Thread by @nickwallis

Okay apologies for the late start. I was writing a piece about something the Post Office QC said yesterday about Horizon and aeroplanes. it’s here: postofficetrial.com/2019/03/horizo…
#postofficetrial
The first witness is in the box. Live tweets to follow.

Mr Adrees Latif’s image is in the witness box. He is being beamed to us via skype from Islamabad. He is being cross-examined by the PO silk Owain Draper. Mr Latif is a former Subpostmaster and presumably a claimant (I don’t have his witness statement yet).

He has been asked how often he was at his branch and the trusted staff he left behind when he wasn’t in the branch. The two senior staff were a female ex-police officer and a male old friend both of whom he trusted explicitly.

I now have Mr Latif’s WS. He is still a serving Postmaster at the Caddington branch in Bedfordshire.

Mr Draper is now taking Mr Latif through a £2000 stock transfer descibed in Mr Latif's WS.

£2K was transferred from one stock tray to another in July 2015. Not an unusual transation. Mr Latif says: "When I moved over to the second stock unit to transfer £2,000 in, I noticed that £2,000 had not transferred to this stock unit successfully…"

“… I immediately performed a cash declaration on the first stock unit and confirmed that £2,000 had left this unit. I also checked the CCTV to make sure that I had performed the transaction correctly. It was the case that £2,000 had simply disappeared from Horizon."

“… Given that I carried out the transaction correctly, I believe that some sort of bug or defect in Horizon caused the discrepancy, quite possibly during the transfer. Certainly Horizon’s limitations in terms of accessing data and reporting functions made it…"

“.. difficult to interrogate the system and locate the source of the error."

“…. I do not know whether the Post Office had any additional ability to identify the source of the error but I called the Helpline who said that there was nothing they could do. There was therefore a shortfall in the Branch account for £2,000."

Mr Draper (let’s call him POB - Post Office Barrister) has taken Mr Latif to a witness statement from Angela van den Bogerd (senior PO bod) which describes the correct process for stock transfers.
Mr Draper is asking him to go through the stock transfer in more detail.

POB “You logged into stock unit AA and you identified the stock unit SP1 that you wanted to transfer the funds?”
AL: “Correct. It’s mandatory.”
POB “It happens automatically”
AL: Yep
POB: You can print another one if you want too can’t you?
AL: Yep

POB: And you need to sign that slip
AL: Yep and you need to generate a slip from the stock unit you’re transferring into
POB: Yep
POB now checking everything had gone according to plan so far. AL agrees.
POB: So you walked from one stock unit to the other carrying £2000 cash?

AL: Yep
POB: And you say you noticed immediately that the £2K had not transferred on Horizon.
AL: Correct.

POB: I’m going to take you through how you think you came to notice this immediately (he does so). AL is agreeing
POB: to check I understand correctly it had disappeared in the sense it was not available as a transfer in.
AL: Correct

POB: You then say you immediately performed a cash declaration on stock unit AA
AL: Correct
POB: This involved you manually counting the cash
AL: Correct
POB: You say the stock unit balanced. Now what you mean by this is that if we assume there was ...

… £10K in the stock unit and £10K according to H. After the transfer there was £8K physical cash and £8K in Horizon. So it matched.
AL: Correct.

POB: Apart from this cash declaration you dont’ identify any other steps you took
AL: I’m happy to take you through them
POB: We’ll come back to that in a minute
AL: I have been with the Post Office for 17 years. I am a post office trainer. I train people up on the new H sofftwar

AL: So I am happy to take you through the process we did to show you that there was no operator error on our behalf.
POB: Let’s do that a bit more quickly. You know what you could have done to print the reports and get to the bottom of what could have gone on.
AL: Yep

POB: You say you went to check the CCTV to check you had done things correctly. But you would have known what you’d done from getting the various reports from H.
AL: Yes but we wanted to double check everything very carefully because H has glitches in it. I’ve seen it in

… other branches and i’ve seen it in my own. By looking at CCTV we wanted to double check there was no theft and nothing untoward had happened.

POB: The process you have described was you personally ensuring you took every step. You carried out the transfer. You physically moved the cash. You tried to process the transfer in on SP1 but you say that failed.
AL: wants to add something which he thinks with hindsight...

… should be in his statement. He reversed the transfer from the incoming stock unit.
POB: Why didn’t you say this in your WS.
AL: I’m not sure. But when I wrote the WS I had lost my father and was going through a period of distress.
POB: I am sorry for your loss.

POB: But earlier this month, you had an oppo to review your WS and you didn’t add this important detail.
AL: I am sorry sir. We are very busy running around. It’s never too late and I am sorry I didn’t add this detail. I tried to keep my WS as simple as possible.

