asks the company secretary assistant asks the company secretary to draft some words. can you recall whether this resulted in a meeting? we didn't have a meeting with —— we did have _ we didn't have a meeting with —— we did have a _ we didn't have a meeting with —— we did have a meeting with her, i remember_ did have a meeting with her, i remember a did have a meeting with her, i remembera meeting. did have a meeting with her, i remember a meeting. gne did have a meeting with her, i remember a meeting.- did have a meeting with her, i remember a meeting. one of the covert recordings _ remember a meeting. one of the covert recordings that _ remember a meeting. one of the covert recordings that we - remember a meeting. one of the covert recordings that we have i remember a meeting. one of the covert recordings that we have is | covert recordings that we have is from the 22nd of may, 2013, the day after you sent an e—mail to paula vennells and in that covert recording there is a discussion over the extent to which she showed all should not be told certain things. certain items, right foot up sorry, i cannot_ certain items, right foot up sorry, i cannot help you there. to certain items, right foot up sorry, i cannot help you there.— i cannot help you there. to what extent did _ i cannot help you there. to what extent did you _

i cannot help you there. to what extent did you understand - i cannot help you there. to what extent did you understand that l i cannot help you there. to what | extent did you understand that at the time of the second sight mps investigation as you called it, fujitsu was involved in the process? i was not aware of anything at that time, _ i was not aware of anything at that time, not — i was not aware of anything at that time, not as— i was not aware of anything at that time, not as far as the discussions that were — time, not as far as the discussions that were going on about the system and all— that were going on about the system and all the _ that were going on about the system and all the rest of it. no idea. did ou know and all the rest of it. no idea. d c you know whether the post office was going back to fujitsu to check or verify information being given? in a verify information being given? in a later document, i have seen, more recently. _ later document, i have seen, more recently, which seems to suggest that, _ recently, which seems to suggest that, that — recently, which seems to suggest that, that fujitsu were involved and are part _ that, that fujitsu were involved and are part of— that, that fujitsu were involved and are part of the discussions with the post office — are part of the discussions with the post office on the system. although this will be a _ post office on the system. although this will be a question _ post office on the system. although this will be a question for _ post office on the system. although this will be a question for second i this will be a question for second sight in due course, what was your understanding of the extent to which underlying data and information held by fujitsu including irq data, for

example, contractual relationships between a post office and fujitsu policies and correspondence between the organisations was obtained and analysed as part of the work of second sight? it analysed as part of the work of second sight?— analysed as part of the work of second siaht? , , . . second sight? it depends at which date ou second sight? it depends at which date you are _ second sight? it depends at which date you are saying. _ second sight? it depends at which date you are saying. i _ second sight? it depends at which date you are saying. i did - second sight? it depends at which date you are saying. i did become| date you are saying. i did become aware _ date you are saying. i did become aware of— date you are saying. i did become aware of it— date you are saying. i did become aware of it at some point but i think— aware of it at some point but i think this _ aware of it at some point but i think this was probably during the mediation scheme itself when we became _ mediation scheme itself when we became aware that, i think it was something — became aware that, i think it was something like 700 requests could be made per— something like 700 requests could be made per year from the post office for this— made per year from the post office for this data from fujitsu without any other— for this data from fujitsu without any other charge being inflicted but then after— any other charge being inflicted but then after that i think there was a charge _ then after that i think there was a charge involved. but i think that was during the time of the mediation scheme _ was during the time of the mediation scheme itself. can was during the time of the mediation scheme itself.—

scheme itself. can i fast forward to after the draft _ scheme itself. can i fast forward to after the draft of _ scheme itself. can i fast forward to after the draft of the _ scheme itself. can i fast forward to after the draft of the second - scheme itself. can i fast forward to after the draft of the second sight| after the draft of the second sight interim report was being circulated, and look at 00961... this is an e—mailfrom paula vennells e—mail from paula vennells internally e—mailfrom paula vennells internally to a group of people within the post office, and so not something you would have seen at the time. if we look at the first paragraph, she says, that she has had two very constructive telephone conversations with you which confirms your willingness to work collaboratively with the post office in taking forward our response to a review, in particular you agreed in a response to a new user forum to provide feedback on training and support issues relating to horizon and bring the existing review process to a conclusion. can you

