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CASE NUMBER 1HQ16X01238 ALAN BATES & OTHERS [CLAIMANT] v POST OFFICE LIMITED [DEFENDANT] FOURTH JOINT STATEMENT OF JASON COYNE AND DR ROBERT WORDEN 4 MARCH 2019 Introduction Jason Coyne ~ In this Joint Statement I have sought to document my agreement or disagreement in respect of the Horizon Issues where I can or cannot reach agreement with Dr Worden. It is my understanding that this is not a responsive report to Dr Worden’s supplemental report, therefore I have not added any further comments, criticisms or observations in respect of any responsive report in this Joint Statement. Robert Worden - The experts have had many or simple agreeme: jons and exchanges on Horizon issues 10-13. While this has helped each expert clarify his own views, it this is due to the differences of opinion between the two experts on the topic of remote access; in part, ‘AS a consequence, some proposed Thave therefore summaris Expert Agreements and Disagreements by Horizon Issue Horizon Issue 10 — Whether the Defendant and/or Fujitsu have had the ability/facility to: (i) insert, inject, edit or delete transaction data or data in branch accounts; (ii) implement fixes in Horizon that had the potential to affect transaction data or data in branch accounts; or (iii) rebuild branch transaction data: a. at all; b. without the knowledge of the Subpostmaster in question; and c. without the consent of the Subpostmaste Index | Sub Topic ‘Agreed/JC/ | Statement Coyne Refs Worden Refs RW 10.1 RW * Atall times, users of Horizon in PO and Fujitsu have been subject to well-defined role-based access controls. ‘¢ The term ‘remote access” in this context refers to the ‘modification of data (in the branch or within the message store for Old Horizon), or in BRDB (for Horizon Online) by Fujitsu, with non-zero financial impact on branch accounts. ‘The number of occurrences of remote access for which I have dence is not more than 10. While some of these might have been done incorrectly, and so might have introduced discrepancies in branch accounts, their impact on the reliability of Horizon as an accounting system is extremely small; and the net impact of remote access is probably pos S usual effect is to fix problems, rather than create them. SSC were very reluctant to modify branch accounts without specialised tools and careful checks. From the evidence I have seen, there has only been one ime of HNG, amongst more BRDB Transaction Correction Tool. ‘The earlier Transaction Repair Tool (TRT) affects only back- end copies of transaction data, and so does not enable remote

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