here by a were being challenged here by a trusted — were being challenged here by a trusted sub—postmaster and her husband. — trusted sub—postmaster and her husband, won't you? | trusted sub-postmaster and her husband, won't you?— trusted sub-postmaster and her husband, won't you? i didn't know them and i — husband, won't you? i didn't know them and i had _ husband, won't you? i didn't know them and i had nothing _ husband, won't you? i didn't know them and i had nothing to - husband, won't you? i didn't know them and i had nothing to dispute| them and i had nothing to dispute that they were anything other than trusted. did that they were anything other than trusted. , , ., ., . , that they were anything other than trusted. , , ., ., ., , ., trusted. did you do anything to investigate _ trusted. did you do anything to investigate whether _ trusted. did you do anything to investigate whether what - trusted. did you do anything to | investigate whether what tracey trusted. did you do anything to - investigate whether what tracey told you was _ investigate whether what tracey told you was right in light of this interview? i didn't, you was right in light of this interview? ididn't, i you was right in light of this interview? i didn't, itook you was right in light of this interview? i didn't, i took it at face _ interview? i didn't, i took it at face value _ interview? i didn't, i took it at face value. it was all kind of back to back, — face value. it was all kind of back to back, coming into this meeting. it is to back, coming into this meeting. it is at _ to back, coming into this meeting. it is at 4:59pm on the monday, it is at liz59pm on the monday, sorry, on the wednesday. and this is on the thursday. this wasn't my meeting. it was kevin's meeting. he asked me to come in and support him, i thought more from an operational perspective. i think kevin did work and a branch at some point, but he didn't have the relevant and

up—to—date experience that i had, and i thought that was why i was there. and that the e—mail from tracy came in very late and i took that advice value. i had no reason to doubt what tracy was saying. i trust her in terms of her professionally, having worked with her a number of years after this. i had no reason to doubt what she said or passed on. that had no reason to doubt what she said or passed on-— or passed on. that is what is going around in my _ or passed on. that is what is going around in my head. _ or passed on. that is what is going around in my head. at _ or passed on. that is what is going around in my head. at 4:59pm, i or passed on. that is what is going around in my head. at 4:59pm, ifl around in my head. at 4:59pm, if i've got what you just said, you get information from her to the effect that, in certain circumstances, fujitsu... you have no reason to doubt what she told you. the following day, you are being challenged at the post office and whether they can do the same, in effect, and you were saying unequivocally, no, they can't. but

what you while not saying, even if it is only to yourself... hang on a minute, fujitsu can do this, so shouldn't i be looking at that? what shouldn't i be looking at that? what i didn't do shouldn't i be looking at that? what i didn't do in — shouldn't i be looking at that? what i didn't do in that _ shouldn't i be looking at that? transit i didn't do in that meeting shouldn't i be looking at that? “ta"usgt i didn't do in that meeting is shouldn't i be looking at that? ita�*ué�*ii i didn't do in that meeting is i didn't volunteer that information. why is that?— didn't volunteer that information. wh isthat? , ., why is that? this, for me, i wasn't reall , why is that? this, for me, i wasn't really. from _ why is that? this, for me, i wasn't really. from my — why is that? this, for me, i wasn't really, from my understanding, - why is that? this, for me, i wasn't really, from my understanding, on| really, from my understanding, on solid ground because i haven't talked to anybody about it, i took it at face value and i didn't understand the technical aspects, so therefore i was relaying. kevin was therefore i was relaying. kevin was the most senior person, he had obviously been involved in those discussions was tracey. i was basically answering some of the questions. mark had said somebody in fujitsu can, and i accepted, but not

