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Tuesday, 19 December 2023 1 all participants in the Inquiry are cooperating
(10.08 am) 2 at all levels, Mr Beer.
MR BEER: Good morning, sir, can you see and hear 3. MRBEER: Thank you very much, sir.
us? 4 RICHARD DUNCAN ATKINSON (continued)
SIR WYN WILLIAMS: I can, thank you. 5 Questioned by MR BEER (continued)
MR BEER: Before we start, two things. I understand 6 MRBEER: Good moming, Mr Atkinson
the live link for those with log-in details is 7 A. Good morning
working, hence we can see and hear you, and 8 Q Canwe pick up topic 8, please, which is the
other people who have those log-in details will 9 topic we were about to move to which is,
be able to access this live feed, but the 10 cross-disclosure of Horizon issues.
YouTube link is not working at the present time. "1 Can we turn please to page 239 of your
It's been your practice in the past, 12 second report. I'll just wait for that to come
I think, to continue to sit because either the 13 up on the screen. At paragraph 668, you say:
YouTube link will be restored and a recording of 14 “As time passed, the number of cases where
now will be available, or people can read the 15 Horizon issues were being raised proliferated
transcript. 16 and the need for cross-disclosure between them.
SIR WYN WILLIAMS: Yeah. 7 should have become all too obvious. It is far
MR BEER: Then, secondly, can I say thank you to 18 from obvious that this was carried out,
David Enright, who gave me a lift to the station 19 however.”
this moming. As you know, he’s a partner at 20 Then further down the page, at
Howe+Co and represents many subpostmasters here 21 paragraph 670, you conclude that
and happens to catch the same train as me and he 22 cross-disclosure between cases where Horizon had
has enabled us to start nearly on time this 23 arisen was not being undertaken and that there
moming. 24 is "no evidence of routine cross disclosure
SIR WYN WILLIAMS: Well, 'm very glad to hear that 25 where Horizon evidence was relied on"; is that
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right? 1 "The relevance of such cross-case issues was
A. Yes. 2 highlighted in Mr Wilson's case by a letter from
Q._ Back in paragraph 19 of your report, no need to 3 his then MP, the Right Honourable Jacqui Smith
tum it up, you'd noted that you had seen 4 MP. In her letter to the [Chief Executive
discussions of the need to disclose in one case, 5 Officer] of the Post Office in December 2009,
in others where similar issues had arisen. 6 she referred to issues with the operation of
Beyond the form of words that we discussed 7 Horizon that had arisen in the case of
yesterday, was any such cross-disclosure in fact, 8 Mr Wilson, and similar issues that had arisen in
provided in any of the cases that you reviewed? 9 the cases of Hughie Thomas, Seema Misra and also
A. Notthat I saw. No. 10 referring to the Falkirk post office ..."
Q._In your Volume 2A report, if we can just turn "1 You say:
that up, please, EXPG0000005, at page 25, at 12 “It is pertinent to observe that if such
paragraphs 71 and 72, you're dealing here with 13 cross-case issues were obvious to Mr Wilson's
the case of Mr Julian Wilson. You say: 14 MP, they should have been alll the more obvious
“Despite this issue having been raised 15 to those concerned in the cases who played
before and at the time of Mr Wilson's plea ..." 16 a role in that of Mr Wilson
That's looking at Horizon issues in other 17 "there is no evidence that cross-case
cases, being this: 18 disclosure was considered."
“.. and at the time of Mr Wilson's plea, 19 So are you there making the point that
there is no evidence of cross-disclosure of 20 cross-disclosure was considered to be obvious to
other cases where complaints about Horizon, even 21 a layperson, in that case Mr Wilson's MP?
though the reviewing lawyers had personal 22 A. To someone who had knowledge of that -- of the
knowiedge of a number”, at least by reference to 23 fact that such issues had arisen in more than
the cases you've considered above. 24 one case, yes.
Then you say: 25 Q. Overall, how serious a failure did you regard
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the absence of cross-disclosure in the Horizon 1 beyond the very limited discussions that I saw.
cases that you looked at? 2 And I consider that to be a serious issue
Well, the case of Mr Wilson highlights it, in my 3 because they should have been considering
view, but in that case, counsel instructed for 4 whether there was disclosure to be made in
the Post Office to prosecute the case, both the 5 relation to the operation of Horizon anyway, but
person originally instructed when the case was 6 for them still not to be addressing it when they
charged and then the person who prosecuted it 7 knew that these issues were coming up and had
once it had reached court, both raised the 8 come up before, is a serious concern
question of whether the kind of issues that 9 Did you see any evidence of consideration of the
Mr Wilson was describing with Horizon had come. 10 issue and a reasoned decision to not give
up before because it's clear that neither of "1 disclosure?
them were aware that they had, but that they 12 No, and so, for example -- and I spotted
recognised, if they had, that was potentially 13 an error in my report, for which I must
disclosable. 14 apologise, in paragraph 667 I suggested that the
And so the position appears, therefore, to 15 same lawyer had dealt with the cases of David
be that the ~- those being instructed in these 16 Blakey and Tahir Mahmood at the charge stage.
cases recognised that the fact that an issue 7 I was wrong about that: it was Mr Singh in the
with Horizon had come up before was potentially 18 case of Mr Blakey and Ms McFarlane in the case
disclosable, and yet those who were responsible 19 of Mr Mahmood. But each of them then went on to
for the superintendence of disclosure in those 20 deal, in rapid succession, with a series of
cases, the in-house lawyers in the Criminal Law 21 further cases.
Division, who knew that they had come up before 22 For example Mr Singh dealt with the cases of
because they were dealing with these cases again 23 Ms Palmer, Mrs Rudkin and Mrs Misra,
and again, had not identified that this was 24 Ms McFarlane dealt with the cases of Ms Thomas
an issue even to be investigated for disclosure 25 and Ms Hall, each of which raised issues with
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Horizon, in the same way that the cases of 1 To give a parallel, one of the virtues of
Blakey and Mahmood had raised issues. And yet 2 the Treasury Counsel system is that, because
I didn't see in their correspondence with the 3 there is a small team who deal with these
Investigators anywhere them saying "It's 4 difficult cases, where one person has an issue
interesting that this person is saying they'd 5 ina case, someone else will have dealt with
had a problem with Horizon because we had this, 6 that issue before and that ~ and where there's
didn't we, last time and should we have 7 an issue that does arise in one case, they can
a conversation about that?" That would have 8 alert the others to watch out for it in other
been a step forward. 9 cases
That document can come down, thank you 10 This was a small team in much the same way
Does the point that you made in 667 of your "1 and the need for inevitability, perhaps, of
second report remain, that this was a small pool 12 sharing of experiences ought to have alerted
of lawyers? 13 them to the fact that this was a problem that
Yes. 14 went beyond one case.
What was the point that you were making on the 15 Thank you. Can we move to topic 9, which is the
back of it being a small pool of lawyers? 16 acceptance of pleas and, to start with, look at
The fact that it was a small pool of lawyers 17 something that you say in relation to Mr Singh,
meant that issues that were coming up in one 18 and it's a point that arises in a number of
case would resonate if they had come up before 19 cases. The point is whether the acceptance of
because there was only a few of them dealing 20 a plea to false accounting is a concession or
with those cases, and so the -- in one sense, 21 arguably a concession of the absence of
they didn't need to be told by anyone that this 22 sufficient evidence to theft. You address this
was something that needed to be looked at 23 on page 127 of your report. It's paragraphs 351
because they knew from their earlier experience 24 and 352. At the end of 351, you say that:
in cases that it was an issue to be dealt with. 25 "Mr Singh observed that ‘if Mrs Misra
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pleaded guilty to the false accounting [charges] 1 alternatives to each other or are referring to
then it is recommended that the prosecution in 2 or addressing different species of criminality?
respect of theft is not proceeded with.” 3 Yes.
Then 352: 4 You have also, I think, given evidence on the
“This was arguably a concession to the 5 last occasion that evidential sufficiency and
absence of actual evidence of theft and 6 public interest must be kept under review
consistent with an approach whereby theft was 7 throughout the life of a case?
charged to encourage pleas to false accounting.” 8 Yes.
Now, I think on the last occasion you 9 Does it follow from that that a change in
confirmed that the judgment of the Court of 10 circumstances may affect whether continuing
Appeal in Eden made it clear that it could be "1 a prosecution is in the public interest?
appropriate to charge both theft and false 12 Very much so.
accounting where they are either put as 13 In a prosecution pursued by the CPS, for
alternatives to each other or where they are 14 ‘example, if a defendant was willing to plead
both advanced to cover different forms or 15 guilty to one count but not another, would the
species of criminality? 16 CPS have to consider whether it remains in the
Yes. 7 Public interest to go to trial on the
Would you agree that that means that the mere 18 outstanding count?
fact that theft and false accounting are charged 19 Yes.
in the same indictment is not, of itself, 20 I think the -- at least the 2010 edition of the
improper, so long as there's sufficient evidence 21 Code, dealing with pleas and the acceptance of
and a public interest to charge both of the 22 pleas includes, amongst the factors to be
counts ~ 23 considered, the following: whether the court
Yes. 24 will have sufficient sentencing powers to match
~- and the two charges are either put as 25 the seriousness of the offending behaviour -
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Yes. 1 benefit to Mrs Misra, that he had concluded that
-- and the wishes and interests of the victim? 2 there was a realistic prospect of a conviction
Yes. 3 for theft of £74,609.84 when there was no
In a private prosecution, where there isn't 4 evidence that Mrs Misra had received £74,609.84.
an obligation to prosecute, even if the 5 So he had charged that, and false
evidential and public interest tests are 6 accounting, with no reference to the case of
satisfied, is a prosecutor entitled to consider 7 Eden, no reference to why both charges were
whether, in the light of a plea or a proposed 8 there, how one was an alternative to the other
plea, pursuit of the remaining count or counts 9 or how one reflected different criminality to
on the indictment is a proportionate use of the 10 the other, but had then said that he considered
private prosecutor's resources? "1 there was a realistic prospect of a conviction
Yes. 12 for theft but, if she pleaded guilty to false
Given those things, why is it that you consider 13 accounting, then that would be sufficient.
that Mr Singh's observation must necessarily — 14 And where there was no explanation as to how
in fact, I don't think you say “necessarily”, 15 he had reached a conclusion as to theft and
you say “arguably” - arguably amounts to 16 where on the face of the investigation report
a concession that there was insufficient 17 there was a limit to the evidence that there had
evidence of theft? 18 been theft, it struck me in those circumstances
Yes, and I don't say necessarily that was -- 19 that it was arguable, rather than necessarily
does reflect Mr Singh's position but, taking it 20 the case, that there was a recognition in his
as a starting point, Mr Singh had reached 21 mind that the case for theft was not strong and
a charging decision without setting out in any 22 therefore false accounting was sufficient and,
way the evidential basis for his conclusions, 23 if that was his mindset, given the lack of
which means it is not clear to me where there 24 evidence, I queried why he was charging theft in
was, on the face of it, no evidence of financial 25 the first place.
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Q. Thank you very much. So it might be that, even 1 a prosecutor when considering whether to accept
if there was sufficient evidence of theft, and 2 a guilty plea to some counts but not others, or
there was a public interest in prosecuting 3 to a lesser or a different offence, to consider
theft, it may not have been in the public 4 the impact on the court's confiscation powers?
interest or the Post Office's private interests 5 It would be reasonable to consider that, yes.
to proceed to trial with the theft account, if 6 So, in Mrs Misra's case, when the Post Office
there was a plea to false accounting, but you 7 was considering whether to accept a plea to
saw no reasoning to that effect — 8 false accounting or whether to proceed with the
A. Yes. 9 theft count, would the impact on confiscation
Q. ~onthe face of the papers? 10 have been a legitimate factor for the Post
A. Yes, and Ill be corrected if I'm wrong but "1 Office to consider as part of the balancing
I think Mrs Misra did then plead to false 12 exercise?
accounting and was still prosecuted for theft. 13 In the sense that, if the theft count reflected
Q Yes. That's exactly right. 14 the actual benefit to Mrs Misra of the money and
A. And I sawno analysis to explain that either. 15 an appropriation by her of the money, which
Q. Thank you. That can come down 16 could lead then to confiscation, if she were
Can we turn to considerations of 7 convicted of taking the money, through
confiscation. I think it's right that the 2010 18 a conviction for theft, on the one hand, and
iteration of the Code did not state that the 19 false accounting reflecting putting off the
availability of the court's powers to make 20 “evil day’, to use the words in Eden, to avoid
confiscation orders was a consideration that had 21 identification that there were errors that had
to be taken into account as part of the public 22 not involved her taking money on the other
interest test. I think that came ina later 23 through false accounting, the latter route
edition of the Code. That notwithstanding, 24 arguably not leading to confiscation
would it have been a proper consideration for 25 Was there any evidence that that was the kind of
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reasoning, that we've just explored, ever 1 of theft was selected without any explanation as
brought into account in Mrs Misra's case? 2 to the evidential basis for it, particularly in
A. No. 3 relation to an evidential basis for
Q._ Can we look more generally about the issue of 4 appropriation and/or dishonesty. And then there
accepting pleas to false accounting instead of 5 was a willingness to accept a plea to false
theft, and you address this on page 227 of your 6 accounting which carried with it a recognition
report. If that can be shown, please. 227, at 7 that there was not sufficient evidence of those
paragraph 640. In 640 you say: 8 elements of theft. It did raise the question as
“The approach to charging as between theft 9 to whether theft was being charged without
on the one hand and factoring on the other 10 sufficient consideration of those elements.
lacked consistency ... In a number of cases "1 And also because the charging decisions were
there was also a lack of [consistency] in the 12 such models of brevity, it was very difficult to
charging decision exhibited by the willingness 13 see how the thought process had been gone
to accept a plea to false accounting instead [of 14 through as to why theft was there as well as
theft." 15 false accounting, in these cases.
‘Are those comments limited to the particular 16 Thank you. Can we tum to page 229, please and
facts of one or more of the cases that you 17 paragraph 644. You say:
examined or are they a general point? 18 “However, the greater concem in a number of
A. [think more of a general point. 19 the cases [that] I have considered was that
Q. Can you help us then: why would a willingness to 20 evidence that the theft charge was used as
accept a plea to false accounting necessarily 21 a means to pressure a defendant into pleading
imply a lack of confidence in the evidential 22 guilty to false accounting, with conditions
merits of the theft charge? 23 attached to the acceptance of that plea ...”
A. Again, it doesn't necessarily reflect one but 24 I think you give three examples: Hughie
where, in case after case after case, a charge 25 Thomas, between paragraphs 645 and 647;
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Josephine Hamilton, 648; and then Alison Hall, 1 shown to have been taken, and to an undertaking
649 to 651. 2 not to criticise the Horizon system.”
Yes. 3 This appears, from the material you'd seen,
Three examples. 4 to have:
Yes, and one -- if one wanted a fourth, 5 *... followed from a discussion between the
Mrs Henderson would be in the same category. 6 principal Post Office lawyer, [Juliet] McFarlane
Allison Henderson too, thank you. If we can 7 and the Post Office agents in the prosecution in
just look at those, the three you've given in 8 which [Juliet McFarlane] said, "... we would
the report, starting with Hughie Thomas, Noel 9 proceed with false accounting providing the
Thomas. If we look at what you say at 10 Defendant accepts that the Horizon system was
paragraph 645 onwards, he pleaded guilty to "1 working perfectly ... Further instructions are
false accounting in September 2006, the theft 12 that the money should be repaid."
charge not pursued. 13 You say that:
‘The memorandum of the hearing noted: 14 "Mr Thomas .... reported to the Second Sight
“This was pursuant to a basis of plea which 15 Review that the approach taken was ‘aggressive
makes it clear that no blame was attributed to 16 and inappropriate."
the Horizon ... system. The defendant accepted 7 You say that, from the perspective of
that there was a shortage but he could not 18 a defendant, it should not be forgotten that
explain how it came about. He accepted that as 19 there is a very significant difference between
a subpostmaster he is contractually obliged to 20 theft and false accounting as outcome:
make good the shortage.” 21 "Theft by an employee in breach of trust, in
You say: 22 the period with which the Inquiry is concerned,
“In other words, the acceptance of this plea 23 was recognised ..."
was made conditional on the repayment of monies 24 You cite two cases, Barrick and Clark, from
which, consistent with the plea, had not been 25 the 1980s, establishing that:
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“... as an offence usually attracting 1 [you] have seen ... are the recovery of money
an immediate custodial sentence even in a case 2 and the protection of the reputation of the
with strong personal mitigation ... a defendant, 3 Horizon system.”
confronted by the evidence of loss deriving from 4 Ona scale of concern about the conduct of
the Horizon system and a lack of possible 5 prosecutions, where does what you identified
questions as to its reliability, would 6 there sit?
understand that a plea to an alternative offence 7 I recognise that it is always open to the
would increase the chances of them retaining 8 prosecution to consider whether, on a review of
their liberty, and it is reasonable to 9 the evidence and a review of the public
anticipate that they would receive legal advice 10 interest, in fact a plea to an alternative count
to that effect.” "1 meets the justice of the case. I also recognise
Does that include, for example, 12 that it is always open to the prosecution to
an anticipation or at least a hope of 13 consider a proffered basis of plea and identify
a suspended sentence? 14 whether that basis of plea is acceptable and, if
Yes. 15 it is not acceptable, to make that clear to
At 647: 16 those acting on behalf of a defendant,
“The Post Office submitted in the context of 17 What concerned me here was that the
the Second Sight Review ... that the decision to 18 discussions that I saw in the communication
accept the plea was reached in accordance with 19 involving Mrs McFarlane were investigating
the Code ... However, as was acknowledged, there 20 internally their view as to whether a plea to
is no evidence of such a review ... which in the 21 false accounting would be acceptable in a case
first instance did not follow the Code test. 22 where she had identified, at the charging stage,
Rather than a review of the evidence, the 23 there was a medium prospect of success and
prospects of conviction or the public interest, 24 identifying, in that context, the concerns being
the only matters raised in the material that 25 recovery of the money and no criticism of
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Horizon 1 case of Josephine Hamilton, and 649 and
It's ~ putting those factors together, it 2 following, in the case of Alison Hall?
seemed to me a reasonable reading of what 3A Yes.
occurred was that those involved from the Post 4 Q@ Thank you
Office side were identifying their conditions 5 A. I should just add, in relation to that, those
for a plea being accepted, which were conditions 6 cases, those of Mrs Hamilton and Mrs Hall, were
of the recovery of money, where there was no 7 considered by the Court of Appeal and the Court
acceptance by the plea that money had been 8 of Appeal took a very clear view of what they
taken, and a lack of any criticism of the 9 considered had occurred there, and the material
system, which was something that Mr Thomas had 10 that I saw did not, in any way, lead me to take
identified from interview on as being a concern "1 a different view from Lord Justice Holroyde and
on his part and would have been mitigation for 12 others.
him, 13 Q. That's paragraph 650 of your report, you're
And so that's a very long way of answering 14 referring to there —
your question, though I think it's a very real 15 A. Yes.
concer that, on the face of those facts, this 16 Q. —ifwe can tum to that on page 231. If we
was a plea that was being tailored to address 7 scroll down ~ thank you ~ you say:
concerns that the Post Office had, in terms of 18 “Adopting the language ....
getting the money and protecting their 19 That's you adopting the language of the
reputation of their computer system, rather than 20 Court of Appeal?
an assessment of the factors in the Code by 21 A. Yes.
reference to evidential sufficiency or the 22 Q. “... when it considered these cases, it was
public interest. 23 ‘improper of the Post Office to have made their
Thank you. Cutting it shortly, do the same 24 acceptance of a plea to a lesser alternative
issues arise in paragraph 648, concerning the 25 offence to theft conditional on the defendant
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not ‘making any explicit criticism of Horizon’.” 1 a computer error. To deny the defendant that
You say that it was improper of the Post 2 mitigation was ‘wrong’."
Office but who within the Post Office had 3 Can you just say what you mean there,
engaged in that improper conduct? 4 please?
Well, in each of those cases there were 5 A. It's, on the one hand, someone who has
documents that I saw that involved discussions 6 dishonestly and deliberately manipulated the
between those in-house — so the lawyers and 7 system and, on the other hand, someone who has
Investigators -- about, effectively again, the 8 been confronted by an error in the system that
preconditions or the necessary conditions for 9 they cannot understand but which they do
there to be a plea accepted by reference to 10 understand they will be held accountable for and
money and by reference to the reputation of "1 made to pay for and, in panic, has adjusted the
Horizon. 12 system to stave off the day when they know that
Thank you. So it's the lawyers on each 13 will be found out, on the other.
occasion? 14 {tis a significant potential difference as
Those are the persons whose emails I saw or 15 to how a judge will view their offending if they
memos I saw that identified those being the 16 are -- if itis a one-off result of panic
factors. 17 through something beyond their control. A judge
Thank you. Then the last sentence of that 18 is much more likely to view that sympathetically
paragraph, I think this is something that you've 19 and much more likely to consider that
mentioned a moment ago: 20 a custodial sentence is not required and, if
“It would ... have been a relevant, and 21 they are prevented from advancing that
likely a strong mitigating factor ... that the 22 mitigation, then they are being prevented from
falsification of records was to cover 23 putting forwarded a strong argument for them not
a shortfall for which the defendant was not, 24 going to prison.
responsible and may [instead] have been 25 @Q. Thank you. Lastly, over the page at
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paragraph 651, the Court of Appeal, in
Hamilton -- it's their paragraphs 113 and 147 —
said that it was ‘irrational and unjust’ for the
Post Office to have required that they ‘had the
money short of theft’ and the Court of Appeal
observed that:
[The Post Office's] conduct gives a firm
impression that the condition of repayment in
return for [the Post Office] dropping the charge
of theft placed undue pressure on Mrs Hamilton.
It gives the impression that {the Post Office]
was using the prosecution to enforce repayment.”
Did you find any material that undermined
the impression that the Court of Appeal formed?
No, and the words that her plea would be
accepted on her recognition that she had the
money short of theft were words from the lawyer
in the Criminal Law Department at the Post
Office and, again ~ and that was a discussion
in advance of Mrs Hamilton pleading to false
accounting.
‘And so, on the one hand, you have
an acceptance of a plea to adjusting records
that revealed a loss, rather than causing the
loss, in the sense of taking the money, through
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or email or terms of reference to provide the
expert with instructions upon what it is that
his or her opinion is sought, setting out the
issues or questions that the expert is expected
to address or to answer; to provide explicit
guidance as to what it is the expert is being
asked to do and the material they are being
asked to consider in order to do it; to set out
the material upon which reliance has been placed
in the prosecution and which may be relevant to
the questions that the expert is expected to
answer; to inform the expert of their duties
under the common law and the Criminal Procedure
Rules; to make sure that the expert not only
understands their duties, but that they had
complied with the duties in order to ensure that
the expert's evidence was admissible; and,
lastly, to satisfy themselves that any material
or any literature of which the prosecutor was
aware, and which might undermine the expert's
opinion, was reviewed by the prosecution and
disclosed to both the expert and to the defence.
Yes. Those — the duties on the expert were
well established before the Inquiry's period
started, the responsibility of the person
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the acceptance of false accounting, rather than
theft, and yet it being a condition of that that
the individual in the criminal proceedings be
made liable for paying back money that you are
accepting they have not taken.
There may be a separate, civil discussion as
to whether, under the postmaster's contract they
were required to make good a loss that they had
not caused but this is in the criminal
proceedings, making it a condition or pursuing
criminal mechanisms in order to get money that
you are accepting they have not taken.
Thank you. Can we turn to topic 10 ~ that can
‘come down, thank you. The last topic is expert
evidence
Can we start by way of a recap of your
previous evidence to the Inquiry. You said that
a prosecutor intending to rely on expert
evidence in criminal proceedings was, during the
relevant period, subject to the following
obligations -- and this is just by way of brief
recap to the questions I am going to ask -- to
satisfy themselves that the expert had been
appropriately instructed, including by the
provision of a detailed letter of instructions
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instructing an expert, the lawyers instructing
an expert, to communicate those duties to the
expert to make sure the expert understood them,
evolved over the period of the Inquiry but, from
quite early in the period, it was again clear
that that was what was required of them.
Yes. In the five case studies in which the Post
Office obtained evidence from Mr Gareth
Jenkins -- that’s Thomas, Misra, Allen, Sefton
and Nield and Ishaq ~
Yes.
~ forgive the use of the surnames -- did you
identify any document or evidence that
demonstrates that Post Office prosecutors or,
later, those acting on their behalf from
Cartwright King, informed or instructed
Mr Jenkins about the duties of an expert?
No.
Did you see any evidence that such prosecutors
were themselves cognisant of the existence of
any of these duties?
No.
Did you see any evidence that they complied with
any of these obligations in their dealings with
Mr Jenkins?
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No. 1 been provided and considered, assumptions which
Did you see any instructions to Mr Jenkins which 2 are material to the opinions expressed?
might conform in any way with a written form of 3 Information relating to who carried out any
instruction that a prosecutor ought to provide 4 examinations or the methodology used and, if
to a person whom it is proposed to give expert 5 they weren't carried out by the expert
witness evidence? 6 themselves, the extent to which there was
No. 7 supervision?
In relation to the evidence that Mr Jenkins 8 Whether there was a range of opinion in the
himself gave, you told us previously about 9 matters dealt with in the report, a summary of
a case in 2006, and then the Criminal Procedure 10 that range of opinion and reasons for the
Rules Rule 33, which came into force in November "1 opinion given?
2006, that there were a number of necessary 12 Relevant extracts of any literature or other
inclusions in a report? 13 material that might assist the court?
Yes. 14 Then, finally, a statement from the expert
We've looked just now at duties on a prosecutor; 15 that they had understood and complied with their
we're now turning to duties on an expert 16 duty to the court to provide independent
themselves. Did they include -- I'm going to 7 assistance by way of an objective and unbiased
summarise them all -- detail of the expert's 18 opinion.
academic and professional qualifications, 19 Yes.
experience and accreditation insofar as they are 20 Were they the necessary inclusions in the report
relevant to the opinions expressed? 21 itself?
Yes. 22 Yes.
A statement setting out the substance of all the 23 In the five case studies that you have
instructions received, the questions upon which 24 considered, did you find that the witness
an opinion is sought, the materials that have 25 statements served by Mr Jenkins set out any of
29 30
those matters that I've mentioned, that are 1 those were not normally set out and there was
necessary inclusions for an expert report or 2 never a statement identifying that he recognised
an expert statement? 3 the duties that were imposed upon him.
In most of his statements he did set out his 4 Thank you. Did you see any evidence that the
qualifications, in some instances, or at least 5 Post Office informed Mr Jenkins that the printed
in one instance, those who were receiving the 6 statements should contain those necessary
statement from him, the lawyers at the Post 7 matters?
Office, did ask him to do that. To an extent, 8 No.
he set out the questions that he'd been asked, 9 Did you see any evidence that the Post Office
in that he would identify what he was making the 10 and, later, lawyers at Cartwright King, were
statement about, but he would not set out the "1 aware that an expert report or an expert
details of what had been asked of him. 12 statement should contain those necessary
He did not, I think, usually set out what 13 inclusions?
materials he had been provided with or what 14 I never saw any material that I can think of
sources of information he was relying upon. 15 that involved the discussion of that to tell me
Insofar as that was the work of others beyond 16 whether they appreciated that or not. They
himself, that was not identified by him. 17 certainly didn't say they did.
Insofar as there was a range of opinions and/or 18 When you gave evidence on the last occasion, you
contrary views or material that was capable of 19 told us that, even with those experts who were
undermining his opinions, that was not set out 20 trained, accustomed and made their living, or at
at all. 21 least in part made their living, from giving
In terms of literature, which would include 22 expert evidence, ie even if you were preaching
expert reports that he had seen in earlier cases 23 to the choir, a prosecutor had to make sure that
in relation to Horizon and which would include 24 the expert understood what their duties and
his own expert reports in earlier proceedings, 25 obligations were; is that right?
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Yes. 1 Q_ So his day-to-day work was as a software
You emphasised that, in relation to an expert 2 engineer or a computer engineer, rather than
who was not functionally independent of the 3 a professional witness?
prosecutor, that it was all the more important 4 A Yes.
that they understood the nature of the role that 5 Q@ He wasn't, I think you know, a member of any
an expert performs and that they properly 6 expert witness institute or similar?
understood what the requirement of independence 7A. I certainly don't recall him listing any such
actually entailed? 8 membership.
Yes, and not least because the expert would need 9 @ Would you agree that the heightened duty applied
to demonstrate that independence and so they 10 in particular because he was not independent of
needed to be reminded to set out the basis upon "1 the subject matter of his evidence --
which it was so demonstrated. 12 A. Absolutely.
Was Mr Jenkins one of those witnesses in respect 13 Q. —he was, in part, speaking about his own work?
of whom there was that heightened duty to ensure 14 A. Yes. His own work and the work of his employer.
that they understood the nature of their expert 15 @. He wasn't, would you agree, functionally
duties and, in particular, what the requirement 16 independent of the prosecutor?
of independence entailed? 17 A. No, because of the interrelation between the
Yes. 18 product that he was talking about and the
Was that because he was not a professional 19 application of that product by the prosecutor.
expert witness? 20 @. Have you seen anything in the material to
It was ~ yes, it was because he was giving 21 suggest that the Post Office or, later,
evidence of something outwith the knowledge of 22 Cartwright King lawyers understood the
the jury, because it was something about which 23 heightened need to ensure that Mr Jenkins
he had knowledge because he worked with the 24 understood his duties as an expert, in
people whose software it was. 25 particular the especial need for independence
33 34
and demonstrating independence? 1 @ Yes.
They understood the - how it might look, in the 2 A. That which I had seen before was a cause for
sense that in the conversations that we looked 3 concern. That which I have seen since
at in emails leading up to the generic statement 4 heightened those concems considerably.
in 2012, there was discussion about whether it 5 Q@ Can! summarise them: did you find that there
was -- it might be better to have someone 6 was a lack of formality in the communications?
independent of Fujitsu, rather than working for 7 A. Yes.
Fujitsu, delivering that statement, That was as 8 Q_ Did you find the guidance given to him to be
far as it went, 9 adequate or inadequate?
So recognising the lack of independence but then 10 A. Inadequate.
not taking the next step: what do we do to 11 Q@._Did you find some of the language used to be
address it? 12 appropriate or inappropriate?
Yes. 13 A. Inappropriate.
Before we look at any of the communications 14 Q._ Did you find that, whether any of the
lawyers had with Mr Jenkins, did you observe 15 instructions given had, as their intent, the
that some of them ~ and this is communications 16 service of the Post Office's interests, rather
between lawyers and Investigators, on the one 17 than the provision of an independent opinion?
hand, and Mr Jenkins, on the other ~ were 18 A. Yes.
inconsistent with how a prosecutor ought to 19 Q@. Aswell as some of the communications being
address and to communicate with an expert? 20 inconsistent with the way a prosecutor ought to
Yes, I should say that I have seen a lot more in 21 approach an expert, did you find any of them to
terms of communications between those at the 22 be the opposite of that, ie the antithesis to
Post Office, on the one hand, and Mr Jenkins, on 23 it?
the other, within the last week than I had 24 A. Yes.
before, 25 Q. Ifit's right that the Post Office or its
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agents, Cartwright King, later, did not provide 1 prosecution policy reflected in the Post
Mr Jenkins with written instructions that 2 Office's practice, as you saw it, in the case of
conform to the requirements that we've 3 Mr Jenkins?
mentioned, didn't provide Mr Jenkins with 4 Yes.
instructions as to his duties as an expert and 5 The things we've spoken about, so far, were
none of the statements included the necessary 6 failures of omission, things that the Post
elements that we've identified, would you be 7 Office didn't do or its lawyers did not do. Did
able to draw an overall conclusion that there 8 you identify any material in the five case
was a fundamental failure by the Post Office 9 studies, that prosecutors and Investigators
properly to instruct Mr Jenkins as an expert? 10 ‘communicated with Mr Jenkins, that were
Clearly, that's ultimately a conclusion for "1 inconsistent with the approach that a prosecutor
others than me but, certainly, it is not 12 ought to take: so worse than mere failure?
a conclusion from which I would dissent at all 13 Some of the emails that we considered yesterday,
With the limitation you've just included, was 14 where, on the face of them, they were telling
that a persistent failure? 15 the expert what to say and telling him what not
Yes. 16 to say, that, I think, goes beyond an omission.
You told us back in your first report ~ it was 7 In material that I've seen, again, since the
paragraph 67, no need to turn it up -- that 18 end of last week, there are examples of
there was "no prosecution document that I have 19 Mr Jenkins’ statements being rewritten by
seen that gave guidance as to what an expert 20 Investigators and lawyers at the Post Office, in
being instructed needed to address". 21 the sense of them saying, "Can you take that bit
No, Post Office document. 22 out, please?" or "That bit doesn't sound good;
Yes, no Post Office document. 23 can you say something else?”
Yes. 24 This is in relation to the evidence of
Was that absence of a framework within 25 an independent expert, that is the role that
37 38
Mr Jenkins was being advanced to perform and, 1 far go to the admissibility of Mr Jenkins’
whilst itis entirely right and proper for 2 evidence?
an Investigator or a prosecutor dealing with 3 They ~ by, for example, removing aspects of his
an expert to say, "I don't understand that 4 statements, which were parts that qualified his
paragraph, can you elucidate it?" or "Can you 5 opinion or identified contrary views to his
think about this section in the light of this or 6 opinion, they resulted in those -- the final
that that you haven't seen, or this or that that 7 versions of the statements, no longer complying
you say further down", that is different from 8 with the requirements for an admissible expert
saying, "That bit is going to give rise to 9 statement. And they also, in various respects,
disclosure issues” or "That bit is going to 10 removed the independence of its contents and so,
cause us problems, can you take it out”, or just "1 yes, it clearly affected its admissibility, had
deleting it, in the way they did, from the 12 any of that been appreciated by anyone who that
drafts 13 the opportunity to question its admissibility
Yes, sometimes they wrote "Can you do X", "Can 14 In order to put that person in a position to do
you delete”, "Can you add”, "Can you rephrase", 15 0, disclosure of the communications would have
and sometimes they simply cut it out? 16 been necessary?
Yes. 17 Yes.
The issues that you identified where the 18 Did you see any evidence at all that such
evidence was amended, deleted or tailored in 19 communications between Investigator and lawyer,
that way, did they go to Horizon integrity 20 on the one hand, and Mr Jenkins, on the other,
issues? 21 were disclosed in any of the five cases?
Absolutely. 22 No.
How serious, in your view, was this conduct? 23 Did you see any evidence of any formal request
Extremely. 24 from the Post Office to Fujitsu for third-party
Did any of the issues that we've identified so 25 disclosure about the matters that Mr Jenkins was.
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referring to? So, to take an example, the 1 Can I start, then, with Lisa Brennan, This
locking issue, which caused transactions to be 2 is paragraph 46 of your Volume 2 report, which
lost, or the record of system errors, the Known 3 is on page 24. There is no need to tum it up
Error Log: did you see any communications at 4 for the moment.
that level? 5 In general terms, you there are critical of
No. 6 the failure to conduct a fuller financial
Did you see anything to suggest that the Post 7 investigation as to any financial benefit to
Office pursued such issues with the Fujitsu Head 8 Ms Brennan of the conduct that was alleged
of Legal, despite, on occasions, that channel of 9 against her, yes?
communication being used? 10 Yes.
{can't think of any, no. "1 As you said yesterday, investigating a suspect's
Thank you. Can I turn, then -- that's the ten 12 financial records was a reasonable line of
topics over -- to the case studies. 13 inquiry?
Your reports address 22 case studies and 14 Yes.
your evidence speaks for itself. It's been 15 During the period 2000 to 2013 would ordinary
disclosed to all Core Participants and is 16 theft and fraud cases be prosecuted in the
available on the Inquiry's website. I'm not 7 public sector, eg by the police and the CPS,
going to go through each of the 22 case studies 18 without any enquiry of this sort having taken
and, instead, only cover those where one of the 19 place?
Core Participants has asked me to ask questions. 20 I'm sure there well have been some but,
of you by way of challenge to what you say — 21 certainly, my experience is that “follow the
Yes. 22 money’ is a mantra for those dealing with any
-- or where one of the Core Participants has 23 form of financial crime and so they would
asked for additional context to be given to what, 24 normally look because, if they found evidence of
you do say in either of your reports. 25 the money, for example, going into someone's
a1 42
bank account, that would be quite good evidence. 1 conviction?
Yes, so you'd want to do it as a prosecutor 2 That would be a fact-specific assessment in
trying to prove your case? 3 terms of where the financial inquiry was and
Absolutely. 4 what material had thus far been generated by it.
But you ought to do it, I think you told us 5 But, clearly, if there was — if a prosecutor
yesterday, as a reasonable line of inquiry 6 was satisfied, despite the fact that the
because it might assist the defendant too? 7 financial inquiry was ongoing, that there was
Yes, 8 a realistic prospect of conviction, then they
Because an active and healthy financial 9 would be entitled to reach an assessment,
investigation which produced nil returns, it 10 providing they were also satisfied that what was
might be powerful evidence for a defendant to be "1 outstanding didn't have a bearing in the public
able to deploy? 12 interest assessment.
Yes, especially if they have, in interview, said 13 I think you would agree that, in a charge of
in terms "I didn't take the money’, that raises 14 theft, i's sufficient to prove the fact of the
the reasonable line of inquiry of, well, did 15 theft, whether by direct evidence or
they? And the obvious place to look as to see 16 circumstantial evidence, without also, in fact,
whether they've got it and whether that be a new 17 being able to show where the money went?
speed boat or the money in the bank, you have 18 Yes.
a look. 19 Was your experience in looking at these papers
Was it usual in that period, 2000 to 2013, for 20 that such financial enquiries that were made had
charging decisions to be made in cases 21 as their focus not proving or disproving theft
prosecuted by the CPS, whilst financial 22 but recovery of proceeds for the benefit of the
inquiries were outstanding, if it was 23 Post Office?
nonetheless the case that there was sufficient 24 Yes, in some cases it wasn't very clear what
evidence to provide a realistic prospect of 25 they had made the financial enquiries that they
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did make for, because there would be a reference 1 position than she was, either at the point of
in an investigation report to the fact that 2 the charging decision or before the jury?
they'd asked the postmaster for consent to 3 ‘Only if it could have confirmed that they had
access their bank account, they'd obtained that 4 looked and not found any evidence that she had
consent, they may have obtained some bank 5 benefited financially and/or confirmed that she,
statements and then there'd be no further 6 if this were the case, had made, attempted to
reference to them, and so it wasn't quite clear 7 make, repayments at an earlier stage of losses,
what they'd done with them. 8 andior if it confirmed that she was not in
But where there was more intensive 9 a position where she needed to steal the money,
examination of the finances, it did appear to be 10 those things would have further supported her
by Financial Investigators preparing for "1 case, not least because they were coming from
confiscation, rather than Investigators 12 the prosecution, rather than, for example, just
preparing for prosecution. 13 from her.
Would you agree that, in the context of a fraud 14 Thank you. That's all I ask in relation to Lisa
involving the alleged theft of cash of the type 15 Brennan's case.
alleged in Lisa Brennan's case, that the absence 16 1am going to move over the cases of David
of evidence of her having the missing money 7 Yates, David Blakey and Tahir Mahmood and turn
could not exclude the possibility that she did, 18 to the case of Carl Page and, in particular,
in fact, take the cash? 19 your consideration of his case at page 58,
It couldn't exclude it, no. 20 paragraph 146 to 148 of your report.
Given that the case was left to the jury on the 21 Page 58, please, paragraph 146.
basis that there was no evidence of her having 22 Between paragraphs 146 and 148, you raise
the money, how, in your view, could 23 some criticisms based on your understanding,
an investigation of her finances by the Post 24 I think, from the Court of Appeal Criminal
Office have placed her in a more advantageous 25 Division's judgment in Hamilton, that the
45 46
prosecution had changed its case between the 1 based on what the Court of Appeal Criminal
first and second trial 2 Division had said in Hamilton?
Yes. 3 In part, also based on the assessment in the
The Inquiry has heard some evidence since the 4 Second Sight review, which was to the same
Court of Appeal's decision from Wanwick Tatford, 5 effect.
the prosecution junior to Mr Stephen John at the 6 That's paragraph 147 that you're referring to
first trial and sole prosecuting counsel at the 7 there?
second trial. He has told the Inquiry that 8 Itis, yes.
there were two counts in trial 1, the first 9 Other than those tertiary sources ~ or
count was an alleged conspiracy to defraud 10 secondary sources ~ did you see anything in the
between Mr Page and Mr Whitehouse in relation to "1 contemporaneous papers to suggest that there had
foreign currency, involving the use of a Forde 12 been a material change of case between the two
Moneychanger and not Horizon — 13 trials?
Yes. 14 I saw a transcript of the evidence or, more
-- and a second count of theft of £282,000, 15 particularly, cross-examination of Mr Page at
alleged against Mr Page alone, based on an audit 16 the first trial, which was very much to the
shortfall and, therefore, based on Horizon. 17 effect that he had stolen foreign currency and
Both defendants were acquitted on Count 1 at 18 that that was the basis upon which the theft
the first trial, jury unable to reach a verdict 19 charge appeared to be presented there, which was
on Count 1 at the first trial, therefore there 20 how Second Sight characterised it in their
was a retrial on Count 2 alone against Mr Page. 21 review.
Yes. 22 So there was that material, contemporaneous
As such, the second trial was a retrial and did 23 material, that accorded with what they were
not involve a change of case. Was your 24 saying had been the prosecution's case at the
conclusion that there had been a change of case, 25 first trial, which was not its case at the
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second trial. I can't, off the top of my head, 1 revised report, included the CCRC referral
remember anything else but I didn't see 2 document?
anything, equally, that would positively say 3 Yes.
that the case had not changed in the sense of 4 The reference to which ~ we needn't display it
a review between trial 1 and trial 2, as to how 5 ~ is POLO0121224. Did your view remain that
the case would now be put in the light of the 6 the case was poorly investigated?
acquittal on Count 1, first time round. 7 Yes.
Does anything that I have said in relation to 8 Did your view remain that, in particular,
what Mr Tatford has told the Chair change your 9 Mrs Adedayo’s account was not explored or
view in relation to this aspect of the case 10 examined by the Investigators or the
against Carl Page? "1 prosecutors?
Clearly, I haven't considered what Mr Tatford 12 Yes, and, in that regard, I focus on the account
had to say. All I can say is that the material 13 that she gave at the time. I've seen what she
that I saw -- and I can only speak to that ~ 14 has said about that since, but I focus purely on
didn't cause me to take a different view to 15 what she gave as an explanation to the
either Second Sight or, more pertinently, the 16 Investigators at the time, which was an account
Court of Appeal, as to the fact that there had 7 that required investigating,
been a change of case. 18 Was it incumbent upon the Investigator,
Thank you. Can I turn to Oyeteju Adedayo's case 19 Ms Bernard, to have investigated that account to
please. You pick this up at page 66 of your 20 see, for example, whether there had been any
report 21 payments to third parties by Ms Adedayo?
Yes. 22 Yes.
-- paragraph 169 and following. I think, 23 Would that have been a relatively
amongst the material that you've seen since the 24 straightforward exercise?
preparation of your original report and this 25 I would have thought so. I'm not a Financial
49 50
Investigator but, yes, I'd have thought so. 1 suggested, yes.
Did you read the transcript of the interview of 2 When she gave evidence to us, the Investigator,
Mrs Adedayo? 3 Natasha Bernard, said that she viewed it as
Yes. 4 inconsistent and confusing, and she said that
I wonder whether we can do this without tuming 5 it's quite clear from her report that she didn't
itup. Would you agree or disagree with the 6 believe what Mrs Adedayo was telling her.
suggestion that, when asked open questions, 7 In certain respects, yes, I agree with that.
Ms Adedayo appeared incoherent in some of her 8 Given the equivocal nature of what was being
answers? 9 said, would you agree that that added an impetus
They weren't easy to follow. 10 for the case to be properly investigated?
Did you find that the account that was "1 Yes.
ultimately attributed to her in the 12 There wasn't any clear evidence of a theft and
Investigating Officer's report was one that had 13 a contradictory or internally inconsistent, in
been extracted through closed questions to her? 14 some respects, baffling confession.
Yes, I think that's a fair characterisation. 15 Yes.
There was -- when open questions were asked 16 Would that have been a questionable basis to
initially, the account she gave was not clear 17 prosecute?
and more -- more closed questions were then 18 Without that being resolved, yes.
asked, from which a clearer account was derived. 19 If we look at paragraph 181 of your report,
But, clearly, it was a clearer account based on 20 please, which is on page 70. Last sentence, in
what she was agreeing with. 21 the light of what you said earlier in
Would you agree or disagree with the suggestion 22 paragraph 181:
that the account overall was internally 23 “In Mrs Adedayo's case, that reliability was
inconsistent and confusing? 24 not an issue, and non-disclosure relating to the
I can certainly understand why that would be 25 operation of Horizon potentially less of
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an issue as a result."
‘Are you there essentially adopting the same
approach as the Court of Appeal Criminal
Division.
A. Yes, I hope so.
Q. Thank you very much. Can we turn to Mr Thomas’
case next, please.
SIR WYN WILLIAMS: Before you do, Mr Beer, can
I just understand what went on in Mrs Adedayo's.
case. Her conviction was quashed by Southwark
Crown Court; that's correct, isn't it?
A. Yes.
SIR WYN WILLIAMS: So this is purely technical but
where you write that she pleaded guilty at the
Crown Court, I don't think can be right, can it?
Presumably what happened, she pleaded guilty at
the Magistrates Court but was then committed for
sentence?
A. That must be right, yes, sir.
SIR WYN WILLIAMS: That's just a mere technicality.
But what's of more interest in her case is
that there's no real rationale, is there, in how
her conviction was quashed or why it was
quashed, because we haven't got a formal
judgment of the Southwark Crown Court; is that
53
described to me and the judge didn't determine
the issue between them?
A. No, that's right, sir
SIR WYN WILLIAMS: So am I right in thinking that
the only objective -- by which I mean
independent of Mrs Adedayo or the Post Office ~
assessment is that which we currently have, is
that which is contained in the reference by the
Criminal Review Commission?
A. Yes.
SIR WYN WILLIAMS: Yes, fine. Thank you.
Sorry, Mr Beer, I wanted to be clear in my
mind about this case.
MR BEER: Yes, thank you.
