WBON0001432
WBON0001432
From: Angela Van-Den-Bogerd GRO ~ 4
To: Emma Campbell-Danesh
Ce: Jonathan Gribbeni_
_t Katie Simmonds
thryn Alexander
—— }, Shirley Hailstones
t GRO I
Subject: RE: Group Litigation - Witness Statement Horizon Issues [WBDUK-AC.FID27032497]
Date: Mon, 4 Mar 2019 13:42:42 +0000
Importance: Normal
Attachments: TA_HNG_Horizon_Help_Transaction_Acknowledgements_130617_(003).pdf;
HOL_Recovery_-_Quick_Reference_Guide_v5_Rev.pdf;
Test_Transaction_Completed_on_Horizon_System_in_Training_Room_-_Lepton.docx;
Lepton_-_Session_data_Oct_2012.xlsx; 4._Lepton_(Helen_Rose) _report.docx
Embedded: unnamed; unnamed(1)
Inline-Images: image008.png; image009.png; image010.png; image011.png; image012.png;
image013.png; image014.png; image015.png
Emma
Sorry this has taken a little while but the responses are comprehensive and evidence has been located to support
these.
Any further queries please let me know.
Thanks,
Angela
Angela Van Den Bogerd
Business Improvement Director
1 Floor,Ty Brwydran,
00
Atlantic Close,Llansamlet
Swansea SA7 9FJ
Confidential Information:
This email message is for the sole use of the intended recipient(s) and may contain confidential and privileged information. Any
WBD_001302.000001
WBON0001432
WBON0001432
unauthorised review, use, disclosure or distribution is prohibited. If you are not the intended recipient please contact me by reply
email and destroy all copies of the original message.
From: Emma Campbell-Danes!
Sent: 28 February 2019 14:10
To: Angela Van-Den-Bogerd/ Ses i)
Cc: Jonathan Gribbeni GRO I Katie Simmonds!
Kathryn Alexander! GRO } Shirley Hailstones I GRO i
Subject: RE: Group Litigation - Witness Statement Horizon Issues [WBDUK-AC.FID27032497]
Angela
Apologies, we have been asked a number of questions in relation to the comments you made on the Coyne report
document (attached again for ease). We would be grateful if you would be able to provide your answers to these
further questions.
Please ignore the questions about whether the documents are in the trial bundle, we will of course pick these up and
check.
Many thanks in advance,
Emma
Emma Campbell-Danesh
Solicitor
Womble Bond Dickinson (UK) LLP.
d:
Stay informed: sign up to our e-alerts
WOMBLE womblebonddickinson.com
BOND
DICKINSON . Ain)
From: Anthony de Garr Robinson {
Sent: 27 February 2019 14:17
WBD_001302.000002
WBON0001432
WBON0001432
To: Emma Campbell-Danesh; Simon Henderson { GRO. }
Owain Draper
Cc: Jonathan Gribben; Andrew Parsons
Subject: RE: Group Litigation - Witness Statement Horizon Issues [WBDUK-AC.FID27032497]
Dear Emma,
I don't know if you are the right person to address these points to. If not, please accept my apologies and pass them on
the person who is dealing with Angela VDB’s evidence.
Thave the following queries and comments on the points made ion Angela’s note responding to Coyne 2:
1. Coyne 2 para 4.71-4.72:
a. Angela appears to be saying here that, in Legacy Horizon, any transactions inserted by the SSC into a
branch’s transaction log will not have a user ID. But in para 184 of her own statement, Angela says that
a transaction could be inserted into a counter and if this was done when the counter was being used, the
transaction would automatically be given the user ID of that user. Have I misunderstood or is Angela
overstating the position/making a mistake? AVDB response: you have misunderstood/I obviously didn’t
explain it well enough. If a branch user is logged on to the system when SSC inject a transaction, that
transaction will show against that branch user. If there are no users logged on to the system at the
time of SSC injecting a transaction this will show on the transaction log with the user ID missing.
b. Incidentally, how does Angela know how the transaction insertions she describes in paras 18.4 and 18.5
worked in Legacy Horizon? When and how did she acquire this knowledge? AVDB response: I first
started getting close to this level of detail when investigating the claims as part of project Sparrow/
Initial Complaints and Mediation Scheme. The source of my knowledge has come predominately from
information provided by FJ.