without it being locked. that fujitsu can, and i accepted, but not without it being locked.— without it being locked. that can come down- _ without it being locked. that can come down- i — without it being locked. that can come down. i will— without it being locked. that can come down. i will move - without it being locked. that can come down. i will move forward | without it being locked. that can l come down. i will move forward a number— come down. i will move forward a number of— come down. i will move forward a number of years to the evidence you .ave number of years to the evidence you gave iri— number of years to the evidence you gave in the _ number of years to the evidence you gave in the horizon issues trial. i should _ gave in the horizon issues trial. i should say— gave in the horizon issues trial. i should say that i will leave the question— should say that i will leave the question of your role in the tmild-up— question of your role in the build—up to the trial and your role in the _ build—up to the trial and your role in the group litigation generally to others _ in the group litigation generally to others to— in the group litigation generally to others to ask questions about and, in every— others to ask questions about and, in every other respect, the evidence you gave _ in every other respect, the evidence you gave to— in every other respect, the evidence you gave to others to ask questions about _ you gave to others to ask questions about and — you gave to others to ask questions about. and the findings that mrjust fraser— about. and the findings that mrjust fraser made to others to ask a question— fraser made to others to ask a question about. this is the only thing _ question about. this is the only thing i— question about. this is the only thing i witi— question about. this is the only thing i will ask you about. can we took— thing i will ask you about. can we took at _ thing i will ask you about. can we took at the — thing i will ask you about. can we look at the next one, please? can you see _ look at the next one, please? can you see that this is the 18th of march — you see that this is the 18th of march 2019, in the high court? this is a transcript of the evidence you gave _ is a transcript of the evidence you ave. , if is a transcript of the evidence you gave- if we _ is a transcript of the evidence you gave- if we go _ is a transcript of the evidence you gave. yes. if we go forward to page

53. you gave. yes. if we go forward to page 53- you are — gave. as; if we go forward to page 53. you are being asked gave. 123 if we go forward to page 53. you are being asked questions here by— 53. you are being asked questions here by mr— 53. you are being asked questions here by mr patrick green, kings council. — here by mr patrick green, kings council. on _ here by mr patrick green, kings council, on the half of the claimants. he is asking you about a witness _ claimants. he is asking you about a witness statement you made in november 2018. witness statement you made in november2018. he witness statement you made in november 2018. he says, and you made this witness _ november 2018. he says, and you made this witness statement in november 2018, _ this witness statement in november 2018. this _ this witness statement in november 2018, this was something you were aware _ 2018, this was something you were aware of— 2018, this was something you were aware of when you made this witness statement, _ aware of when you made this witness statement, isn't it? you say, yes. ie, statement, isn't it? you say, yes. it, the _ statement, isn't it? you say, yes. if, the possibility of inserting transactions. you see the possibility, but i have never seen this happen or stop the possibility of it, _ this happen or stop the possibility of it. yes — this happen or stop the possibility of it, yes. he says, how long have you known— of it, yes. he says, how long have you known about that possibility? the possibility of inserting transactions. you say this is something i have not, because i've not experienced it myself. i've not known _ not experienced it myself. i've not known of— not experienced it myself. i've not known of it— not experienced it myself. i've not known of it that long, actually. he

asks, _ known of it that long, actually. he asks, coutd — known of it that long, actually. he asks, could you give the court a rough _ asks, could you give the court a rough idea _ asks, could you give the court a rough idea of how long you have known _ rough idea of how long you have known it — rough idea of how long you have known it was possible? you see, in terms _ known it was possible? you see, in terms of— known it was possible? you see, in terms of inserting transactions, the last year— terms of inserting transactions, the last year or— terms of inserting transactions, the last year or so. question, who told you about — last year or so. question, who told you about it? you see, fujitsu. just io you about it? you see, fujitsu. just go back— you about it? you see, fujitsu. just go back to — you about it? you see, fujitsu. just go back to the bottom of that page. you are _ go back to the bottom of that page. you are telling the court that the first time — you are telling the court that the first time you knew of the possibility of inserting transactions was in the last year. or so, _ transactions was in the last year. or so, yes — transactions was in the last year. or so. yes-— transactions was in the last year. l or so. yes-_ at or so, yes. that was. wasn't it? at the time. — or so, yes. that was. wasn't it? at the time. i — or so, yes. that was. wasn't it? at the time, i didn't _ or so, yes. that was. wasn't it? at the time, i didn't think _ or so, yes. that was. wasn't it? at the time, | didn't think it _ or so, yes. that was. wasn't it? at the time, i didn't think it was. - the time, i didn't think it was. what had been happening was the message — what had been happening was the message on the remote access kept

changing _ message on the remote access kept changing. so we would ask... they would _ changing. so we would ask... they would be _ changing. so we would ask... they would be some information that says there were _ would be some information that says there were claims of this happening, then we _ there were claims of this happening, then we get pushback that it didn't happen _ then we get pushback that it didn't happen. coming into the gl oh, we were— happen. coming into the gl oh, we were stilt— happen. coming into the gl oh, we were still asking questions of fujitsu — were still asking questions of fujitsu and still getting changing messages. for me, this was about the balance _ messages. for me, this was about the balance in— messages. for me, this was about the balance in transaction, which was the first— balance in transaction, which was the first formal recognition i knew of inserting a transaction, other than _ of inserting a transaction, other than the — of inserting a transaction, other than the legacy system, but it was the balancing transaction that i have _ the balancing transaction that i have since learned had been used in march _ have since learned had been used in march 2010. when it answered the question. — march 2010. when it answered the question, that is what i had in my head, _ question, that is what i had in my head. which— question, that is what i had in my head, which was... i couldn't head, which was... icouldn't remember— head, which was... i couldn't remember the date, head, which was... i couldn't rememberthe date, and i head, which was... i couldn't remember the date, and i still don't know— remember the date, and i still don't know the _ remember the date, and i still don't know the date, but it was leading into the _ know the date, but it was leading into the trial that i became aware that that — into the trial that i became aware that that was actually something that that was actually something

