whereby en existed in the horizon, whereby on occasion, _ existed in the horizon, whereby on occasion, a — existed in the horizon, whereby on occasion, a lock was not released and a _ occasion, a lock was not released and a second process would then wait for a given— and a second process would then wait fora given time and a second process would then wait for a given time before it timed out and reported in error, saying it could _ and reported in error, saying it could not— and reported in error, saying it could not proceed. the problem could occur_ could not proceed. the problem could occur in _ could not proceed. the problem could occur in various places on the rise in applications, in the initial occurrences a reboot of the counter allowed _ occurrences a reboot of the counter allowed the system to resume proper function _ allowed the system to resume proper function with no data lost. then a third _ function with no data lost. then a third bullet — function with no data lost. then a third bullet point, in some cases, the calendar square branch in particular, the lock problem caused data to _ particular, the lock problem caused data to be — particular, the lock problem caused data to be lost when carrying out transfers — data to be lost when carrying out transfers between different stock units, _ transfers between different stock units, thereby causing receipts and payments— units, thereby causing receipts and payments mismatches. so this is a bug. _ payments mismatches. so this is a bug. would — payments mismatches. so this is a bug, would you agree, that has a real impact— bug, would you agree, that has a real impact on balancing, because it causes _ real impact on balancing, because it causes receipts and payments mismatches?— causes receipts and payments mismatches?- and - causes receipts and payments mismatches? yes. and the fourth bullet point. _ mismatches? yes. and the fourth bullet point, there _

mismatches? yes and the fourth bullet point, there appear to mismatches? 1c; and the fourth bullet point, there appear to have been _ bullet point, there appear to have been instances of these repulsed block _ been instances of these repulsed block errors from at least september 2000 _ block errors from at least september 2000 so _ block errors from at least september 2000. so we get the start date. and in this_ 2000. so we get the start date. and in this instance, a postmaster reported — in this instance, a postmaster reported an error when trying to re-declare — reported an error when trying to re—declare their cash, the call was discussed — re—declare their cash, the call was discussed between various teams from post office _ discussed between various teams from post office and fujitsu and then you -ive post office and fujitsu and then you give some _ post office and fujitsu and then you give some further examples of those. then a _ give some further examples of those. then a known error log, the fifth error point, _ then a known error log, the fifth error point, you give the reference, advise _ error point, you give the reference, advise that — error point, you give the reference, advise that rebooting the counter would _ advise that rebooting the counter would resolve incidents where a message — would resolve incidents where a message reported a timeout, waiting for lock _ message reported a timeout, waiting for lock. some of these also led to receipts— for lock. some of these also led to receipts and payments mismatches, which _ receipts and payments mismatches, which after — receipts and payments mismatches, which after investigation were dealt with by— which after investigation were dealt with by the fujitsu msu team, raising — with by the fujitsu msu team, raising a — with by the fujitsu msu team, raising a report said the post office — raising a report said the post office could issue an error notice, 0ffice could issue an error notice, later— 0ffice could issue an error notice, later known — 0ffice could issue an error notice,

later known as a transaction correction, so the postmaster could reconcile _ correction, so the postmaster could reconcile the accounts. bims reports sit out the progress to the resolution of a business incident, _ the resolution of a business incident, the post office would use the information from the bims report to carry— the information from the bims report to carry out _ the information from the bims report to carry out the settlement. it was identified — to carry out the settlement. it was identified that an error in the underlying issue tambe riposte software — underlying issue tambe riposte software because the problem, the issue _ software because the problem, the issue was— software because the problem, the issue was raised with esher who did affix in the — issue was raised with esher who did affix in the s 90 software release due to _ affix in the s 90 software release due to start on the 4th of march 2006 _ due to start on the 4th of march 2006 for— due to start on the 4th of march 2006 for completion by the 14th of april 2006, and by the 22nd of march the s 90 _ april 2006, and by the 22nd of march the s 90 migration report showed the counter— the s 90 migration report showed the counter release was 99.9% complete. -- escher _ counter release was 99.9% complete. —— escher. fujitsu monitored the issue— —— escher. fujitsu monitored the issue on— —— escher. fujitsu monitored the issue on the _ —— escher. fujitsu monitored the issue on the 27th of march and an

employee — issue on the 27th of march and an employee noticed that the timeout locks had _ employee noticed that the timeout locks had gone right down. so that is on _ locks had gone right down. so that is on the _ locks had gone right down. so that is on the fujitsu account of matters _ is on the fujitsu account of matters. it was a problem that was first noticed in september 2000 and a fix was _ first noticed in september 2000 and a fix was applied in march and april 2006, _ a fix was applied in march and april 2006. so _ a fix was applied in march and april 2006, so five and a half years later — 2006, so five and a half years later yes? _ 2006, so five and a half years later- yes?— 2006, so five and a half years later. yes?- in _ 2006, so five and a half years later. yes?- in fact, - 2006, so five and a half years later. yes? yes. in fact, this is an examle later. yes? yes. in fact, this is an example where — later. yes? yes. in fact, this is an example where it _ later. yes? 1c1 in fact, this is an example where it shouldn't be taken to be the _ example where it shouldn't be taken to be the last word on this, mr justice — to be the last word on this, mr justice fraser found that the bug continued in operation until 2010. both on— continued in operation until 2010. both on the fujitsu account this was a trug _ both on the fujitsu account this was a trug that _ both on the fujitsu account this was a bug that was operative for close on a six—year period, is that right? thats— on a six—year period, is that right? that's what— on a six—year period, is that right? that's what that says, yes. let�*s

that's what that says, yes. let's look at another _ that's what that says, yes. let's look at another example - that's what that says, yes. let's look at another example of - that's what that says, yes. let's look at another example of a - that's what that says, yes. let's look at another example of a bug, ijul look at another example of a bug, trug three. — look at another example of a bug, bug three, the suspense account bug. that is— bug three, the suspense account bug. that is page _ bug three, the suspense account bug. that is page 104 of your witness statement. sojust page 104, please. thank you. bug error or defect number— thank you. bug error or defect number three, the suspense account ijul, number three, the suspense account trug. the _ number three, the suspense account bug, the usual opening paragraph, trullet— bug, the usual opening paragraph, bullet 2. — bug, the usual opening paragraph, bullet .2, change introduced into

