ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
The Post Office Horizon IT Inquiry
Wednesday, 12 June 2024
(9.45 am)
MR STEVENS: Good morning, sir.
SIR WYN WILLIAMS: Good morning.
MR STEVENS: We're hearing from Mr Beezer today.
SIR WYN WILLIAMS: Yes.
THOMAS MATHEW BEEZER (sworn)
Questioned by MR STEVENS
MR STEVENS: Thank you. Before we begin, sir, I should say
we're due to have the usual fire alarm test at 10.00.
I propose we simply sit through it.
SIR WYN WILLIAMS: Yes, of course.
MR STEVENS: Please could you state your full name?
A. Thomas Mathew Beezer.
Q. Thank you for attending the Inquiry today to give
evidence. Mr Beezer, you've made two statements to this
Inquiry, and thank you for your written evidence. The
first has Unique Reference Number WITN09510100. That
was read into the record on 2 February 2024 but, as
you're called to give evidence now, I'll ask you to
affirm it. Can I ask you to turn to the front of that
witness statement in front of you, please?
A. Yes, I have it.
Q. Thank you. It should be dated 13 June 2023 and, if
I could ask you please to turn to page 32 of that
1
"distinction"?
A. It should.
Q. The second document, please, is WBON0001747 and about
six lines down, I think it says “but only insofar as
clause x 12" and that should say "clauses X, Y, Z"?
A. Agreed.
Q. Thank you. Can we then, please, turn to WBON0001752.
If we could turn to the second page, please, midway down
there's an asterisk and it says “contract incorp is
a problem in this Clause". I understand that "clause"
should read "class"?
A. Agreed.
Q._ Finally, can we turn to WBON0001888. I'm playing
catch-up with myself, sorry. I think here, if we turn
the page, please, on the third line at the end it says
"May view (QC)". I understand that should read "My
view"?
A. Agreed.
Q. Thank you. That can be taken down now. Subject to
those corrections to the exhibits, are the contents of
your first and second statement true to the best of your
knowledge and belief?
A. They are.
Q. Thank you. That stands as your evidence in the Inquiry.
The first statement has already been published but
3
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
prop
prpro>
12 June 2024
statement, you'll see it runs to 82 paragraphs.
Yes.
Is that your signature?
Yes, it is.
You made a second witness statement on 8 May 2024.
Could I ask you to turn to that, please?
Ihave it.
Thank you. Page 41, please.
Yes.
Is that your signature?
Itis.
Now, as part of your statement, you have exhibited
several handwritten notes or attendance notes of various
meetings you had. You also exhibited versions you'd
typed recently, transcribing what those notes said --
To assist the Inquiry.
Yes, and we're grateful for that. I understand that
since you've re-read your statement you have a four
corrections to make to those?
Yes.
I'll deal with those shortly now. Please can we bring
the first one up. It's WBONO001751.
If you go right to the bottom, please, I understand
that the first correction is where it says,
"distraction" at the bottom line, that should read
2
second statement will be published on the website
shortly. Before I ask you questions about your
evidence, I understand there's a statement you'd like to
make?
Yes, thank you. I'd like to take this opportunity at
the outset of my evidence to reiterate my apology in my
second witness statement. To each and every
subpostmaster and mistress, I'm sorry that the recusal
application added to the complexity and challenges they
faced in the GLO.
Additionally, I'd like to apologise to Mr Castleton
personally. I submitted a witness statement in the
Inquiry in its Phase 4 work and I had anticipated I'd be
called in that phase. I had wanted and planned to make
an apology to Mr Castleton in Phase 4 had I been called.
I was not, hence taking this opportunity to now express
my deep regret about the circumstances he and his family
were placed in.
At the time of the case in 2005 and 2006, I was
confident in the assertions made to me by POL about the
robustness of the Horizon system and I believed I was
acting properly and in accordance with my instructions
when dealing with that case. However, with the
information that has come to light over the course of
this Inquiry, my confidence in such assertions has been
4
(1) Pages 1-4
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
2
prop
prop
pProrop
prop,
The Post Office Horizon IT Inquiry
eroded, so I'm taking this opportunity to now say that
I'm truly sorry.
I'd like to start with some background questions, if
Imay. You qualified as a solicitor in 1996?
Correct, yes.
You joined Bond Pearce in 2003?
Yes.
As the Inquiry knows well, Bond Pearce subsequently
became Bond Dickinson --
Yes.
-- and Bond Dickinson then became Womble Bond Dickinson ?
Yes.
I'll use the terms interchangeably, treat them as
effectively the same body.
Fine.
You were made a partner of Bond Pearce in 2005?
Yes.
You remain a partner of Womble Bond Dickinson today?
Yes.
Have you practised in civil litigation throughout your
career as a solicitor?
Yes.
Do you have any experience of practice in criminal law?
No.
I'm going to primarily focus in evidence today on two
5
summary form, what experience did you have of conducting
litigation for Post Office itself?
I find that quite hard to answer at this distance. It
18/19 years ago. I suspect it will have been some of
the more complex debt recovery, I suspect. But I'm
dredging my memory.
Please can we bring up your first witness statement,
which is WITN09510100, and page 5, paragraph 12, please.
Thank you.
You make a point about an engagement letter relating
to the Castleton litigation, and you then say:
"I cannot now recall why this was done, not least
because my firm had a global engagement in place with
Post Office throughout this period (and, so far as I am
aware, at all times in our relationship) ..."
Could you please describe to me what you mean by
"global engagement"?
I understand that you could call it a framework
agreement; you could calll it an appointment agreement.
's
I can't picture it, I may never have seen it, I may just
know that each year or at the recommencement of
successful tenders a new framework agreement between
Post Office and its panel law firms was put in place.
So there's a fully termed framework agreement,
I believe. Although I can't picture it and may never
7
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
2
12 June 2024
areas: firstly, the case of Post Office v Lee Castleton,
which you've just alluded to and, second, the recusal
application in the GLO proceedings. Before we do that,
I want to turn to Bond Pearce/Womble Bond Dickinson's
relationship with Post Office.
In 2005, when you say you became involved in the
Castleton case, you described the Post Office then as
a significant client?
Yes.
Why did you consider the Post Office to be a significant
client at that stage?
Bond Pearce had acted for the Post Office, I believe,
for many years in a number of streams of work,
commercial work, employment work, some litigation work,
and it was a household name and a significant client.
It was a client we were proud to have.
You've named a few streams of work there. You didn't
mention criminal proceedings. Is that because Bond
Pearce didn't take on criminal work?
In the Civil Litigation Team we didn't take on criminal
work. There may have been parts of the firm that did
criminal work. We have regulatory teams, for example.
So I can't say no criminal work in the firm at all.
I did no criminal work for Post Office.
Prior to dealing with the case of Lee Castleton, in
6
have seen it, I just know it existed.
Based on your knowledge of it or whatever knowledge you
had, would that global agreement then be supplemented by
individual retainers on specific matters?
It may have been. It may have been.
The Inquiry heard evidence from Chris Aujard, who was
General Counsel between October 2013 and March 2014,
with some overlap with Jane MacLeod, as a General
Counsel of Post Office Limited. In his evidence, he
described during that period that Bond Dickinson was so
embedded within Post Office that, in many ways, they
acted as an extension of the in-house team. Would you
accept that is a fair characterisation of how Bond
Dickinson operated with Post Office at that time?
2013/2014?
Yes.
I probably wasn't much to do with the Post Office
relationship at that time, so I can't answer that with
any precision. I suspect I was doing no Post Office
work at all at that time. As a partner in the firm,
I would say we always had a proper lawyer-client
relationship but, from my personal experience, I can't
answer. I wasn't doing Post Office work.
In respect of when you were doing Post Office work,
would that description be fair for any period of time
8
(2) Pages 5-8
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
POPS
>
The Post Office Horizon IT Inquiry
which you were involved with it?
I don't think so. I did Post Office work in those early
years and then, later on, as we will see, in the recusal
but in the intervening years not at all.
So you say "early years", we're talking --
Early 2000s, yeah.
When do you think you stopped doing that work?
It's a guess but, if you want me to guess, I will.
2007/8/9, somewhere like that. Before, probably 2007/8,
I drop out of that vein of work and that relationship.
As a partner in the litigation team during that period,
would you have had any oversight at all of the Post
Office relationship, even when you weren't specifically
working on cases for them?
No, not oversight of the relationship but, as a partner
in the litigation team, I will have had a connection
with the people in the litigation team, yes, and they
may have been doing Post Office work. So I would have
known about stuff going on but we had a proactive
relationship partner for Post Office and that wasn't me.
Who was that?
That was a gentleman called Simon Richardson.
We may come back to that period of time in due course.
I want to look at the early years first and let's start
with 2005, please, and some emails relating to the case
9
anticipation of the criminal trial, Paul Whitaker's.
report and his interview of David Blakey."
So, at this stage, you were aware of an overlap in
some cases between civil proceedings being brought by
the Post Office and criminal proceedings; is that right?
No, probably not. My read of this, when I was sent this
recently by the Inquiry, is that we were doing the debt
recovery afterwards, is what I think, but I don't know
that.
Let me rephrase my question, sorry. You were aware
that, in some cases where you were instructed to pursue
debts on behalf of the Post Office, the Post Office had
prosecuted the people you were pursuing?
I believe that must be right, from this email, yeah.
Presumably, you were aware that Post Office relied on
Horizon data when pursuing those criminal prosecutions?
Yes, probably, but -- I say, "yes, probably" in answer
to that question because I think the first time that was
gone into intellectually as a topic was in the Castleton
case. Everything in the Castleton case suggests to me
we -- me and the people in that case -- are on that
journey for the first time. You know, the language
is -- we're not saying we did this in the last case.
I think that's the first forensic investigation. So --
Just to clarify, are you saying that Castleton was the
1
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
12 June 2024
against Gillian Blakey and David Blakey. Can we please
turn to POL00142517.
(Pause for fire alarm test)
Right, I think that's over.
So we have an email on the screen here, if you could
just scroll up slightly, thank you. So this is from
a solicitor at Bond Pearce, is it Dave Panaech?
Panaech.
Panaech, thank you. It's to Cheryl Woodward at Post
Office and Mandy Talbot, and you are in copy, and it's
referring to sending a letter before action off on the
Riby Square Post Office case. Why would you have been
copied in as a partner on a correspondence such as this?
Dave was a solicitor in the team. In those early times,
I had a footprint within the Post Office relationship.
I think that's why Dave is copying me in.
Okay if we look for an email further on in the timeline,
it's POL00142534, please, from Dave Panaech again to
Cheryl Woodward, you're in copy, dated 22 November.
This concerns civil proceedings and it sets out that
Particulars of Claim were enclosed with the email. The
penultimate paragraph, it says:
"The facts of the case were ascertained from the
documents prepared by the investigators in the POID
file, in particular, the witness statements produced in
10
first time at least you turned your mind to data
produced by Horizon being used as an evidential basis to
pursue claims for debt?
Yes, I think so. I think so but, given that Horizon
underpinned their business, the debts being chased at
this time -- if that's what's happening because I don't
remember this at all -- must have been generated from
Horizon.
It seems that, from here, Bond Pearce, as part of its
debt recovery work, were being sent bundles of documents
relevant to those criminal prosecutions?
That seems to be some of the background material that we
sent but, as I say, I've no memory of this whatsoever.
So, as a broad question, if a solicitor at Bond Pearce
at this time, who was handling a debt recovery action,
if they had or discovered evidence that called into
question the reliability of the Horizon IT System, to
what extent do you think they would have
a responsibility to consider whether that document or
information ought to be disclosed to subpostmasters
convicted of theft or false accounting in criminal
proceedings that relied on data generated by the Horizon
IT System?
As a civil practitioner, I'm not sure I'm really placed
to answer that. Can we unpack that question a little
12
(3) Pages 9 - 12
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
>
o>
oP
prop
The Post Office Horizon IT Inquiry
bit? So if there was a document that demonstrated
the --
Well, let me unpack it. There's a civil practitioner
dealing with a claim for debt --
Yes.
-- and that claim for debt relies on data generated by
the Horizon IT System.
Yeah.
That civil practitioner is aware that his or her client
also prosecutes subpostmasters for theft or false
accounting based on Horizon data?
Yes, if that was what had happened in the Blakey case
but I don't know that.
Yes, setting out some hypotheticals here.
Yes.
In those circumstances, if that civil practitioner
discovered evidence or information that undermined or
tended to undermine the reliability of the Horizon IT
System, do you think there was any responsibility on the
civil practitioner to consider whether that document
ought to be disclosed to subpostmasters who had been
convicted of theft or false accounting?
The specific subpostmasters or subpostmasters generally
as a class?
Well, let's start with generally as a class first.
13
Yes, I believe so. We're going way back into my memory.
Following an audit on 23 March 2004, the Post Office
suspended Mr Castleton because of alleged discrepancies?
I believe, so.
The Post Office subsequently instructed Bond Pearce to
pursue Mr Castleton for the shortfall as a debt?
Yes.
This was initially handled by a team called CMS within
Bond Pearce?
Yes.
Acclaim was issued and served on Mr Castleton --
Yes.
-- and he served a defence and counterclaim on 15 August
2005?
Yes.
The Post Office failed to file a defence to the
counterclaim by the deadline --
Yes.
-- and that was because of an error by a fee earner. We
don't need to go into the details of it but that was
subsequently resolved?
Yes.
But the court had entered judgment in default of
a defence being served, which led to your involvement in
the case?
15
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
>
p>po>
12 June 2024
I don't know how to answer that, to be honest with you.
I'm not trying to avoid answering it. It would need the
civil practitioner to have sufficient knowledge of
criminal process to be able to navigate those waters.
It would certainly have an impact on the civil case that
was on the desk at the time, of course it would.
Absolutely. Would it trigger a solicitor out there in
law land to take on a proactive disclosure duty?
I don't know the answer to that.
Let's not go as far as to say they have a disclosure
duty but do you think there's any responsibility to
raise or discuss it with the client and say, "You may
need to consider your criminal prosecutions" or --
If they had a full enough picture of what was going on,
and so, if a case on a desk had -- if someone was --
became -- actually knew that the data that had
underpinned a civil case or a criminal case was wrong,
I believe there would be a conversation with the client.
I want to move to look at the Lee Castleton case now.
It's a case the Inquiry has looked at in some detail in
Phase 4. Just to refresh on the background,
Mr Castleton was a subpostmaster of the Marine Drive
Post Office from 18 July 2003.
I believe so.
You're nodding, yes?
14
It did.
Let's have a look at a document, then. It's
POL00070496, please. Could we go to page 2, please,
right at the bottom. There's an email from Stephen
Dilley; he was an associate, was he, at the time in Bond
Pearce?
Yes.
Did he report to you?
Yes, on this case.
We see there this is to Bob Heckford on 18 November.
Who was Bob Heckford?
I believe Bob Heckford was one of our internal risk
people. I'm not absolutely sure but I think that's the
role he fulfilled.
So we see "Private, Privileged and Confidential and
Prepared for the Purposes of a Possible Claim Against
the Firm", and this goes on to set out the background
which we've just discussed. We can see you're copied in
to it there. So, against that background, can we turn
to your email on page 1, please. Thank you. So
21 November, you say that you have spoken to Mandy,
that's Mandy Talbot?
Agreed.
What was your working relationship with Mandy Talbot at
that point?
16
(4) Pages 13 - 16
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
2
oP
pPrPororoPr
prop
The Post Office Horizon IT Inquiry
Solicitor-client, cordial. Which aspect do you?
Well, how often did you work with her?
I can't remember but sporadically but regularly.
You said cordial?
Yes.
Is your evidence that it was a cordial relationship?
Yes, yes.
You say:
"I spoke to Mandy. She is understandably a little
disturbed."
Presumably that's by the default judgment?
She was angry.
We've said already in your witness statement you
describe Post Office Limited as a very significant
client. Were you effectively being brought in --
Yes.
-- to calm Post Office's nerves?
Yes.
So it was being brought in to show that a partner was
having clear oversight of this case?
Yes.
Would you usually have been brought into a debt claim
such as this?
No.
If we go down -- it's already there, sorry. You see at
17
she could be quite forceful, and, at this time, I think
she was saying to me words to the effect of "You've
really stuffed up, there's an embryonic class action" to
put fear into me and to tell me off.
That's what I thought at this point, when this
conversation took place. As time moved on, although
I didn't know it at the time this conversation took
place, I think she was overstating the embryonic class
action because, as I understand it, it was, in fact, two
cases, I think, and I think she was overstating the
position to extract her ounce of flesh from the firm for
having made a mistake, is what I think was going on but
I don't know that for certain.
But, at this stage, there's a clear link being drawn
between Mr Castleton's case and an overall background
worry of other cases relating to the integrity of the
Horizon IT System?
Yes.
Point 1, under "Requests from Mandy’, you say "I feel we
MUST comply with", the first one is:
"that she is kept fully informed on this matter --
including steps to be taken. I will lead on this.
"2) that she be sent a full set of proceedings (in
order) and a full set of correspondence ..."
You go on to say:
19
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
12 June 2024
number 2 it says:
"Hugh James are currently trying to contain
an embryonic and not yet issued class action relating to
the Horizon [IT] system. A judgment in relation to it
(even a default) is currently very bad news for RM."
Presumably that's Royal Mail?
Royal Mail, POL; at that time they were the same entity.
So breaking that down, Hugh James are another firm of
solicitors?
Yes.
They are acting for Post Office in relation to what's
described here as a potential class action?
Yes.
Can you recall what Mandy Talbot told you about this
potential class action?
No, because it’s 18/19 years ago. I can go on, if you
want me to, to give you some colour.
Well, yes, what was your understanding of the scale of
the action at this point?
I don't think I had an understanding at this point in
time. What I think was going on here was Mandy was
pretty peeved with the firm. We'd got a default
judgment against them, which -- for £250,000, which is
thoroughly bad news. Mandy -- as I said, I did interact
with Mandy periodically, I knew her reasonably well and
18
"As you know I would like a full set too please."
So you're envisaging a very hands-on role for
yourself, it seems, in this case.
We need to get that default judgment set aside.
So that's getting the default judgment set aside. Was
it also because of wider concerns about a class action
that had been raised?
At this point, I mean, it's a long time ago but, knowing
me because I know me, I will have been laser focused on
the default judgment, the mistake the firm had made, and
responding to the urgency that the client is putting
upon me. And so my concern, my irritation that's coming
across to my internal team here is saying "We're going
to get this default judgment set aside". That's what
I think is going on.
Well, if we look at (3), it says:
"due to matters handled by Hugh James relating to
Horizon, Mandy asks that we speak to them to ensure we
are all pulling in the same direction. This is even
more important given the threatened class action."
You go on to say at (4) about not issuing
proceedings in a claim based on Horizon evidence without
her consent, and (5):
wants a report on how many Horizon based claims
we currently handle."
20
(5) Pages 17 - 20
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
>
oP
prop,
prop,
The Post Office Horizon IT Inquiry
So you may be focused on the default judgment but
the class action was certainly playing a part in your --
Yes.
-- mind and work going forward?
Yes.
At that point, did you or anyone at Bond Dickinson have
a desire to become more involved in handling the wider
potential class action?
I don't believe so, not at that point.
Could we look, please, at POL00070480. This is
an attendance note dated 23 November 2005. We see on
the left in the second tramlines, it says "Name: Stephen
Dilley", and it says:
"I had a telephone conference with Tom Beezer and
Mandy Talbot."
So this is Stephen Dilley's note of that?
Agreed.
Would you have seen that at the time or not?
No. I have seen it since.
So, at this stage, default judgment hadn't been set
aside?
No.
If you just read, as best you -- well, as much as you
need, points 1 to 5, would you agree those are all about
the substance of the case and not the default judgment?
24
-- and serve that as part of the --
I think that's what happens. If I'm wrong, I'm really
sorry but I think that's what's happened.
We then have point 6 about recommendations for counsel:
Richard Morgan, now Richard Morgan KC, who we know came
on to be counsel in this case.
Yes.
At 7, referring to Mandy Talbot, and you say there that
is to attend a hearing on 6 December. Now, that's not
a hearing for the default judgment application to be
heard, was it, because it was still being prepared at
this point?
I don't know but there is a file note on the file that
I read in preparing for hearing this that that hearing
gets vacated. I don't know what it is. Maybe you do,
I don't know.
Then as we carry on, if we go down, Mandy Talbot asked
a question at the meeting on Friday to ask whether
rebooting the system will change the cash accounts, and
then asked for a copy of the expert reports.
Would you accept that the conversation -- I know you
said this is about default judgment and preparation for
default judgment but it's also forward looking to the
substance of the case as a whole.
I -- yes, I suspect, yeah, I -- I think I agree with you
23
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
> oO
rPOPrPOP
12 June 2024
No, I wouldn't agree with that, because -- do you want
me to say why?
Yes, please do.
So the witness statements at (3), John Jones, Helen
Hollingsworth and Cath Oglesby, were the set aside
witness statements, I think. You've got to remember
we're going back 18 years here. I think those were the
witness statements in support of the set aside
application and so I think, in these early stages -- so
the question was: do all five relate only to the forward
facing actions in the case? The answer to that is no.
I think some probably do.
So as I understand what you're saying is the -
admittedly it is a long time ago --
Along time.
-- but, presumably for the purpose of overcoming the
merits test of setting aside a default judgment, rather
than simply putting the solicitor's witness statement,
your evidence is that you're going to obtain witness
evidence of fact --
Yes.
-- from the actual witnesses --
Yes.
-- in the substantive case --
Yes.
22
but what I think is going on here is Mandy and me
desperately trying to get up to speed. I think my first
substantive involvement is on 21 November, I think. when
I sent that note that you've shown me to Bob Heckford
after my first conversation with Mandy, when she told me
off. Mandy then says, "! want a full set of papers";
I say, "I want the same".
We've had a call with Stephen, I think it's
certainly in part -- and I probably would say in large
part -- about understanding what we can know with two
days' worth of exposure to this case about the merits.
At 3 we have the witness statements that I think are
going to be prepared to support the set aside
application and, at 9, we're talking here about
Mr Castleton's expert reports.
It was the Bentley Jennison one and the White
Hoggard or something like that, that had come in in
September before my involvement, I believe, and they
must have been mentioned on this call. So Mandy is
asking here for those expert reports that Mr Castleton
sent on a without-prejudice basis. We didn't have any
expert reports at this point.
Before we turn the page, was it your usual practice in
making an application to set aside default judgment to
lead witness evidence from some or all of the witnesses
24
(6) Pages 21 - 24
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
2
rPOoOPrPO>P
The Post Office Horizon IT Inquiry
you actually intended to call in the litigation, rather
than simply rely on a solicitor's witness statement?
I'm going to say something that I don't mean to be
jocular: I hope I don't have a usual practice in setting
aside default judgments but, at this distance, I don't
know, I just don't know. But this was our mistake, and
and me being the way I'm wired, the kitchen sink was
going to go at this to get that default judgment set
aside for what was an important client of our firm.
If we can turn the page, please, it says:
"Tom made it clear that we were to get counsel
involved at an early stage as [Bond Pearce] were picking
up the tab for rectifying the default judgment and he
wanted to go for a sledge-hammer approach."
Do you recall using the term "a sledge-hammer
approach"?
Not at all.
Is it wording you would use?
In that circumstance, probably.
What do you mean by that?
I mean my firm has made a mistake and, as a partner of
my firm, I'm going to get that mistake rectified.
Did the sledgehammer approach go to the overall conduct
of the case, not just the default judgment?
Not at all, and I've pondered that and I can answer that
25
attempts at settlement and there was no desire for
litigation.
Well, let's just look at this point. You're told at
this point that there's a potential class action in the
background; in your own words in the email before
a default judgment was "very bad news"?
Very bad news.
I assume that, at this stage, Post Office or Mandy
Talbot was saying that the Horizon system is -- has --
it's an -- sorry. Was Mandy Talbot saying to you that
there were any difficulties or problems with the Horizon
IT System?
Not at all.
Presumably, Post Office wished to defend any class
action at this stage?
Yes, I assume.
In this conference, it appears that you do touch on the
merits of the case?
Yes, because we are collating evidence to put in, in
support of the set aside.
So standing back from all that, in that context, is it
really your evidence that the sledgehammer approach was
purely limited to the default judgment or to dealing
with these Horizon claims generally?
It is my evidence that it was purely limited to default
27
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
12 June 2024
more fully if you'd like me to.
Please do.
We can see from later emails that maybe we will go to,
that, after the default judgment is set aside, there is
a definite pause and "What shall we now do", both with
Mandy and from the Bond Pearce side. So, once the case
is regularised, what shall we now do to take this
forward? And so the sledgehammer approach or the
kitchen sink approach isn't a comment about the action
in general and, in fact, it's worth just remembering
that, in November 2005, Stephen Dilley had already
suggested mediation to Mr Castleton's lawyers and, in
January 2006, before the default judgment was set
aside -- I think that's right, in terms of timeline --
a Part 36 offer had already been made. The offer of
mediation was rejected the very next day by
Mr Castleton's lawyers back in November 2005.
So there wasn't a set plan to have litigation here
at all. There was a set plan in my mind to get rid of
a default judgment, absolutely, yes. But sledgehammer,
call it what you will, I was going to do everything that
I could to rectify my firm's mistake for my client. But
there was definitely post-post-set aside of default
judgment, which happened by consent, but quite late in
the day. There was a step back and reflect, further
26
judgment. I'm absolutely sure of that.
Could we look at, please, POL00119895. This is
a document that was sent to you relatively recently by
the Inquiry.
It was.
It's a note of a meeting this Inquiry has seen on
numerous occasions. My understanding is the attendance
list, there's no one from Bond Pearce on that list; is
that correct?
That's what it shows to me. I hadn't seen this document
before and I hadn't seen it come up in the Inquiry. It
was a new document to me completely when you sent it to
me.
I appreciate at this distance: can you recall Mandy
Talbot referring to a meeting such as this to discuss
Post Office's approach to cases that involve challenges
to the integrity of Horizon?
No.
If we turn to page 3, please, we see paragraph 14
there's a reference to Mr Castleton's case, scheduled
for 7 February. Your evidence is that, at this stage,
you weren't consulted, in respect of Mr Castleton's
case, about it being part of this broader strategy
meeting?
No, this is -- when is this, 2006?
28
(7) Pages 25 - 28
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
>
rPOoP.O
2
>
oP
prop
prop
The Post Office Horizon IT Inquiry
2005, sorry.
2005?
6 December 2005, so shortly after the conference note we
just ~-
So this is Mandy saying, on 7 February 2006, because the
date is not there, is it, so -- because this is December
2005.
Yes, it'll be --
So that must be something to do with --
I think it's a case management conference?
Was it, or is it to do with the set aside? Anyway.
Nothing turns on it.
Your evidence is that you cannot recall being consulted
about this meeting?
No.
Thank you. Can we turn, please, to POLO0070910. If you
could turn to page 3, please, that's perfect. Thank
you.
So now, further on in the chronology, this is
an email from Stephen Dilley to Mandy Talbot with you in
copy on 20 February 2006. If we look at number 1, it
says:
"[Post Office's] view of pursuing the claim in the
light of the favourable evidence from John Jones, Cath
Oglesby and Helen Rose ...”
29
Yeah.
-- which is suggesting pursue the claim --
Yes.
-- and, on the other hand, balanced against that, or not
pursuing it, are broader concerns over Horizon issues?
Yes, it says that but I can't be put that into context
for you.
You can't recall because, obviously, you were dealing
with this case to provide reassurance to Post Office?
Yes.
You presumably discussed it with Mandy Talbot since
November --
Yes.
-- and February?
Absolutely.
Can you recall being told anything about concerns about
Horizon issues, broader concerns about Horizon issues,
which would, in your view, lean the Post Office in
favour of not pursuing Mr Castleton?
No, I know Mandy Talbot was concerned that there was
a case that was an issued case that had a counterclaim
for £250,000 that had a challenge to Horizon in the
defence, and so that might be the broader concern. She
was absolutely concerned about that. But that’s against
the background of my understanding and I believe Mandy's
31
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
12 June 2024
So causing there, those are witness statements in
relation to Mr Castleton's case in particular --
And they were the ones in support of the set aside
application.
Mr Dilley's view is that's in favour, in effect, of
pursuing the claim against Mr Castleton?
Yes. He's saying -- I mean, the Inquiry has heard from
Mr Dilley already but my understanding from reading the
file is his view of the merits of the case improved in
the collation of the evidence for the set aside, and
what he's saying here is, in his view, there's
favourable evidence from those three witness statements
that was got in support of the set-aside application so
I think his view -- my reading of the file -- improved
on the merits of the case.
He says:
"... balanced against any broader concerns over
Horizon issues ..."
Is that talking about the potential class action?
I suppose the straight bat answer is I don't know what
was in his mind but that may be. That may be.
Sorry, I'm not asking you about what's in his mind. Let
me rephrase it in another way. At this point, reading
this, do you suggest that, on the one hand, there's the
evidence in the case --
30
understanding that Horizon was robust, to use a word
that we've heard many times.
Can we turn to page 1, then, please. This is Stephen
Dilley to Julian Summerhayes on 24 February and says:
"Since my last email, I have spoken to Mandy to
agree the strategy moving forward."
Do you recall if you were involved in that
conversation as well?
I don't know.
"Internally, the [Post Office] feel conflicted about the
Castleton case. The [Post Office] believes to be the
Horizon system is robust but the downside is the cost
(in [Post Office] time and money) of proving a negative
(ie that there are no faults) is expensive."
It goes on at (2):
"However, her view is that the [Post Office] must
not show any weakness and, even if this case will cost
a lot, there are broader issues at stake other than just
Castleton's claim: if the [Post Office] are seen to
compromise on Castleton, then 'the whole system will
come crashing down’ ie it will egg on other
subpostmasters to issue speculative claims. She knows
that Castleton is talking to Bajaj (the other
subpostmaster bringing a Horizon based claim). Her
clear message is that we must be seen to take a firm
32
(8) Pages 29 - 32
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
oP
p>po>
The Post Office Horizon IT Inquiry
line. With this in mind, our instructions are as
follows ..."
Can you recall if, at this point, you thought there
was a change in approach to Castleton based on wider
concerns to do with Horizon, from -- I should say,
sorry, change in approach from Post Office?
No, no, and so we tried to mediate in November, we'd
issued the Part 36 in January 2006 and there were --
absolutely right, Mandy had broader concerns, as is
displayed quite clearly here. But once a case is issued
and once a counterclaim is issued, you can't get rid of
it unless you settle it or unilaterally walk away.
I think we're talking at cross purposes. So, in the
first email from Stephen Dilley, we had, on the one hand
the evidence in the case from the witness statements was
suggesting go ahead --
Yes.
-- and, in his view, on the other hand, broader Horizon
concerns --
Yeah.
-- saying try to settle it?
Yes.
Here we have an email saying, well, actually, at
number 2, the broader concerns is a reason to pursue the
case, even if it costs a lot. Was that a change in
33
counterclaim. What do we do? We've got to get rid of
this. We've got to try to settle it.
If someone is trying to simply settle a case, just
because, for the reasons I think you said earlier,
publicity or whatever it might be, you adopt a different
litigation strategy to those types of cases, than you do
to, for example, a test case where you're trying to make
a point irrespective of the cost. Would you accept
that?
As a proposition, yes, I would accept that, I think --
I think.
So, in this case, are we seeing here a change from your
firm thinking this may be a case to settle to, "Well,
now we're going to litigate it and treat it as a test
case"?
We tried to settle it throughout, all the way through.
The Inquiry has Stephen Dilley’s long witness statement
and I can picture the table in it that sets out every
attempt at settlement. Post Office wanted to settle
this case. The counterclaim, the £250,000 counterclaim
that sat there as a poison pill was only stepped away
from and dropped to about £11,000 on 7 November 2006,
and that was about a month before trial, and so that was
held on to all the way through, which created huge
problems: how do we get rid of this? Mr Castleton held
35
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
2
12 June 2024
position from Post Office?
I don't read it as that. They're sort of veins of
thought that go through this difficult situation. We
have some issue proceedings. You can't magic them out
of existence. Unless you settle it, which of course
is -- it needs consent of both parties or unless you
unilaterally discontinue -- pay the costs -- you're
still left with the counterclaim of £250,000.
This is a difficult situation that the Post Office
has become locked into and, in fact, if we read on, the
very next step, "With this in mind, our instructions are
as follows: Please can you draft a Part 18 request", now
that Part 18 request was March 2006 and was, I think,
completely directed at what is the problem, what's the
defence, what is the allegation over Horizon, because we
didn't know. We wanted further information. We weren't
trying to avoid engaging with that in any way. We
actually wanted that information. So the very next
thing Mandy says is "Go and get information. Let's try
and get some clarity here".
We wanted to move this case forward. It's
a problem. We as a firm have had a default judgment
entered against our client. That's now sorted. That
still lurks in this case as a sensitivity. There are
issued proceedings. There's a vastly inflated
34
on to that overinflated counterclaim, which I think
actually sat in the hands of a company, really, if one
looks at legal entities.
Well, we have your evidence on that. Let's look at how
the strategy developed in those months, in March. Can
we look at POL00071202, please. Can we turn to page 9.
I think this is a hard copy document, which is why it's
presented like this, but we see there's an email, top
left, from Mandy Talbot, is date is 1 March 2006.
There's Post Office addressees there and then, in the cc
list, this has been sent to you and Stephen Dilley?
Yeah.
It says:
"I write further to the meeting in December 2005
which most of us attended to bring you up to date with
the current state of play."
I think that refers to the note we showed earlier
but you weren't in attendance at?
No.
Do you recall receiving this email?
No, I don't think -- I only saw this very recently when
the Inquiry sent it to me. So it's a new one to me,
other than it was sent to me 18 years ago. I've only
seen it recently.
Can we look at, then, page 6, please. This is further
36
(9) Pages 33 - 36
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
The Post Office Horizon IT Inquiry
‘on in the chain, it appears to have been printed by
Stephen Dilley at the top
Yes.
~- from Mandy Talbot to him and you. If we go down,
please, to where it says, "Both", it says:
"I copied you into my epic email on 1 March 2006 but
the response to the same has been limited in the
extreme."
It goes on to say:
"I have also been contacted by John Cole asking for
assistance in preparing a spec for an external expert or
experts but I think that this is of limited use until we
have reports completed by Fujitsu on the system and [the
Post Office] on the data provided. However in respect
of an external expert from the field of computer systems
and accounting can you suggest any names or firm who may
be suitable?"
Can you recall at this time being involved or
instructed by Post Office to find an expert to assist
with Horizon claims generally, not just in relation to
Mr Castleton?
No.
Can we please bring up POL00070850. This is
a conference note on 7 April 2006. You're in attendance
and lan Herbert of Hugh James, the firm we heard from
37
I'm not sure because I think, at the early stage of the
Castleton case -- and I'm going to class April as
an early stage -- I think there was a -- there's
a letter that Stephen wrote to Fujitsu in the early
stages that suggests they might give an expert report.
Now, with hindsight, that's misconceived because Fujitsu
is too close to be an independent expert, so --
Just pausing there, you say "with hindsight", if you
look at the fourth paragraph, it says:
"Tom Beezer explained that if Fujitsu were not going
to put forward an expert, we would need to take Fujitsu
through questions we have for them."
Okay, so I have already got there: they're not going to
be an independent expert. Okay, that's right, but there
had been a notion early in this case that Fujitsu could
be a Part 35 expert and I think that was misconceived
and I've clearly got to that place here. So, yes, that
must have been attending to get witness statements of
fact from Fujitsu.
So it says:
"The information we get from Fujitsu will not be
an independent expert report ..."
It says:
"We will need to obtain a separate independent
report as well, but this will be easier if we have
39
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
12 June 2024
earlier, dealing with what was described as the
embryonic class action. So was this conference to deal
with strategy or consistent strategy on how to deal with
Horizon related claims?
I think this is the call that Mandy has asked the two
firms to have. I think that's what's going on. What
date is this?
7 April 2006.
Mandy wanted there to be some interaction between the
two firms in dealing with cases of a similar nature.
That's absolutely right.
So it refers to a discussion between you, Stephen Dilley
and lan Herbert, before Mandy Talbot joined. It
referred to Post Office having:
"... difficulty obtaining information from Fujitsu
and that the strategy should be to identify key
individuals at Fujitsu who could provide the relevant
information we require in terms of evidence and then for
Stephen Dilley of Bond Pearce and lan Herbert of Hugh
James to make an appointment to visit those individuals
... to take Proofs of Evidence. Each solicitor could
prepare witness statements for their respective cases
for Fujitsu to sign, thereby making it easy for them.”
In broad terms, was this proposition here to get
evidence of fact from Fujitsu witnesses?
38
Fujitsu's evidence first because then we will be able to
focus the independent expert's report (which [the Post
Office] will need to pay for) on relevant issues.”
Then it goes on to refer to more generic issues of
negotiation between Slaughter and May relating to the
Horizon Online contract.
Now, where you're talking about a separate
independent expert report here and it says, "We will
need to obtain", is that across the board as
an independent expert report, generic report, going to
the integrity of Horizon?
No. I don't believe that. That's a new concept on me.
So, with 18 years passing, it's hard to be absolutely
definitive but at no point have I ever thought we would
get a one-size-fits-all. I don't believe I ever thought
that. I think the "we" here in Stephen Dilley's note --
remember it's his note -- is us, Womble Bond, not
a joint -- I believe that's right.
Were you involved in -- because you obviously had client
care responsibilities in oversight?
Yes.
Were you involved in discussing evidence in the
Castleton case with any representatives of Fujitsu?
Me?
Yes.
40
(10) Pages 37 - 40
ONOaARWN
1
12
13
14
15
16
17
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
o>
>
‘SIR WYN WILLIAMS:
The Post Office Horizon IT Inquiry
No.
Were you involved in discussions with any representative
of Fujitsu about the Horizon IT system generally?
Before preparing for this Inquiry, I would have said no.
I see from the file I did attend a meeting at counsel's
chambers where Anne Chambers was present and there must
have been a discussion but, before preparing for this
event, I would have denied that even took place. So
I've got no memory of it. I clearly met Anne Chambers
once. I don't believe I ever spoke to anybody from
Fujitsu at any other time.
Just on that, so I cover this off, I take it from your
evidence that if were to ask you any questions about
a meeting with Anne Chambers you would simply point me.
to the attendance note of that?
I would.
Could we look at one of the draft --
Actually, sir, looking at the time it may be a good
time to take our first morning break.
(Microphone muted)
MR STEVENS: Sir, I think you're on mute, I think.
‘SIR WYN WILLIAMS: How much longer have we got on
Mr Castleton?
MR STEVENS: Not very long at all.
SIR WYN WILLIAMS: Well, let's finish Mr Castleton and then
2
>
41
double entry is not being put through."
