From: Amy Prime £
To: Michael Wharton }
Ce: Joel Durston
Subject: RE: 917090 Stage 3 Disclosure - Board Papers and GE Docs
Date: Thu, 28 Jun 2018 16:05:18 +0000
Importance: Normal
Inline-Images: image003.png; image004.png; image005.png; image006.png; image009,jpg;
image010,jpg; image011 jpg; image012.jpg; image8905e1.PNG; image42aaa3.PNG;
imageS7b741.PNG
Agree, the 1,548 is manageable — please can you liaise with Joel and Beth in the Southampton office (cc'ed) to review
these documents. I want to keep Plymouth clear for the email accounts.
They will need a full briefing on the scope of documents which need to be disclosed, including the requirement to
disclose all adverse documents we come across. I think we adopt the same approach as the previous board minutes
(ie. redact everything which is not relevant).
Thanks
Amy
Amy Prime
Solicitor
Womble Bond Dickinson (UK) LLP
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From: Michael Wharton
Sent: 28 June 2018 16:55
To: Amy Prime
Subject:
womblebonddickinson.com
A)
E: 917090 Stage 3 Disclosure - Board Papers and GE Docs [WBDUK-AC.FID26896945]
This looks manageable — are we asking Plymouth to do a first level review?
Michael Wharton
Solicitor
Womble Bond Dickinson (UK) LLP
‘Stay informed: sign up to our e-alerts
WBONO0000176
WBON0000176
WBD_000046.000001
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From: Dan Cheal [mailto:
Sent: 28 June 2018 13:38
To: Michael Wharton
Cc: ADUK Viking POD Staff; Amy Prime
Subject: RE: 917090 Stage 3 Disclosure - Board Papers and GE Docs [WBDUK-AC.FID26896945]
Hi Michael
1,304 of these documents are responsive to at least one of the search terms below.
This increases to 1,548 when we include non-responsive family items.
Please find below a summary of results, the full report is attached.
Name Documents with I Documents with Unique hits
hits hits, including group
Bug AND Horizon 20 20 0
Error AND Horizon 209 233 29
Defect AND Horizon 22 22 4
Discrepancy AND Horizon _ I 36 36 6
Shortfall AND Horizon 431 470 99
Loss AND Horizon 981 1,167 552,
Transaction Correction 24 62 6
TC 214 268 145
The responsive items can be found here.
Kind regards
Dan
Dan Cheal
eDiscovery Project Manager
m
* GRO
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ND BRENERY Se"
announcing
ADVANCED DISCOVERY AND CONSILIO
BECOME ONE
READ THE FULL ANNOUNCEMENT >
Advanced Discovery Limited I Registered Office I 6 - 7 Princes Court I 11 Wapping Lane I London E1W 2DA
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From: Michael Wharton
Sent: 28 June 2018 12:59
To: Dan Cheal + GRO ia
WBONO0000176
WBON0000176
Ce: ADUK Viking POD Staff < GRO. I Amy Prime} GRO
Subje E: Stage 3 Disclosure - Board Papers and GE Docs [WBDUK-AC.FID26896945]
Dan
Please could you run the following keyword searches against the 9,305 documents:
bug AND Horizon
error AND Horizon
defect AND Horizon
discrepancy AND Horizon
shortfall AND Horizon
loss AND Horizon
transaction correction
TC
Kind regards
Michael
WBD_000046.000003
Michael Wharton
Solicitor
Womble Bond Dickinson (UK) LLP
GRO
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GREAT
EXHIBITION
From: Dan Cheal [mailto:
Sent: 22 June 2018 11:09
To: Amy Prime
Cc: ADUK Viking POD Staff
Subject: RE: 917090 POL Extraction [WBDUK-AC.FID26896945]
Hi Amy
Processing of this data is now complete.
Please see a full summary below:
Collection & Processing
A total of 10,926 documents were provided and processed.
womblebonddickinson.com
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WBONO0000176
WBON0000176
De-duplication (within this dataset only) reduced this number to 9,305 documents, amounting to less than
6GB.
