WBON0001018 - Email from Paul Loraine to Mark Underwood & Andrew Parsons RE: Letter of Response

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“Loraine, Paul" </O=DICKINSON DEES/OU=EXCHANGE ADMINISTRATIVE

"Mark Underwood GRO P

"Parsons, Andrew" < 7 GRO ”

RE: Private & Confidential: Subject to legal privilege

Fri, 24 Jun 2016 10:07:50 -0000

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Mark

On a separate point, we are going to add a section to the response on counterclaims.

Would you be able to provide a list of the individuals in the 91 who have outstanding debts (along with details of what

those debts are)?

Thanks

Paul

From: Mark Underwood; : GRO, j
Sent: 24 June 2016 07:54

To: Loraine, Paul

Subject: RE: Private & Confidential: Subject to legal privilege

Let me know if need anything further and I will see what else I have

Mark

From: Loraine, Paul [mailté __... GRO
Sent: 23 June 2016 13:59

To: Mark Underwoodisro:

Subject: RE: Private & Confidential: Subject to legal privilege

This looks very helpful Mark, cheers.

I will dig out the Castleton judgment too as it looks like there may be some extra detail in there.

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Thanks

Paul

Paul Loraine

Solicitor
Bond Dickinson LLP

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From: Mark Underwood
Sent: 23 June 2016 13:51
To: Loraine, Paul

Subject: Private & Confidential: Subject to legal privilege

Paul — how is the attached?

From: Loraine, Paul [mailto:
Sent: 23 June 2016 10:00
To: Mark Underwood Dave M King
Subject: RE: Horizon

Thanks Mark — after 12 is fine.

Paul Loraine

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Solicitor
Bond Dickinson LLP

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From: Mark Underwood: GRO J
Sent: 23 June 2016 09:
To: Loraine, Paul; Dave M King
Subject: RE: Horizon

Paul, I think I have some information. Give me a nudge if you have not received it by midday as I am in
meetings until then

Mark

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On Thu, Jun 23, 2016 at 8:52 AM +0100, "Dave M King"

Hi Paul

This will need to come from Fujitsu, and I have been told that the appropriate person to arrange the contact is
Mark (ce’d)

Thanks

° Dave King
Senior Technical Security Assurance Manager

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1 Future Walk,
Chesterfield, S49 1PF

From: Loraine, Paul [mailto: GRO I
Sent: 21 June 2016 11:37

To: Dave M King

Subject: FW: Horizon

Morning Dave

I am trying to dig out some information about the Falkirk / Calendar Square bug which affected branches in 2005.

Would you be able to put me in contact with the relevant person at Fujitsu? I was given Pete Newsome’s name initially
but Andy Winn didn’t think he would be best placed.

Thanks

Paul

Paul Loraine

Solicitor
Bond Dickinson LLP

Follow Bond Dickinson:

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www.bonddickinson.com

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From: Loraine, Paul
Sent: 21 June 2016 11:04
To: andrew.wini
Subject: FW: Horizon

Morning Andrew

I wondered if you had any information on the Falkirk Horizon bug please (see below)?

Kath and Shirley said you may be well placed to help.

Thanks

Paul

From: Loraine, Paul
Sent: 17 June 2016 15:17
To: kath.alexanderi
Subject: Horizon

;; Shirley Hailstones (shirley. hailstones¢”

Kath and Shirley

I am currently drafting part of the letter of response to Freeths dealing with the 3 known Horizon bugs.

I wonder if you could help me gather together information you have on the “Falkirk” bug please? Alternatively, if
someone else is better placed to help, if you could point me in the right direction, that would be great. The bug is
referred to in the Castleton judgment and is also known as the Calendar square bug.

To give you an idea of the sort of info I need, I have copied below some draft wording relating to another of the bugs
we are describing (the suspense account bug). I basically need to be able to explain what the bug was, the scale of its
impact, how it was identified and dealt with and whether there were any losses for SPMRs which flowed from it (and if
‘so, how they were dealt with).

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Let me know if you want to discuss.
Thanks

Paul

Suspense Account “14” bug

141 If a postmaster declares on Horizon that there is a discrepancy between the amount of cash and/or stock in the
branch and the amount of cash and/or stock recorded on Horizon (say following an ad hoc cash/stock count),
the discrepancies are removed from the branch's live Horizon records, so that the branch accounts will reflect
the cash and stock actually in the branch at that point. However, the loss or gain in cash and/or stock is
stored as a temporary accounting record in a separate part of Horizon called the "Discrepancy Account".

1.2 At the end of each trading period, the figures in the Discrepancy Account must be cleared before the branch
can move on to trade during the next trading period (called "rolling over" — see paragraphs [X]-[Y] above). To
do this, postmasters transfer the net value of all discrepancies recorded in Discrepancy Account during that
trading period into a "Suspense Account". The postmaster can then settle any loss or gain in the Suspense
Account by making good the discrepancy or settling centrally (as per paragraph [X]).

1.3. After settling any loss or gain, the Suspense Account resets to zero and the branch rolls over.

1.4 The 14 Bug caused a small number of entries in the Suspense Accounts of 14 branches (4 Crown branches
and 10 postmasters) in 2010 to be erroneously reproduced in those branches’ Suspense Accounts for 2011
and 2012.