. In her final comment on para 4.71 and also on para 4.72, Angela says that any transaction insertions
required strict protocols to be followed, including (1) that Post Office had to approve and (2) the SPM.
had to be told. It may be my fault, by I am not aware of a protocol requiring (2) (I’m not sure about (1),
come to think of it):
°
i. Is this the position? If so, could someone direct me to the relevant
documents? AVDB response: the attached Knowledge Article is the process documentation
required to be populated with 3 POL authorisers before Fujitsu will accept the instruction
to process any transaction insertions etc. Those POL people involved in the authorisation
process are not aware of a policy document setting out the approach however there are
email chains requesting the authorisation from 3 approvers within POL before FJ will
resolve the situation. Email is attached as an example.
ii. How does Angela know that this is the position — what is her source of.
knowledge? AVDB response: As Support Services Director (April 2015 — Dec 2016) I was
responsible for FSC and as part of this role I had working knowledge of this process. I don’t
recall a policy document of this but rather this information was relayed to me in
discussions with colleagues. Knowledge Articles evidence supports AVDB working
knowledge.
2. Coyne 2 para 4.74-4.76:
a. In response to para 4.74, Angela says that if an SPM follows the recovery procedures and the receipts
that are printed, they will not incur a discrepancy. But what makes her confident enough effectively to
say that there has never been a case where this has not happened?
WBD_001302.000003
WBON0001432
WBON0001432
AVDB response: It is likely that there have been cases where a discrepancy has occurred as a result
of the Horizon user not following the process properly. I am not aware of a particular case but I
could imagine it happening if the Horizon user didn’t take the time to read the instructions
properly. I am not aware of any issues with the accuracy of the recovery process itself so am
confident that the process works as it was designed. Where the recovery process is interrupted by
connectivity issues and the recovery failed (as it did in Burke’s case) then such instances are picked
up (on Failed Recovery Report) and investigated by Fujitsu before being passed to FSC for
corrective action.
b. Angela also says that Burke’s situation is always investigated. Is this definitely the case — even if an
issue is not reported by the SPM? If so, what makes her so sure about this — is some check done by Post
Office or Fujitsu which flags these matters for investigation regardless of what the SPM does and if so,
what check and who is it done by?
AVDB response: A failed recovery event is recorded on the Failed Recovery Report. This is report
generated by Horizon and used by Fujitsu to investigate all instances of failed recovery. Fujitsu then
advise FSC by way of a BIMS report of branches affected; what the impact on the branch is and
what the corrective action is eg ‘manual reconciliation required’ means that FSC will need to issue
a TC to correct a financial discrepancy in the branch accounts.
e
Do we have the document Angela refers to at the end of her comment on para 4.74 — the BIMs report
which says manual reconciliation required? If so, could I please have the POL number of the document
and can you confirm that it is in the trial bundles>?AVDB response: Yes WBD have it
d. At the end of her comment on para 4.75, Angela says that SPMs are required to check that the value on
TAs agree with their branch records. Could I please have the POL number of the document which
requires this and can you confirm that it is in the trial bundles? AVDB response: Attached Horizon Help
screen shots — for each of the transactions demonstrated the instruction on screen is ‘Check all cash
and cheques received for these (paystation™/lottery/drop & go) transactions against the TAs
received’
2. Coyne 2 para 4.77 (the Helen Rose report on the Lepton branch reversal):
a. Am I right in thinking that the disconnected session receipts told the Lepton SPM that the relevant
transaction had reversed? Yes
b. Am L also right in thinking that only the SPM has those receipts, they cannot be extracted from Horizon?
They cannot be extracted in receipt format however the detail is documented in the session data extracted
from Credence that was included within the Helen Rose report. Both attached for ease.
