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The Post Office Horizon IT Inquiry
Wednesday, 13 July 2022
(10.30 am)
SIR WYN WILLIAMS: Before we start to hear the submissions,
a I think I said when we were together last Wednesday
there has been further activity so I just want to check
that all the Core Participants have what I have, apart
from two things which I will mention at the end.
So in no particular order, there is a letter dated
12 July 2022 from BEIS, or the treasury solicitor acting
on behalf of BEIS, together with an email in support.
There is a letter of 27 June addressed to Mr Brightwell
of BEIS from Howe+Co. There is a sample letter from the
Insolvency Service, a letter from Howe+Co dated 7 July
addressed to me, and there is also an email dated 9 July
from Mr Brightwell of BEIS addressed to various firms of,
solicitors. I hope that those documents have all
reached the Core Participants.
if not, we can take a short break while that's
repaired so that everybody has those documents right
from the start, I think that would be preferable to
people listening in the dark, so to speak.
I should also say that I have had two emails
addressed to me personally - which have not been
distributed because I don't think there is any need to
do so but I alert the Inquiry to the fact that two of
1
devastation to many good people's lives, damaged
communities and undermined a national institution. It
should never have happened and, indeed, should never
have been possible.
The Government set up this Public Inquiry in order
independently to establish the facts, to identify fault
and make recommendations. As the Department has already
stated publicly on several occasions, not least when
announcing this Inquity, itis essential that the
necessary lessons are leamt so that nothing lke this
can ever happen again. The Department is, of course,
fully supportive of the work of the Inquiry and looks
forward to receiving its conclusions and recommendations
in due course.
At the same time, the Department is all too well
aware that affected subpostmasters continue to feel the
consequences to this day. The lessons for the future
that will no doubt emerge from this Inquiry will not
make good the devastation caused to them and their loved
ones nor help them pay the bills lying on their
doormats.
One of the Department's central objectives is
therefore to make sure that they are promptly, fully and
fairly compensated for their financial losses, distress
and the hardship they have experienced over many years
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the individual Core Participants, loosely under the
heading subpostmasters, have written to me personally to
say that, far from butting out of compensation issues,
I should involve myseff very much in those issues
if there is anyone who doesn't have a relevant
document, I think Ms Page was indicating she may not but
she may now have it, and since you are going last will
it inconvenience you greatly if we make a start,
Ms Page?
Fine. Jolly good
When Mr Chapman is ready, I think we'll be ready
for him
Submissions by MR CHAPMAN
MR CHAPMAN: I make these submissions on behalf of the
Department for Business, Energy and Industrial Strategy,
which I shall refer to as "the Department’. This is the
first time that the Department has made oral submissions
in this Inquiry and its therefore right that it
records at the outset its thanks to you, sir, and to the
entire Inquiry team for undertaking this essentially
important work.
The Horizon scandal is truly the most serious
affront to decency and justice, all the worse because
the Post Office is government-owned and exists to
provide public service. It has caused appalling
2
and it realises that for many subpostmasters the issue
of compensation is absolutely key.
Itis for that reason that the Government framed
the Inquiry’s Terms of Reference to require it
independently to assess whether the commitments made by
Post Office Limited within the mediation settlement,
including the Historical Shortfall Scheme, have been
properly delivered
But further than that, the Department does not shy
away from the fact that fair compensation to all of the
affected subpostmasters has taken longer to deliver than
anyone would have wanted and in a context where some of
these injustices date back over two decades; that is
unacceptable.
It has also noted with concem the issues raised
by some Core Participants prior to and during these
hearings and recognises the need for the Inquiry to
examine the operation of the compensation arrangements.
The Department, therefore welcomes your decision, sir,
to hold these hearings at this stage.
Can I make clear, sir, the Department's objective
in these compensation issues hearings, and indeed
generally throughout this Inquiry, is twofold: firs, to
assist the Inquiry in whatever way it can; and, second,
to listen and to learn with a view to making whatever
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improvements are necessary. The Department wants to do
the right thing on compensation, within the legal and
practical constraints in which it operates and, whilst
itis actively and urgently working towards the goal of
ensuring subpostmasters are fully and fairly compensated
as quickly as possible, it does not claim to have all of
the information or all of the answers.
For that reason, it wll continue to listen
carefully not only to any interim conclusions and
recommendations that the Inquiry should express
following these hearings but also to the representatives
of the other Core Participants and especially those
representing the affected subpostmasters.
But the point about legal and practical
constraints is an important one that's worth dwelling on
briefly. Itis important to recognise that the
Department and Post Office Limited are not one
indivisible entity. The relationship between POL, UKGI
and the Department will be explored in phase 6 of the
Inquiry but it suffices at this stage to note that, for
good reason, operational matters within Post Office are
for the Post Office board and not for the Department to
decide
The Department Secretary of State is POL's
ultimate shareholder, with his company law rights as
5
Interim Report, it has taken on a much more proactive
hands-on role than is usual in the relationship, in
order to make sure POL fulfils the clear objectives that
have been set for it
Perhaps we can briefly go to page 266 of the
hearing bundle where the extent of the role the
Department has taken on for itself is spelt out under
the heading "Government's Role" and there it says:
“The Goverment has responsibilty for providing
the funding for settlement payments, agreeing
significant decisions in relation to the settlement
strategy, and monitoring Post Office's progress towards
reaching final settlements.
"BEIS supported by UKGI has been involved in the
design of the compensation programme and holds regular
monitoring, decision-making and working group meetings.
both internally and with the Post Office. This includes
signing off on processes, principles and oversight on
intial cases. This is to ensure that negotiations are
advancing in line with the Governments desire to see
timely and fair compensation delivered to postmasters."
This is also manifest in the increased resourcing
within BEIS's Post Office policy team. Ordinarily, BEIS
has around three officials supported by a slightly
larger team at UKG, allocated to working on its policy
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ultimate shareholder exercised on his behalf by UKGI, UK
Government Investments Limited, itself a company owned
by HM Treasury.
The Department of course seeks to full policy
objectives through its ultimate ownership of POL,
principally to ensure that the Post Office can viably
continue to provide an essential public service at
reasonable cost to the taxpayer. But its involvement is.
ata strategic and not operational level. The
Post Office is operationally independent of Government
for reasons that have been considered compelling by
successive administrations of different politcal
stripes and its relationship with government is
underpinned by primary legislation in the form of the
Postal Services Acts 2000 and 2011
However, whilst the responsibilty for
compensating victims of the Horizon scandal falls on POL
itself, the Department has always recognised that it has
an essential role to play in overseeing the process and
by proactively using the mechanisms available to it to
ensure that POL compensates affected subpostmasters
fully and fairly and quickly and effectively as
possible.
‘As explained in the Government's response to the
Business, Energy and Industrial Strategy Committee
6
direction for Post Office. It now has eight officials,
focusing on these compensation issues, supported by
a slightly smaller group than that within UKGI and on
11 January 2022 Minister Scully stated to the BEIS
Select Committee that the issue of compensation,
specifically in relation to the GLO Claimants was to
quote
"... by far and away the most pressing issue in my
list of responsibilities as a minister.”
Al of that is to say that the Department has
taken and continues to take the issue of compensation
extremely seriously and is investing significant
resources to ensure that postmasters receive what they
are entitled to. But can I please make absolutely clear
that I am not here to defend the Department or suggest
that its got everything right. Indeed, the Department
is clear that it could have done some things better.
The Department's position is one of genuine and open
engagement with the goal of doing whatever it reasonably
can now and in the future to ensure POL delivers full
and fair compensation as quickly as possible.
So having made those observations by way of
preamble, I turn to the substance of my submissions.
The Inquiry has, of course, seen the Department's
written submissions on these compensation issues, which
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The Post Office Horizon IT Inquiry
are publicly available to read on the Inquiry’s website
I certainly don't seek to repeat what's set out there.
But the focus of my submissions today is on providing
relevant updates on engaging with some of the issues
raised by other Core Participants in their written and
oral submissions, in the hope that that will assist the
Inquiry
Ill address those points under three headings
relating to the three broad categories of compensation
being considered: first the Historical Shortfall Scheme,
HSS; second, final compensation for subpostmasters with
quashed convictions; and, third, fair compensation for
the GLO Claimants.
So I start with the Post Office's Historical
Shortfall Scheme (or HSS). The Department seriously
regrets the initial delays within the HSS. tis, it
recognises, essential that affected subpostmasters who
have already waited far too long for justice and redress
obtain fair compensation quickly. Any delay is
unacceptable.
One key driver forthe initial delays was that POL
had planned and put in place resources on the underlying
assumption that applications to the HSS would be
numbered in the hundreds. If that had been the case,
compensation under the scheme could have been met by POL
9
POL's assumptions and plan for the contingency that they
were wrong. It apologises for its role in contributing
to the delays which resulted
As noted in our written submissions, the
independent advisory panel, as originally constituted,
also did not have sufficient capacity to process the
number of applications actually received. Further
members had to be appointed to improve capacity
‘As well as much higher numbers of applications and
the need to secure budget to fund the scheme, it also
took time to set up the processes to ensure consistency
of decision-making on applications.
In establishing the HSS, an initial round of test
cases was used as the basis for the creation of the case
assessment principles. Those principles were approved
by the Independent Advisory Panel and by BEIS's steering
committee and set out the underlying legal principles
which were then applied to claims within the scheme to
ensure consistency of approach.
After those initial delays and as a result of the
additional Government funding and improved resourcing,
the HSS is now operating at a reasonably good pace. As
of 6 July 2022, 70 per cent of eligible Claimants in the
HSS had received an offer. That is 1,659
subpostmasters. The total amount of compensation
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itself without any additional taxpayer funding. BEIS's
role at the stage of the settlement of the Group
Litigation, and establishment of the HSS, was
a relatively limited one through its role as shareholder
supported by UKGI.
In fact, over 2,500 applications were received,
meaning that POL could not fund the scheme itself and,
therefore, the scheme required a substantial input of
taxpayer money.
When the Department was informed of the problem in
the autumn of 2020, it worked to obtain Treasury
approval for the necessary additional maximum budget
cover, £233 million, as quickly as it could, eventually
securing itin February 2021, and this funding was
announced in March 2021. Its important to note here
that the £233 milion figure is the maximum estimated
required budget cover and POL's most recent best
estimate of the total scheme cost is £150 million, as
published in its 2021 annual accounts. Both BEIS and
POL are contributing to payment of the settlement
amounts.
Whilst POL, UKGI and the Department believed at
the start that POL would be able to deliver the scheme
from its own resources, the Department now considers
that it should have done more to test the risk around
10
offered is now nearly £37 million, an average of
alittle over £22,000 per claim
The Department recognises that the HSS is
administered by POL and it notes that, in these
hearings, POL has indicated that it is on course to make
offers in 95 per cent of cases by the end of this year.
The Department has set POL the aim of making
100 per cent of applicants an offer by the end of this
year and it has been putting pressure on POL to meet
that goal. The Department's view is that all possible
steps should continue to be taken to make fair offers of
compensation to all applicants by the end of this year.
Can I tum to the question of legal support. The
HSS has been arranged so that the more straightforward
claims were considered fist. As you've heard, si, the
intention was for the scheme to be easy to access
without legal advice or representation and the
appointment of legal experts to the Independent Advisory
Panel was intended to obviate the need for legal
representation in most cases. The Department has heard
the submissions made by some of the Core Participants in
these hearings that proper claims for consequential
losses have regularly not been made and the suggestion
that this may be as a consequence of the legal funding
arrangements.
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The Post Office Horizon IT Inquiry
At the same time the Department notes that the
published HSS consequential loss principles and guidance
states in terms that consequential losses ~ that is to
say any losses other than shortfall losses ~ can be
claimed under the scheme and gives examples in layman's
terms of what the losses might be: loss of earnings,
loss of profits, loss of property, loss of opportunity
or chance, penalties and costs of financing, bankruptey
or insolvency, legal and professional fees, stigma and
damage to reputation, and personal injury or harassment.
This guidance was sent to all applicants in
October 2020 and has been published and signposted on
the front page of the HSS website since September 2020.
The application form itself, of course —
SIR WYN WILLIAMS: Just so I don't mislead myself, does that
mean that it hadn't been signposted in the way that you
are suggesting during the initial period of the scheme?
MR CHAPMAN: Correct. It was first sent to ~ the guidance
was first sent to applicants in October 2020 and
published on the website in September 2020, not before
then
SIR WYN WILLIAMS: So I'm not saying this in any kind of
critical way, itis purely neutral, but the plain fact,
is that those people who did apply by August 2020 were
not sent the guidance before they applied?
3
intial discussions with Post Office on this issue and
is expecting to receive a formal proposal shortly. It
is determined to ensure that the process adopted is
a fair one.
turn —
SIR WYN WILLIAMS: So that my note is correct on this, so
far as a decision upon increasing the level of legal
funding, that can be expected within -I think I wrote
"some weeks" but did you say a few weeks?
MR CHAPMAN: IThe next few weeks.
SIR WYN WILLIAMS: What's the timescale for a determination
of late applications?
MR CHAPMAN: The Department's held initial discussion with
the Post Office on that topic and it expects to receive
a formal proposal shortly. I can't be more specific
than that. But the point is that those discussions have
happened and a decision is in train.
SIR WYN WILLIAMS: Now I am not being entirely neutral
This does seem to be hanging around for a long time,
Mr Chapman.
MR CHAPMAN: Well, sir, 'm not here to persuade you
otherwise.
SIR WYN WILLIAMS: Fine, thanks
MR CHAPMAN: I turn, ifI may, to the second of my three
headings: compensation for subpostmasters with quashed
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MR CHAPMAN: Correct.
Turing to the application form itself, that did
ask applicants whether they had:
"... experienced any other losses that directly
related to the alleged shortfalls in respect of which
you would like to claim.”
True itis that the term "consequential losses" is
not used there but the Department believes that what was
being asked was reasonably clear and that the use of
legal terminology, the expression "consequential
losses", on the form itself would have been more likely
to confuse than assist. But the Department has listened
to the concems raised and going forward, as more
complex and larger claims are now being looked at with
greater potential for dispute, the Department recognises
that itis right to reconsider whether the levels of
legal funding remain appropriate.
The Department has been in discussion with the
Post Office with a view to increasing the provision of
legal support costs and expects a decision on this,
within the next few weeks.
Finally on this topic, the HSS, I turn to the
question of late applications. The Department welcomes.
the Post Office's confirmation that itis committed to
considering those applications. The Department has held
14
convictions. For the avoidance of doubt, this category
also includes non-GLO subpostmasters who were wrongly
prosecuted but not actually convicted, either because
the prosecution was withdrawn or because they were
acquitted
Il keep my submissions brief on this topic.
I deal with the issue of disclosure first. The
Department was recently made aware of problems
concerning timely disclosure to applicants of documents
held by Post Office. BEIS is encouraging POL in its
efforts to resolve this issue. If there are any
continuing problems in relation to the issue, the
Department is keen to hear about them as soon as
possible so they can be resolved.
I next address briefly bankruptcy and insolvency
issues. We have received early this morning the letter
from the Insolvency Service to an individual whose
details are redacted. The Department is not presently
in a position to address that letter and would be very
grateful if this and any other specific issues relating
to bankruptcy or insolveney are brought to its
attention. It emphasises that it takes these issues
very seriously and I underline the point already made
that its objective is to ensure full and fair and prompt
compensation.
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The Post Office Horizon IT Inquiry
The next issue is the potential for claw-back,
where interim payments are greater than for final
awards. The Department understands that POL has removed
the claw-back clause from all future offer letters and
has informed those who have already had offers that
payments will not be clawed back. The Department
welcomes this.
Interim payments: the vast majority of what have
been called Category B cases have had convictions
quashed on the ground that they were unsafe. A small
number of cases, three we know of to date, are different
in that they were quashed on public interest grounds.
Interim payments are made —
SIR WYN WILLIAMS: I think, again, they were quashed but POL
did not oppose their quashing on public interest
grounds.
MR CHAPMAN: Thats right
SIR WYN WILLIAMS: I don't think we should assume that the
judge was being asked fo approve that, in any sense
MR CHAPMAN: I accept that.
Interim payments in this category are made as
a down-payment on the final compensation that will
ultimately be paid. In the public interest cases, due
to their distinct facts, its dificult to assess what
level of compensation may be due until full claim is
7
soon as they were agreed which refer possible, rather
than waiting for all heads of loss to be resolved
Again, the Department would invite the
representatives of all affected subpostmasters to raise
any issues with this process.
Turning to the issue of non-pecuniary damages, for
the avoidance of doubt, the Department records its
agreement with other Core Participants that these claims
must be valued according to ordinary principles
applicable to the recovery of damages for malicious
prosecution, including by reference to aggravated and
exemplary damages where appropriate. The Department
welcomes the system of early neutral evaluation of such
claims and the agreed appointment of Lord Dyson as
neutral evaluator.
It stands ready to support the delivery of the
early neutral evaluation process and is keen to ensure
that the outcomes of this process enable fair and swift
compensation.
Finally and briefly, I address the suggestion made
by some Core Participants that individuals with quashed
convictions should be able to opt into the Government's,
‘scheme to give ex gratia top-up compensation to the
GLO Claimants. The Department is considering the
overall point being made but itis important to
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received. For that reason, they have not been eligible
to receive an interim payment which is based on
a simplified assessment of the likely value of the full
claim and, of course, interim payments are ex gratia,
good faith payments
These Claimants can, of course, submit a claim for
full compensation and that claim will be considered on
its merits. The Department would encourage them to
submit their claims so these can be properly considered
Again, the Department emphasises that POL is not the
final arbiter of interim payments. If individuals are
aggrieved by a decision not to make a payment in their
case, legal remedies are available to them
In terms of final payments, at the time of our
written submissions, dated 31 May of this year, POL had
received only two full claims. As of today, a further
three largely quantified claims have been received, as
well as further information from one additional
postmaster. This brings the total of largely quantified
claims to six.
The Department continues to encourage the
Post Office to work at pace with the Claimants’ legal
representatives to reach a fair settlement as quickly as
possible and, as part of that, to make payments of
agreed elements of claims, such as loss of earings, as.
18
emphasise that the GLO Claimants are in a uniquely
dificult position. As a result of the settlement of
the Group Litigation, they have no legal right to
further compensation, meaning there is a very specific
need for bespoke arrangements to be put in place to
ensure they are fully and fairly compensated
The same is not true for the Category B group, as
it has been called, who continue to have recourse to all
legal remedies.
My third and final heading is fair compensation
for the GLO Claimants. Itis the Government's settled
positon that itis only right and proper that
GLO Claimants should receive further compensation, in
addition to that which they agreed when settling the
litigation against POL, to give them compensation
similar to that available to other subpostmasters who
did not participate in the GLO. This was announced by
the Minister for Postal Affairs on 22 March of this year
and reaffirmed in the Department's written submissions
of 31 May. The Minister was clear that it was necessary
to find a way to deliver this additional compensation,
but the Department cannot just allocate tens of millions
of pounds of taxpayer money [Zoom distortion] unilateral
force of will
As I've already explained, it may only act within
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the parameters of the law and here there was no clear
statutory basis for providing the money to POL that was
necessary for this purpose. The Department's power to
subsidise the Post Office is limited by statute to
assisting in the provision of post offices or
Post Office services and there was no legal liability to
pay the additional compensation because the GLO
settlement was expressly full and final
The Department tried, and tried in vain, to find
an existing legal basis to enable it to fund the scheme.
Itreluctantly came to the considered conclusion that no
such legal basis existed and, in normal circumstances,
that would have meant that its only choice would have
been to seek to pass primary legislation to create
‘a bespoke legal basis for this additional funding and
the establishment of a scheme.
Aiter considerable exploration, the Department,
with the help of the Treasury, identified a way through,
in line with the rather arcane Public Accounts Committee
Concordat of 1932, which allows expenditure of
an emergency or non-continuing character to be made
under the sole authority of the Annual Appropriation
Act. Approval of this highly exceptional legal basis
reflects the importance which ministers attach to
providing further compensation to the GLO group.
24
the Department has engaged Freeths, who represented the
GLO Claimants in the Group Litigation, in order to
acoess the data and methodology that they, Freeths,
developed to distribute the 2019 settlement. This will
help BEIS to put in place a system for calculating final
awards of compensation for each of the GLO Claimants.
Third, finally, all members of the GLO group will
be able to claim reasonable legal fees that they incur
as part of participating in the final compensation
scheme,
Can I please be absolutely clear here about two
things, and they are related. First, the Department has
been saying since March that it will consul informally
with both individual subpostmasters and their lawyers.
That consultation must, of course, include all
GLO Claimants and their representatives, not just those
who choose to be represented by Freeths in relation to
the final compensation arrangements.
Second, no-one will be cut out of the final
compensation under these arrangements by choosing to be
represented by a firm other than Freeths or indeed
choosing not to be represented at al
The Department hopes that this allays somebody of
the concems expressed during these hearings about the
involvement of Freeths.
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The other challenge which the Department faced
related to Therium, the firm which had funded the GLO
Claimants’ tigation and which had therefore received
the lion's share of the compensation paid by
Post Office, pursuant to the settlement. Therium had
a possible legal entitement to a share of any further
compensation paid. The Department had to and did
negotiate this issue with Therium and was grateful for
their agreement to waive any further entitlement
That having been done, as the Minister informed
Parliament in a written statement on 30 June this year,
the first few major steps have now been taken to
implement these arrangements, in particular, first,
interim payments to members of the Group Litigation not
covered by other schemes. A total of £19.5 milion has
been allocated to these interim payments.
When this is added to the share of the settlement
obtained in the Group Litigation in 2019, which was
distributed to the Claimants after costs, the GLO
Claimants will have received approximately £30 milion
Although the Department does not consider this to be
fair, inal compensation, it hopes that it goes some way
to helping subpostmasters facing immediate hardship.
Second, with the aim of quickly putting in place
a scheme for final compensation for the GLO Claimants,
22
SIR WYN WILLIAMS: Before you reach your conclusion, just so
that I am clear, I think you just said orally which the
data which Freeths hold will be used ~ this my word not
yours ~ to calculate final awards of compensation to
the GLO Claimants. In the letter that was sent
yesterday, unless I've misunderstood it, it was also
being suggested, or it was being suggested, that this
data would be used to distribute the interim payment sum
of 19.5 million. Have I got both right?
MR CHAPMAN: Yes. Yes, thank you, sir.
SIRWYN WILLIAMS: Thank you.
MR CHAPMAN: Turing to my conclusion, sir, the Department
looks forward, sir, to any update on these issues that
the Inquiry should choose to give and it continues to
stand ready to assist the Inquiry, however it can
Thank you for the opportunity of addressing you today.
SIRWYN WILLIAMS: Thank you. That's fine. Thank you very
much,
Ready, Mr Moloney, or do you want a short break?
Submissions by MR MOLONEY
MR MOLONEY: Sir, as you know, I make submissions on behalf
of the Hudgell Core Participants and there are three
issues upon which you have invited submissions. I won't
repeat them, sir. They have been set out many times.
You have heard substantive submissions from Counsel to
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the Inquiry, Post Office, Howe+Co and BEIS.
In order to avoid repetition of the general
submissions that you have heard, sir, we will aim to
provide practical context to the general issues that we
hope will be of assistance and, in that vein, sir, it
was of course us who provided the letter from the
Insolvency Service this morning. We will ty to provide
practical examples to you, sir, which we hope will help.
Taking each in turn, then first the Historical
Shortfall Scheme. Hudgell Solicitors represent a great
many people in Category A, persons who have made
applications to the HSS, if you will forgive me using
that acronym, sir. We raised concems in our written
submissions about the operation of the HSS and those
concems remain, sir, despite reassurances given on
behalf of Post Office last week.
We have seven points to raise with you in respect
of the HSS scheme, sir. Firstly, the availability of
expert evidence to Claimants under the HSS; secondly,
limitation; third, bankruptey; fourth, the terms of the
outcome letter if you will forgive that shorthand, si;
fifth, interim payments under the HSS; sixth, areas for
further decision by POL; and, finally, the operational
independence of the HSS panels.
Firstly, sir, then the availabilty of expert
25
expertise buil into the process, and that's last week's,
transcript, sir, at page 43, line 12.
She also observed that the panel has obtained
genetic advice on matters such cardiac and mental health
in order to assist itin approaching claims, generally.
She then went on to say, sir, if she will forgive me,
that the panel's Terms of Reference also provide ~ and
you have already been taken to this provision at
section 35 in relation to personal injury claims:
"Where insufficient evidence has been provided for
a claim to succeed without further medical and/or expert
evidence, the panel may nevertheless recommend the
making of an offer to the postmaster which the panel
considers fai.”
She said that this provision is designed to be
advantageous to an applicant
“Itenables an applicant who is not potentialy
able to obtain expert evidence to prove and support
their claim nevertheless to obtain a recommendation from
the panel on the basis of faimess.”
Post Office Limited was also conscious that
an applicant may wish to avoid the inconvenience and
potential distress of obtaining a report which may be of
particularly acute and sensitive concem in cases
involving mental health issues, but the panel has the
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evidence for Claimants under the HSS. One of our
primary concerns, sit, is in respect ofthe issue of
harm caused to the Claimants in the form of mental
health and associated issues which flow from that.
Welll return to this when we address the issues under
Category B, sir, but Hudgell Solicitors have
commissioned medical reports for each of the
63 Core Participants that we represent whose convictions.
have been quashed, Category B.
You won't be surprised to hear I'm sure, sir, that
‘a number of them have severe, enduring psychiatric
issues following their experiences at the hands of
Post Office Limited and a number have developed
long-term physical problems stemming from those
psychiatric problems
It's a serious and widespread problem, sir, and we
have profound concems about the approach to it within
the HSS scheme
Ms Galifant, Queen's Counsel, said last week that
there's no necessity for expert evidence for a variety
of reasons. Firstly she said that every case will be
assessed by three members of the Independent Advisory
Panel comprising one legal specialist, one forensic
accounting specialist and one retail specialist and,
therefore, there's already a very significant degree of
26
power nevertheless, in the absence of such evidence, to
recommend an offer which it considers to be fair.
So, in essence, so far as this issue of expert
evidence on matters such as mental health is concemed,
Post Office contends that there is sufficient expertise
cn the panels so that the Claimants don't require expert
assistance; second, that the panel has reoeived generic
advice to assist it with health matters; and, third, the
panel can make a faimess award when there is
insufficient evidence prevented by the Claimant.
We make the following points in respect of these
remarks, sir. Firstly, none of the experts on the
panel, according to what has been said, have expertise
in matters of mental health and/or personal injury.
This ~ I don't mean to be flippant ~ but is not
a retail issue and itis not a forensic accountancy
issue, the issue of mental health. Itis a specialist
area and not an area where guesswork is desirable when
assessing the appropriate award of damages.
To have any basis for an accurate assessment of
the impact on an individua''s health, an expert view of
the evidence available must be necessary. Forgive me,
sit, ifI say now something that you already know, that
there ate guidelines for the award of personal injury
damages issued by the judicial college. They provide
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ranges of appropriate damages according to the severity
of the personal injury suffered by a claimant,
There is really, sir, a quite considerable range
of appropriate damages within the categories of injury
that people have suffered through mental health
problems, according to whether the impacts are severe,
moderate and less severe, and the level of recovery can
vary dramatically according to the evidence on the
extent, severity and duration of the impacts.
When the injuries are considered severe and where
the prognosis is poor, just to give two examples, sir,
the range of recovery is between £54,830 to £115,730
Itis essentially 55 to 116.
