-
0402250454, 0402250553 and so I read those too, to get a better idea of the
problems being reported by the branch,

6. e-0402251011 Critical event seen @13..00.36 18/02/04 (page ) - the call
was raised several days after the event occurred. The Known Error Log entry
quoted did not match the specific symptoms of this instance. Upon checking
further, I found that hundreds of branches had had the same event at the same
time.. The cause had already been investigated by another member of the SSC on
{insert date and call reference and exhibit call] 18/02/2004 e-0402180803
and was benign.. The event would not have been seen by users at the branches,
and in no way affected the branch accounts.

Continuing discrepancies (several calls)

7. I checked for any central reconciliation report entries for the branch which might
indicate a system problem. Various built in checks occur at the end of each day.
For example, the gateway terminal (i.e. the particular computer at the branch
through which data is uploaded to the central data centre) will total all the
transactions completed on both terminals during the day. The total is transmitted
to the central data centre and compared with the total transactions received at
the data centre from the branch, to ensure that all transactions recorded at the

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branch have reached the data centre. If the gateway terminal is not in
communication with the second terminal, the totals are not calculated until
communications are restored.

8. Further checks are made when the sub-postmaster has produced the weekly cash
account at the end of the financial week - normally Wednesday. The cash
account lines are produced by processing the entire week’s transactions as
recorded at the branch, the paper copies of the cash account are printed, and the
electronic copy is sent to the data centre. Each day, the gateway terminal has
added up the day’s transactions according to where they» should appear in the
cash account, and summarises them at the end of the week. The data centre also
produces a weekly cash account based on all the transactions received from the
branch during the week. There are therefore effectively three weekly cash

accounts:

a) The official branch weekly cash account;

b) The branch daily account, summarised at the end of the week; and
c) The data centre weekly cash account.

Any differences between any of these will result in one or more reconciliation
report entries. Report entries are only produced if there are differences.

9. I found no reconciliation report entries relating to this branch, indicating that all
transactions recorded.at the branch had reached the data centre and had been
included in the official branch cash account. My checks covered at least two
weeks prior to the investigation, i.e. weeks 47 and 48.

10. I examined the branch messagestore as at 26'" February 2004. This contained,
among other things, all the transactions completed in the previous 34 days, and
any cash, stamp and stock declarations or adjustments made at the branch. I
looked primarily at one of the latest financial weeks - I cannot remember now
whether I checked week 47 or 48.

11. Cheques were handled correctly as far as the system was concerned. I checked
the remittance out of the cheques, which is normally done several times a week,
as the sub-postmaster had reported a problem with this on 10‘ February (call
reference e-0402130267) (page _). I found that on that one day, the cheque
listing report was not cut off after the day’s cheques had been remmed out. ‘Cut
off’ involves pressing a button on the system to confirm that you have completed
processing of the report, so that when the report is next printed, it will include

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only transactions done after the cut-off point. Since the report was not cut off,
when next printed, it still included the cheques that had already been despatched.
I confirmed that the total value of cheques remmed out of the system equalled
the values of cheques received, and so the failure in process did not cause any
financial discrepancy.

12. Following up a further point from cail reference e-0402130267, I noticed that
occasionally, when they declared the cash held in the office at the end of the
working day, they did not always use the same declaration identification number.
For example if a sub-postmaster uses number 01 and enters £10,000 and then
changes their number and uses 11 to record it elsewhere, the system will think
that, at that point, the branch has £20,000 whereas it only has £10,000. I
checked to make sure this had not been done when they declared the cash at the
end of the financial week, and it had not.

13. I went through the cash elements of transactions day by day and compared them
with the overnight cash declarations (ignoring any duplicated declarations as
described in paragraph 12 above). 1 expected to find that the cash holding
declared by the sub-postmaster at the end of a day was reasonably close to what
he had declared the previous day, adjusted by the value of the cash transactions
recorded on the system during the day. For example, if at the end of day 1 he
was holding £50,000 cash, and during day 2 recorded transactions showing
£6,000 cash received and.£5,000 cash paid out, the net cash for the day would be
£1,000 received, and so the cash holding at the end of day 2 should be £51,000.
The main reason for making this check was to see if I could narrow down the
source of the discrepancy to a particular day.

14. I was surprised to discover that at the end of each day, the cash the branch
declared in the drawer was tens, hundreds or thousands of pounds astray from
what they had recorded on the system. This meant that it was possible that the
sub-postmaster was not accurately recording all transactions on the system at the
time the cash was physically being put into or taken out of the till. This is not
necessarily a problem, as long as everything is entered and declared correctly by
the end of the financial week, but does suggest that they are not working
accurately, and it meant I could not link the weekly loss to any particular day.

15. There was no evidence whatsoever of any system problem, but the continuing
losses and calls suggested they needed some business assistance. I therefore
contacted a colleague, Julie Welsh, in Fujitsu Customer Services, and asked her to

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inform Post Office (page ). I updated the call with a summary of my investigation
and returned it to HSH, requesting they contact the sub-postmaster and explain
that we had investigated and the discrepancies were caused by the difference
between the transactions they had recorded on the system and the cash they
declared, and were not being caused by the software or hardware.

Conclusion

16. There are no reasonable grounds for believing that the information recorded and
stored on the Horizon system would subsequently become inaccurate because of
improper use of the computer terminal. To the best of my knowledge and belief,
during the material time, the Horizon system was operating properly at the Marine
Drive branch or if not, any respect in which it was not operating properly was not
such as to affect the production of cash account or audit record, or accuracy of
their contents. :

I believe that the facts stated in this witness statement are true.

Signed ......

ANNE CHAMBERS

Date

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Filed on behalf of the: Claimant
Witness: ‘Ann Chambers

Statement: i

Exhibits: "Aci"

Date made: 22/8/06

Claim No. HQ05X02706

IN THE HIGH COURT OF JUSTICE
QUEENS BENCH DIVISION

BETWEEN:
POST OFFICE LIMITED Claimant/Part 20
Defendant
- and -
LEE CASTLETON Defendant/Part 20
Claimant

WITNESS STATEMENT OF ANNE
CHAMBERS

BOND PEARCE LLP
Ballard House
West Hoe Road
-Plvmouth PL13AE
{ GRO
DXi iPlymouth
Ref: SID3.348035.134

Solicitors for the Claimant/Part 20
Defendant

Error! Unknown document property name.
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Filed on behalf of the: Claimant
Witness: A Chambers
Statement: 1
Exhibits: waci"
Date made: 22/8/06
IN THE HIGH COURT OF JUSTICE Claim No.
QUEENS BENCH DIVISION
BETWEEN:
POST OFFICE LIMITED Claimant/Part 20
Defendant
- and -
LEE CASTLETON Defendant/Part
20 Claimant

EXHIBIT "AC1"

This is the Exhibit marked “AC1” referred to in the Witness Statement of Anne
Chambers dated August 2006.

Error! Unknown document property name.