remember that, whether you gave such a commitment? i did remember that, whether you gave such a commitment?— a commitment? i did have telephone conversations — a commitment? i did have telephone conversations with _ a commitment? i did have telephone conversations with paula _ a commitment? i did have telephone conversations with paula and - a commitment? i did have telephone conversations with paula and i - a commitment? i did have telephone conversations with paula and i do - conversations with paula and i do remember— conversations with paula and i do remember one quite long one, really, but remember one quite long one, really, hut it— remember one quite long one, really, but it was— remember one quite long one, really, but it was after the interim report had been — but it was after the interim report had been published, that is the one i had been published, that is the one i really— had been published, that is the one i really do _ had been published, that is the one i really do recall, that phone call. the others, — i really do recall, that phone call. the others, i'm afraid i don't recall — the others, i'm afraid i don't recall. ,, , , the others, i'm afraid i don't recall. ,, , ., recall. she says it is worth emphasising _ recall. she says it is worth emphasising that - recall. she says it is worth emphasising that your - recall. she says it is worth | emphasising that your main recall. she says it is worth - emphasising that your main issue is not the computer but the human aspect and how the post office failed to support muddleheaded sub—postmaster is, was that your view? it sub-postmaster is, was that your view? . . sub-postmaster is, was that your view? . , ., , sub-postmaster is, was that your view? ., , . , , view? it was not 'ust a computer but it was also the — view? it was notjust a computer but it was also the way _ view? it was notjust a computer but it was also the way that, _ view? it was notjust a computer but it was also the way that, she - view? it was notjust a computer but it was also the way that, she has - it was also the way that, she has put it— it was also the way that, she has put it down— it was also the way that, she has put it down is not the computer, but i put it down is not the computer, but i would _ put it down is not the computer, but i would say — put it down is not the computer, but i would say it definitely was the computer—

i would say it definitely was the computer as well. it is also the way that the _ computer as well. it is also the way that the post office dealt with the sort of _ that the post office dealt with the sort of problems and dealt with sub—postmasters in an unconstructive way. sub—postmasters in an unconstructive way~ that _ sub—postmasters in an unconstructive way. that was one of the big problems— way. that was one of the big problems and that we will probably tet problems and that we will probably get to, _ problems and that we will probably get to, something further on, but i will wait _ get to, something further on, but i will wait for — get to, something further on, but i will wait for that. can get to, something further on, but i will wait for that.— will wait for that. can we turn to the next bullet _ will wait for that. can we turn to the next bullet point, _ will wait for that. can we turn to the next bullet point, please? i will wait for that. can we turn to i the next bullet point, please? you raise the idea of setting up a new independent third party that sub—postmasters could approach if they are facing issues with horizon which cannot be resolved through the normal post office processes and she said that aligns with some of their own thinking and they are therefore inclined to agree with the idea, does that accurately reflect what you were suggesting? yes. does that accurately reflect what you were suggesting?— does that accurately reflect what you were suggesting? yes, it does. i lona felt you were suggesting? yes, it does. i long felt they — you were suggesting? yes, it does. i long felt they should _ you were suggesting? yes, it does. i long felt they should be _ you were suggesting? yes, it does. i long felt they should be totally - long felt they should be totally independent —— there should be a totally— independent —— there should be a totally independent third party for sub—postmasters to go to when they had problems who could then request