POB: Okay lets’ go back to the CCTV. You did all the transfer. All the actions. Why did you look at the CCTV. You did it all, didn’t you?
AL: Yep
POB: Why then review the CCTV?
AL: to ensure everything was done correctly
POB: But you hadn’t taken the £2K out of branch, had you?

AL: No I wanted to prove to my colleagues all the correct procedures were followed.
POB: So you’re no longer saying you wanted to check the money hadn’t been stolen?
AL: I just wanted to make sure it was done correctly. To be absolutely confident the correct procedure was...

… followed. By the book.

More queries follow from POB about CCTV.
POB: That footage you took would confirm important parts of your evidence, wouldn’t it?
AL: Yes
POB: And it might help you dispute responsibility for your shortfall.
AL: Yet you haven’t provided that CCTV to PO in these proceedings?

AL: Yep
POB: Why not?
AL: It was a long time ago. We were happy it was all done properly. I showed my colleague and we were satisfied. The thing is with you guys, the Post Office - we’re always wrong. we aways have to put the money in. we’re always liable.

So I put the money in. My own money. we have to balance the books, so I balanced the books. It’s in my contract. We have to do it. It’s always our fault.

I’m a professional and i’m lucky that I can afford to put the money in, but not everyone can do that and that’s why I’m disappointed in the Post Office because of your behaviour.
POB: I’m not sure that answers the question.

We have moved on to the part of Mr Latif’s statement where he complains that "Horizon’s limitations in terms of accessing data and reporting functions made it difficult to interrogate the system and locate the source of the error."

POB: that’s not true. You’ve just said in your evidence H provided you with lots of tools to find out what had happened.
You’ve already said H provided you with the ability to do a cash balance and get reports from each stock unit.
AL agrees

POB: So if your evidence was correct that the transfer out succeeded and the transfer in failed, you would be able to see it all.
AL: yeah but what happened in between - that’s what I want to know. That’s what you’re skirting round and that’s the issue.

POB: You could have phoned the helpline, couldn’t you?
AL: yes but I’m very experienced and so were my two colleagues. so we didn’t
POB: so you and your two assistants were so so experienced you didn’t need to calll the helpline to find out what might have happened.

AL: yes we did ring em. I’m not saying we didn’t. But the helpline is not very good. They’ve got ineperienced people in a call centre we don’t know where. It’s not a helpline. It doesn’t help. Thats’ my personal view.

POB: Okay well let’s have a look at what happens when you and your colleagues do phone the helpline...

POB is taking AL to a helpline log.
POB: you call and say:“is there a report they can do to check what has been transferred through the units”
POB and the answer is “yes”
POB so in Nov 2014 one of your assistants called the helpline and asked how to identify trnsfers and was...

… given the correct answer. Yes?
AL: yes.

Tweeetdeck has almost frozen up. Am rebooting. Wait out.

Mr Draper (POB) is trying to get to the bottom of what Mr Latif (AL) did or didnt’ do to try to get to the bottom of the £2k discrepancy which happened during a cash transfer between stock units. AL has added so much to the witness statement I am a little lost as to where we...

… are.
POB is taking AL through the helpline call logs for other issues raised by his branch.

POB pointing out that people in AL’s branch make mistakes.
AL counters that people make mistakes everywhere.
POB asks about a specific incident and asks how he mitigates mistakes.
AL says that if a mistake is identified it can either be staff or it can be by the issuing..

… of a transaction correction by the Post Office.
AL says the TC situation is hit and miss - it often depends on who is running the helpline.
POB and how well you explain the problem
AL yes but the helpline operators can be very hit and miss.

POB taking AL through the call logs and says that they don’t show the call that AL says he made to the helpline.
AL can’t explain why. Suggests it might be a mistake.
POB Post Office contends you did not make a call to the helpline.

J intervenes as why the logs are not in chronological order
POB not sure, but says the point is these are ALL the calls logged between June - August 2016
POB Mr Latif in your WS you say there was a shortfall in your branch accounts is that there was a £2K shortfall.

… in your branch accounts. PO records say there is no record of a shortfall. Can you explain that?
AL - we made it good before the end of the month
POB - but your variance checks, balance snapshots, balance checks and report generation would leave a trace of this discrepancy

…. wouldn’t it?
AL: yep
POB: so why isn’t the discrepancy there?
AL: don’t know
POB: coming back to this shortfall you allege, when did you say you became aware of the shortfall?
AL: immediately after the cash declaration
POB on which stock unit
AL: SP1?