I think the document that you saw was
a transcript of the hearing at Southwark Crown
Court in front of Her Honour Judge Taylor —
A. Yes.
Q. ~of 14 May 2021. That ends ~ the hearing
starts at 10.47. Do you want to just have
a look at it? I'm not sure we're going to be
able to display this.
I think it's Volume 1 of the Rule 10
material at tab D32.
‘A. Thank you very much. Yes, thank you.
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correct?
A. We have a transcript of the hearing at which it
was indicated by counsel acting for the Post
Office that, although they didn't accept the
reasons that had been advanced on Mrs Adedayo's
behalf for why her conviction should be quashed
they nevertheless considered that it would be
contrary to the public interest to seek to
uphold her conviction and so they didn't oppose
her appeal.
There was no judgment given, and I'l be
corrected if I'm wrong about it, no judgment
given by the Recorder of Westminster who
presided over that hearing, separate from that,
but -- and so the transcript is less than
helpful as to exactly why it came about that
Mrs Adedayo’s conviction was quashed.
Certainly the Post Office made clear they
didn't accept a good deal of what Mrs Adedayo's
case, as considered by the Criminal Cases Review
Commission, had been.
SIR WYN WILLIAMS: So, in effect, at court, there
was an issue which was unresolved by the judge.
Mrs Adedayo's case was presented in a particular
way, the Post Office said what you've just
54
Q. Is that the relevant transcript?
Itis, yes.
Q. The hearing starts, we can see on page 2, at
10.47. Ms Carey, I think that's Jacqueline
Carey, appears on behalf of the prosecution, and
speaks over pages 2, 3 and 4, and then
Mr Moloney, who appeared for both appellants,
says a few words, ten words or so.
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A. Yes, he was largely inaudible, apparently.
Q._ Yes, which is no doubt due to the recording,
rather than Mr Moloney.
A. Sure.
Q. There's then a discussion or something that Her
Honour Judge Taylor said, which concerns
jurisdiction,
A. Yes, because Mrs Adedayo had pleaded guilty in
the ~ and so you're entirely right, she pleaded
guilty in the Medway Magistrates Court to the
offences and was then sent to the Crown Court,
to Maidstone Crown Court for sentence. So,
procedurally, her guilty pleas had to be set
aside before her conviction could be quashed and
0 that's the discussion at the end
Q. Then the hearing concludes with this, Judge
Taylor saying
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“Thank you. In these appeals of Mr Kalia 4 SIRWYN WILLIAMS: Thank you, yes.
and Ms Adedayo, the Court finds that the effect 2 MRBEER: Can we tum on to Mr Thomas’ case then,
of Section 11.2.4 of the Criminal Appeal Act 3 please. This is paragraph 198 and following of
1985 are such that they do not have to apply to 4 your report on page 76. In fact, we needn't
set aside their guilty pleas. We adopt the 5 tum this up, I can deal with this without
background (inaudible) to these cases, which is 6 looking at this material. In paragraphs 193,
set out in Hamilton v Post Office [and the 7 198 and 213 of your report, in the context of
citation given ]. Whilst it is not conceded by 8 Mr Thomas’ case, you examine the preparation of
the performance that these are (inaudible) 9 a witness statement by Gareth Jenkins.
cases, in terms of judgment the appeals are not 10 Yes, I think the first witness statement he
opposed (inaudible), will not be contested and, "1 made.
in the public interest (inaudible). Their 12 Exactly. You say at paragraph 198 that
sentences have been served and we hope that 13 consideration of the reference material,
(inaudible) they can put this behind them and 14 ie material that was referenced in the "Gareth
continue with their lives without the shadow of 15 Jenkins Chronology", is necessary. We mentioned
a conviction. Any other applications ..." 16 the nature and status of that document
It says "Mr Carey’. 7 yesterday.
A. Yes. 18 Yes, that's right.
Q._ It should be Ms Carey. 19 So can we look at the reference material and,
A. Yes. 20 indeed, some other underlying material in
Q._ She says, "No thank you". 21 chronological order. Can we start, please, with
Is that the extent of a judgment determining 22 FUJ00122203. Can we look at page 6, please. If
the appeal? 23 we scroll down, please, we should see
A. Yes, itis 24 an email -- we can -- from Graham Ward -- and
MR BEER: Sir, I hope that helps. 25 it's a generic email account ~ to Fujitsu of
87 58
10 March 2006. This appears to be the original 1 scroll down ~ thank you —- we should see
or originating form of instruction from Mr Ward 2 an email from Mr Pinder to Mr Jenkins, with
of the Post Office to Fujitsu. If we just 3 a heading "Fujitsu Statements Gaerwen":
scroll down, please, and go on to page 7, he 4 “As discussed please see extract from
says: 5 a recent email below in italics from Graham Ward
“On a separate matter, I also require 6 ”
a witness statement in respect of the following 7 We've just looked at that email.
ARGS ... all of which relate to the Gaerwen 8 Yes.
SPSO." 9 *... regarding provision of a statement about
That's Mr Thomas’ branch on Anglesey. 10 nil transactions and online banking. If you are
A. Yes, that's right. "1 able to put something together for us I would be
Q. "We need the usual (leave out paragraphs H(b) 12 very grateful. If you send it back I will
and J, but we do need paragraph K (call logs) 13 arrange for Neneh or Penny to write into
covering an analysis over the period 01/11/04 to 14 a statement for your signature.”
30/11/05. Penny ~- you may recall this one 15 Then you will see the relevant part of
which relates to nil transactions ... Can you 16 Mr Ward's email cut in to this email and the
had an extra paragraph in your statement 17 part in italics:
explaining how online banking transactions are 18 "Can you add an extra paragraph in your
processed and the data downloaded and how nil 19 statement explaining how online banking
transactions can occur." 20 transactions are processed and the data
If we go forwards, so that's 10 May (sic), 21 downloaded and how nil transactions can occur.”
Post Office, Ward, to Fujitsu 22 Having looked at this material, do you agree
A. Yes. 23 that it was the Post Office, via Mr Ward, routed
Q._ If we go forwards, please, to the 21 March, 24 through Mr Pinder, who had asked Mr Jenkins to
FUJ00152582, and look at page 2, please. If we 25 focus on the issue of nil transactions in the
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witness statement
A Yes.
Q. rather than a request to consider any broader
issues affecting the operation and reliability
of Horizon?
A. Yes.
Q._ Would you agree — you'll see the reference to
the three ARQs in the first line of the cut-in
email, I'm not going to read the numbers out —
that it was the Post Office which had selected
the three specific time periods for the
examination of nil transactions, and that it had
done so by enclosing ARQs for time periods that
it had selected?
A. Yes.
Q._ Would you agree that this instruction to
Mr Jenkins didn't constitute or indeed come
close to being a proper instruction to
an expert?
A. Yes.
Q._ Instead, it's a request coming from the Post
Office to the Fujitsu Litigation Support Team
asking them to add a paragraph to their standard
‘statement, which was then rerouted to
Mr Jenkins?
61
MR BEER: Thank you.
(11.32 am)
(A short break)
(11.45 am)
MR BEER: Sir, good moming. Can you continue to
see and hear us?
SIR WYN WILLIAMS: Yes, thank you.
MR BEER: Before I continue with the chronology in
Mr Thomas’ case, can we just return to
Ms Adedayo's case and just clarify couple of
points, in the light of the questions you asked
and the evidence that Mr Atkinson gave.
Can we start, please, Mr Atkinson, just by
explaining the different nature of appeals from
the Crown Court to the Court of Appeal Criminal
Division and from a Magistrates Court to a Crown
Court in CCRC reference cases.
Is it right that an appeal from the Crown
Court to the CCAD (sic) is, essentially,
a review of the safety of the conviction?
A. Yes.
Q. Whereas, if a person has pleaded guilty in the
Magistrates Court, there is no power to appeal,
unless the CCRC make a reference?
A. Yes.
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A. That was how I read it, yes.
Q. Quite aside from the format of the instruction,
is it right that you saw no material in which
the Post Office provided to Mr Jenkins detail as
to what the prosecution case was against
Mr Thomas?
That's right.
No material setting out what Mr Thomas had said,
for example, in interview ~
Correct.
QP
~ or in the audit, and in the audit report?
Yes.
There was no analysis for him of the competing
issues between the parties?
No, that's right.
Would you agree, on these materials, that
Mr Jenkins wasn't, in fact, instructed to
undertake an examination of the scheme ~
Yes, I agree.
~ of the system?
Yes.
Thank you very much.
Sir, its just gone 11.30 now, I wonder if
we could break until 11.45.
SIR WYN WILLIAMS: Certainly, yes.
62
prop
p>
prop
Q. Ifthe CCRC make a reference, the test that the
CCRC apply is not whether the conviction is
unsafe but whether it's arguable that it might
be?
A. Yes.
If the CCRC do make a reference to the Crown.
Court on a case involving a plea in the
a Magistrates Court, that results in a hearing
2
de novo?
Yes, so a rehearing of the case.
Yes, so, essentially, a retrial?
Yes.
A rehearing of the case?
Yes.
Upon such rehearing of the case, the prosecutor
must, or ought to, consider both limbs of the
propor
Code test at that point in time?
Yes.
Q. What happened in Ms Adedayo's case was that the
Post Office made a concession on the public
interest limb of the test, as complained by
Ms Carey in the transcript, that that limb was
>
not at that point satisfied?
A. That's right.
Q. That approach by the Post Office meant that
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Mrs Adedayo did not have the opportunity to 4 @_ Thank you. Can we go back to Mr Thomas’ case,
argue by reference to the evidence and to make 2 please.
submissions whether the evidential threshold was 3 Yes.
met ~ that wouldn't be for the court anyway — 4 Can we look in the next step of the chronology,
but to argue in court, by reference to evidence, 5 at FUJ00152587, and page 5, please. We'd
as to whether her case was an Horizon case or 6 previously been looking at 10 March and
not? 7 21 March. We're now looking at 22 March.
No, that's right. 8 If we scroll down a little bit, please, we
Is that why we don't see a judgment from Her 9 see Mr Ward emailing the Fujitsu employees that
Honour Judge Taylor resolving whether 10 we see set out, confirming, in the second
Mrs Adedayo's case was or was not an Horizon "1 paragraph, that the Post Office required
case because, essentially, the Post Office 12 a witness statement producing ARQ extracts in
offered no evidence against her and there was 13 spreadsheet form, relating to Mr Thomas’ post
nothing for her then to do? 14 office, and a statement explaining the headings
And there had been no submissions before Judge 15 and under what circumstances nil transactions
Taylor on that issue which would have allowed 16 can occur. Can you see that in the second
her to come to a view. 7 paragraph?
No, save that I think in the inaudible part of 18 Yes.
the transcript, it's agreed between the Post 19 Then, if we scroll up, please, to the top of
Office and Mr Moloney that what was said was 20 page 5., we see Ms Lowther providing Mr Ward
that the Post Office analysis that this was not 21 with a draft witness statement later that day on
a Horizon case was not accepted, and he was 22 22 March:
essentially preserving his position and her 23 "Please see the draft [witness statement]
position for the future? 24 for the above re ‘Nil Transactions’
Yes. 25 [Does this meet] your requirements."
65 66
Then the page above, please, page 4. 1 “In particular, I don't feel I can include
A reply from Mr Ward later that day, the 22nd. 2 the last two [paragraphs], which may make the
In the third paragraph, second line: 3 statement useless.”
“.. 'm concemed at the words ‘system 4 Can we look at what that attachment was.
failure’ which is also in an earlier line ... 5 FUJ00122204. 23 March, draft statement. Scroll
“There has been some sort of system failure’ ~ 6 down, please. You'll see the introduction and
What does this mean exactly and is there any 7 then the part of the text in single line
indication of a system failure at this office 8 spacing:
during the period in question?" 9 “There are three main reasons why a zero
Can we go forwards, please, to FUJ00122203, 10 transaction may be generated as part of the
and page 3, please. On that day, 22 March, "1 banking system ..."
Ms Lowther forwards Graham Ward's email to 12 1 and 2, and then 3:
Mr Jenkins: 13 "There has been some sort of System Failure.
“Hi Gareth, 14 Such failures are normal occurrences."
"Please see reply from Graham below 15 So the point remains in Mr Jenkins’
regarding your statement. 16 statement in this draft, despite Mr Ward's
“.. ignore the first bit .." 17 questions expressed to Ms Lowther and passed on
Then: 18 to Mr Jenkins: why is that there, what does it
“Could you please look at his second 19 mean?
[paragraph] and advise with your comments again. 20 Yes.
“I have attached a copy of your draft 21 So he's maintaining that the reasons why a zero
statement ..." 22 transaction may be generated include some sort
If we go up to page 1, please. Reply later 23 of system failure and that they are normal
the next day, the 23rd. Mr Jenkins sending 24 occurrences.
a revised witness statement saying: 25 Can we go to FUJ00122203 —
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I'm so sorry. If we can go to the third 1 insist upon the removal of any references to
page of the witness statement, please. If we 2 system failures from Mr Jenkins’ witness
scroll down, just a little bit, you'll remember 3 statements?
that in his covering email, Mr Jenkins said 4 A. Yes. The emails that we've just seen, I don't
that: I don't think I can say the part in the 5 think there was anything inappropriate about
last two paragraphs, and these are the last two 6 them asking what he meant by that or asking him
paragraphs in the statement. 7 to explain that further, but asking him to
"... no reason to believe that the 8 remove it is a different matter.
information in the statement is inaccurate 9 @Q To the extent that it was removed subsequently,
To the best of my knowledge and belief at all 10 do you agree that Mr Jenkins’ recognition in
.. times the computer was operating properly "1 this draft of his witness statement, that system
* 12 failures are normal occurrences in the system,
Then a records declaration 13 ought properly to have been disclosed in this
Then Mr Jenkins said, as well as in his 14 prosecution --
email, at the foot of the page: 15 A. Yes.
“I'm not sure that the yellow bit is true. 16 Q. —andin others?
Can this be deleted? All I've done is interpret 17 A. Yes, with more information as to what he meant
the data in spreadsheets that you have emailed 18 by that.
tome." 19 @. No matter what went on subsequently, in terms of
Just pausing here for the moment, in 20 the deletion of that line from his witness
relation to the page 1 point, system failures 21 statement, should that have been material
being a reason for nil transactions and being 22 disclosed by Mr Jenkins himself?
normal occurrences in the system, would you 23. A. It should, if it was his view. If it was part
agree that it wasn't appropriate for the Post 24 of his expert assessment, it should have stayed
Office as an Investigator or as a prosecutor to 25 there and formed a part of what he produced.
69 70
Do you agree that Mr Jenkins’ request that the 1 served or disclosed, then his disagreement with
last paragraphs, the two that we're looking at, 2 them needed to be disclosed as well.
be removed from the draft witness statement 3 Q_ Canwe go, please, to FUJ00122210. Just look at
ought to have been disclosed in this 4 the bottom of page 1, please, from Ms Lowther to
prosecution? 5 Mr Ward:
If the two paragraphs remained in the statement 6 “Hi Graham,
as ultimately served, then the fact that he 7 [Please see attached] second draft for the
didn't agree with them clearly needed to be made 8 above with further explanation regarding the
clear. 9 issues you raised.”
That's what happened. Despite his request for 10 That second draft is the one that we've just
their removal, welll see that eventually, in the "1 looked at:
statement of 6 April 2006, those paragraphs 12 "Please let me know of any amendments [as
remained. 13 soon as possible] as we need to put this in the
Without qualification, 14 post’, et cetera,
Yes. 15 Then, further up on page 1, later the same
Yes. 16 day, on the 24th, Mr Ward replies at 11.37:
Therefore, his unhappiness at including those 17 "Neneh,
two paragraphs in a witness statement ought 18 “This statement needs more work ... I have
properly to have been disclosed in this 19 attached a suggested draft with a number of
prosecution? 20 ‘comments (as mentioned previously {I think
Yes. 21 that's the previous email we just looked at]
And in other prosecutions? 22 I think the ‘system failure ... normal
In any prosecution where this statement was 23 occurrence’ line is potentially very damaging).
served and/or disclosed or those paragraphs were 24 It may be worth considering someone from our
included in any further statements that were 25 team taking a statement directly from Gareth
al
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(where is he based?). 1 — and replaced by Mr Ward typing:
“Whilst there is some urgency with this, it 2 "(This is a really poor choice of words
is more important to get it right and ensure 3 which seems to accept that failures in the
that we are not embarrassed at court, which we 4 system are normal and therefore may well support
certainly could be if we produced a statement 5 the postmaster's claim that the system is to
accepting ‘system failures are normal 6 blame for the losses!!!!)"
occurrences’... 7 Do you consider this type of intervention in
“Let me know what you think of the draft.” 8 relation to the content of Mr Jenkins’ evidence
Then if we see at the top of that page there 9 to be appropriate conduct by a member of
later in the day, that's passed, that email, 10 a prosecuting authority?
directly by Ms Lowther to Gareth Jenkins: "1 No.
“[Please] see the mail below and the new 12 Do you consider the degree of input into the
draft statement.” 13 drafting of Mr Jenkins’ witness statement to be
So let's look at Mr Ward's drafting efforts. 14 appropriate, if it was the case that Mr Jenkins
POL00047895. If we scroll down, please, so this 15 was being treated as an expert witness?
is the relevant paragraph at the top of the page 16 No. As I said before, there was no issue with
here: 7 Mr Ward, as he had in earlier emails, asking
“There are three [then Mr Ward has inserted] 18 what system failures meant and having a better
(if these are the main reasons what are the 19 understanding of that, but to take it out
rest?) reasons why a zero value transaction may 20 because it was embarrassing or damaging, or
be generated as part of the banking system ..." 21 would help the postmaster —-
Then I think 1 and 2 remain the same. The 22 The defendant.
third reason, system failure, has been 23 ~help the defendant is very much the opposite
deleted —- can you see that -~ 24 of what they should have been doing,
Yes. 25 Do you agree that, to the extent that
73 74
an Investigator or a Manager of Investigators 1 But it should have generated discussion as
had made deletions or proposed deletions to 2 to why they were wrong or what the issue was
a witness statement and had given as a reason 3 and, if the issue was, as I read Mr Jenkins’
that the evidence that the expert was proposing 4 email to suggest that, for him to attest as to
to give might well support the defendant and, 5 the operation of the system, he needed more
therefore, the words should be deleted, ought to 6 material than he had been given, then the
have been disclosed in the prosecution? 7 discussion needs to be about that, rather than
It shouldn't have happened and, if it did 8 just deleting the paragraphs and moving on as if
happen, it should have been disclosed 9 nothing had happened
Can we go to page 3, please. Can we see that 10 Thank you.
the two paragraphs in relation to the operation "1 Can we move on, please, to POL00122217 —
of the computer — and we'll come back in 12 FUJ00122217. My mistake, I said POL rather than
a moment to exactly what they may have meant, 13 FUJ.
what their focus may have been in a moment, but 14 FUJ00122217. Can we start with page 2,
they have been removed by Mr Ward — 15 please. We can see that Mr Ward's amendments to
Yes. 16 the second draft of the statement are sent back
~-in this draft. Again, was that proper 17 to Mr Jenkins. Then, if we go up, please,
conduct by a member of the prosecuting 18 Mr Jenkins emails Mr Ward directly, copying
authority? 19 Ms Lowther in, an updated draft statement,
It would depend on why it was done and what else 20 saying:
was done in relation to it. Clearly, if the 21 "I've added some further annotations to your
person whose statement this was said that they 22 annotations. Does this move us forward?"
were ~ that they wanted those paragraphs to be 23 So shall we see what the attachment said?
deleted because they were wrong, then it was not 24 FUJ00122218. This is the attachment to that
wrong to delete those paragraphs. 25 email. Although it was being sent on 28 March,
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the statement remained dated 24 March. If we 1 deleting the paragraph.
scroll down, please, you'll see the third 2 In the light of the fact that Mr Jenkins
reason, system failures, remains deleted. 3 recognised, in this further draft or the
You will see Mr Ward's annotations on 4 response to the proposed amendment, that system
“really poor choice of words’, and you'll see 5 failures were anticipated, was it appropriate
Mr Jenkins reply: 6 for the Post Office, as an Investigator or
"Please can you suggest something better 7 prosecutor, to insist upon the removal of the
then? What we have here are genuine failures of 8 reference to "system failures” from the witness
the end-to-end system which are not part of 9 statement?
normal operation, but are anticipated and the 10 No. What was necessary was for them to provide
system is designed to cope with them. Some such "1 a proper explanation of what that meant.
failures could be engineered as part of 12 The recognition in the text that he added that
a malicious attack (but that doesn't apply to 13 such system failures were anticipated, do you
those failures that appear in the evidence 14 agree ought properly to have been disclosed in
presented). In all cases the system is designed 15 the prosecution?
to identify such failures and handle them in 16 Yes.
such a way that the Customer, the Postmaster, 7 If we go over the page, please. Scroll down.
Post Office and [Financial Investigators] are 18 You'll see that the system operation paragraphs,
all clear as to the status of the transaction 19 those two paragraphs at the end that were in the
and any necessary financial reconciliation takes 20 original coloured yellow, remain removed.
place. I guess one option is to delete the 21 Yes.
paragraph since it is purely an introduction to 22 Do you agree that this draft of the witness
the following more detailed description.” 23 statement ought properly to have been disclosed
So Mr Jenkins has asked Mr Ward to suggest 24 in the prosecution?
something better and raised the possibility of 25 Yes.
7 78
Can we go forward to FUJ00152587. Mr Ward 1 Gaerwen occurred ... The same statement needs to
emails Mr Pinder, copying Ms Lowther and 2 include a paragraph which states that there is
Mr Jenkins in, saying: 3 no evidence of a system error at Gaerwen
“I do not understand why this statement ... 4 (assuming this is the case) in relation to 'Nil
is taking so long to be put together. 5 transactions at the office. We do not need to
I appreciate it is slightly unusual, but I do 6 mention ‘system failures being normal
not understand the confusion as I thought I'd 7 occurrences’ if there is no evidence of such
made our requirements clear.” 8 a problem at this office
Remember the word “requirements”, if you 9 ".. it may now be best if the Investigator
may: 10 ... arranges to meet with Gareth to take the
“Unfortunately, Gareth's annotations do not "1 statement in person ..."
take us forward at all (and I'm sure this is not 12 Do you consider this intervention by Mr Ward
Gareth's fault). Gareth has indicated in the 13 to be appropriate conduct by a member of
attachment below that the 3 spreadsheets 14 a prosecuting authority?
produced by your team ... were not produced by 15 No.
him, therefore as he quite rightly points out, 16 Do you consider the degree of input into the
he is not in a position to produce them in his 17 drafting of this witness statement to be
statement." 18 appropriate?
That's a side point. Then scroll down, 19 No.
please: 20 Ought this exchange to have been disclosed in
“As already stated, we urgently need 21 the prosecution?
a statement producing these 3 additional 22 Yes, especially if the statement was being
spreadsheets, explaining in general terms, under 23 relied upon.
what circumstances ‘nil’ transactions occur and 24 No need to tun them up but some evidence the
in particular how the ‘nil transactions at 25 Inquiry has got, FUJ00155721 and FUJ00152592,
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suggests that Mr Pinder of Fujitsu then spoke 1 Q_ ~a compressed version of both statements.
with Ms Matthews, the Investigator, and arranged 2 A. Yes.
for her to meet Mr Jenkins in person on the 3 Q_ So standing back, at the moment, from this run
6 April 2006 to "record the statement". 4 of correspondence, would you agree that
It appears, as a result of that meeting, 5 Mr Jenkins openly referred to system failure in
an updated draft witness statement was prepared, 6 his original draft of the statement?
dated 6 April 2006, if we can look at that, 7 A. Yes.
please, FUJ00122237. If we scroll down, 8 Q_ [twas Mr Ward who objected, on behalf of the
please ~ and again, and again -- you'll see, 9 Post Office, to the reference to system
I think, that the three main reasons for nil 10 failures?
transactions occurring, including system 11 A Yes
generated occurrences, do not appear in this 12 Q. MrWard inserted his criticisms of the inclusion
final witness statement nor any reference to 13 of those words into a text of the statement --
system failures at all 14 A Yes.
That's right. 15 Q. —"Thisis a really poor choice of words" —
But in the last draft, the final draft, the 16 A. Yes.
signed version, the two paragraphs about the 17 Q. —andit appears to be Mr Ward who was pressing
operation of the computer system reappear. Can 18 for the amendment of the statement, because
you see that? There's one on the page there, 19 Mr Ward was worried about how “system failure”
Then, if we scroll to the next page, yes: 20 might be interpreted and that it might actually
“... no reason to believe the information in 21 help a defendant?
this statement is inaccurate because of the 22 A. Yes.
improper use of the computer.” 23 Q. Putting aside whether that approach was
I think they have had been combined into -- 24 acceptable, I think you said that each of the
They have. 25 versions of the statement ought to have been
81 82
disclosed, in particular because, from 2005 1 paragraph 213 of your report, which is on
onwards, the CPIA Code at paragraph 5.1 required 2 page 82, that the snapshot of data that
drafts of statements to have been recorded on 3 Mr Jenkins examined in his witness statement was
the Unused Schedule, if they differed materially 4 avery restricted one —
what the final version? 5 A. Yes.
Yes, and because applying the disclosure test, 6 Q@ ~and that the examination which was undertaken
for reasons that Mr Ward had identified, this 7 does not appear to have been disclosed, so it's
was material that undermined the prosecution 8 limitations were unlikely to have been
case and fell to be disclosed anyway. 9 appreciated by the defence.
So the failure to reveal, by recording on the 10 Having seen now the underlying material, and
schedule the existence of these drafts, may he "1 putting aside the fact that the work done
a breach of Section 7 of the CPIA, in that the 12 reflected, I think, what Mr Jenkins had been
reference to "system failure” in the drafts 13 asked to do, do you agree that Mr Jenkins sought
meant that they might reasonably be considered 14 guidance as to whether what he was doing was the
to be capable of undermining the prosecution or 15 correct approach?
assisting the defence? 16 A. I'mnot sure I entirely follow that.
Yes. 17 Q. Let's look at some other material, then.
So, gathering all of that information together, 18 FUJ00122230. If we scroll down, please, I think
had the Post Office adhered to the law in 19 this is an email of 30 March between Mr Jenkins
relation to disclosure here, then the fact that 20 and Mr Pinder saying:
the witness statement had evolved over time and 21 "Ive taken the data from the PEAK ..."
at whose insistence it had evolved over time 22 Do you recall what PEAKs were?
would have been revealed to the defence? 23 A. No.
Yes. 24 @. You don't, okay:
That can come down. Thank you. You tell us in 25 *... and carried out my own analysis of it
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and presented the results in the attached Word 1 table provides a summary ..."
Document. 2 Then the three ARQ periods are set out by
“Hopefully this is the sort of thing that 3 reference to the three ARQ numbers: 401, 459,
[the Post Office] want. If you want to pass it 4 and 460. Then scroll down:
through to them before Thursday then fine.” 5 "I have produced a separate spreadsheet
So PEAK was an incident management system 6 Then he goes on and explains what he's done
maintained and operated by Fujitsu that recorded 7 A. Yes.
the reporting investigation and possible 8 Q@ Somy question, and I cut to the chase too
escalation of system issues within a certain 9 quickly with you, Mr Atkinson, was that what
level of service helpdesk within Fujitsu. 10 Mr Jenkins did was tell Mr Pinder "This is what
Yes. "1 I've done, attaching this Word document”, and
Mr Jenkins says, he's taken the data off the 12 essentially asking: is this correct, is this
PEAK, so from that system. 13 what the Post Office want, by saying in his
Yes. 14 covering email "Hopefully this is what the Post
If we can look, please, at FUJ00122229. This is 15 Office want"?
the attachment to that email that we've just 16 A. Yes.
looked at. This note sits under Mr Jenkins’ 17 Q. Can you recall any reply to that coming back to
hand: 18 him and saying, "No, you've done the wrong
“This note is provided as input to a Witness 19 thing"?
Statement regarding Gaerwen 20 A. I can't recall one no and this material does
“Penny Thomas provided me with extracts ... 21 reflect what is in the statement of the 6 April.
for 3 [periods from audited data], 22 @. 6 April, yes, exactly. Did you see any
“I have taken this data and extracted 23 instruction or guidance to Mr Jenkins about the
details of all banking transactions and analysed 24 retention of working materials such as this or
the zero value transactions. The following 25 the disclosure of underlying analysis, the type
85 86
of which is referred to in this document? 1 we just look at the end of the witness
No. 2 statement, please. It's that paragraph:
Is that the type of material that should be 3 “There is no reason to believe the
retained by an expert witness and made available 4 information in the statement is inaccurate
for disclosure? 5 because of the improper use of the computer. To
Yes. 6 the best of my knowledge and belief at all
Thank you very much. 7 material times the computer was operating
If we go back to paragraph 213 of your 8 properly, or if not, any respect in which it was
report, which is on page 82, in paragraph 213, 9 not operating properly, or was out of operation
in the middle of the paragraph, can you see 10 was not such as to affect the information held
a line which says: "1 onit.”
"Mr Jenkins of Fujitsu does not appear to 12 A. Yes.
have been asked to review the underlying data 13 Q. Thisis the abridged version of those two
more generally..." 14 computer operation paragraphs —
Then this: 15 A. Absolutely.
“... but does appear to have provided 16 Q. —that we saw earlier.
reassurance as to the integrity of the system 17 A. Yes
despite that underlying data not being 18 Q. Isitthe line "To the best of my knowledge and
analysed.” 19 belief at all material times the computer was
Yes. 20 operating properly’, that you're referring to?
Are you there referring to that line at the end 21 A. Yes.
or that paragraph at the end of Mr Jenkins’ 22 Q._ If we go back to the beginning of the statement,
witness statement? 23 please, and if we scroll down, you'll see in the
Yes. 24 second paragraph Mr Jenkins refers to the
Can we look at that, please. FUJ00122237. If 25 Fujitsu PEAK system:
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“Fujitsu have a fault management system 1 stored and from which it was obtained or could
called the PEAK system, which is used for 2 you not tell?
passing faults around the team and tracking 3 My reading was the latter, that it related to
faults raised regarding the Post Office 4 the ~ relating to the Horizon system, but it's
Account.” 5 not altogether clear.
Then, subsequently, Mr Jenkins records that, 6 So I think you read this paragraph, the abridged
he extracted data from the PEAK system: 7 version of what is a standard paragraph in other
“L extracted data from this system regarding 8 witness statements, as equating to an opinion
the Gaerwen Post Office." 9 that Horizon was working properly, insofar as it
Then he says: 10 affected the Gaerwen branch at all relevant
“From this data, I then extracted all the "1 times —
banking transactions which showed a zero value." 12 Yes.
That's ARQ data 13 ~ rather than that the information in the
Yes. 14 witness statement refers to information
He then produces spreadsheets analysing the 15 extracted from the PEAK system?
existence of or the reasons for the zero values. 16 Rather than that that paragraph related just to
The statement at the end, if we go to it at 7 the PEAK system, yes.
the foot of the next page, please, page 3 at the 18 Thank you. Can you see that this statement is
bottom: 19 at least open to interpretation?
“There is no reason to believe that the 20 Yes.
information in this statement is inaccurate 21 That can come down. Thank you.
because of improper use of the computer.” 22 Before repeal, would you agree that
Was your understanding that the computer 23 Section 69 of PACE permitted the admission into
that was being referred to was the PEAK system. 24 evidence of a statement contained within
or the Horizon system on which the ARQ data was 25 a document where that document had been produced
89 90
by a computer? 1 important because it was that underlying
Yes. 2 material that would help someone, particularly
There was, I think you will remember, concern 3 someone acting on behalf of the defendant, to
that the ambit and effect of Section 69 of the 4 approach what he meant by this and what his
Police and Criminal Evidence Act had been 5 intention was.
fundamentally misunderstood? Do you remember 6 So, in circumstances where an Investigator, as
a case of Miners ~ 7 we've seen the material suggest, took a witness.
Yes, 8 statement from Mr Jenkins, would you agree that,
--which you cite in your second report. Was 9 if the witness was asked to include a form of
Section 69, in fact, only concerned with 10 words such as this at the end of their witness
admission of facts into evidence rather than "1 statement, it was important that it was made
whether the facts were true? 12 clear to the witness what the words were
Yes, it was to do with the operation of the 13 supposed to indicate?
system, rather than the truth of the content. 14 Yes. Particularly where they had expressed
I don't suppose you can assist us on whether — 15 reasons as to why its relation to the operation
you've explained how you understood that 16 of the Horizon system would not be something
statement as referring to Horizon more 17 they would sign up to.
generally? 18 Because the witness was saying, "I've looked at
Yes. 19 ‘one computer system, the PEAK system, I've
You can't assist us as to what Mr Jenkins’, 20 identified from that some data that I need to
obviously, intention was on the basis of the 21 look at, three lots of ARQ data” —
materials that you've seen? 22 Yes.
No, although that perhaps underlines why the 23 ~ "I've extracted three lots of ARQ data from
iterations and evolution of this statement was 24 Horizon, the computer system was working”, I'm
so important and why its disclosure was so 25 ‘summarising it?
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P)
Yes, and what I'm not saying is that the Horizon 1 inaccurate!)"
system was operating correctly. That's - so 2 Then if we go to page 2, please, and scroll
that it was clear what this assertion as to 3 up, we can see the reply from Ms Matthews. Just
correct operation related and to what it, 4 scroll down to her second paragraph — her third
equally importantly, didn't relate to. 5 paragraph, rather, which is a reply to the
‘So you would you agree, I think, that it was 6 request for help from Mr Jenkins:
important that it should be made clear to the 7 “All witnesses will have to be present on
witness what the words were supposed to mean, 8 the 1st day unless the defence has agreed
and to which system they were intended to 9 [their] statement and don't wish to ask any
relate? 10 questions about that evidence."
Yes. "1 Then this:
Can we move forwards, please, to FUJ00152616. 12 “Itis pretty much as you see on the TV
Can we look at page 3 to start with, please. 13 really but remember that you will have sight of
We've moved on from March and April into the 14 your statement prior to taking the stand and can
summer. If we scroll down, please. Yes, this 15 only be asked questions specifically about your
is an email to Diane Matthews, the Investigator 16 statement."
of this case, from Mr Jenkins. At the bottom of 7 Was that guidance appropriate?
the next page, you will see it is dated 12 July, 18 I'm not altogether sure what it means but,
and Mr Jenkins says: 19 insofar as I understand it, no.
“lunderstand also that this trial is at 20 What do you understand it to mean?
Caemarfon. Do you have any idea as to how much 21 Well, I understand it to be saying that the
time will be involved and exactly what is 22 criminal process is like a TV programme,
required? I've never been to court in any 23 presumably an American TV programme, by
capacity and my knowledge of such things is 24 reference to “the stand” and that the witness
based on films and TV (which I'm sure are 25 can only be asked questions about what is
93 94
already in their witness statement, and I don't 1 agree with the suggestion that, overall, the
know where that comes from, even in America. 2 Post Office appeared to seek to harden up
Would you agree that that part is positively 3 Mr Jenkins’ witness statement?
misleading? 4 Yes.
Yes. 5 Looking at that series of communications and
Because it's wrong? 6 drafts, do you agree that it succeeded in that
Yes. 7 objective?
Would it carry any special relevance in 8 Yes.
circumstances where a witness had already been 9 Do you agree that Mr Jenkins participated in
asked to delete aspects of their witness 10 that enterprise?
statement and was now being told by the "1 Yes.
prosecutor "You can't be asked questions about 12 I think you've agreed that all of the drafts
things outside your witness statement, you'll 13 that we've seen, including observations within
only be asked questions specifically about your 14 the drafts and the communications themselves,
statement"? 15 ought to have been disclosed?
Yes, I suppose it might have a different message 16 Yes.
to someone if they understood that the various 17 Thank you. Can we turn to the case of
drafts of their statement had also been 18 Suzanne Palmer, please. You address this in
disclosed and, therefore, questions about their 19 paragraph 229 of your report. In fact, you
statement might include that but, subject to 20 start at 220 but the bit I want to ask about is
that, it would tell them that the final draft is 21 229, which is on page 87
all that you're going to be asked about. 22 In paragraph 229 on page 87, you comment
Thank you. That can come down. 23 that prosecuting counsel, Stephen John, provided
Having reviewed the emails, correspondence, 24 an advice on evidence, which identified a number
and draft statements that we've seen, would you 25 of lines of inquiry or investigation that he
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thought should be pursued but that, other than 1 clear-cut one
commenting on the particulars of the indictment, 2 Q Putitanother way, then: given he advised on
he didn't advise on the sufficiency of evidence 3 further lines of inquiry, is it implicit or can
and say this was another opportunity to review 4 we draw an inference reasonably that he had read
whether there was a proper evidential basis to 5 all of the papers, he'd considered the evidence
assert dishonesty was lost. 6 in the case and decided that there was
Yes. 7 a reasonable prospect of conviction, even if he
Would you agree that dishonesty, as an element 8 never said so?
of many offences, is one which, more often than 9 A. That would be one interpretation and that might
not, is proved by inference from the 10 be the right interpretation. It would perhaps,
circumstances, rather than by direct evidence? "1 to an extent, depend on what his instructions
Yes. 12 asked him to do. Certainly, the standard
Would you agree that, if Mr John, as prosecuting 13 instructions, such as I have seen them in ~
counsel, had taken the view that there was not 14 across these 22 cases, do ask counsel instructed
sufficient evidence to satisfy the first limb of 15 to draft the indictment and to advise on
the Full Code Test, he could not have properly 16 evidence. And where I've seen them, I have seen
continued to prosecute the case? 7 advices from counsel that firstly say, "I attach
I'm not sure I altogether follow that. Clearly, 18 the indictment", and why it does or does not
if he identified that the -- there was 19 include what it does or doesn't include and
insufficient evidence to prove dishonesty for 20 a list of further things that are required.
the purposes of theft, he should have said so. 21 The instructions to counsel didn't
Whether he would have been professionally 22 specifically ask them to advise as to the
embarrassed so he would have to have withdrawn 23 sufficiency of evidence and whether they agreed
from the case if that advice was not acted on, 24 that this was a proper case to prosecute or not,
is a separate question, I think, not a very 25 so I could see that there would be -- there may
97 98
be circumstances where a prosecutor would not 1 or not.
understand that's what they're being asked, 2 Q@ Thank you
although I have to say I think they would still 3 Can we turn to the case of Susan Rudkin,
be duty bound to do so but it may also be that 4 please. I've skipped over Josephine Hamilton.
those who instruct them were not expecting them. 5 If we can look, please, at paragraph 306 of
to do that and, therefore, their failure to do 6 your report, which is on page 113. In this
it wouldn't necessarily tell them very much one 7 paragraph -- and it's an observation that you
way or the other. 8 make elsewhere in your report too -- you say
In fact, we've heard from the lawyers so far 9 that, although the Post Office may have had
that the request to advise on evidence was meant 10 evidence of theft or fraud by way of admissions,
to encompass, was intended to encompass "1 it did not have sufficient evidence or at least
a request to advise on evidential sufficiency, 12 there had been insufficient consideration of the
not just further lines of inquiry, and the 13 adequacy of the evidence to prove the level of
counsel that we've heard from, the only one, 14 the loss. This is a point that you make
Mr Tatford, has said that he understood the 15 a number of times in the report.
request to advise on evidence to include 16 A. Yes
a requirement to advise on evidential 17 Q Would you agree that the amount of
sufficiency but the vagaries of life at the 18 particularised loss in a charge can be relevant
criminal bar was such that there was often not 19 to an assessment of whether a prosecution is in
time to do so. 20 the public interest —
Certainly, my experience would be that, if you 21 A. Yes.
were instructed to prosecute a case, you would 22 Q. ~any sentencing exercise —
not just be looking at whether there was 23 A. Absolutely
a statement from the plan drawer, you would be 24 @. ~and confiscation or other ancillary orders?
looking to see whether the case was sustainable 25 A. Yes, both as to whether it's appropriate to do
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it and certainly as to how much you're asking 1 But it was also relevant to the assessment
for. 2 of the public interest and where there was
Would you agree that although there's 3 a lack of evidence as to that, itis difficult
a requirement to prove that there was a loss for 4 to see how, without further enquiry, one could
offences of theft, the courts do not generally 5 go from the beginning to the end of the charging
consider the amount of loss to be a material 6 process without, at any stage, raising that as
averment in a count on an indictment? 7 aconcem.
No, that's right. 8 Thank you.
Because the amount of loss is not a relevant 9 Ms Rudkin's case raises issues of
consideration in assessing whether a defendant 10 post-conviction disclosure as well, which you
is guilty or not? "1 address in your report on the previous page at
It's not a necessary requirement to establish 12 page 305, at the foot of the page. You say:
that, that’s right 13 “In the subsequent 2014 review by Cartwright
So what's the force of your criticism here, 14 King, the Post Office retained the view that
then, in the light of those points? 15 there was no evidence of Horizon failings
That in this case and in such cases where there 16 contributed to the loss, and was clearly aware
were questions as to whether there was theft, it 7 of potential issues with cross-disclosure to
was clearly relevant for the investigation to do 18 other cases. That advice took a concerning
what it could to identify what it was being said 19 approach to post-conviction disclosure focusing
had been taken. And it was necessary for 20 on the consequences of disclosure rather than
a prosecutor in deciding whether to prosecute to 21 whether it was required.”
have a sense and an understanding of what had 22 Can we just look at that, please —
been taken, because it was relevant to the 23 Yes.
assessment of whether there was a realistic 24 ~ this conceming approach to post-conviction
prospect of conviction: 25 disclosure. It's POL00046579.
401 402
We can see that this is the case of 1 and/or restitution of monies paid by this
Mr Rudkin, Mrs Rudkin's husband. If we scroll 2 appellant under any confiscation order.
down, please, "Analysis". This is written by 3 "Such concessions would have to be disclosed
Harry Bowyer — 4 to those with similar convictions. This may
Yes. 5 well necessitate a review of many hundreds of
-- an in-house barrister at Cartwright King: 6 cases to establish who else may be entitled to
“It is Post Office's firm belief that the 7 such disclosure.
major losses suffered by the Applicant were 8 “if concessions are made that might render
caused by theft by his wife. Other very minor 9 the sentence imposed ... manifestly excessive
losses were likely to have been caused by simple 10 then the Applicant might well be put in
human error ... There is no evidence to support "1 a position whereby she might be able to appeal
the Applicant's assertions that there were 12 that sentence, with similar consequences for
failings with Horizon which contributed to 13 [Post Office}.
losses at the branch. 14 "... again, those concessions would have to
“Unless this position is resiled from this 15 be disclosed ..."
case should not cause any problems with any 16 Then, finally:
[Post Office] prosecutions past or pending.” 17 “This is not a case where any concessions
Then over the page, please, "Dangers to Post 18 can or should be made; to do so has the
Office", second paragraph: 19 potential to render her conviction by guilty
“if concessions are made that might render 20 plea unsafe, or her sentence as manifestly
this conviction unsafe then the Applicant's wife 21 excessive; and accordingly to invite
may well be put in a position whereby she is 22 an application to the Court of Appeal.”
able to appeal that conviction. 23 Are they the paragraphs which you thought
"Were an appeal to succeed, then [the Post 24 indicated a concerning approach to
Office] would be open to a claim for damages 25 post-conviction disclosure?
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pp?
Yes. 1 So my concern was, looking at this document
Can you just explain why, please? 2 overall, it was not clear to me, as the final
Well, if the position was that there was no 3 assessment, whether it was being assessed here
material that -- and that material had been 4 that there was nothing that needed to be
reviewed ~ that there was no material following 5 conceded or that there were reasons of impact
a review that identified any Horizon issues in 6 why they didn't want to concede it.
relation to Mrs Rudkin's case, then there would 7 Can we look, please, at another example -- this
be no material that needed to be disclosed and 8 involves Lynette Hutchings -- whilst we're
no concession that there were Horizon issues 9 looking at post-conviction disclosure.
needed to be made and that would be on a proper 10 POL00060715. This is addressed at 435 to 436 in
assessment of the material. "1 your report, Mr Atkinson.
If the reason not to make such a concession 12 Thank you.
was that it might allow a proper appeal against 13 So POL00060715. This is an advice written by
conviction or it might show that the figure of 14 Simon Clarke of Cartwright King. If we just
loss was not as had been contended, such that 15 scroll through it, please. The offence is set
the sentence that was imposed was excessive, 16 out, the case history is described. If we cary
then that would not be a proper reason to 7 on through the case history, and over the page,
disclose. Indeed, if a concession properly 18 it sets out the prosecution case. If we
would allow for an appeal to be advanced, then 19 continue, please. Then "Discussion":
that would be a reason to disclose it, rather 20 "The defendant has unequivocally admitted
than not. if the reason for not making 21 making false entries into Horizon in the belief
a concession in one case was its impact on 22 that the balances would be corrected in the
others, where that was a concession that was 23 fullness of time ... she stated in her prepared
rightly to be made, then that's right not 24 statement that she did not do so dishonesty.
a reason not to make it. 25 Had she chosen to advance that account at trial
105 106
the jury would have been entitled to accept what 1 and the reference in the Basis of Plea to the
she said and acquit her; or to reject the 2 leading case on the topic ... the Second Sight
account and convict her. Thus the opportunity 3 Report and the Helen Rose report would not
was there to seek an acquittal.” 4 have been disclosable during the currency of the
Over the page. There's a discussion about 5 prosecution and accordingly do not now fall to
Eden in paragraphs 11 and 12; 13 addresses the 6 be disclosed.
defence statement; and then 14 addresses 7 *... had we [possessed] the material at the
conviction. Mr Clarke says: 8 relevant time, we would not have disclosed [it]
“itis not the purpose of this review, nor 9 to the defence ..."
of the review process overall, to determine 10 Why do you say that this misunderstands the
whether or not any particular conviction is "1 disclosure test?
unsafe: that decision is reserved to the Court 12 It proceeds on the basis that there was a guilty
of Appeal only. The purpose of this process is 13 plea and she, Ms Hutchings, could have contested
to identify those cases where the material 14 this matter at trial, she chose not to, she had
contained in the Second Sight Interim Report 15 legal advice, so that’s down to her.
would have met the test for disclosure as 16 It doesn't recognise that there was a stage
provided by the [CPIA], the Code of Practice 17 before Ms Hutchings was arraigned and it was at
enacted thereunder and the [AG's] Guidelines on. 18 that stage that the question should have been
Disclosure, had that material been known to Post 19 asked as to whether there was material that was.