that had — that that was actually something that had happened. you use the words formally— that had happened. you use the words formally and actually in the answer you gave — formally and actually in the answer you gave. in what way whether the communications of december 2010 and january— communications of december 2010 and january 2011 not formal or actual communications of the position? because — communications of the position? because the position changed after that. we were asking... i never actually spoke to fujitsu myself about this, and i never spoke to the it guys directly in terms of adding the claim. the position was changing from within post office that these things were not possible. it was only when i had the balancing transaction information confirmed that that really registered with me that that really registered with me that that really registered with me that that was the formal position, and there was evidence of that having not —— having taken place in

march 2010. having not -- having taken place in march 2010-— having not -- having taken place in march 2010. ., , , march 2010. you were suggesting here that ou had march 2010. you were suggesting here that you had only _ march 2010. you were suggesting here that you had only come _ march 2010. you were suggesting here that you had only come to _ march 2010. you were suggesting here that you had only come to know- march 2010. you were suggesting here that you had only come to know about | that you had only come to know about fujitsu's _ that you had only come to know about fujitsu's ability to insert transactions in mid—2018? fujitsu's ability to insert transactions in mid-2018? . ., transactions in mid-2018? yeah, that would have been... _ transactions in mid-2018? yeah, that would have been... my _ transactions in mid-2018? yeah, that would have been... my recollection i would have been... my recollection is going into the gl oprah, so about 2017 which have been my recollection, but i couldn't put a date on it. recollection, but i couldn't put a date on it— recollection, but i couldn't put a dateonit. , �* ., date on it. why didn't you say, hold on, iwas date on it. why didn't you say, hold on. i was told _ date on it. why didn't you say, hold on, i was told about _ date on it. why didn't you say, hold on, i was told about it _ date on it. why didn't you say, hold on, i was told about it in _ date on it. why didn't you say, hold on, i was told about it in december| on, i was told about it in december 2010? _ on, i was told about it in december 2010? 0r— on, i was told about it in december 2010? orjanuary 2011? asl on, i was told about it in december 2010? or january 2011?— on, i was told about it in december 2010? orjanuary 2011? as i say, at that point. _ 2010? orjanuary 2011? as i say, at that point. the — 2010? orjanuary 2011? as i say, at that point, the messaging - 2010? orjanuary 2011? as i say, at that point, the messaging had - 2010? orjanuary 2011? as i say, at| that point, the messaging had been changing. i’m that point, the messaging had been chanatin. “ ., that point, the messaging had been chanatin. �* ., . that point, the messaging had been chanttin. “ ., . changing. i'm not concerned about messaging. _ changing. i'm not concerned about messaging. i'm — changing. i'm not concerned about messaging, i'm more _ changing. i'm not concerned about messaging, i'm more interested . changing. i'm not concerned aboutj messaging, i'm more interested in the facts —

messaging, i'm more interested in the facts. ., messaging, i'm more interested in the facts. . ., , messaging, i'm more interested in the facts. ., , messaging, i'm more interested in thefacts. . , the facts. that was my recollection at the time. _ the facts. that was my recollection at the time, that _ the facts. that was my recollection at the time, that it _ the facts. that was my recollection at the time, that it was _ the facts. that was my recollection at the time, that it was the - at the time, that it was the balancing transaction that, for me, was that formal recognition from fujitsu that that could be done. just by way of a side issue at the moment. — just by way of a side issue at the moment. in— just by way of a side issue at the moment, in paragraph 223 of your witness _ moment, in paragraph 223 of your witness statement, you see that you recall— witness statement, you see that you recall discussions between the post office _ recall discussions between the post office legal and it teams, fujitsu and garethjenkins in the course of the preparation for the civil litigation, but you were not involved _ litigation, but you were not involved in those discussions, and therefore — involved in those discussions, and therefore you cannot assist for the amount— therefore you cannot assist for the amount by— therefore you cannot assist for the amount by which they provided assistance.— amount by which they providedj assistance._ can amount by which they provided - assistance._ can you assistance. that is correct. can you confirm that _ assistance. that is correct. can you confirm that you _ assistance. that is correct. can you confirm that you had _ assistance. that is correct. can you confirm that you had no _ assistance. that is correct. can you confirm that you had no contact - assistance. that is correct. can you | confirm that you had no contact with