You say in your witness statement that you were
initially concerned by this?
Yes.
Why were you concerned?
Because if there is a problem with the system, that is
concerning in the case.
These are small numbers.
Yes.
But the fact that Horizon wasn't adding transactions or
the allegation appears to be that double entry
accounting wasn't being put through, that's quite
a significant issue for Horizon integrity altogether,
isn't it?
It would be.
Can we look at POL00069612. This is a note of
a telephone call on 6 September 2006, so two days after
that report has been received. Again, I understand this
is Stephen Dilley's note?
Yes.
It refers to a conversation with you and says:
"Also Tom [expressed] his concerns that the expert
said that they found some early indications of possible
problems
It refers to the problem we've just described. It
43
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
12 June 2024
we'll have a break.
MR STEVENS: Ofcourse. Can we look at POL00081490_008.
This a letter of 5 September 2006 to Stephen Dilley from
Michael Mason of BDO Stoy Hayward LLP. They had been
instructed to provide expert evidence subsequently not
relied on in the proceedings.
A. Yes.
Q. Yes. Can we turn to page 3, please, and if we could go
to the bottom, please. Under "Early indications of
problems with the Horizon system", it says:
"We have found that there is some indication of
possible problems with Horizon from our initial review
of the electronic information you sent us. You sent the
transaction summaries for January, February and
March 2004. In theory the system should reflect the
double entry nature of each transaction, eg the system
should show the sale of a stamp and the receipt of the
cash paid by the customer. Therefore the Horizon
transaction entries for a period (whether day or month)
should total zero. From our initial review we can see
that March balances but January is out by £2.47 and
February by £4.05. We have found which transactions
cause the differences and will investigate them in due
course. Although these are very small amounts they do
indicate that some problems may exist, ie that the
42
says:
"My comment to Tom is that I thought those amounts
were quite small and that there will probably turn out
to be a rational explanation because I have met with
Fujitsu and they are utterly convinced of the integrity
of their system and really it is just an electronic
calculator so it is only as good as the person who
inputs information into it."
Did that assuage your concerns at the time?
A. Toadegree. We've got to remember the 5 September
letter 2006 from BDO was their initial letter; they
hadn't done their work; they hadn't prepared a report.
It was more than a passing comment but it wasn't their
concluded view. They had yet to do their work and so,
in this case, as you may know if you've looked into the
history of it, there were lots of blind alleys and lots
of issues that were chased down unbelievably diligently
by Stephen Dilley, for example the Greg Booth
screen-freezing issue.
Q. Well, let's focus on this one?
A. Yeah, for sure, but what I'm saying is we chased down
issue, after issue, after issue. We were diligent and
forensic. This was a comment from BDO before they'd
done any work and it's against that background that
I would have been thinking about these things.
44
(11) Pages 41 - 44
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
oP
prop
The Post Office Horizon IT Inquiry
Well, let's assume this analogy or comparison with
Horizon being an electronic calculator, let's be
favourable to Mr Dilley and assume that's accurate.
Would you agree that for an electronic calculator to be
fit for purpose, it should be able to add up numbers
accurately?
Yes.
So the fact that addition errors were potentially found
by BDO, Mr Dilley's point about it being an electronic
calculator doesn't really take anything anywhere, does
it?
I think you're probably reading too much into
an internal filenote but I agree with you: an electronic
calculator would have to work.
If we look at the third paragraph, it says:
"Agreeing with Tom that the strategy should be that
we pick up the phone to Lee Castleton's solicitors,
point out to them that Castleton has made an error
analysing the cash account ... tell them what our
accountancy expert alone is going to cost and invite
them to ADR before we instruct an expert."
Was this a strategy to try to dissuade Mr Castleton
from obtaining expert evidence on the basis of how much
it would cost?
No, we wanted to understand the defence being put.
45
It does.
Over the page, 6.2.4:
"I do not have an explanation for these errors but
my review of the transaction listings for the three
months has given no indication of any other errors."
Can we then go to page 4, please, and
paragraph 2.1.2(a), summarising the conclusion:
"The only indications of possible computer problems
that are apparent from the accounting records are three
very small differences in the cash account (trial
balance) but each are less than £5. This is discussed
in section 6.2."
So you get the draft report on 29 November and this
addition issue is still raised?
Yes.
So the problem is still there. It's possible or it's at
least raised that Horizon in this case wasn't
implementing double entry bookkeeping?
It's possible.
Did you discuss the BDO report with anyone at Post
Office?
I don't remember but I suspect the answer is yes.
Who would you have discussed it with?
Mandy Talbot.
Anyone else?
47
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
prop
PppoPrpopr
12 June 2024
There was a real desire to get information from
Mr Castleton. We'd Part 18ed in March 2006 on exactly
that point, to try and get information.
Well, let's focus here though, you'd received
an additional letter from an expert that raises
potential problems and the immediate response appears to
be to raise the costs of an expert and go to ADR. Was
it actually the strategy that you didn't want to dig any
further into --
Not at all.
-- into what BDO had found?
Not at all. Not at all.
Can we look at the draft report, this will be the last
question we ask on this. POLO0069955, please. This is
a draft report dated 29 November 2006.
Yes.
Did you receive this?
Yes, I will have done.
Would you have reviewed it?
Ata high level, given the circumstances and the
imminence of the trial, but yes, I will have looked at
it yes.
Can we turn to page 18, please, and if we could go down
to 6.2. We see "Addition errors", and it refers to the
same addition errors as before.
46
I doubt it. No, I would have been speaking only to
Mandy at this time.
Did you discuss the BDO report with anyone at Bond
Pearce?
Stephen Dilley.
After the Castleton case had come to an end, did you
speak about the BDO report with anyone at Bond Pearce or
Womble Bond Dickinson?
No. So that BDO report, just to give you some context
around it, contained one huge glaring error that I knew
about, which has become called the 3,500 point, that was
a glaring error, and that BDO report was a draft report.
It was dreadfully late. It was after all evidence --
expert evidence has been debarred. It had a huge error
in it and it was six days before trial.
There was no time to have the normal toing and
froing that would happen on a draft expert report to
bottom out issues. I simply don't know what would ever
have happened to those small addition errors, as to
whether they would have remained in that report or not,
but no work was done to find out because it was
pointless. The report was privileged, there was no time
to do it. I'd lost confidence in the report, because it
had a huge error in it already, the duplication error,
the 3,500 point, and we were debarred by the order of
48
(12) Pages 45 - 48
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
The Post Office Horizon IT Inquiry
Mr Justice Seymour QC (sic) on 27 November, at which
point we had still been wanting to try to get some
expert evidence in. We were not running away from
expert evidence at all. That expert report was meant to
be in reply to something Mr Castleton was meant to have
served on 10 November. He never served it, although we
know he had it because his solicitors told us, on
17 November, that he had an expert report but they were
not instructed to send it to us.
And so that draft document was meant to be
sequential. It was never meant to be a standalone
document. It was late, it was debarred. It was wrong.
I know it was wrong, in huge degree, and so it was
debarred. We couldn't use it.
Q. You said you know it was wrong in huge degree. You're
referring to a point about £3,500 --
A. Yes --
Q. -- at trial and a balanced snapshot?
A. Something like that, yes.
Q. You didn't know that the addition errors raised -- their
position --
A. No, we didn't but there was no time to bottom out those
kind of issues as you would do with any normal expert
report.
Q. Atthis stage, you were aware that Post Office was
49
A. I just don't know.
MR STEVENS: Sir, that's a good time to break and we'll move
‘on to the recusal next.
SIR WYN WILLIAMS: Right, thank you very much. I make it
11.05. Do we need to be as limited as ten minutes,
given that we have just got one topic to cover before?
What's the timetable, Mr Stevens? Is Mr Lenton coming
in this afternoon or is he available before that, so to
speak?
MR STEVENS: I understand he's available before that.
SIR WYN WILLIAMS: Right, I see.
MR STEVENS: I'm in your hands, sir. I'm happy to take ten
minutes or happy to take 15, whichever you prefer, but
I don't think we're pressed for time.
SIR WYN WILLIAMS: Right. So let's take 15 minutes but it's
‘on the basis that we might jiggle the day, so to speak.
We'll take 15 minutes and then, if we complete Mr Beezer
before 1.00, we'll make a decision about whether we
start Mr Lenton or have an early lunch then. All right?
MR STEVENS: Yes, sounds good. Thank you, sir.
(11.06 am)
(A short break)
(11.20 am)
MR STEVENS: Good morning, sir.
SIR WYN WILLIAMS: Good morning.
51
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
12 June 2024
relying on Horizon data for civil and criminal claims?
A. Yes. Well, certainly civil. Certainly civil. I don't
know what they were doing in criminal claims.
Q. You were aware that there were other cases where
subpostmasters were challenging the integrity of the
Horizon IT System?
A. Ata high level. I mean, I knew of them. I didn't know
any detail.
Q. You had a report that raised a potential issue with
double entry bookkeeping in the Horizon IT System?
A. Yes, but for all the reasons I've just been through it
went one we were confident in.
Q. Buton the addition error, you couldn't say that was
an incorrect opinion?
A. Nor could I say it was correct but, yes, I agree with
you.
Q. Do you accept that it was incumbent on you to advise the
Post Office to investigate that issue further because
there were other -- it would have started a train of
inquiry as to whether the Horizon IT System lacked
integrity?
A. I don't know that I didn't say that, I don't remember.
I will have discussed it with Mandy.
Q. Let me ask you, is your evidence that you did advise
that or can you not remember?
50
MR STEVENS: On timetabling, I anticipate that we will
finish well in advance of 1.00. Whether we have
an early lunch or plough straight on, I think we'll need
to decide when the evidence is finished. I have spoken
to Ms Hodge and there's a couple of logistical matters
that need to be seen to.
SIR WYN WILLIAMS: Yes. Whatever, Mr Stevens. All I'm
indicating is my willingness to be flexible in the way
we deal with these things.
MR STEVENS: Thank you, sir.
I will carry on, then. I want to turn to the
recusal application and, at this point, I'm going to
make a point, almost word for word, that was made by
Mr Beer yesterday. The authoritative legal position in
relation to the issues addressed in the Group Litigation
are set out in the judgments of Mr Justice Fraser -- now
Lord Justice Fraser but, for historical purposes, I'll
refer to Mr Justice Fraser -- so, for the purpose of
your evidence, those judgments include the Common Issues
judgment of 15 March 2019; the recusal judgment, 9 April
2019; and, insofar as relevant, the Court of Appeal's
decisions refusing permission to appeal those. I'm not
going to be exploring the factual legal position
definitively established in Mr Justice Fraser and the
Court of Appeal's judgment.
52
(13) Pages 49 - 52
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
2
The Post Office Horizon IT Inquiry
Understood.
You say in your witness statement that you were broadly
aware of the GLO proceedings but that you didn't have
any material involvement until the recusal application?
Yes.
Now, this was Andrew Parsons' case, effectively, wasn't
it, the GLO proceedings?
Yes.
You hesitate there. Why wasn't it Andrew Parsons’ case,
as solicitor?
Yes, it was but there were other people involved -- the
run in to the GLO was -- took some time and there were
other people involved. So was Andrew Parsons the lead
person? Yes, I think he was, if that's the question
you're asking.
Yes, he was the partner with responsibility for the
conduct of the case?
Yes -- sorry, yeah, I was talking about a different
issue.
In terms of the management structure of Womble Bond
Dickinson, during the currency of the Group Litigation,
where did Mr Parsons sit in relation to you?
So the Group Litigation started in 2016?
It did, yes.
So I was a partner in the Southampton office. I was the
53
a huge surprise to the internal team at Womble Bond. So.
the mood music about the Common Issues trial pre-8 March
was not negative.
I take it from that that no concerns had been raised
with you about the impartiality, apparent or otherwise,
of the judge, before 8 March?
No.
In your second witness statement -- we don't need to
have it up but it's page 5, paragraph 9 -- you say:
"I understood from the Womble Bond Dickinson GLO
team that the draft Common Issues trial judgment was.
very unfavourable to Post Office, that the Womble Bond
Dickinson team and Post Office were dismayed by the
outcome and that there was talk of a possible urgent
appeal."
Who within Womble Bond Dickinson told you about the
Common Issues trial judgment?
It would have been Andrew Parsons, Amy Prime, those kind
of people. I can kind of picture them sitting, the
judgment on their knees, turning the pages getting more
and more distraught, as it were. So I can picture that.
It was --
What did they say to you?
Oh, I don't know. I don't know in detail, "This isn’t
good", "He's got that wrong", "Oh, my God", you know,
55
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
12 June 2024
team leader of the Commercial Disputes Team and he was
a partner in the Commercial Disputes Team.
Did you have any oversight of Andrew Parsons's work at
this stage?
Not his work. I mean, I had oversight of the team and
the things going on the team but day-to-day work, no:
concern over day-to-day work, yes, absolutely. So I'm
not using that answer to try to step away from anything
but would I check another partner's work? No.
For background, Mr Justice Fraser distributed a draft
judgment in common issues on 8 March 2019?
8 March, yes.
The Horizon Issues trial was due to start on 11 March
2019?
Agreed.
What had you heard from members of Womble Bond Dickinson
who worked on the GLO about how the GLO proceedings were
going, in effect, prior to the common issues draft
judgment being distributed?
I had heard positive -- I was going to say positive
signs. You can't hear a positive sign. The mood music
was okay. It wasn't -- if the question you're asking
is, from a management perspective, me, was this a case
that was flagging up as a difficulty pre-Common Issues
draft judgment, it was not, and so the judgment was
54
those kind of comments. But those aren't verbatim
quotes.
When was the first time you were aware of the
proposition to issue or potentially issue an application
for an order that the judge recused himself?
So the first it was either the 11 or 12 March but which
‘one, I don't know. I was provided some papers on
11 March, I think in that tranche of papers was the
David Cavender note on 10 March, I think, and I think
that included a paragraph on recusal so I'm going to say
11 March.
I think in your witness statement you say -- we don't
need to have it up -- at paragraph 14, page 7, to the
best of your understanding, the idea of recusal came
from David Cavender KC?
I think that's right. There's an email of 9 March,
where I think its first raised by him. I'm not copied
in on that, I'm not involved at that stage. But that,
to my knowledge, that's the first time in this matter --
reading in and preparing for this Inquiry, that's the
first time I've seen that the recusal is mentioned.
You were brought in to assist on the recusal application
because the rest of the GLO team in Womble Bond
Dickinson were preparing for the Horizon Issues trial;
is that right?
56
(14) Pages 53 - 56
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
The Post Office Horizon IT Inquiry
Yes, not all of them. Some were working on the further
issues trial. So a nucleus of the Womble Bond Dickinson
team absolutely was preparing for the Horizon because
8 March was a Friday, there was an intervening weekend,
the 11 was the Monday, when Horizon Issues trial
started. So there was no time at all in which to do
anything, hence me being brought in as a senior person
in a point of difficulty for the client with a judgment
that's gone against them.
To what extent, if at all, do you think your lack of
familiarity with the GLO proceedings limited your
ability to advise on the recusal application?
It must be a factor. I don't -- I did not have
familiarity with the GLO proceedings. That's absolutely
right. Was it an impediment? With what I was asked to
do rapidly, which is to get independent advice, it was
not an impediment to carrying out that instruction. As
I got more up to speed, I think comment was passed and
advice was given, although I have to say the client was
not after our advice, Womble Bond's advice, my advice.
They did not want that advice, they wanted new
voices -- you will have seen from the file, the phrase
"new voices" comes up quite a lot -- and independent
advice. So it must be an impediment on hour zero
because I know nothing about it but, as we go forward
57
Neuberger equals insight?
Yes.
"Only 2 days off SA", and this is, presumably, the note
you took of the conversation at the time?
It will be scribbled notes. It's not verbatim, it's
scribbled notes. Obviously this was done out of habit
as a lawyer. This isn't a verbatim note but, yes, these
are my notes of that conversation.
Was this the first conversation you had with Jane
MacLeod?
There might have been an earlier one, if you tell me
this is the first one I'll say yes to that but I can
picture one in blue ink that says “in-depth advice",
I thought that was the first conversation, but if you
tell me this is a later one.
Well, we'll come to another note. Let me rephrase my
question. On 12 March, was that the first time you'd
had some material conversation with Jane MacLeod?
Must have been. I've got documents on the 11th. I was
reading in on the 11th, trying to get up to speed and
the 12th is when I suspect I began to interact with
Jane.
Can you recall on this conversation, we see you're
talking about the instructing counsel --
Yes.
59
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
12 June 2024
‘over the intense few days, I knew more. In any event,
what the client wanted from me was organisation and
logistics to get independent advice from, as it turned
out, Lord Neuberger, and then Lord Grabiner.
I want to look at some of your early conversations with
Jane MacLeod in organising the recusal application. Can
we look at a conversation you had with her on 12 March
2019 and I want to bring up your handwritten note and
your transcript of it, just for ease. So can we have at
the same time, please, WBON0001734 and also WBON0001735.
Now, this is the first time -- we'll see a few of
these. We'll see this is a handwritten note, this is
taken from a notebook of yours —-
Yes.
-- and there are parts which are covered out in yellow,
which are redacted and the Inquiry understand that those
have been redacted for either privilege or relevance
reasons.
Agreed. And the redaction, I should say, is nothing to
do with Post Office. It'll be other clients or -- so
none of the redactions at all relate to Post Office.
Just so that's an issue we cover off.
Yes. So we see there 12 March 2019, it says "Jane
MacLeod" and then a redacted bit. Further down we then
kept, your note which says, "Neub = insight", presumably
58
-- what, if anything, did Jane MacLeod say about her
view of whether the Post Office should bring a recusal
application at this stage?
I think they were interested in the concept of
an application but trepidatious. That's reconstructing
what I think was going on. This is some good few years
ago now. It was a topic that had to be investigated if
there was legal purpose in doing it. That's my
impression.
Did, at this stage, Jane MacLeod say anything about Post
Office's motivation in investigating the recusal
application?
I don't know if it was in this conversation but my
impression -- one of the main planks of their
motivation, I think, was to get to a legally correct
Common Issues judgment. That's what I think was going
‘on. Whether that was said in this conversation or in
later conversations, I don't know. But that's my
impression of their motivations.
So we'll come to the later conversations but, just
taking that there, on what basis did you form that
impression from why that was Jane MacLeod's motive?
Because I suppose, and this me reconstructing, so on the
11th I'm reading in, there are two topics knocking
around. They're intertwined but not necessarily
60
(15) Pages 57 - 60
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
2
>
2
p>po>
The Post Office Horizon IT Inquiry
intertwined, being appeal of Common Issues judgment and
recusal, and the interconnection with those two topics
is large parts of the Common Issues judgment was
perceived to be wrong and perceived to be the judge, as
we've heard from Lord Grabiner, had gone too far. The
apparent bias point.
So in any early conversations with Jane, I must have
been talking about why we're doing any of this. Why
we're on this journey, to look at appealing, to look at
recusing the judge.
You say then "Neuberger = insight, only 2 days off SA",
and then it says “can assist but not be briefed in
person". What does that mean, "Can assist but not be
briefed in person"?
He either had gone, or was about to go, I don't know, to
what we now know to be South America, Argentina, but at
times we thought was South Africa.
So that's referring to whether or not he could attend in
person?
Yes.
Thank you.
Yes, face to face.
Could we please then turn to WBON0001739. So this is
your email to Andrew Parsons and Amy Prime --
Yeah.
61
like a recusal, you've got to get on with it, especially
with the Horizon Issues trial under way. This is urgent
and I remember being frustrated that -- I simply wanted
to know who we were instructing and to get on with it.
And there was prevarication about who to instruct and
I remember being really quite frustrated by that, and
I wanted, personally, to instruct -- and we might come
on to these topics later -- the advocate who could do
the advocacy, the barrister who could do the advocacy.
This two-staged approach, whilst, with hindsight, makes
sense, at the time it frustrated me because it's a time
impediment as to what I see as being urgent.
Just to be sure I've got your evidence right on this,
your frustration is a decision on who to instruct. Was
there any hesitancy from Ms MacLeod at this time as to
whether or not Post Office should even investigate --
No.
-- the recusal application?
No, I don't believe so. I don't believe so. There
wasn't a dead set plan to do it, the Board were nervous
but there was, I felt, some prevarication as to who to
instruct and I just wanted to get on with it, to find
out what the independent advice would say, yes/no, and
so there wasn't a concrete plan of any sort at this
point.
63
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
oP
oP
2
prep
12 June 2024
-- on 12 March at 8.23. You referred to a "Good chat
with GC Jane", and just timing it, you see the third
para down, you say:
"Issue I raised is inability to brief N QC .
Presumably that's Lord Neuberger?
Yes.
".. in person.”
So do I take it that this email follows the note
that we just saw then?
Yes. Yes.
It says:
"Think she begins to agree -- Grab."
Yes.
Is that referring to Lord Grabiner?
Itis.
When you say, "Think she begins to agree", what is that
referring to?
Instructing Lord Grabiner.
That reads almost like she needed to be persuaded into
it or she had a view and, you know, begins to agree to
the instruction of Lord Grabiner. Why is it written in
that way?
What I think is going on here is this is on day two of
my involvement. I'm -- knowing how I'm wired, I'm
perceiving urgency. If you're going to do something
62
Could we then turn, please, to WBON0001745. Fortunately
you've got a typed version, WBON0001747, on the same
screen, please. So this is a note on the 14 March 2019.
I'm going to work from the left one. It says, "Jane and
DCQC call", so that's Jane MacLeod and David Cavender?
Agreed.
When it says, "CC Gideon" is that referring to Gideon
Cohen?
Yes, but I don't know what the "CC" means because,
obviously, this wasn't a letter, so I don't know if he
was there or not. I've no idea.
Briefly looking at the document on the right, we have
black pen and then blue pen. The blue pen, it sort of
fits around the text that's already been written in the
black. Are both entries made by you?
Yes.
Presumably, the blue pen is made later?
Maybe not. I have many pens, a slight fascination of
mine, and multiple colours are habitual and changing pen
is a habit. So I can't say that that didn't happen on
that call.
If we look down, I'm looking at the left again, we see
halfway down two bullet points. It says, "Had LN note",
so that's referring to Lord Neuberger's note of advice,
I assume?
64
(16) Pages 61 - 64
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
>
oP
oP
p>po>
prop,
prpro
The Post Office Horizon IT Inquiry
Yes.
So the call happens after that?
Yes.
It says, then "Stages: 1. What does POL want to do?",
and "3. [Post Office Limited] not able to make
a decision by 12 tomorrow".
Yes.
At this call, do you recall if there was any discussion
of what the Post Office directors thought about whether
or not they should bring in application for recusal?
At this point, no, but this -- you will see that this
builds into the narrative that I'm frustrated -- "What
do you want to do?"
Did you have any impression at this stage of the Board's
position?
14th? No, I don't think I would have done.
If we could go further down, please. Thank you. So at
the bottom, it says "Board call", presumably that's
referring to the need to set up a board call?
It will have been, yes.
Now, help us with how this is structured, because we've
got a second bullet point saying, "Real possibly Board
to speak Neuberger -- possible outcomes"?
Yes.
Does that mean there's a real possibility that the Board
65
Yes.
It records, I assume, what she said, "Tom Cooper,
Chairman, setting up Board call [for] Monday night"?
Yes.
“Board to form a view"?
Yes.
Do you recall whether anything else was said, at that
stage, on the Board's view or individual director's
views?
No, this is me, I think, probably, in that way lawyers
do, jotting down bits of information, as they're given.
This is Jane MacLeod speaking to me, telling me things
and I'm scribbling them down out of habit.
It says, "Tom C", so that's Tom Cooper?
Yes.
Tom Cooper was a UKGI official?
I believe so.
He was the Non-Executive Director appointed to represent
the Government Shareholding interest?
I believe so.
It says, "Tom [Cooper] will struggle to get this through
Shareholder". So in that, "shareholder" means
Government?
I think so, yes.
Do you recall what Jane MacLeod said to you that led you
67
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
>
prop,
12 June 2024
want to speak to Lord Neuberger about his advice?
I suspect this is Jane speaking, saying, well, to take
this forward, we're going to have to have a -- POL will
have to have a Board call. POL will need to take this
issue to the Government but -- that's little number 2 --
and there's a real possibility POL's Board will want to
speak to Lord Neuberger about possible outcomes. So
that - my impression, as I sit here now, is that's me
capturing what Jane is saying.
Okay. What was said at this stage, if you can recall,
about government's involvement in the decision to -- of
whether or not to issue the recusal application?
I think at this stage, Jane is saying, "I will need to
get the Government involved". I think that's all that's
going on at this stage.
Could we --
This is the 14th, yeah?
14th, yes. We'll look at the next day now, please,
WBON0001749 and, at the same time, could we have
WBONO0001752, please. So assuming that means telephone
call in --
Yes.
-- from Jane?
Yeah, she's called me.
She's called you?
66
to make this note?
I think that's what she will have said. This is me
scribbling down -- I will not have really known at this
point, who Tom Cooper was. I probably, had I turned my
mind to it, would have understood the ownership
structure but this is Jane saying things to me and me
writing them down.
You've said that you were -- I think frustrated was the
word you used --
Yes.
-- it may not have been but it conveyed that meaning --
of getting a decision.
Yes.
This presumably, then, wasn't welcome news, if there's
going to be a difficulty to get it through the
shareholder?
It's only unwelcome news if you're going to go for it.
If you're not going to go for it, it doesn't matter
either way.
Did you enquire as to why she formed that view that Tom
Cooper would struggle to get it thorough the
shareholder.
No, the Post Office relations with the Government and
its shareholder, being the Government, were something
I didn't get involved in. We never had substantive
68
(17) Pages 65 - 68
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
2
The Post Office Horizon IT Inquiry
discussions about that, beyond these kind of, I suppose,
why is she telling me this? I suppose it's a timing
conversation this, isn't it? This is all about timing.
Then it seems it refers to a brief note over the
weekend. That's a note to the Board that you assisted
in preparing to explain --
She is asking us. It became called -- she wanted
a plain English note, I think she called it. So I think
Jane is saying to me "I'm going to need a note over the
weekend for the Board", and that's indeed what happened.
Yes. So this is about timing and steps on the way.
I want to just cover the timing of the note a bit
because I think it's relevant to understanding how that
note was formed and what your instructions were. Can we
look, please, at WBON0001499 and page 4, please. Thank
you. If we could go down the page slightly. Thank you.
So your email to David Cavender and Andrew Parsons
is included in copy, "See attached":
"I may be on Jane's wavelength -- I may not be ..."
So this is attaching your initial draft of that
note --
Yes.
-- that she asked for. You said:
be as harsh as you like."
69
know there are competing views around the Board so
I don't want us looking fully partisan."
At that stage, what were you aware of the competing
thing views around the Board?
I don't remember and so, reading this, I must that have
known something to write it. I cannot recall what
I knew about competing views. I just don't know.
Can you assist with this and if this is a fair reading
of that email: what you appear to be saying there is
your current feeling was not to expressly set out, "We
recommend you do this"?
Yeah.
But your view was the substance of the note as
drafted --
Yeah.
-- pushed them in a direction to recuse anyway?
Yes, because -- we mentioned earlier the interconnection
between the appeal on the law of the Common Issues
judgment and the connection with recusal, which is
driven by the procedural unfairness point. So if they
were going to go forward with a head of appeal based on
procedural unfairness, for reasons we might not need to
go into but you'll be aware of, that there had to be --
or it was felt at the time there had to be
an application to recuse.
ral
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
pero
12 June 2024
You're inviting comments, basically?
Yes.
If you go to the bottom of page 3, please.
I'm inviting comments because I'm aware of my paucity of
information and background on this. So I have broken
the back of -- everybody's busy, I thought I've broken
the back of this task and got something down on paper
and got it out to people to finesse.
Then it's Andrew Parsons's email to you, he attaches
another version. It says:
"Did Jane want us to offer a recommendation on
whether to do this or not? It seems like we are sitting
‘on the fence slightly, but sometimes she prefers that."
If we then go up to your response -- so just for
timing, that was Andrew Parsons sent at 11.50 pm on the
15th; your response is just before 4.00 in the
morning --
It was a busy time.
-- on the 16th. You refer to the drafting and then you
say:
“As to recommendations ... I am unsure. My current
feeling is we simply set matters out and then let [Post
Office] Board discuss rather than pushing them one way
(which the note already does to be fair, as it has to as
we have to point out the ‘inconsistency’ risk etc) as we
70
And so that's what I mean by the inconsistency
point. If you appeal on procedural unfairness but don't
try and recuse, the Court of Appeal may later say, well,
that's an inconsistent position to adopt. That's what
the inconsistency phrase is there. And I am saying,
because I know that Jane wants independent advice,
I know that she doesn't want our advice, hence me
drafting a neutral note, but it does have to push them
‘one way, because, if they do want to go down the route
of procedural unfairness, it's inevitable that you have
to promote the concept of a recusal.
If you could turn to page 1, please. So this is David
Cavender's email to you and Andrew Parsons. It's at
11.05 on 16 March, and the final substantive paragraph
says:
"On the issue of giving" --
Sorry, before I ask that: had you spoken, on the
telephone, not in email, to Jane MacLeod in between your
email of just before 4.00 on 16 March and David
Cavender's email?
I've no idea. If we don't have a note, I have no idea.
So Mr Cavender says:
"On the issue of giving [Post Office] a steer
l understand the sensitivity but [it should be
‘I think’] that advisers should advise and not simply
72
(18) Pages 69 - 72
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
>
The Post Office Horizon IT Inquiry
leave it to the Board to come up to their own untutored
view. Surely we should be setting out the options but
making our recommendation?"
We can go to the documents if you wish but, as
I understand it, that advice was accepted and the note
sent following that said that Mr Cavender and Womble
Bond Dickinson recommended that the application be made
as soon as possible?
Yes.
So you accepted that advice from Mr Cavender,
effectively?
Yes, and the amendments that the document were taken in,
and sent to Jane in mark-up, so she could see who had
done what.
Could we please turn to POL00022969. If we could turn
to page 4, please. So we have here an email from Jane
MacLeod, 16 March 2019 to you and Andrew Parsons. So
this is just before, I think a matter of ten minutes or
so, before Mr Cavender's email?
Yeah, okay, yeah.
It says, "Many thanks". It refers to a call with the
Chairman, Al Cameron, and the Minister, Kelly Tolhurst
MP:
although I don't believe that recusal will be
part of the discussion. I have been advised by the UKGI
73
has formed any views on this yet, and if so what they
are?
"The Board is highly nervous of this strategy (our
Chairman has already said to our Minister that while he
recognises that the Board has a fiduciary duty to act in
the best interests of the company, he feels it is
unlikely that they would want to adopt this course of
action)."
Just pausing there, the talk of fiduciary duty, had
there been any discussion of there being a fiduciary
duty on the directors to act, prior to this being
raised?
At that point -- because I know it came up later but
forcefully from Lord Grabiner.
Well, I want to come to that in due course?
I don't know if it had come up already. I don't recall.
It says:
"So we need to be very clear on both why doing it is
the best course of action, and what our prospects of
success are."
You said:
"Jane
“I'll call in 20 minutes."
Now, you recently and helpfully provided another
note --
75
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
12 June 2024
[General Counsel] that ‘government will not express
an opinion on recusal as they will not want the
‘executive’ to be seen as criticising the ‘judiciary’.
"This will put more pressure on our Board, and the
Chairman is acutely conscious that such an application
will not sit well with the perception that [the Post
Office] is arrogant, whereas we are trying to edge
towards ‘contrition’.
"The effect of that is we need to be very clear what
the risks will be of not proceeding with the application
It goes on to set out what she wants.
Yes.
Had you communicated the content of that email to David
Cavender before he sent his email recommending that
a position should be taken on how to advise?
If the -- I don't know, is the straight bat answer. If
the file doesn't show I did, I simply don't know. It's
the kind of information I would have circulated but I'm
unsure as to the timing.
Can we move on actually, please, to POL00330036. If we
go down, thank you. So this is an email later on that
day:
it would be helpful to have a call on this, and
in particular ... to understand whether Lord Grabiner
74
Yes.
-- which I want to go to now. For our Core
Participants, it won't be on CPview(?) yet, it was very
recently provided. That's no criticism but can we turn,
please, to WBON0001899, please, and the typed version
that you've created, WBON0001900. Is this a note of the
call that we were referring to in the email just now?
I suspect so but I don't time these scribbles so, I'm
sorry, but I suspect it may well be.
Do you recall what, if anything, Jane MacLeod said about
the Board or the Chair's concerns about the recusal
application?
No, other than as I've said, they were trepidatious
about -- they were nervous about making it.
Do you recall if anything was said about the
Government's position on the recusal application?
Beyond the emails that we've seen saying that they would
be neutral, no.
Please could we -- it's either scroll down or turn over
the page. I don't have a printed copy.
I think it's scroll down on my note.
Sorry, is there a second page to that document? Yeah,
thank you.
So it says here "BIG PIC": big picture, presumably?
Big picture.
76
(19) Pages 73 - 76
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
>
POPS
pPrPoPro
The Post Office Horizon IT Inquiry
"Told Jane to Jane", what does that mean?
If we can get the handwritten one up, I might be ...
Yes, of course it's on the right. If we could turn to
page 2, please.
"Told Jane", so I suspect they're two different blocks
of conversation "Told Jane" and "to Jane loss all the
way through". So I think they're bits of different
jottings, if you see what I mean. So it's not one
sentence that says, "Told Jane to Jane".
I see. So would it be "Told Jane" --
PR-
-- "PR v Trial"?
Yeah, and "To Jane loss alll the way through”. I think
if you can draw a line mentally down the centre of the
page in that part, anyway.
It says "PR v Trial loss all the way through.”
Yes.
"If not, recuse.”
Yes.
So is this what you were saying, you were advising or
telling Jane MacLeod?
By this stage, we'd had the Lord Neuberger note,
I believe, on the 14th. We were developing our note
that became the note of the 17th, and there was
a process of mutual drafting with Andrew, David Cavender
77
that time, we had decided on Lord Grabiner -- and she
wanted information in from those people. So even our
note that was drafted between the 15th and the 17th,
what she really wanted was what's Lord Grabiner's view
‘on that note? That's all she wanted.
Well, I am going to turn now to a conference with Lord
Grabiner. Now, you set out your recollection of that
conference in your statement. You've exhibited typed
and handwritten notes?
Yes.
We heard from Lord Grabiner yesterday and I don't
propose to deal with lengthy issues on that. I want to
cover two points, briefly. Could we please have
POL00006397. So this is a note of a conference on the
18 March 2019, and then this is the version that's
updated to include 20 March Board dial-in as well?
Yes, Jane wanted a compendium note, as it were, in the
end.
Can we turn to page 2, please? Thank you. So we have
"Duty to act":
“Lord Grabiner explained that in his view if there
is no recusal application made then Post Office will
lose the series of trials set up in this matter.
Without a recusal application Post Office is stuck with
this judge. An appeal on the law may correct some of
79
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
9
10
1
12
13
14 A
15
16
17 Qa
18
19
20
21
22
23
24
2
A
12 June 2024
and Jane herself, and there was the view that, if the
judge remained in place, there was risk to the coming
trials due to the view of apparent bias and entrenched
views.
So it then says:
"High tempo step.
"Jane warned.”
Yeah.
What does that mean?
So that's -- so -- and, if you recall, the red ink note
that we saw earlier, that also had the "PR" bit in it.
So this is my shorthand to myself. I'm warning Jane
about the risk of -- in doing this, "This is a really
aggressive step, Jane, the PR of doing this. So it's
a high tempo step. I've never done this. I've never
had cause to do this in my whole career, Jane. This is
unusual step to take, its high tempo"; that's me warning
Jane.
At this stage, what was your impression of Jane
MacLeod's view of whether or not to pursue the recusal
application?
I think she was -- well, I know she was seeking
independent views. To be blunt, she couldn't care what
I thought. She wanted the views of Lord Neuberger and
Lord Grabiner, or whoever we went on to instruct -- by
78
the very significant errors in the [Common Issues trial]
judgment but then the case will be sent back to this
judge, who has demonstrable apparent bias against Post
Office and hence the firm conclusion that Post Office
will lose and the financial impact of that will be
substantial. Recusal is therefore essential and Lord
Grabiner asserted that in the face of legal advice from
Lord Neuberger that recusal should be applied for and
the quantum of damages that Post Office will pay out on
a loss, then it was Lord Grabiner's view that there was
a duty on Post Office to seek recusal."
What did you understand from that point: that there
was a duty on Post Office to seek recusal?
So to act in the best interests of the company is what
I think I will have taken at that point, from that word,
"Duty to act".
Was your understanding of the advice given by Lord
Grabiner that there was a legal duty to apply for
recusal, or something else?
I don't know and I don't know how hard I would have
turned my mind to that question. Duty to act in the
best interests, did that tip over into the legal meaning
of that in that conference? I don't know. I don't
know.
25 SIRWYNWILLIAMS: Can you tell me, Mr Beezer, this note is
80
(20) Pages 77 - 80
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
The Post Office Horizon IT Inquiry
on Womble Bond Dickinson notepaper?
A. Yes.
SIR WYN WILLIAMS: Someone obviously composed it. Do you
know who actually composed this minute or note?
A. Me.
‘SIR WYN WILLIAMS: I It was you, right.
A. Absolutely, it was me, yes. Yes.
SIR WYN WILLIAMS: Right.
MR STEVENS: Sir, we have on the documents a series of
emails of it being amended, which --
SIR WYN WILLIAMS: Yes, that's fine. I just wanted to have
it clear in my mind while we were discussing it. That's
all.
MR STEVENS: Thank you, sir.
THE WITNESS: So this, whilst not absolutely verbatim, it
will be not far off and the Inquiry has the
contemporaneous handwritten notes that I produced this
from.
SIR WYN WILLIAMS: Yes.
MR STEVENS: I want to turn to that now for a second point.
Could we please bring up WBON0001776 and, sorry,
I should orientate ourselves, so could we also get up
WBON0001737. So we see this is referring to the
handwritten note of the conference call you were just
referring to.
81
stuff, lawyers, as if we're going to go. I still need
to get the board over the line". So we are preparing as
if we are going to -- or, more to the point, the counsel
team is preparing as if it is going to go; she is going
to need to still get the Board over the line.
Q. Soat this stage, did you have any impression of what
Jane MacLeod thought of the merits of the recusal
application?
No, I don't think I did. What she thought personally?
Yes.
I don't think I did.
Your evidence is that wasn't discussed in this
prop,
conference?
A. No. If this note doesn't -- I mean, whilst this is not
an absolutely verbatim note, I will have tried to
capture the salient points. So, no, I don't think so.
Q. I want to ask one brief question on the call of 20 March
2019. If you want to see the note, we can bring it up.
As the note reads, it appears that you and Lord Grabiner
attended the call, Lord Grabiner gave advice and then
you and Lord Grabiner left the call?
