POL00111977
POL00111977
OPUS 2
INTERNATIONAL
Horizons Issues - Alan Bates & Others v Post Office Limited
Day 7
March 20, 2019
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March 20, 2019 Horizons Issues - Alan Bates & Others v Post Office Limited Day 7
1 Wednesday, 20 March 2019 1 MR GREEN: My Lord, yes.
2 (10.32 am) 2. MRJUSTICE FRASER: And one of the days next week has
3 Housekeeping 3 already been set aside for a contested third party
4 MRDEGARR ROBINSON: My Lord, good morning, Before I call 4 disclosure application against Royal Mail which I think
5 my next witness there is one small matter I should raise 5 has been moved by consent from tomorrow to next Tuesday.
6 with your Lordship. Your Lordship may recall that 6 MRGREEN: My Lord, yes.
7 I raised the question of disclosure from the claimants ‘7 MRJUSTICE FRASER: And I don’t want to let sand run through
8 in relation to the documents that were referred to by 8 all our fingers unnecessarily. So we will revisit
9 the claimant witnesses who gave evidence last week. 9 today is Wednesday, we will revisit this at the end of
10 MRJUSTICE FRASER: Yes. 10 today, please.
11 MRDEGARR ROBINSON: Your Lordship will recall that 11. MRGREEN: I'm grateful, my Lord.
12 a letter was sent on Friday which sought a response from 12 MR DE GARR ROBINSON: My Lord, I call David Johnson.
13 Freeths by close of business on Monday. 13. MRJUSTICE FRASER: Yes
14 MRJUSTICE FRASER: Yes. 14 MR DAVID MALCOLM JOHNSON (affirmed)
15 MR DEGARR ROBINSON: I raised it with you on Tuesday. It 15 MRJUSTICE FRASER: Thank you, Mr Johnson. Do have a seat.
16 is now Wednesday morning. I simply wish to make 16 Examination-in-chief by MR DE GARR ROBINSON
17 your Lordship aware that this is an issue and that the 17 MR DE GARR ROBINSON: Mr Johnson, there should be a file of
18 point is fast approaching where I may have to ask 18 documents in front of you. CanI ask you please to go
19 your Lordship to do something. 19 to tab 4 of that file {£2/4}. You will see there
20 MRJUSTICE FRASER: Okay. Have I got a copy of that letter? 20 1 think a sheet of two corrections and then behind that
21 MR DEGARR ROBINSON: My Lord, I don’t believe you have, 21 sheet there should be a witness statement which
22 1 will make sure 22 describes itself as being of David Malcolm Johnson; do
23 MRJUSTICE FRASER: It is not on Magnum, is it? 23 you see that?
24 MR DEGARR ROBINSON: That will need to be checked, my Lord. 24 A. Yes.
25 MRJUSTICE FRASER: Allright. I think the best thing is 25 Q. Andis that your nameand address there on the first
1 3
1 have the letter put on Magnum, I'm just going to explore 1 page?
2 the situation with Mr Green now and if we have to come 2 A. Yes, it is
3 back to it, then obviously we will fit it in with the 3 Q. And could you go to the last page in that same tab
4 trial timetable and if people have to be recalled, they 4 please (E2/4/20}
5 have to be recalled, but obviously I would like to avoid 5 AL Yes.
6 that if possible. 6 Q. Is that your signature on that page?
‘7 MR DEGARR ROBINSON: Of course. 7 AL Yes, it is.
8 MR JUSTICE FRASER: Mr Green. 8 Q. And if you could look briefly at the corrections -- have
9. MRGREEN: My Lord, I'm afraid we have been working on 9 you seen those corrections before?
10 eross-examination and I just don’t know what the 10 A. Havel seen them before?
1. position is on it, but I’msure it is being attended to. 11 Q Yes.
12 I will find out and update your Lordship later in the 12 A. Yes
13 day. Obviously, any documents that they have referred 13° Q. Are they corrections you wish to make to this witness
14 to need to be disclosed and that’s obviously -- we must 14 statement?
15 do it, so I'm 15 A. Yes
16 MRJUSTICE FRASER: Weare in I suppose in a sense on the 16 Q. And then if we go forward in the bundle could I ask you
17 basis that these mightbe -- or these would be documents 17 to go to tab 6 please {E2/6}
18 which Mr De Garr Robinson might want to puta point to 18 A. Okay.
19 a factual witness, then the factual witness would have 19 Q. That's your name and address, I think I can take it from
20 to be recalled anyway, but just in terms of proper and 20 you, on page 1 of that?
21 efficient trial management 21 A. Yes.
22 MRGREEN: Absolutely right 22 Q. And on the back page, page 5 (E2/6/5}, is that your
23 MRJUSTICE FRASER: ~ we've got a little bit of scope next 23 signature?
24 week, but I want all the factual evidence dealt with 24 A. Yes, it is.
25 before the experts are called. 25 Q. So these are two witness statements that you have made.
2
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March 20, 2019 Horizons Issues - Alan Bates & Others v Post Office Limited Day 7
1 Subject to the two corrections that we have just 1 (£2/4/6}. Now, you haven't said there that those have
2 referred to, are those witness statements true to the 2 come from any other source, but they are not actually in
3 best of your knowledge, recollection and belief? 3 the guide, are they?
4A. Yes, they are. 4 A. I don't know.
5 MR DEGARR ROBINSON: Thank you, Mr Johnson. If you wait 5 Q. Canyousee they look a little bit different?
6 there there will be some questions for you. 6 AL Yes.
7 Cross-examination by MR GREEN 7 Q. And if you have a look at the two examples we've got
8 MRGREEN: Mr Johnson, I think you may have been involved in 8 there, in the travel line in the top one can you see
9 training some of the legal representatives 9 “Business Mails” is in italics ?
10 A. I gave some demonstrations on how the Horizon system is 10 A. Yes.
1. used in branch to various parties involved in this, yes 11. Q. And "Drop Mails Suite” is in italics?
12 Q. AndI think one of the points you covered was how to 12 MRJUSTICE FRASER: Sorry, which one are you looking at?
13 reverse a -- howto sell stock into the system, to 13 MRGREEN: I'msorry, in the top box
14 correct too much stock and how to enter a transaction 14 MRJUSTICE FRASER: On page 6.
15 A. Yes. 15 MRGREEN: -- on page 6 on the travel line at F4, you go
16 Q — that would then balance stock and cash? 16 across.
17 A. Yes. 17 MRJUSTICE FRASER: Ise, yes
18 Q. Doyou remember that? 18 MRGREEN: "Business Mails 45” is in italies and the one
19 A. Yes. 19 beneath it is in italics and “Returns” is in italics
20 Q. Andyouare very familiar with how the system works? 20 A. Yes.
21 A. Yes 21. Q. And if we go down to “Licences & Government”, “Sell
22 Q. Youare a trainer? 22 Euros” and "Sell Dollars” are in italies , yes?
23 A. (Nods). 23° A. Yes.
24 Q. In your witness statement you say at paragraph 10, which 24 Q. And wecanalso see "AP Manual Entry” and “Transcash” in
25 is on (£2/4/2}, which is page 2 of your first witness 25 the "Retail F7" line are also in italics?
5 7
1 statement, it will come up onthe screen as well, you 1A. Yes
2 say that: 2 Q. In the one below, none of those ones are in italics .
3 “The screenshots that appear in this statement are 3 ‘There's no system reason for that, is there?
4 primarily taken froma document called Post Office 4 A. Not that I know of.
5 Onboarding Counter Guide ... where a screenshot has been 5 Q. So do you know where these ones have come from?
6 taken from another document I refer to that document” 6 A. No.
7 Is that correct? 7 Q. Did you actually cut and paste these into the statement
8 A. Yes 8 yourself?
9 Q. So what you have done is you have taken the screenshots 9 A. No, I did not.
10 that we see in your witness statement from that guide 10 MRJUSTICE FRASER: Who did?
11 and if they're not from that guide, you have pointed 11 A. Thestatement was provided to me by our solicitors based
12 that out? 12 ‘on conversations and
13. A. Yes. 13 MRJUSTICE FRASER: You don'tneed to tell_ me about that.
14 Q So whenwe look, for example, at the screenshot on 14 I just wondered who had cut and paste these into the
15 page 3 (E2/4/3), that’s come from the guide? 15 statement.
16 A. Yes. 16 A. I don’t know who did that.
17 Q. Wecanseea date in the top, Tuesday 2 December 2014? 17 MRJUSTICE FRASER: You don't know. Right.
18 A. Yes. 18 MR GREEN: Can we go back please to page 5 (E2/4/5}. Just
19 Q. And if we look over the page on page 5 please {E2/4/5}, 19 a couple of practical points. Could we very kindly
20 similarly we see layouts there. There's a date 20 enlarge the bottom table please. Thank you very much,
a1 of October 2017 at the top. 21 So, Mr Johnson, just to understand how it works
22 A. Yes 22 practically , which is your area
23° Q. And August 2017. 23° A. Mmhm
24 A. Yes. 24 Q. — this is a typical screen that an SPM might see
25 Q. Canwe just look over the page now at page 6, please 25 A. Yes.
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Q._— when they're in the branch and they're serving
customers?
AL Yes
Q. Now, a couple of quick points.
“Ist Stamp” in the F2 line, which is "Postal Services”,
yes, what happensis that it registers that a first
class stamp is going to be purchased.
AL Yes
Q. That's right
enter in the price of a first class stamp, do they?
A. No, they don't
When they press
And the SPM doesn’t need manually to
Q. And the reason for that is that there is a reference
data table from which that’s populated?
A. As far as the technical aspects of it, I’mnot familiar
with what goes on behind the scenes, what know is when
you press that button
When you press it
that's what comes up.
- the price of a first cla
Yes.
stamp pops up?
oProPre
So there are two aspects to what's happening: there’s
a button press, which is the actual physical input by
the subpostmaster or subpostmistress?
>
Yes
Q. And then there’s what the -- the value of that
9
transaction, which is coming from the system
Yes.
back onto the screen?
Yes.
oProP
So there are two elements of that interfacing together,
yes?
A. Mmhm.
‘MR JUSTICE FRASER: Exotic though your hand gestures are,
they're not going to come out on the transcript.
MR GREEN: My Lord,
Mr Johnson, those are acting together to produce
what's going into the basket: two components
A. As I understand it, yes.
Q. - a button press -- it’s practically what you would
see?
A. Yes
Q. So the SPM presses a button and the item that they have
pressed and its value should appear in the basket?
AL Yes.
Q. If it is all working well?
AL Yes.
Q. Now, just looking at the layout of that table, there is
quite a lot of white space there, isn't there?
AL Yes.
Q. And the actual buttons are very cosy, they're all stuck
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right together, aren’t they, with no white space between
them: "Ist Stamp", "Ist Large Stamp", "Ist x 12 Stamps”,
they're all absolutely tight together, there’s no white
space separating them?
Yes, the items in the middle of the screen correspond to
the -- in most-- in the vast majority of cases to the
most commonly used products.
And the point I was just seeking to make to you is there
are a number of ways that screen could be laid out, and
on that screen we can see there would be plenty of room
to separate the buttons from each other more, wouldn't
there?
It would appear that way.
Yes. And you are aware that sometimes SPMs have
problems with miskeying, don’t they?
Yes.
Can we look please at {F/932} on page 7 please
(F/932/7}. We-can see here if we look at the -- sorry,
shall we start at the first page just to be fair to you,
so you can see what the documentis.
Okay.
This is a miskeying project feasibility study and you
can see that it is a document from May 2012, yes?
Yes.
And if we go back please to page 7 of the document
ul
{F/932/7}, there are a number of recommendations. I'm
Just going to follow through one particular one. If we
look at the penultimate bullet point there.
Yes.
“Look at the Buy and Sell icons on the travel home
screen are too close together and it becomes difficult
to isolate the correct icon. It would be useful to
clearly show which icon to press showing the Buy and
Sell icons more clearly”
Yes?
I can see that, yes
One of the features of the buyand sell icons, which
you, I think will know about, is that they are at the
end of the transaction, so if you press the wrong one,
the transaction has already gone?
No, that’s not right
Let’s havea look, if we may please, at page 14 of the
document (F/932/14}. Is what's said in the top line of
that correct? Let’s just look at it together, if we
can:
“The Buy and Sell icons on the travel screen are too
close together.”
And the second box says
“Having these two icons next to each other many of
the Counter Colleague hit the wrong icon, which means
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POL-0109545
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March 20, 2019 Horizons Issues - Alan Bates & Others v Post Office Limited Day 7
1 there is no way of reversing the transaction when 1 instead of a 4, or a9 instead of a 2. It’s more
2 a mistake has been issued ” 2 striking, a9 instead of a 2, isn’t it?
3 What is suggested is, 3. A. Acompletely different number would be more striking,
4 “Separate these two icons to a more logical location 4 however, if I were serving a customer and they were
5 on the screen” 5 paying a bill for, let’s say, £350, 1 would check the
6 And so forth. Can you see what's being meant by 6 terminal after I had keyed the entry to make sure that
7 that second box there? 7 is the amount that’s showing on the stack.
8 A. I don’t agree with the second part of that where it says 8 Q. Yes, but what we're talking about is the opportunity for
9 there is no way of reversing the transaction when 9 the system to minimise errors that are made in the
10 a mistake has been issued. The pressing of either the 10 ordinary course by people who are just busily serving
1. buy or the sell icon is at the very start of the il customers, trying to be conscientious and deliver a good
12 transaction, so there are various opportunities before 12 service; that’s all we're talking about.
13 the transaction is completed to recognise that the wrong 13. A. Okay.
14 button may have been pressed. 14 Q. Andit’s right, isn’t it, that if you stop and
15 Q. Burif it is not recognised and the transaction is then 15 rigorously check and never make a mistake, which is
16 completed, it’s correct, is it, there’s no way of 16 perhaps unusual for humans, that wouldn't happen, but
17 reversing the transaction at that point? 17 what this is focusing on is how to improve the system so
18 A. No, to my knowledge a bureau de change buy or sell 18 it is less easy for people to make understandable
19 transaction can be reversed. 19 mistakes. Yes?
20 Q. Asthe system is today? 20 A. Yes, I understand that.
21 A. As understand, yes 21 Q. And that’s a good idea in system design, isn’t it?
22 MRJUSTICE FRASER: Has it always been capable of being 22 A. I think so.
23 reversed? 23 Q. Yes. And the screenshots that we've got have largely
24 A. I believe so. It’s almost nine years since I last 24 maintained the same design since Horizon was brought in,
25 worked on Legacy Horizon. To my knowledge, yes, it has 25 haven't they?
13 15
1 always been possible to reverse a bureau de change 1A. Since original Horizon or Horizon Online?
2 transaction. 2 Q. Since original Horizon. They have broadly looked the
3. MRGREEN: Let's look, if we may, at another facet of this 3 same since Horizon was brought in?
4 We haven't got a sereen for it, but there is on some 4 A. Legacy Horizon, the screen looked rather different
5 sereens a zero anda double zero button, aren't there? 5 because there were kind of small pictures on the icons
6 A. Onthe keyboard, there is a zero anda double zero 6 rather than just -- there were visual representations of
7 button, yes 7 it rather than just the written product, if you like.
8 Q Yes, and they're next to each other? 8 Q. Butthe overall layout itself has stayed broadly the
9 AL Yes. 9 same?
10 Q. Andwecansee that that's got the potential for 10 A. Yes
11 miskeying? 11 Q. Andso the icons were fitted into the little buttons
12 A. I wouldn't say it has any more potential than any other 12 that we have seen here?
13 layout particularly 13. A. As far as I'm aware, yes.
14 Q. Well, if youput in -- I mean, we have seen some of the 14 Q. At paragraph 32 of your witness statement on page 8
15 examples of miskeys already during the trial and there 15 (£2/4/8} you talk about the cash declarations having to
16 are things where items which should be perhaps 3,400 are 16 be made by 6.55 because polling takes place at 7.00 pm.
17 34,000, so quite a lot of them have got an extra nought 17 Is that something you know about in terms of what the
18 onthe end. Can you understand from your knowledge of 18 consequences are if, for whatever reason, the cash
19 the layout why that might sometimes occur, might feature 19 declaration is made at 7.012
20 quite prominently? 20 A. Yes
21 A. Yes, it could happen because the buttons are next to 21. Q. Whathappens?
22 each other one might press the double zero rather than 22 A. The reason we say to make acash declaration by 6.55,
23 the single zero, yes, I can see how that - 23 yes, as it states there, the cash declaration
24 Q. Bur it’s easy -- you can imagine someone not spotting 24 information is sent to the cash management team, so they
25 a double zero as easily as they might spot perhaps a 9 25 are aware of what cash on hand is at the branch and to
4
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1 my understanding — I don’t work in the cash management
2 team, but to my understanding, the cash management team
3 use that information to decide how much cash to send to
4 that branch on their next scheduled delivery, or if
5 they're holding extra then -- more than they need, how
6 much they need to return.
7 Q. Now, part of your witness statement has dealt with the
8 reports available to SPMs.
9 AL Yes.
10 Q Oneof the things they can’t do is export data to a CSV
1. file , can they?
12. A. I don't know what a CSV file is
13 Q Oran Excel spreadsheet?
14 A. No, they can’t export that from Horizon, as far as
15 I know, no.
16 Q. Andhas any thought been given, as far as you know, to
17 allowing that to happen?
18 A. I don't know.
19 Q. ThePost Office itself has Credence, doesn't it?
20 A. Yes.
21 Q. And that allows it to look at the transactions that have
22 happened in branch?
23 A. Yes, as far as I’maware, yes
24 Q. Doyou know why the Post Office just doesn’t use the
25 same reports as are available to the SPM? Why does it
7
1 need Credence?
2 A. I don’t know.
3 Q Because the Post Office could print-out the till rolls
4 and analyse it that way too, couldn't they?
5 A. As far as -- well, 1 don’t know whether the Post Office
6 could print-out a transaction log as you would print out
7 in branch. As far as I’m aware, that is only available
8 in branch.
9 Q Oh, I see.
10 A. In that formar,
11 Q. Oneof the things you have mentioned in your witness
12 statement -- it’s actually in your second witness
13 statement, if we could kindly go to that, which is
14 {£2/6/1}. I will just show you the front page to
15 orientate yourself. This is your second witness
16 statement, yes?
17 A. Yes.
18 Q. And if we go to paragraph 21 on page 5 (E2/6/5}, you say
19 there:
20 “The transaction log is a list of all transactions
21 and transfers completed in the branch, in chronological
22 order.
23 “The transaction log can be used as a general
24 investigation of all transactions or it can be filtered
25 by time, value and product. ‘The transaction log records
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the transaction that has taken place and also shows how
it was settled, for example by cash, card or cheque. It
is therefore possible to see all the transactions where
customers have paid by debit or credit card.”
Yes?
>
Yes.
Q. Now, let's say you're in a situation faced by one of the
Jead claimants, Mr Bates, where he is worried that there
may be duplicate entries in his account, but he doesn’t
know what they are; how does he use the Horizon
reporting system to find them? What does he do?
A. To my knowledge, the transaction log will produce what
I have said there
Q. No, I understand. Mr Johnson, I'mnot trying to be
unfair to you.
this, you suspect there may be some duplicate entries,
Just practically , so we can look at
perhaps giving you a discrepancy that’s unexplained.
Just practically , whatdo you do if you are Mr Bates in
your sub-post office in Craig-y-Don in Wales and you
want to try and find out what's going on?
‘A. Are we saying that these are transactions which don’t
appear on the transaction log?
Q. Well, he doesn’t know whether they will -- we will come
to that in a minute
AL Okay.
19
Q. — but let's just say -- what do you suggest that person
in that situation does?
A. I would advise a postmaster in that instance to first ,
raise the issue with NBSC.
Q. Okay. But if they're told that it is their
responsibility to find discrepancies in the branch, what
can they do for themselves? Do they -- because we have
heard of SPMs printing out very long transaction
rolls --
AL Yes.
Q. - wehave actually got one, it’s quite long. Is that
what they do if they're looking for possible duplicates,
they print out -- because they don't know what the value
is
MR JUSTICE FRASER: You are rolling about two or three
questions into one again, Mr Green.
MR GREEN: Sorry.
MR JUSTICE FRASER: Why don’t you just give me
a walk through of the steps that you say hypothetically
someone in Mr Bates’ position should take.
A. So if a postmaster wants to check what transactions have
gone through, they would goto the transaction log. If
they wanted to look at a particular -- as I have
suggested, it could be filtered in a number of ways: by
date, by product, by value, by stock unit, by user,
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1 there are a number of waysit can be filtered , and
2 obviously the more you can filter it, the shorter the
3 report will be, and then it would bea question of, as
4 you say, printing the transaction log out and manually
5 checking each item.
6 MRGREEN: Butif you're looking for duplicates, you would
7 have to try and remember the figures you have seen?
8 A. Yes, I meanif you're looking for a duplicate then
9 I'm-- I mean, I don't know, I’m-- I'm guessing here
10 that if there would be that there would already be
1. one transaction on the transaction log. I’m not quite
12 sure what you are getting at. Presumably we can see one
13 transaction on the transaction log and there's a thought
14 that that transaction may have been duplicated, is that
15 what we are .?
16 Q. Well, you get an unexplained discrepancy of a figure you
17 don't recognise
18 A. Right.
19 Q. Let's say £1,723.
20 A. Okay.
21 Q. Andyou don't understand how that can have happened
22 You think "Well, maybe there's a duplicate entry of some
23 sort”, just, you know, this is one example, or maybe
24 there’s a number of duplicate entries. You can see it's
25 not very easy, is it?
21
1 A. It’s not the most user-friendly way of investigating
2 Q. That's all I was really asking.
3 MR JUSTICE FRASER: Can I just ask youa question. When you
4 say the filtering that it can be done, that can be done
5 in branch, ean it?
6 A. Yes
7 MR JUSTICE FRASER: Am I right that would only be of any --
8 that would only be of any assistance if you knew what
9 you were looking for already, wouldn't it?
10 A. Not necessarily. A postmaster may have come to the
11 conclusion that a discrepancy occurred on a particular
12 day by virtue of looking at his cash declaration for the
13 previous day and the current day, and the previous day
14 had no discrepancy, the current day does, so he may want
15 to filter then to that particular day when the
16 discrepancy occurred on his cash declaration
17 MRJUSTICE FRASER: Mr Green.
18 MRGREEN: Could we look please at (F/1556} please. Now,
19 this it documentis titled the "Network Development
20 Programme Operation Simplification”, and if we go over
21 the page (F/1556/2}, you can see the sorts of things
22 that it is covering and can we go please to page 6,
23 which is the "Business Context” section (F/1556/6}, and
24 can I just invite you to look at this first paragraph:
25 “There are a number of branch operations processes,
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especially around branch accounting and reconciliation ,
which operate using legacy processes. They are
unnecessarily complex and detract Post Office branch
resources from serving customers. Stock Unit Management
and accountability is very poorly controlled and is
operated on very complex business rules. The lack of
accountability and visibility of cash and stock
transfers between Stock Units can lead to errors, rework
and provides opportunities for fraud.”
Is that a statement that you disagree with, or agree
with?
A. I would agree with that
Q. And then if we look just below:
Similarly , Suspense Accounting is based upon legacy
cash accounting practices, ill-defined and out of date
processes. Inefficiencies lead to poor utilisation of
resources both in Post Office branches and Support
Services °
Is that somet
1g you would agree with or disagree
with? Is that fair?
A. Myexperience of the suspense accounts in branch is that
it works it does what it’s supposed to do.
Q. Can you see why that might be a reasonable view, or is
it a completely unreasonable view?
A. I don't think it’s completely unreasonable, no
23
MR GREEN: Okay, I'm very grateful. My Lord, I have no
further questions for this witness.
MR JUSTICE FRASER: Can you just tell me what date this
document is, Mr Green?
MR GREEN: This is 21 October 2016.
MR JUSTICE FRASER: Mr De Garr Robinson?
Re examination by MR DE GARR ROBINSON
‘MR DE GARR ROBINSON: Mr Johnson, you were asked some
questions about buttons being close together, but there
are some questions you weren't asked that I would like
to ask you now.
As I understand it, you have experience of working
in branch?
Yes.
Do you have experience of working in a busy branch?
Yes.
How much experience of that sort do you have?
I have -- before I started my current role in 20121 had
worked in branches since 1984.
Q. So could you give the court some indication of how
much -- would you consider yourself very experienced,
not very experienced? I'm just trying to get a clear
answer from you.
PoPreor
A. I suppose you could say 1am very experienced at working
in branches.
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1 Q. Thankyou. It was suggested to you that you were
2 shown one of the screenshots in your witness statement
3 and it was suggested to you that the buttons were close
4 together. What you weren't asked about is whether you
5 took the view that the buttons you saw, or the buttons
6 on the screen -- that their closeness together is.
7 a cause of any difficulty in using the system. Would
8 you like to comment on that question?
9 A. The fact that buttons are close together can mean that
10 one does occasionally press the wrong one. However,
1. that is easily rectified .
12 Q. Andwhenyousay it is easily reconciled, why is it
13 easily reconciled?
14 A. Rectified
15 Q. Rectified, 1’mso sorry.
16 A. If one would notice that the wrong button had been
17 pressed -- for example, you may goto sell a first class
18 stamp and you know yourself that the cost of that stamp
19 is 67p. If youwere to hit the first class large stamp,
20 which is next to it, in error, the amount on the stack
21 would bea different amount, so it would be easily
22 recognisable that you had then pressed the wrong button,
23 Q. Andanother question that you were asked is whether the
24 layout of the counter had been broadly consistent over
25 the period of operation of Horizon. Mr Johnson, you may
25
1 not be able to answer this question, but do you have
2 a view as to whether keeping the layout of the screen
3 consistent over time is a good thing or a bad thing?
4 A. That’s -- myopinionon that is it is a good thing
5 Q. Why do you say that?
6 A. Because one gets used to working on the system and the
7 buttons are where you would expect them to be.
8 MR DEGARR ROBINSON: My Lord, I have no further questions
9 ‘Thank you, Mr Johnson.
10 Questions by MR JUSTICE FRASER
11 MRJUSTICE FRASER: I just have a couple about your
12 experience. I know you have said in paragraphs 2 and 3
13 how you started as a counter clerk
14 A. Yes
15 MRJUSTICE FRASER: And that was in a Crown branch I think,
16 ‘wasn't it?
17 A. Yes.
18 MRJUSTICE FRASER: And then you say you became the
19 assistant manager and worked in various branches as the
20 assistant manager. Were they all Crown branches?
21 A. Yes, they were
22 MR JUSTICE FRASER: And your last role was the branch
23 manager at the Barry Crown office?
24 A. Mylast role prior to taking up my current role, yes
25 MRJUSTICE FRASER: Which was in 2012?
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AL Yes.
MR JUSTICE FRASER: I'm sure I can guess from the name, but
Barry Crown office is a Crown branch, isn’t it?
AL Yes.
MR JUSTICE FRASER: All right, that’s very helpful
you very much indeed for coming, and that’s the end of
your evidence.
‘Thank
I assume there are no follow-up
questions to that from either of you?
Further re-examination by MR DE GARR ROBINSON
MR DE GARR ROBINSON: Perhaps one question.
Does it makea difference whether you are working
in terms of operating the system, is there a material
difference between operating the system from.
a subpostmaster branch, an agency branch, or from,
a Crown office?
A. No.
MR DE GARR ROBINSON: Thank you.
MR JUSTICE FRASER: Thank you very much.
MR DE GARR ROBINSON: My Lord, I call Andy Dunks.
MR ANDREW PAUL DUNKS (sworn)
Examination-in-chief by MR DE GARR ROBINSON
MR DE GARR ROBINSON: Mr Dunks, there should be a bundle of
documents in front of you. Can I ask you to go to
divider 10 of that bundle please (E2/10}
a witness statement that describes itself as being by
You will see
27
you. Is that your name and address on the first page?
That's the name of my — where I work.
Where you work, I see.
Yes.
Thank you. And if you go to page 3 (E2/10/3}, is that
your signature?
Yes, it is.
Q. And do you confirm that this statement is true to the
best of your knowledge, recollection and belief?
AL Yes.
MR DE GARR ROBINSON: Thank you. Ifyou could wait there
for a moment.
MR JUSTICE FRASER: Mr Miletic.
Cross: examination by MR MILETIC
MR MILETIC: Good morning, Mr Dunks.
A. Good morning
eProp
>
Q. I would like to start with paragraph 3 of your witness
statement which is [E2/10/1}. There are you say:
“I have been employed by Fujitsu Services Limited,
(Post Office Account), since 11 March 2002
(IT) Security Analyst responsible for audit
data extractions and IT Security.”
onthe ~
as an ~
That's quite a long time, isn't it?
AL Yes.
Q. 17 years of experience you have in this particular area
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of data extractions?
Yes.
And over the course of that 17-year period, how many
extractions do you think you have carried out?
I couldn’t tell. you.
Hundreds?
Yes.
Hundreds.
You have probably seen every issue that possibly could
arise with extraction of data, haven't you?
I would say so, yes.
And how many others havea similar position to yours at
Fujitsu at any given time and carry out data
extractions?
Generally, there is a teamof three or four people.
And do they carry out a similar number of extractions
each year as you would?
Yes.
Would that number vary from year to year, or would it be
fairly consistent?
No, it varies. It varies week by week.
And you have experience of carrying out audit data
extractions both on Legacy Horizon and Horizon Online?
Yes.
If we could please go to {E2/1/10}. This is
Mr Godeseth’s witness statement, his first witness
29
statement, and he is a colleague of yours at Fujitsu,
correct?
Yes.
Now, at paragraph 31 there he says that he has been
informed by a colleague that the number of ARQs issued
since 2014/15 areas follows, and then he sets some out
there at 31.1 to 31.4, do you see?
Yes.
‘That suggests huge fluctuations over the years, doesn’t
ie?
Yes.
729 extractions in 2014/2015. Can you think of why that
would be?
I have no idea. It is what we would get supplied or
requests from the Post Office, so we don't control how
many we get.
Would it make sense to you if that was during the period
when the mediation scheme was taking place and so maybe
you had more requests at that time?
Yes, it could quite well be, yes.
And in 2016/2017 and 2017/2018, over 300 requests. Do
you think that these proceedings may have an impact on
that number and why itis a bit higher than for example
2015/2016?
It could well be, but I can’t guarantee that
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Q. In 2015/2016, 103 without these two alternative events
going on. Is that perhaps more representative of what
you would get on a yearly basis, or do you not know?
A. I would be guessing if I said yes, without looking at
all the previous years and how it has incremented over
the years, I couldn't tell you
Q. Sure.
100 or so?
But in your experience that might be about right,
A. It could be, yes
Q. And for 11,000 branches in a year, it’s not a high
percentage of ARQs that were requested during that year?
A. I suppose so.
Q. Now, there are no figures there for pre-2014, and
the court has had had evidence from Mrs Mather -- and we
don't need to turn it up, but for his Lordship’s note it
is paragraph 19 of her first witness statement which is
(£2/8/4}. There Mrs Mather says that there is
a contractual limit on the amount of data requests that
Post Office can ask for of 720. Is this a limit that
you're aware of?
AL Yes.
Q. If there’s a contractual limit on the amount of ARQs
that can be requested, Fujitsu. must be keeping a record
of how many requests are made each year?
A. Yes, wedo.
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Q. Why then are there no figures seemingly for prior to
2014?
A. [can’t answer that
MR JUSTICE FRASER: Have you been asked to get
A. No.
MR JUSTICE FRASER: You haven’?
A. No.
MR MILETIC: Butas far as you are aware, there would be
a record of those?
A. As far as I’maware, there is, yes.
Q. There should be really?
AL Yes.
Q. The purpose of your witness statement is essentially to
talk about the process of audit extraction, audit data
extraction, and the integrity of data and howit is
maintained during that process, is that fair?
AL Yes.
Q. If we could go back to paragraph 4 of your witness
statement {E2/10/1}, you say:
“During 2009/2010 the Horizon system was upgraded to
Horizon HNGX [Horizon Online] and the detail contained
in this witness statement refers to audited transaction
records generated by this upgraded ... system”
1 just want to be precise about the language there
When you say “audited transaction records”, you are
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talking about transaction records generated from the
audit store; what you're not talking about
the case that those records are actually audited prior
it’s not
to going into the audit archive, correct?
No, it’s just the extraction data that I’m taking out.
Exactly. And so it’s an important distinction because
really the only time when those records are audited is
when they are extracted and then someone uses them to
compare against different records. Does that sound
correct?
I think so. I don’t think they are actually compared.
All the data that we extract is specific data from the
servers with all the transactions so it’s not -- I think
the word “audit data” -. it’s just we extract that data,
we don't then compare it. We then extract the data and
supply it to the Post Office.
Yes, so where it says “audited transaction records” it
might be slightly misleading because it is not that they
are audited prior to going into the audit store; that's
correct, isn’t it?
I don’t know how itis put onto the audit store
And the second sentence there:
“Unless I state otherwise in this statement when
I subsequently refer to the "Horizon System’ I am
referring to the ~... system as upgraded by Horizon
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HNGX”
Looking at your statement I have not seen somewhere
where you have stated otherwise, and so actually your
evidence is limited to the extraction process under
Horizon Online, correct?
It is probably misleading. As I have been doing it that
jong, it is both Horizon and Horizon Online.
But the specific content of your witness statement from
that point onwards only addresses Horizon Online?
I would say it’s -- it’s the data that I have extracted
for these proceedings.
I see. And when you discuss controls, which we will get
onto in a little bit, is it your evidence that those
controls have always been the same and the same
processes have been followed both in Legacy and
Horizon Online?
I believe so. I don't knowall the controls -- the
technical controls which are used for the storage of the
data,
So when you provided your evidence here, you really were
talking about the controls as at effectively today’s
date when you were making extractions for this trial?
Yes.
And if we could go over the page please to paragraph 5
{E2/10/2}, the first sentence:
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“When information relating to
individual transactions is requested, the data is
extracted from the audit archive media of the Horizon
System via the Audit Workstations”
And then this second sentence:
“Information is presented in exactly the same way as
the data held in the archive although it can be filtered
depending on the type of information requested.”
Pausing there, do you always provide data that’s
filtered , or do you sometimes provide data that’s
unfiltered?
We supply data that’s filtered
Are there any circumstances in which you provide
unfiltered data?
To the Post Office, I don't believe I have done.
And then you go on to say:
“The integrity of data retrieved for audit purposes
is guaranteed at all times from the point of gathering,
storage and retrieval to subsequent despatch to the
person making the request.”
Again, just in the interests of being precise, can
you explain exactly what you mean when you're saying
“data integrity"?
That's what I’m led to believe within the systems that
it is - that hasn't -- the integrity is complete, it
35
hasn't been touched in any other way.
So your definition of integrity of data is simply
whether it has been tampered with or not?
No, my definition of integrity is that the data I have
extracted and supplied to the Post Office my I'm
awareof is in - its integrity is complete.
And if I was to say the data integrity is the overall
completeness, accuracy and consistency of that data
which you can measure by comparing between sources,
would you agree with that as a definition of data
integrity?
Yes.
And if we could please go to (D3/1/67}, this is from
Dr Worden’s first expert report, and if we could look at
paragraph 238.6 and what he says there, which is:
“The audit system provides a highly secure and
tamper-proof record of what is entered into Horizon at
the counter, which can be used, in cases of any anomaly,
to provide a ‘gold standard’ for comparison with data
held in other parts of the Horizon estate, supporting
the diagnosis of software errors
kernel and redundant store of data (SEK and RDS)”
I’m not going to ask you about the second sentence
‘This acts as a secure
and those acronyms, but in terms of that first part, is
it your evidence as well that it is highly secure and
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tamper proof?
The -- where the data is stored, I'm not involved in, so
I can’t answer that side of the question,
But in terms of whenit is extracted?
From my point of view, the processes that we follow and
extract them and supply them to the Post Office, that is
my belief
It is highly secure and tamper-proof?
Yes.
Andis it your evidence as well that it can be used in
cases of an anomaly asa gold standard for comparison?
‘They are -- they are words that I probably wouldn't us
but I’m happy with the integrity of the data that I give
to the Post Office.
But "gold standard” might be putting it a bit high for
your -- in your opinion?
Well, no, if you want to use "gold standard”, yes,
I will agree with that.
But in any event, you agree that the accuracy of that
audit data and maintaining the integrity upon extraction
is extremely important, particularly , if it is going to
be used in disputes with subpostmasters?
Yes.
And if we could go back to (E2/10/2}. Paragraph 6 where
you set out what you say the following controls are that
37
apply. Did you look at any specific Fujitsu documents
when listing what amount to 12 controls there?
Where am I looking at here, sorry?
So in paragraph 6 you say:
“During audit data extractions the following
controls apply
Yes.
And then you list out in subparagraphs, 12 specific
particular controls and 1 was just wondering whether you
looked at any specific Fujitsu documents when you set
out those controls?
No, this is the process -- there are security processes
and protocols in place within Fujitsu, but these are
basically the security controls that we have as a team
that we have to extract the data
‘My question might not have been entirely clear,
Mr Dunks, but when you set out these 12 controls, when
you were drafting this part of your statement, did you
look at any specific documents in order to think of
and write out these 12 controls?
No, this is my knowledge of the controls.
So this is purely from your memory thatyou draft the 12
controls?
Yes.
I see. And in terms of those 12 controls, have they
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always been available throughout your time at Fujitsu,
or have some potentially changed?
No, that’s basically as is the whole time I have been
there.
As far as you can recall those are ~
Yes.
Would you say that those are sort of the core controls,
or they just some that you thought of?
No, they are the core controls surrounding the audit
extraction
So at any point in time when we look we should probably
see the 12same controls listed at other points in time?
Yes.
And just over the page, please, {E2/10/3}, at
paragraph 7 you just describe the fact that you have
extracted data in relation to these proceedings. And
then paragraph 8, again, I just wantto be very precise
and I want to make sure that I understand exactly what
is being said in this statement. Paragraph 8 begins:
“There is no reason to believe that the information
in this statement is inaccurate
Pausing there, what is "this statement"? Do you
mean your witness statement?
Yes.
Okay:
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“There is no reason to believe that the information
in this [witness] statement is inaccurate because of the
improper use of the system.”
Whatis the “system” there? Is that the system of
the process of extracting audit data, or is it something
else?
(Pause).
Good question. There's no
meaning by that, “There is no reason to believe
We will take this step-by-step, but just looking at that
I'mnotsure what I was
first sentence, you are not quite sure what you mean by
“system”?
I think I was meaning about the improper use of the
audit data extraction system.
So when you say “system”, you mean the process of
extracting audit data?
Yes, I do.
I see, so
“There is no reason to believe that the information
in this [witness] statement is inaccurate because of the
improper use of the system [in place for extracting
audit data ).”
Yes.
“To the best of my knowledge and belief at all. material
times
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Pausing there, what are “all material times” in your
statement?
‘The whole time I had been using the workstations to
extract the data, as far as I’m concerned, there has
been no issues or faults with the workstations to
extract the data,
So “at all material times” is actually the 17 years you
have been at Fujitsu?
Yes.
I see, so:
“To the best of my knowledge and belief at all
material times the system ...”
Ie the process of extracting data:
~.. was operating properly, or if not, any respect
in which it was not operating properly ..”
Again, pausing there, it is slightly confusing. Are
you aware or not aware of any instances where that
system was not operating properly?
No, not really, no.
Okay. So you're not aware
‘There may have been a few faults -- software faults
I would say software faults -- where the system has
rebooted or whatever, but if that does, it interrupts
the data extraction which doesn’t complete, so we will
then re-run the data extraction. So it's not affecting
aL
any data that’s been extracted
I see. And is that the only example that you can
provide his Lordship as to occasions when that system
wasn't operating properly?
Yes.
So you say it was operating properly:
*. of if not, any respect in which it was not
operating properly, or was out of operation was not such
as to effect the information held within it”
What is "it"?
The data that I have extracted
I see, okay. So, Mr Dunks, how could you possibly say
that in any respect that the system wasn’t operating
properly, it wouldn't affect the data that you have
Surely if that process isn’t operating
properly, it musthave an effect on the data that it
extracted?
produces?
Well, no, because if it doesn't extract the data wholly,
or there is an issue with the PCat the time, it will --
it shows that there is an error, so we actually re-run
the data and there are some checksums within the data
which is a number for each day and if there's a gap
between ~ and we check that there’s no gaps between
those numbers, and on each report it states that there
are no gaps, which would show if it there were any
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issues, but
And is it your case that there has never been
a circumstance where the data that's been produced
I see.
hasn’t[ sie] appeared inaccurate because of the process
used to extract it?
Not to the best of my knowledge, no.
So now that we have deconstructed that paragraph
a little bit, it is a very specific and slightly hard to
follow choice of wording. Has that come from you, or
has that come from somebody else, Mr Dunks?
It - I did produce the witness statement and then it
came back slightly altered to see if 1 was happy with
that and I read it and I was happy with it. Maybe
misunderstanding how it could be interpreted, but...
Yes, but paragraph 8, is that your choice of wording or
now?
1 can’t remember.
Is it more ofa Fujitsu party line whenit comes to
providing statements on extracting data?
There is - as far as witness statements, there are
no -- I’mnot aware of any party line, no,
‘Thank you. Can we please go to {E2/1/10} and we're back
in Mr Godeseth’s witness statement here. We looked at
the ARQ extraction rates over the years. At
paragraph 32, Mr Godeseth says:
43
“I am not aware of any instances where data
retrieved from the Audit Store differs from other
sources of data, nor am aware of any instances where
the integrity checks described in paragraph 30 have
revealed any issues.”
‘Those integrity checks are broadly similar to the
ones that you have outlined, but are you aware of any
instances where data retrieved from the audit store has
differed from other sources of data?
No, because I'm not aware of any other forms -- I'm not
involved in any areas of data storage.
So Fujitsu. wouldn't know that anyway?
Well, I can’t say that
Does Fujitsu keep list of any times when that might
happen?
I don't know.
It would be quite a useful thing to have though, for
Fujitsu's purposes, if they did have such a list,
wouldn't it?
Yes.
And I guess my second question is a bit overlapping with
the first, but are you aware of any instances where
integrity checks have revealed issues?
No, I’m not aware, no.
Not aware of any instances?
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A. No.
Q. And again, Fujitsu don’t keepa list of any of these
times when it might have revealed issues?
A. Again, I don’t know.
Q. Can we please go to (F/1557}. Mr Dunks, this is
actually a Post Office document titled "Back Office
‘Transformation’, It is dated 22 October 2016. The
context -- there’s a little bit in that first part
there:
“This paper outlines the business case for the back
office transformation. An opportunity to_ significantly
improve our basic process and controls, whilst
simplifying the back office application landscape and
reducing our cost base.”
