womblebonddickinson.com
11 February 2019
Freeths LLP
100 Wellington Street
Leeds
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WOMBLE
BOND
DICKINSON
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By email only ‘APGIAP6/364065 1369
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Email: james.hartley!
Dear Sirs
Post Office Group Litigation
Horizon Issues Disclosure
We write in response to your letters of 2 October, 18 December, 21 December, 17 January, 22 January,
4, 6 and 8 February 2019.
% Overarching Response
1.4 Before responding to each of your letters in which the Claimants have sought further disclosure
from Post Office, given the volume, scope and timing of these requests and the prejudice that
these have / are causing to Post Office's trial preparations we feel that is necessary to remind
you of the course that disclosure for the Horizon Issues Trial has taken and our concerns about
this.
1.2 Please do not feel that it is necessary to provide a response to this section of our letter. We
anticipate that there will be disagreement between the parties as to the scope of the disclosure
given by Post Office and the subsequent requests made by the Claimants, but given the
proximity to the Horizon Issues trial there is limited time for a full debate of these matters.
13 Disclosure was principally completed in May and August 2018 with little comment or feedback
from the Claimants. Then, following the Common Issues trial, the Claimants have produced 13
letters relating to Post Office's disclosure — many of which we have responded to already and this
letter addresses the remainder. All your letters have requested further disclosure from Post
Office. The total number of requests is understood to be approx. 70 separate requests. There a
number of concerns about the way in which these requests have been made which are discussed
in paragraphs 1.4 to 1.23 below. Where these concerns arise in relation to a specific letter or
disclosure request, greater detail of Post Office's concerns is provided in the latter sections of this
letter in response to each letter.
Scope
1.4 The majority of the Claimants' disclosure requests have not been drafted in line with the
Disclosure Pilot Scheme which the parties agreed to adopt. It was ordered (following a contested
CMC) that disclosure should be conducted on the basis of Model C (narrow classes or categories
of documents). In a small number of instances, the parties agreed, where appropriate for specific
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issues, to use Model D (narrow search-based disclosure, without Narrative Documents). A large
number of the Claimants’ requests have sought disclosure of documents which are not limited by
a document type/category, date range or custodian. These requests are not Model C requests.
In some instances the requests have been drafted in a way which makes them broader than the
alternative Model D approach (since the Claimants have sought disclosure of Narrative
Documents). For example, the Claimants have requested documents that relate to background
facts that are neither relied upon by witnesses nor central to the Horizon Issues — ie. the request
for disclosure of documents relating to the introduction of PING and the rationale behind this
introduction. Matters have been further complicated by the fact that the Claimants have
presented requests both from the lawyers and from Mr Coyne without, it seems to us, considering
the extent of overlap between the two sets of requests or the Court's directions as to the nature
and timing of disclosure. The upshot is that, albeit by degrees, the Claimants have effectively
requested standard old-style disclosure from Post Office and have disregarded the much
narrower and more precise type of disclosure ordered by the Court.
1.5 The far-ranging scope of the Claimants’ disclosure requests means that Post Office is often
unable to even begin to identify and/or locate the documents that the Claimants wish to be
provided with. Many of the inquiries which you ask Post Office to carry out potentially cover a 20
year period and as you are aware in many cases Post Office simply does not hold documents in
a way which makes searching for categories of documents straightforward. Given that these
requests have been made shortly before the Horizon Issues trial, against the background of a
claim which has still not been pleaded in any detail by the Claimants, it is even more important for
any requests to be narrow so as documents can be gathered, reviewed and disclosed within the
time available to do so. Instead of preparing for trial, Post Office's legal team has had to divert
resources to discussing with Post Office and Freeths the scope and logistics of giving further
disclosure, which has required a considerable undertaking in the redrafting of your requests to
make them compliant with Model C as you will see below.
CPR 31.14
1.6 The Claimants have made multiple, scattered requests under CPR 31.14(1)(b) (see Freeths'
letters of 21 December 2018 and 22 January 2019).
17 In particular, the requests in your letter of 22 January 2019 were premised on the basis that Post
Office's witnesses had "been provided with/had sight of document in order to prepare their
Statements, which have not been disclosed to the Claimants." CPR 31.14(1)(b) provides that a
party may inspect a document mentioned in a witness statement and the witness must make a
specific reference to the document or allude to it directly, otherwise CPR 31.14(1)(b) does not
apply. Almost none of the requests you have made fall within CPR 31.14. They are new
requests for disclosure and it is misleading to present them as if our client has attempted to hold
back documents referred to in their witness evidence.
1.8 Even if we were incorrect, there has been a substantial delay in making these disclosure
requests: our client's evidence having been served on 28 September 2018 and 16 November
2018.
1.9 Despite your requests not being within the scope of CPR 31.14(1)(b), Post Office has provided
the disclosure sought where the scope of the request is sufficiently clear and it has been
reasonable and proportionate to do so. A full response to the requests made in your letter of 22
January 2019 is at section 9 of this letter.
Documents already disclosed
1.10 Onnumerous occasions the documents which the Claimants have sought disclosure of have
already been disclosed. By undertaking analysis of the disclosed documents we have been able
to locate the relevant documents on your behalf. Given that the documents have been disclosed
electronically and with metadata (where available), the Claimants have the same information
available to them as Post Office and should be able to locate these documents themselves. Our
concerns about disclosure requests being made before analysis of the disclosed documents has
been undertaken was raised in our letter of 10 October 2018, but does not seem to have been
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taken into consideration. A good example of this is your request for disclosure of Charles
MacLachlan's reports, which had already been disclosed by your clients to us.
1.11 Again, undertaking this work on your behalf is taking resources away for the trial preparations
and prejudices Post Office's preparations for trial.
Timing
1.12 Disclosure for the Horizon Issues Trial has been split across various CMC Orders:
1.12.1 By the Second CMC Order (dated 2 February 2018) the Court ordered that Model C
Disclosure and the then draft Practice Direction were to apply
1.12.2 I The Third CMC Order (dated 1 March 2018) ordered disclosure of Model C classes of
documents which primarily related to the Common Issues Trial. However, it also
included early disclosure of documents which related to the Horizon Issues Trial, such
as:
(a) Technical documents stored in Dimensions.
(b) Known Error Log.
(c) Minutes of meetings of Post Office's Board of Directors concerning the roll-out of
Horizon and Horizon Online.
(d) Contract between Post Office and Fujitsu (ICL).
(e) Documents relating to the ability of Post Office (whether itself or by Fujitsu)
remotely to detect the occurrence of potential shortfalls or other branch account
discrepancies, when the same occurred and whether those discrepancies were
caused by bugs, errors and/or defects in the Horizon system; the ability of Post
Office and/or Fujitsu to conduct transactions, (by entering, deleting or otherwise
altering the same) in postmasters' branches remotely; and Balancing
Transactions.
Disclosure of these documents was between 10 and 18 May 2018. This Order also set
out a process for introductory demonstrations of Horizon for the IT experts.
1.12.3. The Fourth CMC Order (dated 21 June 2018) then provided for the disclosure of
documents for the Horizon Issues Trial (known as Stage 3 Disclosure). In the lead up
to the CMC on 5 June 2018, at which this Order was made, there was considerable
correspondence between the parties as to the scope of disclosure required for the
Horizon Issues Trial and the Claimants had a large input into the disclosure that was to
be provided by Post Office. It was open to the Claimants to request any documents
which they felt needed to be disclosed at this stage. Stage 3 Disclosure was then
provided on 1 August 2018.
1.13 After the Common Issues trial, which ended 4 months after Stage 3 Disclosure, Post Office has
received numerous requests for further disclosure. The majority of these requests could have
been encompassed within the scope of Stage 3 Disclosure since the issues and categories were
known to your clients. The Claimants did not seek to include these additional documents within
the disclosure ordered but have waited until a couple of months before the trial commences to
make substantial requests. Post Office's position is that your clients could and should have
requested many of these documents long before any witness evidence was served.
Mr Coyne's Request for Further Information
1.14 The Fourth CMC Order also ordered the inspection of the Peak and TfS systems by the
Claimants’ IT Expert (Mr Coyne) by 15 June 2018. This was because these systems are
integrated databases holding over 200,000 unique records that are not designed to be mass
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extracted and disclosed. This inspection took place on 15 June 2018 and Mr Coyne had a
standing offer (and indeed binding right under a Court Order) to inspect those systems again on
reasonable request (but he never did). As was made clear before the CMC and during Mr
Coyne's inspection, it was always possible to extract a small number of Peaks manually for him
(indeed he was provided with some following the inspection visit) but the extraction of all 220,000
Peaks and the TFS entries was an altogether different proposition. Following the first inspection,
no request for disclosure of the full databases has ever been made by the Claimants.