A. Yes. That's exactly what happened.
Q. From that call on 20 March 2019, did you get any
impression of any of the Directors’ views on the merits
of the recusal application or whether it should be
83,
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
2
2
>
prop
12 June 2024
Yes.
Can we please go to page 5 of both notes. Thank you.
You see there's, towards the bottom, "JANE" underlined;
that's Jane MacLeod, isn't it?
Yes.
I read this as, tell me if I am wrong, instructions to
prepare on the basis that the recusal application will
go ahead?
Yes.
Then it says, "Need to get Board over line"
Yes.
What did Jane MacLeod say that led you to make that
note?
That is what she will have said. I mean, that is what
she will have said, that "I need to get the Board over
the line, there's going to be a Board call today and we
are going to schedule a Board call for next Monday". So
that's what she said.
So, at this stage, was it Jane MacLeod's position that
the right decision was to issue the recusal?
No, no, no. Okay, I understand what you're asking. So
she was saying -- because I'm saying, "It's urgent,
Jane. We're waiting. This is -- you know, it's
annoying me".
So she's saying, "Okay, press on, draft, do your
82
brought?
No, It was -- no. There wasn't free-flowing discussion
at all. As the handwritten contemporaneous note will
probably sort of give you the impression, Lord Grabiner
said his bit. There were three or four questions from
unknown voices, unknown to me at the time. So the Board
asked, you know, “Is there a middle way?", I don't know
who, and then we left the call. And so Lord Grabiner
and I were not there for any of the -- what I assume
must have followed as being discursive, "Should we do
it? Shouldn't we do it?" We weren't there for any of
that, if that, in fact, occurred. I wasn't there;
I don't know.
Last document or two documents from me. Please can we
bring up WBON0001792 and, at the same time, please,
WBON0001795. So on the handwritten note we see it says
20 March 2019.
Yes.
There's a "17" on the typed copy. Is that an error?
Yeah, that shouldn't be there. I think that's someone
putting a page number on, isn't it?
Fine.
So sorry about that.
No need to apologise. Just so we're clear, it's
20 March 2019.
84
(21) Pages 81 - 84
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
16
17
18
19
20
21
22
23
24
25
The Post Office Horizon IT Inquiry
A. Yeah.
Q. It says, "Jane" and in quotes "go'
recusal application?
A. Yes.
Q. Yes. Then we get this:
"Uncomfortable [regarding] tone in Judgment."
A. Yes.
Q. "Board really uncomfortable.”
What did Jane MacLeod say to you that led to that
note?
". Is that go on the
A. I mean, it's probably exactly what -- this is my
scribbles during a phone call and so that is what she
will have said. She'll have said, "The Board is really
uncomfortable, they're really sensitive around tone.
You've got to tell the counsel team. I don't want any
high tempo language. I want calm". So that's what she
will have been saying to me in that call.
Q. So what was she saying the Board were uncomfortable
about: was it the language or the making of the
application itself?
A. "Re tone in judgment". So no, the Board is
uncomfortable with how Post Office is portrayed as
aggressive in the Common Issues judgment and she's
saying, "I want these documents that support any recusal
and any witness statement to be calm". So the
85
MR STEVENS: Sir, I have just been handed a note. That may
be the end of my questions but, if I may just have
a moment to discuss it with Ms Price?
SIR WYN WILLIAMS: Yes, of course.
MR STEVENS: Thank you. (Pause)
Sir, there's no further questions from me but I will
just check the room to see if there's --
Ms Page has asked for one issue to be dealt with.
Ms Page has asked for five minutes, sir.
SIR WYN WILLIAMS: Well, I'm sure that we can accommodate
that, Ms Page.
MR STEVENS: Thank you, sir.
Questioned by MS PAGE.
MS PAGE: Thank you.
Mr Beezer, I am going to ask you about a particular
note which is to do with the relationship between the
Bates litigation and the criminal appeals. If I could
ask, please, to bring up WBON0001511, and if we go to
page 4. As far as I've been able to work out, the blue
typing is you chipping in to these emails?
A. That's right, yes.
Q. There's this paragraph in the middle. It reads:
“Also on the topic of settlement it is necessary to
remember that 30 out of the 557 claimants have been
convicted for shortfalls. Those 30 are relevant to the
87
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
12 June 2024
uncomfortable is how the Post Office is portrayed in the
Common Issues judgment. That's what's going on here.
Did Jane MacLeod say to you anything else about her view
on the application itself?
I don't think she did and, since you asked that
question, I've been pondering. I don't think I ever
knew what Jane's own position on it was.
At this point, did you have any understanding of what
the Board's motivation was in making the application?
My understanding of why Post Office wanted to do this is
about the desire to get a legally correct judgment in
the Common Issues, the desire to avoid what seemed to be
a near inevitable series of losses of trials going
forward. They were the motivations, and I can only
speak from my impression that I got from Jane, because
that's all I -- the only person I really interacted with
substantively on any of this, and all of those
motivations seemed, based on the understanding that we
had at the time, proper.
To what extent, if at all, was there any discussion when
concerning the recusal application, that it should be
made to put pressure on the claimants or the litigation
funders?
Not at all, from within my visibility, not at all.
Yeah, not at all.
86
process currently under way at the CCRC. Post Office
cannot therefore currently simply settle with the entire
claimant group as that would throw serious doubt on
safety of those 30 convictions."
First of all, you obviously came in to the Bates
litigation relatively fresh. Can you remember how you
came to find out that some of the claimants had been
convicted?
I will have picked up this information -- and this is
probably the totality of my knowledge on this -- by
osmosis, by being in the office around people who were
dealing with this case. And I don't have deep knowledge
on that, but it seemed a relevant point to put in this
email, because it seems an impediment to settlement,
based on what I was picking up that other people might
be dealing with.
Do you have recollection of others having this sort of
issue, in other words the interrelationship between the
civil and the criminal proceedings being something that
was at the forefront of minds?
I don't believe so. I just knew from conversations in
the office that, in the claimant group, there were
people who had been convicted and that would be an --
how do you pay someone who's been convicted, if you want
to settle? As to detail of who was dealing with that,
88
(22) Pages 85 - 88
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
The Post Office Horizon IT Inquiry
where that was being dealt with, I'm really not sure.
Q. Do you think that the GLO was contested, in that very
vigorous way that it was, partly because to settle would
have been to concede that past convictions were unsafe?
A. I can't answer that. I don't have enough information
but I really shouldn't think that was the case but
I don't know.
MS PAGE: Thank you. Those are the questions I ask, sir.
SIR WYN WILLIAMS: = Can you just show me the date when this
observation is made, please?
MR STEVENS: That will be coming up shortly, sir.
SIR WYN WILLIAMS: That's fine, yes.
A. 19 March.
SIR WYN WILLIAMS: 19th. So it's still in the same period
as you are dealing with the logistics for the recusal
application?
A. Absolutely. I had a sort of short, three-week burst,
and then drifted out.
SIR WYN WILLIAMS: Yes, I follow. That's fine, thanks.
A. Yeah.
MS PAGE: Thank you, sir.
‘SIR WYN WILLIAMS: I Is that it, Mr Stevens?
Thank you, Ms Page.
MR STEVENS: Yes. I'm just doing a final check and that
seems to be everything.
89
is Ms Hodge and I ask questions on behalf of the
Inquiry. Please state your full name.
A. Matthew Guy Lenton.
Q. You should have in front of you a hard copy of your
witness statement dated 14 May 2024; is that right?
A. Yeah.
Q. That statement should run to 54 pages, including
an index of documents; is that correct?
A. Correct.
Q. Could I ask you, please, to turn to page 51 of your
statement.
A. Yeah.
Q. You should see there in the middle of the page
a statement of truth and a signature. Is that your
signature?
A. Yes, itis.
Q. Is the content of this statement true to the best of
your knowledge and belief?
A. Yes, itis.
Q. Thank you. I'm going to begin just by asking some short
questions about your academic and professional
background, please.
A. Okay.
Q. In 1987, you obtained a bachelor's degree in film
studies and philosophy from the University of Kent; is
1
1
2
3
4
5
6
7
8
9
10
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
12 June 2024
‘SIR WYN WILLIAMS: All right.
Well, then thank you very much, Mr Beezer, for
making two witness statements dealing with two, in
effect, discrete issues and I'm grateful to you for
giving oral evidence before the Inquiry this morning.
THE WITNESS: Thank you.
MR STEVENS: Thank you, sir. I have heard from Ms Hodge.
We think that the best approach, subject to you
agreeing, is to take an early lunch now.
SIR WYN WILLIAMS: Yes.
MR STEVENS: So if we could come back for Mr Lenton's
evidence at 1.20.
SIR WYN WILLIAMS: Yes, by all means, Mr Stevens. We will
resume at 1.20.
MR STEVENS: Thank you, sir.
(12.21 pm)
(The Short Adjournment)
(1.20 pm)
MS HODGE: Good afternoon, sir, can you see and hear us?
SIR WYN WILLIAMS: Yes, I can, thank you.
MS HODGE: Thank you, sir. Our next witness is Matthew
Lenton. Please could the witness be sworn.
MATTHEW GUY LENTON (affirmed)
Questioned by MS HODGE
MS HODGE: Good afternoon, Mr Lenton. As you know, my name
90
that right?
A. Correct.
Q. Before joining Fujitsu in 2006 you worked for various
companies in the field of document control; is that
right?
A. Correct.
Q. Could you please explain for those who are unfamiliar
with the term, what document control entails?
A. Yes, so, basically, it's -- somebody doing that role is
normally employed by, obviously, an organisation that
generates large volumes of normally technical but -- or
otherwise formal documentation. So I worked for Arup,
the consulting engineers, also for British Gas, and that
was before working for Fujitsu. And, obviously, those
companiesall produce large volumes of technical
drawings, specifications, et cetera.
It's clearly important that people using those
documents know what version they're using, et cetera,
and that old documents are preserved and records are
correctly kept, basically and, because of the volume,
they employ somebody specifically, or often a team, in
fact, specifically to do that.
And it also involves things such as formal reviews
and approvals of documents with other parties, and
internal peer reviewers.
92
(23) Pages 89 - 92
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
The Post Office Horizon IT Inquiry
Thank you. When you joined Fujitsu in November 2006,
that was the role of Document Manager; is that right?
Correct.
You initially worked on several different accounts,
albeit temporarily on the Post Office Account, as
well -- is that right --
Correct, mm-hm.
-- before you were employed permanently as a Document
Manager in May 2009?
Yeah, before being employed permanently as a Document
Manager on Post Office Accounts, I was actually
recruited by Fujitsu to work on the NHS Account.
Thank you. You remain in that role to the present day;
is that right?
Correct.
Is there more than one Document Manager on the Post
Office Account or are you the Document Manager?
No, that is me and I have an assistant. That's it.
Who is your assistant?
So currently, it's somebody called Ashwini Vishian(?),
who works in Chennai.
And previously?
Previously we had somebody called Hanifa Thariq
Mohammed, who also works in Chennai, and, before that,
there have also been various other people who have
93
the [Post Office Account] is the responsibility for
ensuring that design documentation and key process
documentation is controlled. The basis of that control
is the use of a single repository for such
documentation, which is a configuration management
database known as Dimensions. The database provides the
[Post Office Account] clarity on the latest versions of
current documents, and that previous (superseded)
versions, as well as obsolete documents, are retained."
Would it be right to say that here you're
emphasising the need for there to be one place where all
design and key process documentation are held?
Correct.
One of the reasons for that would be to ensure that such
documents are distributed or disclosed appropriately; is
that right?
Disclosed -- um, mm, so the original purpose of it is
not for that purpose. It's so that people using the
documents in terms of the staff in the company can know
that they are referring to the correct version of
a document, so that we don't have, you know, multiple
versions of documents in various places on local hard
drives, et cetera, that people are looking at that may
be out of date.
So the principal purpose would be an internal one?
95
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
>
prearere>
12 June 2024
worked with me from 2008 until about 2015 or 2016.
Thank you. We may come on to identify some of those
shortly?
Sure.
So far as you're aware, for how long had the role of
Document Manager existed in the Post Office Account?
Since around 1998, I think.
Just some small points of clarification, please. Is it
right you don't have any formal qualifications or
training in information technology?
Um ... mm, I'm not sure about that. I think I do
actually have a formal qualification in IT. I think
it's what used to be known as an NVQ but I'm not sure
that exists any longer, so it's probably not recognised.
Okay, thank you. Would it be correct that you don't
have any legal qualifications or training?
Correct.
I'd like to ask you, please, some questions about the
core part of your role as Document Manager for the Post
Office Account. Please can we show the witness's
statement WITN00530100.
Thank you. On page 3, please, you describe the Post
Office Account Document Manager role, and in your
statement, you say at paragraph 8:
"The core part of my role as Document Manager for
94
Correct.
But it would equally be --
It could -- can therefore be used --
-- useful --
for other purposes --
-- externally?
-- such as you suggest, yeah.
Another reason for having a single repository would be
to ensure that they're retained appropriately; is that
fair?
Correct, yeah.
Is it right that, during the period with which we are
concerned, the Post Office Account did not adhere to
this key principle of document control?
It may -- well, mm, no, I'm not sure that's true,
actually. So, in terms of the documentation that is
stored within Dimensions, as far as I am aware, all of
the documents that have been placed into Dimensions
since, I think, before 2000 are still there and are
still version controlled.
I'm going to ask you, Mr Lenton, about another
repository which is the SSC website?
Sure.
We may explore whether or not that contains key process
documentation, as you've defined there?
96
(24) Pages 93 - 96
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
>
2
The Post Office Horizon IT Inquiry
Mm-hm, mm-hm.
Now, one of the repositories to which you refer in your
statement is a dedicated website that was used by the
SSC for incident management and support documentation;
is that right?
Right, yes, correct.
That website you say contained work instructions
relating to the reporting and management of bugs, errors
and defects; is that right?
Sorry, can you just repeat the last bit of that?
Yes, work instructions relating to the reporting and
management of bugs, errors and defects?
I'm not sure that it did contain work instructions for
that. I mean, certainly there may be some overlap with
processes that do deal with that issue.
So if we could look, please, at page 6. At paragraph
20, please. The final sentence there reads:
"There are also internal SSC-specific work
instructions that relate to the reporting and management
of [bugs, errors and defects] which are stored" --
Sure. So reporting and management, yes. So at a low
level, I would say. So they're work instructions rather
than procedures and processes.
Thank you. What's also contained on the website are
PEAKs and KELs; is that correct?
97
When did you first attain access to the website?
In 2016.
Before you were granted access to the SSC website, so
far as you are aware, was it accessed and controlled
solely by members of the SSC?
That is my understanding, yeah.
Why was that the case; do you know?
I'm not totally sure. My understanding is that, for
historic reasons, the SSC were originally part of
a division in Fujitsu, which wasn't directly part of the
Post Office Account. So they would have dealt with
other accounts as well as the Post Office. So it's kind
of like a shared services support team. So, because of
that, they would have had their own repository for
dealing with incidents across the various accounts, so
it would be owned by that division rather than by the
Post Office Account itself.
Do you know who within the SSC was responsible for
administering the website?
In the time since I've worked there, I believe it is --
has been administered by John Simpkins and Mark Wright
and probably with the assistance of various other
people.
Did you consider it was appropriate, in your role as
Document Manager, for the SSC to have exclusive control
99
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
o>
>
12 June 2024
Correct, yes.
Now, would it be fair to characterise those documents as
key process documents, and Known Error Log?
A Known Error Log isn't really a process document; it's
actually a record of an incident or of the symptoms of
certain incidents, whereas a process document would be
‘one that tells you how to actually record or manage
incidents generally. So I think - I mean, I see the
point you're making but I think that KELs are very
specific to individual incidents, whereas when I am
referring to process documents about how to manage
incidents, I'm talking about much higher level, such as
incident management procedure, for example, which
wouldn't in itself contain any details of any BEDs.
Thank you. When did you first learn about the existence
of the SSC website?
I suspect I probably heard of it shortly after joining
the account, maybe in 2009 or 2010.
What did you understand the website to contain at that
stage?
It's hard to say what I understood at that time.
I mean, I think I knew that it contained PEAKs and
I think I had a fairly vague idea of what PEAKs were but
I didn't regularly come across them, to be honest, as
I wasn't really involved in that area of work.
98
over this website and its content?
I'm not sure whether -- so that probably is a question
that I had debated with my learned friend at certain
times and I think it -- I just accepted it as being the
way that it was and had been for many years. And so --
I mean, I think if I'd questioned it, I'm not sure that
I would necessarily have changed anything, shall we say.
Why were you granted access to the website in 2016?
I can't remember now, actually, what the specific reason
was that prompted it but I think it was possibly looking
at wanting to look at PEAKs, which related to document
updates, so that occasionally, if it had been noticed
that during something like testing, for example, that
a document that an incorrect statement in it, then the
testers may raise a PEAK that says the document needs to
be updated and, therefore, I think when I was being
asked whether a document had been updated correctly or
not or whether progress had been made on that update,
then it was useful to look at PEAK. But I think that
possibly -- well, as I say, I'm not sure why
particularly in 2016 that came up.
Thank you.
I'll just say I don't think it's in any way related to
the issues that we're discussing here. I think it's
something unrelated.
100
(25) Pages 97 - 100
1
2
3
4
5
6
7
8
9
10
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
The Post Office Horizon IT Inquiry
Q. Part of your role as Document Manager involved liaison
with the Post Office; is that correct?
A. Yes, correct, yeah.
Q. If we could turn to page 3, please, of your witness
statement at paragraph 8. You say there in the final
sentence:
“Document issues and receipts between Fujitsu and
Post Office Limited, as well as other parties, are
controlled via a central mailbox owned by me, and those
transactions are recorded and the emails stored."
You seem here to be referring to the present tense:
is that fair, they "are" controlled by you?
A. Correct.
Q. Has that central mailbox been used throughout the time
on which you've worked on the Post Office Account?
A. Yes, it has.
Q. Are you only the member of the account who has access to
the central mailbox?
A. No, so the person I mentioned who assists me at the
moment, she has access and, over -- since I've worked
there, all the other people that have worked with me
have also had access to it.
Q. Would it be right to understand that this is an internal
Fujitsu mailbox, to which those outside the organisation
wouldn't have access?
101
Gareth Jenkins on the subject of data integrity; is that
right?
A. Correct.
Q. What caused these particular documents to stand out in
your memory?
A. Well, only -- well, mainly the fact that they relate to
the issues that we're discussing here. So, obviously,
when I'm asked about them, then that's effectively the
first documents that I remember dealing with that
directly related to this issue. I mean, they were
obviously also slightly unusual documents, in that they
didn't -- most of the documents that I would have dealt
with related to the implementation of the solution, or
processes relating to the implementation, whereas these
clearly are reports on an aspect of it, rather than
being design documents, as it were.
Q. Were they documents that you held in Dimensions?
Yes.
>
Q. But they were of a different character to the other
documents that you held there; is that what you're
saying, in essence?
A. Well, I'm saying that, because of the nature of them,
there's -- they were perhaps somewhat memorable in terms
of being different from most of the other documents,
which are things like high-level designs, test reports,
103
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
12 June 2024
Correct.
Did you respond to or oversee all requests for access to
documents from the Post Office from the date of your
appointment as Document Manager?
Well, only as far as I know. So if people -- if other
people received -- other people on the Account received
requests directly from people within Post Office, then
it was expected that they would pass them to me, but
it's perfectly possible that people may have answered
them directly without me knowing.
If you did not obtain access to the Account until July
2016, does it follow that you did not provide to the
Post Office any documents that were held solely on that
site before that date?
That sounds likely. I mean, I can't say that that's
definitely the case because it's possible that somebody
may have sent me something internally that I then passed
on but that sounds unlikely to me because there wouldn't
have been any need for me to record it.
From quite an early stage in your tenure as Document
Manager you started to handle requests relating to
Horizon data integrity; is that correct?
Yes.
In your statement you say you recall processing and
disclosing to the Post Office two reports produced by
102
et cetera.
At the point when you first came to handle and pass on
these documents to the Post Office, what, if anything,
did you know about Gareth Jenkins’ role in the Post
Office Account?
Yeah, um, I already knew who he was. I mean, he was
a -- one of the most senior architects on the Account.
He sat just upstairs from me, I'd spoken to him before,
so I knew perfectly well who he was.
Do you recall being asked in October 2013 to set up
a SharePoint site on which to store documentation
relating to data integrity?
Yes.
This became known as the data integrity SharePoint; is
that right?
Correct.
Did you know why you were asked to set up that
SharePoint?
I suppose, in general terms, I did, but I wasn't
particularly aware at that time of the investigations
going on within Post Office or of the Mediation Scheme
‘or Second Sight, et cetera. So not in detail,
basically.
What did you understand in general terms?
Well, obviously, only that there was some question over
104
(26) Pages 101 - 104
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
The Post Office Horizon IT Inquiry
the integrity of the data and that various work was
being done between Fujitsu and the Post Office and,
I think, various other parties to investigate that
issue.
Who was granted access to the data integrity SharePoint?
So I don't think I'd be able to give you the full list
but my recollection is that it's about ten people within
the Post Office Account only. So people such as James
Davidson, Torstein Godeseth, Gareth Jenkins and about
five or six other people, I think.
How did you determine who ought to have access to the
SharePoint?
I'm sure I was just asked to provide access to those
people.
So far as you're aware, would any Post Office employees
have had access to that SharePoint?
No.
How did you decide which documents were to be stored on
the SharePoint?
I was asked to download them from Dimensions and put
them on there so, again, I can't really remember who it
was who asked me to do it but, one of those same people
that I mentioned earlier.
Who would have identified to you which documents were
relevant?
105
Yeah.
You're not either the recipient or copied in to this
email?
Mm-hm.
But what it confirms, we can see at the second bullet
point, is that you, Matthew Lenton, are in the process
of setting up the site for all documentation relating to
data integrity and for that to be stored. He goes on to
say:
"Gareth has a lot of data which is on his laptop and
on [his] server share currently but this will proved us
[presumably ‘provide us all'] with a place to keep
drafts/WIP, [work in progress] and historical
documentation."
So I think it's your evidence you weren't
specifically told that by Mr Davidson; is that correct?
No, I don't think I was and I actually don't think that
happened either. So I don't think we did end up storing
a lot of data from Gareth into that SharePoint site.
Thank you. So far as you can recall, did you have any
contact or communication with Gareth Jenkins at this
time about what he held on issues of data --
No, I don't think so. As I say, I think the SharePoint
site only contained documents that I added to it from
Dimensions, as far as I recall.
107
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
2
12 June 2024
Yeah, so probably either Gareth Jenkins or Torstein
Godeseth.
Did you take any steps to consult with members of the
SSC about what could or should be stored on the
SharePoint relating to data integrity?
No.
Why not?
I don't think there's any reason to do that. So I was
really only doing what I was asked to do to set up the
site, give access to certain people, add certain
documents to it.
Did you obtain any documents from sources other than
Dimensions?
As far as I recall, no.
Were you aware that Gareth Jenkins held a lot of
relevant data on his laptop and on his server share at
that time?
I don't think I knew that as a fact, no. I mean, I may
have guessed that. It was common that people did hold
lots of data on their laptops and on file shares at that
time.
Perhaps it might help if we just look at that email.
FUJ00156902, please. Thank you. So this is an email
from James Davidson. Is that who you believe asked you
to set up the SharePoint site?
106
Thank you. When did you first start liaising with
Mr Jenkins directly over issues of data integrity?
I'm sure it was probably the two reports, so the Horizon
and the HNG-X data integrity reports.
Because you obtained those directly from him?
Well, I know they were written by him. So it seems
perfectly possible -- even likely -- that they would
have checked with him that they were the latest versions
and that he hadn't made any other changes to them.
Yeah, before that, I don't think I would have had any
reason to discuss it with him.
When you say you would have checked, this is from the
point of view of version control --
Mm.
-- rather than in relation to the content of the
documents; is that right?
Yeah, I mean, simply I might have, say, version 1 and
I would perhaps check with him that there wasn't a more
recent version that I didn't yet have that he wanted to
provide to Post Office instead.
Thank you. II'd like to move on to a new topic, please,
which concerns your involvement in the Group Litigation
brought by subpostmasters and others against the Post
Office?
In your statement you explain that your role was to
108
(27) Pages 105 - 108
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
The Post Office Horizon IT Inquiry
field requests for information and evidence from the
Post Office's lawyers, Womble Bond Dickinson; to direct
those requests to the appropriate subject matter expert
within Fujitsu; and to provide responses back to Womble
Bond Dickinson. Is that a fair summary?
Yes.
You identify in your statement six individuals from whom
you obtained information about Horizon; is that correct?
Yes.
Perhaps if we could just turn up your statement, please,
where that is addressed at page 18, paragraph 47. Can
you tell us, please, for the benefit of those following
your evidence, who each of those individuals were, and
their roles? You've dealt already with Mr Jenkins.
Okay. So Pete Newsome was -- his job title was often
something like Consulting Manager or something like that
but he was somebody who worked on the Post Office
Account and I believe had worked quite closely with Post
Office themselves, in terms of actually working in their
offices on some occasions. But he was also kind of in
charge of commercial change, at a kind of high level, so
in terms of discussing and fielding changes that the
Post Office wanted to implement. So, effectively, he
was a kind of senior kind of commercial change manager.
Stephen Parker was the Manager of the SSC.
109
from being provided by various Architects, for example,
or Service Managers. So I would know who was subject
matter expert in certain areas.
Who within Fujitsu was responsible for determining what
was or was not disclosed to the Post Office's lawyers?
I suppose, ultimately, in terms of this exercise, it was
Pete Newsome, I guess, as he was effectively managing
this kind of small virtual team of people mentioned
here, plus me.
What were you told about the role that Gareth Jenkins
was to play in supporting the Post Office's defence in
the Group Litigation?
I'm not sure I was told anything specifically in those
terms. I think it was simply that, when we were looking
at providing answers to questions as it came to us from
WBBD, then I think it had been determined that this team
of people would help to analyse the information in order
to answer those questions. And he was one of those
people, because of his longstanding expertise and
knowledge on Horizon. So I don't think I was told
anything specifically about what his role would be,
other than in those terms.
We know that some of the individuals named there gave
witness statements in support of the Post Office's
defence. Who was responsible for determining which of
111
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
12 June 2024
John Simpkins and Mark Wright were both Team Leads
in the SSC. So I think, basically, they were kind of
Steve Parker's deputies. I think they had kind of half
a dozen or so people working under them.
And Torstein Godeseth was the Senior Architect on
the Account. So I think he was -- yeah, effectively he
was senior to Gareth Jenkins, I think.
Thank you. Would it be right to say that these would
not be the only individuals from whom you obtained
information; you say they are the principal ones?
That's right, yeah. So sometimes we would ask other
members of the Account for help with obtaining certain
bits of information, so various subject matter experts,
from various teams.
How did you determine to whom within Fujitsu a request
for information should be directed?
So, often, that would just be simply by discussion with
other the people. I mean, so the staff on the Account
are kind of -- so all of the people listed here were on
the Account for quite a long period of time and,
obviously, I had also been on the Account for, you know,
about 10 years, by this time, so we obviously knew who
dealt with which types of issues and who had expertise
in certain areas.
Personally, I would have seen many document updates
110
Fujitsu's employees were to give witness evidence?
I suspect that was between -- probably, conversations
between Pete Newsome, possibly Chris Jay, the Fujitsu --
I think he's a lawyer, I'm not quite sure what his
qualifications are -- and with WBD, I suspect.
Did you know why Mr Jenkins was not asked to provide
a witness statement?
I believe I wasn't directly involved in that, so I'm not
sure. I think it may be because of the fact that he was
no longer a Fujitsu employee by that time.
Did you know why he was being asked to feed information
and evidence to other witnesses, such as Mr Godeseth?
Feed, mm. So, I mean, I think he's providing analysis,
so he's being asked his opinion on various issues. So
I'm not sure that I would necessarily have seen it as
being characterised in that way but I'm aware that other
people have characterised it like that.
Did you have any concerns at the time about this
approach to the preparation of the witness evidence that
was being provided by Fujitsu?
Personally, no.
The next topic I would like to address with you, please,
concerns the very late disclosure by Fujitsu of
a substantial number of Known Error Logs. Is it right
that you were informed in late November 2017 that the
112
(28) Pages 109 - 112
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
oP
prop,
The Post Office Horizon IT Inquiry
Post Office was required to declare the locations in
which documents relevant to the operation of Horizon
were held?
Yes, I was indirectly made aware of that by being
presently with the EDQ, yes. When I say "indirectly",
I wasn't told that that was what needed to be done in
the terms in which you've just expressed it.
You were asked, were you not, by Womble Bond Dickinson,
to attend a conference call on 30 November 2017 --
Yes.
-- the purpose of that call being to assist them to
understand which documents were held by Fujitsu and
where they were stored; is that right?
Yes.
You attended that call with two other Fujitsu employees;
is that right?
I believe so.
Could you confirm their names and roles?
I think that was probably Pete Newsome and Chris Jay.
You understand Chris Jay to be an internal Fujitsu
lawyer; is that right?
So he's a member of the Fujitsu Legal Team at that time,
yeah.
To assist you, please could we turn up FUJ00158114.
Thank you. In the second half of the page, please, we
113
discussions that took place.
Aweek later, you were sent by Womble Bond Dickinson
a draft appendix to the Post Office's Electronic
Directions Questionnaire -- is that right --
Yes.
-- in which they had attempted to summarise the
documents held by Fujitsu?
Yes.
So if we just scan up while we're on this document,
please, to the top, thank you, this is an email now from
Michael Wharton, again to the same recipients:
"As discussed on Thursday's call, I have attached
our draft appendix to the EDQ [the Electronic Directions
Questionnaire], summarising the documents held by
Fujitsu -- please could I ask you [first] to:
"review it generally and confirm you are happy with
it; and [second]
"confirm the specific points highlighted in yellow
in the attached."
He goes on to say:
"Please accept our apologies for the delay in
getting this over to you such that it is now urgent,
however, please can I ask you to come back to me with
your comments by 14.30 this afternoon, as the EDQs need
to be exchanged today. Your help is greatly
115
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
12 June 2024
have an email here dated 28 November 2017 from Amy
Prime, an employee of Womble Bond Dickinson. It's
addressed to you, Pete Newsome and Chris Jay, who is
referred there as Defence Legal --
Yes.
-- and others copied:
"Chris, Matthew, Pete.
"Post Office are required to inform the court of the
location in which potentially relevant documents are
located. 'Relevant document is a very broad term and
will encompass pretty much all dealings which Fujitsu
have had with Post Office in relation to Horizon and
HNG-X spanning emails (with both POL and internally),
documents stored in Dimension, Transaction and Event
data, HSD logs, PEAKs system and any other document
produced by Fujitsu which relates to Horizon.
I appreciate that this may be a large volume of
documents.
"So as we can understand the documents held by
Fujitsu and where they are stored, it would be helpful
if we could have a call."
Now, do you have any recollection of what was
discussed at that meeting?
I must admit I don't really remember the meeting.
I remember that I did attend it. I don't recall the
114
appreciated."
Now, obviously that email is timed at 10.18 am on
the Wednesday, so you were given just over four hours?
Yes.
Could we please look at the document attached to that
email, so this is the draft appendix, which is at
FUJ00158115.
Now, you make the point in your statement you didn't
have very long to review the document. It wasn't very
lengthy though, was it, it ran to just over two pages?
That's true.
Would it be fair to say that you did have sufficient
time to consult with your colleagues on a number of
points that you raise in the statement?
Yes. Although, yeah, I mean, my recollection and what
I see when I look back at the comments on it now are
that, basically, I consulted with colleagues on the
points which had been highlighted, as I think Michael
Wharton mentions in his email and then, if I spotted any
other things that I knew to be incorrect, then
I commented on those as well. So I think if I saw -- if
I read the rest of it and didn't either see
highlighted -- sections of it highlighted to be queried
or spot that there was something wrong myself, then I'm
not sure that I'd -- I'm pretty sure I didn't generally
116
(29) Pages 113 - 116
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
>
2
The Post Office Horizon IT Inquiry
send this on a review to other people as a whole.
Thank you.
If that makes sense.
Just to look at what we have here, this is obviously one
of several appendices dealing with databases of
electronic documents but these specifically are
Fujitsu's databases; is that right?
Correct.
Now, if we look just above the table, it states:
"This information has been provided by Fujitsu to
Post Office."
Yeah.
Now, presumably that was in the meeting that you had on
30 November?
Um --
Sorry, not attended solely by you but by Pete Newsome
and Chris Jay, as well?
Yes, correct, yeah, although it is possible -- I have
reflected on this and it does seem to me possible that
Pete Newsome had separate either conversations or emails
with WBD. But! -- as I say, I don't recall the details
of the meeting and, certainly, information relating to
KELs wouldn't have come from me, so it's not clear to me
whether it was in that meeting or not.
When you say it's possible he had other communications,
117
within the meeting but, certainly, not from me and it
possibly came from elsewhere, is that I don't think he
would have necessarily known -- come up with that
definition on his own. So that sounds like something
that somebody from the SSC would have provided him with.
Was that something that you knew, that you had knowledge
of at that time, what is described there in relation to
the KEL?
No, not without asking somebody else to provide that
information, no.
The next entry, please, in the column entitled
"Comments" reads:
"The KEL only contains the current database entries
and is constantly updated and so the current version
will not necessarily reflect the version that was in
place at the relevant time."
Now here:
"The previous entries/versions of the current
entries are no longer available."
Again, do you recall providing that information?
No.
By whom do you think that information was provided?
So, again, I suspect that went to -- I mean, I'm
guessing really but I could only assume that that went
to WBD from Pete Newsome but I would also expect that he
119
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
>
2
2
12 June 2024
were you copied in to those?
I don't think so because I think I actually have looked
to see whether that is the case or not. So ...
You haven't found anything?
No.
The first row in the table concerns the Known Error Log
and, in the middle column, it provides a description of
it to this effect:
"The KEL is a proprietary database with
approximately 4,000 entries containing information which
is used by Fujitsu to explain how to deal with or work
around minor issues that can sometimes arise in Horizon
for which (often, because of their triviality)
system-wide fixes have not been developed and
implemented."
Now, do you recall providing that information to the
Post Office's lawyers during your call?
No.
By whom do you think that information was provided?
So, if there was only three of us on the call, I could
only assume that it would be Pete Newsome but, again,
I would have -- so the reason that I say I think it's
seems possible perhaps even likely that he got that
information from elsewhere and provided it to WBD
separately from that meeting is that ~- or possibly
118
had got that information from somebody in SSC. I mean,
I have to say, we know that that last statement that you
just read out is incorrect. But I don't know why it's
incorrect and I don't -- you know, I've looked to see
whether we can trace the source of that error but
I haven't been able to and, I mean, it strikes me now
that it's possibly even just been heard by somebody
incorrectly. Perhaps it doesn't mean "available" but
means "valid", or something like that.
When you read that, when you reviewed the document, as
you were asked to do by Womble Bond Dickinson, that
didn't jump out at you?
No, I don't think that I was -- well, I know that
I wasn't familiar enough with KELs at that time to have
had an opinion on that actioning.
In March 2018, so several months later, you provided to
Womble Bond Dickinson approximately 8,300 KEL entries:
is that correct?
I think that's right, yes.
Who would supply those entries to you?
So those would have come from the SSC and I think it was
probably John Simpkins who obtained them and provided
them.
At the time that you provided those entries, you were
asked by Womble Bond Dickinson to confirm whether the
120
(30) Pages 117 - 120
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
2
The Post Office Horizon IT Inquiry
documents you had provided contained all historic and
current KEL entries; is that right?
Sounds correct, yeah.
Let's take a look at that email, please. FUJ00220950.
On page 3, please -- thank you. So we have an email
from Amy Prime again, of Womble Bond Dickinson, dated
23 March 2018, to you, and copied in to Chris Jay at
Defence Legal, Pete Newsome and, I think, some other
lawyers from Womble Bond Dickinson.
Yes.
It reads:
“Matthew
"Thank you, we have safely received the documents.
"There is also a file named 'KELComplete' uploaded
to the data room. Please could you confirm if this
contains all historic and current KEL entries."
So that was a question that was raised specifically
to you?
Yes.
So what did you understand historic KEL entries to mean?
I think my interpretation of that was, and actually
still is now, that it means KEL entries that are no
longer applicable. So rather than old versions of KELs
that have since been updated, it means old KELs that are
no longer current KELs. So no longer applicable to the
121
Sure, mm-hm.
-- which said the KEL database only holds current
entries of KELs. Now, here we have an email from Amy
Prime, March 2018, which says, “Have we got all historic
and current KEL entries?" So what I'm asking you is, at
the time, did you ask yourself from where are these
historic entries, if the database only holds current
KELs?
I'm not sure that I did ask that but I may well have
discussed it with John Simpkins but I think I took the
KELs that he had provided me with, but again, I think
this is the distinction between historic KEL and
a superseded version of a KEL.
Okay we'll come on to that terminology shortly. Now, to
answer this question that Ms Prime had raised about the
upload that had been made in March, as you say, you
sought some clarification from John Simpkins; is that
correct?
I think I probably did.
If we scroll up, please, to page 1. Thank you. So your
email to him of 23 March 2018 is at the bottom.
"John, I uploaded the KELs to [Womble Bond
Dickinson's] site and let Pete know I'd done it, but it
sounds like maybe he hasn't told them, so they are
checking -- Amy Prime asking 'Please could you confirm
123
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
2
12 June 2024
current system.
So obsolete but for a different reason?
Obsolete because they -- the KEL as a whole is no longer
valid, rather than them being superseded versions of
KELs, yeah.
Weill come on in a bit to the terminology, it gets
a little bit complicated but thank you. Now, bearing in
mind what the electronic directions questionnaire had
said, if the KEL only contained current database
entries, from where had the historic entries been
obtained?
So I think I go on to explain all of that, actually, in
another email to Amy Prime, probably after this,
I guess. So there are various statuses that KELs could
have. So they could either be the currently applicable
KELs, in other words the ones that the SSC would consult
that were deemed to relate to the current version of
Horizon.
Sorry, can I pause you because we will come to that
email.
Okay.
That's quite some time later though. What I want to ask
you about is what you thought at the time that you
received this email. So we dealt firstly with
a questionnaire in late November 2017 --
122
if this contains all historic and current KELs?"
"The answer presumably is yes, and am I okay to
repeat the info you gave to Pete below as the answer to
Amy?"
He answers "Yes, and Yes".
For information below related to the distinction
between a Legacy Horizon KEL and a Horizon Online KEL;
is that correct --
Yes, mm-hm.
-- how to distinguish the two.