mrjenkins _ confirm that you had no contact with mrjenkins or fujitsu with regard to the witness statement you gave in the witness statement you gave in the high— the witness statement you gave in the high court? | the witness statement you gave in the high court?— the high court? i think... i think there might _ the high court? i think... i think there might of _ the high court? i think... i think there might of been _ the high court? i think... i think there might of been two. - the high court? i think... i think there might of been two. i - the high court? i think... i think| there might of been two. i spoke the high court? i think... i think. there might of been two. i spoke to gareth about some of the issues at the time that helen rose was looking at that. 50 the time that helen rose was looking at that. ., ., , the time that helen rose was looking at that. ., .,, . ,, at that. so that was back where the events were — at that. so that was back where the events were happening, _ at that. so that was back where the events were happening, not - at that. so that was back where the events were happening, not in - events were happening, not in preparation for the yellow? is that right? _ preparation for the yellow? is that ri t ht? ., “ . preparation for the yellow? is that ritht? ., v . ., right? that's right. although the helen rose _ right? that's right. although the helen rose report _ right? that's right. although the helen rose report was _ right? that's right. although the helen rose report was part - right? that's right. although the helen rose report was part of. right? that's right. although the i helen rose report was part of that. to be clear, you are not aware whether— to be clear, you are not aware whether you spoke to mrjenkins again— whether you spoke to mrjenkins again in— whether you spoke to mrjenkins again in preparation? i whether you spoke to mrjenkins again in preparation?— whether you spoke to mrjenkins again in preparation? i don't think i did. i again in preparation? i don't think idid- idon't _ again in preparation? i don't think i did. i don't know— again in preparation? i don't think i did. i don't know gareth - again in preparation? i don't think i did. i don't know gareth jenkins, i did. i don't know garethjenkins, there was some e—mail correspondence, and i may have spoken to him once or twice, but i don't remember the details. sol

spoken to him once or twice, but i don't remember the details. so i did have some correspondence about him, but i think that was previously, and i don't know if i spoke to him about the angela burke information, directly or not. did the angela burke information, directly or not.— the angela burke information, directly or not. did you ever meet with gareth _ directly or not. did you ever meet with gareth jenkins? _ directly or not. did you ever meet with gareth jenkins? no. - directly or not. did you ever meet with gareth jenkins? no. you - directly or not. did you ever meet with gareth jenkins? no. you say| with gareth jenkins? no. you say that under— with garethjenkins? the. you say that under cross—examination. in paragraph — that under cross—examination. in paragraph 214 of your witness statement, if we turned that up, please. — statement, if we turned that up, please, which is on page 101... paragraph 214, you are dealing with

your common issues witness statement here. _ here. you see in here. - you see in the here. — you see in the second line, for the most part, this was derived from my own knowledge. most part, this was derived from my own knowledge-— most part, this was derived from my own knowledge. some of which would have been drawn _ own knowledge. some of which would have been drawn from _ own knowledge. some of which would have been drawn from documents - own knowledge. some of which would have been drawn from documents you read over— have been drawn from documents you read over the years. so that wasn't derived _ read over the years. so that wasn't derived from any conversations you had with— derived from any conversations you had with mr— derived from any conversations you had with mrjenkins at that time? sorry? _ had with mrjenkins at that time? sor ? . ., , ., , ., had with mrjenkins at that time? sor ? ., sorry? the contents of your common issues statement. _ sorry? the contents of your common issues statement. that _ sorry? the contents of your common issues statement. that was - sorry? the contents of your common issues statement. that was more - issues statement. that was more broadly about _ issues statement. that was more broadly about post _ issues statement. that was more broadly about post office - issues statement. that was more broadly about post office and - issues statement. that was more | broadly about post office and how issues statement. that was more i broadly about post office and how it operated. broadly about post office and how it o terated. ~ ., broadly about post office and how it o-erated. ~ . ., ., ., operated. what about the horizon issues? does _ operated. what about the horizon issues? does any _ operated. what about the horizon issues? does any of _ operated. what about the horizon issues? does any of that - operated. what about the horizon issues? does any of that come . operated. what about the horizon l issues? does any of that come from conversations with mrjenkins? | conversations with mrjenkins? i don't conversations with mrjenkins? don't think conversations with mrjenkins? i don't think i had a conversations with mrjenkins? i don't think i had a conversation. i don't think i had a conversation. i don't remember, but i don't believe i spoke to gareth. {lila don't remember, but i don't believe i spoke to gareth.— i spoke to gareth. ok, thank you. that can come — i spoke to gareth. ok, thank you. that can come down. _ i spoke to gareth. ok, thank you. that can come down. for - i spoke to gareth. ok, thank you. that can come down. for the - i spoke to gareth. ok, thank you. | that can come down. for the group litigation. _ that can come down. for the group litigation, were you asked to participate in any group disclosure exercise _