horizon — bullet .2, change introduced into horizon 2011 had the unintended consequence of leaving certain orphaned records from november or decemher— orphaned records from november or december 2010 relating to a branch's suspense _ december 2010 relating to a branch's suspense account in a table in the ttranch— suspense account in a table in the branch database rather than branch data base rather than archiving branch database rather than archiving them. the consequence was that once _ archiving them. the consequence was that once a _ archiving them. the consequence was that once a year when an impacted ttranch— that once a year when an impacted branch produced a trading statement, if they— branch produced a trading statement, if they had _ branch produced a trading statement, if they had any amount in their suspense _ if they had any amount in their suspense account of the suspense account _ suspense account of the suspense account records from 2010 were also pulled _ account records from 2010 were also pulled in _ account records from 2010 were also pulled in so — account records from 2010 were also pulled in so that the branch trading statement — pulled in so that the branch trading statement showed a erroneous amount in the _ statement showed a erroneous amount in the suspense account. when the problem _ in the suspense account. when the problem resurfaced a year later, a postmaster contacted fujitsu and a peak was _ postmaster contacted fujitsu and a peak was raised in 2013 and fujitsu diagnose _ peak was raised in 2013 and fujitsu diagnose the issue and identified 14 tiranches_ diagnose the issue and identified 14 branches is being affected. fujitsu held a _ branches is being affected. fujitsu held a conference with the post offices — held a conference with the post office's problem manager and the orphan _ office's problem manager and the orphan records were subsequently removed _ orphan records were subsequently removed by the fujitsu development

team, _ removed by the fujitsu development team, an _ removed by the fujitsu development team, an extra set of checks were introduced — team, an extra set of checks were introduced in october 2013. so if a similar— introduced in october 2013. so if a similar problem surfaced in the future — similar problem surfaced in the future an— similar problem surfaced in the future an error message would be displayed — future an error message would be displayed to the postmaster telling them to— displayed to the postmaster telling them to contact the horizon service desi

bullet— exhibits four documents. the second bullet point, a code fix distributed as part _ bullet point, a code fix distributed as part of— bullet point, a code fix distributed as part of the s 30 release caused a problem _ as part of the s 30 release caused a problem under certain circumstances due to _ problem under certain circumstances due to faulty logic, an occasion when _ due to faulty logic, an occasion when a — due to faulty logic, an occasion when a postmaster attempted to reverse _ when a postmaster attempted to reverse out some which had been remmed — reverse out some which had been remmed in— reverse out some which had been remmed in the balance showed double the amount— remmed in the balance showed double the amount rather than zero. according _ the amount rather than zero. according to the april 2003 service review _ according to the april 2003 service review book, delivery of s30 commenced in april 2003 and by the 2nd of— commenced in april 2003 and by the 2nd of may— commenced in april 2003 and by the 2nd of may 2003 2135 branches were alive _ 2nd of may 2003 2135 branches were alive the _ 2nd of may 2003 2135 branches were alive. the initial issue was reported _ alive. the initial issue was reported by postmaster on the 24th of april— reported by postmaster on the 24th of april 2003, sent to fujitsu third line support, the service support centre, — line support, the service support centre, on— line support, the service support centre, on the 20th of april 2003 who identified that an error had occurred. — who identified that an error had occurred. a _ who identified that an error had occurred, a known error log was

raised _ occurred, a known error log was raised and — occurred, a known error log was raised and the issue was also rooted to fujitsu's — raised and the issue was also rooted to fujitsu's msu team so they could liaise _ to fujitsu's msu team so they could liaise with— to fujitsu's msu team so they could liaise with the post office. it would — liaise with the post office. it would then issue transaction corrections to rectify the accounts following — corrections to rectify the accounts following which it was to be rooted back to _ following which it was to be rooted back to fujitsu so development could produce _ back to fujitsu so development could produce a _ back to fujitsu so development could produce a code fix. stopping there, the bug _ produce a code fix. stopping there, the bug was a doubling up the problem. _ the bug was a doubling up the problem, something we have heard a lot about _ problem, something we have heard a lot about from sub—postmasters themselves. we know from other documents, not asking you to comment on this, _ documents, not asking you to comment on this, the _ documents, not asking you to comment on this, the postmaster that raised the issue _ on this, the postmaster that raised the issue that is referred to in that— the issue that is referred to in that third _ the issue that is referred to in that third bullet point, to raise the issue — that third bullet point, to raise the issue concerning £13,910, he had remmed _ the issue concerning £13,910, he had remmed that some as cash into his horizon _ remmed that some as cash into his horizon terminal but then for a reason — horizon terminal but then for a

reason that is not clear needed to reverse _ reason that is not clear needed to reverse that transaction outcome might— reverse that transaction outcome might have got the wrong figure, the birds till— might have got the wrong figure, the birds till may have said i don't want — birds till may have said i don't want to, — birds till may have said i don't want to, you need to put in that 13.000 — want to, you need to put in that 13,000 cash, whatever it was, wanted to reverse _ 13,000 cash, whatever it was, wanted to reverse the transaction. they did so in _ to reverse the transaction. they did so in instead — to reverse the transaction. they did so in instead of going back to zero, when _ so in instead of going back to zero, when they— so in instead of going back to zero, when they were remming out of the transaction— when they were remming out of the transaction the sum doubled, therefore this estimate showed that therefore this estimate showed that the sub—postmasters should be holding — the sub—postmasters should be holding cash of £27,820 relating to that transaction whereas they wanted to show— that transaction whereas they wanted to show that they were holding none. understood?— to show that they were holding none. understood? yes. and we can see that from the next — understood? 1c1 and we can see that from the next bullet point on the 30th of— from the next bullet point on the 30th of april, the fujitsu eposs development team identified the coding _ development team identified the coding error and that it had been released — coding error and that it had been released with s30, an emergency fix was created, it went live on the 7th of may _

