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From: Rob Houghton <i GRO
To: Andrew Parsons ;_,
Ce: Rodric Williams GRO >, Mark Underwood!
Jane MacLeod
¢
4 - i
Subject: RE: PLSG meeting on Wednesday 24 May 2017 @12 in Tonbridge (1.11)
Date: Mon, 17 Jul 2017 11:03:23 +0000
Importance: Normal
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Response in >>>>
Read through it all. Two comments - on this statement...
(1) AILIT systems experience software coding errors or bugs which require fixes to be developed
and implemented. For a system of Horizon’s scale, Post Office would characterise the number of
errors or bugs in Horizon requiring fixes as relatively low. In any event, as is noted in paragraph [53
and 54XX] below, there are robust measures in place for their detection, correction and remediation.
Can we say they are relatively low? Where did this come from? Not sure I could say this without further
data. THIS IS FJ's LANGUAGE AND THEY WERE HAPPY WITH IT.
>>> Can they defend it? If so — do we need to assign to FJ; the bit I am concerned about is “Post
Office would characterise the number of errors or bugs in Horizon requiring fixes as relatively low...” I
wouldn’t/ couldn’t !
2; As to paragraph 27, it is admitted that, although Hotizen-was-not- designed te-have this funetionatity this
would not usually be classified as "functionality", there was a highly theoretical possibility that certain Fujitsu
personnel could abuse their privileged user rights to circumvent the protections in the system as designed so as
to edit or delete branch transaction data as described in paragraph [57(4)XX] above.
I don’t think it needs the phrase “ although Horizon was not designed to have this functionality” — its not
functionality — admin access is available in every system globally. I would state — In common with all
systems that have administration access .... (which is all). Rob —I can see the force of this argument. We've
discussed this before with Tony. Although from a technical point of view admin access is not functionality,
we decided that this argument would be overly technical and semantic in the eyes of the judge. Is the
amended language above better?
>>> Suggest this.....
>>> As to paragraph 27, itis admitted that, although Ho Sestettest pes ee iss ae
Hy-be-elassified-as ht tity in common sit other comipater systems and not designed as
part of Horizon Piusetinralley there was ISa ate theoretical possibility that certain Fujitsu personnel could
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abuse their privileged user rights to circumvent the protections in the system as designed so as to edit or delete
branch transaction data as described in paragraph [S7A)XXI above
R
From: Andrew Parsons [mailto! GRO.
Sent: 14 July 2017 14:39
To: Mark Underwood]; Jane MacLeod; Angela Van-Den-Bogerd; Mark R Davies; Stuart Nesbit; Patrick
Bourke; Rob Houghton; Rodric Williams; Thomas P Moran; Tom Wechsler; Mark Ellis; Melanie Corfield
Ce: Kevin Morgan; Amy Prime
Subject: RE: PLSG meeting on Wednesday 24 May 2017 @12 in Tonbridge (1.11)
All
Thanks to all those who have commented so far. We're locking down the Defence at 9am on Monday so that we can
complete all the cross referencing and proof reading before the Tuesday deadline. If you have any final comments,
please let us know before then.
Thanks
Andy
Andrew Parsons
Partner
Bond Dickinson LLP
GRO
Follow Bond Dickinson:
www.bonddickinson.com
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Find out rhare > "i CARLYLE
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From: Andrew Parsons
Sent: 12 July 2017 14:49
To: 'Mark Underwood1'; Jane MacLeod; Angela Van-Den-Bogerd; Mark R Davies; Stuart Nesbit; Patrick Bourke; Rob
Houghton; Rodric Williams; Thomas P Moran; Tom Wechsler; Mark Ellis; Melanie Corfield
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Cc: Kevin Morgan; Amy Prime
Subject: RE: PLSG meeting on Wednesday 24 May 2017 @12 in Tonbridge (1.11)
All
Please find attached the draft Defence for your review and comment. As discussed earlier, if possible please provide
comments rather than amendments to the actual text. I've also attached the Claimants' Generic Particulars of Claim
for reference.
You'll see a few points where input from Deloitte and Fujitsu is needed — we expect to get this today.
Please send any comments to me and Amy Prime (copied).
Thanks
Andy
From: Mark Underwood! [mailto‘ GRO. 1
Sent: 12 July 2017 14:40
To: Jane MacLeod; Angela Van-Den-Bogerd; Mark R Davies; Stuart Nesbit; Patrick Bourke; Rob Houghton; Rodric
Williams; Thomas P Moran; Tom Wechsler; Andrew Parsons; Mark Ellis; Melanie Corfield
Cc: Kevin Morgan
Subject: RE: PLSG meeting on Wednesday 24 May 2017 @12 in Tonbridge (1.11)
Dear all, please find attached the open action list, which includes those taken today.
Ihave highlighted in yellow those that require people’s imminent attention.
Many thanks
Mark
° Mark Underwood
Head of Portfolio: Legal, Risk & Governance
Ground Floor
20 Finsbury Street
2017 Winner of the ‘727 ©? 42
Global Postal
Award for
Customer
Experience
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From: Mark Underwood1
Sent: 11 July 2017 13:46
To: Jane MacLeod; Angela Van-Den-Bogerd; Mark R Davies; Stuart Nesbit; Patrick Bourke; Rob Houghton;
Rodric Williams; Thomas P Moran; Tom Wechsler; 'Parsons, Andrew'; Mark Ellis; Melanie Corfield
Ce: Kevin Morgan
Subject: RE: PLSG meeting on Wednesday 24 May 2017 @12 in Tonbridge (1.11)
Dear all, further to my note earlier today, please find attached the final Decision Paper.
Mark
a Mark Underwood
Head of Portfolio: Legal, Risk & Governance
Ground Floor
20 Finsbury Street
2017 Winner of the ‘°n4°" FY 942
Global Postal
Award for
Customer
Experience
Mobile number:{_
From: Mark Underwood!
Sent: 11 July 2017 09:30
To: Jane MacLeod; Angela Van-Den-Bogerd; Mark R Davies; Stuart Nesbit; Patrick Bourke; Rob Houghton;
Rodric Williams; Thomas P Moran; Tom Wechsler; 'Parsons, Andrew’; Mark Ellis; Melanie Corfield
Ce: Kevin Morgan
Subject: PLSG meeting on Wednesday 24 May 2017 @12 in Tonbridge (1.11)
Dear all,
We have a PLSG meeting on Wednesday 12 July @12 in Tonbridge (1.11). Ahead of that meeting please
find attached:
The Agenda
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Decision Paper: Access to Second Sight
Decision Paper: Standstill Agreement with Fujitsu
Decision Paper: Communications Strategy
Decision Paper: Wider Risks to POL [To follow later today]
Open actions list as at 11 July 2017
Please let me know if you are intending to dial in.
Many thanks, and apologies for the delay in circulating these papers.
Mark
Dial-in numbers:
United Kingdom Freefone
United Kingdom International direct:
Chairperson passcode: 85009207 then #
Participant passcode: 82368934 then #
Mark Underwood
Head of Portfolio: Legal, Risk & Governance
Ground Floor
20 Finsbury Street
2017 Winner of the ‘°r¢on F?Y 940
Global Postal
Award for
Customer
Experience
Mobile number
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