Thread by @nickwallis

We are back in court for the afternoon session of Day 6 of the Horizon trial. Part of the Bates v Post Office group litigation. Angela van den Bogerd from the @PostOffice being re-examined. Follow this thread for live tweets.

They are discussing the Helen Rose report, which I just posted up online this lunchtime. postofficetrial.com/2019/03/the-he…

Post Office email to Ron Warmington (@RonRwarming) being discussed in context of Helen Rose report being disclosed to 2nd Sight for Spot Review (this is back in 2013 during 2S’s Horizon investigation.

POQC reading from the email which I think is quoting the spot review into the Lepton SPMR who commissioned the Helen rose report. It is.

POQC returns to email from @RonRwarming asking Mr Armstrong about receipts issue wrt his investigation into the Lepton case. Asks AB to read it.
POQC what Mr A seems to be saying here is the SPMR DID receive disconnected session receipts. What would that have told him?

AB that the BT session hadn’t completed.
POQC let’s go to Simon Baker email with Gareth Jenkins. Please read pars 1 to 9
[she does]

POQC you’ll see Mr Jenkins msg calling for a retry or cancel. Cancel must have been selected generating a receipt. Is that your understanding?
AB yep
POQC having gone through all those docs in your WS 154 you talk about the Rose Report

POQC you say that it was taken out of context. PG said you said you were wrong. What did you mean by it?
AB that reversal was part of that recovery - so it wasn’t a failed reversal - it happened as it should have happened, but I accepted it wasn’t obvious to the SPM...

… because it showed he hadn’t done it even though it said he had.

POQC moves on

POQC A statement from someone we haven’t me coming up. PG put to you that Credence shows a log of every keystroke pressed by the SPM on the basis. Is that true?
AB that’s not my understanding...

… not every single stroke.

POQC PG put to you the introduction of Horizon online was primarily about reducing operating costs reads document that mentions costs first, but making it fit for purpose in the 21st century… HOL should be a simpler system easier to change...

…. and service.

[it does mention lots of things except making it easier for SPMs to use!]

PQOC explain benefits of HOL

AB it was about creating a better system going forward, get product changes done more quickly

NFQ from POQC

J has questions. A couple of times this morning you were asked about corrections to your WS. One of your answers was you didn’t have a lot of time. Was there a time limit on you?
AB only in terms of getting the information together
J what do you mean

AB it was about getting the data and information together
J is there anything else you want to tell me about that?
AB well there was a lot of data and we were under pressure to dig right down into it to get it ready for court
POQC you could ask AB about deadlines?

J no I don’t want to do that. you can ask AB any questions arising from my questions to her when I’ve finished if you wish.
AB explains again the need to get all the info about all the cases together for the trial.

J asks why her team were not named in her WS
AB no reason

J asking about a decision tree where a £150 discrepancy might give rise to a TC rather than necessitate settling centrally.
AB says this chart is a bit confusing and she’s not sure why it is laid out like this. She hasn’t seen it.
J quizzes her further
AB says the doc...

[which is an internal PO doc] doesn’t make sense to her as presented.

POQC asks how much time she had to prepare her WS in response to the claimants WS

AB 3 weeks?

POQC did you have to get info first?

AB yes we had to get NBSC logs and ARQ files

POQC how long did that take

AB about 2 weeks

POQC and you had 3 weeks to get that together after that?

AB it might have been less than that

POQC did you feel pressured?

AB yes

End of a marathon 1.5 days cross- and re-examination.

Dawn Philips (DP) is on the stand. She is Post Office’s team leader for Agent Accounting and Santander banking.

She is being cross-examined by Kathleen Donnelly, barrister for the claiamants.

Your team used to be Debt team.

DP yes
KD is the substance of what you do essentially the same
DP yes
KD and same with Former Agent Accounting - it used to be former Former Agent Debt
DP yes

[so DP sends out letters demanding cash for discrepancies. a letter is given as an example]
KD so the wording of this letter is as if a dispute has been settled. what’s missing from that letter is any mention of a dispute
DP yes
KD tell us about the attachment you would...