1.15 Alongside disclosure, the Claimants’ expert had the opportunity to make requests for further
information. The process for this was set out in the Fifth CMC Order. In his requests lodged on
18 May 2018 and 26 June 2018, Mr Coyne sought a significant amount of further documentation
and he asked a number of questions about the PEAK and TfS systems. These requests were
unclear and despite us seeking clarification, no clarification was provided so Post Office could not
answer those questions. Instead, Post Office offered to try to provide voluntary disclosure of the
documents stored in these systems. It was made clear in Post Office's responses to Mr Coyne's
requests on 6 August 2018 that extraction of these databases would be time-consuming (and at
that time it was not even known if it was technically possible.) Fujitsu had to write special
software code in order to extract the primary text of these databases in a format that was usable
but nevertheless our client committed to doing this voluntarily. Mr Coyne never lodged any
objection to this proposal (as he was entitled to do under paragraph 2 of the Fifth CMC Order)
and so our client proceeded as agreed. The databases were disclosed on 27 September 2018
and 23 January 2019.
1.16 Since providing this disclosure Post Office has been continually criticised by you for providing
disclosure of these documents late. As can be seen above, this disclosure was neither late nor
even ordered. If the Claimants or Claimants’ expert had required further inspection or disclosure
of the Peaks / TfS at an earlier stage then it would have been open for the Claimants to request
this from Post Office and the Claimants could have done so from June 2018 onwards.
1.17. Mr Coyne re-raised some points and posited new questions in a revised request for information
made on 14 December 2018. This response was required by the Fifth CMC Order to be provided
by 18 August 2018. We have repeatedly asked for an explanation as to why the Claimants
disregarded the Court's direction in relation to this but have never received any explanation. This
delay has had an impact on disclosure since Mr Coyne's new RFIs were not limited to information
requests, but extended to requests for further disclosure. The delay in raising these matters has
meant that the parties lost 3 months to locate and disclose the documents sought by the
Claimants’ expert. Any resulting prejudice through disclosure being given shortly before trial has
therefore been caused by the delays of the Claimants and the Claimants' expert.
Letter of claim
1.18 In an attempt to paint a picture that Post Office has been resisting disclosure for long periods,
your letter of 22 January 2019 seeks disclosure of 30 categories of documents, some of which
are said to have been long standing requests originating from disclosure sought in the Claimants'
Letter of Claim dated 28 April 2016. These initial requests were effectively for pre-action
disclosure and were entirely superseded by the bespoke disclosure orders that were extensively
debated, agreed and made by the Court during 2018.
1.19 In any event, we note first that Post Office has disclosed over 510,000 documents and your
clients have disclosed less than 1,600 and less than 50 in relation to the Horizon Issues. The
volume of disclosure alone shows the lengths that Post Office has gone to give disclosure.
1.20 Second, this assertion is simply wrong. Section I of the Letter of Claim sought pre-action
disclosure of 32 broad categories of documents. Three of these requests sought documents
relating to "bugs". The table below set out these requests and the discussion on them between
the parties.
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errors, "bugs" or problems in the
Horizon system"
significant. These
documents will also
not be located in
one place. A full
disclosure exercise
would be required to
locate these
documents."
of Fujitsu if required. Please
reconsider this request and
act reasonably so as to
provide the documents we
have requested.
We also anticipate you will
have previously compiled
documents in this category."
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Letter of Claim Letter of Response I Freeths letter of 25 August I WBD letter of
(16 April 2016) (28 July 2016) ane Sees
Request 7 - "Post Office internal “the volume of “We anticipate that such "As per our
notes, memoranda, documents that may I documents exist, are previous
correspondence, emails and be covered by this accessible, and could be explanation, a
briefing documents regarding request would be provided with the assistance I full disclosure
exercise would
be required to
locate these
documents,
which at this
stage is not
reasonable or
proportionate."
Request 23 - “Internal
memoranda from Fujitsu and PO
referred to by Second Sight as
identifying a “Horizon bug’ with
Horizon Online"
"We do not
recognise the
document to which
you refer. Please
provide further
details."
"We anticipate you should
be in a position to identify
these documents and ask
that you do so."
“as per our
previous
response, we do
not recognise
this documents.
Please provide
further details so
as we can
progress your
request”.
Request 31 - "... The first
document to which Second Sight
refer is named "Correcting
Accounts for "lost" Discrepancies"
and was created by a senior
engineer at Fujitsu in September
2010. The second is entitled
"Receipts/Payments Mismatch
issue notes" which appears to be
a minute of a joint Post Office and
Fujitsu meeting held in August
2010. Please provide copies of
these documents."
"These documents
will be provided."
"We await the documents
you agree to provide, and
have no further request at
this stage."
"Documents
were provided
on 31 August
2016"
1.21 None of the requests which you made on 26 April 2016 seem to be the same as, or
encompassed by, the requests which you have made on 22 January 2019. Further, the lack of
engagement by the Claimants in April 2016 to assist Post Office to formulate a narrow class of
documents which could be disclosed (given that at this time the GLO had not yet been ordered
and there had been no pleadings) or provide further information when asked to do so meant that
Post Office was unable to provide the disclosure which you sought. This cannot be a criticism of
Post Office.
Conclusion on overarching comments
1.22 As set out above, there has been a clear procedure for disclosure request, response and order
which both parties were meant to comply with in early to mid-2018 and which you have effectively
ignored by making repeated last-minute requests outside that procedure and its parameters.
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1.23 It should also be kept in mind that the Claimants' new demands for further late disclosure fall to
be considered against the background of a complete lack of engagement with Post Office's
questions about how the Claimants have undertaken their own disclosure. This matter will be
addressed in a separate letter once Post Office has had the opportunity to review the Claimants
additional disclosure which we were informed of on 7 February 2019.
2. Responses to outstanding disclosure requests
21 The remainder of this letter sets out Post Office's responses to the Claimants' outstanding
disclosure requests.
2.2 Post Office has sought to respond to all of your requests. However, given the volume of requests
that have been made if you believe that any of your requests have not been responded to it
would be appreciated if you could bring these to our attention.
3. Requests on 2 October 2018 — documents relating to known bugs / errors
3.1 Further to our letter of 11 January 2019, please find enclosed a disclosure list named
"Dalmellington, Newport and remuneration overpayment’. This list contains the relevant
documents sourced from the 59 custodian's email accounts used for Stage 3 Disclosure, which
were responsive to the keywords "Dalmellington", "Newport" and “Remuneration overpayment™.
3.2 Anumber of documents have not been disclosed since they are privileged (on the basis of legal
advice and/or litigation privilege) and some documents have been redacted on the basis of legal
advice and/or litigation privilege. These documents have been reviewed by the legal
representative in charge of disclosure.
3.3 It should be noted that Stage 3 Disclosure specifically excluded emails. The majority of
documents which are now being disclosed are emails and therefore did not fall within the scope
of a previous disclosure order.
4. Requests on 18 December 2018 — documents relating to Claimants’ witnesses
41 The Managing Judge made clear from the outset that the Horizon Issues trial was not intended to
be a trial of the merits of individual Claimants’ allegations and as we have set out in other
correspondence gave directions to that effect. Disclosure for the Horizon Issues Trial was
therefore scoped on this basis, with Post Office giving disclosure of documents concerning
Horizon in the generic sense (ie. not documents which concerned the operation of Horizon in
specific Claimants’ circumstances). The disclosure which is now sought by the Claimants is
specific to their individual witnesses and therefore would not fall within the scope of the
disclosure ordered for the Horizon Issues Trial. The Claimants’ obligation, by contrast, was
simply to give disclosure of documents relied upon as well as known adverse documents.
4.2 It was not until 28 September 2018, some two months after Stage 3 Disclosure was given, when
the Claimants served witness evidence from 6 subpostmasters / assistants that Post Office first
knew that these individuals would be involved in the Horizon Issues Trial (the Individual
Witnesses). Despite the Claimants having known the identity of the Claimants’ witnesses from
at least September 2018 (and presumably long before then) you have waited until 18 December
2018 to make the first disclosure requests for documents relating to these people.
43 As a result of the above, there has been no order by the Court requiring either party to provide
disclosure of documents relating to the Individual Witnesses. This has materially prejudiced our
client because had it known that your clients would be relying on individual evidence at trial, it
would have sought appropriate disclosure orders as part of Stage 3 Disclosure. Your lack of
transparency around your witnesses, and breach of a Court Order in filing this evidence, has
deprived our client of that opportunity and risks the trial proceeding on an unfair footing.
44 Notwithstanding the above, our aim is to try to assist the Court at trial. Pursuant to your requests
made on 18 December 2018, a disclosure list named "Claimants' Horizon Witnesses" which
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contains the relevant, non-privileged documents reviewed by Post Office's witnesses during the
production of Post Office's responsive witness statements will be provided to you shortly.