If we could please go to page 4 of that document
{F/1557/4}. Have you seen this document before,
Mr Dunks?
A. No.
Q. Now, there it says "Why do we need to transform?”
“Transformation in the back office is required due
to unsuitable processes and significant operational
risk
"The Post Office has been running the same
sub-optimal back office processes for many years”
If we go down a bit further
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“Industry best processes exist that can, and will be
adopted”
And then 14:
“The back office is currently operating with a far
higher operational risk profile than is accepted by the
Post Office when making investment or project decisions
High proportion of manual accounting steps.”
And then the first arrow bullet point there:
“Lack of system audit trail between transactions”
What do you think that means?
A. I have no idea, 1 would be guessing
MR DE GARR ROBINSON: Is this a fair --
‘MR JUSTICE FRASER: Just - Mr De Garr Robinson.
I’mnot sure you can actually really pursue that
very much further with this witness given he has never
seen the document before.
MR MILETIC: I'm grateful, my Lord.
‘MR JUSTICE FRASER: Is it a phrase you have ever come across
before “lack of system audit trail"?
A. No.
‘MR MILETIC: I suppose the one question 1 would ask Mr Dunks
is: are you aware that Post Office had any concerns
regarding system audit trail as far back as 2016
A. No, because I’m notinvolved in that area at all
Q Tsee. I will move on.
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If we could please go to {F/1716}. This is the
audit extraction client user manual, Presumably you are
very fai
with this document?
I haven't read it for a long time, but I’m aware of it,
yes.
So it’s not something that you really look to ona daily
basis?
No, it’s not.
When do you thinkis the last time you would have looked
at it?
A few years
A few years?
Yes.
The date of this document is 1 December 2017. It’s the
most recent version, as far as we're aware, but you're
hot sure either way probably whether it is or it isn’t,
is that fair?
No, not -- no.
If we could go please to page 9 of this document
{F/1716/9}, the introduction there:
“In addition to the historic data collected under
Horizon, the HNG-X system generates significant amounts
of data that is of interest to Post Office ~... Internal
Audit. and other groups.
“This document describes the Audit Extraction Client
47
application that is run on the Audit Workstations
the AE client provides functionality to manage [ARQs]
and to retrieve and process audit data from the
audit archive.”
It seems like an incredibly important document for
your job, doesn’t it, Mr Dunks?
Yes.
It is effectively a step-by-step guide on how to
contrary out data extraction?
I don't know. I can’t remember reading it but
You can’t remember reading. The definition there of
* filtering " under 3, do you see?
Mm-hm.
“Filtering is the process of searching the retrieved
audit files for specified FAD codes or strings in order
to select a subset of data for further processing.
e
user has the option of selecting the whole file in which
a match is found or of just selecting the matching
messages or records”
So filtering takes place obviously after you have
actually retrieved the files from the archive?
Yes, yes.
Under 4, "Audit Data Integrity", the second paragraph
there:
“The integrity of audit data must be guaranteed at
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all times and controls have been established to provide
assurances to Post Office Internal Audit that this
integrity is maintained.”
That wording actually mirrors paragraph 5 of your
witness statement. Do you recognise that wording?
AL Yes
Q. And then it says:
“During audit data extractions the following
controls apply...”
Now, there are two there on that page which actually
mirror your 6.1 and 6.2 controls and then just over the
page please {F/1716/10}, the third one there matches
your paragraph 6.6
If we could please move forward to page 42 of this
manual (F/1716/42}, the section begins with "Validation
and Query”
“This tab will only be available if the following
conditions have been met:
"1. The retrieved data consists exclusively of TMS
and/or BRDB messages.
"2. Filtering has been performed.”
So this is now the data has been retrieved and now
we have been filtering , is that right?
A. Right, this is
retrieval , one is the fast and one is a slow one.
there would be two forms of data
This
49
is the historic one which I haven't used for quite
awhile, but yes, I believe so.
Q I see.
MR JUSTICE FRASER: Is this the slow one or the fast one?
‘A. It's the slower one.
‘MR JUSTICE FRASER: The slow one.
MR MILETIC: And if we could go over the page, please
{F/1716/43}, it says:
“TMS and BRDB messages are numbered in sequence for
each node. During filtering any retrieved audit message
data is analysed to determine what message sequences are
present in the data and whether there are any gaps or
duplicates in those sequences.
A gap in a message
sequence may indicate that a message is missing from the
audit data. Duplicates may indicate that an audit file
has been gathered twice.”
Taking those in turn, "a gap in a message sequence
may indicate that a message is missing from the audit
data”; that suggests that the underlying audit data is
incomplete, doesn't it, Mr Dunks?
A. I would say so, yes.
Q. But it uses the word "ma
so actually it might be the
case that it is the retrieval process that has caused
the gap?
A. I don't
~ no, I don't think -- I don’t know.
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Q. So the use of the word "may", may just bea slip in
language there?
A. Quite possibly.
MR JUSTICE FRASER: Well, it could be any one of a number of
reasons.
MR MILETIC: Precisely, my Lord.
MR JUSTICE FRASER: But on the basis that the witness didn’t
draft it, I think he has agreed with your proposition to
the extent he can, but he also says he doesn’t know.
MR MILETIC: I'm grateful, my Lord.
And the second part there “duplicates may indicate
that an audit file has been gathered twice”, so that
would be an example of the processing
were describing before, potentially causing duplicates
to be gathered?
A. Yes, possibly
Q. And are you aware whether actually it might be the case
that duplicates were in the underlying data itself
rather than through the process?
the system you
A. I don't know, 1 can’t -- I don't know.
Q. Well, the diagram there shows what would happen in the
event that gaps and duplicates are found, and do you see
it says gaps found shown in red, duplicates found shown
in blue and in block capitals "Seek assistance from
audit support’, Now, on the face of that message
51
first of all, have you seen messages like this before
when you have retrieved data?
A. If I have it wasa long time ago. I"m not saying
T haven't, but it would have beena long time ago
Q. You may have done? Andon the face of it doesn't tell
you what the cause is of those gaps or duplicates, does
it?
No, I don't believe it does, no.
And you wouldn't know what the cause was?
No, I wouldn't know, no.
oPrer
And in block capitals it says "Seek assistance from
audit support”. Seek assistance from audit support, but
there’s no explanation as to what audit support might
do. What do audit support do in that circumstance?
A. I’massuming they would investigate the cause of the
gap.
Q. Doyou have any experience of when you have called audit
support and they have come back to you?
‘A. Possibly. I think I possibly -- yes, I think we have
raised PEAKs, whichis if this ‘we would raise an
issue via a PEAK for the audit team to investigate
Q. It’s. a problem, isn’t it, if gaps and duplicates are
found upon the retrieval process?
A. Yes, I think so
Q. And it’s obviously very important what happens to the
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oProP
>
A
Q,
A
data afterwards. Would you provide ARQs containing gaps
and duplicates, or would that go out of your hands and
then audit support gets involved?
Yes, the latter, yes.
The latter?
Yes
And you're not quite aware of what they do. You say
they investigate?
Mm-hm.
When the ARQis ultimately provided, do they -- do you
know if they provide a version containing gaps and
duplicates, or if they provide a version without gaps
and duplicates because they have removed them?
I don't know.
You don't know?
No.
MR MILETIC: My Lord, would it be a convenient moment for
a break?
‘MR JUSTICE FRASER: Yes, it would.
qa.
ai
Mr Dunks, you are in the middle of giving your
evidence. We havea short break in the morning and
a short break in the afternoon for the shorthand
writers. Please don’t talk to anyone about your
evidence or the case. We will have ten minutes, come
back in at 11.50, but please don't feel constrained to
53
stay in the box, you are allowed to go outside, stretch
your legs, even get some fresh air if you think you can
get down and get back up in time, but 11.50. Thankyou
very much.
.41 am)
(Short Break)
52 am)
‘MR MILETIC: Could Mr Dunks please be shown [F/676}. This
oProP
>
is a witness statement dated 8 July 2010 by
Gareth Jenkins. Do you know Gareth Jenkins?
Yes, I do.
He was a colleague of yours, correct?
Yes, he worked on the same account.
And he provided this witness statement in the trial of
Mrs Seema Misra. I assume you are familiar with
Mrs Misra’s case?
Yes.
In fact I understand, having seen a reference in
a transcript, that you in fact provided at least one
witness statement in that case?
1 did.
Do you remember what the content of that witness
statement, what it was dealing with?
‘That was around the help desk calls
I see. Now, Mrs Misra was a subpostmistress in
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West Byfleet that wasat the time being prosecuted on
charges of false accounting and theft and you recall
that?
Yes.
Have you seen this witness statement of Gareth Jenkins
before?
No,
Could we please go to page 2 of this statement
(F/676/2},
“With Horizon counters, the mechanism by which data
In the first full paragraph it says:
is audited has always worked on the principle that it is
acceptable to audit the same data more than once
in
particular if in doubt as to whether or not it has been
previously audited successfully .
Horizon to retrieve the audit data took this into
The Mechanism used on
account and only presented one instance of such
duplicate data in the ARQextracts. The Audit Mechanism
cannot alter the base information and therefore
a re-running of the audit process will always produce
the same result.”
Does that accord with your understanding of how the
process of retrieving audit data worked in
Legacy Horizon?
Yes
Are you sure or is it
55
No, no, as far as I'mawareit extracts the data that’s
there and if I extract it again, it will bring out the
same data.
I see, so duplicates would not show up at that time?
When you say duplicates
Well, when it says:
*~.. only presented one instance of such duplicate
data in the ARQ extracts.”
As far as I’m concerned the data that -- it is very
process-driven, so we input the FAD code, the dates and
extract the data, and if I extracted it a second time,
it would bring back the same data, so I'm not aware, or
I don't know about duplicates it would bring back -- as
far as I’mconcerned, it brings back the same data.
I see. Mr Jenkins goes on to say:
“In January 2010 a new HNG-X application was
introduced to filter transaction records for
presentation to Post Office Limited. It has recently
been noticed that this HNG-X retrieval mechanism does
not remove such duplicates. An enhancement to the
extraction toolset will be developed, tested and
deployed and will remove such duplicate data in the
future. However until this enhancement is deployed,
there is a possibility that data is duplicated ”
Pausing there, do you recall this being an issue at
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the time?
I vaguely remember it, yes
And he goes on to say
“The reliable way to identify a duplicate
transaction is to use the <Num> attribute that is used
to generate the unique sequence numbers. This will be
included in all future transaction record returns until
the retrieval mechanism is enhanced. A semi-automated
process to copy the returned data, and then to identify
and remove any duplicated records which may be present
from this copy by using the <NUM> attribute, has been
agreed with Post Office Limited for use in the interim
period.”
What that suggests is there was. period of time
when there was ~ it says semi-automated, a partly
manual process in removing duplicate records from ARQ
Does that accord with your memory?
It wasn’t in the process that we did when extracting the
data, I’m aware of that happening, whether it went
extracts .
on -- I don’t know the process of it, but it wasn't in
our daily process for extracting and removing any
duplicates
So where it says that there is a process agreed with
Post Office in the interim period for removing those
duplicate records, that’s not something that you were
87
involved in as the person extracting the data?
No.
And not anyone in the similar role to yours was involved
in that?
I don't believe so, no.
So there was effectively a separate department that was
taking care of that?
‘That was dealt with -- yes, not within our team.
I see. And it says there:
“A transaction log data dise has been produced as
exhibit PT/02 inthe trial of Seema Misra. The
transaction log data dise is made up of ARQs 436 to 448.
It should be noted that ARQ 447 which records the
transactions between 1 November 2007 to 30 November 2007
does contain some duplications of audited records.”
But then Mr Jenkins says:
“It is emphasised that [it doesn’t] ~...
[affect] actual physical transactions recorded on the
‘The duplication of records has...”
If we could turn the page:
oceurred during the auditing process when
records were in the process of being recorded purely for
in any way
counter ~..
audit purposes from the correspondence servers to the
audit servers.”
‘That final paragraph there, does that look familiar
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to you?
Yes, it’s the sameas what's in my statement, yes
There's a slight difference in that it says improper use
of the computer rather than system, but the rest does
seem to match up?
Mm-hm.
But you hadn't seen this witness statement before?
No.
And you're not sure why it would largely replicate your
paragraph 8?
No, I mean, we do have a standard witness statement that
we produce for ARQs. When we supply ARQs we are
sometimes asked for a witness statement to go through
the process and verify as far as I’maware that the data
I supplied is accurate. Now, we use that quite a lot
and it may actually be in that statement.
I see. So when I asked you earlier whether it was
something of a Fujitsu party line you said you didn’t
think it was, but actually it looks as though it is on
the basis of what you have just told me and on this
document as well.
It could be. It may be part of our standard witness
statement that we supply.
And it’s not something you think about too much, that
specific section?
59
No.
It’s just template. You don't think about it, and you
sign?
No.
I see
MR JUSTICE FRASER: Is that no, you are agreeing, or no, you
A
MR MILET!
>
oroPr
are disagreeing?
No, I agree
I'm grateful, my Lord,
Now, if we could please go to {F/573/1}. This is
‘a witness statement of Penelope Anne Thomas. Do you
know Mrs Thomas?
Yes, she used to be a colleague.
And have you seen this witness statement before?
No.
This is a witness statement also in Mrs Misra’s trial
and if you look at the first full paragraph, that
largely replicates your paragraph 3. She was
essentially performing the same role in terms of
providing evidence as you are here, is that fair?
Yes
And if we could turn to page 3 please {F/573/3}, and
just to say, the date of that statement -- it says
4 February on the front page and she describes a bit of
the process there in the second paragraph and in the
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oProP
>
final two sentences, in discussing the transaction
records, she says:
‘They therefore provide the ability to compare the
audit track record of the same transaction recorded in
two places to verify that systems were operating
correctly. Records of all transactions are written to
audit archive media.”
Nothing controversial there, do you agree?
Yes.
And just in passing, the two paragraphs below that where
it says:
“The Horizon system records time in GMT and takes no
account of Civil Time Displacements ...”
This is something we have actually heard some
evidence on earlier, but it’s correct, isn’t it, that
the audit data. six months of the year the time stamp
will be off by an hour?
Yes.
And at the bottom of that page, Penelope Thomas says:
“During audit data extraction the following controls
apply.”
And then over the page (F/573/4}, and she too lists
12 controls that aren’t entirely
match up to the controls that you have set out, for
they don’t entirely
example, one of the controls that I noted appears to be
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sing is in your paragraph 6.9 where you said:
"Checks are made using the JSN that all audited
messages for each counter in the Branch ~..”
I will just let you find it if it would help?
Mm-hm.
“Checks are made using the JSN that all audited messages
for each counter in the Branch have been retrieved and
that no messages are missing.”
‘To your knowledge, was this an available control at
this time when Ms Thomas gave her statement?
I don’t know. I don't know.
So you don’t know when that control came into play?
No, I don't.
I see. Doyouthink if it was available it’s quite an
important check that Ms Thomas would have mentioned it?
Possibly
But it is quite difficult because she hasn't listed
where she derives those controls from either anda point
that we made earlier when looking at your witness
statement -- you said that you had listed 12 controls
effectively from recollection, or what you understand
them to be, but we can’t now verify that by looking at
any documents to see where those controls might appear
and when they were brought into force or not as the case
may be?
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No-- well, I don't know. There may be
How did you satisfy yourself that the controls
you were speaking to in paragraph 6 of your witness
I see.
statement do actually apply as at today's date?
1 was trying to imply
that the data as far as I was concerned, when extracted,
was true and accurate to my best knowledge.
I -- on those checks -- those
Well, stopping just there, You're trying to imply the
result which is that the data is accurate, but the
question is very specific as to the content, the
existence of the controls that are in place. How did
you verify to yourself that those controls are actually
in place?
I was trying to imply that the data that I had extracted
hadn't -- from the date of -- from the time of being
extracted hadn't been manipulated or touched and when
you said before (inaudible) with the Post Office, and
controls to actually go in and log on and extract that
data, there were controls in place to do that
How did you know?
But can you actually be sure that the controls you
listed were in effect and were operating as at the time
you extracted the data?
To the best of my knowledge, yes. Yes.
I see
I had no reason to doubt it.
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Even though you didn’t confirm it through any documents?
No.
I see. And over the page, please, {F/573/5}. Ms Thomas
there just describes that she wasin fact the one that
extracted the records in relation to Mrs Misra so we
see:
“ARQs 436 to 448 .... were received on
26 February 2010 ..”
It goes on to say:
“I produce a copy .. as exhibit PT/O1
extractions of data held on the Horizon system in
accordance with the requirements of ARQs 436 to 448
and followed the procedure outlined above. I produce
the resultant CD as Exhibit PT/02. This CD, Exhibit
PT/02, was sent to the Post Office Investigation section
I undertook
by Special Delivery on 4 March ~..”
Do you recall that PT/02 was the exhibit that
Gareth Jenkins in his witness statement was talking
about?
I'm-- with it being called the same, I’m assumingit is
the same.
Yes, and he, in that statement, referred to ARQ 447
containing duplicate records and then needing to be
removed. I can take you back if you would like to see
that section?
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1 A. No, that’s fine.
2 Q. So then Ms Thomas sets out:
3 ‘This report is formatted with the following
4 headings.”
5 And then over the page, please (F/573/6}:
6 “The Event report is formatted with the following
7 headings.”
8 Now she doesn't mention anywhere there that ARQ 447
9 contained duplicate records, does she? I can give you
10 a moment to look at that section.
11 A. No.
12 Q. And then the paragraph immediately below it, that again
13 is your paragraph 8 although this time word-for-word is
14 the same as your paragraph 8, isn’t it?
15 A. Yes.
16 Q. Andit is consistent with your answer earlier that this
17 is a sort of template Fujitsu. witness statement document
18 that is provided and you sign
19 A. Yes.
20 Q. -- just to show that the extraction has been okay?
21 Ms Thomas not identifying duplicates in ARQ 447,
22 that's slightly problematic, isn’t it, to either
23 Post Office or an SPM that is trying to look at
24 anomalies and compare sources of data? That's not very
25 helpful, is it?
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1 A. Thestatement again is to verify the integrity of the
2 data once extracted and given. We don’t control what's
3 in the data, Our process is about extracting it and
4 securely passing it over to the Post Office. It’s not
5 our concern of what's in the data
6 Q It’s not your concern what's in the data?
7A. No, it’s whatwe're -- we're process-driven to extract
8 certain types of data for certain requests
9 Q. And so whether or not that might match another record or
10 not, or replicate or duplicate or have gaps, that’s not
1. part of your remit, that’s not really part of your
12 concern?
13. A. No, it’s not.
14 Q. I see. So reading that and reading the paragraph 8 as,
15 it wasin your witness statement, it doesn’t give much
16 comfort to somebody that’s then trying to rely on ARQ
17 data as being a gold standard to compare and investigate
18 anomalies, does it?
19 A. Possibly not
20 Q. Are you aware, Mr Dunks, of any other specific issues
21 with the retrieval of audit data that may have impacted
22 disputes between Post Office and subpostmasters or
23 subpostmistresses?
24 A. Not that I can -- not that I can recall would cause
25 those issues, no.
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rope
Could we please look at (F/829}. This is a PEAK,
PCO211833, and do you see under "Summary" it says:
“Audit Retrieval for ARQ Returns Missing Reversal
Indicator ”
Do you see that field?
Yes.
And then under “Impact Statement” in capitals
"Service on stop .. ARQ returns for HNGX
transaction records must stop until resolution
Analysis must identify returns which may require
re- retrieval ”
Do you recall a particular issue in terms of
reversals and audit retrieval?
No. At that time, Penny managed the ARQ retrieval
process and she -- that washer main priority and her
main job, so I wasn’t -- I wouldn't have been
1 wouldn’t have seen this issue, or been made aware of
these issues
You would not have been made aware of this issue at all?
No.
Even though you are the person that’s extracting data?
No. With our team we had a number of different roles
and audit extraction is one of those roles, which is
process driven, so -- and Penny would have managed that
via this PEAK. I wasn't aware of -- and if I was,
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I certainly don't remember.
And if we could go over to page 2 please {F/829/2}. Do
you see that bottom box there? If we look down at
“Impact on operations” -- well, if we start at the top
it say
“Specify the HNG-X platforms impacted”
Do you see that?
Yes.
And it says:
“The platform has been specified and it is the Audit
Server.
“Technical summary: the spreadsheets presented in
support of prosecution at court miss out an indication
as to whether or not a transaction is a reversal ””
And then further down do you see "Impact on
operations *
Yes.
‘There again it says:
“Spreadsheets supplied by the prosecution team miss
out an indication as to whether a transaction is
a reversal”
It says
“The prosecution team are well aware of the
problems; we hope to have a release out in a few days;
a KELis therefore not required.”
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1 Just over the page please (F/829/3}, and it says
2 "Risks (of releasing and of not releasing proposed
3 fix )
4 “There are few risks with this fix. It must be got
5 out or prosecution evidence is incomplete”
6 And then there is a description there of queries.
7 being changed in order to show reversals, and this is
8 taking place now this PEAK from -- August 2011 is when
9 this problem was identified, but you say you were never
10 made aware of it and presumably you weren't aware either
1. of queries being changed subsequently?
12. A. I don't recall this, no.
13 Q. Andonthe final page, please, of this document
14 (F/829/5}, there is a final message there saying:
15 “Fix deployed; all appears to be operating as
16 required. Closing call. Many thanks to all, Penny.”
17 So it is fair to say that up until August 2011, the
18 dara that you were retrieving did not have an indicator
19 as to whether or not reversals had taken place?
20 A. Correct, yes.
21 Q. Doyousee that as detracting somewhat from this being
22 a secure gold standard record to be compared with other
23 sources?
24 A. I honestly can’t say whether that has an implication on
25 that at all or -- that data missing has an implication
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1 on that at all, I don’t know.
2 Q. It’s not in your remit, it’s not in your concern?
3A. No, no.
4 Q. Were you in court on Monday when Mrs van den Bogerd was
5 being cross-examined?
6 A. Yes
7 Q. Did youhear a reference to something that was referred
8 to as the Helen Rose report?
9 A. Tdon't recall it but
10 Q. It’s a very short point I was going to make, but
1. actually perhaps it is fair to take the witness to the
12 document very briefly
13. MRJUSTICE FRASER: It depends what the point is, I suppose.
14 MRMILETIC: Well, the short point is this but actually it
15 might be, Mr Dunks, that you simply don’t know the
16 answer to this either, so the point that I was going to
17 make is that it wasn’t until the summer of 2013, at the
18 time of the Helen Rose report, that in actual fact it
19 was identified to be a problem that the reversal
20 indicator didn’t show whether it was system or
21 user-generated, but is that something that is outside of
22 your knowledge?
23 A. Yes
24 Q. Very well. I won't go to that point then:
25 So, Mr Dunks, having now canvassed through various
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documents and looked at various problems that existed
with ARQ data when it was retrieved, can you just
explain to the court why those things, or a semblance of
those issues were not set out candidly in your witness
statement?
>
Sorry, I don't understand,
Q. So wehave just been through several documents and
several issues in terms of when audit data is retrieved
and the problems in relying on that data, but none of
that is set out in your witness statement, and is there
a particular reason as to why that might be?
A. Again, the -- what! was trying to convey with our
witness statements, as I believe
the data once we have extracted it, and then supplied it
to the Post Office, and the controls around the
is the integrity of
extraction, not the data itself
QI see, so whatyou are not saying in your witness
statement is that the data then is accurate and reliable
in terms of use for disputes between subpostmasters and
Post Office?
A. No, I can’t say that at all
MR MILETIC: You can't say that?
My Lord, I have no further questions.
MR JUSTICE FRASER: Mr De Garr Robinson?
Re examination by MR DE GARR ROBINSON
‘That's fair.
n
MR DE GARR ROBINSON: Mr Dunks, I would just like you to
look at your witness statement please, paragraph 8. You
were asked a question about this paragraph and you were
asked -- it was suggested to you that you didn’t really
think about that paragraph much and I would just like to
take you through it (E2/10/3}. In the first sentence
you say:
“There is no reason to believe that the information
in this statement is inaccurate because of the improper
use of the system.”
Mr Dunks, is that sentence true or is it not true?
A. It is —- well, it’s true. I don’t believe -- there's no
reason to believe that it is inaccurate at all
Q. And did you think about that sentence when you signed
the statement?
A. It wasn't in the forefront of my mind when I was signing
the statement, no.
Q. The next sentence:
“To the best of my knowledge and belief at all
material times the system was operating properly, or if
not, any respect in which it was not operating property,
or was out of operation was not such as to effect the
information held within it”
Is that sentence true?
AL Yes.
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Q. Would you have signed this statement if either of those
sentences had not been true?
A. No.
‘MR DE GARR ROBINSON: Thank you.
Questions by MR JUSTICE FRASER
MR JUSTICE FRASER: Ihave just got a question.
You started doing your current role in 2002, is that
right? I think it is in paragraph 3, you say.
A. I have worked within this team since then, but the roles
have changed within that over that period of time.
MR JUSTICE FRASER: What were you doing before 2002?
A. Iwas there were different roles again within then
ICL, from desktop support, et cetera
MR JUSTICE FRASER: And when did you start at ICL, do you
remember?
A. Good question. About 21 years ago.
‘MR JUSTICE FRASER: 1998?
AL Yes
‘MR JUSTICE FRASER: You are trying to catch me out with some
mental maths.
I don’t have any questions other than that.
I assume there's nothing arising out of that. Thank you
very much for coming, you can now leave the witness box.
MR DE GARR ROBINSON: My Lord, I call Torstein Godeseth.
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MR TORSTEIN OLAV GODESETH (affirmed)
MR JUSTICE FRASER: Have a seat, Mr Godeseth.
Examination-in-chief by MR DE GARR ROBINSON
MR DE GARR ROBINSON: Mr Godeseth, there's a bundle of
documents in front of you. Could I ask you to go to
divider 1 of that bundle please (E2/1}. This is
a document that describes itself as a witness statement
by you.
page?
AL It is
Q. And if you go to the last page, page 20 {E2/1/20}, is
Is that your name and address on the first
that your signature?
A. It is, my Lord.
Q. If wecould go on to tab 7 in the same bundle, please
{£2/7}. 1 believe you will see a page with two
corrections, is that right, at the front of that tab?
AL Yes
Q. And then over the page, there is another witness
statement by you and again, there’s your name and
address on the first page, isn’t there?
‘That's right.
And page 18 (E2/7/18}, that’s yo
It is.
Signature, is it?
ope
And then there's a third statement which should be
behind divider 14 of the bundle {E2/14}. Again, your
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name and address on page 1, and on page 7, is that your
signature? {E2/14/7}
AL It is.
Q. Now, the later statements clarify and in some respects
correct matters that are set out in the earlier
statement. Subject to those clarifications and
corrections, and subject to the two corrections you saw
in the front sheet at tab 7, do you confirm that these
witness statements are true to the best of your
knowledge, recollection and belief?
AL Ido.
Q. Now, Mr Godeseth, I've got a question I would like to
ask you arising from evidence that’s just been given by
Mr Dunks, and with your Lordship’s permission ..?
MR JUSTICE FRASER: Yes.
MR DE GARR ROBINSON: If we could go to (F/1716} please and
could we go to page 43 of that document (F/1716/43).
‘This is a Fujitsu document. It’s the Audit Extraction
Client User Manual
AL Yes.
Do you see that?
Q. Now, just remind me, how long have you been working for
Fujitsu?
A. Since 2010.
Q. And since that time, have you had any familiarity with
the audit extraction process and its reliability and so
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on, and is:
surrounding it?
A. [have clearly been aware that audit extracts have been
happening, but I have not been intimately involved in
that process until more recently.
Q I see.
the page it says:
I would like to ask you about -- at the top of
TMS and BRDB messages are numbered in sequence for
each node, During filtering any retrieved audit message
data is analysed to determine what message sequences are
present in the data and whether there are any gaps or
duplicates in those sequences. A gap in a message
sequence may indicate that a message is missing from the
audit data. Duplicates may indicate that an audit file
has been gathered twice.”
1 would just like to ask you a couple of questions
about that. If there had beena gap in a message
sequence during the extraction process that’s described
here, is that something that you would know about?
A. I believe so, yes, because it would bea highly serious
problem.
Q. Andean I ask you whether there have been any such gaps
during the time that you have been at Fujitsu?
A. I’mcertainly not aware of any, and I’m confident that
1 would have been told
Q. Very good. And then moving on to the next sentence, the
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duplicates
duplicates: what would have happened? Would you be
aware if there were any duplicates?
Could I ask you the same question about
Having seen Gareth’s statement, I would say that
duplicates are probably being misinterpreted here,
because if a record goes into the audit trail twice it’s
simply two copies of the same record. As long as that's
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dealt with, I don't think that’s a problem,
9 MRJUSTICE FRASER: When you say duplicates are being
10 misinterpreted here, do you mean in this document, in
1. Mr Jenkins’ document, or in what you are being asked?
12. A. I think here the issue is -- I clearly understand that
13 the claimants are interested, my Lord, in whether
14 transactions got duplicated, and I think what goes into
15 the audit is a record which has come from a counter,
16 different mechanisms in Riposte and also in the newer
17 Horizon system. 1 think whatMr Jenkins is referring to
18 is that a record can be written to an audit trial twice
19 and as long as you spot that and you deal with it,
20 that’s fine, because it is simply saying, it is
21 simply: 1 wrote down the same thing twice. And the
22 circumstances in which I have some recollection of is
23 that the audit trail got written to Bootle and to Wigan,
24 our separate data centres in the days of Riposte, so
25 clearly I would havea copy of a record in both Bootle
7
1 and Wigan,
2 MRJUSTICE FRASER: I'm not sure that necessarily answers my
3 question.
4A. Sorry, my Lord.
5 MR JUSTICE FRASER: When you said duplicates are being
6 misinterpreted, do you mean misinterpreted in this
7 Fujitsu document, interpreted insofar as you understand
8 what Mr Jenkins is saying, or misinterpreted in the
9 question that Mr De Garr Robinson asked you?
10 A. I think here I'm saying that duplicates may indicate
11 that an audit file has been gathered twice is --
12 MRJUSTICE FRASER: When “here” you mean the Fujitsu
13 document?
14 A.
15 consistent with what Mr Jenkins said in his statement.
16 = MRJUSTICE FRASER: I see.
17 MR DE GARR ROBINSON: "The suggestion here that duplicates
18 may indicate that an audit file has been gathered
19 twice” -
20 MRJUSTICE FRASER: That's what it rs in the paragraph.
21 MR DEGARR ROBINSON: Yes, I have just read out the
In this Fujitsu document. I think that is entirely
22 paragraph, 1 don't know why I did that. If duplicates
23 were being produced in audit extractions, is that
24 something with which Fujitsu would be interested to
25 know?
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A. I think it is important to go back to understand what
the audit trail is looking to do, and I think 1 would
like to start by describing the Horizon Online system
which I'm more familiar with, and the audit trail in my
book is I’m trying to write down, transaction by
transaction what is coming from a counter and I am
keeping a record of effectively the transaction as
entered at the counter as closely as I can possibly make
it
In the Horizon Online, the big protection there is
a thing called the JSN which is the Journal Sequence
Number, and we use this to indicate that -- or to prove
that I have not missed any records and I haven't got any
duplicates. So built into the system at the BOWL(?), we
get a sequence of messages coming up from the counter to
the BOWL, and these all have a JSN in them, and these
are checked to make sure that they just increment by
one.
In the Riposte system, there was a very similar
concept, but this was the message number on the messages
coming froma particular counter, and again, by checking
that I've got a -- whatwe call a dense list which says
I've got every number accounted for, and I -- if I have
duplicates, and they both say the same thing, that is
just the fact that I have written something down twice
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and I imagine from what I have read in Gareth’s
statement that this obviously happened in Riposte days
when there were data centres in Wigan and Bootle and
I know that audit trails were written in both centres,
but I think by then saying "Okay, I have now written
some things down twice, but I can recognise those
because they have the same message number", they are
simply copies of the same thing.
MR DE GARR ROBINSON: My Lord, I'm at the margins of my own
understanding of the system and think I had better
stop now.
MR JUSTICE FRASER: Well, I'm actually just go to pursue
this on your behalf, because your question was quite
simple and it has led to an answer of about a page and
a quarter, so I’m just going to ask the same question.
What Mr De Garr Robinson asked you was if duplicates
were being produced in audited extractions, is that
something that Fujits would be interested in knowing?
And I’m unclear as to what the answer is
A. Yes. Sorry, yes, my Lord.
MR JUSTICE FRASER: The answer is yes?
AL Yes.
have to explain it
MR JUSTICE FRASER: Right.
If you want to ask a follow-up question,
We would be interested in knowing because we would
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Mr De Garr Robinson, you can do so
MR DE GARR ROBINSON: Are you aware of -- since your time at
Fujitsu -- I’m notasking you about Legacy Horizon now,
but since your time at Fujitsu, are you aware of this
issue having arisen in relation to extracting audit
data, duplicates?
A. No, my Lord.
‘MR JUSTICE FRASER: Mr Green, your turn.
Cross-examination by MR GREEN
MR GREEN: Iwill start at the beginning of your statement,
if I may,MrGodeseth. If we canlook at (E2/1/1). You
explain in paragraph 1 that you are employed at Fujitsu
Services Limited as the chief architect on the
Post Office account.
A. 1 am, my Lord.
Q. And you say you are authorised to make this statement on
behalf of Post Office Limited in the proceedings
right, isn't it, that you were first employed by
Post Office?
It is
A. I was employed by Post Office from 1987 for a number of
years
Q. Let's have a look at paragraph 5 of your witness
statement please.
Can we get {E2/1/1}, please.
Sorry, I think we've got the wrong
one there,
Just look at paragraph 5 on page 1 to start with
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(£2/1/)
the bottom of the page, after leaving the Royal Navy you
You give your employment history there and at
joined Forward Trust in November 1981 to work in systems
programming and technical support for their IT systems.
‘Then if we go over the page:
“I joined the Post Office IT department
in November 1987 to work on a project to introduce
technology into Post Office branches.”
What project was that?
A. I know it as the Thames Valley pilot. It was a project
to introduce -- we supported three products in those
days, it was Girobank, DVLA and National Savings,
a pilot in the Thames Valley area which had about 250
offices .
Q. Then at paragraph 6 we see you worked as the technical
advisor to Post Office when they and the Benefits Agency
procured the Horizon system.
A. That's correct, my Lord.
Q. It was unusual asa project; it was being procured by
two different government bodies, wasn’t it?
the Department for Social Security, Benefits Agency, on
the one side and then there was Post Office at that time
‘There was
under Royal Mail on the other?
A. That's right, my Lord,
Q. And latterly you were then technical advisor to
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Post Office when Legacy Horizon changed to
Horizon Online?
Correct.
And then from 2010 you then moved from Post Office to
Fujits.
1 did, yes
What occasioned that move?
I was working asa contractor for Post Office. My
contract came to an end, and I joined Fujitsu on
contract.
But when you say “as a contractor”, do you mean as an
independent contractor
Yes.
rather than employee?
I joined Fujitsu initially as a contractor and then
in November, laccepted a full -time role
And just so we havea vague idea, for what proportion of
your time with Post Office were you employed, and for
what proportion of the time were you an independent
contractor?
I became an independent contractor in 2005, just as
Impact Programme was going live.
Just as ..?
‘The Impact Programme was going live.
Can you explain to the court what the Impact Programme
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was?
The impact -- the major change in the Impact Programme
delivered was to take out the old cash account and
replace it with branch trading statements, but there
were a few other changes implemented at the same time.
Now, you effectively have worked for both Post Office
and Fujitsu_and have been involved in pretty much the
entire history of the Horizon system in different ways,
haven't you?
1 was — pretty much, but I was not involved in the
early days of the roll-out of Horizon, so when
1 finished my stint on the procurement, I worked
elsewhere in the Post Office, then came back to
Post Office counters to deal with banking and since then
I think my time has been pretty much with Post Office
counters. I hada break in 2009 before coming back for
a short contract with Post Office counters and then
joining Fujitsu
Right
so forth in a minute, but just clarifying the
construction of your witness statement, your first
witness statement which we're looking at, which is the
We will come to the introduction of Horizon and
one of 27 September 2018, broadly covers the accuracy of
audit data and the issue of remote access for both
Legacy Horizon and Horizon Online, is that fair?
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It is, yes.
And at paragraph 7 of that witness statement {E2/1/2},
if you just look at that for a moment, do you see at the
bottom of that paragraph it says:
“I therefore have consulted with colleagues who work
in the areas that are covered by this statement to
ensure that my understanding of them is correct.”
Which were the areas that you were referring to
there?
Basically any area that I wanted to just double check,
s0 I don’t see it as anything specific. I work with
a number of people and if I’m uncertain of anything, or
just want to check up, then I would talk to them,
So you were sufficiently uncertain about certain things
to have to go and speak to a number of your colleagues?
1 wouldn't say “uncertain
checking
Who were the colleagues you spoke to?
Off the top of my head, would say Steve Parker and
It is due diligence, double
a couple of guys in his area; Pete Jobson,
Gareth Seemungal, Alan Holmes, Jon Hulme.
Could you just help the court just in relation to each
of those, what were the aspects they were contributing
to your statement, could you just explain?
In Steve Parker's area, certainly there are people who
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have longer
worked. Gareth Seemungal,I talked to about BRDB and
or recollections of how Riposte actually
how Oracle works. Pete Jobson I talked to about how
batch systems work. Alan Holmes knows a fair amount
about audit. Jon Hulme, knows the counter pretty well
Right, that’s helpful. Let's look at paragraph 34
please on page 11 (E2/1/11}. We see there “Audit data
Legacy Horizon”
You say:
“In Legacy Horizon Riposte, a messaging system, was
responsible for storing all data in Post Office branches
and replicating it to data centres
As I was on ‘the
other side of the fence”
Because you were working with Post Office at the
time:
when Riposte was in use I have consulted with
my former colleague, Gareth Jenkins, to prepare this
section of my statement.”
Yes?
Yes.
And in fact we see Mr Jenkins’ name ina number of other
paragraphs throughout your witness statement?
Yes.
And it is fair to say that really the source of that
information that you're giving is Mr Jenkins, isn’t it,
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because you were working for Post Office at the time?
I feel I hada pretty good knowledge of how Riposte
works, since I needed it when I was working on Impact,
but it’s absolutely the case that I would get more
detailed information from Gareth.
Because in a number of paragraphs -- 1 mean, just give
us a couple of examples, At paragraph 38 you say:
“I understand from Gareth that each message included
three key pieces of information...”
And if we go to paragraph 39, over the page
{E2/1/12}
“I also understand from Gareth that messages also
had an associated "Expiry Date’ ..”
Paragraph 41:
“I understand from Gareth that due to the size of
the Post Office network [they] were split into four
separate clusters
Ando forth. Paragraph 43:
“I understand from Gareth that the audit application
read every record that was visible to the correspondence
server...”
Paragraph 44 {E2/1/13}
“I also understand from Gareth that once these files
had been written they became visible to the audit server
which would pick them up ..”
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I'm obviously not going to keep going, but that's.
information you have obtained from Mr Jenkins, isn’t it?
It’s difficult to judge how much I knew beforehand, but
certainly talking to Gareth has freshened up my
understanding of it
I suggest to you it is mostly Mr Jenkins’ explanations
to you which you seem to think
1 would certainly regard Gareth as an expert on Riposte,
having far more knowledge aboutit at a practical level
than I have.
He is the most obvious person to talk about it in
a sense, isn’t he?
Yes.
And let's look, if we may please, at page 16 of your
first witness statement (E2/1/16}. This falls under
a heading called “Balancing Transactions” which has been
given an acronym of "BTSs",
Yes.
We will come back to that. But just for the moment,
just to orientate you where you are in the statement, if
you look -- I'msorry, Mr Godeseth, I didn’t spot you
didn’t have any water.
(Pause).
Just to orientate yourself in the witness statement,
you've got
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“A small group of Fujitsu users from the Software
SupportCentre .. (30 users) have the ability to inject
additional transactions into a branch's accounts in
called a Balancing Transaction”
Now, pausing there, we heard Mr Roll being
cross-examined and it was suggested to him that within
si
9 experience Mr De Garr Robinson went into with Mr Roll,
1
2
3
4 Horizon Online, using a designed piece of functionality
5
6
7
8
there were about 25 members who were -- whose
10 and then five sort of super elite members, as they were
1. described by Mr De Garr Robinson.
120 A. Mmhm.
13° Q. That's a total of 30. Is that about the same size as
14 the department is now? Is 30 users the whole of SSC?
15 A. I wouldn’tknow. Steve would be able to give a far
16 better — but I -- 1 think there was about that number
17 of people there, yes.
18 Q. So Mr Parker would be the person who knows, and you
19 think it's probably about the whole of SSC?
20 A. Yes.
21 Q. So when we just look at the words:
22 “A small group of Fujitsu users from the Software
23 Support Centre.”
24 It’s actually probably the whole or most of the
25 Software Support Centre?
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1A. Mmhm.
2 Q. Everyone, it looks like?
3. AL Yes:
4 Q._ If wecome down to paragraph 589, just go over the page
5 (£2/1/17}, that’s -- that all seems to be dealing with
6 Horizon Online and then at 58.10 you say:
7 "In Legacy Horizon, any transactions injected by SSC
8 would have used the computer server address as the
9 counter position which would be a number greater than
10 32, so it would be clear that a transaction had been
1. injected in this way”
12 Yes? That's what you said in that first witness
13 statement.
14 A. That’s what I said in that statement, correct.
15 Q. Now, just pausing there, you don’t say who you got that
16 from, but did that come from Mr Jenkins?
17 A. Yes. The greater than 32 came from Mr Jenkins, correct
18 Q. So wecould write in there "I understand from Gareth"?
19 A. Yes.
20 Q. Andin fact if we go back to paragraph 36 on page 11
a1 {E2/1/11}, it is effectively mirroring the overall
22 description that the node ID associated with an injected
23 message would be that of the correspondence server at
24 which the message had been injected, and not a normal
25 counter node ID, and therefore would have been clearly
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visible in any audit data.
Yes.
‘That's the same point but without using the number 32,
yes? It’s a broader point, but it captures the point
that you're making in 58.10 and is consistent with ic
‘There were a number of mechanisms for the-- I think the
preferred route for injecting any transactions would
always be to do it at the correspondence server. There
were occasions where it was necessary to inject messages
at the counter. I think that was the point that Mr Roll
was making in identifying that messages had to be
inserted to correct problems at the counter, and there
are a few instances where clearly that happened.
