WBON0001684 - Email chain between Pete Newsome and Elisa Lukas cc: Andrew Parsons and others re: Queries - Post Office Group Litigation - legally privileged

Evidence on official site

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From: "pete.newsome(, F
To: Elisa Lukas {
Ce: Andrew Parsons <j___ - - b
"Legal.Defence(""""” GRO GRO__ Pe
"Torstein.O.Godeseth; Ps

"Steve. Bansal:

Subject: RE: Queries - Post Office Group Litigation - legally privileged
Date: Fri, 6 Oct 2017 09:03:52 +0000

Importance: Normal
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Elisa

We have now sent through the NDA’s and we are able to make available the KEL system in Bracknell on Monday
assuming the NDA’s are signed in advance. I will check on the approximate cost of the 120 days of effort we would
need to recover if the data extraction options were taken up.

Here are the answers below we discussed in outline yesterday evening.

Regards

Pete

Answers to questions asked last week:

Data extraction

We discussed previously that it takes roughly a day to extract a week's data for one branch. Would you agree that to
extract a week of data for 600 branches would take around 600 weeks?

If PO were to ask FJ to design a process to extract data for branches quicker (without invalidating integrity controls)
could this be done, and roughly how much would it cost?

We have looked at the current process for extracting data and have made the following assumptions and would need
dedicated additional staff members funded. We have based the logic on 600 ARQ requests each for 1 months data:

Approximately 120 days of People effort of around

Elapsed time with current Sec Ops resource would be well over a year to complete even with the ability to run multiple
requests at the same time

Elapsed time of around 9 months could be achieved but would need to engage One dedicated resource for 9 months
to complete within 9 months for the 600 ARQs

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Two dedicated heads could complete in 3-4 months
We cannot complete any quicker than that due to the limitations of the technology and processes used
To further improve the speed of extraction Post Office would need to invest in additional technology which would be

very costly e.g. additional AUW workstations and secure environment to run ARQ's and its likely to take longer to
stand up that technology than it would to complete with the additional heads

Horizon Online introduction

On what date was Horizon Online released? Roll out of HNGX started in January 2010 and completed in October
2010.

Peaks
How many peaks are there in the Peaks System? Open 859

Is it possible to export information from Peaks and what format would this be in? No this is not possible without losing
all the key context

Did I note correctly that many of the Peaks have no impact on branch accounting and can relate to entirely separate
parts of Horizon? Fujitsu use the Peak system to report actions and changes required in all of the systems required to
support the Post Office HNGX solution. This includes not just the live system but also testing and other support
systems and include all areas of the system including infrastructure and the request of any data extracts by Post
Office. The vast majority will have no bearing on the branch accounting system

e We discussed previously the possibility of giving the Claimants’ access to inspect the Peaks System as well as
the KEL. Would you be happy with us offering this? Due to the nature of the Peak system Fujitsu believe the best
course of action is to make available the Peak system for any references that are quoted in the KEL system. The
system is not designed for running searches or clarifying Peaks for a particular functional purpose. It also has
information within it which is both proprietary to Fujitsu and release to a wider audience could cause security issues.

Pete Newsome
Account Manager

Post Office Account, Fujitsu UK&l

Web: http://uk.fujitsu.com

Web: uk fujitsu.com

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s Fujitsu named as

Responsible Business

of the Year
Fujitsu is proud to partner with Action for Children
1.010: Global Intelligence for the CIO. Fujitsu's online resource for ICT leaders
‘Sponsors of the 2015 Rugby World Cup
AAD Pease consider the environment - do you realy need to print this emai?
From: Elisa Lukas; GRO !
Sent: Thursday, Octobs 5, 2017 2:26 PM
To: Newsome, Pete <j

; Bansal,

Hi Pete

Sorry to chase you, I was wondering how you are getting on with the below questions?

Kind regards,

Elisa

Elisa Lukas
Solicitor
Bond Dickinson LLP

Follow Bond Dickinson:

www.bonddickinson.com

We are pleased to announce we will be changing our name to Womble Bond Dickinson (UK) LLP on 1 November 2017:

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A new-breed of Cond Diclaagen

transatlantic law firm

Find obt rare

From: pete.newsome¢ __ GRO I

Sent: 04 October 2017 14:10

To: Elisa Lukas

Ce: Andrew P: ; Legal.Defencé
ot

Steve.Bansal¢ _

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Subject: RE: Queries - Post Office Group Litigation - legally privileged [BD-4A.FID26896945]

Elisa

I will discuss the questions with our team and get back to you shortly.

Pete

Pete Newsome
Account Manager
Post Office Account, Fujitsu UK&l

Tel

E-M

Web: http://uk.fujitsu.com

Web: uk fyjitsu.com

jo fiinle)

* Fujitsu named as

Responsible Business
of the Year

Fujitsu is proud to partner with Action for Children
I-ClO: Global Intelligence for the CIO. Fujitsu's online resource for ICT leaders

Sponsors of the 2015 Rugby World Cup

= Please consider the environment - do you really need to print this email?

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From: Elisa Lukas [/
Sent: Tuesday, October 3, 2017 6:53 PM
To: Newsome, Pete <i ~
Ce: Andrew Parsons <j
Subject: Queries

Hi Pete

Thanks very much for your time today in clarifying the technical documents we can make available. I'm afraid I have a
few more questions to trouble you with though. Is it at all possible to provide answers to these before the end of
Thursday as we are currently finalising our evidence for the upcoming hearing.

Data extraction

We discussed previously that it takes roughly a day to extract a week's data for one branch. Would you agree that to
extract a week of data for 600 branches would take around 600 weeks?

If PO were to ask FJ to design a process to extract data for branches quicker (without invalidating integrity controls)
could this be done, and roughly how much would it cost?

Horizon Online introduction

On what date was Horizon Online released?

Peaks
How many peaks are there in the Peaks System?
Is it possible to export information from Peaks and what format would this be in?

Did I note correctly that many of the Peaks have no impact on branch accounting and can relate to entirely separate
parts of Horizon?

We discussed previously the possibility of giving the Claimants’ access to inspect the Peaks System as well as the
KEL. Would you be happy with us offering this?

Kind regards,

Elisa

Elisa Lukas

Solicitor
Bond Dickinson LLP

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WBONO0001684
WBON0001684

A new-breed of
transatlantic law firm

Find obt rare

Please consider the environment! Do you need to print this email?

al and unyafschmenis fs conidia

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