WITN04600300
WITN04600300
Witness Name: Jan Robert Holmes
Statement No.: WITN04600300
Dated: 16 MAY 2023
POST OFFICE HORIZON IT INQUIRY
THIRD WITNESS STATEMENT OF JAN ROBERT HOLMES
I, JAN ROBERT HOLMES, will say as follows:
1. I have been asked to provide a further Rule 9 Witness Statement in regard to my
involvement in the Cleveleys Post Office incident.
2. This witness statement is made to assist the Post Office Horizon IT Inquiry (the
“Inquiry”) with the matters set out in my third Rule 9 Request dated 18 April 2023.
The request was in the form of a six-page 49 point Annex within which questions
were embedded.
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Initial POL contact with Fujitsu POA regarding Cleveleys Post Office
incident.
. lam referred to paragraph 3 of my second witness statement to the Inquiry
(WITN04600200), which says that my first involvement in the Cleveleys Post
Office incident was “via an email from a Pathway colleague, Peter Sewell who
worked in Security, asking if I would be able to take on the task”. I am asked
whether this was the first occasion that a task had been sent to me regarding the
production of a witness statement covering the issue of Horizon equipment at a
particular post office and whether it still contained transaction data. While I had
previously received Witness Statement requests this was, to the best of my
memory, the first such request involving the issue of Horizon equipment to a
particular office and whether it still contained transaction data.
. lam asked about an email, dated 7th August 2003, in which Mr Jim Cruise (POL)
stated that Mrs Wolstenholme (SPM for Cleveleys Post Office) would not release
the equipment because she believed that the expert needed to examine it to
produce his report. He went on to state that “as we know he will not be able to
glean anything from inspecting the equipment”. I am asked whether I agree with
Mr Cruise’s conclusion regarding whether any transaction data could be found on
the Horizon equipment. With regard to transaction data, yes I agree.
. lam referred to a document entitled Review of Expert Witness Report
(FUJ00121504), which was authored by myself, which states that in relation to
POL’s request in February 2003 for a witness statement regarding the Cleveleys
Post Office incident, Fujitsu was unwilling to produce a witness statement at that
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stage. I am asked to explain why this was the case. WITN04600201 has a series
of emails in a chain behind it. The first email, from Kevin Parkin to Jim Cruise
dated 8" August 2003 requested an update on the situation. Jim Cruise
suggested the production of a Witness Statement, signed by Kevin Parkin, to
encourage the Postmaster to reconsider their view that retaining the equipment
for inspection by an Expert might vindicate them. Kevin Parkin took the view that
as he worked for POL the Postmaster may not believe him so the request was
then passed to Peter Sewell at POA Security and subsequently to me. I drafted a
reply to Jim and sought approval from Colin Lenton-Smith on 21% August 2003
(FUJ00121482). Approval was given and I sent an email response to Jim Cruise,
cc Kevin Parkin, on the same date (WITN04600202). That email identifies that
until such time as POA understood more about the situation we would be
unwilling to provide a formal Witness Statement that might be relied on in court
by POL.
. I do not recall having a particular view or an opinion about POL’s request for a
witness statement on the Horizon equipment at the Cleveleys Post Office in
February 2003. It was just another piece of work coming down the line.
. Lam asked who the individuals were at Fujitsu who were involved at this early
stage in providing the response to the POL’s request for a witness statement;
specifically the individuals who assisted by providing me with the information
contained in my email to Jim Cruise, dated 21 August 2003, and individuals who
approved this email (WITN04600202). Initial technical assistance was provided
by Mik Peach (System Support Centre — 3" line support) on 20 August 2003
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((WITN04600301)). Approval was granted by Colin Lenton-Smith on 21S August
2003 ((FUJ00121482)).
POL Request for Fujitsu POA views on Jason Coyne’s Expert Review
8. At paragraph 5 of my second witness statement to the Inquiry, I stated that
nothing further was heard from POL until 6th February 2004 when a letter was
received from POL containing a copy of the Expert’s report. Given that Fujitsu
POA had dealt with POL’s initial request in a timely manner it would be a
professional courtesy for them to respond in a similar fashion. So yes, I was
expecting a more prompt reply than 5 months, especially if there was going to be
further effort to be expended by Fujitsu POA on this topic.