45 In relation to Mr Singh, this Claimant was one of the 12 Claimants who was considered as a
potential Lead Claimant for the Common Issues Trial. During the selection process the parties
provided disclosure of a number of documents relating to Mr Singh (disclosed on 19 January
2018 - over a year ago). Mr Singh provided disclosure of his diary entries showing his calls with
the NBSC (C-0166-0000015 to C-0166-0000026, C-0166-0000028, C-0166-0000031 to C-0166-
0000032) and his transaction receipts (C-0166-0000033 and C-0166-0000034). Post Office also
disclosed Mr Singh's NBSC call logs (POL-0000537). Part of your request for disclosure on 18
December 2018 is therefore duplicative of the disclosure that was provided by both parties over a
year ago.
46 Further, as evident from our second letter of 19 January 2018, Post Office holds limited
documents in relation to Mr Singh due to the age of his claim and requests for disclosure of
documents relating to this Claimant should be made with this in mind.
47 In relation to Mr Patny, the majority of the documents which you have requested had already
been provided either to Mr Patny or Freeths during the course of the parties’ correspondence in
relation to his suspension. Disclosure of the NBSC call logs and a breakdown of the transaction
corrections issued to the branch were disclosed on 12 May 2017 (over a year and a half ago).
Further, copies of the transaction and event data was provided on 29 November 2017. Formal
disclosure of these documents has not yet been given, and so Begin Bates numbers will be
allocated to these documents in the disclosure list to follow.
48 Lastly, a number of the documents of which you requested disclosure were provided to you with
Post Office's responsive witness statements on 16 November 2018 (for example, Mr Latif's and
Mr Patny's HSD logs).
49 The above examples reflect the point made earlier in this letter that due to a lack of diligence on
the Claimants’ side, our client is having to identify already disclosed documents in order to
respond to requests that should not have been made in the first instance.
5. Requests on 21 December 2018 — documents referred to in Post Office's Witness
Statements
5.1 A substantive response to your letter of 21 December 2018 was provided by way of our letter of
17 January 2019. The majority of the documents which you requested disclosure of had already
been disclosed and by undertaking searches of the disclosed documents we were able to locate
these on your behalf. Of note, you requested disclosure of the Horizon System User Guide from
1999/2000 which was included within the Common Issues Trial bundle and referred to on
numerous days at the Common Issues Trial (see Day 7, page 192).
5.2 As previously requested in our second letter of 10 October 2018, before raising concerns and
queries about the disclosure provided by Post Office, please analyse the information, data and
documents which have already been provided. The time and effort required to respond to your
queries is a matter which will be raised when the costs of disclosure fall to be considered.
Further, undertaking this work on your behalf is prejudicing Post Office's preparations for trial.
5.3. There were a number of your requests which required Post Office to undertake further analysis to
locate and provide disclosure of the documents. This work has now been completed and a
disclosure list named "21 December 2018 - responses" will follow shortly.
Request No. I Disclosure Request Response
7 Audit Reports of Horizon I A search for further audit reports held in our e-
carried out annually by discourse platform has been undertaken. These
Ernst and Young or documents will be disclosed.
otherwise. 4 oa
In response to the queries raised in your letter of 8
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Request No. I Disclosure Request Response
February 2019 relating to audit reports:
e Enquiries are being made to understand
who was appointed as auditor of Horizon
prior to 2011. Aresponse to this query
will follow.
e Asexplained above, a search for audit
reports held in our e-disclosure system
(which contains all of the custodian's
documents for Stage 3 disclosure) has
been run. Post Office does not have an
obligation to provide disclosure of all audit
reports on Horizon since 2000. Post
Office has conducted a reasonable and
propionate search to locate the audit
reports and has provided disclosure of
these documents.
9 Advice sent to We confirmed in our letter of 17 January 2019 that
Subpostmasters in Post Office was in the process of searching for
relation to the bug copies of the advice sent to postmasters, but
known at Callender since the bug occurred in 2005 it was not
Square envisaged that Post Office would still hold copies
of this advice.
Post Office has been unable to locate a copy of
this advice, but during this search has come
across a number of documents which may be of
interest. Disclosure of these documents will be
provided.
12 Problem Review Tracker I Fujitsu have provided us with an updated copy of
the Problem Review Tracker as at 24 December
2018. Disclosure of this document will be
provided.
5.4 We trust that the above responses finalise your requests for disclosure made in the first section
of your letter of 21 December 2018.
6. Requests on 21 December 2018 — Horizon Management Council
6.1 In relation to your request for disclosure of documents held by Mr Rees, Ms McGinn and Ms
George, you state in your letter of 21 December 2018 that "there are certain named individuals or
teams / groups within the Post Office organisation that the Claimants were not previously aware
of...". We understand this to be a reference to the Horizon Management Council and the
documents held by the three custodians which you identified. We do not agree with your position
that the Claimants were not previously aware of these custodians. POL-0218577 ("/Redacted]
Action Summary’) was disclosed on 1 August 2018 and discussed in correspondence between
the parties during October 2018. Further, the document was the subject of detailed debate at the
Common Issues Trial during November 2018.
6.2. The Claimants were aware of the three custodians detailed in POL-0218577 from as early as
August 2018. The Claimants’ disclosure request was however not made until 21 December
2018. Nevertheless, Post Office has sought to accommodate the disclosure sought in the time
which is available.
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6.3 In your letter of 8 February 2018 you state that Post Office was required to provide disclosure of
the documents sourced from the email accounts of Mr Rees, Ms McGinn and Ms George and the
Information Security's team's Sharepoint site pursuant to Schedule 1 of the Fourth CMC Order.
Schedule 1 provided for disclosure of documents from three categories of custodians. The
emails accounts of Mr Rees, Ms McGinn and the Information Security team's Sharepoint site
were not custodians within one of these categories and are therefore not within the scope of the
Fourth CMC Order. Further, the categories of documents expressly excluded emails. The
disclosure which we are now providing primarily consists of emails sent or received by these
custodians. Therefore, the disclosure being provided by Post Office does not fall within the
scope of the Fourth CMC Order and any prejudice caused by the delay in receiving these
documents has been caused by your client making these requests late.
64 A Disclosure List which contains the relevant, non-privileged documents from Julie George's
email account which were responsive to the search terms set out in our letter of 17 January 2019
is currently being produced and will be provided to you shortly. A number of documents will not
be disclosed since they are privileged (on the basis of legal advice and/or litigation privilege) and
some documents have been redacted on the basis of legal advice and/or litigation privilege.
These documents have been reviewed by the legal representative in charge of disclosure.
6.5 When reviewing this disclosure it has come to our attention that 121 of the documents that were
responsive to these search terms had already been disclosed. Disclosure of these documents
has not been provided a second time.
66 In respect of the documents from the email accounts of Mr Rees, Ms McGinn and the Sharepoint
site of the Information Security team, as explained in our letter of 17 January 2019 these
documents needed to be extracted before being reviewed for relevance and privilege. We have
now extracted these documents and they have been uploaded to our e-disclosure platform.
Before reviewing these documents it is proposed that the keyword search terms (set out in our
letter of 17 January 2019) that are applied to these documents are narrowed. The reason for this
is that the keyword search terms applied to the email account of Julie George generated a high
volume of false positive documents (documents which contained the keywords but were not
relevant to the issues in this claim). Of the 9,698 documents reviewed, only 13% of the
responsive documents were relevant. The proposed amendments to the search terms will follow
shortly in a separate letter.
7. Textbooks and articles referred to by Dr Worden
71 These documents are in the process of being uploaded to Magnum and it would be appreciated if
access to these could be provided to Mr Coyne.
8. Queries raised on 17 January 2019 - Privileged User logs and MSC Logs
8.1 We refer to your letter dated 17 January 2019. Taking each point in turn:
User IDs
8.2 We have taken further instructions from Fujitsu in respect of the additional USERIDs in your
schedule and set out descriptions of each user below. Please note that there are some
usernames that: 1) do not exist today and never existed in the past as far as Fujitsu are aware.
These are identified in the classification column of the list as "Unknown"; and 2) do not exist
today but did exist in the past.
Username Classification Description
BRDBOMD Unknown Does not exist, there is an OMDBUSER however - the BRDB HLD
B states "User is used by the OMDB (SYSMAN) to read PONR for
HNG-X Branch Migration”
COBENO1 PERSON - SSC. SSC Cath Obeng but also exists below as OPS$COBENO1
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DAVENO1 PERSON - SSC SSC Darren Avenell but also exists below as OPS$DAVENO1
EMDB_SU SYSTEM Automated application user, User used by EMDB to maintain
P EMDB tables for BRDB Estate Management.
