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 ive 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 cant. But what you while not saying, even if it is only to yourself. Hang on a minute, fujitsu can do this, so shouldnt i be looking at that . What shouldnt i be looking at that . What i didnt do shouldnt i be looking at that . What i didnt do in shouldnt i be looking at that . What i didnt do in that shouldnt i be looking at that . Transit i didnt do in that meeting shouldnt i be looking at that . tausgt i didnt do in that meeting is shouldnt i be looking at that . Ita� ue� ii i didnt do in that meeting is i didnt volunteer that information. Why is that . Didnt volunteer that information. Wh isthat . ,. , why is that . This, for me, i wasnt reall , why is that . This, for me, i wasnt really. From why is that . This, for me, i wasnt really. From my why is that . This, for me, i wasnt really, from my understanding, why is that . This, for me, i wasnt really, from my understanding, on| really, from my understanding, on solid ground because i havent talked to anybody about it, i took it at face value and i didnt 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 tmildup 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, isnt it . You say, yes. Ie, statement, isnt it . You say, yes. It, the statement, isnt 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 ive not experienced it myself. Ive not known not experienced it myself. Ive not known of not experienced it myself. Ive not known of it not experienced it myself. Ive 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. Wasnt it . At the time. Or so, yes. That was. Wasnt it . At the time. I or so, yes. That was. Wasnt it . At the time, i didnt or so, yes. That was. Wasnt it . At the time, i didnt think or so, yes. That was. Wasnt it . At the time, | didnt think it or so, yes. That was. Wasnt it . At the time, i didnt think it was. The time, i didnt 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 didnt happen then we get pushback that it didnt 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 couldnt head, which was. Icouldnt remember head, which was. I couldnt remember the date, head, which was. I couldnt rememberthe date, and i head, which was. I couldnt remember the date, and i still dont know remember the date, and i still dont know the remember the date, and i still dont 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 fujitsus that you had only come to know about fujitsus ability to insert transactions in mid 2018 . Fujitsus ability to insert transactions in mid2018 . , transactions in mid2018 . Yeah, that would have been. Transactions in mid2018 . Yeah, that would have been. My transactions in mid2018 . 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 couldnt put a date on it. Recollection, but i couldnt put a date on it recollection, but i couldnt put a dateonit. , �. , date on it. Why didnt you say, hold on, iwas date on it. Why didnt you say, hold on. I was told date on it. Why didnt you say, hold on, i was told about date on it. Why didnt you say, hold on, i was told about it date on it. Why didnt you say, hold on, i was told about it in date on it. Why didnt 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. Im that point, the messaging had been chanatin. . , that point, the messaging had been chanatin. �. ,. That point, the messaging had been chanttin. . ,. Changing. Im not concerned about messaging. Changing. Im not concerned about messaging. Im changing. Im not concerned about messaging, im more changing. Im not concerned about messaging, im more interested. Changing. Im not concerned aboutj messaging, im more interested in the facts messaging, im more interested in the facts. , messaging, im more interested in the facts. , messaging, im more interested in the facts. , messaging, im 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 . Thats right. Although the helen rose right . Thats right. Although the Helen Rose Report right . Thats right. Although the Helen Rose Report was right . Thats right. Although the Helen Rose Report was part right . Thats right. Although the Helen Rose Report was part of. Right . Thats 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 dont think i did. I again in preparation . I dont think idid idont again in preparation . I dont think i did. I dont know again in preparation . I dont think i did. I dont know gareth again in preparation . I dont think i did. I dont know Gareth Jenkins, i did. I dont know garethjenkins, there was some e mail correspondence, and i may have spoken to him once or twice, but i dont remember the details. Sol spoken to him once or twice, but i dont remember the details. So i did have some correspondence about him, but i think that was previously, and i dont 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 wasnt derived read over the years. So that wasnt 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 oerated. ~. ,. ,. , 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 dont conversations with mrjenkins . Dont think conversations with mrjenkins . I dont think i had a conversations with mrjenkins . I dont think i had a conversation. I dont think i had a conversation. I dont remember, but i dont believe i spoke to gareth. {lila dont remember, but i dont 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 dont 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 emails anything. Did you yourself go back and look at your emails or anything. Did you yourself go back and look at your emails 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 KnowledgeOn 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 didnt statement or your oral evidence . The. So you didnt think, i will be asked about so you didnt 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 dont remember the december e mails, and i wouldnt have known to look at that because i dont 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 didnt, going into the two trials, search through my e mails regarding that. I would have forgotten about those e mails, anyway. I dont even remember having the one from john. Is that not the reason, if youre giving is that not the reason, if youre 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 emails . Self reflection and check your emails . ,. , emails . I wish i had, but i didnt. So ou emails . I wish i had, but i didnt. So you maintained emails . I wish i had, but i didnt. So you maintained that emails . I wish i had, but i didnt. So you maintained that the emails . I wish i had, but i didnt. | so you maintained that the emails 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 dont remember readying session . Yes, i dont remember. It readying session . Yes, i dont remember. It was readying session . Yes, i dont remember. It was only readying session . Yes, i dont| remember. It was only coming readying session . Yes, i dont 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