Office Limited during the currency of the 20 capable of undermining the prosecution case or
prosecution and accordingly would or ought to 21 assisting hers that ought to have been
have been disclosed to the defence.” 22 disclosed.
Then over the page: 23 And this is all concerning, as I read it,
“In this case I advise that, given the 24 that the Second Sight review and the issues that
chronology and circumstances of the guilty plea, 25 it gave rise to, as to whether the operation of
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Horizon and material relating to the operation 1 inadvertent rather than anything deliberately by
of Horizon had been properly appreciated and/or 2 the defendant, on the one hand, and to be — to
disclosed. 3 have had confirmed by the prosecution, on the
And to say "We don't need to worry about 4 other.
this because she pleaded’, is to ignore the fact 5 Q Atthat time and indeed today, the leading
that there should have been disclosure before 6 decision — in fact the operative decision —- on
she had the opportunity to. To say "There's 7 post-conviction disclosure obligations was that
a reference in her basis of plea to Eden, 8 of the Supreme Court in Nunn?
therefore, she was clearly advised by counsel", 9 A. Yes.
ignores the fact that counsel had not had this 10 Q. The decision was reflected in the then Attorney
material disclosed to them either and a failure "1 General's Guidelines on Disclosure at
to recognise that it was at least possible that 12 paragraphs 59 and 60, the acid test being
counsel, told that the basis for the prosecution 13 whether there presently existed information
case was susceptible to challenge, may have 14 which might cast doubt upon the safety of the
given different advice to his client to one who 15 conviction?
was not told that. 16 A. Yes.
And also, that in relation to any appeal 17 Q. Thattestis to be applied, have I got this
against sentence that was potentially available, 18 right, irrespective of whether there was a plea
and/or to submissions that could be made to 19 or not, it's material that might cast doubt on
a judge before sentence, issues as to the 20 the safety of the conviction —
operation of the system and confirmation of 21 A. Yes.
those issues by the prosecution, would have been 22 @. ~however the conviction was obtained?
of assistance to the defendant. It is 23 A. Yes.
a different thing for a judge to consider a case 24 @Q. Overall, then, in these two cases, when you
where the explanation is given that this was 25 describe the approach to post-conviction
109 4110
disclosure as being, in the one case, concerning 1 “It's the Horizon system that has let us down"
and, in the other case, involving a fundamental 2 A. (The witness nodded)
misunderstanding of the test to apply, are you 3 Q. That was an interview taking place in September
saying that the approach that was being taken 4 2008. That was after a civil claim involving
was inconsistent with the law? 5 the Cleveleys branch and Mrs Julie Wolstenholme
A. Yes. 6 had been settled, after she raised Horizon
MR BEER: Thank you. 7 integrity issues, after the formation in
Sir, we're about to move to another case 8 December 2005 of a group to examine Horizon
study, that of Peter Holmes. It's 1.00, might 9 integrity issues, after the trial involving Lee
we break until 2.00, please. 10 Castleton in 2007, in which he had directly
SIR WYN WILLIAMS: Of course. "1 challenged the Horizon system, and after a jury
(1.00 pm) 12 had acquitted Suzanne Palmer in less than ten
(The Short Adjournment) 13 minutes in 2007, her having raised issues with
(1.59 pm) 14 the integrity of the Horizon system.
MR BEER: Good afternoon, sir. Can you see and hear 15 Was there, to your understanding, any
us? 16 investigation of Horizon integrity or the
SIR WYN WILLIAMS: Yes, thank you 17 figures produced by Horizon?
MR BEER: Good afternoon, Mr Atkinson. Can we turn 18 A. No.
to Peter Holmes please? 19 Q@. The investigation report recorded that Mr Holmes.
A. Yes. 20 had spent many years in the police service, and
Q._ In paragraphs 309 to 333 of your report -- no. 21 that he had been a subpostmaster at the
need to display them, but they're on page 114 22 Monkseaton branch office for six or seven years.
and following ~ you deal with the prosecution 23 He was of good character. Should such good
of Peter Holmes. One of the things that 24 character have been brought into account when.
happened was that interview, Mr Holmes said 25 considering the investigation of an offence or
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the merits of prosecution? 1 Ought his previous position and the
It should certainly have been a factor in the 2 longevity of his service to be a factor in
public interest test. It would not have been 3 deciding whether to take seriously concerns
the only factor or necessarily the decisive 4 raised by him in interview about the reliability
factor but it was a factor. I'm afraid I can't 5 of the Horizon system?
speak to as whether it was taken into account in 6 Certainly not as a reason not to take those
the charging decision because the public 7 matters seriously.
interest didn't get a mention. 8 Yes. In reality, does it matter who you are if
It was a factor relevant to the assessment 9 you raise issues such as this in an interview,
of Mr Holmes’ credibility. He -- as with any 10 whether you've got good character or not, as to
person of good character, their good character "1 the pursuit of a reasonable line of inquiry?
is a factor in their favour in the assessment of 12 No, but, as I said, the fact that you are of
their credibility, again not decisively so, but 13 good character may support your credibility in
a relevant factor in that regard as well. 14 raising an issue and perhaps give an extra
In fact, it was used against him in the 15 underlining to why it needs to be investigated.
investigation report — 16 Thank you very much. I'm going to move over the
Yes. 7 cases of Seema Misra, Lynette Hutchings, Joan
-- because he said that he hadn't reported the 18 Bailey and Alison Hall, and tum to Allison
accruing shortfalls showing on Horizon for some 19 Henderson. That's paragraph 515 of your report
11 months and the Investigator said that it was 20 to 519 ~ I'm so sorry.
incredulous that he should not have done so, 21 Yes, in paragraph 515 of your report, when
having spent many years in the police service 22 you're dealing with Mrs Henderson's case, you
and having been the subpostmaster for six or 23 say that her case was one where acceptance of
seven years at Monkseaton, so it was used 24 her plea was dependent upon repayment and a lack
against him 25 of criticism of Horizon?
113 414
Yes. 1 false accounting.”
That's a theme that you returned to in 649, 2 Then Mr Wilson's response to Dianne Chan's
which we looked at earlier — 3 email said:
Yes. 4 "Clearly if there were to be a plea to false
-- when you're making your general points. 5 accounting but on the basis that the Horizon
Would you accept that there is a difference 6 system was at fault then that would not be
between acceptance of a plea, on the one hand, 7 an acceptable basis of plea with the
and acceptance of a basis of plea, on the other? 8 prosecution.”
Yes. 9 Do you agree that what was being said by
You cite in 506, that's page 179, if we just go 10 Mr Wilson was not about acceptability of plea
to that, you say: "1 but rather acceptability of a potential basis of
“On 16 November, the day on which it appears 12 plea?
the second defence statement was served, Dianne 13 That's certainly an interpretation of that.
Chan, prosecution counsel, reported ‘have spoken 14 It's not, I have to say, the interpretation the
to a defence solicitor who indicated the 15 Court of Appeal reached but it is
defendant may be willing to [plead] to false 16 an interpretation of it
accounting and pay money back. Taken 17 Was the potential for a guilty plea to false
instructions from Chris [a reference to 18 accounting accompanied by repayment of shortfall
Christopher Knight, the Investigator, we think] 19 an issue first raised by the defence?
who has confirmed that he would be happy to 20 That's not altogether clear because it's not
proceed on that basis.’." 21 clear who, in the conversation between Dianne
You say that: 22 Chan, who was prosecuting counsel, and defence
[Mr Bowyer's] 2014 review also recorded 23 counsel, who it was who first raised repayment.
that the defence had told the Investigator by 24 Certainly, it was part of what was communicated
phone that the defendant might plead guilty to 25 by her to those who instructed her.
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So it's not clear who was tethering repayment to 1 prosecution of Mr Allen.
the plea? 2 If we scroll down, please, an email from
No. 3 Rachael Panter -- if we just scroll up we'll see
What's the basis for your view that the Post 4 that it's on 16 November, thank you. Rachael
Office made acceptance of the plea to false 5 Panter, she is a lawyer at Cartwright King, to
accounting conditional upon repayment? 6 Gareth Jenkins:
In part, I confess I was influenced by that 7 "As you may already be aware, your expert
being the finding of the Court of Appeal in that 8 report detailing the reliability of the Horizon
case, and I quote that at paragraph 511, and the 9 system has been served as evidence in a number
fact that the — I was influenced, I suspect, 10 of cases ..."
also, by the time I dealt with the case of "1 We've seen a similar email to this, I think,
Mrs Henderson, I had already dealt with other 12 twice, yesterday.
cases where there had been that connection, 13 Yes.
those, for example, of Mrs Hall 14 (0 date, most, if not all cases raising the
Thank you. Can we move to the case of Grant 15 Horizon system as an issue have been unable/not
Allen, please, which you address from your 16 willing to particularise what specific issues
paragraph 516 onwards on page 182. Can we look 7 they may have with the system and how that
at some of the underlying material here, please. 18 shapes the nature of their defence.
Can we start please with POL00097138. 19 *... [would like to serve [your report] in
Again, this principally involves a series of 20 each case listed below."
questions about liaison between Post Office, 21 We can see that one of them is Mr Allen,
Fujitsu and Mr Jenkins — 22 number 6, at Chester Crown Court.
Yes. 23 Yes.
--in the preparation of evidence, whether 24 If we scroll down, please. Just under the
witness statements or reports, for the 25 "Grant Allen" highlighted yellow part it says:
417 118
“{ would like to serve your report in the 1 *. there is no commercial cover...”
remaining cases and have attached a case summary 2 Then up the page, please, "concemed about
of each listed above so you may familiarise 3 the approach taken", we saw that yesterday.
yourself with the facts of each case." 4 Then up the page, again. Keep going to
Then, if we go over the page ~ sorry, it 5 Ms Panter's email. She says:
was at the foot of the previous page, actually: 6 “As I provided a list of cases rather than
“In order for me to serve your report in 7 approach each individual Investigator for each
time, please could you either send copies of 8 case, to then [re-pose] the same question
your report via Special Delivery and/or as 9 I thought it would save ... time and duplication
an email attachment." 10
The paragraph above, the request was: "1 “In response to your email Gareth, I do
“... to read the case summaries ... send 5 12 intend to use the report that you have already
original signed and dated copies of your report 13 provided. It doesn't matter that you have not
to [her].” 14 mentioned a specific case in your report, as
Yes. 15 there has not been any specific criticisms
Can we see what happened next, please, 16 raised by any of the defendants provided by the
FUJ00153856. Then scroll down, please. 17 defendants in my list of cases."
Mr Jenkins replies by saying: 18 Reading on:
“Can't you use the report I have already 19 "What I propose to do is serve your
sent you? There is no mention of the case on 20 statement on each defence solicitor so that the
the report’, ie no mention of any of the cases 21 issue of Horizon is then addressed. That will
that you have listed 22 then place the onus on the Defence to specify
"You should really be addressing such 23 what if anything, they say is wrong with the
requests through Post Office Limited rather than 24 Horizon system ...
directly to myself. 25 “That is why it is important for you to
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consider the case summaries that I have provided 1 Q. It, the Post Office, was not providing
so that you are familiar with each case.” 2 Mr Jenkins with any instructions specific to the
Looking at that exchange, as it stands at 3 case in question?
that point in time, were there problems with the 4 A. Ordata, no.
approach that was being taken? 5 Q_Itwas proposing to give or did give Mr Jenkins
Yes, we considered yesterday the issues 6 nothing more than a bare case summary in each
potentially with the generic statement and what 7 case?
it did or did not do, and here we have further 8 A. Quite.
communication in relation to that generic 9 Q That's aside from the limitations of the
statement and the decision that was taken to 10 statement, the generic statement, itself?
rely on, effectively, bald assertion that there 11 A Yes
was “nothing to see here" in relation to the 12 Q. What did you understand the provision of a case
operation of the Horizon system, rather than to 13 summary to be for; what was its purpose?
look at the data on a case-by-case basis, on 14 A. Again, it wasn't altogether clear to me what its
a branch-by-branch basis, to identify whether 15 intended purpose was, other than so that
there was something to see or not and, if so, 16 Mr Jenkins would know perhaps which post office
what. 7 it was, the name of the defendant, the amount of
So the Post Office wasn't itself considering 18 the shortfall. It perhaps would have given him
each case on its merits and was not instructing 19 some indication as to what the postmaster had
Mr Jenkins as an expert in each case? 20 said in interview about it but it wasn't asking
No, that's right. It was effectively 21 him to do anything with that information —
a one-size-fits-all answer to any suggestion 22 Q. Because —
from any postmaster that there may be an issue 23 A. ~other than to know it
with Horizon, without actually looking to see 24 @. I'msomy. As we see here, the Post Office was,
whether there was, in their case. 25 via its agent, telling Mr Jenkins it didn't
421 122
matter that he had not referred to a specific 1 Sefton and Nield, Andrew Bol, copied to
case in his report and yet it was telling him to 2 Ms Panter, to Mr Jenkins:
read the case summary ~ 3 "Please find enclosed outlines of the two
Yes. 4 cases which involve me.
-- for each case? 5 “Of the two ... Sefton and Nield is the more
Yes. 6 urgent ... concentrate on that one first. The
Was that approach made better or worse by the 7 Allen case is only for plea and case management
fact that the statement, on its face, did not 8 ‘on 10 December. In an ideal world I would like
explain that it was itself responsive to the 9 to serve a report before the 10th if possible
four questions that we saw earlier? 10 "
It made it worse, in the sense that no one "1 That doesn't improve the extent of the
coming to a particular case from the defence 12 instructions that Mr Jenkins is being given,
perspective, for example, or a court's 13 does it?
perspective, would know ~- would properly 14. A No.
understand what this statement was or where it 15 Q. Ifwe look, please, at FUJ00124105, Mr Jenkins
had come from. 16 replies on 3 December, adding, I think, Penny
And the genesis of it? 17 Thomas to the chain, saying to Mr Bole:
Absolutely. 18 "Thanks for the info you have supplied me
And, ifit's right that it contained 19 with on these two cases. I thought I should try
limitations, what those limitations were? 20 and clarify exactly what you want from me.
No. 21 "My understanding from Rachael was that all
Can we go forwards to FUJ00153865. We've moved 22 that is required is a signed version of
forward now to the end of November and an email 23 a standard report I produced a couple of months
from a different solicitor at Cartwright King, 24 ago ... If that is the case I can get that
in the case of Allen, and also in the case of 25 produced, scanned and emailed to you in a couple
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of days. 1 4 December from Mr Bole to Mr Jenkins, in the
“However having read through the info you've 2 case of Allen:
given me, perhaps you want me to cover some 3 “I have just spoken to the solicitor for
further things. Some observations ...” 4 Grant Allen."
Then Mr Jenkins sets out some further lines 5 Then skipping a paragraph:
of inquiry — 6 “I attach an extract from Mr Allen's
Yes. 7 interview. As in the case summary I sent you he
-- number 1, in the Sefton and Nield case and, 8 is trying to suggest that an initial loss of
number 2, contrasting the Allen case to the 9 £3,000 is attributable to lost data which has
Sefton and Nield case. Would you agree that at, 10 not reached Head Office because of installation
this point Mr Jenkins appears to be seeking "1 problems. Are you able to comment on this
clarification as to exactly what it was that 12 scenario at all? Ultimately we would need to
lawyers wanted him to do, given that they wanted 13 discredit this as an explanation that holds any
a standard statement because these cases, they 14 water. He denies stealing the subsequent losses
said, didn't give rise to specific Horizon 15 and therefore by implication may be seeking to
systems? 16 blame the system for these losses as well.”
It's a combination of seeking clarification, 7 Is the email from Mr Bole, the lawyer,
because he does say that he's trying to clarify, 18 consistent or inconsistent with the proper
but also an offer of the further help that he 19 instruction of an expert, in that it appears
could give on particular issues that he's 20 informally to ask Mr Jenkins if he can comment
spotted from the case summaries, I presume, that 21 at all on a defence explanation?
he had seen. 22 It's inconsistent but not just for that reason.
Can we move forward to FUJ00153881. If we 23 There's potentially no issue, depending on how
scroll down, please, and again, if we just 24 it is done, with putting a scenario to an expert
scroll up to catch the date it should be 25 and asking for their assessment of it. But
125 126
here, the tenor of the message is rather 1 claiming. However, where there are comms
different, and the use of the word "we", 2 problems it is normal to recover any missing
“Ultimately we would need to discredit this as 3 data once the comms are sorted out (provided it
an explanation that holds any water", and the 4 is within 35 days), so this shouldn't be
approach being to discredit this as 5 a reason for a loss. Also there are processes
an explanation that holds any water, neither of 6 in place to retrieve outstanding data where
those things really fit - well, not "really 7 there are extended comms issues lasting more
fit" — neither of those things fit with the 8 than 7 days, so as to meet contractual
instruction of an independent expert by someone 9 obligations regarding
acting as a minister of justice. 10 I could just make a general statement
So rather than doing what it should do, which "1 relating to that or if we retrieve data from the
was, if it hadn't been done before, to state the 12 time I could check out exactly what [is
expert's duties of independence, it actively 13 happening]."
sought to suggest the outcome? 14 Skip the next paragraph. We should note:
Yes, and that they were working as a team to get 15 [Post Office] have not requested any audit
there. 16 data ... nor been asked about Helpdesk calls
Can we look, please, at FUJ00153881 — that's in 17 “Is it worth asking Post Office to request
fact this document and the reply further up the 18 such data for me to examine before putting
page, please. If we carry on to see Mr Jenkins’ 19 together a specific statement ... or is a simple
reply, if we keep going. So it's the next day 20 generic one sufficient?"
5 December: 21 Then some cost issues.
“I've had a look at the statement here and 22 So Mr Jenkins highlighting no requests for
I think it might be helpful to have a dig as to 23 audit data or Helpdesk call records and that
exactly what went on in the Branch at the time 24 there are two ways of going about this, and
of the loss. I think I understand what he is 25 asking for instruction as to which the
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prosecutor required. 1 with it adequately ... Gareth tells me that it
Yes. 2 is in fact possible for him to retrieve the
If we go further up the page, please. Second 3 actual data from this time to see what actually
line, Mr Bole’s reply: 4 occurred at this branch, and that the retrieval
“I would appreciate if you could add your 5 of the data is free to POL... it will take
general comments at this stage regarding the 6 approximately two and a half days for him to
safeguards in place for comms problems to your 7 look at it and analyse what it means and this
statement, and send this to me as before and 8 will be chargeable to POL at £2,500. I have
I will refer back to the Post Office to consider 9 told him at present that we do not wish to
whether we go on to request the retrieval of 10 pursue this option unless it becomes
data for your further analysis." "1 unavoidable.”
So this exchange, I think you'll agree, 12 Then some instructions.
shows that Mr Jenkins informed the Post Office 13 Mr Jenkins then signed a witness statement
lawyers that he could examine the data to work 14 in Mr Allen's case on 17 December. This was
out "exactly what had happened at the branch"? 15 identical to the general statement, the generic
Yes. 16 statement that had been signed back earlier in
The Post Office said that they didn't want this 7 the year, except for the additional paragraph
to occur in response — 18 that had been included addressing the
Yes. 19 non-polling data. Can we look, please, at that,
~-in the first instance. If we look, please, 20 POL00089077. Thank you.
at POLO0089380, we should be able to see 21 This is the statement dated 17 December,
an email between Mr Bole and the Investigator: 22 it's quite hard to read. I'm not going to go
"Please see [Mr Jenkins’ report]. I had 23 through it because we're familiar with it as the
asked him to look at non-polling issue raised in 24 generic statement but just look at the addition
[the] interview and I believe that he had dealt 25 which is on page 2, if we scroll down. Just
129 130
scroll up a moment, he says: 1 that he, Mr Jenkins, was aware of the specific
“I have been asked to provide a statement in 2 issue raised by Mr Allen and didn't follow
the case of Grant Allen. I understand the 3 through in the investigation of it, but this
integrity of the system has been questioned and 4 appears, however, to have been a Post Office
this report provides some general information 5 decision?
regarding the integrity of Horizon." 6 Yes.
Then if we scroll down. There is then, in 7 Looking at that underlying material that we've
the paragraph undemeath, the explanation of 8 ‘examined, rather than it appears to have been
Mr Jenkins’ evidence on the non-polling issue. 9 a Post Office decision not to obtain this data,
Then over the page, at the end of that paragraph 10 the evidence suggests that it was a Post Office
that's at the top of the page, Mr Jenkins says: "1 decision not to obtain the data?
“I have not had an opportunity to examine 12 Yes, the material that you've just gone through
the detailed logs from this period to see 13 is more than I had seen when I wrote my report.
whether there were any issues, and any 14 So would you agree that it's clear that, in the
justification in the claim that this resulted in 15 face of Mr Jenkins saying that the obtaining of
apparent system losses of £3,000 as claimed." 16 that data would resolve the question of what had
Yes. 17 happened in branch, the Post Office took the
So he has provided the generic explanation 18 decision not to obtain the data?
beforehand? 19 Yes.
Yes. 20 Was that consistent or inconsistent with its
But made it clear, is this right, that he’s not 21 duty to pursue reasonable lines of inquiry?
actually looked at the data? 22 Inconsistent.
Yes. 23 And consistent or inconsistent with its duties
You tell us in your report that this was 24 of disclosure more generally?
an unfortunate failure in the evidence, given 25 Inconsistent.
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1 Q__ Inparagraph 545 of your report, which is on 1 Yes, and I also have in mind there the material
2 page 192, you say: 2 I'd seen in context of the case of Mrs Misra and
3 “The greatest concern in this case is the 3 the discussions back, in memory, from 2010 about
4 instruction of and reliance on expert evidence 4 bugs in the system, and it is for others, not
5 from Mr Jenkins to rebut any question as to the 5 me, to opine as to whether those bugs had any
6 integrity and reliability of Horizon. First 6 potential relevance to the issues of Mr Allen's
7 this is because his offer to examine the data 7 case. The generic statement didn't leave any
8 relating to Mr Allen's branch and his complaints 8 room for there being any apparent bugs at all in
9 was rejected in favour of a generic statement.” 9 the system and that, I think, was the concern
10 We've seen that in the underlying material. 10 Iwas also addressing there.
41 A. Yes. "1 You continue:
142. Q. "This was clearly a missed opportunity for which 12 “A generic report was served, which was
13 little justification was advanced." 13 flawed both in relation to the issue and also in
14 Do you stand by that comment in the light of 14 relation to the limitations of the analysis of
15 the underlying material? 15 actual data that would have confirmed whether
16 A. Yes. 16 the Horizon system was operating correctly or
17 Q. “Secondly, given that his generic statement was 7 not. Whilst there was discussion of this with
18 relied on, itis of note that Mr Jenkins was in 18 Mr Jenkins, there does not appear to have been
19 possession of material directly relevant to that 19 any disclosure of these important limitations.
20 question, which is nowhere referred to. His 20 These represented very real disclosure failings
a duty of disclosure ought to have at least 21 in relation to expert evidence that the
22 required consideration of this, and I have seen 22 prosecution was relying on.”
23 no communication to suggest this." 23 Dealing with the two things that you address
24 ‘Again, do you stand by that comment in the 24 there, content of the report first, then
25 light of the material we've looked at? 25 disclosure second, you say the report, the
133 134
1 statement, was flawed in relation to the 1 prosecutor to comply with theirs.
2 limitations of the analysis of the actual data 2 Thank you. Back in paragraph 528 of your report
3 that would have confirmed whether or not Horizon 3 which is on page 186, you refer to Mr Jenkins’
4 was operating correctly. Given that Mr Jenkins 4 September 2010 witness statement — or report,
5 had indicated to Mr Bolc that the data would 5 rather -- conceming the receipts and payments
6 show what had happened at the branch, given that 6 mismatch bug --
7 Mr Bole, in conjunction with the Investigator 7 Yes.
8 Mr Bradshaw, had decided that Mr Jenkins 8 ~ and state that he did not disclose those
9 shouldn't review the data and, given that 9 issues in Mr Allen's case?
10 Mr Jenkins stated in his witness statement, in 10 No.
ca that paragraph I showed you, that he hadn't "1 I think that's one of the things you were
12 examined the data, would you agree that it was, 12 cross-referring back to there ~
13 the Post Office that was responsible for that 13 Yes, yes.
14 flawed approach? 14 ~ the cross-reference back to the Misra case.
15 A. Ultimately, yes. 15 Then forward to paragraph 540 you say that
146 Q. As to disclosure, which is the second and third 16 omission is of particular concern.
17 sentences of that passage I've just read you 17 Yes, insofar as I understood Mr Jenkins’ report
18 there, who was responsible for the very real 18 from September 2010 and put that against
19 disclosure failings that you identify? 19 questions of the integrity and reliability of
20 A. Well, the answer is both the Post Office as the 20 the system that his generic statement sought to
a prosecutor and Mr Jenkins as the expert, because 21 address, it seemed to me that there was
22 both had disclosure responsibilities, and it was 22 a disjunct between what was known by him and
23 for the expert to comply with his 23 what was set out by him.
24 responsibilities as an expert as to disclosure 24 ‘As we've seen in paragraph 545, you said that
25 and it was certainly for the Post Office as the 25 Mr Jenkins’ own duty of disclosure ought to have
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at least required consideration of disclosure of 1 Mr Jenkins’ email to him saying that there had
that issue and you have seen no communication to 2 been 200,000 faults recorded on the system, and
suggest that occurred? 3 the provision of the receipts and payments
That's right and because, again -- and I may 4 mismatch bug report to Jarnail Singh?
just have completely misunderstood the technical 5 Yes.
nature of all of this — but, on the face of it, 6 Is there anything in the papers to suggest that,
the September 2010 report represented material 7 in the Allen case, Mr Singh considered that
that was inconsistent with or potentially 8 these needed to be explained or disclosed when
inconsistent with conclusions that he was 9 the generic statement was being sought?
asserting in the generic statement and, as such, 10 I'm afraid not.
he had a duty to draw attention to that, "1 More generally, is there anything to suggest
irrespective of the prosecution's own 12 that Mr Singh gave consideration to whether any
unquestionable obligation to do so. 13 of those issues needed to be referred to or
Do you agree, however, that in the material that, 14 explained when the generic statement was being
you have seen, there's nothing to suggest that, 15 sought, ie not just in the context of the Grant
the Post Office informed Mr Jenkins of any 16 Allen case?
disclosure duties that he owed personally and, 7 Not that I've seen.
in particular, at the time of the provision of 18 Ought the drafts of Mr Jenkins’ original witness
the generic statement as an expert? 19 statements, in this case Grant Allen, to have
No, that's right. 20 been recorded on the schedule of unused
I think i's right that your knowledge of the 21 material?
Misra case would indicate to you that the Post 22 As in drafts of the generic statements as it
Office lawyer in that case, Jamail Singh, was 23 evolved in this case? Yes, they should.
aware of the Callendar Square bug, the locking 24 In particular, would you agree that that may
issue that had caused transactions to be lost, 25 have revealed the extent to which Mr Jenkins had
137 138
been asked to address four questions and whether 1 Gosh. As a prosecutor, they should have
he had understood that he was being asked to 2 recognised that they had duties under statute to
answer only those questions and nothing else? 3 complete the three Rs in relation to material
Yes. 4 They needed to recognise that they were relying
Have you seen any evidence that in Mr Allen's 5 on the operation of a computer system as the
case the Post Office gave any formalised or 6 basis for a whole series of prosecutions and
reasoned consideration to obtaining, recording 7 that the reliability of that system was
and then disclosing information about Horizon 8 a potential issue in those cases, and that
hardware or software faults held by other 9 material that was relevant to the question or
departments within the Post Office? 10 potentially relevant to the question of
No. "1 reliability had to be retained, had to be
A duty of disclosure doesn't start with the 12 reviewed and had, ultimately, to be disclosed.
prosecutor going to third parties; is that 13 And they had to recognise that, if they were
right? It must look at which material it itself 14 in the Criminal Law Department and that the
possesses? 15 material as to the operation of the Horizon
Yes, I mean, it can think about both things at 16 system was kept in a department down the
the same time but it has to think about what 17 corridor, they needed to go down the corridor.
it's got itself, absolutely. 18 They couldn't just look at what was in their own
What would you have expected for a prosecutor of 19 office.
this nature, ie a repeat player of many year's 20 Did you see any appreciation by either the
vintage it had been in the business of 21 Investigators or the lawyers that there were
prosecuting people for hundreds of years -- to 22 lots of other departments down the corridor,
have had by way of systems for retaining, then 23 including departments that had, as a function
obtaining by a prosecution division, analysing, 24 liaising with the manufacturer and operator of
recording and then disclosing? 25 the system, Fujitsu, over faults with it?
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No, I think the only departments that would get 1 Yes, and so by way of example of that, they
mentioned in, for example, investigators’ 2 might, because they had it from the audit, look
reports, other than the Criminal Law Department 3 at transaction logs which are derived from -- as
that they would be sending their report to, were 4 I understand it, from the Horizon system, but
the Contract Managers and the Auditors. And 5 were things they had because the auditor had got
that's because it was the Auditors that were 6 to them. They wouldn't look at anything that
identifying the shortfall on the system in the 7 they hadn't got, as a result of that process or
first place and the Contract Manager who would 8 ask for it.
be making a decision about whether to sack the 9 Thank you. Can we turn to the case of Angela
postmaster or not. I think that was it. 10 Sefton and Anne Nield.
So no recognition that, down the corridor, as "1 Yes.
you put it, elsewhere within the business, there 12 I think you've noted that these cases were being
were whole teams of people, most of whom were 13 dealt with in an overlapping way, including, in
called managers, whose job it was to liaise on 14 an overlapping way, with Allen; is that right?
a daily basis with the Post Office or between 15 Yes, and the email from Ms Panter we looked at
the Post Office and Fujitsu, over Horizon 16 earlier had a little list of cases, including
faults? 7 that of Mr Allen, including that of these two,
Whether they appreciated that or not, the 18 and Mr Ishaq, as well.
material I've seen doesn't say, because it 19 Therefore similarly, if we tum up FUJ00124105,
doesn't mention them. 20 in the case of Sefton and Nield too on
No. Instead, was the vista that was looked at 21 3 December 2012, Mr Jenkins is making the point
by Investigators and prosecutors, what is within 22 back to Mr Bole:
the Investigation Team and what is within the 23 "Please tell me exactly what you want from
prosecution team, sometimes extending to what 24 me, also in relation to the Sefton and Nield
happened at audit? 25 case."
141 142
Yes. 1 Would you say that Mr Bolc's rejection of
He makes the point in the email that he hadn't 2 obtaining the ARQ records in these cases was
been presented with any audit data relating to 3 consistent or inconsistent with the approach of
any of these cases, including Sefton and Nield 4 an open minded prosecutor?
to examine — 5 Inconsistent. It was a reasonable line of
Yes. 6 inquiry, it was allied almost inevitably to
-- and he makes suggestions about what might be 7 duties of disclosure.
done? 8 Mr Jenkins signed a witness statement in this
Yes. 9 case on 5 December 2012, that's POL00059424.
If we go to POLO0089394, and go down to 10 I think this is 5 December, maybe 6 December
3 December, reply from Mr Bole: "1 2012, identical to the generic statement that
“The only clarification I think I need at 12 had been signed back in October 2012, except for
the moment relates to the timeline, 2005 removal 13 an additional paragraph addressing an aspect of
of cash ... Could you clarify what this means 14 Ms Sefton and Ms Nield's case. If we scroll
and discount it as a possible explanation for 15 down, we can see that. It begins, in substance:
the losses beginning to occur at that time in 16 "I have been asked to provide a statement in
the Sefton and Nield case. 17 the case of Angela Sefton ... I understand that
“The audit reports will simply show the 18 the integrity of the system has been questioned
money missing so will not take things further.” 19 and this report provides some general
Again, does that contain the loaded language 20 information regarding the integrity of Horizon."
about which you were critical before? 21 Then if we go over the page, please,
Yes. 22 a generic statement that we're all familiar
Because it's an instruction as to what to do: 23 with. If we carry on, please. If we scroll
discount something as a possible explanation? 24 through, just to see that this is the generic
Yes. 25 statement that we're familiar with —
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Yes. 1 the change has no impact on the overall
--and keep going. Then just over the page, 2 integrity of the system as outlined in the
please, we can see the line at the conclusion, 3 statement.
where Mr Jenkins says: 4 You've seen now how the generic statement
*... [would conclude by saying I fully 5 ‘came about and the emails involving Ms Panter
believe [the Horizon system] will accurately 6 and Mr Bole, on the one hand, and Mr Jenkins, on
record all data that is submitted to it and 7 the other, in November 2012, insofar as that
correctly account for it... it cannot 8 statement was adapted to deal with the Sefton
compensate for any data that is incorrectly 9 and Nield case.
input into it as a result of human error, lack 10 A. Yes.
of training or fraud (and nor can any other 11 @. Would you agree that those underlying
system)." 12 ‘communications demonstrate that it was the Post
I think I skipped over — I think it was 13 Office's idea and intention that the statement
page 2, if we can just go back to page 2. 14 should be a generic one?
Yes, there's a reference to the defence 15 A. Yes.
statements on page 2. 16 Q. Thatit was represented to Mr Jenkins, secondly,
Yes. If we scroll down, please. Yes, there: 7 that the cases in which his generic statement
Losses started in 2005, and that Horizon was 18 was being provided were not cases which raised
installed at that time. Horizon was rolled out 19 specific Horizon issues?
in 1999 and 2002, so I am surprised at the 20 A. Specific issues, no.
reference to 2005. There was a change 21 Q. That when he sought clarity on what that meant
implemented in late 2005, the removal of the 22 and what could be done, the Post Office, through
weekly cash report. They were thoroughly tested 23 its lawyers, declined suggestions that further
at the time. There's been no indication of 24 investigations be carried out?
there being any issues regarding this change and 25 A. Yes.
145 146
He wasn't in any case, fourthly, provided any 1A. Yes, the same point I made in relation to
instructions, proper instructions, as an expert 2 Mr Allen and that case
in these cases? 3° Q We should read that across?
No. 4 A Yes.
Less still instructions that were specific to 5 MRBEER: Thank you very much.
the issues that arose in any of these cases? 6 Sir, i's 2.55 now. I wonder if we could
Quite. 7 take the afternoon break now and retum at 3.10.
In paragraph 566 of your report, which is on 8 SIRWYNWILLIAMS: Can you just give me a clue about
page 199, you say that Mr Jenkins’ statement in 9 how much longer you will be and whether or not,
the Sefton and Nield case is generic in its 10 there are likely to be questions from Core
content. It mirrors that served in the case of "1 Participants’ representatives?
Allen, in which Mr Jenkins’ statement reviewed 12 MRBEER: Sir, yes, I'm intending to pick up at 3.10
data specific to that defendant and said he had 13 and finish by 4.00. I think there will be some
also run through hypothetical issues with 14 questions from two or three CP representatives,
integrity, and concluded there was no evidence 15 each of which is five minutes, or so.
of any issues? 16 SIRWYN WILLIAMS: Right. Fine. Thank you.
Yes, in fact, i's clearer to me now from the 17 (2.56 pm)
material I've further seen that he hadn't 18 (Ashort break)
reviewed data specific to that defendant in the 19 (3.10 pm)
way that I thought he had. 20 MRBEER: Good afternoon, sir, can you see and hear
Thank you very much. You tell us in 21 us?
paragraph 565, which is on page 198, that 22 SIR WYN WILLIAMS: Yes, thank you
there's no reference by Mr Jenkins in his, 23 MRBEER: Thank you very much, sir.
statement to his own 2010 report addressing 24 Can we turn to the case study, Mr Atkinson,
a fix for an identified bug. 25 lastly, of Khayyam Ishaq. Can we dive straight
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in with the material, please, by looking at 1 "Please see below. I have read the expert's
POL00059481. Again, this about the genesis of 2 report and it is perfect.”
Mr Gareth Jenkins’ statements. 3 In your report, it's paragraph 611, on
If we scroll down, please, email from 4 page 215 — no need to display it at the
Mr Jenkins to Ms Panter of 8 January. Copied to 5 moment — you characterise generally Mr Jenkins’
Penny Thomas: 6 statement of 15 January 2013, which is the one
"Rachael, 7 being referred to in these emails, as a generic
“I've taken my previous statement and 8 one,
amended it to refer to the Ishaq case." 9 A. Yes.
That's the generic statement that he's 10 Q. Inthe light of the emails that we've just
saying he's taken. "1 looked at, would you agree that this was a case
Yes. 12 in which the Post Office sought a generic
“Reading through the Prosecution and Defence 13 statement from Mr Jenkins?
‘Summaries, I don't think there is anything for 14 A. Inthe main, yes, although the email chain that
me to comment on specifically. 15 we're looking at here, the email that we started
"Please can you confirm this is all you need 16 at was a response from Mr Jenkins to an email
in this case, and if so I'll get a signed copy 7 from Ms Panter on ~
together with the related exhibits to you.” 18 Q. Yes, if we scroll down in this chain. Sorry to
Then if we scroll up, please. 19 speak over you, Mr Atkinson.
"Morning Gareth 20 A. No, notatall. The email header is at the
“Thank you for your statement which I have 21 bottom of page 3 but the content is on page 4.
had an opportunity to read. There is nothing 22 So the bottom of that page.
that you need to add, it covers everything.” 23 Q. Keep going.
Then forwarded by Ms Panter to Martin Smith, 24 A. And so Ms Panter is sending Mr Jenkins and
if we scroll up: 25 copying a cast of thousands into a list of cases
149 150
and indicating what, in some instances, she is 1 @ Here -
sending him. 2 A. I don't share her view as to its perfection.
If we scroll down a little further. 3. Q._ Here she's providing him with a copy of the
Point number 5, in relation to the case of 4 indictment, the summary of facts, and the
Mr Ishaq, she provided him with a number of 5 defence case statement —
documents for his consideration, having asked 6 A. Yes.
him to prepare a report in that case and 7 @ ~and identifying a claim by Mr Ishaq that he
essentially setting out what Mr Ishaq was 8 was not dishonest, he had to make reversals in
saying. And so it is not absolutely clear what 9 order to balance and that there had been
itis she was asking him to do, other than to. 10 a malfunction with the Horizon system?
prepare a report, but she was not, on the face 11 A Yes.
of that paragraph, telling him not to properly 12 Q Can we go forwards, then, a couple of weeks,
examine the issues in relation to Mr Ishaq. 13 until after this statement had been signed off,
I can understand, given the context and the 14 to the 31 January 2013, POL00089427. If we
history that we have gone through, why he may 15 scroll down, please, to 31 January. There we
have considered she was just asking him to sign 16 are, thank you. Rachael Panter to Gareth
a copy of his generic statement for Mr Ishaq's 17 Jenkins and lots of other people:
use but, equally, it was open to him to have, as 18 "The week of 11th ... will be fine..."
he did in other cases that we've looked at 19 Sorry, if we can scroll down a little
earlier, flag up things that had occurred to 20 further, and again:
him, having looked at those materials. 21 “Ishaq ~ Having served your report, the
Indeed, when he did provide a generic statement, 22 defence have queried it and are claiming that
strictly generic statement, she, Ms Panter, 23 Ishaq had to make false entries in order for the
regard it as "perfect"? 24 figures to reconcile, as the Horizon system kept
Yes. 25 malfunctioning.”
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That is something that he'd originally said? 1 to have been provided to an expert, nor provided
Yes. 2 him with all of the material relevant to the
"Please could you make a note in your diary as 3 issues in the case, nor giving him instructions
you will be needed to clarify our position with 4 as to what material himself to obtain?
Horizon." 5 No, quite.
Then can I just check there's nothing 6 Looking at what should have been done, would
underneath this email. Yes, if we just scroll 7 this be right: the lawyers and the Investigator
up, please: 8 should have looked at the defence statement and
“Our barrister has asked if you could read 9 seen what disclosure obligations it gave rise
the Defence case statement attached and make 10 to?
a list of your initial thoughts on the "1 Yes.
assertions he is making. We may need you to add 12 Looked for what issues that it raised and which
a few of these comments into your report so that 13 questions, therefore, required to be answered,
each issue is addressed.” 14 and whether they were to be answered by expert
Do you consider it an appropriate or 15 or lay evidence?
inappropriate approach to send a defence 16 Yes.
statement to a prosecution witness, whether 7 If expert evidence, properly to have instructed
an expert or not, for generalised thoughts or 18 an expert with written instructions complying
comments? 19 with the obligations I mentioned earlier?
It's unusual, certainly, in relation to 20 Yes.
an expert, and I can't imagine it happening in 21 Do you agree that, in addition to being provided
relation to a non-expert witness. 22 with relatively scant information —
In particular, was it appropriate, given the 23 an indictment, a case summary and a defence
context, that the Post Office had not given 24 statement -- asking Mr Jenkins to comment on the
Mr Jenkins the kind of instructions which ought 25 defence case or provide comments on a defence
153 154
case was risky? 1 disclosure issues because his answers were
I suppose it would depend on what they planned 2 rather unprepared by anything they'd given him
to do with what he came back with but, 3 This shift in approach from "the generic will
certainly, if they were then going to comply 4 do’, to now "We're delving into the specifics of
with their obligations properly, yes, it was. 5 a case", was that a moment for the lawyers to
I mean, previously, the instructions had been 6 grasp the instruction of an expert with both
“Don't look at the specifics of any case, your 7 hands and to do it properly?
generalised generic statement will do". They 8 Yes.
were now saying, "We've got a defence statement 9 Can we look, please, at Mr Jenkins’ comments on
here, can you provide comments on it?" and 10 the defence case statement, POLO0059602,
you're saying that the risk that arose or the "1 “Comments on Ishaq [defence case statement]
caution that needed to be applied was dependent 12 DCS", authored by Mr Jenkins on 1 February. He
on what was intended to be done with the reply? 13 says he's been asked to comment on the defence
Yes, and I suppose the issues might arise if 14 case statement:
Mr Jenkins identified something in an aspect of 15 *... [have copied in the [statement] below
the defence statement that was nothing actually 16 in blue font and added my comments in black
to do with him, and expressed his view, for 17 font,
example, on the honesty or dishonesty of 18 “I'm not sure that the responses are of much
someone. That would give rise to issues in and 19 use and I don't think there is anything that can
of itself. But, assuming that he focused on 20 really be added to my statement as a result.
those aspects that had a technical element to 21 However if you feel any of this could usefully
them, then clearly his answers to them were, 22 be added I'm happy to be convinced.
potentially at least, disclosable and, given the 23 "Much of it relates to requiring further
lack of focus as to what they were asking of 24 data for analysis, and past experience indicates
him, it could give rise to all kinds of 25 that help may be required in understanding it.”
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I think you've seen this document. 1 experience with the operation of Horizon. They.
Yes. 2 were being told by their expert that an analysis
Mr Jenkins, in addition to suggesting that 3 of the data would assist in relation to that,
further data may be required for analysis and 4 and that they didn't need to wait for Mr Ishaq
that help may be needed in order to understand 5 to give them further and better particulars to
it, indicates, in relation to Horizon 6 know that that's what clearly needed to happen
malfunctions, that: 7 next.
“if the defence can specify some examples of 8 If there were further and better particulars
this, I'm happy to investigate. However, 9 from Mr Ishaq, clearly that would further aid
I would contend that the system doesn't 10 the process but they weren't an essential
malfunction with leaving some trail to indicate "1 prerequisite to anything being done at all
what has happened. Without examining the logs 12 In paragraph 611 of your report, that's
itis difficult to be more specific.” 13 page 215, you say:
In the light of that, do you agree that, at 14 *... the default statement and exhibits of
the very least, there ought to have been 15 Gareth Jenkins were served in this case. As has.
a discussion or a formal follow-up to the 16 been discussed before its service, the statement
comments made about the need for further data 7 isa generic one.”
analysis ~ 18 Do you agree that the provision and then
Yes. 19 service of a generic statement reflected the
~in order for Mr Jenkins to be able to look at 20 Post Office's intention that the statement be
the system malfunctions that Mr Ishaq had 21 a generic one?
complained about? 22 Yes.
Yes, wel, i's again a two-stage matter. So 23 Although Mr Jenkins explained his ability
far as the prosecution's obligations are 24 further to investigate the specific malfunctions
concerned, Mr Ishaq had raised concerns from 25 of which Mr Ishaq had raised, the Post Office
1587 158
did not, in fact, ask Mr Jenkins to do so? 1 ‘emphatic terms than he did here "If I'm asked
No, that's right. 2 questions about the operation of the Horizon
The further observation I'd make about that, 3 system in relation to this particular post
though, is that Mr Jenkins was being told that 4 office, I need to look at the data to do that".
he was -- in the earlier emails we'd looked at 5 What about the suggestion that that was
from Ms Panter, was being told that he was going 6 a function of the instruction of him being
to be called at trial to give evidence as to the 7 rather muddled, that he was told initially that
integrity of the Horizon system. In his mind, 8 the case raised no specific Horizon issues, then
to do so needed ~ in that case, and given what 9 he was provided with some information about it.
was being said by the defendant in that case, he 10 He wasn't asked to analyse underlying data.
needed to look at the underlying data. So it "1 What was he to do?
wasn't just a matter for the Post Office, it was 12 That the instructions were muddled is clear.
a matter for the expert, exercising independent 13 That they were inadequate is clear. That he
judgment, to make clear to them that to do that 14 could have gone back to them and said more,
he would need to look at the data, rather than 15 I consider also to be clear. I can understand
it was just an option 16 how it came about but that doesn't mean that it
Are you saying that that should have been done 17 was not, in my view, clearly incumbent upon him
by him because he knew that he was going to be 18 to at least continue that discussion before he
called and there would therefore come a moment 19 found himself in the uncomfortable position of
at which it would be crunch time? 20 the witness box dealing with these matters,
Yes. 21 having identified that there is work that he
He would be asked or he might be asked about 22 could do, better prepare himself for it, and not
specifics? 23 being asked to do it.
So, at the least, he could have said in the 24 By September 2012, at least Cartwright King was
course of these exchanges in clear or more 25 aware that the defence had intended to instruct
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a forensic accountant. The cross-reference to 1 day of trial to respond to, or discuss matters
that -- we needn't look at it — is POLO0119433. 2 with, a defence expert was alarming, given that,
Then four or five months later, Mr Jenkins was 3 Mr Jenkins had not been told about any expert
told about that. 4 before then?
