WBON0001962
WBON0001962
From: Amy Prime {
To: Michael Wharton
Subject: FW: Legally Privileged - Fujitsu documents [BD-4A.FID26896945]
Date: Fri, 1 Dec 2017 09:03:28 +0000
Importance: Normal
Attachments: _DISPUTERESOLUTION_37589099(1)_Schedule_to_EDQ.nrl;
_SPREADSHEET_37461815(1)_Schedule_3_Index_-_2017-11-10.nrl
Inline-Images: image001.png; image002.png; image003.png; imagefda6a3.PNG; image78d3a4.PNG;
imagee77113.PNG
Thanks Michael — looks good.
I have made a couple of comments and attached is the Schedule 3 index which I refer to.
Thanks
Amy
Amy Prime
Solicitor
Womble Bond Dickinson (UK) LLP
WOMBLE womblebonddickinson.com
BOND
DICKINSON + Ain)
From: Michael Wharton
Sent: 01 December 2017 08:47
To: Amy Prime
Subject: RE: Legally Privileged - Fujitsu documents [BD-4A.FID26896945]
Amy
See attached — Andy asked me to agree a draft with you for him to review before we send to Fujitsu.
Let me know what you think.
Thanks
Michael
Michael Wharton
Solicitor
Womble Bond Dickinson (UK) LLP
GRO
WOMBLE
BOND
DICKINSON
From: Amy Prime
Sent: 30 November 2017 15:02
To: Michael Wharton
womblebonddickinson.com
A)
Subject: RE: Legally Privileged - Fujitsu documents [BD-4A.FID26896945]
Michael
Agree — if we can insert date ranges in the comment box that would also be helpful.
Thanks
Amy
Amy Prime
Solicitor
Womble Bond Dickinson (UK) LLP
WOMBLE
BOND
DICKINSON
From: Michael Wharton
Sent: 30 November 2017 14:19
To: Amy Prime
womblebonddickinson.com
¥ 0
Subject: RE: Legally Privileged - Fujitsu documents [BD-4A.FID26896945]
WBON0001962
WBON0001962
WBON0001962
WBON0001962
Amy
Andy asked me to check in with you about how to present the schedule for the EDQ following our call with Fujitsu. He
said to keep it high level (1/2 pages max) not least because we're going further than strictly necessary in providing this
information, but also because we don't have full details yet anyway.
I was thinking about a basic table along these lines:
Location of documents Description Comments
eg Dimensions, KEL, Sharepoint, Briefly explain what types of Brief details of any significant
etc. documents are stored in that limitations on our ability to
location and in what format. disclose/the proportionality of
disclosing all of the documents.
What do you think?
Thanks
Michael
Michael Wharton
Solicitor
Womble Bond Dickinson (UK) LLP
WOMBLE womblebonddickinson.com
BOND
DICKINSON ¥0O
From: Amy Prime
Sent: 29 November 2017 19:53
To: Andrew Parsons; Michael Wharton
Subject: FW: Legally Privileged - Fujitsu documents [BD-4A.FID26896945]
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.
WBON0001962
WBON0001962
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 F'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
erga
WOMBLE womblebonddickinson.com
BOND
DICKINSON Ain)
From: Defence Legal (Chris Jay) [mailt
Sent: 29 November 2017 09:18
To: Amy Prime; Lenton Matthew; Newsome Pete
Cc: Michael Wharton; Andrew Parsons; Mark Underwood: GRO i
Subject: RE: Legally Privileged - Fujitsu documents [BD-4A.FID26896945 ]
WBON0001962
WBON0001962
Amy,
11.00 am tomorrow is confirmed.
Look forward to receiving the MI.
Kind regards,
Chris
From: Amy Prime [mailto:
Sent: 28 November 2017 1
To: Defence Legal (Chris Jay’
i GRO.
Ce: Michael Wharton{.
Mark Underwood i
Subject: Legally 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 ( nuk) LLP
WOMBLE womblebonddickinson.com
BOND
’ DICKINSON vy in)
WBON0001962
WBON0001962
Please consider the environment! Do you need to print this email?
The information in this e-mail and any attachments is confidential and lly privileged and protected by law ley GRO} only is authorised to
\d delete any copies.
fas soon as possible
may be unlawful
access this e-mail and any attachments. If you are not Jegal.defenc
Unauthorised use, dissemination, distribution, publication or
"} please notify amy. prim
pying janication or attachments is
Any files attached 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
any loss or damage which may be caused by software viruses and you should carry out yourown virus checks before opening any attachment.
Content of this email which does not relate to the official 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 registered in England and Wales under number 0C317661. Our registered
office is 4 More London Riverside, London, SEI 2AU, where a list of members’ names is open toinspection. 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.
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 is a 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 (Intern ) Limited does not practice law. Please see
www.womblebonddickinson.com/egal notices for further details
Womble Bond Dickinson (UK) LLP is authorised and regulated by the Solicitors Regulation Authority
Unless otherwise stated, this email has been sent from Fujitsu Services Limited (registered in England No
96056); Fujitsu EMEA PLC (registered in England No 2216100) both with registered offices at: 22 Baker
Street, London W1U 3BW; PFU (EMEA) Limited, (registered in England No 1578652) and Fujitsu
Laboratories of Europe Limited (registered in England No. 4153469) both with registered offices at: Hayes
Park Central, Hayes End Road, Hayes, Middlesex, UB4 8FE.
This email is only for the use of its intended recipient. Its contents are subject to a duty of confidence and
may be privileged. Fujitsu does not guarantee that this email has not been intercepted and amended or that it
is virus-free.