SELECT on
ops$brdb.brdb_branch_info.ops$brdb.brdb_branch_node_info,
ops$brdb.rdds_branch_opening_periods
EXI Unknown, Does not exist on BRDB
LVAGENTU SYSTEM Automated application user - used by Near Real Time agents (for
SER1 example) British Gas smart metering system - able to update &
query one table (BRDB_RX_NRT_TRANSACTIONS) via a
PL/SQL interface
LVAGENTU SYSTEM Same as LVAGENTUSER?1 but for agent connecting to BRDB
SER4 instance 4 (i.e. there are 4 of these users LVAGENTUSER[1-4])
OMDBUSE SYSTEM Automated application user, outbound interface to OMDB - the
R BRDB HLD states "User is used by the OMDB (SYSMAN) to read
PONR for HNG-X Branch Migration”
OPS$ABES PERSON - SSC 3rd line support user (SSC group), see “SSC User Privileges”
TO1 section Anne Best — SSC current user
OPS$ACH PERSON - SSC 3rd line support user (SSC group), see “SSC User Privileges”
AM01 section Anne Chambers — SSC defunct user
OPSS$AGIB PERSON - POA 1st line support user (POA Unix), see “POA UNIX User Privileges”
S01 UNIX section Andy Gibson
OPS$AKEI PERSON - SSC 3rd line support user (SSC group), see “SSC User Privileges”
Lo1 below Andy Keil - SSC defunct user
OPS$AWO PERSON - SSC 3rd line support user (SSC group), see “SSC User Privileges”
ob01 section Adam Woodley — SSC current user
OPS$BPEA 3rd line support user (SSC group), see “SSC User Privileges”
co1 below Ben Peacey — SSC defunct user
OPS$BRD SYSTEM Application user, used by training counters to access tables held
BBTR1 by OPS$BRDBTR
OPS$BRD SYSTEM Application user owning a number of tables that hold training
BIR transaction data only - used to train new Counter users. No “live”
transaction data stored within this user.
OPS$BRSS Unknown This looks to be the BRSS (Branch Support database) batch user
BTH1 - not directly related to BRDB. SYSTEM user with respect to
BRSS.
OPS$CCA PERSON - SSC 3rd line support user (SSC group), see “SSC User Privileges”
RDO1 section Cheryl Card — SSC current user
OPS$COB 3rd line support user (SSC group), see “SSC User Privileges”
ENO1 section Cath Obeng — SSC defunct user
OPS$CTU PERSON - SSC 3rd line support user (SSC group), see “SSC User Privileges”
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RRO1 section Clive Turrell - SSC defunct user
OPS$DALL PERSON - SSC. 3rd line support user (SSC group), see “SSC User Privileges”
E01 section Dave Allen — SSC current user
OPS$DAVE PERSON - SSC 3rd line support user (SSC group), see “SSC User Privileges”
NO1 section Darren Avenell - SSC current user
OPS$DSE PERSON - SSC 3rd line support user (SSC group), see “SSC User Privileges”
DbDO1 section Dave Seddon— SSC current user
OPS$EASH PERSON-POA stline support user (POA Unix), see "POA UNIX User Privileges”
FO1 UNIX section Ed Ashford
OPS$GMA PERSON-SSC 3rd line support user (SSC group), see “SSC User Privileges”
xwo1 I section Gary Maxwell — SSC current user
OPS$GSIM PERSON - SSC 3rd line support user (SSC group), see “SSC User Privileges”
P01 section Garrett Simpson — SSC defunct user
OPS$JBAL PERSON - SSC 3rd line support user (SSC group), see “SSC User Privileges”
Lo1 section John Ballantyne — SSC defunct user
OPS$JCHA I PERSON - SSC 3rd line support user (SSC group), see “SSC User Privileges”
RO1 section John Charlton — SSC defunct user
OPS$JHAR PERSON - SSC 3rd line support user (SSC group), see “SSC User Privileges”
R01 section Joe Harrison — SSC current user
OPS$JSIM PERSON - SSC 3rd line support user (SSC group), see “SSC User Privileges”
P01 section John Simpkins — SSC current user
OPS$KMIL 3rd line support user (SSC group), see “SSC User Privileges”
01 section Kevin Miller - SSC defunct user
OPSSLKIA PERSON - SSC 3rd line support user (SSC group), see “SSC User Privileges”
NO1 section Lina Kiang - SSC defunct user
OPS$MCR PERSON - SSC 3rd line support user (SSC group), see “SSC User Privileges”
oso1 section Mike Croshaw — SSC current user
OPS$MOG SYSTEM Oracle goldengate replication user - no privileges on BRDB.
GBRDB
OPS$MWR PERSON - SSC 3rd line support user (SSC group), see “SSC User Privileges”
1GO1 section Mark Wright - SSC current user
OPSS$NMC. PERSON - SSC. 3rd line support user (SSC group), see “SSC User Privileges”
KEO1 section Kevin McKeown — SSC current user
OPSSORA Unknown Does not exist on BRDB
CLE
OPS$PCA PERSON - SSC. 3rd line support user (SSC group), see “SSC User Privileges”
RRO1 section Pat Carroll - SSC defunct user
OPS$PSIM PERSON - POA 1st line support user (POA Unix), see “POA UNIX User Privileges”
P01 UNIX section Paul Simpson
AC_154206149_1 Ww
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OPS$PSTE PERSON - POA 1st line support user (POA Unix), see “POA UNIX User Privileges”
wo1 UNIX section Paul Stewart
OPS$RGEL PERSON - SSC 3rd line support user (SSC group), see “SSC User Privileges”
Do1 section Rob Gelder — SSC current user
OPS$SEN PERSON - SSC 3rd line support user (SSC group), see “SSC User Privileges”
GLO1 section Sarah English - SSC defunct user
OPS$SNEL PERSON - SSC 3rd line support user (SSC group), see “SSC User Privileges”
Lo2 section Sunil Nellikkentavita - SSC defunct user
OPS$SPAR PERSON - SSC 3rd line support user (SSC group), see “SSC User Privileges”
KO1 section Steve Parker — SSC defunct user
OPS$SSAT PERSON - SSC 3rd line support user (SSC group), see “SSC User Privileges”
T01 section Sirous Sattar — SSC current user
OPS$SSU PERSON - SSC 3rd line support user (SSC group), see “SSC User Privileges”
RX01 section Sudip Sur - SSC defunct user
OPS$VKO PERSON - SSC 3rd line support user (SSC group), see “SSC User Privileges”
NAO1 section Venkata Subbarao Konakalla - SSC defunct user
OPS$VRA PERSON - SSC 3rd line support user (SSC group), see “SSC User Privileges”
MA01 section Vishnu Ramachandran — SSC defunct user
OPS$WBR PERSON - SSC 3rd line support user (SSC group), see “SSC User Privileges”
AGO1 section Wayne Bragg — SSC current user
OPS$WCA PERSON - POA 1st line support user (POA Unix), see “POA UNIX User Privileges”
Lvo1 UNIX section Wayne Calvert
ORAEXCP SYSTEM Provides ability for batch users (OPS$BRDBBLV[1-4]) to insert
LV exception messages into table
OPS$BRDB.BRDB_OPERATIONAL_EXCEPTIONS - insert
ability only.
OUTLN SYSTEM Oracle supplied account - EXPIRED & LOCKED on 19th July
2015
PK Unknown Does not exist on BRDB
QLPSTRAD Unknown Does not exist on BRDB - think this is "STRADMIN".
MIN
RDDS Unknown Does not exist on BRDB - A RDDS username does however exist
on the RDDS system (reference data system)
SQUIRLES Unknown Does not exist on BRDB - think this is "SQUIRRELSCAN".
CAN
Re ESE Used by PEN testers, LOCKED on 26th June 2016. User was
created as per requests by SecOps. This user can
e Create any oracle directory object
e Create a session (i.e. logon — but not if the user is locked
as is the case currently)
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* Create tables within its own schema
e Select any table within the database (i.e. read only
access), including application/transactional data
SSC_TOOLS As per Steve Parker - read-only access database user for support
access
STRADMIN SYSTEM Does not exist on BRDB - Automated Oracle streams (precursor
to Goldengate) account, dropped around 4 or more years ago.
STRMAPMIN: I: Unktiown Does not exist on BRDB ~ think this is "STRADMIN" in reality
SYSTEM SYSTEM Oracle supplied admin account - LOCKED on 11th June 2012
HRBALUSER: I/SYSTEM BAL application user - provides access to training schema tables -
see previous description provided for "IV. TRBALUSERs"
TWS User that holds state for batch scheduling software "Tivoli Work
Scheduler" - this user has no access to BRDB transactional data
XXXX Unknown
Does not exist on BRDB
8.3 In respect of the usernames that do not exist today and never existed in the past as far as Fujitsu
are aware, these are all invalid names, i.e. User IDs which someone tried to use in error and the
system did not let them log on because they were not valid. An example of this is as follows:
204928/1 1 IIBRDBOMDBIIprpbdb001 Ipts/0I100I1047IIIIIIIIIIIIIIAuthenticated by:
DATABASE IIbrdbIIIIII20091012140738]II1I8191I0000000000000000)III
8.4 The relevant part is highlighted, which resolves to ORA-01017 and belongs to column
RETURNCODE.
