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From: Andy Garner{i_
Sent: Thur 28/07/2016
To: Porter, Tomt
Parsons, Andrew}
Underwood1
Hailstones[
Hargreaves[! GRO.
Subject: RE: URGENT - Horizon Dispute - document location exercise - confidential and legally privileged
[BD-4A.F1D26859284]
Hi Tom
Tried phoning this afternoon. I am now on leave however David Hargreaves copied in will support in my absence. Is
there anything you specifically need, I am back 8th August.
Thanks
Andrew Garner
Head of IT Service
Network & Financial Services
From: Porter, Tom
Sent: 28/07/2016 08:43
To: Andy Garner; Babu Palathoti; Parsons, Andrew; Mark Underwood]; Shirley Hailstones
Subject: RE: URGENT - Horizon Dispute - document location exercise - confidential and legally privileged [BD-
4A.FID26859284]
Hi Andy.
This has moved on in the last week.
I left you a voicemail yesterday but it sounds like you didn't get it.
I'll try to call again this morning.
Tom
Tom Porter
Associate
Bond Dickii
From: Andy Garner
Sent: 28/07/2016 08:16
To: Andy Garner; Babu Palathoti; Parsons, Andrew; Mark Underwood1; Porter, Tom; Shirley Hailstones
Subject: RE: URGENT - Horizon Dispute - document location exercise - confidential and legally privileged [BD-
4A.FID26859284]
Andrew, Mark, Tom
Please can you advise asap on my call out below ? Can we go to Fujitsu for some of the documentation ?
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Thanks
Andrew Garner
Head of IT Service
Network & Financial Services
From: Andy Garner
Sent: 27/07/2016 08:22
To: Babu Palathoti; andrew.parsons.__
Hailstones
Subject: FW: URGENT - Horizon Dispute - document location exercise - confidential and legally privileged [BD-
4A.FID26859284]
} Shirley
~] Mark Underwood1; tom.porte:
Andrew
My sincerest apologies, for some reason I did not receive Tom or your emails ! Let me attempt to recover the delay asap.
With regards to the software upgrades/architecture documents and error logs requirements, these may be with Atos
however most likely Fujitsu being their internal records/MI. Is it appropriate I request these from Fujitsu ? Not sure what
with the sensitive nature.
Babu - Please can you confirm you are available today to attempt to source the practices /policy and Operations Manual
documents ?
Thanks
Andrew Garner
Head of IT Service
N
From: Andy Garner
Sent: 26/07/2016 21:45
To: Andy Garner
Subject: FW: URGENT - Horizon Dispute - document location exercise - confidential and legally privileged [BD-
4A.FID26859284]
Andrew Garner
Head of IT Service
Network & Financial Services
From: Rob Houghton
Sent: 26/07/2016 09:45
To: Andy Garner; Sharon Gilkes
Subject: FW: URGENT - Horizon Dispute - document location exercise - confidential and legally privileged [BD-
4A.FID26859284]
Nudge - can you help with this?
R
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From: Parsons, Andrew
Sent: 26 July 2016 09:32
To: Rob Houghton
Cc: Porter, Tom; Mark Underwood1
Subject: URGENT - Horizon Dispute - document location exercise - confidential and legally privileged [BD-
4A.FID26859284]
Rob
FYI below. We've been chasing Andy Garner (who I think is in your team) for information on the Horizon Operations
Manual. We've not had a reply and this is now urgent. Please could you give Andy a nudge or let us know if there is
someone else who might be able to help with this.
Thanks
Andy
Andrew Parsons
Partner
Crud Dideingow
Direct:
Mobil
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From: Parsons, Andrew
Sent: 19 July 20
To: ‘andy.garner'
Cc: Porter, Tom; Mark Underwood1
Subject: URGENT - Horizon Dispute - document location exercise - confidential and legally privileged [BD-
4A.FID26859284]
Importance: High
Andy
Apologies for chasing but please can you respond to the below as a matter of urgency. We need an answer by cob
tomorrow at the latest in order to meet a litigation deadline. Any questions, please feel free to call me or Tom.
Kind regards
Andy
Andrew Parsons
Partner
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www.bonddickinson.com
From: Porter, Tom
Sent: 15 July 2016 09:44
To: andy.garner: GRO.
Cc: Mark Underwood! ¢.
Subject: FW: Horizon Dispute - document location exercise - confidential and legally privileged [BD-4A.FID26859284]
Importance: High
Good morning Andy
I just wanted to send you an email to make sure you got the below, and to check that everything is in order.
We are sending the wider points for approval to Legal today — but I suspect we will need to send this to follow.
I look forward to hearing from you.
Tom
Tom Porter
Associate
www.bonddick
From: Porter, Tom
Sent: 04 July 2016 11:28
To: ‘andy.garner.
lential and legally privileged [BD-4A.FID26859284]
Importance: High
Good morning Andy
I have been given your contact details by Shirley Hailstones.
Shirley thought that you might be best placed to help us locate certain documents that we have been asked to disclose
in the Horizon dispute.
We will be taking a view on what to disclose, but as a first step we also need to work out what we have and where. I
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include a small table of documents below, and I would be grateful for any guidance/assistance you can provide for
each.
It may also be useful to have a quick call so I can give you some background to this, and to give us a chance to talk
through the requests. Would you be free for a chat today?
We have an ongoing central dialog with Fujitsu relating to the dispute — if we need to ask Fujitsu for any of these
documents please could you list the documents for us to request (rather than requesting them yourself)?
No. I Document sought by the other side
Comment / request
1 Documents containing non-contractual
understandings, practices, policies etc relating
to Post Office's relationship with Fujitsu and
Fujitsu's performance (Horizon specific)
We consider that this request is too wide.
However, please could you let us know if you
have a single location where you store
information of this type (that would be easily
accessible)?
3 Schedule of Horizon updates, modifications
and software versions since 1999 (including
details of what the updates fixed)
We do not anticipate that this documents exists,
but is there any document showing the various
revisions to Horizon and setting out dates for the
same?
4 Schedule of the software architecture since
1999
We do not know precisely what they are looking
for here. We therefore intend to reject the
request on this basis but, before doing so, I
wanted to make sure that you agreed. Are you
aware of any such schedule?
5 The "known error log" kept by Fujitsu and any
correspondence relating to the same
We are not aware of this document (or whether it
exists). Do you know of a "known error log" and,
if so are you able to provide us with a copy?
Mark Underwood is assisting with a similar exercise for different documents. I have copied Mark to this email on the
off-chance that he finds any of the above documents whilst carrying out his own searches.
I look forward to hearing from you.
Kind regards
Tom
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Tom Porter
Associate
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