POL00133074
POL00133074
From: Jonathan Gribber
Sent: Wed 30/01/2019 1
30:03 AM (UTC)
To: Anthony de Garr Robinson {
Ce:
Subject: Parker 2 [WBDUK-AC.FID27032497]
Attachment: 2019.01.29 Signed Second Witness Statement of Stephen Paul Parker dated ....pdf
Tony,
Yesterday FJ informed us that a Giro bank is also an AP transaction (like bill payments) - it is the only type of bank
account that is and all other banking deposits go through a totally different path. We included it as a footnote to
Steve's statement (para. 35). FJ have now told us that Giro Bank Transactions are not AP, but standard EPOSS
Transactions and that prior to online banking (introduced in 2003), POL did support some (but not all) other banks with
deposit and cheque cashing facilities which were also EPOSS transactions. They think that there was also a paper
trail for those transactions too (so they would be detectable during Post Office's reconciliation processes) and we will
pick this up with POL to confirm, but the immediate point is that we need to provide a replacement version of Steve's
statement with the footnote referred to above removed. Our suggestion is to send Freeths a version without the
footnote by email as follows:
"Dear Sirs,
It has come to our attention that the witness statement we provided yesterday contained a footnote in error.
Please find attached a replacement version.
Yours faithfully"
We will then produce a paper to bottom out the above points.
Please let me know if you agree with this approach.
Kind regards
Jonny
Jonathan Gribben
Managing Associate
Womble Bond Dickinson (UK) LLP
jonathan. gribben GRO.
WOMBLE womblebonddickinson.com
BOND
Ww DICKINSON
From: Gareth Jenkins [
Sent: 30 January 2!
To: pete.newsome(.._.S
Cc: Andrew Parsons; Dave.Ibbet
Subject: RE: SP Second Witness Statement: Possible examples to use - effective software fixes
_i; Jonathan Gribben
IMPORTANT - This email or attached documents contains legal advice (or relates to litigation or anticipated litigation) and is being provided in
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Hi Jonny,
POL00133074
POL00133074
Sorry, but you didn’t send me the actual question until I’d gone off line around 4ish yesterday, so other than the
phone call I had from Pete, I didn’t see the emails until late last night.
A further clarification:
1. The Giro Bank Transactions are not AP, but standard EPOSS Transactions. I don’t know how info on them got
to Giro Bank — it may well be that Giro Bank worked off the paper trail and then sent summaries to POL which
they then reconciled with the Horizon feed. POL would need to provide the details.
2. Prior to online banking (introduced in 2003), POL did support some (but not all) other banks with deposit and
cheque cashing facilities. Again these were EPOSS (not AP) transactions. I assume that there was also a paper
trail here and it would work in a similar way to Giro Bank. Again it is POL that need to define the process. All
Horizon did was provide the buttons to record the electronic part of the transaction.
Is there any point in me re-reading Steve’s statement? I’m out this morning, but could do so this afternoon.
Hope this helps.
Best wishes
Gareth
From: pete.newsome:
Sent: 29 January 2019 1
To: Christopher.Jay;
Cc: andrew.parsons' Dave. IIbbett: ; gi.jenkin: '
Subject: RE: SP Second Witness Statement: Possible examples to use - effective software fixes
Jonny
I read out the questions and then interpreted Gareth's answers into my own words.
Pete
Sent from my Android phone using Symantec TouchDown (www.symantec.com)
== Original Message--
From: Jonathan Gribbe
Received: Tuesday, 2:
To: Newsome, Pete
Legal (Chris Jay,)
CC: Andrew Parson
Jay, Christopher
Defence
J Ibbett, Dave I Gareth Jenkins
i
Subject: RE: SP Second Witness Statement: Possible examples to use - effective software fixes
Pete,
Thanks. When you say you have had to interpret, do you mean interpret my email and/or what Gareth has said, or do
you mean you passed on my email and Gareth confirmed that it is correct?