9. 1am asked, following receipt of Mr Baines’ letter on 6th February 2004, what my
understanding was of what POL required of Fujitsu in the context of the
Cleveleys Post Office incident and Jason Coyne’s expert report. Through the
final paragraph of Keith Baines’s letter (POL00095375) seeking our opinion of
the main points of the Expert's report and our assistance in providing information
which might help him change his opinion.
10.A description of the discussion with Jim Cruise on 12 February 2004 was
presented in the internal POA draft report on the Expert's report
((WITN04600203)). I do not have a contemporaneous day-book entry to
substantiate this. At that time our role was to respond to POL on the Expert’s
report which I did in an objective manner. There were some areas where I
agreed with Jim Cruise’s opinion, but only where I felt the Expert had not
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adequately addressed the topic in question. And no, other than what is
expressed in our initial response I cannot recall any specific instances of Jim
Cruise’s criticism of the report.
11.In order to provide a comprehensive, valid and accurate response to the Expert's
report I consulted with a number of people and departments, including but not
limited to :
a. Mark Jones with regard to HSH call volumes ((WITN04600302)) who supplied
an analysis of 6 counter outlets (WITN04600303).
b. Steve Parker with regard to some of the content generally (WITN04600304).
c. Richard Brunskill with regard to helpdesk responsiveness and SLAs in force
in 2000 (WITN04600305).
d. Dave Cooke with regard to Session Stack management in the event of a re-
boot (WITN04600306).
e. Dave Law with regard to any Complaint activity made by Cleveleys during
2000 (WITN04600307).
12.1 am referred to the emails at FUJ00121485, FUJ00121489, FUJ00121490,
FUJ00121498, FUJ00121502, FUJ00121503, FUJ00121511. 1 am asked to
explain the nature of my discussions with Mr Lenton-Smith between 18 — 20
February 2003 concerning Fujitsu’s response to the expert report, and in
particular:
a. What the “data/response that we/POL have used before” that Mr Lenton-
Smith was referring to in his email of 18 February 2004 (FUJ00121489). I
do not know.
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b. In response to Mr Lenton-Smith’s email, I stated that I could “probably get
something from POL investigations”. I do not recall receiving anything
from POL investigations.
13.1 am asked referred to “Fujitsu Services, Report on Cleveleys Post Office”
(version 0.1, 29 March 2004) (POL00095376), as well as the report's later
iterations atPOL00088579, POL00095379 and FUJ00080715.
14.In my evidence to the Inquiry on 16 November 2022 (INQ00001019), I stated that
I suspect I was probably instructed by Martyn or perhaps asked by Security to
draft this report. As to why I was asked to do this report in March 2004, by now
Cleveleys was taking up a lot of my time and the time of my colleagues. Under
any circumstance I would have written a report on how that time was spent and
what the outcomes were, including any opportunities for improvement. It’s always
possible that Martyn Bennett or Security might have asked for its production but I
cannot remember. It’s always possible that I might have initiated it myself.
15.In the report of 29 March 2004, I was of the view that “arguably you we were
brought into this too late”. I did not communicate this to anyone at POL. It was an
POA internal report.
Jason Coyne’s Reply to POA Response to Expert Report and POL decision
to pursue settlement
16.1 am referred to the the emails at FUJ00121535, FUJ00121521, FUJ00121549,
FUJ00121567, FUJ00121571, FUJ00121602 and FUJ00121557. In
POL00095375 Keith Baines specifically asked POA to identify any areas where
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we did not agree with the Expert’s report and for any information or advice that
we could offer that might lead him to change his (Coyne’s) findings. POA’s
response provided the requested information and advice to POL although at that
time we did not know how it would be used by them.
17.With regards to Mr Coyne’s reply to Fujitsu’s response to his expert report
(FUJ00121535), I was a little disappointed that our initial response had been
rejected but perhaps not surprised that an Expert would not change his position.
POA did prepare a second document FUJ00121554 on the topic which is, I
believe, self explanatory.
18.FUJ00121554 was sent to Jim Cruise and I believe Keith Baines. As to whether
POL shared these concerns, remember that we were responding to a request for
assistance from POL, and not expressing any concerns or otherwise of our own,
In the end POL decided not to forward our updated response to the Expert.
