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Best Practice Group PLC &
London & South East
Prestige House, 106 Baker Street, London WU 6TW
South West & Wales
Aethandune House, Tower Hil, Stawell, Bridgwater TA7 9A)
Midlands & North West (Accounts & Administration)
Oakcroft House, 70 Albert Road West. Bolton BL! SHW
North & Scotland
8 Victoria Quay, Riversway, Preston PR2 2YW
Julie Wolstenholme
21 January 2004
CC: Weightman Vizards
Dear Madam,
Re: Post Office Counters Ltd. -v- Mrs Julie Wolstenholme: Claim Number CR101947
Please find enclosed my brief note after reviewing the papers in the above matter
Z JASON COYNE
fe of 3B
‘=, 2003
Registered in England No. 3903926
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Opinion
Re: Post Office Counters Ltd. -v- Mrs Julie Wolstenholme: Claim Number CR101947
I have been contacted by Weightman Vizards a law firm representing ‘Post Office Counters
LTD’ and Mrs Julie Wolstenholme, an individual, and requested to make initial observations
that would be of value to the court in the matter of “Post Office Counters Ltd -v- Mrs Julie
Wolstenholme” in the Blackpool County Court, Claim number CR101947.
My initial opinion, prior to examination of call logs provided, was that it would be difficult to
establish if the level and type of support calls made by Mrs Wolstenholme were ‘reasonable’ or
otherwise without having access to levels and type of support calls made by a comparable post
office branch. It was explained to me that this direct comparison was not possible, due to such
logs not being available and as a consequence I have been instructed to conduct a more
detailed review of the material already available.
In light of the above I do not consider that I am required at this stage to produce a full expert
witness report as such, and have therefore set out my initial opinions in the format below.
This more detailed examination focused on the following documents provided to me:-
Claim form dated 19 April 2001 and amended Particulars of Claim dated 17 February 2003.
Amended Defence and Counterclaim dated 14 April 2003
Reply and Defence to Counterclaim
Order dated 6 October 2003
Claimant's List of Documents
Defendant's List of Documents
Claimant's witness statement
Defendant's witness statement
Additional set of call logs disclosed by the Claimant to the Defendant.
My observations considering the documents are as follows:
The statement from Ms Elaine Tagg, the retail network manager of the Post Office Ltd, at para
11 stated that:
“Mrs Wolstenholme persisted in telephoning the Horizon System Help Desk in relation to
any problems which she had with the system generally, these problems related to the
use and general operation of the system and were not technical problems relating to
the system.”
This, in my opinion is not a true representation on the evidence that I have had access to. Of
the 90 or so fault logs that I have reviewed, 63 of these are without doubt system related
failures. Only 13 could be considered as Mrs Wolstenholme calling the wrong support help desk
requesting answers to “How do I ..?” type training questions.
The majority of the system issues were screen locks, freezes, and blue screen errors which are
clearly not a fault of Mrs Wolstenholme’s making, but most probably due to faulty computer
hardware software, interfaces or power. In fact, on a detailed view of call 11021413, dated 2
November 2000, Ms Tagg may have witnessed first hand the style of system problems that
Mrs Wolstenholme experienced in her operation of the system. This fault log notes that:
“Elaine reports that one of the counters has a blue screen with the message STOP 0x000000a”
and was advised by the operator to “reboot”.
Although not uncommon in my experience of support helpdesk’s, I find it disconcerting that
the helpdesk’s first line support consistently advised Mrs Wolstenholme to “reboot” the system
(ie. switch the equipment off and back on again), without trying to understand the cause of the
error. It can be noted that a re-boot was advised in 47 out of the 63 occasions where system
errors were logged. This instruction treats the effect and not the cause, leaving the actual fault
which caused the error intact, and with it a recurrence seems inevitable.
Best Practice Group PLC S
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Opinion
The types of faults, as reported in the faults logs were:-
“System Freezing” which is most probably due to either the hardware or interfaces crashing; or
alternatively fully saturated communication lines.
“System Halts displaying...” or “Blue Screen” which are almost certainly hardware faults.
It seems that each time that the system halted, the screen would display an error code. From
this error code, it would have been possible for the helpdesk operatives to establish the detail
of these hardware faults. However, it seems that this type of analysis was not undertaken by
the helpdesk with a simple re-boot being the preferred method of dealing with the issue.
That said, on a number of occasions, certain elements of counter equipment were indeed
exchanged but without any real improvement in the situation until around the end of June
2000.