POB: let’s go back to your witness statement. At par 7 you describe doing a cash dec on AA to see that the £2K had gone out.
AL: yes
POB not in your WS, but you now say you did another cash dec which showed a shortfall. yes?
AL: yes
POB was this before you say you reversed...

… the transfer in?
AL [unclear]
POB: why do you give no evidence about finding and failing to investigate a £2K shortfall in AA?
AL: eh?
POB: look at your WS, Mr latif
AL can you repeat the q?

POB: why do you not say anything in your WS about finding this shortfall in stock unit AA and investigating it?
AL: I am an experienced SPMR and I wrote this for people who are not that experienced in the ways of the PO, but in hindsight I perhaps should have.

AL: the fact remains the £2K disappeared. That definitely happend.
POB: are you saying the cash disappeared too?
AL: the system showed a shortfall

POB are you now saying that immediately after the transfer failed there was a £2k shortfall in stock unit in AA - after you had reversed the transfer out and after you had put the £2K back in AA
AL yep
POB so on your account the physical amount of cash would be the same.

POB you took it out and put it back
AL correct
POB you say tho, that there was a shortfall in that stock unit
AL yep
POB logically that must mean that the H cash figure MUST have gone up £2K
AL blusters
POB On your account the only thing that could have caused this is by...

[there is a distraction in court]

POB if your account were right, the problem would be the Horizon cash figure in AA would suddenly have gone up by £2k - that’s right isn’t it?
AL something went wrong with the transfer
POB answer my question - the H stock figure would have...

… to have gone UP by £2K for there to be an error as there was the same amount of cash in AA when you put it back in?
AL it was lost in the transfer
POB: it would have been very easy for you to identify this error then and put it in your WS, wouldn’t it? That AA went up by

… £2K.
AL that’s what I’m saying
POB you said you had to put £2K of your own money into the branch
AL yep
POB did you dispute this?
AL we are liable
POB even if it’s a computer glitch
AL yes sir we are liable

POB mr latif we don’t accept there was a shortfall or that you paid it in, but if you genuinely believed that this was a glitch and you were not responsible - is it not surprising you didn’t raise it
AL I complained to the area manager a number of times. Don’t know why...

… you’re saying this.
POB so are you saying you raised this with your area manager and raised a complaint.
AL yeah we would have had a discussion. This has happened a number of times before. Many times. It’s a software error.
J what is the name of your area manager?

AL: Nabjot Jando
J: good. can you concentrate on Mr Drapers' specific questions
AL yes
POB did you call your area manager and tell him you have suffered a £2K loss as described
AL yes
POB why did you not put this in your WS
AL I didn’t think it was relevant

POB: do you accept you did not call the helpline?
AL: there would have been a call to the helpline. I’m not quite sure why it isn’t showing up.
POB let me take you through the PO case [he refers to Mrs van den Bogerd’s statement - i can’t see this]
POB: AvdB has taken the...

… transaction and event data. And says that for every £2k transfer out there was a corresponding £2K transfer in.

[sticky wicket for AL here. There appears to be no evidence for this “missing" £2K anywhere]

POB the underlying transaction data for July 2015 says there was no £2K transferred in or out in the month you described this happening. Shall we look at June or are you confident it happened in July.
AL: Why not while we’re here?

POB takes AL to spreadsheet filtered to show only transfers out and in.
POB scan your eye down column L - there are no £2K transfers on this spreadsheet.
AL is looking at it.

There is a long silence.
J: I’m not really sure where this is going to get us. It’s got how many entries? It’s not really fair
POB: Mr Latif, PO says there are no £2K entries - do you accept that?
AL: maybe if that’s what they say, but there was a software glitch

J: how often did you have to replenish the cash in SP1 from AA
AL: quite regularly - at least every other day

POB: there were two £2K transfers in July 2015, but they were both successful
AL how do you define successful?
POB takes AL to the relevant spreadsheet.
POB this data shows a successful transfer out of £2K by Christine Barnett and a £2K transfer in by Christine Bensom.

AL: yep
J asks POB to be specific:
POB:
the transfer out of AA at 13:52:22 for 21/07/2015 by Christine Barnett

transfer in SP1 21/07/2015 at 13:55:01 Christine Fensom also for £2K

J asks him to read the other 2 out.
POB these are back office inverse transactions which the SPMR can’t see on his printouts.
J I see. Next:
POB:
transfer out of SP1 by Mr Deecock on 29/07/2015 of £2K
transfer into AA by Mohammad Latif (AL's brother)
POB was he registered?

AL: yes
ML’s transfer in 29/07/2015 at 11:50:30 - a minute after the transfer out of £2K.
So we say in July 2015 there were two transfers and both succeeded.
AL what’s the def of succeeded? What’s the cash figure? You only know it works if the cash declaration says it worked.