Yes. Ando can I just ask you, did you get this
section in 36 also from Mr Jenkins, broadly?
Yes.
And then just going forward in your third witness
statement at (E2/14/7], paragraph 25 -- I’m so sorry.
If you look at paragraph 25 you say:
“In paragraph 58.10 of my first statement I stated
that any transactions injected by SSC in Legacy Horizon
would have used the computer server address as the
counter position which would be a number greater than
32. I have read Parker 2 and I am now aware that it was
also possible for SSC to insert transactions with
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a counter position with a number less than 32. I did
not discuss this in my first statement because I was not
aware of it”
That's correct.
So at what point did you realise that it was not
correct?
When it was brought to my attention at the time that
Steve was preparing his second statement.
Were you a bit shocked about that, to find it was wrong?
“Shocked” would be too strong a word. It was -- I was
finding out a detail that I didn’t know before.
You were finding out a detail that you didn’t know
before in quite a controversial area, weren't you?
It was clearly an area that was going to be of interest
because of the fact that we were inserting transactions
into Riposte. It wasan operational necessity and it
was done ina controlled way. I had believed that the
way that transactions were being injected would give
them a counter position greater than 32 because the
correspondence servers basically had nodes or addresses
which were above 32, there was a special address for the
gateway server, there wasa special address for the
extra dise in a single position branch andI had
basically expected messages to be introduced using
a different counter position and having read a whole
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Q.
A
number of PEAKs,I can quite clearly see that the
standard practice in Fujitsu was to label something
which was being inserted into Riposte so as to make it
as clear as possible that it was not being done— it
was being done as something out of the ordinary, it was
being inserted because of a problem.
So we had techniques for doing that. You could put
in an attribute because this wouldn't be visible to
a subpostmaster, I fully understand that, but it would
be visible in the audit trail , when you ever come back
to pull out the audit trail, you could put in an
attribute to say “This was done under PEAK 75°
Subpostmasters would never see that. They would not see
it in their account in their branches and I’m fully
aware that that is the case. It wasa better audit than
Mr Roll was alluding to when he said that it was left in
a PINICL, because that would have been an audit which is
separate from the actual data that we would be looking
at should we ever need to pull stuff out of the audit
trail and the intention was always to makeit as clear
as possible that this had been done under exceptional
circumstances.
‘The techniques used to makeit as visible to the
subpostmaster as possible would be to put in references
which referred to a counter that didn’t exist in the
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branch, such as -- I sawa technique described in
a number of cases which said put in a -- you know, if
you are correcting something for counter 1, call it
counter 11; if you're correcting something for counter
2, call it counter 12. These things would have been
visible to a subpostmaster and the reason that you had
to do it that way was to make sure that these
transactions also got picked up and dealt with because
these were legitimate counter numbers.
If I start to put in data with a number which is not
a legitimate counter number then it’s going to be
ignored by systems further down the track
So which were legitimate counter numbers?
Up to 32
Right, so you say less than 32 in your witness statement
at paragraph 25
Sorry, I may have got that
whether 32 was a legitimate
the boundary was at 32;
Don't worry about that. That's not -- that’s not
counter or not, I don't know.
‘MR JUSTICE FRASER: Please don’t talk over each other.
MR GREEN: I'm so sorry.
Don't worry about the boundary. So the short point
is that you learned, when Mr Parker was preparing his
second witness statement, that it wasin fact possible
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to inject transactions which a subpostmaster would not
know about at the counter rather than at the
correspondence server, you learned that for the first
time?
1 cannot see how a subpostmaster would not have been
aware of these transactions being injected, because
there's a technical rationale why the subpostmaster had
to be in his branch -- sorry, it didn’t necessarily have
to be the subpostmaster, it had to be somebody in the
branch who was logged on when these techniques were used
to inject transactions at the counter and the simple
reason is that if you didn’t have somebody logged on,
then Riposte would have generated a message with a blank
user ID. Riposte was responsible for actually wrapping
the message that we were looking fo insert at the
counter, and in doing that, Riposte will tell you the
counter ID, or technically it wasa stream, it would
pick up the user ID, it would pick up the time, so this
was effectively the envelope which wrapped the payload
that we were looking to inject .
If there was no user logged on at the counter then
Riposte would introduce a blank user ID and that would
be picked up in later processing.
But let's take it in stages, if we may.
MR JUSTICE FRASER: Just before you do.
A
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Mr Green is going to be putting quite precise
questions to you. I knowit’s an understandable human
reaction to want to argue wider points, but I would like
you to listen to his questions and answer his questions
please.
Yes, my Lord.
MR JUSTICE FRASER: Right, Mr Green,
MR GREEN: Can we separate what you can do from what you
have inferred was done in many cases from PEAKs you have
looked at, and let's focus on what could be done.
You realised for the first time that it was possible
to inject or insert a transaction with a counter
position less than 32 when Mr Parker was preparing his
second statement?
Correct.
And you knew that that was a contentious issue in this
litigation , yes?
Yes.
And if we can go back please to paragraph 58.10 of
(£2/1/16}. Go over the page please to 10 {E2/1/17}
there it says:
“In Legacy Horizon, any transactions injected by SSC
would have used the computer server address as the
counter position which would bea number greater than
32, so it would be clear that a transaction had been
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injected in this way”
Can we go back to the previous page just to get the
introduction to that {£2/1/16}. It's not immediately
clear from this part of your statement that you got that
information from Mr Jenkins, is it, 58.10?
Sorry, I'mlooking at 58.7 here?
Yes, I'm just showing you~
I agree, yes
So what had actually happened to you is that you had had
a conversation with Mr Jenkins, he had given you the
information on a contentious point in the litigation ,
and youhad repeated it in a way that could be read as
sounding as if you knew aboutit yourself?
That was certainly not deliberate.
No, but I’m just saying that is whathad happened?
I can accept that
And then you found out that was wrong. Did you go back
and talk to Mr Jenkins about it?
I don't think I have, no
Were you not interested to find out from him directly
whether they always used counter numbers other than
those in use by the SPM, rather than inferring matters
from PEAKs as you have suggested?
I have not discussed it further with Gareth.
So you are not in a position to comment on that beyond
97
what you have inferred from the PEAKs?
I think that’s fair, yes.
Now, it would be possible, would it not, to use
a counter number of 1, or 2, or 3?
It would,
And if that counter number was a counter number actually
in use by the SPM, it would appear to the SPM, from the
records they could see, that it wasa transaction which
had been done in their branch, by them or their
assistants?
Yes.
Now, you were at Post Office at the time that
Legacy Horizon wasn use, weren't you?
I was certainly at the Post Office when Legacy Horizon
was in use.
You hada break, I think you mentioned earlier. Was
that around 2009?
In 20091 finished my contract with Post Office counters
in roughly June, and went back to Post Office counters
in the following January, so I hada six-month gap.
And apart from that were you continuously working for
Post Office from 1987 to when you left and joined
Fujitsu?
No. I think it’s covered in my opening statement, that
I was - from Post Office I was outsourced to a company
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called Xansa, and then after a couple of years
probably two and a half years at Xansa, I decided to go
independent.
So when you were outsourced to Xansa
1 continued in roughly the same role.
you continued
Royal Mail IT department outsourced, or were you
did you remain an employee of
outsourced so that you went and worked for someone else
with a direct relationship with them?
I was outsourced from Royal Mail to Kansa as part of
a rationalisation programme, so therefore I was employed
by Xansa, 1 was paid by Xansa.
I understand. So apart from that period and the short
break you had in 2009 that you have described, the
six-month break which began in 2009, you were at
Post Office effectively throughout the period from 19872
1 was at Post Office, 1 was working actively on the
Post Office account for most of that time, but, as
I say, once the procurement of Horizon with ICL Pathway
had come toa sensible juncture, I did spend some time
working with other parts of Post Office, Parcelforce,
the Television Licence Agency and such. So there was
a gap in my time alongside Post Office counters.
In the light of your time and position and role within
Post Office, would you have been regarded as
99
a knowledgeable person within Post Office about whether
remote access of the type we're talking about was
possible?
I believe I would have been regarded as a knowledgeable
person.
Very knowledgeable?
Yes, I would like to think so.
And it is your evidence to the court that you were
completely unaware that inserting transactions in this
way was possible throughout your time at Post Office?
‘To be honest, 1 wouldn't have actually thought about it.
If you are looking to supporta large system, then
I think the logical conclusion is it’s inevitable that
you have to do this sort of thing on occasion.
So if you had been asked whether it was likely that it
would be possible, you would have said
Yes.
it’s inevitable because it's a large system?
I think so, yes.
So were you a bit surprised when Mr Jenkins told you
when you were preparing your first witness statement
that it would not be possible to do it unless it was
done just to the correspondence server?
1 don't think he told methat. I think that is his --
his description to me was afar more generic one rather
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than going into that level of detail
Q. But wasn't the key point that you were giving evidence
about whether or not it would be identifiable as not
having been done by the subpostmaster?
A. I think we were really talking about messages coming in
at the correspondence server which would therefore be
very different from the ones coming from the counter
which would have the lower counter numbers or node
numbers,
Q. The short point is, Mr Godeseth, that your original
witness statement was -- paragraph 58.10, if we can just
look at that finally {E2/1/17}
clearly designed to suggest that it would not be
possible to insert transactions as Mr Roll was
suggesting, wasn't it?
A. I don't see that as the intention at all
Paragraph 58.10 was
1 think there
I was looking to describe -- I think the intention was
to describe that transactions injected by the SSC would
be different from transactions done by the counter.
Q. Well, that’s not quite what you say. This is my last
question on this, I think. You say:
“In Legacy Horizon, any transactions injected by SSC
would have used the computer server address as the
counter position which would be a number greater than
32, so it would be clear that a transaction had been
101
injected in this way”
AL Yes.
Q. Youwere specifically ruling out injection of
transactions in a way that the subpostmaster could see,
weren't you?
‘A. Sorry, could you repeat the question?
Q. That form of words you have used was specifically ruling
out the injection of transactions in a way that
a subpostmaster could not see?
A. I think there are too many negatives in this
Q. The effect of what you were saying there was that any --
wecan read “all” -- transactions injected by SSC would
have hada number greater than 322
AL Yes
Q. And that would makeit clear that a transaction had been
injected?
AL Yes
Q. What you were trying to say by that was it was not
possible for transactions to be injected which would not
be clear that they had been injected?
‘A. I would still say that transactions that have been
injected are clearly identifiable , albeit there may bea
convoluted route to identifying them.
MR GREEN: My Lord, is that a convenient moment?
‘MR JUSTICE FRASER: I think it probably is. We will come
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back at 2 o'clock.
Mr Godeseth, you are in the middle of giving your
evidence so you're not allowed to talk to anybody about
the case over the short adjournment. Come back at
2 o'clock.
(1.03 pm)
(The luncheon adjournment)
(2.01 pm)
MR GREEN: Mr Godeseth, can we look at the introduction of
Horizon itself , paragraph 6 of your witness statement at
{E2/1/2}
advisor in the procurement of the Horizon system and
We have mentioned already you were technical
touched on the fact that it was unusual because it was
two different government entities
It was not uncontroversial, this project, at the
time, was it?
A. Sorry, it was-- certainly it was an interesting project
to be working on, so I'mnot sure...
Q. Well, let's take it in stages. It encountered quite
a lot of difficulties as a project, didn’t it?
AL Yes.
Q. And its sort of birth as a system was not entirely easy,
is that fair?
A. I think that probably the relationship between Post
Office, Benefits Agency and the contractual situation is
103
fairly well-known, yes.
Q. And if you can very kindly look at {F/70} as an example.
This is a Computer Weekly article, 1 November 2000, and
you will see there it says:
“The infamous 1996-1999 Pathway project aimed to
computerise the nation’s post offices and tackle benefit
fraud, But 18 months later, after losing millions and
destroying reputations a credible IT project has
emerged?
So although, as we will see, the problems were
well-known, as you have fairly accepted, a credible IT
project did emerge from it?
Mm-hm.
Which was what we now know as Horizon?
Yes.
oPror
And the article then, in paragraph 2, notes:
“It was one of the largest roll outs in Europe-..
despite its complexities, it is now running smoothly, on
time and to budget”
‘That was the impression they had. And the NAO had
had some concerns about money wasted on the aborted
attempt for the swipe card system, yes?
A. I mustadmit! have no recollection of what the swipe
card system would have been, but
Q. Doyou remember that the focus of the project changed as
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it went along? It was originally going to be very high
levels of security for the direct payment of Social
Security benefits through the system and then in the end
the DSS pulled out and
I certainly recall that the Benefits Agency pulled out
Anda deal was done with Fujitsu to carry on with just
the Post Office -
Yes
as a contracting party. If we look at the reason
that the Select Committee on Trade & Industry was
looking at it in July 1999, if we look halfway down the
page you will see
“Ata hearing of the Select Committee on Trade &
Industry in July 1999, two months after deciding to
cancel the swipe card, and causing massive monetary
loss, three cabinet ministers leaned heavily towards
blaming the supplier, ICL Pathway, for the disaster.”
Now, there was -- I think you have hinted at it,
that the relationships were not very easy, is that
a2
‘There were some very fascinating tensions going on, yes.
Yes. And there was some dispute over the terms on which
Fujitsu would carry on with a project that they had
anticipated and agreed would be both for two clients
essentially , with just one?
105
Yes.
And so the deal that was done with Fujitsu at that stage
‘was one which in some senses compensated Fujitsu for
losing the DSS?
I can’t comment on that. I didn’t know about the
contractual situation at that point
Now, in your paragraph 12 you say Fujitsu began a pilot
of the system in 1996 and it was rolled out across the
Post Office network between 1999 and 2000. Ar that
stage, the pilot was still for the Post Office and the
Benefits Agency, wasn't it?
I honestly don’t know. The objective of the original
Horizon system was very much to replace what was then
the mechanism for issuing pensions and such-like, which
was an order book, you would get 13 slips in it and
so my recollection is that this was what we were looking
to replace
And if we goto (F/3) please. That is the ICL Pathway
‘Technical Environment Description, do you see that?
Yes.
At that stage I think ICL -- Fujitsu hada majority
shareholding in ICL, but only became a 100% shareholder
in 1998, is that right?
I honestly don’t know.
You're not sure, no, If we look at page 9 of that
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document please (F/3/9}, we can see references there.
A. Sorry, I’m looking at page 8 at the moment.
Q. Oh, you should have page 9.
MR JUSTICE FRASER: I think you are looking at page 9.
‘A. Okay, at the bottom it says
MR GREEN: Internal page 8 at the bottom, but at the top,
electronic page 8 -
MR JUSTICE FRASER: No, electronic page 9.
MR GREEN: I'm sorry, electronic page 9.
“References”, you can see who was involved there.
If you look at the bottom of the references you see
“Agent Architecture - Gareth Jenkins ”
Yes.
Is that the same Gareth Jenkins we have been mentioning?
Yes.
oreor
And if we look at page 92 please [F/3/92}, you will see
under the heading "Migration":
“This section describes the mechanism by which the
Outlets that take part in the Limited Go Live will be
integrated into the Pilot Roll-out.”
So there were two sort of phases of that, weren't
there?
A. Again, I don’t have any personal recollection of this
because I wasn’t involved at that time.
Q. You didn’t have any involvement in this bit?
107
A. No, no, no, for the actual roll-out of it, I was not
I was off doing other things
2
What were you doing at that time?
>
Parcelforce, SSL, as they were known, who were the TV
licence guys in Bristol, Post Office Group.
Q. Okay. Let’s just look under “Background” you will see:
"The 10 Outlets that take part in the ~.. Go Live
use early versions of the solution. This includes the
counter PC.”
Which we now know as the Horizon terminal?
A. Yes.
Q. “the BPS application suite
What's that?
I don't know.
Might it be business process systems? You don’t know?
It could be, but I
“Riposte etc"?
Riposte I recognise, the rest I don’t
Okay. And if we go please to {F/3/92} -- sorry, I think
we may have a misreference there.
Let’s go to (F/299} please. Now, this is a document
that begins the migration to Horizon Online
AL Yes.
orporeor
Q. -- and what's contemplated. Pausing there, by the time
you were advising in relation to this, you were aware
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that there had been a number of problems with the old
legacy system that we have seen in many of the PEAKs.
HING-X was very much geared -- or HNG as it started
off -. was geared at refreshing the solution. I don't
remember it being seen as fixing a whole load of PEAKs,
it was simply seen as refreshing the system.
Yes, but pausing there, I -- my question is quite
specific .
Sorry.
Did you have any awareness of any problems that had been
encountered with Legacy Horizon by the time that you
were advising in relation to migration to
Horizon Online?
1 will have been aware of some at the time but
I honestly cannot remember any major issues that I was
dealing with, but because of the work I was doing,
because I was having to ensure that Post Office could
continue to deliver change and whatever, I would have
been aware of it, yes, certainly
Okay. So important PEAKs would have been drawn to your
attention under Legacy Horizon, you think?
I believe so, yes.
And when we look at the aims of the HNG-X plan, this is
dated 21 September 2005?
Yes.
109
Can we look at page 10 please {F/299/10}. This is
a document that you would have known about, isn’t it, in
all. likelihood?
I was certainly involved at this stage, yes.
And you will see that the
“While Post Office has considerably increased
under 1.4 you will se
expectations on cost reductions, the organisation has
also become substantially more open to operational
changes. Post Office has clearly indicated that
aspirations to a more retail -type IT spending are
matched with the acceptance of more retail -type
operational practices ”
And then:
“The original business case for HNG within
Post Office was based ona balance of cost reductions
and improved capabilities. The new business case is.
almost entirely based on cost reductions”,
Now, that was accurate at the time, wasn't it?
I didn’t write it, but I’m not going to argue the case.
And if we look at page 13, paragraph 3.1.1 (F/299/13} we
see under “Assumptions”:
“The fundamental assumes is that Post Office will
accept a solution based on the business capabilities
that the solution provides and will not insist on being
involved in the technical and technology aspects. This
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will require Post Office to fully engage with suitable
empowered personnel in these initial stages and to have
in place assurance and decision-making processes that
align with the time/cost boxed programme milestones”
Now, just pausing there, effectively what is being
said is that Post Office was not insisting on being
involved in the technical and technology aspects, is
that correct?
Certainly it was looking for a more arm's length
relationship, sir, yes.
Amore .2
Arm’s length, 1 think.
Arm’s length?
Yes.
If we look at page 16 of this document please
(F/299/16}, do you see under 4.0 “Business
Applications ”
Mm-hm.
“In order to reduce the overall application development
costs within HING-X, substantial reuse of data centre
application components is proposed.”
Yes.
That's correct, isn’t it?
Yes.
That's what was proposed and what was done:
au
“The Legacy Host database applications (TPS, APS,
LFS, DRS and TES) are to remain largely intact ”
Can you remember what they were?
TPS is transaction processing system, AP is automatic
payment system, LFS is logistics feeder system or
service, DRSis data reconciliation service, TES is
transaction enquiry service.
‘Thank you. And they were remaining largely intact
“The online interfaces (~... Banking Streamline and
ETU)~.."
What was ETU?
ETUis electronic top-up. It's paying for your mobile
phone.
".. will be modified to provide a Web Service interface
in place of Riposte messaging together with
a simplification of the security mechanisms”
Yes.
That's a fair summary of the matters that it deals with
there?
Yes, 1 think so.
Now, that was recycling quite a lot of application
components, wasn’t it?
Yes.
And if we look at page 23 of this document {F/299/23}
you see in the second paragraph:
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“There will be minimal change to legacy
applications. LFS, DRS and TPS will incorporate new
harvesters that will extract transactions from the
Branch database rather than the message store”
And that reflected the change that was going to be
made because the data would no longer be held in the
message store in branch, it would beheld in the branch
database, the BRDB?
That's right
“APS will be modified such that it extracts
transactional data directly from the TPS stream and this,
reduces the need for much of the AP-TP reconciliation .
Can you just tell the court what the AP-TP
reconciliation is?
AP is responsible for sending transactions off to
clients ; TP is responsible for sending transactions to
basically Post Office back-end systems. The
reconciliation was there to make sure that if you sent
something to the back -- to a client, it was also being
sent through to the Post Office back-end systems.
Okay. Then it says
“No other rationalisation is proposed to the data
centre applications as part of HING. A phase II
rationalisation programme is not deemed to be part of
the HING-X project and must be separately justified at
113
a later stage.”
What was phase I, do you know?
I don't think there ever has been a phase Il. We're
currently making changes which will probably get rid of
things like
and LES. TPSis still there, but pretty nearly
or certainly reengineer things like DRS
redundant, so nothing that I would recognise as
‘a phase II rationalisation process.
Okay. And if we look at (F/451} please, this is the
HING-X testing strategy. The documents dated
10 April 2008 and can we just go to page 10 please
{F/451/10}. Now, if you look at the third paragraph
down:
"It has been recognised for some time that this
architecture, whilst providing an extremely robust
operational solution, was not ideally suited to the very
different business and technology drivers that prevail
today”
Now, we see “robust” as a description of the
solution in lots of places in lots of documents, both at
PO and Fujitsu, and it’s a term that you're very
familiar with, isn’t it?
Yes.
‘The latter part of that sentence is saying it is not
ideally suited to the very different business and
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technology drivers that prevail today and it goes on and
says:
“In addition, in common with many elderly systems
that have been subjected to a succession of major
changes, it has become increasingly difficult to make
those changes, and expensive to operate”
Now, that’s a fair description of how the system
originally was perhaps designed jointly with the DSS at
the beginning and launched and then over the years,
between then and 2008, there have been lots of sort of
bolt-ons and additional things that have been changed on
the system, haven't there?
Yes, I think that’s fair. The major one probably in my
mind would be banking.
And if we look at the fourth paragraph down, three lines
down please:
~The main drivers were to create a solution that was
more responsive to business change (faster time to
market), and more efficient to operate, maintain, and
enhance, thus providing lower Total Cost of Ownership
(TCO). However, HING was ambitious, projected costs were
high, and the benefit realisation profile was unclear.
In particular, HNG had been predicated on expecting
a high rate of future business change for the system.
Emerging business strategy in the Post Office indicated
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that this was uncertain and could not be relied upon
sufficiently to support the proposed business case. As
a result HNG was suspended in the summer 2005.”
Yes? Can you remember that happening, the project
being suspended at that point?
Yes.
And if we now look at what is being proposed, the bottom
paragraph of section 1.1 on (F/451/10}:
~The HNG-X programme proposes a somewhat less.
ambitious re-engineering of Horizon, without the branch
network hardware refresh ..”
Yes.
*.. and with the focus squarely on reduction of the TCO
[total cost of ownership]. The principal drivers for
the HNG-X programme are to deliver a solution that
significantly reduces the TCO, whilst maintaining
"Business Equivalence’ (ie the HNG-X solution is to
provide effectively the same business capability as the
existing Horizon solution, but cost less to operate and
maintain)”
Now, is that a fair summary?
1 can’t argue with it, certainly
Can we look, please, at {F/555}. This is a Post Office
online induction training presentation. Can we go to
the next page of that please (F/555/2} and the course
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aimsare to:
give you all the information and skills that
you will need to successfully supporta branch from
Horizon to Horizon Online.”
So this is actually an internal Post Office
document, it appears, and if we look at page 10 please
{F/555/10}. This is Horizon’s current state
"13 year old design and technology to. satisfy
a different business.
“Slow and expensive to use.
“Evolved rather than designed - a consequence of
which is a robust service but complicated to change.”
Do yousee that?
Yes.
Now, the comment on it being a 13-year-old design and
technology is fair, isn’t it?
Yes.
‘The comment on it being slow and expensive to use is
fair, as at that date, or do you feel a bit conflicted
because you now work for Fujitsu?
1 know that Post Office regarded this as expensive and
they also regarded it as slow to change. I personally
didn’t necessarily go along with that because there was
a - there’s an AP-ADC product which since I was
involved in Post Office at this time, AP-ADC was my way
117
of being able to carry on making busines
changes whilst
we were going through this particular phase, so yes,
I feel slightly conflicted because I know that the
Post Office high-level vi
‘was that you couldn't make
changes to Horizon, whereas I was busy
do there were certainly changes you certainly could
not do, but my feeling was that we could continue to
support the business, they could continue to take on new
clients using this facility , AP-ADC.
Okay, well, havea look at the four lines at the bottom
you could
of the page if you would and see whether you think this
is fair
“Horizon is also a system that’s wrapped up in
“barbed wire’ -- making changes difficult and costly
test everything!”
Is that an understandable observation?
I think that I would see that from Post Office
perspective but, as I say, my personal view on this was
that I could still make changes by getting AP-ADC
seripts through, but there were certainly some things
that yes, if -- there were some things that would have
been very difficult to change at that time.
If welook at -- if we just go back if we may please to
{F/451} which is the HNG-X testing strategy of
10 April 2008. If welook at page 33 of that document
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please (F/451/33}, paragraph 2.2.6, "Migration Complex
and Critical *
~The system and data migrations required for HNG-X,
both at the Data Centres, and at the branches (which
continues branch by branch throughout the roll -out
period), are absolutely fundamental to the success of
the deployment. It is a complex area requiring careful
and detailed planning. Thorough verification and
validation will be essential ”
Now, that’s fair, isn’t it? I mean, that’s what you
would expect to see, yes?
Yes.
And if we look at the bottom two paragraphs of that
section
"Migrated data should be introduced into the
mainstream tests as soon as practicable, interleaving
migration tests with functional test cycles”
And then:
“Full -blown rehearsals of the detailed migration
plans must be completed prior to Pilot
Yes?
Yes.
So what this envisages is that before the pilot is done,
there must be full blown rehearsals of detailed
migration plans to try and see if there are any problems
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or difficulties
Yes.
Now, in fact, the pilot had to be stopped, didn’t it?
Do you remember that?
Yes.
Let’s have a look, please, at {F/588}. This is PEAK
PCO195380 and you can see it is created apparently on
2 Mareh in the top box under "Progress Narrative”,
and
‘This is which year, sorry? This is 2010, yes. Yes:
Sorry, I think I’ve got the wrong reference there, wait
a minute, Just give me one second.
I will come back to that in a second, if 1 may.
I think we may not have the correct reference.
Let’s go forward, if we may, to {F/614} and this is
the Horizon Online Programme Update. Who was
Mark Burley?
Mark Burley was my boss whilst I was working on the
preparation for HING-X.
And how long had you worked with him?
On this -- 1 knew him way before I started working with
him. On this project I guess 1 was working for him for
a year, a year anda half
And if we look, please, on that document at page 4
(F/614/4}, we can see Horizon Online status
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>OoPe
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rPOoPop
"614 branches live on Horizon Online (plus 8 Model
Offices )”
Yes.
And then do you see:
“High Volume Pilot suspended”
Yes.
And:
“NESP raised concerns but remain supportive.”
Yes.
And can you remember that the NFSP had raised concerns
about the problems that people were having in the pilot?
No, I can’t, because at this stage -- this is early
2010
Post Office working ona different project and so this
was happening around me, but I was concentrating on
something which was called SMTS.
Okay, so you weren't in touch because you had only just
come back I think, hadn't you?
I had just come back into the Post Office to work on
at that time I was actually - I was back in the
this specific
In March?
No, sorry, I came back in January.
Came back in January?
I came back to the Post Office in January to work on
small money transfer service.
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Okay, at the bottom of that slide we see:
"Fujitsu initiated ‘red Alert’ and independent
reviews.”
Yes.
What did you
Fujitsu meantat the time?
I certainly would have done and when I moved across to
Fujitsu, we were in red alert.
So when you moved to Fujitsu they were in a state of red
alert on this project?
Yes.
did you know what a red alert from
And were there different codes for the colours of alert?
Were there other alerts, amber alert?
You have got me on that one, but I’m sure there were.
Can we infer from "red alert” that it is quite serious?
Oh, it was very serious
And can you tell_his Lordship why it was serious?
‘There was an issue with Oracle which was the biggest
problem, but clearly there were other problems going on
at the same time because it was a brand new system, but
the big one was an Oracle issue which I got involved in.
Can you remember some of the other problems that were
happening at the time?
I have to admit, I was focused on the Oracle problem.
1 was new into Fujitsu. In that sense I was finding my
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feet and trying to work on the big one.
Fair enough. Can we go back to {F/588} please. This is
the same PEAK I think I identified , PCO195380, and can
we go to page 4 of that PEAK please (F/588/4}. Now, can
you see in the box under 5 March 2010 at 08.03.08,
second box down?
Yes
Under -- it says:
“We have received notification from POL regarding
the problemsat this office. PSB ..”
Do you know who PSB was, or what it was?
No, I don’t think it’s a person. I don’t know what PSB
means.
Okay:
“On the Ist of March at the close of business we
found that on node the cash was short of £1,000. All
of the figures for that day match the figures presented
at the time of each transactions
It is possibly "Please see below” but ..
An instant saver
withdrawal of £1,000 was transacted that day, but I was
unable to find this transaction using the online report
facility
error has occurred at the time of this transaction.”
I feel very anxious as I believe a system
So this seems to be being relayed from what the SPM
has rung up about:
“On the 2nd of Marcha transaction for a cash
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withdrawal was completed where the system commanded
a member of staff to issue the money to the customer on
screen but the receipt printed for that transaction
printed out a decline slip. The customer was honest
enough to bring back the decline receipt a day later
with the money”
Then:
“On the 2nd of March on node 5 a £220 cash deposit
was authorised on screen but twenty minutes later the
customer brought back receipt that stated the
We contacted the NBSC as and
when the customer produced the receipt. The NBSC stated
that the transaction approved on the system and had no
transaction had declined
idea why the money was not deposited and why the decline
slip was printed.”
Now, pausing there, was this something that you
would have been aware of in March 2010 or not?
No, I wasin the Post Office at that time and so
I wasn't involved in this bit
What were you
time ..?
you were in the Post Office at that
1 was working in the Post Office on a separate project
T had just come back in on a new project, ona new
contract.
But you were someone who had been working a lot in
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1 relation -- was very knowledgeable about Horizon?
2 A. Yes
3 Q. Did any of this come to your knowledge?
4 A. No.
5 Q. And if we see then:
6 “A rem was scanned in our system and all figures had
7 doubled up. The helpline team was notified at the time
8 to which they seemed more confused as to why it happened
9 than me!”
10 In your time prior to going off in 2009, had you
11 sort of encountered difficulties of this sort in other
12 PEAKs?
13. A. No, this is a problem with Horizon Online, so this is
14 a problem with the new system. I had at the time
15 that I finished my contract with Post Office, we were
16 gearing up for starting the migration process but the
17 big bit that concerned me most was the moving stuff
18 across from one data centre to another. This bit, the
19 counter migrations, was just kicking off in May 2010, so
20 okay, the figures there say that we had 600 branches,
21 I think you said there. So in May 2010 when I was back
22 on the scene but this time on the Fujitsu side, we were
23 in red alert, we did have a big problem with Oracle, we
24 were having to recover the situation so as to get ready
25 to carry on with the counter roll -out.
125
LQ. Nowif we look -- I apologise, I haven't got time to
2 take you to all of it, but there are quite a number of
3 apparent problems that they are wishing to raise, aren't
4 there?
5 A. I think this is the BT one, isn’t it? Does this one end
6 up with the branch transaction -- or the balancing
7 transaction, sorry? This looks to me as though the
8 dates are about right for the balancing transaction,
9 but -- yes, I think there were-- there certainly were
10 issues with the software in the early days of HING-X.
11 Q Yes. And that doesn’t come leaping out of your witness
12 statement, does it?
13. A. No.
14 Q. Andyou know thathis Lordship is trying to determine
15 how well the system worked over this period, don’t you?
16 A. Yes, that’s fair enough.
17 Q. Andis there a reason why there isn’t really any
18 reference to the problems with the system in your
19 witness statement?
20 A. I waslooking to give an overall explanation as to how
21 Horizon works. Obviously 1 was asked to pick up on
22 a number of specific problems that have been experienced
23 in the life of Horizon. There certainly were problems
24 to be dealt with in the early days of Horizon Online
25 Q Now, at paragraph 13 of your witness statement you say
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ero>r
horizon Online was the biggest overhaul. That's at
{2/1/3}, but:
. continuous and iterative updates to the system
over its life ”
You mention those as well, yes?
Sorry, could you remind me where we are?
Sorry. If you look at paragraph 13 of your witness
statement, you talk about the migration to HNG-X--
Yes.
or Horizon Online, that's the same thing?
Yes.
And you say this
“This was the biggest overhaul in the Horizon
infrastructure that I can recall , although there have
been continuous and iterative updates to the system over
its life *
Now, pausing there, we have seen that quite a number
of the system components remained the same, didn't they,
from legacy days?
Yes.
‘And we have also -- you have very fairly accepted that
there were lots of additions made to the system over its
life ; yes?
Yes.
Now, isn’t HING-X, or Horizon Online, an end of life
127
version of the Horizon system rather than
a reinvigorated and rejuvenated version? Is that fair?
No. Horizon Online is the components that were
introduced by Horizon Online is the branch database, new
technology for communication between the branches and
data centres, so that was moving to an online system
which is a radical change to the
change to the architecture compared to Riposte and there
the communications technology change was pretty
dramatic in terms of moving from ISDN to what we have
it’s a radical
are -
now ~ or, sorry, to ADSL, whichis -- so it wasa big
overhaul
Can I pause there. The communications changes that you
mention are significant , aren't they, because there have
been quite a lot of communications problems with the
legacy version of Horizon?
Yes.
And
Sorry, the legacy version of Horizon was far more
susceptible to communication glitches.
Exactly. And so there were two improvements in that
respect: the susceptibility to communication glitches
was reduced, and also the quality of the communications
infrastructure was improved, is that fair?
Yes.
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Q. Can we now look please at (F/1663). This is an IT risk
management document from Post Office and itis dated
20 July 2017. Now, can we look at page 6 of this please
{F/1663/6}. Can you see under the "Where we are now”
heading:
“There is increased risk in our Branch technology
environment:
“The ~... (HNG-X) platform is end of life
AL Yes
Q. *.. and is running on unsupported Windows software,
therefore needs replacing
AL Yes
Q. This is 20177
AL Yes.
Q. Is it fair to describe it in these termsas at the date
of this document?
A. Absolutely.
Q. "Branch counter technology is aged and unreliable, with
frequent hardware failures, resulting in branch
disruptions.”
Is that fair?
A. Yes, I think so.
Q. “The branch IT network service (ISDN) provided by
Vodafone will be switched off on 30 September 2017 and
therefore needs transitioning ”
129
That's a different observation relating to an
external comms change.
A. The ISDN bit was a small number of branches where -- and
I can’t remember the numbers, but there was a relatively
small number of branches that were still running on ISDN
because you could not get ASDL there.
Q. Yes.
points, that’s the least important, isn’t it?
A. Indeed. The straight case is that the platform was
running on NT 4 and any technologist would tell you that
that was too old, but it continued to work surprisingly
well
MR JUSTICE FRASER: That's the Windows NT 4?
A. Yes.
MR GREEN: And under the "Mitigation" heading we see:
“Accelerated plans to transition from HNG-X to
updated HNGA ..”
And that’s going to run basically on Windows 10, it
So that’s in the -- in the hierarchy of those
doesn’t say it there, but that was the plan, wasn't it?
‘A. Well, INGA has now been installed and it is, as you say,
running on Windows 10. At this stage I suspect the
target was Windows 8, but that’s irrelevant
Q. Yes.
statement, if we can go to (E2/1/4} -- you mention in
the footnote there:
In fact, you mention on page 4 of your witness
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oProPr
“HING Xis being replaced by HNG-A. There is no.
functional difference between the two: HNG-A refers to
an implementation of the same counter code as is used in
HNG-X to run ona Windows 10 device (whereas HNG-X
counters are NT4 devices).”
Yes.
Yes? But there's not an explanation to anyone reading
this witmess statement of the sort of state of the
technology in the terms that we have just seen in your
witness statement?
That's a fair point.
And in terms of the roll-out, did the first wave begin
in about February 2017, is that right?
For HNG-A?
Yes.
I can't really remember. The roll-out of HNG-A was not
really a Fujitsu problem.
Who was handling that?
‘There were two aspects to the roll -out of -- there were
two aspects of roll-out. The network was moved from
Fujitsu. to Horizon and then the counters -- the actual
hardware running HNG-A is supported by Computer Centre,
so the software that runs in the counter is. still
Fujitsu's and so that’s -- so we provide the software to
Computer Centre, they wrap it up, they send it to the
131
branches now.
Can you remember roughly when that handover started, or
took place? When did Computer Centre become responsible
for it?
You mentioned the date in 2017, that rings true.
we don't necessarily know the
answer at all, but (F/1710.1}
first , "Post Office Limited audit planning report”; do
you see that? And if we goto page 24 of that report
(F/1710.1/24}, you can see -- it is quite small writing,
but under the first yellow bullet point:
"Branch tech refresh - HNG-Xin branches will be
If we have a look
Let's look at the front
replaced by HING-A in phases, the first wave started
in February 2017’
I'm
You may not know.
I'm certainly not disputing that
‘Thank you.
Can we now turn please to paragraph 17.1 of your
witness statement in relation to data sources, that’s at
(62/1/4}
transaction data are and can we just identify this in
You have identified what the sources of
a little bit more detail please
“The vast majority of transactions are manually
entered by user in branch at the counter, by pressing
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oPporopr
rope
icons on the touchscreen, keying in the transaction on
the keyboard, scanning a barcode, scanning a magnetic
card or some other manual interaction with the system.
These are referred to as “counter transactions “”
Yes?
Mm-hm.
‘Then transaction corrections, as you understand it:
*.. they are produced when Post Office compares the
data entered into Horizon by branches with data
generated from other sources in order to identify any
discrepancies.”
You say there “as I understand it”, that’s because
it’s not something that you knew that much about when
you were at Post Office?
1 know the general principles of it, but I certainly
wouldn't know the detail of how TCs are generated.
And it says:
“TCs are sent to the branch via Horizon”
And there is a footnote
“TCs are incepted in Post Office's POLSAP system
before being communicated to Horizon, via TPS to the
BRDB”
Was that something you knew yourself or something
somebody assisted you with?
Sorry, where are we now?
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Footnote 2, explaining how they are generated.
I’monly seeing footnote 1
If we go over the page, sorry. {E2/1/5}.
I know that they come from POLSAP.
And how they are communicated via TPS to the BRDB, did
you pick that up from someone else or ..?
I could work that out for myself.
Did you, or did someone else tell you?
In this case 1 would have checked it, yes, so
With Gareth or ..2
No, this would be more a Pete Jobson one.
Okay. And you say “then accepted by a user in branch’.
You don’t know what's involved in that, do you?
I understand the principle because TCs were first
introduced in Impact, which I was involved with, and
I remember we had the conversations as to how TCs would
go into the branch and we were very clear that the
postmaster had to be aware, hence the mechanism that
I have seen described, which is they are presented with
the TC, they have to settle, they are given various
options on how to settle.
Yes. So why did
Yes.
you were involved in that design?
Why was there no dispute button?
That was a Post Office decision.
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Can you remember what the pros and cons that they had in
mind were when they made the decision?
1 think the basic argument was that disputes -- we
wanted the flow of data through the system as quickly as
possible because that keeps our books tidy and it was an
inference that there was always the -- you had to press
a button to take things through, but then you would pick
up the phone to NBSC and say that wasn’t right
MR JUSTICE FRASER: Were you involved in the discussion
about that, or were you just told there wasn't going to
bea dispute button?
1 would say that I was aware. I wasn’t particularly
engaged in the conversation. I regarded that as
business processing, my Lord. There is a precedent to
this which is technically very similar, which is
auto-rems, which I wasalso involved in, where the whole
process changed so to save the subpostmaster having to
key in the amounts in each pouch, they were presented
with a screen which said “The amounts coming in are
this, press this button.” I would like to remember, but
I can’t be certain, that at that point there was
a message to say "If you disagree, phone up the help
desk", but again the principle was there to say “This is
the right figure, accept it and then argue the case
outside”
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‘Then we look at "Equipment located in a branch other
than a Horizon terminal.” You say it
"... is required for some transactions, such as
a Camelot terminal for lottery products and a Paystation
terminal for some bill payments”
And the point you make there is that these bits of
‘equipment communicate information direct to a client or
other supplier, who relays that information to
Post Office, or Fujitsu on Post Office's behalf, who
then senda transaction acknowledgement to the branch
via Horizon.
So can we just pause there. Can we trace how
a piece of information gets froma scratchcard
activation into the various repositories of information,
so tracing it through in accordance with what you have
said there, there’s a piece of equipment, namely the
lottery terminal, and the SPM activates some cards on
the lottery terminal, yes?
Yes.
‘That information is then relayed directly to Camelot,
the client?
Yes.
And Camelot then in turn relay that to the Post Office ,
or Fujitsu on the Post Office's behalf, just following
your witness statement.
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A. My apologies
In the case of Camelot, the data goes to the Credence
system,
Q. Okay. So the Camelot data goes to Post Office ’s
Credence system?
A. Correct.
well, apologies for that being unclear.
Q. And then that then automatically engages with Horizon to
send through a transaction acknowledgement to the branch
via Horizon?
A. Yes. Wereceive a file from Credence which then gets
loaded into the branch database, then makes its way down,
to the counters
Q Yes.
is in fact in this case information that has come via
So the information going into the branch database
a third party and back in?
A. I don't see it in quite those terms. I see it as we
have received data which goes into the branch database,
the Horizon system knows absolutely nothing.
about it until this file appears.
30 we-
MR GREEN: Precisely. So just reputting that question
MR JUSTICE FRASER: It might be because you said “via”
A. Sorry, I think that’s probably the case, my Lord.
MR JUSTICE FRASER: Is that the part of it
A. I think so, my Lord, yes.
MR GREEN: That's my fault.
137
MR JUSTICE FRASER: Do you want to just clear it up?
MR GREEN: Yes. So the journey that immediately is seen by
Horizon is information coming in from Camelot
AL Yes.
Q. -- via Credence, is that fair?
‘A. It comes in and we know it is coming from Credence, yes.
‘MR JUSTICE FRASER: So it goes: Camelot terminal in the
branch, to Camelot, to Credence, to Horizon?
A. Correct.
MR GREEN: And because it has come into Credence, it then
goes into the branch database?
‘A. The branch database is the holding place where we put
this data so that it is -- it’s not technically sent to
the branches but -- well, I suppose it is, because at
the appropriate point the data comes from the branch
database to the counters.