If we look, please, at POL00059808, if we 5 That counsel had asked that there be a meeting
scroll down to 14 February, please, thank you 6 between the experts to narrow the issues, in and
“An update for you [Gareth]", from Ms Panter: 7 of itself, was a reasonable thing for them to
“Our counsel Mark Ford would like you to 8 have done. The rules now very much envisaged
attend court on the Monday ... before the start 9 that there will be a meeting between experts in
of the trial to allow you to discuss the case 10 advance of the trial, in order to narrow the
with the defence ‘expert’.” "1 issues but that is in advance of the trial
This seems to be the first, I should say, 12 rather than on the day it starts, in the normal
that Mr Jenkins knows that there is an expert. 13 course of events.
Yes. 14 The experts would not come upon each other
“I think the rationale behind this is to narrow 15 by chance at that meeting. They would know in
any issues we may have with the defence from the 16 advance what the other one was saying, so that
outset so as to reduce the amount of time you 7 they could have assessed the contents of those
are required to attend 18 reports. So it isn't a matter just of
“Our counsel is still waiting to hear from 19 Mr Jenkins’ travel arrangements that needed to
defence counsel and will update us if any issues 20 be planned in advance; he also needed to see the
arise. However your presence on the first day 21 material in advance and arrangements needed to
will still be required so you can make your 22 be put in place for how the experts were to
travel arrangements." 23 meet, what they were going to address and how
Would you agree that suggesting to 24 what they discussed was going to be recorded, so
Mr Jenkins that he should attend on the first 25 that others outside that meeting thereafter knew
161 162
the outcome. 1 a meeting, to either decide whether to agree or
So, before this time, Mr Jenkins ought to have 2 to disagree with suggestions made in the defence
been told at least that there existed a defence 3 expert report?
expert? 4 Yes. Clearly, that would be a more realistic
Yes, and if it was contemplated that he would 5 possibility if he had reviewed the underlying
need at any point to respond to anything in that 6 data himself before producing his original
report, which was perhaps inevitable, then he 7 reports that Ms Ibbotson's report was a response
needed to see the document from the expert, as 8 to. But yes, one of the reasons why an expert
well 9 should see any other expert's report in advance
Yes, ie the defence expert report? 10 is so that they can check it.
Yes. "1 Can we look, please, at FUJ00153977. We're now
You don't just walk into the room with your 12 on the Monday, Monday, the 18th, and we can see
hands in your pockets and say, "What have you 13 that Mr Jenkins has a conversation with Penny
got to say?” 14 Thomas. Can you make out the conversation?
No, quite: "Who are you and what are you doing 15 Yes.
here?" 16 “Next week I'm going to Bradford for the Ishaq
Yes. 17 case. I see you had some ARQs on this", and he
Yes. 18 gives the string of them.
Moreover, Mr Jenkins would not have known what 19 "Do you still have the info you can pass to
material the defence expert had himself or 20 me easily?"
herself examined? 21 Then he gives the branch code.
Quite. 22 “L.can copy all you quote above out for you.
It would also, would this be right, mean that it 23 "That would be good, so at least I have the
would be difficult for Mr Jenkins himself to 24 info, even if I don't have time to analyse it!”
revert to any underlying data in advance of such 25 So it's apparent that Mr Jenkins was seeking
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to obtain material that might help him to answer 4 Q@_ Moving on closer to the trial, then, to
questions and liaise with the defence expert, 2 22 February 2013, which I think is the Friday
even though he had not at that stage been 3 before the Monday, can we look, please, at
provided with a copy of the report or known 4 FUJ00153990. If we scroll down, please, we can
which issues to address? 5 see some travel arrangements being referred to
Yes, it's not clear to me where he had seen that 6 on the 18th. Then, if we go up, please. We can
they had some ARQs, whether that was because 7 see Ms Panter's reply, if we keep going.
they were referred to in Ms Ibbotson's report or 8 On the 22nd at 11.15 in the morning, there's
they were referred to in something else but, 9 ‘some material about the Wylie case and then
clearly, something had told him that there was 10 “Urgent”. We can see there's an attachment
ARQ material available and he had rightly "1 “Addendum (defence case statement":
recognised that he ought to see it 12 *... Please see attached
How concerning was it, as the prosecutor, that 13 "The defence solicitors in the case of Ishaq
the Post Office was asking Mr Jenkins to go to 14 have served an addendum defence case statement
court to respond to expert evidence without him 15 on us this morning, which attempts to
having seen it? 16 particularise the problem with the Horizon
Well, it's moderately remarkable. To expect any 7 system.
witness, but certainly an expert witness, to 18 "Please could you have a look at the
deal with complex issues and to try and narrow 19 ‘comments that they have made and try to address
those complex issues with another expert, not 20 as many of the points as you can, in order that
knowing what that expert said, not knowing what, 21 we can email that to our counsel Mark Ford ahead
material they had seen, not being able to check, 22 of Monday's trial
either, anything that they had said or that they 23 *... apologies for such a last minute
have seen; I can't quite think how anyone 24 request, I think there is no coincidence that
thought that was a good idea. 25 the service of this addendum [defence case
165 166
statement! is last minute.” 1 provided with information that could be obtained
So at this point, there hasn't been, it 2 by the Post Office, in order to consider the
seems, an attempt on the lawyer's part, 3 very points raised by Mr Ishaq
Ms Panter's part, to analyse the defence 4 A Yes.
statement herself and isolate from it issues 5 Q@ Canwe go forward to FUJO0156747. If we see,
that Mr Jenkins would in writing be asked to 6 we're on the 25th now, the first day of trial,
deal with? 7 at 9.37 in the morning. Martin Smith is sending
No. 8 to Mr Jenkins the expert report —
It's just a forwarding and saying, "Please deal 9 A. Yes.
with this", essentially? 10 Q. —with a blank email
Yes. 11 A Yes.
Mr Jenkins’ response to that, please, 12 Q. Sojustan attachment?
FUJ00153997. If we see this reply at 1.10 the 13 A Yes.
same day, the Friday: 14 Q@. Thisis Beverley Ibbotson's report and, later
“I've added my comments to the [amended 15 that day, if we look, please, at FUJ00154006,
defence case statement] 16 Ms Ibbotson herself sent Mr Jenkins, just after
“have now had confirmation that Fujitsu 17 2.00, the appendices -- and there are lots of
have not supplied any details of any Helpdesk 18 them — to her report, which Martin Smith the
calls to Post Office Ltd regarding this Branch. 19 solicitor had not done. I think we can follow
There is nothing I can easily do to address any 20 that up by looking at the attachment to Martin
specifics.” 21 Smith's email earlier in the day.
If we scroll down, please. That was the 22 A. Yes.
response to the last-minute request. 23 Q. You will see it was just the bald report -~
Again, Mr Jenkins was pointing out to the 24 A. Yes.
Post Office's lawyers that he hadn't been 25 Q. ~rather than the attachments.
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So was the result of that, to your 1 Yes. The focus in this case appeared, from the
understanding, that Mr Jenkins had to deal 2 investigative and prosecutorial point of view,
overnight with this rather detailed forensic 3 to be that Mr Ishaq had made allegations against
accountancy report, which he had seen for the 4 an employee or a colleague. There was a lot of
first time on the first day of trial? 5 focus on him and not a lot of focus on anything
A. Yes, that would appear to be the position. 6 else.
Q._He wasn't, unlike Ms Ibbotson, a forensic 7 If we turn up paragraph 619 of your report,
accountant? 8 which is on page 218, you say, at 218, and then
A. No. 9 paragraph 619:
He hadn't been provided with any formal written 10 “Although Mr Jenkins was engaged, he was not
instructions to be an expert in the case nor had "1 asked to analyse the underlying data, and there
he been provided with any broader background to 12 were serious shortcomings to the disclosure of
the case? 13 material within his knowledge relevant to the
A. Beyond as we've seen -—- 14 operation and reliability of the system, and as
Q._ Indictment case summary, defence case statement? 15 to cross-disclosure from ... other cases. This
A. Yes. 16 continued to be the position even after focused
Q._ He had not been asked to obtain the data, 7 defence requests and the instruction of
albeit, off his own bat, had obtained some ARQ 18 a defence expert who, like other experts before
data — 19 her, relied on the material and information
A. Yes. 20 provided by Mr Jenkins to reach her
Q. ~from Penny Thomas. Would you agree with my 21 conclusions."
characterisation of this episode of this part of 22 That last part, is that, in fact, in error,
the prosecution being run chaotically, and with 23 that she wasn't reliant on what Mr Jenkins
little or no grasp as to the significance of the 24 provided her?
need properly to instruct an expert? 25 Yes, I think that must be right.
169 4170
Q._In this case, as in others, is it right that 1 Yes.
disclosure was not made in relation to the 2 Regarding the Fujitsu helpline, you're further
earlier bugs, errors and defects in particular, 3 aware that that had four layers to it: a simple,
which had emerged in the Seema Misra case? 4 if you like, answer the telephone and, we
A. That's right. 5 believe, driven by scripts; those answering the
MR BEER: Thank you. Those are the questions that 6 telephone, our clients say, would basically tell
ask you. There may be some additional 7 our clients to pay up if there was a shortfall.
questions from other Core Participants, I think 8 But there were also other layers to the
starting with Mr Stein. Thank you 9 helpline run by Fujitsu, which were resolving
Questioned by MR STEIN 10 issues if there were issues concemed with the
MR STEIN: Mr Atkinson, you're aware that, "1 Fujitsu Horizon system; is that correct? You're
I represent a large number of subpostmasters and 12 aware of that?
mistresses. 13 Not to any great extent and not least because
A. Yes. 14 there wasn't very much discussion of the
Q._ You answered questions from Mr Beer earlier on 15 different layers of the Fujitsu helpline in any
as to whether there was a system in place that, 16 of the material that I saw.
allowed those investigating or lawyers dealing 17 But outline, you're aware that there was such
with the prosecution of subpostmasters the 18 a helpline —
ability to access material down the corridor? 19 Yes.
A. Yes. 20 ~ and you're aware that there were individuals
Q._ Can we just take that one stage further. You're 21 involved in the process of and fixing issues,
aware, I believe, that there were two helplines 22 bugs, errors, defects, within the Horizon
set up for subpostmasters and mistresses, one 23 system, insofar as they could?
set up by the Post Office itself, and the other, 24 Certainly I was aware that there were people who
if I can call it loosely, a Fujitsu helpline? 25 could be called at Fujitsu when there was
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a problem, whether it was identifying bugs or 1 A. No. Onthe contrary, they would -- when they
not is a separate question. 2 did it at all, would look just at calls from the
All right. So not only would you have, if 3 person they were investigating to the helpline,
you're investigating a particular branch, 4 rather than, on some occasions, even other
an inability to access a library of faults and 5 people at the same branch:
problems with the system, but also, have you 6 Q Sowe've gota lack of access to, overall, the
seen any way that Investigators and lawyers 7 picture of what's going on and the faults within
would have access to the results of the 8 the system, we've got a lack of overall access
telephone line complaints system? 9 to the complaints and the difficulties that are
Well, they were clearly able to obtain records 10 being encountered by subpostmasters, mistresses;
and the contents of contact with the Post "1 do you agree?
Office's own helpline, because there are 12 A. Do you mean access by a defendant?
references to that. They were clearly able to 13 Q. Access, first of all, by Investigators and the
obtain records of and the content of contacts 14 lawyers?
with the Fujitsu line because there were 15 A. Inthe sense that they didn't access it, rather
occasions when ~ I think it was a gentleman 16 than they couldn't access it?
called Mr Dunks made statements in particular 17 Q Yes.
cases about selections from that. 18 A. Yes, lagree.
Did you see anything to suggest that there was 19 Q. Let's move on to the other way round. Now,
a joined-up type of thinking, that when one 20 you've been giving evidence in relation to the
subpostmaster was saying that the system won't 21 system of disclosure that is operated through
work, can't find out what it is, there are these 22 the criminal justice system in the criminal
problems, and tried to explain it, that that was 23 courts?
then linked to other individuals that were 24 A. Yes.
making similar complaints? 25 Q. That's a system that operates in both the
173 474
Magistrates Court and the Crown Court, yes? 1 @_ Okay. Clearly, until there is disclosure by the
Yes. 2 Post Office of the bugs, errors and defects
You've been giving evidence about the disclosure 3 within the system and the problems that the
system that is used by prosecutors. Can we 4 system can cause, in other words create
reverse the coin. So where an individual 5 shortfalls, create hidden losses, it is very
defendant is seeking to make further 6 difficult for the defence to make applications
applications for disclosure, there's a system 7 based upon that material?
for that, as well, isn't there? 8 A. Yes.
Yes. 9 Q. The applications that can be made through the
Right. So what we have, in fact, as a picture 10 process, Section 8 applications — is that
that relates to disclosure is, in theory, how it "1 correct --
should operate is that the prosecution should 12 A. Yes.
identify relevant material that might or may 13 @. —and that would be essentially saying that "We
assist the defence case? 14 wish to have material that relates to.
Yes. 15 a particular aspect of a defence case"?
Okay. Now, there then is a system that relates 16 A. Well, i's asserting we have reason to believe
to the provision of a defence statement by 17 that you have material that will help us in
an individual, where the defence statement, it's 18 relation to this.
not mandatory but, essentially, it is what 19 @. Yes. The way that that can work -- and you've
happens in the courts. The individual will then 20 prosecuted many cases and you well know that
set out what their case is? 21 Ihave defended in many cases ~- the situation
Yes. 22 is that a defence, once on notice of such
Okay. Now, that system has been in operation 23 material, can then make an application for it
now for sometime? 24 If you're prosecuting the case, you can respond
Yes. 25 with the release of material that you believe is
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relevant to that request; is that correct? 1 we don't, in fact, find that there's much of
Yes. 2 an ability for the criminal justice system to
That process can continue. In fact, it can be 3 bite on these disclosure provides as you go
quite a continuation of a process as more and 4 through, unless you get that starting point
more material is targeted and found for 5 right?
disclosure purposes? 6 All that can happen is that, against a blanket
Yes. 7 of silence in relation to a particular topic, is
Eventually, a judge is brought in to sometimes 8 the defence can ask for disclosure of material
resolve any issues that lay between the parties? 9 that might touch on the reliability of the
Yes, and the stage that can intervene between 10 system, as in most of these cases they did. But
those is ~ particularly after the service of "1 there is a limit to how far that can go,
a defence statement, and as was the case in most 12 certainly in terms of any particularity, without
of these cases, there are letters from defence 13 something to bite on, you're right.
solicitors asking for further disclosure without 14 Now, other aspects that you've been discussing
got in the extent of waving Section 8 at the 15 with Mr Beer relate to individual subpostmasters
prosecution, because the prosecution have 16 that have -- Mr Holmes is an example of this —
a continuing duty of disclosure, and so the 7 that have complained about the system, said that
defence ask, and itis often if the prosecution 18 the machine wouldn't work, essentially, is what
either responds saying no, or don't respond, 19 he's saying —
that a Section 8 application may follow. 20 Yes.
Yes. Where we're talking about the starting 21 — and that he rolled over, essentially, didn't
point, the inability or the failure to look into 22 account for those losses in the way that
the questions of errors and defects within the 23 arguably the Post Office required because,
system that you've been discussing with Mr Beer, 24 otherwise, he couldn't be the Post Office open.
when we're looking at that as a starting point, 25 You're aware of that?
177 178
Yes. 1 I think, slightly disentangling that, I think
So, essentially, people were placed in 2 from the position of those acting for
an invidious position, do you agree, that 3 a defendant, where they were -- their
sometimes faced with what was an unaccountable 4 instructions were, if they were in accordance
loss, they would then have to try to account for 5 with the interview, "I don't know why this
it, and those sorts of cases were dealt with in 6 happened but it must be the system because
the Criminal Court of Appeal in the case ~ the 7 I can't explain it otherwise”, that they would
combined case of Hamilton, so that individual 8 be up against, particularly once generic
pleas of guilty, even to false accounting, were 9 statements started floating about, a positive
overturned; do you agree? 10 assertion that there isn't something wrong with
I'm not sure it's for me to express a view on "1 the system
the nature of their position. I can confirm 12 So you have, on the one hand, a defendant
that that is what was said in a lot of these 13 saying "It must be the system", you have the
cases that I considered, and what was said in 14 prosecution's evidence saying "It is not the
a lot of other cases as well that were dealt 15 system", and you then have to decide whether you
with under the blanket of the Hamilton decision. 16 allow your client to proceed to trial against
The burden on criminal solicitors and defending 17 that wall or whether you discuss with your
solicitors and defending counsel was therefore 18 client the possibility that a plea to something
made rather ~- I was about to say more 19 less than theft will keep them out of prison.
difficult, but made very difficult indeed, 20 And that's a decision I wouldn't ~ or
stymied in relation to disclosure processes and 21 a conversation I wouldn't envy anybody.
an entire system that seemed to thwart the 22 You've been referred by Mr Beer to a document ~
ability for subpostmasters to make good what was 23 Ill take you back to it, please -- POLO0059424,
going on at the Post Office branch; do you 24 the statement of Mr Jenkins.
agree? 25 I've seen a few of those.
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Q. Myscreen is not working, so I'm just going to 1A. No, I mean, it's not - because they didn't
use Mr Jacobs’, so I can see it from afar. 2 discuss with Mr Jenkins or provide for
Now, you'll see there that, in relation to 3 Mr Jenkins instructions as to his role as
Mr Jenkins’ statement, that, if you look at the 4 an expert at all. There's nothing in the Post
first page, and if you take your eyes down to 5 Office communications with him that told him at
the first part of the page, you'll see 6 that time.
a sentence that says: 7 Q__Isthat anormal sentence or paragraph to find
“However I understand that my role is to 8 within a statement, an ordinary witness
assist the court rather than represent the views 9 statement?
of my employers or Post Office Limited." 10 A. It's part of a normal sentence —
A. Yes. 11 @_ Normal for who? Normal for what type of
Q._ Now, in your statement, as an example at 12 sentence?
page 241, paragraph 674, you discuss there your 13 A. Well, you would normally expect to see a much
issues that have been brought to your attention, 14 more detailed explanation of an expert's
regarding the instruction of Mr Jenkins? 15 understanding as to what their role was and who
A. Yes. 16 they were there for. You might find a sentence
Q._ Have you found anything within the material that 7 rather more like that in the statement of
you've examined that explains why it is in 18 a witness who is making clear that they're
Mr Jenkins’ statement -- he also refers to his 19 speaking for themselves, rather than for their
own statement as a report, within the body of 20 ‘employer, for example if they were giving not
that document - have you found anything that 21 expert evidence but factual evidence about
explains why it is Mr Jenkins’ report/statement 22 a situation that occurred at work, they might
says, "However I understand that my role is to 23 make clear they were speaking for themselves
assist the court, rather than represent the 24 rather than for anybody else.
views of my employers or POL"? 25 But, if this was seeking to be ticking the
181 182
boxes of the Criminal Procedure Rules in 1 convictions overturned.
relation to what a statement from an expert 2 A. Yes, thank you
should say about their role as an expert, then 3 Q._I wish to just ask you about the case of Khayyam
it doesn't do it. 4 Ishaq and if at any time you can't hear me,
Q._Butit’s a curious sentence to have within such 5 please say so.
a statement, because what it appears to do, at 6 A. You're very kind!
least in part, is provide a direction of travel 7 Q@_Iwant to ask you about disclosure around what
going towards an expert report; do you agree? 8 happened in Birkenshaw Post Office after
A. It perhaps shows an awareness that he was. 9 Mr Ishaq was suspended. Now, Mr Ishaq was very
providing evidence as an expert without really 10 clear from very early in the proceedings that
understanding what ~ or at least setting out "1 the Horizon system was the cause of the apparent
what that meant. 12 shortfalls he'd suffered?
Q._ Yes, and, obviously, you're not privy to any 13 A. Yes. I think he also made reference to someone
discussions, oral discussions, between 14 else who worked there but Horizon was part of
Mr Jenkins and solicitors or advisers on behalf 15 his account from the outset.
of the Post Office. 16 Q. Right. He was essentially saying that one of
A. No, or indeed of Fujitsu 17 the people who had worked there had also done.
MR STEIN: Thank you, Mr Atkinson 18 the balances —
MR BEER: I think Mr Moloney has some questions, as 19 A. Yes.
well, sir. 20 @. ~and so that needed to be looked at?
Questioned by MR MOLONEY 21 A. Yes.
MR MOLONEY: Thank you, Mr Beer. 22 Q Absolutely.
Mr Atkinson, I represent a large number of 23 A. Yes.
postmasters, all of whom were prosecuted and 24 Q. Indeed, you referred to that gentleman,
convicted and all of whom have since had their 25 Mr Liaquat Ali during your evidence when being
183
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asked questions by Mr Beer. 1 establish whether the subsequent subpostmaster
Yes. 2 had any problems with the Horizon system after
I want to show you a few documents, if I may, 3 all the kit in the branch would have presumably
around this issue I've raised about disclosure 4 remained the same.
after Mr Ishaq was suspended and get your views 5 "Many thanks.
on the disclosure process around this issue, 6 "Martin."
yes? 7 Yes.
Okay. 8 So what we see there is that, by 28 January,
So the first document I'd like you to look at, 9 Mr Smith thought it a good idea to prove that
if you would, is POLO0119445. Here we are. 10 any discrepancies could not be due to the
This is an email from Martin Smith on 28 January "1 Horizon system or its associated kit by
2013, and it's to Steve Bradshaw who was the 12 reference to what had happened to the
Investigator in this case? 13 subpostmasters after Mr Ishaq had been
Yes. 14 suspended?
The lead investigator, copying in Mark Ford, now 15 Yes.
Mark Ford King's Counsel, who was prosecuting 16 By 31 January, that email being 28 January, so
counsel in the case? 7 some three days later, Mr Bradshaw had completed
Yes. 18 and signed the statement, which was served as
Usual introductions, but the final paragraph I'd 19 part of a note of additional evidence. That
like to take you to, it's down towards the 20 statement is POL00059592. So this is three days
bottom of the page, and we can probably read it 21 after that email, Mr Smith, the solicitor, the
without having to focus in on it, but it says: 22 reviewing lawyer, suggesting that this issue be
"Given the stance which the defendant is 23 addressed. It's over to the second page of this
still taking with regard to the malfunctioning 24 statement, do you see that's dated 31 January
of the Horizon system, is it possible to 25 2013.
185 186
Yes. 1 Ishaq in early February 2013. If we could put
We see that 2 up the document POL000596852, we see this again.
“The next audit was in February 2011 when 3 I's an email from Martin Smith, it's dated
Mr Ishaq was suspended and a discrepancy in the 4 6 February and it shows that Mr Smith had been
accounts was discovered. 5 to Bradford Crown Court on the moming of
“The cash and stock was then transferred to 6 6 February for the Mention, and the defence were
an interim subpostmaster in February 2011 and 7 unable to persuade the judge to order any
accepted as being correct. 8 further disclosure.
“The cash and stock was again transferred to 9 It's to Steve Bradshaw again, with Mark Ford
a new interim subpostmaster in September 2012. 10 copied in again. The important paragraph is the
During the subsequent transfer of cash and stock "1 second one:
after Mr Ishaq's suspension in February 2011 no 12 “The [defendant's] solicitor told me that
problems or discrepancies had been reported.” 13 the [defendant] still operated the store in
We see there? 14 which the Post Office is situated. The
Yes. 15 [defendant] had instructed them that both
So that statement was, as we see, served in the 16 subsequent [subpostmasters] had told him that
prosecution case. It wasn't unused material, it 17 they had experienced problems with the [Horizon]
was part of the prosecution case, designed to 18 system. Although you have said in your final
assist in demonstrating that there were no 19 statement that ‘During the subsequent transfer
problems with the system? 20 of cash and stock after Mr Ishaq's suspension in
Yes. 21 February 2011, no problems or discrepancies have
That's pursuant to that suggestion in the email 22 been reported’, the defence may well suggest
from Mr Smith to Mr Bradshaw on 28 January? 23 that this does not necessarily mean that no
Yes, so it would appear. 24 problems were encountered by the subsequent SPM.
Yes. There was then a mention of the case of 25 I think it would be sensible to obtain
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statements from both subsequent SPMs confirming 1 penultimate sentence states that no problems or
that they had experienced no problems with the 2 of discrepancies have been reported since the
[Horizon] system ete." 3 transfer to a new interim subpostmaster since
Yes? 4 the suspension of Mr Ishaq in February 2011,
So first of all, Mr Smith has got the 5 with regards to this could you please clarify
statement of 31 January. Now he's looking for 6 whether further enquiries were made ie has
essentially corroboration of what Mr Bradshaw 7 a full audit been undertaken since February 2011
says in that statement of the 31 January by 8 and if so what was the outcome of that audit.
seeking statements from the subsequent 9 “If no discrepancy has been highlighted from
subpostmasters ~ 10 a subsequent audit then please be on notice that
Yes. "1 we will require that data to commission our own
-- essentially saying, "We'd better get some 12 audit.”
statements from those subpostmasters to support 13 Then they look forward to the response.
your assertion” 14 So the defence is essentially saying, "We
There's then a letter dated 8 February 2013 15 know that you say [and this is on the basis of
from Mr Ishaq's solicitors to the Post Office. 16 Mr Bradshaw's statement] that there is no
That is POLO0059675, please. Thank you very 7 reported discrepancy but have you done an audit?
much. 18 And if there is no discrepancy, we want to carry
If we scroll down, please. So this is 19 out our own audit and actually you know that
8 February 2013. The Mention is being held on 20 we've got an expert in place to be looking at
6 February 2013. Two days later we see Musa 21 this in any event’.
Patels, down at the bottom, as the solicitors 22 Yes.
for Mr Ishaq, and the second paragraph reads: 23 Yes. So putting them on notice, as they say,
“Further to the service of the additional 24 that they will carry out that audit, please.
evidence at page 43 Stephen Bradshaws 25 There's then another email from Mr Smith,
189 190
this time to trial counsel, Mark Ford, and this 1 said to Mr Bradshaw about getting the
is POLO0059675. 2 statements.
I'm sorry, I've just given you the same 3 Yes.
reference to the letter from Musa Patels and 4 Then referring to the request from Musa Patels,
I'l just have to check the appropriate 5 he says:
reference for the email 6 “I do not propose to ask Steve to obtain the
In fact, I can read the email, rather than 7 data for the period following Ishaq's removal.
going back to that. It's quite short. It reads 8 Given that there were no problems with the
as follows: 9 system and no significant shortages, it would
“Hi Mark ..." 10 not assist the defence or undermine the Crown's.
So it's to Mr Ford from Mr Smith, copying in "1 case."
Mr Bradshaw: 12 So he is essentially saying to Mr Ford they
“Just to keep you in the loop please find 13 want the data, Mr Bradshaw is getting the
attached a copy of a letter which we have 14 statements I suggested, and he tells him that
received from Musa Patels today.” 15 he's made a decision that they're not going to
So that shows that the email is 8 February 16 get the data on what is essentially the
or thereabouts and it references to a letter 17 disclosure test. It won't assist or undermine
which you've seen from Musa Patels. 18 because we have the statement from Mr Patel
Right. 19 saying there were no significant shortages, and
"Steve is in the process of taking statements 20 he's notifying Mr Ford of the line he’s going to
from two subsequent subpostmasters who have not 21 take.
experienced any problems with the Horizon 22 Yes.
system. They have not had any significant 23 Now, we don't have Mr Ford's reply to that but
shortages." 24 we do have the letter that Mr Smith then sent to
So, essentially, following up on what is 25 the defence, and that is POLO0059729. It's the
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first paragraph of that and it's dated
15 February 2013, and it reads:
“Thank you for your letter of 8 February
2013. We enclose in duplicate copies of
a Notice of Additional Evidence, the statements
of Stephen Bradshaw of 11 February 2013 and
Abdullah Patel of 13 February 2013 and
an up-to-date page count. There is no further
disclosure to be made in this case.”
Now, that's one subpostmaster, Mr Patel, and
essentially that statement simply says, "I've
had no significant shortages at there's been no
problems with the kit", and then simply says,
“and no further disclosure to be made”.
Now, the purpose of these statements was to
make the point that because subsequent
subpostmasters had experienced no significant
shortages, then there can have been no problems
with Horizon in Mr Ishaq's office at the time he
was involved with it.
Yes.
It was thus a point that the prosecution relied
on in respect of a material issue in the case
and it was therefore incumbent on the
prosecution to prove the point.
193
Now, as the reviewing lawyer, could Mr Smith —
forgive this, it may be a rhetorical question -
could he know that the data would not undermine
the prosecution case or assist the defence case
without seeing the data or asking Mr Bradshaw to
even to get the data?
I suppose it's a two-stage thing. If he had —
and it's not clear if he had from what you've
shown me — if he had the results of audits that
showed at points during that period that there
was nothing untoward, that would allow him then.
to assess whether the underlying data took
matters further but, on the face of this, they
weren't even giving any results as to audit.
Wasn't he, in essence, refusing the defence the
data to make its own checks on that point that
the prosecution wished to prove?
Certainly on what you were taking me through, it
appears that the defence were saying, in the
first instance, "Have you looked to see whether
there are any problems by looking for audits?"
That question, as far as I can see, was
never actually answered nor indeed asked by the
reviewing lawyer of the Investigator, and so the
decisions that, on the face of it, were being
195
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22
I couldn't hear you, then, Mr Atkinson.
A. I'mso sorry: yes.
Q._ Having commenced on that strategy for proving
their case, it was an important part of proof of
the integrity of Horizon.
A. Yes
Q. The defence, in saying that they wished to audit
the data for that period, was indicating that it
wished to put the prosecution to proof on that
point?
A. Yes
Q._ Now, if the data for Birkenshaw Post Office,
after Mr Ishaq's suspension, had shown that
there had been shortages, that would obviously
undermine the prosecution case?
A Yes.
Q._It would mean that the prosecution couldn't
prove its point on that part of the case?
A. Yes, it would probably go beyond that, in terms
of calling the operation of the system into
question, as well as proving that their specific
point on it wasn't a valid one.
Q._ Asa natural corollary of that, it would assist
the defence case?
A. Absolutely.
194
made, were being made in the absence of
knowledge, which is never the right position to
be making disclosure decisions about,
Q. And simply a bare assertion that there is no
further disclosure to be made without any
explanation of that?
‘A. Well, making the assertion there's no further
disclosure to be made when, on the face of it,
he didn’t know whether there was any further
disclosure to be made.
MR MOLONEY: Thank you very much. That's all I ask,
Mr Atkinson.
MR BEER: I think, lastly, Mr Henry, sir.
SIR WYN WILLIAMS: Mr Henry, before you start,
I unfortunately have to rise at 4.25 today.
Ihave no choice in the matter, so I'm sorry you
are confined to ten minutes, but you'll have to
blame your colleagues who told me they'd be five
minutes and took about half an hour between
them.
Questioned by MR HENRY
MRHENRY: Yes. Thank you, sir
Mrs Adedayo's overtumed conviction, you
will agree, is a shortfall case?
A. Yes.
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Because, of course, as an irreducible minimum, 1 investigation report, for example, didn't really
the calculations that gave rise to the shortfall 2 fill in the gaps as to what had happened and
are dependent upon data generated and provided 3 there was, I think, no statement from the
for by Horizon? 4 auditor.
Yes. 5 That's correct, but it resulted in what I'm
I don't ask you, of course, to comment on the 6 going to describe in inverted commas as
merits of this but a shortfall which she had 7 a "confession", did it not, although of
a stark choice whether to submit to them -- the 8 an equivocal nature?
figures, that is — sign off on the figures, or 9 Certainly there was reference in the
cease trading, whilst still remaining liable for 10 investigation report to admissions having been
the shortfall? "1 made, which were then addressed in the sense
Yes, again, I'm not familiar with the details of 12 there were -- questions asked about them in the
the contract but that is my understanding from 13 interview. Mrs Adedayo's answers about them
what I've seen. 14 rather less clear to follow.
Yes. Now, you are also now aware that before 15 Exactly. Now, that interview that was actually
Mrs Bernard, the Investigator, had arrived at 16 later conducted -- following what I'm going to
the scene, there was the backdrop of 7 describe as the equivocal confession to the
an interview conducted by an auditor in breach 18 auditor at the scene — but the formal interview
of PACE? 19 conducted by Mrs Bernard was -- well, it
Well, I'm aware that there was ~ that there had 20 elicited contradictory, confusing and internally
been a conversation between Mrs Adedayo and the 21 inconsistent answers, as you have accepted --
Auditor. The material, I have to say, that I'd 22 Yes.
seen, certainly before the end of last week, as 23 ~ described by Counsel to the Inquiry as
to the nature of that and the extent of that 24 “paffling", and you don't disagree with that?
conversation was very unclear. The 25 No, I don't.
197 198
No. Yet no attempt was made by Mrs Bernard to 1 If the Investigator had concerns that it might
investigate Mrs Adedayo's bewildering account, 2 be unreliable, then they needed to investigate
to probe or question the overall effect, in 3 it to ascertain whether it was or not.
other words, as to whether there was any truth 4 Yes. We know from evidence given to the Inquiry
in the mysterious payments to third parties to 5 what Mrs Bernard said was her state of mind at
whom she claims she owed and had paid money? 6 the time, that she did not believe the account
Certainly, I saw no evidence of such enquiries, 7 she'd been given, but she made no attempt, as
no. 8 she admitted to the Inquiry, no attempt, to
No. So, therefore, Mrs Bernard then 9 investigate whether it was true or not?
approached ~ and I don't mean this 10 Yes, I haven't seen or heard Ms Bernard's
pejoratively — an interrogatory approach. In "1 evidence but I understand that from what Mr Beer
other words, she elicited through close-ended 12 said alittle earlier.
questions or leading questions an account which 13 Yes, but an examination of Mrs Adedayo's bank
she proffered to her superiors? 14 accounts conducted by a competent Investigator
Yes. 15 would have established that there were no
Now, if there was a risk that Mrs Adedayo's 16 unexplained transfers of money in or out, no
account was unreliable because of things said or 17 evidence of misappropriation nor any payments
done — notwithstanding the paucity of the 18 alleged to those mysterious third parties.
information that exists now but of course the 19 Sir, can I just, in conclusion, ask you if
circumstances were very different then ~ if 20 you would agree with this: are we not left with
there was a risk that Mrs Adedayo's account was 21 the impression that Mrs Adedayo's case was not
unreliable because of things said or done, it 22 properly investigated?
would have been all the more important, would it 23 I can't say what would have been found had
not, to have actually investigated independently 24 Mrs Adedayo's bank accounts been examined but
of what she was telling Mrs Bernard? 25 then, equally, neither could the Investigator,
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‘SIR WYN WILLIAMS: Yes.
MR BEER: -- which is the last witness for this
year.
SIR WYN WILLIAMS: Thank you for reminding me,
Mr Beer.
MR BEER: Sir.
‘SIR WYN WILLIAMS: See you tomorrow morning,
everyone
(4.24 pm)
(The hearing adjourned until 10.00 am
on the following day)
203
because they didn't look 1 making charging decisions.
Q Yes. So- 2 Q@ Exactly, and to adopt the word you use with
A. And so, it seemed to me that that was 3 perhaps characteristic understatement earlier,
a reasonable line of inquiry, both to pursue 4 “questionable to proceed in such circumstances
what had happened to the money, to assess 5 without further investigation"?
whether there'd been dishonesty and, as you 6 A. Yes.
rightly say, to assess whether the account 7 Q Because we're left, are we not, with the - and
Ms Adedayo had given was a reliable one or not. 8 we've got one more minute left ~ left with the
Q._ So we're left with the impression that it was 9 potential, are we not, that this was a false
not properly investigated? 10 confession, a bewildering, baffling, and
A. And so, therefore, in those circumstances, it "1 internally inconsistent account and that the
was not properly investigated. 12 underlying allegations could have been merely
Q. Therefore, that it was questionable to even 13 an artifact of system error?
charge in such circumstances? 14 A. Yes, I think that's right
A. Well, it was a situation where to an extent 15 MRHENRY: Thank you
I suppose it would depend on the extent to which 16 SIRWYN WILLIAMS: I congratulate you, Mr Henry, on
the Investigator flagged up to the lawyer 7 the conciseness of your questions.
that -- whether there were any concems about 18 And I thank you, Mr Atkinson, very, very
the account. If it was clear from -- and I just 19 much for all the assistance you've given me over
don't remember, I'm afraid, whether it was clear 20 a number of days at this Inquiry. I'm extremely
from the investigation report that Mrs Bernard 21 grateful to you.
had those concerns about the reliability of the 22 THE WITNESS: Thank you, sir.
accounts. If it was communicated in that way to 23 MRBEER: Thank you very much, sir.
the lawyer, then the lawyer, in my view, ought 24 Thank you, Mr Atkinson.
to have been asking questions, rather than 25 Sir, we reconvene tomorrow with Lisa Allen
204 202
at, I believe, at 10.00 am — INDEX
RICHARD DUNCAN ATKINSON (continued)
Questioned by MR BEER (continued).........
Questioned by MR STEIN cscs
Questioned by MR MOLONEY
Questioned by MR HENRY ...
204
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MR BEER: [24] 1/3
1/6 1/18 2/3 2/6 55/14
57/25 58/2 63/1 63/5
63/8 1141/7 111/15
111/18 148/5 148/12
148/20 148/23 171/6
183/19 196/13 202/23
203/3 203/7
MR HENRY: [2]
196/22 202/15
MR MOLONEY: [2]
183/22 196/11
MR STEIN: [2]
171/11 183/18
SIR WYN WILLIAMS;
[22] 1/5 1/17 1/25
53/8 53/13 53/20
54/22 55/4 55/11 58/1
62/25 63/7 111/11
114/17 148/8 148/16
148/22 196/14 202/16
203/2 203/5 203/8
THE WITNESS: [1]
202/22
‘aggressive [1] 18/15)
"During [1] 188/19
“expert' [1] 161/11
"had [1] 25/4
‘have [1] 115/14
‘if [1] 8/25
‘improper’ [1] 22/23
‘irrational [1] 25/3
‘making [1] 23/1
‘Nil [1] 66/24
‘ni [3] 79/24 79/25
80/4
"system [4] 67/4
72/22 73/6 80/6
‘There [1] 67/6
‘wrong’ [1] 24/2
0
04/11/04 [1] 59/14
04 [4] 59/14
05 [1] 59/15
1
1 February [1]
156/12
4.00 [2] 111/9 114/12
4.10 [4] 167/13
1.59 [1] 111/14
10 [2] 26/13 55/23
10 December [1]
124/8
10 March [2] 59/1
66/6
10 May [1] 59/21
10.00 [2] 203/1
203/11
10.08 [1] 1/2
10.47 [2] 55/20 56/4
10th [1] 124/9
41 [1] 107/6
11 February [1]
193/6
11 months [1]
113/20
11.15 in [1] 166/8
11.2.4 [1] 57/3
11.30 [1] 62/23
11.32 [4] 63/2
11.37 [1] 72/16
11.45 [2] 62/24 63/4
113 [2] 25/2 100/6
114 [4] 111/22
11th [1] 152/18
12 [2] 93/18 107/6
127 [1] 8/23
13 [1] 107/6
13 February 2013 [1]
193/7
14 [1] 107/7
14 February [1]
161/6
14 May 2021 [1]
55/19
146 [3] 46/20 46/21
46/22
147 [2] 25/2 48/6
148 [2] 46/20 46/22
15 February 2013 [1]
193/2
15 January [1] 150/6
16 November [2]
115/12 118/4
169 [1] 49/23
17 December [2]
130/14 130/21
179 [41] 115/10
181 [2] 52/19 52/22
482 [1] 117/17
186 [1] 136/3
18th [2] 164/12 166/6
19 [1] 3/3
19 December 2023
(4) 41
192 [1] 133/2
193 [1] 58/6
198 [4] 58/3 58/7
58/12 147/22
1980s [1] 18/25
1985 [1] 57/4
199 [1] 147/9
1999 [1] 145/20
1st [1] 94/8
2
2,500 [1] 130/8
2.00 [2] 111/10
168/17
2.55 [1] 148/6
2.56 [1] 148/17
200,000 [1] 138/2
2000 [2] 42/15 43/20
2002 [1] 145/20
2005 [6] 83/1 112/8
143/13 145/18 145/21
145/22
2006 [7] 17/12 29/10
29/12 59/1 71/12 81/4
81/7
2007 [2] 112/10
112/13
2008 [1] 112/4
2009 [1] 4/5
2010 [7] 10/20 13/18
134/3 136/4 136/18
137/7 147/24
2011 [6] 187/3 187/7
187/12 188/21 190/4
190/7
2012 [8] 35/5 142/21
144/9 144/11 144/12
146/7 160/24 187/10
2013 [15] 42/15
43/20 150/6 152/14
166/2 185/12 186/25
188/1 189/15 189/20
189/21 193/2 193/4
193/6 193/7
2014 [2] 102/13
115/23
2021 [1] 55/19
2023 [1] 1/1
21 March [2] 59/24
66/7
213 [4] 58/7 84/1
87/8 87/9
215 [2] 150/4 158/13
218 [2] 170/8 170/8
22 [3] 41/14 41/18
98/14
22 February [1]
166/2
22 March [3] 66/7
66/22 67/11
220 [1] 96/20
227 [2] 15/6 15/7
229 [4] 16/16 96/19
96/21 96/22
22nd [2] 67/2 166/8
23 March [1] 68/5
231 [1] 22/16
239 [1] 2/11
23rd [1] 67/24
24 [1] 42/3
24 March [1] 77/1
244 [1] 181/13
24th [1] 72/16
25 [1] 3/12
25th [1] 168/6
28 [4] 187/23
28 January [3]
185/11 186/8 186/16
28 March [1] 76/25
282,000 [1] 47/15
2A [1] 3/11
3
3 December [3]
124/16 142/21 143/11
3,000 [2] 126/9
131/16
3.10 [3] 148/7 148/12
148/19
30 March [1] 84/19
30/11/05 [1] 59/15
305 [1] 102/12
306 [1] 100/5
309 [1] 111/21
31 January [5]
152/15 186/16 186/24)
189/6 189/8
31 January 2013 [1]
152/14
33 [1] 29/11
333 [1] 111/21
35 [1] 128/4
351 [2] 8/23 8/24
352 [2] 8/24 9/4
4
4 December [1]
126/1
4.00 [1] 148/13
4.24 [4] 203/10
4.25 [1] 196/15
401 [1] 86/3
43 [1] 189/25
435 [1] 106/10
436 [4] 106/10
459 [1] 86/3
46 [1] 42/2
460 [1] 86/4
5
5 December [2]
127/21 144/10
5 December 2012 [1]
144/9
5.1 [1] 83/2
506 [1] 115/10
514 [1] 117/9
515 [2] 114/19
114/21
516 [1] 117/17
519 [1] 114/20
528 [1] 136/2
540 [1] 136/15
545 [2] 133/1 136/24
565 [1] 147/22
566 [1] 147/8
58 [2] 46/19 46/21
59 [1] 110/12
6
6 April [3] 81/4 86/21
86/22
6 April 2006 [1] 81/7
6 December [1]
144/10
6 February [3] 188/4
188/6 189/21
60 [1] 110/12
6114 [2] 150/3 158/12
619 [2] 170/7 170/9
640 [2] 15/8 15/8
644 [1] 16/17
645 [2] 16/25 17/11
647 [2] 16/25 19/16
648 [2] 17/1 21/25
649 [3] 17/2 22/1
115/2
650 [1] 22/13
654 [2] 17/2 25/1
66 [1] 49/20
667 [2] 6/14 7/11
668 [1] 2/13
67 [1] 37/18
670 [1] 2/21
674 [1] 181/13
69 [3] 90/23 91/4
91/10
7
70 [1] 52/20
74 [4] 3/13
72 [4] 3/13
74,609.84 [2] 12/3
12/4
76 [1] 58/4
8
8 February [3]
189/20 191/16 193/3
8 February 2013 [1]
189/15
8 January [1] 149/5
82 [2] 84/2 87/9
87 [2] 96/21 96/22
9
9.37 [1] 168/7
A
Abdullah [1] 193/7
ability [4] 158/23
171/19 17812 179/23
able [14] 1/10 37/8
43/12 44/17 55/22
60/11 103/23 104/11
126/11 129/21 157/20
165/22 173/10 173/13
about [85] 2/9 3/21
6/17 7/8 15/4 17/19
20/4 23/8 28/17 29/9
31/11 33/23 34/13
34/18 35/5 38/5 39/6
40/25 50/14 54/12
54/16 55/13 60/9 70/5
76/7 81/17 82/19
86/23 94/10 94/15
94/25 95/12 95/14
95/19 95/22 96/20
107/5 109/4 111/8
(52) MR BEER: - about
INQ00001110
INQ00001110
A 13/22 15/2 43/1 45/4 I 78/12 156/16 156/20 I 39/1 54/5 105/19 137/14 138/24 146/11
about. [46] 114/4 I 50/9 50/12 50/16 156/22 167/15 133/13 150/11 154/21 157/14
116/10 117/21 120/2 I 50/19. 51/11 51/17 Iaddendum [3] advancing [1] 24/21 I 158/18 161/24 164/1
4122/20 128/16 128/24I 91/19 51/20 51/23 I 166/11 166/14 166/25Iadvantageous [1] I 169/21 174/11 174/18
134/3 139/8 139/16 I 98/25 89/5 106/25 adding [1] 124/16 I 45/25 179/3 179/10 179/25
439/17 141/9 143/7_ I 107/3 112/24 113/6 addition [3] 130/24 advice [7] 19/10 183/8 196/24 200/20
443/21 14615 14a/e I 145/8. 178/22 179/5_ I 154/21 157/3 96/24 97/24 102/18 Iagreed [4] 65/19 94/8
1449/2 157/17 157/22 I 184/15 199/2 199/13 Iadditional [8] 41/24 I 106/13 108/15 109/15) 96/12 98/23
159/3 159/22 160/2 I 199/17 199/21 200/6 I 79/22 130/17 144/13 Iadvices [1] 98/17 agreeing [1] 51/21
1460/5 160/9 160/16 I 2017/7 201/19 202/11 I 171/7 186/19 189/24 Iadvise [9] 67/20 97/3I ahead [1] 166/21
accountable [1] I 193/5 98/15 98/22 99/10 Iaid [1] 158/9
ate cae seen, I 24/10 address [18] 8/22 I 99/12 99/16 99/17 alarming [1] 162/2
Tare dyer yBurg [accountancy [1] I 15/6 21/17 27/5 35/12I 107/24 albeit [1] 169/18
Trey toe tan. I 16914 35/20 37/21 41/14 advised [2] 98/2 _Ialert [1] 8/8
Tet gen root) [accountant [2] 161/1) 96/18 102/11 117/16 I 109/9 alerted [1] 8/12
Tee teeta saoria I 18918 134/23 136/21 139/1 Iadvisers [1] 183/15 IAli [1] 184/25
Meola oe tye spa/pgIaccounting [31] 8/20) 162/23 165/5 166/19 Iafar [1] 181/2 Alison [3] 17/1 22/2
above [71 3/24 e624 I 911 18 9113 9/19 1216) 167/20 affect [2] 10/10 88/10I 114/18
a ep I 1213 12122 13/7 addressed [5] affected [2] 40/11 IAlison Hall [2] 17/1
Sra salon 13/13 14/8 14/19 I 106/10 120/21 153/14) 90/10 2212
abridged) cata I 14/23 1515 19/14 I 186/28 198/11 affecting [1] 61/4 {all [58] 2/1 2/2 2/17
brig 15/21 16/6 16/15 addresses [2] 107/6 afraid [3] 1135 I 4/14 20/18 29/23
16122 17/12 18/9 I 107/7 138/10 201/20 31/21 33/4 37/13
absence [6] 5/1 8/21 .
