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4 August 2018 Womble Bond Dickinson (UK) LLP
Oceana House
39-49 Commercial Road
Southampton
S015 1GA
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100 Wellington Street Fe '
Leeds Re G RO ;
West Yorkshire
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Third Letter APCIAPGI364068.1369
Your ref:
By email only
Email: james.hartley. } imogen.randall__
Dear Sirs
The Post Office Group Litigation
Stage 3 Disclosure
Pursuant to paragraph 3 of the Fourth CMC Order (as amended by paragraph 3 of the Fifth CMC Order),
please find enclosed Post Office's Disclosure List for Stage 3 Disclosure. The documents are in the
process of being exported by Advanced Discovery to Elevate.
The parties have adopted the draft Practice Direction "Disclosure Pilot for the Business and Property
Courts" and for this stage of disclosure Post Office has been ordered to provide is request-led search
based disclosure under Model C. The classes of documents to be disclosed are set out in Schedule 1 to
the Fourth CMC Order. An explanation of the steps taken to locate the documents which fall within each
of the classes is set out below.
41. Classes 1 to 3, 5to 10 and 15
14 Each of these classes required Post Office to provide disclosure of documents which were
submitted to either a Category 1, 2 or 3 Custodian. Category 1 comprised of Post Office's Board
of Directors and Group Executive. A list of the 68 Custodians who were incorporated within
Categories 2 and 3 is set out at Schedule 1 of this letter.
1.2 In relation to documents submitted to Category 1 Custodians, Post Office's Company Secretarial
team are responsible for managing the documents submitted to Board of Directors and Group
Executive. An extract of the documents held within the Company Secretarial team drive was
taken (amounting to 10,926 documents) and the following keywords were run:
Search Documents with hits (including family)
Bug AND Horizon 20
Error AND Horizon 233
Defect AND Horizon 22 _
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Limited does not practise law. Please see www.wombiebonddickinson.conviegal notices for further details.
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Search Documents with hits (including family)
Discrepancy AND Horizon I 36
Shortfall AND Horizon 470 i
Loss AND Horizon I 1167
Transaction Correction I 62
I TC 268
1.3 These responsive documents (plus family documents) were subject to a manual review for
relevancy and privilege, and disclosure of these documents was provided on 29 June 2018.
1.4 In relation to documents submitted to Category 2 and 3 Custodians, searching the email
accounts of these custodians inherently confirms that the documents were submitted to them and
is likely to return the greatest volume of responsive documents (as explained in our letters of 22
June and 12 July 2018). There were 6.7m documents within these custodians’ email accounts
(or 5.4 million documents post de-duplication). These 5.4 million de-duplicated documents were
uploaded to our e-disclosure platform.
15 To identify the relevant documents which were submitted to these custodians, the search criteria
set out in the table below were applied resulting in 34,785 responsive documents being manually
reviewed for relevancy and privilege.
Class Search Term
41. Reports and briefings (excluding emails) Documents sourced from a Category 1 or 2
produced by Fujitsu and submitted to Category 1 I Custodian which were authored by “Fujitsu”, plus
or 2 Custodians regarding the nature and extent I family documents (known as Search Criteria 1). I
of bugs, errors or defects (not limited to software) .
in Horizon that had the potential to cause branch Note ‘h Post Office volntarly expanded this
accounts to be inaccurate. Search to include emails.
Enquires have also been made with Fujitsu who
have informed us that the documents they submit
to Post Office are known as Major Incident Reports
or Service Review Books. The Major Incident
Reports were stored in Dimensions and therefore
disclosed as part of Stage 2 Disclosure and
disclosure of the Service Review Books has been
provided where they have been responsive to
keywords.
2. Reports and briefings (excluding emails) For Category 1 and 2 Custodians, the documents I
produced by Post Office and submitted to of those custodians were filtered so to create a I
Category 1, 2 or 3 Custodians regarding the pool of documents which had been sent to a I
nature and extent of bugs, errors or defects (not I Category 1 or 2 Custodian, plus family documents.
limited to software) in Horizon that had the
potential to cause branch accounts to be The following search terms were then run on this
pool of documents (known as Search Criteria 2):
inaccurate.
e Document Type is not email
AND
¢ "Horizon"
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Class Search Term
AND I
¢ “bug*” OR I
e “peak*” OR
«© “error” OR
° “defect*” OR
e — “work" w/2 “*round” OR
¢ “shortfall” OR
e “loss*” OR
e “discrepanc* OR
° “problem*” OR
« “mismatch* OR
e “inaccura*” OR
e “transaction data" OR
° "transaction correction"
Note — these are the search terms agreed by the
parties for Category 3 Custodians plus “transaction
correction".