4,694 of these documents originate from the Board Papers directory and can be found here.
4,611 of these documents originate from the GE Documents directory and can be found here.
Below is a high level display of the Sort Date range found in these documents as well as a breakdown of
document types.
e Sort Date Range
WBD_000046.000004
WBONO0000176
WBON0000176
« Document Type Breakdown
fm Document (7,198)
lm Presentation
(1,07)
lm Spreadsheet (590)
Email (323)
image (63)
(i Unrecognised (55)
Encrypted & Non-Text Searchable Documents
Please note that 19 documents are encrypted.
These documents can be found here but will not be accessible without the appropriate password.
If you have the password (or potential passwords), we will attempt to unlock these files.
A further 65 documents are non-text searchable.
For your reference, these documents can be found here and they breakdown by type as follows:
Document Type Category I Grand Total
Image 63
Document 2
Grand Total 65
Please note that encrypted and non-text searchable items will not be responsive to search terms.
In some previous loads, we have been instructed to mass-tag all non-searchable images as Not Relevant and
to OCR all remaining documents.
Should this be done in this case?
Search Term Reporting & Batching
WBD_000046.000005
WBONO0000176
WBON0000176
Are there any search terms to be applied to this data?
Should any/all of this data be batched for review?
Kind regards
Dan
Dan Cheal
eDiscovery Project Manager
ND BENE
announcing
ADVANCED DISCOVERY AND CONSILIO
BECOME ONE
READ THE FULL ANNOUNCEMENT
Advanced Discovery Limited I Registered Office I 6~ 7 Princes Court I 11 Wapping Lane I London E1W 2DA
Registered in England and Wales. Company No. 02862960
Website I Twitter I Linkedin I Insight Blog
From: Amy Prime
Sent: 21 June 2018 10:
To: Dan Cheal
Ce: ADUK Viking POD Siaif 7
Subject: RE: 917090 POL Extra
ion [WBDU.
Hi Dan
Please can the data be de-duplicated within itself.
Many thanks
WBD_000046.000006
WBONO0000176
WBON0000176
Amy
Amy Prime
Solicitor
Womble Bond Dickinson (UK) LLP
d:
m:
‘Stay informed: sign up to our e-alerts
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From: Dan Cheal [mailto:
Sent: 21 June 2018 10:13
To: Amy Prime
Cc: ADUK Viking POD Staff
Subject: RE: 917090 POL Extraction [WBDUK-AC.FID26896945]
Thanks for the update Amy.
We are now in the process of extracting and imaging this data ahead of processing.
I see that we have a total of 84 files, amounting to less than 5GB, uploaded to folders GE Documents and
Board Papers.
This puts the estimated processing cost at £400. However, a number of the files are zipped and so the final
data size/processing cost is likely to increase.
Should this data be de-duplicated against the existing document pool (including nearline archived items) or
only within itself (or not at all)?
Kind regards
Dan
Dan Cheal
eDiscovery Project Manager
WBD_000046.000007
ND BRESNERY See"
announcing
ADVANCED DISCOVERY AND CONSILIO
BECOME ONE
READ THE FULL ANNOUNCEMENT >
Advanced Discovery Limited I Registered Office I 6 - 7 Princes Court I 11 Wapping Lane I London E1W 2DA
Registered in England and Wales. Company No. 02862960
Website I Twitter I Linkedin I Insight Blog
From: Amy Prime
Sent: 21 June 2018 09:
To: Dan Cheal + GRO +
Subject: RE: 917090 POL Extraction [WBDUK-AC.FID26896945]
Hi Dan
I don't know what happened with the hard drive (user error probably) but the encryption process didn't speed up and it
seemed to want to encrypt itself before any data had been put on it. I will send the hard drive back to you. The
documents have instead been uploaded to the FTP.
