when about the integrity of horizon. when you took_ about the integrity of horizon. when you took over responsibility for the contract _ you took over responsibility for the contract administration team, i became — contract administration team, i became aware of claims that the horizon — became aware of claims that the horizon system itself was generating discrepancies in branches. 0k? back to paragraph 29. at the foot of the pogo _ to paragraph 29. at the foot of the page. what did you mean by becoming, formerly— page. what did you mean by becoming, formerly aware? that was the first time i became aware. i was aware that people were claiming that there might be something wrong with the system but it was only when there were those bugs disclosed that i became aware of them. we bugs disclosed that i became aware of them. ~ ., ., ~'

bugs disclosed that i became aware ofthem. ~ . . , . of them. we looked already at the december 2010 _ of them. we looked already at the december 2010 e-mail _ of them. we looked already at the december 2010 e-mail by - of them. we looked already at the december 2010 e-mail by which . of them. we looked already at the - december 2010 e-mail by which e-mail december 2010 e—mail by which e—mail you were _ december 2010 e—mail by which e—mail you were notified of the receipts and payments? | you were notified of the receipts and payments?— and payments? i was notified in december— and payments? i was notified in december 2010? _ and payments? i was notified in december 2010? | _ and payments? i was notified in december 2010? i wasn't. - and payments? i was notified in december 2010? iwasn't. i- and payments? i was notified in | december 2010? iwasn't. i don't recall that. the document you took me to which was the record of the discussion, i was not aware of that at the time. discussion, i was not aware of that at the time-— discussion, i was not aware of that at the time. . ., ., ,, ., at the time. can we look then at the next pol? second _ at the time. can we look then at the next pol? second page. _ at the time. can we look then at the next pol? second page. the - at the time. can we look then at the next pol? second page. the remotei next pol? second page. the remote access— next pol? second page. the remote access issue, the second line of the quotation, — access issue, the second line of the quotation, came up when we were exploring — quotation, came up when we were exploring solutions around a problem generated _ exploring solutions around a problem generated by the system following a

migration— generated by the system following a migration to horizon online. this issue _ migration to horizon online. this issue was— migration to horizon online. this issue was quickly identified and ethics _ issue was quickly identified and ethics are — issue was quickly identified and ethics are put in place and impacted around _ ethics are put in place and impacted around 60 _ ethics are put in place and impacted around 60 branches. —— and a fix put in place _ around 60 branches. —— and a fix put in place it— around 60 branches. —— and a fix put in place. it meant a loss incurred in place. it meant a loss incurred in a particular wheat in effect to disappear— in a particular wheat in effect to disappear from the system. | in a particular wheat in effect to disappear from the system. i do not recall seeing — disappear from the system. i do not recall seeing this _ disappear from the system. i do not recall seeing this at _ disappear from the system. i do not recall seeing this at all, _ disappear from the system. i do not recall seeing this at all, so - disappear from the system. i do not recall seeing this at all, so for - disappear from the system. i do not recall seeing this at all, so for me i recall seeing this at all, so for me the first time on errors and defects or bugs, whatever word was being used, two were being disclosed to second sight as part of the work. are you shutting your mind to the receipt _ are you shutting your mind to the receipt of— are you shutting your mind to the receipt of the information because you know— receipt of the information because you know the difficulty that it creates — you know the difficulty that it creates for you? not you know the difficulty that it creates for you?— you know the difficulty that it creates for you? not at all. if i had remembered _ creates for you? not at all. if i had remembered seeing - creates for you? not at all. if i had remembered seeing this, | creates for you? not at all. if i | had remembered seeing this, i creates for you? not at all. if i - had remembered seeing this, i would certainly, it would be part of my consciousness going forward. i really cannot remember seeing this at all. it was the first time, it was when simon baker produced those

two anomalies, as he called them. that can come down, thank you. were you not— that can come down, thank you. were you not aware — that can come down, thank you. were you not aware at the time, then, in 0ctoher— you not aware at the time, then, in october 2010, that fujitsu formally notified _ october 2010, that fujitsu formally notified the post office of the receipts — notified the post office of the receipts and payments mismatch? | receipts and payments mismatch? [ was receipts and payments mismatch? was not receipts and payments mismatch? i was not aware of that. were - receipts and payments mismatch? i was not aware of that. were you . receipts and payments mismatch? i | was not aware of that. were you not aware at the — was not aware of that. were you not aware at the time _ was not aware of that. were you not aware at the time that _ was not aware of that. were you not aware at the time that it _ was not aware of that. were you not aware at the time that it happened l aware at the time that it happened again— aware at the time that it happened again in— aware at the time that it happened again in october 2010 of the meeting i again in october 2010 of the meeting i showed _ again in october 2010 of the meeting i showed you, the plan for the meeting — i showed you, the plan for the meeting between the post office and fujitsu _ meeting between the post office and fujitsu to _ meeting between the post office and fujitsu to discuss the receipts and payments — fujitsu to discuss the receipts and payments mismatch? | fujitsu to discuss the receipts and payments mismatch?— fujitsu to discuss the receipts and payments mismatch? i was not aware of that. i payments mismatch? i was not aware of that- i was — payments mismatch? i was not aware of that. i was in _ payments mismatch? i was not aware of that. i was in a _ payments mismatch? i was not aware of that. i was in a different _ payments mismatch? i was not aware of that. i was in a different role - of that. i was in a different role in october, it was only when i came into the head of network services role that i started to get involved. at the time you were not aware of

