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Message
From: Angela Van-Den-Bogerd mm ORO nnnnnnnatl
on behalf of I Angela Van-Den-Bogerd ¢+_
Sent: 14/02/2019 07:24:50
To: Katie Simmonds [i
cc: Jonathan Gribben
Subject: RE: Angela Burke ['
Hi Katie
I would rather get the amendments sorted sooner rather than later. My availability tomorrow is until lpm after that my
diary is full. If that’s no good my availability on Monday is between 12 — 230pm and 330pm and 5pm.
Thanks,
Angela
1° Floor,Ty Brwydran,
Atlantic Close,Llansamlet
= Angela Van Den Bogerd
Business Improvement Director
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unauthorised review, use, disclosure or distribution is prohibited. If you are not the intended recipient please contact me by reply
email and destroy all copies of the original message.
From: Katie Simmonds [mailtoj_
Sent: 14 February 2019 06:53
To: Angela Van-Den-Bogerd <
Cc: Jonathan Gribben <_ GRO >
Subject: RE: Angela Burke [WBDUK-AC.FID123822914] .
Angela
Thank you for sending this through.
We're mindful that when we spoke last month, you mentioned that your team had identified a number of areas where you
wouid like to make clarifications/ corrections to your statement. The current pian for dealing with these corrections is to
simply write to the Court/ Freeths a week before trial begins and provide them with a marked up/ corrected version of your
statement. Perhaps a call would be best for us to make a note/ discuss all of the corrections you want to make in one go
so that we can ensure they all get picked up. When would be best for you to speak? Jonny and I have good availability to
speak tomorrow afternoon if that is convenient?
Kind regards
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Katie Simmonds
Associate
Womble Bond Dickinson (UK) LLP.
‘Stay informed: sign up to our e-alerts
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From: Angela Van-Den-Bogerd [mailto:
Sent: 13 February 2019 16:17
To: Katie Simmonds
Cc: Jonathan Gribben; Kathryn Alexander; Shirley Hailstones
Subject: FW: Angela Burke [WBDUK-AC.FID123822914]
Katie
My response to Point 1 is below. I’m still awaiting the information on Point 2 and will provide as soon as I understand
what information we’ve been able to find on this.
Any queries please let me know.
Thanks,
Angela
1 Floor,Ty Brwydran,
Atlantic Close,Llansamiet
Swansea SA7 9FJ
\ Angela Van Den Bogerd
Business Improvement Director
Confidential Information:
This email message is for the sole use of the intended recipient(s) and may contain confidential and privileged information. Any
unauthorised review, use, disclosure or distribution is prohibited. If you are not the intended recipient please contact me by reply
email and destroy all copies of the original message.
From: Katie Simmonds [mailto:
Sent: 07 February 2019 21:2: ee
To: Angela Van-Den-Bogerd <i GRO b
Cc: Jonathan Gribben < ‘GRO I Kathryn Alexander <
Subject: Angela Burke [WBDUK-AC.FID123822914]
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Hi Angela
As discussed today, there are a couple of areas relating to Ms Burke's witness statement that we need to look into further.
Ms Burke essentially complains about two things:
1. arecovery failure (following an outage, a bank withdrawal effected done by a branch was not recovered by
Horizon even though it was successful); and
2. the fact that when Post Office finally sent a TC for the withdrawal, it indicated that the withdrawal was from Lloyds
when it should have been from TSB.
Point 1 - Recovery Failure
As you know, Ms Burke bundled two customers' transactions into one basket and claims that, in relation to the £150 cash
withdrawal transaction, Horizon told her to pay the money to the customer before she closed the stack. We should be
grateful if you would confirm:
¢ The steps that would need to have been followed for Horizon to confirm the transaction had been processed and
Ms Burke could pay the money to the customer; and
Customer asks to withdraw money from their account and inserts debit card into pin pad machine at post office counter.
Counter clerk selects chip and pin icon from Horizon home screen (image 1) and asks customer how much they would
like to withdraw {image 2). Customer says £150, Counter clerk keys in £150 to the Horizon screen {image 3 — example is
£10 here) and asks customer to enter their pin into the pin pad machine to confirm that the amount that is displaying ie
£150 is correct (image 4}. Once pin number is confirmed customer is advised on the pin pad screen to remove card from
the machine (image 5). Transaction is then authorised and counter clerk presses continue. At this point the ‘payment
authorised’ customer receipt prints. The £150 withdrawal is then added to the Horizon stack and the screen message
will be ‘Total due to customer’ (image 7). The counter clerk then removes the £150 from their till and counts out the
cash to the customer. Before handing the cash to the customer the counter clerk settles the basket by pressing the ‘fast
cash.’ The Horizon transaction is then complete and the stack is empty.
