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Message
From: Andrew Parsons} GRO Hl
Sent: 16/04/2019 07:
To: robert worden Jonathan Gribben
cc: ‘Chris Emery'!”
Subject: RE: New approach to evidence
Robert
We'll chase down the evolution of this request and what happened to it. The reality is that he had all the Peaks and could
have done the search himseif.
As to the request for ARQ data on each Claimant ~ they didn’t even ask for this in relation to their 6 witnesses who gave
evidence of a "bug" in Horizon. We voluntarily disclosed the ARQ data.
A
Andrew Parsons
Partner
Womble Bond Dickinson (UK) LLP
SY WOMBLE womblebonddickinson.com
' BOND _
DICKINSON
From: robert worde!
Sent: 15 April 2019 19:57
To: Andrew Parsons
Ce: 'Chris Emery’
Subject: FW: New app
+; Jonathan Gribben I
Andy, all -
Whinge from Coyne, fyi.
Robert
From: Jason Coyne {
Sent: Monday, April 15, 2019 7:54 PM
To: robert worden
Cc: Chris Emery
Siobhan Forster ¢.
James Hartley
“>; Imogen Randall
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Subject: Re: New approach to evidence
Dear Robert,
Thank you for your email.
On the original plan, my involvement in the Horizon trial should have be finished. My time is now focused on other
projects.
It’s frustrating that you adopt such a position now. Both you and I identified the potential importance of these very
same documents on the day of our meeting at Fujitsu (our WP emails from 28" June are a helpful reminder) but
ultimately you would not join me in requesting copies from the Defendant. This was recorded in my open email of 20°
July 2018 (attached — see viii) and was part of the protracted process to finally obtain these documents, albeit without
your support.
As you say, we have an ongoing obligation to the court and I continue to be open minded to all methods. Care does need
to be taken as I have found these documents are used at various different points within Horizon’s life time, none provide
full coverage. Further, I do not agree that they were used as consistently as you may first suggest.
I understand that Siobhan has made contact today and that we have a Skype meeting scheduled tomorrow, I look
forward to discussing further then.
Kind reg
Jason Coy
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From: robert worden I _ _GRO I
Date: Wednesday, 10 April 2019 at 16:40
~ b Siobhan Forster! "GRO i
‘andrew.parsons¢
Subject: New approach to evidence
Dear Jason -
Since attending parts of the trial, it has occurred to me that the experts can take a much more focussed approach to the
evidence, which would complement our previous work, and might be of considerable assistance to the court. The
rationale for this more focussed approach is as follows:
1. Whenever Fujitsu made any authorised remote access to branch accounts, they raised an OCP, OCR or MSC
whose text included (with high probability) the 6-digit FAD codes of the branch or branches involved. It is
therefore possible to search all OCPs, OCRs and MSCs, finding all those which mention any claimant FAD code,
during that claimant's period of tenure. This search gives about 100 OCPs or OCRs, and about 100 MSCs. It is
therefore possible to assess expert issues 12 and 13, as they impact the claimants, by examining this small
document set.
2. For the three bugs acknowledged by PO which impacted branch accounts (Receipts/ payments mismatch,
Callendar Square and Suspense Account) there are Peaks mentioning the FAD codes of the majority of the
branches affected (sometimes the FAD code is embedded in a 12-digit node id). I infer that if some bug impacts
the accounts of any branch, then with high probability, there is a Peak related to the bug which mentions that
branch's FAD code. Typically the Peak will also mention sums of money, which may help to assess the financial
impact on the branch.
3. It is therefore possible to search all Peaks, looking for Peaks which mention any claimant's FAD code during that
claimant's period of tenure. This search yields about 2100 Peaks. This comparatively small document set can
give the experts (and the court) a very good handle on Horizon Issue 1, as it has impacted the claimants.
lam, frankly, kicking myself for not having thought of this before now. But having thought of it now, it is clearly my
expert duty (a) to share the idea with you, so you can investigate it as you wish; (b) immediately to inform the court of
the approach; and (c) to discuss the approach with you, as soon as possible, and (d) to write a very short report
summarising my findings.
However awkward this may be, it seems to me that it may be of considerable assistance to the court, allowing the court
(as much as it wishes to) to focus directly on a small set of evidence which is very pertinent to the Horizon issues as they
impact the claimants - particularly issues 1, 12 and 13.
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While I am sure it is straightforward for you to identify these documents by your own searches, I will nevertheless share
with you the results of my searches, as work in progress on a WP basis.
May see you tomorrow? In any case, ring any time you'd like to discuss.
With Best Wishes
Robert
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