That's right. I think he includes a screenshot, doesn't
he, showing the difference. Yeah.
Is that the answer which you gave to Womble Bond
Dickinson, to the effect that, yes, they had all of --
l assume itis, yes.
Approximately six months later, you received a further
request from the Post Office's lawyers to provide any
KEL entries relating to the Callendar Square bug; do you
recall that?
Yes.
You initially provided to them some statements and
material relating to the bug; is that correct?
Yes.
You told them that you didn't believe that there was
a KEL relating to that particular bug; is that right?
124
(31) Pages 121 - 124
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
>
2
The Post Office Horizon IT Inquiry
So I think it transpired that there wasn't one in the
set that we had given to them and, therefore, it looked
like there wasn't one available.
Is that the basis on which you said, "I believe there
isn't one"?
I'm not quite sure but I suspect that if I -- I may well
have checked with either John Simpkins or Mark Wright
and, if it wasn't in the set that we provided to WBD,
then I expect that, if they went and looked for it, they
wouldn't have found it.
Just to assist you, the relevant email chain is at
FUJ00179779, please. Thank you. The original requests
can be found on page 4, please. Forgive me, if we just
scroll down a little bit, please, to the email from Lucy
Bremner, thank you.
So this is dated 11 September, addressed to you and
Pete Newsome, this email not copied to Mr Jay on this
‘occasion, the lawyer. It reads:
"Matthew, Pete,
"You may recall a while ago I asked you to provide
information on Callendar Square, Falkirk. Apologies if
I have missed your response, however I think this CEO
may still be outstanding.”
So chasing up an earlier request, it would appear;
is that fair?
125
So it is actually a subsite within that site, yeah,
that's correct. So it contained all of the KELs. So
this is basically a means of keeping a record of what we
had provided to WBD. So it seems perfectly possible
that I would have searched that and then not found it
but it also be the case, and seems very likely, that
I would have spoken to John Simpkins about it or Mark
Wright and they may have looked for it as well.
Is this, you say, before this email --
Um...
Because we will come on to see that you did seek some
clarification from John Simpkins?
Yes.
But it's the basis of your assumptions?
So it's not completely clear from this because one thing
you have to remember is that not all of the
conversations I had with people, such as John and Mark,
were done by email, since they sat on the floor directly
above me. So I may well have gone and spoken to them.
If we scroll up, please. So, essentially, forgive me,
we can keep going up through, there's some back and
forth between you and Ms Bremner over what materials
held relevant to Callendar Square --
Yes.
-- and you provide some additional material, including
127
1
2
3
4
5
6
7
8
9
10
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
A
a
12 June 2024
It sounds like it, yes.
"Please could you provide me with any information you
have on this. Could you also confirm whether KELs exist
for this bug?"
If we follow up to your initial response, please.
You initially reply, 12 September:
“Lucy,
"The attached email I sent to you in July included
the zip file that was originally provided to Second
Sight, and which includes information relating to the
Callendar Square case.
"I don't believe there is a related KEL but I will
check for other information.”
My question was what the basis of that assertion was
and I think your answer is that it wasn't contained
within the original batch and, therefore, you'd assumed
that it didn't exist.
So I think it's -- looking at that now, I think it's
quite likely that, when the -- when we provided WBD with
the set of KELs, I believe we also uploaded the same set
‘on to our SharePoint site, which, therefore, was
separate from the SSC's original database, but then,
in--
Can I just clarify, which SharePoint site are you
referring to? Is this the data integrity —
126
statements from Gareth Jenkins; is that correct?
Yes, I believe, so.
Then -- thank you -- on 24 September Ms Bremner says:
"On our call last week you said you were waiting for
Gareth to confirm whether there is a KEL for Callendar
Square -- can you let me know?
"Kind regards,
"Lucy."
Now, is that something you recall raising with
Gareth Jenkins at the time?
I don't recall it, no.
It seems as though you've told Ms Bremner that that was
something you were doing?
It seems likely that -- yeah, possibly. Or she may have
thought that I -- I mean, it seemed to me from this
email thread that I was talking to Gareth about other
aspects of what they were looking at, at this point. So
it may be that she thought I was waiting for him to
confirm that as well, although that may not be the
case -- it kind of seems more likely to me that I would
have spoken to SSC about it, rather than Gareth, as to
whether there was a KEL.
Why is that?
Because they're the custodians of that system.
I suppose it is possible that -- I mean, because we got
128
(32) Pages 125 - 128
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
>
prop
The Post Office Horizon IT Inquiry
into the point of whether -- so I believe that Callendar
Square was a Horizon issue rather than HNG-X issue, so
it seems possible that the KEL may have been deleted,
but since Gareth was working there at the time,
I suppose it's possible in theory that he may have had
a local copy of it that hadn't been deleted. But,
I mean, that's speculating in some ways and I'm not --
don't think that is the discussion I was having with
him.
When you say a local copy, you mean stored on a laptop
or--
Indeed.
Thank you. Can we scroll up, please. So you contact
John Simpkins, having been pressed again by Ms Bremner
for an answer on this issue as to whether there exists
a KEL for Callendar Square. You say:
"John,
"lam being asked if we can confirm if there is/was
a KEL for the 'Callendar Square’ issue. Are you able to
confirm that definitively please?"
You say:
“Please see the attachment which describes it
(points 1-4); it seems that it was a known issue that
was fixed in S90..."
Do you recall what that is?
129
say that I think it shouldn't have been deleted.
That's your opinion as a Document Manager?
Yeah.
If we turn, please, to first page, we can see -- forgive
me, at the bottom of the first page -- we can see the
initial response you received from John Simpkins on
25 September 2018. He says:
"... Matthew,
“I have spent some time trying to track this down
via the branch name, date range, release, problem
description etc.
"However I have yet to find a matching KEL.
"I think that the best fitting PEAK is [and he gives
a reference] which is for the branch [named] but the
branch is in Falkirk."
He references another PEAK, which has:
"a good description of the problem, which is in
the Escher product, fixed in the new version at S90."
He then says:
"This KELJSimpkins338Q appears to apply which should
have been in the extract supplied to [you]."
To them.
Forgive me, to them, being the Post Office's lawyers.
Mm.
If we scroll up the page, please, we can see your
131
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
p>po>
12 June 2024
So that's a major release in Legacy Horizon.
A software release?
Correct, yeah.
"... and that in this context was of interest because it
was brought up in connection with the West Byfleet case.
“If it was fixed, and therefore the bug wouldn't
arise again, would a KEL, had it existed, have been
deleted?”
So did that reflect an understanding you had at the
time about the processes relating to the deletion of
KELs or is this simply an assumption that you --
Yeah, I'm not sure. I mean, it seems from the way I've
asked the question that I didn't know that at the time
and that's why I was seeking clarification, yeah.
I mean, I may have either started to suspect it, or --
yeah. I mean, logically, it seems possible, doesn't it?
So again, bearing in mind the fact that this
Callendar Square was a Legacy Horizon issue, that
related to Riposte. So by the time we got, you know,
several years into operation of HNG-X then it would have
had no operational relevance any longer.
What was your understanding at this stage about
Fujitsu's internal policy in relation to the retention
or deletion of KELs?
In terms of KELs specifically, I don't know but I would
130
response. You say:
"John,
"Thanks for this. It looks like [the KEL]
JSimpkins338Q no longer exists, it wasn't in the set
that we sent them. Do KELs get deleted?”
So, as you said before, some uncertainty on your
part as to what the correct procedures were.
Yes.
The response you received from John Simpkins:
"Yes KELs can get deleted.
"I will see if I can dig out the deleted KEL
details, or would you prefer that it is just stay as
‘deleted’.
Presumably that was meant to read that “it just
stays as deleted"?
I think so.
What did you understand Mr Simpkins to mean when he
wrote, "would you prefer that it just stay as deleted"?
Yeah, I'm not sure. I mean, to be honest, I'm not
really sure why he said that but, you know, I think I'd
interpret it in the same way that I guess anyone would,
which is that do you want me to not reveal it? I guess.
Essentially, was he asking you whether or not he should
be concealing the existence of a deleted KEL, even if it
could be retrieved?
132
(33) Pages 129 - 132
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
The Post Office Horizon IT Inquiry
It certainly does sound like that. I don't really know
what his intention is, to be honest.
What did you make of that suggestion at the time?
I think that it -- I mean, I wouldn't agree with doing
that and I don't think I did at the time, and I think
that that we didn't follow or even discuss following
that proposal, as it were.
Just going back, please, to your email, that you sent
him, beginning on the 26th, in that, you said it looks
like that particular KEL no longer exists. Do you know
how you established that, namely that the KEL no longer
existed?
So, again, as I said before, I would guess that was by
looking it up in the repository of KELs that I had on
the SharePoint site and possibly also looking in the SSC
website at the KEL repository. So the fact that it had
been deleted does mean that it would no longer exist if
you did a search in either of those places. You
wouldn't find it.
By deletion, did you understand at that stage that we
were talking about data that was irretrievable?
I don't think that I was sure, because I think I was --
as you can see here, that I wasn't even clear at that
stage whether they could be deleted or not. So I'm not
sure that I would have known what "deleted" meant,
133
"I have managed to retrieve this from the deleted
Horizon KELs table."
Then he proceeds to, in the body of the email he has.
copied and pasted the information that he has
recovered --
Yes.
-- in relation to that KEL. Now, so far as you're
aware, from where had Mr Simpkins retrieved this
information?
From something called the deleted Horizon KELs table
I mean, yeah, that's all I knew at that stage.
Did you know where that table resided?
Not -- not from that email, no. I mean, I think I found
out later that it's somewhere within the SSC database.
Was this the first time that you became aware that there
existed deleted Horizon KELs which could be retrieved by
Fujitsu?
Yeah, I think so.
Were you concerned to discover that there existed
a repository of KELs of which you'd not previously been
aware?
Well, I think the answer is yes and I think from -- in
the same email chain, you can see me asking whether
we've told WBD that before and raising some issues
around the fact that we have now some -- effectively
135
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
12 June 2024
necessarily. But you're right, deletion could be
deletion but retrievable or deletion but not
retrievable.
But that’s not something to which you addressed your
mind at the time, you don't think?
Not immediately.
A short time later, so after confirming that he would
make some enquiries and querying with you whether he
should provide anything if he finds it, he writes to
confirm that he has, in fact, retrieved the details of
the deleted KEL; is that correct?
Yes, it looks -- that's what he says, yes.
Could we please take a look at that email chain, which
is at FUJ --
Sorry, just one sec. So "I will see if I can dig out
the deleted KEL details". So he's not, actually, at
that stage saying that he has found it, I don't think.
No, we're going to move on to another chain. It's
a different chain so we don't see that reference to
whether it should stay deleted?
Right.
This is at FUJ00179940, please, on page 2. So this is
‘on the same day, about an hour later, after the email we
have just looked at. He says:
"Matthew,
134
some more KELs that we haven't previously referred to.
We'll come to that. Just staying where we are for now,
it would have occurred to you, would it not, that the
previous assurance which you had given to Womble Bond
Dickinson about having provided all historic and current
KELs, was incorrect?
I'm not sure that it did occur to me immediately in the
context of the EDQ, no. I mean, this is like several
months later, isn't it?
Sorry, not in the context of the EDQ but you were asked
by Womble Bond Dickinson to give a specific assurance --
Oh, right, yeah.
-- that you had disclosed all historic and current KELs
and, on the basis of what John Simpkins had told you,
you confirmed that was correct. I think you confirmed
that was correct?
Yes. Yes, correct. Yeah.
Now, what I'm saying is, it would have occurred to you,
wouldn't it, that, if there existed deleted KELs which
could be retrieved, you had not, in fact, provided all
historic and current KELs to the Post Office's lawyers?
Correct, yeah. So again -- well, I mean I don't think
it occurred to me in terms of that statement but I think
I go on to raise that question in this chain.
We will come to it.
136
(34) Pages 133 - 136
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
>
oP
prop
The Post Office Horizon IT Inquiry
Yeah.
Did you go back to Womble Bond Dickinson to notify them
that your earlier assurance about the disclosure of all
historic and current KELs was wrong?
Well, again, I think not immediately. But then, I think
we discuss it in this email chain and then I think
eventually we do go back and tell them that. Again,
I don't know about specifically referring back to that
email in which they asked that question and got that
response but I think we did provide them.
Well, let's look now at how the issue was handled by you
and your colleagues. We're on the same document,
please, at page 1. At the bottom of that page we see --
this is your email to Dave Ibbett. Could you just
confirm his role, please?
So Dave Ibbett was a Project Manager, a Fujitsu Project
Manager, who had been tasked with helping to project
manage this exercise, basically.
He was someone with whom you worked; is that correct?
Correct, yeah.
So he was supporting you in the management of requests
for information from the Post Office's --
Correct, yes.
There's also Pete Newsome and John Simpkins. So this is
following on from John's email to you; is that right?
137
possibility that you would not share the KEL and the
associated PEAKs with the Post Office's lawyers; is that
fair?
It is fair to say that. I mean, I -- I think when
I wrote this email, I was assuming that we were going to
share it, hence "when", and then I think I considered
that someone else may have a different view, bearing in
mind that Pete Newsome is, effectively, the manager of
this exercise, and he may have taken a different view.
So, ina way, it's not really my decision but I think
I'm pretty clear that it's going to happen, actually.
So your evidence is, essentially, you're looking to Pete
for direction on how to deal with it --
Yes.
-- did you consider that consider providing relevant
information to the Post Office was optional?
Err --
Was it your own view that it was optional?
I don't think it was, no.
You do express here some concerns that the existence of
deleted KELs appears to be inconsistent with information
you've already provided to the Post Office's lawyers; is
that fair?
Yeah, I think so.
If we scroll up to the top of the page, please. We can
139
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
2
12 June 2024
I believe so.
If we scroll down, please, sorry, slightly, we can
see -- thank you. So you're forwarding John's email
now, copying in Pete Newsome and Dave Ibbett?
Yeah.
You say:
“Pete, in looking into Lucy Bremner's questions
about whether there is a KEL for Callendar Square, John
has identified two PEAKs which he believes describe the
same issue, even if they were not raised in direct
relation to that same branch, and from that a KEL, which
has been deleted and was therefore not in the set of
KELs that we have shared with [Womble Bond Dickinson].
John has managed to retrieve the content of the KEL as
shown in the email below.
"When (if?) I share this KEL, indeed the PEAKs since
they reference the KEL, I'll need to raise the subject
of there being KELs which have been deleted. Is that
okay, have we previously mentioned to them that there
are deleted KELs?
"If we have to explain that then I suppose we need
to know why; John, do you know the criteria? Was this
a Horizon System only KEL that once fixed by $80, or
once superseded by HNG-X, was no longer required?"
Now, here you appear to be considering the
138
see the first response you received to your query from
Pete Newsome. He says:
"Matthew
"I think we should send to [Womble Bond Dickinson]
saying how we identified the KEL and that it was deleted
from the database by John ..."
Sorry, presumably it should read 'but John"?
Mm-hm.
"... was able to find a copy on a local drive.
"Pete."
So what Mr Newsome appears to say is, yes, we do
disclose the deleted KEL; is that fair?
Yes.
But, by way of explanation for the late disclosure, he
suggests that you tell Womble Bond Dickinson that it was
found on a local drive?
Yes.
Did you consider that statement to be true?
No, because I think John had -- I think in hits -- well,
in his email beneath this he had said that he'd found it
in the deleted table and I think I probably had
a discussion with him in which he said that it was
a table within the database. So that, to me, would
immediately sound like it wasn't a local drive but was
a table within the SSC website somewhere.
140
(35) Pages 137 - 140
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
The Post Office Horizon IT Inquiry
From where do you think Mr Newsome obtained the
information that John had been able to find a copy on
a local drive?
I think -- well, I mean, I can only assume he's making
an incorrect assumption.
Do you think it's possible that that was simply made up
by Mr Newsome to avoid any further questions about
deleted KELs?
It's possible.
Please could we look at the response you received from
John Simpkins to your query about why the KEL had been
deleted. This can be found in a separate chain, please,
at FUJ00179952.
Thank you. At the bottom of that first page,
please, we can see an email from John Simpkins dated
26 September, in which he says, in answer to your
question:
"Yes, I would expect that once S90 was released the
proved that this was fixed the KEL was deleted."
So, obviously, some grammatical errors there but
essentially saying that it was his expectation that it
was deleted once the release was thought to have fixed
the problem; is that fair?
Yes, well, he's saying he -- it looks like he's assuming
that. He doesn't know that for a fact but --
141
why it was there; is that what you're asking?
No, forgive me. I'm simply making the point that here,
a short time later, he's advancing a further
explanation.
Mm-hm.
But forgive me, he's instructing you to give a different
explanation as to why the KEL had been -- as to why the
deleted KEL had been discovered.
Well, no, I'm saying that's too separate things though,
isn't it? So the reason it's been discovered is not the
same as the reason it was deleted.
Forgive me.
Yeah, he's providing the reason why it was deleted, not
how or why it was found.
But providing an explanation as to why it wasn't
disclosed in the first place; isn't that the
underlying —-
Um, yeah, I guess so. It's -- yeah. I mean, the fact
that it was deleted is the reason that it wasn't
disclosed in the first place, not why it was deleted
though. I mean, why it was deleted, in some ways, could
be another reason, couldn't it? But it's connected but
it's not the same thing.
No, I agree with that. But it's all part of, is it not,
an attempt to explain away why Fujitsu has discovered
143
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
>
12 June 2024
He's making an assumption?
Yeah.
Do you know why Mr Simpson would have been making
an assumption rather than knowing the reason for the
deletion of the KEL?
I mean, I think unless somebody had made a note as to
why the KEL was deleted, then there wouldn't be any
other explanation recorded anywhere. So I think he
would just -- he's just kind of logically deducing that
that is almost certainly the case, in his opinion.
If we scroll up to the top of that first page, please,
we now see a further instruction from Pete Newsome. So
very shortly after the email we looked at earlier, in
which he suggested providing explanation about a local
drive. He now says:
"Matthew
“Include this as to why we deleted the KEL."
Now, this explanation didn't rely on a purported
discovery of the KEL and a local drive but upon
an assumption that Mr Simpkins had made that the KEL had
been deleted; is that fair?
So that's two separate things, though, isn't it?
Forgive me, I'm saying so we've moved on from the
original explanation, which was --
So one of them is how he found it and the other one was
142
a KEL that wasn't previously disclosed?
I guess so, yeah.
This is the explanation which you provided to Womble
Bond Dickinson, is it not, when you handed over the
deleted KEL; do you recall that?
The explanation as to why it was deleted, I believe that
is what I told them.
Can we look at FUJ00159985. Thank you. Your email is
at the bottom of page 1, on to page 2. Thank you. So
it's dated 28 September. You say:
"Lucy,
"We have locked into this, and it appears that the
relevant PEAKs are [give the references] attached.
"The two related KELs were deleted, due to the fact
that the S90 release was proven to have fixed the issue,
and they so would not be included in the set of KELs
which you have.
"We have been able to retrieve the text from one
[of] them [it should presumably read] however, as
attached [and you provide that as KEL JSimpkins338Q]."
Now, in this email, you assert as fact that the two
related KELs had been deleted because it was shown the
issue had been fixed by a software release, do you not?
Yes.
You didn't know whether that was, in fact, the reason
144
(36) Pages 141 - 144
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
The Post Office Horizon IT Inquiry
why they'd been deleted, did you?
Well, I was given that explanation by John Simpkins, and
assumed, therefore, that it was true, since that was his
view, and I'm not sure what other explanation -- I mean,
yeah, I -- I'm not --
Forgive me, the point I'm trying to make is that you had
an assumption that he'd made and you accepted that that
was an assumption and you assert it here as a fact?
Okay. Yes.
If you were being entirely accurate, you would have
said, "We don't know why they were deleted but we assume
it was because the problem had been fixed by a software
release", would you not?
I could have stated it in that way. I'm not sure that
it was clear to me how sure John Simpkins was of that --
his view. So, I mean, I -- if what I'm saying --
If he wasn't sure if his view, how could you be sure --
Well, I'm not sure that I had any particular reason to
doubt it but you're right though: maybe this is
overstated in terms of sounding like it's a 100 per cent
certainty.
Were you hoping to shut down any further enquiries into
the existence of deleted KELs?
I don't think so, no. I mean, to be honest, I am not
sure that I would have had any interest in doing that.
145
the corresponding issues are fixed ..
She then lists four questions. Firstly:
"Is that procedure a general rule?
“If so, is it enshrined in a formal process?"
Thirdly:
"If so, which -- and do we have the corresponding
documentation?"
Fourthly:
“Are all deleted KELs available in a searchable
archive? I assume that text could, in principle, be
retrieved from other KELs."
She asked for an urgent response because they are
having a call with the experts that morning.
Now, you refer these queries to John Simpkins; is
that right?
I think so.
It appears you carry out some research yourself into the
processes for deletion of KELs; is that right?
I think so.
On the basis of that research and the responses you
received from Mr Simpkins, you respond to Ms Bremner.
We can see that response, please, at FUJ00160063, at
page 2, please. So we see a list of the original
questions and your responses in bold; is that correct?
Correct, yeah.
147
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
12 June 2024
Do you think you were being entirely transparent in the
explanation that you gave?
I think possibly more information could have been given
but, I mean, to be honest, I think I thought I was being
helpful and providing them with an answer to the
question that they had given. I mean, I don't -- to be
honest, I just don't think -- no -- it's of no interest
to me to hide whether there were deleted KELs or not.
It makes no difference to me.
Would you have been concerned, though, about the
reputation of Fujitsu and how it had handled the
disclosure of KELs to date?
Not really.
Two weeks later, you receive a number of queries from
Womble Bond Dickinson about the deletion of KELs; is
that right?
I think so, yeah.
Can we take a look at that email, please, at
FUJ00181400. Thank you. If we could scroll down,
please, to page 4. So this is an email of 11 October
from Lucy Bremner. She says:
“Matthew,
"We have sent the two KELs for Callendar Square to
our IT experts. They have come back with the following
questions for you relating to KELs being deleted when
146
In square brackets, you've written "Matthew Lenton" to
indicate you're the author of the text?
Yes.
So you answer the first two questions in the
affirmative, that's correct?
Yes.
The third you provide some documentation that you've
managed to source; is that from Dimensions?
Correct.
Finally, the fourth question, about whether or not
deleted KELs are searchable and can be retrieved, you
state:
“They are not text searchable in their current
location, but all deleted KELs can potentially be
retrieved, although this would require additional time
and effort to do, after which those retrieved would then
be searchable. It is believed that all deleted KELs are
still in the archive table.”
Now, from where had you obtained that information?
Almost undoubtedly from John Simpkins.
Did you make any specific enquiries of Mr Simpkins as to
whether or not all deleted KELs could in fact be
retrieved?
Well, I was going to say I think it transpires later on
that that's not correct and that there were deleted KELs
148
(37) Pages 145 - 148
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
prop,
prop
The Post Office Horizon IT Inquiry
that were retrievable and deleted KELs that were not
retrievable.
Thank you. We will come on to that shortly.
Now, I think within minutes of sending this response
to Womble Bond Dickinson, you receive a further email
asking you to confirm how many KELs have been deleted --
Right.
- is that right?
I think so.
We can look at that, please, FUJ00160063. I think that
may be where we are anyway. On the first page, please.
Thank you. So she follows up with that query, which you
refer to John Simpkins, please, at FUJ00181400. Thank
you. So, at the bottom of the first page, please, we
can see your email to John Simpkins:
"John, do you know how many KELs have been deleted
to date?
"That's [Womble Bond Dickinson's] question for now,
are you able to provide an answer please?
"I think I know what's coming next."
What did you mean by that?
Well, once we tell them, they'll ask for all of them.
We can see Mr Simpkins’ response, in the middle of the
page, please, at 16.01. He says:
"Horizon deleted KELs -- [there are] 1,281.
149
I think it transpires in early November, you do provide
a tranche of deleted KELs, 1,491, in response to their
request; do you recall that?
I believe so, yeah.
Now, in early February 2019, you receive several queries
from Womble Bond Dickinson which were prompted by the
claimants’ technical expert. Do you have any
recollection?
I'm sure I do. If you show me --
Yes, of course.
-- more specifically what we're talking about.
That email is at FUJ00086758, please. Thank you,
page 3, please. If we could scroll down, please, to the
bottom of page 3, thank you, so this is 6 February from
Lucy Bremner, she says:
"Matthew,
Jason Coyne", who was the claimant's technical
expert. Do you recall him as such?
Yes, yeah.
"... has referred to a number of PEAKs/KELs in his
supplemental report that he states have not been
disclosed. Can you let me know why they are not in the
PEAK/KEL extracts that we have received from you? Is it
because they were all from the system 'PinICL'? If you
can provide any dates relating to them that would be
151
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
9
10
"1
12
13
14
15
16
17
18
19
20
21
22
23
12 June 2024
"HNG-X [Horizon Online] deleted KELs -- 212."
He goes on to say:
“Please note however that come KELs would have been
deleted because they were wrongly raised as well as.
those out of date. So we cannot confirm that all the
information in these is valid, ie if the SMC raised
a KEL wrongly the SSC may well have deleted it as such.
Therefore I have reservations about supplying an export
of deleted KELs."
What we appear to see here, do we not, is some
reluctance by John Simpkins to consent to the disclosure
of the deleted KELs; is that fair?
Yeah, I mean, I'm not completely clear what he means
about reservations. I mean, I don't know whether he
means reluctance to supply them at all or just those are
his reservations, in that there may well be
a significant number of deleted KELs that are actually
not valid as KELs at all. I mean, I think I recall
there was a fairly, fairly regular problem with SMC
raising KELs for which there were already KELs. So you
would end up with a duplicate. And I think he's
referring to those also being included in that set.
So I'm -- it's possible that his reservation is more
about we can't just send the whole load over because
some of them just simply aren't valid and never were.
150
appreciated."
We can see here you have again adopted the method of
putting your responses in the body of the email in bold.
In relation to the KELs, you say several of them are
deleted, not deactivated, and they cannot be retrieved.
Now, that, of course, was different to what you'd
said previously, which was that you'd understood them
all to be retrievable.
Yes, although, as I say, later it transpired that some
deleted KELs were not retrievable. I'm not quite clear
whether this is before or after that statement. I mean,
I think you can see from this that there's a kind of
lack of knowledge on my part about whether -- about the
status of deleted KELs.
If we go to page 2, please --
Forgive me, sir, I may have an erroneous reference.
In any event, I think we're due to give the transcriber
a break, so I wonder if we could, please, briefly break
now, whilst I make sure I have the correct reference
when we come back and I can take Mr Lenton to the
relevant email.
SIR WYN WILLIAMS: Certainly. When you say "briefly", do
you mean we take a 15-minute afternoon break or just —-
24 MSHODGE: Yes, please. Our regular break, thank you.
25 SIRWYN WILLIAMS: Fine. So it's 2.50, so 3.05.
152
(38) Pages 149 - 152
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
The Post Office Horizon IT Inquiry
MS HODGE: Thank you sir, yes.
(2.50 pm)
(A short break)
(3.05 pm)
MS HODGE: Good afternoon, sir, can you see and hear us?
SIR WYN WILLIAMS: Yes, thank you.
MS HODGE: Sir, thank you for the time.
The reference, please, is FUJ00086758.
Mr Lenton, you mentioned more than once in your
evidence there was some ambiguity in the terminology
used but that you did clarify that in an email to Womble
Bond Dickinson. This is your email of the 13th -- well,
it's Ms Prime's email of 13 February. We can see at the
very top there you confirm that you've inserted your
comments into the body of the email --
A. Yes.
Q. -- as you'd done on previous occasions. So if we scroll
down, please, to Ms Prime's email, where we have her
questions and your answers in bold. The first related
to the PinICL system which was the predecessor to PEAK;
is that right?
A. Yes, that's correct.
Q. The second point relating to deleted KELs. She asks:
are [these] not retrievable? Or were [they]
provided to us on 5 November 2018 ..."
153
Q. You go on to confirm that that is the set of KELs that
had been provided to the Post Office's lawyers in
November 2018.
Then we have another category which you describe as
deactivated KELs. She says:
... these were provided to us in the extract in
[March or November]?"
You say:
"These are KELs that have not been deleted into the
‘deleted table’ but are excluded from the SSC's default
searches which focus on live KELs, but can be included
easily by changing the search criteria.”
They formed part of the original March batch, so
they were presumably the historic KELs that you did
provide in March 2018; is that correct?
A. I believe so, yes.
Q. Then a fourth category is deprecated KELs, is that the
correct pronunciation?
A. Yes.
Q. She said:
"... these were provided to us in the extract in
March 2018, or on 5 November 2018?"
So asking "Have we had them?"
You say:
"When a KEL is updated, the old version of that same
155
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
12 June 2024
So this is triggered by some confusion as to whether
or not deleted KELs were or were not retrievable?
Yes.
You explained that there are two categories. Firstly,
deleted KELs that are no longer retrievable because
they've been completely deleted. You said:
"This was before the SSC started saving them into
a ‘deleted table’."
I think you said in your evidence that that was not
something you would approve of from a document
management perspective; is that correct?
Correct, yeah.
You say:
"These cannot be provided, and if a KEL is referred
to by us as not being retrievable, and, I believe, all
KELs that are referred to in [the Claimants’ expert's]
report as not having been disclosed, then they fall into
this category", so deleted KELs which you cannot
retrieve.
The other category of deleted KELs are those which
are retrievable due to being deleted into a deleted
table, to which Mr Simpkins originally referred you in
response to the Callendar Square bug query; is that
correct?
I believe so, yeah.
154
KEL is deprecated, so these are superseded versions of
live or deactivated KELs. We have only provided the
most recent versions, so we have not separately provided
these superseded versions. Note that there are no
deprecated versions of KELs in the category 2a", that
being KELs which were deleted before to the introduction
of the deleted KEL table and which fall within your
definition of irretrievable; is that right?
Correct.
The final category she has are live KELs. You confirm
these were provided in March and you confirm when she
says, "Are there any other ... KELs", no, all KELs are
covered by categories 2 to 5 above.
Now, the fourth category of deprecated KELs, this
was another category of historic KELs which hadn't been
disclosed; is that right?
So, rather than using the word "historic KELs", because
that has possibly the implication that they're no longer
current KELs, so deprecated KELs could be just
superseded versions of any KELs that exist.
So both current and historic?
Well, I'm assuming that deactivated KELs could be
regarded as historic but, from what it says here there
would be deprecated or superseded versions of those.
Of the deactivated ones?
156
(39) Pages 153 - 156
ONOaARWN
oP
1
12
13
14
15
16 A.
17
18 AL
19
20 a
21
22 Q
23
24
25
prop
2
>
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24 A.
25 Q
The Post Office Horizon IT Inquiry
Yeah, as well as the live ones, yeah, of course.
Now, as earlier iterations of either a current or
a deactivated KEL -- sorry, these were earlier
iterations, that's essentially the point you're making?
Yes.
They would have contained information relating to the
symptoms of the fault, it's underlying causes, the
solution and related PEAKs, would it not?
Possibly.
Be consistent with what we see in other KEL documents?
Yeah, mm-hm.
If they contained that information, would they not have
provided valuable evidence about the detection,
diagnosis, and remedial action which had been taken
previously in response to the --
Potentially.
Possibly?
Yes. I mean, bearing in mind of course that the most
recent versions were provided.
The current versions?
Yeah.
Now, I think the point you make later is that here in
this email, perhaps not advertising, but you were
drawing to the attention of the Post Office's lawyers
that there is yet a further category which Fujitsu holds
157
relation to KELs
That's the passage of course which we looked at
earlier. She said:
"Can you confirm that this is definitely the correct
position ... We need to respond to Freeths ..."
Now, your response a little further up,
unsurprisingly, was that that was not entirely correct.
You say:
"The second sentence is not correct, [that being]:
‘The previous entries/versions of the current entries
are no longer available’."
You say:
“You may recall that there are three status
categories of KEL: current, deprecated and deleted. For
those that are current or deprecated, they have been
updated in such a way that previous content is not
permanently overwritten, but instead a new version is
created, with the previous versions being retained and
accessible. For those that have been deleted, only the
last version at the point of deletion has been
retained."
Now, you had disclosed a batch of deleted KELs in
November, that's correct, isn't it? We've covered that.
Yes.
But you hadn't disclosed any of the KELs falling into
159
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
prop
oP
prop
12 June 2024
which hasn't been disclosed?
Correct, yeah, and yeah, as I'm sure you're leading to
already, this is contrary to what was stated in the EDQ,
yeah.
So we come, then, to a further query in late September
2019 and this relates to the accuracy of the Electronic
Document Questionnaire. Do you recall that being raised
with you by the Post Office's lawyers?
Ido. It's - did you just tell me the date just then
it.
This is late September?
Yeah, I mean, it was after this email, isn't it,
I believe?
That chain, please, is FUJ00166835.
Yeah, so it's considerably after that last email,
I think, in fact, isn't it?
Thank you. Pages 9 to 10. Bottom of page 9 on to
page 10, please. Sorry, if we scroll down, please,
a little further, we'll have the original email from
Ms Bremner. Thank you. So that's 30 September 2019.
She says:
“Matthew,
"Post Office is seeking to closed from its
Electronic Documents Questionnaire submitted back in
2017. It's seeking to rely on the following quote in
158
the deprecated category?
That's correct, yeah.
Do you recall how many deprecated KELs existed?
I believe a figure of something like 5,000.
Could we, please, turn to FUJ00166835. Thank you. So
this is in early October. You've been asked to provide
an entirely refresh extraction of KELs; is that correct?
Yes.
Here you provide a breakdown of the different
categories. We see there against deprecated KELs there
were 6,155; is that right?
Right.
Does that sound correct?
Yes.
Is that the number of KELs which were disclosed by
Fujitsu after the conclusion of the Horizon Issues
trial?
That's the total number of new documents that were
disclosed, yeah, because it says that there were 14,365
disclosed, of which about 8,000/9,000, had already been
disclosed.
I think you've accepted that these 6,155 documents might
have provided valuable evidence about the detection,
diagnosis and remedial action taken to address known
errors in the system; is that right?
160
(40) Pages 157 - 160
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
o>
The Post Office Horizon IT Inquiry
Potentially.
I'd like to move on to a new topic, please, which
relates to your knowledge of and information which you
provided about remote access. In your statement, you
say you were not aware until the Group Litigation that
Fujitsu staff had the ability to insert transaction data
into branch accounts without the express knowledge or
consent of the subpostmaster; is that right?
Correct. Yeah.
It appears, from the documents we have, that this issue
was brought to your attention in or around May 2018
because of a request for information made by the
claimants’ technical expert; is that right?
Right. I think so.
If we look, please, at FUJ00222620. Now, I think,
please, if we could scroll to the very bottom of that
document, we see the original request from Womble Bond
Dickinson. Thank you. So this is just for reference.
This was the genesis of the request that came in,
requests for information from the claimants’ experts.
You were asked, were you not, to identify documents
which were responsive to that request?
Yes.
One of the topics covered by the claimants’ expert in
his request for information was remote access; do you
161
following page -- forgive me, and one on, please. Thank
you.
So the other questions relating to remote access
1.14 to 1.16. 1.14 states:
"Can it be described what privileges and
capabilities administrators had in relation to branch
remote access and the relevant processes and
procedures?"
1.15:
"Please describe how transaction amendments
(including reversals and balancing transactions) can be
identified for those which were not carried out by the
SPM in the audit/transaction data/logs ..."
So if we can, please, briefly look at the comments
on the followed page, these are comments from the Post
Office's lawyers. J14 and J15 indicate their
understanding that the query relates both to balancing
transactions and privileged user access; do you see
that?
Mm-hm, yeah.
Now, I think it’s right, is it not, you took steps to
identify documents which you understood to be responsive
to those requests; is that right?
I believe so, yeah.
You also sought information from a subject matter
163
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
12 June 2024
recall that?
I believe so, yeah.
I wonder, please, if we could show the information
request, it bears the reference FUJ00222364. Thank you.
The relevant section relating to remote access, please,
is on page 2, under the heading "In relation to Issue
7". Forgive me, this contains the comments. It will be
the following page. Thank you.
If we scroll down, please, "In relation to 7", thank
you. So at question 1.13, the claimants’ expert asked:
"When Fujitsu accessed branch accounts to modify or
insert data, can it be described what the need for that
access was and what modifications were performed? Can
it be confirmed how many times this occurred?"
Now, we can see some small boxes with the letters
and numbers J9, J10, J11. Do you recall what they were?
So I think these are comments by Jonathan Gribben from
WBD.
Thank you. So just dealing first with question 1.13,
essentially, what you're being asked there is what
records you hold or what records Fujitsu hold indicating
for what reason and how often Fujitsu had inserted data
into branch accounts; is that fair?
Right. Yes.
Thank you, Could we scroll down, please, to the
162
expert, which, in this case, was Stephen Parker; is that
right?
Yes, I think so.
Let's look briefly at that exchange, please. It can be
found at FUJ00222620. Thank you. Your email to
Mr Parker can be found at the top of page 2, please.
Thank you. It's dated 24 May 2018. You explain to him
the documents which you've attached to your email. They
comprised the request for information, which we've just
looked at, as well as a table of documents, that you'd
prepared that you understood to be responsive to the
request; does that sound right?
Yes.
You then say this, the third paragraph:
"Questions 1.13 to 1.16 all relate to issues around
remote access to the live system and corrections ...
Something I've tried to point out is that there are two
different processes both named ‘Transaction
Correction’ -- one is the TPS/POL Finance Systems
corrections generated wholly within POL which are
delivered via the file described in [you state the
reference], and I understand this happens regularly.
The other is the ‘Transaction Correction Tool’ which is
described in [you state document reference] which
happens very rarely (once?); this is where I'm getting
164
(41) Pages 161 - 164
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
2
prop
rPOPrPOPOP
The Post Office Horizon IT Inquiry
referred to SSC. Are you able to provide additional
information in response to the questions in the comments
labelled 'JONATHANG' for 1.13 to 1.16? Are there logs
of it being requested, being done, and what is the
procedure for authorising and doing it ..."
In that section we've just read, you identify two
tools by which corrections can be made to branch
accounts, the first is in the Post Office's back end
accounting systems; is that correct?
I believe, so, yeah.
The second being a transaction correction tool developed
for the use in Horizon Online?
Yes.
You don't make any mention there of privileged access
rights; is that fair?
I don't, no.
Why is that?
Well, I'm not sure. I'm just simply not commenting on
it. I suppose it's sort of covered by the last sentence
in that paragraph in a way, since that includes asking
about the procedure for authorising and doing it.
Were you aware at that stage of what those rights were
and what they entailed?
I don't think so.
You receive a response from Mr Parker on 25 May and, if
165
"These systems will contain full details of the required
correction, method of execution, approval, etc.”