the provision of notes concerning the provision of notes concerning the receipts and payments mismatch to members of the legal team, the pol to members of the legal team, the pot iegal— to members of the legal team, the pol legal team? to members of the legal team, the pol legalteam? no. in the to members of the legal team, the pol legal team? no. in the context pol legalteam? no. in the context ofthe pol legal team? in the context of the seema pol legal team? tic. in the context of the seema misra case? pol legalteam? no. in the context of the seema misra case? no. - pol legalteam? no. in the context of the seema misra case? no. it i pol legal team? no. in the context l of the seema misra case? no. it was much later that _ of the seema misra case? no. it was much later that i _ of the seema misra case? no. it was much later that i heard _ of the seema misra case? no. it was much later that i heard about - of the seema misra case? no. it was much later that i heard about that i much later that i heard about that case. , , ., much later that i heard about that case. , ~ ., ., ., case. did you know that a meeting was arranged _ case. did you know that a meeting was arranged in _ case. did you know that a meeting was arranged in november - case. did you know that a meeting was arranged in november 2010 i was arranged in november 2010 including — was arranged in november 2010 including mark weaver, mark burley, dave king. _ including mark weaver, mark burley, dave king, will russell, emma langfield, lynn hobbs and anita taytor, — langfield, lynn hobbs and anita taylor, to— langfield, lynn hobbs and anita taylor, to discuss how to resolve the discrepancy is generated by branches, add branches, by the receipts— branches, add branches, by the receipts and payments mismatch? | receipts and payments mismatch? i don't believe i was. this _ receipts and payments mismatch? i don't believe i was. this came - receipts and payments mismatch? i don't believe i was. this came as i receipts and payments mismatch? i don't believe i was. this came as a |

don't believe i was. this came as a siunificant don't believe i was. this came as a significant new— don't believe i was. this came as a significant new news _ don't believe i was. this came as a significant new news to _ don't believe i was. this came as a significant new news to you? - don't believe i was. this came as a significant new news to you? in - significant new news to you? in terms significant new news to you? terms of significant new news to you? in terms of the bugs being disclosed? yes. ~ , ., ., ., ., ., yes. were you aware in that time at mid-2013 of — yes. were you aware in that time at mid-2013 of any _ yes. were you aware in that time at mid-2013 of any discussions - yes. were you aware in that time at mid-2013 of any discussions within l mid—2013 of any discussions within the post _ mid—2013 of any discussions within the post office senior management as to how— the post office senior management as to how high _ the post office senior management as to how high up within the organisation knowledge of the now three—year—old payments had gone? no. three—year—old payments had gone? no 0n— three-year-old payments had gone? no. , , ., ., ,, no. on the publication of the second siuht no. on the publication of the second sight report. — no. on the publication of the second sight report. did _ no. on the publication of the second sight report, did you _ no. on the publication of the second sight report, did you seek _ no. on the publication of the second sight report, did you seek to - sight report, did you seek to ascertain _ sight report, did you seek to ascertain it when the post office first became aware of that bug? sorry. _ first became aware of that bug? sorry. the — first became aware of that bug? sorry, the report that the two bugs, the interim report?— sorry, the report that the two bugs, the interim report? yes. no. sorry, the report that the two bugs, the interim report?- no.- sorry, the report that the two bugs, the interim report?- no. the interim report? yes. no. did you seek to ascertain _ the interim report? yes. no. did you seek to ascertain which _ the interim report? yes. no. did you seek to ascertain which individuals i seek to ascertain which individuals within— seek to ascertain which individuals within the — seek to ascertain which individuals within the post office knew about

that trug? — within the post office knew about that bu ? ., within the post office knew about that bug? no. why not? within the post office knew about that bug?- why not?- within the post office knew about that bug?- why not? that bug? no. why not? because the wa it was that bug? no. why not? because the way it was presented _ that bug? no. why not? because the way it was presented was _ that bug? no. why not? because the way it was presented was that, - that bug? no. why not? because the way it was presented was that, we i way it was presented was that, we have got these bugs, so that was a surprise to me, and i was reassured thatis surprise to me, and i was reassured that is routine and it is being sorted, and i did not push any further on it.— sorted, and i did not push any further on it. ~ , ., ., ., ., further on it. were you aware that the suspense _ further on it. were you aware that the suspense account _ further on it. were you aware that the suspense account which - further on it. were you aware that the suspense account which is - further on it. were you aware that the suspense account which is the j the suspense account which is the second _ the suspense account which is the second of— the suspense account which is the second of the two bugs about which the post _ second of the two bugs about which the post office made a disclosure to second _ the post office made a disclosure to second sight, had in fact been discovered by the post office in fehruary— discovered by the post office in february 2012 before fujitsu? no. february 2012 before fu'itsu? no. did ou february 2012 before fu'itsu? no. did you ask— february 2012 before fujitsu? tic. did you ask similar questions, what do we _ did you ask similar questions, what do we know— did you ask similar questions, what do we know about this bug and when would _ do we know about this bug and when would we _ do we know about this bug and when would we have become the first aware of it? _ would we have become the first aware of it? ., would we have become the first aware of it? no. second sight mentioned a

third of it?- second sight mentioned a third bug, _ of it?- second sight mentioned a third bug, as_ of it? tic. second sight mentioned a third bug, as well. that was known, we have _ third bug, as well. that was known, we have evidence from the post office, — we have evidence from the post office, in — we have evidence from the post office, in true thousand six, —— in 2006. _ office, in true thousand six, —— in 2006. which _ office, in true thousand six, —— in 2006, which offers knowledge of that when reading the second sight report? — when reading the second sight report? -- _ when reading the second sight report? —— was your first knowledge. i report? —— was your first knowledge. i don't _ report? —— was your first knowledge. i don't remember. it was the two bugs that were disclosed, that was my first knowledge, i was aware of a third because there is an exchange in what is being disclosed and i was querying why we had only given second sight two if we already knew about the third but i did not know about the third but i did not know about the third at the time. if it was really _ about the third at the time. if it was really the _ about the third at the time. if it was really the case that the second si-ht was really the case that the second sight report revealed three bugs,

