POL00366968 - Email from Anthony De Garr Robinson to Simon Henderson, Jonathan Gribben and Andrew Parsons RE: Parker 2.

Evidence on official site

POL00366968
POL00366968

Message

From: Anthony de Garr Robinson

Sent: 30/01/2019 11:32:49 _
To: ‘simon Henderson’ Jonathan Gribben:
cc: Andrew Parsons

Subject: RE: Parker 2 [WBDUK-AC.FID27032497]

Dear Jonny,

In Parker’s first WS, he said (1) that transaction injections could not be used to benefit anyone, such as (2) by procuring a
payment into a bank account.

In para 35 of his second WS, he stands by and defends (2), but accepts that (1) was wrong. He adds that transaction
injections could be used to procure payments into gyro accounts, but — as he explains in a footnote — this is because the IT
mechanism involved was very different from the IT mechanism involved in procuring payments into banks accounts.

Now, it appears that the IT mechanism involved was not very different at all. This seems to mean that para 35 is wrong
(not just the footnote). If so, Parker has to serve a corrective witness statement explaining the true position and why he
got it wrong twice before. To be clear, the correction would not merely involve retracting the footnote — indeed, retracting
the footnote without changing the conclusion based on that footnote (that gyro payments could be procured but not bank
account payments) would create an apparent illogicality in the statement and draw the claimants’ attention to the problem
with flashing lights.

Unless I have misunderstood your emails, Parker now appears to be telling us that he was completely wrong in his first

statement last year and that he was also completely wrong in his statement last night. This is horrifying and the damage
that it is likely is incalculable. It seems to me that just writing to delete a footnote when we don't know where we stand
could result in increasing the damage substantially.

In short, we can and should say nothing to Freeths until we know the true position. This is urgent. It probably needs to be
escalated to the highest level in Post Office and Fujitsu.

I fervently hope I have misunderstood your emails, by the way.
Best wishes,

Tony

From: Simon Henderson
Sent: 30 January 2019 10:53
To: ‘Jonathan Gribben' +
Cc: Andrew Parson:
Subject: RE: Parker 2 [WBDUK-AC.FID27032497]

Anthony de Garr Robinson

OK but what other bank accounts did PO support deposit facilities for? If the only account anyone ever used the PO to
make a deposit into was a Giro account, all well and good but is that right? Even if no deposit could be made into 3%
party bank accounts (i.e. NatWest etc) the PO (at least today and I imagine at the relevant time) offers all sorts of savings
accounts, ISAs etc. Could FJ have inserted transactions which had the effect of making deposits into (i) 3 party
accounts or (ii) PO accounts? If not, why not?

Best

Simon

From: Jonathan Gribben [mailt:
Sent: 30 January 2019 10:48

Anthony de Garr Robinsot
POL00366968
POL00366968

Cc: Andrew Parsons }.
Subject: RE: Parker 2 [WBDUK-AC.FID27032497]

Simon,

Based on FJ's comments this morning, it looks like the statement that a Giro transaction was a type of PO transaction that
was different from any other payment to a bank may not be correct, which is why we are proposing to remove the full
footnote.

Based on FJ's current comments it appears that a SSC user could inject a transaction into a Giro bank account and any
other bank accounts that PO supported deposit facilities, but there would be a paper trail. We need to confirm this with
Post Office and I suspect that will take some time, hence the suggestion to remove the footnote and prepare a paper to
cover off the point.

Let me know if you want to discuss.

Kind regards

Jonny

Jonathan Gribben
Managing Associate
Womble Bond Dickinson (UK) LLP.