19.1 am asked if I can recall if a request was made by POL for me to provide this
further response to Mr Coyne’s reply. FUJ00121536 is a letter sent by Suzanne
Helliwell (Weightman Vizards) to Jim Cruise seeking his views on the Expert's
response to POAs reply to his report. I have a copy of that letter so I must
assume that Jim passed on that request to me resulting in FUJ00121554.
20.As to how I felt about POL’s decision not to forward my further response to Mr
Coyne, I suspect that at the time I was somewhat frustrated but acknowledged
that this was POL’s case to deal with as they saw fit.
21. I can’t comment on how POL interacted with the expert. All I saw were
documents.
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22.In my email of 12 March 2004 to Jim Cruise regarding Jason Coyne’s rejection of
our response to his report, I indicated that Fujitsu would be happy to
“accommodate him at any or all of our locations and arrange such interviews and
access to data that he requires, and would ask that you make this offer to him”
(FUJ00121567 & FUJ00121554). As to how I felt about the fact that POL did
not make this offer to Mr Coyne, POA had gone out of its way to try and
accommodate the Expert's needs and spent time and effort preparing a second
response so it was frustrating to find that document not used. However, as stated
elsewhere, this was a POL matter for them to manage.
23.In my email of 19 March 2004, I provided Mr Lenton-Smith with an update on this
case, following a discussion with Mr Cruise. As to my views on how POL
intended to proceed with regards to the Cleveleys Post Office incident, it was
POL’s business. We had no say on how they conducted themselves in this
matter.
24.In my email of 19 March 2004, I stated that “They recognise the difficulty of
providing objective evidence to counter Coyne's non-specific assertions and I get
the impression they want to avoid a showdown for that reason”. I am asked what
Mr Cruise stated for me to reach this view. Other than what is in my daybook I do
not recall the specifics of the conversation. However, the Expert was appointed
by the Court so it was POL themselves under scrutiny. POA were doing what we
could to assist them but ultimately it was for POL to manage their relationship
with the Expert. The Expert had already indicated his unwillingness to shift his
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position and I suspect POL realised this hence the statement. WITN04600206 is
ascan of my daybook entry of that conversation with Jim Cruise.
25.In my evidence to the Inquiry on 16 November 2022 (INQ00001019, page 166), I
stated that the fear of a precedent being set if Mr Coyne’s report went
unchallenged probably came through Jim Cruise. I do not specifically recall what
Mr Cruise said for me come to this view.
SubPostmaster’s Rejection of POL offer and Preparation for Trial
26.1 am asked to consider FUJ00121637 and FUJ00121639, and explain what my
understanding was of Mandy Talbot's view on the best way to proceed following
the SPM’s rejection of POL’s offer, considering my comment in my email to Mr
Lenton-Smith that “Mandy's view/belief was that the safest way to manage this is
to throw money at it and get a confidentiality agreement signed” (FUJ00121637).
This followed a conversation with Mandy Talbot on 7 May as captured in my
Daybook at the time WITN04600308.
27.With regards to Mandy Talbot's criticism of the expert report, she, like us, felt the
Expert’s report did not provide sufficient specific evidence to support his findings
and was too general.
28.1 am referred to FUJ00121668, FUJ00121689 and FUJ00121702. As to how POL
had interacted with Fujitsu over the course of this litigation, I did not have a view
either way. It was POL’s activity with us providing information and advice as
requested. If they were late in seeking this information then that just added a bit
of pressure to our timeframe. The delay between the problems being reported by
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Cleveleys (2000) and our initial involvement (2003), and the resultant loss of
transaction data and HSH records due to contractual retention periods, just
exacerbated the situation with regard to detail and the Expert’s report. The
possibility of giving evidence in court was a little problematic since I did not know,
at that stage, what that evidence was going to be and, unless it was purely a
statement of known fact and record, and whether I was best qualified to do it.
29. Other than possibly appearing in Court I had no concerns about this case. It was
work. You can see from the numerous emails that I had constantly kept Colin
Lenton-Smith in the information loop and while not my immediate superior Colin
was the Finance and Contract Manager and was on the Senior Management
Team.
30.1 have been provided with emails at FUJ00121686, FUJ00121696, FUJ00121697
and FUJ00121700. I am asked why a conference call was initiated in relation to
the Cleveleys Post Office case, who initiated this conference call, who attended
and what was discussed. I suspect time was getting tight and a level of urgency
was needed. I do not recall who initiated the call. See Daybook scan
WITN04600309 for details of attendees and my notes on the meeting.