that you — sight report revealed three bugs, that you personally were not previously aware of, surely you would — previously aware of, surely you would have wanted to know how that had happened? for would have wanted to know how that had happened?— had happened? for the third one, i did question _ had happened? for the third one, i did question how— had happened? for the third one, i did question how have _ had happened? for the third one, i did question how have we - had happened? for the third one, i did question how have we only - had happened? for the third one, i did question how have we only now realised there is a third and we had not at the time because if we had become aware and i was not involved in these conversations, but if we had become aware there were a couple of bugs, then surely we should have askedif of bugs, then surely we should have asked if there were any more but i was not involved in those discussions.— was not involved in those discussions. ~ ., , ~ ., discussions. was there any kind of postmortem _ discussions. was there any kind of postmortem which _ discussions. was there any kind of postmortem which examined - discussions. was there any kind of| postmortem which examined when discussions. was there any kind of- postmortem which examined when did the post _ postmortem which examined when did the post office corporately know about _ the post office corporately know about these bugs for the first time? and what— about these bugs for the first time? and what is— about these bugs for the first time? and what is being done with the knowledge that we had? not and what is being done with the knowledge that we had? not that i was aware of _ knowledge that we had? not that i was aware of at _ knowledge that we had? not that i was aware of at the _ knowledge that we had? not that i was aware of at the time. - knowledge that we had? not that i was aware of at the time. the - was aware of at the time. the information that came, it was given

to second sight and i'm not sure, i think i have seen something since that said we did something but i don't remember. i was not involved in those conversations. what don't remember. i was not involved in those conversations.— in those conversations. what was our role in those conversations. what was your role at _ in those conversations. what was your role at the _ in those conversations. what was your role at the time _ in those conversations. what was your role at the time of— in those conversations. what was your role at the time of the - in those conversations. what was i your role at the time of the second sight _ your role at the time of the second sight report? | your role at the time of the second sight report?— sight report? i have been working alontside sight report? i have been working alongside ron _ sight report? i have been working alongside ron and _ sight report? i have been working alongside ron and ian _ sight report? i have been working alongside ron and ian on - sight report? i have been working alongside ron and ian on the - sight report? i have been working i alongside ron and ian on the reviews and my role was ready to facilitate the provision of information to rana, that they needed, and that is what i was doing, going into the business to find out where the information was that we needed for that, and i was also looking at the situation myself which is why i got involved in the leptin case and understanding what had gone wrong in that case. you understanding what had gone wrong in that case. ., ., ., that case. you were leading for the post office? _ that case. you were leading for the post office? sorry? _ that case. you were leading for the post office? sorry? weren't - that case. you were leading for the post office? sorry? weren't you i that case. you were leading for the | post office? sorry? weren't you the lead? no, i— post office? sorry? weren't you the lead? no. lwas— post office? sorry? weren't you the lead? no, i was there _ post office? sorry? weren't you the lead? no, i was there to _

post office? sorry? weren't you the lead? no, i was there to assist i post office? sorry? weren't you the lead? no, i was there to assist in i lead? no, i was there to assist in terms of information _ lead? no, i was there to assist in terms of information to _ lead? no, i was there to assist in terms of information to them. i lead? no, i was there to assist in i terms of information to them. who was the lead _ terms of information to them. who was the lead in _ terms of information to them. who was the lead in terms _ terms of information to them. who was the lead in terms of the engagement with second sight? they were engaged — engagement with second sight? inez were engaged by engagement with second sight? the: were engaged by alice, engagement with second sight? tie:1: were engaged by alice, paul engagement with second sight? ti9:1: were engaged by alice, paul and susan was there at the time, so it was susan really who was the overall lead —— paula. was susan really who was the overall lead -- paula-— lead -- paula. you were in charge for the provision _ lead -- paula. you were in charge for the provision of _ lead -- paula. you were in charge for the provision of information i lead -- paula. you were in charge for the provision of information to j for the provision of information to second _ for the provision of information to second sight from the post office? not formally, i was there to help them. ~ :, :, , not formally, i was there to help them. ~ :, : :, :, them. who was in charge of the rovision them. who was in charge of the provision of _ them. who was in charge of the provision of information? i'm i them. who was in charge of the l provision of information? i'm not sure we ever _ provision of information? i'm not sure we ever defined _ provision of information? i'm not sure we ever defined that - provision of information? i'm notl sure we ever defined that because the whole engagement of second sight at the start and the initial inquiry and then into the scheme, it kind of evolved over time, and even when we started the scheme and were developing it through the working group as we were going forward, and i don't believe there were any roles defined at the start. this

i don't believe there were any roles defined at the start.— defined at the start. this is before jul the defined at the start. this is before july the 8th. _ defined at the start. this is before july the 8th. 2013. _ defined at the start. this is before july the 8th, 2013, so _ defined at the start. this is before july the 8th, 2013, so did - defined at the start. this is before july the 8th, 2013, so did you i july the 8th, 2013, so did you yourself— july the 8th, 2013, so did you yourself consider what impact if any the revelation of the existence of three _ the revelation of the existence of three bugs in the system may have had on _ three bugs in the system may have had on the — three bugs in the system may have had on the criminal prosecutions that the — had on the criminal prosecutions that the post office had mounted sometime successfully over the previous— sometime successfully over the previous decade? no, sometime successfully over the previous decade?— sometime successfully over the previous decade? no, i didn't. i knew we had — previous decade? no, i didn't. i knew we had an _ previous decade? no, i didn't. i knew we had an investigation i previous decade? no, i didn't. i. knew we had an investigation team and i knew we were bringing the prosecutions ourselves, that was not always known to me but that became known to me quite early on. but i had, apart from being reassured that everything, there was a proper process for prosecutions and it was donein process for prosecutions and it was done in line with the code for prosecution, code for prosecutors, i had no insight into that, sol

