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From: Andrew Parson:
To: Jonathan Gribben
GRO b
atie Simmonds
“Aimy Prime)” ~ 0 i
Subject: Re: Draft Email to Freeths - KEL Disclosure
Date: Tue, 15 Oct 2019 07:07:26 +0000
Importance: Normal
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Good to go
On Tue, Oct 15, 2019 at 7:56 AM +0100, "Amy Prime";
I wrote:
All
Additional questions in yellow below re Coyne viewing the previous versions.
Jonny — once this has gone to FJ would you be able to ask the same question to Worden, although from memory I
don't think he attended the same demo as Coyne so may not be able to assist?
Thanks
Amy Prime
Associate
Womble Bond Dickinson (UK) LLP
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Andrew Parsons
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From: Amy Prime
Sent: 14 October 2019 20:48
: dr toe. I Jonathan Gribben
GRO I Katie Simm Michael W
Subject: Draft Email to Freeths - KEL Disclosure
All
Please find below a draft email to FJ seeking response so as we can respond to Freeths — all thoughts/comments
welcome.
Thanks
A
{DRAFT}
Dave, Matthew
We have received the attached letter from Freeths in relation to the disclosure of the previous versions of the KELs.
So as Post Office can provide a response to this letter, please could you consider and provide a response to the
following queries — given the importance of these documents to the Horizon Issues Trial, it would be appreciated if
your response are accurate and provide a detailed explanation where possible. If it would be helpful to have a call
to discuss the below before you respond, please let me know.
Scripts
Please could you provide:
1. An explanation of the script(s) and/or methods by which FJ extracted the KELs disclosed in:
a. May 2018 (being KELs generated up to March 2018)
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b. January 2019 (being KELs generated from March to December 2018 and deleted KELs)
2. Ifa script was used, please could you provide us with a copy of the scripts used in each of the above extractions (up
to March 18, March 18 to Dec 18, and Deleted KELs).
Versions
We understand from Matthew's email (attached) that when Horizon moved from Horizon Legacy to Horizon Online
only the current versions of the KELs were kept and migrated — please could you confirm:
a. where the documents were migrated from and to.
b. On migration, was a back-up taken of the non-migrated KELs?
Please could you explain how version numbering operates.
Is it possible to amend a KEL without generating a new version? Does each update create a new version? Is the
version control automatically generated by the database when any change is made to a KEL, or is it necessary to
generate a new version manually?
KEL JSimplins4251P (attached) was raised on 9 September 1999, and last updated on 20 Jan 2003 but is shown as
being "Version 1". Please could you explain why there is a difference between the raised and last updated dates,
but no subsequent versions have been generated? If a KEL has been updated since being raised, should it be
Version 2? Is there any way to track what was updated on 20 Jan 2003?
The same query arises in relation to GMaxwell574P, AChambers3558R and PCarroll2243R.
I
a could we aay webconference demo to show WBD how new versions of a KEL are generated and how
Deletion of KELs
10, Matthew's email refers to a "housekeeping procedure" by which FJ deleted versions where the KEL had more than
3 versions - please could you explain how this procedure operated (for example, were these ad hoc deletions or was
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a policy followed)?
Duplicates
. Matthew's email refers to a “defect in the KEL system" which produced duplicate KELs. Please could further
information by provided on why these duplicates exist and the reasons why they are believed to have been caused
by a defect.
, Have these documents been reviewed to confirm they are exact duplicates? If not, how did FJ learn that they were
duplicates?
Kind regards
Amy