… add to this
DP it would be the list of settled centrally entries
KD looks back to letter (which was sent to claimant Mr Tank) and displays attachment. This statement doesn’t have any indication it is possible to dispute this amount.
DP yes

KD going back to your statement you say if you don’t get a response you send another letter.
DP yes
KD brings up second letter sent to Mr Tank - it is an overdue payment letter. All the same language - it IS a debt. Then a threat here about escalation. What’s that about?

DP that it will be brought to the attention of their contracts manager.
KD No mention of dispute
DP it says you can call in to discuss
it
KD bit different to say you can call in about the contents of this letter rather than you can dispute this amount. yes?
DP yes

Long and interesting exchange which the judge has asked KD to repeat. DP has just said her debt recovery team only check to see if a settled centrally amount is in dispute if it is more than £5000.
There is some incredulity at this from gallery, judge and barrister.

If it is less than £5K they get a debt recovery letter whether they’ve disputed it or not.

We go through it again. DP says it’s not always £5K it depends on the volume of calls.

KD asks if this process is audited at all.
DP yes we are checked by a external company

KD do you report to them which value you check the helpline logs for?
DP no
KD so that area isn’t audited
DP no

KD asks when they do send a dispute form to the SPM
PD not if it’s a simple misskey
KD you don’t always investigate and you don’t always sent a branch dispute form
DP no
[branch dispute forms were introduced in 2018]
KD you suggest this was a sea change improvement...

…. DP it made it better
KD how many dispute forms are you sending out
DP don’t know
KD around?
DP wouldn’t like to guess
J Thousands or 2
DP no no about 5 a month.
KD so you are describing this as a great new process

… but it’s only 5 a month.
DP explains the dispute form is a useful information gathering exercise as an SPM might be running a branch in absence so the PO need to know who they are dealing with.

[we go to the branch dispute form]
KD its’ possible an SPM might not know the product or date the discrepancy arose
DP we can’t deal with them - we send them straight to NBSC
KD you can’t deal with them. and if the SPM can’t find out he date of the error you don’t investigate...

… and you proceed with debt recovery.
DP yes

[DP is talking in terms of the SPM “making an error” “if the error happens” etc seems to confirm claimants view that PO sees all discrepancies as user errors]

[KD now showing dispute flow-chart]
KD do you recognise this flow-chart?
DP not the title
KD have a look at p2
DP wait…
DP okay… [looks at p2]
DP that’s a very old one
J old?
DP yep stopped using that a long time ago
J when does it go back to?
DP around 2015...

KD this is obviously NOT the current process is it?
DP no

KD is there currently an appeal process if the dispute goes against the SPM
DP they can come back to us and we can see if there’s [something to the effect of - having another look]

KD but there’s no appeal process above your department
DP no.

[we go to DP’s role as head of Santander liaison at PO and a Mr Smith’s witness statement for this trial]

DP corrects something stated in Mr Smith’s WS.
KD did you give those figures to Mr Smith?
DP yes

KD did you know why he wanted them?
DP yes
KD to give a sense of proportion of the number of TCs issued

[KD raising some confusion about both IT experts on this. oh crivens we’re getting into re-reviews of WS from witnesses I don’t know and haven’t seen]

KD How many of the 3978 TCs issued by Santander to PO were disputed by branch SPMs
DP we don’t record that figure
KD if Santander issue 19.5K TCs and Post Office only pass on 3978 what happens to the rest.
DP I would say 50% can be resolved by writing to the branch and asking...

… for their paperwork.
KD so you do some kind of an internal audit process?
DP yes
KD so it’s alot more complicated than perhaps Mr Smith makes out
DP maybe

Sorry it was 3968 not 3978 in my last tweet but one...

Dawn Philips leaves the witness box.
We are about to have a break.

Tracy Jane Mandy Mather (pronounced May-ther) in the witness box. She is the Financial Services Team Leader for the Post Office.

POQC asks re par 12 in her WS if when she says cCredence records all key strokes, what she means.

™ says it records transactional data.

PG on his feet. Asks if she is the team leader or a team leader
™ she is a team leader working on various teams
PG how many people work at FSC
™ 60
PG do you get much training do you move from team to team?
™ no you just pick it up
PG do you get much training when you join

TM well when I started as a PA I was trained at that so yes

PG raises the credence issue. Credence is useful to understand what happened in a branch because it records all key strokes. You’ve now said it’s sales

™ transactional data yeah

PG what else does it record
™ explains it gives transactional data
PG you don’t get ARQ logs
[shakes head]
J you don’t
TM no not through credence
PG can you tell the court what you do see
™ we don’t use credence for money gram
PG what do you use credence for?