Q. Yes
morning and logs on, they have some TAs on the screen?
AL Yes
So when someone turns on their terminal in the
Q. And they have no choice but to accept those?
A. I don't know whether they have the option to stop them,
but I think the principle is certainly right, that the
TAs are going down there with the expectation that they
have to be -- that they will be accepted.
Q. Just so you know, it is not controversial that they
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No, that’s fine. Thank you.
It’s at that point that they enter the branch accounts?
Yes.
And that is the data that is then captured by the audit
system?
Yes.
And that’s true -- with minor differences but
substantially correct -- for the other items of
equipment that you have in mind in paragraph (c)?
Yes, the difference is that the Paystation data comes
from Ingenico to us. Weload it into the branch
database in separate tables and we generate the TA, but
then you are onto a common stream.
And then again, that is the data that then goes into the
audit store?
Yes, it’s the action at the counter which then contains
data which comes up into the branch database and that is
the bit that goes into the audit store
Whatis the action that you are talking about there at
the counter?
Pressing the “Accept” button
On the TA?
Yes.
And then at (d) you say:
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“In Horizon Online it
is possible for Fujitsu to
insert a balancing transaction - see paragraph 58
below.”
Yes.
We will come back to that later. We have already dealt
with it, at least in part. Just focusing on (a), (b)
and (c) for a moment, when we look at the data that
‘we're concerned about in paragraph 17.2(a), you point
out, quite rightly, that:
“The vast majority of transactions are manually
entered by a user in branch at the counter ..”
And then importantly *.. by pressing icons on the
touchscreen”, yes?
Yes.
So the significance of that is that the transaction data
comprises the fact of a press -- one press by an SPM on
a particular icon, yes, andthe significance of that in
the reference data table being put together so that
something pops up in the basket, as I mentioned to
Mr Johnson when he was giving evidence, yes?
type in the price of a first class stamp?
No, absolutely not
You don't
The price of something would be
calculated for the majority of products.
Yes, and that data is in the reference data table,
isn't it?
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1 AL Yes 1 about the case.
2 Q. Soin the transaction data there are two elements. 2 A. Understood, my Lord, thank you.
3 ‘There is what the SPM hasin fact done in terms of 3 (3.00 pm)
4 a keystroke. 4 (Short Break)
5 A. I don't see it in those terms. 5 (3.10 pm)
6 Q I understand. 6 MRGREEN: Can we just touch ona couple of brief points in
7A. Wesee the result of actions at the counter as a basket 7 relation to transferring and storage of data. At
8 and I think -- so wesee the outcome from the counter 8 paragraph 19 of your statement at {E2/1/6} you say:
9 application putting together a basket and it is that 9 “Due to the different ways that Legacy Horizon and
10 basket that we then put into the audit trail 10 Horizon Online transfer and store data, I address them
11 Q. Totally understand. I was just trying to be precise il separately below when dealing with integrity of data
12 about the result that wesee, whichis the fruit of two 12 being transferred through Horizon.”
13 different pieces of data: there is which icon the SPM 13 We touched on the information flows in relation to
14 has pressed on the screen and the relevant reference 14 third parties already, but that wasin the context of
15 data in the reference data table for that icon. 15 the BRDB, wasn't it, our discussion we just had before
16 A. If you're looking at something such asa first class 16 the break?
17 stamp then yes, I agree. If you're looking at other 17 A. Yes
18 things then it could be much more complicated. 18 Q. And under Legacy Horizon you were on the other side of
19 Q. Ofcourse, but for many many things there are -- 19 the fence, as it were, to where you are now?
20 A. Yes. 20 A. Yes.
21 Q. The reason you say “by pressing icons on the 21 Q. Legacy Horizon days.
22 touchscreen” in paragraph 17.2(a) of your statement, is 22 If we look at paragraph 34 of your witness statement
23 because for quite a lot of transactions that's how it is 23 at (E2/1/11}, you make the point that the messaging
24 done? 24 system was responsible for storing all the data in the
25 A. Yes. 25 Post Office branch and replicating it to data centres
M1 143
1 Q. There are some where the SPM has to actually manually 1 The basic set up is that the counters held ds
2 enter in what's happening 2 a message store.
3 A. There are some where the subpostmaster has to enter far 3 AL Yes.
4 more data, such as on an AP-ADC transaction. There are 4 Q. And the correspondence server also had a message store?
5 some where data will come from a PIN pad, there are some 5 AL Yes.
6 where data will come froma barcode, weigh scales 6 Q. And the data inserted at the counter would be replicated
7 Q Indeed. And that is the data -- the result of that, 7 in the correspondence server message store?
8 what's shown in the basket, in the transaction if you 8 A. Correct.
9 like, is what's then captured in the BRDB and in due 9 Q And vice versa if there wasa
10 course in the audit store 10 A. If youneeded to push data -- Riposte was responsible
11 A. Simultaneously. The first part of that is actually -- 11 for replicating data to wherever you told it to.
12 the audit store at that stage is actually simply a table 12 Q. Indeed. At paragraph 43 of your witness statement
13 in the branch database. 13 {E2/1/12}, you have mentioned that:
14 MRGREEN: Okay. 14 *[You] understand from Gareth that the audit
15 My Lord, would that be a convenient moment for 15 application read every record that was visible to the
16 a break? 16 correspondence server ... and wrote a text copy of that
17 MRJUSTICE FRASER: Idare say. Are you going to be dealing 17 data to a text file”
18 with Mr Godeseth for the whole of the afternoon? 18 Do you know whether the audit server was hosted by
19 MRGREEN: Iam. 19 Riposte or not?
20 MRJUSTICE FRASER: We're going to have a short break, 20 A. Theaudit server is definitely outside of Riposte.
21 Mr Godeseth. ‘Ten minutes -- or do you want five? 21. Q. Let's look at the Horizon Next Generation plan X
22 MRGREEN: That's fine 22 document again please, at page 28 {F/299/28}. Do you
23 MRJUSTICE FRASER: Ten minutes. We will have a ten minute 23 see under “Audit” at paragraph 4.3.2.7 it says
24 break for the shorthand writers. If youcould comeback 24 “The audit application remains largely unchanged
25 at 10 past. Same score as before, don’t talk to anyone 25 apart from various modifications to the configuration of
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audit collection points throughout the estate.
“An audit conversion tool will be required to
convert existing audit data from Riposte to another
readable/searchable format”
What is that referring to?
A. I think it’s just wrong.
MR JUSTICE FRASER: You think that’s wrong?
‘A. Yes. Yes, my Lord, because I have seen audit data from
Riposte days and it is in Riposte attribute language, so
I -- I can’t see how that’s right because the audit data
that I have seen is in Riposte attribute language.
MR GREEN: So the audit data that was stored was in
iposte
attribute language?
It was basically the message store -— it
pretty much as simple as a copy of the message store
A. Correct s
Q. Andin relation to who was managing the Riposte system,
what was Escher’s role?
A. Escher provided Riposte software, so they provided the
software in which Fujitsu deployed applications
Q. And did they provide support for the Riposte software as
well, or not?
A. Yes, they did, but I honestly don't know what the
contractual relationships were, so I can’t really
comment in any detail on that.
Q. You wouldn't have known at the time what the
145
arrangements between Escher and Fujitsu were if there
were problems with Riposte?
A. I certainly don’t know. I’m obviously conscious, having
looked at PEAKs, that there were issues, but I was not
aware of those at the time.
Q. I understand. You deal with Horizon Online from
paragraph 20 (E2/1/6} in relation to the accuracy of
Is it fair to say this is more within
your own knowledge, this bit of your statement?
I feel that 1 know this pretty well, yes.
So back on home turf in a sense?
transaction data.
In that sense, yes.
And in paragraph 26 (E2/1/7} you mention the controls
oPror
that were in place. Do you know whether those controls
ever failed? Take the first one, “A basket must balance
to zero”
A. We have checked this. If you do something ona test
system to cause a basket not to balance to zero, it
shows an error.
Q. And you mentioned the Journal Sequence Number. It’s
impossible, isn’t it, for the database to accept two
items with the same JSN number?
A. Correct.
Q. Can we look please at {F/590/7}. Just t0 orientate you
in this, perhaps we can goto the first page, I’m sorry
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(F/590}. You will see that this is PEAK PCO195561. Do
you see that?
Yes.
And if we go to page 7 {F/590/7} and we look at
24 March 2010 at 14.45.49, which is the middle one, do
you see there:
“Time-outs were the underlying cause of the issue
and that there were long delays waiting on the DB ..”
That’s the database, yes?
to process the 4 requests.”
Mm-bhm.
“In this case two of the requests were committed and two
correctly detected that the transaction had already
succeeded. There is an issue with the 2 commits because
this shouldn't have happened. However the behaviour of
the OSR from CTR 25.07 onwards is to roll the
transaction back ona time-out. In this scenario all
the requests would have failed and no reconciliation is
required.
“We would like to find the root cause of the issue
as to how the duplicate entry was committed in the DB”
Now, I know you were working on other things
in March 2010, but were you aware of any problems with
items with a duplicate JSN number, Journal Sequence
Number, being committed to the database?
147
I'mnotsure this is saying we had duplicate JSNs, but
I would obviously have to check the detail and no,
1 wasn’t aware.
You weren't aware of that problem generally?
No.
Okay. And you were here! think for Mr Dunks’ evidence
this morning.
Mm-hm.
Paragraph 32 of your witness statement (E2/1/10} says:
“I am not aware of any instances where data
retrieved from the audit store differs from other
sources of data, nor am aware of any instances where
the integrity checks described in paragraph 30 have
revealed any issues.”
Yes?
Yes.
Were you aware that there had been duplication of data
identified in Seema Misra’s case?
Misra I believe was on the old system,
Yes, legacy.
Yes. So no, I was not aware of that
In terms of ARQ figures, can we look at paragraph 31 of
your witness statement please {E2/1/10}. You say there:
“I have been informed by my colleague Jason Muir
(Operational Security Manager in Security Operations
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Team) that the number of ARQs issued since the 2014/15
financial year is as follows
And you then say one ARQ equals one month ofan
individual branch data so one Post Office request for
data could have multiple ARQs, yes?
A. Yes.
Q. Just to explain what the figures are. And you have
a footnote to that which says:
"These figures do not include the ARQs that Fujitsu
has issued in relation to these proceedings.”
So is it actually -. where did you get that
information from?
A. From Jason.
Q. So what did you ask him?
‘A. Personally I didn’t ask him anything, This was
information that was being requested to go into the
witness statement, so I'm confident that it is correct
I have no particular motive in providing that
information.
Q. I’mjust trying to -- I’mnot talking about motive, I’m
just trying to identify how it has ended up in your
witness statement.
A. I was effectively asked to put it in.
Q. So did Jason Muir actually inform you of this in
response to any requests from you?
149
AL No.
Q. Because that saves me asking the next question which was
why didn't you ask him for earlier years.
Now, can we just look at the years that we've got
there, 31.1 to 31.4, When you were shown the
information that you were to put into your witness
statement you must have noticed that it only went from
the 14/15 year to the 17/18 year.
A. I didn’t pay it any particular attention
Q. Bur you have been dealing with Legacy Horizon which
pre-dates 2010
A. That's true
Q. - in the same witness statement, so you must have had
in mind what the chronological sweep of this witness
statement was supposed to deal with, mustn't you?
A. ['mafraid I didn’t do my job in that case.
MR GREEN: Can we move now to
‘MR JUSTICE FRASER: Just before you move off that, can you
think of any reason why there should be a cut off at the
beginning of 2014, in terms of the system, or the way it
worked, or anything?
A. I can’t think of any reason why that information would
not be available further back.
MR JUSTICE FRASER: Mr Green.
MR GREEN: Can we deal with the problem management procedure
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now. Can we look please at (F/1692}
bea Fujitsu document. We see at the bottom "Fujitsu
restricted" and “Copyright Fujitsu Limited 2017. The
title of the document is "Post Office Account - Customer
This appears to
service problem management procedure” and can we please
go -- if younote the “abstract” there:
“To describe and document the customer service
problem management process.”
Now, you are the chief architect, aren't you, in
relation to the responsibility for changes being made to
the system being implemented without prejudicing the
continued operation of the system? That's what you say
in your witness statement?
Yes, that’s right.
And this is a recent document which relates specifically
to the Post Office account. Is this a document you have
seen before?
1 can’t honestly say. It’s certainly not one that I'm
particularly familiar with,
Okay. Let’s havea look, if we may please, at page 8
(F/1692/8}. You will see just under 1.1 "Process
objective and scope”:
“The objective of this documentis to define the
process for problem management in the POA environment to
support the contracted infrastructure and application
151
services described in the HNG-Xcontract. Other
infrastructure and services used by POA to provide and
support delivery of the HNG-Xcontract are also in scope
of the process.”
Now, just pausing there for a second, POA js the
Post Office account team at Fujitsu, isn’t it?
Correet.
Then it says:
“For the purpose of this documenta problem is
defined as the unknown underlying root cause of one or
more incidents”
Yes?
Yes.
“The problem management process covers both reactive and
proactive functions of problem management”
Yes.
Now, if one is to havea robust system it’s important,
isn’t it, to make informed assessments of where problems
lie based on the relevant information that was
available?
Yes
And it’s important to capture and track that in a way
that can readily be analysed, is that fair?
Yes.
And that seems to be at least consistent, if not the aim
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of this procedure, yes?
Agreed, yes
Let's look please at the document history on page 4
please {F/1692/4}. Wecan see that the draft document
was updated in 2007 and we can see various changes going
in and out and various revisions going forward on that
basis. If we go over the page {F/1692/5}, we can see up
to a date in September 2017, yes?
Yes.
Now, can I just give you the context in which this
document has come to the fore, so that you can see it
clearly. The two experts both comment onit. If we go
please to {D2/1/96}, this is MrCoyne’s report. We get
to paragraph 5.156 there and it is clear from that
paragraph that Mr Coyne was working on the basis that
the problem management procedure had actually been acted
upon and you can see there, at 5.156, he says
“The Post Office account customer service problem
management procedure document ..”
Which he footnotes:
identifies the process metrics and key
performance indicators required for measuring the
effectiveness of the process and service specifically in
relation to problem management. The problem management
procedure is set out in more detail at appendix E ...
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relevant to this section and issue 6 are the metrics and
KPIs to measure/control and reduce the risk of failure
to detect, correct and remedy Horizon errors and bugs.”
Yes?
Now, if we go please to page 97 over the page
{D2/1/97} and we look at 5.157, he says:
“From the above, it is my opinion that Post Office
should be aware of all recorded bugs/errors/defects in
addition to those previously acknowledged by them, from
the process metries compiled above.”
So what Mr Coyne seems to have inferred is that the
problem management process had been implemented and
there would be feedback from Fujitsu to Post Office
about what errors and bugs -- that seems to be the basis
he is proceeding on, doesn't it, onthe face of it?
On the face of it, certainly.
And if we go now to {D3/7/81} we can see Dr Worden
this is his second report and he appears to be working
on the basis also that the problem management procedure
had been brought in. If we look at the third column he
says -- so it is row 21, it relates to 5.156, which is
Mr Coyne'’s paragraph I just showed you, the extract of
Mr Coyne’s paragraph is there, and then if you look on
the right-hand side under “Commentary” you will see:
“This document isa rather high level and generic
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description of the problem management process.
“It is difficult to extract a clear picture from
this document of how the process works in practice
For instance, there are listed about 20 types of process
input and 20 types of process output,
discern from these long lists which inputs and outputs
‘were most important.
It is hard to
“As another indication of its generic nature, the
words "bug’, “defect ’, ‘software’ and ‘reference da
a
never occur in the document. The word ‘error’ does
occur. Errors are discussed generically not as specific
types of error such as errors in Horizon”
So both experts appear to be approaching it on the
basis that it had been acted upon.
Now, if we look at (F/1692/10}, going back to the
problem management document at page 10, we can see what
the relevant metries are. Now, those are competent
professional metries that you would expect to see in
a policy of this sort, aren’t they?
Yes.
You can see that what's proposed there is
“The following metrics, to be reported monthly, will
be used to measure effectiveness of the process and
drive performance of the process and overall service in
general.”
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‘That’s the way it is going to work?
Yes.
‘And were you aware, as you are one of the key people at
Fujitsu, that Mr Coyne had asked for documents to be
provided which he thought should exist based on the
problem management procedure? Did you know ~ did that
come to your attention at all?
It has not come to my attention.
Well, I will take it quite quickly. Let's havea look
at (D2/5/22}. This is a request for information and
a response and you can see that in relation to this
in the Post Office response to requests for information,
if we go down to page 26 (D2/5/26} you will see in the
left -hand column at the bottom:
“Please provide how many times (and over what
period) the ‘problem management process’ has recorded
the potential for a system or software error?”
And then in the column with Post Office ’s response:
"Post Office objects to this request. Fujitsw
believes that it does not record problems in such a way
that would allow this to be determined without
retrospectively carrying out detailed analyses.”
Andso forth. Over the page:
“This would require a disproportionate effort and
cost.”
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You have addressed this issue at paragraph 63 of
your witness statement at {E2/7/16}, haven't you?
A. T have.
Q. And what you have explained there
witness statement this is. What you say there is
“I have spoken to my colleague Steve Bansal,
Fujitsu's senior service delivery manager, who has
in your second
informed me that the Post Office account customer
service problem management procedure document was
introduced by Saheed Salawu, Fujitsu's former Horizon
lead service delivery manager and that Saheed Salawu
left the Fujitsu Post Office account in
around February 2013, before the new procedure had been
implemented. I understand from Steve that
Saheed Salawu's replacement did not wish to implement
the changes and therefore the records referred to by
Mr Coyne in paragraphs 5.157 to 5.159 of his report do
not exist, as we continued to follow the previous
existing reporting methodology”
Now, can we just unpack that slowly. Who was
Saheed Salawu's replacement?
A. I don't know. As youcan tell I’ma bit vague on this
area, I remember Saheed, I don’t know whether it was
‘Tony Wicks who took over from him or somebody else.
Q. Because when we go back to the document itself, at
157
{F/1692/4], here is the "Summary of changes and reason
for issue”, The document's history goes back to 2007,
doesn't it?
AL Yes.
Q. And it looks like it wasissued for approval in 2014,
doesn't it?
‘A. Well, it was issued for approval on 9 December 2013,
yes.
MR JUSTICE FRASER: “Issued for approval” appears in
a number of places I think
A. Yes and the convention is that when you goto a "0"
version then that’s one that is being issued for
approval.
MR JUSTICE FRASER: Hence 2.0, April 2008;
3.0, December 2013; 4.0, July 2014?
A. Yes
‘MR JUSTICE FRASER: And that's why they are all "0" because
they are all issued for approval?
‘A. They should all be issued for approval, yes.
MR GREEN: And thatis after the date when you say Mr Salawu
left .
A. I think so because! think Saheed left in 2013, so it
looks as though it was Tony Wicks who came in to take
on -- take up from him,
Q. So can you explain to his Lordship what the procedure
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for adopting a policy or procedure of this sort is?
It’s governance within the account
team, I am certainly no expert on that aspect of it.
Q. Okay, because when we go over the page {F/1692/5} in
2017 we see no comments from review cycle. It is still
being dealt with in 2017 and we can see the name of
‘Tony Wicks for review comments, can't we?
A. I'mafraid not.
>
Yes
Q. Requested by 14 December 2017. Is he the person we
would really have to ask about this?
‘A. If my suppositions are correct then it looks as though
Tony Wicks is the man who has driven this.
MR JUSTICE FRASER: He is the what, sorry?
‘A. He would be the man who has driven this
MR GREEN: And he is the person we would really have to ask
about what happened after February 2013?
A. Yes, if my suppositions are right that he took over from
Saheed
MR JUSTICE FRASER: Well, would you like to look at page 1
{F/1692}. What does "Approval authorities” mean?
A. Approval -- sorry, that would be Steve Bansal who would
sign it off
MR GREEN: Let's look at the Legacy Horizon reporting system
because in your paragraph 63-- if wecan just go back
to that (E2/7/16} - you say there in the last line of
159
that:
we continued to follow the previous existing
reporting methodology.”
Is that a reporting methodology with which you're
familiar?
No.
So that’s whathe -- you've got all of that from Steve?
I got -- basically I got this from Steve.
And you don't really know what the reporting methodology
is?
oPpoPr
A. Notin any detail at all.
Q. Doyou imagine it ought to be documentary, or would it
be oral, or ..2
A. I imagine it happening via the service review meetings
that Steve chairs. We have regular sessions with ATOS,
with other suppliers, but I have not -- I can’t remember
actually going to one. I’maware that there are
meetings with Post Office and ATOS to talk about service
issues.
Q. Okay. Let’s look in paragraph 64 where you are dealing
with the service review book. You say:
“When Legacy Horizon was in place problem management
was reported in a specific section within the service
review book (SRB).”
Is that something you also got from Steve or
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something that you knew about yourself?
No, that is from Steve. I have probably seen service
review book outputs in the past but
That was a fairly high level review of problem
management and (inaudible) main problems, was it?
Very high level, yes.
If we look please at your paragraph 65 (E2/7/16}, is
this still Steve Bansal?
Yes.
So how far down does that go? Is this all -- just give
usa feel for how far down we go.
I think to the bottom of the page.
To the bottom of the page, I see.
In paragraph 65 you say that:
“From September 2010 these SRBs reported metrics
only against contractual service level agreements
ands there are no contractual SLAs for problem
management, itis not covered in the SRB reports
between ... 2010 and 2014”
That's right, is it? That's what you understand
from Steve?
That's certainly what! understand from Steve.
Okay. I mean wouldn't Post Office want to know the sort
of information that would be conveyed from that sort of
reporting procedure?
161
1 would imagine so and I did not attend the meetings
with Post Office and ATOSso
There's only so far wecan take it?
Yes.
And you say at paragraph 66 (E2/7/16} -- and
I appreciate this is also from Steve Bansal:
“For the years 2014 to 2017 there are annual problem
review reports
Yes?
Yes.
Is that system still in place in 2018?
I just do not know.
‘MR JUSTICE FRASER: I'm having grave difficulty with
following this at what might be called face value, which
is why I'm just interrupting. Is the import or the
summary of your paragraph 63 to 66 that these types of
metrics are only available between the years you have
identified in those paragraphs and that Fujitsu doesn’t
keep them, or hasn't kept them for years outside the
ones identified in those paragraphs?
1 don’t know the answer to that, my Lord. I don’t know
whether there were records available, I would have to
speak in far more detail to Steve and others to
ascertain that
25 MRJUSTICE FRASER: But! thought you had already spoken to
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Steve about this?
A. I waslooking for a high level response ona specific
issue that was being requested.
MR JUSTICE FRASER: And what specific issue was that?
‘A. I think it was raised by Mr Coyne.
MR JUSTICE FRASER: Insofar as you can remember, do you
remember what it was?
‘A. It was simply looking for -- my recollection of it was
that he was concerned that Saheed had suggested an
improvement to problem management and was looking for
the evidence that that had been implemented and when
1 spoke to Steve and said "Did we implement this?” he
said no.
MRJUSTICE FRASER: All right. Mr Green.
MR GREEN: If we look at [F/1420}, this is headed "2014 POA
problem management - problem review”, do you see that?
A. I do.
Q. It is called version 1.0, at the bottom right-hand side,
which suggests it has been issued for approval and we
see "Document statu:
AL Yes
Q. Again Mr Bansal’s name under "Approval authorities”.
Y approval’.
Was this one actually implemented, or do you not know?
A. I don't know.
Q. Have a quick look at page 6 {F/1420/6}. I'm going to
163
have to take this quite quickly, Mr Godeseth, because
it’s obviously not something you're familiar with, but
this appears to contemplate undertaking a trend analysis
and so forth to review the knowledge database, review
problems and so forth, and if we goto page 7
(F/1420/7}, on the face of it looks as if there are
considerations, for example, of specific problems that
have in fact occurred. Do you see that?
AL Yes.
Q. So onthe face of it it does look from this document as
if there is a problem management review document with
some actual problems in it, although it seems to be
issued for approval. Is this something you know
anything about?
A. No.
Q. Just quickly then, very briefly, if you look at page 13
please (F/1420/13). If welook in the middle stripe,
41939577. Do yout see that?
AL Yes.
Q. It mentions First Rate. Who are First Rate?
A. First Rate Exchange Services are, I believe, a joint
venture owned by Post Office and Bank of Ireland, but
they provide foreign -- they provide bureau services.
Q. And they say:
“First Rate has identified an anomaly over the way
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Horizon reversed transactions are recorded and polled
through to them”
Is this something that came to your attention at
all?
No.
Because it does seem to have been fixed in counter
release for R9.
Yes
Release 9?
I don't remember what date release 9 was. It would have
been on my watch, but
It’s not something you remember particularly?
No.
And you don’t remember having seen this document either?
No.
If we look at (F/1497}, this one is the "2015 POA
problem management - problem review” and if we look at
page 7 there (F/1497/7}, do you recognise this one at
all or not?
I think I do from the recent review, but I couldn't be
certain without checking it in more detail
Because it is in the same formatas the previous one,
isn’t it?
Yes.
And in the bottom stripe we see 410821106:
165
“Transaction discrepancies can occur during the
rem-in process especially when transferring cash from
one branch to another (eg between their main branch to
their outreach branch ).”
Can we go back up very kindly. And then under
“Description”:
“The underlying cause of this problemis that
a logout before a user has fully logged on, then
subsequently a pouch is rem-in manually, then after the
rem-in slip has been printed, the same screen is
redisplayed and if the user press enter again,
a duplicate will occur. A code fix has been developed
and is in release 12.88 hot fix.”
Does that ring any bells?
That sounds like Dalmellington is it Dalmellington?
Yes, it is the Dalmellington bug, isn’t it?
And it doesn’t capture how many branches were
affected, does it, that report?
That's true.
It doesn’t capture how long it took to find?
No.
It doesn't capture the financial amounts involved?
No.
So is it fair to say that that report is not
a particularly rigorous or robust treatment of recording
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oppor
the problem, its extent and duration and effect?
I think that’s a fair comment.
Can we turn now please to understand a little bit better
the issues around balancing transactions that we touched
on earlier and can we first look please at {F/1692).
This is another Tony Wicks Post Office account customer
service problem management procedure document. Now ~
we will perhaps come back to that
Let me take you forward, if I may ~ or back in the
bundle to (F/425} and just show you this to get the
chronology. If yousee at the top, the title onthe top
is, "Host BRDB transaction correction tool low level
design.” Do yousee that?
Yes.
And this is the low level design document, isn’t it, for
the branch database transaction correction tool?
Yes.
And it says “Document status: draft” and the “Approval
authorities” is Graham Allen. Do you know Graham Allen?
I do.
Do you work with him?
Yes.
And the author and department it says Rajesh Shastri.
Do you work with him?
I don't recognise his name.
167
And if we just go forward to page § (F/425/5} we can see
that the document history shows the draft version being
produced in October 2007 and then, 29 September 2009,
“Add transaction correction journal auditing” Do you
know what transaction correction journal auditing is?
Sorry, where are we?
Sorry, bottom of the 0.2 table.
29 September 2009, yes.
Now, this was a tool that was being developed for
Horizon Online, wasn’t it?
Yes.
And if we go to page 8 (F/425/8}, under "Overview" it
explains that:
“This document provides the low level design for the
branch database transaction correction tool module. The
utility will allow SSC to correct transactions by:
inserting balancing records to
transactional /accounting/stock tables in the BRDB
system. It will also audit the changes made. There
will be no updating/deleting of records in the branch
database”
And then it says:
"Warning: the use of this powerful tool has inherent
risks. If the SQL statement is incorrect or badly
written, it is possible to cause unintended
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1 consequences, some of which may cause serious problems 1 no updating or deleting of records.
2 to the branch database. It is expected that only 2 A. Correct.
3 a small number of skilled staff will run this tool and 3 Q. And that’s actually reflected, at least to some extent
4 that they will have detailed guidance as to when and how 4 we will see - just trace it through. Let's look at the
5 to use the tool.” 5 objects because identifying the permitted database
6 Now, are you familiar personally with the use of, 6 objects is important to identifying the scope of
7 this tool in Horizon Online? 7 potential application of the tool with this design,
8 A. I’ve never seen it used because I was -- the one time it 8 isn't it?
9 was used, as we have already established, I was 9A. Absolutely.
10 elsewhere. I have had pretty lengthy conversations with 10 Q Sowelook at paragraph 2.4.1 on page {F/425/9}, the
1. Gareth Seemungal about how this tool is put together, so il next page, andwesee there's a table there. 24 is the
12 I feel that I understand how it works 12 objects used. We will just go through these carefully
13 Q Pretty lengthy conversations with .? 13 2.4.1, "Database objects used”, so in the database
14 A. Gareth Seemungal. 14 objects tables, these are the object names to which the
15 Q. Let’s look at the "Solution components”. It says there 15 specific functions that we are concerned with have
16 are five main components to the solution. There is the 16 access, yes?
17 UNIX shell script. There is the PL/SQL package. 17 AL Yes.
18 ‘There's: 18 Q. Okay, let's havea look. You can see there's the BRDB
19 “A set of template files, one for each transaction 19 operational exceptions table?
20 table for which balancing transactions are allowed to be 20 A. Yes.
21 inserted. Each file contains a template for an SQL 21 Q. The system parameters table?
22 insert statement for the table in question. This makes 22 A. Yes.
23 it easier for users to produce new transaction files by 23 Q. FADhash outlet mapping table?
24 basing them on the template files ” 24 A. Yes
25 And then there is the possibility for branch 25 Q. Theprocess audit table?
169 471
1 seeding, new branches to be processed by the tool, and 1A. Yes
2 the bottom one: 2 Q. Process audit sequence table?
3 “Transaction correction journal auditing - a new 3 AL Yes.
4 process generates audit files for the input day's 4 Q. Transaction correction tool journal table -- sorry,
5 audible transaction correction records. See section 5 5 “process audit sequence” was a sequence.
6 for details * 6 MRJUSTICE FRASER: Yes,1 don’t think that’s a table
7 Now, just taking this in stages, the seed records, 7 MRGREEN: Yes, that’s actually a sequence, which we will
8 in the penultimate bullet point there in red, last 8 come back to. My mistake.
9 line -- do you see that? 9 ‘The transaction correction tool journal table, the
10 A. Yes. 10 FAD hash current instance table, transaction correction
11 Q. Theseed records have a node ID of 997 11 tool control table, branch info table and then -- branch
12 A. Yes. 12 operators exception sequence, is that?
13 Q. Now, that’s like having a branch ID number a counter 13 MRJUSTICE FRASER: “Operational” I imagine.
14 number of greater than 32, isn't it? 14 MRGREEN: Or “operational”.
15 A. That is the counter number that this transaction would 15 MRJUSTICE FRASER: Is that right, Mr Godeseth, do you
16 be recorded against because the node ID is the counter. 16 think?
17 Q. Exactly. Now, just clarifying where we are, we have 17 MRGREEN: Something like that.
18 seen what you will and will not be able to doin 1.1, so 18 AT
19 it will allow SSC to correct transactions by inserting 19 MRJUSTICE FRASER: Or you don't know?
20 balancing records to transactional /accounting or stock 20 A. I don't know to that level
21 tables in the BRDB system, also audit the changes made, 21. MRGREEN: Okay. And then we see what the privileges
22 “There will be no updating/deleting of records in the 22 granted are:
23 branch database.” So this is the design for the tool? 23 “The following transaction tables have been granted
24 A. Yes 24 INSERT privileges.”
25 Q. So insertions of balancing records, yes; auditing, yes; 25 Yes?
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1 to OPSSSUPPORTTOOLUSER. The transaction
2 correction statement is only allowed to insert into
3 these tables”
4A. Yes.
5 Q Andit identifies effectively all the important
6 transactions tables and
7A. I think there are probably another two or three on the
8 next page.
9 Q. Onthe next page, exactly, I was just going to take you
10 there (F/425/10}. Plus the events table
11 A. Yes
12 Q. Session data, you see that as well?
13. A. Yes.
14 Q. Andat 2.42, the files used, it says:
15 “The process uses the following files
16 “Transaction file containing an SQL INSERT statement
17 that creates the required balancing transaction.”
18 So this would be where there is one half of
19 fa transaction missing another half of a transaction?
20 A. Yes.
21 Q. Andthe insert statement, the "SQLINSERT” statement
22 effectively goes in and puts in the missing other side
23 of that transaction?
24 A. Yes
25 Q. And the method on the next page, page 11 (F/425/11}
173,
1 “Having logged into their own UNIX user, the SSC
2 team members will change directory .. and place their
3 transaction file in the .. subdirectory. They will
4 then invoke BRDBXO1S manually. The shell script module
5 will be owned by the UNIX user ‘supporttooluser ‘”
6 And then it explains what the module will do and the
7 insert statement and so forth and you see that set out
8 at 3.1 in the method
9 A. Yes.
10 Q. Nowcan we go forward please from there to look at
11 {H/218} please. This is a letter from Wombles to
12 Freeths about the request for disclosure of the audit
13 records for the use of the tool and it says:
14 “This log is produced in relation to the use of
15 balancing transactions via the transaction correction
16 tool as described in paragraph 58 of Mr Godeseth’s first
17 witness statement.”
18 And you were describing in your paragraph 58 the
19 tool we have just been looking at, weren't you?
20 A. Yes
21 Q. Andlet’s look at what the audit table shows in terms of
22 number of non-zero audit files . We can see there 2010,
23 46,000 files -- 47,000 nearly, and one file with more
24 than zero content and then you can see 322, 553, 122,
25 129, 228, 420, so in total -- over the page -- over the
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period: 2,297 (H/218/2),
Now, just to give you the context of what's being
said, if you go back a page what's said in the middle of
that letter there is:
“Fujitsu have extracted the data from 2010 to 2019
and provided the following explanation for the
documents. It should be noted that Relativity is not
able to recognise OKB documents since these do not
contain any data and therefore disclosure can only be
provided of the 2,297 files which contain data. We
understand from Fujitsu that a OKB file is produced
where there was no logged activity . A disclosure list
is enclosed”
So that’s the explanation for the difference between
46,976 and 1, yes?
Yes.
‘And when we go over the page please (H/218/2), it says:
“Each document is associated with a single SQL
statement which made a database correction. There are
two different types of correction shown in the
files - the SQL statements for each are of the form:
“1. Update OPSSBRDB.brdb_rx_recovery_transactions
SET settlement_complete_time stamp = ..”
And then the “INSERT INTO” command.
It says
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“Type 1 reflects the action taken to reset the
recovery flag on a transaction. This will have no
effect on branch accounts (see footnote 58 in our letter
of response ...)”
Which says:
“Several hundred other balancing transactions have
been used but not in a manner that would affect branch
accounting. These were generally used to ‘unlock’
a stock unit within a branch”
Do you see that?
Yes.
Were you asked about the explanations that are being
given here, or would it be someone else at Fujitsu who
would know about this?
‘This would have been written by others but I’m fully
aware of
And then it says:
“Type 2 reflects the action taken to insert
a Balancing Transaction.”
It has a big "B" anda big
“Transaction”:
‘Balancing
where it changes transaction data in the main
transactional tables. This will affect branch
accounts.”
‘Yes?
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1 AL Yes 1 table for correcting in the manner suggested
2 Q. Sowhatis being said there in relation to type 1 is 2. A. For the locks.
3 that the 2,296 other uses of the tool have been used 3 Q. For the locks, do we?
4 mostly to unlock a stock unit within a branch and not in 4 A. Lean’t contradict you on that, so no.
5 a way which would affect branch accounts 5 Q. So it is clear, isn’t it, that the use of the tool has
6 A. Correct 6 now gone way beyond what we find in this low level
7 Q. Andthen there is one whieh it is accepted did accept 7 design document, is that fair?
8 a branch account and that’s the first one. 8 A. Certainly there are -- there is tooling which is based
9 AL Yes. 9 on this which has two aspects to it, certainly, so
10 Q. And that’s your understanding too? 10 I think I’m agreeing with you.
11 A. Thatis absolutely my understanding. The only way you 11 MRGREEN: Yes. Now, if we look at (H1/2/25}
12 would be allowed to write into those tables listed is 12 MRJUSTICE FRASER: Just before you move off, just to clear
13 using this tool and that would be listed as a balancing 13 it up for me, can we look at page 11 (F/425/11}. Now,
14 transaction 14 I accept that this is in Oracle, I think, these
15 Q. Just looking at the command that's being used for 15 commands, and if you don’t -- I’m sure you've got at
16 number 1, it’s not an insert command, is it? 16 least a basic knowledge of some Oracle
17 A. I'mnot sufficiently au fait with Oracle to -- sorry, 17 A. Lhopeso but
18 the first one, no, it says it is an update so 18 MRJUSTICE FRASER: I'm sure your knowledge of Oracle is far
19 Q. Yes, andthe point is, if we go back please to the low 19 wider than mine, but I do understand it a little bit,
20 level design which I took you to with some care at 20 but if you look at the second paragraph under "Method"
a1 {F/425/8}, it is clear, isn’t it, from this design 21 do you see it says:
22 that -- if we look at the last part of 1.1, the last 22 “The module will read the contents of the input
23 sentence of that first paragraph: 23 transaction file, which will be in the form of an SQL
24 “There will be no updating/deleting of records in. 24 insert statement.”
25 the branch database” 25 A. Yes.
W7 179
1A. Yes, it says that 1 MRJUSTICE FRASER: “Onlya single insert statement is
2 Q. If welook on the next page, page 9 (F/425/9}, you can 2 allowed and (after an optional introductory comment) it
3 see in-between the two tables: 3 must start with the ‘insert into’ clause.”
4 “The following transaction tables have been granted 4 AL Yes.
5 insert privileges ..” 5 MRJUSTICE FRASER: Am I right that you would then expect to
6 A. Yes 6 see the block capitals command at the beginning of the
7 MR JUSTICE FRASER: Where are you reading? 7 insert?
8 MRGREEN: Between the two tables, my Lord, at the bottom, 8 A. I think it is telling methat 1 would see an “insert
9 “The following transaction tables have been granted 9 into” one of those tables and then whatever data had to
10 insert privileges.” 10 be inserted into that table
11 MRJUSTICE FRASER: Yes. 11 MRJUSTICE FRASER: Yes and the insert would be part of the
12 MRGREEN: And that means that people who have the 12 command, wouldn'tit?
13 privileges of the “OPSSSUPPORTTOOLUSER” are allowed to 13 A. ‘The insert would be in the SQL seript because what I’m
14 run SQL insert commands, aren't they? 14 trying to do is to get a record into that table.
15 A. Theintention of this tool is to allow a set of people 15 MRJUSTICE FRASER: Thank you very much. That’s how
16 to run a transaction which will insert records into one 16 I understood it but I just wanted to check it.
17 or more of those tables and it will be audited 17 Right, Mr Green, over to your H reference
18 MRGREEN: Well, that’s not an answer to my question. 18 MRGREEN: I'mvery grateful.
19 MRJUSTICE FRASER: I don’t think it’s even vaguely in the 19 If we look at (H/2/25}. Now, at 5.16.3 you will
20 field of answering the question, with respect. Do you 20 see:
21 want to put it again, Mr Green? 21 “Fujitsu. (not Post Office) has the capability to
22 MRGREEN: This tool is confined to a privilege to insert, 22 inject a new ‘transaction’ into a branch's accounts.
23 isn't it, as described here? 23 This is called a balancing transaction. The balancing
24 A. I think so, yes. 24 transaction was principally designed to allow errors
25 Q. Andwedon'tsee the necessary database object fields 25 caused by a technical issue in Horizon to be corrected
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1 an accounting or operational error would typically be
2 corrected by way of a transaction correction
3 A balancing transaction can add a transaction to the
4 branch's accounts but it cannot edit or delete other
5 data in those accounts. Balancing transactions only
6 exist within Horizon Online .... and so have only been in
7 use since around 2010. Their use is logged within the
8 system and is extremely rare. As far as Post Office is
9 currently aware a balancing transaction has only been
10 used once to correct a single branch's accounts (not
1. being a branch operated by one of the claimants ).”
12 Then 5.16.4:
13 "Database and server access and edit permission is
14 provided, within strict controls ... to a small,
15 controlled number of specialist Fujitsu
16 administrators. As far as we are currently aware,
17 privileged administrator access has not been used to
18 alter branch transaction data. We are seeking further
19 assurance from Fujitsu on this point”
20 Now, this letter was in 2016. Can you remember
21 being asked about these matters in 2016 at all, or was
22 it not directed to you?
23 A. 1 don’t remember any specific requests, but I have been
24 working in this sort of area for a long time so -- yes.
25 Q. Okay. And in your witness statement you have also
181
1 referred to only one use of the tool, the point you have
2 made orally as well
3A. Correct.
4 Q. Fora balancing transaction purpose.
5 A. Fora balancing transaction
6 Q. Canwe please look now at {F/590}. 7 March 2010s the
7 target date. We're looking at PEAK 0195561, which we
8 have already identified , and you will see this relates
9 to 4 March 2010 and this time we're going to look on the
10 first page, at the second box down, and you will see
11 there call 2083169:
12 "PM was trying to transfer out 4,000 pds. The
13 system crashed. PM was issued with 2 x 4,000 pds
14 receipts"
15 Do you see that?
16 A. Yes.
17 Q. And that’s repeated at the bottom of that page.
18 If we go forward please to page 3 {F/590/3},
19 10 March 2010 at 8.51, which is the third box down,
20 Cheryl Card:
21 “After discussion with Gareth Jenkins, the suggested
22 correction is to negate the duplicate transfer out by
23 writing 2 lines to the BRDB_RX_REP_SESSION and
24 BRDB_RX_EPOSS_TRANSACTIONS tables, with
25 “1) Product 1, Quantity 1, Amount 4,000.00, Counter
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mode ID 7... 2), Product 6276, Quantity - 1, Amount
4,000.00 ... This should be done using the transaction
correction tool. An OCP approved by POL will be
needed”
Now, just focusing on your time at Post Office,
1 think at this time you're not really working on.
Horizon any more, are you?
Correct.
Did you hear on the grapevine of anyone at Post Office
being asked for authorisation for this sort of thing to
be done?
No.
Once you arrived at Fujitsu did you have any involvement
in seeking approval, or discussions with Gareth Jenkins
about anything like this being done?
No.
Did you know that Post Office 's approval had been sought
for this particular transaction?
No,
If we go forward please to page 9 (F/590/9},
22 April 2010:
“I have gone through the counter logs, OSR logs and
the DB dumps provided in the PEAK. Let’s analyse this
from serateh *
Pausing here, you have acknowledged under legacy
183
there were sometimes problems with duplications within
the Riposte system, yes?