prosecution, code for prosecutors, i had no insight into that, so i make no connection from those bugs to the previous convictions.— previous convictions. whose responsibility _ previous convictions. whose responsibility was _ previous convictions. whose responsibility was it - previous convictions. whose responsibility was it to i previous convictions. whose | responsibility was it to make previous convictions. whose i responsibility was it to make a connection between the bugs and the prosecutions? that connection between the bugs and the prosecutions?— prosecutions? that would be the letal prosecutions? that would be the legal team- _ prosecutions? that would be the legal team. and _ prosecutions? that would be the legal team. and who _ prosecutions? that would be the legal team. and who in - prosecutions? that would be the l legalteam. and who in particular? in terms legalteam. and who in particular? in terms of — legalteam. and who in particular? in terms of my _ legalteam. and who in particular? in terms of my contact _ legalteam. and who in particular? in terms of my contact with - legalteam. and who in particular? in terms of my contact with legal, | in terms of my contact with legal, it was mostly roderick williams, and i had very little contact with jamail at, and then andrew parsons. so on the publication of the second si-ht so on the publication of the second sight report which mentions the three _ sight report which mentions the three bugs, you are not aware of any investigation or introverted look by the post _ investigation or introverted look by the post office as to when we found out about _ the post office as to when we found out about these bugs and what did we do? i— out about these bugs and what did we do? :, �* ~' out about these bugs and what did we do? :, �*

do? i don't think i was at the time. i have do? i don't think i was at the time. i have seen — do? i don't think i was at the time. i have seen things _ do? i don't think i was at the time. i have seen things through - i have seen things through disclosure that we were looking at past cases but i was not involved in that. :, _ past cases but i was not involved in that. :, :, ;;:: :, that. you say in paragraph 30 that ou were that. you say in paragraph 30 that you were aware — that. you say in paragraph 30 that you were aware before _ that. you say in paragraph 30 that you were aware before july - that. you say in paragraph 30 that you were aware before july 2013 i that. you say in paragraph 30 that| you were aware before july 2013 of general _ you were aware before july 2013 of general rumbles of complaints, had that treen— general rumbles of complaints, had that been for the entirety of your time _ that been for the entirety of your time in _ that been for the entirety of your time in the — that been for the entirety of your time in the post office since horizon _ time in the post office since horizon was introduced since about 2000? _ horizon was introduced since about 2000? :, :, , horizon was introduced since about 2000? :, ., . ,.: horizon was introduced since about 2000? :, :, :, ::':: 2000? no. it was really around 2010, around that time, _ 2000? no. it was really around 2010, around that time, so _ 2000? no. it was really around 2010, around that time, so it _ 2000? no. it was really around 2010, around that time, so it is _ 2000? no. it was really around 2010, around that time, so it is when - 2000? no. it was really around 2010, around that time, so it is when i i around that time, so it is when i took on responsibility for the contracts team and i think at that time, orthereabouts, contracts team and i think at that time, or thereabouts, there was the inside programme, a couple of tv programmes, one in the south and one in the midlands. the programmes, one in the south and one in the midlands.— in the midlands. the rumblings you seak in the midlands. the rumblings you speak about _ in the midlands. the rumblings you speak about is _ in the midlands. the rumblings you speak about is from _ in the midlands. the rumblings you speak about is from about - in the midlands. the rumblings you speak about is from about 2010 i speak about is from about 2010 onwards? —

speak about is from about 2010 onwards? . speak about is from about 2010 onwards? , :, , ,:, onwards? yes. there had been some postmasters — onwards? yes. there had been some postmasters saying _ onwards? yes. there had been some postmasters saying it _ onwards? yes. there had been some postmasters saying it must _ onwards? yes. there had been some postmasters saying it must be i onwards? yes. there had been some postmasters saying it must be the i postmasters saying it must be the system but not that i could have put my finger on at the time. what system but not that i could have put my finger on at the time. what could ou not my finger on at the time. what could you rrot put — my finger on at the time. what could you rrot put your _ my finger on at the time. what could you not put your finger _ my finger on at the time. what could you not put your finger on? - my finger on at the time. what could you not put your finger on? not i my finger on at the time. what could you not put your finger on? not that | you not put your finger on? not that i can you not put your finger on? not that i can remember— you not put your finger on? not that i can remember where _ you not put your finger on? not that i can remember where i _ you not put your finger on? not that i can remember where i heard i you not put your finger on? not that i can remember where i heard that l you not put your finger on? not that l i can remember where i heard that in terms of, there are some issues. it was really about 2010, 2011 when i started getting involved. flan was really about 2010, 2011 when i started getting involved.— started getting involved. can we started getting involved. can we start by looking _ started getting involved. can we start by looking at _ started getting involved. can we start by looking at the _ started getting involved. can we start by looking at the next i started getting involved. can we| start by looking at the next one? if we can have a look at the foot of the page — if we can have a look at the foot of the page. this is 2004.—

the page. this is 2004. remind us our 'ob the page. this is 2004. remind us yourjob would _ the page. this is 2004. remind us yourjob would have _ the page. this is 2004. remind us yourjob would have been - the page. this is 2004. remind us yourjob would have been then? i l the page. this is 2004. remind us. yourjob would have been then? i was head of area — yourjob would have been then? i was head of area for _ yourjob would have been then? i was head of area for the _ yourjob would have been then? i was head of area for the rural— yourjob would have been then? i was head of area for the rural network in wales — head of area for the rural network in wales. :. head of area for the rural network in wales. :, :, . , head of area for the rural network in wales. :, :, _ : :, in wales. the rural agency in wales? yes. in wales. the rural agency in wales? yes- there — in wales. the rural agency in wales? yes- there is — in wales. the rural agency in wales? yes. there is an _ in wales. the rural agency in wales? yes. there is an e-mail _ in wales. the rural agency in wales? yes. there is an e-mail from - in wales. the rural agency in wales? yes. there is an e-mail from the i yes. there is an e—mail from the contract — yes. there is an e—mail from the contract support manager under a heading _ contract support manager under a heading lower eggleton, and she said, _ heading lower eggleton, and she said. i_ heading lower eggleton, and she said, i have passed a file that you sent to _ said, i have passed a file that you sent to rigid ashcroft to look at and request information from fujitsu services _ and request information from fujitsu services -- _ and request information from fujitsu services —— richard. a telling point in the _ services —— richard. a telling point in the case — services —— richard. a telling point in the case is — services —— richard. a telling point in the case is that there are no calls— in the case is that there are no calls to — in the case is that there are no calls to the _ in the case is that there are no calls to the helpline logged and i would _ calls to the helpline logged and i would have thought that if he believed he had a problem, he would have done _ believed he had a problem, he would have done that quite properly, isn't it amazing — have done that quite properly, isn't it amazing that the accountant from a couple _ it amazing that the accountant from a couple of — it amazing that the accountant from a couple of doors away knows enough about _ a couple of doors away knows enough about horizon to put his name to the assertion _ about horizon to put his name to the assertion that it is a system