By contrast, a less severe injury, the low end of
the scale, might recover something between £1,540 to
£5,860. So there's really quite a range, sir, of awards
that might be made and I point out, si, that those sums
relate only to the pain, suffering and loss of amenity
connected with the injury and not any loss consequential
to the subpostmaster becoming unwell, such as loss of
earnings
So the severity of the personal injury may on its
‘own make a big difference to damages and the
consequential losses may make even more difference. We
say, sir, that matters of this nature need to be
29
whole body and develops after stress. The panel gave
£15,000 in total because the panel did not consider that
the available evidence established that Horizon
shortfalls were the dominant cause of the medical
issues.
It may be, sir, that in circumstances such as
that, the panel should have called for a medical report
and not dismissed the specific claim and it's hard to
see, we say, how any kind of faimess results from
failing to seek an expert assessment in circumstances
such as that
There is a concem, sir, perhaps, that ~ and
perhaps the clue is in the name -- that the scheme is
about shortfalls and is set up for the assessment of
pecuniary damages for which a forensic accountant and
a retail expert are very well qualified but not,
perhaps, so finely-tuned to dealing with non-pecuniary
damages which result from the problems experienced by
subpostmasters.
We also, sir, refute the suggestion by
Ms Gallifant that an applicant may wish to avoid the
inconvenience and potential distress of obtaining
a report, which may be a particularly acute and
sensitive concem in cases involving mental health
issues. Sir, there's no evidence at all that
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rigorously dealt with, with reliable expert evidence
obtained, to inform the panel's consideration of harm,
causation and the recovery of consequential losses, such
as lost earings, which could be very considerable.
Failure to explore that harm caused to
‘a subpostmaster’s health by the failings of Horizon
could create an entirely distorted and diminished
picture of their true loss.
Secondly, the reliance on section 35, we say, may
lead to unfairness in some circumstances, and not
faimess. We say that if there's a variable psychiatric
or other medical issue, the panel should not make
a fairness decision if other evidence which would enable
an objective decision to be made were able to be
secured
We provide one example, si, from the experience
of Hudgell Solicitors. A case where £15,000 was
offered, where the person had suffered from
a stress-related illness, resulting from shortfalls and
had, in turn, contracted a diagnosed physical condition
connected to stress. There's limited information we can
provide while these claims remain without prejudice,
sir, but the person had to have three years off work,
the medical condition in question was diagnosed by
a consultant, is a very painful one which affects the
30
subpostmasters would seek to avoid a report. In fact,
that runs really contrary to our experience. But there
is plenty of reason to believe that they wouldn't be
able to afford it because of what Post Office has done
to them:
We say, sir, that Post Office's concem would be
better directed at ensuring that applicants have the
opportunity to secure such a report in circumstances
where most simply couldn't afford it.
Secondly, sit, limitation — limitation within
HSS. Ms Gallifant said last week that Post Office has
agreed not to take any limitation defence in relation to
claims brought under the scheme, and that is at page 72,
line 24, of last week's transcript should it need to be
looked at, sir.
Sir, we say that that's not at all clear and if we
could please, sir, take you to page 287 of the bundle,
which is the Terms of Reference of the Independent
Appeals Panel and to paragraph 34 of that. So that's,
tab 15, paragraph 31. That reads in fact, sir, that
"Many eligible claims will relate to shortfall
losses and consequential losses sutfered a significant
number of years ago. In order to draw a line under the
issues caused by previous versions of Horizon and treat
postmasters who have been affected fairly, the scheme,
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The Post Office Horizon IT Inquiry
including the panel, will not apply the laws of
limitation in its assessment of shortfall losses or
consequential losses but shall deal with each claim on
the basis that itis not barred by the expiry of any
relevant limitation period."
So far So good, sir, but it goes on:
"Post Office's rights to rely on limitation
defences outside the scheme (including in any subsequent
litigation or arbitration proceedings commenced under
the dispute resolution process) are strictly reserved."
It continues:
“Given the large number of applicants to the
scheme, claims may take some time to investigate and
assess. Post Office is therefore wiling to agree in
respect of each applicant that time will not run for
limitation purposes from the date the applicant joined
the scheme to the date on which the applicant receives
their offer letter."
Now, sir, if that term means that the ordinary
limitation period or six years, three years, whatever,
will only start to run once the applicant has pulled out
of the scheme, then all well and good. But we suspect
that that's not what it means, sir, and if it means that
an applicant who is way out of time is fine to join the
scheme and Post Office won't bother about limitation but
33
Where a claim is an asset in a bankruptcy your trustee,
the Official Receiver, has to consider how best to take
the action forward
“The Official Receiver has confirmed to the
Post Office that he wishes to continue with the claim
and asked for details of the compensation being offered
under the scheme. Some of the compensation award will
be paid to you where an award is made. You will receive
all payments in respect of the time you have spent
dealing with the Horizon shortfall issues and any
compensation for health issues, damage to your
reputation or distress. But the parts of the claim that
relate to financial losses will be paid into the
bankruptcy estate and this may represent the majority of
your claim.
“The Post Office will contact you at the Official
Receiver’s request to provide any information they
require in support ofthe claim. Please provide this
information as the claim cannot proceed if you refuse to
co-operate and no compensation be paid unless you fully
and truthfully answer all the questions the Post Office
ask of you."
Sir, two points on that to begin with. First,
given that, on the face of things, the only damages that
are going to be allowed to stay with the Claimants in
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if they pull out and proceed to litigation or other
forms of alternative dispute resolution, then
Post Office may use a knock-out limitation defence, then
we say, si, that that would be very wrong.
For those subject to limitation concerns, it could
produce real pressure to settle in this process. It may
have significant impact on the position of
subpostmasters during the earlier stages of dispute
resolution, especially, sir, as we, certainly as Hudgell
Solicitors, we suspect we are coming to the now more
complex claims being resolved within this HSS
if may turn to bankruptey, sir, now, as the
third point, Post Office have recognised the differences
with bankruptcy cases and this is not just
an administrative problem. May we refer you to the
letter, sir, that we provided.
SIR WYN WILLIAMS: Yes, please.
MR MOLONEY: Sir, itreads at the first main paragraph:
"As a result of the bankruptcy order made against
you [and we've redacted the date from this to hide the
identity of the person receiving the letter, si] have
to inform you that your right to make a claim for
compensation under the scheme is something which forms.
part of your bankruptey estate because the errors
happened prior to the bankruptcy order being made
34
the HSS when bankrupt are non-pecuniary damages, this
position provides all the more reason for proper
attention to be paid during the HSS considerations,
whether that be by HSS or by the panel, as to loss of
reputation, personal injury, including psychiatric
injury; essentially, sir, to place a greater emphasis on
non-pecuniary damages rather than pecuniary damages.
Secondly, sir, there would appear to be no
consideration of the fact, in this letter at least, that
it was more often than not Post Office's actions that
made the person bankrupt in the first place. In
a vicious circle, all pecuniary losses they endured will
be swallowed up by a bankruptcy that was caused by the
pecuniary losses they endured. The letter continues
over the page, sir:
"The money paid to the Official Receiver will be
used to pay your bankruptcy debts, other than any claim
by the Post Office which was based on the Horizon
shortfall erors. It may be possible for your
bankruptcy to be annulled, (cancelled) so I have
enclosed information on the steps you would need to take
if you wanted to apply for an annulment.
“If you have any queries about the content of this
letter, please do not hesitate to contact me.”
Sit, we say first of all that, without legal
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The Post Office Horizon IT Inquiry
advice, i's very difficult to imagine that many
subpostmasters will know where to start with a letter of
this nature. There is guidance, sir, quidance comes
with the letter and itis appended to the letter, but we
do say that to attempt fo navigate an annulment of
bankruptcy when unrepresented might be quite difficult,
to say the least, and there is no provision for
subpostmasters to have legal funding for this purpose.
Just looking at the guidance, sir, which is on the
third and fourth page of this document, it says at the
very outset "You do not have to employ a solicitor or
get independent advice, for example, from the
Citizens Advice Bureau to apply for an annulment but you
might find it helpful to do so, You must ensure all
relevant information is given to the court and the
proper procedure is followed."
This is sent to bankrupt subpostmasters with all
the lack of resources that that status entails. Then
the procedure for the annulment is explained, sir, in
the body of the first page.
Then at the bottom, sir:
"Paying your debts in full
"The Official Receiver will use the money they
receive from the Post Office to make a payment to your
creditors. This may not be enough to pay all the debts
7
be achieved for bankrupt postmasters.
Finally, sir, in respect of bankruptcy, our
experience is that none of the claims from people who
have suffered bankruptcy have reached the stage of
an offer letier. Ms Gallfant expected that some would
be dealt with in the next few weeks but itis now nearly
two years since the scheme closed, sir ~ or closed for
the first time, slightly longer to when it closed for
the second time.
These people, we say, sir, are people who are
likely to be in real financial trouble and we say, we
observe, at this stage, sir, that this perhaps very much
reflects the overall impression, right or wrong, that,
0 far as the HSS scheme is concemed ~ the Historical
Shortfall Scheme is concerned ~ that the low hanging
fruit has been picked by Post Office so far in dealing
with these claims and the more complex claims are to
come.
itis, si, Post Office which determines the order
in which claims are dealt with and come before the
panel.
Next, the outeome letter, sir. It was said last
week that the outcome letter lists the all the
contemporaneous evidence which the panel assessed to
make the recommendation and it expressly explains that
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and costs of your bankruptcy in full. If your
application is made because you intend to pay your debts
in full you will need to make the additional payments
yourself,
"You must allow time before the hearing for
payment to be confirmed. You need to allow at least
three working days before the hearing. You will also
need confirmation from the creditors that they don't
intend to claim interest on the debts between the date
of your bankruptey order and the date they are paid in
full and if your debts are not paid before the hearing
but you have made arrangements to have money available
to pay them, for example via a guarantee from a third
party or a solicitor, they must attend the hearing with
you to explain how the debts will be paid
"ifthe bankruptcy order is annulled before the
compensation claim under the Historical Shortfall Scheme
is settled, the claim in full will be transferred back
to you.”
Sir, we say there needs to be real faimess for
bankrupt subpostmasters. They need help and the Inquiry
may ~-as Mr Chapman has just said that they are not
able to address this letter at this stage but the
Inquiry may wish to raise questions with the Post Office
and the insolvency services as to how real fairness can
38
the applicant can request a copy of any or all of those
documents and pieces of evidence. Applicants can also
request a copy of the Post Office investigation report,
the Herbert Sith Freehills legal case assessment and
a tecord of the panel assessment and recommendation and
that all ofthis data is provided in order to support
the applicant's consideration of the offer and, of
course, having considered it the applicant is free to
accept of reject the offer
Now, sit, we say about that that the purpose of
the outcome letter is to enable the applicant to
consider the offer. Ifitis to assist the applicant's
consideration of the offer, we say it would plainly be
much better ifthe evidence, the Post Office report, the
HSF assessment and the panel assessment and
recommendation were sent at the same time as the outcome
letter, so that the applicant can make a fully informed
consideration of the offer.
For cash-strapped applicants with enormous
financial pressures, after waiting so long for
a payment, they may not wish to take the extra step of
seeking the explanation for the offer and many may
decide just to take the offer in order to ease the pain
of their current circumstances.
Provision of the information with the letter would
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mean that any lawyer they go to would also be much more
able to assess the merits of the offer and the merits of
any challenge to the offer, without engaging in more
correspondence with the Post Office before they can do
anything of substance. We say, sir, there is no reason
not to send all the information in order to assist the
applicants.
Next, interim payments and the HSS. In our
written submissions, sir, we raised the limited
provision for interim payments in the HSS including
where individuals had agreed offers made by the
Post Office in part and remained in dispute over other,
heads of loss. There are a number of reasons given by
Post Office as to why a change of approach, so far as
interim payments, was not necessary.
Firstly, that interim payments would be paid in
circumstances of hardship. We say, sir, that there's
litle transparency over when hardship will be
sufficiently severe for Post Office to countenance such
‘a payment and we ask for clarity as to that. Whatever
the test being applied by the Post Office, itis not one
which has been publicised or otherwise drawn to the
attention of subpostmasters
Secondly, sir, you pressed Post Office as to why
itis that no interim payments are countenanced when
a
surely that can be something which could be paid and
there could not be any dispute about that in the future
if the panel has identified that shortfall
We have concerns, sir, that the premise of our
written submission and the worst fears of some of our
clients may be right, that the reality of requiring
a global agreement on an offer, before any payment will
be made, whether rightly or wrongly, creates
an incentive to settle rather than continue the dispute
over the heads of loss
Just two matters remain, sir, in respect of the
HSS scheme. Firstly, areas for further decision by
Post Office. There were two areas on which we heard
that Post Office's thinking about whether more can be
done and, in fact, we've heard from BEIS in the same way
this morning: firstly, what to do on the question of the
small number of additional claims made after the close
of the shortfall scheme; and, secondly, on the matters
of additional legal costs in the dispute resolution
process
Firstly, sir, on those who have applied to the
scheme after the close, you have heard during the impact
hearings, sir, of continuing distress of those excluded
from HSS applications. The scheme has been closed for
almost two years now, sir, and the Post Office is still
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there's agreements on some losses and dispute over
others, and that was concer We expressed within our
submissions, si.
The answer ~ and I hope I do justice to the
answer - is that the approach under the scheme is to
reach an overall offer, rather than breakdown the offer
by individual heads of loss and that offers are made in
the round so there might be able to be agreement in
principle and say, "Well, we accept this or that, but
it wouldn't follow that then there was able to be
agreement overall and the applicant would actually
obtain through civil litigation a sum anything lke the
amount that is being offered based on the
applicant friendly principles.
We say, sir, i the panel is agreed that they will
pay, le’s say, £200,000 to an HSS applicant, we say
there's no reason why the applicant can't be given
a proportion of that £200,000, recognising the financial
and other hardships the applicants are likely to be
facing whilst they consider their options, just to help
them along the way, in the same way that all other
Claimants are helped: those in the GLO in the new scheme
will receive interim payments; the Core Participants in
Category B received interim payments.
We do ask, sir, why not even identified shortfall,
42
thinking about how to accommodate claims that are out of
time.
We have one client, sir, whose husband was
subpostmaster in 2004. Her husband was arrested and
interviewed by the police after shortfalls were
discovered at his Post Office. He was released under
investigation and attempted suicide. He became
seriously mentally ill. He was not prosecuted because
of his medical state but was dismissed and required to
repay the shortfall. When left on his own for a day for
the first time, he took his own life and it was only
after hearing the impact evidence in this case, si,
that his wife felt able to revisit what was terrible
trauma. She submitted a claim to the HSS, obviously out
of time and, in May of this year, she was informed that
her case would be looked into but she's not heard
anything since.
Again, sir, the feeling on the part of many
applicants is that the simple cases are being dealt with
but cases which pose difficulty are less of a priority
and this is something which is a concern when
considering the delay faced by HSS Claimants who have
suffered bankruptey as well
As to legal costs, we repeat our written
submissions: only 45 cases where costs of legal
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representation have been paid. On the basis of the
experience of Hudgell Solicitors the high number of
settlements agreed so far does not necessarily mean that
those claims have resulted in full and fair compensation
for those subpostmasters.
Post Office accepts that cases now progressing to
offer are more complex and more likely to lead to
dispute but the limited funds made available for
subpostmasters to seek legal advice are wholly
inadequate, we say, sir. Post Office has spent
£16 million setting up and administering the scheme, and
less than £50,000 has been spent on legal advice for
applicants. Without access to advice and representation
through the dispute resolution process, there's a real
risk, sir, that further unfaimess will result.
Finally, sir, the operational independence of the
panel. Hudgell Solicitors is concerned that there ought
to be transparency and greater clarity around the
practical working of the relationship between the panel
and Post Office and HSF. The system in place is one
where Post Office carries out an intemal investigation
and prepares a report, and then HSF Herbert Smith
Freehils, sir, makes a recommendation to the panel.
With the best will in the world, sir, there is
‘a danger in a process like that, that the panel becomes
45
to produce either an interim report or an update, as the
case may be, within weeks rather than months?
MR MOLONEY: Entirely, si. Ill come on to what we say,
sit, about the way forward. Ill come back to this but
we don't ask you to butt out, sir. We do not ask you to
butt out but we think, sir, that everybody would
benefit, and I will come back to why, by you keeping
a very close eye on the developments in these issues of
compensation for subpostmasters.
Sir, just finally on the panel, Hudgell Solicitors
have now been involved in good faith meetings and it's
been asserted that heads of loss which have been missed
are subsequently identified. Sir, Hudgell Solicitors,
have notes sent to them by Post Office in relation to
ood faith meetings where i's asserted -- and these are
Post Office notes not Hudgell notes of the meetings ~
which says that Post Office will only take a new head of
loss into consideration at this stage in exceptional
circumstances and they queried whether there are any
reasons why it had not been raised previously.
Now, sir, you have already made the observation
this morning that for those who completed their
application under the HSS scheme by August 2020, the
original closing date for the scheme, then the guidance
as to consequential loss was not available. Cases going
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familiar with the reports prepared by Herbert Smith
Freehills and makes decisions that are closely aligned
to the HSF recommendations. That may be, sir, because
they are uniformly right, of course, but it may also be
because of other reasons.
What Post Office suggests, that the panel is not
awarded less than the recommendation made by HSF on any
occasion, and whilst that is to be commended, we say it
cannot mean much on its own, There are no figures
available, sir, as to how often the panel recommendation
has been the same as the HSF recommendation and no
figures on how often or when the panel challenges the
lack of information or points out that heads of loss are
missed
We say, sir, that the Inquiry might be assisted by
examining the decisions that have been made so far, to
lock at the Post Office recommendation, the HSF
recommendation, and assessing the extent to which the
panel decisions differ from HSF recommendations in terms
of heads of claim and the quantum allowed for the claim,
and we may then see, sir, the extent to which there is,
as it were, an independent action by the panel, and
hopefully put the concerns of subpostmasters to bed.
SIR WYN WILLIAMS: There's a practical dificulty, is there
not, in undertaking an exercise of that sort and trying
46
to good faith meetings at this stage may well be the
ones that were the early submissions. We don't know but
that, sir, would be a very conceming position if only
those heads that had been identified in the form were to
be considered and only heads of loss that were not ~
heads of loss that were not in the form would only be
considered in exceptional circumstances.
In another good faith meeting, sir, a client was
told that it was understood that there was no provision
for obtaining expert reports in the HSS. That at least
suggests, sir, that things may be different on the
ground to what is thought to be happening and reflected
in our written submissions.
That's it, sir, in respect of the Historical
Shortfall Scheme.
SIR WYN WILLIAMS: Thank you.
MR MOLONEY: You will be relieved to know, sir, that
I believe our submissions in respect of the rest are
much briefer.
SIR WYN WILLIAMS: We appear to have a substantial part of
the day left, Mr Moloney. I am not encouraging you to
spin itout, as they say, but, equally, you must take
your time to explain your point of view sensibly to me.
MR MOLONEY: Thank you, sir.
Sir, Category B: final compensation for
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subpostmasters with quashed convictions. Hudgell
Solicitors represents 63 of the total 73 Category B
subpostmasters, that is to say those who have had their
convictions quashed either by the Court of Appeal
(Criminal Division) or in the Crown Court at Southwark.
There are a further five appellants represented by
Hudgell Solicitors whose appeal against conviction will
not be opposed by Post Office on 25 July
SIR WYN WILLIAMS: Then do you think I need to attend, even
remotely? I was going to ask you, actually, if you knew
anything about it because the Court of Appeal alerts the
Inquiry when these things are happening, so we knew of
the date. But if i's going to be 10 minutes or
20 minutes or whatever, where the facts are briefly
explained and then the convictions quashed, it may be
that I should spend my time writing not watching
MR MOLONEY: Sir, I will confirm the position for you but
I believe ten minutes is about right for 25 July. But
I will confirm that.
(Interruption)
(11.50 am)
(A short break)
(12.04 pm)
MR MOLONEY: Sir, I'd just introduced Category B and tried
to save you some time and, whilst it's obviously ~ we
49
chronology, the appeals were heard in March 2021, the
decision in Hamilton and Others was handed down in
April 2021. This is 7 January 2021, when my instructing
solicitor was touching base, as it were, as to the
potential for actions for malicious prosecution. He
said:
“For completeness, I would stress none of my
clients will participate in any sort of Post Office
scheme."
Hudgell Solicitors stand by that position, si.
The prior history of Post Office schemes, the mediation
scheme, was unfortunate, we say at the least, but
there's never been any further dialogue, no offer of
an alternative scheme, an independent scheme. That was
it:7 January. There has been no further discussions
around that.
As you may be aware, sir, now tuming to the
update and just putting that particular submission from
POL and BEIS in context, funding is not available for
these cases but Hudgell Solicitors have, nonetheless,
been taking all necessary steps to ensure that the
Claimants receive the fair compensation they are
entitled to, and Hudgell Solicitors have made the
commitment that the Claimants will not have to pay them
one penny piece of the damages they receive
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anticipate that, of course, there will now be on
25 July, if the Court of Appeal accedes to our grounds
of appeal, then there will be a further five which, will
be 68 represented by Hudgell Solicitors.
‘As we understand it, and we will be corrected if
we're wrong, of those ten not represented by Hudgell
Solicitors, then Howe+Co represent three Category B
SPMs. I'm not sure ifits Hodge Jones & Allen or
Mr Marshall who represents three, and then each of the
other four solicitors named at paragraph 48 of POL's
supplementary submissions, Aliant Law, Clarke Kiernan,
John Donkin Solicitors and Brewer Harding & Rowe
Solicitors, represent one subpostmaster each.
Before we update you, sir, as to the progress of
those cases, may we make just one clarification in
respect of the submissions of Post Office and BEIS in
their written submissions and oral submissions. ir, it
was said that one of the reasons why no scheme was ever
proposed in relation to Category B Claimants was that
Hudgell Solicitors had said in correspondence that they
would not take part ina scheme. We asked for the basis
of that assertion to be provided and its based on one
line from an email to Post Office Limited from my
instructing solicitor on 7 January 2021
just to have that, as it were, fixed in the
50
So in that vein, sir, Hudgell Solicitors have
engaged the services of expert accountants to analyse
the financial position of each subpostmaster, in order
to best understand the pecuniary losses they have
suffered, and all 63 subpostmasters have had the benefit
of those accountancy services.
SIR WYN WILLIAMS: I'm sorry, before we leave that,
I thought that, in respect of final payments of
compensation to convicted persons who have had their
convictions quashed, that the Minister had said they
would pay reasonable fees
MR MOLONEY: Indeed, si, but there's no funding upfront.
SIR WYN WILLIAMS: I'm with you. Sorry, I was just
misinterpreting —
Ultimately, there will be reasonable reimbursement
of fees and disbursements but not upfront?
MR MOLONEY: Not upfront, sir, absolutely. But that goes —
specialist accountancy services have been secured in
relation to all 63,
‘As Ms Gallifant pointed out last week and as we
have shown through the HSS correspondence submitted to
the Inquiry, bankruptcy is a complicating feature of
these claims as well, not just the HSS. In fact, its
a significant factor in claims amongst this category.
20 per cent, sir, one in five, of the Category B
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Claimants represented by Hudgell Solicitors became
bankrupt, and that's just one symptom of the havoc
wreaked in people's lives by the unreliability of
Horizon.
So, therefore, expert assistance has been
commissioned to establish the best way to deal with
bankruptcy issues in these cases. The same goes for the
tax position of these Claimants. Sir, you can imagine
there's very little point in getting damages to put
‘a person back in the position they would have been in
but for the actions of Post Office, only then to find
a very large percentage of it swallowed back up by the
very department which is responsible for authorising the
payments in the first place, So Hudgell Solicitors have
commissioned expert assistance on the tax implications
of the compensation payments, in order to secure the
best position.
As well as taking statements from all the
Core Participants and their families, Hudgell Solicitors
have also arranged medical reports for each of the
Claimants, and we have established, sir, although itis,
often said, we have now established it to be the case
that many subpostmasters have suffered serious,
long-term psychiatric damage through what they
experienced and that has led to significant
53
in September. In both cases the Claimant will receive
another payment on account and we hope, sir, that
dealing with those two lead cases in that way will lead
to an established process so that the remaining 60-odd
cases can be resolved between now and the end of the
year.
SIR WYN WILLIAMS: It's in the context of this category of
Claimants that the notion of me butting in or butting
out, whichever way you lke to put it, first raised its
head, although I accept entirely that it can raise its
head in all kinds of other different scenarios.
But I am conscious, and you are confirming it,
that there appear to be meaningful discussions taking
place between those instructing you and POL's lawyers
and, therefore, itis a matter of some concer to me to
get it right, the extent to which I can assist of what
might be a delicate moment, particularly because,
although you represent the bulk of the people in these
categories, there are, in fact, a number of other people
who are represented by other solicitors, which may or
may not make it easier or more difficult. I don't know
where much about these things, in the sense that I don't,
know what is going on behind the scenes.
So itis a situation in which, to use a more
judicial type of phrase, I wish to tread carefully.
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consequential losses.
Exemplary damages are available in this area, sir.
Ms Gallifant was quite right to point out that exemplary
damages may ordinarily be available for actions in
contract but they are available for actions in malicious
prosecution and the experiences of Claimants and their
families, and the effects upon them, medical or
otherwise, are ultimately highly relevant to that
category of damages, as well of course, as aggravated
and general damages which are compensatory damages not
punitive damages.
There has been a great deal of work to get us
where we are now, sir. Much of what has gone on is
confidential and without prejudice because the parties
need to trust that their discussions are confidential,
in order that they are able to negotiate. But we
consider there has been so far been positive dialogue
towards a resolution. We can't go into great detail in
respect of the negotiations between our clients and
Post Office Limited but we are able to say with their
agreement that, firstly, the parties have concentrated
on two lead cases,
In one we've almost resolved all the heads of
pecuniary loss. In the other, we've resolved most of
the heads and the remaining heads will go to mediation
54
MR MOLONEY: Sir, can we, in that vein, tell you the
remainder of what is going on, so that you can assess
how to tread carefully, so that your decision as to the
tread is fully informed and so, sir, as I said, we hope
that that - dealing with the pecuniary losses in
relation to two cases will mean that the other 60-odd
Claimants — that will provide a framework for dealing
with the pecuniary losses in relation to the other
60-odd that we represent.
Sir, tigation in the courts is seen as the
option of last resort but it must always remain open to
protect the position of our clients.
Now, we have instituted the early neutral
evaluation process, in order to try to resolve issues
around the appropriate levels of non-pecuniary damages.
Just to make clear, sir, if we may, there are further
submissions by Hodge Jones & Allen last night that we
received, which at paragraph ‘(a) say that Herbert Smith
Freehills (HSF) have instructed Lord Dyson to lead
a process of early neutral evaluation to help determine
non-pecuniary loss for Category B Claimants which
includes the CPs we represent.
\ don't know if you have ~ they are not in the
core bundle.
‘SIR WYN WILLIAMS: No, but I have read them.
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MR MOLONEY: Sir, i's repeated at paragraph 21 that the
scheme should, of course, make use of any published
guidance arising from HSF instructing Lord Dyson. Sir,
that is absolutely not the case. The process is
an early neutral evaluation and, in that process, the
parties consider between them various options as to the
appointment of the evaluator and then they agree upon
the evaluator to give an indication as to what they
consider would be the appropriate damages afer trial
HSF have not instructed Lord Dyson; the parties
have instructed Lord Dyson.
SIR WYN WILLIAMS: So that I'm under no misapprehension, how
do you define the parties there, Mr Moloney?
MR MOLONEY: I's essentially Post Office Limited and the
clients that we represent.
SIR WYN WILLIAMS: So its the Hudgell Core Participants —
MR MOLONEY: Yes.
SIR WYN WILLIAMS: -- and POL?