was created, it went live on the 7th of may 2003, instructions for test is detailed — of may 2003, instructions for test is detailed how the fix was to be implemented. this tells us, i think this is— implemented. this tells us, i think this is right, — implemented. this tells us, i think this is right, that the error was because — this is right, that the error was because of— this is right, that the error was because of an attempted fix to another— because of an attempted fix to another bug. | because of an attempted fix to another bug-— because of an attempted fix to another bug. because of an attempted fix to another bu. ~ . , ., another bug. i think that is what it is sa int , another bug. i think that is what it is saying. ves- _ another bug. i think that is what it is saying. ves- so. _ another bug. i think that is what it is saying, yes. so, and _ another bug. i think that is what it is saying, yes. so, and if- another bug. i think that is what it is saying, yes. so, and if we - another bug. i think that is what it is saying, yes. so, and if we lookl is saying, yes. so, and if we look into the detail _ is saying, yes. so, and if we look into the detail of _ is saying, yes. so, and if we look into the detail of it, _ is saying, yes. so, and if we look into the detail of it, we _ is saying, yes. so, and if we look into the detail of it, we have - is saying, yes. so, and if we look into the detail of it, we have got| into the detail of it, we have got the underlying documents. the horizon — the underlying documents. the horizon code problem was that the person— horizon code problem was that the person who had written the horizon code had _ person who had written the horizon code had applied the incorrect mathematical symbol to reverse the remming _ mathematical symbol to reverse the remming rain, so instead of applying the opposite mathematical simple to what had _ the opposite mathematical simple to what had been remmed ruin, so instead —

what had been remmed ruin, so instead of— what had been remmed ruin, so instead of a minus following a plus, it applied _ instead of a minus following a plus, it applied a — instead of a minus following a plus, it applied a second plus. understand? | it applied a second plus. understand? . :, it applied a second plus. understand? , . :, , understand? i understand the maths. i don't understand? i understand the maths. i don't know — understand? i understand the maths. i don't know whether _ understand? i understand the maths. i don't know whether all _ understand? i understand the maths. i don't know whether all of _ understand? i understand the maths. i don't know whether all of that - understand? i understand the maths. i don't know whether all of that was i i don't know whether all of that was behind this. if i don't know whether all of that was behind this— behind this. if we were to delve into the underlying _ behind this. if we were to delve into the underlying material- behind this. if we were to delve i into the underlying material that's exactly _ into the underlying material that's exactly what i would show. i put some _ exactly what i would show. i put some money in place, but the reversal— some money in place, but the reversal wants to reverse that, it should _ reversal wants to reverse that, it should then apply a— to take it back to zero _ should then apply a— to take it back to zero. what it did was the mathematical symbol in the code was another— mathematical symbol in the code was another plosaj in so it doubled it. understood, and i agree. it another plosaj in so it doubled it. understood, and i agree.- understood, and i agree. it was reorted understood, and i agree. it was reported according _ understood, and i agree. it was reported according to _ understood, and i agree. it was reported according to that - understood, and i agree. it was| reported according to that bullet point _ reported according to that bullet point in — reported according to that bullet point in april and affixed to the problem — point in april and affixed to the problem caused by the earlier fix was applied in may 2003. —— another plus sign _ was applied in may 2003. —— another plus sign. could we look at the fourth — plus sign. could we look at the fourth bug, page 119.

this is the data to rebuild failure and if— this is the data to rebuild failure and if this— this is the data to rebuild failure and if this is split into a number of sub— and if this is split into a number of sub issues. this is issue one, the only— of sub issues. this is issue one, the only one _ of sub issues. this is issue one, the only one i'm going to address. second _ the only one i'm going to address. second bullet point, fujitsu understands this issue was first reported — understands this issue was first reported to a branch on the 10th of november— reported to a branch on the 10th of november 1999. after a discrepancy in the _ november 1999. after a discrepancy in the account. a number of pinnacles _ in the account. a number of pinnacles for similar incidents were raised _ pinnacles for similar incidents were raised between february and may 2000 _ raised between february and may 2000 a — raised between february and may 2000. a list of cross the main problems— 2000. a list of cross the main problems was in the monthly service review— problems was in the monthly service review books to be discussed in the service _ review books to be discussed in the service review forum with post office — service review forum with post office. the issue with the dungannon branch— office. the issue with the dungannon branch was— office. the issue with the dungannon branch was tracked in a number of these _ branch was tracked in a number of these to — branch was tracked in a number of these. to resolve the issue, fujitsu implemented two changes, specific diagnostics, to log a failure to build — diagnostics, to log a failure to build the _ diagnostics, to log a failure to build the data tree and more error checking _ build the data tree and more error checking in— build the data tree and more error checking in the application. these

diagnostics were distributed to 99% of the _ diagnostics were distributed to 99% of the estate by the 16th of may 2000 — of the estate by the 16th of may 2000. this would allow recurrences of the _ 2000. this would allow recurrences of the problem to be monitored. and then the _ of the problem to be monitored. and then the last bullet point, error checking. — then the last bullet point, error checking, was included in a later release~ — checking, was included in a later release~ so— checking, was included in a later release. so the issue was first reported — release. so the issue was first reported in the 10th of november 1999 according to the second bullet point~ _ 1999 according to the second bullet point. again, if we dug into the documents we would see that concern of a £43,000 discrepancy, so quite a sizeable _ of a £43,000 discrepancy, so quite a sizeable sum of money, and a fix was rolled _ sizeable sum of money, and a fix was rolled out _ sizeable sum of money, and a fix was rolled out we — sizeable sum of money, and a fix was rolled out we see from this last bullet _ rolled out we see from this last bullet point up until october 2000. yes? _ bullet point up until october 2000. yes? . bullet point up until october 2000. yes? yes. lastly, by way of example, .ae. yes? yes. lastly, by way of example, -ae~ 146 yes? yes. lastly, by way of example, page 146 of — yes? yes. lastly, by way of example, page 146 of your— yes? 1c1 lastly, by way of example, page 146 of your witness statement, please _