9/6 37/25 45/16 196/1I 18/20 20/21 25/21 Iaddressing [7] 6/6 after [19] 15/25 15/25] 40/18 41/16 46/14
26 115/17 116/1 I 10/2 119/23 130/18 I 1124 11216 11217 _ I 49/13 59/8 69/10
absolutely [10] 34/12) +6165 146/18 117/16 I 134/10 144/13 147/24I 11219 112/11 152/13 I 69/17 77/15 77/19
oO nin 9/18 179/9 Adedayo [10] 50/21 I 168/16 170/16 177/11) 79/12 81/14 83/18
151/9 184/22 194/25 [accounts [4] 187/5 I 51/3 51/8 52/6 55/6 I 184/8 185/5 186/2 85/24 88/6 88/19
academic [1] 29/19 I 200/14 200/24 201/23I 56/16 57/2 65/1 186/13 186/21 187/12I 89/11 90/10 94/7
accept [11] 14/1 14/7 accreditation [1] 197/21 201/8 188/20 194/13 95/22 96/12 98/5.
29/20 Adedayo's [19] 49/19Iafternoon [4] 111/15 I 108/23 118/14 121/22I
15/14 15/21 16/5
49/19 54/4 4/19 74/3IAcctUing [1] 113/19 I 50/9 52/23 53/9 54/5 I 111/18 148/7 148/20 I 124/21 126/12 126/21
4107/1 115/6 accurately [1] 145/6 I 54/17 54/19 54/24 IAG's [1] 107/18 134/8 137/6 144/22
acceptability [2] accustomed [1] 63/10 64/19 65/11 {again [29] 5/23 5/24 I 145/7 149/16 150/20
eNO 116/11 32/20 196/23 198/13 199/2 I 15/24 23/8 25/19 28/5I 154/2 155/25 158/11
acceptable [5] 20/14 acid [1] 110/12 199/16 199/21 200/13] 38/17 67/20 75/17 I 164/22 173/3 174/2
20/15 20/21 82/24 \acknowledged [1] I 200/21 200/24 81/9 81/9 104/14 174/13 178/6 182/4
116/7 19/20 adequacy [1] 100/13 I 113/13 117/20 120/4 I 183/24 183/25 186/3
acceptance [13] 8/16I2cauit [1] 107/2 adequate [1] 36/9 I 122/14 125/24 133/24] 189/5 196/11 199/23
8/19 10/21 16/23 acquittal [2] 49/7 Iadequately [1] 130/1 I 137/4 143/20 149/2_ I 202/19
17/23 21/8 22/24 107/4 adhered [1] 83/19 I 152/20 157/23 167/24] allegations [2] 170/3
25/23 26/1 114/23 IAequitted [2] 47/18 adjourned [1] 203/11) 187/9 188/2 188/9 I 202/12
4158/7 115/8 117/58 I 112/12 Adjournment [1] 188/10 197/12 alleged [6] 42/8
accepted [8] 17/17 Iacross [2] 98/14 111/13 against [15] 42/9 I 45/15 45/16 47/10
17/19 21/6 23/10 148/3 adjusted [4] 24/11 I 47/16 47/21 49/11 I 47/16 200/18
25/16 65/22 187/8 [Act [2] 57/3 91/5 adjusting [1] 25/23 I 62/5 65/13 105/13 _I Allen [20] 28/9
498/21 acted [1] 97/24 admissibility [3] 40/1] 109/18 113/15 113/25] 117/16 118/1 118/21
accepting [4] 15/5 [acting [6] 20/16 40/11 40/13 136/18 170/3 178/6 I 118/25 123/25 124/7
26/5 26/12 73/6 28/15 54/3 92/3 admissible [2] 27/17 I 180/8 180/16 125/9 126/2 126/4
accepts [1] 18/10 I 127/10 180/2 40/8 agent [1] 122/25 131/3 132/2 138/7
access [11] 1/10 active [1] 43/9 admission [2] 90/23 Iagents [2] 18/7 37/1 I 138/16 138/19 142/14
45/4 171/19 173/5 {actively [4] 127/13 I 91/11 ago [2] 23/20 124/24 I 142/17 147/12 148/2
1473/8 174/6 174/8 actual [5] 9/6 14/14 Iadmissions [2] agree [57] 9/18 34/9 I 202/25
474/12 174/13 174/18] 130/3 134/15 135/2 I 100/10 198/10 34/15 44/13 45/14 I Allen's [6] 126/6
174/16 actually [11] 33/8 Iadmitted [2] 106/20 I 51/6 51/22 52/7 52/9 I 130/14 133/8 134/6
accompanied [1] 82/20 119/6 121/24 I 200/8 60/22 61/7 61/16 136/9 139/5
116/18 130/3 131/22 155/16 Iadopt [2] 57/5 202/2 I 62/16 62/19 69/24 _Iallied [1] 144/6
190/19 195/23 198/15I adopting [3] 22/18 I 70/10 71/1 71/8 74/25) Allison [2] 17/7
199/24 22/19 53/2 78/14 78/22 82/4 114/18
adapted [1] 146/8 I advance [9] 25/20 84/13 90/22 92/8 93/6I allow [5] 105/13
add [7] 22/5 39/15 106/25 162/10 162/11) 95/3 96/1 96/6 96/9 I 105/19 161/10 180/16)
60/18 61/23 129/5 162/16 162/20 162/21I 97/8 97/13 100/17 195/11
149/23 153/12 163/25 164/9 101/3 116/9 125/10 I allowed [2] 65/16
added [7] 52/9 76/21 Iadvanced [5] 9/15 129/12 132/14 135/12) 171/17
accordance [2]
19/19 180/4
accorded [1] 48/23
accordingly [3]
104/21 107/21 108/5
account [32] 13/6
(63) about... - allowed
INQ00001110
INQ00001110
A Andrew [1] 124/1 172/13 172/15 173/7 I 110/17 155/12 arguable [2] 12/19
almost [1] 14476 IAngela [2] 142/9 177/9 178/12 183/13 apply [4] 57/4 64/2 I 64/3
alone [2] 47/16 47/21 144/17 184/4 186/2 186/10 I 77/13 111/3 arguably [6] 8/21 9/5
already [7] 79/21 Anglesey [1] 59/10 I 188/7 190/21 191/22 Iapplying [1] 83/6 11/16 11/16 14/24
95/1 96/9 117/12 Anne [1] 142/10 191/23 195/14 195/21I appreciate [2] 79/6 I 178/23
4118/7 119/19 120/12 annotations [4] 196/5 196/9 199/4 129/5 argue [2] 65/2 65/5
also [35] 4/9 10/4 76/21 76/22 77/4 200/17 201/18 appreciated [5] argument [1] 24/23
15/12 16/11 20/11 79/11 anybody [2] 180/21 I 32/16 40/12 84/9 arise [4] 8/7 21/25
40/9 44/10 44/16 4g/3I2nether [7] 10/15 I 182/24 109/2 141/18 155/14 161/21
59/6 67/5 93/20 95/18 97/4 98/2 106/7 111/8Ianyone [3] 7/22 appreciation [1] arisen [5] 2/23 3/6
99/4 102/1 109/17 165/20 190/25 40/12 165/24 140/20 4/7 4/8 4/23
415/23 117/11 123/25/answer [7] 27/5 anything [23] 34/20 Iapproach [25] 9/7 _Iarises [1] 8/18
425/19 128/5 134/1 27/12 121/22 135/20 I 41/7 48/10 49/2 49/3 I 15/9 18/15 36/21 arose [2] 147/6
434/10 134/13 142/24] 139/3 1685/1 172/4 I 49/8 70/5 110/1 38/11 53/3 64/25 155/11
447/14 160/18 162/20I answered [4] 154/13 I 120/23 122/21 138/6 I 82/23 84/15 92/4 _I around [4] 89/3
4163/23 17218 173/68 I 194/14 171/15 195/23] 138/11 142/6 149/14 I 102/19 102/24 104/24I 184/7 185/4 185/6
481/19 184/13 184/17/answering [2] 21/14 I 156/2 156/19 158/11 I 110/25 111/4 120/3 IARQ [10] 66/12 86/2
197/15 17215 163/6 165/23 170/5 I 120/7 121/5 123/7 86/3 89/13 89/25
alternative [4] 12/8 answers [5] 51/9 173/19 181/17 181/21) 127/5 135/14 144/3 I 92/21 92/23 144/2
19/7 20/10 22/24 155/22 156/1 198/13 Ianyway [3] 6/5 65/4 I 153/16 156/3 199/11 I 165/11 169/18
alternatives [2] 9/14 198/21 83/9 approached [1] ARQs [5] 59/8 61/8
10/1 anticipate [1] 19/10 Ianywhere [1] 7/4 199/10 61/13 164/17 165/7
although [11] 54/4 anticipated [3] 77/10 I apologies [1] 166/23 Iappropriate [13] 9/12) arraigned [1] 108/17
76/25 91/23 99/3 78/5 78/13 apologise [1] 6/14 36/12 69/24 74/9 arrange [1] 60/13
1400/9 101/3 150/14 anticipation [1] apparent [4] 131/16 I 74/14 78/5 80/13 arranged [1] 81/2
158/23 170/10 188/18 19/13 134/8 164/25 184/11 I 80/18 94/17 100/25 I arrangements [4]
198/7 antithesis [1] 36/22 Iapparently [1] 56/9 I 153/15 153/23 191/5 I 161/23 162/19 162/21
altogether [5] 90/5 I@¥ [138] 3/8 3/9 6/9 Iappeal [28] 9/11 22/7I appropriately [1] 166/5
94/18 97/18 116/20 11/22 14/25 16/1 21/9) 22/8 22/20 25/1 25/5 I 26/24 arranges [1] 80/10
122/14 22/10 23/1 25/13 25/14 46/24 48/1 appropriation [2] __Iarrived [1] 197/16
always [2] 20/7 20/12 27/18 27/19 28/13 49/17 53/3 54/10 57/3) 14/15 16/4 artifact [1] 202/13
am [9] 1/2.26/22 28/19 28/21 28/23 I 57/23 63/15 63/18 Iapproximately [1] _Ias [247]
46/16 55/4 63/2 63/4 28/24 29/2 29/3 30/3 I 63/23 103/23 103/24 I 130/6 ascertain [1] 200/3
145/20 203/1 203/11 30/12 30/25 32/4 32/9) 104/11 104/22 105/13/April [6] 71/12 81/4 I aside [6] 56/22 57/5
ambit [1] 91/4 32/14 34/5 34/7 35/14I 105/19 107/13 109/17] 81/7 86/21 86/22 62/2 82/23 84/11
amended [3] 39/19 36/14 36/21 38/8 116/15 117/8 179/7 I 93/14 122/9
149/9 167/15 39/25 40/12 40/18 Appeal's [1] 47/5 April 2006 [1] 71/12 Iask [20] 26/22 31/8
amendment [2] 78/4 40/21 40/23 40/23 appeals [3] 57/1 are [88] 2/1 4/19 9/13) 41/20 46/14 94/9
82/18 41/4 41/11 42/7 42/18) 57/10 63/14 9/14 9/19 9/25 10/1 96/20 98/14 98/22
amendments [2] 42/22 46/4 50/20 appear [9] 45/10 11/6 15/16 15/18 126/20 142/8 159/1
72/12 76/15 52/12 57/16 61/3 67/7I 77/14 81/12 84/7 18/11 20/1 23/15 171/7 177/18 178/8
America [1] 95/2 70/1 71/23 71/25 87/12 87/16 134/18 I 24/16 24/21 24/22 184/3 184/7 192/6
American [1] 94/23 72/12 77/20 81/13 169/6 187/24 26/4 26/12 27/7 29/20I 196/11 197/6 200/19
amongst [2] 10/22 86/17 86/22 88/8 appeared [5] 48/19 I 30/2 31/1 38/18 42/5 Iasked [46] 27/7 27/8
49/24 93/21 93/23 94/9 95/8) 51/8 56/7 96/2 170/1 I 53/2 57/4 57/9 57/10 I 31/9 31/12 41/20
amount [5] 100/17 100/22 102/6 103/16 Iappears [13] 5/15 59/18 60/10 60/20 41/24 45/3 51/7 51/16
101/6 101/9 122/17 I 103/16 104/2 104/17 I 18/3 56/5 59/1 81/5 I 68/9 68/14 68/23 69/6I 51/19 60/24 63/11
teuir 4105/6 107/11 109/17 I 82/17 115/12 125/11 I 70/12 7314 73/6 73/18I 7/24 84/13 87/13
amounts [1] 11/16 112/15 113/10 119/21] 126/19 132/4 132/8 I 73/19 73/19 74/4 92/9 94/15 94/25
ate EL ory I 120/15 120/16 121/22) 18316 195/19 76/16 77/8 77/9 77/10I 96/10 96/12 95/14
a ecerig I 121/23 122/2 126/13 Iappellant [1] 104/2 I 77/18 86/2.87/21 I 95122 98/12 99/2
ae 127/4 12716 128/2 I appellants [1] 56/7 I 93/25 98/20 103/20 I 108/19 128/16 129/24
anatyeed 2} 85/24 I 128/15 191/14 131/14 appendices [1] I 104/8 104/23 111/38 I 1312 139/1 139/2
4139/5 134/5 134/7 I 168/17 114/8 114/12 12172 I 144/16 151/6 15319
; 134/8 134/19 137/16 IApplicant [2] 103/8 I 126/11 128/1 128/3 I 156/13 159/22 159/22
analysing [2] 89/15 I «38/42 13915 13916 I 104/10 1428/5 128/7 128/24 I 160/1 160/10 160/23
anatyets (14) 19/18 I 140/20 14313 14344 Applicant's [2 1442/3 148/10 152/16 I 162/5 167/6 169/17
analysis [14] 19/18 I 145/9 145/11 145/26 I 103/12 103/21 152/22 156/18 157/24) 170/11 185/1 195123
84/25 86/25 103/3 147/1 147/1 147/6 application [4] 34/19 I 159/17 161/18 163/15] 198/12
129/11 134/14 135/2 I 147/16 155/7 156/21 I 104/22 176/23 177/20) 163/15 168/17 171/6 Iasking [19] 61/23
156/24 157/4 157/18 I 161/16 161/20 162/3 I applications [5] 173/12 173/22 174/9 I 70/6 70/6 70/7 74/17
4158/2 163/6 163/25 164/9 I 57/16 175/7 176/6 177/13 185/10 195/21I 86/12 101/1 122/20
ancillary [1] 100/24 165/17 167/18 167/18] 176/9 176/10 196/17 197/3 197/15 I 126/25 128/17 128/25
167/20 169/10 169/12I applied [3] 34/9 200/20 202/7 202/9 I 151/10 151/16 154/24
(64) almost - asking
INQ00001110
INQ00001110
A 168/25 Bailey [1] 114/18 16/13 17/25 18/1 21/8] 170/18 196/14 197/15
asking... [5] 155/24 attack [1] 77/13 balance [1] 152/9 21/12 23/21 23/25 197/23
165/14 177/14 195/5 Iattempt [4] 167/3 balances [2] 106/22 I 24/8 26/23 27/9 30/1 Ibeforehand [1]
201/25 199/1 200/7 200/8 184/18 31/9 31/12 31/14 131/19
aspect [4] 49/10 attempted [1] 46/6 Ibalancing [1] 14/11 I 40/12 40/16 41/15 beginning [3] 88/22
144/13 155/15 176/15Iattempts [1] 166/15 Ibald [2] 121/11 42/20 44/4 47/25 102/5 143/16
aspects [4] 40/3 attend [3] 161/9 168/23 48/12 48/24 49/18 begins [1] 144/15
95/10 155/21 178/14 I 161/18 161/25 bank [6] 43/1 43/18 I 50/20 50/23 51/14 behalf [7] 20/16
assert [1] 97/6 attention [2] 137/11 I 45/4 45/5 200/13 52/16 54/5 54/21 28/15 54/6 56/5 82/8
asserting [2] 137/10 181/14 200/24 57/13 65/15 66/6 67/6I 92/3 183/15
176/16 attest [1] 76/4 banking [7] 59/18 68/13 70/13 70/21 behaviour [1] 10/25
assertion [6] 93/3 [Attorney [1] 110/10 I 60/1060"19 68/11 I 71/4 71/19 73/23 I behind [2] 57/14
121/11 180/10 189/14Iattracting [1] 19/1 I 73/21 85/24 89/12 I 74/24 75/7 75/9 75/14) 161/15
196/4 196/7 attributable [1] 126/9Ibar [1] 99/19 75/15 76/6 78/14 being [70] 2/15 2/23
assertions [2] attributed [2] 17/16 Ibare [2] 122/6 196/4 I 78/23 80/20 81/24 _I 3/18 5/16 7/16 16/9
103/12 153/12 51/12 Barrick [1] 18/24 82/25 83/3 83/23 84/7I 20/24 21/6 21/11
assess [3] 195/12 [audit [19] 47/16 barrister [2] 103/6 I 84/8 84/12 87/13 21/17 23/16 24/22
201/5 201/7 62/11 62/11 128/15 I 153/9 90/25 91/5 93/23 95/9] 26/2 27/6 27/7 36/19
assessed [2] 106/3. I 128/23 141/25 142/2 Ibased [9] 46/23 95/18 96/15 97/22 I 37/21 38/19 39/1
4162/17 143/3 143/18 187/3 I 47/16 47/17 48/1 48/3I 100/12 101/20 101/23] 41/10 44/17 52/8
assessing [1] 101/10] 190/7 190/8 190/10 I 51/20 73/1 93/25 103/10 105/4 105/15 I 52/18 61/18 69/22
assessment [15] 190/12 190/17 190/19] 176/7 107/1 107/19 107/22 I 69/22 74/15 76/25
D111 44/2 44/9 44/12I 190/24 194/7 195/14 Ibasically [1] 172/6 I 108/4 108/18 108/21 I 80/6 80/22 87/18
48/3 55/7 70/24 audited [1] 85/22 [basis [26] 11/23 16/2I 109/2 109/6 109/22 I 89/24 95/11 99/2
400/19 101/24 102/1 [auditor [5] 142/5 16/3 17/15 20/13 112/6 112/21 112/24 I 101/19 106/3 110/12
405/11 106/3 113/9 I 197/18 197/22 198/4 I 20/14 33/11 45/22 I 113/2 113/3 113/23 I 111/1 111/4 116/9
413/12 126/25 198/18 48/18 52/16 91/21 117/13 118/9 118/15 I 117/8 121/5 124/12
assist [13] 30/13 [Auditors [2] 141/5 I 97/5 108/1 108/12 I 120/15 127/12 128/16] 127/5 134/8 138/9
43/7 91/15 91/20 141/6 109/8 109/13 115/8 I 130/16 130/18 131/2 I 138/14 139/2 142/12
158/3 175/14 181/9 [audits [2] 195/9 116/5 116/7 116/11 I 131/4 132/4 132/8 145/25 146/18 150/7
181/24 187/19 192/10I 195/21 117/4 121/14 121/15 I 134/18 138/2 138/20 I 154/21 158/2 158/11
192/17 194/23 195/4 [authored [1] 156/12 I 140/6 141/15 190/15 I 139/1 139/21 143/3_ I 159/4 159/6 159/10
assistance [3] 30/17 authority [3] 74/10 Ibasis.' [1] 115/21 144/12 144/16 144/18] 160/6 160/23 165/22
109/23 202/18 75/19 80/14 bat [1] 169/18 145/24 152/9 152/13 I 166/5 169/23 174/10
assisting [2] 83/16 I@Vailability [1] 13/20 Ibe [236] 154/1 154/6 155/6 I 184/25 186/16 187/8
108/21 available [5] 1/15 Ibearing [1] 44/11 I 156/13 157/15 158/16) 189/20 195/25 196/1
associated [1] 41/17 87/4 109/18 Ibecause [72] 1/13 _ I 159/17 162/3 163/3_ belief [5] 69/10 88/6
186/11 165/11 5/11 5/23 6/3 7/6 7/20) 165/3 167/2 167/25 I 88/19 103/7 106/21
assuming [2] 80/4 /averment [1] 101/7 I 7/24 8/2 16/11 33/9 I 169/10 169/12 169/17/believe [13] 52/6
155/20 avoid [1] 14/20 33/19 33/21 33/23 I 174/20 175/3 175/23 I 69/8 81/21 88/3 89/20)
assumptions (1) [aware [18] 5/12 33/24 34/10 34/17 I 177/24 178/14 180/22) 129/25 145/6 171/22
s0/t 27/20 32/11 102/16 I 42/24 43/7 43/9 45/1 I 181/14 186/13 187/13) 172/5 176/16 176/25,
118/7 132/1 137/24 I 46/11 53/24 56/16 188/4 188/22 190/2 I 200/6 203/1
at page 2 [1] 59/25 160/25 171/11 171/22] 65/12 74/20 75/24 190/7 190/9 193/12 I below [7] 60/5 67/15
at page 25 [4] 3/12 172/3 172/12 172/17 I 81/22 82/18 83/1 83/6I 193/18 194/14 197/21I 73/12 79/14 118/20
ATKINSON [17] 2/4 172/20 172/24 178/25I 88/5 89/22 92/1 92/18] 198/10 199/23 200/7 I 150/1 156/15
at [275]
197/15 197/20 95/6 101/9 101/23 I 200/23 200/24 201/6 Ibenefit [4] 12/1 14/14]
a este oo eed awareness [1] 183/9 I 109/5 113/7 113/18 I 201/25 202/12 42/7 44/22
450/19 171/11 183/18, ~—~~S*S*SC~C*S*Y «8820 122/02 125/14 I Beer [13] 2/2 2/5 I benefited [1] 46/5
183/23 194/1 196/12 I———>— > = I 125/18 126/10 130/23) 53/8 55/12 171/15 I Bernard [9] 50/19
202/18 202/24 204/2 Iback [26] 3/3 7/16 I 133/7 135/21 137/4 I 177/24 178/15 180/22I 52/3 197/16 198/19
attach [2] 98/17 26/4 37/17 60/12 66/1] 141/6 141/19 142/2 I 183/22 185/1 200/11 I 199/1 199/9 199/25
4126/6 75/12 76/16 82/3 142/5 143/23 156/1 I 203/6 204/3 200/5 201/21
attached [9] 16/23 86/17 87/8 88/22 159/18 165/7 172/13 Ibefore [39] 1/6 3/16 IBernard's [1] 200/10
67121 72/7 72/19 B5/1I 115/17 129/9 130/16 I 173/12 173/15 17/16] 5/11 5/18 5/22 6/8 _I best [4] 69/10 80/9
119/2 183/10 166/12 I 1394/3 136/2 136/12 I 178/23 180/6 182/1 I 7/19 8/6 27/24 35/14 I 88/6 88/18
491/14 136/14 142/22 144/12] 183/6 192/18 193/16 I 35/25 36/2 46/2 53/8 Ibetter [9] 35/6 74/18
attaching [1] 86/11 145/14 155/3 160/14 I 197/1 199/17 199/22 I 56/22 63/8 65/15 T7IT T7125 123/7
attachment [9] 68/4 180/23 191/8 201/1 202/7 74/16 85/5 90/22 158/5 158/8 160/22
76/23 76/24 79/14 IPackdrop [1] 197/17 Ibecome [1] 2/17 108/17 109/6 109/20 I 189/12
85/16 119/10 166/10 IDackground [2] 57/6 Ibecomes [1] 130/10 I 124/9 127/12 128/18 I between [33] 2/16
168/12 168/20 169/12 been [158] 1/12 3/15 I 129/8 143/21 158/16 I 2/22 15/9 16/25 18/5
attachments [1] baffling [3] 52/14 4/14 6/3 7/9 12/18 160/18 161/9 162/4 I 18/19 23/7 34/17
198/24 202/10 13/4 13/25 14/10 163/2 164/6 166/3 I 35/17 35/22 40/19
(65) asking... - between
INQ00001110
INQ00001110
B 90/10 103/14 112/5 IC 166/21 167/20 168/5 Icategory [1] 17/6
petween.. [22] 46/22) 112/22 121/16 121/15) oS ton ray oayaI 168/19 171/21 171/25I cause [6] 36/2 39/11
27/1 A714 48/12 49/5) 127/24 129115 130/4 I red etions [1] 175/4 176/4 176/9 I 49/15 103/16 176/4
55/2 62/14 65/9 192/17 133/8 13516 Io0/5 176/19 176/23 176/24] 184/11
84/19 115/7 116/21 164/21 167/19 173/4 call [3] 59/13 128/23 177/3 177/3 177/10 I caused [5] 26/9 41/2
178/6 178/8 178/11 I 103/9 103/10 137/25,
174/5 179/24 186/3
117/24 129122 136/22) ach [3] 18/21 171/28 179/12 181/2 185/21 Icausing [1] 25/24
141/15 162/6 162/9 called [6] 89/2
83/12 197/18 191/7 193/18 195/22 Icaution [1] 155/12
177/9 177/10 183/14 break [5] 62/24 63/3 141/14 159/7 159/19 200/19 CCAD [1] 63/19
196/19 197/21 reak [5] 172125 173/17 m4
Beverley [1] 168/14 111/10 148/7 148/18 IG stendar [1] 137/24 can't [13] 41/11 49/1 ICCRC [6] 50/1 63/17
bewildering [2] Brennan [2] 42/1 calling [1] 194/20 86/20 91/20 95/12 63/24 64/1 64/2 64/6
4218 113/5 119/19 153/21 Icease [1] 197/10
199/2 202/10 Brennan's [2] 45/16 I°2lls [3] 128/16 165/24 173/22 180/7 Icertain [2] 52/7 85/9
beyond [8] 3/7 6/1 167/19 174/2 i
46/15 184/4 200/23 certainly [25] 32/17
8/14 24/17 31/16 ; came [7] 13/23 17/19
brevity [1] 16/12 cannot [2] 24/9 145/8] 34/7 37/12 42/21
38/16 169/14 194/19 bre 29/11 54/16 146/5
‘ brief [1] 26/21 capable [3] 31/19 I 51/25 54/18 62/25
Birkenshaw [2] broader [2] 61/3 185/3 160/16 83/15 108/20 73/5 98/12 99/21
184/8 194/12 can [176] 1/3 1/5 1/8
, 169/12 capacity [1] 93/24 I 101/1 113/2 114/6
bit [9] 38/21 38/22 hr cught [4] 15/2 I 15 18 2/8 2/11 ey 5] 56/4 56/5. I 116/13 116/24 135/25
39/9 39/10 66/8 67/17 3/14 7/10 817 8/15
112/24 177/8 181/14 57/17 57/19 64/22 I 153/20 155/4 165/18
69/3 68/16 96/20 Ioug [4] 136/6 137/24 I 13/16 13/17 15/4 15/7I co ray 46/18 49/11 I 172/24 178/12 195/18
bite [2] 178/3 178/13 IPUS 15/20 16/16 17/7 a
138/4 147/25 carried [6] 2/18 16/6 I 197/23 198/9 19/7
Hae ioe sag [bugs [7] 134/4 134/5 I 52/18 2013 26/13 I s0/3 30/5 84/25 cetera [1] 72/14
lakey [4] 6/16 6/18 I sig 47113 172/22 I 20/15 26/16 32/14 I ago hain [3] 124/17
712 46/17 173/1 176/2 36/5 38/21 38/23 39/5 6] 95/8 108/16) 150/14 450718
blame [4] 17/16 7416 I eeian cay 17917 I S/S 39011 30r14 I Ee is 190/18I Chair [1]. 49/9
126/16 196/18 urden [1] 39/14 39/15 39/15 air [1]
A business [2] 139/21 190/24 challenge [2] 41/21
ank [1] 168/10 _/Pusines aari2agii agg I 190124 halen
blanket [2] 1786 ta aio sig I 40/14 49/19 51/5 oat edi2 (challenged [1
179/16 Bie eoi19 torts I 81725 8316 S318 59/15) FE ee oye THT eT
blue [1] 156/16 11/20 12/10 12/12 I 93/15 56/3 57/14 88/2 gia 4418/5 123/24 \chan [2] 115/14
boat [1] 43/18 13/7 13/11 14/2 15/24] 98/5 58/19 58/21 160/24 116/22
poay Til 181/20 17/18 23/3 24/9 26/9 I 58/22 58/24 59/16 I ee to4ty Chan's [1] 116/2
ole [10] 124/1 59/20 60/18 60/21
Ol rape I 27/15 28/4 31/11 I Rae ante Bz 4 leases [78] 2/14 2/22 Ichance [1] 162/15
4129/22 135/5 1385/7 I 35/1037/12.42/20 I ban aig eet 3/9 3/18 3/21 3/24 4/9I chances [1] 19/8
43/5 44/5 44/22 45/9 4/15 5/25/17 5/21 Ichange [9] 10/9
142/22 143/11 146/6 67/10 68/1 68/4 68/25
Bole’s [2] 129/4 49/2 50/14 51/1 51/20] Bor gays 69/17 72/3 I 9/23 6/15 6/21 6/22 I 47/24 47/25 48/12
14/4 53/13 53/17 53/21 I Pang 7eng 7a1q I 8/24 7/1 7/21 7/25 B/4I 49/9 49/18 145/21
54/15 59/13 64/3 65/5 8/9 8/19 15/11 15/17 I 145/25 146/1
both [21] 5/5 5/8 9/12 76/11 76/14 76/15
70/7 74/19 75/14 76/1 16/15 16/19 18/24 I changed [2] 47/1
9/15 9/22 12/7 27/22 77IT 79/1 81/7 81/18
77/40 77/13 79/6 22/6 22/22 23/5 31/23) 49/4
47118 5617 64/16 82/1) song arte e7/16 I 89/25 85/15 86/17 I ong 47/16 43/21 hannel [1] 41/9
100/25 134/13 135/20 87/10 87/25 90/18 channel [1]
435/22 139/16 156/68 I 90/4 94/13 94/18 90/21 91/18 93/12 I 44/24 46/16 54/20 I chaotically [1]
174/25 188/15 19/1 I 95/20 96/20 97/1 99/4I G3143 oa/3 ga/14 57/6 57/10 63/17 169/23
2014 99/18 102/1 111/22 I Sa/95 9503 6/17 I 77/1598/14 101/16 I character [6] 112/23
bottom [7] 72/4 113/5 113/13 114/12 I 9873-49073 100/5 102/18 104/6 107/14 I 112/24 113/11 113/11
116/5 116/11 116/15 110/24 114/17 117/13] 114/10 114/13
89/19 93/17 150/21 100/18 102/22 103/1 sear
122/20 125/19 126/22) 118/10 118/14 119/2 I characterisation [2]
150/22 185/21 189/22) 104/18 105/2 106/7
126/25 130/24 131/21 119/21 120/6 120/17 I 51/15 169/22
bound [1] 99/4 114/15 111/18 117/15) "
132/3 137/6 139/17 124/4 124/19 125/14 I characterise [1]
Bowyer [1] 103/4 417/17 117/19 118/21
142/4 150/21 151/11 140/8 142/12 142/16 I 150/5
Bowyer's [1] 115/23 119/16 123/22 124/24: -
151/18 155/3 155/20 143/4 144/2 146/17 I characterised [1]
box [1] 160/20 125/23 126/20 127/17
158/10 160/16 162/11 146/18 147/3 147/6 I 48/20
boxes [1] 183/1 130/19 139/16 142/9 sees
164/8 165/9 165/18 150/25 151/19 170/15] characteristic [1]
Bradford [2] 164/16 144/15 145/3 145/11
188/5 17218 172/17 17316 I 4 45144 4148/8 148/20 I 173/18 176/20 176/21) 202/3
175/19 178/10 179/20) 177/13 178/10 179/6 Icharge [12] 6/16 9/12)
Bradshaw [11] 135/8 148/24 148/25 149/16
180/6 182/21 182/25 179/14 179/15 9/22 15/23 15/25
185/12 186/17 187/23) 151/14 152/12 152/19
188/9 189/7 191/12 I 183/5 184/14 185/19 I Je 316 455/10 156/9 ICash [8] 45/15 45/19 I 16/20 17/13 25/9
1492/1 192/13 193/6 185/22 190/17 192/23) 456/19 157/8 160/15 143/14 145/23 187/6 I 44/13 48/19 100/18
195/13 196/17 197/7 187/9 187/11 188/20 I 201/14
Bretohaw's ir] 197/13 198/5 198/18 tone toate ait cast [3] 110/14 chargeable [1] 130/8
189/25 190/16 199/19 200/7 200/11 I 164/99 1668/3 166/4 I 119/19 150/25 charged [5] 5/7 9/8
200/13 200/24 1466/6 166/10 166/20 ICastleton [1] 112/10 I 9/19 12/5 16/9
branch [19] 59/10 catch [2] 1/22 125/25I charges [3] 9/1 9/25
(66) between... - charges
INQ00001110
INQ00001110
Cc 165/6 182/18 182/23 I 15/16 67/20 72/20 concerned [8] 4/15 I 24/8
charges... [1] 12/7 _ 184/10 195/8 198/14 I 129/6 153/13 153/19 I 18/22 20/17 67/4 confusing [3] 51/24
charging [11] 11/22 201/19 201/20 154/25 155/10 156/9 I 91/10 120/2 157/25 I 52/4 198/20
12/24 15/9 15/13 clear-cut [1] 98/1 156/11 156/16 157/17) 172/10 confusion [1] 79/7
46/11 20/22 43/21 clearer [3] 51/19 166/19 167/15 concerning [8] 21/25I congratulate [1]
46/2 102/5 113/7 51/20 147/17 commercial [1] 102/18 102/24 104/24I 202/16
202/1 clearly [22] 37/11 120/1 108/23 111/1 136/5 I conjunction [1]
chase [1] 86/8 40/11 44/5 49/12 commission [3] 165/13 135/7
check [5] 128/12 51/20 71/8 75/21 54/21 55/9 190/11 concerns [9] 20/24 Iconnection [1]
1453/6 164/10 165/22 97/18 101/18 102/16 Icommitted [1] 53/17 I 21/18 36/4 56/14 117/13
1914/5 109/9 116/4 133/12 Icommon [1] 27/13 114/3 157/25 200/1 Iconsent [2] 45/3 45/5)
checks [1] 195/16 I 195/22 158/6 158/9_ Icomms [4] 128/1 201/18 201/22 consequences [2]
Chester [1] 118/22 160/17 164/4 165/10 I 128/3 128/7 129/7 concession [10] 8/20I 102/20 104/12
Chief [1] 4/4 173/10 173/13 176/1 Icommunicate [2] 8/21 9/5 11/17 64/20 I consider [24] 6/2
choice [5] 74/2 77/5 Cleveleys [1] 112/5 I 28/2 35/20 105/9 105/12 105/18 I 10/16 11/7 11/13 14/3)
82/15 196/16 197/8 {Client [3] 109/15 communicated [3] 105/22 105/23 14/5 14/11 20/8 20/13)
choir [1] 32/23 180/16 180/18 38/10 116/24 201/23 Iconcessions [5] 24/19 27/8 61/3 64/16
chose [1] 108/14 Iclients [2] 172/6 communication [5] I 103/20 104/3 104/8 I 74/7 74/12 80/12
chosen [1] 106/25 172/7 20/18 41/10 121/9 104/14 104/17 80/16 101/6 109/24
Chris [4] 115/18 close [2] 61/18 133/23 137/2 conciseness [1] 121/1 129/9 153/15
Christopher [1] 199/12 communications [12]I 202/17 160/15 168/2
415/19 close-ended [1] 35/14 35/16 35/22 Iconclude [2] 2/21 _ I considerably [1]
chronological [1] 199/12 36/6 36/19 40/15 145/5 36/4
58/21 closed [2] 51/14 40/19 41/4 96/5 96/14I concluded [2] 12/1 Iconsideration [13]
chronology [4] 58/15 51/18 146/12 182/5 147/15 6/9 13/21 13/25 16/10
63/8 64107126. Icloser [1] 16/1 compensate [1] concludes [1] 56/24 I 46/19 58/13 100/12
circumstances [13] clue [1] 148/8 145/9 conclusion [7] 12/15I 101/10 133/22 137/1
too 12/18 66/16 \COLt] 1/21 competent [1] 37/8 37/11 37/13 138/12 139/7 151/6
79/24 92/6 95/9 97/11 code [11] 10/21 200/14 47/25 145/3 200/19 I considerations [1]
99/1 107/25 199/20 I 13/19 13/24 19/20 I competing [1] 62/13 Iconclusions [3] 13/17
201/11 201/14 202/4 I 19/22 21/21 64/17 complained [3] 64/21] 11/23 137/9 170/21 Iconsidered [21] 3/24
circumstantial [1] 83/2 97/16 107/17 157/22 178/17 condition [3] 25/8 4/18 4/20 10/23 12/10
44/16 164/21 complaints [5] 3/21 I 26/2 26/10 16/19 22/7 22/9 22/22)
citation [1] 57/8 cognisant [1] 28/20 I 133/8 173/9 173/25 Iconditional [3] 17/24) 30/1 30/24 38/13
cite [3] 18/24 91/9 coin [1] 175/5 174/9 22/25 117/6 49/12 54/7 54/20
115/10 coincidence [1] complete [1] 140/3 Iconditions [4] 16/22 I 83/14 98/5 121/6
civil (2) 26/6 11214 I 166/24 completed [1] 24/5 21/6 23/9 138/7 151/16 179/14
claim [5] 74/5 103/25 colleague [1] 170/4 I 186/17 conduct [9] 20/4 23/4! considering [6] 6/3
412/4-131/15 12/7 \COlleagues [1] completely [1] 137/5 I 25/7 39/23 42/6 42/8 I 14/1 14/7 72/24
claimed [1] 131/16 196/18 complex [2] 165/19 I 74/9 75/18 80/13 112/25 121/18
claiming [2] 128/1 coloured [1] 78/20 165/20 conducted [4] consistency [2]
152/22 combination [1] complied [3] 27/16 I 197/18 198/16 198/19) 15/11 15/12
claims [1] 199/6 125/17 28/23 30/15 200/14 consistent [6] 9/7
Clarification [3] combined [2] 81/24 Icomply [3] 135/23 Iconfess [1] 117/7 I 17/25 126/18 132/20
425/12 125/17 143/12! 179/8 136/1 155/4 confession [4] 52/14} 132/23 144/3
clarify [6] 63/10 come [18] 2/12 5/10 Icomplying [2] 40/7 I 198/7 198/17 202/10 Iconspiracy [1] 47/10
124/20 125/18 143/14 5/18 5/22 6/8 7/10 154/18 confidence [1] 15/22 Iconstitute [1] 61/17
4153/4 190/5 7/19 13/16 26/14 compressed [1] 82/1Iconfined [1] 196/17 Icontact [1] 173/11
clarity [1] 146/21 61/17 65/17 75/12 computer [17] 21/20 Iconfirm [2] 149/16 I contacts [1] 173/14
Clark [1] 18/24 83/25 90/21 95/23 24/1 34/2 69/11 75/12) 179/12 contain [3] 32/6
Clarke [2] 106/14 123/16 159/19 162/14] 81/18 81/23 88/5 88/7I confirmation [2] 32/12 143/20
4107/8 comes [1] 95/2 88/14 88/19 89/22 109/21 167/17 contained [4] 55/8
clear [43] 5/11 9/11 coming [6] 6/7 7/18 I 89/23 91/1 92/19 confirmed [8] 9/10 I 90/24 107/15 123/19
11/24 17/16 20/15 46/11 61/21 86/17 92/24 140/5 46/3 46/5 46/8 110/3 Icontemplated [1]
22/8 28/5 44/24 45/7 123/12 concede [1] 106/6 115/20 134/15 135/3 I 163/5
BI/17 52/5 52/12 commas [1] 198/6 conceded [2] 57/8 I confirming [2] 66/10 I contemporaneous
B48 86/12 71/9 Icommenced [1] 106/5 189/1 [2] 48/11 48/22
77/19 79/8 90/5 92/12I 194/3 concentrate [1] confiscation [9] contend [1] 157/10
93/3 93/7 98/1 106/2 [comment [9] 96/22 I 124/6 13/18 13/21 14/4 14/9I contended [1]
116/20 116/21 117/1 126/11 126/20 133/14I concern [12] 6/8 14/16 14/24 45/12 105/15
422/14 131/21 132/14 133/24 149/15 154/24I 16/18 20/4 21/11 100/24 104/2 content [6] 74/8
1451/9 159/14 159/25 156/13 197/6 21/16 36/3 91/3 102/7Iconform [2] 29/3 91/14 134/24 147/11
460/12 160/13 160/15Icommenting [1] 97/2) 106/1 133/3 134/9 37/3 150/21 173/14
comments [14] 136/16 confronted [2] 19/4 Icontents [3] 40/10
(67) charges... - contents
INQ00001110
INQ00001110
Cc 164/22 165/4 191/14 Icourse [6] 111/11 4/13 4/17 dated [9] 77/1 81/7
contents... [2] 162/17 copying [5] 76/18 159/25 162/13 197/1 Icross-disclosure [9] I 93/18 119/13 130/21
173/11 79/2 150/25 185/15 I 197/6 199/19 2/10 2/16 2/22 3/8 186/24 188/3 189/15
contested [2] 57/11 191/11 court [52] 5/8 9/10 3/20 4/20 5/1 102/17 I 193/1
108/13 Core [5] 41/16 41/20 I 10/23 22/7 22/7 22/20) 170/15 David [4] 1/19 6/15
context [9] 19/17 41/23 148/10 171/8 I 25/1 25/5 25/14 30/13Icross-examination I 46/16 46/17
20/24 41/24 45/14 corollary [1] 194/23 I 30/16 46/24 47/5 48/1) [1] 48/15 day [22] 14/20 24/12
58/7 134/2 138/15 correct [11] 53/11 49/17 53/3 53/11 cross-reference [2] I 34/1 34/1 66/21 67/2
151/14 153/24 54/1 62/10 84/15 53/15 53/17 53/25 136/14 161/41 67/11 67/24 72/16
continuation [1] 86/12 93/4 172/11 54/22 55/17 56/18 cross-referring [1] 73/10 94/8 115/12
1477/4 176/11 177/1 187/8 56/19 56/20 57/2 136/12 127/20 161/21 162/1
continue [8] 1/13 198/5 63/15 63/15 63/16 Crown [13] 53/11 162/12 167/14 168/6
57/15 63/5 63/8 corrected [3] 13/11 I 63/17 63/19 63/23 53/15 53/25 55/16 168/15 168/21 169/5
106/19 134/11 160/18 54/12 106/22 64/7 64/8 65/4 65/5 I 56/19 56/20 63/15 203/12
17713 correctly [4] 93/2 73/4 93/23 104/22 63/16 63/18 64/6 days [8] 125/1 128/4
‘ 134/16 135/4 145/8 I 107/12 110/8 116/15 I 118/22 175/1 188/5 I 128/8 130/6 186/17
continued (8) tS I correspondence [3] I 117/8 118/22 161/9 [Crown's [1] 192/10 I 186/20 189/21 202/20
204/3 7/3 82/4 95/24 165/15 175/1 175/1 Icrunch [1] 159/20 IDCS [1] 156/12
continuing [2] 10/10 [Corridor [5] 140/17 II 179/7 181/9 181/24 curious [1] 183/5__Ide [1] 64/9
T7I7 140/17 140/22 141/11] 188/5 currency [4] 47/12 Ide novo [1] 64/9
contract [4] 26/7 171119 court's [3] 13/20 14/4] 48/17 107/20 108/4 Ideal [10] 6/20 8/3
1441/5 141/8 197/13 Ie0froboration [1] 123/13 currently [1] 55/7 I 54/19 58/5 111/23
contractual [1] 128/8I 1897 courts [3] 101/5 custodial [2] 19/2 I 146/8 165/19 167/7
contractually [1] cost [1] 128/21 174/23 175/20 24/20 167/9 169/2
17/20 could [46] 9/11 14/16Icover [5] 9/15 23/23 ICustomer [1] 77/17 Idealing [10] 3/13
contradictory [2] 17/18 45/18 45/23 I 41/19 120/1 1125/3 Ieut [5] 39/16 60/16 I 5/23 7/20 10/21 39/3
52/13 198/20 46/3 56/22 62/24 __I covering [3] 59/14 I 61/8 86/8 98/1 42/22 114/22 134/23
contrary [4] 31/19 I 87/19 73/5 77/12 90/1I 69/4 86/14 cut-in [1] 61/8 160/20 171/17
4015 54/8 174/1 97/16 98/25 101/19 Icovers [1] 149/23 ICutting [1] 21/24 _Idealings [1] 28/24
contrasting [1] 125/9I 12/4 108/13 to9/19 ICP [1] 148/14 D.___ Iealt [12] 6/15 6/22
contributed [2] 119/8 125/20 128/10 ICPIA [3] 83/2 83/12 6/24 7/25 8/5 30/9
102/16 108/13 128/12 129/5 129/14 I 107/17 D32 [1] 55/24 417/11 117/12 129/25
control [1] 24/17 143/14 146/22 148/6 ICPS [4] 10/13 10/16 Idaily [1] 141/15 142/13 179/6 179/15
conversation {7] 7/8 I 199/3.153/9 155/25 I 42/17 43/22 damages [1] 103/25 IDecember [14] 1/1
116/21 164/13 164/14I 156/21 159/24 160/14] create [2] 176/4 damaging [2] 72/23 I 4/5 112/8 124/8
480/21 197/21 197/25I 160/22 162/17 166/18] 176/5 74/20 124/16 126/1 127/21
conversations [1] 168/1 172/23 172/25 Icredibility [3] 113/10 IDangers [1] 103/18 I 130/14 130/21 142/21
186/10 188/1 190/5 I 113/13 114/13 data [73] 59/19 60/20I 143/11 144/9 144/10
7 195/1 195/3 200/25 Icrime [1] 42/23 69/18 84/2 84/21 144/10
corvieted ay tart I 202/12 criminal [26] 5/21 I 85/12 85/22 85/23 _IDecember 2009 [1]
183/25 couldn't [6] 45/20 I 25/18 26/3 26/9 26/11I 87/13 87/18 89/7 89/8) 4/5
conviction [34] 12/2 I 140/18 174/16 178/24) 26/19 27/13 29/10 I 89/11 89/13 89/25 decide [2] 164/1
tot 14/18 19/24. I 194/1 194/17 46/24 48/1 53/3 54/20) 92/20 92/21 92/23 I 180/15
counsel [26] 5/4 8/2 I 55/9 57/3 63/15 91/5 I 121/14 122/4 126/9 I decided [2] 98/6
ban ae ate 288 47IT 54/3 96/23 97/14) 94/22 99/19 140/14 I 128/3 128/6 128/11 135/8
57/16 63/20 64/2 98/7! 98/14 98/17 98/21 141/3 174/22 174/22 I 128/16 128/18 128/23) deciding [2] 101/21
101/25 102/10 102/19 99/14 109/9 109/10 I 178/2 179/7 179/17 I 129/11 129/14 130/3 I 114/3
409/13 115/14 116/22I 183/1 130/5 130/19 131/22 I decision [20] 6/10
Toate togloe tosiiaI 116/23 1641/8 161/19 criminality [3] 9/16 I 132/9 132/11 132/16 I 11/22 15/13 19/18
Teale toni tayiri I 161/20 162/5 166/21 I 10/2 1219 132/18 133/7 134/16 I 46/2 47/5 107/12
tron teers siong I 179/18 185/16 185/17 eritical [2] 42/5 135/2 135/5 135/9 I 110/6 110/6 110/10
M002 ope 19ein3I 19171 198/23 143/21 135/12 143/3 145/7 I 13/7 124/10 132/5
count [14] 10/15 criticise [1] 18/2 I 145/9 147/13 147/19 I 132/9 132/11 132/18