Yes.
But we're not dealing with that system here, we're
dealing with Horizon Online, aren't we?
Yes. If it mentions OSR, certainly.
Okay. The second paragraph of that says:
“PEAK has heen raised when a clerk attempted to
transfer out of 4,000.00 from stock unit BBto MS. Due
to a system problem the transfer out doubled up, so when
the transfer in was done on counter 1 at 16.15, it was
for 8,000.00. The branch now has alot of (£4,000]"
Do you see that?
Yes.
And there’s then some discussion and then if we come
down to:
“But, I have noticed that the retried request (with
an ID] ... was ignored by time out monitor in the
(Branch Access Layer] side and continued to execute
But from the OSRiog file and OSR message log,
1 couldn't find this request was failed due to the
duplicate JSN record in the journal table (which was
expected and the normal behaviour of OSR), didn’t happen
in this case
“I have requested for the journal table dump to
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check whether duplicate JSN entries exists in the table.
But from the DB dump I couldn't find any duplicates ”
Now, the whole point of JSN entries is that they
should not duplicate and if they are duplicates they
should not be committed to the database; that’s right,
isn't it?
Yes. AndI think you will see there that the retried
requests failed because there was already a journal
record in the database with that JSN.
Well, let's just follow this through, if we may. If we
look now please at (F/594}, you will see that this is
PEAK 0195962. Do yousee that? This is Cheryl Card
again,
Yes.
And if we just go down to the yellow bar it says:
“The transaction correction tool has now been used
in live. The templates for use with this tool need to
be updated to correct some details”
Yes?
Yes.
So the idea was to have templates so that the scripts
wouldn't have too many errors in them when they were
deployed.
Yes.
And that PEAK refers in turn, we can see -- if we look
185
at (F/1095} please. Wecan see this is the OCP 25882
Can you just tell his Lordship what an OCP is?
Operational Change Process I believe
And there's also an OCR, isn’t there?
Yes, that is Operational Change Request, as I understand
it
And one is for the change to the front end and one is to
change the back-end. The OCPis for the front end and
the OCRis
1 don't know.
You don’t know. If welook at this document at
{F/1095}, the branch 226542 transfer out doubled up. We
can see:
“Due to a system fault, the branch did
a transfer out of £4,000 and a corresponding transfer in
of £8,000.
” Justification : correct a loss of £4,000 at the
branch due to a system fault
transfer in details were incorrectly doubled up when
they were written to the BRDB. This needs to be
corrected using the transaction correction tool ”
Do you see that?
Yes.
extra detail: the
Now, on the face of it this appears to be consistent
with at least one use of the transaction correction tool
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for one balancing transaction, yes?
Yes.
And are you aware of any reason why Post Office couldn't
have just used a transaction correction for £4,000 to
correct the SPM’s position?
If we-- the only reason that we would need to use the
branch transaction tool is if I got a one-sided
transaction
If you got a one-sided transaction?
Yes.
Let’s look, if we may please, at (F/485/1). This is
PEAK PCO175821. Do you see that?
Yes.
And the call status onthe right is “Closed - solicited
known error” Do you know when that code is used or
now?
No.
If you look down on 19 February 2009 at 17.39.40, can
you see:
“There are two sides to the problem relating to
these transactions. The first is where all five SC
transactions mi
ing core data as described in the
above-mentioned KEL”
Yes
That's one aspect of the problem in this PEAK:
187
“Second is absence of equal but opposite
(ie settlement) lines. See PCO152014 for a similar
problem and how problem was resolved.”
Yes.
“For the first problem, I have used the TRT to insert
the missing data ie Region, Margin, Margin Product and
EffectiveExRate ”
Now, pausing there, what does it look to you is
going on here?
It looks to meas though we are inserting into a totally
different database because it is TMS_RX so this is
the -- this is not the branch database.
No. Andalso they seem to be using the transaction
repair tool
Yes
Rather than the transaction correction tool
Which I think would be what I have referred to as the
TIP(2) repair tool.
Yes?
And TMSis -- yes, it's not part of the BRDB.
But what we do see -- and this is in February 2009, so
this is Horizon Online, isn’t it?
It could be .. 2009 was migration, so I don’t for
certain know without looking further at whether this was
old or new.
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1 Q. Would they be using the TIP repair tool with 1 MRJUSTICE FRASER: You are cross-examining him.
2 Legacy Horizon? 2 MRGREEN: Of course.
3 A. Yes, the TIP repair tool has beenused -- it was 3 MR JUSTICE FRASER: Just pause one second
4 basically moved across from legacy onto BRDB. It 4 Mr De Garr Robinson, it seems to me the witness
5 fulfils the samefunction, It sits inside the -- I'm 5 ought to be allowed to see those documents.
6 sorry, I have forgotten the name of the database, but it 6 MRDEGARR ROBINSON: Absolutely, my Lord. This illustrates
7 sits inside -- yes, TPS. 7 the difficulty , particularly with using Magnum for this
8 MRGREEN: Okay, Let's just take it 8 kind of cross-examination.
9. MRJUSTICE FRASER: Do you want to continue with this one 9 MR JUSTICE FRASER: Well
10 now to the end? 10 MRDEGARR ROBINSON: I'm not complaining, but it would be
11 MRGREEN: My Lord, if 1 may. I will try and take it 11 helpful and, my Lord, it would also be helpful it seems
12 quickly 12 to me if the witness is also given a copy of PCO175821
13 MRJUSTICE FRASER: Well, yes, but don’t take it quickly as 13 MRJUSTICE FRASER: That's exactly what I was then about to
14 in speaking so quickly the witness can’t really follow 14 suggest because they are linked and the same problem has
15 you. 15 arisen in that PEAK as well.
16 MRGREEN: I'm grateful 16 Mr Green, is the quickest and easiest way for you
17 MRJUSTICE FRASER: Idon’t want you to feel under pressure 17 have you got unmarked copies?
18 of time at all on this, Mr Godeseth, so 18 MRGREEN: Idon't, my Lord. I have only got mine marked
19 A. Thank you, my Lord. 19 up.
20 MRGREEN: Ifwe look at 19 February 2009, 17.39.40, which 20 MRJUSTICE FRASER: Have either of you got the facility to
21 is the line we were looking at, do you see the two sides 21 print those documents relatively promptly?
22 of the problem relating to these transactions and we 22 MRGREEN: We can go back to chambers and print them off,
23 just read this text? 23 MR DE GARR ROBINSON: My Lord, we might be able to print
24 A. Yes. 24 them off in a room we have just around
25 Q. “The first is where all five SC transactions missing 25 MRJUSTICE FRASER: Perfect. I’m going to leave it to your
189 191
1 core data as described in the above-mentioned KEL.” 1 two joint good offices .
2 A. Yes. 2 Mr Godeseth, unlike the usual warning "don't talk to
3 Q. And that appears to be the KEL reference at the top of 3 anyone about the case”, you are allowed to talk to each
4 the page, "KEL obenge3120K", yes? 4 of these two gentlemen who are going to give you the
5 A. Yes. 5 documents to look at
6 Q. And the second point is the absence of equal but 6 A. Thank you, my Lord.
7 opposite settlement lines. So what you've got there in 7 MR JUSTICE FRASER: I'm inno way limiting the time that you
8 the data is not a zero sum basket, in the data. There's 8 look at them, it is completely up to you, you're going
9 half of it missing, isn't there? 9 to restime at 10.30 tomorrow, but just in terms of common
10 A. That’s what it appears to be saying, so to do it full 10 sense I wouldn't sit and stare at them every minute
11 justice 1 would want to spend more time looking at it 11 between now and 10.30 tomorrow morning and that’s not me
12 but 1 12 being flippant, everyone reacts. differently when they
13 MRGREEN: understand, Well, perhaps -- I don’t know 13 are presented with documents in the middle of their
14 whether it would be 14 evidence and I don't really want you to come back in the
15 MRJUSTICE FRASER: How many pages are there in this PEAK? 15 morning having spent however many hours there are
16 MRGREEN: There are only three, my Lord, but you do have to 16 between now and then just staring at endless PEAKs.
17 look at the KEL. I wonder if it would be fair to the 17 A. Thank you, my Lord.
18 witness if he could be provided with a copy of this and 18 MRJUSTICE FRASER: But other than that, please don’t talk
19 a copy of the PEAK 0152014 and KEL 017510 overnight so 19 to anyone about the case.
20 he can consider those. 20 A. Understood.
21 MRJUSTICE FRASER: Well, rather than just grandly say "Yes 21 MRJUSTICE FRASER: Does that deal with that issue?
22 he shall be provided”, let's work out who is going to 22 MRGREEN: My Lord, yes.
23 provide it to him. 23 MRJUSTICE FRASER: I don’t think there is anything else?
24 MRGREEN: He is not our witness, but we would be happy to 24 No. So far as tomorrow is concerned .?
25 do anything we can. 25 MRGREEN: Weare going to be finishing with Mr Godeseth in
190
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the morning and then we don’t know the position in
relation to Mr Membery and then we will finish with
Mr Parker.
‘MR JUSTICE FRASER: Iwill leave you to discuss that between
yourselves. Just let_ me know in the morning.
MR GREEN: Most grateful.
MR JUSTICE FRASER: So there's no housekeeping or anything
of that nature and I shall see everyone and you as well,
Mr Godeseth, at 10.30 tomorrow.
A. Thank you very much.
(4.33 pm)
(The court adjourned until 10.30 am on Thursday,
21 March 2019)
193
1
2 INDEX
3 Housekeeping sesso
4 MR DAVID MALCOLM JOHNSON (affirmed) 3
5 Examination-in-chief by
MR DE GARR ROBINSON
6
Cross-examination by MR GREEN
7
Re-examination by MR DE GARR ROBINSON ou.24
8
Questions by MR JUSTICE FRASER 26
9
Further re-examination by MR DE GARR
10 ROBINSON
21 MR ANDREW PAUL DUNKS (sworn) sn DT
12 Examination-in-chief by ses DT
MR DE GARR ROBINSON
13
Cross-examination by MR MILETIC esoenue28
14
Re examination by MR DE GARR ROBINSON ow. 71
15
Questions by MR JUSTICE FRASER
16
MR TORSTEIN OLAV GODESETH (affirmed) 74
17
Examination-in-chief by ssn
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19 Cross-examination by MR GREEN soe
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154:8 156:3 160.17
176.16 181:9,16 187-3
awareness (1) 109:10
'b (2) 140:6 176:20
back (67) 2.3 422 6:18
103 11:25 3218,
37:24 431222
456,10,13,20.24
464,28 52:18 53:25
54:3 5612,13.14
6424 791 6413.16
88.19 90:20 93:10
9639 97.247 98.19
1031.4 11319 11823
12013
121:13,18.9.22,28,28
1232 1245.10.23
12521 13715 1405
142:24 146.11 147.17
150.23 15515 157.25,
158.2 159-24 1665
1678.9 1728 1753
177.19 191:22 192.14
backend (3) 113:17,20
1068
background (1) 108.6
bad (1) 26:3
badly (1) 168:24
balance (4) 5:16 110:15
146158
balancing (24) 68:16
095 12668 1402
167-4 168:17 16920
1702025 17817
17415 176.69.20
177.13 100:23,28
101359 10245
e731
bank (1) 168.22
banking (3) 84:14 112.9
ns14
bansal (4) 157:6 159:21
161.6 1626
bansals (1) 163:22
bar (1) 185.15
barbed (1) 11824
barcode (2) 133:2 142.6
barry (2) 26:23 27:3
base (2) 45:16 55:18
based (8) 8:11 23:14
110:15,17,23 1529
1565 1798
Opus 2 International
Official Court Reporters
POL-0109545
POL00111977
POL00111977
March 20, 2019 Horizons Issues - Alan Bates & Others v Post Office Limited Day 7
basic (4) 45:12 135:3, 164:21 186:3 120:8 123:5,6 built (1) 79:14 captured (2) 139:5 chief (2) 81:13 151.9 coming (12) 10:1 27:6
1442 17936 believed (1) 92:17 182:10,19 bullet (a) 12:3 468 029 choice (3) 43.915 73:23 7965.21
basically (10) 38:14 believes (1) 156:20 boxed (1) 111:4 132:11 1708 captures (1) 91:4 138.20 84:16 101:5,7 135:19
393.0510 92.20.24 I bells (1) 16614 bps (1) 10822 bundle (8) 416 card (8) 19:24 chronological (2) 1021 I 13836
13:17 130:18 145:14 below (7) 8:2 23:13 branch (93) 5:11 9:1 27:22,24 74:4,6,14,25, 104:22,24 105:15 150:14 command (5) 175:24
160.8 189:4 61:10 65:12 123:13 16:25 17:4,22 167:10 133:3 162.20 185:12 chronology (1) 167:11, 177:15,16 180:6,12
basing (1) 169.24 403 14322 167,8,21 20:6 225,25 I bureau (2) 1318 141 I cards (1) 136.17 circumstance (2) 433 I commanded (1) 126:1
basis (10) 2:17 31:3 beneath (1) 7:19 23:1,3,21 24:13,15 164.23 care (2) 58:7 177.20 524 commands (2) 178:14
41:7 51:7 59:20 benefit (2) 104:6 2615.22 273.1414 I burley (2) 12037,18 I careful (1) 129:7 circumstances (3) 3513 I 17935
3537.15 15414,19 us 62:3,7 044 92:23 94.1 I busily (1) 15:10 carefully (1) 17112 7122 9322 comment (9) 25:8
155.14 benefits (6) 82:16,21 95:8,10 98:9 113:4,7.7 I business (24) 1:13 carried (1) 29:4 celvil (1) 61.13 97:25 106:5 117:15,18
basket (10) 10:12,18 30325 1053510611 I 16.0 117311955 I 79,28 2223 236 carry (6) 29:25 claimant (1) 19 145.24 153.2 1672
140:19 141:7,9,10 best (11) 1:25 5:3 28:9 126:6 128.4 45:10 108:15 105:6,23 118:1 125:25 I claimants (4) 1:7 19:8 1802
1428 1461518 1908 I 40:26 4121436461 I 1296,0.19,23 11014,2623 11:16 I carrying (2) 29:21 7731611 commentary (1) 154.28
batch (1) 06:4 637,23 72:19 759 132.1225 13318 n14a7.25 156.22 clarifications (1) 75:6 I comments (2) 159:5,7
bates (3) 19:6,18 20:20 I better (4) 80-10 89:16 134:12,17 136:1,10 115:18,24,25, cases (5) 11:6 36:18 clarify (1) 75:4 commits (1) 147:14
be (1) 1849 9315 1673 137.8,11,13,17 u16247,18 1179 37:21 94:2 96:9 clarifying (2) €4:20 committed (4)
became (4) 26:16 83:21 I between (24) 11:1 23:8 138:8,11,12,15 116:1,8 1235 135.24 I cash (20) 5:16 170.17 147:12,21,25 185:5
97:28 10622 27.13 36:9 42.23.23 139:3,12.18 140.11 I busy (2) 245 1185 16:15,18,2223.24.25 I lass (7) 9:7.10.9 committee (2)
become (3) 11081155 I 469 58:14 66:22 142.13 143.25.149.4 I button (14) 936,22 y7a23192221216 I 2571914021 1051023
1323 71:19 103:24 106.9 166:3,3,4 167:16 10:14,17 13:14 14:57 23:7.15 84:3 141.16 ‘common (3) 115:3
becomes (1) 126 31510 1285 131:2 168.15,20 169:2.25 25:16,22 13424 123:16,25 12681662 I clause (1) 1803 139141929
before (20) 1:4 225 veaier1916217 I 1703323 17221, catch (1) 7319 clear (17) 24:22 38:16 I commonly (1) 11:7
4920 1312 2618 1663 175.16 1788 1763.79.23 cause (12) 25:7 90:10 93:4,20 96:25 I comms (1) 1302
45:16 462629 5124 I 19232,16 1934 177.45,8.25 3141 1421 1621 52.69.15 66:24 97-4 101-25 102.15,20 I communicate (1) 1367
52: 55:6 59:7 6014 I beyond (2) 97251796 I eLilieiesz219 I 289253559267 I 14638 1477.20 13457 138: 15316 I communicated (2)
3:27 7321 6426 I big (8) 79:10 122.22 106.12,1418 1877 I buy (6) 125,812.21 352.10 166716825 I 155217721179522 I 133211345
993,13 9525 11923 I 1933 1957.23 182.12 Frerery 1691 clearly (14) 12:2.9 762 I communication (3)
120:21 133:21 142.25 128-11 176:20,20 branches (21) 23:17 byfleet (1) 55:1 caused (2) 50:23 180:25 I 77.12.25 90.25 91:13 128:5,20,22
14315 150.8 15117 I biggest (2) 122.18 2419.25 2619.20 causing (2) 51:14 924932 10112 I communications (4)
15713166817932 I 127aa3 aio 628 6621 oe 105315 122210912219 I 1269,13.15.23
beforehand (1) 88:3 bill (2) 15:5 136:5, 93:14 119-4 121.1 I ed (2) 64:14.14 153.12 company (1) 98:25
began (2) 9915 106.7 I bith (1) 10322 125.20 1285 1203.5 centre (9) €9:2.2325 I clerk (2) 2613 1048 I compare (8) 339,15
begin (1) 131:12 bit (24) 2.23 7:5 30:23, 132.112 1339 136.16 I ¢ (2) 13910 140.7 111-20 113:23 125:18 I client (7) 47.2.25 48.2 61:3 65:24 66:17
beginning (4) 81:20 3433 3735 438 166.17 1704 (1) 205.26 7519 11319 1367.21 I compared (3) 35:12
1159 15020 1806 4421 458,25 60:28 I branchs (4) 89:3 160.22 I calculated (1) 140.23 I centres (7) 77:24 60:3.4 I clients (3) 105.24 6922 1288
begins (3) 39:19 49:15. 92:9 100:20 107:25 161:4,10 call (10) 1:4 3:12 27:19 86:12 119:4 128-6 113-16 118:9 compares (1) 133:8
108 11719 12619 brand (1) 122.20 69:16 73:24 79:22 3.25 close (7) 1:13 12:6,22 I comparing (1) 36:9
behatf (4) 6013 617 I 12527281303 brdb (16) 49:20 50:9 94:35 16211 16714 I certain (6) 66.80.6534 I 249253919315 I comparison (2) 36.19
1369.24 3322313919 1469 I 7678621138 called (12) 2:25 6:4 135.21 165.21 16924 I closed (1) 16726 371
behaviour (2) 147.15 1722167317919 I 13322 1345 1429 52.17 64207911 I cetera (1) 73:13 closely (1) 79:8 compensated (1) 106:3
184:23 bits (1) 1366 143:15 167:12 168:18 88:16 69:5 99:1 chairs (1) 160:15 closeness (1) 25:6 ‘competent (1) 15:17
behind (3) 320935 I blaming (1) 205.27 170.21 17:8 18620 I 121:16 162.14 16316 I chambers (1) 191.22 I closing (1) 69:16 compiled (1) 154:30
7425 blank (2) 95:13.22 188.20 19:4 180.28, change (20) 13:16 141 I clusters (1) 87:7 complaining (1) 191:10
being (66) 211 322 I block (3) 51:28 52:11 I brdbrxeposstransactions I alls (1) 54:24 24:2 109161131,5 I code (4) 56101313 I complete (3) 35.25 36.6
136,22 26.9 2725 1806 (1) 16224 came (10) 43126212 I 1518.261172222 I 16612 28715 4128
35:21 39:19 55:1 blue (1) 51:24 brdbrarepsession (1) 83:9 84:13 90:17 118-22 128:7,89 codes (2) 48:15 122.12 I completed (5) 13:13,16
56:25 58:22 63:15 bodies (1) 82:20 182:23 121:22,23,24 158:23 130:2.174:2 colleague (8) 12:25 18:21 119:20 124:1
64:20 66:17 bogerd (1) 70:4 brdbx015 (1) 174.4 165:3 186.3,5,7,8 30:1,5 54:12 60:13 completely (5) 15.3
697,11.21 705 boltons (1) 115:11 break (13) 53:18,21,22 I camelot (8) 1364.20.23 I changed (8) 39:2 26.17 148.24 157:6 23:26.25 1009 1928
7759.1 785.23 book (5) 79:5 106:15 54:6 €4:16 98:16 13724 1383.78 697117310631 I colleagues (3) completeness (1) 36.8
80:17 82:19 89:6 160:21,24 161:3 99:14,15 142:16,20,24 I cancel (1) 105:15 104-25 115.11 135:17 855,15,16 complex (4) 23:3.6
92:28 93:3,45,6.956 I books (1) 1355 1434.16 candidly (1) 724 changes (18) 845 collected (1) 47.22, noa7
1095 110:26 11156 I bootle (3) 77:23,25 brief (1) 1436 cannot (4) 55:18 95:5 11091144 1155,6 I eolleetion (1) 145:2 complexities (1) 104:18
113.19 11657 80:3 briefly (3) 4:8 70:12 109-15 1814 126:1,5,6,14,19 colours (1) 12:12 complicated (2) 117.12
n1735,18 181 boss (1) 120:18 164:16 ‘cant (28) 17:10,14 126:13 151.10 1535 I column (3) 154:20 anaes
123.23 1311 13321 I both (15) 25:17 20:22 I bring (4) 562.12.13 3025 3233734317 I as7a6iseaise19 I 1561416 components (7) 10:12
137.1 140-18 143.12 347.15 77:25 79:26 1245 44:13 48:10,11 51:20 170.21 176.22 come (42) 2:2 6:1,15 311.21 122.22 127.18
14725 149.16 20:6 64:6,24 105.24 I brings (1) 56:14 62.22.6924 71:21.22 I charges (1) 55:2 7.2.85 109 1923 1263 169:15.16
151:10,11 158:12 124:20 119-4 152.14 I bristol (1) 108-5, 106:5 116:22 12112 I check (10) 15:5,15 22:10 43:9,10 46:18 I comprises (1) 140:16
159:6 163:3 168:2,9 153:12 155.13 broader (1) 91:4 130:4 131.16 135:21 20:21 42:23 62:15 52:18 53:24 77:15 computer (9) 59:4 90:8
3752 17612177215 I bottom (22) €:20 61:29 I broadly (6) 162.8 25.24 I 145:20,23 150.22 #5:10.13 1482 i606 I e419 8619 904.16 I 91:22 96:23 101.23
161:11,21 183:10,15 68:3 62:2 85:4 44:6 84:23 91:15 18118 159:7 160:16 185-1 93:10 99:20 102:25 104:3 131:22,25 132:3
192.12 107.5,6,11 116:7 brought (6) 15:24 16:3 179:4 189:14 checked (4) 1:24 79.17, 103-4 12013 ‘computerise (1) 104.6
belief (7) 5:3 28:9 37:7 118-10 119-13 122.1 62.24 92:7 124-10 canvassed (1) 70:25 134-9 146.17 121.18,19 124.23 concentrating (1)
40:26 41:11 729 1512 15614 154.20 capabilites (2) checking (4) 2257921 I 1253 12611 1344 115
‘75:10 161:12,13 163:18 br (1) 126:5 110:16,23 85:17 165:21 137-14 136:10 140:5 concept (1) 79:20
believe (24) 1:21 13:24 165:25 168-7 170:2 bts (1) 88:17 capability (2) 116:18 checks (7) 44:4.6.23 142:5,6.24 153-11 concer (4) 66:5,6,12
34:17 35:15,24 39:20 ‘178:8 182:17 budget (1) 104:19 180:21 62:2,6 63:5 148:13 156:7,8 167:8 172:8 70:2
40:1,9.19 50:2 52:8 boundary (2) 94:17,23 I bug (2) 155:9 16:16 capable (1) 13:22 checksums (1) 42:21 184.15 192:14 concemed (9) 41:4
585 71:3 728,123 I bow! (2) 7914.6 bugs (2) 1543.14 capitals (4) 51:24 52:12 I cheque (1) 19:2 comes (6) 9:18 43:18, 56:9,14 63.6 125:17
74:15 76:19 100:;4 box (11) 7:13 12:23 bugserrorsdefects (1) 67:7 180:6 cheryl (2) 182.20 1386.15 139:11,18 1408 163-9 171-15
so2212321 we19 I 1375416037303 I 1548 capture (4) 152.22 105:12 comfort (1) 66:16 19224
366:17,20,22
Opus 2 International transcriptsI__GRO_
Official Court Reporters ro GRO
POL-0109545
March 20, 2019
Horizons Issues - Alan Bates & Others v Post Office Limited
POL00111977
POL00111977
Day 7
concerns (4) 46:22
104:21 121:8,10
conclusion (2) 22:11
10033,
conditions (1) 4938
confident (2) 76:23
49.17
configurati
14425,
confined (1) 176
confirm (3) 26:8 64:1
Be
conflicted (2) 117.19
1183
confused (1) 1258
confusing (1) 41:16
cons (1) 135:
conscientious (1) 15:11
conscious (1) 146:3,
consent (1) 35
consequence (1) 127.11
consequences (2) 16:18
1692
consider (2) 24:21
190:20
considerably (1) 120:6
considerations (1)
164.7
consistency (1) 36:8
consistent (8) 25:24
26:3 29:19 65:16
78:5 91:5 152:25
18626
consists (1) 49:9
constrained (1) 5325
construction (1) 6421
consulted (2) 85:5
86:16
contacted (1) 1242
contain (3) 58:15
1759.10
contained (2) 32:21
69
containing (4) $3:2,12
64:23 17316
contains (2) 139:17
169.21
contemplate (1) 164:3,
contemplated (1)
10824
content (4) 34:8 54:22
63:20 174.24
contentious (2) 96:16
orn
contents (1) 179.22
contested (1) 3:3
context (5) 22:23 45:6
143:14 15310 175.2
continue (4) 109.18
1187.8 169:9
continued (7) 995.6
33011 15112 157:18
1602 164.19
continues (1) 1195
continuous (2) 127:3.15
‘continuously (1) 96:21
‘contract (8) 83:9.10
84:17 98:18 126.24
12525 1521.3,
contracted (1) 151:25
contracting (1) 105:9
contractor (6)
83:8,11,12.15.20.21
@
‘contractual (7)
31:16,22 103:25 1066
14523 161:16,17
‘contradict (1) 179:4
‘contrary (1) 48:9
‘contributing (1) 65:23
control (5) 30:15
629,12 66:2 17231
controlled (3) 23:5
9207 18138
controls (40)
34:12,14,17,16.21
3725
382,69.11.14.17,20.21
397,912 45:12
492,911
61:20,23,24.25,
62:18,20,23
632,11,12,18,19,20
75 146.1314
3114
‘controversial (3) 618
92:3 136.25
‘convenient (3) 53:17
10224 142.15,
‘convention (1) 158:11
conversation (2) 97:10
13513
conversations (4) 8:12
136:16 169:10,13
conversion (1) 145:2
convert (1) 145:3
convey (1) 72:12
‘conveyed (1) 161.28
convoluted (1) 102:23
copies (3) 77:7 80:8,
1117
copy (10) 1:20 579.11
64:10 77.25 144.16
145.15 190:18,19
asia
‘copyright (1) 151:3
core (4) 39:7,9 18722
3902
correct (46) 5:14 67
32739 1326 30:2
33:4,10,20 345 54:12
61:5 69:20 755
82:18 83:3 85:7
90:24,17 91:12 92:46
96:5 121°8,23 12014
1376 1389 139.9
144:8 145:14 146:23
149.17 152.7 1543
159:11 168:16 170.19
171:2 176 181:10
1623 1638 185:18
16:17 167:5
corrected (3) 180.25
161.2 18621
correcting (3) 94.3.4
1793
correction (22)
167:12,16 168:4.5.15
1703.5 172:4,9.10
173217435
1752920 1812
12:22 183:3 185:16
196:21,25 187-4
18:16
corrections (9) 320
489,13 5: 7416
7557.7 1337
correctly (2) 616
147.13
correspond (1) 12.5
correspondence (11)
58:23 87:20 90:23
91:8 92.20 95:3
10023 101.6
1444,7.16
corresponding (1)
166.15
cost (9) 25:8 45:14
1107.25.17 115:20
116:24,19 156.25
abaly (1) 118.14
costs (2) 111-20 115.21
cosy (1) 10:25
couldnt (8) 18:4 29:5,
31:6 118-4 165:20
184.21 165:2 1873
counter (67) 65 12.25
25:24 26:13 36:18
5819 623,7 7715
796,0.15.21 065
9019.25 91:10,12,28,
92:1,29,25 93:25,
94:3,4,45,9,11,13.20
952,11,16,17.22
962.24 97:01,
98:4.6,6 101:7.8,19,24
108.9 125:19.25
12918 131:3.28
152.25 133:4
1397.21 140.11
141.78 1446 165:6
17013,15,36 162:25
16322 18411
counters (12) 55:10
#4:14,16,17 96:18,19
9.23 131:5,21 137.2
13816 146
couple (8) 8:19 9:4
26:11 76:15 85:20
87-7 99:1 1436
course (7) 27 15:10
293 11625 141.19
34210 191:2
covered (4) 5:12 856
9824 161.18
covering (1) 22:22
covers (2) 84:25 15214
coyme (5) 153:15 154.12
156:4 157.17 1635
coynes (3) 153:13
154.2223,
craigydon (1) 19:19
crashed (1) 162:13
create (1) 115.17
created (1) 1207
creates (1) 1737
credence (9) 17:19 18:1
13725,10
138:56,8,10
credible (2) 1046.11
credit (1) 194
ctieal (1) 119:2
‘rossexamination (8)
220 5:7 28:14 81:9
191:8 19461319
‘rossexamined (2) 70.5
wor
crossexamining (1)
yL1
crown (6) 26:15.2
27:3,3,15
csv (2) 170,22
ctr (1) 147.16
current (7) 221314
28:18 26:24 73.7
317.7 172:10
currently (4) 46:4 114:4
181.916
‘customer (10) 15:4
124:24,10,12 151:4,7
153:18 157:8 1676
customers (4) 9:2 15:11
19:4 234
cut (3) 87,14 150:19
cycle (1) 159:5
cycles (1) 11917
d (1) 139:25
42196 (1) 153:13
2197 (1) 1546
42522 (1) 156:10
42526 (1) 15633,
43167 (1) 36.13
43781 (1) 15417
daily (2) 47:6 57:21
dalmettington (3)
166:15,15,16
dare (1) 14237
data (210) 9:13 17:10
28:22 20:21,9,12,21
3:18 32.1615,
335.12,12,14,145
340,19
35:27,9,1012.14.17,23
36:2,4,7.8,10.19,22
37.2.13,20 385,15
39.26 405,24,16,22
41:4,6,13,24.25
422,11,34,16,1821.21
433,19 441,3.89.1
472.23
48:3,9,16,23.25
49:8,19,22,24
5021,12,15,19,19
51:28 52.2 531
96:1012,15,17.22
561,389.11.12,4,22.2
57.9,19 58:1,10,22
59:24 61:16.20
6369,14,19.22 6411
65:24
662.356.817.201
67-21 69.10.25
7:28.914368
76:9,10,13 77:24 803
81:6 04:24 667.1,12
91:1 9318 98:10
11:20 1126
1136,1.22
119.34,15 12518,
1266 132.20
153.99 1354
137.246,17 1383.15
339512518
140:7.15,18,24,24
141-2355,
14245,6,7
343°7.10,1.24.25,
144:16,30,1.17
145,3,8,10,12 146.8
148:10,12,7 149.45
155:9 17312
1755,9.10 176.22
180.9 1815.18 16722
1886 1901.88
database (34) 112
11348 1284
33711317
1382.12.16
339.13,18 14213
146-21 147.9,25 166:4
167.6 1685.21
169217028
37151313 175.19
177-25 17625 181:13
1855.9 186:11,12
1096
date (10) 617,20 20.25
23:15 24:3 38.22
47.24 60:23 63:4.15,
87:33 11749 12915
1325 1536 15820
165.10 1827
dated (5) 45:7 549
309.26 114.10 129:2
dates (2) 56:10 1268
david (4) 312.1422
aoa
day (11) 233
22:92,13,3,3,1415,
42:22 1231719 1285
days (12) 3:2 69:24
77:24 60:2 62:12
84:11 126:10.24
12719 143.21 165:9
a0
db (4) 147:0,21 13:23
1852
de (53) 1:4,11,15.21.28
27,18 312,16,17 55
13:18 143 2867.8
268
27:94047,19,21,22
28:11 4612.13
71:24,25 72a 73:4.24
743.4 75:36
789.1721 809,16
811,2899,11
191.4,6,10,23
1945,7.9,12,14.18
deat (9) 7719 84.14
1056 106-2 1466
350.15,25 192.21
eating (9) 5423 905
309.16 142.7 14311
150:10 160:20 184:4,5
deals (1) 1128
dealt (8) 2:24 17:7 58:8
77:8 94:8 126.28
1405 1596
debit (1) 194
december (5) 6:17
47:14 1587.15 1599
decide (1) 173
decided (1) 99:2
deciding (1) 10514
decision (2) 134.25
1352
decisionmaking (1)
a3
decisions (1) 46:6
dectaration (5)
16:19,22.23 2212.16
dectarations (1) 16:15,
decline (3) 1244.54
dectined (1) 124.22
deconstructed (1) 43:7
deemed (1) 113:24
defect (1) 155:9
define (1) 151:23,
defined (1) 15210
definitely (1) 144:20
definition (4) 362.410
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delays (1) 1476
delete (1) 181-4
deleting (1) 172.1
deliberate (1) 97:14
deliver (3) 15:11 10918,
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delivery (8) 17:4 64:16
3523 177,11
demonstrations (1)
5:20
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dense (1) 79.22
department (6) 58:6
82:6.21 89:14 99:7
167.23
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depends (1) 703,
deployed (8) 56:22,23
69:15 145:19 185:23,
deployment (1) 119:7
deposit (1) 1248
deposited (1) 124.14
derives (1) 62:18
describe (5) 39:15
yo1i7.ie 12915
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76:7 69.11 941
99:14 13419 148.13,
3521 17616 178.23
18722 1901
describes (7) 3:22 27.25
47.25 6024 64:4 747
10718
describing (3) 51:14
79317418
description (8) 63:6
90:22 10025 106:19
31429 125:7 155
1666
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1178.15 134:22
1671315 16814
370.23 .171:7
377:20,21 1797
designed (5) 89:4
301131158 11741
180.24
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despatch (1) 35.29
despite (1) 104.18,
destroying (1) 104:8
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133.16 145:24 1482
35325 160.11 162.23
1365.21 186.18,
detailed (6) 87:5
119:6,19,24 16:22
1694
details (3) 170.6 18518
18619
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detected (1) 147.13
determine (3) 50:21
76912614
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detract (1) 23:3
detracting (1) 69:21,
developed (3) 56:21
16:12 168:9
development (2) 2219
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devices (1) 131.5
diagnosis (1) 36:21
diagram (1) 51:21
didnt (24) 51:7 59.18
64:1 7020724
86:21,22 92:11,12
93:25 958,12 10320
106'5 107.25 110:19
11723 12033 127:18
149.18 150:3.9,16
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differed (1) 44:9
difference (6) 27:11.13
59:3 131.2 13011
17514
diferences (1) 139.8
diferent (24) 75.153
164 25:21 339 67:22
73:12 77:16 6220
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1179 124-14 12212
1301 141.13 1439
17520 168:11
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difers (2) 442 148.11
diticule (7) 12:6 62:17
883.1155 11816.22
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dliticulties (3) 103:20
02 12511
aliicuty (3) 25:7
362.13 1917
ditigence (1) 85:26
direct (3) 999 105.2
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directly (3) 97:20
113.11 136:20
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disagree (3) 23:10,19
13522
disagreeing (1) 60:7
disaster (1) 105:17
dise (3) 58:10,12 92:23
discem (1) 155:6
disclosed (1) 2.14
disclosure (5) 17 34
17412 175:9,12
discrepancies (3) 20.6
13811 1661
discrepancy (5) 1917
2116 22:11.14.16
discuss (3) 34:12 92:2
1934
discussed (2) 97:24
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discussing (1) 61:1
discussion (4) 1359
14315 182:21 184.15
discussions (1) 18314
Opus 2 International
Official Court Reporters
transcripts’ GRO
pot.