1.5 [The issue was discovered when 2 postmasters who suffered significant discrepancies raised the matter with
Post Office in early 2012. Post Office began an investigation and identified the bug as being the cause of the
issue in January 2013. In the interim period, Post Office suspended any attempts to recover known losses from
affected postmasters. However, some of the losses were not identified by the postmasters or Post Office at the
time (principally because they were too small to raise any concern) and were therefore settled by postmasters
in the normal course of managing their branches.

1.6 Some of the entries were losses and some were gains. For example, at the Dundas branch, the postmaster put
a £5.84 gain into Suspense in Trading Period 9 of 2010. This £5.84 gain then erroneously re-appeared in the
branch's Suspense Account in Trading Period 9 of 2011 and 2012.

1.7 _ This error forced postmasters to re-settle the incorrect entries in order to clear their Suspense Accounts in 2011
and 2012 despite those entries already having been settled in 2010. In effect, some branches accidentally
benefited from the same gain three times and some branches suffered the same loss three times.

The information in this e-mail and any attachments is confidential and may be legally privileged and protected by law.
dave.m.king GRO “} only is authorised to access this e-mail and an’ attachments. If you are not

please notify Paul.Loraine: {as soon as possible and delete any
copies. Unauthorised use, dissemination, distribution, publication or copying of this communication or attachments is
prohibited and may be unlawful

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Any files attached to this e-mail will have been checked by us with virus detection software before transmission. Bond
Dickinson LLP accepts no liability for any loss or damage which may be caused by software viruses and you should
carry out your own virus checks before opening any attachment.

Content of this email which does not relate to the official business of Bond Dickinson LLP, is neither given nor
endorsed by it.

This email is sent by Bond Dickinson LLP which is a limited liability partnership registered in England and Wales under
number OC317661. Our registered office is 4 More London Riverside, London, SE1 2AU, where a list of members’
names is open to inspection. We use the term partner to refer to a member of the LLP, or an employee or consultant
who is of equivalent standing. Our VAT registration number is GB123393627.

Bond Dickinson LLP is authorised and regulated by the Solicitors Regulation Authority.

JS SSIS JOSIE SOCIO ISIS I OSISIS ISIS ICIS ISISISI I ISIS SIGIR ICICI I ICICI I ICIS ICICI I CIO

This email and any attachments are confidential and intended for the addressee only. If you are not the
named recipient, you must not use, disclose, reproduce, copy or distribute the contents of this
communication. If you have received this in error, please contact the sender by reply email and then delete
this email from your system. Any views or opinions expressed within this email are solely those of the
sender, unless otherwise specifically stated.

POST OFFICE LIMITED is registered in England and Wales no 2154540. Registered Office: Finsbury
Dials, 20 Finsbury Street, London EC2Y 9AQ.

ASE SES OISIEE IIIS OIE SSIES I GEISISI IASI IIIS RACE IG ICAI AISI ACR aA A ok oa ak oe

The information in this e-mail and any attachments is confidential and may be legally privileged and protected by law.
mark.underwood? GRO. k, dave.m.Kingh...-m~GRO----.s0nly is authorised to access this e-mail and any
attachments. lf you are not mark,underwood GRO. lave.m.king! GRO} please notify
Paul.Loraine} is soon as possible and delete any copies. Unauthorised use, dissemination,
distribution, publication or copying of this communication or attachments is prohibited and may be unlawful.

Any files attached to this e-mail will have been checked by us with virus detection software before transmission. Bond
Dickinson LLP accepts no liability for any loss or damage which may be caused by software viruses and you should
carry out your own virus checks before opening any attachment.

Content of this email which does not relate to the official business of Bond Dickinson LLP, is neither given nor
endorsed by it.

This email is sent by Bond Dickinson LLP which is a limited liability partnership registered in England and Wales under
number OC317661. Our registered office is 4 More London Riverside, London, SE1 2AU, where a list of members’
names is open to inspection. We use the term partner to refer to a member of the LLP, or an employee or consultant
who is of equivalent standing. Our VAT registration number is GB123393627.

Bond Dickinson LLP is authorised and regulated by the Solicitors Regulation Authority.

The information in this e-mail and any attachments is confidential and may be legally privileged and protected by law.
mark.underw GRO only is authorised to access this e-mail and any attachments. If you are not
mark.underwoot please notify Paul.Loraine, is soon as possible and delete
any copies. Unauthorised use, dissemination, distribution, publication or copying of this communication or
attachments is prohibited and may be unlawful.

Any files attached to this e-mail will have been checked by us with virus detection software before transmission. Bond
Dickinson LLP accepts no liability for any loss or damage which may be caused by software viruses and you should
carry out your own virus checks before opening any attachment.

Content of this email which does not relate to the official business of Bond Dickinson LLP, is neither given nor
endorsed by it.

This email is sent by Bond Dickinson LLP which is a limited liability partnership registered in England and Wales under
number OC317661. Our registered office is 4 More London Riverside, London, SE1 2AU, where a list of members’
names is open to inspection. We use the term partner to refer to a member of the LLP, or an employee or consultant
who is of equivalent standing. Our VAT registration number is GB123393627.

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Bond Dickinson LLP is authorised and regulated by the Solicitors Regulation Authority.

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