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From: "Michael.Harvey GRO
To: "Parsons, Andrew" < GRO p
Ce: Rodric Williams { GRO
GRO Md E
Subject: RE: Horizon Group Litigation Update - Subject to Privilege [BD-4A .FID26859284]
Date: Wed, 27 Jul 2016 10:11:47 +0000
Importance: Normal
Inline-Images: image005.jpg; image007.jpg; image009.jpg; image011.png
Andy,
Apologies for the delay, unfortunately with holidays and a number of other things happening at once this one has
proven to be a struggle to get the right people to review in a timely manner. I will call you this afternoon after I
have a call with the team to get an update. We will provide you some interim views but our legal team have asked
to get involved given some of the inferences made in the document about Fujitsu and so please let me know what
the absolute deadline is and why this is key.
The primary issue we have at the moment is that we don’t believe the key element regarding the sanctity of the
Core Audit Process comes through in your proposed response and this remains the cornerstone of our inputs to
date and the presentations we’ve done on this point in the past to Post Office and Bond Dickinson. To say that Post
Office has never said the system is “error free” whilst correct fails to make the point that the system is built on the
expectation that the overarching system could have errors over time but the Core Audit Process captures every
submitted “basket” accurately and without error and cannot subsequently be changed but only added to (all such
additions include details as to what created the addition etc. to create a full audit log). Numerous audits have
proved this and it is the Core Audit Process that forms the basis of the first level of analysis with respect to any
suspect fraud or loss and hence why we believe that Horizon is robust.
Kind regards,
Mike
From: Parsons, Andrew [mailto, GRO Hi
Sent: 26 July 2016 1:
To: Harvey, Michael ¢_
Cc: Rodric Williams I
‘ GRO
Mike
I think Rod tried to call you re the below and I left you a message earlier today. Have you got an ETA for your
comments? It's now extremely urgent.
If you could give me a call with an update that would be appreciated.
Kind regards
Andy
Andrew Parsons
Partner
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From: Michael.Harvey
Sent: 22 July 2016 09:07
To: Parsons, Andrew
Ce: Rodric Williams
Subject: RE: Horizon Group Litigation Update - Subject to Privilege [BD-4A.FID26859284]
Andrew,
Apologies for the delay in responding. I have forwarded the previous document to the relevant team members
and I will do the same without the document you attached to the below email. I will catch up with the team to
understand progress but we will not be responding today on either document. We will respond as soon as we can
once we have had chance to consolidate the responses and review them with our legal team.
Kind regards,
Mike
From: Parsons, Andrew [mailto} GRO i
Sent: 21 July 2016 19:
To: Harvey, Michael
Ce: Rodric Williams
Subject: RE: Horizon Group Litigation Update - Subject to Privilege [BD-4A.FID26859284]
Mike
I should be grateful if you could confirm that the review below is underway and that you're on course for a response by
tomorrow.
Please could you also review the attached very short document, which addresses a very specific point around Post
Office's / Fujitsu's capability to change branch data (this overlaps with Deloitte's work).
Apologies for the short notice but please could you again come back with any comments by close tomorrow.
Kind regards
Andy
Andrew Parsons
Partner
www.bonddickinson.com
From: Parsons, Andrew
Sent: 19 July 2011
To: 'Michael.Harvey
Ce: 'Rodric Williams’
Subject: RE: Horizon Group Litigation Update - Subject to Privilege [BD-4A.FID26859284]
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Mike
Further to below, please find attached relevant extracts in relation to Horizon from our draft Letter of Response.
I should be grateful if you (or someone suitably placed at Fujitsu) could review the attached and flag / amend any
points that you consider to be incorrect. If possible, please could you provide your feedback by the end of this week.
Amendments by way of track changes would be perfect.
I've also attached relevant extracts from the Letter of Claim for context (no need to comment on these but feel free to
do so if appropriate).
Please keep circulation of our draft Letter within Fujitsu to the absolute minimum necessary to undertake the above
task. This document has been prepared for litigation purposes and should it be circulated for any other purpose within
Fujitsu, then legal privilege over the document may be lost.
Any questions, please do not hesitate to call.
Kind regards
Andy
Andrew Parsons
Partner
Bond Dickingsw
mak: I GRO
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From: Rodric Williams [mailto!
To: 'Michael.Harvey
Cc: Parsons, Andrew
Subject: RE: Horizon Group Litigation Update - Subject to Privilege
Mike — thanks for calling me back.
Andy Parsons (cc’ed) is the partner at Bond Dickinson leading our defence of the Group Litigation. The Bond
Dickinson team has been preparing a substantive response to the long Letter of Claim received from the claimants’
solicitors Freeths, and I have asked Andy to contact you directly to get Fujitsu’s input on the sections of the
response which concern the services Fujitsu supplies to Post Office.
Andy — can you please drop Mike a line or give him a cal ‘0 get this moving.
With thanks for your continued cooperation, Rodric
From: Rodric Williams
Sent: 18 July 2016 1:
To: 'Michael.Harvey:
Subject: RE: Horizon Group Litigation Update - Subject to Privilege
Mike —I hope this finds you well.
I’ve just left a fairly long voicemail with you (apologies!), but I’d be grateful if you could please give me a call when
you get a moment so I can give you an update on where we have got to in the Group Litigation, our next steps, and
the input we’d like from Fujitsu to help us advance our position.
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With thanks and kind regards, Rodric
From: Rodric Williams
Sent: 15 April 2016 19:00
To: 'Michael.Harvey: ]
Subject: Horizon Group Litigation Update - Subject to Privilege
Mike,
Just to let you know that earlier this week we received a letter from Freeths LLP (a firm of solicitors) advising that
on 11 April 2016 they issued a Claim Form against Post Office in the High Court on behalf of some 91 claimants.
They have not as yet served the Claim Form or any Particulars of Claim on us, and did not send a Pre-Action Letter
of Claim before issuing, so we remain unsighted on the basis of the claim or who has brought it.
So we’re not really that much further forward, although Freeths did say they intend to send us a Letter of Claim by
26 April 2016 (which I’m sure you'll appreciate is rather putting the horse after the cart...).
Apologies for not being in touch sooner — I had intended to give you the courtesy of a call much sooner, but
unfortunately kept running out of time. I am in the office all week next week so will try to give you a call then (one
of the things we will need to discuss is document preservation), but please feel free give me a call any time.
Kind regards, Rodric
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