Now, to which tools or methods of access did you
understand Mr Parker to be referring here?
When he says "These systems”, you mean?
Yes?
So he's referring to MSC or OCP.
But, specifically, MSC and OCP were not tools, were
they, to insert data into a branch account?
Okay, so sorry, you're asking about --
The method --
The methodology.
-- of the record?
Okay, sure, um ~
To what method did you understand him to be referring?
So he's talking about the balancing transactions, so the
HNG-xX tool, that is referred to, the second one referred
to in my previous email. So he's saying, not the
POL-TC.
You didn't understand him to be referring to privileged
access rights?
He's not overtly referring to that, is he? But the ...
he's not but, again, I think it's kind of -- in his
mind, I'm sure it's contained in that last sentence
where he talks about approvals, et cetera. So yeah.
167
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
prop,
12 June 2024
we scroll back to the top of the first page of this
document, please, thank you. He says:
“Matthew,
"Starter for 10 as follows ..."
In response to that first query, question 1.13, he
states:
“There is no functionality in Horizon for either
a branch, Post Office or Fujitsu to modify or remove
transaction data once it has been recorded in a branch's
accounts. It is only possible to post auditable
correcting transactions to a branch's accounts."
He then states:
"In the very rare circumstances where an accounting
error cannot be corrected by POL's use of a TC
[transaction correction, presumably] and it is necessary
for support to make such a correction it has been
subject to whatever change approval process is in use at
that time. Currently MSC ..."
What is that referring to, please?
That's a system. It stands for Managed Service Change.
"... latterly, OCP."
Which was?
Operational Change -- I'm struggling to remember what
the P stands for -- process. Proposal, sorry. That's
right.
166
He's not explicitly referring to it, though, I agree.
Did you make any further enquiries with him at this
stage, do you know?
I don't remember off the top of my head.
The issue of remote access arose again in January 2019,
so quite some time later, when the Post Office's lawyers
requested disclosure of logs relating to the auditing of
privileged user access.
Right.
Do you have any recollection of that?
I think so, yeah.
If we could look, please, at FUJ00188147. Thank you.
Page 5 and on to page 6, we can see the original
request, please. Thank you. So it arose in connection
with, I think on this occasion, the evidence of Torstein
Godeseth, and it was a query relating to managed service
change, which we saw referenced in Mr Parker's previous
email, and to what we call sign-off documents. What
were they, please?
Well, managed service change involves a method of
proposing and planning a change to a live system and
then sign off means somebody approving it.
So it was suggested at the time these provided an audit
log of the use of privileged access; is that fair?
Correct, yeah. They're like a manual audit log though,
168
(42) Pages 165 - 168
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
>
2
prop
pProrop
The Post Office Horizon IT Inquiry
so somebody actually
It requires an individual —-
Yeah, correct.
Now, is it right you carried out some enquiries to
locate relevant logs of the type we see here, the
managed service change logs: do you recall doing that --
I think so, yeah.
-- searching the system, which produced only nine
positive results.
Err, yeah --
If we scroll up please to page 3 --
I think so, yeah. I think I recall this, yeah.
Thank you. So you email Mr Parker, Mr Ibbett and
Mr Godeseth to say that you've, I think, run some.
searches on the MSC data archive and this has
produced -- there are ten listed, you say, that match
the search that you've run, the last one being the only
MSC with APPSUP in its title?
Right.
That being the Application Support privileged access; is
that right?
Yeah, correct.
You then cite one of the logs entitled "LIVE -- Remote
access to APPSUP database role from SSC users". You say
that one isn't relevant; that leaves nine examples —
169
logs?
Yes, that's right, yeah, so -- yes, indeed.
If we scroll down to the bottom of his email, he says:
“Not sure if this is an issue with the dataset or
the search method?"
That is to say he's not agreeing that nine could be
the right number --
It sounds --
-- and he's querying why it is
Yeah.
-- that your search has thrown up that number?
Yeah, mm-hm.
I think you then carried out some further searches, is
that right, in which you established an additional 61
instances in which the privileged access rights have
been used; is that correct?
I think so, yeah.
When you referred those results back to Mr Parker, he
suggested again that that appeared to be low, did he
not?
Yeah, he did, yeah.
Could we please take a look at his response, and the
reasons which he gives, and that's at page 1, please, of
this document. It's in the middle of the page, please,
Mr Parker's email of 4 January. He says:
171
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
prpo>r
12 June 2024
Mm-hm.
-- five of which are from 2010. You're saying to
Mr Parker, Mr Ibbett, Mr Godeseth, “Does that sound
realistically like it might be all there are?" So nine
instances --
Mm-hm, yeah.
-- of manually recording the use of the access right --
Yeah.
If we scroll up a bit, please. You have a response back
from Mr Parker, in which he says:
"For the use of APPSUP with full MSCs, that's
a reasonable number BUT I'm surprised that the search is
not throwing up any subtasks."
Can you translate that for us, please?
I think so, yeah, I think there's a concept within MSC.
of having an individual MSC for a task or a change and
then there's also having -- I think it's called possibly
amaster MSC. So where it's effectively an MSC covering
off a whole series of separate but possibly identical or
similar tasks that are carried out under that
authorisation, I think. That's what it's referring to.
He then cites an example of where he's found such
a subtask, is that right
I think that's right, yeah.
-- which hasn't been picked up by your search of the MSC
170
"It still seems low. The trouble is the systems.
were not designed for this kind of retrospective
interrogation and just don't support it. There is no
tag on an incident or change control which classifies
the kind of remedial action needed, the description of
any remedial action can be in a number of places."
Then he cites two examples of how a user might have
recorded the use of the tool but not done so explicitly;
is that fair?
Correct, yeah.
He says:
"I think we need to give the claimants the results
of this search while:
"(a) Clearly telling them the criteria used to
search.
"(b) Caveatting that we do not believe it is
complete and that it is not practical to return
a complete list because they would require applying
a mark one eye ball to all 220,000 PEAKs."
What did you understand Mr Parker to mean by
applying a mark one eyeball to all 220,000 PEAKs?
I think he means that somebody is going to have to look
at literally each one of them to determine whether that
role was used in order to close out that PEAK or as part
of that PEAK. I mean, I think, generally, my
172
(43) Pages 169 - 172
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
2
pProrop
The Post Office Horizon IT Inquiry
understanding of this is when he says there is no tag,
which classifies the kind of remedial action needed, he
means there isn't a tick box, for example, that says,
use APPSUP, tick, and therefore you'd be able to
retrieve them more easily knowing that it had been used.
So unless somebody went through each one of the PEAKs,
you couldn't say definitively -
That's my understanding of what he's saying, yeah.
-- how many times it had been used or why --
Correct.
-- and what had been done with it?
Yes.
Three days later you respond to Mr Parker, it appears
following a conversation with the Post Office's lawyers,
and we see that, please, at the very top of this page.
You say:
"Steve, I think you are right -- we haven't yet
covered off the MSC question, despite what Jonny just
said."
Can you confirm who the reference to Jonny is?
Jonathan Gribben from WBD.
You then say:
"Below is where we are up to in the discussion. As
he has said he is happy, shall we let it lie for a bit
and see if it comes up again? Or shall we provide what
173,
Parker, yeah, but I'm asking him to make the decision.
Now, approximately two months later, you received
a further query from WBD concerning the ability of SSC
users to grant themselves privileged access without
prior authorisation. Could we look at that, please, at
FUJ00089798.
Thank you. It's on page 2, please. We can see the
original request. So this one's from Andrew Parsons,
a partner at Womble Bond Dickinson. He says:
"One follow-up question on APPSUP, which I think may
be for Dave Haywood(??)"
Who was Dave Haywood, please?
So he is the -- well, he was and is the Lead Security
Architect at Fujitsu, for Post Office Account.
He says:
"I have attached the relevant PEAK. Could Dave (or
someone at [Fujitsu]) explain why it took 4 years for
this issue to get resolved?
"We suspect that Cs [a reference to the claimants]
will attack [Fujitsu] on this PEAK saying that [Fujitsu]
knew SSC had more access permissions than they should
have had and that [Fujitsu] were dilatory in fixing that
issue. If there is an explanation for why it took so
long that would be good? Or an explanation for why it
doesn't matter that it took so long?"
175
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
2
12 June 2024
we've worked out below?"
In his earlier email Mr Parker had stated that the
results ought to be disclosed but that the disclosure
should be accompanied by a caveat as to the scope of the
searches that had been carried out; is that fair?
Yeah.
By contrast, here you're suggesting that it might be
simply better to let it lie for a bit, in the hope that
the issue goes away; is that fair?
I'm not sure I'm saying it might be better. I'm just
offering him -- basically, I'm asking him to make the
decision on what we do.
Were you concerned that the response which Mr Parker had
provided raised more questions than it answered?
No, I don't think so. I mean, I must admit, the thing
that is missing from this email that I don't recollect
is what Jonny just said. So I'm assuming it's a phone
call that we've just been involved with. So I don't
know what was actually said and it could -- yeah, I just
don't know.
The implication seems to be that he's not pressing you
for an answer?
It sounds like it, doesn't it? Yeah.
So the opportunity is taken to let the issue slide?
I guess I'm offering that as a possibility to Steve
174
If we look at your response to that query, please,
on page 1 -- thank you -- so that's dated 8 March 2019.
You begin by clarifying what appeared to be some
contradictory statements that you and your colleague,
Mr Ibbett, had made; is that right?
Yes.
Then you go on to say this, this the second paragraph
under points 1 and 2:
"The ability for SSC users to switch themselves into
the APPSUP role without prior authorisation was removed
from existing users in August 2016; as to the reasons
why this took so long, we don't have an explanation for
the delay between the recognition of the preference for
removing the role from being a permanent role for SSC,
and that change actually being executed. Two things to
note about [the relevant PEAK] however are [firstly]
that was not originally raised in order to cover off
this particular issue, and that original purpose of the
PEAK was indeed closed off, [secondly] that it appears
that it was closed incorrectly, so that instead of it
being routed to Unix DBA as suggested by the penultimate
ended, it was instead closed. Following an audit in
August 2016 a new PEAK was raised ... in order to follow
up the task to remove the APPSUP role.”
Finally you say:
176
(44) Pages 173 - 176
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
>
The Post Office Horizon IT Inquiry
“As has been stated on previous occasions, even when
SSC had the ability to switch into the role themselves,
it was always a conscious decision to do so (so the role
was never a permanently applied state) and the switch
into it was always audited."
What did you mean when you said the switch into it
was always audited?
Presumably it's recorded that they've used that
permission or that role.
You had established, had you not, in your earlier
discussions with Stephen Parker that you, in fact, had
no way of accurately establishing how often the role had
been used without reviewing every single PEAK?
That sounds correct, yeah, although -- yeah. I'm not
sure what happened in between that and this, so there
may have been some other discussion about it.
But are you not here giving false assurance that the use
of the right is fully audited and can be accounted
for --
On the face of it, yes
-- when, in fact, you can knew that that wasn't the
case?
I suppose so, yes.
Now, you received a further query from Womble Bond
Dickinson in early March 2019, concerning the accuracy
177
end up probably going into the statement so, arguably,
you could say that I did but, I mean, I wasn't actively
involved in actually deciding what they would say,
I don't think.
I would like to ask you some questions about the wording
of a statement provided by Andrew Dunks in the Group
Litigation, please. Do you recall being asked to obtain
a witness statement for the Post Office's lawyers
concerning the extraction of audit data?
So I must admit I didn't recall it until you disclosed
the emails to me in the last couple of days.
Do you know why the request was directed to you?
Not really, no. I mean, only in that many of the
requests did come through to me, and it’s possibly just
one that I was able to answer. I'm not quite sure now.
Do you recall providing a draft statement to Womble Bond
Dickinson, now that you've read those emails?
So the draft statement in this case, I believe, was the
standard ARQ witness statement, so it was effectively
like a templated statement used by the security
Operations Team.
From where had you obtained that draft statement?
I think it was provided to me by Jason Muir.
Did you know by whom the standard form of words had been
drafted?
179
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
12 June 2024
of the evidence provided by Stephen Parker; do you
recall that?
A. Not immediately. But --
Q. That reference is FUJ00089798, please. Can we go to
page 9, please.
Forgive me, sir, I think on this occasion I do have
the wrong reference so if I have an opportunity I'll
return to it but we'll leave the subject of Mr Parker's
evidence for the moment, please.
‘SIR WYN WILLIAMS: = All right.
MS HODGE: My next topic, please, is the preparation of
witness evidence.
Please could you describe your role in the
reparation of witness statements provided by Fujitsu
employees?
A. Myrole. Yes. So similar to what we've seen in the
rest of the work that I did on this. It's largely
around assisting people with finding information,
answering questions or helping to answer questions or
finding information for -- to answer questions put by
WBD.
Q. Do you recall whether you had input into the drafting of
statements?
A. I don't believe that I did but there are questions that
I'm asked which I then obtained information for, which
178
A. No.
Q. Did you know in what context that statement had been
prepared?
A. If I didn't -- I may not have known at that time but,
I mean, since then, I do have an understanding of what
it's for but I can't recall whether that was the first
time that I was aware of it or not.
Q. Can we please look at some of the wording contained in
that statement at FUJ00160508. Thank you.
This is a copy of the draft statement which you
provided to the lawyers of the Post Office; is that
right?
A. Yes.
Q. We can see it's dated 13 November 2018.
A. Mm-hm.
Q. So that's, I think, just the day before you provided it,
so presumably you inserted that date?
A. I'm not sure. Possibly not.
Q. Just to orient ourselves, please, if we look at the
first paragraph of the draft statement, it reads:
"I have been employed by Fujitsu Services Limited,
on the Post Office Account, since 11 March 2002 as
an Information Technology Security Analyst responsible
for audit data extractions and IT Security. I have
working knowledge of the computer system known as.
180
(45) Pages 177 - 180
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
2
2
The Post Office Horizon IT Inquiry
Horizon, which is a computerised accounting system used
by Post Office Limited. I am authorised by Fujitsu
Services Limited to undertake extractions of audit
archived data and to obtain information regarding system
transactions recorded on the Horizon system."
Now, the statement goes on to provide an explanation
of the Horizon system, as well as what might be
described as controls around the extraction of data; is
that correct?
Right. I think so. Mm-hm.
The section of the statement I'd like to ask you about
can be found at the bottom of page 4, please, and on to
page 5. So the last two paragraphs read:
"A request was received on 3 October 2018 and asked
for information in connection with the post offices at
Caddington, Spencefield, Newport and Fleckney.
I undertook extractions of data held on the Horizon
System and followed the procedure outlined above.
I produced a CD containing the required data."
Now, was that information that you inserted, do you
recall?
No, I don't think so. So I think that WBD specified
what they were asking for and this was basically
inserted in order to provide the information requested.
Whether I inserted that in there or not, I don't know.
181
It's at FUJ00160649, please. Thank you. If we could go
down to page 2, please. To the bottom of that page,
please. So here, this is just one example, but here you
say:
"Lucy,
"Section now reads as follows (and as attached)."
You proposed effectively some amended wording to the
paragraph we just looked at:
"Does that need to be signed today, or can it be
done on Monday?"
Right.
Now, was that redrafting done by you or by someone else?
So I think it's at the -- I think either below this or
another email that specifies what it is that they're
looking for, so I think this is effectively just putting
into the statement what's being requested.
I think what -- I'm not suggesting that you were
necessarily making a decision as to what information
should be contained in it but you were actually doing
the drafting, is that fair --
Um --
-- based on the information that you had been fed?
I must say it is not what I would refer to as "doing the
drafting" but, you know, I inserted some words into it
at somebody else's request, yeah.
183
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
2
rPOPrPOP
12 June 2024
It may well have been Jason Muir.
It goes on to say:
"There is no reason to believe that the information
in this statement is inaccurate because of the improper
use of the system. To the best of my knowledge and
belief at all material times the system was operating
properly, or if not, any respect in which it was not
operating properly, or was out of operation was not such
as to affect the information held within it.”
What did you understand that statement to mean?
So my understanding of that is that it's referring to
the audit retrieval system.
When it refers to the system was operating properly?
Yeah.
You didn't understand it to be a generalised comment
about the integrity of the Horizon system?
No.
After providing this initial draft, you liaised with
Womble Bond Dickinson to clarify the wording of the
statement; do you agree with that?
I believe, so.
You proposed some amendments?
Um --
You can look at the email chain --
Did I?
182
Before we move on, please, to our final topic, at the
top of this page we have an email from you -- forgive
me, at the top of page 1 we have an email from you to
Ms Bremner, about the extraction -- forgive me, we can
see the middle of the page, 16 November 2018. You say:
"Lucy,
“Attached is the scan of the witness statement
signed by Andrew Dunks, and the same in word format.
"Just to clarify, Andy has confirmed to me that the
first retrieval was supplied to WBD on CD and to Gareth
by loading to a laptop; the second request was supplied
to Gareth on a CD, but not to WBD. So factually the
statement is correct ..."
This is in relation to the method by which the data
was supplied.
Right.
What I want to ask you is this: why was it that Gareth
Jenkins was being supplied with the audit data extracted
in relation to the lead claimants?
I assume it's because he was being asked to carry out
some analysis on it.
Thank you.
Final topic, please, before a couple of
clarifications. You've indicated in your statement that
the process of disclosure by Fujitsu was not supported
184
(46) Pages 181 - 184
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
2
prop
>
The Post Office Horizon IT Inquiry
by appropriate legal advice and oversight; is that
right?
In my opinion. Correct.
Now, we've seen in the documents to which I've referred
you today that Chris Jay, a senior member of Fujitsu's
Legal Team, attended meetings and was copied into emails
to requests for information and to responses; is that
fair?
Yes. But I think a relatively small number, from what
we can see in many of the other emails that we've looked
at, he's not included.
He was quite closely involved in the early stages of
disclosure; is that right?
In the early stages --
Particularly --
-- more so.
-- involving issues around the claimants’ access to KEL
software and Fujitsu's intellectual property rights?
I think that's right. I think he was involved in the
discussion around the non-disclosure agreement, for
example, yeah.
He continues to be copied into emails -- I accept not
all emails, but he continues to be copied into emails
throughout the period, does he not?
I'm not sure whether that's true. I mean, without
185
was an email where he said he was handing over to
somebody else, I think. So I can't quite remember the
name of the person but --
Was the concern that you -- sorry, I interrupted.
Yeah, so I mean, as I say, I can't quite remember now
but, in some ways, that's actually almost, you know,
indicative of the fact that I don't think there was that
much oversight, is that I don't quite remember what
happened to him in the end and whether he was replaced
by someone else. But I'm fairly sure that I saw
an email from him earlier in which he said he was
handing over to another person -- Julia someone,
possibly -- anyway.
Was this a concern which you had at the time?
I think it's -- I think it was much less clear to me at
the time and I'm not sure that it particularly worried
me at the time but I think, looking back on, that's
quite clear.
What prompted you to look back on it, to conclude in
hindsight there wasn't sufficient advice and oversight?
I think particularly, for example, the amount of
‘oversight that there has been in dealing with this
Inquiry, for example, has been much greater than it was
over our interaction with WBD for the trial.
How do you think you would have acted differently, had
187
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
>
prop
12 June 2024
looking at it and investigating it, I couldn't give you
a definite answer off the top of my head, but I -- my
impression is that he wasn't closely involved with the
process.
Some --
Latterly, particularly.
-- not all? Sorry, I didn't mean to interrupt you. He
was copied into some but not all, I think, is your --
That's my recollection and that's what I believe I see
from emails I look at, including many of the ones we've
looked at here today and that you've shown me over the
last few weeks, yeah, correct.
When you say that you feel that you weren't given
appropriate advice and oversight, is that specifically
directed at Mr Jay?
No, I mean, I don't think it would have mattered who it
was, but maybe the Fujitsu Legal Department generally.
So it's not about a specific person, it's about a --
I didn't mean to imply it's personal but he obviously
had some oversight. You're saying it wasn't sufficient
oversight?
Um -- that's --
So does responsibility for that fall on him, do you
think?
I don't know. I mean, I recall recently seeing there
186
you had better advice and oversight?
I think, probably, there would have been a lot more
resource, for one thing and, as I think I explain in my
witness statement, effectively, many of the people
involved in this were kind of doing it as well as their
normal day-to-day jobs. In fact, I don't think it was
really -- I suppose, probably apart from Dave Ibbett,
but even then I'm not sure about him, whether anyone was
actually doing it as their sole task.
‘And there would have been more resource, perhaps, in
terms of tools, and just the ability to actually do
greater amount of investigation and information
gathering and to be sure that we had all of the
information that was available.
I mean, in some ways -- yeah. No. That's ...
Thank you. I have some very short points of
clarification which I've been asked to raise and which
I'll do briefly now, if I may.
During and after the Group Litigation, did you
liaise with external lawyers other than Womble Bond
Dickinson?
After the Group Litigation? Um .
The reason I ask this specifically is --
In any context, do you mean?
So did you receive and deal with the requests for
188
(47) Pages 185 - 188
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
The Post Office Horizon IT Inquiry
disclosure from a Scottish law firm known as BTO.
Solicitors; do you have any recollection of that?
A. Possibly. I vaguely think I've heard of them, so I may
have done but I don't recall.
Q. You're not able to provide any details in relation to
that disclosure?
A. Not without looking it up, potentially, no. I don't
remember that.
Q. Do you recall whether you disclosed any documents
directly to the Crown Office or the Procurator Fiscal
Service in Scotland?
A. I don't believe so. So I have been asked questions in
relation to those bodies but via Peters & Peters,
I think, for Post Office.
Q. Whilst you were dealing with document disclosure in the
context of the Group Litigation, did you receive any
advice or instruction about retaining documents for any
of the following purposes: firstly, use by the Criminal
Case Review Commission?
A. Not directly no.
Q. Secondly, compliance with the ongoing duty of disclosure
in criminal proceedings, whether by the CPS or to --
A. No, I don't think so.
Q. Do you recall there being any discussions about
documents which you provided to the Post Office's
189
MR STEIN: Sir, I have one question for the witness and it
will take less than a minute.
‘SIR WYN WILLIAMS: All right, well, that's easy.
MR STEIN: I hope so sir, in terms of a break, I have
a personal matter, that I need to deal with at 4.15, so,
even if there is going to be a break would you allow me
permission to ask that single question?
SIR WYN WILLIAMS: Of course. We'll have that in a second.
Who is wanting to ask questions which will take longer
than Mr Stein's one minute-ish?
MS PAGE: I also would like to ask some questions, sir.
I could keep it to ten minutes.
SIR WYN WILLIAMS: = Right. Anyone else?
MS OLIVER: Sir, yes, I would like to ask some questions, if
possible. I can also keep it to ten minutes, please.
‘SIR WYN WILLIAMS: Right. So we will have Mr Stein's minute
or so now, then we will have a short break and then we
will have two 10-minute sessions. All right. I think
that's reasonable, in all the circumstances.
Everyone at least content?
Fine.
So, Mr Stein. Ask your questions and then we'll
have a short break.
Questioned by MR STEIN
MR STEIN: Mr Lenton, in my 60-second countdown, can I ask
191
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
12 June 2024
lawyers being used in connection with any criminal
proceedings or appeals?
No.
In your role as Document Manager, have you been asked to
locate and retain the scripts that were used by Fujitsu
helpline?
I have been involved in that question, yeah, but
I recall not being able to do that. So yeah,
unsuccessfully, if I was asked to be involved in it.
MS HODGE: Thank you, sir.
With the exception -- sorry, excuse me one minute.
SIR WYN WILLIAMS: Yes.
MS HODGE: Forgive me, sir. With the exception of Stephen
Parker's evidence, that would conclude my questions.
SIR WYN WILLIAMS: Yes.
MS HODGE: Some of the recognised legal representatives
would like to ask questions. I'm conscious of the time.
It's 4.00, sir, and I think we will need to give our
transcriber, one additional break, perhaps a short break
of ten minutes, so it's really a question of whether we
can get things wrapped up today within the time
available.
SIR WYN WILLIAMS: Well, that's -- who wants to ask
pProPro
A
questions and how long are they going to take? Let's
see where we are?
190
you just this: you've just been asked by Ms Hodge
questions that relate to the location and retention of
scripts —-
Right.
- from the Fujitsu helpline. Your answer was you
recall not being able to do that. Why were you not able
to do that?
Because I wasn't able to locate them or find anybody who
knew where they were but I'm also aware of the fact that
I wasn't the only person asked that question and it was
also, fairly certain, investigated by some other people
in Fujitsu. So I didn't -- I mean, I don't think
I reached a definitive conclusion on it and others may
have done.
Right, the others being?
Other people working for the Fujitsu Legal Team.
Okay. Do you know their names?
Um, God, I do. What are their names? Um --
To assist us, would you put that in writing and provide
that answer to the Inquiry?
I can do.
MR STEIN: Thank you.
Thank you, sir.
SIR WYN WILLIAMS: Right, we'll resume again at 4.15, and we
will aim to conclude by 4.35.
192
(48) Pages 189 - 192
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
The Post Office Horizon IT Inquiry 12 June 2024
MS HODGE: Thank you, sir.
(4.05 pm)
(A short break)
(4.15 pm)
MS HODGE: Sir, can you see and hear us?
SIR WYN WILLIAMS: Yes, I can, thanks.
MS HODGE: I'm not sure who is going to go first.
Ms Page, thank you.
Questioned by MS PAGE
MS PAGE: Thank you.
2
a
My first topic is short and I want to ask you about
your recollection to do with the providing of the
Jenkins reports on data integrity. In your witness
statement, you appeared to have quite a clear memory of
those reports and putting them on to your Dimensions
system; is that fair?
Right, yes.
Is there a reason why, given that this goes back,
I mean, many years -- the first email correspondence is
from 2010 and, presumably, a little earlier when you
actually put them on the system -- is there any reason
why you can remember these reports so clearly?
I think it really is because, obviously, subsequently
their significance has become much more apparent to me
but then, also, there's the limited number of times in
193
technical.
Yes. All right. Thank you. Then, in that case, what
I'd like to move on to is the disclosure around remote
access. You've described how the disclosure process was
really iterative and responsive.
Yeah.
But when it came to the issue of remote access, there
did come a time when it became quite a structured
approach, didn't it? With a long table, and various
different issues relating to it that you were responding
to?
Um -- yeah --
We can come to it in due course.
I was going to say I'm not completely sure what you're
referring to but I think there was a -- I think you're
referring to there's an Excel file I think which has --
effectively is a big table showing all the different
types of what could be regarded as remote access and who
would be able to do them, et cetera?
Yeah. All right --
SIR WYN WILLIAMS: Before you go any further, Ms Page, so
that I'm not being slow, we're talking about disclosure
relating to remote access in the GLO, are we?
MS PAGE: Yes, that's absolutely right, sir. Sorry.
SIR WYN WILLIAMS: Yes. That's fine.
195
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
which we have provided them to Post Office, which we've
done on more than one occasion, I think, and in the fact
that there's only two of them, and there's one for each
version of Horizon. So it's a kind of -- yeah. I mean,
that's it really. They're just quite unusual, as I said
earlier, in terms of the types of documentation that we
hold.
Q. Was there a sense that there was a concern around data
integrity and that these reports sort of highlighted
that and something, something around that?
A. Well, clearly when you read them, then it's apparent
that someone at least does have some concern about it,
yeah, because that's clearly what they're about.
I mean, they're not very long, either of them, and
they're clearly attempting to address a question --
Q. Did you read them at the time? Do you have a memory of
that?
A. I think I probably -- yeah, I think so. I mean, they're
only, like, six pages, aren't they, I think?
Q. Indeed and that might be why they stick out because they
are about these concerns; is that fair?
A. Possibly, and I think the other thing is that, unlike
many of the documents I see, they're actually just
written in kind of what you might call normal prose that
anybody might understand, rather than being highly
194
MS PAGE: So, as part of that process, you looked into the
history of the SSC team using what they call the change
control process, in order to record occasions when they
inserted transactions into branch accounts; do you
remember that?
A. Yeah, I'm not sure that I did personally but I might
have done some of the work contributing to that, yeah.
Q. Allright. Well, let's look at a document. It's
FUJ00189522. If we can scroll to page 3 when it comes
up, please. So on this page here, perhaps if we just go
up a little we can see what is going on. This is from
Steve Parker to you, 24 January, various other people
copied in, and he describes the -- it's sort of slightly
in shorthand but it seems that the subject is in
relation to Richard Roll, "Roll 2", and there seems to
be a sort of a further subject heading in the sense that
he says:
“Review a sample of OCPs to give an indication as to
how frequently transaction data was injected."
A. Yeah.
Q. Then he addresses you:
"Matthew,
"Has become very difficult to provide.
"The original plan was to examine sample months of
change control data and produce rough figures. This led
196
(49) Pages 193 - 196
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
The Post Office Horizon IT Inquiry
me to the realisation/remembering that support did not
use change control in the earlier years for [Business As
Usual] support actions. We relied on the audit trail
within the incidents (PEAKs) to document support
actions. We had auditability of the work done but no
change control entries. Reasoning behind this was:
implementing support actions ASAP, nobody around to sign
off overnight anyway, audit trail is enough where no
financial impact.”
He then goes on to talk about trying to sample PEAK
records.
Yeah.
So one of the reasons -- well, the reason behind this,
not using the proper change control process, was
evidently a sort of a needs must; is that fair?
It sounds like it, doesn't it? Yeah.
If we could please keep a sort of an eye on that wording
and go to how it was then communicated by you in
document FUJ00163098. This is quite a long email train.
If we go down to, first of all, page 3, just to give us
some location of where we are. So that email at the
bottom, 24 January, from you to Jonathan Gribben,
various other people copied in, including Gareth Jenkins
and Andrew Parsons.
This is the sort of table that I was talking about,
197
control in the earlier years. Do you think that was
properly communicated?
I must admit, to me, I'm not sure if there's a big
difference in those two things. I mean, it became
apparent to us, looking at this question, as a result of
Steve Parker remembering or whatever it was that he
said.
All right, well, let's go a little further down.
“We relied on the audit trail within the incidents
(PEAKs) to document support actions. We had
auditability of the work done but no change control
entries."
Then:
"We assume that the reasoning behind this was to
allow implementation of support actions ASAP, and the
audit trail being good enough where there was no
financial impact."
So that really is a slight softening, if you like,
of the needs-must wording that we saw in Mr Parker's
email; do you think that's fair?
Well, possibly. I mean, the meaning is almost the same,
I would have said, isn't it?
What we don't see there is the reference to there just
simply being no one around on the overnight desk. There
is still this attempt to assure and provide assurance,
199
ONOaARWN
©
11 Qa
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
9
10
"1
12
13
14
15
16
17
18
19 A.
12 June 2024
it looks like it probably did come from Excel or
something but it's --
Okay, it's not the one I was thinking of but, anyway.
Right. Well, there's a long table with various aspects
of disclosure that are being looked into. If we scroll
all the way down, please, to page 10, we can look at the
bit which follows the email that we were just looking at
from Steve Parker. If we scroll a little further we can
see that chunk in the middle that says "Matthew Lenton"?
Mm-hm.
The header there is the same as we saw in the email from
Steve Parker, "Review a sample of OCPs to give
an indication as to how frequently transaction data was
injected", and then you've inserted the description but
slightly different wording:
"This is proving difficult to provide [the same].
The original plan was to examine sample months of change
control data and produce rough figures.”
Then, slightly different:
"As Pete Newsome already discussed with you, this
led to it becoming apparent that support did not use
formal change control in the earlier years for [Business
‘As Usual] support actions.”
So that's gone from Mr Parker saying that he
actually remembered that they didn't use formal change
198
but there is a sort of a softening; would you accept
that or not?
Possibly. I mean, yeah.
Allright. Well, then just this: the answers that you
received from Mr Parker about what the SSC team were
doing and those needs-must actions that they were
taking, the wording that you've used was more or less
conveyed to Mr de Garr Robinson KC and that was in the
context of him having said that answers around this
issue and if it were true that the SSC were not using
change control processes, it would be "disastrous for
the case". I'll give the reference so that those
interested can look it up -- we don't need to go there
now -- POL00416010.
So, evidently, this answer was considered important
by the person in charge of the litigation. Was there
ever any comeback, ever anything further to you, or
anything that you know of to Mr Parker on this subject?
Not that I recall specifically, no.
20 MSPAGE: No. Allright. Well, thank you very much,
21
22 A.
Mr Lenton. Those are my questions.
Thank you.
23 SIRWYNWILLIAMS: Thank you, Ms Page.
24
Questioned by MS OLIVER
25 MSOLIVER: Thank you, sir. I ask questions on behalf of
200
(50) Pages 197 - 200
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
oP
prop,
The Post Office Horizon IT Inquiry
Gareth Jenkins and I want to ask you some questions
about Fujitsu's work in the context of the GLO
proceedings, if I may.
You've been asked some questions earlier today about
Mr Jenkins' role and you said, essentially, that there
was a team of people who would help to analyse the
information in order to answer questions from Womble
Bond Dickinson --
Right.
-- and he was one of these people because of his
longstanding expertise and knowledge in Horizon.
Yeah.
Is that right; have I paraphrased that correctly?
I think so, yeah.
Thank you. But you weren't told anything specifically
about his role, other than in those terms; is that
correct?
No, not really. I mean, obviously I knew him fairly
well, in any case, so yeah, I mean, I just accepted that
that's what he was doing. He was analysing information
that we were providing to him when he was asked to.
Does it follow that you weren't informed as to why
Mr Jenkins was not called as a witness in the GLO
proceedings?
I don't believe so no.
201
and KELs, answering questions from WBD on discrete
technical issues -- sorry, you're nodding.
Correct, yes.
Thank you. Providing commentary on witness statements
and expert reports, such as the Coyne Report, the Jason
Coyne reports that had been served by the claimants in
the proceedings?
Yes.
Preparing technical analysis of bugs, errors and defects
that had been identified?
Correct, yeah.
And, indeed, commenting on the draft witness statements
that were produced by the Fujitsu witnesses who were to
be called by POL?
Yes. I believe so. Yeah.
You, as you've said, identified six individuals who were
part of that team but I think you've made clear that
that wasn't an exhaustive list?
No, that's right. There were other people who also
worked on the Post Office Account who were consulted
about various matters, correct.
So is it fair to say that Mr Jenkins was one of a number
of Fujitsu personnel or, to use your phrase, a team of
people, who performed these tasks including commenting
on witness statements?
203
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
>
12 June 2024
Were you ever told by WBD or POL not to direct queries
to Mr Jenkins unless this was unavoidable?
No.
You've also been asked about why Mr Jenkins, who was not
himself a GLO witness, was being asked to feed
information and evidence to individuals who were
witnesses from Fujitsu --
Right.
-- and I think Mr Godeseth was mentioned in particular
in the context of that question.
Yeah.
I think your answer was that you would not necessarily
characterise it in that way; do you recall that?
Correct. Yeah.
Was the position that there were multiple individuals
within Fujitsu who assisted the Post Office with
technical input into the expert and witness evidence
that transpired as part of the GLO proceedings?
Yeah, and, in fact, there were people in that immediate
virtual team who weren't witnesses, such as John
Simpkins and Mark Wright.
Yes, indeed, within the six that you have identified.
Yeah.
Is this right: that these individuals were performing
tasks such as providing analysis on material like PEAKs
202
Correct. Yeah.
Indeed, is this right: that it would have been
practically impossible for one person in Fujitsu to
perform that role because of its sheer scale but also
the multiplicity of expertise that it demanded?
That's correct. So I recall, for example, that I think
we'd split up all of the -- I'm trying to remember the
phrase that was used but all of the issues that came out
of the supplemental report of Jason Coyne were split
among the members of that virtual team, yeah.
You've identified one of the two examples I'm going to
come to, the 22 bugs that Jason Coyne identified?
Right, and I think there your more than that originally,
actually that they were asked to analyse, yeah.
Thank you. Before I come on to those examples: is this
also right: that this process that was going on within
this team was collaborative; people were working
together on these tasks?
Correct, yeah.
I say it was collaborative, partly because there was
a fundamental principle of peer review within that team:
people would review each other's output?
That's correct, yeah.
Also, there was sometimes something in the form of
a dialogue between people of different expertise within
204
(51) Pages 201 - 204
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
2
prorop
The Post Office Horizon IT Inquiry
Fujitsu. So, for example, someone might say this is
a question that's better placed within the SSC, it would
be forwarded to someone like John Simpkins, he would
feed back --
Yes.
-- and it would all enter the mix.
I think that's definitely true, yeah, because, I mean,
I think the issues items weren't just kind of randomly
divided up among people, they were depending on who was
seen as on being more expert in that area, yeah.
Thank you very much if we can go to two examples. I'll
take your example first, if I may, I think what you're
referring to was the exercise that was conducted in May
2019 of effectively dividing up the 22 -- or I think it
then transpired 29 -- bugs that had been identified by
Mr Coyne --
Right.
-- amongst individuals within this team.
Right.
Do you recall that?
Yes.
I'm not going to take you to the email, just because of
time but, for everyone else's note, it's FUJ00081836.
But do you recall an instruction from Pete Newsome,
which was communicated to the likes of Dave Ibbett,
205
"Alan, Gareth S and Gareth J,
"Please see attached Torstein's draft witness
statement. He has asked that the three of you review it
and provide any feedback/clarifications.”
Moving down:
"Note that currently the draft has been provided to
Torstein by WBD based on a previous statement with
yellow highlighted sections where WBD are asking
specific questions and, as you can see, Torstein has
made amendments as tracked changes, and added comments."
If we go to the next email in that change, please,
thank you. The following day, 21 September, Pete
Newsome says:
"WBD have asked for a response today if at all
possible.
"Let me know if you can't do this ..."
Just as a side note, was it often the case that
Fujitsu were being asked to respond to requests by WBD
within very tight and pressurised time frames?
Yeah, that happens -- happened quite often, yeah.
Thank you. Also, of course, this is an example, isn't
it, where technical input is being asked for but from
Alan Holmes and Gareth Seemungal, who aren't in your
shortlist of six people?
Correct, yeah.
207
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
12 June 2024
Steve Parker, Mark Wright, John Simpkins, Torstein
Godeseth and Mr Jenkins, effectively saying we need to
divide up this list of bugs, each one needs a lead
person.
Yeah.
Do you recall that? There will then be a process of
consolidation and peer review; do you recall that being
the process?
I believe so, yeah, and I believe that I actually
tracked the progress on each of them, yeah. So yeah.
I'm grateful. So you were effectively administering
that process, were you?
Helping to keep track of what was going on, yeah.
Thank you. Can I then go to a second example which
I suggest is indicative of this collaborative way of
responding to the GLO proceedings and, if we go to this
document, please, it's FUJ00179541. Just while that is
being brought up, this is in the context of Torstein
Godeseth's first draft statement in September 2018. If
we can go to the bottom of this chain, please.