problem. _ assertion that it is a system problem, and whilst i believe there is no _ problem, and whilst i believe there is no evidence to this, i do not want _ is no evidence to this, i do not want to— is no evidence to this, i do not want to make sweeping assumptions and would _ want to make sweeping assumptions and would rather be certain when the circumstances may lead to termination of contract. richard or one of— termination of contract. richard or one of his — termination of contract. richard or one of his team will be in touch in due course — one of his team will be in touch in due course. and then at the top of the page. — due course. and then at the top of the page, mr ashcroft e—mails you and says— the page, mr ashcroft e—mails you and says he — the page, mr ashcroft e—mails you and says he agrees withjill and he has asked — and says he agrees withjill and he has asked to put together a checklist of obvious things which have _ checklist of obvious things which have caused a discrepancy in the branch— have caused a discrepancy in the branch and — have caused a discrepancy in the branch and if we can discount those it gives _ branch and if we can discount those it gives us — branch and if we can discount those it gives us a — branch and if we can discount those it gives us a greater level of confidence that it really is a postmaster error and he asks you as to whether— postmaster error and he asks you as to whether you have any timescales on this _ to whether you have any timescales on this. why was this being raised with you _ on this. why was this being raised with you first of all?— with you first of all? lower eggleton, _ with you first of all? lower eggleton, even _ with you first of all? lower eggleton, even though i with you first of all? lower| eggleton, even though that with you first of all? lower i eggleton, even though that is with you first of all? lower - eggleton, even though that is not in wales, that would have come under the area that i was responsible for. this is a sub—postmaster raising an

issue _ this is a sub—postmaster raising an issue of— this is a sub—postmaster raising an issue of the — this is a sub—postmaster raising an issue of the horizon system error as a possible _ issue of the horizon system error as a possible cause of a discrepancy and had — a possible cause of a discrepancy and had seemingly deployed the view of an accountant to support his view? — of an accountant to support his view? l— of an accountant to support his view? :. of an accountant to support his view? :, :, :, of an accountant to support his view? . :, :, . ,:, , view? i had forgotten about this until i view? i had forgotten about this until i had _ view? i had forgotten about this until i had this _ view? i had forgotten about this until i had this in _ view? i had forgotten about this until i had this in disclosure, i view? i had forgotten about this| until i had this in disclosure, and i do remember meeting with steve morgan and this brought it back. i did not get disclosed his initial request and whether it came in in writing but back then i would have had somebody working more closely with the branches and i was overseeing. with the branches and i was overseeing-— with the branches and i was overseeing. with the branches and i was overseeina. , , . :, overseeing. does this fall into the cate . o overseeing. does this fall into the category of _ overseeing. does this fall into the category of a _ overseeing. does this fall into the category of a rumbling? _ overseeing. does this fall into the category of a rumbling? in - overseeing. does this fall into the category of a rumbling? in 2004, | overseeing. does this fall into the i category of a rumbling? in 2004, mr moraan category of a rumbling? in 2004, mr morgan has raised concerns, - morgan has raised concerns, obviously, and i did not know where to go with those concerns and then i reached out because i did not know joel campbelljohn at the time. that

was me, she wanted some information from the system, and i had reached out to see where we can get the system for him and i provided it to him. ~ :, , , . system for him and i provided it to him. ,, . :_ him. would this be an early rumbling? _ him. would this be an early rumbling? yes. _ him. would this be an early rumbling? yes. do - him. would this be an early rumbling? yes. do you i him. would this be an early. rumbling? yes. do you know him. would this be an early i rumbling? yes. do you know what him. would this be an early _ rumbling? yes. do you know what was done as a rumbling ?m do you know what was done as a result? _ rumbling? yes. do you know what was done as a result? i _ rumbling? yes. do you know what was done as a result? i sent _ rumbling? yes. do you know what was done as a result? i sent a _ rumbling? yes. do you know what was done as a result? i sent a letter- rumbling? yes. do you know what was done as a result? i sent a letter to i done as a result? i sent a letter to him which — done as a result? i sent a letter to him which i _ done as a result? i sent a letter to him which i saw _ done as a result? i sent a letter to him which i saw in _ done as a result? i sent a letter to him which i saw in disclosure i done as a result? i sent a letter to him which i saw in disclosure and i l him which i saw in disclosure and i provided the horizon logs as he requested, and i don't remember, i had asked him to make the loss unless he could establish something within that but from the information i had from this team, there was nothing in the logs that pointed to the horizon system. but i don't recall what happened after that. let's have a look at the next one.