MR MOLONEY: Indeed, sir, yes. Sir, in that vein, we
retum, if we may, to paragraph (a) where
Hodge Jones & Allen assert that Herbert Smith ~ HSF
have instructed Lord Dyson to lead a process of early
neutral evaluation to help determine non-pecuniary loss
for Category B Claimants, which includes the CPs we
represent. It's not for all Category B Claimants. t's
57
involvement or at least the agreement of Hudgells. We
don't know where that comes from, sir. This is not
meant to be a process for all Category B subpostmasters
but we have reached the stage, sir, in our dealings, the
preparation of these cases, where we have all our
necessary evidence in place, we're ready for this stage,
we have made good progress on pecuniary damages, and
there are no heads of loss which are excluded in this
process, we make clear.
But we are concerned about this, sir, because our
clients have suffered enough worry over the past many
years and they don't need further worry about
Herbert Smith Freehills having instructed the neutral
evaluator and itnot being an agreed and decided
position when there is absolutely no foundation to that
suggestion
It's Wednesday, sir. The hearing is on Monday.
I ought to say, in that vein, sir, as well, that
Mr Stein asked you last week if the evaluation of
Lord Dyson might be made available. Well, sir, the
parties formally agreed weeks ago that the evaluation
would be made available to you if you requested it, with
that in mind, sir.
That's how things are progressing, sir, and also
there have been some positive developments in the run-up
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a stage that has been reached between the
Core Participants in Category B represented by Hudgell
Solicitors and the Post Office, with the claims that we
have.
We hope, sir, that the general principles of
evaluation by Lord Dyson will be able to be applied to
the remainder of our 68 clients and facilitate
assessment of non-pecuniary damages across the board for
our clients. We hope that that will be possible
It may assist the remaining ten persons, variously
represented by other solicitors, but i's a matter for
them, sir, as to whether or not they are assisted by it.
Neither party is bound by the evaluation of Lord Dyson,
certainly none of the other Category B Claimants are
bound by the evaluation of Lord Dyson. This is not for
all Category B Claimants, sr.
At paragraph 8 of the Hodge Jones & Allen
submissions, it reads:
"HSP's instructions to Lord Dyson appear to have
been drafted with the involvement or at least the
agreement of Hudgells but Paul Marshall, who acts for
the CPs we represent, is not even aware that Lord Dyson
had been instructed until after the event."
Now, we're not really sure, sir, what instructions
are being spoken about there and what is meant by the
58
to your hearings over these two days in July, sir. As
Mr Chapman acknowledged, there have been difficulties in
disclosure, so far as these cases are concemed. We
have been pursuing discovery ~ we are happy to say that
we received letters last night which have moved things
forward significantly.
But you will also have seen in our submissions,
sir, that we explain that many of our clients were
worried about Post Office clawing back the interim
payments they have received. They have been reluctant
to rely on those funds as being secure and, for many,
that has meant continuing financial hardship in the
absence of any reassurance from the Post Office on their
claims.
‘At paragraph 41 of our further submissions to the
Inquiry, which is at page 84 of the bundle, we say that
it would of course be open to the Post Office to make
any such concession or give such reassurance to the
Claimants because Hudgell Solicitors raised the question
of claw-back nine months ago and had chased it since.
On 5 July, si, we're happy to say, as
Ms Gallifant reported last week and confirmed by
Mr Chapman this morning for BEIS, that we've received
an assurance that there would be no claw-back of interim
payments.
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Now, that provides some comfort to the
subpostmasters, sir, but it isn't the end of the matter.
Many of these subpostmasters have been in significant
debt for very long periods of their lives and it's what
we say would rightly be described, sir, without
hyperbole, as crippling debt. £100,000 sounds like
a lot of money, itis a lot of money, but the debts of
subpostmasters were usually well in excess of £100,000,
and the interim payments have often been used to settle
some of those debts and are now gone.
In fact, some of the interim payment was said to
recompense interim legal costs incurred by the
solicitors but such is the position of these
subpostmasters that Hudgell Solicitors represent, then
they did not take anything from the interim payments to
cover any of the funds they've expended
The position genuinely, sir, of many of the
Claimants is really bad and you can perhaps imagine that
it would be case after 15 years of being a criminal,
a bankrupt and unemployed or employed in very low-paid
jobs. With £100,000 they haven't won the lottery, sir,
its just one step towards putting them back into the
position they would have been but for the actions of
Post Office
It's a feature of these cases, sir, that many of
61
to enjoy their retirement as much as possible after
‘enduring what they did.
Sir, in practical terms what that means is they
need now to be able to have good experiences with their
children and grandchildren and other family and friends
to try and replace the terrible memories that they have
had since they suffered injustice at the hands of
Post Office, caused by the unreliability of Horizon. So
we say, sir, there needs to be expedition with these
claims so that the Claimants can start to regain the
lives that were wrongly taken from them for such a long
period of ime.
Not shortcuts, this is a really important process
and the Claimants have to get what they are entitled to
in law with a willingness, on the part ofall involved,
for these claims to be resolved as soon as realistically
possible. The time for adversarial aggressive
Itigation, we say, is long gone and what happens from
now on should be geared to finding solutions with the
interests of the subpostmasters at the heart of
everything that is done and not the interests of
Post Office or BEIS or UKGI, or firms of solicitors or
counsel
So far from asking you to butt out, sir, we have
never wanted you to butt out, we would ask you to
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the people who were convicted and many in the wider GLO
group were in middle age when they took over their
branch at the Post Office. Given how long the injustice
they suffered was sustained for, the vast majority of
them are now either approaching retirement age or past
retirement age but they just can't rete. They can't
afford to retire. The last third of their earning life
was blighted by this scandal and so any earnings
potential over that time was destroyed and they are not
ina good enough financial position to retire.
This is Jo Hamilton, who's here today, and I hope
she will forgive me if I say that she continues to work
as a cleaner and a dog walker and her husband is
75 years old and is stil working
So leaving aside the awful realty, and itis
a reality, that some of these Claimants’ parents died
while they were still convicted and the terrible
potential that some of them may die before
compensation ~ and I won't dwell on the details of
that, sir, but one of the Claimants represented by
Hudgell Solicitors has inoperable brain cancer and
counsel for Howe+Co Core Participants mentioned the
circumstances of another two of Hudgells clients last
week, so I don't propose to drag it up for their
families again but, essentially, these Claimants deserve
62
continue to watch both the situation with these claims
and the HSS scheme because we believe that, fora
variety of reasons, those who hold the purse strings
don't want you to think badly of them, si.
Anything you say on these things, sir, will be
very, very important to them. So we ask, sir, that you
retum to the position on compensation during the autumn
when we resume the hearings, and return at convenient
times as the Inquiry proceeds, in order to see how the
Claimants in these cases are being compensated. I's
not a position we say, sir, where you can make firm
conclusions that will apply right the way across the
board at this stage.
May we please say something, sir, about the three
Claimants in this category who have not received
an interim payment after making a request. As you know,
sit, these three Claimants had their convictions
referted by the Criminal Cases Review Commission to the
Crown Court at Southwark, on the basis that there was
a real possibilty that their convictions would be
quashed. That's the statutory basis for the referral by
the Criminal Cases Review Commission, whether to the
Court of Appeal or to the Crown Court, and they all went
to Southwark Crown Court
There were matters to be resolved in the cases of
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the complainants, which were important to the
determination of the appeal. The Post Office decided to
offer no evidence in their cases, in the interests of
justice and, as a result, sir, not guitly verdicts were
entered. They were all found not guilty and the matters
to be resolved as identified by the CCRC were not
resolved. Now, the Claimants had no say in that
process, nor indeed did the court, but the Post Office
now refuses to pay compensation to them. In effect,
they say "Sue us in the Civil courts"
They say to these people who were wrongly
convicted by the Post Office, because they are not
guilty ofthe allegations they were wrongly convicted
of, they say to these people who were part of the
GLO Litigation where Post Office fought tooth and nail
to the defend the indefensible, they say to these three
people who are ineligible for the HSS and ineligible for
the BEIS GLO scheme in contemplation, they say that they
will not pay them.
The time for litigation, sir, was at
Southwark Crown Court where the court was seized of the
issues which were central to the determination of
whether Horizon data was essential for their prosecution
and Post Office would have had to prove their guilt o
the criminal standard. The Post Office had the
65
don't fall into the GLO because they weren't part of the
GLO but they may have a cause in malicious prosecution
SIR WYN WILLIAMS: Absolutely, but my point was I'm, as
‘a matter of fact, not aware of any such person. I'm
aware of people who were within the GLO who fall into
this category but I am not actually aware of any people
who were not within the GLO but who yet were prosecuted
but acquitted.
MR MOLONEY: I Sir, there are five people that Hudgells
represent.
SIR WYN WILLIAMS: {I'm sure that in due course I will be
made aware of them, if they exist, but !m just putting
that out because that's the state of my knowledge and if
its because I've missed a detail in the papers
I apologise. But that is the state of my knowledge.
MR MOLONEY: Sir, you haven't missed any detail but there
are a number, and Hudgell Solicitors represent five of
them —
SIR WYN WILLIAMS: Right.
MR MOLONEY: I -- who were not part of the GLO but were
prosecuted and were not convicted. They have actions in
malicious prosecution but they are not part of
Category B.
SIR WYN WILLIAMS: I've caught up now, Mr Moloney. So they
have no rights under the GLO scheme that's about to
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opportunity at that point to contest their appeals and
unilaterally chose not to. In those circumstances, we
say, si, it would be wrong to ask them to go right back
to the start.
Finally, under this section, sir, of the Claimants
who have had their convictions quashed, may we deal with
the position of persons who were prosecuted but not
convicted. Anybody who was prosecuted but not convicted
may have an action in malicious prosecution, just the
same as anybody who was convicted. As they were not
convicted, they don't automatically come within the
group of Category B people. Now, in those cases, si,
in the Category B cases Post Office is not relying on
limitation. We say the natural position for these
people who are prosecuted but not convicted is in
Category B because the same issues arise.
SIR WYN WILLIAMS: As things stand, and I want to clear my
thoughts upon this, there's the further complication of,
I think, the people involved, so far as Im aware, being
GLO Claimants, yes?
MR MOLONEY: No, sir. So there are people who were part of
the GLO who were prosecuted but not convicted. They
will stay in the GLO scheme. They are in there but
there are others, sir, who were not part of the GLO
scheme but were prosecuted and not convicted. Now, they
66
flower?
MR MOLONEY: I That's it
SIRWYN WILLIAMS: So, at the moment, they are a genuine
lacuna?
MR MOLONEY: They are, sir, and we simply ask, sir, that ~
SIRWYN WILLIAMS: Except for-- sorry, to be articulating
this as we're going along — but have not BEIS said
that, in respect non-GLO people of this category,
although the Minister used the shorthand "convicted
people" in his announcement of December 2021, in fact he
always intended that people that you were now talking
about should fall within this category. Have I got that
right, Mr Chapman?
MR CHAPMAN: Quite, sir, yes
MR MOLONEY: Thank you, sit. We ask that the same
concession be extended in terms of limitation to those
people as it s to the people in terms of Category B.
That's what we ask.
SIR WYN WILLIAMS: So that in my head before today, and
I want to throw this out in case I've not got this
right, one way or another every category of person now
falls within a scheme.
MR MOLONEY: Sir, yes.
SIR WYN WILLIAMS: Right, fine
MR MOLONEY: Sir—
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SIR WYN WILLIAMS: So that there's no doubt about it, the
HSS clearly is the HSS. The interim/final compensation
scheme, if can put itn that way, now catches and
always was intended to catch people who were acquitted,
who are not part of the GLO and those who were acquitted
but were part of the GLO are now in the scheme that wil
be developed over the next coming months.
MR MOLONEY: That's it sir. Thank you
SIR WYN WILLIAMS: Fine.
MR MOLONEY: We're grateful for that, sir.
Sir, final fair compensation for GLO Claimants.
Sir, at the weekend Hudgell Solicitors, along with
‘a number of other firms, were invited to take part in
discussions with Secretary of State for BEIS over how
best to approach scheme to fairly compensate members of
the GLO and they will do whatever they can to assist.
A number of the Hudgell Core Participants were members
of the GLO and leading members of the GLO, who have been
active in the JFSA campaign for many years and what the
GLO members achieved with that ligation was
extraordinary by any standards.
The members of the GLO supported each other and
will continue to support each other and the
Core Participants represented by Hudgell Solicitors will
help in supporting in whatever ways they can
69
loss of relationships and reputation, for some the loss
of liberty and we ask, sir, that compensation is full
and fair and quick in these cases.
SIR WYN WILLIAMS: There's just one point of detail fd ike
to raise with you~
MR MOLONEY: Sir.
SIR WYN WILLIAMS: relating to one of the three persons
who had not been paid an interim compensation payment,
notwithstanding the quashing of their conviction,
MR MOLONEY: Sir.
SIR WYN WILLIAMS: You said, I think, in your written
submissions, that that one person was also the subject,
of a confiscation order
MR MOLONEY: Yes.
SIR WYN WILLIAMS: -- and that hasn't been repaid?
MR MOLONEY: No.
SIR WYN WILLIAMS: I'm using you now as a kind of letter
box, so to speak, but my understanding is that - if 'm
wrong, I'm wrong, but I don't think I am ~ but
a Crown Court can only make a confiscation order against
a convicted person.
MR MOLONEY: Yes, sir
SIR WYN WILLIAMS: So once the conviction is quashed, the
confiscation order, in effect, has no effect
MR MOLONEY: Yes, sir.
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We say that, clearly, si, there should be parity
of outcome forall of these people who have worked
together in this way, recognising the common and
case-specitic harms that they have suffered
Finally, sir, just to conclude, we focused our
submission on addressing points raised by others in
providing a practical context to our written submissions
but the importance of this issue can't be
over-estimated. We're very grateful to the Inquiry and
to you, sir, for recognising that there can be no more
delay and, in opening these hearings, Mr Beer began with
a chronology of the issue of compensation, which
highlighted the start of the GLO Litigation in 2017, but
before that came the failed mediation scheme, terminated
in 2015. Before that, for many Core Patticipants, came
years of campaigning for redress.
What our Core Participants can't forget and which
they ask you, sir, to recall in considering the points
made to you, is that for many of them these losses
stretch back over two decades and for every SPM, every
subpostmaster in each of the categories, their losses
start with money taken from them by the Post Office for
shortfalls to which, really, they had no legitimate
claim and which led to the loss of businesses and
incomes, the collapse of health and well-being and the
70
SIR WYN WILLIAMS: So how can itbe that the money's not
repaid, I ask both rhetorically and otherwise, and
Leave that for people to ponder.
MR MOLONEY: Certainly, sir, and i's something we have been
pondering. Thank you
SIR WYN WILLIAMS: Now then, Ms Page, itis 12.40 by this
fine clock that I have putin front of me. I'm in your
hands. If you are going to make submissions which would
conclude by, say, 1.30, then my preference would be to
hear them and then we can all adjourn for the day, so to
speak
Mr Beer, I see you are about to intercept me
before I make any such ruling,
MR BEER: Sony to intervene unexpectedly. Whilst you have
been sitting, there has been a request from the Howe+Co
Core Participants to make some short supplemental
submissions, in particular in the light of the BEIS
letter that was distributed this moming. So Mr Stein
has applied by email, which you won't have read, to make
those submissions. That might have a modest impact on
timing. That's the only reason for the intervention.
SIR WYN WILLIAMS: First of all, Ms Page, how long do you
think you are likely to be? I am not going to hold you
to minutes
MS PAGE: I certainly imagine being finished by 1.30 if I
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were the next one to —
SIR WYN WILLIAMS: Short, I take it, means no more than
15 minutes, does it, Mr Stein?
MR STEIN: Sit, if! can assist, it will be no more than
five,
SIR WYN WILLIAMS: So are we stil okay then to proceed and
then finish once I have allowed Mr Stein his
five minutes? Is everyone happy with that?
Good, well then, over to you, Ms Page
‘Submissions by MS PAGE
MS PAGE: I speak for the three Post Office victims
represented by Hodge Jones & Allen, and we are, on their
behalf, dealing with the fallout from the most
widespread devastating miscarriage of justice in legal
history, where hundreds of honest hardworking people
were hounded by a state-owned entity and all because of
unreliable documentary hearsay from a faulty IT system,
That led to the golden thread of our criminal
justice system, that is the duty of the Prosecution to
prove guilt, being broken. People were told, in effect,
that they must prove their innocence and when they tried
to do so, as we know from Seema Misra's case, the
Post Office hid the evidence that might have enabled
them to do so.
The devastation that that inflicted on people's
73
caused Mrs Misra to raise an eyebrow last Wednesday when
she saw the rows of desks set aside for the Post Office.
In answer to the question posed to the
Post Office - should they be the final arbiter of
compensation offered to Category B Claimants -- the
Post Office says that if they don't lke the settlements
they are offered, they can always seek ADR, arbitration
or litigation. That is rich indeed.
They say this to three women whose lives were
destroyed by the Post Office, three women who showed the
resource and courage necessary to join the 555 when the
Post Office fought them tooth and nail, and three women
who also stood out on their own at the Court of Appeal
because the Post Office would not accept ground 2 abuse
and, again, fought them tooth and nail
Now, the Post Office says "Well if you don't ike
what we offer you, we should be allowed to fight you
tooth and nail again”. Once again, the answers the
lawyers will get paid while the Post Office resists
doing the right thing,
There is, we say, a simple way out ofthis: the
Post Office can stop resisting doing the right thing
We have heard repeatedly that the Post Office has
changed. We are told that the "historic" failings are
a matter of great regret but there is little evidence of
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lives is immeasurable. The dignity of those who gave
evidence at the human impact hearings was as impressive
as their stories were heart-breaking. That is what i
means to be a Category B Claimant
The three Core Participants I represent are all
amongst those who had their wrongful convictions
overtumed but were also part of the 555, the
GLO Claimants. We are here to try to find a way to make
some amends but there is no sum of money that will give
them back their lives.
Itis for this reason that we argue, in the
strongest possible terms, that compensation must not be
ruled by narrow legalistic argument about heads of loss
but by the need to ensure that compensation is fair and
swift and, if some legal hurdles need to be surmounted
or ignored to achieve those aims, then so be it, and it
may do something to redress the balance, because the
Core Participants I represent have spent years fighting
and yet fair compensation still seems a long way of,
partly because they have no reason to trust the law or
lawyers.
The lawyers have continued to be paid, even while
they have been unable to get the compensation that they
desperately need and rightly deserve. The Post Office
continues to employ many lawyers, That, in itself,
74
Take the issue of disgorgement just raised, sir.
Of those sums which were wrongly taken from my clients
by way of post conviction confiscation or compensation,
as you said, sir, only possible to be taken because of
their convictions. They were sums that were fictional
Horizon losses and they took the money from those
convicted in any way they could
In the case of Mrs Misra, her flat in London was
seized and sold. In the case of Ms Felstead, her family
hoped that if they gave the Post Office the money she
would be spared jail; she was not but she paid her
family back anyway by remortgaging her home. In
Ms Skinner's case after she had already lost her home
and the Post Office had hounded her for sums of money
she didn't know they were trying to take from her they
still succeeded in taking the litle she had left, and
there is simply no justification in the Post Office
keeping these sums.
It has been well over a year since the convictions
were overturned and the Post Office has made no moves of
its own initiative to give these sums back
The one small sum which has very recently been
retumed to Ms Skinner was due to the intervention of
the Court Service. Where is the proactive desire to
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right wrongs, to rectify the damage, to make sure that
full and fair compensation is paid?
We've heard of course about the Historic Shortfall
Scheme, another opportunity for the Post Office to
demonstrate how they have changed, and I will not repeat
the submissions of others which elucidate clearly how
the Post Office has failed to take that opportunity. So
I say very litle evidence of the much vaunted change at
the Post Office, lttle evidence that the failings are
indeed histori.
So it's against that backdrop that we absolutely
urge you, sir, not to butt out of the compensation
arrangements as they affect Category B Claimants.
The Core Participants I represent have no reason
to trust that the negotiations currently taking place
will produce full, fair compensation and they do not
want to have to fight the Post Office again if those
negotiations fail. They want the reassurance of being
able to turn at their option to an open, transparent
scheme run independently of the Post Office
It now transpires that such a scheme is being
established in any event, albeit for Category C
Claimants. But we say there can be no valid distinction
between the two categories. Its right that Category B
Claimants have the distinct right to pursue claims in
7
very stressful, Group Litigation which broke the
scandal. And yet the current course is set to see them
parcelled off from the rest of the 555 and left to sink
cr swim in their negotiations with Post Office. Worse
stil, the settlement deed took away all their rights,
except their malicious prosecution claims; so the
Post Office would be potentially legally entitled to
limit their settlements without any further
consideration of their contractual positions.
For each and every one of the three
Core Participants I represent, the settlement from the
Group Litigation was woefully inadequate. The reports
of the 555 are to have that settlement reopened and
their contractual rights will not be circumscribed when
considering compensation. It must be right that
Category B Claimants deserve to be empowered in the same
way. They deserve to be able to seek full and fair
compensation from the Post Office and if they don't
believe they have got it directly, we ask that they
should have another realistic course of action open to
them which wil stil deliver, one would hope, a just
and swift result
Id lke to respond directly to the Post Office's
submissions in respect of Mr Marshall's submissions
because they called into question whether Mr Marshall's
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malicious prosecution but, in other respects, their
contractual rights were negotiated away in the
settlement deed in just the same way as Category C
Claimants. The same potential heads of loss will apply
to both sets of Claimants, the same issues of process
apply to both sets of Claimants, the money to pay the
compensation ultimately comes from the same place. It
is all taxpayers’ money.
We are told that BEIS has found an ingenious way,
We are told this moming, to fund the compensation for
the Category C Claimants. There is no substantive
reason why that scheme could not be open to Category B
Claimants at their option. Of course, Category B
Claimants should not be able to claim twice. No doubt,
ifthe negotiations fail, they would be turning to the
scheme as an alternative and if the negotiations,
succeed, no doubt that will resolve all their issues.
But where is the sense or justice in requiring them to
invoke a separate process of ADR, arbitration or
Itigation i those negotiations do fail?
The main point is this: Category B Claimants of
all the subpostmasters have borne the brunt of this
scandal the most severely, not only were their lives
blighted by the wrongful convictions but they also had
the courage to join that very pioneering, and no doubt
78
submissions were within the terms of this Inquiry. We
find that a disappointing but not a surprising response.
The terms of the Inquiry make it plain that the a key
aim is to find out not only what went wrong but whether
the Post Office's learning lessons and making the
necessary changes. Are Marshalls submissions should be
seen by the Post Office as an opportunity to think about
whether they are learning the lessons and making the
changes. Instead the reaction is to stop up their ears
and seek to deflect those submissions as outside the
terms of the Inquiry.
I'm afraid this is typical of how the Post Orfice
has behaved "historically" and it is a shame that they
do not appear yet to be changing. As we've said in
writing, term D of the Terms of Reference, taken
together with C and F, make it plain that this Inquiry
is fully empowered to consider the issue of whether full
and fair compensation has been paid and that is what
Mr Marshalls submissions were directed towards.
Again, as we've already said in writing, it was
a mis-characterisation of those submissions to suggest
that there was an invitation to make a finding of fraud
at this stage. Of course that would be premature. But
the point is it would be also premature and quite wrong
to allow finalised payments to be made on the assumption
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that nothing more untoward than breach of contract has
occurred. Given what we know already in the
unreasonable delays that have been occasioned by
Post Office's actions, it would be right and proper to
ensure that issues of remoteness and foreseeabilty are
dealt with generously as if the claims were in fraud
if I may also respond to submissions from BEIS
this morning, it is good to hear that they are listening
and that they do not seek to defend themselves but
rather to assist the Inquiry. It would be good if the
Post Office were to take the same stance
It seems from what has been said very recently in
communications and here today that the Department
acknowledges and seeks to make it clear that BEIS will
not have a special relationship with Freeths setting up
the scheme and that other lawyers will be feeding into
that fully. That is as it should be. It is not as if
all of the 555 were happy with the outcome of the
settlement negotiated by Freeths and, whatever the
rights and wrongs of that, and I don't trespass into
that area, it was extremely unfortunate that
GLO Claimants were led to believe that if they wanted to
have any say in the BEIS scheme, they needed to
reinstruct the very firm who negotiated that settlement.
That was particularly unfortunate in the context of this
81
situation -- of course it is a delicate situation - and
itis hard to make sure that everybody gets what they
want but what we would suggest is that the submissions
that we make on behalf of our Core Participants need not
stand in the way of the actions that are being taken on
behalf of those Core Participants who are represented by
Hudgells. Its an opt-in that we advocate for and
there would be no reason why anyone should opt in if
they don't with to.
SIR WYN WILLIAMS: If I've understood you correctly, your
position is that there should be an option for both your
clients, but for that matter any other Category 8
clients, to become part of the scheme that will be
developed with the GLO Claimants.
MS PAGE: Exactly.
SIR WYN WILLIAMS: That doesn't preclude people reaching
their own settlement if that suits them,
MS PAGE: Exactly
SIR WYN WILLIAMS: I've got it, yes
MS PAGE: That would simply make the BEIS scheme open to all
the 555 which is, in fact, a figure that BEIS has often
used when talking about proper compensation for the SPMs
but, of course, once the Category B Claimants are taken
out of the picture, itis no longer the 555.
As part of the recommendation that we suggest, we
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case when the subpostmasters have so many reasons to
mistrust the law and lawyers
‘As we said in writing, it was also regrettable
that Freeths wrote to Category B Claimants as if they
had not been excluded from the first phase of this
scheme. We endorse Mr Stein's submissions from last
Wednesday. BEIS should not be conducting their
interactions with the GLO Claimants and this Inquiry
through press release, and if more thought had been
given to communicating properly for the GLO Claimants,
the unfortunate communications from Freeths might have
been prevented
BEIS says its listening and it says today, and
we welcome, that its giving consideration to our
submission that Category B Claimants should be given an
opt.in to their scheme and so we ask you, si, to help
them to reach a positive decision on that.
if I may respond then to Hudgelis and I'm very
grateful to Mr Moloney for clarifying the situation with
respect to the instructions which did not come solely
from HSF to Lord Dyson, but from Hudgells as well as
HSF. That's very helpful and apologies for any ~ well,
indeed for the misapprehension and the mis-communication
on my part - our part.
What we would say is that itis a delicate
82
say that through that scheme the best approach to
aggravated and exemplary damages would be to resolve
a preliminary payment on that head but to leave that
head open until the conclusion of the Inquiry. We
suggest that that would be the best way to ensure that
con the one hand there is a swift resolution but on the
other hand there is a full and fair resolution
We accept, of course, that everyone wants a swift
solution and indeed no doubt departmental budgets make
it difficult to leave that head of damage open for what
may be a relatively long period of time. But we suggest
that if all payments on the head of aggravated and
exemplary damages have been finalised, the findings of
the Inquiry might not have the impact that they could.
Therefore, we ask that the desire to close off and tidy
up should not prevent relatively late additions to that
head of damage. In the same vein, we would ask that the
scheme be left open for as long as it takes for the 555
to make any claims they may wish to but at least until
the end of this Inquiry. It is a finite group and once
principles and process are in place, it should not be
hard to make provision for late claims.
Those are the submissions that I would like to
make. I would lke to conclude, however, by offering
apologies for Mr Henry, who I know has written directly
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and apologises that he is unable to be here today.
SIR WYN WILLIAMS: That's fine. I'm very glad he's busy.
Right, thank you. That concludes those submissions.
So I think, as he always anticipated he would,
Mr Stein will have the last word.
‘Submissions by MR STEIN
MR STEIN: May I thank you for the opportunity to make these
short further submissions.
It perhaps was useful that there was a break this,
morning which allowed my instructing solicitor,
Mr Enright, and Mr Brightwell from BEIS to have
a discussion in Paternoster Square. Whether I can call
that "Paternoster Square Protocol" as yet, !'m not sure.