The number of fault logs reduces after the end of June 2000, this could be due to the system
faults reducing in frequency i.e. being fixed, or simply that Mrs Wolstenholme tired of the
support department telling her to reboot the system (an activity which she could do herself). I
have no information to form an opinion either way.
It is interesting and certainly warrants further examination that in November 2000 the ‘system
freezing’ is reported again with the support operator stating: “They all freeze, but if it gets bad
give us a call and we will investigate” [11084054 dated 8 November 2000]
From the 31* of October (starting at call log number 10253234) there seems to be a number
of logs which talk of ‘large discrepancies’ in stock figures, trial balances with “all sorts of
figures showing minus figures” [Call Log 10311359].
Referenced in call log 11012223 there is a comment noted by the support operative that the
“pm advised that this is an intermittent problem occurring since the counters were upgraded
on 23.10”. Although the documents do not list an upgrade taking place, it does seem that
these “large” reported discrepancies occur very frequently and shortly after this noted
upgrade. Again this should be investigated further as another six system errors were noted in
November which seem to be a resurgence of the earlier, pre-July type errors.
Best Practice Group PLC &
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Opinion
In Summary:-
From a computer system installation perspective it is my opinion that the technology installed
at the Cleveleys sub-post office was clearly defective in elements of its hardware, software or
interfaces. The majority of the errors as noted in the fault logs could not be attributed to being
of Mrs Wolstenholme’s making or operation of the system.
The helpdesk operated by the Post Office would seem to be more focused on ‘closing calls’
than attempting to get to the bottom of the continual recurrence. The instruction to ‘re-boot’
would allow a call to be closed as the postmaster could continue to work once the system had
powered back up.
Without further examination, it is unclear whether the reduction of calls logged between July
and late October 2000 is attributable to a period of comparative system stability or merely
user disillusionment with the helpdesk. What is more clear is that from late October
recurrences of faults, which had been the subject of earlier logged calls, are reported once
again along with worrying ‘discrepancies’ in audits. This may, or may not be to do with an
‘upgrade’ of the counters which seems to have occurred on or around the 23 November 2000,
or may simply be an unconnected recurrence of the earlier faults.
Jason Coyne
20 January 2004
Best Practice Group PLC &
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CPR35 Statement and CV
I confirm that I have made clear in my report those facts that are within my own knowledge
and which I believe to be true, and that the opinions I have expressed represent my true and
complete professional opinion.
I have no known connection with any of the parties, witnesses or advisers involved in this
case.
Under the requirements of the Civil Procedure Rules 1999, as amended in January 2002 I
confirm that I fully understand my duty to the court and I have complied and will continue to
comply with that duty.
My business address is:
Best Practice Group PLC
106 Baker St
London
W1U 6TW
Law Society 2003 Accredited Expert Witness No. 229.
lam a troubleshooting specialist in computer system procurement, implementation, design,
infrastructure, hardware configuration and software development. My experience over the last
15 years is as follows: -
Hardware/infrastructure/operating systems:
Novell;
Windows NT, 3x, 95, 98, 2000,2003, ME, XP;
Unix (most variants), Solaris, Xenix, AIX, VMS;
IBM AS400, RS6000, Sun, Amdahl, DEC (now Compaq), Hewlett Packard and most PC based
equipment;
3COM, Cisco, Aircom;
Ethernet, Token Ring, SNA, CATS and various Fibre Optic configurations.
Server Centric Computing
Internet communications, MPLS, VoIP and VPN
Software development:
Languages — Dataflex, Powerflex, Oracle Forms, Delphi (Pascal), Visual Basic, Foxpro, Dbase,
Access, Informix and Progress;
Databases - Oracle, Informix, Sybase, Sequel, Dbase, Powerflex and Dataflex.
Application Systems design in Manufacturing, Distribution, Mail Order, CRM and Point of sale.