For category 3 custodians, the search terms as
agreed between the parties were applied to the
documents sourced from the Category 3
Custodians’ email accounts (known as Search
Criteria 3).
Note — Post Office voluntarily expanded this
search to include emails and documents sent or
authored by Category 3 Custodians (in addition to
documents submitted to Category 3 Custodians).
3. Reports and briefings (excluding emails) Documents (plus family documents) sourced from
produced by ATOS and any other third party IT a Category 1 or 2 Custodian which were sent or
suppliers (excluding individual contractors) who authored by:
was engaged by Post Office to work primarily on
the Horizon system, Bank of Ireland and Camelot © “Atos”
and submitted to Category 1 or 2 Custodians ° “Bol” I
regarding the nature and extent of bugs, errors 7 .
or defects (not limited to software) in the Horizon * "Camelot
system that had the potential to cause branch AND
accounts to be inaccurate between: (i) 1 January a
1999 to 31 December 2000; (ii) 1 January 2005 * Documents within the date ranges set out
to 30 Apri! 2006; and (iii) 1 January 2010 to 31 in the Class.
July 2013. (known as Search Criteria 4)
Note — Post Office voluntarily expanded this
search to include emails.
5. Reports and briefings (excluding emails) Same as Search Criteria 1.
produced by Fujitsu and submitted to Category 1
or 2 Custodians regarding necessary or
recommended measures for preventing/fixing
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Class
Search Term
bugs in Horizon that might cause branch
accounts to be inaccurate.
6. Reports and briefings (excluding emails)
produced by Fujitsu and submitted to Category 1
or 2 Custodians regarding necessary or
recommended measures for developing Horizon
so to mitigate the risk that Horizon might cause
branch accounts to be inaccurate.
Same as Search Criteria 1.
7. Reports and briefings (excluding emails)
produced by Post Office and submitted to
Category 1, 2 or 3 Custodians regarding
necessary or recommended measures for
preventing/fixing bugs in Horizon that might
cause branch accounts to be inaccurate.
I
I
I
Same as Search Criteria 2 and 3.
8. Reports and briefings (excluding emails)
produced by Post Office and submitted to
Category 1, 2 or 3 Custodians regarding
necessary or recommended measures for
developing Horizon so to mitigate the risk that
Horizon might cause branch accounts to be
I inaccurate.
Same as Search Criteria 2 and 3.
9. Reports and briefings (excluding emails)
produced by ATOS and any other third party IT
suppliers excluding individual contractors) who
was engaged by Post Office to work primarily on
the Horizon system, Bank of Ireland and Camelot
and submitted to Category 1 or 2 Custodians
regarding necessary or recommended measures
for preventing/fixing bugs and developing the
Horizon system, to mitigate or prevent impact on
branch accounts or transactions between: (i) 1
January 1999 to 31 December 2000; (ii) 1
January 2005 to 30 April 2006; and (iii) 1
January 2010 to 31 July 2013.
Same as Search Criteria 4
10. Reports and briefings (excluding emails)
submitted to Category 1, 2 or 3 Custodians
regarding the nature and extent of postmaster
complaints, reports or notifications regarding
bugs, errors or defects in Horizon that had the
potential to cause a branch accounts to be
inaccurate.
Same as Search Criteria 4
15. Reports and briefings (excluding emails)
submitted to Category 1 or 2 Custodians
regarding aggregated (not branch specific)
information on the underlying causes of, or
circumstances leading to, transaction corrections
issued to the branch network via Horizon.
Same as Search Criteria 2.
16
In running final checks on disclosure during the course of yesterday and today, it was discovered
that the Search Criteria 1 and 2 had not accurately run against the following email accounts:
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Andy Garner, lan Trundell, Dave Hulbert, Ben Cooke, Steve Beddoe, Neil Wilkinson, Michael
Austin, Mick Mitchell, Rob Houghton and Steve Alichorn.
1.7 Having corrected this, additional responsive documents have been identified. We are
considering these and how best to filter / review them for disclosable documents and will update
you on this shortly.
