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From: Alisdair Cameronf_
Sent: Wed 20/03/2019 9:
To: Rodric Williams!”
Subject: RE: Update on Horizon Issues Trial - Post Office Group Litigation - SUBJECT TO LEGAL
PRIVILEGE - DO NOT FORWARD
Thank you Rod. In the following para I think that you have exactly summed up what we are “losing” on.
The cross-examination was aimed at, and was largely successful at demonstrating:
* a variety of incidents with Horizon, both in its software and the transaction records it generates, which:
© impact branch accounts;
© paint a picture of a system susceptible to failures, even if they are isolated and ultimately resolved; and
© are consistent with the errors experienced by the Claimants.
* Post Office’s reliance on Horizon is overstated and blinkered, leading to an improper presumption of
postmaster fault and liability for branch losses.
* Post Office has access to far better information from Horizon about branch accounting issues, which it is
better placed to use but does not share with, or actively withholds from, postmasters.
* Post Office has overstated the improvements made to Horizon over the years, which it has been slow to roll
out and implemented purely to save costs.
And which I would expect to continue to lose on.
My questions are
© We have always felt that even if the above was true it didn’t mean that the system generated the
losses complained of. Can we really demonstrate that?
« I wouldn’t disagree on some aspects of this — indeed a lot of our strategy is to rectify some of the
cultural underpinnings that still exist. So are we fighting all these points or accepting some but making
the point above?
Al
Alisdair Cameron
Chief Finance & Operating Officer
20 Finsbury Street
London
EC2Y 9AQ
From: Rodric Williams ¢
Sent: 20 March 2019 08:40
To: Alisdair Cameron
MacLeod <~~
Jane
; Mark R Davieg >; Mohinder Kang
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‘>; Owen Woodley Rob Houghton
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Update on Horizon Issues Trial - Post Office Group Litigation - SUBJECT TO LEGAL PRIVILEGE - DO NOT
FORWARD
Post Office Group Litigation - SUBJECT TO LEGAL PRIVILEGE - DO NOT FORWARD
All,
On Monday and Tuesday the Claimants’ counsel team cross-examined Angela van den Bogerd, Dawn Phillips, Tracy
Mather and Paul Smith from Post Office, with Angela’s cross-examination by the Claimants’ QC Patrick Green
occupying just over a day and a half of the two days.
The cross-examination was aimed at, and was largely successful at demonstrating:
* a variety of incidents with Horizon, both in its software and the transaction records it generates, which:
© impact branch accounts;
© paint a picture of a system susceptible to failures, even if they are isolated and ultimately resolved; and
© are consistent with the errors experienced by the Claimants.
* Post Office’s reliance on Horizon is overstated and blinkered, leading to an improper presumption of
postmaster fault and liability for branch losses.
* Post Office has access to far better information from Horizon about branch accounting issues, which it is
better placed to use but does not share with, or actively withholds from, postmasters.
* Post Office has overstated the improvements made to Horizon over the years, which it has been slow to roll
out and implemented purely to save costs.
Through the cross-examination, the Judge has challenged on a number of occasions the content of the Post Office
witnesses’ statements (e.g. where the witness has provided information collated with the assistance of other Post
Office personnel, or has corrected or clarified the evidence). He has also taken issue with Post Office’s document
disclosure, in particular where redactions have been made. When considered in the context of the Common Issues
Judgment, these challenges suggest he could be equally critical of Post Office’s evidence when giving judgment on the
Horizon Issues.
The Claimants will today cross-examine the final Post Office employee, Dave Johnson, before starting their cross-
examination of the four witnesses Post Office has called from Fujitsu. The Claimants are required to complete their
cross—examination by the end of Thursday.
Kind regards, Rod
Rodric Williams
Head of Legal - Dispute Resolution & Brand
20 Finsbury Street
London EC2Y 94Q
2017 Winner of the Global
Postal Award for Customer
Experience
E: rodric.williams@!
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