My experience spans the management of around 400 core business installations, of which
approximately 170 were described as failing prior to my engagement. My instructions are often
to provide advice to steer projects to completion
Best Practice Group PLC >
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Best Practice Group PLC &
Technical and Legal News and Advice for 1T Procurement and Dispute Resolution
Mr Jason Coyne
Occupation: Computer and IT Risk Consultant
Organisation: Best Practice Group PLC
Address: 8 Victoria Quay
Riversway
Preston
Lancs
PR2 2YW
(View Location Map)
(View Aerial Photo)
Office Telephone: I
wri: GRO
Fax:
Email: (Cli
Email to Fax:
Article (1) : Is choosing an IT expert witness a gamble? (Jan ‘03)
Article (2) : Responsibilities and Liabilities of Experts in Computer Disputes
Article (3) : In support of lawyers (IT Dispute Resolution and IT Procurement)
Publications: Click here
Areas of Expertise: Head of the company's Forensic and Expert Witness teams
Extensive experience as a technical expert witness
and has been instructed in a number of major cases
Software experience includes the design and implementation
of a number of vertical market systems, including :-
Process and jobbing manufacturing
IT risk management
Distribution
Stock control
Accounting
Order processing
Logistics
Point-of-sale computer systems
Implementation of e-commerce systems
Physical examination of software applications
(specialist experience of installation, administration and
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problem resolution of a number of major operating
systems, including SUN-OS, Solaris, SCO-UNIX,
SCO-XENIX, HP_UX, DG_UX, DEC UNIX, SGI IRIX,
LINUX, AIX Novell, Windows 95,98 and NT)
UNIX and its integration with the desktop
LAN, WAN and 4GL programming
Criminal investigations conducted to ACPO
guidelines, utilising Encase tools.
Best Practice Group PLC has over 30 years' specialist experience
in resolving information technology disputes between users and
suppliers. The company does not accept a matter unless it strongly
believes that it will be able to achieve the client's objectives. As a
final resort, if all else fails, the company acts as expert in detailing
specifically where the system does not work, why it does not work
and the consequential damages the business has suffered during
the period the system has not worked.
On the basis that ‘protection is better than cure' the company
provides a full independent ‘requirements analysis’ in relation
to the installation of new systems and/or software. This can be
used to provide a watertight specification to the IT supplier and
ensures strong contractual protection in the event that something
goes wrong. With systems procurement/specification the company
analyses the requirements of the client's business, correlating these
with the client's present and future IT needs. Further, the company
can advise on the selection of an I.T. supplier, specify the client's
requirements and project manage implementation.
Best Practice Group PLC also has offices at the following locations
- please note that all of these offices may be contacted via the
following (local call rate) central contact telephone and fax nos :-
Tel) GRO
(1) Oakcroft House
70 Albert Road West
Heaton
Bolton
BL1 SHW
(2) Aethandune
Tower Hill
Stawell
Bridgwater
Somerset
TA7 9AJ
(3) Prestige House
106 Baker Street
London
W1U 6TW
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Av. no. of new instructions a year : 20
No. of reports written in last 3 years : 50
No. of court appearances in last 3 years : 1
ADR skills : Arbitration and Mediation
Geographical area of work : All of the UK
fi, gf,
Law Society: $"j¢i3 "2 Entry No. 557 "gay "p’ Entry No. 229 (Click here)
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Best Practice Group PLC &
London & South East
Prestige House, I06 Baker Street, London WU 6TW
South West & Wales
‘Aethandune House, Tower Hill Stawell, Bridgwater TA7 9A)
Midlands & North West (Accounts & Administration)
(Oakcroft House, 70 Albert Road West, Botton BL! SHW
Engagement Instruction neal
8 Victoria Quay, Riversway, Preston PR2 2YW
I GRO
I Client Details I
_— Tie
I Mess MtoRstenboime IInstruction Date I 26/41/2003
————
I Instruction Ref. I 10696
Instruction Title I 10696 (Documentation Review)
I Instruction Description
I This instruction is a joint instruction between Weightman Vizards and Mrs Wolstenholme. This instruction is an estimate, with both
I parties being responsible for 50% of the total fee value. If the time taken to complete the tasks as outlined takes less time than
estimated, then the lower fee will be charged, conversely you will be charged for any additional work undertaken above the estimated
fee. Any work outside of these tasks which we are asked to undertake will be charged on a separate instruction entitled General
Correspondence. This will be invoiced on a time and materials basis in line with our Engagement Terms.
I
1. Expert Witness; Review documentation bundle and provide a brief note outlining what can and cannot be reported upon I
I
I Instruction Value:
1. All charges for this agreed instruction are subject to travel, disbursements, general correspondence and VAT at the prevailing rate. I
2. Note that the times for each element ofthis instruction may vary, but the overall time incorporating all ofthe elements will not be
exceeded without your agreement. I
3. All invoices are paid by Direct Debit as detailed in the Engagement Terms.
4, Any questions that relate to this instruction must be sent to your Case Manager in writing prior to your authorisation of this instruction,
the instruction ata later date, it may not be possible to complete the instruction within the balance of the instruction time and therefore
the issue of a further instruction may be necessary.
Name : JUMe Wersterholme
Position
I
I
I
I 5. I'you request that Best Practice Group stops work on ths instruction prior to completion and you choose to complete
Registered in England No. 3903926