It serves, though, to provide the basis for an
update. So you are aware of the correspondence, sir,
that we had yesterday from BEIS and you will see the
various matters that are set out there insofar as they
touch upon the interim compensation scheme, how that
might be rolled out and how that would affect the
GLO Claimants
Sir, the way ahead appears to be this. Now, this
is aspirational because this relates to a discussion
today and it therefore requires firming up, but it does
provide some light at the end of the tunnel to secure
those interim payments for the GLO Claimants
85
we put a marker done, if I can put it that way, for
disclosure to those representatives of individuals
before this Inquiry of that methodology when its
available to BEIS. We do that because, sir, you're
aware having been addressed last week on the basis that
there have been already some concerns raised as to how
that was dealt with originally in evidence.
Lastly, if lam approaching the end of my five
minutes, I will use my last few seconds to just say
this. Sir, you have been addressed on the basis today
and last week that you should keep yourself involved in
discussions and keep an eye on what is going on.
Various ways have been looked at as to how that should
be done, either butting in or not as regards discussions
and progress being made. Our primary submission was
made that you should, if you would accept it, issue an
interim report.
Having considered all the matters said on the last
occasion and today, and if, sir, you are wiling to
retain the oversight job to make sure that compensation
is delivered in a timely fashion, may we tentatively
suggest that you plan for a third day. The reason for
that would be to have a date in the future that in
a faiily traditional legal way that could be vacated if
it was unnecessary by agreement from all parties, but it
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Freeths will provide a schedule of GLO Claimants
to BEIS setting out the using the Freeths distribution
methodology the amount payable to that group as being
the first step. Next, BEIS will then pay Freeths the
sum of money that is required within, they hope and they
believe, a week. Thirdly, within a similar timetable
Freeths will then pay the interim compensation monies to
the individual GLO Claimants, as I repeat, hopefully
within a week.
So the sort of timetable that we are talking about
that may assist you in understanding what we are looking
at when people refer to "a few weeks" or "as soon as
possible" or similar remarks, it provides a way of
accessing the possibilty that isin discussion today of
getting money to people that urgently require it within
very few weeks. Itis possible within something like
three weeks
May I just also refer to the question of the
Freeths methodology. As you are aware, BEIS has
confirmed in their correspondence that that methodology,
which was adopted for the distribution of monies as
a result ofthe settlement of the GLO litigation, that
is being supplied to BEIS. Our concem is, as you have
discussed today, that there is a need to make sure that
all matters are dealt with transparently, openly, and so
86
would provide perhaps a work-towards date that may
assist
That also might assist you, sir, n resolving the
issue of whether an interim report is, in fact, required
because if you came to the conclusion that good progress
is being made in a timely fashion given all of the
delays, you might come to the conclusion that a third
day would either be necessary to resolve any final
matters or it could be vacated if required or it might
resolve the issue as to how to deal with overall the
position that you are left within looking at the
compensation issues in the round.
Sir, those are our submissions. We also do
represent an individual who fits within that other
category of people, and so there are of course for
Hudgell Solicitors, Howe+Co and I'm sure for
Hodge Jones & Allen individuals we represent that fit
within all aspects of the different A, B and C
categories that you, sir, have identified.
Can I assist any further?
SIR WYN WILLIAMS: No. Thank you very much, Mr Stein.
Well, my thanks to all the advocates who have
spoken this morning. Clearly we've made very good
progress today because we've now reached the end of the
intended submissions.
88
(22) Pages 85 - 88
eye aroen a
10
1
12
13
14
15
16
17
18
19
20
21
23
24
25
The Post Office Horizon IT Inquiry
As I said in my short written note which preceded
the first hearing, I intend to reduce to writing ~ I am
choosing my words very carefully ~ my thought processes.
aS a consequence of the submissions that I have heard.
I will not announce now whether it will be a progress
update or an interim report but what I will say is, so
that people have some expectation of a timescale, that
ifit is an interim report I have in mind that
Parliament will resume after the summer vacation on
5 September, so that would appear to be a time when any
such report, or shortly thereafter, could be laid before
Parliament; obviously in terms of a progress update,
that legal step is not a requirement but I expect that
I would be working to much the same sort of timetable.
So that’s what we have in mind, ladies and gentlemen
I hate to make predictions about the pace of my own work
but I will do my best to adhere to what I have just
said.
So thank you all very much. Please feel free to
leave because I'm just going to stand up and walk out
and then everybody can do the same.
(1.07 pm)
(The hearing concluded)
89
BIH HARON
11
12
13
14
15
17
18
19
20
21
22
23
24
25
INDEX
‘Submissions by MR CHAPMAN
‘Submissions by MR MOLONEY
Submissions by MS PAGE
‘Submissions by MR STEIN ..
90
INQ00001056
INQ00001056
13 July 2022
24
73
85
(23) Pages 89 - 90
INQ00001056
INQ00001056
8/4 3 A Bit
11.50 [1] 49/24 30 June [1] 22/11 lable [18] 10/23 19/22 I@cduitted [4] 16/5
MR BEER: [4] 72/14
MR CHAPMAN: [12] Heri) ts 30 million [1] 22/20 I 23/8 27/18 30/14 32/4 sevonyen {11 25113
arta 13118 14/1 18/10 pe HL oe 31 [2] 32/19.32/20 I 36/28 41/2 4a18 42r10 Iaerony wa dare oari2
tora 1521 1524/12 UN 272 at ay (2} tarts I 44/43 54/16 54/20 across [2] 58/8 Oi
4717 17/20 24/10 uly 2022 [1] 20/20 58/6 63/4 77/19 78/14 I2°t [2]
12.04 pm [1] 49/23
12.40 [1] 72/6
43 July 2022 [1] 1/1
acting [1] 1/9
action [4] 35/3 46/22
66/9 79/20
24/12 68/14
MR MOLONEY: [32]
24/21 34/18 47/3
35 [2] 27/9 30/9 79/7
37 million [1] 12/1 about [32] 5/44 16/13
7] 23/11 23/24 25/14
45 [1] 32/20 4 actions [9] 36/10 51/5
48/17 48/24 49/17 ] SI gi47 31114 33/25
49/24 52/12 52/17 minutes " Vas 41 [1] 60/15 36/23 40/10 43/2 ay ot oo 81/23
56/1 57/1 57/14 57/17 pve I yeu aig (Cott 27/2 43/14 48/1 47/4 49111 I Oo ean
57/19 66/21 67/9 000 [2] ig (OL) 44/25 4gite 55/22 58/25 {active [1] I
67/16 67/20 68/2 68/5 te, mon i ent 48 [1] 5010 I sonosoriz6o9 —_— actively ti te
68/15 68/23 68/25 million [4] 5 6414.67/25 68/12 ‘(I activity [1]
69/8 69/10 71/6 74/10 I 19-0 Million [2] 22/15) 69/1 72/12 74/13 77/3 I2ets [2] 6/15 58/21
marine rio. I 249 5 July [1] 60/21 go/7 8322 serio (actually [5] 11/7 16/3
1932 [1] 21/20 5 September [1] 42/11 49/10 67/6
rae Tak 89/10 89116 acute [2] 27/24 31/23
MR STEIN: [2] 73/4 sence [2] 28/1
Bh STEW: (2 2 Ee s,e60 1] 216 [uence (I added [1] 22/17
MS PAGE: [5] 7225 [> minutes Ty 401g 000 1) 45/12 absolutely (8) 4/2 Iagation Ii] Mle
54,830 [1] 29/12 additional [10] 10/1
eon 8315 85/18/90 per cent [1] 52/25 /55 [1] 20/13 aren iia 10/12 11/21 18/18
,I200,000 [2] 42/16 I 555 [8] 74/7 75/11 20/21 21/7 21/15 38/3
SIR WYN WILLIAMS: I") abuse [1] 75/14
79/3 79/13 81/18 43/17 43/19
[54] 1/3 13/15 13/22 logo 11) 6/15 accedes [1] 50/2 wi
45/6 15/11 15/18 {] 83/21 83/24 84/18 accept [7] 17120 40/9 [Aditions [1] 84/16
2004 [1] 44/4 address [6] 9/8 16/15
2015 [1] 70/15 6 July 2022 [4] 11/23 38/23
34/17 46/24 48/16 accepts [1] 45/6
48/20 49/9 52/7 52/13 [2047 {!) 70/13 80-odd [3] 55/4 56/6 3] 12/16 23/3) 2ddressed [6] 1/11
2019 [2] 22/18 23/4 I 5619 access [3] 4/14 1115 1/23 87/5
55/7 56/25 57/12 I 9q0 [7] 10/11 13/12 I63 [3] 49/2 52/5 52/19I 49/13 87/40
57/16 57/18 66/17 I 43/43 13/19 13/20 63 Core Participants I@¢0essing [1] 86/14 i
67/67/11 67/19 I a3/04 47103 rt] 2608 Pants I sccommodate [1] accressing [2] 24/16
87/24 6813 6816 68/19 Iq94 1g) 10/14 10/15 I68 [2] soase7 = I 441 adhere [1] 89/17
68/24 69/1 6919 71/4 I“so/49 S004 84/1 S113 en laccording [5] 19/9 [tt
7 adjourn [1] 72/10
THT TUM TANS I sara 68/10 28/13 29/1 29/6 29/8 I@dioun
TANT 74123 72/1 7216 TJanuany i) S11 [account [1] 55/2 administered [1] 12/4
2022 [4] 1/1 1/9 8/4 I7 January [1] 51/15 administering [4]
72/22 73/2 73/6 83/10 I 4493 7 January 2021 [2] accountancy [3] 45/11
83/16 83719852 loa ray srt 50/24 54/3 28/16 52/6 52/18 1.
88/21 accountant [1] 31/15 I2dministrations [1]
22 March [1] 20/18 [7 July [1] 1/43 4] 52/2 I 0/12
1 22,000 [1] 12/2 70 per cent [1] 11/23 Iaccountants [1] Bis dministratve [1]
+540 (Dong (233 million [2] 10/13 I72 [1] 32/13 accounting [1] 34/15
540 [1] 40/16 73 [1] 49/2 accounts [2] 10/19 I vt rot 46/3
1,659 [1] 11/24 2119 adopted [2]
24 [4] 32/14 75 years [1] 62/14 2601
1.07 pm [1] 89/22 25 July [3] 49/8 49/18 accurate [1] 28/20
4.30 [2] 72/9 72/25 y 8 achieve [1] 74/16 ADR [2] 75/7 78/19
it 50/2 oa W) advancing [1] 7/20
10 minutes [1] 49/13 266 [1] 7/5 84 [1] 60/16 achieved [2] 39/1 ig
10.30 [1] 1/2 ar dunett] 1/11. QT 89/20 advantageous [1]
100 percent 1] 1a fr umel] 11 9 acknowledged tt} I 27/18
400,000 [3] 61/6 61/8 I287 [1] 9 July [4] 1/14 60/2 vice it eat
61/24 95 per cent [1] 12/6 advice
44 January 2022 [1] P " acknowledges [1] I'o9/g 37/1 37/12 37/13
(24) MR BEER: - advice
INQ00001056
INQ00001056
A aims [1] 74/16 11/10 16/2 24/6 27/3 I 55/4 32/12 33/4 33/8 35/10
advice... [3] 459 albeit [1] 77/22 27/7 27/21 31/20 38/7 Ian exercise [1] 46/25 I 35/17 36/17 36/23
45/12 45/13 alert [1] 1/25 40/2 41/1 46/4 53/20 Ian existing [1] 21/40 I 40/4 41/4 41/3 43/2
advisory [4] 11/5 alerts [1] 49/11 59/24 60/7 71/12 74/7 Ian expert [2] 28/21 I 43/7 46/7 47/19 51/8
14/16 12/18 26/22 Aliant [1] 50/14 75/13 78/24 80/24 31/10 51/13 57/2 60/13
advocate [1] 83/7 Aliant Law [1] 50/11 I 81/7 82/3 86/18 88/3 Ian eyebrow [1] 75/1 I 60/18 61/16 62/8 67/4
advocates [1] 88/22 aligned [1] 46/2 88/13 an HSS [1] 42/16 67/6 67/16 69/21
Affairs [1] 20/18 all [66] 1/6 1/16 2/23 [alternative [3] 34/2 Ian important [1] 5/15] 72/13 76/8 77/22 79/8
affect [2] 77/13 85/19 3/15 4/10 5/6 5/7 8/10 I 51/14 78/16 an incentive [1] 43/9 I 81/23 82/22 83/12
affected [7] 3/16 4/11 12/10 12/12 13/11 although [5] 22/21 Ian independent [1] I 84/19 88/8 88/20
5/13 6/21 9/17 1914 I 17/4 19/2 19/4 20/8 I 53/21 56/10 55/18 51/14 89/10
30195 23/7 23/15 23/22 68/9 an indication [1] 57/8I anybody [2] 66/8
affects [1] 30/25 31/25 32/16 33/22 jalways [6] 6/18 56/11 Ian individual [4] 66/10
afford [3] 32/4 32/9 35/9 35/21 36/2 36/12 I 68/11 69/4 75/7 85/4 I 16/17 anyone [3] 2/5 4/12
62/7 36/25 37/14 37/17 jam [12] 1/2 8/15 an individual's [1] 83/8
37/25 39/23 40/1 40/6 I 15/18 24/2 48/21 28/21 anything [6] 41/5
affront [1] 2/23 wage
afraid [1] 80/12 41/6 42/21 51/21 52/5 I 49/21 55/12 67/6 an initial [1] 11/13 42/12 44/17 49/11
52/19 53/18 54/23 71/49 72/23 87/8 89/2 Ian interim [4] 18/2 I 61/15 64/5
team 55/11 57/25 58/16 Iamends [1] 74/9 47/1 64/16 71/8 anyway [1] 76/13
43/17 43/20 44/5 59/3 59/5 63/15 64/23 amenity [1] 29/18 {an internal [4] 45/21 Iapart [1] 1/6
44/12 57/9 58/23 65/5 70/2 72/10 72/22 Iamongst [2] 52/24 _Ian objective [1] 30/14/apologies [2] 82/22
61/19 63/1 64/16 73/16 74/5 78/8 78/17 I 74/6 an offer [6] 11/24 84/25
76/14 89/9 78/22 79/5 81/18 amount [3] 11/25 12/8 27/13 28/2 39/5 I apologise [1] 67/15
83/20 84/12 86/25 42/13 86/3 43/7 apologises [2] 11/2
again [11] 3/11 17/14
rN 44/18 87/18 87/25 88/6 amounts [1] 10/21 jan overall [1] 42/6 I 85/1
88/18 88/22 89/19 jan accurate [1] 28/20Ian update [1] 47/1 I appalling [1] 2/25
62/26 75/16 75/18 allays [1] 23/23 an action [1] 66/9 —_Ianalyse [1] 52/2 appeal [8] 49/4 49/7
agains 6} 20115: allegations [1] 65/13 Ian administrative [1] Iannounce [1] 89/5 I 49/11 50/2 50/3 64/23
34/19 49/7 71/20 alleged [1] 14/5 34/15 announced [2] 10/15 I 65/2 75/13
TTI Allen [6] 50/8 56/17 jan agreed [1] 59/14 I 20/17 appeals [3] 32/19
57/21 58/17 73/12 an alternative [1] announcement [1] 51/1 66/1
aorvated (4) 19/11 88/17 51/14 68/10 appear [6] 36/8 48/20
54/9 84/2 84/12 allocate [1] 20/22 an annulment [3] announcing [1] 3/9 I 55/13 58/19 80/14
aggressive [1] 63/17 allocated [2] 7/25 36/22 37/5 37/13 annual [2] 10/19 89/10
. 22/16 an applicant [5] 21/22 appears [1] 85/21
pena sone allow [3] 38/5 38/6 I 27/16.27/17 27/22 _Iannulled [2] 36/20 appellants [1] 49/6
9 80/25 31/21 33/24 38/16 appended [1] 37/4
allowed [5] 35/25 an area [1] 28/18 annulment [4] 36/22 Iapplicable [1] 19/10
agree [2] 33/14 97/7 Veo 73/7 7517 anasset[1] 35/1 I 37/5 37/13379 applicant [17] 27/16
agreed [10] 18/25
19/1 19/14 20/14 85/10 an assurance [1] another [6] 48/8 55/2 I 27/17 27/22 31/21
30/42 41/11 42/15 [allows [1] 21/20 60/24 62/23 68/21 77/4 33/15 33/16 33/17
45/3 59/14 59/24 almost [2] 43/25 an average [1] 12/1 I 79/20 33/21 33/24 40/1 40/8
agreeing [1] 7/10 54/23 an award [1] 35/8 — Ianswer [5] 35/21 42/4/ 40/11 40/17 42/11
agreement [9] 19/8 along [3] 42/21 68/7 Ian early [4] 57/5 4215 75/3 75/18 42/14 42/16 42/17
29/9 42/8 42/11 43/7 69/12 an email [3] 1/10 1/14Ianswers [1] 5/7 applicant's [2] 40/7
54/21 58/21 59/1 already [13] 3/7 9/18 I 50/23 anticipate [1] 50/1 40/12
87/25 16/23 17/5 20/25 an emergency [1] anticipated [1] 85/4 I applicant-friendly [1]
agreements [1] 42/4 26/25 27/8 28/23 21/24 any [53] 1/24 5/9 9/19} 42/14
ahead [1] 85/21 47/21 76/14 80/20 an entirely [1] 30/7 I 10/1 13/4 13/22 14/4 Iapplicants [14] 12/8
aim [4] 12/7 22/24 81/2 87/6 an essential [2] 6/7 I 16/11 16/20 17/19 12/12 13/11 13/19
also [30] 1/14 1/22 I 6/19 19/5 22/6 22/9 24/13 I 14/3 16/9 32/7 33/12
28/3 60/4 4/15 5/11 7/22 11/6 Ian established [1] 28/20 29/19 31/9 40/2 40/19 41/7 42/19
(25) advice... - applicants
INQ00001056
INQ00001056
A 56/15 assumptions [1] 11/1]badly [1] 64/4 47/11 47/12 47/12
Tanlinante 191 aajiqiatranged [2] 12/14 Iassurance [1] 60/24 Ibalance [1] 74/17 47/20 48/4 51/13
apencants.. [2 44/19)'5 3/00 attach [1] 21/24 Ibankrupt [7] 36/1 I 54/15 54/21 52/18
application [4] 13/14 arrangements [8] attempt [1] 37/5 36/11 37/17 38/21 53/5 53/10 54/12
Py 380 £7103 4/18 12/25 20/5 22/13 attempted [1] 44/7 I 39/1 53/2 61/20 54/17 54/17 58/1
applications [10] I 23/1828/20 38/12 attend [2] 38/14 49/9 Ibankruptey [23] 1/8 I §8/20 58/23 59/25
ooo uir7 14g I 7713 attention [3] 16/22 I 16/15 16/21 25/20 I 60/2 60/4 60/10 61/3
112 14103 140g attested [1] 44/4 I 36/3.41/23 34/12 34/14 34/19 I 61/9 61/23 69/18 71/8
15/2 28/12 4304 IAlticulating [1] 68/6 IAugust [2] 13/24 I 34/24 34/25 36/1 I 74/15 72/4 72115
applied a) 11118 (#8 (182) 47123 35/14 36/13 36/17 I 72/15 74/23 76/20
vros atin agin aside [2] 62/15 7512 I August 2020 [2] 36/20 37/6 38/1 38/10 I 76/23 80/18 81/3
53/6 72110 ask [20] 14/3 35/22 I 13/24 47/23 38/16 39/2 39/4 44/23 I 81/12 82/5 82/9 82/12
apply [7] 13124 3311 I 41/20 42/25 47/5 47/5 authorising [1] 63/13 I 6222 83/7 84/13 87/5 87/6 87/10
ey 37H13 e4/1p I 49/10.63/25 64/6 66/3 authority [1] 21/22 Ibarred [1] 33/4 87/13
734 7816 68/5 68/15 68/18 automatically [1] _Ibase [4] 51/4 Beer [2] 70/11 72/12
appointed (1) 11/8 I 70/18 71/2 72"2 79/19] 66/11 based [4] 18/2 36/18 Ibefore [20] 1/3 13/20
appointment [3] I 62/1884/15 84/17 autumn [2] 10/11 42113 60/22 13/25 24/1 38/5 38/7
pina tania s77—_(asked [5] 14/9 17/19 I 64/7 basis [16] 11/14 21/2 I 38/11 38/16 39/20
approach (6) 11/19 I 35/60/21 59/19 [availability [2] 26/18 I 24/10 21/12 21115 I 41/4 4317 60/14 6217
sir aiid 4s (Asking [1] 63/24 I 25125 21/23 27/20 28/20 I 62/18 68/19 70/14
69/15 34/4 aspects [1] 88/18 available [17] 6/20 I 33/4 45/1 50/21 64/19I 70/15 72/13 87/3
aspirational [1] 85/22) 9/1 18/13 20/16 28/22 I 64/21 85/14 87/5 I 89/11
approaching [3] 27/5
62/5 87/8
appropriate [7] 14/17
19/12 28/19 29/1 29/4
56/15 57/9
Appropriation [1]
21/22
approval [2] 10/12
21/23
approve [1] 17/19
approved [1] 11/15
approximately [1]
22/20
April [1] 51/3
April 2021 [4] 54/3
arbiter [2] 18/114 75/4
arbitration [3] 33/9
75/7 78/19
arcane [1] 21/19
are [137]
area [4] 28/18 28/18
54/2 81/24
areas [3] 25/22 43/12
43/13
argue [1] 74/11
argument [1] 74/13
arise [1] 66/16
arising [1] 57/3
around [6] 7/24 10/25
15/19 45/18 51/16
assert [1] 57/21
asserted [2] 47/12
4715
assertion [1] 50/22
assess [5] 4/5 17/24
33/14 41/2 56/2
assessed [2] 26/22
39/24
assessing [2] 28/19
46/18
assessment [11]
11/15 18/3 28/20
31/10 31/14 33/2 40/4
40/5 40/15 40/15 58/8
asset [1] 35/1
assist [17] 4/24 9/6
14/12 24/15 27/5 28/8
40/12 41/6 55/16
58/10 69/16 73/4
81/10 86/11 88/2 88/3
88/20
assistance [4] 25/5
28/7 53/5 53/15
assisted [2] 46/15
58/12
assisting [1] 21/5
associated [1] 26/4
assume [1] 17/18
assumption [2] 9/23
80/25
31/3 38/12 45/8 46/10
47/25 51/19 54/2 54/4
54/5 59/20 59/22 87/4
average [1] 12/1
avoid [4] 25/2 27/22
31/21 32/4
avoidance [2] 16/1
19/7
award [5] 28/9 28/19
28/24 35/7 35/8
awarded [1] 46/7
awards [4] 17/3 23/6
24/4 29/16
aware [12] 3/16 16/8
51/17 58/22 66/19
67/4 67/5 67/6 67/12
85/15 86/19 87/5
away [4] 4/10 8/8
78/2 79/5
awful [1] 62/15
B
back [18] 4/13 17/4
17/4 17/6 38/18 47/4
4T7IT 53/10 53/12 60/9
60/20 60/24 61/22
66/3 70/20 74/10
76/13 76/22
backdrop [1] 77/11
bad [1] 61/48
87/10
be [198]
be corrected [1] 50/5
became [2] 44/7 53/1
because [34] 1/24
2/23 16/3 16/4 21/7
31/2 32/4 34/24 38/2
44/8 46/3 46/5 49/11
54/14 55/17 59/10
60/19 64/2 65/12
66/16 67/1 67/13
67/14 73/16 74/17
74/20 75/14 76/5
79/25 85/22 87/4 88/5
88/24 89/20
become [1] 83/13
becomes [1] 45/25
becoming [1] 29/20
bed [1] 46/23
been [82] 1/5 1/23 3/4I 8/4 10/19 16/10 23/5
4/7 6/11 7/4 7/14 9/24
9/25 12/9 12/14 12/23
13/12 13/16 14/11
14/18 17/9 18/1 18/17
20/8 21/14 22/10
22/12 22/16 23/13
24/24 26/9 27/8 27/10
28/13 32/25 39/16
41/22 43/24 45/1
45/12 46/11 46/16
began [1] 70/11
begin [1] 35/23
behalf [8] 1/10 2/44
6/1 24/21 25/16 73/13
83/4 83/6
behaved [1] 80/13
behind [1] 55/23
being [30] 9/10 14/9
14/14 15/18 17/19
19/25 24/7 24/7 34/11
34/25 35/6 41/21
42/43 44/19 58/25
59/14 60/11 61/19
64/10 66/19 70/25
72/25 73/20 77/18
77/21 83/5 86/3 86/23
87/15 88/6