8.5 The confirmation of the explanation for each is shown in this table:
Username Classification Description
BRDBOMDB Unknown Examination of the audit files reveals that the username
entered was deemed as invalid.
ORA-01017: invalid username/password; logon denied
EX! Unknown, Examination of the audit files reveals that the username
entered was deemed as invalid.
ORA-01017: invalid username/password; logon denied
OPS$BRSSBTH1 Unknown Examination of the audit files reveals that the username
entered was deemed as invalid.
ORA-01017: invalid username/password; logon denied
OPS$ORACLE Unknown, Examination of the audit files reveals that the username
entered was deemed as invalid.
ORA-01017: invalid username/password; logon denied.
There is also an instance of
ORA-01013 user requested cancel of current operation
‘AC_154206149_1 13
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which suggests the user entered ctri-c to cancel the
logon operation before the user could be informed that
the logon was denied.
PK
Unknown
Examination of the audit files reveals that the username
entered was deemed as invalid.
ORA-01017: invalid username/password; logon denied
QLPSTRADMIN
Unknown
Examination of the audit files reveals that the username
entered was deemed as invalid.
ORA-01017: invalid username/password; logon denied
RDDS
Unknown,
SQUIRLESCAN
Unknown
Examination of the audit files reveals that the username
entered was deemed as invalid.
ORA-01017: invalid username/password; logon denied
Examination of the audit files reveals that the username
entered was deemed as invalid.
ORA-01017: invalid username/password; logon denied
STRMADMIN
Unknown,
Examination of the audit files reveals that the username
entered was deemed as invalid.
ORA-01017: invalid username/password; logon denied
XXXXK
Unknown
Examination of the audit files reveals that the username
entered was deemed as invalid.
ORA-01017: invalid username/password; logon denied
8.6 In respect of SSC user privileges, SSC users (those identified as "PERSON — SSC" under
Classification) will typically have the following privileges/roles:
8.6.1 the ability to create the following objects within their own schema/user:
(a) create cluster, create index, create procedure, create sequence, create table,
create trigger, create type.
8.6.2 granted the “SSC” role which contains the ‘MONITOR’ role and which in turn contains
“CONNECT”, allowing a user to log onto the database.
8.6.3 granted the “SELECT ANY TABLE” privilege which allows the user read access to any
table within the database.
8.6.4 granted the ability to execute a single function owned by OPS$BRDB,
FN_BRDB_EXTRACT_CLOB. This function reads large text strings out of the
database and makes it available to the user.
8.6.5 “PAF_COUNTER’ role which contains:
(a) SELECT on 2 tables PAF_OWNER.PAF_ADDRESS_POINT_[AIB]. Postcode
Address Finder data as provided by Royal Mail, used by the Counter to do
8.6.6 granted the “SELECT ANY DICTIONARY’ privilege which allows the user to read the
address lookups.
oracle data dictionary tables (i.e. not application related).
AC._154206149_1
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8.6.7 granted the ability to execute the following executable functions:
(a) OPS$SUPPORTTOOLUSER.PKG_BRDB_CLEAR_RO_LOCK - allows an SSC
user to remove a rollover lock from a branch
(b) OPS$SUPPORTTOOLUSER.PKG_BRDB_CLEAR_SU_LOCK - allows an SSC
user to remove a stock unit rollover lock from a specific branch
(c) OPS$SUPPORTTOOLUSER.PKG_BRDB_RO_FAD_FYR - allows an SSC user
to roll a branch over to a different financial year
(d) OPS$SUPPORTTOOLUSER.PKG_BRDB_UPD_RVY_TXN - allows an SSC
user to update recovery data
(e) OPS$SUPPORTTOOLUSER.PKG_BRDB_TXN_CORRECTION -— framework to
allow user to insert fully audited balancing records into a BRDB transaction table
(made against node ID 99).
87 In respect of POA Unix user privileges, POA Unix users (those identified as “PERSON —- POA
UNIX” under Classification) will typically have the following privileges/roles:
8.7.41 granted the “CONNECT” ROLE which allows the user to log onto the database.
8.7.2 granted the “EXP_FULL_DATABASE” ROLE which allows the user to export data from
the database using Oracle export tools. Note this is an Oracle supplied/defined role.
8.7.3 granted the “SELECT ANY TABLE” privilege.
8.7.4 granted “SELECT ANY DICTIONARY’ which allows the user to read the oracle data
dictionary tables (i.e. not application related).
8.7.5 granted the “SELECT ANY TABLE" privilege which allows the user read access to any
table within the database.
8.7.6 granted the ability to create the following objects within the user’s own schema:
(a) create cluster, create index, create procedure, create sequence, create table,
create trigger, create type.
8.7.7 granted the “UNXADM'" role which contains the following role:
(a) granted the “DBA" role. This is an Oracle supplied role for use by database
administrators (DBAs). Lots of privileges are granted to this role so users have
the ability to update/delete/insert into any of the Branch database tables.
8.7.8 Granted the ability to execute the following executable functions:
(a) OPSS$SUPPORTTOOLUSER.PKG_BRDB_TXN_CORRECTION -— framework to
allow the user to insert fully audited balancing records into a BRDB transaction
table (made against node ID 99).
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DML == Data Manipulation Language
88 DML is a generic database term (i.e. not specific to Oracle) references to which are plentiful on
the internet. It was included to give context to terms such as SELECT, UPDATE, INSERT.
SSC_tools
8.9 “SSC_TOOLS’ is a read-only access database user (DRS, TES, APS2, TPS, LFS, BRDB,
BRSS) used for support tools such as HORIce and “Smiley”. It was introduced in 2014 as part of
the introduction of Service Level Reporting using HORIce.
OCP records
8.10 These have been disclosed to you, as per our letter dated 24 January 2019.
9. Requests on 22 January 2019 - Witness Statement disclosure
9.41 In this letter you have made a number of further requests for documents based on assertions
that: (1) there are gaps in our client's disclosure; and/or (2) our client's witnesses "have been
provided with/had sight of documents in order to prepare their statements, which have not been
disclosed to the Claimants". As explained above, under CPR 31.14 disclosure of documents on
the basis of a witness having sight of them is not the correct test to be applied. In relation to the
gaps in our clients’ disclosure, save for a small number of exceptions, your requests are new and
wide ranging requests for further disclosure for which the Claimants have not attempted to draft
as a Model C request. Although you assert that there are gaps in our client's disclosure, you
have made no attempt to point to any provisions of the Second, Third or Fourth CMC Orders that
our client is said to have breached. We respond to your requests below but if you seriously wish
to maintain the position that Post Office has not complied with CMC Orders, please explain which
disclosure obligations have not been fulfilled by Post Office. We reserve our client's right to
respond further in the event that you seek to articulate your assertion in this regard.
Paul Smith requests
9.2 Your requests for disclosure of documents relating to TCs issued, challenged and successfully
challenged; the introduction of the TC case management system and records from that system;
and the decisions to issue TCs and resolve disputes about TCs are all outside of the scope of the
Horizon Issues Trial.
9.3 As already explained in our letter dated 8 August 2018, the full extent of Post Office's back-office
reconciliation procedures (i.e. the procedures by which TCs are issued and disputes in relation to
TCs resolved) are not within the scope of the Horizon Issues Trial.
9.4 It should be noted that paragraph 10 of the Third CMC order required our client to “/...] prepare a
document, from the information available [...], setting out the aggregate volume and value of
Transaction Corrections issued annually since 1999". That document was provided to you under
cover of our letters dated 18 May 2018 and 28 June 2018 and our client has therefore satisfied its
obligation under paragraph 10 of the Third CMC Order. Further, Category 25 of the Stage 2
Disclosure required Post Office to disclose "Post Office written policies, process documents, and
formal internal guidance documents (not emails) regarding the issuing of Transaction
Corrections." A review of the documents disclosed under this category should provide adequate
information for the purposes of the Horizon Issues Trial.
95 If the Claimants wish to continue to pursue this request for disclosure, please could you confirm
which Horizon Issue(s) these documents are relevant to and provide a revised request by way of
a Model C class of documents.
96 Finally, your request for documents on which Dr. Worden has made assumptions is incorrect. Dr.
Worden refers to facts presented to him in Mr Smith's statement, not documents. There are
therefore no documents to be disclosed under this request.
