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From: Mark Underwo {cx} =MMS/OU=EXCHANGE ADMINISTRATIVE GROUP
(FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=MARK UNDERWO0222A42EC-51A8-4DFA-A353-
DCEA512679657B4]
Sent: Fri 27/11/2015 10:09:11 AM (UTC)
To: Rodric William:
Ce: Patrick Bourke;
Subject: RE: Chairman's Review - Further Information - SUBJECT TO LEGAL PRIVILEGE
Are you OK with me sending Lorraine to deliver the Deloitte bits today — at around 4pm?
Mark Underwood
Complaint Review and Mediation Scheme
From: Rodric Williams
Sent: 26 November 2015 16:38
To: Christopher Knight:
Cc: Jonathan Swift:
Subject: Chairman’
In - SUBJECT TO LEGAL PRIVILEGE
Chris,
I respond below to your requests for various further information. The majority of the attachments will follow in
separate emails due to their size.
1. Deloitte
I cannot email the “Horizon: Desktop Review of Assurance Sources and Key Control Features” draft report
dated 23 May 2014 and “Board Briefing” dated 4 June 2014, so will have hard copies sent to Chambers. I
suggest you start with the Board Briefing.
2. Ernst & Young
I attach the “Description of Fujitsu’s System of IT Infrastructure Services supporting Post Office Limited’s
POLSAP and HNG-X applications Throughout the Period 1 April 2014 to 31 December 2014” report prepared
by Fujitsu/Ernst & Young for Post Office Limited and its auditors (also Ernst & Young).
This report was prepared in accordance with ISAE 3402, the audit standard for reporting on controls at
organizations which provide services likely to be relevant to the user’s financial reporting. Similar reports
have been prepared for some earlier periods, but not (so far as I am aware) over the full period of the
postmaster complaints.
3. Brian Altman QC
We will prepare a letter for you/Jonathan/Tim addressing Post Office’s response to the recommendations
Brian made in his 31 October 2013 advice.
4. Further Legal Advice
Could you please call me to discuss which “legal advice documents in the original list” you require. As we
have discussed, Post Office has received a wide variety of advice in various formats from different sources in
the course of responding to the challenges to Horizon, and it would be helpful to narrow down the areas /
topics / allegations etc with which you are most concerned.
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5. Hamilton File:
You have asked us for an indication of the size of the full Hamilton prosecution file:
- The file made available to the CCRC via the Millnet platform contains 409 documents. These are of
varying lengths, but we can ask Millnet to “image” the documents if you want to know the exact number
of pages.
- We have also uploaded onto the Millnet platform some 184,000 Post Office Security documents taken
from electronic storage locations within Post Office and Royal Mail, which potentially respond to the
Section 17 Notices issued by the CCRC for the 20 individual applicants (the “Security Documents”). The
Security Documents are held essentially as a data dump which can be searched by key word, date range
and other meta-data fields, but are not currently stored in any meaningful structure.
- To get an indication of how many of the Security Documents may relate to Josephine Hamilton, we have
run a couple of key word searches which produced the following results:
Keyword Docs Docs inc Family*
Hamilton 6,177 11,318
Jo* w/2 Hamilton 767 905
Josephine Hamilton 572 663
Josephine Hamilton AND between 1 31 31
March 2006 (audit) and 30 Nov 2007
(conviction)
[* “Family” documents are those connected to documents having a keyword e.g. an email may contain a keyword; the
attachments to the email (which do not contain a keyword) will be family documents.]
- There are also a further 380 documents relating to Jo Hamilton’s case on her civil litigation file. That file
was created in response to a letter before (civil) action received from Shoosmiths LLP in 2011, and is likely
to duplicate substantially material from the prosecution file.
6. Misra File
The trial full trial transcript will follow in 4 separate emails.
In case it assists your review of the transcripts, I will also email three tables (and a summary memorandum)
which cross-reference the transcript entries addressing whether Horizon was free from defects, whether the
postmaster training was adequate, and whether the Helpline advice was adequate. These documents were
prepared in or about October 2011 in response to the letters of claim issued by Shoosmiths.
I will also email:
- the “Case Review” report dated 22 January 2014 prepared by Cartwright King for the Misra prosecution.
This report considered whether further disclosure to Misra was required following the publication of
Second Sight’s July 2013 report, and was prepared as part of the past prosecution review process on
which Brian Altman QC advised in written advice notes dated 2 August 2013 and 15 October 2013. Post
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Office has recently asked Cartwright King to reconsider the advice provided in the Case Review report
(which was based on a review of the trial transcripts only) now that the full prosecution files are available,
and in connection with a document referred to by BBC Panorama in the “Trouble at the Post Office”
programme broadcast on 17 August 2015.
- witness evidence from the Misra trial (including that of the Fujitsu expert Gareth Jenkins); and
- the defence expert reports of Charles McLachlan (without appendices - please let me know if you would
like these).
Please note that the Misra file made available to the CCRC via the Millnet platform contains 2,608
documents. Further documents are likely to be located within the Security Documents.
7. Castleton
To the best of my knowledge, the Castleton case is the only civil judgment on the Horizon issue.
I will email to you the witness statement of Anne Chambers, the Fujitsu witness referred to in para. 23 of the
judgment. This is one of 19 statements filed in the case, three of which were filed for the Defendant/Pt20
Claimant Mr Castleton.
Ms Chambers’ statement does not deal with the “Falkirk” bug. The Falkirk bug was however considered by
the experts in the Misra prosecution - see the Jenkins statements of 8 March 2010 and 8 October 2010.
8. Richard Roll
I know Mark Underwood has emailed you separately on the contribution Mr Roll made to the Panorama
programme, but just in case it is not clear to you, the BBC’s failure to provide us with any information about
Mr Roll’s contribution (including his name), thereby preventing Post Office from formally commenting on that
contribution for the programme, is one of Post Office’s formal grounds of complaint to the BBC about the
broadcast (see the letter from CMS Cameron McKenna LLP to BBC Programme Legal Advice and BBC
Complaints dated 15 September 2015, from para. 3 page 4, whch will follow separately).
9. “Spot Reviews”
Although you have not asked for them, in case they become relevant I will email separately the “Spot Review
Bible”. This contains the technical issues put to Post Office which Second Sight reported on in its July 2013
Report, and Post Office’s responses.
Please let me know if I have overlooked anything, or if you require anything further.
Kind regards, Rodric
POST
OFFICE