2. Class 4 and 11 to 14
21 Enquires have been made with Fujitsu to source the documents which fall within Classes 4 and
11 to 14.
Class 4 - Documents or records recording all data sources outside of Horizon which provide financial or
transactional data into Horizon.
2.2 The Application Interface Specification (AIS) documents (disclosed as part of Stage 2 Disclosure)
record the interfaces between Horizon and external systems. The AIS documents can be found
using a keyword search. Disclosure has also been provided of documents within this Class
which were revealed by the searches explained above.
Class 11 - Written policies and processes regarding how the Horizon Service Desk is operated (by both
Fujitsu historically and ATOS now).
2.3 Documents which relate to the operation of the Horizon Service Desk by Fujitsu were disclosed
as part of Stage 2 Disclosure. Fujitsu have identified these as documents with the following
references:
2.3.1 SVM/SDM/PRO/0021
2.3.2 SVM/SDM/SD/0001
2.3.3 CS/SER/002
2.3.4 SVM/SDM/PRO/0003
2.3.5 CS/FSP/021
2.3.6 SVM/SDM/SD/0023
2.4 Documents which relate to the operation of the Horizon Service Desk by ATOS were disclosed
within the early tranche of Stage 3 Disclosure given on 29 June 2018.
2.5 Further documents have also been located through the searching of the Category 2 and 3
Custodians' email accounts as explained above.
Classes 12 - Written policies and processes regarding database administrator access to Horizon,
including relating to the implementation of fixes that had the ability to impact upon branch accounts or
transactions.
26 See document POL-0215659 which was disclosed as part of Stage 2 Disclosure. This Class also
overlaps with the requests made by the Claimants’ expert which Post Office shall be responding
on shortly.
Class 13 - Any logs in Horizon of when database administrator access has been used and how it was
used.
27 Horizon does keep logs of database administrator access. Fujitsu are working on extracting the
logs. We will update you on this shortly.
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Class 14 - Documents containing lists of individuals who had or have database administrator access to
the Horizon Audit Store and the BRDB (Branch Database), from 1999 to date, which allows them to
implement fixes in branch accounts or transactions.
28 There is no formal record or single document that lists individuals with database administrator
access (historic or present). A current list of database administrators could be compiled but it
would only reflect the position on the day it was produced.
Yours faithfully
A obl. Bord Dutintor (ve) LLP
Womble Bond Dickinson (UK) LLP
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SCHEDULE 1
Category Custodians
Category 2 Custodians
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1. Antonio Jamasb
[ 2. Emma Langfield
3. Alan Simpson
4. Julia Marwood
5. lan Trundell
6. Andrew Winn
7. Clive Read
8. Delwar King
9. David Smith
10. Michael Young
11. Lesley Sewell
12. Robert Houghton
13. Michael Kevin Mitchell
14. Michael Terence James Austin
15. Neil Wilkinson
16. Paul Antony Bleasby
17. Blake Griffin
18. Jason Black
19. Jeffrey William Alexander Smyth
20. Benjamin Tom Cooke
21. Andrew John Garner
22. Catherine Hamilton
23. Donna Sharon Yvette Gilkes
24. Alistair Roman
25. Michael Passmore
26. Nicholas Paul Sambridge
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Category Custodians
27. David Andrew Hulbert
28. Colin Andrew Pletts
29. Timothy White
30. Stephen Taylor
31. Stephen Beddoe
32.
Patricia Stewart
33.
Susan Lowther
34.
Michael Gallagher
35.
Timothy Clifton Connold
36.
Stephen Bell
37.
John Bethell
38.
Richard Evans
39.
Edward Coleman
40.
Ursula Williams
41.
Matthew Williams
42.
Kirk Delaney
43.
Andrew McLean
44.
David Smith
45.
Keith Rann
46.
Nicholas Gittens
47.
Stephen Allchorn
48.
Mark Burley
Simon Baker
. Christopher Taylor
"51. Andrew Jones
. David Gray
Steven Rogers
. Simon Baker
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Category
Custodians
55. Neil Lecky-Thompson
56. Brian Deveney
57. Mark Pearce
58. Julie George
59. Peter Goodman
60. Blake Griffin
61. Mike Wells
62. lan O'Driscoll
63. Mark Burley
Category 3 Custodians
64. John Jenkinson
65. John Scott
66. Lynn Hobbs
67. Kevin Gilliland
68. Rob Bolton
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