POB we are going on your evidence. There is no evidence for a transfer out, but no transfer in. Do you follow that?
AL I follow that, but there was a glitch. There are time it worked, there are times it didn’t work. That’s what I’m saying.

POB: AvdB look at the rest of the transfers for the stock units and they were all successful. Do you want me to take you through it?
AL no
POB: Post Office says your transfer never happened?
AL you call me a liar
POB you may be mistaken or you may be lying. ...

…. the point is there is no evidence of these transactions taking place. Are you saying they are wrong?
AL yes.

We move on to the part of AL's WS about Transaction Acknowledgments.

From the WS: "In or around January 2018, Camelot sent information to Horizon in relation to scratch cards. Camelot sent this information to Horizon twice.” (par 9)

"Shortly after this, I received a notice from Post Office saying that Camelot had made a mistake and that Post Office would send me a Transaction Correction to put the mistake right."

"I received the Transaction Correction from Post Office and accepted the Transaction Correction. However, the stock figure of scratch cards remained unchanged and Horizon …"

“...showed that I had an extra £1,000 worth of scratch cards showing, despite not having these in a physical form. Therefore, the Transaction Correction did not work."

"In order to rectify this, I would either have to produce the £1,000 worth of scratch cards, which I did not have, or remove £1,000 worth of scratch cards manually from Horizon. The latter would result in a £1,000 loss on Horizon."

"I have been in touch with Post Office in relation to this issue but it has not been rectified."

"It is clear to me that there is an issue with how Horizon has processed this Transaction Correction. The difficulties with accessing data and reporting functions within Horizon means I cannot confirm what the precise issue is."

POB: Why is paragraph 9 so vague?
AL gives a long explanation in which he says that the helpline told him that this mistake had happened in every post office in the country.
POB: when did you phone the helpline
AL immediately
POB and they told you to accept them

AL: yes
POB: why didn’t you put this important information in your WS?
AL: we make a lot of calls to the helpline. the PO also sent a message round as a memo on the horizon terminal acknoledging this glitch.
POB you say this notice told you Camelot made a mistake

AL: they say it was a mistake and they were working with Camelot to resolve the issue.
POB: have you provided any info to the Post Office about this TC or notice of this mistake
AL: no but it’s commonly available to everyone who works for the Post Office.
J what is this notice?

AL: a Memo View
J is that what you’re talking about in par 10?
AL: that’s it
POB: are you misremembering this?
AL: no. AL explains Memo View system

POB do you say you personally processed the transaction acknowledgment that you describe in paragraph 9
AL; it was done by christine. It comes through to the first person who logs in.
POB did you personally receive the notice
AL the branch did
POB - you or one of your staff?

AL: it was christine barnett
POB: did you see this? or were you told this?
AL: it came through to me
POB is it right to say everything in pars 9 and 10 of your evidence are things Miss Barnett told you?
AL: no
POB: which bits are from your own personal knowledge?

AL describes how Memo Views and TAs work.
AL: every operator gets a Memo View - have I made myself clear?
POB: no because you have not answered the question. Did you see and process the TA or did Mrs Barnett?
AL blusters
POB moves on to par 11
POB did you accept that TC yourself?

POB in March 2018?
AL: yep
POB: you say the TC did not change the stock figure so the TC did not work. Can you explain that?
AL the TC was meant to correct the stock that was wrongly assigned to us - duplicated. It should have reduced it down to £500 to £1000

POB so it worked technically, but didn’t resolve the problem?
AL: same thing - it didn’t change the stock level up
POB I’m sorry I don’t understand. It did change the stock level, didn’ it?
AL: no - the TC should have changed the stock level but it didn’t. (goes on to explain..

… how TCs work. What you say is that the H figure for scratchcards went up by £1000 but of course the physical number didn’t change.
AL no I don’t think you understand. Shall I explain it to you?
J: I’m pretty sure I understand and I’m also sure Mr Draper understands.

J: Perhaps Mr Draper could put it to you as a question.
POB: I’ll take you to AvdB’s witness statement. [AL reads]
POB: AvdB says scratchcards are activated at the lottery terminal - I think we agree about this process...

J has just intervened to say this is incredibly slow going and asked how much longer he is going to be with this witness. 15 - 20 mins comes the answer

AL agrees what AvdB says about the process for dealing with scratchcards.
POB: AvdB says problem in your branch started when you received two TAs in Jan 2018. They were mistakenly negative in value when they should have been positive.