“GRO
POL-0109545
March 20, 2019
Horizons Issues - Alan Bates & Others v Post Office Limited
POL00111977
POL00111977
Day 7
displacements (1) 61:13
disproportionate (1)
156.24
dispute (3) 105:22
13426 13521
disputes (4) 37.22
66.22 71391353
disputing (1) 132.17
disruptions (1) 129:20
tinction (1) 33.6
divider (3) 27:24
74625
document (71) 6:4,6,6
11:20,23,25 12:18
22:19 244 45:6 2516
46.16 47:3.16,1925
485 59:21 65:17
69:13 7032 74:7
7547.18 77:10,11
77,3324 1074
08:21 1102 11135
3324 11410 1176
1825 12024
129.216 144:
3512.47 25.26.23
1529 1533.41.19
15425 1553.10.16,
1579.25 163:20
164:10.11 16514
167,715.18 168:2.14
17518 1797 18631
documentary (1)
16012
documents (22) 1:8
2437 318 27:23
381,209 6223 64
71a7 745 11620
1564 158217578
1915.21 192513
does (33) 3725,
930,31 20.2 2234
2322 25302721
339 41.23 46.16
52:60 56:21 5629
57:17 585,25 50:4
65:9 66:18 126:5,12
155.20 15620 159:20
161.10 168.10 1656
166.26.18 1688
192.21
docant (24) 9:9
179,24 19.923 309
4124 4228 48:6
5020 51.9 52:5 587
65:6 665 12621
13019 15415 158.36
162.18 16637,20,22
doing (8) 346 73:7.21
93:7 95:16 1082.3
10916
dollars (1) 7.22
done (27) 69 22.44
35:15 52 9217
9345.12.21 969.10
98:9 100.23 1014.19
1056 1062 111:25
119.28 1227 141:3.24
3632,11,5 20621
dont (122) 1:21 2:10
3:7 74 813,167
9111115138
172218 1625
1921 203328
21.9,17,21 23:25
3035 3115
33:11,15,21 36:17
35:5 44:16 452.4
48:10 50,25,25,25
5120.20 528
53:16,15,23,25 5613,
57:20 58:5 60:2 61:23
6202,11,12.13 631
662 68:1 69:12
703.915 716 72:12
7321 778 76:22
8521 9015
94:19,20,21.23 97:19
100:24 101.16
106:12,24 107.23,
108:14,15,18 109:4
1143 12312,12
126.15 1326 134.13
137.16 13821 1393
140:20 141:5 142.25
145.22 146.3
157.2223 1609
162:21,21 163:24
165:10,14 167.25
1726.19.20 178:29,25
179.15 181-28,
106:10,11 188.23
389.13,17 19013,
191.18 192:2,14,18,23
1932
double (6) 145.6,22.25
85:10,16
doubled (4) 1257
18610 186.12.19
doubt (2) 55:13 63:25
‘down (26) 7:21 45:25
54:3 68:3,18 77.21,
795,25 80:6 90:4
94:12 10511 114.13
118:15,16 1236
137.11 138.23 15613
161:10,11 182:10,19
184:16 185.15 16718
ddr (2) 36:14 15417
draft (6) 38:22 518
153:4 16718 1682
drafting (1) 38:28
‘dramatic (1) 12810
drawn (1) 109:20
drive (1) 155:24
driven (2) 1912.14
drivers (4) 114.17
182,17 11614
drop (1) 72
drs (4) 1122.6 1132
4s
dss (3) 105-4 1064
se
‘due (9) 45:20 85:16
87.15 1429 1439
164:9,21 186:14.18
dump (2) 184-25 1852
‘dumps (1) 183:23
‘dunks (22) 27:19,20,22
2815 38:17 4212
4320 455,17 46.21,
48:6 50:20 53:20 54:8
66:20 70:15,25,
724,11 75:4 1486
39411
duplicate (22) 19:9.16
21:8,20,24 55:17
56:7,22 57:4,16,25
64:23 65:9 66:10
147:21,26 148:2
16:12 162.22 164.22
154
duplicated (4) 21.14
56:24 57:10 77:14
duplicates (37) 20:12
22:6 50:13,25
52:11,14,18,22,23
526,22 58:2,12.13
56:4,5,13,20 57:22
65:21 76:11,13
7712.35
785,10,17,22
7914.24 80:16 81:6
105.24
duplication (2) 58:19
44.17
duplications (2) 52:15,
1881
duration (1) 167:
during (14) 14:15 30:17
31:11 32.1620 385
49:8 50:10 58:21
61:20 76:8,17,22
166.1
dvla (1) 82:12
© (1) 15325
21 (1) 746
e210 (1) 27:28
e2101 (2) 28:18 3229
2102 (2) 3425 37.24
€2103 (3) 285 3914
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e211 (3) 61:12,28 622
2110 (4) 29:24 4322
1489.23
e211 (3) 66:7 90.21
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e212 (2) 67:11 146.13
e213 (1) 8722
2116 (3) 68:25 96:20
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e217 (3) 905 96:20
10112
e212 (2) 65:2 103.11
2120 (1) 7421
e213 (1) 127.2
e214 (3) 74:25 130.24
132.21
e247 (2) 752 91:18
e215 (1) 1343
e216 (2) 143:6 146:7
eat (1) 146.13
28 (1) 3:19
£282 (1) 5:25
£2420 (1) 4:4
£243 (1) 625
€245 (2) 619 818
£246 (1) 72
£249 (1) 16:15
€26 (1) 417
£261 (1) 16:14
€265 (2) 422 16:18
e27 (1) 7425
2716 (8) 187.2 159:25
161-7 162.5
2718 (1) 7422
£204 (1) 32.7
earlier (8) 59.37 61:15
62:19 65.16 75:5
98:16 1503 1675
carly (5) 84:11 1088
3212 1261024
easier (1) 169:23
easiest (1) 191.26
easily (5) 14.25
25:11,12,13,21
easy (8) 14:26 15.18,
21:25 10322 105:18
edit (2) 1814.13
effect (7) 42:9.16 63:21
72:22 102:11 1671
1763
cffectiveexrate (1)
188:7
effectively (14) 34:21
48:8 58:6 62:21 79.7
84:6 90:21 95:19
99:16 1115 11618
149.23 1735.22
effectiveness (2) 153:25
155:23
efficient (2) 2:21 115.19
effort (1) 15624
eg (1) 166:3
her (10) 13:10 27:8
47-16 62:38 65:22
69:10 70:16 73:1
365:14 191.20
elderly (1) 115:3,
lectronic (4) 107:7.8.9
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elements (2) 10:5 1412
(2) 8910
else (8) 406 43:10 99:8
134.68 187.26 17613
392:23
elsewhere (2) 24:13
169:10
femerge (1) 104:12
emerged (1) 104:9
emerging (1) 115:25
‘emphasised (1) 58:27
‘employed (6) 28:19
81:12,18,20 83:18
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employee (2) 8314 99:6
employment (1) 82:2
‘empowered (1) 1112
enclosed (1) 175:13
encountered (3) 10319
309.11 12521
end (12) 3912.14
14:18 27.6 83:9 105:3,
16:5 127.25 1298
106:7.8 189:10
fended (1) 149.22,
endless (1) 19216
cengoge (1) 111.1
engaged (1) 135:13,
engages (1) 137°7
enhance (1) 125:20,
enhanced (1) 57:8
enhancement (2)
5620.23
enlarge (1) 8:20
enough (3) 123:2 1245
126.16
enquiry (1) 1127
ensure (2) 85:7 10937
enter (6) 5:14 910
1393 1422.3 16611
entered (8) 36:17 79:8
132.25 1339 14011
ire (1) 848
entirely (6) 38:16
61:23.23 78.14 103:22
uo.7
entities (1) 103:14
entries (5) 19:9.16
21:26 18513
entry (4) 7:24 156
2122 wa721
envelope (1) 95:19
environment (3) 106.39
309-7 181.24
envisages (1) 119:23
equal (2) 188:1 190:6
equals (1) 1493,
equipment (4)
136:1,7,16 139:10
equivalence (1) 126-17
error (9) 25.20 42:20
123:22 14619
155:10.12 15617
yen 18715
errors (9) 15:9 23:8
36:21 184:3,16
155:11,12 180.24
385:22
escher (2) 145:18 146:1
cesehers (1) 14517
especialy (2) 23:1
16:2
essential (1) 19:9
essentially (3) 3213
60:19 105:25
established (2) 49.1
1699
estate (2) 3620 145:1
et (1) 73:13,
ete (1) 10817
etu (3) 11210,11,12
europe (1) 104:17
euros (1) 7:22
even (4) 54:2 64:1
67:21 17819
event (3) 37:19 51:22
656
events (2) 32:1 173:10
ever (5) 46:18 93:10,19
3143 14615
every (5) 29.8 79:23
67:20 144.15 19210
everyone (3) 90:2
1922 1938
everything (1) 118.15
evidence (22) 19 224
27:7 31:14 34:4,13,20
36:25 37:20 53:21,24
60:20 61:5 69:5,
75:13 1008 1012
1033 140-20 148.6
63:1 19214
evolved (1) 117.1
exactly (8) 33:6 35:6.22
3928 12821 170.17
73919113
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vet (6)
3:16 27:21 743
1945127
example (10) 6.14 19:2
21:23 25:17 30:23
42.2 51:13 61-25,
1042 1647
examples (3) 7:7 1415
877
excel (1) 17:13
exception (1) 17212
exceptional (1) 93:21
exceptions (1) 17219
exchange (1) 164-21
exclusively (1) 49:19
execute (1) 16419
cetibit (5) 58.12
64:10,14.1417
exist (5) 46:1 93:25
1565 157.18 1616
existed (1) 72:2
existence (1) 63:12
existing (4) 116:19
45:3 157-19 160:2
exists (1) 185
exotic (1) 10:8
expect (4) 267 11931
155.18 1605
expectation (1) 138.25,
expectations (1) 1107
expected (3) 92:24
3692 18423
expecting (1) 115:25
expensive (4) 1156
u1710,18.21
experience (10) 23:21
2412.15.17 26:12
28:25 29.21 31:7
5217 699
experienced (4)
2421.22.24 126:22
expert (3) 36:14 86:8
1593
experts (3) 2:25 153.12
35513
expiry (1) 87:13
explain (8) 35:22 71:3
80:23 61:12 63:25
85:24 149:7 158.25
explained (1) 157-4
explaining (1) 134:1
explains (2) 1683
74s
explanation (8) 52:13,
32620 1317 1756.14
explanations (2) 88:6
612
explore (1) 2:2
export (2) 17:10.14
extent (3) 51:9 1672
3
external (1) 130.2
extra (4) 1617 175
92.28 166:18
extract (16)
33:12,14.15 37.6
38.15 414.6 4238
435 562.11 63:18
667 1133 154
1552
extracted (18) 33:8
3420 35:3 365 37.4
396 422,2115
56:11 636.14.16.22
645 66:2 71:14 1755
extracting (11)
405,16.21 41:13
43:19 67:18,21 58:1
66:3 67:21 815
extraction (22) 29:9
32:14,15 335 34:4
37:20 39:10 40:14
41:24.25 43:24
472,25 48:9 56:21
61:20 65:20 67:23
71:16 75:18.25 76.17
extractions (13) 28:22
29:1,4,13,15,22 30:12
34.22 385 498 64:11
78:23 80:17
extracts (6) 55:17
561.8 57.17 76:2
1330
extremely (3) 37:22,
114.15 161:8
1095 (2) 186,12
11420 (1) 1635
142013 (1) 16637
£14206 (1) 163:25
114207 (1) 164:6
11497 (1) 1656
14977 (1) 165:28
£1556 (1) 22:18
15502 (1) 22:21
£15566 (1) 22.25
1587 (1) 45:5
15574 (1) 45.16
£1663 (1) 129
£16636 (1) 129:4
fig9z (3) 151.1 159.20
1675
fiosz10 (1) 15515,
ug924 (2) 183:4 158-1
16925 (2) 153:7 159-4
16928 (1) 151:21
fu7io1 (1) 132.7
fari01z¢ (1) 132.0
A716 (2) 47:1 75:16
171610 (1) 49:32
171642 (1) 49.15
171643 (2) 50:8 75:17
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2(1) 95
(299 (1) 108:21
29910 (1) 120.1
29013 (1) 120:20
‘29916 (1) 121.16
29923 (1) 11224
29020 (1) 144:22
8 (1) 106.18
#39 (1) 1072
392 (2) 107.26 108:19
f4.(1) 715
£425 (1) 16720
42510 (1) 173:20
f42541 (2) 173:25
1933,
14255 (1) 1681
4258 (2) 16812 17.21
£4259 (2) 171.10 1782
451 (2) 1149 11824
fas110 (2) 126.12 1168
45133 (1) 119.1
4951 (1) 167.12
£555 (1) 126.23
85510 (1) 117.7
5552 (1) 116.25
£5731 (1) 60:10
15733 (1) 60:22
5734 (1) 61:22
Opus 2 International
Official Court Reporters
transcripts GRO}
POL-0109545
March 20, 2019
Horizons Issues - Alan Bates & Others v Post Office Limited
POL00111977
POL00111977
Day 7
£5735 (1) 643,
£5736 (1) 655
£568 (2) 120:6 1232
(5084 (1) 1234
590 (2) 147-1 1826
5903 (1) 16218
£5907 (2) 146.24 1474
5909 (1) 183:20
(594 (1) 18513
f614 (1) 120.15
6148 (1) 120:25
(676 (1) 54:8
£6762 (1) 559
(1) 7:25
£70 (1) 2042
£029 (1) 67:1
292 (1) 68:2
£6293 (1) 6921
0205 (1) 69.14
(932 (1) 127
93214 (1) 1218
(9327 (2) 1148122
face (8) 51:25 52:5
15415,16 16224
168.610 186.24
faced (1) 19:7
facet (1) 14:3,
facility (3) 118:9 123.21
191:20
factual (3) 219,19,24
fad (4) 48:15 56:10
17123 17230
(a) 14615 147.18
18421 1858
re (1) 158.2
failures (1) 12919
fair (36) 11:19 23:20
32:6 46:12 47:17
60:20 69:17 70:11
71:22 84:25 06:4,24
982 103:28 1128
1157.13 16:21,
117.2619 182
119:10 1252 126.16
1282,24 229:15,21,
13121 1385 1468
152.28 16:28 167.2
1797 19037
fairly (5) 29:19 104,21
127.21 1618
fait (1) 17747
fats (1) 26.15
false (1) 55:2
familie (11) 5:20 9:24
47.3 54:15 58:25 79:4
11422 151.9 1605
1642 1696
farniiarity (1) 75:24
far (33) 9:24 1633
17:34,36,23 1657
32.810 395 414
43:20 46:4,28 47.15
86:,9.16 5914 636
88:9 89.15 100:25
12619 1423
161.20,11 1623.23
179.28 181:8.16
19228
fascinating (1) 105:22
fast (3) 1:18 49:25 50:4
faster (1) 11558
faute (3) 137.25
186:14.18
faults (4) 41:5,21.21,22
feasibility (1) 11:22
feature (1) 24.19
features (1) 1212
february (9) 60:24 64:8
13133 13254 157.3
159.16 167.18 168.21
189.20
feedback (1) 154:13
feeder (1) 1125
feel (9) 53:25 87:2
479 116:3 12321
146.20 161:11 169:12
18937
feoling (1) 118:7
feet (1) 128:1
fence (2) 86:13 143:19
few (7) 41:23 471,32
68:24 69:4 84:5 91.13
field (2) 67:5 176.20
fiekts (1) 178-25,
figure (2) 21:26 135:24
figures (20) 21:7 31:13
32a 1287.17
125.620 148
97.9
file (20) 3:27.19
371,32 48:17 50:15
51:12 7613 78:11,38
1372039 1447
169.21 17316
1745323 1751
179.23 18420
files (13) 48:25,21
07:23 169:19,23,24
1704 1732425
1742223 1750.21
fiter (3) 21:2 22.5
s6a7
filtered (6) 18.24 20:24
2a 35:7,1022
fivring (8) 22:4
48:32,14,20 49:21,23
50,0 768
final (4) 58:25 61:2
6913.14
nally (1) 201:12
financial (2) 149:2
166.22
ad (13) 242 19:11,20
206 62:4 92:9 97:20
12520 147.20 166.20
1796 184-21 1852
finding (3) 921.12
12225
fine (8) 65:1 77:20
139214222
ngers (1) 3:6
finish (1) 193:2
nished (3) 84:12 96:18
12535
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fist (58) 3:25 5:25
96.10.19 11:19 203
2224 25:17,19 28
29,25 31:16 34.25
364,24 40:21 4422
45:8 46:8 52: 55:9
60137 72:6 74:8,20
1:28 64:21 68:15
90132 91:20 92:2 95:3
96:1 10023 131:22
1528,11,18 13414
140.21 141.26 1421
146:15.25
164:20,20,21.25 1675
174:16 1778.18.23
162-10 18721 1885
169.25
fi (1) 23
fitted (1) 16.11
five (5) 89:10 14221
169.16 187:21 169:25
fix (5) 6934.15
166.1213
fixed (1) 165:6
fixing (1) 209:5
flag (1) 1762
flippant (1) 19212
flow (1) 135.4
flows (1) 14313
fluctuations (1) 30:9
focus (3) 96:10 104.25
n613,
focused (1) 122:24
focusing (3) 15:17
1406 183:5
follow (7) 12:2 37:5
439 157.18 1602
185,10 169.14
followed (2) 34:15
643
following (16) 37:25
385 49:8,17 61:20
653.6 96:20 13624
155:22 16214 17223
173.15 175:6 178:4.9
follows (2) 30:6 149:2
followup (2) 27:7 60:25
footnote (6) 130:25
13319 1361.2 1498
1763
footnotes (1) 153:20
force (1) 62:24
fore (1) 1532
forefront (1) 7216
foreign (1) 164:23
forgotten (1) 189.6
form (3) 102.7 175.21
179.23,
format (3) 18:10 1454
165.22
formatted (2) 65:3,6
former (2) 26:17 157.10
forms (2) 44:10 49:24
forth (7) 13.6 84:20
87:18 156:23 164:4,5
1747
forward (11) 4:16 49:14
82:3 917 120.15
153.6 167-9 168.1
174:10 182.18 183:20
found (7) 48:18,
51:22,23,23 52.23
97.17 12816
four (3) 29:14 87:16
nei0
fourth (1) 115.15
fraser (127)
220,14,20,23.25
2:8,16,23 3.2.7.13,15
732,347 810137
10:8 13:22 20:15,18
2237.17 2436
26:10,11,25,18,22.25
27:2,5,18 28:13 32:46
46:13,18 50:46 51:47
53:19 60:6 70:13
71:24
735,6,11,14179
74:2 75:5 779
78:2.5,12,16.20
20:12,21,28 818
94:21 95:25 96:7
02:25 107:4,8 13013,
135.9 137:21,23
138:1,7 142:17,20,23
145.7 150:18,24
158:9,14,17 159:13,19
162:13,25 163:4,6,14
17263,15,19
1787.11.19 179:12,38
100:1,5,11,15
169:9,13,17 190:15,21
291:1,3,9.13,20,25
192:7,16.21,23
193:4,7 1948.15,
fraud (2) 23:9 106.7
freeths (2) 1:13 17412
frequent (1) 129:19
fresh (1) 54:2
freshened (1) 86:4
friday (1) 1:2
front (10) 3:18 16:14
27:23 60:24 74:5.16
75:8 132-7 106:7,8
fruit (1) 141.12
fujitsu (73) 26:19 29:12
30:2 31:23 38:1,10,13
39:4 418 4338
44:12,4 45:2 5918
65:17 75:18,22 76:22
78:7,12,14,24 80:18
01:3,4,12 635.915
84:7.18 89:1,22 93:2
98:23 105:6.23
106:2,3,7,21 16:21
117-20 1222.6.8,9.25
295:22 1317.21
136:9,24 140:1 145:19
146:1 1499 151:2,2.3
1526 154.13 1564.19
157.12 16238
17551 17633,
180.21 181:15,19
383:13,
fujtsus (4) 44:18
181-28 157:7,10
is (1) 1095
full (3) 55:9 60.27
390110
fullblown (2) 119:19,24
fulltime (1) 83:16
fully (5) 93:9.14 122.1
166: 176.15
function (1) 189.5,
functional (2) 119.17
131.2
functionality (2) 48:2
B04
functions (2) 152:15
anas
fundamental (2) 110.22
196
further (14) 24:2 268
27-9 45:25 46:15
48:16 66:15 71:23
94:12 97:24 15023
1681:18 188:24 194-9
fu
future (3) 56.23 57-7
115:24
gap (9) 42:22
50:13,17,24 5216
76:11,16 98:20 99:23
gaps (13) 42.23.25,
50:12 1:22.23
52:6.22 53:1,11,12
66:10 76:10,21
gareth (25) 54:10,10
55:5 64:18 85:21
862,17
87-5.8,12,15,19.23,
88:4,8 90:18 97.24
307.12.14 134.10
146-14 169:11,14
16221 18314
sgareths (2) 77:4 80:1
arr (51)
1:4,11,15,21,24 27,18
3:12,16,17 5:5
28:6,7.8 26.8
71:24,25 72:1 73:4.24
743.4 75:36
78:9.7,21 809,16
811,2899,11
191:4,6,10.23
1945,7.9,12,14.18
sgateway (1) 92.22
gathered (6) 50:16,
51:12,15 76.18
re11.18
sathering (1) 35:28
gave (3) 19 510 62:10
geared (2) 109.34
searing (1) 12516
general (3) 10:28,
138.5 155.25
generate (2) 576
13933,
generated (6) 32.23
33:1 95:13 133:10.16
ase
senerates (2) 47.22
1704
generation (1) 144-21
generic (3) 100:25
154-25 155-8
generically (1) 155:11
gentlemen (1) 1924
gestures (1) 10:8
get (23) 21:16 24.22
30:14,16 31:3 324
34:12 54:2,3,3 79:15
81:24 87:4 91:14 97.2
106.15 114:4 125.26
130.6 149.11 153.13
167.10 180314
gets (4) 26:6 53:3
136:13 1370
getting (2) 21:12
ue19
sirobank (1) 62:12
sive (16) 20:18 24:20
37:13 65:9 66.15 62:1
07:6 09:15 92:18
1172 120.12 126.20
1530 16110 175:2
as24
siven (10) 176 2912
46:5 66:2 75:13
88:17 97:10 13420
17618 19:12
siving (6) 19.17 53:20
£86.25 101-2 1032
14020
ailtches (2) 128:20,22
samt (1) 61:12
sgodeseth (20) 43:25,
73:24 74124 7512
81:11 8621 10:10
1032.9 1428.22
3641 17235 169:18
1922.25 1939 19416
sodeseths (3) 29:25
43.23 17416
oes (16) 9:15 56:25
57.3 649 76.4
1511372427
1367.11 13035.9
1862 17322
soing (50) 21.97
109,12 122 1920
31:2 33:4.19 36.23
37:21 7010.16 60.5
85:22.24 86:1, 9117
92.14 94:11 963
201: 105:1.21 11039
1135 1182 12219
125:0 130:18 135:10
13738 138:23
142.17 20 15356
15515 156:1 160.17
16825 173:9 182.9
1869 19022 191:25
1924,8.25
sold (6) 3639
37.1,15,37 66.7
om
sone (4) 12:15 20:22
1796 183:22
good (12) 14 1511.21
26:34 2815.16 40:8
73:16 7625 87.2
321
sgovemance (1) 159:2
government (3) 7:21
62:20 10314
sraham (2) 167:19,19
srandty (1) 190:21
ranted (8) 172:22.23
we49
srapevine (1) 163.9
srateful (8) 3:11 24:1
46:17 51-10 609
18018 109,16 193:6
srave (1) 162:13
sreater (8) 909.17
91.28 92:19 96.24
101-24 10213 17014
sreen (80) 22.69.22
3:16.11 5:78
713,156 818 1010
143 201637 216
2217 18 241,45
818,910 9422
96:1,7,8 102:24 1039
10769 13015
1372025 1382.20
142:14,19.22 1436
15:12 150:17,24,25
158:20 159:15,23
163:14.15
172714,7,.21,
178:8,12,18,21,22
179.11 180:17,18
169:8.11 16,20
190:13,16.24
191:2.16 16,22
192:22,95 193.6
1946.19
group (3) 891,22 108:5
groups (1) 47:28
guarantee (1) 30:25
guaranteed (2) 25:18
48:25,
guess (3) 27:2 44:21,
12022
guessing (3) 21.9 31:4
4611
guidance (1) 169:4
guide (6) 6:5,10,11,15
73488
guys (2) 85:20 108.5
h(a) 160.17
ane (1) 17412
ano (2) 1751.7
i225 (2) 179:11 18029
hhadnt (4) 59:7 63:15,16
iia
hat (5) 99:2 12023
173:18,19 190.9
hatfway (1) 105.12
hhand (2) 10:8 26:25
hhandting (1) 131.18
hhandover (1) 132.2
hhands (1) 53:2
hhappen (6) 1421 15:16
1747 44:5 51:20
18423
hhappened (10) 17:22
21:21 77:2 60:2 91:13
979,15 1258 147.15
159.16
happening (8) 9:21
579 763 1164
12415 122.23 142.2
160.14
hhappens (3) 96 1621
52.25
hhappy (4) 37.13
432,13 190.24
hard (2) 43:8 15555,
hardware (3) 11621
12919 131:22
harvesters (1) 1133
hhash (2) 171.23 17210
hasnt (4) 3525 3621
627 16219
hhasntste (1) 43:4
hhavent (13) 72.144
15:25 299326 474
50 524 79:13 84.9
1152 126:1 157.2
hhaving (19) 12.26 16:25
5418 7025 77:4 015
86.9 92.25 1014
20937 12:11 125:24
135517 146:3 162:13
165:4 170:13 1762
1215,
Opus 2 International
Official Court Reporters
transcript,__ GRO
POL-0109545
March 20, 2019
Horizons Issues - Alan Bates & Others v Post Office Limited
POL00111977
POL00111977
Day 7
head (1) 85:19
headed (1) 163:15
heading (4) 86:16
10727 1295 13035
readings (2) 65:4.7
hear (2) 70:7 183.9
heard (3) 20:8 61:14
6
hearing (1) 105:13
heavily (1) 105:16
held (8) 35:7 36:20 42.9
64:11 72:23 1136,7
1462
helen (2) 70:8,18
hp (8) 54:24 62:4
95:22 135.22
helpful (5) 27:5 65:25,
96:6 191:11,11
helpline (1) 125:7
hence (2) 134:18
15814
here (22) 12:18 16:12
21:9 34:20 38:3 43:23
60:20 76:18
7784032
78:10,12,17 97:6
148.6 15817613
178.23 13:25 184:4
high (11) 31:10 37:25
46:7 105:1 115:22,24
1215 156.25 1614.6
1632
higher (2) 3023 465
ighlevel (1) 118:4
bighty (4) 36.26.25 37-8
7639
hinted (1) 105.18
historic (2) 47:22 502
bistory (5) 62:2 84:8
1533 158.2 168:2
bit (2) 12:25 25:9
tng (6) 109:3 110.14
11325 115:21,23
163
tinga (8) 130:17.20
1311,2,14,16,22
13233,
tngx (29) 32.21 34.1
47.22 96:16,19 678
68:6 109:3,28 111:20
11325 11410
1169,15,17 110:24
1193 12019 126.10
127.8,25 129.8 130:16
1315.44 13232
35233
holding (2) 175 13822
holmes (2) 85:21 864
home (2) 12:5 146:21
honest (2) 100:13 124.4
honestly (6) 69:24
1306.12.24 10925
14522 151.8
hope (2) 68:26 179.7
horizon (121) 5:10
13:25 15:28
162.1234 .1738
19:20 25:25 29:20,20
32:20,21,21 33:24.25
3457.79.16 353
36:37,20 47:20
55:10,15,23 61:12
64:1 727 793.10
813 82:17 63:12
84:8,11,19.25,25
868,10 89:4 90:67
91:21 96:22 98:13,14
9929 101.22
103:10,12 104.14
106-13 108:10,22
309:12,13,21
11620.19 1174.4
185,13 1201625
124 125,13
126:21,23,28
1272,10,13,25,
128:1,3,4.16,19
151.21 133:9,18,21
1362.11 137:7,9.18
1383.8 140:1
143:9,10,12.16.21
144-21 1466 150:10
1543 15512 157.20
159.23 160.22 165:1
168:10 169:7 180.25
1816 1837 184.5
168-22 1892
horizons (1) 1177
hhost (2) 11221 1672
hosted (1) 144-28
hour (1) 61:17
hhours (1) 1925,
housekeeping (3) 1:3
193:7 1963
however (6) 15:4 25:10
56:28 115.21 147.25
39235
huge (1) 30:9
fhulme (2) 85:21 665
human (1) 96:2
humans (1) 15:16
tbundred (1) 1766
hundreds (2) 29:56
‘hypothetically (1) 20:19
fel (7) 73:43,14 9:19
105:27 106:18,21,22
toon (7) 12.7.8,25 13:11
140.27 141:23,15,
Teons (11)
125,9,12.21,24 134
165,11 133: 140312
aa.2a
ia (11) 90:22.25
95414,17,10,22
170:11,13,16 183:
tet)
Idea (6) 15:21 30:14
4611 83:17 126.14
195.23
Ideally (2) 114:16,25
identifiable (2) 101:3,
10222
Identified (9) 69:9
70.219 123:3 132.21
148.28 162:18,20
164:25 102.8
Identifies (2) 153:21
1735
Identify (6) 57:4,9 67:10
132.22 13:10 149.21
identifying (5) 65:21,
921 102.23 171:56
Je (4) 41:13 116:17
188.26
ignored (2) 94:12
e418
W (4) 113:23 114:2.3,8
illdefined (1) 23:15
ilstrates (1) 3926
im (104) 2:1,9,11,15,
gan 733 934322
1613 37.23 187
19142199911
241,22 25:15 272
3210 395 95:24
365,23 372.13 408
aa a3an
44103028
46:1427,24 47.4
51:10 523.5
561,912.14 5719
59.14 609 64.20.20
762323 782.10
79:45 60:9,2.15,19
#13 9512 681.23
suae 9934 94:22
976,745 103.18
107.29 11039 122.14
132.3517 1342
146:325 1481
449.17 2020.20
10:16 151.18 15722
159.2 160.17
3162.13.15 163.25
17615.17737
179.0,528
180.1318 1995.16
3191.10.25 1927
imagine (6) 14:24 80:1
3160.12.14 1623
17213
immediatly (3) 65:12
9731362
‘impact (11) 30:22 67:7
69:435 93.22.2625
0422 673 1345
impacted (2) 66:21 68:6
‘implement (2) 157:15
163:12
implementation (1)
1313
implemented (6) 845
51 154312 15714
163:1123
implication (2) 69.24.25
imply (3) 63:5.8.24
‘import (1) 162:15
important (13) 33:6
37:21 485 5225,
6215 79a 109:20
130:8 152.17,22 155.7
171.6735
importantly (1) 140;12
imposible (1) 146:21
impression (1) 104:20
improper (5) 40:3,13.21
593729
improve (2) 15:17 45:12
improved (2) 110.16
126.24
improvement (1)
16310
improvements (1)
126.21
inaccurate (6) 39:21
402.20 434 72,13
inaudible (2) 63:17
1615
inbetween (1) 178:3
Incepted (1) 133:20
Incidents (1) 152312
include (1) 149.9
Included (2) 57:7 87:8
includes (1) 1088
complete (2) 50:20
65
corporate (1) 113:2
Incorrect (1) 168:24
Incorrectly (1) 18619
increased (2) 110:6
1296
increasingly (1) 115:5
Increaibly (1) 48:5
Increment (1) 79:17
incromented (1) 31:5
independent (5)
83:22,9.21 99:3
a2
Index (1) 1942
icate (9) 50:14.15,28
sill 7612.13
7ea018 79:12
indicated (2) 120.9
115.5
indication (4) 26:20
68:13,20 155:8
Indicator (3) 67:4 69:18
70:20
Indicators (1) 153:22
individual (2) 35:2
1494
Induction (1) 116.24
industry (3) 46:1
105-10.14
efficiencies (1) 25:16
evitable (2) 100:23.18
Infamous (1) 1045
infer (1) 1225
Inference (1) 135:6
Infered (3) 96:9 96:1
3541
inferring (1) 97:22
info (1) 37223
inform (1) 149.24
Information (37) 16:24
17:3 3516.8 39:20
4oa.a9 42.9 55:8
728.23 8625 8759
982 975,11 1172
1367,8,13,14,20
1373.14 1383
443.13 14922,36,19
150.622 152:19
156:10.12 161:24
Informed (4) 305
348.24 152.18 1578
Infrastructure (4)
127-14 126.24 151.25
3522
Ingenico (1) 139:12
Inherent (1) 168:23,
intial (1) 23:2
Initially (2) 65:5
initiated (1) 1222
Inject (7) 89:2 91:9
96:1,11,20 96:12
38022
injected (17)
90:7.11,22,24 91:21,
92:18 95:6 96.22 97:2
301:18.22
302:1,12,16,19,20,22
Injecting (1) 91:7
Injection (2) 1023.8
input (8) 9:22 56:20
155.5 170:4 179.22
inputs (1) 155.6
wert (28) 91:25 95:15
96:12 101.14 140:2
169.22 172.24
373:2,16,21,21 1747
375.24 17638 177-16
178'5,10,14,16,22
379.24
1801,37,.81113,
1885
Inserted (6) 91:12
933.6 144-6 169:21
160:10
inserting (5) 92.15
1009 168:17 170.19
368:10
wertions (1) 170:25
inside (2) 18957
wist (1) 110.24
insisting (1) 111.6
insofar (2) 78:7 163:6
installed (1) 130.20
instance (5) 20:3 55:16
567 155:4 17210
instances (9) 41:17
44:1,3,8,22,25 91:13
348:10.12
instant (1) 123.18
Instead (3) 15:1.1.2
intact (2) 1222.8,
integrated (1) 107:20
wtegrity (21) 32:15
35:7,23.25
36:2.4.6,7.11 3713.20
44:4,6,23 48:23,25
49:3 66:1 71:13
vMg:t1 14813,
intention (4) 93:20
301.1617 1785
interaction (1) 1333
terest (2) 47.23 92:14
interested (5) 77:13,
78:24 80:18,22 97:20
Interesting (1) 10317
interests (1) 35:21
interface (1) 11214
interfaces (1) 1129
interfacing (1) 105
interim (2) 57:12.24
Interteaving (1) 119:16
intemal (8) 47:23 49:2
10761175
interpreted (2) 43:14
787
interrupting (1) 162.15
Interrupts (1) 42.23
intimately (1) 76:3
into (52) 5:13 87.14
3022 1621 20.16
334,19 36:17 55:15
62:12,24 77:64
79:14 62:8 87:16
69.3.9 92:16 933
3012 10720 119.15
321-19 122.25 133.9
3347 1364
1371137
13610,1
13912,15,10,19
14110 149.16 150:6
1732 1741 175.24
17712 178.16
18039101422
38610
roduce (3) 827.1
95.22
introduced (6) 56:17
92:28 119.15 1284
13445 157.10
introduction (4) 47:20
84:19 97:3 1039
Introductory (1) 180:2
investigate (4) 5225.21
53.8 66:17
investigating (1) 22:1
Investigation (2) 18:24
645
investment (1) 46:6
lnvite (1) 2224
fnvoke (1) 1744
‘involved (25) 58.12
37.2 44:11 46:28 53:3,
58:13 763 647,10
107:10.24 1104.25
nn7 11725 122.01
y2439 1343.15.22
1359.16 166:22
involvement (2) 107.25
1833,
ireland (1) 164:22
inrelevant (1) 130:22
‘san (4) 128.10 120:23,
13035
ont (43) 10:23
15:2,16,21 273 2823
33:20 42:15 47.36
52:22 61:15 65:14,22
74:20 61:18 66:25
882,12 102 111.28
11422 117.16 119:10
1265.17 12725 1308
14025 146:21
1526.18 165:23
166.16 167:15 17014
3748 177.21 178-23
1795 1856 106.4
186.22 190:9
isolate (1) 127
fesued (14) 13.210 305
149110
1565,7,9,12,18,19
368:19 16413 182:13
Issues (17) 41:5 43:1
485,23 45:3 66.20.25,
6738 714.8 761
30915 12610 146:4
148.14 160:19 167:4
Issuing (1) 106.14
itatcs (8)
7.9,13,18,19,19,22.95
82
item (2) 1017 215,
Items (5) 11:5 16:16
3399 146:22 147.24
erative (2) 127:3.15,
is (65) 10:14,18
3316.24 1428
152,14 16:12 20:11
21:24 22:1 23:22.25
3110 33:2,56,13,14
34:10,10 36:6 41.25
476,8,14 505
52.22.25 59:2.28 60:2
e135 6214
66:4,6,7,13 70:2,2.10
72:12 7518.25 776
27:4 88:3 09:19,.24
91:4 98:11 96:2 97:3,
98:24 100.13,18.18
103:22 104:18 11212
114.21 12312
127:4,16,22 128.7
13333 13741 13813,
1393.17 145:6,14
14620 15118
152:17,22 15:8 159.2
164:2 16512 167:1
177.16 178:19 198.20
Itself (9) 3:22 16:8
1719 27:25 51:18
71:6 747 10310
157.25
ive (6) 75:12 79:22,23
120:11 169:8
january (5) 56:16 98:20
301.22,23.24
Jason (3) 148:24
149:13,24
Jenkins (26) 54:10,10
555 56.15 58.16
6418 77:17
788,15 8617.21.25
88:2,6 90:16.17 91:15
97'5,10,18 100:20
107.1214 162.21
read
job (3) 48:6 67:16
250.16
Jobson (3) 65:20 06:3
1341
johnson (15)
3:22,14,15,17,22 55,8
821 1011 19:14 248
2525 269 14020
1964
joined (5) 623.6
839,15 98.22
joining (1) 04:18
joint (2) 164.21 1922
jointly (1) 1258
jon (2) 85:21 96:5
journal (11) 79:11
146.20 147:24 16845
1703 17249
186-22,25 1858
journey (1) 138:2
jpn (10) 62:26 7921.16
146-22 147:24 184.22
2951.39
jsns (2) 148.2
judge (1) 883
july (5) 549 105.22.14
1293 158.15
juncture (1) 99:20
june (1) 96:29
justification (1) 186.17
justified (1) 113.25
Opus 2 International
Official Court Reporters
transcript.
