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From: Simon Henderson 4
To: 'Katie Simmonds’ Rebecca Keating
Ce: Jonathan Gribben {__ Lucy Bremner
i GRO GRO p, "Andrew
Parsons" 4 GRO
Subject: RE: 7 additional bug reports [WBDUK-AC.FID 123887118]
Date: Thu, 23
Importance: Normal
May 2019 09:00:03 +0000
Inline-Images: image001.png; image002.png; image003.png
Dear Katie
Rebecca has looked at the bug scripts and the docs you raise queries on below. We then discussed the docs and
the general approach and I set out our thoughts below. Essentially, we think that (i) where a doc has already been
disclosed and is relevant to the story of the bug, it should be put in the TB; (ii) we should not be providing further
disclosure unless we are under an obligation to do so (adverse doc or should have been previously disclosed etc);
and (iii) we should not at this stage be asking 3" parties for further docs.
1am conscious that some of the docs may not be seen as helpful to PO’s case. However, if, as seems to be the
case, they are part of the story of that bug, I think it is artificial to omit them
I think the intention is to upload a big batch of docs: these should form part of that batch.
Any questions, do not hesitate to ask or call
Best
Simon
Bug Name Disclosure/ trial bundle point I Queries for Counsel team I Response from Counsel
pz Bureau de NBSC call logs relating to T. Should we disclose T.No. The NBSC call
Change PC0129767 [F/318.1] show no the NBSC call log log does not appear to
record of a call to the helpdesk by be adverse to our case;
the SPM. 2. Ifso, should the but the point that the
NBSC call log be ‘SPM did not call is or
added to the trial marginal importance
bundle and could have an
alternative
explanation.
2. NIA.
2 Wrong Branch I None None
Customer
Change
25 Tyca Top Up I 2x BIMS (BE.0203284 and ‘ounsel team to confirm if _IYes, add both please.
BE.0203215) have been disclosed _}word versions of these 2 BIMS
with our letter of 22 May 2019, should be added to the trial
although not in word format, [bundle.
26 TPS250 2x OCRs (11819 and 11782) have [Counsel team to confirm if es, add.
been referred to and disclosed but _ {these should be added to the
not uploaded to the trial bundle. _ [trial bundle.
7 TPS ‘None fone
28 Drop and Go T. There are several new T. Counsel team to T. Add: Spreadsheet of
documents that we are in confirm which branch TCs run by
the process of documents should be Post Office's Core
disclosing. We have added to the trial Finance team; NBSC
indicated in the bug note bundle. Call Logs confirming
WBD_000160.000001
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WBON0000290
which of these we think SPM reported the
would be helpful to add issue on 20 June 2017
to the trial bundle. and Test report issued
2. Counsel team to by ATOS during
2. There is a document confirm whether we resolution of Drop and]
relating to the further/ should ask ATOS for Go issue.
second fix that we could this document
potentially ask ATOS for. 2. Donot ask for this
I'm not sure precisely
how long it would take to
obtain this but my initial
view was not to ask for
this as doing so will
generate further
disclosure and potentially
draw Freeths' attention to
the further instance of the
issue and the
shortcomings in the
additional document.
original fix.
29 I Network Banking I I. There are OCRs and I T. Counsel team to T. Add
Peak (embedded in the confirm which 2. Given this is
bug note) that are documents should be ing di
disclosed but not in the added to the trial being disclosed,
trial bundle. bundle. adel ta TH
2. Weare in the process of 2. Counsel team to
disclosing the NBSC call confirm if the NBSC
logs and Remedies call logs and
Report (as well as finding Remedies Report,
out and including once disclosed, these
information about where should be added to the
the Remedies Report trial bundle,
came from i.e. which
database).
From: Katie Simmonds [mailto:
Sent: 22 May 2019 15:59 .
To: Rebecca Keating Simon Henderson +
Ce: Jonathan GribbenI GRO “I Lucy Bremne
Atkinson {- .
Subject: 7 additional bug reports [WBDUK-AC.FID123887118]
Rebecca, Simon,
As promised, please find attached copies of the 7 additional bug reports. As discussed yesterday, these have not
been reviewed by Andy. I have included our queries regarding disclosure and the addition of documents to the trial
bundle in the below table below. In terms of timings for adding documents to the trial bundle, we propose to keep a
record of any and add these to the list Tony sends through before trial so that everything can be added in one go,
unless you need the trial bundle references sooner.
Kind regards
Katie
Bug Name Disclosure/ trial bundle point Queries for Counsel team
23 Bureau de Change NBSC call logs relating to PC0129767 1. Should we disclose the NBSC
[F/318.1] show no record of a call to the call log
helpdesk by the SPM.
2. If so, should the NBSC call
log be added to the trial
bundle
24 Wrong Branch None None
Customer Change
25 Lyca Top Up 2x BIMS (BE.0203284 and BE.0203215) [Counsel team to confirm if word
have been disclosed with our letter of 22 \versions of these 2 BIMS should be
WBD_000160.000002
WBONO000290
WBON0000290
May 2019, although not in word format. _jadded to the trial bundle.
26 TPS250 2 x OCRs (11819 and 11782) have been [Counsel team to confirm if these
referred to and disclosed but not should be added to the trial bundle.
uploaded to the trial bundle.
27 TPS None None
28 Drop and Go 1. There are several new 1. Counsel team to confirm
documents that we are in the which documents should be
process of disclosing. We have added to the trial bundle.
indicated in the bug note which
of these we think would be
helpful to add to the trial bundle.
2. Counsel team to confirm
2. There is a document relating to whether we should ask ATOS
the further/ second fix that we for this document
could potentially ask ATOS for.
I'm not sure precisely how long it
would take to obtain this but my
initial view was not to ask for this
as doing so will generate further
disclosure and potentially draw
Freeths' attention to the further
instance of the issue and the
shortcomings in the original fix.
29 Network Banking 1. There are 2 OCRs and 1 Peak 1. Counsel team to confirm
(embedded in the bug note) that which documents should be
are disclosed but not in the trial added to the trial bundle.
bundle.
2. Counsel team to confirm if the
2. We are in the process of NBSC call logs and Remedies
disclosing the NBSC call logs Report, once disclosed, these
and Remedies Report (as well should be added to the trial
as finding out and including bundle.
information about where the
Remedies Report came from —
ive. which database).
Katie Simmonds
Associate
Womble Bond Dickinson (UK) LLP
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