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From: Simon Henderson [mailt
Sent: 30 January 2019 10:38
To: Jonathan Gribben; Anthony de Garr Robinson
Cc: Andrew Parsons

Subject: RE: Parker 2 [WBDUK-AC.FID27032497]

Jonny

This is obviously very concerning. Before we fire off any letter, we need to be absolutely sure we have now got things
right. If it is right that Giro was a standard EPOSS transaction and that FJ could have injected a Giro transaction, doesn’t
it also follow that FJ could have injected a transaction to any bank account? If so, that is a drastic departure from Parker
land 2. The paper trail point may help but it doesn’t solve the fundamental issue. Parker 2 presently says that a Giro
transaction was a type of PO transaction that was different from any other payment to a bank. Is that correct or not?
Best

Simon

From: Jonathan Gribben [mailto! GRO j
Sent: 30 January 2019 10:30
To: Anthony de Garr Robinso!

POL00366968
POL00366968

Cc: Simon Henderson
Subject: Parker 2 [WBD

Andrew Parson:

Tony,

Yesterday FJ informed us that a Giro bank is also an AP transaction (like bill payments) - it is the only type of bank
account that is and all other banking deposits go through a totally different path. We included it as a footnote to Steve's
statement (para. 35). FJ have now told us that Giro Bank Transactions are not AP, but standard EPOSS Transactions
and that prior to online banking (introduced in 2003), POL did support some (but not all) other banks with deposit and
cheque cashing facilities which were also EPOSS transactions. They think that there was also a paper trail for those
transactions too (so they would be detectable during Post Office's reconciliation processes) and we will pick this up with
POL to confirm, but the immediate point is that we need to provide a replacement version of Steve's statement with the
footnote referred to above removed. Our suggestion is to send Freeths a version without the footnote by email as follows:

"Dear Sirs,

It has come to our attention that the witness statement we provided yesterday contained a footnote in
error. Please find attached a replacement version.

Yours faithfully"
We will then produce a paper to bottom out the above points.
Please let me know if you agree with this approach.
Kind regards

Jonny

Jonathan Gribben
Managing Associate
Womble Bond Dickinson (UK) LLP

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From: Gareth Jenkins [m:
Sent: 30 January 2019 07:2
To: pete.newsome@! RO 5 "; Legal.Defence¢~
Cc: Andrew Parsons; Dave.Ibbett@ i

Subject: RE: SP Second Witness Statement: Possible examples to use - effective software fixes

“i; Jonathan Gribben

IMPORTANT - This email or attached documents contains legal advice (or relates to litigation or anticipated litigation) and is being provided in
circumstances for which Legal Privilege may be claimed. Do not copy or forward this document without permission.

Hi Jonny,

Sorry, but you didn’t send me the actual question until I’d gone off line around 4ish yesterday, so other than the phone
call I had from Pete, I didn’t see the emails until late last night.

A further clarification:

1. The Giro Bank Transactions are not AP, but standard EPOSS Transactions. I don’t know how info on them got to
Giro Bank — it may well be that Giro Bank worked off the paper trail and then sent summaries to POL which they
then reconciled with the Horizon feed. POL would need to provide the details.

2. Prior to online banking (introduced in 2003), POL did support some (but not all) other banks with deposit and
cheque cashing facilities. Again these were EPOSS (not AP) transactions. I assume that there was also a paper
trail here and it would work in a similar way to Giro Bank. Again it is POL that need to define the process. All
Horizon did was provide the buttons to record the electronic part of the transaction.

Is there any point in me re-reading Steve’s statement? I’m out this morning, but could do so this afternoon.
Hope this helps.
Best wishes

Gareth
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From: pete.newsomef

Sent: 29 January 2019 19:45

To: Christopher.Jayé Legal.Defencet
Cc: andrew.parson: Dave.Ibbett!

———
Subject: RE: SP Second Witness Statement: Possi

gi.jenkins;
s to use - effective software

Jonny
I read out the questions and then interpreted Gareth's answers into my own words.
Pete

Sent from my Android phone using Symantec TouchDown (www.symantec.com)

Original Message
From: Jonathan Gribber
Received: Tuesday, 29 Jan 2019, 17:33

Jay, Christopher Defence Legal

Ibbett, Dave Gareth Jenkins

itness Statement: Possible examples to use - effective software fixes

Thanks. When you say you have had to interpret, do you mean interpret my email and/or what Gareth has said, or do you
mean you passed on my email and Gareth confirmed that it is correct?