Attached Image List ~ these are screen shots taken of a personal banking withdrawal for £10 I did on Tuesday to step
through the transaction.
@ Image 1 — Home Screen — choose chip & Pin (73)
e image 2 ~ Amount Screen ~Branch User enters this
@ {mage 3 ~ Same screen as number 2 with the change captured of branch user entering the £10.00 withdrawal
amount requested
e image 4 -Pin Pad displays message to customer of what to do and screen advises branch user that customer pin
is required to be entered
Image 5 - £10.00 transaction authorised and advises customer to Remove Card — Stack has £0.00 at this point
image 6 — Transaction authorised ~ Branch user has to press continue to complete
Image 7 - Completed transaction stack shows £10.00 due to customer
Next step would be for branch user to press ‘fast cash’ to finish (F12)
ee oe
e Whether or not it is possible Ms Burke was told to pay the customer the money before completing the
transaction/ clearing the stack.
As can be seen from the images above the Horizon screen says the transaction has been authorised at image 5 and
image 6. Image 7 is when the Horizon screen message is ‘Total due to customer’ = £10 in the image example.
Is it possible to demonstrate that, if Ms Burke had properly followed all of the procedures and instructions through
Horizon, this wouldn't have happened?
There are two areas where Mrs Burke didn’t follow the correct process in this instance.
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e The first is having more than one customer transactions in the stack at the same time ie she didn’t settle the
previous customer's basket before entering the £150 cash withdrawal. This did not in this instance contribute to
the £150 transaction failing to be recovered.
* The second was in handing the money to the customer before finalising the transaction on Horizon je pressing
the Fast Cash icon. Had Mrs Burke completed the transaction on Horizon before handing the cash fo the
customer she would have known that there was a problem with the transaction before the customer had left the
counter/branch.
However in this case the £150 had already been authorised by the customer's bank and therefore Mrs Burke giving the
£150 to the customer was the correct thing to do. As a result of giving the £150 to the customer the branch account would
have been showing a loss of £150 as the corresponding £150 cash withdrawal transaction was not showing on the
transaction log and therefore not recorded in the branch accounts. Ms Burke was very proactive in tracking down the
customer and gathering the information to evidence that the £150 withdrawal had taken place at her branch. However this
would have been identified as part of the reconciliation process undertaken at Post Office Finance Service Centre (FSC).
There would have been a mis-match between the banking information received from the client and what was recorded on
Horizon. This would have then triggered an investigation and in this case a TC to correct the branch account position
would have been issued. This is what did actually happen — Mrs Burke was in this instance quicker than the reconciliation
process as she had identified the issue as it happened.
Point 2 - Lloyds/ TSB
Counsel is keen to understand why Post Office would have sent a TC specifying the wrong bank and whether this could
have created problems for Post Office when trying to reconcile its Horizon Online data with the corresponding data held
by TSC/ Lloyds? Kath helpfully assisted us with this before, copy email correspondence attached, and we can see that
the TC narrative was accurate, however, the Item ID from the Horizon entry's narrative was 'Lloyds TSB Cash
withdrw''. We understand that it is plausible that the code for TSB didn't change for a period until after the Lloyds/ TSB
split in 2013, however, we're mindful that the relevant transaction here took place on 9 May 2016 so this does appear to
be a relatively long period after this time for the code to still be unchanged. Please could we ask you to look into this
further, specifically:
1. What happened in relation to the item codes following the Lloyds/ TSB split in 2013 and when were these
changed? and
2. Did the fact that the Horizon item code specified the wrong bank create problems for Post Office when trying to
reconcile its Horizon Online data with the corresponding data held by TSC/ Lloyds?
As a final more general trial preparation point, the factual witnesses for you to focus on are: Burke, Latif, Patny, Tank and
Singh.
I hope the above is all in order but please feel free to give me a call if it would be useful to discuss further.
Kind regards
Katie
Katie Simmonds
Associate
Wombie Bond Dickinson (UK) LLP
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