bug 18. and again, like the last bug that we _ bug 18. and again, like the last bug that we looked at, there were a number— that we looked at, there were a number of— that we looked at, there were a number of issues which have been split out, — number of issues which have been split out, so— number of issues which have been split out, so sub issues. this concerns— split out, so sub issues. this concerns the concurrent log in bug an issue. — concerns the concurrent log in bug an issue. or— concerns the concurrent log in bug an issue, or sub issue two of it, second — an issue, or sub issue two of it, second bullet point, issue two consenting receipts and payments mismatch— consenting receipts and payments mismatch that occurred due to a coding _ mismatch that occurred due to a coding issue which permitted a postmaster to transfer money from one county— postmaster to transfer money from one county to another while the first counter was being rolled over. the system — first counter was being rolled over. the system should have prevented this. the system should have prevented this the _ the system should have prevented this. the incident was raised with fujitsu _ this. the incident was raised with fujitsu on— this. the incident was raised with fujitsu on the 24th ofjuly 2000. by the 28th, _ fujitsu on the 24th ofjuly 2000. by the 28th, fujitsu had established what had — the 28th, fujitsu had established what had happened after discussing the circumstances with the postmaster and confirmed he shouldn't have been able effectively to log _ shouldn't have been able effectively to log into two counters with the same _ to log into two counters with the same user— to log into two counters with the same user id number. on the 1st of

august— same user id number. on the 1st of august 2000, a further incident was recorded _ august 2000, a further incident was recorded as — august 2000, a further incident was recorded as another instance of the same _ recorded as another instance of the same issue — recorded as another instance of the same issue. next bullet point, a number— same issue. next bullet point, a number of— same issue. next bullet point, a number of detailed analyses were carried _ number of detailed analyses were carried out with an interim diagnosis on the 4th of october, on the 22nd _ diagnosis on the 4th of october, on the 22nd of— diagnosis on the 4th of october, on the 22nd of november fujitsu determined this was a transient bug caused _ determined this was a transient bug caused by— determined this was a transient bug caused by two modules in the application using different methods to communicate with each other. an early— to communicate with each other. an early release known as c 145 to communicate with each other. an early release known as c145 should have already fixed the issue. so, a ijul have already fixed the issue. so, a bug identified injuly with a decision that an existing release by november— decision that an existing release by november 2000 should have fixed it. that can _ november 2000 should have fixed it. that can come down. all of those 29 summaries— that can come down. all of those 29 summaries are there for people to

read, _ summaries are there for people to read. the — summaries are there for people to read, the core participants have got the and _ read, the core participants have got the and add them for many months now _ the and add them for many months now. �* :, y :, the and add them for many months now. �* :, , the and add them for many months now. �* :, i. ~�* now. before you carry on, mr beer i want to be _ now. before you carry on, mr beer i want to be clear _ now. before you carry on, mr beer i want to be clear about _ now. before you carry on, mr beer i want to be clear about something . now. before you carry on, mr beer i j want to be clear about something in the previous— want to be clear about something in the previous examples _ want to be clear about something in the previous examples you - want to be clear about something in the previous examples you looked l want to be clear about something ml the previous examples you looked at with mr— the previous examples you looked at with mr paterson, _ the previous examples you looked at with mr paterson, mr— the previous examples you looked at with mr paterson, mr beer, - the previous examples you looked at with mr paterson, mr beer, you - with mr paterson, mr beer, you reference — with mr paterson, mr beer, you reference documents _ with mr paterson, mr beer, you reference documents which - reference documents which demonstrated _ reference documents which demonstrated that - reference documents which demonstrated that the - reference documents which | demonstrated that the post reference documents which - demonstrated that the post office was made — demonstrated that the post office was made aware _ demonstrated that the post office was made aware of— demonstrated that the post office was made aware of each - demonstrated that the post office was made aware of each of - demonstrated that the post office was made aware of each of those i demonstrated that the post office - was made aware of each of those bugs more or— was made aware of each of those bugs more or less _ was made aware of each of those bugs more or less contemporaneously. - was made aware of each of those bugs more or less contemporaneously. i'mi more or less contemporaneously. i'm not concerned — more or less contemporaneously. i'm not concerned about _ more or less contemporaneously. i'm not concerned about the _ more or less contemporaneously. i'm not concerned about the detail - more or less contemporaneously. i'm not concerned about the detail of - not concerned about the detail of those _ not concerned about the detail of those documents. _ not concerned about the detail of those documents. in _ not concerned about the detail of those documents. in the - not concerned about the detail of those documents. in the last- not concerned about the detail of those documents. in the last one that we _ those documents. in the last one that we looked _ those documents. in the last one that we looked at, _ those documents. in the last one that we looked at, unless - those documents. in the last one that we looked at, unless i - those documents. in the last one that we looked at, unless i havei that we looked at, unless i have missed — that we looked at, unless i have missed it. — that we looked at, unless i have missed it. you _ that we looked at, unless i have missed it, you haven't - that we looked at, unless i have. missed it, you haven't referenced that we looked at, unless i have i missed it, you haven't referenced a contemporaneous _ missed it, you haven't referenced a contemporaneous documents - missed it, you haven't referenced a contemporaneous documents or. contemporaneous documents or anything _ contemporaneous documents or anything else — contemporaneous documents or anything else to _ contemporaneous documents or anything else to suggest - contemporaneous documents or anything else to suggest that i contemporaneous documents orl anything else to suggest that the post office — anything else to suggest that the post office was _ anything else to suggest that the post office was made _ anything else to suggest that the post office was made aware - anything else to suggest that the post office was made aware of. anything else to suggest that the . post office was made aware of that iju l . post office was made aware of that bug i_ post office was made aware of that bug ijust— post office was made aware of that bug ijust want— post office was made aware of that bug ijust want to— post office was made aware of that bug. ijust want to be _ post office was made aware of that bug. ijust want to be clear- post office was made aware of that bug. ijust want to be clear about . bug. ijust want to be clear about this _ bug. ijust want to be clear about this is— bug. ijust want to be clear about this is your— bug. ijust want to be clear about this. is your evidence _ bug. ijust want to be clear about this. is your evidence that - bug. ijust want to be clear about this. is your evidence that each l bug. ijust want to be clear about . this. is your evidence that each and every— this. is your evidence that each and every bug _ this. is your evidence that each and every bug was — this. is your evidence that each and every bug was notified _ this. is your evidence that each and every bug was notified to _ this. is your evidence that each and every bug was notified to the - this. is your evidence that each and every bug was notified to the post i every bug was notified to the post office _ every bug was notified to the post office contemporaneously, - every bug was notified to the post office contemporaneously, or- every bug was notified to the post.