Kind regards

Jonny

Jonathan Gribben
Managing Associate
Womble Bond Dickinson (UK) LLP

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From: pete.newsome@!_
Sent: 29 January 2019 1
To: Jonathan Gribben; Christopher.Jay: }; Legal.Defenc:
Cc: Andrew Parsons; Dave.Ibbett! Gareth Jenkins
Subject: RE: SP Second Witness Statement: Possible examples to use - effective software fixes [WBDUK-
AC.FID27032497]

POL00366968
POL00366968

IMPORTANT - This email or attached documents contains legal advice (or relates to litigation or anticipated litigation) and is being provided in
circumstances for which Legal Privilege may be claimed. Do not copy or forward this document without permission.

Jonny
I talked to Gareth and the answer is below. I have had to interpret as Gareth was not able to send a response.
Pete

Pete Newsome
Account Manager
DHL and Post Office Account, Fujitsu UK&l

TGR TOjtsi-com
Web: uk. fujitsu.com

My normal working week is Monday to Thursday

© £I¥in/e)

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. . k wrt
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Sent: Tuesday, January 2¢
To: Newsome, Pete: +; Jay, Christopher
Cc: Andrew Parson: Ibbett, Dave
Subject: RE: SP Second Witness Statement: Possible examples to use - effective software
AC.FID27032497]

Yes it has been sent to Gareth, but it is:

How is it possible for SSC to inject a GIRO bank transfer into a set of branch accounts but it isn't possible to inject
another bank deposit? Gareth's answer Giro Bank paying in was possible into accounts by AP as it was
introduced before on line banking so you needed was the account number and detailed knowledge of the system
so theoretically it was possible. But there was a paper work trail to back this up that the sub-postmaster had to
send in to POL which should then reconcile to the AP transaction file from Horizon. (Post Office would understand
how it worked). A report was produced daily to reconcile against the Horizon feed, any discrepancy Post Office
may find where the paper work was not present would be discussed with the branch at the time. Post Office can
describe what would happen if the paperwork was not available.
POL00366968
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Steve thinks the answer is:

I think the answer is that Giro bank is also an AP transaction (like bill payments). It is the only type of bank
account that is. All other banking deposits go through a totally different path. There may have been other banks
who had similar facilities before on line banking was introduced in 2004? but you would have to ask Post Office as
they were AP transactions.

Thanks

Jonny

Jonathan Gribben
Managing Associate
Womble Bond Dickinson (UK) LLP

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From: pete.newsomd an a :
Sent: 29 January 2019 16:59

Cc: Andrew Parsons; Dave.Ibbett:
Subject: RE: SP Second Witness Statement: Possible examples to use - effective software fixes [WBDUK-
AC.FID27032497]

Hi
What is the question? Has it been sent to Gareth already?
Pete

Pete Newsome
Account Manager
st Office Account, Fujitsu UK&l

Web: hitp77UKTotso:corn
Web: uk fujitsu.com

My normal working week is Monday to Thursday

© fI¥in/e)

POL00366968
POL00366968

Fujitsu named as

Responsible Business
of the Year

Fujitsu is proud to partner with Action for Children
I-CIO: Global Intelligence for the CIO. Fujitsu’s online resource for ICT leaders
Sponsors of the 2015 Rugby World Cup

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From: Jonathan Gribben
Sent: Tuesday, January 29, 2019 4:58 PM
To: Newsome, Pete
Cc: Andrew Parsons <__
Subject: RE: SP Second
AC.FID27032497]

; Jay, Christopher

examples to use - effective software fixes [WBDUK-

Pete,

Steve has signed his statement and we are holding it subject to one point that Gareth Jenkins needs to check. Can you
make contact with Gareth and ask him to do that ASAP please?