post office _ had problems who could then request post office records. it is an alternative scheme so as not to expose — alternative scheme so as not to expose sub—postmasters to the raft of new _ expose sub—postmasters to the raft of new post office straight off —— wrath~ _ of new post office straight off —— wrath~ i— of new post office straight off —— wrath~ i was _ of new post office straight off —— wrath. i was being contacted over the years— wrath. i was being contacted over the years by a number of sub—postmasters who had serious losses. _ sub—postmasters who had serious losses. i'rn — sub—postmasters who had serious losses, i'm talking about 30, £40,000 _ losses, i'm talking about 30, £40,000 of losses, which they never declared _ £40,000 of losses, which they never declared to— £40,000 of losses, which they never declared to the post office because they were — declared to the post office because they were so terrified of what was going _ they were so terrified of what was going to _ they were so terrified of what was going to happen to them. they did not know— going to happen to them. they did not know what to do or how to move on from _ not know what to do or how to move on from that — not know what to do or how to move on from that position. i could see something — on from that position. i could see something like a third party that they could have gone to directly, that might have been able to assist or assist— that might have been able to assist or assist their concerns, that might have _ or assist their concerns, that might have been— or assist their concerns, that might have been useful. if

or assist their concerns, that might have been useful.— have been useful. if we can go, lastl , have been useful. if we can go, lastly. over— have been useful. if we can go, lastly, over the _ have been useful. if we can go, lastly, over the page, - have been useful. if we can go, lastly, over the page, please. l have been useful. if we can go, i lastly, over the page, please. the lastly, over the page, please. the last bullet point, in terms of the report itself, we received a full draft from a second sight yesterday which was the 6th ofjuly, on the friday, the day before, and we and fujitsu believe the draft has elements which are factually inaccurate. did you know that fujitsu were working with the post office to provide answers to concerns raised during the second sight investigation process? hat concerns raised during the second sight investigation process? hot at sight investigation process? not at this sta . e. sight investigation process? not at this stage- did _ sight investigation process? not at this stage. did you _ sight investigation process? not at this stage. did you ever _ sight investigation process? not at this stage. did you ever have - sight investigation process? not at this stage. did you ever have an i this stage. did you ever have an opportunity _ this stage. did you ever have an opportunity to — this stage. did you ever have an opportunity to meet _ this stage. did you ever have an opportunity to meet with - this stage. did you ever have an opportunity to meet with fujitsu senior managers and any technical specialists within fujitsu to discuss directly your concerns? ida. discuss directly your concerns? no, it was never — discuss directly your concerns? no, it was never an _ discuss directly your concerns? no, it was never an offer made. post office _ it was never an offer made. post office always used to take the

position— office always used to take the position that we were contracted to them _ position that we were contracted to them to— position that we were contracted to them to the post office, and it fujitsu — them to the post office, and it fujitsu was a third party, if you like. _ fujitsu was a third party, if you like, contracted to post office. so we were — like, contracted to post office. so we were not directly contracted to fujitsu _ we were not directly contracted to fujitsu or — we were not directly contracted to fujitsu or had control over anything that went _ fujitsu or had control over anything that went on then. unfortunately. the report, — that went on then. unfortunately. the report, the interim report is published on the 8th ofjuly, 2013, and if we turn to page 41 of your witness statement, please. paragraph 128. you say, i'm not sure

how many of the group saw the report or whether it was discussed and overall the interim report was positive in general as it showed there were issues occurring but we had a real concern over the interim report stating there were no systemic flaws. what was your concern about the report stating that? ~ concern about the report stating that? . .,. ., , concern about the report stating that? . ., , ., that? well, i actually thought there were systemic _ that? well, i actually thought there were systemic flaws _ that? well, i actually thought there were systemic flaws in _ that? well, i actually thought there were systemic flaws in their - that? well, i actually thought there were systemic flaws in their and i that? well, i actually thought there were systemic flaws in their and in | were systemic flaws in their and in the way— were systemic flaws in their and in the way that the post office operated and the way it dealt with people _ operated and the way it dealt with people and all the rest of it, perhaps— people and all the rest of it, perhaps not being interpreted in the way they— perhaps not being interpreted in the way they work with the computer system, — way they work with the computer system, even though there were flaws of that _ system, even though there were flaws of that nature in there. but i knew perfectly— of that nature in there. but i knew perfectly well that out of a 30 odd pa-e perfectly well that out of a 30 odd page report, the post office would jump— page report, the post office would jump on— page report, the post office would jump on one particular line or one comment. — jump on one particular line or one