convictions [2] 1044 s/1g 11/9 14/9 14/13I criticism [5] 20/25 I 186/24 157/4 187/17 I 141/9 179/16 180/20
convinced [1] 156/22 20/10 47/10 47/15 21/9 23/1 101/14 158/3 159/11 159/15 I 192/15
‘ 47/18 47/20 47/21 I 114/25 160/4 160/10 163/25 I decisions [5] 16/11
panne 211 I 49/7 101/7 193/8 _Ieriticisms [3] 46/23 I 164/6 169/17 169/19 I 43/21 195/25 196/3
Soe ay 2a [Count 4 [3] 47/18 I 82/12 120/15 470/14 190/11 192/7 I 202/1
eed a te tayio I 47/20 49/7 cross [17] 2/10 2/16 I 192/13 192/16 194/8 I decisive [1] 113/4
copies [3] 11918, [Count2 [1] 47/21 I 2122 2/24 318 3120 4/1I 194/12 19513 19515 decisively [1] 113/13
eae counts [4] 9/23 11/9 I 4/13 4/17 4/205/1 I 195/6 195/12 195/16 Ideclaration [1] 69/13
copy (7) 67/21 14/2 47/9 48/15 102/17 136/12 I 197/3 declined [1] 146/23
eT eriry 15213 Icouple [4] 63/10 I 136/14 1641/1 170/15 Idate [3] 118/14 default [1] 158/14
124/23 124/25 152/12Icross-case [3] 4/1 I 125/25 193/8 defects [4] 171/3
(68) contents... - defects
INQ00001110
INQ00001110
D Delivery [1] 119/9 I 40/23 41/4 41/7 43/15] 3/20 4/18 4/20 5/1 I division [5] 5/22 48/2
defects. [a] 172/22 [delving [1] 186/4 I 45/1 45/10.45/18 I 5/20 5/25 6/4 6/11 I 53/4 63/16 139/24
4176/2 177123 demonstrate [2] 47/23 48/10 50/5 50/8) 39/10 40/15 40/25 I Division's [1] 46/25
defence 73] 27/22 I 33/10 146/12 51/2 51/11 65/1 75/8 I 52/24 83/6 83/20 do [101] 21/24 24/9
83/16 83/23 84/9 94/eI demonstrated [1] I 86/10 86/22 100/11 I 86/25 87/591/25 _I 27/7 27/8 31/8 36/11
107/7 107/22 1908/9. I 33/12 106/24 121/8 121/8 I 102/10 102/17 102/19] 35/11 38/7 38/7 39/14
415/13 118/16 115/24/demonstrates [1] I 122/5 122/12 123/8_ I 102/20 102/25 104/7 I 40/14 41/25 43/2 43/5
teria 116/22 118/18) 20/14 136/8 140/20 151/19 I 104/25 106/9 107/16 I 51/5 53/8 55/20 57/4
420/20 120/22 123/12I4emonstrating [2] I 151/22 159/1 160/1 I 107/19 108/11 109/6 I 59/13 60/22 64/6
4126/21 145/15 149/13} 30/1 187/19 173/19 174/2 178/10 I 110/7 110/11 111/1 I 65/14 70/10 71/1 74/7
452/5 152/22 153/10 denies [1] 126/14 198/7 200/6 132/24 133/21 134/19] 74/12 74/25 78/13
153/16 154/8 154/23 deny [1] 24/1 didn't [34] 7/3 7/7 I 134/20 134/25 135/16I 78/22 79/4 79/6 79/11
164/28 164/25 1565/9 IdePartment [4] 25/18) 7/22 32/17 37/4 38/7 I 135/19 135/22 135/24] 80/5 80/12 80/16
185/16 186/10 156/11) 120/14 140/16 141/3 I 43/14 44/11 49/2 I 136/25 137/1 137/17 I 81/12 84/13 84/13
186/13 187/8 160/25 IdePartments [4] 49/15 52/5 54/4 54/9 I 139/12 144/7 154/9_ I 84/22 91/6 91/13
461/11 161/16 161/20) 139/10 140/22 140/23] 54/19 55/1 61/17 71/8I 156/1 170/12 170/15 I 93/21 94/20 96/6 96/9
4162/2 16/3 163/10. I 1471 93/5 97/3 98/21 106/6I 171/2 174/21 175/3 I 98/12 98/14 99/4 99/6}
163/20 164/2 1965/2 AePend [4] 75/20 I 1139/8 122/25 125/15 I 175/7 175/11 176/1_ I 99/6 99/20 100/25
466/11 166/13 166/14) 98/11 155/2 201/16 I 129/17 132/2 134/7 I 17716 177/14 177/17 I 101/5 101/18 104/18
466/25 167/4 167/16 Idependent [3] 158/4 174/15 178/21 I 178/3 178/8 179/21 I 106/24 108/5 108/10
469/18 170/17 170/18] 114/24 155/12 197/3 I 182/1 196/9 198/1 I 184/7 185/4 185/6 I 116/9 120/11 120/19
475/14 175/17 175/18I4ePending [1] 201/1 188/8 192/17 193/9 I 121/8 122/21 125/13
4176/6 176/15 176/22 I 126/23 differed [1] 83/4 193/14 196/3 196/5 I 127/11 130/9 133/14
477/12. 177/13 177/18] 4ePlov [1] 43/12 Idifference [3] 18/19 I 196/8 196/10 133/24 137/13 137/14
178/8 1886 188/22 [derived [2] 51/19 I 24/14 115/6 discount [2] 143/15 I 143/23 151/10 153/15]
4190/14 192/10 192/25) 142/3 different [16] 9/15 I 143/24 154/21 155/3 155/8
4194/7 194/24 1985/4 IAeriving [1] 19/4 I 10/2 12/9 14/3 22/11 Idiscovered [1] 187/5I 155/17 156/4 156/7
195/15 195/19 describe [3] 110/25 I 39/8 49/15 63/14 70/6I discredit [3] 126/13 I 157/14 158/18 159/1
defendant [34] 10/14] 198/6 198/17 95/16 109/15 109/24 I 127/3 127/5 159/9 159/14 160/4
1621 17/17 tag described [3] 55/1 I 129/24 127/2 172/15 Idiscrepancies [4] __I 160/11 160/22 160/23
18/18 1913 20116. I 106/16 198/23 199/20 186/10 187/13 188/21) 164/19 167/20 174/11
20/25 23194 24/1 ASIT difficult [8] 8/4 16/12 I 190/2 174/12 179/3 179/10
43/11 74122 74/23 ip 102/3 157/13 163/24 Idiscrepancy [4] 179/24 183/4 183/6
75/5 B2/21 92/3 designed [3] 77/11 I 176/6 179/20 179/20 I 187/4 190/9 190/17 I 183/8 186/24 192/6
401/10 106/20 109/23) 77/15 187/18 difficulties [1] 174/9 I 190/18 192/24
4110/2 145/16 115/25 Idespite [6] 3/15 41/9 Idig [1] 127/23 discuss [5] 161/10 Idocument [21] 7/10
420/17 147/13 147/19] 24/6 68/16 71/10 Idirect [2] 44/15 97/11] 162/1 180/17 181/13 I 28/13 37/19 37/22
459/10 174/12 175/6 I 87/18 direction [1] 183/7 I 182/2 37/23 50/2 55/15
4180/3 180/12 185/23 Idetail [2] 29/18 62/4 Idirectly [6] 72/25 Idiscussed [4] 3/7 I 58/16 85/2 86/11 87/1
188/13 188/15 detailed [5] 26/25 I 73/11 76/18 112/10 I 60/4 158/16 162/24 I 90/25 90/25 106/1
defendant's [1] 77/23 131/13 169/3_ I 119/25 133/19 discussing [2] 127/18 157/1 163/8
188/12 182/14 disagree [4] 51/6 I 177/24 178/14 180/22 181/21 185/9
defendants [3] 47/18I tailing [1] 118/8 I 51/22 164/2 198/24 discussion [15] 18/5 188/2
120/16 120/17 details [6] 1/7 1/9 Idisagreement [1] _I 25/19 26/6 32/15 35/5Idocuments [3] 23/6
defended [4] 176/21 I 31/12.85/24 167/18. I 7211 56/13 56/23 76/1 76/7I 151/6 185/3
defending [2] 179/17I 197/12 disclosable [4] 5/14 I 106/19 107/5 134/17 Idoes [24] 7/11 8/7
179/18 determine [2] 55/1 I 5/19 108/4 155/23 I 157/16 160/18 172/14] 10/9 11/20 19/12 20/5
defraud [1] 47/10 I 107/10 disclose [4] 3/5 _Idiscussions [7] 3/5 I 49/8 66/25 67/7 68/18
degree [2] 7412 [determining [1] 105/18 105/20 136/8 I 6/1 20/18 23/6 134/3 I 76/22 84/7 86/20
Boe 57/22 disclosed [31] 27/22 I 183/14 183/14 87/12 87/16 98/18
delete [4] 3915 [Diane [1] 93/16 40/21 41/16 70/13 Idisentangling [1] I 98/18 98/19 114/8
75/28 77/21 95/10 [Dianne [3] 115/13 I 70/22 74/4 71/19 _I 180/1 124/13 125/18 134/18
deleted [6] 3919 I 1162. 116/21 71124 72/1 72/2 75/7 Idishonest [1] 152/8 I 143/20 188/23
Cort? 73/24 75/6 (diary [1] 153/3 75/9 78/14 78/23 __Idishonestly [2] 24/6 Idoesn't [13] 15/24
75/24 7113 did [68] 4/256/9 —_I 80/20 83/1 83/9 84/7 I 106/24 38/22 77/13 98/19
deleting [3] 3912 I 13/12 13/19 16/8 I_I 95/19 96/15 104/3 I dishonesty [6] 16/4 I 108/16 120/13 124/11
70/8 Tet 19/22 22/10 25/13 I 104/15 105/8 107/22 I 97/6 97/8 97/20 139/12 141/19 141/20
deletion [1] 70/20 I 28/12.28/19 28/23 I 108/6 108/8 108/22 I 155/18 201/6 187/10 160/16 183/4
deletions [2] 75/2. I 292 29/17 30/24 31/4) 109/3 109/11 138/8 disjunct [1] 136/22 Idoing [4] 74/24 84/14
75/2 31/8 31/13 32/4 32/9 I 140/12 display [4] 50/4 127/11 163/15
deliberately [2] 24/6 I 32/17 35/15 36/5 36/8I disclosing [2] 139/8 I 55/22 111/22 10/4 Idon't [29] 11/15
ON 36/11 36/14 36/21 I 139/25 disproving [1] 44/21 I 11/19 34/7 39/4 53/15]
delivering [1] 35/8 I 37/1 38/7 38/7 39/12 Idisclosure [78] 2/10 /dissent [1] 37/13 I 65/9 68/1 69/5 70/4
39/20 39/25 40/18 I 2/16 2/22 2/243/8 dive [1] 148/25 84/24 91/15 94/9 95/1
(69) defects... - don't
INQ00001110
1NQ00001110
D during [8] 26/19 182/24 184/14 34/2 eventually [2] 71/11
don't... [16] 1094 42/15 67/9 107/20 elsewhere [2] 100/8 Iengineered [1] 77/12) 177/8
149/14 152/2 155/7 I 108/4 184/25 187/11 I 141/12 enquiries [4] 44/20 Iever [1] 15/1
156/19 163/12 164/24] 195/10 elucidate [1] 39/5 I 44/25 190/6 199/7 __I everyone [1] 203/9
177/19 178/1 180/5 [duties [19] 27/12 email [50] 27/1 58/24 I enquiry [2] 42/18 everything [1]
492/23 197/6 198/24 I 27/15.27/16 27/23 I 58/25 60/2 60/5 60/7 I 102/4 149/23
498/25 199/10 201/20] 28/2 28/17 28/21 60/16 60/16 61/9 Enright [1] 1/19 evidence [114] 2/24
done [24] 45/8 61/13 I 29/15 29/16 32/3 67/12 69/4 69/15 ensure [4] 27/16 2/25 3/20 4/17 6/9
69/17 75/20 75/21 I 32/24 33/16 34/24 I 72/21 73/10 76/4 33/14 34/23 73/3 8/22 9/6 9/21 10/4
84/11 86/6 86/11 37/5 127/13 132/23 I 76/25 84/19 85/16 —_Ientailed [2] 33/8 11/18 11/25 12/4
g6/18 113/21 126/24 I 137/17 140/2 144/7 I 86/14 93/16 116/3 I 33/17 12/17 12/24 13/2
127/12 143/8 146/22 [duty [10] 30/16 33/14I 118/2 118/11 119/10 enterprise [1] 96/10 I 14/25 16/7 16/20 19/4
4154/6 155/13 158/11 I 34/9 99/4 132/21 120/5 120/11 123/23 entire [1] 179/22 19/21 19/23 20/9
489/17 1682/8 1ea/19 I 133/21 136/25 137/11] 126/17 129/22 138/1 Ientirely [3] 39/2 26/15 26/17 26/19
484/17 190/17 199/18] 139/12 177/17 142/15 143/2 149/4 I 56/17 84/16 27/17 28/8 28/13
199/22 E I 150/14 150/15 150/16I entitled [4] 11/7 44/9I 28/19 28/23 29/6 29/8
doubt [3] 56/10 = 150/20 153/7 166/21 I 104/6 107/1 32/4 32/9 32/18 32/22
110/14 110/19 each [22] 6/19 6/25 I 168/10 168/21 185/11Ientries [2] 106/21 33/22 34/11 38/24
down [54] 2/20 7/10 9/14 10/1 23/5 23/13 I 186/16 186/21 187/22I 152/23 39/19 40/2 40/18
13/16 22/17 26/14 I 41/18 82/24 118/20 I 188/3 190/25 191/6 envisaged [1] 162/8 I 40/23 41/15 42/24
39/8 58/23 59/4 60/1 119/3 119/4 120/7 191/7 191/16 envy [1] 180/21 43/1 43/11 43/25
86/8 68/6 69/3 73/15 I 1207 120/20 1212 emailed [2] 69/18 episode [1] 169/22 I 44/15 44/16 45/17
7712 78/17 79/19 arya) 121/19 121/20 122/6 I 124/25 equally [4] 49/3 93/5 I 45/22 46/4 47/4 48/14
83/25 84/18 86/4 123/5 148/15 153/14 Iemailing [1] 66/9 151/18 200/25 52/2 52/12 63/12 65/2
88/23 90/21 93/15 I 162/14 emails [12] 23/15 Iequating [1] 90/8 I 65/5 65/13 74/8 75/4
94/4 95/23 103/3 earlier [20] 7/24 35/4 38/13 70/4 74/17I equivocal [3] 52/8 I 77/14 80/3 80/7 80/24)
108/18 119/1 118/2 I 31/23 31/25 46/7 76/18 79/2 95/24 198/8 198/17 90/24 91/5 91/11
tero4 119/17 128/24) 22/21 7/5 74/17 146/5 150/7 150/10 error [9] 6/13 24/1 I 94/10 96/24 97/3
130/25 131/7 140/16 I 88/18 115/3 123/10 I 15915 24/8 41/4 80/3 103/11) 97/11 97/15 97/20
440/17 140/22 141/11] 130/16 142/16 151/20] embarrassed [2] 145/10 170/22 202/13] 98/5 98/16 98/23
4agiio 144/15 145/17] 124/19 159/5 168/21 I 73/4 97/23 errors [6] 14/21 41/3 I 99/10 99/16 100/10
4149/4 150/18 15113 I 12/3 171/15 200/12 I embarrassing [1] 171/3 172/22 176/2 I 100/11 100/13 102/3
452/15 152/19 161/6 I 2023 74/20 177123 102/15 103/11 117/24
4166/4 167/22 171/19 I®rly [3] 28/5 184/10 Iemerged [1] 171/4 escalation [1] 85/9 I 118/9 131/9 131/25
181/5 185/20 189/19 I 1881 emphasised [1] 33/2 Iespecial [1] 34/25 132/10 133/4 134/21
189/22 easily [2] 164/20 emphatic [1] 160/1 Iespecially [2] 43/13 I 139/5 147/15 154/15
downloaded [2] 167/20 employee [2] 18/21 I 80/22 154/17 159/7 165/15
59/19 BU/21 easy [1] 51/10 170/4 essence [1] 195/15 I 174/20 175/3 180/14
draft [24] 66/21 Eden [5] 9/11 12/7 Iemployees [1] 66/9 Iessential [1] 158/10 I 182/21 182/21 183/10
66/23 67/21 68/5 14/20 107/6 109/8 —_Iemployer [2] 34/14 essentially [21] 53/2 I 184/25 186/19 189/25
68/16 70/11 71/3 72/7I edition [2] 10/20 182/20 63/19 64/11 65/12 193/5 199/7 200/4
72/10 72/19 73/8 13/24 employers [2] 181/10] 65/23 86/12 151/8 —_ I 200/11 200/17
7313 75/17 7e16 — \effect [8] 13/8 19/11 I 181/25 167/10 175/19 176/13I evidential [11] 10/5
76/19 78/3 78/22 81/6I 28/9 48/17 54/22 57/2) enabled [1] 1/23 178/18 178/21 179/2 I 11/6 11/23 15/22 16/2
81/16 81/16 82/6 91/4 199/3 enacted [1] 107/18 I 184/16 189/7 189/12 I 16/3 21/22 65/3 97/5
95/21 95/25 98/15 _ I@ffectively [3] 23/8 jenclose [1] 193/4 190/14 191/25 192/12] 99/12 99/17
drafting [3] 73/14 121/11 121/21 enclosed [1] 124/3 I 192/16 193/11 evil [1] 14/20
74/13 80/17 efforts [1] 73/14 enclosing [1] 61/13 Iestablish [3] 101/12 Ievolution [1] 91/24
drafts [10] 39/13 eg [1] 42/17 encompass [2] 99/11] 104/6 186/1 evolved [4] 28/4
83/3 83/1183/13 eg by [1] 42/17 99/11 established [2] 27/24I 83/21 83/22 138/23
95/18 96/6 96/12 either [13] 1/13 9/13 I encountered [2] 200/15 exactly [15] 13/14
96/14 138/18 138/22 I 125 19/15 41/25 46/1) 174/10 188/24 establishing [1] 54/16 58/12 67/7
draw [3] 37/8 98/4 I 49/16 109/11 119/8 encourage [1] 9/8 I 18/25 75/13 86/22 93/22
137/11 140/20 164/1 165/23 Iend [15] 8/24 38/18 let [1] 72/14 124/20 125/12 127/24
drawer [1] 99/24 177/119 56/23 77/9 77/9 78/19Iet cetera [1] 72/14 I 128/12 129/15 142/23
driven [1] 172/5 element [2] 97/8 87/21 87/22 88/1 etc [1] 189/3 198/15 202/2
dropping [1] 25'9 I 155/21 89/17 92/10 102/5 _Ieven [17] 3/21 5/25 I examination [6]
due [2] 56/10 186/10 elements [3] 16/8 I 123/23 131/10 197/23] 11/5 13/1 19/2 32/19 I 45/10 48/15 61/12
DUNCAN [2] 2/4 16/10 37/7 ended [1] 199/12 32/22 95/2 98/7 62/18 84/6 200/13
204/2 elicited [2] 198/20 lends [1] 55/19 164/24 165/3 170/16 Iexaminations [1]
Dunks [4] 173/17 199/12 enforce [1] 25/12 174/4 179/9 195/6 I 30/4
duplicate [1] 193/4 else [10] 8/5 38/23 I engaged [2] 23/4 195/14 201/13 examine [8] 58/8
duplication [1] 120/9I 492,75/20 104/6 170/10 event [1] 190/21 112/8 128/18 129/14
139/3 165/9 170/6 engineer [2] 34/2 __ events [1] 162/13 I 131/12 133/7 143/5
(60) don't... - examine
INQ00001110
1NQ00001110
E 61/19 70/24 74/15 I extremely [2] 39/24 I 202/9 37/17 47/2 47/7 4719
examine... [1] 151/13 75/4 87/4 118/7 202/20 falsification [1] 23/23] 47/19 47/20 48/16
examined [8] 15/18. I 121/20 126/19 126/24Ieyes [1] 181/5 familiar [5] 121/2 I 48/25 49/7 58/10 61/8
50/10 84/3 132/8 127/9 133/4 134/21 I__I 130/28 144/22 144/25) 67/17 97/15 116/19
135/12 163/21 181/18) 135/21 136/23 135/24) _I 197/12 116/23 124/6 129/20
200/24 137/19 147/2 153/18 Iface [12] 11/25 12/16 Ifamiliarise [1] 119/3 I 133/6 134/24 141/8
examining [1] 157/12 153/21 153/22 154/1 I 13/10 21/16 38/14 _—_Ifar [9] 2/17 35/9 38/5 I 161/12 161/21 161/25
example aa 6/12 154/14 154/17 154/18I 123/8 132/15 137/6 I 40/1 44/4 99/9 157/24) 168/6 169/5 169/5
4156/6 158/2 159/13 I 151/11 195/13 195/25] 178/11 195/22 174/13 181/5 1841/6
oie dope jena 40/3) 164/13 162/2 162/3 I 196/8 fault [3] 79/13 89/1 I 185/9 189/5 193/1
50/20 62/9 106/7 163/4 163/8 163/10 Ifaced [1] 179/4 116/6 195/20
Tia44 123/13 141/2 I 163/20 164/3 164/8 fact [40] 3/8 4/23 Ifaults [8] 89/3 89/4 firstly [1] 98/17
HOM 15/18 trai I 165/2 165/15 165/18 I 5/17 7/17 813 9119. I 438/2 1390/9 140/25 I fit [3] 127/7 12718
4181/12 182/20 198/1 I 165/20 165/21 168/8 ats 20110 44/2 44/6I 141/17 173/5 17417 I 127/18
examples [4] 16/24 I 169/11 169/25 170/18 favour [2] 113/12 /fits [1] 121/22
17/4 38/18 157/8 182/4 182/21 183/2 I 45/19 49/17 58/4 133/9 five [7] 28/7 30/23
except [2] 130/17 I 1839/3 183/8 183/10 I 62/17 71/7 78/2 83/20IFebruary [20] 156/12) 38/8 40/21 148/15
144/12 190/20 84/11 91/10 96/19 I 161/6 166/2 187/3 I 161/3 196/18
excessive [3] 104/9 I@xPert's [7] 27/17 99/9 109/5 109/10 I 187/7 187/12 188/1 I fix [1] 147/25
104/21 105/16 27/20 29/18 127/13 I 110/6 113/15 114/12 I 188/4 188/6 188/21 _Ifixing [1] 172/21
exchange [3] 80/20 I 190/1 164/9 182/14 I 117/10 1239/8 127/18 I 189/15 189/20 189/21/flag [1] 151/20
121/3 129/12 experts [6] 32/19 I 130/2 147/17 159/1_ I 190/4 190/7 191/16 I flagged [1] 201/17
exchanges [1] 162/6 162/9 162/14 I 170/22 175/10 17/3 I 193/2 193/3 193/6 _I flawed [3] 134/13
factor ‘ebruary loating
a 1 4518 I gre 23/22 113/2 113/4 I 187/3 187/7 187/12 Ifocus [10] 44/21
Executive [1] 4/4 [explain [7] 13/15 I 113/5 113/5 113/9 I 190/4 190/7 50/12 50/14 60/25
exercise [3] 14/12 I 17/19 70/7 105/2 113/12 113/14 114/2 IFebruary 2013 [1] I 75/14 195/24 170/1
50/24 100/22 123/9 173/23 180/7 Ifactoring [1] 15/10 I 188/1 170/5 170/5 185/22
exercising [1] 159/13I°*Plained [4] 91/16 factors [4] 10/22 Ifeed [1] 1/10 focused [2] 155/20
h 138/8 138/14 158/23 I 21/2 21/21 23/17 _Ifeel [2] 68/1 156/21 I 170/16
exhibits [2] 149/18 explaining [5] 59/18 Ifacts [6] 15/17 21/16 Ifell [1] 83/9 focusing [1] 102/19
158/14 60/19 63/14 66/14 I 91/1191/12 119/4 few [5] 7/2056/8 _Ifollow [14] 10/9
existed [2] 110/13 I 79/28 152/4 153/13 180/25 185/3 I 19/22 42/21 51/10
163/3 explains [3] 86/6 _Ifactual [1] 182/21 I figure [1] 105/14 84/16 97/18 132/2
existence [3] 28/20 I 181/18 181/22 failings [4] 102/15 Ifigures [4] 112/17 I 157/16 168/19 177/20}
83/11 89/16 explanation [16] 103/13 134/20 135/19] 152/24 197/9 197/9 I 198/14
exists [1] 199/19 12/14 16/1 50/15 72/8I failure [18] 4/25 37/9 Ifill [4] 198/2 follow-up [1] 157/16
expect [2] 165/17 I 78/11 109/25 126/13 I 37/15 38/12 42/6 67/8\fiims [1] 93/25 followed [1] 18/5
182/13 126/21 127/4 127/6 I 68/13 68/23 72/22 —_Ifinal [8] 40/6 81/13 I following [14] 10/23
expected [3] 27/4 I 13178 131/18 143/15 I 73/23 82/5 82/19 81/16 83/5 95/21 22/2 26/20 49/23 58/3
7/11 139/19 143/24 182/14 196/6 I 83/10 83/13 99/6 106/2 185/19 188/18 I 59/7 77/23 85/25
expecting [1] 99/5 [explicit [2] 23/1 27/5 I 109/11 131/25 177/22) finally [2] 30/14 105/5 111/23 191/25
experience [7] 7/24 explored [2] 15/1 failure’ [2] 67/5 67/6 I 104/16 1492/7 198/16 203/12
29/20 42/21 44/19 I 90/9 failures [19] 38/6 [finances [2] 45/10 _I follows [1] 191/9
99/21 156/24 158/1 [exPress[1] 179/11 I 68/14 69/21 70/2 45/24 font [2] 156/16
experienced [4] expressed [5] 29/21 I 70/12 73/6 74/3 74/18I financial [15] 11/25 I 156/17
188/17 1489/2 191/22 I 30/2 68/17 92/14 77/3 7718 77/12 77/14I 42/6 42/7 42/12 42/23I foot [4] 69/15 89/18
193/17 155/17 77/16 78/5 78/8 78/13) 43/9 43/22 44/3 44/7 I 102/12 119/6
experiences [1] 8/12 I@Xtended [1] 128/7 I 80/6 81/14 82/10 44/20 44/25 45/11 I force [2] 29/11
expert [96] 26/14 I@xtending [1] 141/24 Ifair [1] 51/15 50/25 77/18 77/20 101/14
26/18 26/23 27/2 27/4I extent [13] 30/6 31/8 IFalkirk [1] 4/10 financially [1] 46/5 IFord [9] 161/8
27/6 27/11 27/12 57/22 70/9 74/25 _Ifall [1] 108/5 find [14] 25/13 30/24 I 166/21 185/15 185/16)
27/14 27/22 27/23 98/11 124/11 138/25 Ifalse [34] 8/20 9/1 36/5 36/8 36/11 36/14] 188/9 191/1 191/11
28/1 28/2 28/3 28/3 I 172/13 177/15 197/24 9/8 9/12 9/19 12/5 36/21 51/11 124/3 192/12 192/20
201/15 201/16 12/12 12/22 13/7 173/22 178/1 182/7 I Ford's [1] 192/23
at en Peres extra [3] 59/17 60/18 I 13/12 14/8 14/19 182/16 191/13 Forde [1] 47/12
31/25 32/11 32/11 I 114/14 14/23 15/5 15/14 finding [1] 117/8 _I foreign [2] 47/12
32/22 32/24 33/2 39/6I extract [2] 60/4 126/6 15/21 16/5 16/15 finds [1] 57/2 48/17
33/9 33/15 33/20 34/6I extracted [7] 51/14 I 16/22 17/12 18/9 _Ifine [4] 55/11 85/5 I forensic [3] 161/1
34/24 35/20 36/21 I 85/23 89/7 89/8 89/11] 18/20 20/21 25/20 I 148/16 152/18 4169/3 169/7
37/5 37/10 37/20 I 90/15 92/23 26/1 106/21 115/16 finish [1] 148/13 I forgive [2] 28/12
38/15 38/25 39/4 4orelextracts [3] 30/12 I 116/1 116/4 116/17 firm [2] 25/7 103/7 _ I 195/2
66/12 85/21 117/5 152/23 179/9 I first [35] 12/25 19/22 Iforgotten [1] 18/18
(61) examine... - forgotten
INQ00001110
1NQ00001110
F 93/12 58/14 67/14 72/25 I 75/3 76/6 98/2 107/24] 118/25 126/4 131/3
form [6] 377 2018 I/FUso01s3856 [1] I 73/11 79/13 80/10 I 109/16 109/25 122/18] 138/15 138/19
42/23 59/2 66/13 92/9I 119/17 118/6 120/11 130/1 I 124/12 125/3 125/13 Igrasp [2] 156/6
formal [5] 40/23. IFUJ00153865 [1] 149/3 149/20 152/16 I 131/25 133/17 135/4 I 169/24
53/24 157/16 169/10 I 129/22 158/15 161/7 135/6 135/9 151/14 I grateful [2] 60/12
198/18 FUJ00153881 [2] IGareth Jenkins [1] I 153/23 153/24 155/23] 202/21
formalised [1] 139/6 I 125/23 127/17 11816 156/2 159/9 162/2 I great [1] 172/13
formality [1] 36/6 IFUI00153977 [1] IGareth’s [2] 79/11 I 185/23 191/3 192/8 I greater [1] 16/18
format [1] 62/2 164/11 79/13 200/4 200/7 201/8 I greatest [1] 133/3
formation [1] 112/7 IFUs00153990 [1] I gathering [1] 83/18 I 202/19 group [1] 112/8
formed [2] 25/14 I 166/4 gave [14] 1/19 29/9 Igives [4] 25/7 25/11 Iguess [1] 77/21
70/25 FUJ00153997 [1] I 32/18 37/2050/13 I 164/18 164/21 guidance [6] 27/6
forms [1] 9/15 167/13 50/15 51/17 52/2 I giving [7] 32/21 36/8 37/20 84/14
forward [9] 7/9 76/22/FU00154006 [1] I 63/12 108/25 138/12 I 33/21 154/3 174/20 I 86/23 94/17
FON 79/42 123/23, I 168/15 139/6 154/9 197/2 I 175/3 182/20 195/14 I Guidelines [2]
125/23 136/15 168/5 IF¥J00155721 [1] general [10] 15/18 I glad [1] 1/25 107/18 110/11
190/13 80/25 15/19 42/5 79/23 Igo [40] 10/17 39/20 I guilty [20] 9/1 10/15
forwarded [2] 24/23 IFUJ00156747 [1] 115/5 128/10 129/6 I 40/1 41/18 59/4 59/21I 12/12 14/2 16/22
$49/24 168/5 130/15 131/5 144/19 I 59/24 66/1 67/10 17/11 53/14 53/16
forwarding [1] 167/9 IFuiltsu [28] 35/7 36/8IGeneral's [1] 110/11 I 67/23 68/25 69/1 72/3I 56/16 56/18 56/21
forwards [7] 59/21 40/24 41/8 58/25 59/3I generalised [2] 75/10 76/17 78/17 57/5 63/22 101/11
coyoa By e7/i2 I 99/22 60/3 61/22 66/9) 153/18 155/8 79/1 87/8 88/22 89/17) 104/19 107/25 108/12
81/1 85/7 85/10 87/12) generally [7] 15/4 94/2 102/5 115/10 115/25 116/17 179/9
beeen fer 24s 4d 88/25 89/1 117/22 87/14 91/18 101/5 119/5 123/22 129/3 H...
46/4 160/19 177/5 140/25 141/16 167/17I 132/24 138/11 150/5 I 129/10 130/22 140/17\2"
481/17 181/21 200/23I 171/25 172/2 172/9 _Igenerated [7] 44/4 I 143/10 143/10 144/21 had [226]
four [4] 123/10 139/1 172/11 172/15 172/25] 68/10 68/22 73/21 145/14 152/12 165/14I hadn't [8] 113/18
161/3 172/3 173/15 183/17 76/1 81/12 197/3 166/6 168/5 178/3 127/12 135/11 142/7
fourth [1] 17/5 full [2] 97/16 190/7 I generic [38] 35/4 178/11 194/19 143/2 147/18 167/25
fourthly [4] 147/1 fuller [1] 42/6 58/25 121/7 121/9 goes [2] 38/16 86/6 I 169/10
framework [1] 37/25 fullness [1] 106/23 I 122/10 128/20 130/15I going [35] 24/24 half [2] 130/6 196/19
fraud [4] 42/16 45/14 fully [1] 145/5 130/24 131/18 133/9 I 26/22 29/17 39/9 Hall [6] 6/25 17/1
1400/10 145/11 function [2] 140/23 I 133/17 134/7 134/12 I 39/10 41/18 42/25 22/2 22/6 114/18
free [1] 130/5 160/6 136/20 137/10 137/19I 46/16 55/21 61/9 117/14
Friday [2] 166/2 functionally [2] 33/3 I 138/9 138/14 138/22 I 95/22 114/16 120/4 IHamilton [12] 17/1
167/14 34/15 144/11 144/22 144/24) 127/20 128/24 130/22) 22/1 22/6 25/2 25/10
front [1] 55/17 fundamental [2] 37/9} 146/4 146/14 146/17 I 139/13 145/2 150/23 I 25/20 46/25 48/2 57/7
FUJ [1] 76/13 11/2 147/10 149/10 150/7 I 155/4 159/6 159/18 I 100/4 179/8 179/16
FUJ00122203 [3] fundamentally [1] 150/12 151/17 151/22) 162/23 162/24 164/16) hand [13] 14/18
58/22 67/10 68/25 I 91/8 151/23 155/8 56/3 I 166/7 174/7 179/24 I 15/10 24/5 24/7 25/22
FUJ00122204 [1] [further [50] 2/20 6/21 158/17 158/19 158/21] 181/1 183/8 191/8 I 35/18 35/23 40/20
68/5 18/11 39/8 45/6 46/10] 180/8 192/15 192/20 198/6 I 85/18 110/2 115/7
FUJ00122210 [1] 70/7 71/25 72/8 72/15I genesis [2] 123/17 I 198/16 146/6 180/12
7213 76/21 78/3 98/3 98/20I 149/2 gone [5] 16/13 62/23 Ihandle [1] 77/16
FUJ00122217 [2] 99/13 102/4 1214/8 I gentleman [2] 132/12 151/15 160/14I hands [2] 156/7
76/12 76/14 125/4 125/5 125/19 I 173/16 184/24 good [22] 1/3 2/6 2/7 I 163/13
FUJ00122218 [1] 127/18 129/3 129/11 Igenuine [1] 77/8 17/21 26/8 38/22 43/1/happen [3] 75/9
76/24 143/19 146/23 147/18] get [12] 26/11 73/3 I 54/1963/5 111/15 I 158/6 178/6
FUJ00122229 [1] 151/3 152/20 156/23 I 113/8 124/24 127/15 I 111/18 112/23 112/23] happened [17] 53/16
85/15 157/4 157/17 158/5 I 1414/1 149/17 178/4 I 113/11 113/11 114/10] 64/19 71/10 75/8 76/9
FUJ00122230 [1] 158/8 158/9 158/24 I 185/5 189/12 192/16 I 114/13 148/20 164/23] 111/25 119/16 129/15
4/18 159/3 171/21 172/2 I 195/6 165/25 179/23 186/9 I 132/17 1356/6 141/25
FUJ00122237 [2] 175/6 177/14 188/8_Igetting [3] 21/19 IGosh [4] 140/41 157/12 180/6 184/8
818 87/25 189/24 190/6 193/8 I 192/1 192/13 got [16] 43/17 53/24 I 186/12 198/2 201/5
FUJ00124105 [2] 193/14 195/13 196/5 Igive [16] 6/108/1 I 80/25 110/17 114/10 Ihappening [2]
124/15 142/19 196/7 196/9 202/5 I 16/24 29/5 39/9 75/5 I 139/18 142/5 142/7_ I 128/13 153/21
FUso0152582 [1] _ future [1] 65/24 114/14 122/5 122/5 I 155/9 163/14 174/6_Ihappens [2] 1/22
59/25 G I 125/15 125/20 148/8 I 174/8 177/15 189/5 I 175/20
FUJ00152587 [2] > —__________I 155/19 155/25 158/5 I 190/20 202/8 happy [3] 115/20
66/5 79/1 Gaerwen [7] 59/8 159/7 Graham [5] 58/24 156/22 157/9
60/3 80/1 80/3 85/20 Igiven [42] 10/4 11/13] 60/5 67/12 67/15 72/6I hard [1] 130/22
7490152592 [1] I ggv9 90/10 12/23 17/8 30/11 36/8IGraham Ward's [1] Iharden [1] 96/2
FUJ00152616 [1] gaps [1] 198/2 36/15 41/24 45/21 67/12 hardware [1] 139/9
Gareth [16] 28/8 58/9] 52/8 54/11 54/13 57/8IGrant [6] 117/15 Harry [1] 103/4
(62) form - Harry
INQ00001110
INQ00001110
H 159/18 159/22 159/22I 204/6 34/13 34/14 34/14 193/19 194/5 197/4
has [43] 1238/4 159/24 160/1 160/7 Iher [57] 4/4 14/15 34/24 37/5 40/3 40/4 IHorizon' [1] 23/1
24/5 24/7 24/11 27/9 I 160/9 160/10 160/11 I 14/22 25/15 25/16 40/5 46/19 65/23 hour [1] 196/19
41/20 41/23 47/4 47/8) 160/13 160/18 160/21) 27/3 42/9 45/17 45/22) 67/19 69/4 69/14 house [3] 5/21 23/7
49/9 50/14 63/22 67/6I 161/25 162/20 163/5 I 45/24 45/25 46/10 70/11 70/20 70/23 103/6
68/13 73/18 73/23 163/7 164/5 164/17 I 46/13 51/8 51/12 70/24 71/10 71/17 how [36] 4/25 12/8
77/24 79/13 80/25 164/21 165/3 165/6 I 51/14 52/5 52/6 53/10I 72/1 79/17 82/6 82/12I 12/9 12/14 16/13
94/8 99/15 104/18 165/11 165/12 167/25] 53/21 53/23 54/6 54/9I 84/3 86/13 92/4 98/11] 17/19 24/15 35/2
106/20 112/1 115/20 I 169/4 169/7 169/10 I 54/10 55/17 56/13 103/9 109/15 114/1 I 35/19 39/23 45/23
118/9 120/15 126/9 I 169/12 169/17 170/10] 56/21 56/22 65/6 65/9) 114/2 123/2 133/7 48/20 49/5 53/22
1431/4 131/18 139/17 I 178/21 178/24 181/19] 65/13 65/14 65/17 133/8 133/17 133/20 I 59/18 59/19 60/19
144/18 146/1 153/9 I 1839/9 184/13 184/16 I 65/23 81/3 94/4 94/4 I 135/10 135/23 136/20) 60/21 62/1 79/25
157/12 158/15 164/13I 192/5 192/12 192/14 I 104/19 104/20 106/23] 146/17 147/23 147/24] 82/19 91/16 93/21
175/23 183/19 189/5 I 193/19 195/3 195/7 I 107/2 107/3 108/15 I 1541/6 151/17 155/17 I 1041/1 102/4 118/17
qa0/e 190/9 195/8 195/9 195/15 I 109/8 112/13 114/23 I 155/22 156/1 158/23 I 126/23 146/4 148/9
hasn't [1] 167/2 196/9 114/24 116/25 116/25I 159/8 164/6 169/18 I 160/16 162/22 162/23
have [235] he'd [4] 31/9 98/5 I 119/14 152/2 168/18 I 170/13 181/19 182/3 I 165/13 165/24 175/11
haven't [4] 39/7 153/14 184/12 170/19 170/20 170/24] 184/15 178/11
49/12 53/24 200/10 {he's [15] 1/20 68/21 I 199/14 200/5 history [3] 106/16 IHowe [1] 1/21
having [20] 3/15 85/12 86/6 125/18 —_Ihere [22] 1/21.3/13 I 106/17 151/15 however [13] 2/19
OMB 45/17 45/22 I 125/20 131/21 149/10] 20/17 69/20 73/17 holds [3] 126/13 16/18 19/20 110/22
60/22 74/18 Baio I 149/11 186/13 178/19] 7/8 83/20 101/14 I 127/4 12716 4125/2 128/1 132/4
95/24 112/13 113/22 I 189/6 192/15 192/20 I 106/3 117/18 121/8 IHolmes [6] 111/9 _ I 137/14 156/21 157/9
113/23 125/2 181/6 I 192/20 121/12 122/24 127/1 I 111/19 111/24 111/25) 161/21 181/8 181/23
451/21 182/21 160/21/head [3] 41/8 49/1 I 127/22 150/15 152/1 I 112/19 178/16 Hughie [3] 4/9 16/24
465/16 185/22 194/3 I 126/10 152/3 155/10 160/1 IHolmes' [1] 113/10 I 17/9
198/10 header [1] 150/20 I 163/16 185/10 Holroyde [1] 22/11 Ihuman [2] 103/11
he [160] 1/22 1211 [heading [1] 60/3 hers [1] 108/21 honesty [1] 155/18 I 145/10
12/5 12/10 12/15 [headings [1] 66/14 herself [3] 163/21 Honour [3] 55/17 I hundreds [2] 104/5
toed t7it t7ne__ \healthy [1] 43/9 167/5 168/16 56/14 65/10 139/22
17/19 17/20 31/4 31/9Ihear [9] 1/3 1/8 1/25 IHi[3] 67/14 72/6 Honourable [1] 4/3 Ihusband [1] 103/2
34/10 31/10 31/11 I 83/6.111/15 148/20 I 191/10 hope [4] 19/13 53/5 IHutchings [4] 106/8
31/13 31/14 31/18 I 161/19 184/4 194/1 Ihidden [1] 176/5 I 57/13 57/25 108/13 108/17 114/17
31/23 32/2 33/19 Iheard [4] 47/4 99/9 highlighted [3] 4/2 IHopefully [2] 85/3 I hypothetical [4]
33/21 33/24 33/24 I 99/14 200/10 118/25 190/9 86/14 147/14
34/5 34/10 34/13. Ihearing [9] 17/14 I highlighting [1] Horizon [96] 2/10. I
54/2 54/14 55/16 128/22 2/15 2/22 2/25 3/17
34/15 34/18 47/8 ae ladvise [1] 107/24
48/17 56/9 58/10 59/4) 99/19 56/3 56/24 64/8) highlights [1] 5/3 3/21 4/7 5/1 5/10 5/18II advise [1] 107/24
65/22 70/6 7017 I 203/11 him [56] 21/13 31/7 I 6/5 7/1 7/6 17/17 18/2I! agree [3] 52/7 62/19
70/25 71/7 73/1 74/17I heightened [4] 33/14] 31/8 31/12 31/17 32/3] 18/10 19/5 20/3 21/1 I 174/18
76/5 76/6 78/12 79/16] 34/9 34/23 36/4 34/7 36/8 38/15 62/13I 23/12 31/24 39/20 _IL also [3] 20/11 59/6
7917 83/11 B4/14Iheld [4] 24/10 88/10 I 70/6 70/7 76/4 79/16 I 47/13 47/17 52/25 I 134/1
86/6 89/7 89/10 89/16I 139/9 189/20 86/18 98/12 113/15 I 61/5 65/6 65/11 65/22II altogether [1] 97/18
92/4 96/25 97/3 97/teIHelen [1] 108/3 113/25 114/4 122/18 I 89/25 90/4 90/9 91/17I1 am [2] 26/22 46/16
97/19 97/21 97/22 Ihelp [14] 15/20 74/21] 122/21 123/2 125/13 I 92/16 92/24 93/1 _I appreciate [1] 79/6
74123 82/21 9212 94/6I 129/24 130/2 130/6 I 102/15 103/13 105/6 II ask [3] 46/14 171/7
Sere tote tot I 125/19 156/25 157/5 I 130/9 136/22 136/23 I 105/9 106/21 109/1 I 196/11
18 Tiana tarts) 105! 176/17 4138/1 151/2 181/5 I 109/2 112/1 112/6 _ILattach [2] 98/17
Fee rato 138 nelpdesk [4] 85/10 I 151/7 181/10 154/12 I 112/8 112/11 112/14 I 12616
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11/10 97/2 98/15 61/21 141/21 interrelation [1] 141/2 156/1 160/8 161/16
98/18 101/7 152/4 institute [1] 34/6 34/17 invidious [1] 179/3 I 161/20 162/6 162/11
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120/7 175/8 175/18 Iinstructed [12] 5/4 intervene [1] 177/10 I 124/4 172/21 177/9 181/14
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Jacqui [1] 4/3 job [1] 141/14 kind [4] 5/9 14/25 I 27/13 83/19 111/5 I Liaquat [1] 184/25
January [12] 149/5 IYohn [3] 47/6 96/23 I 153/25 184/6 140/14 141/3, liberty [1] 19/9
4150/6 152/14 152/15 I 97/13 kinds [1] 155/25 _Ilawyer [13] 6/15 18/6I library [1] 173/5
185/11 186/8 186/16 Ijoined [1] 173/20 I King [10] 28/16 25/17 40/19 118/5 I ife [2] 10/7 99/18
186/16 186/24 187/23 Josephine [3] 17/1 I 32/10 34/22 37/1 126/17 137/23 186/22 I ift [1] 1/19
4189/6 189/8 22/1 100/4 102/14 103/6 106/14 I 195/1 195/24 201/17 Itight [11] 11/8 39/6
Jarnail [2] 137/23 jiudge [13] 24/15 I 118/5 123/24 160/24 I 201/24 201/24 49/6 52/21 63/11 78/2
138/4 24/17 54/23 55/1 King's [1] 185/16 lawyer's [1] 167/3 101/15 133/14 133/25)
Jenkins [133] 28/9 55/17 56/14 56/24 kit [3] 186/3 186/11 Ilawyers [26] 3/22 150/10 157/14
28/17 28/25 29/2 29/8I 65/10 65/15 109/20 I 193/13 5/21 7/13 7/16 7/17 Itike [10] 94/22
30/25 32/5 33/13. 109/24 177/8 188/7 Iknew [5] 5/226/7 I 23/7 23/13 28/1 31/7 I 118/19 119/1 124/8
34/23 35/18 35/18 \iudgment [9] 9/10 I 7/24 159/18 162/25 I 32/10 34/22 35/15 I 161/8 170/18 172/4
35/23 37/2 37/4 37/101 46/25 53/25 54/11 IKnight [1] 115/19 _I 35/17 38/7 38/20 99/9I 182/17 185/9 185/20
38/3 38/10 39/1 40/20I 54/12 57/10 57/22 I know [18] 1/20 24/12I 125/13 129/14 140/21I likely [5] 23/22 24/18
65/9 159/14 34/5 72/12 73/8 95/2 I 146/23 154/7 156/5 I 24/19 103/10 148/10
bone ies ae 0/2 Julian [1] 3/14 122/16 122/23 123/14I 167/25 171/17 173/7 Ilimb [3] 64/21 64/22
62/4.62/17 67/13 IYulie [1] 112/5 158/6 162/15 176/20 I 174/14 97/15
67/24 68/18 69/4. [Juliet [2] 18/6 18/8 I 180/5 190/15 190/19 Ilay [2] 154/15 177/9 Ilimbs [1] 64/16
69/14 70/22 73/11 IYuly [1] 93/18 195/3 196/9 200/4 layers [3] 172/3 it [2] 12/17 178/41
74/14 76/17 76/18 Ijunior [1] 47/6 knowing [2] 165/21 I 172/8 172/15 tation [1] 37/14
77IG 77/24 78/2 79/3 Iiurisdiction [1] 56/15) 165/21 layperson [1] 4/21 I limitations [7] 84/8
81/3 82/5 84/3 84/12 IJury [6] 33/23 45/21 Iknowledge [11] 3/23 Ilead [3] 14/16 22/10 I 122/9 123/20 123/20
84/13 84/19 85/12 _ I 46/2 47/19 107/1 4/22 33/22 33/24 185/15 134/14 134/19 135/2
86/10 86/23 87/12 I 112/11 69/10 88/6 88/18 _Ileading [5] 14/24 _I imited [5] 6/1 15/16
88/24 89/6 92/8 93/17IJust [76] 2/12 3/11 93/24 137/21 170/13 I 35/4 108/2 110/5 107/20 119/24 181/10!