Kind regards

Jonny

Jonathan Gribben
Managing Associate
Womble Bond Dickinson (UK) LLP.

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From: pete.newsomd)
Sent: 29 January 2019
To: Jonathan Gribben; Christopher.Jay:
Cc: Andrew Parsons

Subject: RE: SP Second Witness Statement: Possible examples to use - effective software fixes [WBDUK-
AC.FID27032497]

POL00366968
POL00366968

Jonny
Is available for a call now. Try his mobile. 5.30 is when he needs to stop.....
Pete

Pete Newsome

Account Manager

DHL and Post Office Account, Fujitsu UK&l
Tel:

Web: uk. fujitsu.com

My normal working week is Monday to Thursday

Fujitsu named as
Responsible Business
of the Year

Fujitsu is proud to partner with Action for Children
I-CIO: Global Intelligence for the CIO. Fujitsu's online resource for ICT leaders
Sponsors of the 2015 Rugby World Cup

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From: Jonathan Gribben
Sent: Tuesday, January 29, 2019
To: Jay, Christopher
Cc: Andrew Parson:
Subject: FW: SP Second Witness Statement: Possible examples to use - effective software fixes [WBDUK-
AC.FID27032497]

1PM

lewsome, Pete

Chris, Pete,

We are close to finalising Steve's statement and it really needs to go today, but he is saying he isn't available after
5:30. Would you be able to speak to him to explain the importance of this please?

Kind regards

Jonny
POL00366968
POL00366968

Jonathan Gribben
Managing Associate
Womble Bond Dickinson (UK) LLP

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From: ParkerSP!
Sent: 29 January 2019 1
To: Jonathan Gribben

Subject: RE: SP Second Witness Statement: Possible examples to use - effective software fixes

No, can’t be available after 5:30

From: Jonathan Gribben
Sent: Tuesday, Jani
To: Parker, Steve
Subject: RE: SP Second Witness Statement: Possible examples to use - effective software fixes

Steve,
I should have said, we really do need to get this out today. Are you available this evening?

Thanks
Jonny
Jonathan Gribben

Managing Associate
Womble Bond Dickinson (UK) LLP.

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From: Jonathan Gribben
Sent: 29 January_2019 1
To: 'ParkerSI
Cc: Matthew.Lento:

Parsons

Dave. Ibbett¢ Lucy Bremner; John.Simpkin: Andrew

POL00366968
POL00366968

Subject: RE: SP Second Witness Statement: Possible examples to use - effective software fixes [WBDUK-
AC.FID27032497]

Steve,

Thank you for this. Updated version attached. We are down to one point to bottom out, which is the GIRO bank theory in
para. 35. The bit we are struggling with is that it if it is possible to deposit money in a Giro bank account, how is it not
possible to deposit money in a normal account. Why is a paper slip necessary for this type of account?

It might be worth having a quick call on this. Are you free?

Kind regards

Jonny

From: ParkerSP@
Sent: 29 January 20
To: Jonathan Gribber
Cc: Matthew.Lentoné
Parsons

Subject: RE: SP Second Witness Statement: Possible examples to use - effective software fixes [WBDUK-
AC.FID27032497]

Andrew

; Lucy Bremner; John.Simpkins¢

Latest comments / change marked

Steve

From: Jonathan Gribben
: Tuesday, Janua!
arker, Steve ¢

; Ibbett, Dave

Lucy Bremner
5 Andrew Parsons

Subject: RE: SP Second Witness Statement: Possible examples to use - effective software fixes [WBDUK-
AC.FID27032497]
Importance: High

Steve,

Please see attached the updated version of your statement and a comparison showing the changes made.
Can we discuss the comments at 2:00pm please?