Could I please be provided with a copy of a disconnected session receipt to see what it looks like and
how it tells the SPM that the relevant transaction has not been effected? Is there a sample in the trial
bundles anywhere? AVDB response: the HOL Recovery Quick Reference Guide (attached for ease but in
my witness bundle) sets out the steps and has an example Disconnected Session receipt and Recovery
Receipt within
d. The Armstrong/second sight email chain that Angela attaches indicates that the Lepton SPM
(Armstrong?) received three disconnected session receipts several minutes after the transaction. I have
the following questions about this:
e
i. Does this email have a POL number and if so, what is it. Is it in the trial
bundles? WBD to answer
ii. Is this the best evidence we have that Horizon gave him those receipts (I
would rather not use a second sight document if I can avoid it)? As 3.b. above
iii. Is there any other evidence (for example, did Armstrong ever produce
the receipts? Armstrong didn’t present the receipts to Post Office however he did reproduce in
the email from him to Ron Warmington 25 June 2013 11 :34pm. The disconnected session
receipts clearly show that the BT bill for £76.09 had been cancelled and was showing as 0.00.
The £80 LTSB cash withdrawal was showing as 80.00- with instruction of Total due to
customer 80.00. The recovery receipt that was produced at 10.37 shows that the BT bill had
not been processed and that the £76.09 should be given to the customer. And is what Jenkins
WBD_001302.000004
WBON0001432
WBON0001432
says on page 2 of the Helen Rose report evidence —“... row 71 of events 4 to 25 Oct 12.xls
shows that a receipt was generated from the session 537805 (not explicitly but it was the only
session at the time)”?) Yes — this is the recovery receipt advising the postmaster that the BT
bill had not been processed.
iv, Armstrong’s email of 25/06/13 @ 11.34pm quotes the session receipts
that he received. Can someone please take me through those receipts to explain whether it
shows that the BT payment had not been effected? The explanation is detailed above — please
let me know if you still need to be taken through the steps.
v. The later emails also suggest that Armstrong should not have completed
the transaction, given the customer a stamped BT bill and allowed him to leave the premises?
Armstrong didn’t actually complete the transaction as to do so it would have needed to be
completed on the Horizon system ie the basket settled. Date stamping the hardcopy BT bill
confirmed to the customer that Lepton Post Office had taken the payment of £76.09 but unless
the payment was sent to BT it wasn’t completed.Why not? Customers should not leave the
counter until the transaction has completed and in the case of paying a bill until the receipt has
been printed. Bill payment receipts do not print until the basket has been settled. Why should
he have kept the customer at the premises, can could I please have the POL number of the
document which requires this and can you confirm that it is in the trial bundles? Horizon User
Guide; Bar-coded bill payments (includes BT Bill) pages 12- 21 documents the transaction.
I know everyone is very busy but I’d be grateful for as full an answer as possible as soon as possible. Amongst other
things, these will help ensure that Angela does not go off piste and it will help in my preparations to cross examine Mr
Coyne.
Best wishes,
Tony
From: Emma Campbell-Daneshi
Sent: 26 February 2019 15:52
To: Anthony de Garr Robinson.
} Simon Henderson I
__..} Owain Draper
Ce: Jonathan Gribben
Andrew Parsons
Subject: RE: Group Litigation - Witness Statement Horizon Issues [WBDUK-AC.FID27032497]
All,
Please find attached the comments from Angela VDB on Coyne's report.
Many thanks,
Emma
WBD_001302.000005
WBON0001432
WBON0001432
Emma Campbell-Danesh
Solicitor
Womble Bond Dickinson (UK) LLP
‘Stay informed: sign up to our e-alerts
WOMBLE womblebonddickinson.com
BOND
DICKINSON . Ain)
From: Andrew Parsons
Sent: 20 February 2019 14:05
To: Anthony de i
Owain Draper!
Cc: Jonathan Gri 7] Danesh
Subject: FW: Group Litigation - Witness Statement Horizon Issues [WBDUK-AC.FID27032497]
1 Henderson:
Comments from Paul Smith on Coyne's report.
Andrew Parsons
Partner
Womble Bond Dickinson (UK) LLP
‘Stay informed: sign up to our e-alerts
WOMBLE womblebonddickinson.com
BOND
DICKINSON tin)
Sent: 20 February 2019 11:32
To: Emma Campbell-Danesh
Cc: Andrew Parsons; Jonathan Gribben
Subject: RE: Group Litigation - Witness Statement Horizon Issues [WBDUK-AC.FID27032497]
Hi all,
WBD_001302.000006
WBON0001432
WBON0001432
Please see attached.
Where the wording is in yellow, I cannot see something specifically to answer, it appears to be a statement of
displeasure from Mr Coyne.