POL-0109545
March 20, 2019
Horizons Issues - Alan Bates & Others v Post Office Limited
POL00111977
POL00111977
Day 7
eep (4) 4414 45:2
ee 16229
keeping (3) 262 31:23,
197
keeps (1) 1355
kel (7) 68:25 18723
1902,34,17.29
kept (1) 162:19
ome! (1) 36:22
key (5) 87.9 101.2
13518 153.21 15633
keyboard (2) 14:6 133.2
keyed (1) 15:6
keying (1) 1331
keystroke (1) 141:6
kicking (1) 125:19
kind (2) 165 191-8
kindly (4) 839 3183
1042 1665
knew (8) 22:8 88:3
96:6 97:23 120.21
1333.28 161
kenow (115) 2:20 7:4
8:45,16.17 915 1233
36a7
17:2,15,16.18.24
16:25 1910.28 2013
22:9,23 25:18 26:12
31:3 3321 34:7
44:22,16 45:4 49:10
50:25 51:9,20.20
529.10 5311.14.15
54:20 56:13 57:20
60:32 62:11,11,12
632,13 70:15 7618
78:22,25 €0:4 €2:10
gos 92:11,12
94:2,20 95:2 96:2
10424 106:5,12,28
30810,14,15 1142
11721 1183 1225
12341,12 12614
1326.16 1385.16
1344.13 1386.21.25
14438 145:22
146:3,10,14 147:22
156.6 157:22.23 160:9
16123 162:12,21,21
163:25,24 16423
167.19 1685
17219,20 17614
1637 186.1011
167.15 188:24 190:13
1931.5
knowing (2) 60:18.22
knowledge (23) 5:3
13:16,25 1418 19:12
28:9 38.21 40:28
4121 43:6 62.9
63:7.23 70:22 72:19
75:20 87:2 88.9 125:3
146.9 164:4 179:6,18
knowiedgeable (4)
100.46 1252
known (4) 108:4 110.2
145,25 18715
knows (4) 96.4.5 69:18
13738
kis (1) 1542
label (1) 93:2
lack (3) 236 46:9,19
toid (1) 12:9
landscape (1) 45:33
language (5) 32:24 51:2
1459.11.13,
Jorge (4) 11:2 25:19
100:12.18
largely (6) 15:23 59:9
6018 1122.8 14428
largest (1) 104:17
last (12) 1:9 4:3 13:24
26:22,26 47:9 74:11
101.20 159.25 1708
177:22,22
later (8) 2:22 75:4
95:23 108.7 114.1
124591405,
latter (3) 53:45 124-24
latterly (1) 62:25
launched (1) 125:9
layer (1) 16419
layout (6) 10.22
143,19 16:8 25:24
262
layouts (1) 6:20
lead (4) 19:8 238,16
as7at
leaned (1) 105.16
leaping (1) 126.22
teamed (2) 94:24 95:3
least (7) 54:19 1308
140.6 15225 171:3
179.16 186.25,
leave (3) 73:23 191:25
1934
leaving (1) 82:2
led (2) 35:24 60:14
left (5) 93:16 98:22
15732 1582122
lefthand (1) 15614
legacy (36) 13:25 16:4
232,16 29:22 34:15,
55:8 81:3 63:1 84:25
868,10 90:7 91:21
96:22 98:13,16 101:22
209:2,11,21 1124
33212729
128:16,19 1439,18,21
148:20 150.10 159.23
160.22 183,25 189:2,4
legal (1) 5:9
legitimate (4)
949,11,13.18
legs (1) 54:2
length (3) 111:9,12.13
lengthy (2) 169:10,13,
fess (6) 15:18 92:1
94:15 96:3 116:9,19
let (4) 3:7 624 1679
1935
lets (33) 12:17,10 14:3
155 19:7 203 22:9
81:22 86.6 86:14
95:24 96:10 103:19
108.6.21 120:6,15
132:7 144.23 151:20
1533 1569 159.23
160:20 169.5,
171:4,18 17421
163:23 185.10 187.11
19:6 190.22
letter (7) 112,20 21
3741 17541763
161:20
level (13) 68:9 101.2
15425 161:4,6.16
1632 167:12,15
168:16 17220 17720
1796
levels (1) 1052
ifs (4) 1122.5 113.2
146
licence (2) 99:22 1085
ences (1) 7:21,
le (2) 15219
life (6) 126:23
127-4,16,23,25 1298
light (1) 99:24
like (28) 255 16:7 24:10
2598 26:17 485 52:1
64:28 72,5 75:12
765.15 79:3 902 96:3
100.7 1145.5 135:20
142.9 167.20 1585
159.19 166:15 17013
1727 183:15
likefinood (1) 10:3,
likely (2) 100:25
imit (3) 31:18,19,22
limited (9) 28:19 344
5618 57.12 61:13,17
107-19 1328 151:3
limiting (1) 1927
line (11) 7:6,15,25 9:5
12:16 43:18,21 59:18
159.25 1709 169.21
lines (8) 115:15 12810
162.28 186:2 190:7
linked (1) 191.14
list (7) 18:20 38:8
4:14.18 452 79:22
1532
listed (7) 39:12
6217.20 63:21 1554
17731213
listen (1) 96-4
listing (1) 38:2
lists (2) 61:22 1556
litigation (2) 96:17
97a
little (9) 223 75 16:1
34:3 438 458
152.28 167:3 179.19
live (6) 83:22.24 107:19
1087 121:1 185.17
load (2) 109:5 139:22
loaded (1) 137.11
located (1) 136:1
location (1) 13:4
locks (2) 179:2.3,
log (15) 18:6,20.23,25
19:12,22 20:22
21:411,13 58:10,12
68:18 174-14 184:20
logged (7) 95:10,22.22
16:8 1741 175:12
1617
logical (2) 13-4 100.13
logistics (1) 122:5
logout (1) 16658
logs (3) 13818
163:22.22
long (15) 208,12 28:23
3457 47:4 52:34 75:21
777.29 12020 1478
15516 166.20 161.24
longer (2) 06:2 113:6
look (124) 4:8
6149.25 757
117,18 123,57,9
3431721 1915
20.28 22.1626 23:13
36:14 36:19 3931
47:6 5825 6017
65.1023 67.1 663
722 113,20.25 853
96:6 9814.21 89.21
91:19 101:12 1039
304.2 105:9.13 106.25
107:11,26 106.6
109.23 1103.20
niias 11224
11492 115.5
167231176
11810.2825 119.13
120626 126: 127.7
1291.3 13267 1363
1407 143.20 14821
346.24 147-4 148.22
350.4 151.20 1533
15462023 15515
156.9 159.19.23
36020 161.7
163.15.25
166:10.1637
1656.17 1675
16915 171.4028
y7430.21 1772
372 17921.13,20
16019 16269
365:12,25 166321
167.11.18 1688
189.20 19037 19258
looked (8) 16:2,4 38:10
43.23 479 711 9620
1464
looking (38) 732 10:22
20:12 2168 229.12
314 342 383 4020
62.1922 792 84:20
93:18 95:5.20 97:6
y0042 101.7 10521
10616 1072.69
326.20 161:16,17
163:29,10 17419
17735 1627 160.24
369.21 19021
tooks (8) 59:19 902
1267 1585523 159.21
164.6 168.10
lordship (11)
1661.17.29 22
423 12037 12614
158.25 1662
loedships (2) 31:15
7514
losing (2) 104-7 106:4
toss (2) 105:16 186:17
fot (9) 1028 1617
59:15 103:20 11221
124,25 12815 141.28
yee2
lots (4) 114:20,20
nasao 127.22
lottery (3) 136:4.17.18
tow (5) 167:12,15
368.14 1779 1796
lower (2) 101:8 115:20
luncheon (1) 103.7
magnetic (1) 1332
magnum (3) 1:23 2
ai7
mail (4) 3:4 62:23
99:70
mails (3) 7:9,12,18
‘main (7) 6715.16
115.17 161:5 1663
369.16 17622
mainstream (1) 129:16
‘maintain (2) 125:19
11620
maintained (3) 15.24
32:16 49:3
maintaining, (2) 37:20
ues
major (4) 84:2 109.15
415413
majority (5) 11.6
106-21 132.24
140:10,23
sakes (2) 137.11
169.22
making (8) 34:22 35:20
46:6 91:51 1164
ug..i4
malcolm (3) 3:14.22
194
man (2) 159:12.14
manage (1) 48:2
managed (2) 67.14.24
‘management (31) 2:21
16:24 17:2 234
1292 150.25
1515,0.26 15216,15,
153:16,19.24,24
354:12.19 1551.36
156 6,16 157:9 160:22
1615.18 163:10.16
364.12 165.7 167:7
manager (6)
26:19,20,23 148:25
1771
managing (1) 145:16
‘manipulated (1) 63:16
manner (2) 176.7 179.2
‘manual (7) 7:24 46:7
47:2 49:15 57.16
75291333
manually (7) 9:9 21:4
382.24 14020 1421
16:9 174-4
many (18) 12:24
2931 3016 31:28
45:24 69:16 96:9
102,10 1092 115:3
34129,19 15635
166.17 185:22 190.15
a2a5
‘mapping (1) 271.25
march (16) 11 28.20
64:16 1208 121.21
1235,15,25 124:8,17
1475.23 1826919
1933,
margin (2) 188:6.6
margins (1) 80.9
smark (2) 120:7.16
marked (1) 191.28
market (1) 135.9
‘massive (1) 105:25
match (5) 48:18 595
61:24 66:9 12317
‘matched (1) 1101
matches (1) 49:12
‘matching (1) 48:18
‘material (6) 27:12
4024 411,712 72:20
smather (2) 314,17
maths (1) 73:20
matter (1) 15
matters (4) 75:5 97:22
uzie 16121
maybe (4) 21:22,23
30.18 4313,
mean (17) 14:14 21:8.9
259 35:22 39.23
40:11,15 59:11 77:0
786,12 63:11 87:6
119.10 19:20 161:28
meaning (2) 40:9.13
means (4) 12:25 4610
19313 17812
meant (2) 13:6 122.6
measure (2) 36:9
155.25
imeasurecontrot (1)
1542
‘measuring (1) 153:22
‘mechanism (8)
§5.10,14.17 56:19
57:8 10614 107.18
13418
mechanisms (3) 77:26
91.6 11236
media (2) 35:3 61:7
‘mediation (1) 30:28
meetings (3) 160:14.18
1621
member (1) 1242
members (3) 89:8,10
42
smembery (1) 1932
memory (2) 38:22 87:17
imental (1) 73:20
mention (6) 65:8 127:5
128-14 130:23.24
346.13
mentioned (8) 18:21
62:15 98.16 10311
1325 140.19 146.13
14620
‘mentioning (1) 107.14
‘mentions (2) 164:20
1846
message (29)
50:10,11,13,147.18
5125 6914
768,9.11,12,16 79:20
80:7 87:8 90:23,24
95.13.15 11347
13522 104:2.4,7
145:14.15 18420
messages (15) 48:19
49:20 50:9 521
623.68 76:7 79:15,20
87:12 919.21 92:24
1015,
messaging (3) 86:20
M1235 143:23,
met (1) 49:18
method (3) 173:25
3748 17920
methodology (4)
15719 1603.49
metrics (8) 15321
154:1,10 155:17,18,22
26155 162:17
middle (7) 11:5 5320
1082 14735 16417
1753 192.13
might (25) 2:17.18 8:28
1419,19,22,25 23:28
a7 3348 3715,
3816 44:14 45:3,
5022 51:7 52:13
62.23 66:9 70:15
7at 106.15 137.21
162.14 191:23
‘migrated (1) 11935
migration (10) 107:17
108.22 109:12
2192,17,19,25 125:16
127.8 168:23
migrations (2) 1393
12519
milestones (1) 131-4
siletic (15) 28:23,24,25
32:8 46.17.21 507
516,10 53:17 548
609 7014 71:22
19413,
silions (1) 104:7
sind (5) 72:26 115.24
1352 19:10 150:14
sine (2) 179:19 191-18
‘minimal (1) 133:
minimise (1) 15:9
ministers (1) 1056
minor (1) 1398
minute (5) 19:24 84:20
12012 142:23 192:10
minutes (4) 53:24 1249
142.21.28,
smieror (1) 49:21
snieroing (1) 90:22
smierrs (1) 49:4
misinterpreted (5)
775,10 7866.8
imiskeying (3) 11:15,22
pert
imiskeys (1) 1425
‘nisleading (2) 33:18
346
snisra (6) 54.15.25,
56:11 645 14819
smisras (3) 54:16 60:16
14618
smisreference (1) 108-20
miss (2) 68:13.19
missed (1) 79:3
smissing (13) 50:24.18
62:1,8 67:3 6925
76412 1739;
167-22 188:6 19:25
1909
mistake (4) 132.20
1515 1728
mistakes (1) 15:19
misunderstanding (1)
agua
mitigation (1) 130.25
smmtim (13) 8:23 10:7
48:13 53:9 59:6 625
8912 90:1 10413
nis 133:6 147-12
1488
mobile (1) 112.12
mode (1) 18351
Opus 2 International
Official Court Reporters
POL-0109545
March 20, 2019
Horizons Issues - Alan Bates & Others v Post Office Limited
POL00111977
POL00111977
Day 7
‘model (1) 121:1
modifications (1)
144.25
modified (2) 112114
11320
module (4) 16815
174:4,6 179:22
‘moment (9) 28:12
53:17 65:10 95:3
1407 14235
monday (2) 1:13 70:4
‘monetary (1) 105:15
money (5) 104.21
121.25 124:2.6,14
‘monitor (1) 164.16
month (1) 149:3,
‘monthly (1) 155:22
months (3) 61:16 104.7
10534
more (39) 11:11 12.9
134 1422 154,3175
212 30:19 31-2 43:18
55:12 76:4 79:4 87:4
28:9 10:25
1108,10,11 111.911
1154819 1258
12829 132.23 134:11
141.38 142:4 146:8
15241 153:25 162.23
165:21 174.23 178:17
1837 1901
moming (11) 1°4.16
26:15,16 53:21 1388
14a7 1921,15
1931.5
most (10) 11.6.7 221
47,35 88:11 69:24
99:38 125:17 155.7
1936
mostly (2) 88:6 17:4
motive (2) 149:18,20
move (6) 46:25 49:14
83:7 150:17,18 179:12
moved (6) 35 834
1227,9 131:20 189:4
moving (4) 76:25
12527 1286.10
ims (6) 62.10.15 64:3,
65:2.21 184.9
much (26) 5:14 8:20
1736 2417.21
2716.18 46:15 54.4
59:24 66:15 72:5,
73:23 84:7,10,15 68:3
106:13 1093 11312
13343 141:18 145:15
180.5 193:10
muir (2) 148:26 149.24
multiple (1) 149.5
must (15) 214 31:23,
42:16 48:25 67:9,10
69:4 104:23 11325
11920,24 14635
150:7,13 1803,
smustnt (1) 150.25
myself (1) 1347
name (13) 3:25 4:19
27:2. 28:1.2 748,19
75:1 96:21 1596
163:22 167.25 1896
namely (1) 136.16
snares (1) 17114
tnao (1) 104:20
narrative (1) 1208
national (1) 62:12
nations (1) 1046
nature (2) 155:8 193:8
navy (1) 62:2
inbsc (8) 20:4 124.132
1358
nearly (2) 1146 174.23,
necessarily (5) 22:10
782 95:8 117.28,
1526
necessary (2) 91:9
17825
necessity (1) 92:16
need (14) 1:26 2:14
813991756 181
31:5 4519 9329
1132 1173 185:17
1876
needed (3) 87:3 146-10
1834
‘needing (1) 64:23
needs (3) 129:21,25
18620
negate (1) 162:22
negatives (1) 102:10
network (6) 22:19 87:16
106.9 136:11 129:23
13120
snover (7) 15:15 43:2
4615 699 95:13,
155:10 1698
snower (1) 77:26
next (19) 15 2:23 325
12:24 148,21 174
25:20 72:18 76:25
126.25 146.21 150.2
171.21 1738.9,25
1782
fap (2) 122:6,10
tine (1) 13:24
‘node (9) 50:10 76:8
9022.25 101:8 123316
1248 17031.16
nodes (1) 92:20
‘nods (1) 5:23
none (2) 8:2 71:9
nonzero (1) 174:22
thor (2) 44:3 146:12
‘normal (2) 90:24 184.23
note (2) 51:15 1516
noted (3) 56:13 61:25
157
notes (1) 104:16
nothing (4) 618 73:22
47 13728
notice (1) 25:16
noticed (3) 56:19 150°7
18437
notification (1) 123:9
notified (1) 125.7
‘nought (1) 1437
november (6) 58:14,14
823.7 83:16 1083,
int (2) 130:10,13
nea (1) 1315
‘oun (2) 57°5,11
‘umber (58) 11:9 124
153 2024 2131.24
22.25 295,18
305,23 42:22 514
67:22 79:12,20,23
807 81:20 85:12,15,
26:21 87:6 89:16 90:9
91:3,6,23 92:1 93:1
94:2,10,11 96:24
98:4,6,6 101:24
202.13 109:1 126:2,22
127.17 13035
146:20,22 147:26,25,
149-1 158:10 169:3
170:13,14,25 174.22
17:16 181.15
numbered (2) 50:9 76.7
numbers (8) 42:24 57:6
94:9,13 97:21 101:8,9
1304
o
‘obenge3120k (1) 190:4
object (2) 171.14
17825
objective (3) 10612
151.2223,
objects (6) 15619
171:56,12,13.14
observation (2) 118:16
13031
obtained (1) 88:2
obvious (1) 88:11
obviously (13)
2:35.34 21.2 48:20
5225 80.2 85:1
126.21 146:3 1482
1642
occasion (1) 100:24
‘ccasionally (1) 25:10
‘occasioned (1) 83:7
occasions (2) 42:3 91:9
occur (5) 1419
155:10,11 166:1,12
occurred (5) 22:12,16
5821 123.22 1688
clock (2) 103:1.5,
cep (4) 183:3 186:1.2.8
oct (2) 16:49
‘october (4) 6:21 24:5
4571683
office (134) 6:4
1719.24 183.5 19:19
233,17 2623 273.15,
2820 30:15 31:19
33:16 35:15 36:5
376,14
45:6,6,11,13,20,23.24
46:4.6,22 47:23 49.2
56:48 57.12.26 63:17
64:15 65:23 66:4,22
m520
a14,7.19,20
826,816.22
8324218
246,13,14,15.7
86.114 87:.16
9822,24,18,19,22.25,
99116,27,18,21.28.25
100:1,20 103:25 105:7
106:9,20 108.5 109:17
1106,9,15,22 11:16
113:17,20 115:25
11623 1175.21.25,
1184.17 121.16,19.24
123:10 124:18,20,22
12535 1292 1328
133:8,14 134-25
136:9.23 143:25 149:4
151:4,16 152.6 153:18
354:7,13 1561219
157:8,12 160:18
161:23 1622 164:22
167-6 180.21 181:8
183591873
offices (10) 62:14 104.6
321.2 133:20 136:9.24
137:4 156.18 183:17
a2
oh (3) 18.9 107:3
12:16
okay (37) 1:20 4:18
11.21 18.13 19:25
20:5 21:20 24:1 39:25
41:20 42:12 65:20
8055 107.5 1086.19
209:20 11321 1149
31610 121.17 1221
123:14 125.20 13612
137-4 142.14 1486
151:20 159.4 160:20
361.23 171.18 172.21
181.25 1647 1898
olay (2) 74:1 196.16
old (6) 84:3 1091 1178
10:11 148.29 186.25
onboarding (1) 65
once (7) 85:12 66:2
71:14 87.23 99:19
361-10 163:3,
ones (5) 8:25 44:7
301.7 162:20
comesided (2) 167:7.9
online (38) 16:1 29:22
32.21 345,7.9.16
793,10 83:2 84:25
89:4 90:6 108:22
309.13 1129 116:24
17:4 1206.25 1211
323:20 125.13 12624
327:1,10.25 1283.46
4401 143:10 1466
168:10 1697 181.6
194:5 168.22
onto (4) 10:3 33:21
139:14 1894
onwards (2) 34:9 147.36
open (1) 1108
‘opening (1) 98:24
operate (4) 23:2
115.6,19 116:19
operated (2) 23:6
yeni
operating (16) 27:12.13
4114518
42:46,8.13.15 464
61:5 63.21 69.15
7220.21
operation (5) 22:20
25:25 42:8 7222
3112
‘operational (13) 45:21
465 9216 1108.12
114.16 14825 171.19
37233,14 1612
186:3.5
operations (4) 22:25,
68:4,16 148.25
‘operators (1) 17212
opinion (3) 2644 37:16
1547
opportunities (2) 13:12
239
opportunity (2) 15:6
45a
opposite (2) 188:
07
copsbrdbbrdbrerecoverytra
(@) 175.22
opssupporttooluser (2)
yaa 17613
option (2) 48:17 138.21,
optional (1) 180.2
options (1) 134-21
oracle (9) 66:3
322:6.21,26 125123
3777 179143618
oral (1) 160.13,
orally (1) 162:2
order (7) 1622 38:39
48:25 69:7 106.15
uizag 13310
ordinary (2) 15:10 93:5,
organisation (1) 110.7
orientate (4) 1815
£8:20,24 146:24
original (5) 162.2
30150 10632 11014
originally (2) 105:
use
osr (5) 14736 163.22
1846.20.23
ostiog (1) 184.20
others (3) 29:11 162:23
17635
otherwise (2) 33:23,
34:3
fought (2) 60:12 191:5
outcome (1) 1418
outlet (1) 171:23
outlets (2) 107:19 108:7
outlined (2) 44:7 6413,
outlines (1) 45:10
‘output (1) 1555
outputs (2) 155:6 161.3
outreach (1) 16:4
outs (1) 10837
outside (5) 54:2 70.21
135:25 144:20 16219
outsourced (5) 98:25
99:4,7,8,10
over (47) 6:19.25 22:20
25:24 26:3 29:3,
309.21 31:5 34:24
39:14 43:24 49.1
50:7 61:22 64:3 65:5
66:4 68:2 69:1 73:10
Ta:18 €2:5 87:10 90:4
94:21 96:20 108:4
105:22 1159 12615
107-4,15.22 1343
153:7 1545 1565.23
157.26 159.417
164-25 174-2525
90:21 111:19 126:20
15:24
overtiaul (3) 127:1,33
38:12
overlapping (1) 44:21
overnight (1) 19019
overview (1) 160.12
own (3) 60:9 146.9
yaa
conned (2) 164:22 274:5
‘ownership (2) 115:20
neis
E
ssaachage (1) 169:17
pad (1) 142:5
pages (1) 190:25
paid (2) 19:4 99:12
paper (1) 45:10
parageaph (103) 5:24
y6:4 1816 2224
28.7 304 3116
32:48 34:24 36:15
37.24 384
39:16,17.39
43:7,15.25 44 4823
49:4,13 55.9 58.25
59:10 6017.16.25
621 68:3 6512.13.14
6614 722.35 738
78.2022 81:12,22.25
82.15 85.2.4 866
677,104,182
9014.20 91:18,19,20
94:16 96:19 101:11.12
108:10 10416 106:7
31020 112.25 114.12
11515 1268 1192
12625 127.7 152.19
139.10 140.28 141.22
1438.22 144:12,23
1467.13 1489.13.22
153:18,5 15422.23
187.1 159:24 160:20
1617.14 1625.16
17110 174:16.18
17723 179,20 184:7
paragraphs (8) 26:12
(61:10 86:22 67:6
un93 157.17
162:18.20
parameters (1) 171-21
parcelfrce (2) 99:21
1084
parker (6) 85:19 89:18
91:24 94:24 9613
1933
parkers (1) 65:25
part (22) 13:8 17:7
36:24 38:16 458
51:11 6922 66:11,11
97:4 99:10 107.9
1087 113.23.24
114.26 137:28 140:6
34211 17:22 180.11
188.20
particular (16) 12:2
20:23 22.11.15 28:25
38.9 55:13 67:12
man 7921 115.23
1162 14017 149.18
1509 16318
particularly (7) 14:13
37-21 13542 151.29
165:12 166:25 191:7
parties (2) 5:11 143:14
party (1) 57:15
pats (2) 36:20 99.22
party (6) 33 4318.21
59:18 1059 137.15
passing (2) 61:10 66-4
past (2) 14225 161:3
paste (2) 87.14
pathway (4) 99:19,
1045 105:17 106:18
paul (2) 27:20 19813,
pause (5) 40:7 88:23
126.13 136:12 191:3
pausing (15) 35:9 39:22
41:1,16 56.25 69:6
90:15 108:24 109:7
2115 12636 127.7
1525 183.25 1688
pay (1) 150:9
paying (2) 15:5 11212
payload (1) 95:19
payment (2) 105:2
1125
payments (1) 1365
paystation (2) 136:4
13911
pe (2) 42:29 1089
pc0152014 (1) 168:2
pe0175821 (2) 187.22
aiaz
1pc0195380 (2) 1207
1233
pcO195561 (1) 147.1
1pc0211633 (1) 672
pods (2) 262:12.13
peak (19) 52:21 67:1,25
698 98:12 1206
1233.4 1471 1627
16323 1848
165:12.25 167:12.25
190.2519 19115
ppeaks (11) 52:20 93:1
969 97:23 982
1092.5,20 125:12
146.4 19216
penelope (2) 60:11
e119
penny (3) 67:24,24
626
pensions (1) 106.14
penultimate (2) 12:3
1708
people (11) 24
1510.18 2914
5:12.25 6917 121.11
1563 1761215
percentage (1) 31:12
perfect (1) 191.25
performance (2) 153:22
15524
performed (1) 49:21
performing (1) 60:19
perhaps (11) 14:16,25
1516 1917 27:0
312 7041 1158
14625 167:8 190.13
period (13) 25:25 29:3
3027 57:13.14,24
7320 9913.16 1196
12615 156:16 175.1
permission (2) 75.24
18113
permitted (1) 1715
person (11) 20:1 35:20
58:1 67.21 68:11
89:8 1003.5 123:
1599.15
personal (2) 107:23
Opus 2 International
Official Court Reporters
POL-0109545
POL00111977
POL00111977
March 20, 2019 Horizons Issues - Alan Bates & Others v Post Office Limited Day 7
11838 187.11 192.8, 1873 16:10 23:2.16 34:15 37:5 providing (5) 43:19 69:33,21
personally (3) 117:22 I plenty (1) 11:10 postal (1) 9:5 printing (2) 20:8 21:4 38:12 45:21,24 46:2, (60:20 114-15 115:20 70:2,4,7,10,24 71:7,17
149.15 1696 plsal (1) 169:27 Postmaster (4) 20:3,21 I printout (3) 18:3,6.6 13 vasas 723418 731
personnel (1) 111.2 plus (2) 121:1 73:10 22:10 134:18 prior (6) 26:24 32:1 processing (5) 48:16 psb (3) 123:10,11,12 74:11,14,10,22.24
perspective (1) 116:18 I pm (8) 16:16 1036. I potential (4) 14:10,12 38:3,19 11920 12510 I 52:13 95:23 1124 prot (1) 64:10 75:4,12.21,24
pete (3) 85.20 86:3 143.3,5 182.1213, 156.17 171.7 priority (1) 67.15 135.4 ptoz (4) 58:12 765,21,25 8116.22
Fereed
phase (5) 113-23
1142.38 1182
phases (2) 107-22
13233
phone (3) 2123
1358.22
phrase (1) 46:18
physical (2) 9:22 58:18
pick (6) 67:25 9516.18
12621 134:6 135.7
Picked (2) 94:8 95:23
pleture (1) 155.2
pictures (1) 165
piece (3) 89:4 136:13.16
pieces (2) 67:9 241:13
pilot (10) 62:20,23
106:7,20 307:20
119:20,28 1203
12151
pin (1) 1425
1 (1) 93:17
place (19) 1616 191
30:8 38:13 40:21
48:20 63:11,13,19
698,19 111:3 112.15
1323 13812 14634
160.22 162.11 178:2
places (3) 61:5 114:20
1580
plan (3) 10928 1309
ana
planning (2) 119:6
1328
plans (3) 119:20.25,
13036
platform (3) 68:10
1298 1309
platforms (1) 68:6
play (1) 6222
please (102) 3:10.18
44,17 6:19.25 6:18.20
3127,17.5 a7
22:38,18,22 27:24
29:24 34:26 36:13
394 43:22 45:5,15
47:19 4912.14 507
53:23,25 54:8 55:8,
60:10,22 68:3 65:5,
67:2 682 691,23 72
146.4 75:16
01:23,24 66:7 68:16
94:22 9635.19.20
10638 107:1.16
108:19.21 1103
ais 1149.11
1156 116:23,25
2176 11823 1192
1206,24 125:2,4.13
19311
po (1) 114.21
poa (8) 151:24 152.25
16315 16516
pointed (1) 6:12
points (8) 512819 94
39:12 96:3 1308
1436 1452
pot (2) 123:9 183:3,
policy (2) 155:29 159:2
polled (1) 165:1
potting (1) 16:36
polsap (2) 133:20 1344
poor (1) 23:16
Poorly (1) 235
pops (2) 9:19 140.19
populated (1) 9:13
Position (16) 2:12 20:20
29:11 90:9 91:23
922,19,23.25
96:13,24 97:25 99:28
101:24 187.5 193:
Possibtty (2) 56:24
169:25
possible (20) 2:6 14:1
193 20:12 91:25
93:4,21,24 94:25
96:11 98:3
100:3,10,16,22 101:14
102.19 1385 1402
16825
possibly (10) 29:8 42:12
513,16 52:19,19
62:16 6619 798
33333
post (130) 6:4 17:19.24
1835 23:37 2820
30:5 31:19 33:16
35:15 365 376,14
456,23 46:6,22 47:23
492 56:18 5712.24
63:7 64:15 65:23,
6634.22 71:18,20
81:4,17,19,20
826,8,16.22
832.48.18
84:6,13,14,15.17
86:11,16 87:1,16
98:12,14,18,19.22.25
99:26,17,28,21,23,25
100:1,10 103:24 1046
105:7 106:9,10 108:5,
10917 1106,9.15,22
311:1 6 113:17,20
11525 116.23,
1175.21.25 1184.17
321:1419,28
324,28,20,22 1255
1292 1328
potentially (2) 39:2
sis
pouch (2) 135:28 1669
powerful (1) 168:23
practicable (1) 119:16
practical (2) 819 889
practically (4) 8:22
1016 1915.18
practice (2) 99:2 155:3
practices (2) 23:15
no12
pre2014 (1) 31:13
precedent (1) 135-14
precise (5) 32.24 35:21
3917 963 141-11
precisely (2) 51:6
137.20
predates (1) 150:11
predicated (1) 115:23
preferred (1) 91:7
prejudicing (1) 151:12
preparation (1) 120.19
prepare (1) 86:17
preparing (4) 92:8
94:26 96:13 10021
present (3) 50:12 57:10
7630
presentation (2) 56.18
11624
presented (8) 35:6
55:16 56:7 68:12
12317 13419 13518
19213
press (14) 9:4,16.17,22
1014 128,14 1422
2510 1356.20
140:16,16 166.11
pressed (5) 10:18 13:4
2547.22 4114
presses (1) 1017
pressing (5) 13:10
132.95 139.22 14012
14121
pressure (1) 189:17
presumably (3) 21:12
472.6910
pretty (11) £47,10.15
965 672 1146 1289
145.15 146.10
169:10,13
preval (2) 12417 115.2
previous (7) 22:13,13
315972 15738
160.2 165:22
previously (2) 55:14
1549
price (8) 9:10.19
140:21,22
primarily (1) 6:4
privilege (1) 178.22
privileged (1) 181.17
privileges (8) 172:21,24
1785.10.13
proactive (1) 152:15
probably (16) 29:6 346
37:12 39:11 47:16
7755 89:19,24 99.2
102:25 10324 1144
15:13 137.22 1612
137
problem (52) 52:22
69:9 70.19 76:20 77.8
93:6 122:19.26
325:13,14.23 131.17
18:4 150:25
1515826
1529.14.15
153:16,10,24,24
154:12,19 155:1.16
156:6.16 157:9 160:22
161:4,17 1627
163:10,16,16 164.11
165:17,17 16:7
367.17 184.10
187:20,25 1883.35
389:22 19114
problematic (1) 65:22
problems (28) 11:15
68:26 71:19 91:12
104:10 109.1.10
319.25 12111
322:19,22 123.10
126:3,18,22,23 12615
146:2 147.23 15218
156:20 1615
166:5,7,12 169:1
184
procedure (15) 64:13
150.25 1515
153:1,16.19,25 154.19
156.6 157:9.13 158.25
359.1 161.25 1677
proceeding (1) 154:15
proceedings (5) 30:22
34:11 39:16 61:17
149.10
process (60) 32:14.16
344 36:12 405,15,
4113 42.15 43:4
45:12 48:3,14 50.23
51:19 52:23 56:19,22
87.9,16,18,20,21.23
58.21.22 59:14 60:25,
66:3 67:15 75:25
764.27 10825 1148
325:16 13517 147.10
351,8.21,24 1524.14
158:21,23 154:10,12
procured (2) 82.17.19
procurement (3) 84:12
9919 10312
produce (8) 10:11 19:12
43:11 55:19 59:12
6410.13 169:23
produced (9) 43:3
58:10 78:23 60:17
106:12 1336 1683
3741417511
produces (1) 42:17
product (7) 16:7 18:25
20:25 117:24 162.25
1831 1886
products (4) 11:7 62:11
136-4 140.23
professional (1) 155.18,
profile (2) 46.5 115:22
programme (11) 22:20
83:22,26.25 842
go.n1 1114 11324
1169.18 120:16
programming (1) 82-4
progress (1) 1208
project (21) 11:22 466
62:7,9.10.19
103:18.17.20
1065,8,12,25 105:23
113.25 1164 120:22
yaia4 12210
324:22,23
projected (1) 135:21,
prominently (1) 14:20
promptly (1) 191:22,
proper (1) 2.20
properly (10)
4114.15.18
42.46.8146
7220.21
proportion (3) 46:7
63:17.19
proposed (7) 69:2
312.21,25 11322
1162.7 155.01,
proposes (1) 116:9
proposition (1) 51.6
pros (1) 135.1
prosecuted (1) 55:1
prosecution (4)
68:13,19.23 695
protection (1) 79:10
protocols (1) 38:13
prove (1) 79:12
provide (19) 35:9.10.13
36:19 42:3 492
53:111,12 613
312.14 11618 131.24
145.20 152:2 15615
164:23,23 190.28,
64:18.5,17
pul (2) 9323.19
pulled (2) 105:4.5
purchased (1) 9°7
purely (2) 38:22 58.22
purpose (3) 32:13 1529
1524
purposes (3) 35:17
44:18 58:23
pursue (2) 46:14 80:12
push (1) 144:20
puts (1) 173.22
putting (3) 3715 96.1
1419
4 (661) 3:25
43.6,8,11,13.16 19.22.24
5:12,16,10,20,22,24
6:9,14,27,19,23,25
75,741,21,24
825,724
9:1,4,9,12,17,19,21,25
30:3,5,14,27,20,22.25
118,14.17,22,25,
325,12,17 13:15,20
148,104.24
158,14,21.23
162.811.1421
37°7,10,13,16,30,21,24
183,911.18
197,14,23 20:5,11
21:16,19,21 22:2
23:13,23 24:15,17.20
25:1,12,15,23 265
28:3,5,8.17,25,
29:3,6,8,11,15,18,21,24
30:4,9,12,17,21
311,7,20,13,22
32:1,11,13,18
33:6,17,22
34:8,12,20,24
95:13,16 36:2.7,13
37:4,8,10,15,19,24
38:4,8,16,22,25
395,7,12,14,25
40:10,15,18,24
41-7,10,20 422,612
43:2,7,35,18,22
44:12,14,17,21,25
45:2,5,19 4625,
47°6,9,12,14,19
48:8,11,14,23 49:7
50:3,20 S1-1,7,21
52.5,9,11,17,22,25
535,7,10,15
54:12,14,18,22,25
555,0,25 56:4,6,15
2235,19,25
83:4,7,11,14,17,23,25
24:6,19 85:2,14,10,22
26:6,21.26 87:6
88:6,11,14.19
29:13,16,21
90:2,4.15,18,20
913.1417 92:5.9,12
94:13,15,19 95:24
96:16.19
97°7,9,15,7,20,25
98:3,6.12,16,21
99:4,6,13,24
100:6.8,15,18,20
101:2,10,20
1023.7,11,15,18
103:19,22
104:2.14,16,25,
105:6.9.2
106:2,7.18,21,25
107:3.14,16,25
108:3,6,12,15,17,19,24
109:7,10,20.23
310:1,5,20
112.11,13,15,19,23,25
112:8,14,18,21,24
1130.21 1149.24
15:15 116:7,13.23
117.15,18 118.1023
119.13,23
120:3.6.11.20,24
321:4,7,10,17,21,23
3221.5,9,12,15,17,22
123:2,8,14 124:20,25,
1253.5
126:1,11,14,27,25
197°7,10,12,21,25
128:13,18.21
129:1,10,13,25,18,23
1307.23
131:7.12,15.18
1322.6,16,18
1337.17
1341,3.5,8,10,12,22.24
138:1 136:1,20,23
13747.13
1385.17 20.25
139:3,5,8,25,20,23,25
1405.15.28
141.2,6.11,19.21
142:1,7 143:8,21
144:4,6.9,12.21
145:16,20,25,
146:6,11,13,20.24
uar4aa
148:4.6.9,17,20,22
149°7.14,20,24
150.2,10,13 151.15,20
152:8,14,17,20,25
129:1,3 132:19,23 133:8,14,20 134:25 principal (1) 116-14 155:1,3,4,5,23,24 provided (16) 8:11 57:3,23 58:3,6,9 153:3,10 154:17
144:22 146:24 148:23 136.9,9,23,24 137:4 principally (1) 180:24 156:16 166:2 170:4 34:20 53:10 54:14,19 99:3,7,9,17,24 155.21 156:3,9
151:1,5,20 153:3.4,13 143:25 149:4 151:4,16 I principle (4) 55:11 171.25 1722.5 173415 I 65:18 12928 60:2,5,14,16,22 157-4,25 1585,25
1545 156:15 161:7 152:6 153:18 154:7,13 134:14 135.23 138:22 186:3 145:18,18 1565, 61:10,19 159:4,9 160:7,9,12,20
1647 16735 156:12,10.19 157.2,12 I principles (1) 13325 I processdriven (3) 56:20 I 1756.10 261:14 626121417 161:4,7.10.13,23
174:20,11 175.7 160.18 161-23 162:2 print (4) 20:13 66:7 67:24 ‘183.23 190-1822 63:2,8,20,24 64:1,3.22 162:3,5,11
177:19 182:6,18 164:22 167:6 180:21 191:21,22,23 processed (1) 170:1 provides (5) 23:9 36:16 (65:2,12,16,20 163:18,22,25
183.20 185:11 186:1 181:8 1835,9,17 printed (4) 124:3,4,15 I processes (10) 22:25 48:2 110-24 168.14 66:6.9,14,20 164:10,16,20,24
672,7,9,21 682,98
Opus 2 International transcript GRO ?}
Official Court Reporters
POL-0109545
March 20, 2019
Horizons Issues - Alan Bates & Others v Post Office Limited
POL00111977
POL00111977
Day 7
1656,9,12,18.16,22,25
166:16,20,22,24
1673,15,18.21.23
168:1,7,9.12
169235
170.1,13,17,25
171:3,10,18,21,23,25,
1722.4
1735,9,12,14,21.25,
1742021 17537
1761217
1772,7,10.5,9
178:2,25 1793.5,
181.25 182:4,6,17
183:9,13,17,20
1844.75
185:10,15,21,25
186:4,7,11.24
1873,9,11.14,18,25
1885,13,16.19.21
189:1,25 190:3.6
quality (1) 128.23
quantity (2) 18225,
1831
quarter (1) 80:25
‘queries (2) 69:6,11
query (1) 49:16
question (31) 1:7 22:3
22:3 25:6,23 26:1
270 37:3 38.16 40:8
44:21 46:21 63:10
723 736,16 75:12
7 7839
80:13,15,25 101:21
1026 1097 13720
150:2 16922
1781820
‘questions (17) 5:6
20:26 24:2,9.10
268,10 27:8 7123,
735,21 76:15 96:2.4.4
1948.15
quick (2) 9:4 163:25
‘quickest (1) 191:16
quickly (7) 135-4 1569
164:1,16 380:12,13,14
quite (33) 10:23
1417,20 20:11 21:11
28:23 30:20 40:11
44:27 50:1 51:3 53.7
59:15 62:14,17 80:13,
9233 93:1 96.
101.20 10319 109.7
112.21 12235 126.2
127.17 12815 13210
13726 1409 141.23
1569 166:
9 (1) 1657
radical (2) 1287.7
raise (4) 1:5 20:4 52:20
1263
raised (7) 1:7,15 52:20
121:8,10 1635 184.8
rajesh (1) 16723,
rare (1) 181:8
rate (5) 115:24
164:20,20,21,25
rates (1) 43:24
rather (16) 14:22
16:46,7 51:19 50-4
93:24 95:2 97:22
100.25 113-4 117:11
128:1 154.25 168:16
190:2
rationale (1) 95.7
rationalisation (4)
99:1 1132224 1148
rds (1) 36:22
reaction (1) 96:3
reactive (1) 152:14
reacts (1) 19212
read (12) 43:13 47.4
7@21 80:1 87:20
91:24 92:25 97:12
302412 14415 179.22
169:23
readablesearchable (1)
54
readily (1) 152:23,
reading (6) 46:10.11
66:16,14 131:7 1787
ready (1) 12524
realisation (1) 11522
realise (1) 92
realised (1) 96:11
really (21) 22.2 32:21
33:7 34:20 41:19
46:16 47.6 66:11 724
86:28 1015 126.17
131.1617 14523
159:10,15 1609 1836
29:14 192.14
reason (22) 83 9:12
16:18,22 39:20
40:,9,19 63:25 71:11
728,13 94:6 95:12
105.9 12617 141.21
150:19,22 158:
18736
reasonable (1) 23:23
reasons (1) 515
rebooted (1) 41:23
recall (12) 116.11 39:5
55:2 56:25 64:17
6624 67:12 69:12
709 105:5 127:14
recalled (3) 2:45.20
receipt (4)
3243,5,1022
receipts (1) 16214
receive (1) 13710
received (3) 64.7 123:9
437.17
recent (3) 47:15 15115
165:20
recently (2) 56:18 76:4
recognisable (1) 25:22
recognise (9) 13:13
2197 4955 80:6
108.18 114.7 165:18
167.25 1758
recognised (2) 13:5,
31434
recollection (9) 5:3 26:9
6221 7510 7722
104-23 106.36 107.23
1638
recollections (1) 86:1
recommendations (1)
yaa
reconciled (2) 25:12,13
reconciliation (6) 23:1
3126 113121418
147.18
record (19) 31:23 32:9
36:17 57-7 61:4 66:9
69:22 77:6,7,15,18.25
79:7 87.20 14415
156:20 180:14 184.22
185.9
recorded (7) 58:18,22
61:4 1548 156:16
165:1 17016
recording (1) 166:25
records (40) 18.25
32:23,25 33:,37.9.17
48:19 56:17
57:10,6,25
59:13,15,19,22
61.2.6,12 68:5,23 65:9
679 79:13 988
157:16 162.22
via 17453 177.24
17816
recover (1) 125:28
recovery (1) 176:2
rectified (3) 25:11,24.15
recycling (1) 112.21
red (8) 51:23
122.25,8.9.5 125:23
1708
redisplayed (1) 166:11
reduce (2) 111:19 154:2
reduced (1) 128:23
reduces (2) 11312
116.16
reducing (1) 45:26
reduction (1) 11613
reductions (3)
110.735,17
redundant (2) 36:22
147
reengineer (1) 1145
reengineering (1)
16:10
reexamination (6) 24:7
27.9 7125 194:7.9,14
refer (2) 6:6 33:24
reference (13) 9:12
5418 707 1201114
126.18 140:16,24
141.1415 155:9
180.17 1903
references (4) 93:24
107.1,10,11
referred (10) 1:8 213
5:2 68:22 70:7 93:25
1334 157.6 1621
1887
referring (4) 38:25
Tray 6581455
refers (3) 32:22 131.2
185.25,
reflected (2) 1135
m3
reflects (2) 176:1,18
refresh (2) 116.12
13212
refreshing (2) 109:4.6
regard (1) 088
regarded (5) 99:25
100:4 117-21,22
135.3
regarding (2) 46:23
1239
region (1) 18:6
registers (1) 9:6
regular (1) 16035
rehearsals (2) 119:19,24
reinvigorated (1) 128:2
rejuvenated (1) 1282
relates (3) 151.15
154.21 1628
relating (4) 351 130:
187:20 169.22
relation (20) 1:8 39:16
645 815 85:22
106:25 109.22 125.1
132:20 1437.13
145.16 146.7 149:10
351-10 153.24 15611
374.14 17721932
relationship (3) 99:9
203:24 11:10
relationships (2) 105:29
145.23
relatively (2) 130.4
ya
telativity (1) 175:7
relay (1) 136.23
relayed (2) 12323,
136.20
relays (1) 13636,
release (5) 68:24
165:7.9,10 166:13
releasing (2) 69:2.2
relevant (4) 141.14
35219 1541 156:17
reliability (1) 75:25
reliable (2) 87:4 72:18
relied (1) 1161
rely (1) 66:16
relying (1) 71:9
tem (1) 125:6
remain (3) 99:6 112.2
a8
temained (1) 127.28
remaining (1) 1128
remains (1) 148:24
remedy (1) 154:3
remember (32) 518
217 43:17 4810.11
5422 67:2 681 7315
304.25 1095.15 1123
116-4 120:4 121.10
322,22 1304 131.16
332:2 14:16 135:1,20
157.23 16016 1636.7
165:10,12,14
381:20.23
remin (3) 166:2.9,10
remind (2) 75:21 1276
remit (2) 66:11 702
remote (2) 84:24 1002
remove (3) 56:20.22
57.20
removed (2) 53:13
64:24
removing (3)
57:16.21,24
repair (4) 18624,18
399.13
repeat (1) 102:6
repeated (2) 97:12
382.17
replace (3) 844
10613.17
replaced (2) 131:
13243
replacement (2)
1575.21
replacing (1) 32923
replicate (2) 59:9 66:10
replicated (1) 144-6
replicates (1) 6018
replicating (3) 86.12
143.25 14431
report (15) 21:3 3626
42:24 6536 708.18
12320 13289 15313
15416 15737
166:18.24
reported (3) 155:22
160.23 161.15
reporting (7) 39:22
157.19 159.23
160:3,49 161.25
reports (4) 178.25
aeiie 1628
repositories (1) 136.14
representations (1) 166
representative (1) 31:2
representatives (1) 5:9
reputations (1) 104:8
reputting (1) 137-20
request (8) 35:20 149:4
15610,19 17412
18.17.21 1865
requested (8) 31:11.25
35:28 149316 1599
163:3 184.25
requests (13)
30.15,923 3138.24
66:8 147 10.238,
149-25 156:12 161.28
1858
require (3) 67:10 211.1
156.24
required (9) 45:20
68:25 69.6 1193
1363 145214719
353:22 17347
requirements (1) 64:12
requiring (1) 119.7
reretrieva (1) 67:33
rerun (2) 41:25 42:20
rerunning (1) 5519
reset (1) 1762
resolution (1) 67.9
resolved (1) 186.3
resources (2) 23:4.17
respect (6) 41:14
427.13 7221 128.22
17820
respects (1) 75:4
response (7) 1:32
149.25 15611.12.18
163:2 1764
responsibilty (2) 20.6
asi0
response (8) 2:21
66:11 95:4 113156
3323 143.26 148.10
responsive (1) 15:18.