Kind regards

Jonny

Jonathan Gribben

Managing Associate
Womble Bond Dickinson (UK) LLP

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POL00366968
POL00366968

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Sent: 29 January 2019 10:
To: Jonathan Gribben
Subject: RE: SP Second Witness Statement: Possible examples to use - effective software fixes [WBDUK-
AC.FID27032497]

Yes, will do

From: Jonathan Gribben

Sent: Tuesday, January 29, 2019 10:40 AM
To: Parker, Stev

Lucy Bremner

SP Second Witness Statement: Possible examples to use - effective software fixes [WBDUK-
AC.FID27032497]

Steve,
Thank you for this.

I'm working on the statement now — next (and hopefully final version) will be with you within 30 minutes. We need to get it
out today, so please can you review on receipt? I'll send you a comparison so you can easily see the changes made.

Kind regards

Jonny

Jonathan Gribben
Managing Associate
Womble Bond Dickinson (UK) LLP

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From: ParkerSP!
Sent: 29 January 2019 09:10

To: Jonathan Gribbei
Cc: Matthew.Lentort’ SRO. Gareth

Jenkins
POLO0366968
POL00366968

IMPORTANT - This email or attached documents contains legal advice (or relates to litigation or anticipated litigation) and is being provided in
circumstances for which Legal Privilege may be claimed. Do not copy or forward this document without permission.

Jonny, we’ve been looking at some potential examples to use within the witness statement. Suggest WBD have a look
and decide if it is useful to add them as examples?

Effective Software Fixes

Pc0089918: PSteed2847N - reverse a rem, but when this has been reversed it is doubling up on a
balance
+ve: Already mentioned in statement but still shows a quick software error turn round

28/04/03: SSC (Paul Steed) identified error

28/04/03: Paul Steed updated and sent to MSU to handle discrepancy with FAD & POL

30/04/03: Development identify error

01/05/03: Work Package generated: PWY_WP_16353 B3S30R

07/05/03: Tested on LST. Fix released.

09/05/03: I have spoken to the PM to say that the software fix was sent down and became active on 07-May-2003 and
so there should be no recurrences of the original problem.

PC0123699: 28/07/05 ...payments and receipts are mismatched...PM states he was balancing on node 2

but there was discrepancies...

-ve: Initial SSC response was erroneous, to send back to Helpdesk.

+ve: Fast fix to live for financial issue

+ve: Demonstrates passing to MSU to tie up financial impact with POL

+ve: Example of looking at more than one site, diligence identifying other sites with issue

+ve: Shows how an initial R&P error is seen by PM and support are subsequently able to identify other events that tie it
in to other sites

28/07/05: Incorrectly sent back by SSC ...Balancing problems should be dealt with initially by NBSC...

28/07/05: ...Have spoken with the PM and advised...All that remains now is for us to try and identify the root cause of
the discrepancy which may take a while. As per usual we will forward our findings on to the MSU who will advise POL
accordingly...

29/07/05 With development. Work Package PWY_WP_22602 generated

01/08/05: BI3S80R_WP22602 is now ready for test

02/08/05: Release PinICL PCO123865

08/08/05: This has passed testing in LST and is being returned to RM for live pilot.

09/08/05: sent out to the Pilot 100 successfully

05/09/05: Applied to all live outlets and now in the live Generic Prodlists roll-outs using both $70 and S80 spares

When the PM went to produce a trail balance a discrepancy was shown but at the bottom the receipts and payment
totals did not match.

The £170 discrepancy was down to an APS txn message that had no product number and no primary or secondary
mappings. There was a critical event raised on 21st Jul on counter 9 which helped to identify this (Event Id:4 with the
text "Error Message: Failed to generate EPOSSCore transaction grammar").

As the txn message was incomplete it was omitted from the rollover 'calculations' and thus caused the discrepancy
reported.

When I checked the tivoli event archives yesterday I found that 216 of these events had been logged in the past 7 days
at different offices/counters

Looks like whenever the event is raised it is either down to a cancelled quantum txn
POL00366968
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Have checked out a sample of 40 to 50 sites and they're all at S80 so its probably safe to assume its an S80 problem.

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POL00366968
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