‘AC_154206149_1 16
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Responses to requests made in the schedule
9.7 Please find enclosed at Schedule 1 of this letter our responses to the disclosure requests which
were made in the schedule to your letter of 21 January 2019.
10. Requests on 4 February 2019 - Witness Statement disclosure
10.1 Werefer to our comments in section 4 above in relation to the requests made in your letter of 18
December 2018. These comments apply equally to the requests which you made on 4 February
2019. In response to your requests for disclosure:
Request I Request Response
No
Mr Anup and Mr Akash Patny
y Es
Please disclose all documents relating to the
acknowledged Horizon system outage (Mrs Van
Den Bogerd paragraph 61, and also 103 in
relation to Mrs Burke), and its effects on
branches.
We anticipate these documents will have been
considered by Mrs Van Den Bogerd and/or her
small team and therefore fall within our 18
December 2018 requests, but if for any reason
they were not, please in any event disclose
them.
The request for disclosure of “all documents"
is not a Model C request for a narrow class
or category of documents and this broad
request has been made 1 month before the
commencement of trial. You have made the
widest possible requests which we cannot
realistically comply with just before the trial —
and moreover we do not understand why
since we cannot see any issue which this
admitted outage goes to. We cannot see
any proper basis for this request.
Disclosure of the documents relating to Mr
Patny which Mrs Van Den Bogerd had
reference to when preparing her witness
statements will be disclosed in the list
"Claimants' Horizon Witnesses".
if further documents are sought then please
could you provide a disclosure request by
way of a Model C narrow class of
our 18 December 2018 request includes all
available transaction data for the Spencefield
documents.
2 Please confirm if the document referred to at POL-0444069 is the HSD call logs relating to
paragraph 62 (POL-0444069) is the document Mr Patny's branch for May 2016. The
that Mrs Van Den Bogerd intended to rely on correct document is the NBSC call logs,
and if not, please identify the correct document I which will be disclosed in the list "C/aimants’
reference. Horizon Witnesses".
a, Please identify and disclose the document(s) POL-0444059 is the event log for Ms Burke's
intended to be referred to at paragraph 63 (the branch during May 2016.
current exhibit reference (POL-0444059) does . 7
not relate to this branch) and, if different, H elakalyeesaaly even ae ree ce or
subsequent references to “The branch's Hi ae ithe aie He pad ii is Ha Hi
transaction and event data” (paragraph 65), and 7h oo oes ae Sun ee een
the references to cash declarations. einen
Details of the cash declarations which are
made reference to will be disclosed in the list
"Claimants' Horizon Witnesses".
4. Please in any event ensure your response to Disclosure of the transaction and event data
for the Spencefield branch was given on 29
‘AC_184206149_1
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Request I Request Response
No
branch relating to the events of 9 May 2016, November 2017.
Jnetucina fort eg aca of doubt, unfitered Formal disclosure of the transaction and
event has been given as POL-044405 and
POL-0444075. The filtered ARQ data will be
disclosed in the list "Claimants’ Horizon
Witnesses".
5. Please confirm if the document referred to at I POL-0444060 is the event data for Mr
paragraph 71 (POL-00444060) is the intended Patny's branch during February 2016. The
document reference, and in any event disclose I document which was intended to be referred
all available data for the period 22 to 24 to was the transaction data for the
February 2016, including in relation to cash Spencefield branch was disclosed on 29
declarations. November 2017.
Formal disclosure of the transaction data will
be disclosed in the list "Claimants' Horizon
I Witnesses".
The cash declarations for February 2016 will
also be disclosed in the list “Claimants'
Horizon Witnesses
6. Please disclose requests for and relating to the I The TC data was already disclosed to Mr
Credence report referred to within the disclosed I Patny on 12 May 2017. Formal disclosure of
NBSC call log (see entry on 21 June 2016) and I this document will be provided in the list
any other related documents which were “Claimants' Horizon Witnesses". Further
generated at this time relating to the issuing of a I enquires are being made as to the credence
transaction correction. report.
Your request for “any other related
documents" relating to the issuing of a
transaction correction is not a Model C
request for a narrow class or category of
documents and this broad request has been
made 1 month before the commencement of
trial. You have made the widest possible
requests which we cannot realistically
comply with just before the trial - and
moreover we cannot see any issue which
this goes to. We cannot see any proper
basis for this request.
Mr Jayesh Tank
7. Mrs Van Den Bogerd refers to NBSC logs (at Disclosure of these documents will be
paragraphs 77, 79 and 83) but provides no provided in the list “Claimants' Horizon
exhibit. Please ensure your response to our 18 Witnesses". The call logs cover the date
December 2018 request incudes a complete set I range of January 2001 to March 2017
of NBSC call logs for the Fleckney Post Office
for the period Mr Tank was Subpostmaster
(May 2006 to March 2017).
Mr Adress Latif
8. Mrs Van Den Bogerd refers to “the ARQ data” The reference to "ARQ data" is to the
at paragraph 90, without exhibit. Please identify I transaction data for the branch which
the intended document. referred to the exhibit mentioned in the
AC_154206149_1 18
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to the decision to issue the transaction
correction referred to at paragraph 100, and the
transaction correction itself.
Request I Request Response
No
previous sentence.
9. Also at paragraph 90, Mrs Van Den Bogerd Disclosure of the transaction and event data
exhibits transactional data for June to August which were referred to by Mrs Van Den
2015. We anticipate that data outside of this Bogerd has been disclosed as: POL-
range was identified by Post Office and 0444063, POL-0444062, POL-0444061,
considered by Mrs Van Den Bogerd and/or her I POL-044407. The remaining data and
small team, and our 18 December 2018 request I filtered data will be disclosed in the list
seeks disclosure of that data. As Post Office “Claimants' Horizon Witnesses".
hae alec) bar peli Ab i cident. These documents cover the date ranges of
” June to August 2015 and January to March
2018.
10. Mrs Van Den Bogerd refers to a review of the The NBSC call logs for Mr Latif will be
NBSC logs (at paragraph 93) but provides no disclosed in the list "Claimants' Horizon
exhibit. Please ensure your response to our 18 Witnesses". The document will cover the
December 2018 request incudes a complete set I date ranges of June 2016 to May 2017.
of NBSC call logs for the Caddington Post
Office for the period Mr Latif was
Subpostmaster (October 2001 onwards).
tt. Please confirm if the document referred to at POL-0444076 is the event data for Mr Latif's
paragraph 98 (POL-0444076) is the intended branch during March 2018. The document
document, and if not provide the document to which was intended to be referred to was the
which Mrs Van Den Bogerd intended to refer. transaction data for January 2018, which will
be disclosed in the list “Claimants' Horizon
Witnesses".
12. Please identify and disclose the document to The event log for January 2018 will be
which Mrs Van Den Bogerd refers at paragraph I disclosed in the list “C/aimants' Horizon
99. Witnesses".
13, Please disclose documents recording or relating I The TC data for Latif's branch will be
disclosed in the list "Claimants' Horizon
Witnesses".
Your request for “documents recording or
relating to the decision to issue the
transaction" is not a Model C request for a
narrow class or category of documents and
this broad request has been made 1 month
before the commencement of trial. This is a
very wide request which we cannot
realistically comply with just before the trial —
and moreover we cannot see any issue
which this goes to. We cannot see any
proper basis for this request
Mrs Angela Burke
14. We have requested documents relating to the See our response to Request No 1 above.
admitted national system outage, at point 1
above, which applies equally in Mrs Burke’s
case.
16. Please ensure your response to our 18 The transaction, event and filtered data for
AC_154206149_1
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Request I Request Response
December 2018 request includes all available the Newport branch will be disclosed in the
transaction data for the Newport branch relating I list "Claimants' Horizon Witnesses".
to the events of 9 May 2016, including for the
avoidance of doubt, unfiltered ARQ data for that
date.
16. Please disclose documents recording or relating I The TC data for Burke's branch will be
to the decision to issue the transaction disclosed in the list "Claimants' Horizon
correction referred to at paragraph 110, and the I Witnesses".
transaction correction itself Your request for "documents recording or
relating to the decision to issue the
transaction" is not a Model C request for a
very wide request which we cannot
realistically comply with just before the trial
and moreover we cannot see any issue
which this goes to. We cannot see any
proper basis for this request.
narrow class or category of documents and
this broad request has been made 1 month
before the commencement of trial. This is a
10.2 We trust that the above responses provides clarity of the documents referred to in Mrs Van Den
Bogerd's witness statement and a full response to your letter of 4 February 2019.