rest (2) 59:4 108:18
restricted (1) 151:3,
result (6) 55:20 63:9
1363 1417.12 1427
resultant (1) 64:14
resulting (1) 129.19
resume (1) 1929
retail (1) 725
retailtype (2) 110:10.12
retried (2) 18417 185:7
retrieval (10) 35:19
49:25 50.23 52:23
56:19 57:8 66:21
673.1314
retrieve (2) 48:3 55:15
retrieved (14) 35:17
4428 4814.21
49:19,22 50:10 52.2
6277128 768
Mel
retrieving (2) 55:22
6918
retrospectively (1)
15622
return (1) 17:6
retuned (1) 57:9
retums (5) 719 57:7
673.810
reuse (1) 131:20
revealed (4) 44:5,23
45:3:148:14
reversal (4) 67:3
6614.21 70:19
reversals (3) 67:13
697.19
reverse (2) 5:13 14:2
reversed (3) 13:19,23
16521
reversing (3) 15:2.9.17
review (14) 159:5,7
160:14.21,24 1613.4
1628 16316
164:4,4.11 165:17,20
reviews (1) 1223,
revisions (1) 1536
revisit (2) 38.9
rework (1) 23:8
id (1) 1144
fighthand (2) 154.24
16318
vightly (1) 240:9
Figorous (1) 166.25
rigorously (1) 15:25
Hing (1) 16:14
Fings (1) 1325
Finoste (32) 77.16.24
79:19 60.2 8611.10.16
87.2 88:8 9216 933
95:13,14.16.22
108:17,18 11215
1286 144:10.19,20
145:3.99,11,12,16.18 29]
1462 184.2
isk (5) 45:22 46:5
129.1,6 1542
Fisks (3) 692,4 168:24
robinson (51)
1:412,25,21,24 27,8
312,167 55
246,78 268
279,017,19,21,22
28:11 4612.13,
7:24.25 721 73424
743.4 75:16
789,17.21 809.16
22:2,2699,11
191:4,6.10.23
1945,7,10.12,14.18
robust (5) 114:15.19
317.12 152.17 16:25
role (11) 2418,
26:20.28.28 58:3,
60:19 73:7 63:16
995,24 1457
roles (4) 67.22.23
739,12
roll (7) 896,9 91:10
98:16 101-14 108:17
14736
rolled (1) 1068
rolling (1) 205,
rollout (9) 84:11 107:20
106.1 1195 125:25
131:12,16.19.20
rolls (2) 18:3 20:9
room (2) 12:10 191.24
root (2) 147:20 152:10
rose (2) 70:8.18
roughly (3) 98:19 99:5,
1322
route (2) 91:7 10223,
row (1) 154:22
royal (8) 3:4 62:2.28
997,10
rules (1) 236
ruling (2) 2023.7
tun (7) 3:7 48 13018
1314 169:3 178.416
rung (1) 123.24
running (7) 45:23
104.18 129:10
1305.10.21 181.22
runs (1) 131-23,
saheed (8)
1571011.15.21.23
156.22 159:18 163:9
salawa (3) 257:10,12
158.20
salawus (2) 157.35,21
same (48) 4:3 15:24
163.9 17.25 344,14
356 39:12 45:23,
5413 55.12.20
56:3,12,14 59:2 60:19
61-4 64.20.21 65:14
7414 771,72) 79:24
807,8.5 e45 913,
91:3 995 10714
116.8 122:20 123:3
12720,18 131:3
142.25 146:22 150:13
165.22 166:10 169:5
aiad
sand (1) 37
satisfy (2) 63:2 117.8
save (1) 13537
saver (1) 123.18,
saves (1) 1502
savings (1) 6232
saw (3) 25:5 75:7 94
soying (14) 19.21 35.22
523 6914 7117
77:20 768,20 605
97:5 102411 114:24
148:1 190:10
se (2) 187-21 169.25
scales (1) 1426
scanned (1) 1256
scanning (2) 199.22
scenario (1) 1477
scene (1) 125:22
Opus 2 International
Official Court Reporters
transcript GRO
GRO
POL-0109545
March 20, 2019
Horizons Issues - Alan Bates & Others v Post Office Limited
POL00111977
POL00111977
Day 7
seenes (1) 9:15
scheduled (1) 17:4
scheme (1) 30:18
scope (A) 2:28 15122
1523 1716
score (1) 14225
seratch (1) 18324
seratchcard (1) 1363
screen (19) 61 8.24
10:3 11:5.9,10 126,21
135 14:4 16:4 256
26:2 124:3,9 136.19
136:18 141.14 166:10
screens (1) 145
screenshot (2) 6:5,14
screenshots (4) 63.9
15:23 25:2
script (3) 169:27 1744
18013,
scripts (2) 12820
185.21,
searching (1) 46:14
seat (2) 315 742
second (29) 12:23
13:78 16:12,18 3322
3555 36:23 44:21
48:28 51:21 56:11
60125 92:8 94:25
96:14 11225
120:12,13 1236 1525
154:18 157:4 179.20
162.10 1867 188:
1906 1913
section (14) 22:23
49:15 59.25 64:25,25,
65:10 96.28 91:15
107.18 1168 119.14
354.1 160.23 1705
secure (5) 36:16,21.25
37:8 69:22
securely (1) 66:4
security (10) 26:21,22
38:22,16 62:21
105:2,3 12:16
148:25,25
see (183) 319.23
610,17,20 75.8.17,24
8:24 1015
310,28,20.23 1212
13:6 14:10,23 16:9
19:3 21,12,24 22.21
23:23 27:24 28:3 307
34:12 38.25 39:12
40:18 41:20 422.12
43:2,12 46:25 48:12
50:3 51:22 54:25
56:4.15 58:9 5917
605 62:14,23 63:2.24
64:36.24 66:14 672.5
68:37:15 69.21 71:17
7425 75:19 76:5
78:16 82:25 65:3.11
86:7.21 9:13.13,
95:5 98:8 101.16
1024.9 104:4.10
105.12 106.19
1072,10,12,26 108.6
1105,521 111:16
21295 11419 117.13
318:11,17 119:11,25
320:7,25 121:4 1221
1235,13 125:5 1294
130:15 1329.10
1376.16 1402
1415,7,8.12 14423,
145.10 147:12.6
1512.21
15345,71,7
15417,28
155:16.10,20
156.11,13 1595.6
61:13 163:16,20
164 8,28 165:25
1671.33 168:
170591724118
17221 17312
17497,22,26 1763.10
178325 179.21
18036 8,20
1828,10,15 18413
18597.1,12.25,
186:,13,22 187:12,19
180:2.21 16921 191:5
1938
seed (2) 170°7.1
seeding (1) 170
seeing (1) 194.2
seek (3) 51:28 52:11,12
seeking (3) 11:6 16118
134
seom (4) 59:5 88:7
165.6 188:13
seoma (3) 54:15 58:11
148.18
seemed (1) 125:6
seemingly (1) 32:1
seems (9) 48:5 905
198:23 152.25
158.11,16 164.12
1914.11
seemungal (4) 85:21
862 169:11,18
seen (30) 4:9.10 24:14
1632 22:7 29:8 34:2
45:26 46:16 52:1,
54:18 55:5 59:7 60.14
67.7 77:4 1032.56
1277 1319 13819
1362 145:8,11 15137
161.2 16514 1698
aos
sek (1) 36.22
select (3) 48:36
1050.13,
selecting (2) 46.17.18
sell (10) 5:3 7.21.22
195,9,2.21 1341.28
257
semblance (1) 71:3
semiautomated (2)
578.15
send (4) 17:3 131.25
13610 1378
sending (2) 113.15.16
senior (1) 3577
sense (7) 2:16 30:17
8812 12225
146:11,12 192.10
senses (1) 106°3
sensible (1) 99:20
sent (7) 1:12 16.28
64:35 123:18,20
13818 13813
sentence (13) 33:22
3425 3555 36.23,
aoa
726,11,14,18.24
76:25 14:24 177.23
sentences (2) 61:1 73:2
separate (9) 1111 13:4
586 77:24 87:17
93:18 968 124:22
13913,
separately (2) 113:25
aan
separating (1) 11:4
september (7) 84:23
109.26 19:24 1538
16115 1683.8
sequence (16)
5019,14,17 57:6
767,32,17 791,15
146:20 147.24
172.25,5,7.12
sequences (4) 50:11,13
769.1
serious (5) 76:19
122:15,16,17 169.1
server (19) 68:11
87.21.24 908,28
91:82 92:22 95:3
96:23 100.23 101:6,23
144:47,26,16.20
18113
servers (4) 33:13
58.23.26 92:20
service (24) 15:12 67:8
11266,7.14 11712
121:25 129.23 1515.7
153:18,23 155:24
187.79.11
160:16,18,21.23
1612.16 1677
serviees (8) 9:5 23:18
26:19 61:13 1521.2
164:21,23
serving (4) 91 15:4,10
234
session (1) 17332
sessions (1) 160.15,
set (14) 3:3 37:25
380,37 6128
714,20 75:5 1441
153.25 169.19 1747
375.23 1785
sets (2) 30.6 65:2
settle (2) 134:20,21
settled (1) 19:2
settlement (2) 188.2
1907
settlementcompletetime
(a) 17523
several (3) 71:7.8 1766
shal (3) 11.19 190:22
1938
shareholder (1) 106:22
shareholding (1) 106:22
shhastei (1) 167.23
sheet (3) 320.21 758
shrll (2) 169.27 174.4
shocked (2) 92:9.20
short (13) 53:22,22 546
7010.14 86:7 94:23
99:13 101:10 1034
123.16 14220 1434
shorter (1) 21:2
shorthand (2) 53:22
14224
should (22) 1:5 3:17.21
30:28 14:16 20:20
27-22 32:01 30:11
58:3 74.28 93:19
107-3 129:15 15019
154.8 156:5 158:9
1757 183:2 1854.5
shouldnt (1) 147.15
show (8) 12:8 18:14
42:25 56:4 65:20 69:7
70:20 167.10
showed (1) 154-22
showing (3) 12:8 15:7
977
shown (7) 25:2
51:23,23 54:8 142.8
3505 175:20
shows (6) 19:1 42:20
51:21 146:19 168:2
aan
side (9) 37:3 62:22
8633 125:22 14318
454.24 16338 17322
38419
sides (2) 187.20 189:21
sign (3) 60:3 65:28
159.22
signature (6) 46,23
286 7412.22 75:2
signed (2) 7234 732
significance (2)
140:15,17
significant (3) 45:21
4722 12834
significantly (2) 45.22
1616,
signing (1) 72:26
similar (7) 29:21.25
44:6 583 7919
13555 1882
similarly (2) 6:20 23:4
simple (3) €0:14 95:22
145.5
simplification (2)
u2a6
simplifying (1) 45:3
simuttancously (1)
waa
since (19) 1324 1524
16.1,2,3 26:19 28:20
30:6 739 75.23.24
01:24 64:14 67.3
117-24 149 1758
a7
single (5) 14:28 92:23
4375:18 180: 161:10
sir (1) 121.0
sit (1) 19230
sits (2) 109:5,7
situation (6) 2:2 19:7
20:2 108.25 1066
3524
sx (1) 61:36
sixmonth (2) 98:20,
99.25
size (2) 87:15 69:13
skilled (1) 1693,
skills (1) 127.2
slas (1) 161:17
slide (1) 122
slight (1) 59:3,
slightly (6) 33:28 41-16
4318.12 6522 1183
slip (4) 51:1 128:4,35,
16610
slips (1) 106.15,
slow (6) 49:25 50:4.6
nivaoe.22
slower (1) 50:5
slowly (1) 157.20
small (10) 1:5 165
691.22 121.25
130335 132-10 169:3
yea
‘smoothly (1) 104:18
sts (1) 122.6
social (2) 82:21 105:2
software (15) 36:21
a1.21,22 69.1225
126.10 129.10
3312324
145,16,19,20 155.9
156.7
solicited (1) 167.14
solicitors (1) 8:11
solution (12) 106.8
3094 11023,24
11416,20 11517
n16.1547,19
169.1516
somebody (6) 43:0
66:16 95:9,12 133.24
157.24
someone (9) 14:24
20:20 33:8 99:8
12425 13468 138.7
613
something (36) 1-19
16:17 23:19 405 476
57:25 5918.26 61:14
707.21 76:8 78:24
79:25 e0.18 93:2.5
94:34 11329 121.16
32416 138132323
40.39.22 141:16
146.17 16025 161.1
1642.13 165:3,12
yaar
sometimes (5) 11:14
14:19 35:10 5913,
yeaa
‘somewhat (2) 69:21
n69
somewhere (1) 34:2
soon (1) 119.16
sort (18) 21:23 24.17
39:7 65:17 69:10
300:14 108-22 107:21
1150 19511,11
3318 15519 1592
161.28,24 161:24
18310
sorts (1) 22.21
sought (2) 1:12 169.17
sound (1) 33.9
‘sounding (1) 97:13
sounds (1) 166:25
source (2) 7:2 86.24
sources (9) 36:9 44:39
65:26 69:23 1522021
1331014612
space (3) 1023 11:14
speak (2) 85:15 162:23.
speaking (2) 63:3
16914
special (3) 64:16
9221.2
specialist (1) 161:25
specific (21) 3812 348
38:1,8.10,19 43:8
59:25 63:10 66:20
85:11 1098 121:20
326.22 155:11 16023
1632.4 164.7 171.5
38123
specifically (4) 1023.7
351.15 153.28,
specified (2) 48:15
68:10
specity (1) 68:6
spend (2) 99:20 190:11
spending (2) 120-10
spent (1) 1925
split (1) 87:26
spm (14) 8:24 9910.17
17.25 65:23 97:22
96:7.7 123.23 136.17
340.16 141:3.13 1421
spms (4) 12:14 17:6
208 1875
spoke (2) 85:16 163:12
spoken (2) 157:6 162.25
spot (3) 1425 7:19
69.21
spotting (1) 14.28
spreadsheet (1) 17:13
spreadsheets (2)
66:12,19
sal (9) 168.24 169:21
1731621 175:18.21
378.14 179:23 180:13
squarely (1) 11613
stb (2) 160:24 16118
stbs (1) 161.15
ssc (13) 89:8,14,19 90:7
91.21.25 96:2
yo118.22 10212
368:16 170:19 1741
ss (1) 108:4
stack (2) 15:7 25:20
staff (2) 124:2 1603,
stage (8) 106:2.10,21
u0-4.1143 12112
330.21 14212
stages (4) 95:24 103:39
3121707
stamp (13) 95,710.19
11.22 2518.16.19
61.16 140.21 14117
17525
stamps (1) 11:2
standard (9) 36:19
37:11,15.17 59:11,22
66.17 69:22 932
stare (1) 192.10
staring (1) 192.16
start (10) 11:19 13:11
28:17 684 73:14 793
£81:10,25 94:10 1603
started (7) 2418 26:13
737 1093 12021
1322.13
starting (1) 12516
stated (4) 34:3 91:20
3241012
statement (142) 3:21
4:14 5:24 61,310
87.11.15 1614 177
3812.13.26 23:10
25.2 27:25 268.18
2925 30:1 31:16
3243.19.22 33:28,
342.8 3818
39:19,21,22.23
402,20 41:2 43:11,28
495 549,420.23
5558
59.2,7,11,13,16,23
60:11.14,16.23
62:10:20 63:4
6418.22 65:17
66:15 677
715,018
7229847 73
74:7,19,24 75:6 774
78:5 60:2
£1:10,16,28 64:21,22
952,6.26 86:18.22
£86:15,20,26 90:13,14
91:18:20 922.8
94:15,25 96:14 97.4
96:24 100.23 101.11
208.10 126:22,19.25
1278 130:24 1318.0
132.20 136:25 141.2
1438.22 148:12 146.9
148 9,23 149:17,22
150:7.13,15 151.3
157.25 168.24 169.22
1732,16,21.21
1747.17 17549
179.24 18081 181.25
statements (9) 4:25 5:2
43.19.20 71:13 75:49
24417521
states (2) 16:23 42:24
status (4) 120.25
163.20 167:18 167.14
stay (1) 58:1
stayed (1) 16:8
stepbystep (2) 40:10
488
steps (2) 2019 467
steve (19) 85:19,25
89:5 926 1576.14
15921 160:7,8,15.25
1612.8,21,22
3626.23 1631.12
stil (9) 10221 106:10
1146 118:19 1305
13123 159:5 1618
162
stint (1) 64:12
stock (11) 5:13,14.16
2025 23:4,78 170:20
1769 177:4 1849
stop (5) 15:14 67.8.9
8011 138-21
stopped (1) 1203
stopping (1) 63:8,
storage (4) 34:18 35:19
44 1437
store (19) 33:2.19,21
3622 442.8 1134.7
139:16,19 142.1012
14310 1442.47
145145 14811
stored (2) 37:2 145:12
storing (2) 86:11 143:24
straight (1) 130:9
strategy (8) 114:10
11525 138:24
stream (3) 95:17
Opus 2 International
Official Court Reporters
transcripts!” “GRO.
GRO
POL-0109545
March 20, 2019
Horizons Issues - Alan Bates & Others v Post Office Limited
POL00111977
POL00111977
Day 7
13a 13914
streamline (1) 1129
stretch (1) 54:1
strict (1) 181:14
striking (2) 15:2.3
strings (1) 48:15
stripe (2) 16417 165.25,
strong (1) 92:10
stuck (1) 20:25
study (1) 11:22
stuff (2) 93:19 12527
subdirectory (1) 1743
subject (3) 5:1 75:67
subjected (1) 115:4
suboptimal (1) 45:24
subparagraphs (1) 38:8
subpost (1) 19:19
subpostmaster (14)
9:23 27:14 939.24
94:6 95:1,5,7.9 1014
1024.9 135117 1423,
subpostmasters (4)
37:22 66.22 71:19
933
subpostmistress (2)
9:23 54:25
subpostmistresses (1)
66:23
subsequent (1) 35:19
subsequently (3) 33:24
69:11 1669
subset (1) 4816
substantial (1) 111:20
substantially (2) 110.6
1399
succeeded (1) 147.14
success (1) 119:6
successfully (2) 55:14
173
suceession (1) 115:4
suchlike (1) 106.14
sufficiently (3) 65:14
116217717
suggest (4) 20:1 886
10133 19114
suggested (10) 13:3
20:28 25:1,3 72:4 897
97:23 1639 1793
19221
suggesting (1) 101.15
suggestion (1) 78.17
suggests (4) 30:9 50:19
57:16 16319
suitable (1) 112.1
suite (2) 7:11 208-12
suited (2) 11416,25
sum (1) 1908
summary (6) 67:2 68:12
11238 116.21 158.1
1626
summer (2) 70:17 1163
super (1) 89:10
supplied (5) 30:14 365
59:5 68.19 71:14
supplier (2) 105:17
1368
suppliers (1) 160.16
supply (5) 33:16 35:12
37:6 59:12,23,
support (21) 25:17
5125
529212131418
53:3 68:13 73:13 824
99:2,23,25 100.12
nn62.1173 1188
145:20 151.25 1523
supported (2) £23
13122
supporting (1) 36:20
supportive (1) 121°6
supporttooluser (1)
1745
suppose (6) 216 24.24
aia 462 703
yee
supposed (2) 23:22
15035
suppositons (2)
159417
sure (24) 1:29 231 156
2uaz 272 317 398
409,11 46:16 4726
5525 599 6320 762
7947 94x7 10318
10625 113.18 12234
4423 1791538
surely (1) 42:15
suprised (1) 10020
surprisingly (1) 130-11
surrounding (2) 399
764
‘susceptibility (1) 128:22
susceptible (1) 126-20
suspect (2) 19:26
13023
suspended (3) 12635
11s
suspense (2) 2314.21
sweep (1) 150.14
swipe (3) 1042223,
10515
switched (1) 29:28
sworn (2) 27:20 19431
system (112)
50,13,20 63 103
1320159,7.1
1911 257 266
272,33 3220.23
3324.25 35:4 3636
4034412142521
4312.30.20 42313
46:9,19,28 «7:22
51a 59 61:2
64:11 7020 7220.20
77aT 793.14,19
8010 827 848
86.10 100.12,38
1031222 1042224
1053 1068.13
1092.6 1124.55
11573224 110313
1193 122.20 12321
124:1,13 125:6,14
1265.18
127.3,15,18,22
12816 133:3,20
135.4 1373,5,18
13946 143.24 145:16
146.18 148:19 150:20
151:11,12 15237
156.17 159:25 16211
16819 170:23 171.21
81:8 18213
184:2,4,10 186:14,18
systems (10) 35:24 61:5
82:3,4 86:4 94:12
108:15 113:17,20
153
(1) 176-20
ta (2) 139:13,23
tab (7) 319 43,17
49.17 74:14,16 75:6
table (30) 620 9:13
10:22 140:16,24
14145 14212 1687
169:20,22
271:11,19,21,23,25
172:2,4,6.9,10,1,11
173:10 174.21 179.
180:10,14 184:22,25
1852
tables (16) 139:13
168:18 170.21 171.16
172.23 173:3.6 176.23,
177.12 178:3.48,97
180:9 18224
tackle (1) 104:6
taken (7) 64.6.9 19:1
69:19 1761.18
takes (3) 16:16 48:20
ena
taking (7) 26:24 30:18
33:5 50:17 58:7 69:8
1707
talk (14) 16:15 32:14
53:23 85:13 88:12
94:21 97:18 1083
127-8 142:25 160318
192.2318
talked (2) 86.2.3,
talking (11) 158.12
33:1,2 34:21 64:18
88:4 100:2 101:5,
139:20 149.20
tampered (1) 36:3
tamperproof (3) 36:17
3718
target (2) 130-22 162.7
tas (2) 138:10,23
te (1) 134-20
teo (3) 115:21
116.1316
tes (5) 133:16.18,20
136.1416
team (16) 16:24 17:22
29.24 38:14 52:21
58:8 67:22 68:19,23,
739 15:7 149-1
152.6 159:3 174.2
tech (1) 132112
technical (12) 9:14
34:18 68:12
02:4,15,25 95:7
103-11 106.19 110.25
1117 180.25
technically (3) 95.17
135:15 13613
technique (1) 94:1
techniques (3) 93:7,23
95:10
technologist (1) 13010
technology (12) 82:8
310-25 111.7 14:17
ns 117.816
12659 129,18
119
television (1) 99:22
teting (1) 160:8
template (5) 60:2 65:17
169:19,21.24
templates (2) 185:17,20
ten (4) 53:24
142:21,23,23
tensions (1) 105:23
term (1) 14:21
terminal (9) 15:6
108.10
136:2.4.5,17.18
138.717
terms (22) 2.20 16.17
27-12 36:24 37:4
38:25 60:19 67:12
71:8,19 105.22 126:10
129:15 1319.12
13736 141:3.5 148:22
150:20 17421 1929
tes (2) 11226
test (3) 118.15 119:17
346.17
tested (1) 56:21
testing (2) 11410
118.24
tests (2) 1196.17
text (3) 1441617
169:23
thames (2) 62:10.13
thank (23) 3:15 5:5
8:20 25:1 269
27'5.17,18 285,11
43:22 543 734,22
2126 13218 1302
13:2 180.15 169:19
192.6,17 193:10
thanks (1) 69:16
thats (117) 2:14 419
615 99,13,18 12:16
1420 18:7.12,21
1917 222 26:4 2756
282,23 33:19
35:9,10,12,24 39:3,
42:1 43:3 56:1 57:25,
65:122.28
6620,12,16 6721,
71:22 7421.22 75:13,
16:17 77:7.8,20 78:20
£2:18,24 86:6 88:2
89:13 90.5,12,14 913
92:4 9419,19 98:2
301-20 111.2325,
312.18 1139 115:7,13
118.13 11910,10
326-16 127.1,10
130:1,7.8,13,16,22
331:11,24 132.20,
333:12 1387.22.25,
139:2.8 141.23 142.22
145:7,10 147:9 150:12
35192,14 1563
158:12,17 1607
161:20,20,22 16:19
367217013 1713
372.67 1754
377.8,10.5 17818
160.15 16217 1855
387:25 190:10 191.13
yeaa
theft (1) 55:2
themselves (1) 207
therefore (12) 19:3
55:18 61:3 68:25 05.5
90:25 99:11 1016
129:2,25 157.16
1759
theres (33) 6:20 6:3
9:21.25 113 1336
21:13,2224 31:22
40:8 42.22.23 45:8
523 693 7212
73:22 7441924 95:7
117.24 1317 13636
162-3 16918
a71a1.36 1845
186:4 190.8 1937
theyre (10) 611 92.1
109.25 113 148175
205.12
thing (12) 1:25 26:3.3.4
447 77:21 7931.24
80:8 10014 127.10
36310
third (9) 33 49:12
74:24 91.27 11412
137.5 143.4 15420
a219
thomas (8) 60:12,12
61:19 62:10.15 64:3
65.221
thorough (1) 119.8
though (9) 10:8 48:17
59:19 64:1 67:22,
12657 158:23 159:11
188.10
thought (6) 17:16 21:13
39:8 10021 1565
162.25
three (8) 20:5 29:16
82:11 67:9 105:16
115.5 1737 190.16
through (23) 37 122
20:22 51:19 59.13
64:1 70.25 71:7 726
305:3 113:20 1182.20
13547 136315 137.8
3432 165:2 171-412
163.22 185:10
throughout (6) 392
86:22 99:16 100.10
1195 1451
thursday (1) 193.12
thus (1) 13520
tidy (1) 1355
tight (1) 12:3
wit (1) 183,
time (89) 18:25 26:3
26:23 29:12 30:19
33:7 39:1,3,12,12 41:3
42319 47-49 523.4
54:3 56:1 564,11
57:1,16 61123316
62:10 63:15,21 65:13
67.14 7038 73:10
75:24 76:22 61.2.4
62:22 63:18.19
£45.15 8615 87:1
92:7 96:4.18 96:11
98:12 99:18,20.23,28
300.10 10326 104.19
107.24 1083.24
y09:1,14 11028
anda 11526 117:25
31822 12:13
3226,20,23 123:18,22
3248.21,
125:7,10,14,22
1261 I trail (11) 46:9.19,23
145.25 146:5 169:8 776.23 79:24
361:24 1629 1835.6 I 93:10,11,20 141.20
304.16 169:18 190.11 I trails (1) 20:4
1927 trainer (1) 5:22
timecost (1) 111:4 training (2) 5:9 116.24
timeout (1) 147.17 transacted (1) 123:19
timeouts (1) 147-7 transaction (129) 5:14
times (10) 35:18 4025 I 102 1218.15
402,712 44:14 45:3 18:,9,1243,15,17,19
49:1 72:20 15615 142 186,20,23,25
timetable (1) 24
191,12,.22 208,22
tip (3) 18818 1891.3 21-4,11,11,13,13,14
title (2) 151:4 167:11 32:22,25 331,17
titled (2) 22:19 4
tms (4) 49:19 50:
18:20
tmsrx (1) 186:11
56 56:17 5755,7 58:10,12
9767 I 61:1,4 67:9 6814.20
795,6,7 89:5 90:10
96:12.25 98:8 101.25
today (5) 39,10 13:20 30215 11247
ua418 1152 123:20,22,25,
todays (2) 34:21 63:4 1243.11.13 1266.7.8
together (15) 10°5.12 13222 133:1,7 136110
111,3126,19.22249 I 1378 1402.15 1412
25:4,6,9 112.35 1424.8 1468
340.18 141.9 169-11 147.13,17 1661
told (7) 20:5 59:20 167:12.16 168-45.15
76:24 1020.24 169:19,23 170:35,15,
335:10 14411 172:4,9,1023
tomorrow (5) 35
173:1,16,17.19,19,23,
1929,11,24 193.9 1743.15
tony (5) 157:24 15823 I 176:2,19,21,22 17734
1597.12 1676 178:4,9.16 179.23
too (11) 5:14 12:6,21 160:22,23,24
10:4 59.24 61:22 161.2,3,3.9,18 162-45
‘92:10 10210 130211 1632.16 16516
177.10 185:22 106:21,25
took (7) 25:5 55:15 1871.4,7.8,9
1323 157-24 159.17 108.13,16
166:20 17:20,
too! (36) 145:2
transactional (2)
113.1 176:23
167.12,16 168:9,15,23 I transactionalaccounting
1693571 1703.23 I (1) 17020
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1 transactionalaccountingstock
374131619 1773.13 I (1) 1688
178:15,22 179 162.1 I transactions ($8) 17:21,
1833 1851617 1820.24 193,21
186.21,25 187.7 20:21 33:13 35:2 469
38814,16,18 18013 I 58.1418 616 77:4
tooling (1) 1798
toolset (1) 56:21,
topup (1) 11212
88:16 89:3 90:7
91.7,21.25 92.15.18
94:8 95:21,6,11 96:22
torstein (3) 7324741 I 1009 101:14.16.19.20
19416 1024,8,1219,21
total (4) 09:13 11520 I 1133,15,6 12838
116.14 174.25 132.24 133:4 136:3
totally (2) 41:11 140;10 141:23 16521
186.10 167-4 168:16 169:20
touch (2) 12017 143:6 I 170.19 1736 17435
touched (5) 3616316 I 1766 1815 167:21,22
1031314313 1674 I 16022.25
touchscreen (3) 1331 I transcash (1) 7.24
140.8 141:22 transcript (2) 109
towards (1) 105:16 S419
tp) 1316, transfer (11) 121:25
tps (6) 1122,41132.11 I 14320 162:12,22
3146 13821 1345 1849.10.11
1897 18612.15.5,19
trace (2) 136121714 I transferred (1) 143:12
track (3) 61:4 94:
15222
tracing (1) 13615 transferring (2) 143:7
a2 166:2
transfers (2) 18.21 23:8
13 transform (1) 45:19,
trade (2) 105:10,
trading (1) 84:4
transformation (3)
Opus 2 International
Official Court Reporters
transcripts¢_ GRO
GRO !
POL-0109545
March 20, 2019
Horizons Issues - Alan Bates & Others v Post Office Limited
POL00111977
POL00111977
Day 7
45:741,20
transition (1) 130:16
transitioning (1) 129.25,
travel (8) 7:85,
12521
treatment (1) 166:25
trend (1) 168:3
tral (8) 24,21 1415
34:22 54:26 58:22
606 77:28
tt (1) 2885
true (13) 5:2 28:6 63:7
7241,11,12.24 732
75:9 15255 1398
15032 166.19
trust (1) 823
try (4) 29:20 22.7
11925 189.11
tying (19) 15:11 10.14
24:22 635,814 65.23,
66.36 71:22 73:19
795 10238 123
326.36 14111
149.2021 180:14
18222
tuesday (3) 135 35
6a7
turf (1) 146.22
tum (9) 51:15 50.17
58:20 60:22 €1:8
13249 136:23 167:3
18525
tums (1) 1387
tv (1) 1064
twenty (1) 124.9
twice (10) 50:16 51:22
7634 77:6,18.21,
78:21,19 79:25 80:6
type (6) 35:8 100:2
140.21 1761.18 1772
types (6) 66:8
155:4,5,12 162.16,
17520
typical (2) 8:28
typically (1) 163.1
ultimately (1) 53:10
tunable (1) 123.20
‘unaware (1) 100:9
uncertain (4)
85:12,14,16 116:1
unchanged (1) 144:24
unclear (3) 80:19
11522 1372,
uncontroversial (1)
10325
underlying (5) 50:19
S18 1477 15220
1667
understand (39) 8:21
10:13 13:21 14:38
15:20 19:14 21:21
242 39:18 54:18
62:21 71:6 77:12 78:7
79:1 87:8,12,15,19,23
90:18 93:9 99:13,
1337.12 134.14
141:6,11 144.14 1466
157.24 161:20,22
1673 169:12 175311
17919 18635 19013
‘understandable (3)
15:8 962 11816
‘understanding (8)
17,2 55:21 80:10
85:7 885 177:10.11
‘understood (3) 1432
160:16 192.20
undertaking (1) 164:3
undertook (1) 64:20
‘unexplained (2) 29:27
2116
‘unfair (1) 19:15
unfiltered (2) 35:12,14
‘unintended (1) 168.25,
‘unique (1) 57:6
‘unit (5) 20:25 23:4
1769 1774 184.9
units (1) 23:8
vunbx (3) 1697 1742.5,
‘unknown (1) 252:10
‘unless (2) 33:23 100-22
unlike (1) 192:2
unlock (2) 176:6 17:4
‘unmarked (1) 191.17
‘unnecessarily (2) 38
233
‘unpack (1) 15720
‘unreasonable (2)
23:26,25
‘unretible (1) 129:28
‘unsuitable (1) 45:21
‘unsupported (1) 129:10
until (8) 56:23 57.7
67:9 69:17 70:17 764
13729 19312
‘unusual (3) 15.16 6219
103.13,
update (4) 2:12 120.16
17522 177.18
updated (3) 13017
1535 18518
updates (2) 127:3,15
‘updating (1) 271:1
‘updatingdeleting (3)
168:20 170.22 17:24
upgraded (3) 32.20.23
33:5,
‘upon (6) 23:14 37:20
5223 1163 15317
15514
used (40) 5:12 11:7
1623 2666 34:18
36:18 37:10,22 435
50:1 55:14 57:5 60:13
90:8 91:22 93:23
95:10 96.23 97:21
101.23 102:7 131:3
1522 15523 169.89
a7va2.a3 173306
1767.8 1773.15
3810.17 18536
167:4,15 1885 1693,
useful (2) 127 44:17
user (15) 20:25 47:2
4827 75:19
95:14,18,21,22 132.25
33412 14032,
166:8,11 1741.5
wserfrendly (1) 22:1
‘usergenerated (1) 70:21
users (5) 69:1,2,14,22
16923
uses (4) 338 50.22
17315 173
using (17) 23:2 25:7
41:3 57:11 62.2.6 89:4
92:3 92:28 118.9
123:20 17:13 1832
186.21 186:13 1891
1917
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utilisation (1) 23:16
tility (1) 168:16
v
vague (2) 83:17 157:22
vaguely (2) 57:2 178.19
validation (2) 49:15
ng
valley (2) 8210.33
value (6) 925 10:18
10.25 2013.5 162.14
van (1) 70:4
varies (2) 29:20,20
various (10) 5:11 13:12
2619 7025 7h:
134-20 136.14 144.25
15356
vary (1) 29:28
vast (3) 11:6 132:24
140.10
venture (1) 164.22
vetfcation (1) 119:8
verity (5) 5914 61:5
62:22 63:12 66.1
versa (1) 144:9
version (10) 47.15
s3a1a2
128.12.16,19 15812
163:18 1682
versions (1) 108:8
via (13) 3545221
67.25 133:18,21 1345
136:11 137.9,14.21
13855 160:16 174315
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virtue (1) 22:12
sbity (1) 287
Visible (8) 87:20,24 91.1
93:8,10,23 94:6
14415,
visual (1) 16:6
vodafone (1) 129.24
volume (1) 121:5
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wait (3) 5:5 26:11
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1g (1) 1478
wales (1) 19:19
walkthrough (1) 20:19
wants (1) 20:21
warning (2) 168:23
1922
wasnt (24) 26:16
42:4,13 57:18,20
67.16.25 70:17 7236
82:20 101:2,15 106:12,
107-24 110.18 112.22
126:19 130.39
135:8,10,12 1435
148:3 168:10
wasted (1) 104.21
wateh (1) 165:12
water (1) 88:22
wave (2) 13112 13213
way (35) 11:13
13:1,9.16 18:4 22:1
35:6 36:1 47:16 57:4
58:17 90:11 92:17.18
94:7 97,12 100.0
102,48 117.25
320:21 137.11 15020
152:22 1561,20
166.25 1775.11 179.6
361-2 191.16 1927
ways (5) 11:9 20:28
211 868 1439
web (1) 11214
wednesday (3) 11,16
39
week (5) 1:9 2:28 3:2
2920.20
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weigh (1) 142.6
wellknown (2) 1042.22
went (6) 87:19 69:9
98:19 998 105:2
1507
werent (10) 24:10 25:4
69:10 92:13 96:13
3025 107.21 121.17
Me:4 174.19
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weve (5) 2.23 7:7 15:23
61:28 1504
whatever (4) 16:18
41:28 109.18 1609
whats (18) 9:21 10:12
32:18 136 1920 59:2
66:28,6 108:13,24
13613 1422.89
355:21 175.23
whereas (2) 116.5 131:4
wherever (1) 144.12
whilst (8) 45:12 126.15
116.16 1181 12018
white (3) 10:23 11:1,3
whole (11) 39:3 4:3
48:17 99:14.19.24
92:25 100:5 135.16
142.18 1653
wholly (1) 42:18
whose (1) 698
wicks (5) 157:24 158.23
3597.12 167.6
wider (2) 96:3 179.19
wigan (3) 77:23 78.1
80:3
windows (6) 129.10
130:13,1821,22 1316
wire (1) 11614
wish (3) 1:36 4.13
15718
wishing (1) 126:3
withdrawal (2) 123.19
261
witness (104) 15
219,19 321 4:13.25
5:2.24.25 6:10 16:14
377 18.11,12,15 242
25:2 27:25 2817
29.25.25 31:16
3213.18.22 348
39:28 40.2,20
43:11,20.23 46:15
495 517
549,14.20,
555
59:7.11,13,22
60:11,14,16 62:19
63:3 64:18 65:17
66:5 7011
71:410,13,17 72:2
73:23 747.18 75:9
81:22 64:21,22 05.2
06:22 88:15,24 90:12
91:17 94:25,25 100.21
yori 10310
326:11.19,25 127.7
130.23 131:8,10
132:20 136.25 143.22
144-12 1489.23
M49:17,22 15061314
351.13 157.25 17417
161:25 16914
190:18,24 191:4.12
witnesses (1) 1.9
wombles (1) 17612
wonder (1) 190-17
wondered (1) 8:14
wondering (1) 38:9
wont (1) 70:24
worden (1) 154:17
wordens (1) 3614
wordforword (1) 65:13
wording (4) 43:9,15
49.45
work (19) 17:2 282.3
62:3,7 855,11 86-4
309.16 117.20
ya19.24 1232
330:11 1347 1561
167:21.26 190.22
worked (15) 13:25
24:19 26.19 54:13
55:11,22 73.9 62:18
84612 66:2 998
1320.20 126.15 150:21
working (27) 2:9 10:20
2412.15.24 266
27:11 75.21 63:8
96:14 67.1.3 98.21
99:17,21 103:18
320:18,21,22 121.14
1326-22,25 147-22
353.5 154.18 181:24
1836
works (8) 5:20 8:21
23:22 86:3 87:3
126-21 15:3 169:12
8 (4) 35:4
4135 482
worried (1) 198
worry (2) 94:19,23
wouldnt (22) 11:11
M42 15.16 229
37:12 42.24 4412.19
52:9,10 67:16,17
95:16 6935 93:8
300:11 133.16 145.25
361-23 160:22 185:2
392.30
wrap (1) 131.25
wrapped (2) 95:19
uig.3
wrapping (1) 95:14
write (5) 38:20 795
90:16 110.19 17712
writers (2) 53:28 142.24
writing (2) 132.10
162.23
workstati
written (11) 167 62:6
778,23 79:25 80:45,
87:24 168.25 176:15
10620
wrong (12) 1214.25
18:13 25:10,16,22
281.23 92.9 97.7
320.11 145:6,7
wrote (2) 77:21 144.16
x (3) 11:2 144.21
36213
xansa (6)
99:1,2.4,10,12,12
year (14) 29:16,18,18
31:10,11,28 61:16
1178 120:10,23,28
1492 15088
yearly (1) 31:3
years (20) 13:24 28:25
30.9 31:56 41:7 43:24
45.24 47.11.12 73:6
61.21 99121159
1503.4 162:7.17,19
yellow (2) 13211
10535
youre (23) 197 216.8
31:20 33:2 35:22
41:20 47.15 53:7 59:9
63:8 06:25 91:5 94:4
1033 106.25 114.21
141:16,17 160-4 164.2
1836 1928
yours (4) 29:11 30:1
5412 583
yourself (10) 6:8 18:15
24.21 25:18 632,12
88:24 97.13 13323
yea
yourselves (1) 193.5
youve (4) 88:25 160-7
17915 190:7
zero (11)
165,56.6.2223.25
14616,16 174.24
1908
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(0152014 (1) 190.19
017510 (1) 190:19
(0195561 (1) 182.7
0195962 (1) 18512
02 (1) 1087
(050308 (1) 123:5
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1 (24) 4:20 47:14 49:19
59.14 74:6 75
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1043 1342 159.19
175:15,22 176.1
177.2,16 182.25 25,25
1631 184.11 1943
10 (16) 5:24 27:24
96:20 106:7 10:1,
3141111 1176
18:25 130:18,21
1314 142.25 155:16
163:18 162:19
100 (2) 31:6 106:22
1000 (2) 123:16.19
103 (2) 31:1 1036
1030 (4) 1929.11
1939.12
1032 (1) 12
11 (10) 28:20 86:7
90.20 94.4 1168
151:21 170:28 173.25
17722 179:13,
11000 (1) 31:10
114 (1) 545
1150 (2) 53:25 54:3
s2 (1) 547
12. (12) 11-2
382,8.17,20,22.25
39.12 61:23 62:20
945 1067
122 (1) 174.28
1268 (1) 166.13
129 (1) 174.25,
13 (6) 10615 110:20
1178 126.25 127.7
166.16
1Byearold (1) 127.5
14 (5) 12:17 46:3 74:25
1105 1599
1415 (1) 1508
aasag (1) 1475
16 (2) 88:14 111.15
y615 (1) 184.12
17 (2) 28:25 417
471 (1) 1329
1718 (1) 1508
1723 (1) 21:19
¥72a (2) 140.8 141:22
173940 (2) 18718
189:20
year (1) 29:3
16 (2) 74:22 1047
19 (4) 31:16 1438
187.18 189:20
2981 (1) 62:3
1984 (1) 2419
1987 (4) 81:20 627
96:22 99:16
1996 (1) 106.6
19961999 (1) 1045
41998 (2) 73:17 106.23
1999 (3) 105:11,14
1069
Ast (5) 9:5 1122.2
12318
2 (21) 5:25 67 152.2
26:12 49:21 55.8 682
91:24 945 98:4
108:1,5 10816 1208
1341 14736 176.18
16213,23 1681
20 (7) 1:1 741 129:3
1467 155.45 158:14
2000 (2) 108:3 106.9
2002 (3) 28:20 737.11
2005 (3) 83:21 109:24
1163
Opus 2 International
Official Court Reporters
GRO. }
POL-0109545
March 20, 2019
Horizons Issues - Alan Bates & Others v Post Office Limited
POL00111977
POL00111977
Day 7
2007 (5) 56:14,14 1535
1582 1683
2008 (4) 114:13 115.10
11825 15814
2009 (12) 84:16
987,18 99:14,15
12520 1683.8 107.18
188.21,23 189:20
20092010 (1) 32:20
201 (1) 1038
2010 (23) 58:9 56:16
64:8 75:23 83:4
12030 121.13 1285
12437 1251921
147:5,23 150:11,
161:15,19 17422
1755 1817
1826,9,19 163.21
2011 (2) 698.17
2012 (3) 11:28 24:18
26.25
2013 (6) 707 157.13
1587.15.22 159:16
2014 (8) 6:17 32:2
150:20 1585.15
161:19 1627 16335
201415 (2) 306 149:1
20142015 (1) 30:12
2015 (1) 16516
20152016 (2) 30:24
31a
2016 (5) 245 45:7
46:23 181:20.21
20162017 (1) 30:21
2017 (15) 6:23.28 47:24
1293,13,24 1313
1325.14 1513 1538
1595569 1627
20172018 (1) 30°21
2018 (2) 84:23 16212
2019 (3) 11.2755
19333
2083169 (1) 1621
24 (6) 16:18 28:5 73:16
109.24 15421 193:13
22 (2) 45:7 183:21
220 (1) 1248
226 (1) 1191
226542 (1) 186512
228 (1) 17425
2296 (1) 1773
2297 (2) 1752.30
23 (1) 11224
2386 (1) 36:5
24 (4) 132.9 1475
amar 1947
2an (2) 1711033
24a (1) 17334
25 (a) 698 91:1819
946
250 (1) 8213
2507 (1) 147.16
25882 (1) 186:
26 (8) 64.8 146513
15613 194.8,
27 (a) 8423,
1949.11.12
26 (2) 146-22 194.13
29 (2) 16838
2nd (2) 12825 1248
3 (12) 615 2612
285,17 48:12
60:18,22 73:8 98:4
192.8 194:4,5
30 (8) 44:4 58:14
09:2,13,14 129:24
14g. 1585
300 (2) 30:21 143:3,
31 (3) 30:4 14822
1748
310 (1) 143:5
311 (3) 30:7 11020
1505
314 (2) 30:7 1505
32 (19) 16.14 43:25,
90:10,17 91:3,24
924,19,21
94:14,15,17.18
96:13,25 101:25
102.13 148:9 170-14
322 (1) 17424
33 (1) 128.25
34 (2) 86:6 143:22
3400 (1) 14:16
34000 (1) 14:27
350 (1) 155
36 (2) 90:20 91:15
38 (1) 87.7
39 (1) e710
4 (15) 3:19 15:1 32:18
45:15 48:25 60:24
64:16 12024 1284
13010,13,23 14710
1523 1829
40 (2) 111.16 15815
4000 (6) 182:12.13
39412 186:15.17
aera
‘400000 (3) 182.25
1932 1049
i (1) 87.14
a2 (1) 4918
420 (1) 174:25
43 (3) 75:17 87.18
1442
4327 (1) 14423
433 (1) 19511
436 (3) 58.12 64:7,12
44 (1) 87:22
447 (8) 58:13 64:20
658.21
‘440 (3) 50.12 64.7.2
45 (1) 718
46000 (1) 174:23
46976 (1) 17525
47000 (1) 174:23
5 (14) 422 6:9 628
1838 34:28 49:6
01:22,25 1235.16
1248 168:1 1705
1946
5156 (3) 153:24.17
15421
5187 (2) 154:6 157.17
s159 (1) 157.7
5163 (1) 160.19
5164 (1) 161.12
353 (1) 17424
58 (4) 140:2 174:26.18
1763
5810 (7) 90:6 915,20
96:9 975 101:11,22
587 (1) 976
589 (1) 90:4
6 (13) 427 625 724,5
20.20 3724 384.633
#235 10310 1293
156:1 168.25
600 (1) 125:20
61 (1) 49:22
614 (1) 32821
62 (1) 4931
6276 (1) 183:
69 (3) 1572 15924
16216
64 (1) 160:20
65 (2) 1617.24
655 (2) 16:16,22
66 (3) 4913 1625.16
67p (1) 2519
69 (1) 621
7 (12) 12:17.25 39:15
74:14 75:1,8 85:2
147-4 1645 165:18
162.6 183:1
700 (1) 16.16
701 (1) 16:19
71 (1) 194324
720 (1) 31:19
729 (1) 30:12
73 (1) 19435
74 (2) 198367
75 (1) 93:2
8 (17) 1624 39:7.19
4915 549 59:10
65:13,4 66:16 722
107:26,7 1211
150.22 151.20 166.12
8000 (1) 18636
‘800000 (1) 16412
81 (1) 194.19
ast (1) 16239
9 (1a) 14.25 15,2
47:19 106.25
107.3489 1587
165:9,10 178.2 183:20
92 (1) 1076
97 (1) 1545
99 (1) 17031
Opus 2 International
Official Court Reporters
transcripts} GRO =
GRO
POL-0109545