office contemporaneously, or more every bug was notified to the post - office contemporaneously, or more or less contemporaneously? _ office contemporaneously, or more or less contemporaneously? or- office contemporaneously, or more or less contemporaneously? or is - office contemporaneously, or more or less contemporaneously? or is it - office contemporaneously, or more or less contemporaneously? or is it the i less contemporaneously? or is it the case that— less contemporaneously? or is it the case that there — less contemporaneously? or is it the case that there may— less contemporaneously? or is it the case that there may have _ less contemporaneously? or is it the case that there may have been - less contemporaneously? or is it the case that there may have been somej case that there may have been some bu-s case that there may have been some bugs which _ case that there may have been some bugs which were _ case that there may have been some bugs which were not? _ case that there may have been some bugs which were not? if— case that there may have been some bugs which were not? if i _ case that there may have been some bugs which were not?— bugs which were not? if i have missed the — bugs which were not? if i have missed the reference - bugs which were not? if i have missed the reference in - bugs which were not? if i have missed the reference in bd - bugs which were not? if i have| missed the reference in bd 18, missed the reference in bd18, please — missed the reference in bd18, please put me right, but i can't see it at the _ please put me right, but i can't see it at the moment. and please put me right, but i can't see it at the moment.— it at the moment. and i can't see it there either. _ it at the moment. and i can't see it there either, so _ it at the moment. and i can't see it there either, so i _ it at the moment. and i can't see it there either, so i think _ it at the moment. and i can't see it there either, so i think you - it at the moment. and i can't see it there either, so i think you are - there either, so i think you are correct that the vast majority of bugs and errors and defects were shared, whether they had 18 was in this example i would need to check. as mr beer noted in you will be returning — as mr beer noted in you will be returning so _ as mr beer noted in you will be returning so there _ as mr beer noted in you will be returning so there is _ as mr beer noted in you will be returning so there is no- as mr beer noted in you will bej returning so there is no greater urgency— returning so there is no greater urgency about _ returning so there is no greater urgency about it _ returning so there is no greater urgency about it but _ returning so there is no greater urgency about it but i— returning so there is no greater urgency about it but i wanted . returning so there is no greater| urgency about it but i wanted to raise _ urgency about it but i wanted to raise it — urgency about it but i wanted to raise it while _ urgency about it but i wanted to raise it while it _ urgency about it but i wanted to raise it while it was _ urgency about it but i wanted to raise it while it was fresh - urgency about it but i wanted to raise it while it was fresh in - urgency about it but i wanted to raise it while it was fresh in my| raise it while it was fresh in my mind — raise it while it was fresh in my mind thank— raise it while it was fresh in my mind. thank you. _ raise it while it was fresh in my mind. thank you.— raise it while it was fresh in my mind. thank you. you are right to raise it. generally _

mind. thank you. you are right to raise it. generally the _ mind. thank you. you are right to raise it. generally the summary i raise it. generally the summary where _ raise it. generally the summary where the — raise it. generally the summary where the post office has been notified — where the post office has been notified or information shared says so. so. _ notified or information shared says so. so, looking at the 29 as a whole. — so. so, looking at the 29 as a whole, would you agree with the following? firstly, in each case fujitsu — following? firstly, in each case fujitsu agrees that the bug error or defect _ fujitsu agrees that the bug error or defect existed?— fujitsu agrees that the bug error or defect existed? yes. secondly, on fu'itsu's defect existed? yes. secondly, on fujitsu's own _ defect existed? 1c1 secondly, on fujitsu's own assessment by looking at this— fujitsu's own assessment by looking at this appendix, the bug is afflicted _ at this appendix, the bug is afflicted both legacy horizon and horizon — afflicted both legacy horizon and horizon online?— afflicted both legacy horizon and horizon online? yes. thirdly, we can see by reference _ horizon online? 1c1 thirdly, we can see by reference to this summary, and in _ see by reference to this summary, and in particular if we read it alongside _ and in particular if we read it alongside the bugs, errors and defects— alongside the bugs, errors and

defects report which contains much more _ defects report which contains much more detail, we can see the date on which _ more detail, we can see the date on which according to fujitsu, at least, — which according to fujitsu, at least, the _ which according to fujitsu, at least, the bug, error or defect was recorded _ least, the bug, error or defect was recorded or— least, the bug, error or defect was recorded or recognised by fujitsu? yes. recorded or recognised by fu'itsu? yes. :, :. , recorded or recognised by fu'itsu? yes. :, , yes. fourth, we can see the impact that fujitsu — yes. fourth, we can see the impact that fujitsu assesses _ yes. fourth, we can see the impact that fujitsu assesses the _ yes. fourth, we can see the impact that fujitsu assesses the bug - yes. fourth, we can see the impact that fujitsu assesses the bug to - that fujitsu assesses the bug to have _ that fujitsu assesses the bug to have had — that fujitsu assesses the bug to have had on the estate? yes. fifthl , have had on the estate? yes. fifthly. we — have had on the estate? yes. fifthly, we can _ have had on the estate? yes. fifthly, we can see _ have had on the estate? yes. fifthly, we can see for - have had on the estate? yes. fifthly, we can see for most i have had on the estate? 1c1 fifthly, we can see for most bugs, errors— fifthly, we can see for most bugs, errors and — fifthly, we can see for most bugs, errors and defects whether it was notified _ errors and defects whether it was notified to — errors and defects whether it was notified to the post office, and if so, when — notified to the post office, and if so, when fujitsu say when the bug was communicated to the post office? yes. ~:: was communicated to the post office? yes. a“, : :, , was communicated to the post office? yes. ~:: : :, , ., yes. 60, we can see that the earliest bug _ yes. 60, we can see that the earliest bug of— yes. 60, we can see that the earliest bug of the _ yes. 60, we can see that the earliest bug of the 29 - yes. 60, we can see that the earliest bug of the 29 bugs, l yes. 60, we can see that the - earliest bug of the 29 bugs, errors and defects was in november 1990 nine, _ and defects was in november 1990 nine, one — and defects was in november 1990 nine, one of the examples i took you two? _ nine, one of the examples i took you two? so— nine, one of the examples i took you