BEIS [35] 1/9 1/10
1/12 1/45 7/14 7/23
25/1 43/15 50/16
51/19 60/23 63/22
65/18 68/7 69/14
72/17 78/9 81/7 81/14
81/23 82/7 82/13
83/20 83/21 85/11
85/16 86/2 86/4 86/19
86/23 87/4
BEIS's [3] 7/23 10/1
11/16
(26) applicants... - BEIS's
INQ00001056
INQ00001056
B broken [1] 73/20 cancer [1] 62/21 I 48/25 49/2 49/24 50/7 I 79/14
aliave 17) 29/2 aajiaIProught [2] 16/21 cannot [3] 20/22 50/19 52/25 56/21 circumstances [11]
pea rai 18 3013 35/19 46/9 57/24 57/25 58/2 I 21/12 30/10 31/6
31/22 86/6 brunt [1] 78/22 capacity [2] 11/6 11/8] 58/14 58/16 59/3 I 31/10 32/8 40/24
. udget cardiac
believed {1} 10122 [budget [3] 10112 diac [1] 27/4 I 66126613 66/16 I 41/17 47/19 48/7
40/17 11/40 carefully [4] 5/9 I 67/23 68/17 75/5 I 62/23 66/2
believes [1] 14/8
ss budgets [1] 84/9 55/25 56/3 89/3 T7713 77/24 78/12 zens [1] 37/13
beapoke bt 208 built [1] 27/4 carries [1] 45/21 78/13 78/21 79/16 I Citizens Advice
ONS bulk [1] 55/18 case [19] 9/24 11/14 I 82/4 82/15 83/12 Bureau [1] 37/13
best [10] 10/17 35/2 bundle [4] 7/6 32/17 I 18/13 26/21 30/17 83/23 civil [2] 42/12 65/10
45/24 52/4 53/6 53/17 56/24 60/16 40/4 44/12 44/16 47/2 ICategory C [3] 77/22 Iclaim [28] 5/6 12/2
69/15 84/1 84/5 89/17 Bureau [1] 37/13 53/22 57/4 61/19 78/3 78/11 14/6 17/25 18/4 18/6
better [3] 8/17 32/7 Business [2] 2/15 68/20 70/4 73/22 76/9 I caught [1] 67/24 18/7 23/8 27/11 27/19
40/14 6/25 76/10 76/14 82/1 causation [1] 30/3 I 31/8 33/3 34/22 35/1
between [11] 5/18 businesses [1] 70/24 Icase-specific [1] 70/4/cause [2] 31/467/2 I 35/5 35/12 35/15
29/12 29/15 38/9 busy [1] 85/2 cases [34] 7/19 11/14I caused [8] 2/25 3/19 I 35/18 35/19 36/17
45/19 54/19 55/5 but [121] 12/6 12/20 17/9 17/11 I 26/3 30/5 32/24 36/13 I 38/9 38/17 38/18
55/14 57/6 58/1 77/24 I butt [5] 47/5 47/6 17/23 27/24 31/24 I 63/8 75/1 44/14 46/20 46/20
big [1] 29/23 63/24 63/25 77/12 — I 34/14 44/19 44/20 ICCRC [1] 65/6 70/24 78/14
bills [1] 3/20 butting [4] 2/3 55/8 I 44/25 45/6 47/25 cent [4] 11/23 12/6 claimant [4] 28/10
blighted [2] 62/8 55/8 87/14 50/15 51/20 53/7 12/8 52/25 29/2 55/1 74/4
78/24 by [123] 54/22 55/1 55/3 55/5 I central [2] 3/22 65/22IClaimants [73] 8/6
board [3] 5/2258/8 IC 56/6 59/5 60/3 61/25 Icertainly [5] 9/2 34/9 I 9/13 11/23 18/6 19/24
64/10 64/18 64/22 58/14 72/4 72/25 20/1 20/11 20/13
boty 2 31/1 37/20 [Calculate [1] 24/4 I 64/25 65/3 66/12 I challenge [2] 22/1 I 22/19 22/20 22/25
borne [1] 78/22 calculating [1] 23/5 I 66/13 71/3 4113 23/2 23/6 23/16 24/5
both [10] 7/17 10/19 call [1] 85/12 cash [1] 40/19 challenges [1] 46/12 I 25/19 26/1 26/3 28/6
23/14 24/9 55/1 64/1 (Called [4] 17/9 20/8 cash-strapped [1] _ Ichance [1] 13/8 35/25 42/22 44/22
7212 78/5 78/6 83/11 I 27 79/28 40/19 change [2] 41/14 77/8I 50/19 51/22 51/24
bother [1] 33/25 came [4] 21/11 70/14 Icatch [4] 69/4 changed [2] 75/24 I 53/4 53/8 53/21 54/6
bottom (4] 37721 I 70/1886 catches [1] 69/3 I 77/5 55/8 56/7 56/21 57/24
bound [2] 58/13 campaign [1] 69/19 categories [6] 9/9 — Ichanges [2] 80/6 80/9I 57/25 58/14 58/16
58/15 campaigning [1] 29/4 55/19 70/21 Ichanging [1] 80/14 I 60/19 61/18 62/20
box [1] 74/18 70/16 77/24 88/19 Chapman [8] 2/11 I 62/25 63/10 63/14
brain [1] 62/21 can [50] 1/183/11 [category [50] 16/1 I 2/13 15/20 38/22 60/2I 64/10 64/15 64/17
branch [1] 62/3 4/21 4124 6/6 7/5 8/14) 17/9 47/21 20/7 25/11 I 60/23 68/13 90/4 65/7 66/5 66/20 69/11
breach [1] 81/1 8/20 12/13 13/4 15/8 I 26/6 26/9 42/24 48/25Icharacter [1] 21/21 I 74/8 75/5 77/13 77/23
break [4] 1/18 24/19 16/14 18/6 18/9 23/11 I 49/2 49/24 50/7 50/19 Icharacterisation [1] I 77/25 78/4 78/5 78/6
49/22 85/9 24/16 28/9 29/7 30/21 I 52/24 52/25 54/9 55/7 I 80/21 78/11 78/13 78/14
breakdown [1] 42/6 38/25 40/1 40/2 40/17 I 56/21 57/24 57/25 Ichased [1] 60/20 —_I 78/21 79/16 81/22
41/4 43/1 43/14 53/8. I 58/2 58/14 58/16 59/3 Icheck [4] 1/5 82/4 82/8 82/10 82/15
Brewer han? 55/5 55/10 55/16 56/1 I 64/15 66/12 66/13 Ichildren [1] 63/5 I 83/14 83/23 85/20
56/2 61/18 63/10 66/16 67/6 67/23 68/8 Ichoice [1] 21/13 85/25 86/1 86/8
brits} u8/19 64/11 69/3916 I §8/12.68/17 68/21 Ichoose [2] 23/17 _IClaimants' [3] 18/22
briefly [5] 5/16 7/5 69/25 70/10 71/20 I 74/4 75/5 77/13 77/22 I 24/14 22/3 62/16
46/18 19120 49114. I 21 72/10.73/4 75/7 I 77/24 78/3 78/11 I choosing [3] 23/20 claimed [1] 13/5
Brightwell [3] 1/11 75/22 77/23 85/12 I 78/42 78/13 78/21 I 23/22 89/3 claims [37] 11/18
4/15 85/11 87/1 88/20 89/24 79/16 82/4 82/15 —_Ichose [1] 66/2 12/15 12/22 14/14
brings [1] 18/19 can't [7] 15/15 42/17 I 83/42 83/23 88/15 I chronology [2] 51/1 I 18/9 18/16 18/17
broad [f] 9/9 54/18 62/6 62/6 70/8 ICategory A [1] 25/11 I 70/12 18/20 18/25 19/8
broke [1] 79/1 70/17 Category B [34] 17/9 Icircle [1] 36/12 19/14 27/5 27/9 30/22
cancelled [1] 36/20 I 20/7 26/6 26/9 42/24 Icircumscribed [1] I 32/13 32/21 33/13
(27) believe - claims
INQ00001056
INQ00001056
Cc 82/20 88/7 7418 74/12 74/14 confirm [2] 49/17 23/15
claims... [20] 34/11 comes [3] 37/3 59/2 I 74/19 74/23 75/5 76/4I 49/19 contact [2] 35/16
39/3 39/17 39/17 78/7 77/2 77/12 77/16 78/7 Iconfirmation [2] 36/24
39/20 43/17 44/1 45/4 [Comfort [1] 61/1 78/10 79/15 79/18 14/24 38/8 contemplation [1]
52/23 52/24 58/3 coming [2] 34/10 69/7) 80/18 83/22 85/18 —_Iconfirmed [4] 35/4 I 65/18
60/14 63/10 63/16 commenced [1] 33/9 I 86/7 87/20 88/12 38/6 60/22 86/20 contemporaneous [1]
64/1 77/25 79/6 81/6 commended [1] 46/8 Icompensatory [1] confirming [1] 55/12 I 39/24
84/19 84/22 Commission [2] 54/10 confiscation [4] contends [1] 28/5
clarification [1] 50/15 64/18 64/22 complainants [1] TAA3 71/20 71/24 content [1] 36/23
clarifying [1] 82/19 commissioned [3] 65/1 76/4 contest [1] 66/1
clarity [2] 41/20 45/18 26/7 53/6 53/15 completed [1] 47/22 Iconfuse [1] 14/12 context [6] 4/12 25/4
Clarke [4] 50/11 commitment [1] completeness [1] connected [2] 29/19 I 51/19 55/7 70/7 81/25
Clarke Kiernan [1] 51/24 517 30/21 contingency [1] 11/1
50/11 commitments [1] 4/5 Icomplex [4] 14/14 {conscious [2] 27/21 Icontinue [9] 3/16 5/8
clause [1] 17/4 committed [1] 14/24 I 34/11 39/17 45/7 55/12 6/7 12/11 20/8 35/5
claw [4] 17/1 17/4 committee [4] 6/25 I complicating [1] consequence [2] 43/9 64/1 69/23
60/20 60/24 8/5 11/17 21/19 52/22 12/24 89/4 continued [1] 74/22
claw-back [4] 17/1 common [1] 70/3 complication [1] consequences [1] [continues [7] 8/11
17/4 60/20 60/24 communicating [1] I 66/18 37 18/21 24/14 33/11
clawed [1] 17/6 82/10 comprising [1] 26/23 Iconsequential [12] 36/14 62/12 74/25
clawing [1] 60/9 communication [1] [concentrated [1] 42/22 13/2 13/3 14/7 Icontinuing [4] 16/12
cleaner [1] 62/13 82/23 54/21 14/10 29/19 29/24 21/21 43/23 60/12
clear [14] 4/21 7/3 communications [2] Iconcern [9] 4/15 30/3 32/22 33/3 47/25 I contract [2] 54/5 81/1
3/14 8/17 14/9 20/20 I 81/13 82/11 27/24 31/12 31/24 54/1 contracted [1] 30/20
21/4 23/11 24/2 32/16 [Communities [1] 3/2 I 32/6 42/2 44/21 55/15 I consider [9] 22/21 I contractual [3] 78/2
56/16 59/9 66/17 ICOMPany [2] 5/25 6/2) 86/23 34/2 35/2 40/12 42/20 I 79/9 79/14
841/14 compelling [1] 6/11 Iconcerned [6] 28/4 I 54/17 57/6 57/9 80/17 Icontrary [1] 32/2
clearly [4] 69/2 70/1 compensate [1] 39/14 39/15 45/17 I considerable [3] contrast [1] 29/14
77/6 88/23 69/15 59/10 60/3 24/17 29/3 30/4 contributing [2]
client [2] 44/3 48/8 compensated [4] concerning [2] 16/9 Iconsideration [8] 40/20 11/2
clients [13] 43/6 51/8 3/24 5/5 20/6 64/10 I 48/3 30/2 36/9 40/7 40/13 Iconvenient [1] 64/8
54/19 56/12 57/15 compensates [1] concerns [10] 14/13 I 40/18 47/18 79/9 convicted [17] 16/3
58/7 58/9 59/11 60/8. I 9/21 23/24 25/13 25/15 82/14 52/9 62/1 62/17 65/12
62/23 76/3 83/12 compensating [1] 26/2 26/17 34/5 43/4 Iconsiderations [1] I 65/13 66/8 66/8 66/10
83/13. 67 ; 46/23 87/6 36/3 66/11 66/15 66/22
clock [1] 72/7 compensation [82] _Iconcession [2] 60/18] considered [11] 6/11 I 66/25 67/21 68/9
close [4] 43/17 43/22 2/3 4/2 4/10 4/18 4/22 I 68/16 9/10 12/15 18/7 18/9 I 71/21 76/8
47/8 84/15 5/2 7/15 7/21 8/2 8/5 Iconclude [3] 70/5 I 21/11 29/10 40/8 48/5 conviction [4] 49/7
closed [4] 39/7 39/7 8/11 8/21 8/25 9/9 7219 84/24 48/7 87/18 71/9 71/23 76/4
39/8 43/24 9/11 9/12 9/19 9/25 Iconcluded [1] 89/23 Iconsidering [5] 14/25Iconvictions [16] 9/12
closely [1] 46/2 11/25 12/12 15/25 Iconcludes [1] 85/3 I 19/24 44/22 70/18 16/1 17/9 19/22 26/8
closing [1] 47/24 16/25 17/22 17/25 _ I conclusion [6] 21/11 I 79/15 49/1 49/4 49/15 52/10
clue [1] 31/13 18/7 19/19 19/23 20/4 I 24/1 24/12 84/4 88/5 Iconsiders [3] 10/24 I 64/17 64/20 66/6 74/6
co [8] 1/12 1/13 25/1 20/10 20/13 20/15 88/7 27/14 28/2 76/6 76/20 78/24
35/20 50/7 62/22 20/21 21/7 21/25 22/4 Iconclusions [3] 3/13 Iconsistency [2] 11/11/copy [2] 40/1 40/3
72/15 88/16 22/7 22/22 22/25 23/6 I 5/9 64/12 11/19 core [28] 1/6 1/17 2/1
co-operate [1] 35/20 23/9 23/18 23/20 24/4 IConcordat [1] 21/20 Iconstituted [1] 11/5 I 4/16 5/12 9/5 12/21
collapse [1] 70/25 34/23 35/6 35/7 35/11 Icondition [2] 30/20 Iconstraints [2] 5/3 I 19/8 19/21 24/22 26/8
college [1] 28/25 35/20 38/17 45/4 47/9 I 30/24 5/15 42/23 53/19 56/24
come [8] 39/18 39/20 48/25 51/22 52/9 conducting [1] 82/7 Iconsult [1] 23/13 57/16 58/2 62/22
47/3 47/4 47/7 66/11 53/16 62/19 64/7 65/9 I confidential [2] 54/14] consultant [1] 30/25 I 69/17 69/24 70/15
69/2 69/11 70/12 71/2 I 54/15 consultation [1] 70/17 72/16 74/5
(28) claims... - core
INQ00001056
INQ00001056
Cc 61/16 35/10 39/16 55/3 56/5I 3/15 4/9 4/19 5/1 5/17 Idialogue [2] 51/13
core 15) 74/18 77/14Icovered [1] 22/15 56/7 73/13 5/19 5/22 5/24 6/4 54/17
ee Oe ma CPs [3] 56/22 57/24 I dealings [1] 59/4 6/18 7/7 8/10 8/15 did [12] 11/6 13/24
Core Participants 58/22 dealt [7] 30/1 39/6 I 8/16 9/15 10/10 10/22 I 14/2 15/9 17/15 20/17
[18] 19/8 19/21 24/22 create [2] 21/14 30/7 I 39/20 44/19 81/6 10/24 12/3 12/7 12/20 I 22/7 31/2 61/15 63/2
53/19 57/16 58/2 creates [1] 43/8 86/25 87/7 13/1 14/8 14/12 14/15 I 65/8 82/20
62/22 69/17 69/24 —-I creation [1] 11/14 debt [2] 61/4 61/6 14/18 14/23 14/25 didn't [1] 76/16
70/15 70/17 72/16 Icreditors [2] 37/25 I debts [9] 36/17 37/22) 16/8 16/13 16/18 17/3 Idie [1] 62/18
74/5 74/18 77/44 38/8 37/25 38/2 38/9 38/11I 17/6 18/8 18/10 18/21 Idied [4] 62/16
criminal [6] 49/5 38/15 61/7 61/10 19/3 19/7 19/12 19/24 I differ [1] 46/19
TOT 83/4 B36 eti1964/18.64/22 (decades [2] 413 I 20/22 24/9 21/17 22H difference [2] 29/23
correct [3] 13/18 14/1
15/6 65/25 73/18 70/20 22/7 22/21 23/1 23/12 I 29/24
corrected [1] 50/5 crippling [1] 61/6 December [1] 68/10 I 23/23 24/12 53/13 differences [1] 34/13
correctly [1] 83/10 critical [1] 13/23 December 2021 [1] I 81/13 different [5] 6/12
correspondence [5] Crown [6] 49/5 64/19 I 68/10 Department's [8] 17/11 48/11 55/11
4/4 50/20 52/24 64/23 64/24 65/21 decency [1] 2/23 3/22 4/21 8/18 8/24 I 88/18
85/15 86/20 71/20 decide [2] 5/23 40/23 I 12/10 15/13 20/19 difficult [6] 17/24
cost [2] 6/8 10/18 current [2] 40/24 79/2Idecided [2] 59/14 21/3 20/2 37/1 37/6 55/21
costs [8] 13/8 14/20 currently [1] 77/15 I 65/2 departmental [1] 84/9] 84/10
cut [1] 23/19 decision [14] 4/19 Idescribed [1] 61/5 [difficulties [1] 60/2
22/19 38/1 43/19
44/24 44/25 61/12 ID
could [16] 8/179/25 Isanacs te dao
40/7 10/13 30/4 30/7 damage a
32/17 34/5 43/1 43/2 I sarag ga/t7
7G 11/12 14/20 15/7 Ideserve [4] 62/25 difficulty [2] 44/20
45/17 18/12 25/23 I 74/24 79/16 79/17 I 46/24
30/13 30/14 43/12 Idesign [1] 7/45 dignity [1] 74/4
51/2 56/3 82/17 designed [1] 27/15 Idiminished [1] 30/7
decision-making [2] Idesirable [1] 28/18 I directed [2] 32/7
ea core at damaged [1] 3/1 I 7/16 1112 desire [3] 7/20 76/25 I 80/19
couldn't [1] 32/9 damages [28] 19/6 decisions [4] 7/11 84/15 direction [1] 8/1
19/10 19/12 28/19 I 46/2 46/16 46/19 —_Idesks [1] 75/2 directly [4] 14/4
couse Fare 28/25 29/1 29/4 29/23 Ideed [2] 78/3 79/5 _Idesperately [1] 74/24] 79/19 79/23 84/25
31/15 31/18 35/24 defence [2] 32/12 _Idespite [1] 25/15 _I disappointing [1]
countenance MM I 36/4 36/7 36/7 51/25 I 34/3 destroyed [2] 629 I 80/2
countenanced [1] 53/9 54/2 54/4 54/9 defences [1] 33/8 I 75/10 disbursements [1]
4125 54/10 54/10 54/11 defend [3] 8/15 65/16 Idetail [4] 54/18 67/14 I 52/16
courage [2] 75/11 I 96/158719 58/8 5917 I g/g 67/16 71/4 disclosure [4] 1677
78/25 84/2 84/13 define [1] 57/13 details [3] 16/18 35/6 I 16/9 60/3 87/2
danger [1] 45/25 —_I deflect [1] 80/10 62/19 discovered [1] 44/6
course [26] 3/11 3/14
og 8724 1215 134 IAark tH Jaa 3403
18/4 1816 2315 25/6 I oa 4016 85103
40/8 46/4 50/1 54/9 late [14] 4/13 17/11
57/2 60/17 67/11 77/3 I sarag 3a/17 34/20
78/13 79/2 79/20 I 38/9 38/10 47/24
80/23 83/1 83/23 84/8 I 49/13 87/03 Balt
degree [1] 26/25 determination [3] discovery [1] 60/4
delay [3] 9/19 44/22 I 15/11 65/2 65/22 discussed [1] 86/24
70/11 determine [2] 56/20 Idiscussion [5] 14/18
delays [6] 9/16 9/21 I 57/23 15/13 85/12 85/22
11/3 11/20 81/3 88/7 Idetermined [1] 15/3 I 86/14
delicate [3] 55/17 determines [1] 39/19 Idiscussions [8] 15/1
88/15 82/25 83/1 devastating [1] 73/14) 15/16 51/15 54/15
court [15] 37/15 49/4 dated [4] 1/8 1/13 I deliver [4] 4/11 10/23 Idevastation [3] 3/1 I 55/13 69/14 87/12
49/5 49/11 5012 64/19 I 14 18/15 20/21 79/21 3/19 73/25 87/14
64/23 64/23 64/24 (22 16] 3/1744/10 I delivered [3] 4/8 7/21 Ideveloped [4] 23/4 I disgorgement [1]
65/8 65/21 65/21 48/21 72/10 87/22 I 87/21 26/13 69/7 83/14 76/2
71120 75/13 76125 I 208 delivers [1] 8/20 Idevelopments [2] _Idismissed [2] 34/8
courts [2] 56/10 days [2] 38/7 60/1 delivery [1] 19/16 I 47/8 59/25 44/9
65/10 deal [6] 16/7 33/3 —_I demonstrate [1] 77/5 Idevelops [1] 31/1 _Idispute [11] 14/15
cover [3] 10/13 10/17 53/6 54/12 66/6 88/10 I department [57] 2/15 Idiagnosed [2] 30/20 I 33/10 34/2 34/8 41/12
dealing [7] 31/17 =I 2462/17 3/73/11_—_I 30/24 42/4 43/2 43/9 43/19
(29) core... - dispute
INQ00001056
INQ00001056
D Donkin [1] 50/12 elements [1] 18/25 Ientered [1] 65/5 27/12 27/18 28/1 28/4
dispute...[2] 45/8 doormats [1] 3/21 _ Ieligible [3] 11/23 18/4)entire [1] 2/20 28/10 28/22 29/8 30/1
45/14 doubt [8] 3/18 16/1 I 32/21 entirely [4] 15/18 30/13 31/3 34/25
distinct [2] 17/24 19/7 69/1 78/14 78/17 \elucidate [1] 77/6 30/7 47/3 55/10 39/24 40/2 40/14
77/25 78/25 84/9 email [4] 1/10 1/14 entitled [4] 8/14 51/23) 44/12 59/6 65/3 73/23
down [2] 17/22 51/2 I 50/23 72/19 63/14 79/7 74/2 75/25 77/8 7/9
distinction [4] 77/23
distorted [1] 30/7
distortion [1] 20/23
distress [5] 3/24
27/23 31/22 35/12
43/23
distribute [2] 23/4
24/8
distributed [3] 1/24
22/19 72/18
distribution [2] 86/2
86/21
Division [1] 49/5
do [27] 1/25 5/1 24/19
36/24 37/5 37/11
37/14 41/4 42/4 42/25
43/16 47/5 49/9 57/13
69/16 72/22 73/22
73/24 74/17 77/16
78/20 80/14 81/9 87/4
88/13 89/17 89/21
document [2] 2/6
37/10
documentary [1]
73/7
documents [4] 1/16
1/19 16/9 40/2
does [8] 4/9 5/6 13/15
15/19 22/21 45/3 73/3
85/23
doesn't [2] 2/5 83/16
dog [1] 62/13
doing [3] 8/19 75/20
75/22
dominant [1] 31/4
don't [24] 1/24 9/2
13/15 17/18 28/6
28/15 38/8 47/5 48/2
55/21 55/22 56/23
59/2 59/12 62/24 64/4
66/11 67/1 71/19 75/6
75/16 79/18 81/20
83/9
done [8] 8/17 10/25
22/10 32/4 43/15
63/21 87/4 87/14
drafted [1] 58/20
drag [1] 62/24
dramatically [1] 29/8
draw [1] 32/23
drawn [1] 41/22
driver [1] 9/21
due [5] 3/14 17/23
17/25 67/11 76/24
duration [1] 29/9
during [7] 4/16 13/17
23/24 34/8 36/3 43/22
64/7
duty [1] 73/19
dwell [1] 62/19
dwelling [1] 5/15
Dyson [13] 19/14
56/19 57/3 57/10
57/11 57/22 58/6
58/13 58/15 58/19
§8/22 59/20 82/21
E
each [13] 23/6 25/9
26/7 33/3 33/15 50/9
50/13 52/3 53/20
69/22 69/23 70/21
79/10
earlier [1] 34/8
early [8] 16/16 19/13
19/17 48/2 56/13
56/20 57/5 57/22
earning [1] 62/7
earnings [5] 13/6
18/25 29/21 30/4 62/8
ears [1] 80/9
ease [1] 40/23
easier [1] 55/21
easy [1] 12/16
effect [4] 65/9 71/24
71/24 73/20
effectively [1] 6/22
effects [1] 54/7
efforts [1] 16/11
eight [1] 8/4
either [6] 16/3 47/1
49/4 62/5 87/14 88/8
emails [1] 1/22
emerge [1] 3/18
emergency [1] 21/21
emphasis [1] 36/6
emphasise [1] 20/1
emphasises [2] 16/22I
18/10
employ [2] 37/11
74125
employed [1] 61/20
empowered [2] 79/16
80/17
enable [4] 19/18
21/40 30/13 40/11
enabled [1] 73/23
enables [1] 27/17
enclosed [1] 36/21
encourage [2] 18/8
18/21
encouraging [2]
16/10 48/21
end [11] 1/7 12/6 12/8
12/12 29/14 55/5 61/2
84/20 85/24 87/8
88/24
endorse [1] 82/6
endured [2] 36/12
36/14
enduring [2] 26/11
63/2
Energy [2] 2/15 6/25
engaged [2] 23/1 52/2I
engagement [1] 8/19
engaging [2] 9/4 41/3
enjoy [1] 63/1
enormous [1] 40/19
enough [3] 37/25
59/41 62/10
Enright [1] 85/11
ensure [16] 6/6 6/21
TIA9 8/13 8/20 11/41
11/19 15/3 16/24
19/17 20/6 37/14
51/21 74/14 81/5 84/5
ensuring [2] 5/5 32/7
entails [1] 37/18
entitlement [2] 22/6
2219
entity [2] 5/18 73/16
equally [1] 48/22
errors [2] 34/24 36/19)
especially [2] 5/12
34/9
essence [1] 28/3
essential [5] 3/9 6/7
6/19 9/17 65/23
essentially [5] 2/20
29/13 36/6 57/14
62/25
establish [2] 3/6 53/6
established [5] 31/3
53/21 53/22 55/4
77/22
establishing [1]
11/13
establishment [2]
10/3 21/16
estate [2] 34/24 35/14)
estimate [1] 10/18
estimated [2] 10/16
70/9
evaluation [11] 19/13
19/17 56/14 56/20
57/5 57/23 58/6 58/13
58/15 59/19 59/21
evaluator [4] 19/15
57/7 57/8 59/14
even [5] 29/24 42/25
49/9 58/22 74/22
event [2] 58/23 77/22
eventually [1] 10/13
ever [2] 3/11 50/18
every [5] 26/21 68/21
70/20 70/20 79/10
everybody [4] 1/19
47/6 83/2 89/21
everyone [2] 73/8
84/8
everything [2] 8/16
63/21
evidence [27] 25/19
26/1 26/20 27/10
87/7
ex [2] 18/4 19/23
Exactly [2] 83/15
83/18
examine [1] 4/18
examining [1] 46/16
example [3] 30/16
37/12 38/13
examples [3] 13/5
25/8 29/11
except [2] 68/6 79/6
exceptional [3] 21/23
47/18 48/7
excess [1] 61/8
excluded [3] 43/23
59/8 82/5
exemplary [5] 19/12
54/2 54/3 84/2 84/13
exercise [1] 46/25
exercised [1] 6/1
exist [1] 67/12
existed [1] 21/12
existing [1] 21/10
exists [1] 2/24
expect [1] 89/13
expectation [1] 89/7
expected [2] 15/8
39/5
expecting [1] 15/2
expects [2] 14/20
15/14
expedition [1] 63/9
expended [1] 61/16
expenditure [1] 21/20
experience [4] 30/16
32/2 39/3 45/2
experienced [4] 3/25
14/4 31/18 53/25
experiences [3]
26/12 54/6 63/4
expert [15] 25/19
25/25 26/20 27/11
27/18 28/3 28/6 28/21
30/4 31/10 34/16
48/10 52/2 53/5 53/15
expertise [3] 27/1
(80) dispute... - expertise
INQ00001056
INQ00001056
E fair [25] 4/10 7/21 fighting [1] 74/18 fits [1] 88/14 86/2 86/4 86/7 86/19
expertise... [2] 28/5 8/21 9/12 9/19 12/11 I figure [2] 10/16 83/21 Ifive [8] 49/6 50/3 friendly [1] 42/14