Kind regards
Jonny
Jonathan Gribben
Managing Associate
POL00133074
POL00133074
Womble Bond Dickinson (UK) LLP
womblebonddickinson.com
WOMBLE
BOND
DICKINSON
From: pete.newsome:
Sent: 29 January 2019 17:22
To: Jonathan Gribben; Christopher.Jayé
Cc: Andrew Parsons; Dave. Ibbettt
Subject: RE: SP Second Witness
AC.FID27032497]
Gareth Jenkins
ible examples to use - effective software fixes [WBDUK-
IMPORTANT - This email or attached documents contains legal advice (or relates to litigation or anticipated litigation) and is being provided in
circumstances for which Legal Privilege may be claimed. Do not copy or forward this document without permission.
Jonny
I talked to Gareth and the answer is below. I have had to interpret as Gareth was not able to send a response.
Pete
Pete Newsome
Account Manager
DHL and Post Office Account, Fujitsu UK&l
My normal working week is Monday to Thursday
Ss
oS Fujitsu named as
Responsible Business
of the Year
Fujitsu is proud to partner with Action for Children
I-ClO: Global Intelligence for the ClO. Fujitsu's online resource for ICT leaders
Sponsors of the 2015 Rugby World Cup
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From: Jonathan Gribben {
Sent: Tuesday, January 29, 2019 5:04 PM
To: Newsome, Pete Jay, Christopher 4 GRO.
Cc: Andrew Parsons ; Ibbett, Dave { GRO
Subject: RE: SP Second Witness Statement: Possible examples to use - effective software fixes iWEDUK-
AC.FID27032497]
Yes it has been sent to Gareth, but it is:
How is it possible for SSC to inject a GIRO bank transfer into a set of branch accounts but it isn't possible to
inject another bank deposit? Gareth’s answer Giro Bank paying in was possible into accounts by AP as it was
introduced before on line banking so you needed was the account number and detailed knowledge of the
system so theoretically it was possible. But there was a paper work trail to back this up that the sub-postmaster
had to send in to POL which should then reconcile to the AP transaction file from Horizon. (Post Office would
understand how it worked). A report was produced daily to reconcile against the Horizon feed, any discrepancy
Post Office may find where the paper work was not present would be discussed with the branch at the time.
Post Office can describe what would happen if the paperwork was not available.
Steve thinks the answer is:
I think the answer is that Giro bank is also an AP transaction (like bill payments). It is the only type of bank
account that is. All other banking deposits go through a totally different path. There may have been other
banks who had similar facilities before on line banking was introduced in 2004? but you would have to ask
Post Office as they were AP transactions
Thanks
Jonny
Jonathan Gribben
Managing Associate
Womble Bond Dickinson (UK) LLP
womblebonddickinson.com
yO
From: pete.newsome
Sent: 29 January 2019 16:59 .
To: Jonathan Gribben; Christopher.Jayé
POL00133074
POL00133074
Cc: Andrew Parsons; Dave. Ibbettinceeresm rerun
Subject: RE: SP Second Witness Statement: Possible examples to use - effective software fixes [WBDUK-
AC.FID27032497]
Hi
What is the question? Has it been sent to Gareth already?
Pete
Pete Newsome
Account Manager
DH
T
EA
Web: http://uk.fujitsu.com
Web: uk.fujitsu.com
Account, Fujitsu UK&l
My normal working week is Monday to Thursday
& Fujitsu named as
Responsible Business
of the Year
Fujitsu is proud to partner with Action for Children
\-ClO: Global Intelligence for the ClO. Fujitsu's online resource for ICT leaders
Sponsors of the 2015 Rugby World Cup
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From: Jonathan Gribben ¢
To: Newsome, Pete ¢ Jay, Christopher
Ce: Andrew Parsons ¢ GRO
Subject: RE: SP Second Witness Statement: Possible examples to use - effective software fixes [WBDUK-
AC.FID27032497]
Pete,
Steve has signed his statement and we are holding it subject to one point that Gareth Jenkins needs to check. Can
you make contact with Gareth and ask him to do that ASAP please?
