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From: Parsons, Andrewf,_
Sent: Thur 13/03/2014
To: Rodric Williams
Ce: Belinda Crowe’
Subject: RE: Strictly Private & Confidential - Subject to Legal Privilege
Rodric
I think we hold fire until we see the thematic report. At the WG meeting on Friday, SS hinted that their concern is not
acomms failure between branch and data centre (and therefore a failure to record transactions to the audit log in the
DC) but rather it was where a third party system received the transaction (eg. bank withdraws cash from a customer
account) but there is then a comms failure that stops the transaction completing at the branch end (eg. customer
doesn't get handed any cash). They call this the "one-sided" transaction issue. This point is not expressly drawn out
in M014 but does come out more clearly in M001 — Castleton
This variation on the comms theme is not directly covered in the FJ Data Integrity documents so we may need to
commission further work from FJ once we know for certain how SS have characterised this in their thematic report.
On that basis, I think that sending more info at SS at this stage risks them asking more questions. My preference is
for a targeted attack on the SS' report when we understand the specifics of their position rather than be on the back
foot in trying to defend the entire Horizon comms infrastructure.
Please say if you disagree.
Kind regards
Andy
Andrew Parsons
Senior Associate
for and on behalf of Bond Dickinson LLP
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From: Rodric Williams [mailto3_
Sent: 12 March 2014 14:05
To: Parsons, Andrew
Cc: Belinda Crowe
Subject: FW: Strictly Private & Confidential - Subject to Legal Privilege
Andy,
What are your thoughts on how we should feed to SS FJ’s response below on SS’s M014 report?
Kind regards, Rodric
Rodric Williams I Litigation Lawyer
iC) 148 Old Street, LONDON, EC1V 9HQ
Ps
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© @postofficenews
From: Rodric Williams
Sent: 06 March 2014 11:49
To: Parsons, Andrew
Subject: FW: Strictly Private & Confidential - Subject to Legal Privilege
Pls see below
Rodric Williams I Litigation Lawyer
148 Old Street, LONDON, EC1V $HQ
(oy Post Office stories
® @postofficenews
From: Kay Alastair [mai
Sent: 06 March 2014 10:00
To: Rodric Williams
Cc: Andy Holt
Subject: Strictly Private & Confidential - Subject to Legal Privilege
Hi Rodric
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The attached Horizon Integrity doc and details of findings on an email referencing Semilong 226226 branch are the
specific docs referenced in Question 2
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Regards
ALASTAIR
From: Rodric Williams [mi
Sent: 05 March 2014 18:04
To: Kay Alastair
Cc: Andy Holt
Subject: RE: Strictly Private & Confidential - Subject to Legal Privilege
Alastair,
Thank you again for your email below. So that I know we are looking at the same thing, could you please send me /
cross refer me to the specific documents to which you refer in your answer to Question 2, i.e.:
- the “Horizon Integrity Witness Statement and accompanying papers”; and
- the “specific case evidence already submitted” which shows that operator error during the recovery process
did not contribute in any significant way to losses at the office.
By all means give me a call if it’s easier to discuss.
Kind regards, Rodric
Rodric Williams I Litigation Lawyer
i) 148 Old Street, LONDON, EC1V $HQ
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Fro ‘ay Alastair [mailto GRO
Sent: 05 March 2014 14:29
To: Rodric Williams
Cc: Andy Holt
Subject: Strictly Private & Confidential - Subject to Legal Privilege
Hi Rodric
The following details the Fujitsu response to questions 1 to 4 ( which have already been vetted by Michael
Harvey and Pete Newsome):
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1. Could communications line problems be responsible for: (a) transaction discrepancies; and/or
(b) branch losses?
Communications line problems cannot be responsible for transaction discrepancies which lead to branch losses
/ gains. The answer to question 2 answers why this is the case. They can however be the catalyst for miss-
operation by Post Office staff which can cause discrepancies (see the description of the recovery process in the
answer to 2 below).
2. What safeguards exist within the Horizon system to protect against a communications line
failure becoming responsible for a transaction discrepancy and/or branch loss?