Thank you. Sorry, can we just go up a little bit so
I can -- thank you very much, that's perfect.
So this is an email from you to Alan Holmes, Gareth
Seemungal and Gareth Jenkins, copying in Pete Newsome
and Dave Ibbett:
206
Thank you. If we can scroll up, then, please, to the
next email in the chain, so we see Alan Holmes provides
a version of the document with comments and then, if we
scroll up, please. I think the two Gareths are being
asked to build on that as a base so add their comments
in to Alan Holmes' document?
Yeah.
If we can go up then, please, an email from Gareth
Jenkins:
"I've just got back in.
"I'l certainly add to Alan's comments. Not sure if
I can finish this afternoon -- depends how long it is.
“I'll look after lunch".
Then up please, Gareth Seemungal, I think, at this
stage, has added his comments so asks Gareth Jenkins:
"Are you okay to build on top of this version ...
please?"
Then, if we go up to the next email, please, from
Gareth Jenkins, later that same day:
"I've finally gone through it all. Attached is the
version with everybody's comments.
"There are a couple of my comments that suggest that
Gareth S may like to add clarifications, but I see he
had not picked up on those areas.”
Then the final email in this chain, from Gareth
208
(52) Pages 205 - 208
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
The Post Office Horizon IT Inquiry
Seemungal:
"Gareth
“Responded to your questions -- attached.”
The reason I suggest this might be typical is
because what we see here is a multiplicity of
individuals commenting on a draft statement; is that
right?
Certainly that's what there is here, yes.
Also, something of that dialogue that I mentioned
between the two Gareths, posing questions and answering
questions between each other?
That's true. Yeah.
Would you have said that this process that we see here
with Torstein Godeseth's statement was relatively
typical of the way that Fujitsu worked on these draft
witness statements?
So, yeah, well -- I must admit I'm not quite -- so
I think in terms of -- I'm trying to think of how many
there were. So, obviously, this is Torstein's and then
there was Steve Parker's. I mean, I assume that Steve
Parker's was looked at in considerable detail,
particularly by his SSC colleagues, and I think the Andy
Dunks witness statement we've already looked at and that
was very short and was more or less pre-written, as it
were. Then I think the other one was Bill Membery and
209
(The hearing adjourned until 9.45 am the following day)
211
ONOaARWN
9
10
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
12 June 2024
I have to admit I don't really recall the content of
that one.
So, certainly, in the case of this witness
statement, it was done like that but there were only
four witnesses, I think.
SIR WYN WILLIAMS: Can I shortcut it, in terms of the two
technical witnesses, Mr Godeseth and Mr Parker, it seems
clear from even this limited line of questioning that
there was a good deal of collaboration before the
witness statements were finalised?
A. Yes.
SIR WYN WILLIAMS: Fine. I think you've made your point.
MS OLIVER: Thank you, sir. No further questions.
SIR WYN WILLIAMS: § Thank you. Right. Well, that brings the
session to a close today.
Thank you very much, Mr Lenton, for your witness
statement and for answering the questions of a number of
people throughout the afternoon. II'm grateful to you.
So we'll break off now and resume again tomorrow
morning with Mr Parker -- sorry, Mr Parsons, not
Mr Parker. I shouldn't confuse those two people,
I don't think.
Allright. Thanks very much.
MS HODGE: Good afternoon, sir.
(4.39 pm)
210
INDEX
THOMAS MATHEW BEEZER (sworn) ..
Questioned by MR STEVENS .
Questioned by MS PAGE. 87
MATTHEW GUY LENTON (affirmed) .... 90
Questioned by MS HODGE ... 90
Questioned by MR STEIN ..... 191
Questioned by MS PAGE .. 193
Questioned by MS OLIVER .. 200
212
(53) Pages 209 - 212
MR STEIN: [4] 191/1
191/4 191/25 192/22
MR STEVENS: [25]
113 1/5 1/9 1/13 41/21
41/24 42/2 51/2 51/10
51/12 51/20 51/24
52/1 52/10 81/9 81/14
81/20 87/1 87/5 87/12
89/11 89/24 90/7
90/14 90/15
MS HODGE: [15]
90/19 90/21 90/25
152/24 153/1 153/5
153/7 178/11 190/10
190/13 190/16 193/1
193/5 193/7 210/24
MS OLIVER: [3]
191/14 200/25 210/13}
MS PAGE: [8] 87/14
89/8 89/21 191/11
193/10 195/24 196/1
200/20
SIR WYN WILLIAMS:
[47] 1/4 1/6 1/12
41/20 41/22 41/25
51/4 51/11 51/15
51/25 52/7 80/25 81/3
81/6 81/8 81/11 81/19
87/4 87/10 89/9 89/12
89/14 89/19 89/22
90/1 90/10 90/13
90/20 152/22 152/25
153/6 178/10 190/12
190/15 190/23 191/3
191/8 191/13 191/16
192/24 193/6 195/21
195/25 200/23 210/6
210/12 210/14
THE WITNESS: [2]
81/15 90/6
"but [1] 140/7
‘Callendar [1] 129/19
‘contrition’ [1] 74/8
"deleted [2] 154/8
155/10
‘deleted’ [1] 132/13
"executive' [1] 74/3
"government' [1]
74/1
IA] 72/25
"I think' [1] 72/25
‘inconsistency’ [1]
70/25
"JONATHANG' [1]
165/3
‘judiciary’ [1] 74/3
"KELComplete' [1]
121/14
"PinICL' [1] 151/24
‘Please [1] 123/25
‘provide [1] 107/12
‘Relevant [1] 114/10
‘the [2] 32/20 159/10
‘Transaction [2]
164/18 164/23
0
008 [4] 42/2
=
1 March [2] 36/9 37/6
1,281 [1] 149/25
1,494 [1] 151/2
1-4 [1] 129/23
4.00 [2] 51/18 52/2
1.13 [5] 162/10
162/19 164/15 165/3
166/5
1.14 [2] 163/4 163/4
1.15 [1] 163/9
1.16 [3] 163/4 164/15
165/3
1.20 [3] 90/12 90/14
90/18
10 [4] 158/17 158/18
166/4 198/6
10 March [1] 56/9
10 November [1]
49/6
10 years [1] 110/22
10-minute [1] 191/18
10.00 [1] 1/10
10.18 am [1] 116/2
100 [1] 145/20
11 [3] 56/6 57/5
125/16
11 March [4] 54/13
56/8 56/11 180/22
11 October [1]
146/20
11,000 [1] 35/22
11.05 [2] 51/5 72/14
11.06 [1] 51/21
11.20 [1] 51/23
11.50 [1] 70/15
11th [3] 59/19 59/20
60/24
12 [5] 1/1 3/5 7/8
56/6 65/6
12 March [4] 58/7
58/23 59/17 62/1
12 September [1]
126/6
12.21 [1] 90/16
12th [4] 59/21
13 February [1]
153/13
13 June [1] 1/24
13 November [1]
180/14
13th [1] 153/12
14 [2] 28/19 56/13
14 March [1] 64/3
14 May [1] 91/5
14,365 [1] 160/19
14.30 [1] 115/24
14th [4] 65/16 66/17
66/18 77/23
15 [2] 51/13 51/17
45 August [1] 15/13
15 March [1] 52/20
15 minutes [1] 51/15
415th [2] 70/16 79/3
46 [2] 72/14 72/19
16 March [1] 73/17
16 November [1]
184/5
16.01 [1] 149/24
46th [1] 70/19
17 [1] 84/19
17 November [1]
49/8
47th [2] 77/24 79/3
18 [4] 34/12 34/13
46/23 109/11
18 July [1] 14/23
18 March [1] 79/15
18 November [1]
16/10
18 years [3] 22/7
36/23 40/13
18/19 years [2] 7/4
18/16
18ed [1] 46/2
19 [1] 89/13
1987 [1] 91/24
1996 [4] 5/4
1998 [1] 94/7
19th [1] 89/14
2
2 February [1] 1/19
2.1.2 [1] 47/7
2.47 [1] 42/21
2.50 [2] 152/25 153/2
20 [2] 75/23 97/17
20 February [1]
29/21
20 March [5] 79/16
83/17 83/23 84/17
84/25
2000 [1] 96/19
2000s [1] 9/6
2002 [1] 180/22
2003 [2] 5/6 14/23
2004 [2] 15/2 42/15
2005 [13] 4/19 5/16
6/6 9/25 15/14 21/11
26/11 26/17 29/1 29/2
29/3 29/7 36/14
2006 [19] 4/19 26/13
28/25 29/5 29/21 33/8
34/13 35/22 36/9 37/6
37/24 38/8 42/3 43/17,
44/11 46/2 46/15 92/3
93/1
2007/8 [1] 9/9
2007/8/9 [1] 9/9
2008 [1] 94/1
2009 [2] 93/9 98/18
2010 [3] 98/18 170/2
193/20
2013 [2] 8/7 104/10
2013/2014 [1] 8/15
2014 [2] 8/7 8/15
2015 [1] 94/1
2016 [8] 53/23 94/1
99/2 100/8 100/21
102/12 176/11 176/23}
2017 [5] 112/25
113/9 114/1 122/25
158/25
2018 [16] 120/16
121/7 123/4 123/21
131/7 153/25 155/3
155/15 155/22 155/22)
161/11 164/7 180/14
181/14 184/5 206/19
2019 [20] 52/20
52/21 54/11 54/14
58/8 58/23 64/3 73/17
79/15 83/18 83/23
84/17 84/25 151/5
158/6 158/20 168/5
176/2 177/25 205/14
2023 [1] 1/24
2024 [4] 1/1 1/19 2/5
91/5
21 November [2]
16/21 24/3
21 September [1]
207/12
212 [1] 150/1
22 [2] 204/12 205/14
22 November [1]
10/19
220,000 [2] 172/19
172/21
23 March [3] 15/2
121/7 123/21
23 November [1]
21/11
24 February [1] 32/4
24 January [2]
196/12 197/22
24 May [1] 164/7
24 September [1]
128/3
25 May [1] 165/25
25 September [1]
1341/7
250,000 [4] 18/23
31/22 34/8 35/20
26 September [1]
141/16
26th [1] 133/9
27 November [1]
49/1
28 November [1]
114/1
28 September [1]
144/10
29 [1] 205/15
29 November [2]
46/15 47/13
2a [1] 156/5
3
3 October [1] 181/14
3,500 [3] 48/11 48/25
49/16
3.05 [2] 152/25 153/4
30 [3] 87/24 87/25
88/4
30 November [2]
113/9 117/14
30 September [1]
158/20
32 [1] 1/25
35 [1] 39/16
36 [2] 26/15 33/8
4
4 years [1] 175/17
4,000 [1] 118/10
4.00 [3] 70/16 72/19
190/18
4.05 [2] 42/22 193/2
4.15 [3] 191/5 192/24
193/4
4.35 [1] 192/25
4.39 [4] 210/25
41 [4] 2/8
47 [4] 109/41
5
5 November [2]
153/25 155/22
5 September [2] 42/3
44/10
5,000 [1] 160/4
51 [1] 91/10
54 pages [1] 91/7
557 [1] 87/24
6
6 December [2] 23/9
29/3
6 February [1]
151/14
6 September [1]
43/17
6,155 [2] 160/11
160/22
6.2 [2] 46/24 47/12
6.2.4 [1] 47/2
60-second [1] 191/25]
64 [1] 171/14
7 April [1] 38/8
7 April 2006 [1]
37/24
7 February [2] 28/21
29/5
7 November [1]
(54)
MR STEIN: - 7 November
7
7 November... [1]
35/22
8
8 March [5] 54/11
54/12 55/6 57/4 176/2
8 May [1] 2/5
8,000/9,000 [4]
160/20
8,300 [1] 120/17
8.23 [1] 62/1
82 paragraphs [1]
2/1
9
9 April [1] 52/20
9 March [1] 56/16
9,000 [1] 160/20
9.45 [2] 1/2 211/1
AU
ability [6] 57/12
161/6 175/3 176/9
177/2 188/11
able [21] 14/4 40/1
45/5 65/5 87/19 105/6!
120/6 129/19 140/9
141/2 144/18 149/19
165/1 173/4 179/15
189/5 190/8 192/6
192/6 192/8 195/19
about [143] 3/3 4/2
4/17 4/20 7/10 9/19
18/14 20/6 20/21
21124 23/4 23/22
24/10 24/11 24/14
26/9 28/23 29/14
30/19 30/22 31/16
31/16 31/17 31/24
32/10 35/22 35/23
40/7 41/3 41/13 44/25]
45/9 48/7 48/11 49/16)
51/18 53/18 54/17
55/2 55/5 55/16 57/25I
59/24 60/1 60/10 61/8
61/15 63/5 65/9 66/1
66/7 66/11 69/1 69/3
69/11 71/7 76/10
76/11 76/14 76/14
76/15 78/13 84/23
85/19 86/3 86/11
87/15 91/21 94/1
94/11 94/18 96/21
98/11 98/12 98/15
103/8 104/4 105/7
105/9 106/4 107/22
109/8 110/22 111/10
111/21 112/18 122/23
123/15 127/7 128/16
128/21 130/10 130/22
133/21 134/23 136/5
137/3 137/8 138/8
1441/7 141/11 142/14
150/8 150/14 150/24
161/4 165/21 167/10
177/16 179/5 181/11
182/16 184/4 186/18
186/18 188/8 189/17
197/10 197/25 200/5
201/2 201/4 201/16
202/4 203/21
above [4] 117/9
127/19 156/13 181/18)
absolutely [17] 14/7
16/13 26/20 28/1
31/15 31/24 33/9
38/11 40/13 54/7 57/3)
57/14 81/7 81/15
83/15 89/17 195/24
academic [1] 91/21
accept [8] 8/13 23/21
35/8 35/10 50/17
115/21 185/22 200/1
accepted [6] 73/5
73/10 100/4 145/7
160/22 201/19
access [39] 99/1
99/3 100/8 101/17
101/20 101/22 101/25)
102/2 102/11 105/5
105/11 105/13 105/16)
106/10 161/4 161/25
162/5 162/13 163/3
163/7 163/18 164/16
165/14 167/3 167/21
168/5 168/8 168/24
169/20 169/24 170/7
171/15 175/4 175/21
185/17 195/4 195/7
195/18 195/23
accessed [2] 99/4
162/11
accessible [1]
159/19
accommodate [1]
87/10
accompanied [1]
174/4
accordance [1] 4/22
account [31] 45/19
47/10 93/5 93/12
93/17 94/6 94/20
94/23 95/1 95/7 96/13)
98/18 99/11 99/17
101/15 101/17 102/6
102/11 104/5 104/7
105/8 109/18 110/6
110/12 110/18 110/20)
110/21 167/9 175/14
180/22 203/20
146/10 146/15 148/10)
151/11 152/13 152/13)
157/13 160/20 160/23)
167/16 167/25 176/16)
189/24 193/11 194/12)
194/13 194/21 195/22)
accountancy [1]
45/20
accounted [1]
177/18
accounting [9] 12/21
13/11 13/22 37/16
43/12 47/9 165/9
166/13 181/1
accounts [12] 23/19
93/4 93/11 99/12
99/15 161/7 162/11
162/23 165/8 166/10
166/11 196/4
accuracy [2] 158/6
177/25
accurate [2] 45/3
145/10
accurately [2] 45/6
177/12
across [4] 20/13 40/9
98/24 99/15
act [6] 75/5 75/11
79/20 80/14 80/16
80/21
acted [3] 6/12 8/12
187/25
acting [2] 4/22 18/11
action [24] 10/11
12/15 18/3 18/12
18/15 18/19 19/3 19/9}
20/6 20/20 21/2 21/8
26/9 27/4 27/15 30/19
38/2 75/8 75/19
157/14 160/24 172/5
172/6 173/2
actioning [1] 120/15
actions [8] 22/11
197/3 197/5 197/7
198/23 199/10 199/15}
200/6
actively [1] 179/2
actual [1] 22/22
actually [37] 14/16
25/1 33/23 34/18 36/2
41/18 46/8 74/21 81/4
93/11 94/12 96/16
98/5 98/7 100/9
107/17 109/19 118/2
121/21 122/12 127/1
134/16 139/11 150/17]
169/1 174/19 176/15
179/3 183/19 187/6
188/9 188/11 193/21
194/23 198/25 204/14
206/9
acutely [1] 74/5
add [5] 45/5 106/10
208/5 208/11 208/23
added [4] 4/9 107/24
207/10 208/15
adding [1] 43/10
addition [7] 45/8
46/24 46/25 47/14
48/19 49/20 50/13
additional [6] 46/5
127/25 148/15 165/1
171/14 190/19
Additionally [1] 4/11
address [3] 112/22
160/24 194/15
addressed [5] 52/15
109/11 114/3 125/16
134/4
addresses [1] 196/21
adhere [1] 96/13
adjourned [1] 211/1
Adjournment [1]
90/17
administered [1]
99/21
administering [2]
99/19 206/11
administrators [1]
163/6
admit [6] 114/24
174/15 179/10 199/3
209/17 210/1
admittedly [1] 22/14
adopt [3] 35/5 72/4
75/7
adopted [1] 152/2
ADR [2] 45/21 46/7
advance [1] 52/2
advancing [1] 143/3
advertising [1]
157/23
advice [24] 57/16
57/19 57/20 57/20
57/20 57/21 57/24
58/3 59/13 63/23
64/24 66/1 72/6 72/7
73/5 73/10 80/7 80/17,
83/20 185/1 186/14
187/20 188/1 189/17
advise [5] 50/17
50/24 57/12 72/25
74/16
advised [1] 73/25
advisers [1] 72/25
advising [1] 77/20
advocacy [2] 63/9
63/9
advocate [1] 63/8
affect [1] 182/9
affirm [1] 1/21
affirmative [1] 148/5
affirmed [2] 90/23
212/8
Africa [1] 61/17
after [24] 24/5 26/4
29/3 43/17 44/22
44/22 48/6 48/13
57/20 65/2 98/17
122/13 134/7 134/23
142/13 148/16 152/11
158/12 158/15 160/16
182/18 188/19 188/22
addressees [1] 36/10)
208/13
afternoon [9] 51/8
90/19 90/25 115/24
152/23 153/5 208/12
210/18 210/24
afterwards [1] 11/8
again [24] 10/18
43/18 64/22 105/21
115/11 118/21 119/20)
119/23 121/6 123/11
129/14 130/7 130/17
133/13 136/22 137/5
137/7 152/2 167/23
168/5 171/19 173/25
192/24 210/19
against [14] 10/1
16/16 16/19 18/23
30/6 30/17 31/4 31/24I
34/23 44/24 57/9 80/3)
108/23 160/10
aggressive [2] 78/14
85/23
ago [7] 7/4 18/16
20/8 22/14 36/23 60/7I
125/20
agree [14] 21/24 22/1
23/25 32/6 45/4 45/13
50/15 62/12 62/16
62/20 133/4 143/24
168/1 182/20
Agreed [8] 3/6 3/12
3/18 16/23 21/17
54/15 58/19 64/6
agreeing [3] 45/16
90/9 171/6
agreement [6] 7/19
7/19 7/22 7/24 8/3
185/20
ahead [2] 33/16 82/8
aim [1] 192/25
Al [4] 73/22
Al Cameron [1]
73/22
Alan [5] 206/23 207/1
207/23 208/2 208/6
Alan's [1] 208/11
alarm [2] 1/10 10/3
albeit [1] 93/5
all [110] 6/23 7/15
8/20 9/4 9/12 12/7
20/19 21/24 22/10
24/25 25/17 25/25
26/19 27/13 27/21
35/16 35/24 40/15
41/24 46/10 46/12
46/12 48/13 49/4
50/11 51/19 52/7 57/1
57/6 57/10 58/21
66/14 69/3 77/6 77/13)
77/16 79/5 81/13 84/3
86/16 86/17 86/20
86/24 86/24 86/25
88/5 90/1 90/13 92/15
95/11 96/17 101/21
(65) 7 November... - all
A
all... [58] 102/2 107/7
110/19 114/11 121/1
121/16 122/12 123/4
124/1 124/14 127/2
127/16 135/11 136/5
136/13 136/20 137/3
143/24 147/9 148/14
148/17 148/22 149/22)
150/5 150/15 150/18
151/24 152/8 154/15
156/12 164/15 170/4
172/19 172/21 178/10}
182/6 185/23 186/7
186/8 188/13 191/3
191/18 191/19 195/2
195/17 195/20 196/8
197/20 198/6 199/8
200/4 200/20 204/7
204/8 205/6 207/14
208/20 210/23
all’ [1] 107/42
allegation [2] 34/15
43/11
alleged [1] 15/3
alleys [1] 44/16
allow [2] 191/6
199/15
alluded [1] 6/2
almost [6] 52/13
62/19 142/10 148/20
187/6 199/21
alone [1] 45/20
already [20] 3/25
17/13 17/25 26/11
26/15 30/8 39/13
48/24 64/14 70/24
75/4 75/16 104/6
109/14 139/22 150/20}
158/3 160/20 198/20
209/23
also [42] 2/14 13/10
20/6 23/23 37/10
43/22 58/10 78/11
81/22 87/23 92/13
92/23 93/24 93/25
97/18 97/24 101/22
103/11 109/20 110/21
119/25 121/14 126/3
126/20 127/6 133/15
137/24 150/22 163/25)
170/17 191/11 191/15}
192/9 192/11 193/25
202/4 203/19 204/4
204/16 204/24 207/21
209/9
although [12] 7/25
19/6 42/24 49/6 57/19)
73/24 116/15 117/18
128/19 148/15 152/9
177/14
altogether [1] 43/13
always [4] 8/21 177/3I
177/15 177/7
am [17] 1/2 7/14
51/21 51/23 70/21
72/5 79/6 82/6 87/15
96/17 98/10 116/2
124/2 129/18 145/24
181/2 211/1
ambiguity [1] 153/10
amended [2] 81/10
183/7
amendments [4]
73/12 163/10 182/22
207/10
America [1] 61/16
among [2] 204/10
205/9
amongst [1] 205/18
amount [2] 187/21
188/12
amounts [2] 42/24
44/2
Amy [8] 55/18 61/24
114/1 121/6 122/13
123/3 123/25 124/4
analogy [1] 45/1
analyse [3] 111/17
201/6 204/14
analysing [2] 45/19
201/20
analysis [4] 112/13
184/21 202/25 203/9
Analyst [1] 180/23
Andrew [16] 53/6
53/9 53/13 54/3 55/18
61/24 69/17 70/9
70/15 72/13 73/17
77/25 175/8 179/6
184/8 197/24
Andy [2] 184/9
209/22
angry [1] 17/12
Anne [3] 41/6 41/9
41/14
annoying [1] 82/24
another [16] 18/8
30/23 54/9 59/16
70/10 75/24 96/8
96/21 122/13 131/16
134/18 143/22 155/4
156/15 183/14 187/12)
answer [36] 7/3 8/18
8/23 11/17 12/25 14/1
14/9 22/11 25/25
30/20 47/22 54/8
74/17 89/5 111/18
123/15 124/2 124/3
124/13 126/15 129/15)
135/22 141/16 146/5
148/4 149/19 174/22
178/19 178/20 179/15)
186/2 192/5 192/20
200/15 201/7 202/12
answered [2] 102/9
174/14
answering [5] 14/2
178/19 203/1 209/10
210/17
answers [5] 111/15
124/5 153/19 200/4
200/9
pate [1] 52/1
al pated [1] 4/13
anticipation [1] 11/1
any [97] 5/23 8/19
8/25 9/12 13/19 14/11
24/21 27/11 27/14
30/17 32/17 34/17
37/16 40/23 41/2
41/11 41/13 44/24
46/8 47/5 49/23 50/8
53/4 54/3 58/1 61/7
61/8 63/15 63/24 65/8
65/14 75/1 75/10 83/6
83/23 83/24 84/9
84/11 85/15 85/24
85/25 86/8 86/17
86/20 94/9 94/14
94/16 98/14 98/14
100/23 102/13 102/19}
105/15 106/3 106/8
106/12 107/20 108/9
108/10 112/18 114/15}
114/22 116/19 124/17
126/2 130/21 141/7
142/7 145/18 145/22
145/25 148/21 151/7
151/25 152/17 156/12
156/20 159/25 165/14]
168/2 168/10 170/13
172/6 182/7 188/24
189/2 189/5 189/9
189/16 189/17 189/24]
190/1 193/21 195/21
200/17 201/19 207/4
anybody [3] 41/10
192/8 194/25
anyone [8] 21/6
47/20 47/25 48/3 48/7
132/21 188/8 191/13
anything [19] 31/16
45/10 54/8 57/7 60/1
60/10 67/7 76/10
76/15 86/3 100/7
104/3 111/13 111/21
118/4 134/9 200/17
200/18 201/15
anyway [7] 29/11
71/16 77/15 149/11
187/13 197/8 198/3
anywhere [2] 45/10
142/8
apart [1] 188/7
apologies [2] 115/21
125/21
apologise [2] 4/11
84/24
apology [2] 4/6 4/15
apparent [9] 47/9
55/5 61/6 78/3 80/3
193/24 194/11 198/21
199/5
appeal [8] 52/22
55/15 61/1 71/18
71/21 72/2 72/3 79/25)
Appeal's [2] 52/21
52/25
appealing [1] 61/9
appeals [2] 87/17
190/2
appear [4] 71/9
125/24 138/25 150/10}
appeared [3] 171/19
176/3 193/14
appears [13] 27/17
37/1 43/11 46/6 83/19)
131/20 139/21 140/11
144/12 147/17 161/10}
173/13 176/19
appendices [1] 117/5I
appendix [3] 115/3
115/13 116/6
applicable [3] 121/23
121/25 122/15
application [39] 4/9
6/3 22/9 23/10 24/14
24/24 30/4 30/13
52/12 53/4 56/4 56/22,
57/12 58/6 60/3 60/5
60/12 63/18 65/10
66/12 71/25 73/7 74/5)
74/10 76/12 76/16
78/21 79/22 79/24
82/7 83/8 83/25 85/3
85/20 86/4 86/9 86/21
89/16 169/20
applied [2] 80/8
177/4
apply [2] 80/18
131/20
applying [2] 172/18
172/21
appointed [1] 67/18
appointment [3] 7/19
38/20 102/4
appreciate [2] 28/14
114/17
appreciated [2]
116/1 152/1
approach [13] 25/14
25/16 25/23 26/8 26/9
27/22 28/16 33/4 33/6
63/10 90/8 112/19
195/9
appropriate [4] 99/24]
109/3 185/1 186/14
appropriately [2]
95/15 96/9
approval [2] 166/17
167/2
approvals [2] 92/24
167/25
approve [1] 154/10
approving [1] 168/22
approximately [4]
118/10 120/17 124/16)
175/2
APPSUP [7] 169/18
169/24 170/11 173/4
175/10 176/10 176/24)
April [4] 37/24 38/8
39/2 52/20
Architect [2] 110/5
175/14
architects [2] 104/7
111/1
archive [3] 147/10
148/18 169/15
archived [1] 181/4
are [146] 3/20 3/23
10/10 11/21 11/25
18/2 18/8 18/11 20/19}
21/24 24/12 27/19
30/1 31/5 32/14 32/18)
32/19 33/1 34/11
34/24 35/12 42/24
43/8 44/5 47/9 47/9
47/11 52/16 58/15
58/15 58/16 59/8
60/24 64/15 64/19
70/12 71/1 74/7 75/2
75/20 82/17 83/2 83/3I
87/25 89/8 89/15 92/7
92/19 92/19 93/17
95/9 95/12 95/15
95/20 95/23 96/12
96/19 96/19 97/18
97/20 97/24 98/9 99/4
101/8 101/10 101/12
101/17 103/15 103/25}
107/6 110/10 110/19
112/5 114/8 114/9
114/20 115/16 116/16)
117/6 119/19 121/22
121/24 122/14 123/6
123/24 126/24 129/19)
136/2 138/20 144/13
147/1 147/9 147/12
148/11 148/13 148/17
149/11 149/19 149/25)
150/15 150/17 151/22)
152/4 153/24 154/4
154/5 154/16 154/20
154/21 155/9 155/10
156/1 156/4 156/10
156/12 156/12 159/11
159/13 159/15 162/17)
163/15 164/17 164/20)
165/1 165/3 169/16
170/2 170/4 170/20
173/17 173/23 176/16)
177/17 178/24 190/24)
190/25 192/18 194/21
195/23 197/21 198/5
200/21 207/8 208/4
208/16 208/22
area [2] 98/25 205/10
(56) all... - area
A
areas [4] 6/1 110/24
111/3 208/24
aren't [4] 56/1 150/25)
194/19 207/23
Argentina [1] 61/16
arguably [1] 179/1
arise [2] 118/12
130/7
arose [2] 168/5
168/14
around [22] 48/10
60/25 64/14 71/1 71/4
85/14 88/11 94/7
118/12 135/25 161/11
164/15 178/18 181/8
185/17 185/20 194/8
194/10 195/3 197/7
199/24 200/9
ARQ [1] 179/19
arrogant [1] 74/7
Arup [1] 92/12
as [270]
ASAP [2] 197/7
199/15
ascertained [1]
10/23
Ashwini [1] 93/20
aside [19] 20/4 20/5
20/14 21/21 22/5 22/8
22/17 24/13 24/24
25/5 25/9 26/4 26/14
26/23 27/20 29/11
30/3 30/10 30/13
ask [40] 1/20 1/21
1/25 2/6 4/2 23/18
41/13 46/14 50/24
72/17 83/17 87/15
87/18 89/8 91/1 91/10)
94/18 96/21 110/11
115/15 115/23 122/22
123/6 123/9 149/22
179/5 181/11 184/17
188/23 190/17 190/23
191/7 191/9 191/11
191/14 191/22 191/25}
193/11 200/25 201/1
asked [54] 23/17
23/20 38/5 57/15
69/23 84/7 86/5 87/8
87/9 100/17 103/8
104/10 104/17 105/13
105/20 105/22 106/9
106/24 112/6 112/11
112/14 113/8 120/11
120/25 125/20 129/18
130/13 136/10 137/9
147/12 160/6 161/21
162/10 162/20 178/25
179/7 181/14 184/20
188/17 189/12 190/4
190/9 192/1 192/10
201/4 201/21 202/4
202/5 204/14 207/3
207/14 207/18 207/22
208/5
asking [22] 24/20
30/22 37/10 53/15
54/22 69/7 82/21
91/20 119/9 123/5
123/25 132/23 135/23
143/1 149/6 155/23
165/20 167/10 174/11
175/1 181/23 207/8
asks [3] 20/18
153/23 208/15
aspect [2] 17/1
103/15
aspects [2] 128/17
198/4
assert [2] 144/21
145/8
asserted [1] 80/7
assertion [1] 126/14
assertions [2] 4/20
4125
assist [10] 2/16
37/19 56/22 61/12
61/13 71/8 113/11
113/24 125/11 192/19)
assistance [2] 37/11
99/22
assistant [2] 93/18
93/19
assisted [2] 69/5
202/16
assisting [1] 178/18
assists [1] 101/19
associate [1] 16/5
associated [1] 139/2
assuage [1] 44/9
assume [16] 27/8
27/16 45/1 45/3 64/25
67/2 84/9 118/21
119/24 124/15 141/4
145/11 147/10 184/20)
199/14 209/20
assumed [2] 126/16
145/3
assuming [5] 66/20
139/5 141/24 156/22
174/17
assumption [7]
130/11 141/5 142/1
142/4 142/20 145/7
145/8
assumptions [1]
127/14
assurance [5] 136/4
136/11 137/3 177/17
199/25
assure [1] 199/25
asterisk [1] 3/9
at [318]
attached [14] 69/18
115/12 115/19 116/5
126/8 144/13 144/20
164/8 175/16 183/6
184/7 207/2 208/20
209/3
attaches [1] 70/9
attaching [1] 69/20
attachment [1]
129/22
attack [1] 175/20
attain [1] 99/1
attempt [3] 35/19
143/25 199/25
attempted [1] 115/6
attempting [1]
194/15
attempts [1] 27/1
attend [5] 23/9 41/5
61/18 113/9 114/25
attendance [6] 2/13
21/11 28/7 36/18
37/24 41/15
attended [5] 36/15
83/20 113/15 117/16
185/6
attending [2] 1/15
39/18
attention [2] 157/24
161/11
audit [14] 15/2
163/13 168/23 168/25]
176/22 179/9 180/24
181/3 182/12 184/18
197/3 197/8 199/9
199/16
audit/transaction [1]
163/13
auditability [2] 197/5
199/11
auditable [1] 166/10
audited [3] 177/5
177/7 177/18
auditing [1] 168/7
August [3] 15/13
176/11 176/23
Aujard [1] 8/6
author [1] 148/2
authorisation [3]
170/21 175/5 176/10
authorised [1] 181/2
authorising [2] 165/5
165/21
authoritative [1]
52/14
available [8] 51/8
51/10 119/19 120/8
125/3 147/9 188/14
190/22
available’ [1] 159/11
avoid [4] 14/2 34/17
86/12 141/7
aware [27] 7/15 11/3
11/10 11/15 13/9
49/25 50/4 53/3 56/3
70/4 71/3 71/23 94/5
96/17 99/4 104/20
105/15 106/15 112/16}
113/4 135/8 135/15
135/21 161/5 165/22
180/7 192/9
away [6] 33/12 35/21
49/3 54/8 143/25
174/9
B
bachelor's [1] 91/24
back [30] 9/23 15/1
22/7 26/17 26/25
27/21 70/6 70/7 80/2
90/11 109/4 115/23
116/16 127/21 133/8
137/2 137/7 137/8
146/24 152/20 158/24}
165/8 166/1 170/9
171/18 187/17 187/19
193/18 205/4 208/10
background [12] 5/3
12/12 14/21 16/17
16/19 19/15 27/5
31/25 44/24 54/10
70/5 91/22
bad [4] 18/5 18/24
27/6 27/7
Bajaj [1] 32/23
balance [1] 47/11
balanced [3] 30/17
31/4 49/18
balances [1] 42/21
balancing [3] 163/11
163/17 167/16
ball [1] 172/19
barrister [1] 63/9
base [1] 208/5
based [11] 8/2 13/11
20/22 20/24 32/24
33/4 71/21 86/18
88/15 183/22 207/7
basically [10] 70/1
92/9 92/20 104/23
110/2 116/17 127/3
137/18 174/11 181/23
basis [12] 12/2 24/21
45/23 51/16 60/21
82/7 95/3 125/4
126/14 127/14 136/14}
147/20
bat [2] 30/20 74/17
batch [3] 126/16
155/13 159/22
Bates [2] 87/17 88/5
BDO [10] 42/4 44/11
44/23 45/9 46/11
47/20 48/3 48/7 48/9
48/12
be [239]
bearing [4] 122/7
130/17 139/7 157/18
bears [1] 162/4
became [10] 5/9 5/11
6/6 14/16 69/7 77/24
104/14 135/15 195/8
199/4
because [87] 6/18
7/13 11/18 12/6 15/3
15/19 18/16 19/9 20/6I
20/9 22/1 23/11 27/19)
29/5 29/6 31/8 34/15
35/4 39/1 39/6 40/1
40/19 43/6 44/4 48/21
48/23 49/7 50/18
56/23 57/3 57/25
60/23 63/11 64/9
65/21 69/13 70/4
7117 72/6 72/9 75/13}
82/22 86/15 88/14
89/3 92/20 99/13
102/16 102/18 103/22)
108/5 111/19 112/9
118/2 118/13 122/3
122/19 127/11 127/15}
128/24 128/25 130/4
133/22 140/19 144/22)
145/12 147/12 150/4
150/24 151/24 154/5
156/17 160/19 161/12)
172/18 182/4 184/20
192/8 193/23 194/13
194/20 201/10 204/4
204/20 205/7 205/22
209/5
become [5] 21/7
34/10 48/11 193/24
196/23
becoming [1] 198/21
BEDs [1] 98/14
been [144] 3/25 4/15
4/25 6/21 7/4 8/5 8/5
9/18 10/12 12/7 13/21
17/22 20/7 20/9 21/20
24/19 26/15 36/11
37/1 37/7 37/10 39/15
39/18 41/7 42/4 43/18
44/25 48/1 48/14 49/2
50/11 55/4 55/18
58/17 59/11 59/19
61/8 64/14 65/20
68/11 73/25 75/10
85/17 86/6 87/1 87/19
87/24 88/7 88/23
88/24 89/4 93/25
96/18 99/21 100/5
100/12 100/17 100/18}
101/14 102/19 110/21
111/16 116/18 117/10)
118/14 120/6 120/7
121/24 122/10 123/16)
129/3 129/6 129/14
130/7 1341/1 131/21
133/17 135/20 137/17)
138/12 138/18 141/2
141/11 142/3 142/21
143/7 143/8 143/10
144/18 144/22 144/23)
145/1 145/12 146/3
(57) areas - been
B
been... [50] 146/10
149/6 149/16 150/3
151/21 154/6 154/17
155/2 155/9 156/15
157/14 158/1 159/15
159/19 159/20 160/6
160/20 166/9 166/16
170/25 171/16 173/5
173/9 173/11 174/5
174/18 177/1 177/13
177/16 179/24 180/2
180/21 182/1 183/22
187/22 187/23 188/2
188/10 188/17 189/12
190/4 190/7 192/1
201/4 202/4 203/6
203/10 204/2 205/15
207/6
Beer [1] 52/14
Beezer [11] 1/5 1/7
1/14 1/16 21/14 39/10}
51/17 80/25 87/15
90/2 212/2
before [53] 1/9 4/2
6/3 9/9 10/11 24/18
24/23 26/13 27/5
28/11 35/23 38/13
41/4 41/7 44/23 45/21
46/25 48/15 51/6 51/8)
51/10 51/18 55/6
70/16 72/17 72/19
73/18 73/19 74/15
90/5 92/3 92/14 93/8
93/10 93/24 96/19
99/3 102/14 104/8
108/10 127/9 132/6
133/13 135/24 152/11
154/7 156/6 180/16
184/1 184/23 195/21
204/15 210/9
began [1] 59/21
begin [3] 1/9 91/20
176/3
beginning [1] 133/9
begins [3] 62/12
62/16 62/20
behalf [3] 11/12 91/1
200/25
behind [3] 197/6
197/13 199/14
being [92] 11/4 12/2
12/5 12/10 15/24
17/15 17/19 19/14
23/11 25/7 28/23
29/13 31/16 37/18
43/1 43/12 45/2 45/9
45/25 54/19 57/7 61/1
63/3 63/6 63/12 68/24
75/10 75/11 81/10
84/10 88/11 88/19
89/1 93/10 100/4
100/16 103/16 103/24
104/10 105/2 111/1
112/11 112/14 112/16)
112/20 113/4 113/11
122/4 129/18 131/23
138/18 145/10 146/1
146/4 146/25 150/22
154/15 154/21 156/6
158/7 159/9 159/18
162/20 165/4 165/4
165/11 169/17 169/20)