The answers in RED are provided by Dawn Phillips. Dawn provided the original information in my statement and
therefore needed to provide the clarification.
The answers in Blue, are my comments and answers based on the information provided.
I hope this proves useful. I am currently reviewing my statement as recommended by Bond Solon, and will get
back to you on any minor amendments (I am aware it’s too late for anything major!)
Regards
° Paul Smith
Operations Support Manager
Fire Precautions Officer/FSC H&S
Finance Service Centre
PO Ltd,
No.1 Future Walk,
Chesterfield,
S49 1PF
Private and Confidential - Subject to Legal Privilege:
This email message is for the sole use of the intended recipient(s) and may contain confidential and privileged information. Any unauthorised
review, use, disclosure or distribution is prohibited.
If you are not the intended recipient please contact me by reply email and destroy all copies of the original message.
From: Emma Campbell-Danesh! GRO i
Sent: 11 February 2019 08:09
To: Paul I Smith
Cc: Andrew Parsons! GRO Jonathan Gribben {”
Subject: Group Litigation - Witness Statement Horizon Issues [WBDUK-AC.FID27032497]
WBD_001302.000007
WBON0001432
WBON0001432
Dear Paul,
The Claimants' expert has produced a supplemental report. In this report he comments on our witness evidence and
the sections which refer to your witness statement have been extracted into the attached word document.
We would be grateful if you could provide your comments on this, particularly if there is anything you think is
inaccurate or misleading. I suggest that the easiest way to do this would be to add your comments in red into the word
document at the relevant sections, but please let me know if you would prefer to discuss this over the phone.
Many thanks,
Emma
Emma Campbell-Danesh
Solicitor
Womble Bond Dickinson (UK) LLP
‘Stay informed: sign up to our e-alerts
WOMBLE womblebonddickinson.com
BOND
DICKINSON Sin)
Please consider the environment! Do you need to print this email?
tachments is confidential and may be
ittachments. If you are not paul i.smithf
, dissemination, distribution, publication oF copyin;
‘The information in this e+ lly privileged and protected by law. paul “Jonly is authorised to
“js soon as possible and delete any
ay be unlawful. Information about how
please notify emma.campbell-daneshf”
OF {his communication or attachments is prohibited and
we use personal data is in our Privaey Policy, on our website.
Any
any loss or dam
hed to this e-mail will have been checked by us with virus detection software before transmission. Womble Bond Dickinson (UK) LLP accepts no liability for
ge 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 offi
business of Womble Bond Dickinson (UK) LLP, is neither given nor endorsed by it.
This email is sent by Womble Bond Dickinson (UK) LLP which is a limited liability partnership r
office is 4 More London Riverside, London, SEI 2AU, where a list of members’ names is open to
employee or consultant who is of equivalent standing. Our VAT registration number is GB12339362
stered in England and Wales under number 0C317661. Our registered
ction. We use the term partner to refer to a member of the LLP, or an
Womble Bond Dickinson (UK) LLP is a member of Womble Bond Dickinson (International) Limited, which consists of independent and autonomous law firms providing
services in the US, the UK, and elsewhere around the world. Each Womble Bond Dickinson entity isa separate legal entity and is not responsible for the acts or omissions of,
nor can bind or obligate, another Womble Bond Dickinson entity. Womble Bond Dickinson (International) Limited does not practice law. Please see
www.womblebonddickinson.com/legal notices for further details,
Womble Bond Dickinson (UK) LLP is authorised and regulated by the Solicitors Regulation Authority
AES EES SISSIES SSSI SEI SSIES AGES ASIC IICIACK ACI IG ICAI ACI ocak aca A ok a acai oe
WBD_001302.000008
WBON0001432
WBON0001432
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.
ASI ESE EI SISSIES ICICISIO I ICI ICC CIOR CCCI CA IR ACAI EAA AER ACA IK AAR EAC AR A A a
“Post Office Limited is committed to protecting your privacy. Information about how we do this can be
found on our website at www.postoffice.co.uk/privacy”
This email has been scanned by the Symantec Email Security.cloud service.
For more information please visit http://www.symanteccloud.com
This email has been scanned by the Symantec Email Security.cloud service.
For more information please visit http://www.symanteccloud.com
WBD_001302.000009