™ mainly cheques
PG Credence holds info for 3 months
™ aware of discussions about holding it longer?
PG we’ve also got a system called Horace which hold info for longer, One member of our team has access to Horace so we can look on there.

[we go to a document from 2013]
PG how long is data available on Horizon to you for
™ if it’s an open item - as long as it needs to be
PG on there it says transactional data and adjustments for credence
™ yep
PG and that’s why on your statement it says it helps to see...

… what happens in a branch.

[PG notes a document where it says credence data could be available for 24 months]
PG would that be helpful?
™ we’ve got it in some places already
PG when was that brought in?
™ starts trying to answer
PG says don’t worry if you dont know the...

…. answer you don’t have to give the answer, but it is helpful to tell the court if yo uknow it.
PG asks if she knows what POCA is
™ doesn’t know
PG starts talking about fraud and recovery but they agree they don’t get involved too much in that.

PG shows her a PEAK document - do you get involved in these?
™ no
PG does anyone on your team?
™ no
PG reads from doc about TESQA - what’s TESQA
™ never worked on it myself, but it gives more information about things at the branch
PG more than Credence?
™ yes

PG would it be useful to have that data? What id someone raised a dispute say 102 days later?
™ seems to agree
PG this dispute here is raised in Aug 2013 and relates to a visit in Dec 2012 - more than 90 days. see that?
™ yep

PG so Credence wou;dn’t be much help
™ no
PG do you know how long TESQA would keep the data?
™ No
PG there is a note asking to retrieve the data to disprove any future claim made by counter. Are you aware of any defensiveness about Horizon?

™ we always took any complaint by an SPM seriously and then we would go back to the evidence in the TC
PG takes her to her statement
™ I think what I was trying to get across is that if an SPM called us we would try to help whatever his query was.

PG you say as an end user you don’t know if Credence has bugs, but you’ve never heard of one
™ yes
PG is it fair to say therefore you’re not in a position to comment?
™ yes

PG takes her to an Ernst and Young report into Credence p12 which shows that developers for Credence had access which would allow them to add their own data and fixes “risk of loss of data and unauthorised activity”. Where you ...

… aware in 2011 of any concerns about the integrity of credence
™ No
PG did you see any changes in credence
™ I wasn’t working in this area
PG were you using credence at all at that time?
™ no
PG before reading IT expert’s report did you know there was a difference in time...

data in Horizon and Credence (this must be about Horizon’s fix on GMT)
™ No.
PG asking about the Helen Rose report. ™ says in her statement: "Looking at the Helen Rose report referred to in paragraph 5.49 of Mr Coyne's …"

“… report, Post Office was able to use Credence to identify that the Subpostmaster had reversed a transaction but had also taken £76.09 payment from the customer. In reversing the transaction, the…"

“… Subpostmaster had effectively removed the payment to British Telecomm, making the bill unpaid.”
PG were you aware of the Helen Rose report?
™ no
PG outlines how she has changed it slightly but it looks like she is blaming the SPMR

™ says it wasn’t his fault it was the fault of the system
[™ is being a good witness, but she is a wee bit out of her depth as there are things in her witness statement which seem beyond her expertise or experience]

PG goes to f/728 the infamous email chain about Pam Stubbs office and initiating an audit trail given interest about Horizon from media and MPs [this came out in first trial]. Does that chime with anything you’ve experienced?
™ no.

PG are you aware of the charging regime
™ I was aware they had a certain amount and thereafter they would be charged
PG so you were aware of that
™ yes but we could get what we wanted it if we needed

J I have a question - do you know why you are telling us Christopher Knight knows in par 19 rather than Mr Knight telling us himself?
™ no
J and what is your understanding of keystroke activity on Credence?
™ transactional data
J so if you look at par 12 of your WS...

… you are telling me I should cross out “all keystroke activity” what should I put instead.
™ goes into quite a long explanation
J going back to my question what should I put into that sentence
™ records all transactional data performed in that branch
[J writes that down]

J really wants to drill down into what Credence shows.
™ tells him what she would see on the screen when checking Credence data.