176/14 176/15 176/21
179/7 183/16 184/18
184/20 189/24 190/1
190/8 192/6 192/15
194/25 195/22 198/5
199/16 199/24 202/5
205/10 206/7 206/18
207/18 207/22 208/4
belief [3] 3/22 91/18
182/16
believe [55] 6/12
7/25 11/14 14/18
14/24 15/1 15/4 16/12
21/9 24/18 31/25
40/12 40/15 40/18
41/10 63/19 63/19
67/17 67/20 73/24
77/23 88/21 99/20
106/24 109/18 112/8
113/17 124/24 125/4
126/12 126/20 128/2
129/1 138/1 144/6
151/4 154/15 154/25
155/16 158/13 160/4
162/2 163/24 165/10
172/16 178/24 179/18)
182/3 182/21 186/9
189/12 201/25 203/15)
206/9 206/9
believed [2] 4/21
148/17
believes [2] 32/11
138/9
below [6] 124/3
124/6 138/15 173/23
174/1 183/13
beneath [1] 140/20
benefit [1] 109/12
Bentley [1] 24/16
best [11] 3/21 21/23
56/14 75/6 75/19
80/14 80/22 90/8
91/17 131/13 182/5
better [4] 174/8
174/10 188/1 205/2
between [24] 7/22
8/7 11/4 19/15 38/9
38/12 40/5 71/18
72/18 79/3 87/16
88/18 101/7 105/2
112/2 112/3 123/12
124/7 127/22 176/13
177/15 204/25 209/10)
209/11
beyond [2] 69/1
76/17
bias [3] 61/6 78/3
80/3
big [5] 76/24 76/24
76/25 195/17 199/3
Bill [1] 209/25
bit [14] 13/1 58/24
69/12 78/11 84/5
97/10 122/6 122/7
125/14 170/9 173/24
174/8 198/7 206/21
bits [3] 67/11 77/7
110/13
black [2] 64/13 64/15
Blakey [4] 10/1 10/1
11/2 13/12
blind [4] 44/16
blocks [1] 77/5
blue [5] 59/13 64/13
64/13 64/17 87/19
blunt [1] 78/23
board [32] 40/9
63/20 65/18 65/19
65/22 65/25 66/4 66/6
67/3 67/5 69/5 69/10
70/23 71/1 71/4 73/1
74/4 75/3 75/5 76/11
79/16 82/10 82/15
82/16 82/17 83/2 83/5
84/6 85/8 85/13 85/18
85/21
Board's [3] 65/14
67/8 86/9
Bob [4] 16/10 16/11
16/12 24/4
bodies [1] 189/13
body [4] 5/14 135/3
152/3 153/15
bold [3] 147/24 152/3)
153/19
Bond [69] 5/6 5/8 5/9
5/11 5/11 5/16 5/18
6/4 6/4 6/12 6/18 8/10)
8/13 10/7 12/9 12/14
15/5 15/9 16/5 21/6
25/12 26/6 28/8 38/19
40/17 48/3 48/7 48/8
53/20 54/16 55/1
55/10 55/12 55/16
56/23 57/2 73/7 81/1
109/2 109/5 113/8
114/2 115/2 120/11
120/17 120/25 121/6
121/9 123/22 124/13
136/4 136/11 137/2
138/13 140/4 140/15
144/4 146/15 149/5
149/18 151/6 153/12
161/17 175/9 177/24
179/16 182/19 188/20
201/8
Bond's [1] 57/20
bookkeeping [2]
47/18 50/10
Booth [1] 44/18
both [11] 26/5 34/6
37/5 64/15 75/18 82/2
110/1 114/13 156/21
163/17 164/18
bottom [23] 2/23
2/25 16/4 42/9 48/18
49/22 65/18 70/3 82/3)
123/21 131/5 137/13
141/14 144/9 149/14
151/14 158/17 161/16}
171/3 181/12 183/2
197/22 206/20
box [1] 173/3
boxes [1] 162/15
brackets [1] 148/1
branch [12] 131/10
131/14 131/15 138/11
161/7 162/11 162/23
163/6 165/7 166/8
167/9 196/4
branch's [2] 166/9
166/11
break [17] 41/19 42/1
51/2 51/22 152/18
152/18 152/23 152/24
153/3 190/19 190/19
191/4 191/6 191/17
191/23 193/3 210/19
breakdown [1] 160/9
breaking [1] 18/8
Bremner [10] 125/15
127/22 128/3 128/12
129/14 146/21 147/21
151/15 158/20 184/4
Bremner's [1] 138/7
brief [3] 62/4 69/4
83/17
briefed [2] 61/12
61/14
briefly [7] 64/12
79/13 152/18 152/22
163/14 164/4 188/18
bring [11] 2/21 7/7
36/15 37/23 58/8 60/2
65/10 81/21 83/18
84/15 87/18
bringing [1] 32/24
brings [1] 210/14
British [1] 92/13
broad [3] 12/14
38/24 114/10
broader [9] 28/23
30/17 31/5 31/17
31/23 32/18 33/9
33/18 33/24
broadly [1] 53/2
broken [2] 70/5 70/6
brought [11] 11/4
17/15 17/19 17/22
56/22 57/7 84/1
108/23 130/5 161/11
206/18
BTO [1] 189/1
bug [6] 124/18
124/22 124/25 126/4
130/6 154/23
bugs [7] 97/8 97/12
97/20 203/9 204/12
205/15 206/3
build [2] 208/5
208/16
builds [1] 65/12
bullet [3] 64/23 65/22)
107/5
bundles [1] 12/10
burst [1] 89/17
business [3] 12/5
197/2 198/22
busy [2] 70/6 70/18
but [239]
Byfleet [1] 130/5
Co
Caddington [1]
181/16
calculator [5] 44/7
45/2 45/4 45/10 45/14
call [44] 7/18 7/19
24/8 24/19 25/1 26/21
38/5 43/17 64/5 64/21
65/2 65/8 65/18 65/19
66/4 66/21 67/3 73/21
74/24 75/23 76/7
81/24 82/16 82/17
83/17 83/20 83/21
83/23 84/8 85/12
85/17 113/9 113/11
113/15 114/21 115/12)
118/17 118/20 128/4
147/13 168/18 174/18)
194/24 196/2
called [17] 1/20 4/14
4/15 9/22 12/16 15/8
48/11 66/24 66/25
69/7 69/8 93/20 93/23}
135/10 170/17 201/23)
203/14
Callendar [11]
124/18 125/21 126/11
127/23 128/5 129/1
129/16 130/18 138/8
146/23 154/23
calm [3] 17/17 85/16
85/25
came [12] 23/5 56/14
75/13 88/5 88/7
100/21 104/2 111/15
119/2 161/19 195/7
204/8
Cameron [1] 73/22
can [159] 1/21 2/21
3/7 3/13 3/19 7/7 10/1
12/25 16/18 16/19
18/14 18/16 24/10
25/10 25/25 26/3
28/14 29/16 31/16
(58) been... - can
Cc
can... [140] 32/3 33/3
34/12 35/18 36/5 36/6
36/25 37/16 37/18
37/23 42/2 42/8 42/20
43/16 46/13 46/23
47/6 50/25 55/19
55/21 58/6 58/9 59/12
59/23 61/12 61/13
66/10 69/14 71/8 73/4,
74/21 76/4 77/2 77/14
79/19 80/25 82/2
83/18 84/14 86/14
87/10 88/6 89/9 90/19)
90/20 94/20 95/19
96/3 97/10 107/5
107/20 109/11 114/19}
115/23 118/12 120/5
122/19 125/13 126/24
127/21 128/6 129/13
129/18 131/4 131/5
131/25 132/10 132/11
133/23 134/15 135/23
138/2 139/25 141/4
141/12 141/15 144/8
146/18 147/22 148/11
148/14 149/10 149/15
149/23 151/22 151/25}
152/2 152/12 152/20
153/5 153/13 155/11
159/4 162/12 162/13
162/15 163/5 163/11
163/14 164/4 164/6
165/7 168/13 170/14
172/6 173/20 175/7
177/18 177/21 178/4
180/8 180/14 181/12
182/24 183/9 184/4
185/10 190/21 191/15}
191/25 192/21 193/5
193/6 193/22 195/13
196/9 196/11 198/6
198/8 200/13 205/11
206/14 206/20 206/21
206/22 207/9 208/1
208/8 208/12 210/6
can't [21] 6/23 7/20
7/25 8/18 8/22 17/3
31/6 31/8 33/11 34/4
54/21 64/20 89/5
100/9 102/15 105/21
150/24 180/6 187/2
187/5 207/16
cannot [9] 7/12 29/13
71/6 88/2 150/5 152/5
154/14 154/18 166/14
capabilities [1] 163/6
capture [1] 83/16
capturing [1] 66/9
care [2] 40/20 78/23
career [2] 5/21 78/16
carried [5] 163/12
169/4 170/20 171/13
174/15
carry [4] 23/17 52/11
147/17 184/20
carrying [1] 57/17
case [87] 4/19 4/23
6/1 6/7 6/25 9/25
10/12 10/23 11/20
11/20 11/21 11/23
13/12 14/5 14/15
14/17 14/17 14/19
14/20 15/25 16/9
17/20 19/15 20/3
21/25 22/11 22/24
23/6 23/24 24/11
25/24 26/6 27/18
28/20 28/23 29/10
30/2 30/9 30/15 30/25)
31/9 31/21 31/21
32/11 32/17 33/10
33/15 33/25 34/21
34/24 35/3 35/7 35/12)
35/13 35/15 35/20
39/2 39/15 40/23 43/7)
44/15 47/17 48/6 53/6
53/9 53/17 54/23 80/2
88/12 89/6 99/7
102/16 118/3 126/11
127/6 128/20 130/5
142/10 164/1 177/22
179/18 189/19 195/2
200/12 201/19 207/17,
210/3
cases [10] 9/14 11/4
11/11 19/10 19/16
28/16 35/6 38/10
38/22 50/4
cash [4] 23/19 42/18
45/19 47/10
Castleton [32] 4/11
4/15 6/1 6/7 6/25 7/11
11/19 11/20 11/25
14/19 14/22 15/3 15/6
15/11 24/20 30/6
31/19 32/11 32/20
32/23 33/4 35/25
37/21 39/2 40/23
41/23 41/25 45/18
45/22 46/2 48/6 49/5
Castleton's [9] 19/15
24/15 26/12 26/17
28/20 28/22 30/2
32/19 45/17
catch [1] 3/14
catch-up [1] 3/14
categories [4] 154/4
156/13 159/14 160/10
category [10] 154/18
154/20 155/4 155/17
156/5 156/10 156/14
156/15 157/25 160/41
Cath [2] 22/5 29/24
cause [2] 42/23
78/16
caused [1] 103/4
causes [1] 157/7
causing [1] 30/1
caveat [1] 174/4
Caveatting [1]
172/16
Cavender [9] 56/9
56/15 64/5 69/17
72/22 73/6 73/10
74/15 77/25
Cavender's [3] 72/13
72/20 73/19
ce [3] 36/10 64/7
64/9
CCRC [1] 88/1
CD [3] 181/19 184/10
184/12
cent [1] 145/20
central [3] 101/9
101/14 101/18
centre [1] 77/14
CEO [1] 125/22
certain [9] 19/13 98/6
100/3 106/10 106/10
110/12 110/24 111/3
192/11
certainly [14] 14/5
21/2 24/9 50/2 50/2
97/14 117/22 119/1
133/1 142/10 152/22
208/11 209/8 210/3
certainty [1] 145/21
cetera [7] 92/16
92/18 95/23 104/1
104/22 167/25 195/19}
chain [14] 37/1
125/11 134/13 134/18
134/19 135/23 136/24]
137/6 141/12 158/14
182/24 206/20 208/2
208/25
Chair's [1] 76/11
Chairman [4] 67/3
73/22 74/5 75/4
challenge [1] 31/22
challenges [2] 4/9
28/16
challenging [1] 50/5
chambers [4] 41/6
41/6 41/9 41/14
change [28] 23/19
33/4 33/6 33/25 35/12,
109/21 109/24 166/17)
166/20 166/23 168/17
168/20 168/21 169/6
170/16 172/4 176/15
196/2 196/25 197/2
197/6 197/14 198/17
198/22 198/25 199/11
200/11 207/11
changed [1] 100/7
changes [3] 108/9
109/22 207/10
changing [2] 64/19
155/12
character [1] 103/19
characterisation [1]
8/13
characterise [2] 98/2
202/13
characterised [2]
112/16 112/17
charge [2] 109/21
200/16
chased [3] 12/5
44/17 44/21
chasing [1] 125/24
chat [1] 62/1
check [5] 54/9 87/7
89/24 108/18 126/13
checked [3] 108/8
108/12 125/7
checking [1] 123/25
Chennai [2] 93/21
93/24
Cheryl [2] 10/9 10/19
chipping [1] 87/20
Chris [9] 8/6 112/3
113/19 113/20 114/3
114/7 117/17 121/7
185/5
chronology [1] 29/19
chunk [1] 198/9
circulated [1] 74/19
circumstance [1]
25/19
circumstances [5]
4/17 13/16 46/20
166/13 191/19
cite [1] 169/23
cites [2] 170/22
172/7
civil [16] 5/20 6/20
10/20 11/4 12/24 13/3}
13/9 13/16 13/20 14/3}
14/5 14/17 50/1 50/2
50/2 88/19
claim [12] 10/21 13/4
13/6 15/11 16/16
17/22 20/22 29/23
30/6 31/2 32/19 32/24
claimant [2] 88/3
88/22
claimant's [1] 151/17
claimants [7] 86/22
87/24 88/7 172/12
175/19 184/19 203/6
claimants’ [7] 151/7
154/16 161/13 161/20}
161/24 162/10 185/17)
claims [8] 12/3 20/24
27/24 32/22 37/20
38/4 50/1 50/3
clarification [5] 94/8
123/17 127/12 130/14
188/17
clarifications [3]
184/24 207/4 208/23
clarify [5] 11/25
126/24 153/11 182/19}
184/9
clarifying [1] 176/3
clarity [2] 34/20 95/7
class [17] 3/11 13/24
13/25 18/3 18/12
18/15 19/3 19/8 20/6
20/20 21/2 21/8 27/4
27/14 30/19 38/2 39/2
classifies [2] 172/4
173/2
clause [3] 3/5 3/10
3/10
clauses [1] 3/5
clear [20] 17/20
19/14 25/11 32/25
74/9 75/18 81/12
84/24 117/23 127/15
133/23 139/11 145/15}
150/13 152/10 187/15}
187/18 193/14 203/17)
210/8
clearly [10] 33/10
39/17 41/9 92/17
103/15 172/14 193/22)
194/11 194/13 194/15)
client [18] 6/8 6/11
6/15 6/16 8/21 13/9
14/12 14/18 17/1
17/15 20/11 25/9
26/22 34/23 40/19
57/8 57/19 58/2
clients [1] 58/20
close [3] 39/7 172/24
210/15
closed [4] 158/23
176/19 176/20 176/22)
closely [3] 109/18
185/12 186/3
CMS [1] 15/8
Cohen [1] 64/8
Cole [1] 37/10
collaboration [1]
210/9
collaborative [3]
204/17 204/20 206/15
collating [1] 27/19
collation [1] 30/10
colleague [1] 176/4
colleagues [4]
116/13 116/17 137/12)
209/22
colour [1] 18/17
colours [1] 64/19
column [2] 118/7
119/11
come [36] 4/24 9/23
24/17 28/11 32/21
48/6 59/16 60/20 63/7)
73/1 75/15 75/16
90/11 94/2 98/24
115/23 117/23 119/3
120/21 122/6 122/19
123/14 127/11 136/2
(68) can... - come
Cc
come... [12] 136/25
146/24 149/3 150/3
152/20 158/5 179/14
195/8 195/13 198/1
204/12 204/15
comeback [1] 200/17!
comes [3] 57/23
173/25 196/9
coming [5] 20/12
51/7 78/2 89/11
149/20
comment [6] 26/9
44/2 44/13 44/23
57/18 182/15
commentary [1]
203/4
commented [1]
116/21
commenting [4]
165/18 203/12 203/24}
209/6
comments [19] 56/1
70/1 70/4 115/24
116/16 119/12 153/15)
162/7 162/17 163/14
163/15 165/2 207/10
208/3 208/5 208/11
208/15 208/21 208/22)
commercial [5] 6/14
54/1 54/2 109/21
109/24
Commission [1]
189/19
common [16] 52/19
54/11 54/18 54/24
55/2 55/11 55/17
60/16 61/1 61/3 71/18
80/1 85/23 86/2 86/12
106/19
communicated [4]
74/14 197/18 199/2
205/25
communication [1]
107/21
communications [1]
117/25
companies [2] 92/4
92/15
company [4] 36/2
75/6 80/14 95/19
comparison [1] 45/1
compendium [1]
79/17
competing [3] 71/1
7113 71/7
complete [3] 51/17
172/17 172/18
completed [1] 37/13
completely [6] 28/12
34/14 127/15 150/13
154/6 195/14
complex [1] 7/5
complexity [1] 4/9
compliance [1]
189/21
complicated [1]
122/7
comply [1] 19/20
composed [2] 81/3
81/4
comprised [1] 164/9
compromise [1]
32/20
computer [3] 37/15
47/8 180/25
computerised [1]
181/1
concealing [1]
132/24
concede [1] 89/4
concept [4] 40/12
60/4 72/11 170/15
concern [7] 20/12
31/23 54/7 187/4
187/14 194/8 194/12
concerned [8] 31/20
31/24 43/3 43/5 96/13)
135/19 146/10 174/13)
concerning [5] 43/7
86/21 175/3 177/25
179/9
concerns [20] 10/20
20/6 30/17 31/5 31/16
31/17 33/5 33/9 33/19)
33/24 43/22 44/9 55/4
76/11 108/22 112/18
112/23 118/6 139/20
194/21
conclude [3] 187/19
190/14 192/25
concluded [1] 44/14
conclusion [4] 47/7
80/4 160/16 192/13
concrete [1] 63/24
conduct [2] 25/23
53/17
conducted [1]
205/13
conducting [1] 7/1
conference [13]
21/14 27/17 29/3
29/10 37/24 38/2 79/6
79/8 79/14 80/23
81/24 83/13 113/9
confidence [2] 4/25
48/23
confident [2] 4/20
50/12
Confidential [1]
16/15
configuration [1]
95/5
confirm [21] 113/18
115/16 115/18 120/25)
121/15 123/25 126/3
128/5 128/19 129/18
129/20 134/10 137/15}
149/6 150/5 153/14
155/1 156/10 156/11
159/4 173/20
confirmed [4] 136/15
136/15 162/14 184/9
confirming [1] 134/7
confirms [1] 107/5
conflicted [1] 32/10
confuse [1] 210/21
confusion [1] 154/1
connected [1]
143/22
connection [6] 9/16
71/19 130/5 168/14
181/15 190/1
conscious [3] 74/5
177/3 190/17
consent [5] 20/23
26/24 34/6 150/11
161/8
consider [8] 6/10
12/19 13/20 14/13
99/24 139/15 139/15
140/18
considerable [1]
209/21
considerably [1]
158/15
considered [2] 139/6
200/15
considering [1]
138/25
consistent [2] 38/3
157/10
consolidation [1]
206/7
constantly [1] 119/14
consult [3] 106/3
116/13 122/16
consulted [4] 28/22
29/13 116/17 203/20
consulting [2] 92/13
109/16
contact [2] 107/21
129/13
contacted [1] 37/10
contain [5] 18/2
97/13 98/14 98/19
167/1
contained [14] 48/10
97/7 97/24 98/22
107/24 121/1 122/9
126/15 127/2 157/6
157/12 167/24 180/8
183/19
containing [2]
118/10 181/19
contains [5] 96/24
119/13 121/16 124/1
162/7
contemporaneous
[2] 81/17 84/3
content [8] 74/14
91/17 100/1 108/15
138/14 159/16 191/20}
210/1
contents [1] 3/20
contested [1] 89/2
context [13] 27/21
31/6 48/9 130/4 136/8)
136/10 180/2 188/24
189/16 200/9 201/2
202/10 206/18
continues [2] 185/22
185/23
contract [2] 3/9 40/6
contradictory [1]
176/4
contrary [1] 158/3
contrast [1] 174/7
contributing [1]
196/7
control [17] 92/4
92/8 95/3 96/14 99/25)
108/13 172/4 196/3
196/25 197/2 197/6
197/14 198/18 198/22}
199/1 199/11 200/11
controlled [5] 95/3
96/20 99/4 101/9
101/12
controls [1] 181/8
conversation [19]
14/18 19/6 19/7 23/21
24/5 32/8 43/21 58/7
59/4 59/8 59/9 59/14
59/18 59/23 60/13
60/17 69/3 77/6
173/14
conversations [8]
58/5 60/18 60/20 61/7
88/21 112/2 117/20
127/17
conveyed [2] 68/11
200/8
convicted [6] 12/21
13/22 87/25 88/8
88/23 88/24
convictions [2] 88/4
89/4
convinced [1] 44/5
Cooper [6] 67/2
67/14 67/16 67/21
68/4 68/21
copied [16] 10/13
16/18 37/6 56/17
107/2 114/6 118/1
121/7 125/17 135/4
185/6 185/22 185/23
186/8 196/13 197/23
copy [14] 10/10
10/19 23/20 29/21
36/7 69/18 76/20
84/19 91/4 129/6
129/10 140/9 141/2
180/10
copying [3] 10/16
138/4 206/24
cordial [3] 17/1 17/4
17/6
core [3] 76/2 94/19
94/25
correct [94] 5/5 28/9
50/15 60/15 79/25
86/11 91/8 91/9 92/2
92/6 93/3 93/7 93/15
94/15 94/17 95/13
95/20 96/1 96/11 97/6I
97/25 98/1 101/2
101/3 101/13 102/1
102/22 103/3 104/16
107/16 109/8 117/8
117/18 120/18 121/3
123/18 124/8 124/22
127/2 128/1 130/3
132/7 134/11 136/15
136/16 136/17 136/22!
137/19 137/20 137/23)
147/24 147/25 148/5
148/9 148/25 152/19
153/22 154/11 154/12)
154/24 155/15 155/18)
156/9 158/2 159/4
159/7 159/9 159/23
160/2 160/7 160/13
161/9 165/9 168/25
169/3 169/22 171/16
172/10 173/10 177/14I
181/9 184/13 185/3
186/12 201/17 202/14)
203/3 203/11 203/21
204/1 204/6 204/19
204/23 207/25
corrected [1] 166/14
correcting [1] 166/11
correction [6] 2/24
164/23 165/11 166/15)
166/16 167/2
Correction’ [1]
164/19
corrections [5] 2/19
3/20 164/16 164/20
165/7
correctly [3] 92/20
100/17 201/13
correspondence [3]
10/13 19/24 193/19
corresponding [2]
147/1 147/6
cost [5] 32/12 32/17
35/8 45/20 45/24
costs [3] 33/25 34/7
46/7
could [97] 1/13 1/25
2/6 3/8 7/16 7/18 7/19I
10/5 16/3 19/1 21/10
26/22 28/2 29/17
38/17 38/21 39/15
41/17 42/8 46/23
50/15 61/18 61/23
63/8 63/9 64/1 65/17
(60) come... - could
Cc
could... [70] 66/16
66/19 69/16 72/12
73/13 73/15 73/15
76/19 77/3 79/13
81/21 81/22 87/17
90/11 90/22 91/10
92/7 96/3 97/16 101/4
106/4 109/10 113/18
113/24 114/21 115/15)
116/5 118/20 119/24
121/15 122/14 122/15
123/25 126/2 126/3
132/25 133/24 134/1
134/13 135/16 136/20
137/14 141/10 143/21
145/14 145/17 146/3
146/19 147/10 148/22)
151/13 152/18 156/19
156/22 160/5 161/16
162/3 162/25 168/12
171/6 171/22 174/19
175/5 175/16 178/13
179/2 183/1 191/12
195/18 197/17
couldn't [6] 49/14
50/13 78/23 143/22
173/7 186/1
counsel [9] 8/7 8/9
23/4 23/6 25/11 59/24
74/1 83/3 85/15
counsel's [1] 41/5
countdown [1]
191/25
counterclaim [9]
15/13 15/17 31/21
33/11 34/8 35/1 35/20
35/20 36/1
couple [4] 52/5
179/11 184/23 208/22)
course [20] 1/12 4/24I
9/23 14/6 34/5 42/2
42/24 75/7 75/15
75/19 77/3 87/4
151/10 152/6 157/1
157/18 159/2 191/8
195/13 207/21
court [5] 15/23 52/21
52/25 72/3 114/8
cover [6] 41/12 51/6
58/22 69/12 79/13
176/17
covered [6] 58/15
156/13 159/23 161/24}
165/19 173/18
covering [1] 170/18
Coyne [6] 151/17
203/5 203/6 204/9
204/12 205/16
CPS [1] 189/22
CPview [1] 76/3
crashing [1] 32/21
created [3] 35/24
76/6 159/18
criminal [22] 5/23
6/18 6/19 6/20 6/22
6/23 6/24 11/1 11/5
11/16 12/11 12/21
14/4 14/13 14/17 50/1
50/3 87/17 88/19
189/18 189/22 190/1
criteria [3] 138/22
155/12 172/14
criti ing [1] 74/3
criticism [1] 76/4
cross [1] 33/13
Crown [1] 189/10
Cs [1] 175/19
currency [1] 53/21
current [29] 36/16
70/21 71/10 95/8
119/13 119/14 119/18)
121/2 121/16 121/25
122/1 122/9 122/17
123/2 123/5 123/7
124/1 136/5 136/13
136/21 137/4 148/13
156/19 156/21 157/2
157/20 159/10 159/14
159/15
currently [10] 18/2
18/5 20/25 88/1 88/2
93/20 107/11 122/15
166/18 207/6
custodians [1]
128/24
customer [1] 42/18
DO
damages [1] 80/9
data [48] 11/16 12/1
12/22 13/6 13/11
14/16 37/14 50/1
102/22 103/1 104/12
104/14 105/1 105/5
106/5 106/16 106/20
107/8 107/10 107/19
107/22 108/2 108/4
114/15 121/15 126/25)
133/21 161/6 162/12
162/22 163/13 166/9
167/9 169/15 179/9
180/24 181/4 181/8
181/17 181/19 184/14)
184/18 193/13 194/8
196/19 196/25 198/13)
198/18
data/logs [1] 163/13
database [12] 95/6
95/6 118/9 119/13
122/9 123/2 123/7
126/22 135/14 140/6
140/23 169/24
databases [2] 117/5
4117/7
dataset [1] 171/4
date [14] 29/6 36/9
36/15 38/7 89/9 95/24
102/3 102/14 131/10
146/12 149/17 150/5
158/9 180/17
dated [13] 1/24 10/19
21/11 46/15 91/5
114/1 121/6 125/16
141/15 144/10 164/7
176/2 180/14
dates [1] 151/25
Dave [13] 10/7 10/14
10/16 10/18 137/14
137/16 138/4 175/11
175/12 175/16 188/7
205/25 206/25
David [10] 10/1 11/2
56/9 56/15 64/5 69/17,
72/12 72/19 74/14
77/25
David Blakey [1]
10/1
Davidson [3] 105/9
106/24 107/16
day [19] 26/16 26/25
42/19 51/16 54/6 54/6
54/7 54/7 62/23 66/18
74/23 93/13 134/23
180/16 188/6 188/6
207/12 208/19 211/1
days [7] 43/17 48/15
58/1 59/3 61/11
173/13 179/11
days’ [4] 24/11
DBA [1] 176/21
DCQC [1] 64/5
de [4] 200/8
deactivated [6] 152/5I
155/5 156/2 156/22
156/25 157/3
dead [1] 63/20
deadline [1] 15/17
deal [11] 2/21 38/2
38/3 52/9 79/12 97/15
118/11 139/13 188/25]
191/5 210/9
dealing [18] 4/23
6/25 13/4 27/23 31/8
38/1 38/10 88/12
88/16 88/25 89/15
90/3 99/15 103/9
117/5 162/19 187/22
189/15
dealings [1] 114/11
dealt [7] 87/8 89/1
99/11 103/12 109/14
110/23 122/24
debarred [4] 48/14
48/25 49/12 49/14
debated [1] 100/3
debt [9] 7/5 11/7 12/3
12/10 12/15 13/4 13/6
15/6 17/22
debts [2] 11/12 12/5
December [4] 23/9
29/3 29/6 36/14
decide [2] 52/4
105/18
decided [1] 79/1
deciding [1] 179/3
decision [11] 51/18
63/14 65/6 66/11
68/12 82/20 139/10
174/12 175/1 177/3
183/18
decisions [1] 52/22
declare [1] 113/1
dedicated [1] 97/3
deducing [1] 142/9
deemed [1] 122/17
deep [2] 4/17 88/12
default [29] 15/23
17/11 18/5 18/22 20/4}
20/5 20/10 20/14 21/1
21/20 21/25 22/17
23/10 23/22 23/23
24/24 25/5 25/8 25/13)
25/24 26/4 26/13
26/20 26/23 27/6
27/23 27/25 34/22
155/10
defects [4] 97/9
97/12 97/20 203/9
defence [10] 15/13
15/16 15/24 31/23
34/15 45/25 111/11
111/25 114/4 121/8
defend [1] 27/14
defined [1] 96/25
definite [2] 26/5
186/2
definitely [4] 26/23
102/16 159/4 205/7
definition [2] 119/4
156/8
definitive [2] 40/14
192/13
definitively [3] 52/24
129/20 173/7
degree [4] 44/10
49/13 49/15 91/24
delay [2] 115/21
176/13
deleted [83] 129/3
129/6 130/8 131/1
132/5 132/10 132/11
132/15 132/18 132/24}
133/17 133/24 133/25]
134/11 134/16 134/20}
135/1 135/10 135/16
136/19 138/12 138/18
138/20 139/21 140/5
140/12 140/21 141/8
141/12 141/19 141/22)
142/7 142/17 142/21
143/8 143/11 143/13
143/19 143/20 143/21
144/5 144/6 144/14
144/22 145/1 145/11
145/23 146/8 146/25
147/9 148/11 148/14
148/17 148/22 148/25)
149/1 149/6 149/16
149/25 150/1 150/4
150/7 150/9 150/12
150/17 151/2 152/5
152/10 152/14 153/23)
154/2 154/5 154/6
154/18 154/20 154/21
154/21 155/9 156/6
156/7 159/14 159/19
159/22
deletion [10] 130/10
130/24 133/20 134/1
134/2 134/2 142/5
146/15 147/18 159/20)
delivered [1] 164/21
demanded [1] 204/5
demonstrable [1]
80/3
demonstrated [1]
13/1
denied [1] 41/8
Department [1]
186/17
depending [1] 205/9
depends [1] 208/12
deprecated [11]
155/17 156/1 156/5
156/14 156/19 156/24I
159/14 159/15 160/1
160/3 160/10
depth [1] 59/13
deputies [1] 110/3
describe [7] 7/16
17/14 94/22 138/9
155/4 163/10 178/13
described [12] 6/7
8/10 18/12 38/1 43/25]
119/7 162/12 163/5
164/21 164/24 181/8
195/4
describes [2] 129/22
196/13
description [6] 8/25
118/7 131/11 131/17
172/5 198/14
design [3] 95/2 95/12
103/16
designed [1] 172/2
designs [1] 103/25
desire [5] 21/7 27/1
46/1 86/11 86/12
desk [3] 14/6 14/15
199/24
desperately [1] 24/2
despite [1] 173/18
detail [6] 14/20 50/8
55/24 88/25 104/22
209/21
details [8] 15/20
98/14 117/21 132/12
134/10 134/16 167/1
(61) could... - details
D
details... [1] 189/5
detection [2] 157/13
160/23
determine [3] 105/11
110/15 172/23
determined [1]
111/16
determining [2]
111/4 111/25
developed [3] 36/5
118/14 165/11
developing [1] 77/23
diagnosis [2] 157/14
160/24
dial [1] 79/16
dial-in [1] 79/16
dialogue [2] 204/25
209/9
Dickinson [46] 5/9
5/11 5/11 5/18 8/10
8/14 21/6 48/8 53/21
54/16 55/10 55/13
55/16 56/24 57/2 73/7
81/1 109/2 109/5
113/8 114/2 115/2
120/11 120/17 120/25
121/6 121/9 124/14
136/5 136/11 137/2
138/13 140/4 140/15
144/4 146/15 149/5
151/6 153/12 161/18
175/9 177/25 179/17
182/19 188/21 201/8
Dickinson's [3] 6/4
123/23 149/18
did [117] 6/10 6/21
6/24 7/1 9/2 11/23
16/1 16/8 17/2 18/24
21/6 25/23 41/5 44/9
46/17 47/20 48/3 48/6)
50/24 53/22 53/24
54/3 55/23 57/13
57/21 60/1 60/10
60/21 65/14 68/20
70/11 74/18 80/12
80/22 82/12 83/6 83/9
83/11 83/23 85/9 86/3
86/5 86/8 96/13 97/13
98/15 98/19 99/1
99/24 102/2 102/11
102/12 104/4 104/17
104/19 104/24 105/11
105/18 106/3 106/12
106/19 107/18 107/20
108/1 110/15 112/6
112/11 112/18 114/25}
116/12 121/20 123/6
123/9 123/19 127/11
130/9 132/17 133/3
133/5 133/18 133/20
135/12 136/7 137/2
137/10 139/15 140/18
145/1 148/21 149/21
153/11 155/14 158/9
167/3 167/15 168/2
171/19 171/21 172/20)
177/16 178/17 178/24
179/2 179/14 179/24
180/2 182/10 182/25
188/19 188/25 189/16)
194/16 195/8 196/6
197/1 198/1 198/21
didn't [36] 6/17 6/19
6/20 19/7 24/21 34/16
46/8 49/20 49/22 50/7
50/22 53/3 64/20
68/25 98/24 103/12
108/19 116/8 116/22
116/25 120/12 124/24,
126/17 130/13 133/6
142/18 144/25 167/20)
179/10 180/4 182/15
186/7 186/19 192/12
195/9 198/25
difference [3] 124/12
146/9 199/4
differences [2] 42/23
47/10
different [20] 35/5
53/18 77/5 77/7 93/4
103/19 103/24 122/2
134/19 139/7 139/9
143/6 152/6 160/9
164/18 195/10 195/17,
198/15 198/19 204/25)
differently [1] 187/25
difficult [4] 34/3 34/9
196/23 198/16
difficulties [1] 27/11
difficulty [4] 38/15
54/24 57/8 68/15
dig [3] 46/8 132/11
134/15
dilatory [1] 175/22
diligent [1] 44/22
diligently [1] 44/17
Dilley [15] 16/5 21/13
26/11 29/20 30/8 32/4
33/14 36/11 37/2
38/12 38/19 42/3
44/18 45/3 48/5
Dilley's [6] 21/16
30/5 35/17 40/16
43/19 45/9
Dimension [1]
114/14
Dimensions [9] 95/6
96/17 96/18 103/17
105/20 106/13 107/25)
148/8 193/15
direct [3] 109/2
138/10 202/1
directed [4] 34/14
110/16 179/12 186/15)
direction [3] 20/19
71/16 139/13
directions [3] 115/4
115/13 122/8
directly [10] 99/10
102/7 102/10 103/10
108/2 108/5 112/8
127/18 189/10 189/20
Director [1] 67/18
director's [1] 67/8
directors [2] 65/9
75/11
Directors’ [1] 83/24
disastrous [1]
200/11
disclose [1] 140/12
disclosed [22] 12/20
13/21 95/15 95/17
111/5 136/13 143/16
143/20 144/1 151/22
154/17 156/16 158/1
159/22 159/25 160/15}
160/19 160/20 160/21
174/3 179/10 189/9
disclosing [1] 102/25]
disclosure [20] 14/8
14/10 112/23 137/3
140/14 146/12 150/11
168/7 174/3 184/25
185/13 185/20 189/1
189/6 189/15 189/21
195/3 195/4 195/22
198/5
discontinue [1] 34/7
discover [1] 135/19
discovered [5] 12/16
13/17 143/8 143/10
143/25
discovery [1] 142/19
discrepancies [1]
15/3
discrete [2] 90/4
203/1
discursive [1] 84/10
discuss [9] 14/12
28/15 47/20 48/3
70/23 87/3 108/11
133/6 137/6
discussed [10] 16/18
31/11 47/11 47/23
50/23 83/12 114/23
115/12 123/10 198/20
discussing [5] 40/22
81/12 100/24 103/7
109/22
discussion [13]
38/12 41/7 65/8 73/25)
75/10 84/2 86/20
110/17 129/8 140/22
173/23 177/16 185/20
discussions [5] 41/2
69/1 115/1 177/11
189/24
dismayed [1] 55/13
played [1] 33/10
Disputes [2] 54/1
54/2
dissuade [1] 45/22
distance [3] 7/3 25/5
28/14
distinction [3] 3/1
123/12 124/6
distinguish [1]
124/10
distraction [1] 2/25
distraught [1] 55/21
distributed [3] 54/10
54/19 95/15
disturbed [1] 17/10
divide [1] 206/3
ided [1] 205/9
dividing [1] 205/14
division [2] 99/10
99/16
do [155] 5/23 6/3
8/17 9/7 12/18 13/19
14/11 17/1 22/1 22/3
22/10 22/12 23/15
25/15 25/20 26/2 26/5)
26/7 26/21 27/17 29/9)
29/11 30/24 32/7 33/5)
35/1 35/1 35/6 35/25
36/20 42/24 44/14
47/3 48/23 49/23
50/17 51/5 57/6 57/10)
57/16 58/20 62/8
62/25 63/8 63/9 63/20
65/4 65/8 65/13 65/13)
67/7 67/11 67/25
70/12 71/11 72/9
76/10 76/15 78/16
81/3 82/25 84/10
84/11 86/10 87/16
88/17 88/24 89/2
92/22 94/11 97/15
99/7 99/18 104/10
105/22 106/8 106/9
114/22 118/16 118/19
119/20 119/22 120/11
124/18 129/25 132/5
132/22 133/10 137/7
138/22 139/20 140/11
141/1 141/6 142/3
144/5 144/23 146/1
147/6 148/16 149/16
150/10 151/1 151/3
151/7 151/9 151/18
152/22 158/7 158/9
160/3 161/25 162/16
163/18 168/3 168/10
169/6 172/16 174/12
177/3 178/1 178/6
178/22 179/7 179/12
179/16 180/5 181/20
182/20 186/23 187/25}
188/11 188/18 188/24,
189/2 189/9 189/24
190/8 192/6 192/7
192/17 192/18 192/21
193/12 194/16 195/19)
196/4 199/1 199/20
202/13 205/20 205/24I
206/6 206/7 207/16
document [62] 3/3
12/19 13/1 13/20 16/2I
28/3 28/10 28/12 36/7I
49/10 49/12 64/12
73/12 76/22 84/14
92/4 92/8 93/2 93/8
93/10 93/16 93/17
94/6 94/19 94/23
94/25 95/21 96/14
98/4 98/6 99/25
100/11 100/14 100/15)
100/17 101/1 1041/7
102/4 102/20 110/25
114/15 115/9 116/5
116/9 120/10 131/2
137/12 154/10 158/7
161/17 164/24 166/2
171/24 189/15 190/4
196/8 197/4 197/19
199/10 206/17 208/3
208/6
document' [1]
114/10
documentation [14]
92/12 95/2 95/3 95/5
95/12 96/16 96/25
97/4 104/11 107/7
107/14 147/7 148/7
194/6
documents [63]
10/24 12/10 59/19
73/4 81/9 84/14 85/24
91/8 92/18 92/19
92/24 95/8 95/9 95/15
95/19 95/22 96/18
98/2 98/3 98/11 102/3I
102/13 103/4 103/9
103/11 103/12 103/16
103/17 103/20 103/24I
104/3 105/18 105/24
106/11 106/12 107/24)
108/16 113/2 113/12
114/9 114/14 114/18
114/19 115/7 115/14
117/6 121/1 121/13
157/10 158/24 160/18}
160/22 161/10 161/21
163/22 164/8 164/10
168/18 185/4 189/9
189/17 189/25 194/23}
does [21] 45/10 47/1
61/13 65/4 65/25
70/24 72/8 77/1 78/9
102/12 117/19 133/1
133/17 160/13 164/12)
170/3 183/9 185/24
186/23 194/12 201/22!