= 15/4 16/24 18/23 figures [2] 46/9 46/12I 52/25 67/9 67/17 73/5 Ifriends [1] 63/5
experts [2] 12/18 19/18 20/10 22/22 final [21] 7/139/11 I 73/8 87/8 from [67] 1/7 1/9 1/12
28/12 27/14 28/2 45/4 51/22 I 17/2 17/22 18/11 five minutes [1] 73/8 I 1/42 1/43 1/45 1/20
expiry [1] 33/4 69/11 71/3 74/14 18/14 20/10 21/8 fixed [1] 50/25 2/3 3/18 4/10 10/24
explain [3] 38/15 TAI19 77/2 77/16 22/22 22/25 23/5 23/9 Iflat [1] 76/9 16/17 17/4 18/18
48/23 60/8 79/17 80/18 84/7 23/18 23/19 24/4 flippant [1] 28/15 24/25 25/6 26/4 26/14
explained [4] 6/24 fairly [7] 3/24 5/5 6/22I 48/25 52/8 69/2 69/11 Iflow [1] 26/4 27/19 30/16 30/18
20/25 37/19 49/15 20/6 32/25 69/15 75/4 88/8 flower [4] 68/1 30/19 31/9 31/18
explains [1] 39/25 87/24 finalised [2] 80/25 focus [1] 9/3 33/16 34/20 37/12
fairness [7] 27/20 84/13 focused [1] 70/5 37/24 38/8 38/13 39/3
explanation [1] 40/22
exploration [1] 21/17
explore [1] 30/5
explored [1] 5/19
express [1] 5/10
28/9 30/11 30/13 31/9 Ifinally [9] 14/22 19/20Ifocusing [1] 8/2 43/15 43/24 46/19
38/20 38/25 23/7 25/23 39/2 45/16 I follow [1] 42/10 50/23 50/23 51/18
faith [5] 18/5 47/11 I 47/10 66/5 70/5 followed [1] 37/16 I 53/48 57/3 59/2 60/13
47/15 48/1 48/8 financial [8] 3/24 following [3] 5/11 61/15 63/11 63/18
fall 3] 67/1675 I 36/13 39/11 40/20 I 26/12 28/11 63/24 70/22 72/15
expressed [2] 23/24 I art2 42/18 5213 6012 force [1] 20/24 73/13 73/17 73122
expression [1] 14/10 [fallout [1] 7313 I 62/10 forensic [3] 26/23 I 76/3 76/7 76/16 78/7
expressly (21/8. {falls (21 6/17 6822 financing [1] 1378 I 2e/t6 34/15 79/3 79/11 79/18 81/7
pias familiar [1] 46/1 find [7] 20/21 24/9 Iforeseeability [1] I 81/12 82/5 82/6 82/11
extended [1] 68/16 {families [3] 53/19 I 37/14 50/11 748 8072] 15 82/21 82/21 85/11
extent [5] 116.209 I 54/7 622 80/4 forget [1] 70/17 I 85/16 87/25
ee set serie. {family [3] 63/5 76/10 Ifinding [2] 6319 forgive [5] 25/12 front [2] 13/13 72/7
extra [1] 40021 76/13 80/22 25/21 27/6 2822 —_Ifruit [1] 39/16
extraordinary (1] "2° [15] 28.818 98 findings 4] e4rt3 I 62/12 fulfil [1] 6/4
a 15/7 28/3 33/6 39/14 [fine [8] 210 15/23 Iform [7] 6/14 13/14 [fulfils (1) 7/3
extremely [2] 812 I39/1644/14 45/3 I 24/17 33724 a8/24 I 14/2 14714 26/3 48/4 [ful [19] 8120 16724
MD 46/16 54/17 60/3 I 69/9 72/7 85/2 48/6 17/25 18/3 18/7 18/16
eye 2) 4718 srit2 I 83724 60/19 finely [1] 31/17 [formal [2] 15/2 15/15 I 21/8 37/22 38/1 38/3
eyetrow [1] 75/1 fashion [2] 87/24 886finely-tuned [1] 31/17 formally [1] 50°21 I 98/11 38/8 45/4 7172
fault [1] 3/6 finish (1] 73/7 forms [2] 34/2 34/23 I 77/2 77/16 79117
F faulty [1] 73/17 finished [1] 72/25 [forward [6] 3/13 I 80/17 84/7
face [1] 3524 ‘(fears [1] 4315 finite [1] 84/20 44/13 24/13 35/3 47/4 [fully [10] 3/12 3128
faced [2} 22/1 44/22 feature [2] 62/22 [firm [4] 22/2 23121 I 60/6 5/5 6/22 20/6 35/20
facilitate [1] 58/7 I 61/25 64/11 81/24 fought [3] 65/15 I 40/17 56/4 80/17
facing (2) 22/23 42I20IFebruary [1] 10/14 [firming [1] 85/23 I 75/12 75115 Btit7
fact [15] 1/25 4/10. IFebruary 2021 [1] firms [3] 1/15 63/22 Ifound [2] 65/5 78/9 fund [4] 10/7 11/10
4016 13/23 30/1 32/20I 10/14 69/13 foundation [1] 59/15 I 21/10 78/10
36/9 43/15 52/23 (feeding [1] 81/16 [first (24) 2/17 4/23 Ifour [4] 50/10 funded [1] 22/2
55/1964/11 67/4 (feel [2] 3/1689/19 I 9/10 12/15 13/18 I fourth [2] 25/20 37/10Ifunding [14] 7/10
ba/t0 83/21 88/4 [feeling [1] 44/18 I 13/19 16/7 22/12 framed [1] 4/3 40/1 10/14 11/21
factor [1] 5224 {fees [4] 19/9.23/8 I 22113.23/1225/ I framework [1] 96/7 I 12/24 14/17 1518
facts [3] 3/6 17/24 I 82/11 52/16 34/18 35/23 36/11 Ifraud [2} 80/22 81/6 I 21/15 37/8 51/19
49/14 Felstead [1] 76/10 I 36/25 37/20 30/8 free [2] 40/8 8919 II 52/12
fail [3] 77/18 78/18 {felt [1] 44/13 44/11 53/14 55/9 IFreehills (5] 40/4 funds [3] 45/8 60/11
78100 few [8] 14/21 15/9 I 72/22 82/5 86/4 89/2 I 45/23 46/2 56/19 I 61/16
failed {2} 70/14 7717 I 15/10 22/12 30/6 firstly [9] 25/18 26/25] 59/13 further [25] 1/5 4/9
failing [1] 31/0 86/1286/16.87/9 I 26/21 28/1241/16 I Freeths [15] 23/1 I 11/7 18/16 18/18 20/4
failings [3] 30/6 75/24Ifictional [1] 76/6 I 43/12.43/16.43/21 I 23/3 23/17 23/21 I 20113 21/25 2216 2219
7719 fifth [4] 25/22 54/21 23/25 24/3 81/15 I 25/23 27/11 43/12
Failure [1] 30/5 fight [2] 75/17 77/17 Ifit [4] 88/17 81/19 82/4 82/11 86/1 I 45/15 49/6 50/3 51/13
(31) expertise... - further
INQ00001056
INQ00001056
F
further... [8] 51/15
56/16 59/12 60/15
66/18 79/8 85/8 88/20
future [5] 3/17 8/20
17/4 43/2 87/23
G
Gallifant [7] 26/19
31/21 32/11 39/5
52/20 54/3 60/22
gave [3] 31/4 74/1
76/11
geared [1] 63/19
general [4] 25/2 25/4
54/10 58/5
generally [2] 4/23
27/5
generic [2] 27/4 28/7
generously [1] 81/6
gentlemen [1] 89/15
genuine [2] 8/18 68/3
genuinely [1] 61/17
get [6] 37/12 54/12
55/16 63/14 74/23
75/19
gets [1] 83/2
getting [2] 53/9 86/15
give [8] 19/23 20/15
24/14 29/11 57/8
60/18 74/9 76/22
given [11] 25/15
33/12 35/24 37/15
41/13 42/17 62/3 81/2
82/10 82/15 88/6
gives [1] 13/5
giving [1] 82/14
glad [1] 85/2
GLO [52] 8/6 9/13
16/2 19/24 20/1 20/11
20/13 20/17 21/7
21/25 22/2 22/19
22/25 23/2 23/6 23/7
23/16 24/5 42/22 62/1
65/15 65/18 66/20
66/22 66/23 66/24
67/1 67/2 67/5 67/7
67/20 67/25 68/8 69/5
69/6 69/11 69/16
69/18 69/18 69/20
69/22 70/13 74/8
81/22 82/8 82/10
83/14 85/20 85/25
86/1 86/8 86/22
GLO Claimants [13]
9/13 19/24 20/1 20/11
20/13 23/16 74/8
81/22 83/14 85/20
85/25 86/1 86/8
GLO Litigation [1]
65/15
global [1] 43/7
go [5] 7/5 41/1 54/18
54/25 66/3
goal [3] 5/4 8/19
12/10
goes [4] 22/22 33/6
52/17 53/7
going [13] 2/7 14/13
35/25 47/25 49/10
49/13 55/23 56/2 68/7
72/8 72/23 87/12
89/20
golden [1] 73/18
gone [3] 54/13 61/10
63/18
good [20] 2/10 3/1
3/19 5/21 11/22 18/5
33/6 33/22 47/11
47/15 48/1 48/8 59/7
62/10 63/4 73/9 81/8
81/10 88/5 88/23
got [6] 8/16 24/9
68/12 68/20 79/19
83/19
government [8] 2/24
3/5 4/3 6/2 6/10 6/13
7/9 11/24
Government's [5]
6/24 7/8 7/20 19/22
20/11
government-owned
[1] 2/24
grandchildren [1]
63/5
grateful [5] 16/20
22/8 69/10 70/9 82/19
gratia [2] 18/4 19/23
great [4] 25/10 54/12
54/18 75/25
greater [4] 14/15 17/2
36/6 45/18
greatly [1] 2/8
ground [3] 17/10
48/12 75/14
grounds [3] 17/12
17/16 50/2
group [16] 7/16 8/3
10/2 20/3 20/7 21/25
22/14 22/18 23/2 23/7
62/2 66/12 79/1 79/12
84/20 86/3
guarantee [1] 38/13
guesswork [1] 28/18
guidance [9] 13/2
13/41 13/18 13/25
37/3 37/3 37/9 47/24
57/3
guidelines [1] 28/24
guilt [2] 65/24 73/20
guilty [3] 65/4 65/5
65/13
H
had [42] 1/22 9/22
9/24 11/8 11/24 14/3
17/5 17/9 18/15 22/2
22/3 22/5 22/7 30/18
30/20 30/23 41/11
47/20 48/4 49/3 50/20
52/5 52/9 52/10 58/23
60/20 63/7 64/17 65/7
65/24 65/25 66/6
70/23 71/8 74/6 76/14
76/15 76/17 78/24
82/5 82/9 85/16
hadn't [4] 13/16
Hamilton [2] 51/2
62/11
hand [2] 84/6 84/7
handed [1] 51/2
hands [4] 7/2 26/12
63/7 72/8
hands-on [1] 7/2
hanging [2] 15/19
39/15
happen [1] 3/11
happened [3] 3/3
15/17 34/25
happening [2] 48/12
49/12
happens [1] 63/18
happy [4] 60/4 60/21
73/8 81/18
harassment [1] 13/10
hard [3] 31/8 83/2
84/22
Harding [1] 50/12
hardship [5] 3/25
22/23 41/17 41/18
60/12
hardships [1] 42/19
hardworking [1]
73/15
harm [3] 26/3 30/2
30/5
harms [1] 70/4
has [75] 1/5 1/19 2/17
2/25 3/7 4/11 4/15
6/18 6/18 7/1 7/7 7/9
7/14 7/24 8/1 8/10
8/24 12/5 12/7 12/9
12/14 12/20 13/12
14/12 14/18 14/25
17/3 17/5 20/8 22/15
23/4 23/12 27/3 27/10
27/25 28/7 28/13 32/4
32/11 33/21 35/2 35/4
38/22 39/16 41/22
43/3 43/24 45/10
45/12 46/11 51/15
53/5 53/25 54/12
54/13 54/17 58/1
60/12 62/21 71/24
72/15 72/19 75/23
76/20 76/21 76/23
77/7 78/9 80/13 80/18
81/1 81/12 83/21
84/25 86/19
hasn't [1] 74/15
hate [1] 89/16
have [179]
haven't [2] 61/21
67/16
having [6] 8/22 22/10
40/8 59/13 87/5 87/18
havoc [1] 53/2
he [10] 35/5 44/6 44/7
44/8 44/11 51/5 68/10
85/1 85/4 85/4
he's [1] 85/2
head [9] 47/17 55/10
55/11 68/19 84/3 84/4
84/10 84/12 84/17
heading [3] 2/2 7/8
20/10
headings [2] 9/8
15/25
heads [16] 19/2 41/13
42/7 43/10 46/13
46/20 47/12 48/4 48/5
48/6 54/23 54/25
54/25 59/8 74/13 78/4
health [13] 26/4 27/4
27/25 28/4 28/8 28/14
28/17 28/21 29/5 30/6
31/24 35/11 70/25
hear [5] 1/3 16/13
26/10 72/10 81/8
heard [12] 12/15
12/20 24/25 25/3
43/13 43/15 43/22
44/16 51/1 75/23 77/3
89/4
hearing [9] 7/6 38/5
38/7 38/11 38/14
44/12 59/17 89/2
89/23
hearings [12] 4/17
4/20 4/22 5/11 12/5
12/22 23/24 43/23
60/1 64/8 70/11 74/2
hearsay [1] 73/17
heart [2] 63/20 74/3
heart-breaking [1]
74I3
held [3] 14/25 15/13
16/10
help [10] 3/20 21/18
23/5 25/8 38/21 42/20
56/20 57/23 69/25
82/16
helped [1] 42/22
helpful [2] 37/14
82/22
helping [1] 22/23
Henry [1] 84/25
her [10] 44/4 44/16
62/13 76/9 76/10
76/12 76/13 76/14
76/15 76/16
Herbert [6] 40/4
45/22 46/1 56/18
57/21 59/13
Herbert Smith [1]
57/21
Herbert Smith
Freehills [1] 59/13
here [9] 8/15 10/15
15/21 21/1 23/11
(2) further... -here
INQ00001056
INQ00001056
H
here... [4] 62/11 74/8
81/13 85/1
hesitate [1] 36/24
hid [1] 73/23
hide [1] 34/20
high [4] 45/2
higher [1] 11/9
highlighted [1] 70/13
highly [2] 21/23 54/8
him [4] 2/12
his [9] 5/25 6/1 44/6
44/9 44/10 44/11
44/13 68/10 73/7
historic [3] 75/24
77/3 77/10
Historical [7] 4/7 9/10
9/14 25/9 38/17 39/14
48/14
historically [1] 80/13
history [2] 51/11
73/15
HM [4] 6/3
HM Treasury [1] 6/3
Hodge [6] 50/8 56/17
57/21 58/17 73/12
88/17
Hodge Jones [5]
56/17 57/21 58/17
73/12 88/17
hold [4] 4/20 24/3
64/3 72/23
holds [1] 7/45
home [2] 76/13 76/14
honest [1] 73/15
hope [12] 1/16 9/6
25/5 25/8 42/4 55/2
56/4 58/5 58/9 62/11
79/21 86/5
hoped [1] 76/11
hopefully [2] 46/23
86/8
hopes [2] 22/22 23/23)
Horizon [11] 2/22
6/17 30/6 31/3 32/24
35/10 36/18 53/4 63/8
65/23 76/7
hounded [2] 73/16
76/15
how [23] 31/9 35/2
38/15 38/25 44/1
46/10 46/12 56/3
57/12 59/24 62/3 64/9
69/14 72/1 72/22 77/5
77/6 80/12 85/18
85/19 87/6 87/13
88/10
Howe [7] 1/12 1/13
25/1 50/7 62/22 72/15
88/16
however [3] 6/16
24/15 84/24
HSF [14] 40/15 45/20
45/22 46/3 46/7 46/11
46/17 46/19 56/19
7/3 57/10 57/21
82/21 82/22
HSF's [1] 58/19
HSS [42] 9/11 9/15
9/16 9/23 10/3 11/13
41/22 11/24 12/3
12/14 13/2 13/13
14/22 25/12 25/14
25/18 25/19 25/22
25/24 26/1 26/18
32/41 34/11 36/1 36/3
36/4 39/14 41/8 41/10
42/16 43/12 43/24
44/14 44/22 47/23
48/10 52/21 52/23
64/2 65/17 69/2 69/2
Hudgell [32] 24/22
25/10 26/6 30/17 34/9
45/2 45/17 47/10
47/13 47/16 49/1 49/7
50/4 50/6 50/20 51/10
51/20 51/23 52/1 53/4
53/14 53/19 57/16
58/2 60/19 61/14
62/21 67/17 69/12
69/17 69/24 88/16
Hudgell Solicitors [2]
53/19 62/21
Hudgells [7] 58/21
59/1 62/23 67/9 82/18
82/21 83/7
human [1] 74/2
hundreds [2] 9/24
73/15
hurdles [1] 74/15
husband [3] 44/3
44/4 62/13
hyperbole [1] 61/6
I accept [2] 17/20
55/10
l address [1] 19/20
lalert [1] 1/25
lam [10] 8/15 15/18
24/2 48/21 55/12 67/6
TAIN9 72/23 87/8 89/2
I apologise [1] 67/15
lask [4] 72/2
assist [1] 88/20
I believe [2] 48/18
49/18
I can [4] 55/16 69/3
85/12 87/1
I can't [1] 15/15
I certainly [2] 9/2
72125
Ideal [1] 16/7
Ido [1] 42/4
I don't [10] 1/24 13/15)
17/18 28/15 55/21
55/22 56/23 62/24
TAIN9 81/20
lexpect [1] 89/13
I got [2] 24/9 68/12
I hate [1] 89/16
Ihave [10] 1/6 1/22
34/21 36/20 56/25
72/7 73/7 89/4 89/8
89/17
I hope [3] 1/16 42/4
62/11
lintend [1] 89/2
I just [2] 1/5 86/18
I know [1] 84/25
leave [1] 72/3
I make [3] 2/14 24/21
723
I may [3] 34/12 81/7
82/18
Ineed [1] 49/9
Inext [1] 16/15
I ought [1] 59/18
I please [2] 8/14
23/11
I point [1] 29/17
l repeat [1] 86/8
[represent [4] 74/5
74/18 77/14 79/11
I said [3] 1/4 56/4
89/1
I say [3] 28/23 62/12
7718
Isee [1] 72/12
I shall [4] 2/16
I should [3] 1/22 2/4
49/16
I speak [1] 73/11
Itake [1] 73/2
I thank [1] 85/7
I think [9] 1/4 1/20 2/6
2/11 15/8 24/2 66/19
71/11 85/4
I thought [1] 52/8
Iturn [4] 8/23 14/22
15/5 15/24
I want [2] 66/17 68/20
Iwas [2] 49/10 52/13
Iwill [8] 1/7 47/7
49/19 67/11 7/5 89/5
89/6 89/17
I wish [1] 55/25
I won't [4] 62/19
I would [4] 51/7 84/23
84/24 89/14
I wrote [1] 15/8
I'd [3] 49/24 71/4
79/23
Fil [4] 9/8 16/6 47/3
47/4
I'm [22] 13/22 15/21
26/10 50/8 52/7 52/13
57/12 66/19 67/3 67/4
67/11 67/12 71/17
71/18 71/19 72/7
80/12 82/18 85/2
85/13 88/16 89/20
I've [7] 20/25 24/6
67/14 67/24 68/20
83/10 83/19
identified [7] 21/48
421/25 43/3 47/13 48/4
65/6 88/19
identify [1] 3/6
identity [1] 34/21
if [77] 1/18 2/5 2/8
9/24 15/24 16/11
16/20 18/11 25/12
25/21 27/6 28/23
30/11 30/13 32/16
33/19 33/23 34/1
34/12 35/19 36/22
36/23 38/1 38/11
38/16 40/12 40/14
42/45 43/3 48/3 49/10
49/13 50/2 50/5 50/8
56/16 56/23 57/20
59/19 59/22 62/12
67/12 67/13 69/3
71/18 72/8 72/25 73/4
TAINS 75/6 75/16
76/41 77/17 78/15
78/16 78/20 79/18
81/6 81/7 81/10 81/17
81/22 82/4 82/9 82/18
83/8 83/10 83/17
84/12 87/1 87/8 87/16
87/19 87/24 88/5 88/9
89/8
ignored [1] 74/16
il [1] 44/8
illness [1] 30/19
imagine [4] 37/1 53/8
61/18 72/25
immeasurable [1]
74/1
immediate [4] 22/23
impact [7] 28/21 34/7
43/22 44/12 72/20
74/2 84/14
impacts [2] 29/6 29/9
implement [1] 22/13
implications [1]
53/15
importance [2] 21/24
70/8
important [8] 2/21
5/15 5/16 10/15 19/25
63/13 64/6 65/1
impression [1] 39/13
impressive [1] 74/2
improve [1] 11/8
improved [1] 11/21
improvements [1] 5/1
inadequate [2] 45/10
79/12
incentive [1] 43/9
include [1] 23/45
includes [4] 7/17 16/2
56/22 57/24
including [6] 4/7
19/11 33/1 33/8 36/5
44/10
incomes [1] 70/25
@3) here... - incomes
INQ00001056
INQ00001056
I initiative [1] 76/22 I 22/16 24/8 25/22 41/8] 26/4 26/5 26/12 27/25 I 43/11 47/10 49/24
inconvenience [3] IiNiuries [1] 29/10 I 41041154116 I 31/5 31/2532/24 I 50/15 60/25 61/18
918. 27102 31/02 injury [11] 13/10 27/9] 44/25 42/23 42/24 I 35/10 35/11 47/8 53/7 I 52/13 52/23 53/2
increased [1] 7122 I 28/14 28/24 20/2 20/4 47/1 60/9 60/24 61/9 I S6/'4 65/22 66/16 I 56/16 61/22 62/6 66/9
increasing [2] 14/19 I 29/14 29/19 20/22 61/11 61/1261/18 I 78/6 78/17 81/5 88/12 67/12 70/5 71/4 7612
15/7 36/5 36/6 64/16 69/2 71/8 85/18 it's [27] 816 2616 I 78/3 79/21 86/18 87/9
incur [1] 23/8 injustice [2] 62/3 63/7] 85/25 86/7 87/17 88/4I 30/25 31/8 37/1 47/11 I 89/17 89/20
incurred [1] 61/12 Iinlustices [1] 4/13 80/6 808 47/15 49/13 49/25 Ijustice [7] 2/23 9/18
indeed [11] 3/3 4/22. [innocence [1] 73/21 interimifinal [1] 69/2 I 60/22 62/28 86/7 57/1 I 42/4 65/4 73114 73/19
B16 23/21 59/12 (inoperable [1] 62/21 Iinternal [1] 45/21 I §7/1457/1657/25 I 78/18
57/19 8518 75/8 77/10 IinPut [1] 10/8 internally [1] 7/17 I 57/25 58/11 59/17 —_Ijustification [1] 76/18
80/93 84/9 Inquiry [35] 1/25 2/18 interruption [1] 49/20] 61/461/2261/25 yy
indefensible [1] 2/20 3/5 3/9 3/12 3/18 Iintervene [1] 72/14 I e4oe7/14 724 [RA
6st 4/17 4/23 4/24 5/10 intervention [2] 72/24I 77/11 87/3 keen [2] 16/13 19/17
independence 2) I 9208/24 9/7 24114 I 76/24 its [23] 2/19 3/13 6/5 IKeep [3] 16/6 87/11
25/24 45/16 24/15 25/1 38/21 interviewed [1] 44/5 I 6/8 6/13 7/25 10/4 I 87/12
independent [9} 6/10 I 38/2446/15 49/12 into 12] 19/22 27/1 I 10119 10124 11/2 [keeping [2 47/7
118 11/16 121g I 2/2260/16 64/9 7O/9I 35/13 44/16.47/18 I 16/10 16/21 16/24 _I 76/19,
26/22 32/18 37/12 I 80/1 80/3 80/11 BO/16 I 54/18 61/22 67/1 67/5) 18/8 19/7 21/13 29/22 Ikey [3] 4/2 9/21 80/3
46/22 51/14 81/10 82/8 84/4 84/14 I 79/25 81/16 81/20 I 33/2 46/9 50/8 55/9 I Kiernan [1] 0/11
84/20 87/3 introduced [1] 49/24 I 55/10 76/22 kind [3] 13/22 31/9
independently [3] 3/6
4/5 77/20
indicated [1] 12/5
indicating [1] 2/6
indication [1] 57/8
individual [6] 2/4
16/17 23/14 42/7 86/8
88/14
individual's [1] 28/21
individuals [5] 18/41
19/21 41/11 87/2
88/17
indivisible [1] 5/18
Industrial [2] 2/15
6/25
ineligible [2] 65/17
65/17
inflicted [1] 73/25
inform [2] 30/2 34/22
informally [4] 23/13
information [10] 5/7
18/18 30/21 35/17
35/19 36/21 37/15
40/25 41/6 46/13
informed [6] 10/10
17/5 22/10 40/17
44/15 56/4
ingenious [1] 78/9
initial [8] 7/19 9/16
9/21 11/13 11/20
13/17 15/4 15/13
Inquiry's [2] 4/4 9/1
insofar [1] 85/17
insolvency [7] 1/13
13/9 16/15 16/17
16/21 25/7 38/25
Instead [1] 80/9
instituted [1] 56/13
institution [1] 3/2
instructed [6] 56/19
57/40 57/11 57/22
58/23 59/13
instructing [5] 50/24
51/3 55/14 57/3 85/10
instructions [3] 58/19)
58/24 82/20
insufficient [2] 27/10
28/10
intend [3] 38/2 38/9
89/2
intended [4] 12/19
68/11 69/4 88/25
intention [1] 12/16
interactions [1] 82/8
intercept [1] 72/12
interest [4] 17/12
17/15 17/23 38/9
interests [3] 63/20
63/21 65/3
interim [37] 5/9 7/1
17/2 17/8 17/43 17/21
18/2 18/4 18/11 22/14
investigate [1] 33/13
investigation [3] 40/3
44/7 45/24
investing [1] 8/12
Investments [1] 6/2
invitation [1] 80/22
invite [4] 19/3
invited [2] 24/23
69/13
invoke [1] 78/19
involve [1] 2/4
involved [5] 7/14
47/11 63/15 66/19
87/11
involvement [4] 6/8
23/25 58/20 59/1
involving [2] 27/25
31/24
isn't [1] 61/2
issue [24] 4/1 8/5 8/8
8/14 15/1 16/7 16/11
16/12 17/1 19/6 22/8
26/2 28/3 28/16 28/17
28/17 30/12 70/8
70/12 76/2 80/17
87/16 88/4 88/10
issued [1] 28/25
issues [32] 2/3 2/4
AN15 4/22 8/2 8/25 9/4
16/16 16/20 16/22
19/5 24/13 24/23 25/4
itself [9] 6/2 6/18 7/7
10/1 10/7 13/14 14/2
14/11 74/25
a
jail [1] 76/12
January [4] 8/4 50/24
51/3 51/15
JFSA [1] 69/19
Jo [4] 62/11
job [1] 87/20
jobs [1] 61/21
John [4] 50/42
join [3] 33/24 75/11
78/25
joined [1] 33/16
Jolly [1] 2/40
Jones [6] 50/8 56/17
57/21 58/17 73/12
88/17
judge [1] 17/19
judicial [2] 28/25
55/25
July [10] 1/1 1/9 4/13
1/44 11/23 49/8 49/18
50/2 60/1 60/21
June [2] 1/11 22/11
just [35] 1/5 13/15
20/22 23/16 24/1 24/2
29/11 34/14 37/9
38/22 40/23 42/20
TAT
kinds [1] 55/14
knew [2] 49/10 49/12
knock [1] 34/3
know [15] 17/41
24/21 28/23 37/2 48/2
48/47 55/21 55/23
56/23 59/2 64/16
73/22 76/16 81/2
84/25
knowledge [2] 67/13
67/15
nm
lack [2] 37/18 46/13
lacuna [1] 68/4
ladies [1] 89/15
laid [4] 89/14
large [2] 33/12 53/12
largely [2] 18/17
18/19
larger [2] 7/25 14/14
last [23] 1/4 2/7 25/16
26/19 27/1 32/11
32/14 39/22 52/20
56/11 56/17 59/19
60/5 60/22 62/7 62/23
75/1 82/6 85/5 87/5
87/9 87/11 87/18
Lastly [4] 87/8
late [4] 14/23 15/12
(G4) inconvenience - late
INQ00001056
INQ00001056
L let's [1] 42/16 79/12 86/22 lost [2] 30/4 76/14 I 4/1 24/24 25/11 32/21
fate. [2) 84/16 64rzo Ileter [27] 1/8 41/11 litle [7] 12124418 tot 2) 647 81/7 I 37/t 40/22 44/18
law [6] 525.2111 I 1/12 1/13 16/16 16/19 I 53/9 75/26 76/17 77/8IIlottery [1] 61/21 I 83/23 59/11 60/8
50/11 63/15 74/20 _ I 24/5 25/6 25/21 33/18] 77/9 loved [1] 3/19 60/11 61/3 61/17
32/2 34/16 34/21 36/9 _ lives [8] 3/4 53/3 61/4Ilow [3] 29/14 39/15 I 61/25 62/1 69/19
laws [1] 33/1 36/14 36/24 37/2 37/4 I 63/11 74/1 74/10 75/9 I 61/20 70/15 70/19 74/25
lawyer [1] 44/1 37/4 38/23 39/5 39/22 I 78/23 low-paid [1] 61/20 I 82/1