participate in any group disclosure exercise crusher mug no, not that i remember~ — exercise crusher mug no, not that i remember. he were not asked to look at your— remember. he were not asked to look at your e—mails? to turn up, for example. — at your e—mails? to turn up, for example, the e—mail of the 5th of december— example, the e—mail of the 5th of december or the 5th ofjanuary? | december or the 5th ofjanuary? i think december or the 5th ofjanuary? think the december or the 5th ofjanuary? i think the disclosure exercise was done within the business and everything was pulled that way. i don't remember being asked to go back and look at anything or to search on my particular laptop for anything. did search on my particular laptop for an hint. , , ., search on my particular laptop for an hint., , ., anything. did you yourself go back and look at _ anything. did you yourself go back and look at your _ anything. did you yourself go back and look at your e-mails - anything. did you yourself go back and look at your e-mails or - anything. did you yourself go back and look at your e-mails or otherl and look at your e—mails or other document— and look at your e—mails or other document repositories so that you could _ document repositories so that you could consider your state of knowledge on the issues relevant to the horizon— knowledge on the issues relevant to the horizon issues trial, for the purposes— the horizon issues trial, for the purposes of preparing your witness statement or your oral evidence? no. so ou statement or your oral evidence? no. so you didn't — statement or your oral evidence? the. so you didn't think, i will be asked about— so you didn't think, i will be asked about horizon integrity, i should look at _ about horizon integrity, i should look at nry— about horizon integrity, i should look at my e—mail account to see what _ look at my e—mail account to see what i _ look at my e—mail account to see what i have — look at my e—mail account to see what i have received over time about

horizon _ what i have received over time about horizon integrity so i can give straightforward and open evidence? i never searched back. i don't remember the december e—mails, and i wouldn't have known to look at that because i don't even remember receiving them. the ferndown interview, it was less about the horizon integrity and remote access, it was more about supporting kevin in that meeting and it was about the relationship reset. so i didn't, going into the two trials, search through my e—mails regarding that. i would have forgotten about those e—mails, anyway. i don't even remember having the one from john. is that not the reason, if you're giving — is that not the reason, if you're giving evidence in court under oath, you might _

giving evidence in court under oath, you might perform an exercise in self reflection and check your emails? _ self reflection and check your e—mails? | self reflection and check your e-mails?_ self reflection and check your e-mails? , ., , “ e-mails? i wish i had, but i didn't. so ou e-mails? i wish i had, but i didn't. so you maintained _ e-mails? i wish i had, but i didn't. so you maintained that _ e-mails? i wish i had, but i didn't. so you maintained that the - e-mails? i wish i had, but i didn't. | so you maintained that the e-mails so you maintained that the e—mails we have _ so you maintained that the e—mails we have looked at of december 2010 and january 2011 were not either showing — and january 2011 were not either showing to you by solicitors preparing your witness statement or found _ preparing your witness statement or found by— preparing your witness statement or found by you as part of an evidence readying _ found by you as part of an evidence readying session?— readying session? yes, i don't remember- — readying session? yes, i don't remember. it _ readying session? yes, i don't remember. it was _ readying session? yes, i don't remember. it was only - readying session? yes, i don't| remember. it was only coming readying session? yes, i don't - remember. it was only coming into this exercise that i remembered the ferndown being involved at all. did you conduct any exercise on self reflection. _ did you conduct any exercise on self reflection, searching your own diaries— reflection, searching your own diaries or— reflection, searching your own diaries or e—mail inboxes and sent items. _ diaries or e—mail inboxes and sent items, looking for any notes you may have made? — items, looking for any notes you may have made? for items, looking for any notes you may have made?— have made? for the horizon trial? yes.