Please could you process into Relativity the documents in the folders named:
Board Papers (20 June 18 Extraction)
GE Documents (extracted 20 June 2018)
Could the documents please be kept into two separate folders in Relativity, one named Board Papers and the other
named GE Papers.
Many thanks
Amy
Amy Prime
Solicitor
Womble Bond Dickinson (UK) LLP
GRO
er30
WBONO0000176
WBON0000176
WBD_000046.000008
WBONO0000176
WBON0000176
Stay informed: sign up to our e-alerts
WOMBLE womblebonddickinson.com
BOND
DICKINSON Lin)
From: Dan Cheal [mail
Sent: 20 June 2018 11:4:
To: Amy Prime
Subject: RE: 917090 POL Extraction [WBDUK-AC.FID26896945]
Hi Amy
That does seem on the slow side, how much data is being encrypted?
Dan Cheal
eDiscovery Project Manager
“GRO
ND BRENERY See
announcing
ADVANCED DISCOVERY AND CONSILIO
BECOME ONE
READ THE FULL ANNOUNCEMENT >
Advanced Discovery Limited I Registered Office I 6 - 7 Princes Court I 11 Wapping Lane I London E1W 2DA
Registered in England and Wales. Company No. 02862960
Website I Twitter I Linkedin I Insight Blog
From: Amy Prime
Sent: 20 June 2018 11:33
To: Dan Cheal { GRO i
Subject: RE: 917090 POL Extraction [WBDUK-AC.FID26896945]
Hi Dan
WBD_000046.000009
WBONO0000176
WBON0000176
The BitLocker Drive Encryption seems to be taking a long time (20 minutes to do 3.4%) — is this normal?
Many thanks
Amy
Amy Prime
Solicitor
Womble Bond Dickinson (UK) LLP
a:
m:
“ GRO
e:
‘Stay informed: sign up to our e-alerts
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From: Dan Cheal [mail
Sent: 20 June 2018 09:13
To: Amy Prime
Subject: RE: 917090 POL Extraction [WBDUK-AC.FID26896945]
Incidentally, the password for the drive you have received is: BjzwK8gy(Dy!MHe6p0.a
Dan Cheal
eDiscovery Project Manager
I [Dp DI NE Aas
announcing
ADVANCED DISCOVERY AND CONSILIO
BECOME ONE
READ THE FULL ANNOUNCEMENT >
Advanced Discovery Limited I Registered Office I 6 - 7 Princes Court I 11 Wapping Lane I London E1W 2DA
Registered in England and Wales. Company No. 02862960
WBD_000046.000010
Website I Twitter I Linkedin I Insight Blog
From: Dan Cheal
Sent: 20 June 20
To: 'Amy Prime! {
Ce: ADUK Viking
Subject: RE: 917090 POL Extraction [
Hi Amy
I'll check availability at this end and will get back to you.
Does the custodian have full admin rights/access to the data to be collected?
Dan Cheal
eDiscovery Project Manager
“GRO
ND BREE
announcing
ADVANCED DISCOVERY AND CONSILIO
BECOME ONE
READ THE FULL ANNOUNCEMENT >
Advanced Discovery Limited I Registered Office I 6 - 7 Princes Court I 11 Wapping Lane I London E1W 2DA
Registered in England and Wales. Company No. 02862960
Website I Iwitter I Linkedin I Insight Blog
From: Amy Prime
Sent: 20 June 2018 09:09
To: Dan Cheal } GRO
Ce: ADUK Viking POD Staff 7~
Subject: POL Extraction [WBDUK: “ACFIDSESEOIST
WBONO0000176
WBON0000176
WBD_000046.000011
WBONO0000176
WBON0000176
Morning Dan
Is it possible to try a remote forensic extraction of the POL documents today? I am meeting with the custodian at
11am and if this doesn't work then we can just drag and drop the documents. No worries if not but thought it might be
worth a try.
Many thanks
Amy
Amy Prime
Solicitor
Womble Bond Dickinson (UK) LLP
‘Stay informed: sign up to our e-alerts
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WBD_000046.000012