11. Queries raised on 6 February 2019 — Oracle Audit Table
11.1 Your letter states that "/t{his information should have been provided along with your client's
disclosure and the delay in receiving it is unacceptable." Post Office is required to provide
disclosure of documents. There is no further obligation on Post Office to explain the contents of
documents or provide assistance with the interpretation of them. Post Office has done so ona
number of occasions not because it is required to do so, but so as to assist the Claimants. This
should not be mistaken with a requirement for Post Office to provide further information. Further
and as we have explained on numerous occasions, Post Office is not in control of a number of
documents which you request disclosure of and is reliant on the assistance of Fujitsu to locate
and disclose documents. The information which you have requested was not readily available to
Post Office since it is data held by Fujitsu.
11.2 Inresponse to your queries, Fujitsu have confirmed the numerical codes mean:
OQ UNKNOWN 70 ALTER RESOURCE COST 162 DROP JAVA
1 CREATE TABLE 71 CREATE MATERIALIZED VIEW 163 CREATE OPERATOR
2 INSERT LOG 164 CREATE INDEXTYPE
3 SELECT 72 ALTER MATERIALIZED VIEW LOG I 165 DROP INDEXTYPE
4 CREATE CLUSTER 73 DROP MATERIALIZED VIEW LOG I 166 ALTER INDEXTYPE
5 ALTERCLUSTER 74 CREATE MATERIALIZED VIEW 167 DROP OPERATOR
6 UPDATE 75 ALTER MATERIALIZED VIEW 168 ASSOCIATE STATISTICS
7 DELETE 76 DROP MATERIALIZED VIEW 169 DISASSOCIATE
8 DROP CLUSTER 77 CREATE TYPE STATISTICS
9 CREATE INDEX 78 DROP TYPE 170 CALL METHOD
10 DROP INDEX 79 ALTER ROLE 171. CREATE SUMMARY
11. ALTER INDEX 80 ALTER TYPE 172 ALTER SUMMARY
12 DROP TABLE 81 CREATE TYPE BODY 173. DROP SUMMARY
13. CREATE SEQUENCE 82 ALTER TYPE BODY 174 CREATE DIMENSION
14 ALTER SEQUENCE 83 DROP TYPE BODY 175 ALTER DIMENSION
15 ALTER TABLE 84 DROP LIBRARY 176 DROP DIMENSION
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16 DROP SEQUENCE 85 TRUNCATE TABLE 177 CREATE CONTEXT
17. GRANT OBJECT 86 TRUNCATE CLUSTER 178 DROP CONTEXT
18 REVOKE OBJECT 88 ALTER VIEW 179 ALTER OUTLINE
19 CREATE SYNONYM 91 CREATE FUNCTION 180 CREATE OUTLINE
20 DROP SYNONYM 92 ALTER FUNCTION 181 DROP OUTLINE
21. CREATE VIEW 93 DROP FUNCTION 182 UPDATE INDEXES
22 DROP VIEW 94 CREATE PACKAGE 183 ALTER OPERATOR
23 VALIDATE INDEX 95 ALTER PACKAGE 192 ALTER SYNONYM
24 CREATE PROCEDURE 96 DROP PACKAGE 197 PURGE
25 ALTER PROCEDURE 97 CREATE PACKAGE BODY USER_RECYCLEBIN
26 LOCK 98 ALTER PACKAGE BODY 198 PURGE DBA_RECYCLEBIN
27 NO-OP 99 DROP PACKAGE BODY 199 PURGE TABLESPACE
28 RENAME 100 LOGON 200 PURGE TABLE
29 COMMENT 101 LOGOFF 201 PURGE INDEX
30 AUDIT OBJECT 102 LOGOFF BY CLEANUP 202 UNDROP OBJECT
31 NOAUDIT OBJECT 103 SESSION REC 204 FLASHBACK DATABASE
32 CREATE DATABASE LINK I 104 SYSTEM AUDIT 205 FLASHBACK TABLE
33 DROP DATABASE LINK 105 SYSTEM NOAUDIT 206 CREATE RESTORE POINT
34 CREATE DATABASE 106 AUDIT DEFAULT 207 DROP RESTORE POINT
35 ALTER DATABASE 107 NOAUDIT DEFAULT 208 PROXY AUTHENTICATION
36 CREATE ROLLBACK SEG I 108 SYSTEM GRANT ONLY
37 ALTER ROLLBACK SEG 109 SYSTEM REVOKE 209 DECLARE REWRITE
38 DROP ROLLBACK SEG 110 CREATE PUBLIC SYNONYM EQUIVALENCE
39 CREATE TABLESPACE 111. DROP PUBLIC SYNONYM 210 ALTER REWRITE
40 ALTER TABLESPACE 112 CREATE PUBLIC DATABASE LINK EQUIVALENCE
41 DROP TABLESPACE 113. DROP PUBLIC DATABASE LINK 211 DROP REWRITE
42 ALTER SESSION 114 GRANT ROLE EQUIVALENCE
43 ALTER USER 115 REVOKE ROLE 212 CREATE EDITION
44 COMMIT 116 EXECUTE PROCEDURE 213 ALTER EDITION
45 ROLLBACK 117 USER COMMENT 214 DROP EDITION
46 SAVEPOINT 118 ENABLE TRIGGER 215 DROP ASSEMBLY
47 PL/SQL EXECUTE 119 DISABLE TRIGGER 216 CREATE ASSEMBLY
48 SET TRANSACTION 120 ENABLE ALL TRIGGERS 217 ALTER ASSEMBLY
49 ALTER SYSTEM 121 DISABLE ALL TRIGGERS 218 CREATE FLASHBACK
50 EXPLAIN 122 NETWORK ERROR ARCHIVE
51 CREATE USER 123 EXECUTE TYPE 219 ALTER FLASHBACK
52 CREATE ROLE 128 FLASHBACK ARCHIVE
53 DROP USER 129 CREATE SESSION 220 DROP FLASHBACK
54 DROP ROLE 130 ALTER MINING MODEL ARCHIVE
55 SET ROLE 131 SELECT MINING MODEL 225 ALTER DATABASE LINK
56 CREATE SCHEMA 133. CREATE MINING MODEL 305 ALTER PUBLIC DATABASE
57 CREATE CONTROL FILE 134 ALTER PUBLIC SYNONYM LINK
59 CREATE TRIGGER 135 DIRECTORY EXECUTE
60 ALTERTRIGGER 136 SQL*LOADER DIRECT PATH
61 DROP TRIGGER LOAD
62 ANALYZE TABLE 137 DATAPUMP DIRECT PATH
63 ANALYZE INDEX UNLOAD
64 ANALYZE CLUSTER 157 CREATE DIRECTORY
65 CREATE PROFILE 158 DROP DIRECTORY
66 DROP PROFILE 159 CREATE LIBRARY
67 ALTER PROFILE 160 CREATE JAVA
68 DROP PROCEDURE 161 ALTER JAVA
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Yours faithfully
WAS ‘bank Diderson (v LU?
Womble Bond Dickinson (UK) LLP
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SCHEDULE 1
Responses to disclosure requests made in the schedule attached to Freeths' letter of 22
January 2019
Request I Disclosure Request Response to Request
No
Godeseth 1
1. Paragraph 17.2(c)
i. Documents regarding the i. Mr Godeseth's statement does not contain any reference
introduction of PING and the to the introduction of PING.
rationale behind this, including ; or
documents setting out the Further, the documents which you are seeking disclosure
- efi of relate to background facts that are not relied upon by
options to an SOM on receiving -
. “ witnesses or central to the Horizon Issues. Therefore, the
a PING (including the screen reed on z
options that the SPM will see); documents would fall within the definition of a Narrative
* Document. The parties have agreed to adopt Model C
ii. Documents recording disclosure and in the exceptions where Model D
instructions to SPMs regarding disclosure has been adopted instead, Narrative
Transaction Documents have been excluded. The disclosure you are
Acknowledgements, including now seeking is akin to Model E disclosure. In any event,
the dispute process and how as part of disclosure of the Dimensions documents, Post
Post Office resolves TA dispute Office has already provided disclosure of POL-0122708
process (and its family documents). TST/SOT/HTP/1510 is
understood to relate to the introduction and requirements
of PING
ii, I Mr Godeseth explains the concept of Transaction
Acknowledgments (TA) in paragraph 17.2(c) of his first
statement. The TA dispute process is outside the scope
of the Horizon Issues Trial.
In any event, Post Office has already provided disclosure
of a number of documents showing the instructions given
to SPMs regarding the TA process (the below list is not
intended to be exhaustive but to assist with locating
further relevant documents): POL-0171120, POL-
0171121, POL-0176868, POL-0176870, POL-0183342,
POL-0177607, POL-0177608
a Paragraph 31
iii. I The underlying documents iii. I Enquires are made and a response to this request will
which set out the figures that follow shortly.
