WBON0001961 - Email chain from Amy Prime to Andrew Parsons; Michae; Wharton; Chris Jay, and others, re: Legally Privileged - Fujitsu documents [BD-4A.FID26896945]

Evidence on official site

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From: Amy Prime!
To: Andrew Parsons I GRO } Michael Wharton

Subject: FW: Legally Privileged - Fujitsu documents [BD-4A.FID26896945]
Date: Wed, 29 Nov 2017 19:53:06 +0000
Importance: Normal
Attachments: DISPUTERESOLUTION_36810957(5) AP_fourth_witness_statement.nrl

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Both

I have put a call in our diaries to speak with FJ tomorrow at 10:30am. I may be able to join some of this call but not all
of it.

The purpose of the call is to discuss with FJ them providing a list of locations in which they hold documents which are
potentially relevant to the Group Action and also to provide a heads up on any issues there may be with extracting
these from these locations. It would also be helpful if FJ could provide a list of 4 or 5 individuals who have contact with
the POL IT team who we could list in the EDQ as Fu's key custodians. This list of documents and custodians would
then be inserted as a Schedule to the EDQ.

The current documents / locations I am aware of are:

Technical documents in Dimensions

Known Error Log (do not know what database/software hosts this)

Peaks System (do not know what database/software hosts this)

HSD call logs before June 2014 (note — we are aware of issues with extracting them due to Windows 2003
issues due to be hosted in Powehelp)

Transaction and event data in the Data Centre

Counter logs which had held on the Horizon terminals

SharePoint

Emails (assume Outlook)

Michael — please could you join this call with Andy and then going forward liaise with FJ to produce the schedule of
documents to be included in the EDQ. The EDQ is going to Rod on Monday evening so it would be good to have the
list from FJ by Monday lunchtime. If you read through paragraphs 42, 134 — 152 and 165 -170 of the attached witness
statement you will get a good overview of the current knowledge.

Thank you both
Amy

Amy Prime
Solicitor
Womble Bond Dickinson (UK) LLP

WOMBLE womblebonddickinson.com
BOND
DICKINSON . Ain)

From: Defence Legal (Chris Jay) I GRO

Sent: 29 November 2017 09:18

To: Amy Prime; Lenton Matthew; Newsome Pete

Cc: Michael Wharton; Andrew Parsons; Mark Underwood:
Subject: RE: Legally Privileged - Fujitsu documents [BD-4A\ pibseuseoesy =

Amy,
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11.00 am tomorrow is confirmed.
Look forward to receiving the MI.

Kind regards,
Chris

From: Amy Prime,
Sent: 28 November 2017 14:50
To: Defence Legal (Chris Jay):
i GRO.
Cc: Michael Whartor,

Mark

Subject: Legaliy Privileged - Fujitsu documents [BD-4A.FID26896945]

Chris, Matthew, Pete

Post Office are required to inform the Court of the location in which potentially relevant documents are located.
"Relevant document" is a very broad term and will encompass pretty much all dealings which Fujitsu have had with
Post Office in relation to Horizon and HNG-X spanning emails (both with POL and internally), documents stored in
Dimension, Transaction and Event data, HSD logs, Peaks system and any other document produced by Fujitsu which
relates to Horizon. I appreciate that this may be a large volume of documents.

So as we can understand the documents held by Fujitsu and where they are stored, it would be helpful if we could
have call. Would you be available at 11am on Thursday?

Kind regards
Amy

Amy Prime
Solicitor
Womble Bond Dickinson (UK) LLP

WOMBLE womblebonddickinson.com.
BOND
DICKINSON Ain)

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