this is— let's have a look at the next one. this is the — let's have a look at the next one. this is the letter that you wrote to mr morgan. this is the letter that you wrote to mr morgan-— this is the letter that you wrote to mr morgan. yes. the 1st of march, 2004. so mr morgan. yes. the 1st of march, 2004- so you _ mr morgan. 193 the 1st of march, 2004. so you have been supplied mr morgan. 19:3 the 1st of march, 2004. so you have been supplied with a copy— 2004. so you have been supplied with a copy of— 2004. so you have been supplied with a copy of a _ 2004. so you have been supplied with a copy of a transaction log to enable — a copy of a transaction log to enable you further to analyse the cause _ enable you further to analyse the cause of— enable you further to analyse the cause of the discrepancy of £1400. i initiated _ cause of the discrepancy of £1400. i initiated a _ cause of the discrepancy of £1400. i initiated a further examination of the logs— initiated a further examination of the logs which reaffirmed there is no horizon — the logs which reaffirmed there is no horizon related discrepancy, it says _ no horizon related discrepancy, it says in— no horizon related discrepancy, it says in this— no horizon related discrepancy, it says. in this specific case reversing and incorrect remittance that provided that the cash figure declared — that provided that the cash figure declared is correct. all of which appeared — declared is correct. all of which appeared to be in order. my letter previously— appeared to be in order. my letter previously gave you until a date to make _ previously gave you until a date to make good — previously gave you until a date to make good the loss. or provide

supporting evidence that the discrepancy was generated by a systems— discrepancy was generated by a systems error and not a user error. please — systems error and not a user error. please provide the evidence or make -ood please provide the evidence or make good the _ please provide the evidence or make good the loss. yes? yes. when you were asked — good the loss. yes? yes. when you were asked to _ good the loss. yes? 193 when you were asked to become involved in this. _ were asked to become involved in this. did _ were asked to become involved in this, did you wish to understand what _ this, did you wish to understand what the — this, did you wish to understand what the root cause of the discrepancy was? i what the root cause of the discrepancy was? what the root cause of the discrean was? . :, . :, discrepancy was? i wanted to provide the information _ discrepancy was? i wanted to provide the information that _ discrepancy was? i wanted to provide the information that mr _ discrepancy was? i wanted to provide the information that mr morgan i discrepancy was? i wanted to provide the information that mr morgan had i the information that mr morgan had requested so he could understand what had gone on in his branch. but i'm asking, did you want to seek to understand — i'm asking, did you want to seek to understand the root cause? in 2004, there wasn't — understand the root cause? in 2004, there wasn't a _ understand the root cause? in 2004, there wasn't a facility _ understand the root cause? in 2004, there wasn't a facility to _ there wasn't a facility to investigate branch issues like we introduced in the scheme and it was very much the postmaster was

required to produce the evidence to dispute the loss that had been sustained in his branch. horn dispute the loss that had been sustained in his branch. how would a ostmaster sustained in his branch. how would a postmaster or _ sustained in his branch. how would a postmaster or produce _ sustained in his branch. how would a postmaster or produce evidence i sustained in his branch. how would a postmaster or produce evidence to i postmaster or produce evidence to dispute _ postmaster or produce evidence to dispute the loss in relation to a computer— dispute the loss in relation to a computer system to which she had no access? _ computer system to which she had no access? he _ computer system to which she had no access? . . :: , , :, access? he did have access to the comuter access? he did have access to the computer system _ access? he did have access to the computer system and _ access? he did have access to the computer system and it _ access? he did have access to the computer system and it would i access? he did have access to the i computer system and it would have been for 42 days and then he reached out to me to be able to get more information for him which is what i have done so at this point i had resisted as much as i could and i did meet with mr morgan sol resisted as much as i could and i did meet with mr morgan so i don't know if i have done anything further because i cannot see... i have got nothing else to disclose but i remember going to his branch and meeting with him. you remember going to his branch and meeting with him.— remember going to his branch and meeting with him. you asked fu'itsu to roduce meeting with him. you asked fu'itsu to produce the fi meeting with him. you asked fu'itsu to produce the logs i meeting with him. you asked fu'itsu to produce the logs for i meeting with him. you asked fu'itsu to produce the logs for the i meeting with him. you asked fujitsu to produce the logs for the case? i i to produce the logs for the case? i asked to produce the logs for the case? asked our to produce the logs for the case? i asked our team because campbelljohn

is not fujitsu and they reached out to fujitsu, and i said i did not know where to go with this, but i made some inquiries about where do i go to get the information, i was directed towards jill go to get the information, i was directed towardsjill campbelljohn, directed towards jill campbelljohn, and then directed towardsjill campbelljohn, and then i assumed it was the liaison point into fujitsu. liaison point into fu'itsu. knowing what ou liaison point into fu'itsu. knowing what you know — liaison point into fujitsu. knowing what you know now, _ liaison point into fujitsu. knowing what you know now, do _ liaison point into fujitsu. knowing what you know now, do you i liaison point into fujitsu. knowing| what you know now, do you accept liaison point into fujitsu. knowing i what you know now, do you accept it is not _ what you know now, do you accept it is not possible to identify system errors _ is not possible to identify system errors from the logs that were produced _ errors from the logs that were produced alone? if errors from the logs that were produced alone?— produced alone? if there was something — produced alone? if there was something in _ produced alone? if there was something in the _ produced alone? if there was something in the logs, i produced alone? if there was something in the logs, that. produced alone? if there was i something in the logs, that missed produced alone? if there was - something in the logs, that missed a transaction or something, but from the perspective of a postmaster, they would not have known what to look for, and in 2004 i would not have known what to look for either. when you qualified to look at the logs? _ when you qualified to look at the lots? :, when you qualified to look at the logs? no. who was? when you qualified to look at the logs?- who was?— when you qualified to look at the logs?- who was? logs? no. who was? it was richard, and i logs? no. who was? it was richard, and i don't — logs? no. who was? it was richard, and i don't know _ logs? no. who was? it was richard, and i don't know that _ logs? no. who was? it was richard, and i don't know that person, i logs? no. who was? it was richard, and i don't know that person, but i and i don't know that person, but thatis and i don't know that person, but that is the team, i was looking to them for the expertise to provide