two? so that— nine, one of the examples i took you two? so that was in the course of the national roll—out? two? so that was in the course of the national roll-out?— two? so that was in the course of the national roll-out? yes, agreed. the latest, — the national roll-out? yes, agreed. the latest. l'm _ the national roll-out? yes, agreed. the latest, i'm not— the national roll-out? yes, agreed. the latest, i'm not going _ the national roll-out? yes, agreed. the latest, i'm not going to - the national roll-out? yes, agreed. the latest, i'm not going to take i the latest, i'm not going to take you to _ the latest, i'm not going to take you to it— the latest, i'm not going to take you to it now, may 2018, the bureau discrepancy— you to it now, may 2018, the bureau discrepancy bug, bug 14?— discrepancy bug, bug 14? agreed. bus, discrepancy bug, bug 14? agreed. bugs. errors _ discrepancy bug, bug 14? agreed. bugs, errors and _ discrepancy bug, bug 14? agreed. bugs, errors and defects - discrepancy bug, bug 14? agreed. bugs, errors and defects afflicted| bugs, errors and defects afflicted the horizon system on fujitsu's own assessment for a period of nearly two decades?— assessment for a period of nearly two decades? yes. and then lastly, we can see — two decades? yes. and then lastly, we can see fujitsu's _ two decades? 1c1 and then lastly, we can see fujitsu's assessment of the length — we can see fujitsu's assessment of the length of time for which the bug was operative, sometimes that was a substantial _ was operative, sometimes that was a substantial period of time, the first one — substantial period of time, the first one i_ substantial period of time, the first one i took you two, calendar sguare, — first one i took you two, calendar sguare, for— first one i took you two, calendar square, for at least six years or ten years— square, for at least six years or ten years by reference to mrjustice fraser's _ ten years by reference to mrjustice fraser's findings?— ten years by reference to mrjustice fraser's findings? yes. i think it follows from this _ fraser's findings? 1c1 i think it follows from this that it is plain that fujitsu staff knew about bugs, errors _ that fujitsu staff knew about bugs, errors and — that fujitsu staff knew about bugs, errors and defects in horizon well

before _ errors and defects in horizon well before 2010?— errors and defects in horizon well| before 2010?_ fujitsu before 2010? yes, i agree. fu'itsu staff knew «hi before 2010? yes, i agree. fu'itsu staff knew of them i before 2010? yes, i agree. fu'itsu staff knew of them on i before 2010? yes, i agree. fujitsu staff knew of them on fujitsu's - before 2010? yes, i agree. fujitsul staff knew of them on fujitsu's own account _ staff knew of them on fujitsu's own account from at least november 1999? agreed _ account from at least november 1999? agreed. and account from at least november 1999? at reed. : :, account from at least november 1999? at reed. : . , account from at least november 1999? aareed. : . , _, :, account from at least november 1999? aareed. : . , :, _ agreed. and that this recognition by fu'itsu agreed. and that this recognition by fujitsu reflected _ agreed. and that this recognition by fujitsu reflected in _ agreed. and that this recognition by fujitsu reflected in your _ agreed. and that this recognition by fujitsu reflected in your witness - fujitsu reflected in your witness statement here doesn't need any investigator work to be undertaken by the _ investigator work to be undertaken by the inquiry? no, investigator work to be undertaken by the inquiry?— by the inquiry? no, it doesn't, it is in the notes, _ by the inquiry? no, it doesn't, it is in the notes, i _ by the inquiry? no, it doesn't, it is in the notes, i agree. - by the inquiry? no, it doesn't, it is in the notes, i agree. it - by the inquiry? no, it doesn't, it. is in the notes, i agree. it doesn't need any application ofjudgment by anyone because it is here in black and white in fujitsu's own words. indeed, in your own words? agreed. when did fujitsu _ indeed, in your own words? agreed. when did fujitsu realise _ indeed, in your own words? agreed. when did fujitsu realise that - indeed, in your own words? agreed. when did fujitsu realise that the - when did fujitsu realise that the bugs, _ when did fujitsu realise that the bugs, errors and defects in its horizon — bugs, errors and defects in its horizon system impacted on the evidence — horizon system impacted on the evidence that was being relied on to investigate and prosecute