The Horizon system stores a complete basket of a customer's transactions to the Data Centre in one
communications interaction. This interaction will be either fully processed or entirely lost:
+ There is a digital signature on the whole basket (included in the same interaction) to ensure that the
data has not been corrupted en route.
+ Every financial transaction has a sequence number. The system checks that there are no gaps in the
sequence.
If the entire communications interaction is lost, then there are retries and if these fail the user is made aware of
the problem and is logged out.
When the user logs back in the recovery process is invoked. This completes any reconciliation required
between the counter and the data centre view of the transaction. Thus a communication fault can only be an
indirect cause of a financial loss / gain. This would only be significant if there were a large number of
recoveries due to forced Log Outs and the clerk has not settled with the customer (i.e. declared cash or
product handed over / received) in line with what has been recorded on the system and notified to the clerk.
This subject is also covered in the Horizon Integrity Witness Statement and accompanying papers.
It should be noted that in this specific case evidence already submitted does not indicate that possible mistakes
made by the clerk as a result of recovery contribute in any significant way to losses at the office.
3. Specifically, could transaction discrepancies and/or branch losses be caused by: (a) the
communications line being shared with a telephone; and/or (b) a “loop” or “noise on the line”?
As stated above, a communications line failure cannot cause transaction discrepancies. The reason for this
failure, whether because the line is shared with a telephone or “noise on the line” is therefore not relevant.
Clearly these factors may increase the risk of a communications line failure which increases the risk that the
sub-postmaster will not be able to process transactions, not that it will causes a discrepancies or losses
4, What does Fujitsu say about the temporal connection between the resolution of problems with
the communications lines and the cessation of transaction discrepancies and branch losses?
Fujitsu cannot comment on temporal connections. As stated above, the communication line problems do not,
technically, cause transaction discrepancies or branch losses. The Horizon system provides an accurate
representation of what was inputted into the system and what was and was not processed, due to
communication line issues or otherwise.
The reader might also consider:
e Page 7 of the document M014_POL_Case_Review_Summary_KA[1].pdf does record another
discrepancy on 03/04/13 (loss of £108.36) which might refute a statement of “no further allegations”
e Re-use of logins
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e Incorrect processing of cheque payments
As contributory factors that could start and cease on any date
Regards
ALASTAIR
Alastair Kay
Project Manager
Post Office Account
From: Rodric Williams [mailto!
Sent: 03 March 2014 15:30
To: Harvey Michael
Cc: Newsome Pete; Kay Alastair; Andy Holt
Subject: Strictly Private & Confidential - Subject to Legal Privilege
Michael,
As discussed earlier today and with apologies for the delay (IT problems!), can Fujitsu please provide us with
an answer to the following questions:
1. Could communications line problems be responsible for: (a) transaction discrepancies; and/or (b)
branch losses?
2. What safeguards exist within the Horizon system to protect against a communications line failure
becoming responsible for a transaction discrepancy and/or branch loss?
3. Specifically, could transaction discrepancies and/or branch losses be caused by: (a) the
communications line being shared with a telephone; and/or (b) a “loop” or “noise on the line”?
4, What does Fujitsu say about the temporal connection between the resolution of problems with the
communications lines and the cessation of transaction discrepancies and branch losses?
We require these answers so that we can properly consider the statements made by Second Sight in para’s
4.2 (“Whilst we have seen no technical evidence that links communications line problems to transactional
discrepancies, we find the proximity of this solution to the resolution of the alleged problems to be quite
compelling”) and 5.1 (“Whilst we have not been able to establish a direct causal link between
communication line problems and the losses reported, we believe that communication line problems did
play some part in these losses”) in the attached Draft Report prepared by Second Sight. I also attach the
Post Office Investigation Report to which Second Sight’s Draft Report responds.
As discussed, we need the answers as a matter of urgency, and are happy to receive them piecemeal if that
is going to be quicker. Can you please let me know when we can expect to receive them?
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I also look forward to receiving from you the list of the issues which the Draft Report raised for you.
Please give me a call if we need to discuss further.
Kind regards, Rodric
Rodric Williams I Litigation Lawyer
148 Old Street, LONDON, EC1V 9HQ
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