Kind regards
Jonny
Jonathan Gribben
Managing Associate
Womble Bond Dickinson (UK) LLP.
womblebonddickinson.com
A)
From: pete.newsome:
Sent: 29 January 2019 16:49 .
To: Jonathan Gribben; Christopher. Jayé
Cc: Andrew Parsons
Subject: RE: SP Second Witness Statement: Possible examples to use - effective software fixes [WBDUK-
AC.FID27032497]
Jonny
\s available for a call now. Try his mobile. 5.30 is when he needs to stop.....
Pete
Pete Newsome
Account Manager
Account, Fujitsu UK&l
Web: htto://uk fujitsu
Web: uk fujitsu.com
My normal working week is Monday to Thursday
© f/¥iin/el\c-
¥
ero
Fujitsu named as Tenet
ane
Responsible Business uur"
of the Year
Fujitsu is proud to partner with Acti C
I-ClO: Global Intelligence for the CIO. Fujitsu's online resource for ICT leaders
Sponsors of the 2015 Rugby World Cup
= Please consider the environment - do you really need to print this email?
POL00133074
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POL00133074
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From: Jonathan Gribben:
Sent: Tuesday, January 29, 2019 4:41 PM
To: Jay, Christopher Newsome, Pete ¢
Cc: Andrew Parsons G RO
Subject: FW: SP Sec
AC.FID27032497]
examples to use - effective software fixes [WBDUK-
Chris, Pete,
We are close to finalising Steve's statement and it really needs to go today, but he is saying he isn't available after
5:30. Would you be able to speak to him to explain the importance of this please?
Kind regards
Jonny
Jonathan Gribben
Managing Associate
Womble Bond Dickinson (UK) LLP.
womblebonddickinson.com
WOMBLE
/ BOND
DICKINSON y ©@
To: Jonathan Gribben
Subject: RE: SP Second Witness Statement: Possible examples to use - effective software fixes
No, can’t be available after 5:30
From: Jonathan Gribben! — fe] RO —
Sent: Tuesday, Ja! 2
To: Parker, Stev
Subject: RE: SP Secon
itness Statement: Possible examples to use - effective software fixes
Steve,
I should have said, we really do need to get this out today. Are you available this evening?
Thanks
Jonny
POL00133074
POL00133074
Jonathan Gribben
Managing Associate
Womble Bond Dickinson (UK) LLP
Stay informed: sign up to our e-alerts
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From: Jonathan Gribben
Sent: 29 January 2019 16:13
To: 'ParkerSP@uk.fujitsu.co!
Cc: Matthew.Lentont GRO
Andrew Parsons
Subject: RE: SP Second Witness Statement: Possible examples to use - effective software fixes [WBDUK-
AC.FID27032497]
Steve,
Thank you for this. Updated version attached. We are down to one point to bottom out, which is the GIRO bank
theory in para. 35. The bit we are struggling with is that it if it is possible to deposit money in a Giro bank account, how
is it not possible to deposit money in a normal account. Why is a paper slip necessary for this type of account?
It might be worth having a quick call on this. Are you free?
Kind regards
Jonny
From: ParkerSPi
Sent: 29 January 2019 14:47
To: Jonathan Gribben
Cc: Matthew.Lentont
Andrew Parsons
Subject: RE: SP Second Witness Statement: Possible examples to use - effective software fixes [WBDUK-
AC.FID27032497]
} Lucy Bremner; John.Simpkins¢,
Latest comments / change marked
Steve
From: Jonathan Gribben I
Sent: Tuesday, Ja!
To: Parker, Steve
Cc: Lenton, Matt!
ndrew Parsons
POL00133074
POL00133074
Subject: RE: SP Second Witness Statement: Possible examples to use - effective software fixes [WBDUK-
AC.FID27032497]
Importance: High
Steve,
Please see attached the updated version of your statement and a comparison showing the changes made.
Can we discuss the comments at 2:00pm please?
Kind regards
Jonny
Jonathan Gribben
Managing Associate
Womble Bond Dickinson (UK) LLP
womblebonddickinson.com
}) WOMBLE
Wise’ BOND
DICKINSON Sin)
From: ParkerSP¢_ GRO.