sub—postmasters for criminal sub— postmasters for criminal offences? sub—postmasters for criminal offences? is sub-postmasters for criminal offences?— sub-postmasters for criminal offences? . . , , offences? is that in my second statement? — offences? is that in my second statement? no. _ offences? is that in my second statement? no. this - offences? is that in my second statement? no. this is - offences? is that in my second statement? no. this is going i offences? is that in my second l statement? no. this is going to ourthird statement? no. this is going to yourthird statement _ statement? no. this is going to yourthird statement litigation i yourthird statement litigation support. yourthird statement litigation su . ort. yourthird statement litigation su--ort. :, �* ~ :, support. so, i don't know the exact date of- -- — support. so, i don't know the exact date of- -- just _ support. so, i don't know the exact date of... just repeat _ support. so, i don't know the exact date of... just repeat the _ support. so, i don't know the exact date of... just repeat the questionl date of... just repeat the question again. date of... just repeat the question aaain. ~ . date of... just repeat the question aaain. ~ , :, , date of... just repeat the question auain.~ , :, , :, again. when did fu'itsu realise that the bus, again. when did fu'itsu realise that the bugs. errors _ again. when did fujitsu realise that the bugs, errors and _ again. when did fujitsu realise that the bugs, errors and defects - again. when did fujitsu realise that the bugs, errors and defects in - again. when did fujitsu realise that the bugs, errors and defects in its. the bugs, errors and defects in its horizon _ the bugs, errors and defects in its horizon system impacted on the evidence — horizon system impacted on the evidence that was being relied on to investigate and prosecute sub—postmasters for criminal sub— postmasters for criminal offences? sub—postmasters for criminal offences? in sub-postmasters for criminal offences?— sub-postmasters for criminal offences? in the company's second statement we _ offences? in the company's second statement we draw _ offences? in the company's second statement we draw attention - offences? in the company's second statement we draw attention to - offences? in the company's second| statement we draw attention to the company knew several times that that evidence had been presented needed to be corrected, given some bugs and errors, orthe to be corrected, given some bugs and errors, or the data needed to be rerun. so i think there would be several examples in the second statement which answers your question. i can't give you the exact

date on each and every one of them. i think in each particular irq request it would be applied differently. in request it would be applied differently.— request it would be applied differentl . :, :, , �* differently. in other words, i'm askin: differently. in other words, i'm asking when — differently. in other words, i'm asking when did _ differently. in other words, i'm asking when did fujitsu - differently. in other words, i'm asking when did fujitsu put - differently. in other words, i'm| asking when did fujitsu put two differently. in other words, i'm - asking when did fujitsu put two and two together and realise they added up two together and realise they added up to four— two together and realise they added up to four for maghrebi and we need to tell— up to four for maghrebi and we need to tell the _ up to four for maghrebi and we need to tell the post office about these bugsr _ to tell the post office about these bugs, errors and defects, not because — bugs, errors and defects, not because there is a problem with this system _ because there is a problem with this system that we are selling to them, but because they are prosecuting sub—postmasters on the basis of the evidence _ sub—postmasters on the basis of the evidence that we are providing to them _ evidence that we are providing to them. . :, . evidence that we are providing to them. , :, , :, : :, them. there is lots of evidence of us in performing _ them. there is lots of evidence of us in performing the _ them. there is lots of evidence of us in performing the post - them. there is lots of evidence of us in performing the post office l them. there is lots of evidence of| us in performing the post office of the data that we just discussed, bugs and errors, and how the bugs and errors did or did not impact the financial position as reported. what the post office did with that particular piece of data do not fujitsu knew at the time but certainly latterly, of course the company became more aware that it

was being used nearly solely for prosecutions. studio: we are going to leave the inquiry for a moment. we will keep you up—to—date with paul patterson and what he has to say to the inquiry but we have some breaking news for you. that is, a newborn baby girl has been found wrapped in a towel in a shopping bag in east london. police say the baby was discovered in newham by a member of the public who kept her warm until paramedics arrived. let's get more on this from our correspondence sean dilley in the newsroom. what can you tell us? police are growing very concerned for the mother of the newborn baby. the details are, as you set out, a dog walker in the east london borough of newham called paramedics and also police became involved at 9:13pm last night. that member of

the public, that person who is a member of that community, thought very quickly, they kept the baby warm until specialist paramedics arrived and took the baby to an east london hospital. the police say that no matter what the circumstances are of the mother they want her to know that her little baby daughter is safe, well and being cared for. they say that whatever your circumstances to the mother, and in fact if she is watching our police would like her to call 999 two seeks an urgent support. whatever the circumstances there will be concerns for the mother's health, there will be concerned to check that she is fit and well. and of course they will be eager to understand what has happened, what led up to this. but the priorities for the medical care of the newborn baby who is doing well at the moment and the mother. sean, thanks very much indeed. we

will keep you up—to—date with that. meanwhile, let's go back to the post office inquiry and here a little bit more from paul patterson, the head of fujitsu in europe, who was giving evidence to the inquiry. that of fujitsu in europe, who was giving evidence to the inquiry.— evidence to the inquiry. that would be one word _ evidence to the inquiry. that would be one word l _ evidence to the inquiry. that would be one word i would _ evidence to the inquiry. that would be one word i would use, _ evidence to the inquiry. that would be one word i would use, yes. - evidence to the inquiry. that would i be one word i would use, yes. what's the other one? _ be one word i would use, yes. what's the other one? shameful, _ be one word i would use, yes. what's the other one? shameful, appalling. | the other one? shameful, appalling. my understanding _ the other one? shameful, appalling. my understanding of _ the other one? shameful, appalling. my understanding of how— the other one? shameful, appalling. my understanding of how our- the other one? shameful, appalling. my understanding of how our laws i my understanding of how our laws work in this country, that all of the evidence should have been put in front of the sub—postmaster, that the post office was relying on to prosecute them. can the post office was relying on to prosecute them.— the post office was relying on to prosecute them. the post office was relying on to rosecute them. . , :, prosecute them. can we turn these to our third prosecute them. can we turn these to your third witness _ prosecute them. can we turn these to your third witness statement, - your third witness statement, please? — your third witness statement, please? the matters about which you speak _ please? the matters about which you speak in _ please? the matters about which you speak in your third witness statement and we are about to address— statement and we are about to address through my questions to you a-ain address through my questions to you again are _ address through my questions to you again are generally the product of you having been provided with documents by your team, or briefed by your— documents by your team, or briefed by your team, documents by your team, or briefed by yourteam, in documents by your team, or briefed by your team, in the same way as your— by your team, in the same way as your second — by your team, in the same way as your second witness statement was created _ your second witness statement was created is — your second witness statement was created. is that right?— your second witness statement was created. is that right?- i'm| created. is that right? correct. i'm rroin to created. is that right? correct. i'm going to ask— created. is that right? correct. i'm