comment, and that is what would be appearing _ comment, and that is what would be appearing in the media and in their press _ appearing in the media and in their press releases, and it was. to what extent did they _ press releases, and it was. to what extent did they deploy _ press releases, and it was. to what extent did they deploy that - press releases, and it was. to what extent did they deploy that line? i extent did they deploy that line? they did, they kept saying that second — they did, they kept saying that second sight, an independent investigators, found that there were no systemic flaws in horizon, they kept on _ no systemic flaws in horizon, they kept on picking that one line out of a 30 odd _ kept on picking that one line out of a 30 odd page report, which identified many of the concerns right— identified many of the concerns right across the whole of the issue. did it _ right across the whole of the issue. did it take — right across the whole of the issue. did it take until the judgments of mrjustice fraserfor did it take until the judgments of mrjustice fraser for anybody in a decision—making role to acknowledge the existence or find the existence of systemic faults and failures in the horizon system?— of systemic faults and failures in the horizon system? well, we are auoin the horizon system? well, we are going back — the horizon system? well, we are going back now — the horizon system? well, we are going back now to _ the horizon system? well, we are going back now to controlling - the horizon system? well, we are going back now to controlling the | going back now to controlling the narrative — going back now to controlling the narrative and that was the first time _ narrative and that was the first time post— narrative and that was the first time post office lost control of the narrative, — time post office lost control of the narrative, once we got into the high

court _ narrative, once we got into the high court so. _ narrative, once we got into the high court. 50, yes, that's when the truth _ court. 50, yes, that's when the truth started to come out, at that point _ truth started to come out, at that oint. . , ., truth started to come out, at that oint. . i. ., , truth started to come out, at that oint. . ., , , ., point. had you months before then, months before _ point. had you months before then, months before the _ point. had you months before then, months before the 8th _ point. had you months before then, months before the 8th of _ point. had you months before then, months before the 8th ofjuly - months before the 8th ofjuly publication, had you drawn attention to the problems with using the phrase systemic flaws and systemic failures and faults to?— phrase systemic flaws and systemic failures and faults to? yes. can we looked as 309, _ failures and faults to? yes. can we looked as 309, 8315. —— can we look at. bottom e—mail, please. thank you. this is two months before publication time, so the 12th of may. you write to ron warmington of

second sight and there is a whole heading, system errors versus systemic failures. you point out, i will not go through exactly what you said in the interest of time because we still have a lot of ground to cover, but in short order, what was your point?— cover, but in short order, what was your point? one of the points was, i have made — your point? one of the points was, i have made you _ your point? one of the points was, i have made you that _ your point? one of the points was, i have made you that post _ your point? one of the points was, i have made you that post office - your point? one of the points was, i l have made you that post office would 'ump have made you that post office would jump on _ have made you that post office would jump on it _ have made you that post office would jump on it as being the systemic failures, — jump on it as being the systemic failures, with the horizon system, and there — failures, with the horizon system, and there were system failures in there _ and there were system failures in there but— and there were system failures in there but i— and there were system failures in there but i could not understand why they felt _ there but i could not understand why they felt that was so important to put in _ they felt that was so important to put in something of that sort in their— put in something of that sort in their when— put in something of that sort in their when it was obvious that there were systemic failures in the way that post — were systemic failures in the way that post office dealt with sub—postmasters and the way they process _ sub—postmasters and the way they process things, it was a total failure — process things, it was a total failure of— process things, it was a total failure of the post office