Mr Godeseth makes reference iv. Please find enclosed the process flowchart which explains
to, including any documents
how ARQ requests are made and the ARQ Request
regarding approaching or Form. A disclosure list containing these documents will
exceeding the contractually follow short! 9
agreed limit and the claims ¥
for/payments of/discussions
surrounding penalty payments.
iv. Examples of ARQ requests
made by Post Office.
3. Paragraphs 34 - 46
v. Disclosure of procedures v. Enquires are made and a response to this request will
relating to Legacy Horizon follow shortly.
Riposte, the ability to inject
‘AC_154206149_1
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Request I Disclosure Request Response to Request
No
messages at the
correspondence server and
how the inserted messages
appeared.
4. Paragraph 58.2
vi. Disclosure of vi. I We understand from Fujitsu that this is a table ina
"BRDB_TXN_CCRR_TOOL_J database and it may not be possible to extract the data.
OURNAL" Enquires are ongoing to understand whether and in what
format the table could be extracted.
5. Paragraph 58.5
vii. Disclose an audit log which vii. This has been requested from Fujitsu and we expect to be
records the number of uses of in a position to provide it within 7 days.
the branch correction tool.
6. Paragraph 59.4
viii. I Disclose any documents which I viii. I As explained in row 5 of the table in our first letter dated
relate to management, analysis 17 January 2019, disclosure of relevant information held
or audit of the information in by Fujitsu was given on 21 December 2018 under Begin
this table. Bates numbers of POL-0444105 -> POL-0447287.
7. Paragraph 59.6
ix. Disclose any documents which ix. As explained in row 6 of the table in our first letter dated
relate to management, analysis 17 January 2019, disclosure of the MSC logs was given
or audit of the MSC information. on 21 December 2018 under Begin Bates numbers of
POL-0444102, POL-0444103 and POL-0444104. Your
request for further documents relating to the
management, analysis or audit of the information is not a
valid request under CPR 31.14(1)(b), nor is it a Model C
request for a narrow class or category of documents.
This is a very wide request which we cannot realistically
comply with just before the trial. We cannot see any
proper basis for this request
Membery 1
8. Paragraph 11
2 Disclosure of any internal Post x. Additional audit reports were voluntarily disclosed to you
Office or Fujitsu documents on 30 January 2019 and under paragraph 5.3 of this
commenting on the audit letter.
outcomes Or required acunns, This request does not specify a date range, custodians or
keywords. It is therefore not a Model C request for
disclosure and is unworkable in the time available. This is
a very wide request which we cannot realistically comply
with just before the trial - and moreover we cannot see
any issue which this goes to. We cannot see any proper
basis for this request
Phillips 1
9. Paragraph 11-12
xi.__ Disclose documents relating to xi. _ Post Office's process in relation to the Branch Dispute
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Request I Disclosure Request Response to Request
No
Post Office's procedures in its Form is detailed in Ms Phillips' statement and a copy of
use of the Branch Dispute the form is exhibited to Mrs Phillip's statement. Enquires
Form, including internal actions are being made to understand whether a document
taken on receipt. relating to Post Office's procedures in relation to use of
the Branch Dispute Form exists.
Van den Bogerd 2
10. Paragraph 35
xii. Confirmation of whether Post xii. Post Office has not conducted such a search. The
Office has conducted searches meaning of the phrase "across its documents" is not clear
across its documents using the and we do not believe there to be a way for Post Office to
exact phrase "phantom run a keyword search across the entirety of its IT
transaction"? infrastructure.
However, running a search for the word “phantom
transaction" across the documents that Post Office is
currently hosting in our e-disclosure platform returns 40
documents, 31 of which have already been disclosed.
Disclosure of the remaining 9 documents will be provided
shortly.
11. Paragraph 176
xiii. Disclose documents that relate I xiii. I Post Office does not understand the focus of this request.
to the change in accounting If itis related to the fact of the change, the position is as
process from the Cash Account set out in the first witness statement of David Johnson.
mo Grencr radia. Further, the documents which you are seeking disclosure
of relate to background facts that are not relied upon by
witnesses or central to the Horizon Issues. Therefore, the
documents would fall within the definition of a Narrative
Document. The parties have agreed to adopt Model C
disclosure and in the exceptions where Model D
disclosure has been adopted instead Narrative
Documents have been excluded. The disclosure you are
now seeking is akin to Model E disclosure.
12. Paragraph 188.2
xiv. _ Disclose documents which xiv. We refer to our letter of 28 June 2018, in which we
record the process of explained the disclosure of POL-0031913 (NBSC Incident
monitoring calls to the helpline SLA Summary). We asked you to explain the basis on
and which record the outcome which further disclosure of these documents should be
of that monitoring. provided. No response has been received to this query.
Post Office has already provide disclosure of 63
documents with the file name "SLA Summary" which we
understand to fall within your revised request for
disclosure. Post Office has also already provided
disclosure of the Horizon Helpdesk standing data, An
example of this is POL-0052754.
13. Paragraph 188.4
xv. Disclose the branch user forum I xv. A keyword search of the documents already disclosed
records.
shows that 118 documents have been disclosed which
contain the phrase “branch user forum". In particular,
POL-0220828, POL-0219748, POL-0220834, POL-
0219749, POL-0219763 and POL-0217391 are records
‘AC_154206149_1
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Request I Disclosure Request Response to Request
No
from the branch user forum and POL-0220858, POL-
0219764, POL-0220899, POL-0220909 are minutes from
the branch user forum.
A number of similar documents that have not yet been
disclosed have been located. These are being reviewed
for relevance and privilege and will be disclosed shortly.
Godeseth 2
14. Various
xvi. Disclose any letter or other xvi. Post Office has carried out searches and has been unable
communication sent to any to locate these documents. Please also see the
SPM relating to the Local disclosure provided under section 5.3 above.
rena alta pera xvii. Post Office provided specific Peak references in relation
to this issue on 17 January 2019 in response to a request
TOG2 pages 7 to 12, or by Mr C {i R for Furth
otherwise: y Mr Coyne in response toa ‘equest for Further .
7 Information. The request for “all additional documents" is
xvii. Disclose all additional too broad and is not a Model C request.
documents relating to this bug,
that have not previously been
disclosed.
18, Paragraphs 12-16
xviii. Disclose all additional xviii. Post Office provided specific Peak references in relation
documents relating to Callendar to this issue on 17 January 2019 in response to a request
Square that have not previously by Mr Coyne in response to a Request for Further
been disclosed. Information. The request for "all additional documents" is
too broad and is not a Model C request. Please also see
the disclosure provided under section 5.3 above
16. Paragraph 45
xix. Disclose all additional xix. Post Office provided specific Peak references in relation
documents relating to receipts to this issue on 17 January 2019 in response to a request
and payments mismatch that by Mr Coyne in response to a Request for Further
have not previously been Information. The request for "all additional documents" is
disclosed. too broad and is not a Model C request.
17. Paragraphs 55-61
xx. Disclose documents relating to xx. Post Office has already agreed to carry out a search for
"4 items still to be confirmed", documents relating to this issue (see our letter dated 11
“no corrections obvious in January) and disclosure of these document has been
database Post Office to advice provided under cover of this letter (see section 3 above).
is any corrections etc. raised” If following a review of these documents further disclosure
referred to within internal page is sought please could you confirm the class of
3 of the Fujitsu presentation at documents that you are seeking to be disclosed.
TOG2 pages 13 to 27,
including (1) any
communications with affected
SPMs and (2) any TCs issued.
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Request I Disclosure Request Response to Request
No
Mather 1
18. Paragraph 7 and 15
xxi. Disclose documents which xxi. An explanation on this matter can be found at paragraph
record whether the 13 of Ms Mather's statement.
recommendation referred to in
the Helen Rose Report was
implemented and if so, when.
19. Paragraph 19
xxii. Disclose any and all guidance xxii. Please find enclosed the process flowchart which explains
notes setting out the how ARQ requests are made and the ARQ Request
circumstances under which Form. A disclosure list containing these documents will
ARQ requests can be made follow shortly.
and authorised.
Smith 1
20. xxiii. Various xxiii. Please see our response above.
Dunks 1
21. Paragraph 6.3
xxiv. Disclose documents relating to I xxiv. Please see POL-0440079 for details of the maintenance
(i) management, control or and monitoring of Audit Record Queries. There is also an
audit of the ARQs; and (ii) the Audit Extraction Client User Manual (POL-0215531). This
process of ARQ extraction. has already been disclosed to you. Enquires are being
made to understand whether there are any other
documents which would fall within your disclosure
request.
Parker 1
22. Appendix 1 and 2
xxv. Disclose documents relied xxv. Confirmation is being sought from Fujitsu on this matter.
upon or referred to by the team
from SSC who produced the
tables and explanations
contained within them at
Appendix 1 and 2.
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