WBON0001113 - Email from Andrew Parsons to Anthony de Garr Robinson, Owain Draper, Amy Prime and others re: Draft Executive Summary

Evidence on official site

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From: "Parsons, Andrew"!
To: Anthony de Garr Robinso
(odrapert GRO

} "Owain Draper

‘Lukas, Elisa"

‘GRO

Subject: FW: Private and Confidential - Subject to Legal Privilege
_DOC_36115520(1)_Privileged Users - Draft Executive Summary.DOCX [BD-
4A.FID26896945]

Date: Mon, 19 Jun 2017 18:55:00 +0000
Importance: Normal
Attachments: _DOC_36115520(1)_Privileged_Users_-_Draft_Executive_Summary.DOCX
Inline-Images: image7ba2fe.JPG; image0d38c1.PNG; image7885e2.PNG; image7ecb34.PNG

Tony, Owain

See attached a draft exec summary for Deloitte's work on remote access. This is a summary that BD drafted and this
morning Deloitte said that they broadly agreed with its conclusions (which was a miracle!). It will likely get watered
down a bit as Deloitte dislike being definitive and tend to shy away from clear views — as you will see from their
comments in the attached.

However, I'd be grateful for your thoughts on whether a summary like the attached is useful for the Defence?

Please bear in mind that Deloitte were not tasked to review the whole of Horizon but asked to focus on the integrity of
transaction data within the system and the effect on the integrity of that data in light of the allegations of "remote
access". The reason for this is that if we can establish that the data in the system is accurate, then we can eliminate a
number of the Claimant's allegations about their accounts simply being manifestly incorrect. This of course does not
rule out the possibility that an error elsewhere in Horizon or in the branch could cause incorrect data to be put into the
accounts, but at least we could say that Horizon keeps an accurate and complete record of that incorrect data.

Andy

Andrew Parsons

Partner
Bond Dickinson LLP

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WOMBLE

From: Westbrook, Mark (UK - Manchester); GRO
Sent: 19 June 2017 09:04 ~

To: Parsons, Andrew

Cc: Keating, Lewis (UK - Leeds)

Subject: Private and Confidential - Subject to Legal Privilege _DOC_36115520(1)_Privileged Users - Draft Executive
Summary.DOCX

Hello Andy,

Some immediate thoughts below (incomplete and will need more time to consider more fully), but thought you’d
appreciate some immediate feedback.

We should probably consider how we structure the presentation of this information between our Firms.

Thanks,

Mark

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