them for the expertise to provide the information to mr morgan and when i referred to initiating further analysis, when i referred to initiating furtheranalysis, it when i referred to initiating further analysis, it was from them that that information came. hagar further analysis, it was from them that that information came. how were they qualified — that that information came. how were they qualified to _ that that information came. how were they qualified to analyse _ that that information came. how were they qualified to analyse the - that that information came. how were they qualified to analyse the logs i they qualified to analyse the logs and to— they qualified to analyse the logs and to identify whether a system error caused the discrepancy? | error caused the discrepancy? don't error caused the discrepancy? i don't know. you _ error caused the discrepancy? i don't know. you think- error caused the discrepancy? i don't know. you think they i error caused the discrepancy? i | don't know. you think they were qualified? _ don't know. you think they were qualified? l _ don't know. you think they were qualified? i don't _ don't know. you think they were qualified? i don't know - don't know. you think they were qualified? i don't know if - don't know. you think they were qualified? i don't know if they i don't know. you think they were i qualified? i don't know if they were or not but that _ qualified? i don't know if they were or not but that was _ qualified? i don't know if they were or not but that was the _ qualified? i don't know if they were or not but that was the point i qualified? i don't know if they were or not but that was the point of i or not but that was the point of contact i was directed to within the business. i contact i was directed to within the business. :, :, :, business. i will move on. on to the next one- — business. i will move on. on to the next one- we _ business. i will move on. on to the next one. we are _ business. i will move on. on to the next one. we are still— business. i will move on. on to the next one. we are still in _ business. i will move on. on to the next one. we are still in march i next one. we are still in march 2014 — next one. we are still in march 2014 we — next one. we are still in march 2014. we will see in a moment...

communicate pages 3—4, please? —— can we_ communicate pages 3—4, please? —— can we look— communicate pages 3—4, please? —— can we look at. and if we look at the foot— can we look at. and if we look at the foot of— can we look at. and if we look at the foot of three, thank you, there is an— the foot of three, thank you, there is an e-mail— the foot of three, thank you, there is an e—mailto the foot of three, thank you, there is an e—mail to you and we canjust see the— is an e—mail to you and we canjust see the end— is an e—mail to you and we canjust see the end if_ is an e—mail to you and we canjust see the end if we scroll down. from clive _ see the end if we scroll down. from clive burton, — see the end if we scroll down. from clive burton, the former sub—postmaster accounts team, agents debt, three, — sub—postmaster accounts team, agents debt, three, in chesterfield, what were _ debt, three, in chesterfield, what were they? — debt, three, in chesterfield, what were they? this was within a team in chesterfield. do were they? this was within a team in chesterfield-— chesterfield. do you know what the a . ent debt chesterfield. do you know what the agent debt is? _ chesterfield. do you know what the agent debt is? i _ chesterfield. do you know what the agent debt is? i did _ chesterfield. do you know what the agent debt is? i did not _ chesterfield. do you know what the agent debt is? i did not know - chesterfield. do you know what the agent debt is? i did not know at. chesterfield. do you know what the | agent debt is? i did not know at the time. �* , , ., ~ agent debt is? i did not know at the time. r, ., ~ �* ., agent debt is? i did not know at the time. ., ~ �* .,

time. let's see what mr burton says. mrs puah time. let's see what mr burton says. mrs pugh from _ time. let's see what mr burton says. mrs pugh from the _ time. let's see what mr burton says. mrs pugh from the 21st _ time. let's see what mr burton says. mrs pugh from the 21st of— time. let's see what mr burton says. mrs pugh from the 21st of april, - mrs pugh from the 21st of april, when _ mrs pugh from the 21st of april, when her— mrs pugh from the 21st of april, when her contract the services were suspended. — when her contract the services were suspended, the final audit resulted in a deficiency of £9,000 but many error notices were later issued which — error notices were later issued which increased the overall debt to £31,000. — which increased the overall debt to £31,000, and recovery has been referred — £31,000, and recovery has been referred to — £31,000, and recovery has been referred to legal services to pursue and a _ referred to legal services to pursue and a case — referred to legal services to pursue and a case management conference was heard irr— and a case management conference was heard in 2004 and directions have been _ heard in 2004 and directions have been made. the legal services department have been asked to prepare — department have been asked to prepare a — department have been asked to prepare a number of statements regarding various accounting errors that form _ regarding various accounting errors that form part of the debt and we are irr— that form part of the debt and we are in the — that form part of the debt and we are in the process of preparing these — are in the process of preparing these and _ are in the process of preparing these and there are other issues where _ these and there are other issues where clarification is required and statements are needed. it would be very much— statements are needed. it would be very much appreciated if you could provide _ very much appreciated if you could provide assistance with the following items or say who to contact _ following items or say who to contact. the defence alleges that the introduction of the horizon

system — the introduction of the horizon system itself caused problems and evidence _ system itself caused problems and evidence is needed about the training — evidence is needed about the training given to mrs pugh and evidence — training given to mrs pugh and evidence of the call logs to show whether— evidence of the call logs to show whether she was seeking help in relation — whether she was seeking help in relation to the operation of the system — relation to the operation of the system. telephone link was cut between — system. telephone link was cut between february and june 2001. in a statement _ between february and june 2001. in a statement about closure of the office — statement about closure of the office. and then over the page. generat— office. and then over the page. general statements required as to how the _ general statements required as to how the accounting system worked at a sub-post _ how the accounting system worked at a sub—post office and how documents are graded, _ a sub—post office and how documents are graded, so going back to the previous— are graded, so going back to the previous page and at the bottom, the defence _ previous page and at the bottom, the defence alleges that horizon itself caused _ defence alleges that horizon itself caused problems, yes? yes. would this be one — caused problems, yes? yes. would this be one of _ caused problems, yes? yes would this be one of the category caused problems, yes? 19:3 would this be one of the category of rumblings?— this be one of the category of rumblings? this be one of the category of rumblinus? :, , :, , , , rumblings? from my memory, yes, because, rumblings? from my memory, yes, because. and _ rumblings? from my memory, yes, because, and again _ rumblings? from my memory, yes, because, and again i _ rumblings? from my memory, yes, because, and again i did _ rumblings? from my memory, yes, because, and again i did not- because, and again i did not remember this, because, and again i did not rememberthis, but because, and again i did not remember this, but when i requested