lawyers [8] 23/14 I 992840114017 ILondon [1] 76/9 lying [1] 3/20 March [4] 10/15 20/18
55/14 74/21 74/22 I 40/25 71/17 7218 long [13] 9/18 15/19 Ip 28/13. 1/4
74/25 75/19 g1/16 (letters [2] 17/4 60/5 I 26/14 40/20 53/24 I —_________IMarch 2021 [2] 10/15
32/2 level [4] 6/9 15/7 61/4 62/3 63/11 63/18 Imade [41] 2/174/5 I 51/4
layman's [1] 13/5 I, 17/25 29/7 72122 74/19 84/11 I 8/22 12/21 12/23 16/8 I marker [4] 87/1
led [7] 30/10 45/7 {levels [2] 14/16 56/15) 84/18 16/23 17/13 17/21 IMarshall [2] 50/9
54/22 55/3 55/3 56/19 I liability [1] 21/6 long-term [2] 26/14 I 19/20 19/25 21/21 I 58/24
57/22 liberty [1] 71/2 53/24 25/11 29/17 30/14 I Marshall's [4] 79/24
leading [1] 69/1 {life [2] 44/11 62/7 IIonger [3] 4/11 30/8 34/19 34/25 35/8 79/25 80/6 80/19
learn [1] 4/25 light [2] 72/17 85/24 I 83/24 36/11 38/2 38/12 I matter [6] 55/15
learning [2] 80/5 60/6I/*Ke [13] 3/10 14/6 Ilook [1] 46/17 41/11 42/7 43/8 43/17 I 58/14 61/2 67/4 75/25
learnt [1] 3/10 42/12 45/25 55/9 61/6 Ilooked [4] 14/14 I 45/8 46/7 46/16 47/21) ga/12
least [9] 3/8 36/0 37/7I 11/4 75/6 75/16 79/23) 32/15 44/16 87/13 I $123 59/7 59120 matters [14] 5/21
38/6 48/10 51/12 I 84/2384/24 86/16 Ilooking [3] 37/9 86/11) $9/22 67/12 70/19 I 27/4 28/4 26/8 28/14
58/20 59/1 84/19 ‘(likely [6] 14/11 18/3 I 88/114 76/21 80/25 87/15 I 29/25 43/11 43/18
leave [5] 52/7 72/3 I 39/1142/19.45/7 looks [2] 3/12 24/13 87/16 88/6 88/23 64/25 65/5 85/17
34/3 84/10 89/20 (I 72/28 loosely [1] 2/1 main [2] 34/18 78/21 I 86/25 87/18 88/9
leaving [1] 62/15 _I limit [1] 79/8 Lord [13] 19/14 56/19Imajor [1] 22/12 maximum [2] 10/12
led [4} 53125 70/24 _Ilimitation [14] 25/20 I 67/3 67/10 67/11 majority [3] 17/8 10/16
73/18 81/22 32/10 32/10 32/42 57/22 58/6 58/13 35/14 62/4 may [61] 2/6 2/7
left [6] 44/10 48/21 I 39/2 39/5 39/7 33/16 I 58/16 68/19 58/22 make [52] 2/8 2/14 I 42/24 15/24 17/25
76/17 79/3 84/18 33/20 33/25 34/3 34/5 I 59/20 82/21 3/7 3/19 3/23 4/21 7/3 I 48/45 20/20 20/25
88/11 66/14 68/16 Lord Dyson [13] 8/14 12/5 12/41 18/12) 27/12 27/22 27/23
legal [38] 5/25/14 limited [13] 4/6 5/17 I 19/14 56/19 57/3 18/24 24/21 28/9 29/22 29/24 30/9 31/6
4447 12/13 1217 I 6/2 10/4 21/4 2613 I §7/10 87/41 57/22 I 28/11 29/23 29/24 I 34/24 31/23 33/13
tone 12/19 12/24 I 27/21 30/21 41/9 45/8 I 58/6 58/13 58/15 30/12 34/22 37/24 I 34/3 34/6 34/12 34/15
43/9 14/10 14/17 50/23 54/20 57/14 I 58/19 58/22 59/20 —_I 38/3 39/25 40/17 35/14 36/19 37/25
44/20 15/7 18/13 line [6] 7/2021/19 I 82/21 50/15 55/21 56/16 38/22 38/24 40/21
18/22 20/3 20/9 24/6 I 27/2 32/14 32/23 floss [30] 13/2 13/6 I 57/2 59/9 60/17 64/11) 4o/22 43/6 44/15 46/3
ano 222115 I 50/23 13/7 13/7 13/7 18/25 I 71/20 72/8 72/13 46/4 46/21 47/2 48/1
24/23 2216 23/8 26/23 Iline 12 [1] 27/2 19/2 29/18 29/19 72/16 72/19 74/8 77/1 I 48/11 49/15 50/15
36/25 37/8 40/4 43/19 Iline 24 [1] 32/14 29/20 30/8 36/4 41/13 I 80/3 80/16 80/22 51/17 54/4 55/20
44/24 44/25 45/9 —_IWon's [1] 22/4 42/7 43/10 46/13 81/14 83/2 83/4 83/20 I 55/21 56/16 57/20
45126112 73/14 list [1] 8/9 47/12. 4718 47/25 —_I 84/9 84/19 84/22 58/10 62/18 64/14
74/45 87/24 89/13. Ilisten [2] 4/25 5/8 I 48/5 48/6 54/24 56/21 I 84/24 85/7 86/24 66/6 66/9 67/2 74/17
legalistic [1] 74/13 {listened [1] 14/12 I 57/23 59/8 7o/24 71/1 87/20 89/16 81/7 82/18 84/11
legally [1] 79/7 listening [3] 1/21 81/8) 74/1 74/13 78/4 makes [2] 45/23 46/2 I g4/19 85/7 86/11
legislation [2] 6/14 I 82/13 losses [26] 3/24 making [8] 4/25 7/16 I 96/18 87/21 88/1
Nd lists [1] 39/23 12/23 13/3 13/4 13/4 I 11/12 12/7 27/13 me [13] 1/14 1/23 2/2
litigation [21] 10/3 I 13/6 14/4 14/7 14/11 I 64/16 80/5 80/8 25/12 27/6 28/22
legitimate [1] 70/23
less [5] 29/7 29/14
44/20 45/12 46/7
20/3 20/15 22/3 22/14 I 29/24 30/3 32/22 _Imalicious [8] 19/10 I 36/24 48/23 55/8
22/18 23/2 33/9 34/1 I 32/22 33/2 33/3 35/13] 51/5 54/5 66/9 67/2 I 55/45 62/12 72/7
42/12 56/10 63/18 I 36/12 36/44 42/1 52/4 I 67/22 78/1 79/6 722
lessons [4 3110 3/17) ees 65/20 69/20 I 84/1 56/5 56/8 70/19 Imanifest [1] 7/22 I mean [6] 13/16 28/15
70/13 75/8 78/20 79/1 I 70/21 76/7 many [22] 3/13/25 I 41/1 45/3 46/9 56/6
(35) late... - mean
INQ00001056
INQ00001056
M 20/18 20/20 22/10 I 2517 43/16 47/22 —_I 72/6 72/22 73/9 73/10 Inegotiated [3] 78/2
——______I sa/t0 6819 60/23 72/18 78/10 I 90/6 81/19 81/24
meaning) 3st Minister Scully [1] I 81/8 85/10 88/23 IMs Skinner's [1] __Inegotiations [8] 7/19
8/4 most [8] 2/228/8 I 76/14 54/19 7715 77/18
means [6] 33/19 ministers [1] 24/24 I 10/17 12/20 3219 (much [16] 2147/1 I 78/15 78/16 78/20
a 38/23 63/3 7312 minutes [7] 49/13 §4/24 73/13 78/23 11/9 24/18 39/12 79/4
meant [4] 21/13 58/25 49/14 49/18 72/24 Imoved [1] 60/5 40/14 41/1 46/9 48/19 INeither [1] 58/13
59/3 60/12 73/3 73/8 87/9 moves [1] 76/21 54/13 55/22 63/1 77/8 Ineutral [10] 13/23
mis [2] 80/21 82/23 IMr [35] 1/11 1/15 2/11] 88/21 89/14 89/19 15/18 19/13 19/15
mechanisms [1] 6/20) Fis communication I 2/13 15/2024/19 must [11] 19/9 23/15 I 19/17 56/13 56/20
mediation [4] 4/6
51/11 54/25 70/14 [1] 82/23 24/20 38/22 48/21 28/22 37/14 38/5 57/5 57/23 59/13
medical [9] 26/7 misapprehension [2] I 50/9 57/13 59/19 60/2 I 38/14 48/22 56/11 never [4] 3/3 3/3
27/11 30/12 30/24 57/42 82/23 60/23 67/24 68/13 73/21 74/12 79/15 51/13 63/25
31/4 31/7 44/9 53/20 miscarriage [1] 73/14) 70/41 72/12 72/18 my [31] 8/8 8/23 9/3 [nevertheless [3]
54/7 misinterpreting [1] I 73/3 73/7 79/24 79/25I 15/6 15/24 16/6 20/10 I 27/12 27/19 28/1
12/14 80/19 82/6 82/19 24/3 24/12 49/16 new [2] 42/22 47/17
meet [1] 12/9
meeting [1] 48/8
meetings [5] 7/16
mislead [4] 13/15 84/25 85/5 85/6 85/11 I 50/23 51/3 51/7 66/17 Imext [10] 14/21 15/10
Misra [2] 75/1 76/9 I 85/11 88/21 90/4 90/5I 67/3 67/13 67/15 16/15 17/1 39/6 39/22
471 47/i6.47/16 IMisra's [1] 73/22 I 90/7 68/19 71/18 72/9 76/3 I 41/8 69/7 73/1 86/4
48/1 missed [4] 46/14 Mr Beer [2] 70/11 82/24 85/10 87/8 87/9 Inight [2] 56/17 60/5
members [9] 11/8 47/12 67/14 67/16 7212 88/22 89/1 89/3 89/3 Inine [1] 60/20
22/14 23/7 26/22 mistrust [1] 82/2 Mr Brightwell [3] 1/11) 89/16 89/17 nine months [1]
69/15 69/17 69/18 misunderstood [4] I 1/15 85/11 myself [2] 2/4 13/15 I 60/20
69/20 69/22 24/6 Mr Chapman [8] 2/11) 9 no [52] 1/8 3/18 20/3
moderate [1] 29/7 I 2/13 15/20 38/22 60/2 vall(a] OSHS TED 21/1 21/6 21/11 23/19
modest [1] 72/20 I 60/23 68/13 90/4 _—_—Inai 26/20 31/25 35/20
Fe ena + (Moloney [7] 24/19 Mr Enright [1] as/t1 I 75/16 76/18 96/8 37/7 44/5 41/25
28/17 29/5 31/24 24/20 48/21 57/13 IMr Henry [1] 84/25 Iname [1] 31/13 42117 46/9 46/11 48/9
mentally [1] 44/@ I 97/2482/19 90/5 Mr Marshall [1] 50/9 named [1] 50/10 50/18 51/13 51/15
mention [1] 1/7 moment [2] 55/17 I Mr Marshall's [3] narrow [1] 74/13 52/12 56/25 57/12
mentioned [1] 62/22 I 68 79/24 79/25 80/19 —_Inational [1] 3/2 59/8 59/15 60/24 65/3
merits (3] 18/8 41/2 IMonday [1] 59/17 I Mr Moloney [7] 24/19 natural [1] 66/14 65/7 66/21 67/25 69/1
4/2 money [17] 10/9 24/20 48/21 57/13 Inature [2] 29/25 37/3 I 70/10 70/23 71/16
met [1] 9/25 20/23 21/2 36/16 67/24 82/19 90/5 Inavigate [1] 37/5 71/24 73/2 73/4 74/9
methodology [5] 23/3) 37/23 38/12 61/7 61/7 IMr Stein [8] 59/19 nearly [2] 12/1 39/6 I 74/20 76/18 76/21
86/3 86/19 86/20 87/3 I 70/22 74/9 76/7 76/11 I 72/18 73/3 73/7 85/5 Inecessarily [1] 45/3 I 77/44 77/23 78/11
middle [1] 62/2 76/15 78/6 78/8 86/5 I 85/6 88/21 90/7 necessary [12] 3/10 I 78/14 78/17 78/25
might [17] 13/6 29/15I 86/15 Mr Stein's [1] 82/6 I 5/4 10/12 20/20 21/3 I g3/8 83/24 84/9 88/21
29/17 37/6 37/14 42/3 (money's [1] 72/1 Mrs [2] 75/1 76/9 28/22 41/15 51/21 Ino-one [1] 23/19
46/15 55/17 59/20 Imonies [2] 86/7 86/21)Mrs Misra [2] 75/1 I 59/6 75/11 80/6 88/8 non [14] 16/2 19/6
memories [1] 63/6
monitoring [2] 7/12. I 76/9 necessity [1] 26/20 I 21/21 31/17 36/1 36/7
aaeae eee gaia gairI 716 Ms [17] 216 29 26/19 Ineed [24] 1/24 4/17 I S6115 S621 67/23
38/9 months [3] 47/2 31/21 32/11 39/5 11/10 12/19 20/5 58/8 68/8
60/20 69/7 52/20 54/3 60/22 72/6I 29/25 32/14 36/21 Inon-continuing [1]
million [8] 10/13
10/16 10/18 12/4
22/15 22/20 24/9
45/11
millions [4] 20/22
mind [3] 59/23 89/8
89/15
minister [7] 8/4 8/9
more [23] 7/1 10/25 I 72/22 73/9 73/10 38/3 38/6 38/8 38/21 I 21/21
12/14 14/11 14/13 I 76/10 76/14 76/24 —_—I 49/9 54/15 59/12 63/4 Inon-GLO [2] 16/2
15/15 29/24 34/10 I 90/6 74/14 74/15 74/24 I 68/8
36/2 36/10 39/17 41/1 IMs Felstead [1] 76/10I 83/4 86/24 non-pecuniary [8]
41/3 43/14 45/7 45/7 IMs Gallifant [7] 26/19Ineeded [1] 81/23 19/6 31/17 36/1 36/7
55/21 55/24 70/10 I 34/21 32/11 39/5 needs [2] 38/20 63/9 I 56/15 56/21 57/23
73/2 73/4 81/4 82/9 I 52/20 54/3 60/22 negotiate [2] 22/8 I 58/8
morning [10] 16/16 IMs Page [7] 2/6 2/9 I 54/16 none [4] 28/12 39/3
(86) meaning - none
INQ00001056
INQ00001056
N obtaining [3] 27/23 I 30/16 30/2541/21 —_I 49/13 49/14 50/8 54/7 I 86/23 87/15 88/13
none...[2] 51/7 sa/t4 I 91/22 48/10 44/3 45/20 50/13 55/8 55/20 55/21 out [34] 2/3 7/7 9/2
nonetheless [1] obviate [1] 12/19 I 50/1550/18 50/22 I 58/12 58/20 59/1 14/17 23/19 24/24
54/20 obviously [3] 44/14 I 51/25 52/25 53/2 60/18 61/20 62/5 29117 33/21 33/24
nor [2] 3/20 65/8 49/25 89/12 54/23 61/22 62/20 I 63/22 63/22. 63/22 I 34/1 34/3. 44/1 44/14
normal [t] 21/12 [occasion [2] 46/8 I 68/21 71/4 74/7 71112) 63/22 64/23 68/21 I 45/21 46/13 47/5 4716
not [157] 87/19 73/1 76/23 79/10 74/16 74/20 75/8 76/4 I 48/22 52/20 54/3 55/9
note [4] 5/20 10/15 [Oecasioned [1] 81/3 I 79/21 B4l6 78/18 78/19 79/4 63/24 63/25 67/13
45/6 89/1 occasions [1] 3/8 ones [2] 3/20 48/2 I 86/12. 86/13. 87/14 I 68/20 75/13 75/21
noted [2] 4/15 11/4 [Oecurred [1] 81/2 only [20] S/9 18/16 I 86/9 88/9 896 89/11 I 77/12 80/4 B3I24
notes [5] 12/4 13/1 [October [2] 13/12 I 20/12 20/25 21113 oral [3] 2/17 916 50/17) 85/17 86/19 86/2
amare a7iig I 13/19 29/18 33/21 35/24 orally [1] 24/2 89/20
nothing [2] 3/10 61/1 IOctober 2020 [1] 44/11 44/25 47/17 order [23] 1/8 3/5 7/3 Ioutcome [7] 25/21
notion [1] 55/8 13/19 48/3 48/5 48/6 53/11 I 23/2 25/2 27/5 32/23 I 39/22 39/23 40/11
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44/24 77/5 86/8 resolution [8] 33/10 I 64/22 saw [1] 75/2
reject [t} 409 repeated [1] 57/1 I 34/2 34/9 43/19 45/14Irevisit [1] 44/13 I Say [67] 1/22 2/3 8/10
repeatedly [1] 75/23 I 54/18 84/6 84/7 rhetorically [1] 72/2 I 13/4 15/9 27/6 28/23
ret 2918 32721 repetition [1] 25/2 resolve [6] 16/11 rich [1] 75/8 20/25 30/9 30/11 31/9
related [4] 14/5 22/2 IePlace [1] 63/6 56/14 78/17 84/2 88/8 Iright [30] 1/19 2/18 I 32/6 32/16 34/4 36/25
23/12 30/19 report [15] 7/1 27/23 I 88/10 5/2 8/16 14/16 17/17 I 37/5 37/7 38/20 39/10
relates [1] 85/22 I 31/7 31/23 32/1 32/8 Jresolved [10] 16/14 I 20/3 20/12 24/0 34/22) $9/11 40/10 40/13
relating [3] 9/9 16/20 I 40/3. 40/14 45/22 47/1 I 19/2 34/11 54/23 I 39/13 .43/6 46/4 49/18 I 41/8 41/17 4219 42/15
nT 87/17 88/4 89/6 89/8 I 54/24 55/5.63/16 I 54/3 55/16 64/12 66/3 42/16 42/16 45/10
, 89/14 64/25 656.6577 ‘I 67/19 68/13 68121 I 46/8 46/15 47/3 48/22
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poroariasong (reports [5] 26/7 46/1 resort [1] 56/11 I 77/1 77/24 77/25 I 96/18 59/18 60/4
sorte S016 sae I 48/1053/20 79112 resource [1] 75/11 I 79/1581/4 85/3 I 60/16 60/21 61/5
relationship [5] 5/18 I"@Present [20] 25/10 Iresources [4] 8/13 Irightly [3] 43/6 64/5 62/12 63/9 63/18 64/5
B13 72 dere paris, I 26/8 35/14 S017 SOI13I 9122 10124 37/18 I Targa 64/11 64/14 65/7
relationships [1] 71/1 95/18 569 56/22 resourcing [2] 7/22. Irights [7] 61253317 I 65/10 85/11 65/14
relatively o) 10/4, I 97/15 87726 5822 I 11721 67/25 7812 79/5 79/14 I 65/16 65/18 66/3
84/11 84/16 61/14 67/10 67/17 _Irespect [16] 14/5 81/20 66/14 70/1 72/9 75/9
release [1] 82/9 7415 74/18 7/14 25/17 26/2 28/11 rigorously [4] 30/1 I 75/21 77/8 77/23
released [1] 44/6 79/11 88/14 88/17 I 33/45 35/9 39/2 43/11 Irisk [2] 10/25 45/15 I 81/23 82/25 84/1 87/9
relevant [5] 2/5 9/4 Ifepresentation [4] I 48/14 48/18 50/16 role [7] 6/19 7/2 716 89/6
33/5 37/15 54/8 12/17 12/20 45/1 52/8 54/19 68/8 79/24 I 7/8 10/2 10/4 11/2 I saying [2] 13/22
4 45/13 82/20 rolled [1] 85/19 23/13
relanee' (it ayy _Ifepresentatives [5] respects [1] 78/1 round [3] 11/13 428 Isays [7] 7/8 37/10
5/11 18/23 19/4 23/16 Irespond [3] 79/23 I 88/12 47/17 7516 75116
(40) redacted... - says
INQ00001056
INQ00001056
Ss 53/16 60/11 85/24 81/15 86/2 should [34] 1/22 2/4 I 13/22 15/6 15/6 16/14
says... [2] 82/13 secured [2] 30/15 [settle [3] 34/6 43/9 I 3/3 3/3 5/10 10/25 18/9 24/1 28/3 28/3
82/13 52/1 8 61/9 12/11 17/18 19/22 28/6 29/16 29/22
scale [1] 29/15 securing [1] 10/14 {settled [2] 20/11 20/13 24/14 30/12 31/17 32/19 33/6 33/6
scandal [5] 2/22 6/17 see [7] 7/20 31/9 38/18 31/7 32/14 49/16 57/2 I 36/20 37/14 39/14
62/8 78/23 79/2 46/21 64/9 72/12 79/2 Isettlement [19] 4/6 I 63/19 68/12 70/4 75/4 I 39/16 40/17 40/20
scenarios [4] 55/11 85/16 7/A0 7/11 10/2 10/20 I 75/17 78/14 79/20 41/14 42/8 45/3 46/16
scenes [1] 55/23 seek [9] 9/2 21/14 18/23 20/2 21/8 22/5 I 80/6 81/17 82/7 82/15 I 49/12 52/1 53/5 53/14
schedule [1] 86/1 31/10 32/1 45/9 75/7 I 22/47 23/4 78/3 79/5 I 83/8 83/11 84/16 54/17 55/4 55/24 56/2
scheme [76] 4/7 9/10 79/17 80/10 81/9 79/11 79/13 81/19 84/21 87/11 87/13 56/3 56/4 57/12 57/16
9/15 9/25 10/7 10/8 (Seeking [1] 40/22 81/24 83/17 86/22 87/16 60/3 62/8 62/15 62/24
seeks [2] 6/4 81/14 settlements [4] 7/13 Ishowed [1] 75/10 63/8 63/10 63/24 64/6
10/18 10/23 11/10
11/18 12/16 13/5
13/17 19/23 21/10
21/16 22/25 23/10
25/10 25/18 26/18
31/13 32/13 32/25
33/8 33/13 33/17
33/22 33/25 34/23
35/7 38/17 39/7 39/14
39/15 42/5 42/22
43/12 43/18 43/22
43/24 45/11 47/23
47/24 48/15 50/18
50/21 51/9 51/12
51/14 51/14 57/2 64/2
65/18 66/23 66/25
67/25 68/22 69/3 69/6
69/15 70/14 77/4
77/20 77/21 78/12
78/16 81/16 81/23
82/6 82/16 83/13
83/20 84/1 84/18
85/18
schemes [2] 22/15
51/11
Scully [1] 8/4
second [7] 4/24 9/41
15/24 22/24 23/19
28/7 39/9
secondly [6] 25/19
30/9 32/10 36/8 41/24
43/18
seconds [1] 87/9
Secretary [2] 5/24
69/14
section [3] 27/9 30/9
66/5
section 35 [2] 27/9
30/9
secure [5] 11/10 32/8
seem [1] 15/19
Seema [1] 73/22
Seema Misra's [1]
73/22
seems [2] 74/19
81/12
seen [4] 8/24 56/10
60/7 80/7
seized [2] 65/21
76/10
Select [1] 8/5
send [1] 41/6
sense [3] 17/19 55/22
78/18
sensibly [1] 48/23
sensitive [2] 27/24
31/24
sent [8] 13/11 13/18
13/19 13/25 24/5
37/17 40/16 47/14
separate [1] 78/19
September [4] 13/13
13/20 55/1 89/10
September 2020 [2]
13/13 13/20
serious [3] 2/22
26/16 53/23
seriously [4] 8/12
9/15 16/23 44/8
serves [1] 85/14
service [6] 1/13 2/25
6/7 16/17 25/7 76/25
services [6] 6/15 21/6)
38/25 52/2 52/6 52/18
set [11] 3/5 7/4 9/2
44/11 14/17 12/7
24/24 31/14 75/2 79/2
85/17
sets [2] 78/5 78/6
setting [3] 45/11
45/3 75/6 79/8
settling [1] 20/14
seven [1] 25/17
several [1] 3/8
severe [6] 26/11 29/6
29/7 29/10 29/14
AMN9
severely [1] 78/23
severity [3] 29/1 29/9
29/22
shall [2] 2/16 33/3
shame [1] 80/13
share [3] 22/4 22/6
2217
shareholder [3] 5/25
6/1 10/4
she [18] 2/6 2/7 26/21
27/3 27/6 27/6 27/15
44/14 44/15 62/12
62/42 75/2 76/11
76/12 76/12 76/14
76/16 76/17
she's [1] 44/16
short [7] 1/18 24/19
49/22 72/16 73/2 85/8
80/1
shortcuts [1] 63/13
shortfall [17] 4/7 9/10
9/15 13/4 25/10 32/21
33/2 35/10 36/19
38/17 39/15 42/25
43/3 43/18 44/10
48/15 77/3
shortfalls [6] 14/5
30/19 31/4 31/14 44/5
70/23
shorthand [2] 25/21
68/9
shortly [3] 15/2 15/15
89/11
shown [1] 52/21
shy [4] 4/9
significant [8] 7/11
8/12 26/25 32/22 34/7
52/24 53/25 61/3
significantly [1] 60/6
signing [1] 7/18
signposted [2] 13/12
13/16
similar [3] 20/16 86/6
86/13
simple [2] 44/19
75/21
simplified [1] 18/3
simply [4] 32/9 68/5
76/18 83/20
since [8] 2/7 13/13
23/13 39/7 44/17
60/20 63/7 76/20
sink [1] 79/3
sir [203]
sitting [1] 72/15
situation [5] 55/24
64/1 82/19 83/1 83/1
six [2] 18/20 33/20
six years [4] 33/20
sixth [1] 25/22
Skinner [1] 76/24
Skinner's [1] 76/14
slightly [3] 7/24 8/3
39/8
small [3] 17/10 43/17
76/23
smaller [1] 8/3
Smith [6] 40/4 45/22
46/1 56/18 57/21
59/13
so [84] 1/5 1/8 1/19
4/21 1/25 3/10 8/22
9/14 12/14 13/15
66/19 66/21 67/24
68/3 68/19 69/1 71/18
71/23 72/1 72/10
72/18 73/6 73/22
73/24 74/16 77/7
77/11 79/6 82/1 82/16
85/4 85/15 86/10
86/25 88/15 89/6
89/10 89/15 89/19
sold [1] 76/10
sole [1] 21/22
solely [1] 82/20
solicitor [6] 1/9 37/11
38/14 50/24 51/4
85/10
solicitors [36] 1/16
25/10 26/6 30/17
34/10 45/2 45/17
47/10 47/13 49/2 49/7
50/4 50/7 50/10 50/12
50/13 50/20 51/10
51/20 51/23 52/1 53/4
53/14 53/19 55/20
58/3 58/11 60/19
61/13 61/14 62/21
63/22 67/17 69/12
69/24 88/16
solution [1] 84/9
solutions [1] 63/19
some [29] 4/12 4/16
8/17 9/4 12/21 15/9
19/21 22/22 30/10
33/13 35/7 39/5 42/1
43/5 49/25 55/15
59/25 61/1 61/10
61/11 62/16 62/18
TAM 72/16 74/9 74/15
85/24 87/6 89/7
somebody [1] 23/23
something [9] 28/23
(41) says... - something
INQ00001056
INQ00001056
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something... [8]
29/15 34/23 43/1
44/21 64/14 72/4
74/17 86/16
soon [4] 16/13 19/1
63/16 86/12
sorry [4] 52/7 52/13
68/6 72/14
sort [4] 46/25 51/8
86/10 89/14
sounds [1] 61/6
Southwark [4] 49/5
64/19 64/24 65/21
Southwark Crown [1]
65/21
spared [1] 76/12
speak [4] 1/21 71/18
72/11 73/14
special [1] 81/15
specialist [5] 26/23
26/24 26/24 28/17
52/18
specific [5] 15/15
16/20 20/4 31/8 70/4
specifically [1] 8/6
spelt [1] 7/7
spend [1] 49/16
spent [4] 35/9 45/10
45/12 74/18
spin [1] 48/22
SPM [1] 70/20
SPMs [2] 50/8 83/22
spoken [2] 58/25
88/23
Square [2] 85/12
85/13
stage [13] 4/20 5/20
10/2 38/23 39/4 39/12
47/18 48/1 58/1 59/4
59/6 64/13 80/23
stages [1] 34/8
stance [1] 81/11
stand [5] 24/15 51/10
66/17 83/5 89/20
standard [1] 65/25
standards [1] 69/21
stands [1] 19/16
start [11] 1/3 1/20 2/8
9/14 10/23 33/21 37/2
63/10 66/4 70/13
70/22
state [6] 5/24 44/9
67/13 67/15 69/14
73/16
stated [2] 3/8 8/4
statement [1] 22/11
statements [1] 53/18
states [1] 13/3
status [1] 37/18
statute [1] 21/4
statutory [2] 21/2
64/21
stay [2] 35/25 66/23
steering [1] 11/16
Stein [8] 59/19 72/18
73/3 73/7 85/5 85/6
88/21 90/7
Stein's [1] 82/6
stemming [1] 26/14
step [4] 40/21 61/22
86/4 89/13
steps [4] 12/11 22/12
36/21 51/21
stigma [1] 13/9
still [8] 43/25 62/14
62/17 73/6 74/19
76/17 79/5 79/24
stood [1] 75/13
stop [2] 75/22 80/9
stories [1] 74/3
straightforward [1]
12/14
strapped [1] 40/19
strategic [1] 6/9
strategy [3] 2/15 6/25
TA2
stress [4] 30/19 30/21
31/1 51/7
stressful [1] 79/1
stretch [4] 70/20
strictly [1] 33/10
strings [1] 64/3
stripes [1] 6/13
strongest [1] 74/12
subject [2] 34/5 71/12!