going to ask you — created. is that right? correct. i'm going to ask you questions - created. is that right? correct. i'm going to ask you questions about | created. is that right? correct. i'm i going to ask you questions about the question— going to ask you questions about the question of— going to ask you questions about the question of litigation support by fujitsu — question of litigation support by fujitsu to the post office in connection with the horizon system. and in— connection with the horizon system. and in particular the use, the non-use _ and in particular the use, the non—use and the reliability of arq datar _ non—use and the reliability of arq data. audit — non—use and the reliability of arq data, audit record query, or arq data _ data, audit record query, or arq data you — data, audit record query, or arq data. you start your third witness statement — data. you start your third witness statement perhaps naturally with the contractual and other forms of formal— contractual and other forms of formal documents that regulated, or ought _ formal documents that regulated, or ought to— formal documents that regulated, or ought to have regulated, the litigation support to be provided by fujitsu _ litigation support to be provided by fujitsu to _ litigation support to be provided by fujitsu to the post office. that's where _ fujitsu to the post office. that's where i— fujitsu to the post office. that's where i am going to start. so starting — where i am going to start. so starting with the contract, are you aware _ starting with the contract, are you aware that— starting with the contract, are you aware that fujitsu was contractually bound _ aware that fujitsu was contractually bound to _ aware that fujitsu was contractually bound to provide evidence in support of post _ bound to provide evidence in support of post office prosecutions and civil proceedings?— of post office prosecutions and civil proceedings? yes. are you aware that _ civil proceedings? yes. are you aware that fujitsu _ civil proceedings? 1c1 are you aware that fujitsu operated a fraud and litigation support office? yes, i'm and litigation support office? yes, l'm aware- — and litigation support office? yes, i'm aware. which _ and litigation support office? yes, i'm aware. which still _ and litigation support office? yes, i'm aware. which still exists, - and litigation support office? yes, i'm aware. which still exists, i - i'm aware. which still exists, i think. i don't _ i'm aware. which still exists, i think. i don't know— i'm aware. which still exists, i think. i don't know if- i'm aware. which still exists, i

think. i don't know if it - i'm aware. which still exists, i think. i don't know if it does i i'm aware. which still exists, i i think. i don't know if it does still exist, i would _ think. i don't know if it does still exist, i would need _ think. i don't know if it does still exist, i would need to _ think. i don't know if it does still exist, i would need to check - think. i don't know if it does stilll exist, i would need to check that. this office, the fraud and litigation support office, was to provide — litigation support office, was to provide horizon evidence to support prosecutions and civil actions, correct? — prosecutions and civil actions, correct? . prosecutions and civil actions, correct? : prosecutions and civil actions, correct?_ would l prosecutions and civil actions, i correct?_ would you correct? yes, correct. would you acce -t correct? yes, correct. would you accept that _ correct? yes, correct. would you accept that as — correct? yes, correct. would you accept that as fujitsu _ correct? yes, correct. would you accept that as fujitsu was - correct? yes, correct. would you accept that as fujitsu was an - accept that as fujitsu was an integral— accept that as fujitsu was an integral part of the system supporting legal proceedings against sub—postmasters and knew that it wasr _ sub—postmasters and knew that it was, it _ sub—postmasters and knew that it was, it had — sub—postmasters and knew that it was, it had a duty to ensure that the data — was, it had a duty to ensure that the data it — was, it had a duty to ensure that the data it supplied was accurate and complete?— the data it supplied was accurate and complete? yes. has what you discovered — and complete? yes. has what you discovered lead _ and complete? 1c1 has what you discovered lead you to the conclusion that the data supplied was not — conclusion that the data supplied was not accurate and complete? yes, it has. was not accurate and complete? yes, it has- the — was not accurate and complete? yes, it has. the company _ was not accurate and complete? yes, it has. the company made _ was not accurate and complete? 1c1 it has. the company made that in this statement, number three.

can we look atjust this statement, number three. can we look at just what the contract _ can we look at just what the contract said? so this is your third witness _ contract said? so this is your third witness statement w itn 06650 600. pa-e witness statement w itn 06650 600. page three. and again in general terms _ page three. and again in general terms i'm — page three. and again in general terms i'm going to restrict my questions _ terms i'm going to restrict my questions to what you have included in your— questions to what you have included in your witness statement rather than _ in your witness statement rather than looking at underlying materials, partly because of the limitations of your evidence, given your position, partly because i suspect— your position, partly because i suspect it _ your position, partly because i suspect it will turn into an exercise _ suspect it will turn into an exercise of you saying you weren't in the _ exercise of you saying you weren't in the relevant post at the time and you didn't _ in the relevant post at the time and you didn't see this document or that document— you didn't see this document or that document at the relevant time. but you can _ document at the relevant time. but you can read the document like the rest of— you can read the document like the rest of us _ you can read the document like the rest of us and i don't want you just interpreting — rest of us and i don't want you just interpreting documents. can we look at paragraphs six and seven, please?

you say. _ at paragraphs six and seven, please? you say, from the outset of horizon, fujitsu _ you say, from the outset of horizon, fujitsu has— you say, from the outset of horizon, fujitsu has been acquired by contract _ fujitsu has been acquired by contract to maintain an audit trail of all— contract to maintain an audit trail of all transactions and events. see for example paragraph 3.1 of schedule a03 to the codified agreement of the 20th ofjuly1999, and paragraph 3.1 of schedule d five to version— and paragraph 3.1 of schedule d five to version 13 of the codified agreement of 23rd of november 2020. i'm agreement of 23rd of november 2020. im not— agreement of 23rd of november 2020. i'm not going to ask you any questions _ i'm not going to ask you any questions about the agreement of 2020 _ questions about the agreement of 2020 biggest prosecutions had stopped by then. this contractual obligation flowed from requirement 699 contained at paragraph 1.102 of schedule _ 699 contained at paragraph 1.102 of schedule a15, to the 1999 codified agreement. in particular, requirement 69—9 notes at: 1.1026

the content _ requirement 69—9 notes at: 1.1026 the content of the audit