throughout all of that. and i found it a bit— throughout all of that. and i found it a bit frustrating and even to this day. _ it a bit frustrating and even to this day, and ron warmington will remember— this day, and ron warmington will remember this this day, and ron warmington will rememberthis in great this day, and ron warmington will remember this in great detail, and we have _ remember this in great detail, and we have a — remember this in great detail, and we have a lot of discussions over this at— we have a lot of discussions over this at the — we have a lot of discussions over this at the time. he feels they got it wrong, — this at the time. he feels they got it wrong, the one thing they got wrong _ it wrong, the one thing they got wrong in — it wrong, the one thing they got wrong in that report, was that. thank— wrong in that report, was that. thank you _ wrong in that report, was that. thank you. now to the interim report, it is published on the 18th ofjuly, 2013. did you know that the post office was informed that a witness it had used in a series of prosecutions, garethjenkins, had failed to disclose to the court material which undermined the opinions that he gave, that he had not complied with his duties to the court, that his credibility as an

expert witness was undermined and that the post office had been in breach of its duties as a prosecutor and that there were a number of convicted sub—postmasters to whom disclosure of these facts should have been given but was not? hat disclosure of these facts should have been given but was not? not at that time. when _ have been given but was not? not at that time. when was _ have been given but was not? not at that time. when was the _ have been given but was not? not at that time. when was the first - have been given but was not? not at that time. when was the first time i that time. when was the first time that time. when was the first time that ou that time. when was the first time that you learned _ that time. when was the first time that you learned that _ that time. when was the first time that you learned that the - that time. when was the first time that you learned that the post - that you learned that the post office had been given that information? it office had been given that information?— office had been given that information? . , t, office had been given that information? . , . ., information? it was quite late on. to summarise _ information? it was quite late on. to summarise the _ information? it was quite late on. to summarise the first _ information? it was quite late on. to summarise the first simon - information? it was quite late on. i to summarise the first simon clarke advice? . to summarise the first simon clarke advice? , . , to summarise the first simon clarke advice? , ., , ., , , to summarise the first simon clarke advice? , , , . advice? yes. it was probably at the time of the — advice? yes. it was probably at the time of the appeal _ advice? yes. it was probably at the time of the appeal court _ advice? yes. it was probably at the time of the appeal court hearings i time of the appeal court hearings for the _ time of the appeal court hearings for the overturned convictions, that is when _ for the overturned convictions, that is when it— for the overturned convictions, that is when it really started... for the overturned convictions, that is when it really started. . ._ is when it really started... 2021? yes. is when it really started... 2021? yes- was — is when it really started... 2021? yes. was anything _ is when it really started... 2021? yes. was anything ever - is when it really started... 2021? | yes. was anything ever discussed is when it really started... 2021? i yes. was anything ever discussed or even hinted — yes. was anything ever discussed or even hinted at _ yes. was anything ever discussed or even hinted at in _ yes. was anything ever discussed or even hinted at in all— yes. was anything ever discussed or even hinted at in all of— yes. was anything ever discussed or even hinted at in all of the _

even hinted at in all of the meetings that you held, all of the conversations that you were a party to, all of the letters that you wrote, all of the e—mail exchanges that you had with everyone at the post office from alice perkins, paula vennells down? about such problems with convictions? ida. were problems with convictions? no. were there any convicted sub—postmasters within it at that time? yes. i read it was about _ within it at that time? yes. i read it was about a _ within it at that time? yes. i read it was about a third _ within it at that time? yes. i read it was about a third of— within it at that time? yes. i read it was about a third of them, and that must vary over the course of time. what was the proportion? br; time. what was the proportion? by the time we got to the] and o, the time we got to the] and 0, about— the time we got to the] and 0, about 60 — the time we got to the] and 0, about 60 of them, about 10%, roughly — about 60 of them, about 10%, roughly. in fact, that had been the issue _ roughly. in fact, that had been the issue that — roughly. in fact, that had been the issue that had caused problems with the original lawyers that were

supporting us,