She leaves the witness box.

Paul Smith (PS), Operations Support Manager at FSC now in the witness box. He has two witness statements.

PG for the claimants on his feet.

PG We’ve heard how you get info re transaction data. On par 13 it says I understand from PO solicitors that the processes by which FSC determines whether a TC is required is outside the scope of the Horizon Issues trial...

… Broadly it involves FSC comparing data entered onto Horizon by branch staff with data received from other sources and resolving any discrepancies between them."

PG asks PS to expand - he does.

PG now talking about rollout of new system from Sep 2018 about making things easier.
PS says it hasn’t been fully rolled out
PG when will it be completed
PS don’t know.
PG two teams are high volume users of the new system

PG which two
PS automated payments team and the debit card/ATM

[this is a new case management system which records disputes and produces reports]

PG did you think it was worth looking at these reports for this trial?

PS no cos they’re very recent
PG so is your WS...

PG you could have put the info in your WS.
PS yeah but [he tries to explain why it wasn’t worth doing so]
PG you said you didn’t include anything about the TC correction system or any analysis because it was recent - but you could have put something in. Was there a reason...

… why you didn’t.
PS no. there is no reason.
PG and you didn’t exhibit any documents to support your WS was there?
PS no
PG your figures show 680 disputes - 40 upheld. relating disputes with pouches received by branches

PG where did you get that understanding from
PS an email - I can’t remember who sent it.
PG reads “TCs issued by the Personal Banking Team are rarely disputed. This is because they run a report in Horice to determine whether a surplus is evident”

… who told you this?
PS don’t know

PG notes table in par 20 where there are 24K Lottery TCs issued and an estimated 1500 disputed and 500 compensated. next line down there is 3110 debit card TCs issued. estimated 1500 disputed and 500 disputed.
PG is that accurate? at all?

PS doesn’t know
PG there’s no underlying data here
PS no
PG goes through the on the face of it back of a fag packet way PS got to these figures.
J that’s more a matter for me Mr Green
PG yes my lord

PG goes to par 30 “I have been shown par 6.66 of a report by Jason Coyne … he refers to two TCs of £810K in ref to [a PEAK] and he suggests they may have been made in error. This is not correct. Two TCs were required in this instance because the method of payment was a cheque."

PG showing PS Jason Coyne’s report data and PS now saying he’s not familiar with this part of the report.
PG takes him to Dr Worden’s report (he’s the PO IT expert - Jason Coyne is the claimants’ expert).
takes him to p h58

PS starts talking about how all TC data is stored on a sharepoint site which is updated daily.
PG okay let’s have an analysis or TCs by branch type you can see there - if we just take DVLA as an example where your evidence is that the present number of TCs is a handful...

… can you see 2010/11 out turn that’s 2,000 odd - that’s not recognisable from your WS - is that because it’s gone down radically?
PS yes because we now have a corporate relationship with the DVLA [explains how that works]
PG looking at the figures for the DVLA in...

…earlier years - it doesn’t surprise you?
PG I don’t know
PS so you have no way of knowing how reliable the information you are getting from other people is?
PG no
No further questions
J i have two questions

J What’s your new case management system called?
PS Dynamix or Dynamics

J what are the reports called where you can analyse the data you are getting?
PS I don’t know I don’t think it has one it’s inside Dynamix like a dashboard
J and how can you get the data - weekly? monthly?

PS seems to suggest you can have it how you like to show volumes graphically and in any timeframe

J how many disputes are you getting re MoneyGram
PS one or two a month
J disputes regarding what
PS my assumption would be disputes over TCs received in branch

We are done for evidence we are now into housekeeping.

The judge rises.

Okay we are done for the day. Back for another day of Post Office witnesses starting 10.30am tomorrow.

Today was interesting. I'll get a post up on postofficetrial.com tonight and will post the transcript as soon as I get it.
Same for the witness statements.

There is so much time, money and effort going into this trial it is mind-boggling.

Thanks for reading, thanks for the retweets and comment and please do chuck a few quid in the tip jar at postofficetrial.com if you can.

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@threadreaderapp unroll pls

@threadreaderapp Horizon trial day 6 unperfected transcript up!

postofficetrial.com/2019/03/horizo…