15/1 17/8 22/5 24/3 I 196/2 199/13 line [20] 42/12 43/6
(66) it's... - line
INQ00001110
1NQ00001110
L looked [24] 5/2 7/23 I 198/11 199/1 20/7 IMark [7] 161/8 137/4 138/24 151/15
iine...[18] 43/16 61/6 I 29/15 35/3 46/4 60/7 IMagistrates [6] 166/21 185/15 185/16] 153/12 156/25 157/4
67/3 67/5 68/7 70/20 I 60/22 72/11 72/21 I 53/17 56/18 63/16 I 188/9 191/1 191/10 I 157/5 161/16 1741/7
72/23 87/11 87/21 I 85/17 92/18 115/3_I 63/23 64/8 175/1 Mark Ford [4] 161/8 I 175/13 177/20 185/3
88/18 114/11 129/4 131/22 133/25 141/21IMahmood [4] 6/16 IMartin [7] 149/24 188/22 195/2
144/5 145/3 173/9 I 142/15 150/11 151/19I 6/19 7/2 46/17 168/7 168/18 168/20 Imaybe [1] 144/10
173/15 192/20 201/4 I 151/21 154/8 154/12 IMaidstone [1] 56/20 I 185/11 186/6 188/3 IMcFarlane [5] 6/18
lines [5] 96/25 98/3. I 159/5 184/20 195/20 Imail [1] 73/12 match [4] 10/24 6/24 18/6 18/8 20/19
90/13 125/5 132/21 I!ooking [22] 3/17 __Imain [4] 68/9 73/19 Imaterial [95] 18/3 __Ime [45] 1/19 1/22
link [3] 1/7 1/11 41714 I 44/19 58/6 66/6 66/7 I 81/10 150/14 19/25 22/9 25/13 27/7I 11/24 12/18 20/17
linked [1] 173/24 71/2 96/5 99/23 99/25I maintained [1] 85/7 I 27/9 27/18 30/2 30/13I 21/3 22/10 32/15
Lisa [4] 42/145/16 I 105/1 106/9121/3 I maintaining [1] 31/19 32/14 34/20 I 37/12 41/20 49/15
46/14 202/25 121/24 132/7 149/1 I 68/21 38/8 38/17 44/4 48/12) 55/1 69/19 72/12 73/8}
Lisa Brennan [1] 150/15 154/6 168/20 Imajor [1] 103/8 48/22 48/23 49/13 I 85/21 106/2 119/7
aah 177/25 189/6 190/20 Imake [34] 13/20 49/24 55/24 58/6 122/14 124/4 124/18
Lisa Brennan's [1] I 195/21 17/21 20/15 26/8 58/13 58/14 58/19 I 124/20 125/3 125/3
45/16 loop [1] 191/13 27/14 28/3 32/23 45/1I 58/20 60/22 62/3 62/8I 128/18 129/8 130/1
list [6] 98/20 12016 loosely [1] 171/25 I 46/7 63/24 64/1 64/6 I 70/21 76/6 83/8 84/10) 134/5 136/21 142/23
120/17 142/16 150/25ILrd [1] 22/11 65/2 68/2 100/8 84/17 86/20 87/3 88/7I 142/24 147/17 148/8
153/11 Lord Justice 100/14 105/12 105/25I 88/19 92/2 92/7 101/6I 149/15 164/20 165/6
listed [3] 118/20 Holroyde [1] 22/11 I 128/10 152/8 152/23 I 105/4 105/4 105/5 I 179/11 184/4 188/12
1149/3 119/22 loss [15] 19/4 25/24 I 153/3 153/10 159/3 I 105/8 105/11 107/14 I 195/9 195/18 196/18
listing [1] 34/7 25/25 26/8 100/14 I 159/14 161/22 164/14] 107/19 108/7 108/19 I 201/3 202/19 203/5
literature [3] 27/19 I 100/18 101/4 101/6 I 175/6 176/6 176/23 I 109/1 109/11 110/19 I mean [15] 24/3 55/5
30/12 31/22 1041/9 102/16 105/15 I 179/23 182/23 193/16] 117/18 132/7 132/12 I 67/7 68/19 93/8 94/20
Litigation [1] 61/22. I 126/8 127/25 128/5 I 195/16 133/10 133/15 133/19] 139/16 155/6 160/16
little [8] 66/8 69/3 17915 makes [3] 17/16 133/25 134/1 137/7 I 163/23 174/12 182/1
133/13 142/16 151/3 I!osses [12] 46/7 74/6] 143/2 143/7 137/14 138/21 139/14] 188/23 194/17 199/10}
452/19 169/24 200/12) 1093/8 103/10 103/14 Imaking [15] 4/19 140/3 140/9 140/15 Imeans [6] 9/18 11/24
live [2] 1/7 1/10 126/14 126/16 131/16] 7/15 26/10 31/10 141/19 147/18 149/1 I 16/21 94/18 130/7
lives [1] 57/15 143/16 145/18 176/5 I 105/21 106/21 115/5 I 154/2 154/4 162/21 I 143/14
living [2] 32/20 32/21) 178/22 141/9 142/21 153/12 I 163/20 165/1 165/11 Imeant [12] 7/18
loaded [1] 143/20 fost [4] 41/3 97/6 173/25 182/18 196/3 I 165/22 166/9 170/13 I 64/25 70/6 70/17
locking [2] 41/2 126/9 137/25 196/7 202/1 170/19 171/19 172/16I 74/18 75/13 78/11
137/24 lot [5] 35/21 170/4 _ Imalfunction [2] 175/13 176/7 176/14 I 83/14 92/4 99/10
tog [3] 1/7 119.4114 I 1705 179/13 179/15 I 152/10 187/11 176/17 176/23 176/25] 146/21 183/12
login [2] 1/7 1/9 If9ts [5] 92/21 92/23 Imalfunctioning [2] I 17/5 178/8 181/17__ I mechanisms [1]
logs [4] 59/13 131/13), 140/22 152/17 168/17I 152/25 185/24 187/17 193/23 197/22I 26/11
142/3 157/12 Lowther [7] 66/20 I malfunctions [3] materially [1] 83/4 Imedium [4] 20/23
long [3] 9/21 21/14 67/12 68/17 72/4 157/7 157/21 158/24 Imaterials [6] 29/25 IMedway [1] 56/18
78 73/11 76/19 79/2 Imalicious [1] 77/13 I 31/14 62/16 86/24 _I meet [5] 66/25 80/10
longer [2] 40/7 148/9 Ltd [1] 167/19 management [3] 91/22 151/21 81/3 128/8 162/23
longevity [1] 114/2 ILynette [2] 106/8 I 85/6 89/1 124/7 matter [13] 34/11 Imeeting [6] 81/5
look [61] 8/16 15/4 I 114/17 Manager [2] 75/1 59/6 70/8 70/19 162/5 162/9 162/15
17/8 17/10 35235/14/m=~«“‘s#UO!#*«*d#é« AWS 108/14 114/8 120/13 I 162/25 164/41
42/24.43/16.43/19 I I= IManagers [2] 141/5 I 123/1 157/23 159/12 Imeets [1] 20/11
52/19 65/21 aig (machine [1] 178/18 I 141/14 159/13 162/18 196/16I member [4] 34/5
58/22 59/25 66/4 made [55] 6/4 7/11 Imandatory [1] matters [9] 19/25 74/9 75/18 80/13
67/19 68/4 72/3 73/14) 2/11 17/24 22/23 175/19 30/9 31/1 32/7 40/25 Imembership [1] 34/8
81/7 84/17 85/15 24/11 26/4 32/20 manifestly [2] 104/9 I 114/7 160/20 162/1 I memorandum [1]
87/25 88/1 92/21 32/21 43/21 44/20 104/20 195/13 17/14
93/13 100/5 102/22 I 44/25 46/6 54/18 manipulated [1] 24/6 IMatthews [3] 81/2 Imemory [1] 134/3
4106/7 117/17 121/14 I 28/11,64/20 71/8 75/2 mantra [1] 42/22 93/16 94/3 memos [1] 23/16
424/15 127/17 127/22I 79/8 87/4 92/11 93/7 I manufacturer [1] may [48] 10/10 13/4 Imention [8] 80/6
429/20 129/24 1307/7 I 103/20 104/8 104/18 I 140/24 23/25 26/6 27/10 45/5I 113/8 119/20 119/21
430/19 130/24 139/14] 105/10 105/24 109/19] many [10] 1/21 97/9 I 55/19 59/15 59/21 141/20 187/25 188/6
qaolte 142/2 14/6. I 117/5.123/7 123/11 I 104/5 112/20 113/22 I 68/2 68/10 68/22 189/20
4155/7 156/9 157/20 I 131/21 148/1 157/17 I 139/20 166/20 176/20I 72/24 73/20 74/4 mentioned [8] 23/20
459/11 159/15 160/4 I 164/2 166/19 170/3 I 176/21 186/5 75/13 75/14 79/10 I 31/1 37/4 58/15 72/20
4161/2 161/5 164/11 I 12/2 173/17 176/9 I March [12] 59/1 80/9 83/11 98/25 99/4I 120/14 141/2 154/19
4166/3 166/18 168/15 I 179/19 179/20 184/13) 59/24 66/6 66/7 66/7 I 100/9 103/22 104/4 Imere [3] 9/18 38/12
17412 177122 181/4 I 190/6 192/15 193/9 I 66/22 67/11 68/5 104/6 109/14 114/13 I 53/20
4185/9 190/13 2011 I 199/14 196/1 1986/1 I 76/25 77/1 84/19 115/16 118/7 118/17 Imerely [1] 202/12
196/5 196/8 196/10 I 93/14 119/3 121/23 126/15 Imerits [4] 15/23
(67) line... - merits
INQ00001110
INQ00001110
M Moloney [6] 56/7 130/14 133/8 134/6 I 76/18 77/6 77/24 78/2IMr Smith [9] 186/9
merits... [3] 1731 56/11 65/20 183/19 I 136/9 139/5 79/3 81/3 82/5 84/3 I 186/21 187/23 188/4
121/19 197/7 183/21 204/5 Mr Atkinson [15] 2/6 I 84/12 84/13 84/19 189/5 190/25 191/11
message [2] 95/16 moment [11] 23/20 I 63/12 63/13 86/9 85/12 86/10 86/23 192/24 195/1
4127/1 42/4 69/20 75/13 106/11 111/18 148/24) 87/12 88/24 89/6 92/8) Mr Stein [3] 171/9
met [2] 65/4 107/16 75/14 82/3 131/1 150/19 171/11 183/18) 93/17 93/19 94/6 96/9I 171/10 204/4
methodology [1] 143/13 150/5 156/5 I 183/23 194/1 196/12 I 117/22 119/18 121/20IMr Stephen [1] 47/6
30/4 159/19 202/18 202/24 122/2 122/5 122/16 IMr Tatford [3] 49/9
middle [4] 87/10 Monday [4] 161/9 Mr Beer [11] 2/2 53/8] 122/25 124/2 124/12 I 49/12 99/15
might [37] 13/1 27/20 164/12 164/12 166/3 I 55/12 171/15 177/24 I 124/15 125/5 125/11 IMr Thomas [4] 18/14
29/3 30/13 35/2 35/6 IMonday's [1] 166/22 I 178/15 180/22 183/22) 126/1 126/20 128/22 I 21/10 62/6 62/8
43/7 43/11 64/3 75/5 IMoney [29] 14/14 185/1 200/11 203/6 I 129/13 130/13 131/11IMr Thomas' [7] 53/6
82/20 82/20 83/14 14/15 14/17 14/22 Mr Blakey [1] 6/18 I 132/1 132/15 133/5 I 58/2 58/8 59/10 63/9
95/16 95/20 98/9 18/12 20/1 20/25 21/7IMr Bolc [9] 124/17 I 133/18 134/18 135/4 I 66/1 66/13
103/20 104/8 104/10 I 21/8 21/19 23/11 25/5] 126/1 126/17 129/22 I 135/8 135/10 135/21 IMr Ward [20] 59/2
404/11 105/13 105/14I 25/17 25/25 26/4 135/5 135/7 142/22 I 137/16 138/25 142/21I 60/23 66/9 66/20 67/2
410/14 410/19 1114/9 I 26/11 42/22 42/25 I 143/11 1466 144/8 145/4 146/6 I 72/5 72/16 73/18 74/1
415/25 127/23 142/2 43/14 43/18 44/17 Mr Bolc's [2] 129/4 146/16 147/23 149/5 I 74/17 75/15 76/18
4143/7 156/14 159/22 I 45/17 45/23 46/9 144/1 150/13 150/16 150/24] 77/24 79/1 80/12 82/8
4165/1 175/13 178/9 I 115/17 143/19 199/6 IMr Bowyer's [1] 153/25 154/24 155/15I 82/12 82/17 82/19
182/16 182/22 200/1 I 200/16 201/5 115/23 156/12 157/3 157/20 I 83/7
mind [5] 12/21 85/13 /Moneychanger [1] _ IMr Bradshaw [8] 158/23 159/1 159/4_IMr Ward's [5] 60/16
134/1-159/8 200/8 I 47/13 135/8 186/17 187/23 I 161/3 161/13 161/25 I 68/16 73/14 76/15
minded [1] 1444 Imonies [2] 17/24 I 189/7 191/12 192/1 I 162/3 163/2 163/19 I_I 77/4
mindset [1] 12/23 I 104/1 192/13 195/5 163/24 164/13 164/25IMr Whitehouse [1]
Miners [1] 91/7 Monkseaton [2] Mr Bradshaw's [1] I 165/14 167/6 167/24 I 47/11
minimum [4] 197/1 I 112/22 113/24 190/16 168/8 168/16 169/2 _IMr Wilson [5] 4/8
minister [1] 127/10 Imonths [3] 113/20 IMr Carey [1] 57/17 I 170/10 170/20 170/23) 4/16 5/3 5/10 116/10
minor [1] 103/9 124/23 161/3 Mr Clarke [1] 107/8 I 180/24 181/15 182/2 IMr Wilson's [6] 3/16
minute [4] 166/23 Imore [41] 4/14 4/23 IMr Dunks [1] 173/17 I 182/3 183/15 3/19 4/2 4/13 4/21
Te7/1 167/23 2027/8 I 15/4 18/17 15/19 I Mr Ford [3] 191/11 Mr Jenkins’ [30] 1146/2
minutes [4] 112/13 I 24/18 24/19 33/4 192/12 192/20 38/19 40/1 68/15 70/2I Mrs [51] 6/23 6/23
148/18 196/17 196/19] 35/21 45/9 45/25 I Mr Ford's [1] 192/23 I 70/10 71/1 74/8 74/13) 8/25 12/1 12/4 13/12
mirrors [1] 147/11. I 48/14 49/16 51/18 Mr Gareth [2] 28/8 I 76/3 85/17 87/22 14/6 14/14 15/2 17/6
misappropriation [1] I 51/18 83/21 70/17 I 14913 91/20 96/3 127/19 I 20/19 22/6 22/6 25/10)
OO 72/18 73/3 76/5 77/23IMr Henry [5] 196/13 I 129/23 131/9 136/3 I 25/20 50/9 51/3 52/6
misleading [1] 95/4 I 87/14 91/17 97/9 196/14 196/21 202/16I 136/17 136/25 138/1 I 52/23 53/9 54/5 54/17
mismatch [2] 136/6 I 122/6 12415 128/7 I 204/6 138/18 147/9 147/12 I 54/19 54/24 55/6
1308/4 132/13 132/24 138/11IMr Holmes [3] 150/5 156/9 162/19 I 56/16 65/1 65/11
Misra [13] 4/9 6/23 157/13 159/25 160/14} 111/25 112/19 178/16] 167/12 181/4 181/19 I 103/2 105/7 112/5
8/25 12/1 12/4 13/12 I 184/4 177/4 17/5 __IMr Holmes’ [4] 181/22 114/22 117/12 117/14
14/14 28/9 114/17 I 179/19 182/14 182/17I 113/10 Mr John [1] 97/13 I 134/2 196/23 197/16
4134/2 136/14 137/22 I 199/28 202/8 Mr Ishaq [19] 142/18 IMr Julian [1] 3/14 I 197/21 198/13 198/19
174/4 Moreover [1] 163/19 I 151/5 151/8 151/13 IMr Kalia [1] 57/1 199/1 199/2 199/9
Misra's [2] 14/6 15/2 IMorming [12] 1/3 I 152/7 187/21 157/25 IMr Liaquat [1] 199/16 199/21 199/25
missed [1] 133/12 _ I 20 1/24 2/6 2/7 63/5] 158/4 158/9 158/25 I 184/25 200/5 200/13 200/21
missing [3] 45/17 I 149/20 166/8 166/15 I 168/3 170/3 184/9 [Mr Mahmood [1] 200/24 201/21
12812 145/19 168/7 188/5 203/8 I 184/9 185/5 186/13 I 6/19 Mrs Adedayo [6]
mistake [1] 76/12 most [5] 31/4 118/14 I 187/4 189/23 190/4IMr Moloney [6] 56/7 I 51/3 52/6 55/6 56/16
141/13 177/12 178/10IMr Ishaq's [6] 151/17I 56/11 65/20 183/19 I 65/1 197/21
ireaes 8 474/19/Move [11] 2/9 8/15 I 187/12 188/20 189/16] 183/21 204/5 Mrs Adedayo's [16]
misunderstanding I 46/16 76/11 76/22, I 193/19 194/13 Mr Page [4] 47/11 I 50/9 52/23 53/9 54/5
iy 11473 93/12 111/8 114/16 IMr Jacobs’ [1] 181/2I 47/16 47/21 48/15 I 54/17 54/19 54/24
misunderstands (1) I 117/15 125/23 174/19IMr Jenkins [126] __/Mr Patel [2] 192/18 I 65/11 196/23 198/13
108/10 moved [2] 93/14 28/17 28/25 29/2 29/8I 193/10 199/2 199/16 199/21
misunderstood [2] I 12322 30/25 32/5 33/13 Mr Pinder [6] 60/2 I 200/13 200/21 200/24
9116 1397/8 moving [2] 76/8 34/23 35/15 35/18 I 60/24 79/2 81/1 84/20IMrs Bernard [7]
mitigating [1] 23/22 I 166/1 35/23 37/2 37/4 37/10) 86/10 197/16 198/19 199/1
mitigation [4] 19/3 IMP.[4] 4/3 4/4 4/14 I 38/3 38/10 39/1 40/20/ Mr Rudkin [1] 103/2 I 199/9 199/25 200/5
Piie2 Dale DaI22 4/21 40/25 60/2 60/24 IMr Singh [7] 6/17 I 201/21
models [1] 1612 Mr [358] 61/17 61/25 62/4 6/22 8/17 8/25 11/21 IMrs Hall [2] 22/6
moderately [1] Mr Allen [4] 118/1 I 62/17 67/1367/24 I 138/7 138/12 147/14
TeS/i7 118/21 132/2 148/2 I 68/18 69/4 69/14 _—_IMr Singh's [2] 11/14 IMrs Hamilton [3]
Mr Allen's [6] 126/6 I 70/22 74/14 76/17 I 11/20 2216 25/10 25/20
(68) merits... - Mrs Hamilton
INQ00001110
1NQ00001110
M Ms Panter's [3] 3/5 7/22 8/11 33/9 I 65/15 65/18.69/8 —_I 76/9 106/4 121/12
Mrs Henderson [2] I 1205 166/7 167/4 I 34/23 34/25 37/18 I 7019 74/11 74/16 I 122/6 137/15 139/3
17/6 117/12 Ms Rudkin's [1] 42/3 59/12 59/13 __I 74/16 78/10 80/3 80/7I 149/22 153/6 155/16
Mrs Henderson's [1] I 1929 72/13 79/21 80/5 I 80/15 80/19 80/24 I 167/20 182/4 195/11
114/22 Ms Sefton [1] 144/14I 80/24 92/20 109/4 I 81/21 84/23 86/18 _Inotice [4] 176/22
Mrs Julie Ms Thomas [1] 6/24 I 111/22 126/12 127/3 I 86/20 87/2 88/3 89/20) 190/10 190/23 193/5
Wolstenholme [1] IMuch [34] 2/3 8/10 I 143/12 149/16 149/23] 91/23 94/19 101/8 I notifying [1] 192/20
12/5 10/12 13/1 24/18 I 150/4 153/12 157/17 I 102/15 103/11 105/3 Inotwithstanding [2]
Mrs McFarlane [1) I 24/19.48/16 53/6 I 158/4 159/15 160/4 I 105/5 105/8 105/9 I 13/24 199/18
pins 55/25 62/22 74/23 __I 163/6 169/25 111/21 112/18 114/12] November [5] 29/11
87/7 93/21 94/12 99/7Ineeded [26] 7/23 117/3 119/20 119/21 I 115/12 118/4 123/23
Mrs Misra [7] 6/23 I I ao4i4 114/16 147/21 I 33/11 37/24 46/9 71/8I 120/1 121/21 12/4 I 146/7
8/25 12/1 12/4 13/12
14/14 134/2 148/5 148/9 148/23 I 72/2 76/5 105/8 123/11 123/21 124/14I November 2012 [1]
Mrs Misra's [2] 14/6 156/18 156/23 162/8 I 105/10 106/4 138/8 I 126/23 128/22 133/23] 146/7
15/2 172/14 178/1 182/13 I 138/13 140/4 140/17 I 136/10 137/2 137/20 Inovo [1] 64/9
Mrs Rudkin [1] 6/23 189/18 196/11 202/19] 153/4 155/12 157/5 I 139/11 141/1 141/11 I now [42] 1/15 9/9
Mrs Rudkin's [2] 202/23 158/6 159/9 159/11 I 141/21 145/24 146/1 I 29/15 29/16 49/6
103/2 105/7 muddled [2] 160/7 I 162/19 162/20 162/21I 146/20 147/4 147/15 I 62/23 66/7 80/9 84/10)
Ms [48] 6/18 6/23 160/12 163/8 184/20 200/2 I 147/23 150/4 150/20 I 95/11 108/5 123/23
6/24 6/24 6/25 42/8 IMusa [5] 189/21 needn't [3] 50/4 58/4 I 154/5 159/2 160/8 146/4 147/17 148/6
50/19 50/21 51/8 56/4 191/4 191/15 191/18 I 161/2 163/15 166/24 167/8 I 148/7 155/9 156/4
57/2 57/19 63/10 192/4 needs [4] 72/18 76/7 I 169/9 169/24 174/1 I 162/8 164/11 167/17
64/19 64/22 66/20 IMust [9] 6/13 10/6 I 80/1 114/15 177/19 182/1 183/17 I 168/6 174/19 175/16
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ere 460/17 167/15 169/21] 187/10 190/3 200/15 200/16 100/15 118/9 118/22
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nature [11] 33/5 60/25 61/12 66/15 154/3 169/11 195/23 I objective [3] 30/17
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6/18 6/24 necessary [13] 23/9 I 37/22 37/23 40/7 not [242] 11/14 100/7 159/3
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page 1 [4] 67/23 52/19 52/22 58/3 16/17 particular [23] 15/16 Iperfect [2] 150/2
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page 113 [1] 100/6 I 60/1861/23 66/11. I 17/11 46/18 50/8 54/24 68/1I perfection [1] 152/2
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age 227 [4] 15/6 I 70/7 170/9 181/13 I paragraph 674 [1] [particulars [3] 97/2 I 61/13 85/22 86/2
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page 5 [2] 66/5 66/20I 58/3 58/12 paragraphs 113 [1] Ipast [3] 1/12 103/17 I 18/17 123/13 123/14
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4146/17 117/2 117/5 177/22 177/25 178/4 I 103/15 103/22 104/11) 110/25 private [3] 11/4 11/11
1424/7 180/18 193/16 193/22 193/25] 105/3 114/1 153/4 postmaster [6] 45/3 I 13/5
plead [4] 10/14 13/12 194/10 194/18 194/22] 160/19 169/6 170/16 I 74/21 77/17 121/23 I privy [1] 183/13
115/16 115/25 195/16 179/3 179/12 180/2 I 122/19 141/10 probably [2] 185/21
pleaded [9] 9/1 12/12 pointing [1] 167/24 I 196/2 postmaster's [2] 194/19
17/11 53/14 53/16 (Points [7] 63/11 positive [1] 180/9 I 26/7 74/5 probe [1] 199/3
56/16 86/17 63/22 I 79/16 101/15 115/5_ I positively [2] 49/3 I postmasters [1] problem [5] 7/6 8/13
109/5 166/20 168/3 195/10 I 95/3 183/24 80/8 166/16 173/1
pleading [2] 16/21 POL [4] 76/12 130/5 Ipossessed [1] 108/7 Ipotential [8] 24/14 I problems [22] 39/11
25/20 130/8 181/25 possesses [1] 102/17 104/19 116/11] 103/16 121/4 126/11
pleas [8] 8/16 9/8 POL00046579 [1] 139/15 116/17 134/6 140/8 I 128/2 129/7 173/6
10/21 10/22 15/5 102/25 possession [1] 202/9 173/23 176/3 186/2
56/21 57/5 179/9 POL00047895 [1] 133/19 potentially [10] 5/13 I 187/13 187/20 188/17}
please [123] 2/8 2/11 73/15 possibility [4] 45/18 I 5/18 52/25 72/23 188/21 188/24 189/2
3/12 15/7 16/16 24/4 IPOL00059424 [2] 77/25 164/5 180/18 I 109/18 121/7 126/23 I 190/1 191/22 192/8
38/22 46/21 49/20 144/9 180/23 possible [9] 19/5 137/8 140/10 155/23 I 193/13 193/18 195/21
52/20 83/7 58/3 58/21IPOL00059481 [1] 72/13 85/8 109/12 I power [1] 63/23 procedurally [1]
58/22 58/23 59/4 149/2 124/9 130/2 143/15 I powerful [1] 43/11 56/21
59/24 59/25 60/4 POL00059592 [1] 143/24 185/25 powers [3] 10/24 Procedure [3] 27/13
63/13 66/2 66/5 66/8 186/20 post [133] 4/54/10 I 13/20 14/4 29/10 183/1
66/19 66/23 67/1 POL00059602 [1] 5/5 13/5 14/6 14/10 I practice [3] 1/12 38/2I proceed [6] 13/6
67/10 67/11 67/15 156/10 18/6 18/7 19/17 21/4 I 107/17 14/8 18/9 115/21
67/19 67/23 68/6 69/2 POL00059652 [1] 21/18 22/23 23/2 23/3I preaching [1] 32/22 I 180/16 202/4
72/3 72/4 T2I7 72/12 188/2 25/4 25/7 25/9 25/11 I preconditions [1] proceeded [1] 9/3
73/12 73/15 75/10 POL00059675 [2] 25/18 28/7 28/14 31/7) 23/9 proceedings [5] 26/3
76/11 76/15 76/17 189/17 191/2 32/5 32/9 34/21 35/23I preparation [3] 49/25) 26/10 26/19 31/25
77/2 77/7 78/17 79/20) POL00059729 [1] 36/16 36/25 37/9 58/8 117/24 184/10
81/8 81/9 84/18 85/15I 192/25 37/22 37/23 38/1 38/6I prepare [3] 151/7 _ I proceeds [2] 44/22
87/25 88/2 88/23 POL00059808 [1] 38/20 40/24 41/7 151/11 160/22 108/12
89/18 93/12 93/13 161/5 44/23 45/24 54/3 prepared [2] 81/6 process [13] 16/13
93/15 94/2 96/18 POL00060715 [2] 54/18 54/25 55/6 57/7I 106/23 94/22 102/6 107/10
1400/4 100/5 102/22 106/10 106/13 59/3 59/22 60/23 preparing [2] 45/11 I 107/13 142/7 158/10
1403/3 103/18 105/2 POL00089077 [1] 61/10 61/21 62/4 45/13 172/21 176/10 177/3
1406/7 106/15 106/19 130/20 64/20 64/25 65/12 prerequisite [1] 177/4 185/6 191/20
411/10 111/19 117/16 POL00089380 [1] 65/19 65/21 66/11 158/11 processed [2] 59/19
417/18 117/19 118/2 129/21 66/13 69/24 72/14 presence [1] 161/21 I 60/20
118/24 119/8 119/16 POL00089394 [1] 77/18 78/6 82/9 83/19] present [3] 1/11 94/7 I processes [2] 128/5
119/17 120/2 124/3 143/10 85/4 86/13 86/14 89/4) 130/9 179/21
124/15 125/24 127/17) POL00089427 [1] 89/9 96/2 100/9 presented [5] 48/19 I produce [1] 79/17
127/19 129/3 129/20 152/14 102/10 102/14 102/19) 54/24 77/15 85/1 produced [10] 43/10
129/23 130/19 142/23IPOL00097138 [1] 102/24 103/7 103/17 I 143/3 70/25 73/5 79/15
144/21 144/23 145/3 17/19 103/18 103/24 104/13) presently [1] 110/13 I 79/15 86/5 90/25
4145/17 149/1 149/4, IPOLO0119433 [1] I 104/25 106/9 107/19 Ipreserving [1] 65/23 I 112/17 124/23 124/25
tage 149/19 15011 I 1812 110/7 110/25 117/4 Ipresided [1] 54/14 I produces [1] 89/15
152/18 163/3 13/8 IPOL00119445 [1] I 117/21 119/24 121/18I pressing [1] 82/17 I producing [3] 66/12
teo/9 tous tere, I 185/10 4122/1 122/16 122/24 Ipressure [2] 16/21 I 79/22 164/6
Teant soca reer /POLOO121224 [1] I 128/15 128/17 12919 I 25/10 product [2] 34/18
166/6 166/12 166/18 I 505 129/13 129/17 132/4 I presumably [3] 34/19
Toyo ter tyne [POLO0122217 [1] I 132/9 132/10 132/17 I 53/16 94/23 186/3 _I professional [3]
468/18 190/23 184/5, I 7611 135/13 135/20 135/25Ipresume [1] 125/21 I 29/19 33/19 34/3
tee? 189119 19018 (Police [4] 42/17 91/5 I 137/16 137/22 139/6 Ipretty [1] 94/12 I professionally [1]
toot0 tonrn4 191/13) 112/20 113/22 139/10 141/15 141/16I prevented [2] 24/21 I 97/22
policy [1] 38/1 446/12 146/22 150/12I 24/22 proffered [2] 20/13
(72) plea... - proffered
INQ00001110
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P prosecutions [4] 113/7 185/1 198/12 199/13 [reading [4] 21/3 90/3
proffered...[q]_ I 20/5 71/22 103/17 [purely [3] 50/14 199/13 201/25 202/17I 120/18 149/13
499/14 - 140/6 53/13 77/22 quickly [1] 86/9 reads [3] 189/23
programme [2] 94/22! prosecutor [30] 11/7 Ipurpose [5] 107/9 I quite [15] 28/5 43/1 I 191/8 193/2
94/23 14/1 26/18 27/19 29/4I 107/13 122/13 122/15] 45/7 52/5 62/2 79/16 Ireal [4] 21/15 53/22
proliferated [1] 2/15 29/15 32/23 33/4 193/15 122/8 130/22 147/7 134/20 135/18
proof [2] 194/4 194/9 34/16 34/19 35/19 purposes [2] 97/21 I 154/5 163/15 163/22 Irealistic [6] 12/2
roper [12] 13/25 36/20 38/11 39/3 43/2) 177/6 165/24 177/4 191/8 12/11 43/25 44/8
MOpeie rai? I 44/5 64/15 69/25 78/7I pursuant [2] 17/15 Iquote [2] 117/9 101/24 164/4
78/11 97/5 98/24 95/12 99/1 101/21 187/22 164/22 reality [1] 114/8
405/10 105/13 105/17! 129/1 135/21 136/1 I pursue [3] 130/10 R really [10] 74/2 77/5
126/18 147/2 139/13 139/19 140/1 I 132/21 201/4 Ro 2/15 94/13 119/23
properly [24] 33/6 144/4 165/13 pursued [4] 10/13 IRachael [5] 118/3 4127/7 127/7 156/20
37/10 52/10 69/11 prosecutor's [1] 17/13 41/8 97/1 118/4 124/21 149/7 I 183/10 198/1
70371119 78/14 I 1/14 pursuing [1] 26/10 I 152/16 reappear [1] 81/18
78/23 88/8 88/9 88/20 prosecutorial [1] pursuit [2] 11/9 raise [3] 16/8 46/22 Ireason [17] 69/8
90/9 97/16 105/18 170/2 114/11 114/9 69/22 73/23 75/3 77/3
1409/2 123/14 151/12 [Prosecutors [6] put [16] 9/13 9/25 raised [24] 2/15 3/15 I 81/21 88/3 89/20
454/17 1855/5 186/7_ I 28/1428/19 38/9 I 40/14 49/6 57/14 _I 5/8 6/25 7/2 19/25 I 105/12 105/17 105/20
469/25 200/22 201/10] 50/11 141/22 175/4 I 60/11 72/13 79/5 98/2I 72/9 77/25 89/4 112/6) 105/21 105/25 114/6
201/12 prospect [7] 12/2 103/22 104/10 136/18] 112/13 114/4 116/19 I 126/22 128/5 176/16
proportionate [1] 12/11 20/23 43/25 141/12 162/22 188/1 I 116/23 120/16 129/24) reasonable [12] 14/5
11/10 44/8 98/7 101/25 194/9 132/2 146/18 154/12 I 19/9 21/3 42/12 43/6
propose [2] 120/19 prospects [1] 19/24 Iputting [8] 14/19 157/25 158/25 160/8 I 43/15 98/7 114/11
4192/6 protecting [1] 21/19 I 21/2 24/23 82/23 168/3 185/4 132/21 144/5 162/7
proposed [4] 11/8 [Protection [1] 20/2 I 84/11 126/24 128/18 Iraises [2] 43/14 201/4
29/5 75/2 78/4 prove [9] 43/3 44/14 I 190/23 102/9 reasonably [2] 83/14
proposing [2] 75/4 97/20 100/13 101/4 (ne raising [3] 102/6 98/4
122/5 186/9 193/25 194/18 . . 114/14 118/14 reasoned [2] 6/10
prosecute [7] 5/5 195/17 qualification [1] range [3] 30/8 30/10 I 139/7
11/5 52/17 97117 [Proved [1] 97/10 I 71/14 31/18 reasoning [2] 13/8
98/24 99/22 101/21 provide [15] 27/1 qualifications [2] rapid [1] 6/20 15/1
27/5 29/4 30/16 37/1 I 29/19 31/5 rather [48] 12/19 reasons [12] 30/10
prosecuted [6] 57 I 3714 43/25 78/10 qualified (1] 40/4 I 19/23 21/20 26/24 I 54/5 68/9 68/21 73/19
176/20 183/24 131/2 144/16 151/22 Iquashed [6] 53/10 I 26/1 34/2 35/7 36/16 I 73/20 81/10 83/7
, 154/25 155/10 182/2 I 53/23 53/24 54/6 45/12 46/12 56/11 I 89/16 92/15 106/5
prosecuting [11]
183/7 54/17 56/22 61/3 76/7 76/12 90/13] 164/8
snacamvome® provided [29] 3/9 queried [2] 12/24 90/16 91/11 91/14 reassurance [1]
116/22 139/22 176/24] 30/1 31/14 62/4 85/19 152/22 94/5 97/11 102/20 87/17
185/16 85/21 87/16 96/23 question [20] 5/9 105/20 110/1 116/11 Irebut [4] 133/5
; 107/17 120/6 120/13 I 16/8 21/15 40/13 67/9I 119/24 120/6 121/13 Irecall [5] 34/7 59/15
Prosecution [61] or? I 120/16 121/1 12813 I 86/8 97/25 108/18 I 127/1 127/11 1328 Bare BAT 8620
fo/at torts THA 1817) sag 1a6l16 147/1 I 120/8 122/3 132/16 I 136/5 196/2 159/15 _Irecap [2] 26/16 26122
ae ee eag I 18105 154/1 154/1 I 139/5 133/20 140/9 I 160/7 162/12 168/25 Ireceipts [2] 136/5
ae eaten] 184/21 16019 165/4 I 140/10 17372 194/21 I 16913 1744 174/15. I 13813
ae Sere woke worn I 168/1 169/10 169/12 I 195/2 195/22 199/3 I 179/19 181/9 181/24 I receive [1] 19/10
Fe eens ysr7I 170/20 170124 19713 Iquestionable [3] I 182/17 182/19 182/24I received [3] 12/4
provides [4] 86/1 52/16 201/13 202/4 191/7 198/14 201/25 I 29/24 191/15
role aorie tung 131/5 144/19 178/3 Iquestioned [10] 2/5 Irationale [2] 53/22 I receiving [1] 31/6
1406/18 107/21 108/5 providing [6] 18/9 131/4 144/18 171/10 I 161/15 recent [1] 60/5
1408/20 109/13 109/22! 44/10 66/20 122/1 183/21 196/21 204/3 Ire [2] 66/24 120/8 recognise [6] 20/7
4140/3 111/23 113/1 152/3 183/10 204/4 204/5 204/6 re-pose [1] 120/8 20/11 108/16 109/12
115/14 116/8 118/1_ [Proving [3] 44/21 questions [41] 19/6 Ireach [3] 44/9 47/19 I 140/4 140/13
434/22 139/24 141/24! 194/3 194/21 26/22 27/4 27/11 170/20 recognised [7] 5/13
provision [8] 26/25 I 29/24 31/9 41/20 51/7Ireached [6] 5/8 11/21I 5/17 18/23 32/2 78/3
ite Rene toed 36/17 60/9 122/12 I 51/1451/16 51/18 I 12/15 19/19 116/15 I 140/2 165/12
477/16 177/18 187/17] 137/18 138/3 158/18 I 63/11 68/17 94/10 I 126/10 recognising [1]
487/18 193/22 193/25) 175/17 94/15 94/25 95/12 Iread [19] 1/1551/2 I 35/10
jou/9 194/18 194/17, [Public [20] 9/22 10/6 I 95/14 95/19 101/17 I 61/9 62/1 76/3 90/6 I recognition [6] 12/20)
4195/4 195/17 410/11 10/17 11/6 13/3] 117/21 123/10 136/19I 98/4 108/23 119/12 I 16/6 25/16 70/10
prosecution's [4) I 13/4,18/22 19/24 2019) 139/1 139/3 148/10 I 129/3 125/2 190/22 I 7e/12 141/11
MBDA T3TTID toning I 212342117 44/11 I 148/14 154/13 160/2 I 136/17 148/3 149/22 I recommended [1]
180/14 54/8 57/12 64/20 165/2171/6 171/8 I 150/4 153/9 185/21 I 9/2
400/20 102/2 113/3 I 171/15 177/23 183/19] 191/7 reconcile [1] 152/24
(73) proffered... - reconcile
INQ00001110
INQ00001110
R 131/6 144/20 145/25 Iremained [4] 71/6 153/13 158/12 163/7 Irespects [3] 40/9
reconciliation [1] I 167/19 172/2 181/15 I 71/13 7/1 186/4 163/10 164/3 164/7 I 52/7 52/14
77/20 regards [1] 190/5 remaining [3] 11/9 164/9 165/4 165/8 respond [5] 162/1
reconvene [1] rehearing [3] 64/10 I 119/2 197/10 168/8 168/14 168/18 I 163/6 165/15 176/24
202/25 64/13 64/15 remains [3] 10/16 168/23 169/4 170/7 I 177/19
record [3] 41/3 81/4 reject [1] 107/2 68/15 77/3 181/20 181/22 183/8 Iresponds [1] 177/19
4145/7 rejected [1] 133/9 remarkable [1] 198/1 198/10 201/21 Iresponse [9] 78/4
recorded [7] 83/3 _ {election [1] 144/1 I 165/17 report/statement [1] I 116/2 120/11 129/18
85/7 112/19 115/23 IFelate [4] 59/8 93/5 Iremember [7] 49/2 I 181/22 150/16 164/7 167/12
1438/2 138/20 162/24 93/10 178/15 69/3 79/9 91/3 91/6 Ireported [6] 18/14 167/23 190/13
Recorder [1] 54/13 related [4] 90/3 90/16I 94/13 201/20 113/18 115/14 187/13I responses [1]
recording [5] 1/14 93/4 149/18 reminded [1] 33/11 I 190/2 190/17 156/18
56/10 83/10 139/7 relates [6] 59/16 reminding [1] 203/5 Ireported' [1] 188/22 Iresponsibilities [2]
439/25 143/13 156/23 175/11I removal [6] 70/1 reporting [1] 85/8 135/22 135/24
records [9] 23/23 175/16 176/14 71/11 78/7 143/13 reports [9] 31/23 responsibility [1]
25/23 42/12 69/13 relating [8] 30/3 145/22 192/7 31/25 41/14 41/25 27/25
89/6 128/23 144/2 52/24 66/13 90/4 remove [1] 70/8 117/25 141/3 143/18 Iresponsible [4] 5/19
1473/10 173/14 109/1 128/11 133/8 Iremoved [5] 40/10 162/18 164/7 23/25 135/13 135/18
recover [1] 128/2 143/3 70/9 71/3 75/15 78/20I represent [4] 171/12 Iresponsive [1] 123/9
recovery [4] 20/1 relation [44] 6/5 8/17 Iremoving [1] 40/3 181/9 181/24 183/23 Irest [1] 73/20
20/25 21/7 44/22 16/3 22/5 29/8 31/24 Irender [3] 103/20 representatives [2] restitution [1] 104/1
reduce [1] 161/17 33/2 38/24 46/14 104/8 104/19 148/11 148/14 restored [1] 1/14
refer [3] 129/9 136/3 47/11 49/8 49/10 repaid’ [1] 18/12 represented [3] restricted [1] 84/4
149/9 69/21 74/8 75/11 repayment [8] 17/24 I 134/20 137/7 146/16 Iresult [7] 24/16 53/1
75/21 80/4 83/20 I 25/8 25/12 114/24 Irepresents [1] 1/21 I 81/5 142/7 145/10
oreo 3) ae I 92/15 105/7 109/17 I 116/18 116/23 117/1 reputation [3] 20/2 I 156/20 169/1
121/9 121/12 134/13 I 117/6 21/20 23/11 resulted [3] 40/6
24 50/8 58/13 carro] 134/14 134/21 136/1 Irepayments [1] 46/7 Irequest [16] 40/23 I 131/15 19815
Ae Ty Coed eayI 140/3 142/24 148/1 repeal [1] 90/22 I 61/3.61/21 71/1 71/10Iresults [5] 64/8 85/1
OTe Oe eee) 15114 151/13 153/20 Irepeat [1] 139/20 I 94/6. 991099112 _ I 173/8 195/9 195/14
153/22 157/6 158/3 Irephrase [1] 39/15 I 99/16 119/11 128/17 Iretained [3] 87/4
Shion aan 160/3 171/2 174/20 Ireplaced [1] 74/1 129/10 166/24 167/23] 102/14 140/11
176/18 178/7 179/21 Ireplies [3] 72/16 177/1 192/4 retaining [2] 19/8
Meee too wee 181/3 183/2 119/18 124/16 requested [1] 128/15) 139/23
184/13 186/12 191/4 Irelatively [2] 50/23 Ireply [15] 67/2 67/15 Irequests [3] 119/24 Iretention [1] 86/24
191/6 198/9 154/22 67/23 77/6 86/17 94/3] 128/22 170/17 retrial [3] 47/21
referenced [1] 58/14 IFelease [1] 176/25 I 94/5 127/18 127/20 Irequire [2] 59/6 47/23 64/11
references [3] 70/1 relevance [3] 4/1 129/4 143/11 155/13 I 190/11 retrieval [2] 129/10
173/13 191/17 95/8 134/6 166/7 167/13 192/23 Irequired [20] 24/20 I 130/4
referral [1] 50/1 relevant [24] 23/21 Ireport [102] 2/12 3/3 I 25/4 26/8 28/6 50/17 Iretrieve [3] 128/6
referred [13] 4/6 82/5I 26/20 27/10 29/21 3/11 6/13 7/12 8/23 I 66/11 83/2 93/23 128/11 130/2
87/1 89/24 123/1 30/12 56/1 60/15 12/16 15/7 17/9 22/13) 98/20 102/21 124/22 I return [3] 25/9 63/9
133/20 138/13 150/7 I 73/16 90/10 100/18 I 29/13 30/9 30/20 31/2I 129/1 133/22 137/1 I 148/7
4165/8 165/9 166/5 101/9 101/18 101/23 I 32/11 37/17 42/2 45/2I 154/13 156/25 157/4 Ireturned [1] 115/2
180/22 184/24 102/1 108/8 113/9 46/20 49/21 49/25 161/18 161/22 178/23] returns [1] 43/10
referring [10] 4/10 113/14 133/19 140/9 I 50/1 51/13 52/5 52/19I requirement [5] 33/7 Ireveal [1] 83/10
10/1 22/14 41/1 48/6 I 140/10 154/2 170/13 I 58/4 58/7 62/11 84/1 I 33/16 99/17 101/4 revealed [3] 25/24
87/21 88/20 91/17 I 175/13 17/1 87/9 91/9 96/19 100/6I 101/12 83/23 138/25
136/12 192/4 reliability [12] 19/6 I 100/8 100/15 102/11 Irequirements [5] _Ireversals [1] 152/8
refers [3] 88/24 52/23 61/4 114/4 106/11 107/15 108/3 I 37/3 40/8 66/25 79/8 Ireverse [1] 175/5
90/14 18419 118/8 133/6 136/19 I 108/3 111/21 112/19 I 79/9 revert [1] 163/25
reflect [3] 11/20 140/7 140/11 170/14 I 113/16 114/19 114/21Irequiring [1] 156/23 Ireview [23] 10/6
15/24 86/21 178/9 201/22 118/8 118/19 119/1 Irerouted [1] 61/24 I 18/15 19/18 19/21
reflected [6] 12/9 I‘ellable [1] 2018 I 119/7 119/9 119/13 reserved [1] 107/12 I 19/23 20/8 20/9 48/4
14/13 38/1 24/12 IFeliance [2] 27/9 119/19 119/21 120/12Iresiled [1] 103/15 I 48/21 49/5 54/20 55/9
410/10 158/19 133/4 120/14 123/2 124/9 Iresolve [2] 132/16 I 63/20 87/13 97/4
reflecting [1] 14/19 Ifellant [1] 170/23 I 124/23 129/23 131/5 I 17/9 102/13 104/5 105/6
refusing [1] 195/15 relied [5] 2/25 80/23 I 131/24 132/13 133/1 Iresolved [1] 52/18 107/9 107/10 108/24
regard [5] 4/25 50/12 133/18 170/19 193/22I 134/12 134/24 134/25I resolving [2] 65/10 I 115/23 135/9
113/14 151/24 185/24I"ely [2] 26/18 121/11 I 136/2 136/4 136/17 I 172/9 reviewed [8] 3/9
regarding [14] 60/9 relying [3] 31/15 137/7 138/4 141/4 resonate [1] 7/19 27/21 95/24 105/5
67/16 72/8 85/20 8g/4I 134/22 140/4 144/19 145/23 147/8 Iresources [1] 11/11 I 140/12 147/12 147/19)
89/8 128/9 129/6 remain [5] 7/12 50/5 I 147/24 150/2 150/3_ Irespect [5] 9/3 33/13 I 164/5
50/8 73/22 78/20 151/7 151/11 152/21 I 59/7 88/8 193/23 reviewing [4] 3/22
(74) reconciliation - reviewing
INQ00001110
INQ00001110
R 25/3 26/17 42/11 145/5 149/11 151/9 I Section 69 [3] 90/23 I 165/16 165/22 165/24!