submission [5] 43/5
51/18 70/6 82/15
87/15
submissions [61] 1/3
2/13 2/14 2/17 8/23
8/25 9/3 9/6 11/4
12/21 16/6 18/15
20/19 24/20 24/21
24/23 24/25 25/3
25/14 41/9 42/3 44/25
48/2 48/13 48/18
50/11 50/16 50/17
50/17 56/17 58/18
60/7 60/15 70/7 71/12
72/8 72/17 72/20
73/10 77/6 79/24
79/24 80/1 80/6 80/10
80/19 80/21 81/7 82/6
83/3 84/23 85/3 85/6
85/8 88/13 88/25 89/4
90/4 90/5 90/6 90/7
submit [2] 18/6 18/9
submitted [2] 44/14
52/21
subpostmaster [5]
29/20 44/4 50/13 52/3
70/24
subpostmaster's [1]
30/6
subpostmasters [40]
2/2 3/16 4/1 4/11 5/5
5/13 6/21 9/11 9/17
11/25 15/25 16/2 19/4
20/16 22/23 23/14
31/19 32/1 34/8 37/2
37/8 37/17 38/21
41/23 45/5 45/9 46/23
47/9 49/1 49/3 52/5
53/23 59/3 61/2 61/3
61/8 61/14 63/20
78/22 82/1
subsequent [1] 33/8
subsequently [1]
47/13
subsidise [1] 21/4
substance [2] 8/23
41/5
substantial [2] 10/8
48/20
substantive [2] 24/25
78/11
succeed [2] 27/11
78/17
succeeded [1] 76/17
successive [1] 6/12
such [20] 18/25 19/13)
21/12 27/4 28/4 28/4
29/20 30/3 31/6 31/11
32/8 41/19 60/18
60/18 61/13 63/11
67/4 72/13 77/24
89/11
Sue [1] 65/10
suffered [12] 29/2
29/5 30/18 32/22 39/4
44/23 52/5 53/23
59/11 62/4 63/7 70/4
suffering [1] 29/18
suffices [1] 5/20
sufficient [2] 11/6
28/5
sufficiently [1] 41/19
suggest [7] 8/15
80/21 83/3 83/25 84/5
84/11 87/22
suggested [2] 24/7
24/7
suggesting [1] 13/17
suggestion [4] 12/23
19/20 31/20 59/16
suggests [2] 46/6
48/11
suicide [1] 44/7
suits [1] 83/17
sum [5] 24/8 42/12
74/9 76/23 86/5
summer [1] 89/9
sums [6] 29/17 76/3
76/6 76/15 76/19
76/22
supplemental [1]
72/16
supplementary [1]
50/11
supplied [1] 86/23
support [8] 1/10
12/13 14/20 19/16
27/18 35/18 40/6
69/23
supported [5] 7/14
7/24 8/2 10/5 69/22
supporting [1] 69/25
supportive [1] 3/12
sure [12] 3/23 7/3
26/10 50/8 58/24
67/11 77/4 83/2 85/13
86/24 87/20 88/16
surely [1] 43/1
surmounted [1] 74/15)
surprised [1] 26/10
surprising [1] 80/2
suspect [2] 33/22
34/10
sustained [1] 62/4
swallowed [2] 36/13
53/12
swift [5] 19/18 74/15
79/22 84/6 84/8
swim [1] 79/4
symptom [1] 53/2
system [5] 19/13 23/5
45/20 73/17 73/19
T
tab [1] 32/20
tab 15 [1] 32/20
take [19] 1/18 8/11
32/12 32/17 33/13
35/2 36/21 40/21
40/23 47/17 48/22
50/21 61/15 69/13
73/2 76/2 76/16 77/7
81/41
taken [14] 4/11 7/1
TIT 8/14 12/41 22/12
27/8 63/11 70/22 76/3
76/5 80/15 83/5 83/23
takes [2] 16/22 84/18
taking [6] 25/9 51/21
53/18 55/13 76/17
775
talking [3] 68/11
83/22 86/10
tax [2] 53/8 53/15
taxpayer [4] 6/8 10/1
10/9 20/23
taxpayers’ [1] 78/8
team [3] 2/20 7/23
7/25
tell [4] 56/4
ten [3] 49/18 50/6
58/10
ten minutes [1] 49/18
tens [1] 20/22
tentatively [1] 87/21
term [5] 14/7 26/14
33/19 53/24 80/15
terminated [1] 70/14
terminology [1] 14/10)
terms [17] 4/4 13/3
13/6 18/14 25/20 27/7
32/18 46/19 63/3
68/16 68/17 74/12
(42) something... - terms
INQ00001056
INQ00001056
T 56/25 57/6 58/12 26/25 33/14 53/5 66/12 68/16 69/5 70/3 80/16
terms... [5] 80/1 80/3 61/22 62/5 62/18 55/15 84/15 85/23 72/20 74/1 74/6 74/16 Itold [5] 48/9 73/20
80/11 80/15 89/12 63/11 64/4 64/6 65/9 I Therium [3] 22/2 22/5] 76/3 76/7 77/17 78/20 I 75/24 78/9 78/10
terrible [3] 44/13 65/19 66/3 67/12 2218 80/10 80/21 83/6 too [2] 3/15 9/18
62/17 63/6 67/18 70/19 70/22 these [57] 2/14 4/13 I 84/23 85/3 85/25 87/2 Itook [5] 11/11 44/11
test [3] 10/25 11/13 72/10 73/24 74/10 4/16 4/20 4/22 5/41 I 88/13 62/2 76/7 79/5
44/24 75/12 75/15 78/18 8/2 8/25 12/4 12/22 Ithough [1] 85/14 tooth [4] 65/15 75/12
79/2 79/21 82/17 16/22 18/6 18/9 19/8 Ithought [4] 48/12 75/15 75/18
than [21] 4/9 4/11 7/2
8/3 13/4 14/12 15/16
17/2 1912 23/21 36/7
36/10 36/17 42/6 43/9
45/12 46/7 47/2 73/2
73/4 81/4
thank [14] 24/10
24/41 24/16 24/17
24/17 48/16 48/24
68/15 69/8 72/5 85/3
85/7 88/21 89/19
thanks [3] 2/19 15/23
88/22
that [513]
that's [20] 1/18 5/15
24/17 27/1 32/16
32/19 33/23 48/14
53/2 59/24 64/21
67/13 67/25 68/2
68/18 69/8 72/21
82/22 85/2 89/15
their [64] 3/19 3/20
3/24 9/5 17/15 17/24
18/9 18/12 22/9 23/14
23/16 26/12 27/19
30/8 33/18 40/24
42/20 47/22 49/3
50/17 52/9 53/19 54/6
54/15 54/20 60/13
61/4 62/2 62/7 62/24
63/1 63/4 64/17 64/20
65/3 65/23 65/24 66/1
66/6 70/21 71/9 73/12
73/24 74/3 74/6 74/10
75/13 76/6 77/19 78/1
78/13 78/17 78/23
79/4 79/5 79/6 79/8
79/9 79/14 80/9 82/7
82/16 83/17 86/20
them [40] 3/19 3/20
16/13 18/8 18/13
20/15 24/24 26/11
32/5 38/13 42/24
47/14 51/24 54/7
83/17
themselves [1] 81/9
then [33] 11/18 13/21
25/9 25/25 27/6 33/22
34/2 34/3 37/18 37/21
42/10 45/22 46/21
47/24 49/9 49/15 50/3
50/7 50/9 53/11 57/7
61/14 72/6 72/9 72/10
73/6 73/7 73/9 74/16
82/18 86/4 86/7 89/21
there [82] 1/5 1/8
4111 1/12 1114 1124
2/5 7/8 9/2 14/8 16/11
20/4 21/1 21/6 24/22
28/5 28/9 28/24 29/3
31/12 32/2 36/8 37/3
37/7 38/20 41/5 41/13
42/8 42/10 43/2 43/13
45/17 45/24 46/9
46/21 46/24 47/19
48/9 49/6 50/1 50/3
51/45 52/15 54/12
54/17 55/13 55/19
56/16 57/13 58/25
59/8 59/15 59/25 60/2
60/24 63/9 64/19
64/25 66/21 66/23
66/24 67/9 67/16 70/1
70/10 72/15 74/9
75/21 75/25 76/18
77/23 78/11 80/22
83/8 83/11 84/6 84/7
85/9 85/17 86/24 87/6
88/15
there's [17] 26/20
26/25 29/16 30/11
30/21 31/25 41/17
42/1 42/17 45/14
46/24 51/13 52/12
53/9 66/18 69/1 71/4
thereafter [1] 89/11
therefore [11] 2/18
3/23 4/19 10/8 22/3
22/13 22/16 23/20
23/24 24/13 28/11
30/22 39/10 39/17
47/8 47/15 49/12
51/20 52/23 53/7 53/8
55/18 55/22 59/5 60/1
60/3 61/3 61/13 61/25
62/16 62/25 63/9
63/16 64/1 64/5 64/10
64/17 65/11 65/14
65/16 66/14 70/2
70/141 70/19 71/3
76/19 76/22 85/7
they [140]
they've [1] 61/16
thing [3] 5/2 75/20
75/22
things [11] 1/7 8/17
23/12 35/24 48/11
49/12 55/22 59/24
60/5 64/5 66/17
think [18] 1/4 1/20
1124 2/6 2/11 15/8
17/14 17/18 24/2 47/6
49/9 64/4 66/19 71/11
71/19 72/23 80/7 85/4
thinking [2] 43/14
44/1
third [11] 9/12 20/10
23/7 25/20 28/8 34/13
37/10 38/13 62/7
87/22 88/7
Thirdly [1] 86/6
this [135]
those [54] 1/16 1/19
2/4 5/12 8/22 9/8
44/15 11/20 13/24
14/25 15/16 17/5
23/16 25/14 26/14
29/17 34/5 40/1 42/22
43/21 43/23 45/4 45/5
47/22 48/4 49/3 50/6
50/15 52/6 55/3 55/14
60/11 61/10 64/3 66/2
52/8 82/9 89/3
thoughts [1] 66/18
thread [1] 73/18
three [24] 7/24 9/8
9/9 15/24 17/11 18/17
24/22 26/22 30/23
33/20 38/7 50/7 50/9
64/14 64/17 65/16
TAIT 73/11 74/5 75/9
75/10 75/12 79/10
86/17
three years [2] 30/23
33/20
through [10] 6/5 10/4
21/48 29/5 42/12
45/14 52/21 53/24
82/9 84/1
throughout [1] 4/23
throw [4] 68/20
tidy [1] 84/15
time [26] 2/17 3/15
41/11 13/4 15/19
18/14 33/13 33/15
33/24 35/9 38/5 39/8
39/9 40/16 44/2 44/11
44/15 48/23 49/16
49/25 62/9 63/12
63/17 65/20 84/11
89/10
timely [4] 7/21 16/9
87/21 88/6
times [2] 24/24 64/9
timescale [2] 15/11
89/7
timetable [3] 86/6
86/10 89/14
timing [1] 72/24
to [713]
today [14] 9/3 18/16
24/16 62/11 68/19
81/13 82/13 85/1
85/23 86/14 86/24
87/10 87/19 88/24
together [4] 1/4 1/10
top [1] 19/23
top-up [1] 19/23
topic [3] 14/22 15/14
16/6
total [6] 10/18 11/25
18/19 22/15 31/2 49/2
touch [1] 85/18
touching [1] 51/4
towards [6] 5/4 7/12
54/18 61/22 80/19
88/1
traditional [1] 87/24
train [1] 15/17
transcript [2] 27/2
32/14
transferred [1] 38/18
transparency [2]
41/18 45/18
transparent [1] 77/19
transparently [1]
86/25
transpires [1] 77/21
trauma [1] 44/14
tread [3] 55/25 56/3
56/4
treasury [4] 1/9 6/3
10/11 21/18
treat [1] 32/24
trespass [1] 81/20
trial [1] 57/9
tried [4] 21/9 21/9
49/24 73/21
trouble [1] 39/11
true [3] 14/7 20/7
30/8
truly [1] 2/22
trust [3] 54/15 74/20
TTS
trustee [1] 35/1
truthfully [1] 35/21
try [4] 25/7 56/14 63/6
74/8
trying [2] 46/25 76/16
tuned [1] 31/17
(43) terms... - tuned
INQ00001056
INQ00001056
T understood [2] 48/9 I 24/3 24/8 36/17 61/9 Iwalk [1] 89/20 52/23 53/18 54/9
tunnel [1] 85/24. 83/10 68/9 83/22 walker [1] 62/13 59/18 59/20 61/8
turn [9] 8/23 12/13 undertaking [2] 2/20 Iuseful [1] 85/9 want [8] 1/5 24/19 I 70/25 73/9 75/16
44/22 15/5 15/24 25/9 I 46/25 using [4] 6/20 25/12 I 64/4 66/17 68/20 76/20 82/21 82/22
30/20 34/12 77/19 IHnhemployed [1] TAIT 86/2 TTT 77/18 83/3 88/22
turning [5] 14/2 19/6 61/20 usual [1] 7/2 wanted [4] 4/12 36/22I well-being [1] 70/25
24/12. 54/17 78/15 I4Nexpectedly [1] usually [1] 61/8 63/25 81/22 went [3] 27/6 64/23
twice [1] 78/14 72/14 Vn wants [2] 5/1 84/8 I 80/4
unfairness [2] 30/10 was [93] were [78] 1/4 10/6
two [49] 4/7 4/22 1/25
4/13 18/16 23/11
29/11 35/23 39/7
43/11 43/13 43/25
54/22 55/3 56/6 60/1
62/23 70/20 77/24
two days [1] 60/1
two decades [2] 4/13
70/20
two years [2] 39/7
43/25
twofold [1] 4/23
type [1] 55/25
typical [1] 80/12
UK [1] 6/1
UKGI [8] 5/18 6/1
7/14 7/25 8/3 10/5
10/22 63/22
ultimate [3] 5/25 6/4
6/5
ultimately [4] 17/23
52/15 54/8 78/7
unable [2] 74/23 85/1
unacceptable [2]
4114 9/20
under [23] 2/1 7/7 9/8
9/25 13/5 21/22 23/20
25/19 25/22 26/1 26/5
32/13 32/23 33/9
34/23 35/7 38/17 42/5
44/6 47/23 57/12 66/5
67/25
underline [1] 16/23
underlying [2] 9/22
11/7
undermined [1] 3/2
underpinned [1] 6/14
understand [2] 50/5
52/4
understanding [2]
71/18 86/11
understands [1] 17/3
45/15
unfortunate [4] 51/12
81/21 81/25 82/11
uniformly [1] 46/4
unilateral [1] 20/23
unilaterally [1] 66/2
uniquely [1] 20/1
unless [2] 24/6 35/20
unnecessary [1]
87/25
unreasonable [1]
81/3
unreliability [2] 53/3
63/8
unreliable [1] 73/17
unrepresented [1]
37/6
unsafe [1] 17/10
until [4] 17/25 58/23
84/4 84/19
untoward [1] 81/1
unwell [1] 29/20
up [15] 3/5 11/41
19/23 31/14 36/13
45/11 53/12 59/25
62/24 67/24 80/9
81/15 84/16 85/23
89/20
update [7] 24/13 47/1
50/14 51/18 85/15
89/6 89/12
updates [1] 9/4
upfront [3] 52/12
52/16 52/17
upon [6] 15/7 24/23
54/7 57/7 66/18 85/18
urge [1] 77/12
urgently [2] 5/4 86/15
us [3] 25/6 54/12
65/10
use [6] 14/9 34/3
37/23 55/24 57/2 87/9
used [8] 11/14 14/8
vacated [2] 87/24
88/9
vacation [1] 89/9
vain [1] 21/9
valid [1] 77/23
value [1] 18/3
valued [1] 19/9
variable [1] 30/11
variety [2] 26/20 64/3
various [4] 1/15 57/6
85/17 87/13
variously [1] 58/10
vary [1] 29/8
vast [2] 17/8 62/4
vaunted [1] 77/8
vein [6] 25/5 52/1
56/4 57/19 59/18
84/17
verdicts [1] 65/4
versions [1] 32/24
very [37] 2/4 16/19
16/23 20/4 24/17
26/25 30/4 30/25
31/16 34/4 37/4 37/11
39/12 47/8 48/3 53/9
53/12 53/13 61/4
61/20 64/6 64/6 70/9
76/23 77/8 78/25 79/1
81/12 81/24 82/18
82/22 85/2 86/16
88/21 88/23 89/3
89/19
via [1] 38/43
viably [1] 6/6
vicious [1] 36/12
victims [2] 6/17 73/11
view [5] 4/25 12/10
14/19 28/21 48/23
Wo
waited [1] 9/18
waiting [2] 19/2 40/20
waive [1] 22/9
watch [4] 64/4
watching [1] 49/16
way [33] 4/24 8/22
13/16 13/23 20/21
24/18 22/22 33/24
42/21 42/21 43/15
47/4 53/6 55/3 55/9
64/12 68/21 69/3 70/3
74/8 74/19 75/21 76/4
76/8 78/3 78/9 79/17
83/5 84/5 85/21 86/13
87/1 87/24
ways [2] 69/25 87/13
we [171]
we'll [2] 2/11 26/5
we're [7] 50/6 58/24
59/6 60/21 68/7 69/10
70/9
we've [10] 34/20
43/15 54/23 54/24
60/23 77/3 80/14
80/20 88/23 88/24
website [3] 9/1 13/13
13/20
Wednesday [5] 1/1
1/4 59/17 75/1 82/7
week [12] 25/16
26/19 32/11 39/23
52/20 59/19 60/22
62/24 86/6 86/9 87/5
87/11
week's [2] 27/1 32/14
weekend [1] 69/12
weeks [10] 14/21
15/9 15/9 15/10 39/6
47/2 59/21 86/12
86/16 86/17
welcome [1] 82/14
welcomes [4] 4/19
14/23 17/7 19/13
well [22] 3/15 11/9
15/21 18/18 31/16
33/22 42/9 44/23 48/1
11/2 11/15 11/18
12/15 13/24 16/2 16/4
17/10 17/12 17/14
19/1 30/14 31/4 40/16
43/13 44/5 46/22 48/2
48/4 48/5 48/6 50/25
51/1 51/4 60/8 61/8
62/1 62/2 62/17 63/11
64/25 65/1 65/4 65/5
65/6 65/11 65/13
65/14 65/22 66/7
66/10 66/21 66/22
66/24 66/25 67/5 67/7
67/7 67/20 67/20
67/21 68/11 69/4 69/5
69/6 69/13 69/17 73/1
73/16 73/20 74/3 74/7
75/9 76/3 76/6 76/6
76/16 76/21 78/2
78/23 80/1 80/19 81/6
81/41 81/18 81/22
weren't [1] 67/1
what [45] 1/6 8/13
13/6 14/8 17/8 17/24
28/13 32/4 33/23
43/16 44/13 46/6 47/3
48/12 53/24 54/13
55/16 55/23 56/2 57/8
58/24 58/25 61/4 63/2
63/3 63/14 63/18
68/18 69/19 70/17
74/3 75/17 80/4 80/18
81/2 81/12 82/25 83/2
83/3 84/10 86/11
87/12 89/6 89/15
89/17
what's [2] 9/2 15/11
whatever [9] 4/24
4/25 8/19 33/20 41/20
49/14 69/16 69/25
81/19
when [32] 1/4 2/11
3/8 10/10 20/14 22/17
(44) tunnel - when
INQ00001056
INQ00001056
Ww
when... [26] 26/5 28/9
28/18 29/10 36/1 37/6
39/8 41/18 41/25
44/10 44/21 46/12
49/12 51/3 59/15 62/2
64/8 73/21 75/1 75/11
79/14 82/1 83/22
86/12 87/3 89/10
where [29] 4/12 7/6
17/2 19/12 27/10
28/18 29/10 30/17
30/18 32/9 35/1 35/8
37/2 41/11 44/25
45/21 47/15 49/14
54/13 55/22 57/20
59/2 59/5 64/11 65/15
65/21 73/15 76/25
78/18
whether [18] 4/5 14/3
14/16 29/6 36/4 43/8
43/14 47/19 58/12
64/22 65/23 79/25
80/4 80/8 80/17 85/12
88/4 89/5
which [78] 1/7 1/23
2/16 5/3 8/25 11/3
11/18 14/5 18/2 19/1
20/14 21/20 21/24
22/1 22/2 22/3 22/18
24/2 24/3 24/23 25/8
26/4 27/13 27/23 28/2
30/4 30/13 30/25
31/15 31/18 31/23
32/18 33/17 34/23
36/18 37/9 39/19
39/20 39/24 41/22
43/1 43/13 44/20
44/21 46/18 46/21
ATIN2 47/17 50/3
53/13 54/10 55/16
55/20 55/24 56/18
56/21 57/24 59/8 60/5
60/16 65/1 65/22
70/12 70/17 70/23
70/24 72/8 72/19 76/3
76/23 77/6 79/1 79/24
82/20 83/21 85/10
86/21 89/1
whichever [1] 55/9
while [5] 1/18 30/22
62/17 74/22 75/19
whilst [7] 5/3 6/16
10/22 42/20 46/8
49/25 72/14
who [58] 2/5 9/17
13/24 16/2 17/5 20/8
20/16 23/1 23/17 25/6
25/41 27/17 32/25
33/24 39/3 39/10
43/21 44/22 47/22
49/3 50/9 52/9 55/20
58/21 62/1 64/3 64/15
65/11 65/14 65/17
66/6 66/7 66/8 66/10
66/15 66/21 66/22
66/24 67/5 67/5 67/7
67/7 67/20 69/4 69/5
69/5 69/18 70/2 71/8
74/1 74/6 75/10 75/13
81/24 83/6 84/25
88/14 88/22
who's [4] 62/11
whole [1] 31/1
wholly [1] 45/9
whose [5] 16/17 26/8
44/3 49/7 75/9
why [9] 41/14 41/24
42N17 42/25 47/7
47/20 50/18 78/12
83/8
wider [1] 62/4
widespread [2] 26/16
73/14
wife [1] 44/13
will [101]
willing [2] 33/14
87/19
willingness [1] 63/15
wish [6] 27/22 31/21
38/24 40/21 55/25
84/19
wishes [1] 35/5
with [91]
withdrawn [1] 16/4
within [29] 4/6 5/2
5/21 7/23 8/3 9/16
11/48 14/21 15/8
20/25 26/17 29/4
32/10 34/11 42/2 47/2
66/11 67/5 67/7 68/12
68/22 80/1 86/5 86/6
86/9 86/15 86/16
88/14 88/18
without [10] 10/1
12/17 27/11 30/22
36/25 41/3 45/13
54/14 61/5 79/8
woefully [1] 79/12
women [3] 75/9 75/10
752
won [1] 61/21
won't [5] 24/23 26/10
33/25 62/19 72/19
word [2] 24/3 85/5
words [1] 89/3
work [8] 2/21 3/12
18/22 30/23 54/12
62/12 88/1 89/16
worked [2] 10/11 70/2I
working [7] 5/4 7/16
7/25 38/7 45/19 62/14
80/14
world [1] 45/24
worried [1] 60/9
worry [2] 59/11 59/12
worse [2] 2/23 79/4
worst [1] 43/5
worth [4] 5/15
would [74] 1/20 4/12
9/23 10/23 14/6 14/11
16/19 18/8 19/3 21/13
21/13 24/8 30/13 32/1
32/6 34/4 36/8 36/21
39/5 40/13 40/25 41/1
41/16 42/11 44/16
47/6 48/3 48/6 50/21
51/7 52/11 53/10 57/9
59/22 60/17 60/24
61/5 61/19 61/23
63/25 64/20 65/24
66/3 72/8 72/9 75/14
76/12 78/15 79/7
79/21 80/23 80/24
81/4 81/10 82/25 83/3
83/8 83/20 84/2 84/5
84/17 84/23 84/24
85/4 85/19 87/16
87/23 88/1 88/8 89/10
89/14
wouldn't [2] 32/3
42/10
wreaked [1] 53/3
writing [5] 49/16
80/15 80/20 82/3 89/2
written [17] 2/2 8/25
9/5 11/4 18/15 20/19
22/11 25/13 41/9 43/5
44/24 48/13 50/17
70/7 71/11 84/25 89/1
wrong [9] 11/2 34/4
39/13 50/6 66/3 71/19
TAI9 80/4 80/24
wrongful [2] 74/6
78/24
wrongly [6] 16/2 43/8
63/11 65/11 65/13
76/3
wrongs [2] 77/1 81/20
wrote [2] 15/8 82/:
year [9] 12/6 12/9
12/12 18/15 20/18
22/11 44/15 55/6
76/20
years [13] 3/25 30/23
32/23 33/20 33/20
39/7 43/25 59/12
61/19 62/14 69/19
70/16 74/18
yes [12] 24/10 24/10
34/17 57/17 57/19
66/20 68/14 68/23
TAIN4 71/22 71/25
83/19
yesterday [2] 24/6
85/16
yet [5] 67/7 74/19
79/2 80/14 85/13
you [139]
you're [1] 87/4
you've [1] 12/15
your [24] 4/19 24/1
34/22 34/24 35/1
35/11 35/15 36/17
36/19 37/22 37/24
38/1 38/1 38/2 38/10
38/11 48/23 48/23
56/3 60/1 71/11 72/7
83/10 83/11
yours [1] 24/4
yourself [2] 38/4
87/11
Zoom [1] 20/23
(45) when... - Zoom