31.1 am referred to an email FUJ00121686 which outlines numerous actions which I
was to complete for the purpose of a witness statement being completed on my
behalf. I do not recall if there were any other areas that were under
consideration for inclusion in my witness statement. In fact the opposite occurred
with regard to the deleted transaction data and HSH records and the ‘Clean Start’
evidence where this was available but not included in the Witness Statement.
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While I provided the information it was physically drafted by Suzanne Helliwell of
Weightmans.
32.1 am referred to emails WITN04600214, FUJ00121704 and attachments to
emails concerning my witness statement FUJ00121705, FUJ00121706,
FUJ00121707. I can not recall why my analysis on escalation and site visits were
being withheld from my witness statement. I did provide said information to
Suzanne during the Witness Statement drafting process. See WITN04600310.
POL Settlement with Subpostmaster and Future Litigation Strategy
33.1 am referred to the email at WITN04600215. As to my view on the settlement
amount to Mrs Wolstenholme, up to the 16"" November 2022 that figure I had
been aware of was £25k, which I understood to be roughly the equivalent of 3
months money, reflecting the minimum notice period that POL were obliged to
give to PostMasters. However, while I might have been ‘fairly stunned’ in 2022
(my evidence to the Inquiry on 16 November 2022 (INQ00001019, page 169) at
the amount finally settled it was none of my business and it was for POL to
decide in 2004 how they wanted this to play out.
34.1 am asked how I became aware that Mrs Wolstenholme was going to call other
postmasters as part of her case if the matter proceeded in court and whether this
issue was discussed in the conference call held before the hearing date. The
email WITN04600215 was sent to Bill Mitchell on 16" August 2004, after the
settlement was reached, so I don’t understand the question. Given that this
threat/promise was made after the settlement it would have not been known, by
me anyway, beforehand and was certainly not discussed during the 3 August
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2004 Conference Call. As to whether I discussed the implications of this with any
individuals from POL, other than the email to Bill Michell, no.
35.FUJ00121724 is an internal POA email to two senior colleagues in that
organisation, written to 2004. In my capacity as Risk Manager it was my job to
consider what might constitute a risk to POA or our relationship with POL. At that
time I felt it appropriate to raise this matter internally.
It was my view that it could be construed that POL bought off Mrs Wolstenholme
rather than defend their system was based on earlier conversations with Mandy
Talbot before the case reached Court WITN04600310. See my reply at
paragraph 34s.
36. It was my view that that POL realised “that to expose the HSH transcripts in
Court would not help their case” because if I could see potential pitfalls in the
form and content of the HSH transcripts then a Barrister’s forensically trained
mind would see that as well. I cannot specifically recall what in the HSH
transcripts that would not help POL’s case.
37.1. am asked to explain why I was of the view that POL could not rely on HSH
transcripts to counter claims made by SPMs that they wanted to prosecute. I was
raising a question, not making a statement, about POL’s reliance on HSH
records.
38.With regards to the Shobnall Road case, I believe the original request for a
Fujitsu witness statement was made to Bill Mitchell, POA Security Manager
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39.
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FUJ00121724. I would not raise a Witness Statement unless specifically asked
to. I do not recall such a request being made to me.
I am referred to my evidence to the Inquiry on 16 November 2022
(INQ00001019, page 169), and asked about why I indicated that the Cleveleys
case was a missed opportunity in getting to the bottom of problems with Horizon.
For clarification, in 2022 my response to Mr Blake’s question was ‘yes’ but then
qualified with ‘possibly’. However, in 2004 I had no specific reason to believe that
there were any fundamental problems with Horizon so would not have asked that
question of myself or others.
40.1 am asked whether there were any mistakes in POL or Fujitsu's approach to the
41
Cleveleys Post Office Incident or whether there anything I think I could have
been done differently. No. My only complaint was the time-gaps and little
communication with POL until such time as we were up against the wire to get
stuff done.
Other Matters
.For the avoidance of doubt I would like to present my understanding of the
relationship between POL and POA in the matter of ‘prosecution support’ in
2003/4, that being the timeframe of this Witness Statement. Investigations into,
and any subsequent prosecutions of Postmasters was entirely the responsibility
of POL. It was their decision as to where to target their efforts, who to investigate,
what offices to consider and how far to take those investigations and
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prosecutions. POA’s role, as custodians of the audit data, was to provide audit
data, on request, to meet POL’s needs.
