POL00266141 - Email from Mark Underwood1 To: andrew.parsons, Rodric Williams, Angela Van-Den-Bogerd and others re Expert joint memo [WBDUK-AC.FID27032497]

Evidence on official site

POL00266141
POL00266141

From: Mark Underwood, _. GRO ee!
Sent: Mon 25/02/2019 8:21:56 AM (UTC)
To: Rodric f
igela Van-Den-Boger
Ce: Jonathan Gribbenf
Subject: RE: Expert joint memo [WBDUK-AC.FID27032497]
Thanks —

Does Robert have the short explanation against each bug explaining why he disagrees with Coyne? Clearly this needs
to be included somehow. If it isn’t included in the joint statement — how do we get it in?

Mark
Mark Underwood
Portfolio Director: Legal, Risk &
Governance
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for Customer 20 Finsbury Street
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Mobile number!

From: Andrew Parson:
Sent: 25 February 201
To: Rodric Williams ¢_
Angela Van-Den-Bogerd GRO

Ce: Jonathan Gribben +_

Subject: Expert joint memo [WBDUK-AC.FID27032497]

Rodric, Mark, Angela

The expert joint memo has been delayed until 2pm today. The Court has been updated (by the experts directly) and
Fraser has agreed an extension of time.

The joint memo today is likely to be incomplete. It will cover the question of Horizon's reliability (ie. the 22 Coyne
bugs) but not remote access. A separate second joint memo will be produced for this later in the week. This approach
has been devised and agreed between the experts.

Coyne is being very difficult. He is opposing lots of Robert's ideas. For example, it is accepted by both that the
experts do not agree that all Coyne's 22 bugs are material problems. Robert wants to put a short explanation against
each bug explaining why he disagrees with Coyne. Coyne opposed this, wanting to just say that the bugs were
disputed. This would of course be useless for the Judge who would then only know that there was a dispute, but not
the substance of the dispute.

The cynic in Robert believes that Coyne is doing this intentionally, so to run out the clock thereby forcing the experts to
put in a lightweight memo that avoids any criticism of his supplemental report.
A
POL00266141
POL00266141

Andrew Parsons
Partner
Womble Bond Dickinson (UK) LLP

womblebonddickinson.com

A)

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