reviewing... 3] 43/13 48/2 49/8 50/14) 155/9 155/11 159/17 I 91/4 91/10 169/4 169/14 173/7
186/22 195/1 195/24 I 52/3 52/4 52/9 52/21 I 162/16 167/9 173/21 ISection 7 [1] 83/12 I 180/25 191/18 197/14
revised [2] 50/1 54/25 56/14 62/8 176/13 177/19 178/19I Section 8 [2] 176/10 I 197/23 200/10
67/25 65/20 69/4 69/14 180/13 180/14 184/16) 177/15 Sefton [14] 28/9
74/16 75/22 76/12 189/12 190/14 192/12Isector [1] 42/17 124/1 124/5 125/8
rewritten [1] 38/19
thetorical [1] 195/2 76/23 82/24 97/21 192/19 194/7 195/19 Isee [105] 1/3 1/8 6/9 I 125/10 142/10 142/20,
RICHARD [2] 2/4 98/8 99/15 101/19 says [22] 56/8 57/17 I 7/3 16/13 28/19 28/23I 142/24 143/4 143/17
204/2 107/2 111/25 113/18 I 57/21 59/5 85/12 29/2 32/4 32/9 40/18 I 144/14 144/17 146/8
right [50] 3/1 4/3 113/20 114/12 116/3 I 87/11 89/10 93/19 40/23 41/4 41/7 43/16] 147/10
13/14 13/18 32/25 116/9 122/20 125/15 I 107/8 118/25 120/5 I 48/10 49/2 50/20 56/3I selected [3] 16/1
36/25 39/2 53/15 129/17 136/24 147/13] 1314/1 131/11 145/4 I 58/23 60/1 60/4 60/15) 61/10 61/14
53/19 55/3 55/4 56/17I 1939/1 159/10 159/24 I 156/13 181/7 181/23 I 61/7 63/6 65/9 66/9 I selections [1] 173/18
58/18 59/11 62/3 62/7I 190/14 165/21 165/23I 185/22 189/8 192/5 I 66/10 66/16 66/20 I send [5] 60/12 119/8
62/15 63/18 64/24 178/17 179/13 179/14] 193/11 193/13 66/23 67/15 68/6 119/12 129/8 153/16
65/8 73/3 81/15 98/10) 188/18 192/1 199/17 Iscale [1] 20/4 71/11 72/7 73/9 73/12I sending [5] 67/24
1401/8 101/13 105/24 I 199/22 200/5 200/12 Iscanned [1] 124/25 I 73/24 75/10 76/15 141/4 150/24 151/2
110/18 121/21 123/19ISame [19] 1/22 6/15 Iscant [1] 154/22 76/23 77/2 77/4 77/5 I 168/7
1431/21 137/4 137/20 I 7/1 8/10 9/20 17/6 scenario [2] 126/12 I 78/18 81/9 81/19 sense [10] 7/21
137/21 139/14 142/14I 21/24 48/4 53/2 72/15] 126/24 86/22 87/10 88/23 14/13 25/25 35/3
148/16 154/7 159/2. I 73/22 80/1 120/8 scene [2] 197/17 90/18 93/18 94/3 38/21 49/4 101/22
163/23 170/25 171/1 I 139/17 148/1 167/14 I 198/18 94/12 98/25 99/25 123/11 174/15 198/11
1741/5 173/3 175/10 I 174/5 186/4 191/3 schedule [3] 83/4 102/4 103/1 111/15 Isensible [1] 188/25
178/5 178/13 184/16 ISatisfied [4] 11/7 83/11 138/20 118/3 118/21 119/16 Isent [7] 56/19 76/16
191/19 196/2 202/14 I 44/6 44/10 64/23 scheme [1] 62/18 121/12 121/16 121/24I 76/25 119/20 126/7
rightly [4] 79/16 satisfy [3] 26/23 screen [2] 2/13 181/1I 122/24 127/19 129/21) 168/16 192/24
105/24 165/11 201/7 I 27/18 97/15 scripts [1] 172/5 129/23 130/3 131/13 Isentence [20] 19/2
rise [8] 39/9 108/25 ISave [2] 65/18 120/9 Iscroll [46] 22/17 140/20 144/15 144/24] 19/14 23/18 24/20
125/15 154/9 155/19 ISaw [20] 3/10 6/1 58/23 59/4 60/1 66/8 I 145/3 148/20 150/1 I 52/20 53/18 56/20
155/25 196/15 197/2 I 13/8 13/15 20/18 66/19 68/5 69/3 73/15] 162/20 163/8 164/9 I 104/9 104/12 104/20
risk [3] 155/11 22/10 23/6 23/15 77/2 78/17 79/19 81/8I 164/12 164/17 165/12] 105/16 109/18 109/20}
199/16 199/21 23/16 32/14 38/2 81/20 84/18 86/4 166/5 16/7 166/10 I 181/7 182/7 182/10
risky [1] 155/1 48/14 49/14 55/15 I 88/23 93/15 94/2 94/4) 166/12 167/13 168/5 I 182/12 182/16 183/5
62/3 88/16 120/3 103/2 106/15 118/2 I 168/23 173/19 181/2 I 190/1
role [8] 4/16 33/5
38/25 181/8 181/23 I 123/10 172/16 199/7 I 118/3 118/24 119/17 I 181/3 181/6 182/13 Isentences [2] 57/13
182/3 182/15 183/3_ [Say [67] 1/18 2/13 125/24 125/25 130/25I 186/8 186/24 187/2 I 135/17
rolled [2] 145/19 3/14 3/25 4/11 8/17 I 131/1 131/7 144/14 I 187/14 187/16 188/2 Isentencing [2] 10/24
t78/24 8/24.11/15 11/16 I 144/23 145/17 149/4 I 189/21 195/20 195/22) 100/22
room [2] 134/8 11/19 15/8 16/17 I 149/19 149/25 150/18] 203/8 separate [6] 26/6
Toate 17/10 17/22 18/13 _I 151/3 152/15 152/19 Iseeing [1] 195/5 _I 54/14 59/6 86/5 97/25
Rose [1] 108/3 18/17 22/17 23/2 24/3I 153/7 161/6 166/4 Iseek [3] 54/8 96/2 I 173/2
round [2] 49/7 32/17 35/21 38/15 I 167/22 189/19 107/4 September [7] 17/12
174/19 38/16 38/23 39/4 39/8I second [33] 2/12 _Iseeking [7] 125/11 I 112/3 136/4 136/18
route [1] 14/23 41/21 41/25 49/3 I 7/12 18/14 19/18 47/2I 125/17 126/15 164/25] 137/7 160/24 187/10
routed [1] 6023 I 49/13.49/13 58/12 I 47/8 47/15 47/23 48/4) 17516 182/25 189/9 I September 2006 [1]
routinet] 2/24 69/5 97/4 98/17 99/3 I 48/20 49/1 49/16 ISeema [3] 4/9 114/17] 17/12
Rs [1] 1403 100/8 102/12 108/10 I 66/10 66/16 67/3 I 1741/4 September 2010 [2]
Rudkin [3] 6/23 109/4 109/7 114/23 I 67/19 72/7 72/10 Iseemed [4] 21/3 _I 136/18 137/7
1400/3 103/2 115/11 115/22 116/14] 76/16 88/24 91/9 94/4) 136/21 179/22 201/3 I September 2012 [2]
Rudkin’s [3] 102/9 I 120/23 125/18 133/2 I 103/19 107/18 108/2 Iseems [3] 74/3 160/24 187/10
4103/2 105;7 134/25 136/15 141/19I 108/24 115/13 129/3 I 161/12 167/3 series [4] 6/20 96/5
Rule [2] 29/11 55123 I 144/1 147/9 158/13 I 134/25 136/16 186/23Iseen [50] 3/4 18/3 I 117/20 14016
Futes [4] 27/14 2o/11 I 161/12 163/13 163/14] 188/11 189/23 20/1 31/23 34/20 _I serious [5] 4/25 6/2
62/8 183/1 170/8 17216 179/19 ISecond Sight [1] I 35/21 36/2 36/3 37/20I 6/8 39/23 170/12
run [4] 82/3 147/14 I 83/3 184/5 190115 I 107/18 38/17 39/7 49/24 I seriously [2] 114/3
169/23 17219 190/23 197/22 200/23I secondary [1] 48/10 I 50/13 70/4 84/10 I 114/7
Ar I 2017 secondly [3] 1/18 I 91/22 92/7 95/25 _I seriousness [1]
s saying [41] 7/4 7/5 I 133/17 146/16 96/13. 98/13 98/16 I 10/25
sack [1] 1410 I 38/21 39/9 48/24 ——_I section [9] 39/6 57/3 I 98/16 118/11 125/22 Iserve [5] 118/19
safeguards [1] 129/7I 59/25 67/25 76/20 I 83/12 90/23. 91/4 I 132/13 139/10 133/22] 119/1 119/7 120/19
safety [3] 63/20 79/3 84/20 86/13 I 91/10 176/10 177/15 I 134/2 136/24 137/2 I 124/9
110/34 110/20 86/18 92/18 93/1 177/20 137/15 138/17 139/5 Iserved [14] 30/25
said [55] 12/10 1/8 I 94/21111/4 11918 [Section 14.2.4 [1] I 141/19 146/4 147/18 I 57/13 7117 71124 72/1
124/17 132/15 138/1 I 57/3 154/9 157/1 165/6 I 115/13 118/9 134/12
(75) reviewing... - served
INQ00001110
INQ00001110
Ss shortfalls [3] 113/19 ISingh [9] 6/17 6/22 I 127/20 128/4 128/8 I 39/16 141/24 177/8
served... [6] 147/11 176/5 184/12 8/17 8/25 11/21 128/22 129/12 131/18] 179/4
152/21 158/15 166/14 shortly [1] 21/24 137/23 138/4 138/7 I 132/14 137/13 141/11/soon [1] 72/13
186/18 187/16 should [51] 2/17 4/14) 138/12 142/1 143/19 145/20 I sorry [10] 55/12 69/1
service [10] 36/16 6/3 7/7 18/12 18/18 I Singh's [2] 11/14 148/15 149/17 150/22I 114/20 119/5 122/24
85/10 112/20 113/22 22/5 32/6 32/12 35/21I 11/20 150/24 151/9 153/13 I 150/18 152/19 191/3
1414/2 158/16 158/19 54/6 57/19 58/23 60/1Isingle [1] 68/7 157/23 159/1 159/9 I 194/2 196/16
1466/25 177/11 189/24] 70/21 70/23 70/24 sir [21] 1/3 2/3 53/19 I 159/11 159/24 161/17/sort [5] 42/18 67/6
set [19] 27/8 30/25 74/24 75/6 75/9 76/1 I 55/3 57/25 62/23 63/5) 161/22 162/16 162/18) 68/13 68/22 85/3
31/4 31/9 31/11 31/13) 87/3 93/7 97/1 97/21 I 111/8 111/15 148/6 I 162/24 163/2 164/10 I sorted [1] 128/3
31/20 32/1 33/11 103/16 104/18 108/18] 148/12 148/20 148/23I 164/23 164/25 167/2 Isorts [1] 179/6
56/21 57/5 57/7 66/10I 1097/6 112/23 113/2 I 183/20 196/13 196/22) 168/12 169/1 173/3 I sought [9] 27/3 29/25
86/2 106/15 136/23 I 119/21 119/23 124/19I 200/19 202/22 202/23) 174/6 175/5 175/10 I 84/13 127/14 136/20
125/25 127/11 128/14] 202/25 203/7 177/17 179/2 179/8 I 138/9 138/15 146/21
ete (2) 108118 1251 129/21 138/23 140/1 Isit [2] 1/13 20/6 180/12 181/1 181/2 I 150/12
setting [6] 11/22 27/3) 146/14 148/3 154/6 sits [1] 85/17 184/5 184/20 185/9 Isound [1] 38/22
90/23 62/8 151/8 154/8 159/17 161/12 Isituated [1] 188/14 I 186/8 186/16 186/20 Isources [3] 31/15
183/11 161/25 164/9 175/12 Isituation [3] 176/21 I 187/16 187/24 189/5 I 48/9 48/10
settled [1] 112/6 175/12 183/3 182/22 201/15 189/19 190/8 190/14 ISouthwark [3] 53/10
seven [2] 112/22 [Shouldn't [3] 75/8 Isix [2] 112/22 113/23) 190/23 191/11 191/16) 53/25 55/16
113/24 128/4 135/9 size [1] 121/22 191/25 192/12 194/2 Ispacing [1] 68/8
seven years [1] show [5] 44/17 Skip [1] 128/14 195/24 196/16 199/9 Ispeak [3] 49/14
112/25 105/14 135/6 143/18 Iskipped [2] 100/4 I 201/2 201/3 201/9 I 113/6 150/19
shadow [1] 57/15 I 185/3 145/13 201/11 speaking [3] 34/13
shall [1] 76/23 showed [3] 89/12 _Iskipping [1] 126/5 I software [3] 33/25 I 182/19 182/23
Shapes [1] 118/18 I 138/11 195/10 slightly [2] 79/6 34/1 139/9 speaks [2] 41/15
share [1] 152/2 showing [1] 113/19 I 180/1 sole [1] 47/7 56/6
Sharing [1] a/12 [Shown [4] 15/7 18/1 Ismall [5] 7/12 7/16 Isolicitor {7] 115/15 I special [2] 95/8
she [55] 4/6 12/12 I 194/13 196/9 7/17 8/3 8/10 120/20 123/24 126/3 I 119/9
ia/16 20/22 25/16 Shows [4] 129/13 ISmith [15] 4/3 168/19 186/21 188/12I species [2] 9/16 10/2
45/18. 6/1 dole aols I 83/9 18/4 191/16 I 149/24 168/7 168/18 Isolicitors [7] 166/13 Ispecific [19] 44/2
eB 46/9 50/13 50/13/8i€ [2] 59/21 63/19 I 185/11 186/9 186/21 I 177/14 179/17 179/18] 61/11 118/16 120/14
SOS S1/47 51/21 (Side [2] 21/5 79/19 I 187/23 188/3 188/4 I 183/15 189/16 189/22I 120/15 122/2 123/1
Bo old S214 50/5 ISight [9] 18/14 19/18 I 189/5 190/25 191/11 Isome [48] 14/2 31/5 I 125/15 128/19 132/1
53/14 53/16 56/17 48/4 48/20 49/16 192/24 195/1 35/16 36/11 36/19 146/19 146/20 147/5
57/21 103/22 104/11 I 94/13 107/15 108/2 ISmith's [1] 168/21 38/13 42/20 44/24 147/13 147/19 157/13)
106/23 106/24 106/25I 198/24 snapshot [1] 84/2 45/5 46/23 47/4 51/8 I 158/24 160/8 194/21
4107/2 108/13 108/14 ISign [3] 92/17 151/16Iso [160] 4/19 5/15 52/14 58/20 67/6 specifically [4] 94/15
108/14 109/5 109/7_ I 197/9 6/12 7/21 9/21 10/12 I 68/13 68/22 73/2 95/14 98/22 149/15
1409/9 112/6 1189/5 ISignature [1] 60/14 I 12/5 13/1 14/6 21/14 I 76/21 77/11 80/24 —_I specifics [4] 155/7
1420/5 151/1 151/5 [Signed [10] 81/17 23/7 23/13 25/22 84/17 92/20 113/19 I 156/4 159/23 167/21
151/10 151/11 151/16I 119/13 124/22 130/13] 33/10 33/12 34/1 117/18 122/19 125/3 I specify [2] 120/22
151/23 170/23 197/7 I 130/16 144/8 144/12 I 35/10 38/5 38/12 125/4 125/5 128/21 I 157/8
1499/6 199/6 199/12 I 149/17 152/13 186/18] 39/25 40/10 40/15 130/12 131/5 144/19 Ispeed [1] 43/18
199/14 199/25 200/6 ISignificance [1] 41/1 42/23 43/2 45/7 I 148/13 151/1 157/8 I spent [2] 112/20
200/7 200/8 169/24 48/22 50/25 51/1 53/5I 157/11 160/9 164/17 I 113/22
she'd [1] 200/7 significant [7] 18/19 I 53/13 54/9 54/15 165/7 166/5 166/9 SPM [1] 188/24
she's [1] 152/3 24/14 191/23 192/9 I 54/22 55/4 56/8 56/17) 169/18 171/7 174/4 ISPMs [1] 189/1
shift [1] 156/3 192/19 193/12 193/17I 56/20 56/23 58/19 183/19 186/17 189/12I spoke [1] 81/1
short [6] 25/5 25/17 silence [1] 178/7 59/21 61/13 64/10 someone [12] 4/22 Ispoken [3] 38/5
63/3 111/13 148/18 I Similar [7] 3/6 4/8 64/11 68/15 68/21 8/5 24/5 24/7 35/6 115/14 126/3
191/8 34/6 104/4 104/12 69/1 73/14 73/15 72/24 92/2 92/3 95/17I spotted [2] 6/12
shortage [2] 17/18 118/11 173/25 76/23 77/24 79/5 82/3] 127/9 155/19 184/13 I 125/21
17/21 similarly [1] 142/19 I 83/10 83/18 84/7 85/6)someone's [1] 42/25 I spreadsheet [2]
shortages [6] 191/24 Simon [1] 106/14 85/13 86/8 90/6 91/25I something [22] 7/23 I 66/13 86/5
192/9 192/19 193/12 [Simple [3] 103/10 91/25 92/6 93/2 93/6 I 8/17 21/10 23/19 spreadsheets [4]
193/18 194/14 128/19 172/3 97/21 97/23 98/8 24/17 33/22 33/23 69/18 79/14 79/23
shortcomings [1] simply [5] 39/16 98/25 99/4 99/9 99/20} 38/23 56/13 60/11 89/15
470/12 143/18 193/11 193/13] 101/14 104/18 106/1 I 77/7 77/25 92/16 SPSO [1] 59/9
shortfall [10] 23/24 196/4 106/13 106/24 108/15) 121/16 143/24 153/1 ISquare [1] 137/24
47/17 116/18 122/18 ISince [10] 36/3 38/17I 113/13 113/21 113/24) 155/15 165/9 165/10 Istage [12] 6/16 20/22
141/7 172/7 196/24 I 47/4 49/24 50/14 114/20 117/1 119/3 I 178/13 180/10 180/18] 46/7 102/6 108/16
1497/2 197/7 197/11 I 77/22 183/25 190/2 I 120/20 121/2 121/16 Isometime [1] 175/24 I 108/18 129/6 157/23
190/3 190/7 121/18 122/15 127/11Isometimes [5] 39/14 I 165/3 171/21 177/10
(76) served... - stage
INQ00001110
INQ00001110
s 133/9 133/17 134/7 Istraightforward [1] Isufficient [13] 8/22 I 187/4
stage [i] 1957 I 135/1 135/10 136/4 I 50/24 9/21 10/24 12/13 I suspension [4]
stanes [i] 486/23 I 136/20 137/10 137/19Istrategy [1] 194/3 I 12/22 13/2 16/7 16/10] 187/12 188/20 190/4
stand [4] 94/14 94/24] 138/9 138/14 144/8 Istrictly [1] 151/23 I 43/24 44/14 97/15 I 194/13
433/14 133/24 144/11 144/16 144/22I string [1] 164/18 100/11 128/20 sustainable [1] 99/25)
standard [5] 61/23. I 144/25 146/3 146/4__ strong [4] 12/21 19/3 suggest [16] 34/21 ISuzanne [2] 96/18
90/7 98/13 124/23 I 146/8 146/13 146/17 I 23/22 24/23 41/7 48/11 76/4 7/7 I 112/12
125/14 147/9 147/12 147/24 Istruck [1] 12/18 77/24 92/7 126/8 I Suzanne Palmer [2]
standing [1] 82/3 I 1498 149/10 149/21 I studies [6] 28/7 127/14 133/23 137/3 I 96/18 112/12
stands [1] 121/3 150/6 150/13 151/17 I 30/23 38/9 41/13 137/15 138/6 138/11 Isympathetically [1]
stark [1] 197/8 151/22 151/23 152/5 I 41/14 41/18 173/19 188/22 24/18
Start [14] 1/6 1/23 I 182/13 183/10 153/17) study [2] 111/9 suggested [4] 6/14 Isystem [139] 8/2
8/16 26/16 42/1 sa/21I 154/8 154/24 155/8 I 148/24 52/1 72/19 192/14 I 17/17 18/2 18/10 19/5I
63/13 76/14 99/13 __ I 1595/9 155/16 156/10 Istymied [1] 179/21 Isuggesting [3] 157/3I 20/3 21/10 21/20 24/7
96/20 117/19 130/12 I 156/11 156/14 156/15] subject [3] 26/20 I 161/24 186/22 24/8 24/12 41/3 62/20
1e1/9 196/14 156/20 158/14 158/16I 34/11 95/20 suggestion [6] 51/7 I 67/6 67/8 68/11 68/13
started [4] 27/25 _ I 158/19 158/20 166/11/ submissions [3] 65/3 51/22 96/1 121/22 I 68/23 69/21 69/23
1445/18 150/15 180/9 166/14 167/1 167/5 65/15 109/19 160/5 187/22 70/2 70/11 70/12
starting [6] 11/21 I 167/16 169/15 175/17/submit [1] 197/8 I suggestions [3] 73/21 73/23 74/4 74/5}
17/9 194/9.177/01 I 175/18 177/12 180/24I submitted [2] 19/17 I 143/7 146/23 164/2 I 74/18 76/5 77/3 77/9
177/25 17814 181/4 181/12 181/19 I 145/7 suggests [2] 81/1 I 77/11 77/15 78/4 78/8
starts [3] 55/20 56/3 I 181/20 181/22 182/8 Isubpostmaster [9] I 132/10 78/13 78/18 80/3
162/12 182/9 182/17 183/2 I 17/20 112/21 113/23 Isummaries [4] 81/11 81/14 81/18
state [4] 13/19 183/6 186/18 186/20 I 173/21 186/1 187/7 I 119/12 121/1 125/21 I 82/5 82/9 82/19 83/13
127/12 136/8 20015 I 186/24 187/16 188/19I 187/10 190/3 193/10 I 149/14 85/6 85/9 85/13 87/17
stated [3] 79/21 189/6 189/8 190/16 Isubpostmasters [13] Isummarise [2] 29/18I 88/25 89/1 89/2 89/7
106/23 135/10 192/18 193/11 198/3 I 1/21 171/12 171/18 36/5 89/8 89/24 89/25 90/4!
statement [196] statements [30] 171/23 174/10 178/15] summarising [1] 90/15 90/17 91/14
29/23 30/14 31/3 31/7I 30/25 31/4 32/6 37/6 I 179/23 186/13 188/16] 92/25 92/16 92/19 92/19
31/11 32/2 32/12 35/4) 28/19 40/4 40/7 45/6 I 189/10 189/13 191/21Isummary [10] 30/9 I 92/24 93/2 93/9
35/8 4079 58/9 Se/10 I 60/3 70/3 71/25 82/1 I 193/17 86/1 119/2 122/6 109/21 112/1 112/11
59/7 59/17 60/9 60/14] 83/3 90/8 95/25 subsequent [12] 122/13 123/3 126/7_ I 112/14 114/5 116/6
60/19 B11 61/24 117/25 138/19 138/22I 102/13 126/14 186/1 I 152/4 154/23 169/15 I 118/9 118/15 118/17
66/12 66/14 66/21 145/16 149/3 173/17 I 187/11 188/16 188/19Isummer [1] 93/15 120/24 121/13 126/16)
66/23 67/16 67/22 180/9 189/1 189/9 188/24 189/1 189/9 Isuperintendence [1] I 131/4 131/16 134/4
489/13 191/20 192/2 I 190/10 191/21 193/16] 6/20 134/9 134/16 136/20
Coe sory mere Tot I 192/14 193/5 193/15 Isubsequently [3] superiors [1] 199/14 I 138/2 140/5 140/7
Soe oer oo o/l1 5Istates [2] 80/2 190/1 I 70/9 70/19 89/6 _Isupervision [1] 30/7 I 140/16 140/25 141/7
oad loa yeig Istation [1] 1/19 substance [2] 29/23 Isupplied [2] 124718 I 142/4 144/18 14516
ps rye rans (status [2] 58/16 I 144/15 167/18 445/12 146/2 152/10
ee oe aye I 77/19 succeed [1] 103/24 Isupport [6] 61/22 I 192/24 167/10 157/21
ree cero ona 7aig\Statute [1] 140/2 Isucceeded [1] 96/6 I 74/4 75/5 103/11 I 159/8 160/3 166/17
rot eee stave [1] 24/12 success [1] 20/23 I 114/13 189/13 470/14 171/16 172/11
79/22 80/1 80/11 stayed [1] 70/24 succession [1] 6/20 Isupported [1] 46/10 I 172/23 173/6 173/9
rong gorse pila erie steal [1] 46/9 such [44] 3/841 suppose [6] 91/15 I 173/21 174/8 174/21
Soe ee ya stealing [1] 126/14 I 4/12 4/23 16/12 19/21] 96/16 18512 155/14 I 174/22 174/25 17514
Bits 80/22 B2f6 stein [3] 1719 I 28/19 34/7 40/18 44/6I 196/7 201/16 47517 175/16 175/23
Slot bala aema I 171/10 20414 44/20 47/23 57/4 Isupposed [2] 92/13 I 176/3 176/4 177/24
Sa ee eee gaialstep [3] 7936/11 I eaiseait4 77/11 I 9318 4178/2 178/10 178/17
Bo 728 82 884 G64 TING 777 78/13 ISupreme [1] 110/8 I 179/22 180/6 180/11
90/14 90/18 90/24 ~—«I Stephen [4] 47/6 80/7 86/24 88/10 sure [14] 27/14 28/3 I 180/13 180/15 184/11
91/17 91/24 92/8 96/23 189/25 193/6 I 92/10 93/24 98/13 32/23 42/20 55/21 185/25 186/2 186/11
92/11 94/9 94/14 Steve [4] 185/12 99/19 101/16 104/3 I 56/12 69/16 79/12 187/20 188/18 189/3
94/16 95/1 95/14 188/9 191/20 192/6 I 104/7 105/12 105/15 I 84/16 93/25 94/18 191/23 192/9 194/20
95/13 95/15 95/18 _I Still [10] 6/6 13/13 112/23 114/9 119/23 I 97/18 156/18 179/11 I 202/13
95/20 96/3 99/24 99/3 147/5 161/19 128/18 137/10 163/25I surnames [1] 28/12 Isystems [2] 125/16
106/24 107/7 115/13 161/22 164/19 185/24I 166/23 172/17 176/22Isurprised [1] 145/20 I 139/23
420/20 121/7 121/10 188/13 197/10 183/5 199/7 201/14 ISusan [1] 100/3 T
422/10 122/10 123/8 stock [4] 187/6 187/9I 202/4 susceptible [1]
423/15 125/14 127/22 187/11 188/20 suffered [2] 103/8 109/14 tab [1] 55/24
428/10 128/19 129/8 [Stolen [1] 48/17 184/12 suspect [1] 117/10 table [1] 86/1
430/13 130/15 130/16IStore [1] 188/13 sufficiency [6] 10/5 Isuspect's [1] 42/11 Tahir [2] 6/16 46/17
430/21 130/24 131/2 [Stored [1] 90/1 21/22 97/3 98/23 suspended [5] 19/14 Itailored [2] 21/17
straight [1] 148/25 I 99/12 99/18 184/9 185/5 186/14 I 39/19
(77) stage... - tailored
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T tests [1] 11/6 114/19 115/2 115/10 I 27/18 28/20 29/17 _—I therefore [20] 5/15
fake 1241 99/10 30/19 tethering [1] 117/1 I 116/13 116/20 121/21] 30/6 96/14 182/19 12/22 47/17 47/20
take en eee text [3] 68/7 78/12 122/9 127/17 131/11 I 182/23 TAI17 74/4 75/6 79/16)
43/14 45/19 49/15 82/13 136/11 137/4 137/20 Ithen [148] 1/18 2/20 I 95/19 99/6 109/9
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143/19 148/7 171/21 I 26/1 34/2 35/7 35/24 I 1714/5 174/25 180/20 I 14/16 15/20 16/4 17/1] 199/9 201/11 201/13
180/23 181/5 185/20 I 26/17 37/12 38/12 186/24 187/22 193/10) 23/18 24/22 29/10 _I thereunder [1]
192/21 45/12 46/1 46/12 48/9) 196/11 198/5 202/14 I 30/14 35/10 41/12 107/18
taken [21] 13/22 18/1 54/15 56/11 61/3 76/6Itheft [50] 8/22 9/3 9/6) 42/1 44/8 45/6 51/18 Ithese [41] 5/16 5/23
18/15 21/9 26/5 26/12I 76/7 76/12 90/13 9/7 9/12 9/19 11/18 I 53/17 56/6 56/13 6/7 8/3 16/15 22/22
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takes [1] 77/20 122/23 127/11 128/8 I 16/8 16/9 16/14 16/20I 73/18 73/22 75/24 134/19 134/20 138/8
taking [12] 11/20 132/8 132/13 1414/3 I 17/12 18/20 18/21 76/6 76/17 77/8 79/19] 142/12 142/17 143/4
14/17 14/22 25/25 151/10 159/15 160/1 I 22/25 25/10 25/17 81/1 81/20 83/20 144/2 147/3 147/6
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94/14 112/3 185/24 I 174/16 180/19 181/9 I 44/15 44/21 45/15 86/6 87/15 89/6 89/10} 160/20 173/22 177/13
191/20 195/18 181/24 182/19 182/24I 47/15 48/18 52/12 89/11 89/15 94/2 178/3 178/10 179/13
talking [2] 34/18 191/7 201/25 97/21 100/10 101/5 I 94/11 98/2 101/15 193/15
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Taylor [5] 55/17 23/13 23/18 24/25 21/20 22/23 24/15 110/10 110/24 116/2 I 19/10 22/8 24/9 24/9
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team [9] 8/3 8/10 53/6 55/11 55/14 30/15 32/20 32/21 120/21 120/22 125/5 I 26/7 26/8 26/12 27/7
61/22 72/25 79/15 55/25 55/25 57/1 32/24 33/15 36/15 126/5 128/21 130/12 I 27/15 28/23 29/17
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teams [1] 141/13 83/25 87/7 90/18 71/11 75/14 92/10 139/8 139/23 139/25 I 32/17 33/5 33/6 33/10
technical [3] 53/13 90/21 95/23 96/17 94/9 95/1 95/10 95/18] 144/21 145/2 149/19 I 33/15 35/2 38/14
137/5 155/21 100/2 102/8 106/12 I 95/19 99/6 113/11 149/24 152/12 153/6 I 39/12 39/14 39/16
technicality [1] 53/20 1141/7 111/17 114/16 I 113/12 113/13 118/18] 155/4 155/22 158/18 I 39/20 40/3 40/6 40/9
telephone [3] 172/4 117/15 118/4 130/20 I 121/25 126/25 140/18] 160/8 161/3 162/4 42/23 42/24 43/13
1472/6 173/9 136/2 142/9 147/21 141/4 155/5 158/2 163/7 164/21 166/1 43/16 44/8 44/10
tell [10] 32/15 83/25 148/5 148/16 148/22 I 175/21 179/12 180/3 I 166/6 166/9 170/8 44/25 44/25 45/5 46/3
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131/24 142/23 147/21I 161/6 171/6 171/9 183/25 194/4 194/21 I 176/23 179/5 180/15 I 54/4 54/7 54/9 54/18
17216 183/18 183/22 184/2 Itheirs [1] 136/1 183/3 187/6 187/25 I 57/4 57/14 68/23
telling [7] 38/14 189/17 193/3 196/11 Ithem [58] 2/16 5/12 I 189/15 190/10 190/13} 74/24 75/13 75/15
38/15 52/6 122/25 196/22 202/15 202/18] 6/6 6/19 7/4 7/20 8/13I 190/25 192/4 192/24 I 75/22 75/23 75/24
4123/2 151/12 199/25 I 202/22 202/23 202/24) 19/8 24/23 28/3 28/6 I 193/13 193/18 194/1 I 76/2 81/24 81/25 83/4
tells [2] 130/1 192/14 203/5 29/18 35/16 36/5 195/11 198/11 199/9 I 83/14 92/14 92/17
ten [4] 41/12 56/8 thanks [2] 124/18 36/21 38/14 38/21 199/20 200/2 200/25 I 93/9 95/17 98/23 99/3
112/12 196/17 186/5 45/7 45/8 55/2 57/14 I 201/24 104/23 106/6 118/17
tenor [1] 127/1 that [1198] 61/23 70/6 71/8 72/2 Itheory [1] 175/11 120/23 125/13 125/14)
terms [13] 21/18 27/1 that I [1] 6/1 77/11 77/16 78/10 I there [236] 127/15 129/17 138/23)
31/22 35/22 42/5 that's [63] 3/17 13/14I 79/17 80/24 85/5 there'd [2] 45/6 201/6I 140/1 140/2 140/4
43/14 44/3 57/10 21/14 22/13 22/19 95/21 98/13 98/16 —_Ithere's [23] 8/6 9/21 I 140/4 140/13 140/13
70/19 79/23 160/1 28/9 37/11 41/12 98/22 99/5 99/5 99/7 I 53/22 56/13 81/19 140/17 140/18 141/4
178/12 194/19 46/14 48/6 51/15 109/11 111/22 118/21] 101/3 107/5 109/7 141/18 142/1 142/2
tertiary [1] 48/9 53/11 53/20 55/3 56/4I 141/20 142/6 155/22 I 126/23 137/15 145/15) 142/5 142/6 142/7
test [14] 13/23 19/22 56/23 58/18 59/10 155/22 158/5 159/14 I 145/24 147/23 153/6 I 145/23 154/14 155/2
59/11 59/21 62/7 160/14 162/7 164/18 I 166/8 166/10 175/7 I 155/4 155/8 155/24
Cae torte OBA 62/15 64/24 65/8 168/18 180/19 188/15) 178/1 182/4 189/15 I 158/1 158/4 158/10
410/12 110/17 111/3 I 71/10 72/21 73/10 190/23 196/20 197/8 I 190/25 193/12 196/7 I 160/13 162/15 162/17!
4113/3 192/17 79/19 81/15 89/13 198/12 198/13 thereabouts [1] 162/23 162/24 164/10)
tested [1] 145/23 93/2 99/2 101/8 theme [1] 115/2 191/17 165/7 165/8 165/9
101/13 105/24 108/15I themselves [8] 26/23Ithereafter [1] 162/25 I 165/22 165/23 165/23}
(78) take - they
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4180/7 182/1 182/16 I 38/2 58/8 59/10 63/9 Itime [41] 1/11 1/23 I 66/24 typing [1] 74/1
482/20 182/22 182/23I 6/1 66/13 2/14 3/16 3/19 7/7 transcript [9] 1/16
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they'd [6] 7/5.45/3 I 7/21 11/13 12/18 110/5 117/11 119/8 I 188/19 190/3 unable [3] 47/19
45/4 45/8 15612 15/16 16/7 16/10 17/8I 120/9 121/4 127/24 transferred [2] 187/6I 118/15 188/7
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they're [4] 99/2 22/5 22/6 23/5 23/7 I 139/17 143/16 145/19Itransfers [1] 200/16 I 118/15,
111/22 182/18 192/15] 29/15 23/16 27/23 145/24 159/20 161/17Itravel [4] 161/23 unaccountable [1]
they've [1] 43/17 28/2 28/15 31/1 31/6 I 163/2 164/24 169/5 I 162/19 166/5 183/7 I 179/4
thing [5] 85/3 86/19 32/1 32/6 32/12 32/19] 182/6 184/4 191/1 Treasury [1] 8/2 unavoidable [1]
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things [20] 1/6 11/13 41/19 42/22 46/10 _I timeline [1] 143/13 Itrial [29] 10/17 13/6 Iunbiased [1] 30/17
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434/23 136/11 139/16) 88/13 99/5 101/15 I 191/15 196/15 49/5 93/20 106/25 Iunder [10] 10/6 26/7
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90/6 91/3 93/6 96/12 I 104/23 120/9 124/19 Itook [6] 22/8 92/7 _ITuesday [1] 1/1 195/3
97/25 99/3 115/19 I 147/20 165/25 186/9 I 102/18 132/17 195/12Iturn [24] 2/11 3/4 I undermined [2]
148/11 124/16 127/23I thoughts [2] 153/11 I 196/19 3/11 13/17 16/16 25/13 83/8
127/25 129/12 134/9 I 193/18 top [5] 49/1 66/19 22/16 26/13 37/18 I undermining [3]
436/11 137/21 139/16 thousands [1] 73/9 73/16 131/11 I 41/12 42/3 46/17 31/20 83/15 108/20
439/17 141/1 141/10 I 150/25 topic [7] 2/8 2/9 8/15 I 49/19 53/6 58/2 58/5 I underneath [2] 131/8
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171/8 173/16 180/1 [three days [2] 186/17) 185/20 TV [4] 93/25 94/12 I 94/21 99/2 122/12
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4188/25 196/13 198/3 (threshold [1] 65/3 trading [1] 197/10 _Itwice [1] 118/12 142/4 144/17 151/14
202/14 through [26] 14/17 I trail [1] 157/11 two [29] 1/69/25 I 157/5 160/15 181/8
thinking [2] 55/4 14/23 16/14 24/17 train [1] 1/22 18/24 47/9 48/12 68/2I 181/23 200/11
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third [11] 40/24 60/24 85/5 106/15 training [1] 145/11 I 71/18 75/11 78/19 I 46/23 74/19 89/23
50/21 67/3 69/1 73/23I 106/17 119/24 125/2 Itransaction [5] 68/10I 81/17 88/13 110/24 I 101/22 112/15 124/21
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third-party [1] 40/24 I 149/13 151/15 174/21Itransactions [19] I 142/17 148/14 157/23I understands [1]
this [248] 176/9 178/4 195/18 I 41/2 59/16 59/18 171/22 189/21 191/21I 27/15
199/12 59/20 60/10 60/20 I 195/7 understatement [1]
(79) they... - understatement
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84/6 190/7 166/10 155/17 160/17 170/2 I 189/12 140/21 141/4 141/6
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10820 37/17 39/11 43/5 52/2I 181/9 181/25 185/5 I 55/21 66/7 71/2 106/8I 155/4 155/9 155/22
unexplained [1] 60/11 63/6 76/22 I vintage [1] 139/21 I 1141/8 130/23 144/22 I 155/24 156/1 158/2
200/16 79/12 83/25 91/15 —_Ivirtues [1] 8/1 144/25 150/15 156/4 I 158/8 158/15 160/12
unfortunate [1] 91/20 111/16 112/1 I vista [1] 141/21 164/11 168/6 177/21 I 160/13 162/22 162/23
131/25 131/24 147/21 148/21IVolume [3] 3/11 42/2] 177/25 201/9 202/7 I 165/8 165/9 170/12
unfortunately [2] 161/20 166/15 176/17I 55/23 we've [30] 15/1 29/15) 171/22 172/8 172/9
79/11 196/15 use [14] 11/10 14/20 IVolume 4 [1] 55/23 I 37/3 37/7 38/5 39/25 I 172/10 172/20 172/24
unhappiness [1] 28/12 47/12 81/23 IVolume 2[1] 42/2 _I 60/7 70/4 72/10 85/16 173/10 173/13 173/15
TAY 88/5 89/22 119/19 IVolume 2A [4] 3/11 I 92/7 93/14 95/25 173/24 174/3 179/2
unjust’ [1] 25/3 120/12 127/2 151/18 I__I 96/13 99/9 99/14 179/6 179/9 179/15
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103/15 130/10 178/4 \4sed [8] 16/20 30/4 I wait [2] 2/12 158/4 I 133/10 133/25 136/24] 182/16 182/20 182/23}
unlike [1] 169/7 36/11 41/10 89/2 waiting [1] 161/19 I 150/10 151/19 155/9 I 183/24 187/19 188/6
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unprepared [4] 156/2/4Sefully [1] 156/21 Iwall [1] 180/17 190/20 202/8 192/19 195/18 195/19
P Pi bie [1] [Useless [1] 68/3 want [16] 43/2 55/20 Iwebsite [1] 41/17 195/25 196/1 198/11
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unreliable [3] 199/17 [Usual [3] 43/20 59/12] 96/20 106/6 124/20 I 152/18 164/16 197/23] 201/18
renabe 185/19 125/3 129/17 142/23 Iweekly [1] 145/23 Iweren't [4] 30/5
unresolved [4] 54/23/4sually [2] 19/1 184/7 185/3 190/18 Iweeks [1] 152/12 I 51/10 158/10 195/14
unsafe [4] 64/3 31/13 192/13 well [39] 1/25 5/3 Westminster [1]
103/21 ee 107/M12\y (I anted [5] 17/5 16/14 23/5 27/24 54/13
tH [5] 62/24 114/10) Vo 55/12. 75/23 12513 I 36/19 42/20 43/15 Iwhat [194] 7/15
a 203/11 IVagaries [1] 99/18 I 125/13 69/14 72/2 74/4 75/5 I 17/10 20/5 20/17 21/3}
valid [1] 194/22 Ward [23] 58/24 59/2I 94/21 102/10 103/22 I 22/8 24/3 27/2 27/6
untoward [1] 195/11 I yaiue [3] 73/20 85/25I 59/22 60/5 60/23 66/9I 104/5 104/10 105/3 I 28/6 31/10 31/12
unused {31 34 89/12 66/20 67/2 72/5 72/16] 113/14 126/16 127/7 I 31/13 31/14 32/24
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