AvdB says this was a PO mistake. Someone put a minus sign there by mistake.
POB the mistake would have been obvious from looking at the TC itself. You would see this if you looked at it. Yes?
AL: we would have looked at our stock figure and that would have been negative.

POB yes that was because the TA was negative and that would have been obvious from looking at the TA.
AL yes But the TA was done twice in error.
POB we agree that point mr latif. AvdB is not saying that there was a mistake made duplicating - it was neg when it should be pos?

POB: agreed?
AL: yes. AL explains the system for making good. He’s gone back to the idea that the TA was sent in twice.
POB we’ll disagree on that
AL: you can check
POB you were required to check the TAs. PO made a mistake and you missed it. Do you accept that?

AL says the Post Office made a mistake - the TA failed.

J intervenes again. Is your intention that we should just sit here until you’ve finished or are we going to have a short break or what. This is a time-limited trial.
POB: I want to show Mr Latif something and how he responds to that will determine how many more q’s i need to ask

POB asks if AL agrees with an AvdB statement. He does.

Judge orders a 5 minute break and then the final 15 - 20 minutes of evidence will be heard from AL.

We’re back. AL has been asked to read par 99 of AvdB’s WS. He agrees it. POB then asks him to read par 100.
POB do you agree it?
AL yes.
POB okay read par 101...

POB are you done?
AL yep
POB agree with it?
AL yep
POB do you agree with the conclusion reached by AvdB in par 102?
AL yep

POB so do you agree that although it was a confusing situation that AvdB was right?
AL: there was an audit of my branch and it was stil showing negative and there have been a number of calls to the helpline and the problem has not been resolved.

POB: AvdB says the PO mistake caused the discrepancy, but you performed a stock reversal, so when the TC came down it created a surplus. But your stock reversal still needs to be reversed back and that is why there is still a discrepancy.

AL If you’re coming back with this evidence I think there’s still a problem somewhere - we were audited and there was still a discrepancy
POB that’s inconsistent with what you’ve just agreed. Why don’t you mention your audit in your WS?
AL we made a number of calls to the helplin

… which didn’t get fixed.
POB we say this problem was caused all the way through by human error, not a bug in H. Do you agree?
AL I agree, but there is a problem that can’t be explained.
POB not sure I understand. Human error or a bug in H?
AL the human error was the...

.. original cock up but by trying to resolve it there was an unexplained discrepancy and its still there. I was pleading with the helpline to resolve this issue.
POB okay let’s leave that and move on to your allegations about H in your WS

POB I can’t meaningfully engage with them as there’s no detail. PO does not accept they are correct. Do you understand?
AL okay, as long as you accept I think that there are problems with H.

[Not sure who selected this witness, but he’s done the Post Office no harm at all. Filleted like a fish.]

POB do you accept that everything in your WS can be explained by human errors either at PO or branch end and that it might not be computer error.
AL: no, no, no. some errors are human, some are bugs in Horizon.
POB is it a mistake in your WS that you say you are still an...

… subpostmaster when in fact you are not.
AL yes I discussed this with my sister and she said as it happened when I was a Subpostmaster it didn’t matter.
AL no further questions...

So he’s not now a Subpostmaster, despite his witness statement saying he is.
What a witness!

AL is now being re-examined by Patrick Green QC for the claimants.

PG QC going back to the spreadsheet which showed the successful balance transfers to AL earlier. He is asking for different filter terms to be applied.
PG QC can you see on the 22nd June we can see in row “L” there is a call from “Chris” trying to complete a reversal...

… and getting an error message. Do you know what that was about?
AL to be perfectly honest, I don’t.

PG QC asks for unfiltered version of the same spreadsheet to be shown.
Gets to 26 Jan 2018 - you mentioned there were a number of calls about the issue...

PG QC reads from log showing that his branch called up re a doubled TC, worried that if he accepts it will cause discrepancy. What’s that?
AL that’s the scratchcard issue
PG QC follows the escalation but it is not clear from the notes. asks AL what came back?
AL nothing! that’s..

… the problem. Nothing came back and that’s why it came up at the audit in September.
PG QC no further questions.
J asks name of auditor
AL Jane Lawrence
J name of area manager at audit time - still Mr Jando?
AL yes.
AL dismissed

Judge giving POB a mild bollocking for taking too long and suggesting things are going to have to move along a bit quicker after lunch if we’re going to get back on track.
We reconvene at 2.15pm Short lunch.

If you want some lunchtime reading, here is my take on yesterday's comparison that the PO QC made with Horizon software as being similar to the software which keeps planes in the air. postofficetrial.com/2019/03/horizo… with a hat tip to @tonyrcollins
#postofficetrial

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