further disclosure to see what i did with this, and i have concluded that at this point this was just a routine request for information, so i forwarded routine request for information, so iforwarded on routine request for information, so i forwarded on to the contract manager that was part of my team. page three, please. is that the email? — page three, please. is that the e-mail? , , , ., , page three, please. is that the e-mail? , , , ., e-mail? yes. emlyn hughes was a contracts manager _ e-mail? yes. emlyn hughes was a contracts manager working - e-mail? yes. emlyn hughes was a contracts manager working within | e-mail? yes. emlyn hughes was a i contracts manager working within my team at the time. and he was more familiar with where to go for the information which is what he has done, reaching out to a number of places. irate done, reaching out to a number of laces. ~ , done, reaching out to a number of laces. . , , places. we can see further up the chain that on _ places. we can see further up the chain that on the _ places. we can see further up the chain that on the 23rd _ places. we can see further up the chain that on the 23rd of- places. we can see further up the chain that on the 23rd of march i places. we can see further up the i chain that on the 23rd of march and then on— chain that on the 23rd of march and then on the — chain that on the 23rd of march and then on the 8th of april, you appear to have _ then on the 8th of april, you appear to have received a list of core logs -- catt—

to have received a list of core logs -- catt logs, — to have received a list of core logs —— call logs, yes? if you look at the middle _ —— call logs, yes? if you look at the middle of page one. -- call logs, yes? if you look at the middle of page one.- —— call logs, yes? if you look at the middle of page one. yes. if you scroll down- — the middle of page one. yes. if you scroll down. the _ the middle of page one. 19:3 if you scroll down. the call the middle of page one. 193 if you scroll down. the call logs between those _ scroll down. the call logs between those dates from this office? yes. i had been copied _ those dates from this office? yes. i had been copied into _ those dates from this office? yes. i had been copied into some - those dates from this office? yes. i had been copied into some of- those dates from this office? yes. i had been copied into some of themj had been copied into some of them but not all of them. can had been copied into some of them but not all of them.— had been copied into some of them but not all of them. can we see what mr huuhes but not all of them. can we see what mr hughes did _ but not all of them. can we see what mr hughes did in _ but not all of them. can we see what mr hughes did in the _ but not all of them. can we see what mr hughes did in the next _ but not all of them. can we see what mr hughes did in the next one? - but not all of them. can we see what mr hughes did in the next one? top| mr hughes did in the next one? top of the _ mr hughes did in the next one? top of the page — mr hughes did in the next one? top of the page. we can see your e—mail. he says. _ of the page. we can see your e—mail. he says, having spoken with glenn regarding — he says, having spoken with glenn regarding the issue below and in particular— regarding the issue below and in particular regarding the horizon question. — particular regarding the horizon question, he suggested i contact you. _ question, he suggested i contact you, mention you supported several offices _ you, mention you supported several offices within the former chester cluster—

offices within the former chester ctuster so— offices within the former chester cluster so if it is possible you went — cluster so if it is possible you went to — cluster so if it is possible you went to provide assistance to mrs pugh— went to provide assistance to mrs pugh in— went to provide assistance to mrs pugh in the early days. so asking the question if it was somebody who went out— the question if it was somebody who went out to — the question if it was somebody who went out to the former chester cluster— went out to the former chester cluster to — went out to the former chester cluster to provide assistance as to whether— cluster to provide assistance as to whether or— cluster to provide assistance as to whether or not they went to that branch? — whether or not they went to that branch? :, :, whether or not they went to that branch? :, ., ., . ., , branch? from that e-mail i can see, es. do branch? from that e-mail i can see, yes- do you — branch? from that e-mail i can see, yes- do you know — branch? from that e-mail i can see, yes. do you know what _ branch? from that e-mail i can see, yes. do you know what happened . branch? from that e-mail i can see, l yes. do you know what happened after this in relation _ yes. do you know what happened after this in relation to _ yes. do you know what happened after this in relation to the _ yes. do you know what happened after this in relation to the sub _ this in relation to the sub postmistress mrs pugh who had raised in her— postmistress mrs pugh who had raised in her defence in county court litigation, _ in her defence in county court litigation, horizon being the problem because of a system fault? i don't problem because of a system fault? don't know problem because of a system fault? i don't know what happened after this. was this not the kind of issue that should _ was this not the kind of issue that should have triggered an investigation, a thorough investigation?— investigation, a thorough investiuation? , ., :, investigation? the investigation would have _ investigation? the investigation would have been _ investigation? the investigation would have been done - investigation? the investigation would have been done by- investigation? the investigation would have been done by the i would have been done by the investigation team at this point. so anything into criminal case, it was

the security investigation team that would have done... but the security investigation team that would have done. . ._ the security investigation team that would have done... but this is about the civil recovery _ would have done... but this is about the civil recovery seeking _ would have done... but this is about the civil recovery seeking to - the civil recovery seeking to recover _ the civil recovery seeking to recover £31,000 from mrs pugh. | recover £31,000 from mrs pugh. i don't recover £31,000 from mrs pugh. don't know. recover £31,000 from mrs pugh. i don't know. this was for me a routine request because in 2001 we had moved from a regionalised structure into the head of area structure, and i don't know what date,it structure, and i don't know what date, it was probably around this date, it was probably around this date, and then all the branch files were distributed into the head of area and then they were reaching out for information and the information they required did not sit within my team which is why i asked emlyn hughes to facilitate the provisional information so i'm not aware of what or if any investigation was done into that at the time. not aware of what or if any investigation was done into that at the time. investigation was done into that at time. do investigation was done into that at time. ,:, ~' ,:, investigation was done into that at time. ,:, ~ ,:, ,:, investigation was done into that at time. ~ :, time. do think some sort of investigation _ time. do think some sort of investigation should - time. do think some sort of investigation should have i time. do think some sort of. investigation should have been time. do think some sort of- investigation should have been done if in legal— investigation should have been done if in legal proceedings, the sub—postmistress is saying the loss that you _ sub—postmistress is saying the loss that you are seeking to cover from