42. However, as POA were responsible for the collection, safekeeping and
subsequent retrieval of data, possibly to be used in court as evidence, we were
sometimes asked to provide a Witness Statement to support POL's case. These
might be to do with how the data audit data was collected, stored and
subsequently retrieved, how the integrity of the data was maintained during that
process; how certain elements of Horizon worked, for example how time was
managed in the system; how support was provided to the POL users of Horizon.
43.As far as I can remember, other than R829C2 there was no contractual obligation
to provide this support service, other than data retention being extended if an
Outlet was being investigated (and we were notified by POL) and the volumes of
extractions. The role evolved over time.
44.POA were not in a position to undertake any kind of ‘due diligence’ of POLs
activities in this area. I am confident that had we attempted anything like this we
would have been told to ‘mind our own business’.
I betove G RO-B ren to be true.
Statement of Truth
JAN ROBERT HOLMES
Dated : 16 bas San 2024
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Index to Third Witness Statement of Jan Robert Holmes
WITN04600300
TN04600300
No I URN Document Description
1. WITN04600200 Second Witness Statement of Jan Holmes — 27
January 2023
2. FUJ00121504 Post Office Account - FAD: 153405 Cleverleys -
Runnymede Ave, Thornton Cleverly, Lancs,
FYS 1DF Review of Expert Witness Report:
Claim CR101947
3 WITN04600201 Email chain re Cleveleys (15.08.2003)
FUJ00121482 Email from Colin Lenton-Smith to Jan R
Holmes re: Cleverleys - Horizon equipment
(21.08.2003)
5 WITN04600202 Email from Jan Holmes to Jim Cruise copied
. Kevin Parkin re Cleveleys — Horizon Equipment
(21.08.2003)
6. WITN04600301 Email from Mik Peach to Jan Holmes re: Horizon
Equipment (20.08.2003)
7. POL00095375 Letter from Keith Baines to Colin Lenton-Smith
re: Post Office Counters Ltd v Mrs Julie
Wolstenholme (05.02.2004)
WITN04600203 Internal POA draft report on the Expert’s report
WITN04600302 Email from Mark Jones to Jan Holmes re: HSH call
volumes (11.02.2004)
40, I WITN04600303 Spreadsheet with HSH 6 Counter Call Analysis
(12.02.2004)
41. I WITN04600304 Email from Steve Parker to Jan Holmes
(17.02.2004)
42, I WITN04600305 Email from Richard Brunskill to Jan Holmes re:
SLAs (18.02.2004)
13. I WITN04600306 Email from Dave Cooke to Jan Holmes re: Stacks
(20.02.2004)
14, I WITN04600307 POL NBSC Complaint from Cleveleys (31.03.2000)
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15, I FUJ00121485 Email from Jan R Holmes to Colin Lenton-
Smith re: Cleverleys Response - Early view
(18.02.2004)
16. I FUJ00121489 Email from Colin Lenton-Smith to Jan R
Holmes re: Cleverleys Response early view
(18.02.2004)
17, I FUJ00121490 Email from Jan R Holmes to Colin Lenton-
Smith re: Cleverleys Response - Early View
(18.02.2004)
18. I FUJ00121498 Email from Jan R Holmes to Colin Lenton -
Smith re: Cleverleys v3 (19.02.2004)
49. I FUJ00121502 Email from Colin Lenton-Smith to Jan R
Holmes re: Cleverleys latest (20.02.2004)
20, I FUJ00121503 Email from Jan R Holmes to Colin Lenton-
Smith re: Cleverleys latest (20.02.2004)
24. I FUJ00121511 Email from Colin Lenton-Smith to Keith Baines
re: Letter re Cleveleys Branch (20.02.2004)
22. I POL00095376 Fujitsu Report on Cleveleys Post Office
(version 0.1) (29.03.2004)
23. I POL00088579 Postmasters' In Service Debt Policy v1.2 draft
24, I POL00095379 Fujitsu Report on Cleveleys Post Office
(version 0.3) (03.08.2004)
25. I FUJ00080715 Fujitsu Services: Report on Cleveleys Post
Office (V.1.0) (01.09.2004)
26. I 1NQ00001019 Transcript from 16 November 2022 public
hearings (16.11.2022)
27. I FUJ00121535 Email from J Coyne to Weightman Vizards re:
Post Office Limited v Mrs J Wolstenholme
(02.03.2004)
28, I FUJ00121521 Email from Jan R Holmes to Colin Lenton-
Smith re: Letter re Cleveleys Branch
(23.02.2004)
29. I FUJ00121549 Email from Jan R Holmes to Colin Lenton-
Smith re: Cleveleys reply (04.03.2004)
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30.