Sent: 29 January 2019 10:52
To: Jonathan Gribben
Subject: RE: SP Second Witness Statement: Possible examples to use - effective software fixes [WBDUK-
AC.FID27032497]
Yes, will do
From: Jonathan Gribben {
Sent: Tuesday, Ja
To: Parker, Steve
Gareth Jenkins
RE: ftware fixes [WBDUK-
AC.FID27032497]
Steve,
Thank you for this.
I'm working on the statement now — next (and hopefully final version) will be with you within 30 minutes. We need to
get it out today, so please can you review on receipt? I'll send you a comparison so you can easily see the changes
made.
Kind regards
POL00133074
POL00133074
Jonny
Jonathan Gribben
Managing Associate
Womble Bond Dickinson (UK) LLP
Stay informed: sign up to our e-alerts
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Gareth Jenkins tee . wo GRO ie eenuenennesnesn i
Subject: SP Second Witness Statement: Possible examples to use - effective software fixes
IMPORTANT - This email or attached documents contains legal advice (or relates to litigation or anticipated litigation) and is being provided in
circumstances for which Legal Privilege may be claimed. Do not copy or forward this document without permission.
Jonny, we’ve been looking at some potential examples to use within the witness statement. Suggest WBD have a look
and decide if it is useful to add them as examples?
Effective Software Fixes
Pco0g9918: PSteed2847N - reverse a rem, but when this has been reversed it is doubling up ona
balance
+ve: Already mentioned in statement but still shows a quick software error turn round
28/04/03: SSC (Paul Steed) identified error
28/04/03: Paul Steed updated and sent to MSU to handle discrepancy with FAD & POL
30/04/03: Development identify error
01/05/03: Work Package generated: PWY_WP_16353 B3S30R
07/05/03: Tested on LST. Fix released.
09/05/03: I have spoken to the PM to say that the software fix was sent down and became active on 07-May-2003
and so there should be no recurrences of the original problem.
PC0123699: 28/07/05 ...payments and receipts are mismatched...PM states he was balancing on node
2 but there was discrepancies..
-ve: Initial SSC response was erroneous, to send back to Helpdesk.
+ve: Fast fix to live for financial issue
+ve: Demonstrates passing to MSU to tie up financial impact with POL
+ve: Example of looking at more than one site, diligence identifying other sites with issue
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+ve: Shows how an initial R&P error is seen by PM and support are subsequently able to identify other events that tie
it in to other sites
28/07/05: Incorrectly sent back by SSC ...Balancing problems should be dealt with initially by NBSC...
28/07/05: ...Have spoken with the PM and advised...All that remains now is for us to try and identify the root cause of
the discrepancy which may take a while. As per usual we will forward our findings on to the MSU who will advise POL
accordingly...
29/07/05 With development. Work Package PWY_WP_22602 generated
01/08/05: BI3S80R_WP22602 is now ready for test
02/08/05: Release PinICL PC0123865
08/08/05: This has passed testing in LST and is being returned to RM for live pilot.
09/08/05: sent out to the Pilot 100 successfully
05/09/05: Applied to all live outlets and now in the live Generic Prodlists roll-outs using both S70 and $80 spares
When the PM went to produce a trail balance a discrepancy was shown but at the bottom the receipts and payment
totals did not match.
The £170 discrepancy was down to an APS txn message that had no product number and no primary or secondary
mappings. There was a critical event raised on 21st Jul on counter 9 which helped to identify this (Event Id:4 with the
text "Error Message: Failed to generate EPOSSCore transaction grammar").
As the txn message was incomplete it was omitted from the rollover 'calculations' and thus caused the discrepancy
reported.
When I checked the tivoli event archives yesterday I found that 216 of these events had been logged in the past 7 days
at different offices/counters
Looks like whenever the event is raised it is either down to a cancelled quantum txn
Have checked out a sample of 40 to 50 sites and they're all at S80 so its probably safe to assume its an S80 problem.
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