FUJ00121567
Email from Jan R Holmes to Jim Cruise re:
Cleveleys - Reply to Jason Coyne's Paper
(12.03.2004)
31.
FUJ00121571
Email from Jan Holmes to Colin Lenton-Smith
re: Cleveleys Update (19.03.2004)
32.
FUJ00121602
Email from Jan R Holmes to Colin Lenton-
Smith re: FW: Cleveleys PO Mrs J
Wolstenholme. Relates to settlement
negotiations (06.04.2004)
33.
FUJ00121557
Email from Jan R Holmes to Colin Lenton-
Smith re: Cleveleys (11.03.2004)
34.
FUJ00121536
Letter from Suzanne Helliwell (Weightman Vizards)
to Jim Cruise re Witness Availability (03.03.2004)
35.
WITN04600206
Scanned daybook entry conversation
Holmes/Cruise (12.03.2004)
36.
FUJ00121637
Email from Jan Holmes to Colin Lenton-Smith
re 'Cleveleys'. Refers to conversation with
Mandy Talbot (07.06.2004)
37.
FUJ00121639
Email from Jan Holmes to Mandy Tablot re
Cleveleys (07.06.2004)
38.
WITN04600308
Scanned daybook entry conversation
Holmes/Talbot (19.03.2004)
39.
FUJ00121668
Email from Jan Holmes to Colin Lenton-Smith
and lan Lamb re Clevieys Court Case — Update
(30.07.2004)
40.
FUJ00121689
Email from Jan R Holmes to Devinder Purewal
and Peter Jeram re: Programme Board Material
- Wednesday 4th August 2004 (04.08.2004)
41.
FUJ00121702
Email from Jan Holmes to David Barker re:
Cleveley Additional Evidence - Next Steps
(10.08.2004)
42.
FUJ00121686
Email from Jan R Holmes to Keith Baines re:
Actions post conference call — Cleveleys
(03.08.2004)
43.
FUJ00121696
Email from Jan Holmes to Keith Baines, Mandy
Talbot and Susanne Helliwell re 'Clean Start
Evidence - Cleveley' (05.08.2004)
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44.
FUJ00121697
Horizon Migration Acceptance Form by Julie
Wolstenholme (WIT 11) confirming the live
operations on Horizon had taken place as part
of the migration process (10.02.2000)
45.
FUJ00121700
Email from Jan Holmes to Mandy Talbot re:
‘Cleveley Additional Evidence - Next Steps'
(10.08.2004)
46.
WITN04600309
Scanned daybook entry Conference Call
(07.05.2004)
47.
WITN04600214
Email from Jan Holmes to David Barker
(Masons) re final witness statement in
Cleveleys Post Office case (12.08.2004)
48.
FUJ00121704
Email from Jan R Holmes to Colin Lenton-
Smith regarding Mrs J Wolstenholme
(11.08.2004)
49.
FUJ00121705
Notes to go with Jan Holme's statement and
cover email (FUJ00121704) (11.08.2004)
50.
FUJ00121706
Notes to go with Jan Wolstenholme's statement
and cover email (FUJ00121704) (11.08.2004)
51.
FUJ00121707
Draft Witness Statement from Jan Holmes
working for Fujitsu and dealing with the Post
Office, regarding a description of the support
services provided by Fujitsu to the PO in
respect of Horizon and its users (11.08.2004)
52.
WITN04600310
Notes between Holmes and Helliwell on draft
Witness Statement (03.08.2004)
53.
WITN04600215
Email from Jan Holmes to William Mitchell re
settlement of Cleveleys Post Office case
following acceptance of POL offer by Mrs
Wolstenholme (16.08.2004)
54.
FUJ00121724
Email from Jan R Holmes to Colin Lenton-
Smith and Mitchell William regarding Risk
Position on Litigation Support (20.08.2004)
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