doesn't [12] 45/10
68/18 72/7 74/18
83/14 120/8 124/11
130/16 141/25 174/23}
(62) details... - doesn't
D
doesn't... [2] 175/25
197/16
doing [27] 8/19 8/23
8/24 9/7 9/18 11/7
50/3 60/8 61/8 75/18
78/13 78/14 89/24
92/9 106/9 128/13
133/4 145/25 165/5
165/21 169/6 183/19
183/23 188/5 188/9
200/6 201/20
don't [142] 9/2 11/8
12/6 13/13 14/1 14/9
15/20 18/20 19/13
21/9 23/13 23/15
23/16 25/3 25/4 25/5
25/6 30/20 32/9 34/2
36/21 40/12 40/15
41/10 47/22 48/18
50/2 50/22 50/22 51/1
51/14 55/8 55/24
55/24 56/7 56/12
57/13 60/13 60/18
61/15 63/19 63/19
64/9 64/10 65/16 71/2
71/5 71/7 72/2 72/21
73/24 74/17 74/18
75/16 75/16 76/8
76/20 79/11 80/20
80/20 80/23 80/23
83/9 83/11 83/16 84/7
84/13 85/15 86/5 86/6
88/12 88/21 89/5 89/7
94/9 94/15 95/21
100/23 105/6 106/8
106/18 107/17 107/17)
107/18 107/23 108/10}
111/20 114/24 114/25}
117/21 118/2 119/2
120/3 120/4 120/13
126/12 128/11 129/8
130/25 133/1 133/5
133/22 134/5 134/17
134/19 136/22 137/8
139/19 145/11 145/24}
146/6 146/7 150/14
165/14 165/16 165/24}
168/4 172/3 174/15
174/16 174/18 174/20}
176/12 178/24 179/4
181/22 181/25 186/16)
186/25 187/7 187/8
188/6 189/4 189/7
189/12 189/23 192/12)
199/23 200/13 201/25}
210/1 210/22
done [26] 7/12 44/12
44/24 46/18 48/21
59/6 65/16 73/14
78/15 105/2 113/6
123/23 127/18 153/17)
165/4 172/8 173/11
183/10 183/12 189/4
192/14 194/2 196/7
197/5 199/11 210/4
double [5] 42/16 43/1
43/11 47/18 50/10
doubt [3] 48/1 88/3
145/19
down [42] 3/4 3/8
3/19 17/25 18/8 23/17
37/4 44/17 44/21
46/23 58/24 62/3
64/22 64/23 65/17
67/11 67/13 68/3 68/7
69/16 70/7 72/9 74/22
76/19 76/21 77/14
125/14 131/9 138/2
145/22 146/19 151/13)
153/18 158/18 162/9
162/25 171/3 183/2
197/20 198/6 199/8
207/5
down' [1] 32/21
download [1] 105/20
downside [1] 32/12
dozen [1] 110/4
draft [29] 34/12
41/17 46/13 46/15
47/13 48/12 48/17
49/10 54/10 54/18
54/25 55/11 69/20
82/25 115/3 115/13
116/6 179/16 179/18
179/22 180/10 180/20)
182/18 203/12 206/19)
207/2 207/6 209/6
209/15
drafted [3] 71/14
79/3 179/25
drafting [6] 70/19
72/8 77/25 178/22
183/20 183/24
drafts [1] 107/13
drafts/WIP [1] 107/13
draw [1] 77/14
drawing [1] 157/24
drawings [1] 92/16
drawn [1] 19/14
dreadfully [1] 48/13
dredging [1] 7/6
drifted [1] 89/18
drive [7] 14/22 140/9
140/16 140/24 141/3
142/15 142/19
driven [1] 71/20
drives [1] 95/23
drop [1] 9/10
dropped [1] 35/22
due [11] 1/10 9/23
20/17 42/23 54/13
75/15 78/3 144/14
152/17 154/21 195/13)
Dunks [3] 179/6
184/8 209/23
duplicate [1] 150/21
duplication [1] 48/24
during [8] 8/10 9/11
53/21 85/12 96/12
100/13 118/17 188/19}
duty [12] 14/8 14/11
75/5 75/9 75/11 79/20
80/11 80/13 80/16
80/18 80/21 189/21
E
each [13] 4/7 7/21
38/21 42/16 47/11
109/13 172/23 173/6
194/3 204/22 206/3
206/10 209/11
earlier [22] 35/4
36/17 38/1 59/11
71/17 78/11 105/23
125/24 137/3 142/13
157/2 157/3 159/3
174/2 177/10 187/11
193/20 194/6 197/2
198/22 199/1 201/4
early [25] 9/2 9/5 9/6
9/24 10/14 22/9 25/12
39/1 39/3 39/4 39/15
42/9 43/23 51/19 52/3
58/5 61/7 90/9 102/20)
151/1 151/5 160/6
177/25 185/12 185/14]
earner [1] 15/19
ease [1] 58/9
easier [1] 39/25
easily [2] 155/12
173/5
easy [2] 38/23 191/3
edge [1] 74/7
EDQ [5] 113/5 115/13
136/8 136/10 158/3
EDQs [1] 115/24
effect [7] 19/2 30/5
54/18 74/9 90/4 118/8
124/14
effectively [19] 5/14
17/15 53/6 73/11
103/8 109/23 110/6
1114/7 135/25 139/8
170/18 179/19 183/7
183/15 188/4 195/17
205/14 206/2 206/11
effort [1] 148/16
eg [1] 42/16
eg the [1] 42/16
egg [1] 32/21
either [18] 56/6 58/17
61/15 68/19 76/19
106/1 107/2 107/18
116/22 117/20 122/15
125/7 130/15 133/18
157/2 166/7 183/13
194/14
electronic [12] 42/13
44/6 45/2 45/4 45/9
45/13 115/3 115/13
117/6 122/8 158/6
158/24
else [10] 47/25 67/7
80/19 86/3 119/9
139/7 183/12 187/2
187/10 191/13
else's [2] 183/25
205/23
elsewhere [2] 118/24
119/2
email [115] 10/5
10/17 10/21 11/14
16/4 16/20 27/5 29/20}
32/5 33/14 33/23 36/8)
36/20 37/6 56/16
61/24 62/8 69/17 70/9
71/9 72/13 72/18
72/19 72/20 73/16
73/19 74/14 74/15
74/22 76/7 88/14
106/22 106/23 107/3
114/1 115/10 116/2
116/6 116/19 121/4
121/5 122/13 122/20
122/24 123/3 123/21
125/11 125/14 125/17}
126/8 127/9 127/18
128/16 133/8 134/13
134/23 135/3 135/13
135/23 137/6 137/9
137/14 137/25 138/3
138/15 139/5 140/20
141/15 142/13 144/8
144/21 146/18 146/20}
149/5 149/15 151/12
152/3 152/21 153/11
153/12 153/13 153/15]
153/18 157/23 158/12
158/15 158/19 164/5
164/8 167/18 168/18
169/13 171/3 171/25
174/2 174/16 182/24
183/14 184/2 184/3
187/1 187/11 193/19
197/19 197/21 198/7
198/11 199/20 205/22,
206/23 207/11 208/2
208/8 208/18 208/25
emails [16] 9/25 26/3
76/17 81/10 87/20
101/10 114/13 117/20}
179/11 179/17 185/6
185/10 185/22 185/23
185/23 186/10
embedded [1] 8/11
embryonic [4] 18/3
19/3 19/8 38/2
emphasising [1]
95/11
employ [1] 92/21
employed [4] 92/10
93/8 93/10 180/21
employee [2] 112/10
114/2
employees [4]
105/15 112/1 113/15
178/15
employment [1] 6/14
enclosed [1] 10/21
encompass [1]
114/11
end [9] 3/15 48/6
79/18 87/2 107/18
150/21 165/8 179/1
187/9
ended [1] 176/22
engagement [3] 7/10
713 717
engaging [1] 34/17
engineers [1] 92/13
English [1] 69/8
enough [5] 14/14
89/5 120/14 197/8
199/16
enquire [1] 68/20
enquiries [5] 134/8
145/22 148/21 168/2
169/4
enshrined [1] 147/4
ensure [3] 20/18
95/14 96/9
ensuring [1] 95/2
entailed [1] 165/23
entails [1] 92/8
enter [1] 205/6
entered [2] 15/23
34/23
entire [1] 88/2
entirely [4] 145/10
146/1 159/7 160/7
entities [1] 36/3
entitled [2] 119/11
169/23
entity [1] 18/7
entrenched [1] 78/3
entries [23] 42/19
64/15 118/10 119/13
119/18 119/19 120/17
120/20 120/24 121/2
121/16 121/20 121/22!
122/10 122/10 123/3
123/5 123/7 124/18
159/10 159/10 197/6
199/12
entries/versions [2]
119/18 159/10
entry [6] 42/16 43/1
43/11 47/18 50/10
119/11
envisaging [1] 20/2
epic [1] 37/6
equally [1] 96/2
equals [1] 59/1
eroded [1] 5/1
Err [2] 139/17 169/10
erroneous [1] 152/16
error [15] 15/19
45/18 48/10 48/12
(63) doesn't... - error
E
error... [11] 48/14
48/24 48/24 50/13
84/19 98/3 98/4
112/24 118/6 120/5
166/14
errors [14] 45/8
46/24 46/25 47/3 47/5)
48/19 49/20 80/1 97/8
97/12 97/20 141/20
160/25 203/9
Escher [1] 131/18
especially [1] 63/1
essence [1] 103/21
essential [1] 80/6
essentially [7]
127/20 132/23 139/12)
141/21 157/4 162/20
201/5
established [4] 52/24
133/11 171/14 177/10)
establishing [1]
177/12
et [7] 92/16 92/18
95/23 104/1 104/22
167/25 195/19
et cetera [7] 92/16
92/18 95/23 104/1
104/22 167/25 195/19
ete [3] 70/25 131/11
167/2
even [19] 9/13 18/5
20/19 32/17 33/25
41/8 63/16 79/2 108/7I
118/23 120/7 132/24
133/6 133/23 138/10
177/1 188/8 191/6
210/8
event [4] 41/8 58/1
114/14 152/17
eventually [1] 137/7
ever [8] 40/14 40/15
41/10 48/18 86/6
200/17 200/17 202/1
every [3] 4/7 35/18
177/13
everybody's [2] 70/6
208/21
everyone [2] 191/20
205/23
everything [3] 11/20
26/21 89/25
evidence [64] 1/16
1/17 1/20 3/24 4/3 4/6)
5/25 8/6 8/9 12/16
13/17 17/6 20/22
22/19 22/20 24/25
27/19 27/22 27/25
28/21 29/13 29/24
30/10 30/12 30/25
33/15 36/4 38/18
38/21 38/25 40/1
40/22 41/13 42/5
45/23 48/13 48/14
49/3 49/4 50/24 52/4
52/19 63/13 83/12
90/5 90/12 107/15
109/1 109/13 112/1
112/12 112/19 139/12)
153/10 154/9 157/13
160/23 168/15 178/1
178/9 178/12 190/14
202/6 202/17
evidential [1] 12/2
evidently [2] 197/15
200/15
exactly [3] 46/2
83/22 85/11
examine [2] 196/24
198/17
example [17] 6/22
35/7 44/18 98/13
100/13 111/14 170/22
173/3 183/3 185/21
187/21 187/23 204/6
205/1 205/12 206/14
207/21
examples [5] 169/25
172/7 204/11 204/15
205/11
Excel [2] 195/16
198/1
exception [2] 190/11
190/13
exchange [1] 164/4
exchanged [1]
115/25
excluded [1] 155/10
exclusive [1] 99/25
excuse [1] 190/11
executed [1] 176/15
execution [1] 167/2
Executive [1] 67/18
exercise [4] 111/6
137/18 139/9 205/13
exhaustive [1]
203/18
exhibited [3] 2/12
2/14 79/8
exhibits [1] 3/20
exist [5] 42/25 126/3
126/17 133/17 156/20)
existed [8] 8/1 94/6
130/7 133/12 135/16
135/19 136/19 160/3
existence [5] 34/5
98/15 132/24 139/20
145/23
existing [1] 176/11
exists [4] 94/14
129/15 132/4 133/10
expect [3] 119/25
125/9 141/18
expectation [1]
141/21
expected [1] 102/8
expensive [1] 32/14
experience [3] 5/23
7/1 8/22
expert [40] 23/20
24/15 24/20 24/22
37/11 37/15 37/19
39/5 39/7 39/11 39/14
39/16 39/22 40/8
40/10 42/5 43/22
45/20 45/21 45/23
46/5 46/7 48/14 48/17
49/3 49/4 49/4 49/8
49/23 109/3 111/3
151/7 151/18 161/13
161/24 162/10 164/1
202/17 203/5 205/10
expert's [2] 40/2
154/16
expertise [5] 110/23
111/19 201/11 204/5
204/25
experts [5] 37/12
110/13 146/24 147/13
161/20
explain [10] 69/6
92/7 108/25 118/11
122/12 138/21 143/25)
164/7 175/17 188/3
explained [3] 39/10
79/21 154/4
explanation [19] 44/4)
47/3 140/14 142/8
142/14 142/18 142/24
143/4 143/7 143/15
144/3 144/6 145/2
145/4 146/2 175/23
175/24 176/12 181/6
explicitly [2] 168/1
172/8
explore [1] 96/24
exploring [1] 52/23
export [1] 150/8
exposure [1] 24/11
express [4] 4/16 74/1
139/20 161/7
expressed [2] 43/22
113/7
expressly [1] 71/10
extension [1] 8/12
extent [3] 12/18
57/10 86/20
external [3] 37/11
37/15 188/20
externally [1] 96/6
extract [4] 19/11
131/21 155/6 155/21
extracted [1] 184/18
extraction [4] 160/7
179/9 181/8 184/4
extractions [3]
180/24 181/3 181/17
extracts [1] 151/23
extreme [1] 37/8
eye [2] 172/19
197/17
eyeball [1] 172/21
F
face [4] 61/22 61/22
80/7 177/20
faced [1] 4/10
facing [1] 22/11
fact [33] 19/9 22/20
26/10 34/10 38/25
39/19 43/10 45/8
84/12 92/22 103/6
106/18 112/9 130/17
133/16 134/10 135/25)
136/20 141/25 143/18)
144/14 144/21 144/25
145/8 148/22 158/16
177/11 177/21 187/7
188/6 192/9 194/2
202/19
factor [1] 57/13
facts [1] 10/23
factual [1] 52/23
factually [1] 184/12
failed [1] 15/16
fair [30] 8/13 8/25
70/24 71/8 96/10 98/2
101/12 109/5 116/12
125/25 139/3 139/4
139/23 140/12 141/23}
142/21 150/12 162/23
165/15 168/24 172/9
174/5 174/9 183/20
185/8 193/16 194/21
197/15 199/20 203/22}
fairly [6] 98/23
150/19 150/19 187/10
192/11 201/18
Falkirk [2] 125/21
131/15
fall [3] 154/17 156/7
186/23
falling [1] 159/25
false [4] 12/21 13/10
13/22 177/17
familiar [1] 120/14
familiarity [2] 57/11
57/14
family [1] 4/17
far [14] 7/14 14/10
61/5 81/16 87/19 94/5)
96/17 99/4 102/5
105/15 106/14 107/20
107/25 135/7
fascination [1] 64/18
fault [1] 157/7
faults [1] 32/14
favour [2] 30/5 31/19
favourable [3] 29/24
30/12 45/3
fear [1] 19/4
February [11] 1/19
28/21 29/5 29/21
31/14 32/4 42/14
42/22 151/5 151/14
153/13
fed [1] 183/22
fee [1] 15/19
feed [4] 112/11
112/13 202/5 205/4
feedback [1] 207/4
feedback/clarificatio
ns [1] 207/4
feel [3] 19/19 32/10
186/13
feeling [2] 70/22
71/10
feels [1] 75/6
felt [2] 63/21 71/24
fence [1] 70/13
few [5] 6/17 58/1
58/11 60/6 186/12
fiduciary [3] 75/5
75/9 75/10
field [3] 37/15 92/4
109/1
fielding [1] 109/22
figure [1] 160/4
figures [2] 196/25
198/18
file [14] 10/25 15/16
23/13 23/13 30/9
30/14 41/5 57/22
74/18 106/20 121/14
126/9 164/21 195/16
filenote [1] 45/13
film [1] 91/24
final [8] 72/14 89/24
97/17 101/5 156/10
184/1 184/23 208/25
finalised [1] 210/10
finally [4] 3/13
148/10 176/25 208/20)
Finance [1] 164/19
financial [3] 80/5
197/9 199/17
find [10] 7/3 37/19
48/21 63/22 88/7
131/12 133/19 140/9
141/2 192/8
finding [2] 178/18
178/20
finds [1] 134/9
fine [9] 5/15 81/11
84/22 89/12 89/19
152/25 191/21 195/25)
210/12
finesse [1] 70/8
finish [3] 41/25 52/2
208/12
finished [1] 52/4
fire [2] 1/10 10/3
firm [19] 6/21 6/23
7/13 8/20 16/17 18/8
18/22 19/11 20/10
25/9 25/21 25/22
32/25 34/22 35/13
37/16 37/25 80/4
189/1
(64) error... - firm
F
firm's [1] 26/22
firms [3] 7/23 38/6
38/10
first [61] 1/18 2/22
2/24 3/21 3/25 7/7
9/24 11/18 11/22
11/24 12/1 13/25
19/20 24/2 24/5 33/14}
40/1 41/19 56/3 56/6
56/17 56/19 56/21
58/11 59/9 59/12
59/14 59/17 88/5
98/15 99/1 103/9
104/2 108/1 115/15
118/6 131/4 131/5
135/15 140/1 141/14
142/11 143/16 143/20)
148/4 149/11 149/14
153/19 162/19 165/8
166/1 166/5 180/6
180/20 184/10 193/7
193/11 193/19 197/20
205/12 206/19
firstly [6] 6/1 122/24
147/2 154/4 176/16
189/18
Fiscal [1] 189/10
fit [1] 45/5
[2] 40/15 64/14
ing [1] 131/13
five [4] 22/10 87/9
105/10 170/2
fixed [10] 129/24
130/6 131/18 138/23
141/19 141/22 144/15)
144/23 145/12 147/1
ixes [1] 118/14
fixing [1] 175/22
flagging [1] 54/24
Fleckney [1] 181/16
flesh [4] 19/11
flexible [1] 52/8
floor [4] 127/18
flowing [1] 84/2
focus [5] 5/25 40/2
44/20 46/4 155/11
focused [2] 20/9 21/1
follow [7] 89/19
102/12 126/5 133/6
175/10 176/23 201/22)
follow-up [1] 175/10
followed [3] 84/10
163/15 181/18
following [14] 15/2
73/6 109/12 133/6
137/25 146/24 158/25}
162/8 163/1 173/14
176/22 189/18 207/12)
211/1
follows [7] 33/2
34/12 62/8 149/12
166/4 183/6 198/7
footprint [1] 10/15
forceful [1] 19/1
forcefully [1] 75/14
forefront [1] 88/20
forensic [2] 11/24
44/23
forgive [16] 125/13
127/20 131/4 131/23
142/23 143/2 143/6
143/12 145/6 152/16
162/7 163/1 178/6
184/2 184/4 190/13
form [5] 7/1 60/21
67/5 179/24 204/24
formal [7] 92/12
92/23 94/9 94/12
147/4 198/22 198/25
format [1] 184/8
formed [4] 68/20
69/14 75/1 155/13
forth [1] 127/22
Fortunately [1] 64/1
forward [11] 21/4
22/10 23/23 26/8 32/6
34/21 39/11 57/25
66/3 71/21 86/14
forwarded [1] 205/3
forwarding [1] 138/3
found [20] 42/11
42/22 43/23 45/8
46/11 118/4 125/10
125/13 127/5 134/17
135/13 140/16 140/20)
141/12 142/25 143/14)
164/5 164/6 170/22
181/12
four [5] 2/18 84/5
116/3 147/2 210/5
four hours [1] 116/3
fourth [4] 39/9
148/10 155/17 156/14)
Fourthly [1] 147/8
frames [1] 207/19
framework [3] 7/18
7/22 7/24
Fraser [5] 52/16
52/17 52/18 52/24
54/10
free [1] 84/2
free-flowing [1] 84/2
Freeths [1] 159/5
freezing [1] 44/19
frequently [2] 196/19
198/13
fresh [1] 88/6
Friday [2] 23/18 57/4
friend [1] 100/3
froing [1] 48/17
front [3] 1/21 1/22
91/4
frustrated [5] 63/3
63/6 63/11 65/12 68/8)
frustration [1] 63/14
FUJ [1] 134/14
FUJ00081836 [1]
205/23
FUJ00086758 [2]
151/12 153/8
FUJ00089798 [2]
175/6 178/4
FUJ00156902 [1]
106/23
FUJ00158114 [1]
113/24
FUJ00158115 [1]
116/7
FUJ00159985 [1]
144/8
FUJ00160063 [2]
147/22 149/10
FUJ00160508 [1]
180/9
FUJ00160649 [1]
183/1
FUJ00163098 [1]
197/19
FUJ00166835 [2]
158/14 160/5
FUJ00179541 [1]
206/17
FUJ00179779 [1]
125/12
FUJ00179940 [1]
134/22
FUJ00179952 [1]
141/13
FUJ00181400 [2]
146/19 149/13
FUJ00188147 [1]
168/12
FUJ00189522 [1]
196/9
FUJ00220950 [1]
12114
FUJ00222364 [1]
162/4
FUJ00222620 [2]
161/15 164/5
Fujitsu [75] 37/13
38/15 38/17 38/23
38/25 39/4 39/6 39/10)
39/11 39/15 39/19
39/21 40/23 41/3
41/11 44/5 92/3 92/14
93/1 93/12 99/10
101/7 101/24 105/2
109/4 110/15 111/4
112/3 112/10 112/20
112/23 113/12 113/15}
113/20 113/22 114/11
114/16 114/20 115/7
115/15 117/10 118/11
135/17 137/16 143/25]
146/11 157/25 160/16)
161/6 162/11 162/21
162/22 166/8 175/14
175/17 175/20 175/20
175/22 178/14 180/21
181/2 184/25 186/17
190/5 192/5 192/12
192/16 202/7 202/16
203/13 203/23 204/3
205/1 207/18 209/15
Fujitsu's [7] 40/1
112/1 117/7 130/23
185/5 185/18 201/2
fulfilled [4] 16/14
full [10] 1/13 14/14
19/23 19/24 20/1 24/6}
91/2 105/6 167/1
170/11
fully [5] 7/24 19/21
26/1 71/2 177/18
functionality [1]
166/7
fundamental [1]
204/21
funders [1] 86/23
further [32] 10/17
26/25 29/19 34/16
36/14 36/25 46/9
50/18 57/1 58/24
65/17 87/6 124/16
141/7 142/12 143/3
145/22 149/5 157/25
158/5 158/19 159/6
168/2 171/13 175/3
177/24 195/21 196/16}
198/8 199/8 200/17
210/13
G
Gareth [33] 103/1
104/4 105/9 106/1
106/15 107/10 107/19)
107/21 110/7 111/10
128/1 128/5 128/10
128/16 128/21 129/4
184/10 184/12 184/17
197/23 201/1 206/23
206/24 207/1 207/1
207/23 208/8 208/14
208/15 208/19 208/23
208/25 209/2
Gareths [2] 208/4
209/10
Garr [1] 200/8
Gas [1] 92/13
gathering [1] 188/13
gave [5] 83/20
111/23 124/3 124/13
146/2
GC [1] 62/2
general [7] 8/7 8/8
26/10 74/1 104/19
104/24 147/3
generalised [1]
182/15
generally [10] 13/23
13/25 27/24 37/20
41/3 98/8 115/16
116/25 172/25 186/17
generated [4] 12/7
12/22 13/6 164/20
generates [1] 92/11
generic [2] 40/4
40/10
genesis [1] 161/19
gentleman [1] 9/22
get [45] 20/4 20/14
24/2 25/8 25/11 25/22
26/19 33/11 34/19
34/20 35/1 35/25
38/24 39/18 39/21
40/15 46/1 46/3 47/13
49/2 57/16 58/3 59/20
60/15 63/1 63/4 63/22
66/14 67/21 68/15
68/21 68/25 77/2
81/22 82/10 82/15
83/2 83/5 83/23 85/5
86/11 132/5 132/10
175/18 190/21
gets [2] 23/15 122/6
getting [5] 20/5 55/20)
68/12 115/22 164/25
Gideon [2] 64/7 64/7
illian [1] 10/1
give [20] 1/15 1/20
18/17 39/5 48/9 84/4
105/6 106/10 112/1
136/11 143/6 144/13
152/17 172/12 186/1
190/18 196/18 197/20)
198/12 200/12
given [16] 12/4 20/20
46/20 47/5 51/6 57/19)
67/11 80/17 116/3
125/2 136/4 145/2
146/3 146/6 186/13
193/18
gives [2] 131/13
171/23
giving [4] 72/16
72/23 90/5 177/17
glaring [2] 48/10
48/12
GLO [18] 4/10 6/3
53/3 53/7 53/12 54/17
54/17 55/10 56/23
57/11 57/14 89/2
195/23 201/2 201/23
202/5 202/18 206/16
global [3] 7/13 7/17
8/3
go [66] 2/23 14/10
15/20 16/3 17/25
18/16 19/25 20/21
23/17 25/8 25/14
25/23 26/3 33/16 34/3I
34/19 37/4 42/8 46/7
46/23 47/6 57/25
61/15 65/17 68/17
68/18 69/16 70/3
70/14 71/21 71/23
7219 73/4 74/22 76/2
(65) firm's - go
G
go... [31] 82/2 82/8
83/1 83/4 85/2 85/2
87/18 122/12 136/24
137/2 137/7 152/15
155/1 176/7 178/4
183/1 193/7 195/21
196/10 197/18 197/20
199/8 200/13 205/11
206/14 206/16 206/20
206/21 207/11 208/8
208/18
God [2] 55/25 192/18
Godeseth [10] 105/9
106/2 110/5 112/12
168/16 169/14 170/3
202/9 206/2 210/7
Godeseth's [2]
206/19 209/14
goes [13] 16/17
32/15 37/9 40/4 74/12
107/8 115/20 150/2
174/9 181/6 182/2
193/18 197/10
going [72] 5/25 9/19
14/14 15/1 18/21
19/12 20/13 20/15
21/4 22/7 22/19 24/1
24/13 25/3 25/8 25/22
26/21 35/14 38/6 39/2
39/10 39/13 40/10
45/20 52/12 52/23
54/6 54/18 54/20
56/10 60/6 60/16
62/23 62/25 64/4 66/3
66/15 68/15 68/17
68/18 69/9 71/21 79/6}
82/16 82/17 83/1 83/3
83/4 83/4 86/2 86/13
87/15 91/20 96/21
104/21 127/21 133/8
134/18 139/5 139/11
148/24 172/22 179/1
190/24 191/6 193/7
195/14 196/11 204/11
204/16 205/22 206/13,
gone [7] 11/19 57/9
61/5 61/15 127/19
198/24 208/20
good [19] 1/3 1/4
41/18 44/7 51/2 51/20)
51/24 51/25 55/25
60/6 62/1 90/19 90/25)
131/17 153/5 175/24
199/16 210/9 210/24
got [29] 18/22 22/6
30/13 35/1 35/2 39/13,
39/17 41/9 41/22
44/10 51/6 55/25
57/18 59/19 63/1
63/13 64/2 65/22 70/7
70/8 85/15 86/15
118/23 120/1 123/4
128/25 130/19 137/9
208/10
Government [6] 66/5
66/14 67/19 67/23
68/23 68/24
government's [2]
66/11 76/16
Grab [1] 62/12
Grabiner [19] 58/4
61/5 62/14 62/18
62/21 74/25 75/14
78/25 79/1 79/7 79/11
79/21 80/7 80/18
83/19 83/20 83/21
84/4 84/8
Grabiner's [2] 79/4
80/10
grammatical [1]
141/20
grant [1] 175/4
granted [3] 99/3
100/8 105/5
grateful [4] 2/17 90/4
206/11 210/18
greater [2] 187/23
188/12
greatly [1] 115/25
Greg [1] 44/18
Gribben [3] 162/17
173/21 197/22
group [12] 52/15
53/21 53/23 88/3
88/22 108/22 111/12
161/5 179/6 188/19
188/22 189/16
guess [10] 9/8 9/8
111/7 122/14 132/21
132/22 133/13 143/18)
144/2 174/25
guessed [1] 106/19
guessing [1] 119/24
GUY [3] 90/23 91/3
212/8
H
habit [3] 59/6 64/20
67/13
habitual [1] 64/19
had [179] 2/14 4/13
4/14 4/15 6/12 7/13
8/3 8/21 9/12 9/16
9/19 10/15 11/12
12/16 13/12 13/21
14/14 14/15 14/16
15/23 18/20 20/7
20/10 21/14 24/8
24/17 26/11 26/15
31/21 31/22 33/9
33/14 34/22 39/15
40/19 42/4 44/14
46/11 48/6 48/14
48/24 49/2 49/7 49/8
50/9 54/5 54/16 54/20
55/4 58/7 59/9 59/18
60/7 61/5 61/15 62/20
64/23 68/4 68/25
71/23 71/24 72/17
73/13 74/14 75/9
75/16 77/22 78/11
78/16 79/1 86/19 88/7
88/23 89/17 93/23
94/5 98/23 99/14
100/3 100/5 100/12
100/17 100/18 101/22
105/16 108/10 109/18!
110/3 110/21 110/23
111/16 114/12 115/6
116/18 117/13 117/20
117/25 119/6 120/1
120/15 121/1 122/8
122/10 123/11 123/15}
123/16 124/14 125/2
127/4 127/17 129/5
130/7 130/9 130/21
133/14 133/16 135/8
136/4 136/13 136/14
136/20 137/17 140/19}
140/20 140/21 141/2
141/11 142/6 142/20
142/20 143/7 143/8
144/22 144/23 145/6
145/12 145/18 145/25)
146/6 146/11 148/19
155/2 155/23 157/14
159/22 160/20 161/6
162/22 163/6 173/5
173/9 173/11 174/2
174/5 174/13 175/21
175/22 176/5 177/2
177/10 177/10 177/11
177/12 178/22 179/22
179/24 180/2 183/22
186/20 187/14 187/25)
188/1 188/13 197/5
199/10 203/6 203/10
205/15 208/24
hadn't [9] 21/20
28/10 28/11 44/12
44/12 108/9 129/6
156/15 159/25
half [2] 110/3 113/25
halfway [1] 64/23
hammer [2] 25/14
25/15
hand [4] 30/24 31/4
33/14 33/18
handed [2] 87/1
144/4
handing [2] 187/1
187/12
handle [3] 20/25
102/21 104/2
handled [4] 15/8
20/17 137/11 146/11
handling [2] 12/15
21/7
hands [3] 20/2 36/2
51/12
hands-on [1] 20/2
handwritten [9] 2/13
58/8 58/12 77/2 79/9
81/17 81/24 84/3
84/16
Hanifa [1] 93/23
happen [3] 48/17
64/20 139/11
happened [10] 13/12
23/3 26/24 48/19
69/10 83/22 107/18
177/15 187/9 207/20
happening [1] 12/6
happens [5] 23/2
65/2 164/22 164/25
207/20
happy [4] 51/12
51/13 115/16 173/24
hard [7] 7/3 36/7
40/13 80/20 91/4
95/22 98/21
harsh [1] 69/24
has [63] 1/18 3/25
4/24 4/25 14/20 25/21
27/9 28/6 30/7 34/10
35/17 36/11 37/7 38/5
43/18 45/18 47/5
48/11 48/14 70/24
75/1 75/4 75/5 80/3
81/16 87/8 87/9 99/21
101/14 101/16 101/17,
101/20 107/10 117/10}
131/16 134/10 134/17)
135/3 135/4 138/9
138/12 138/14 143/25]
151/20 156/10 156/18}
159/20 166/9 166/16
169/15 171/11 173/24
177/1 184/9 187/22
187/23 193/24 195/16}
196/23 207/3 207/6
207/9 208/15
hasn't [3] 123/24
158/1 170/25
have [320]
haven't [4] 118/4
120/6 136/1 173/17
having [13] 17/20
19/12 38/14 88/17
96/8 129/8 129/14
136/5 147/13 154/17
170/16 170/17 200/9
Hayward [1] 42/4
Haywood [2] 175/11
175/12
he [144] 4/17 8/9
15/13 16/5 16/5 16/8
16/14 25/13 30/16
49/6 49/7 49/8 51/8
53/14 53/16 54/1
61/15 61/18 64/10
67/18 70/9 74/15 75/4,
75/6 104/6 104/6
104/8 104/9 107/8
107/22 108/9 108/19
109/17 109/20 109/23)
110/6 110/6 111/7
111/18 112/9 112/11
115/20 117/25 118/23}
119/2 119/25 123/11
123/24 124/5 124/11
124/12 129/5 1314/7
131/13 131/16 131/19}
132/17 132/20 132/23)
132/23 134/7 134/8
134/9 134/9 134/10
134/12 134/17 134/24)
135/3 135/3 135/4
137/19 137/21 138/9
139/9 140/2 140/14
140/20 140/22 141/16)
141/24 141/25 142/8
142/14 142/15 142/25)
145/17 149/24 150/2
150/13 150/14 151/21
166/2 166/5 166/12
167/5 167/22 167/25
170/10 170/22 171/3
171/18 171/19 171/21
171/23 171/25 172/7
172/11 172/22 173/1
173/2 173/24 173/24
175/9 175/13 175/13
175/15 184/20 185/12)
185/19 185/22 185/23}
185/24 186/3 186/7
186/19 187/1 187/1
187/9 187/11 187/11
196/13 196/17 196/21
197/10 198/24 199/6
201/10 201/20 201/20)
201/21 205/3 207/3
208/23
he'd [2] 140/20 145/7
he's [30] 30/7 30/11
51/10 55/25 112/4
112/13 112/14 113/22)
134/16 141/4 141/24
141/24 142/1 142/9
143/3 143/6 143/13
150/21 167/7 167/16
167/18 167/22 167/23)
168/1 170/22 171/6
171/9 173/8 174/21
185/11
head [3] 71/21 168/4
186/2
header [1] 198/11
heading [2] 162/6
196/16
hear [4] 54/21 90/19
153/5 193/5
heard [13] 8/6 23/11
30/7 32/2 37/25 54/16
54/20 61/5 79/11 90/7I
98/17 120/7 189/3
hearing [6] 1/5 23/9
23/10 23/14 23/14
(66) go... - hearing
H
hearing... [1] 211/1
Heckford [4] 16/10
16/11 16/12 24/4
held [16] 35/24 35/25
95/12 102/13 103/17
103/20 106/15 107/22
113/3 113/12 114/19
115/7 115/14 127/23
181/17 182/9
Helen [2] 22/4 29/25
help [6] 65/21 106/22
110/12 111/17 115/25}
201/6
helpful [3] 74/24
114/20 146/5
helpfully [1] 75/24
helping [3] 137/17
178/19 206/13
helpline [2] 190/6
192/5
hence [5] 4/16 57/7
72/7 80/4 139/6
her [11] 13/9 17/2
18/25 19/11 20/23
32/16 32/24 58/7 60/1
86/3 153/18
Herbert [3] 37/25
38/13 38/19
here [58] 3/14 10/5
12/9 13/14 18/12
18/21 20/13 22/7 24/1
24/14 24/20 26/18
30/11 33/10 33/23
34/20 35/12 38/24
39/17 40/8 40/16 46/4,
62/23 66/8 73/16
76/24 86/2 95/10
100/24 101/11 103/7
110/19 111/9 114/1
117/4 119/17 123/3
133/23 138/25 139/20}
143/2 145/8 150/10
152/2 156/23 157/22
160/9 167/4 169/5
1747 177/17 183/3
183/3 186/11 196/10
209/5 209/8 209/13
herself [1] 78/1
hesitancy [1] 63/15
hesitate [1] 53/9
hide [1] 146/8
high [8] 46/20 50/7
78/6 78/15 78/17
85/16 103/25 109/21
high-level [1] 103/25
higher [1] 98/12
highlighted [6]
115/18 116/18 116/23
116/23 194/9 207/8
highly [2] 75/3
194/25
him [29] 37/4 56/17
104/8 108/5 108/6
108/8 108/11 108/18
119/5 123/21 128/18
129/9 133/9 140/22
151/18 164/7 167/15
167/20 168/2 174/11
174/11 175/1 186/23
187/9 187/11 188/8
200/9 201/18 201/21
himself [2] 56/5
202/5
hindsight [4] 39/6
39/8 63/10 187/20
his [49] 4/17 8/9 11/2
13/9 30/9 30/11 30/14
30/21 30/22 33/18
40/17 43/22 49/7 54/5
66/1 74/15 79/21 84/5)
106/16 106/16 107/10)
107/11 109/15 111/19}
111/21 112/4 112/14
116/19 119/4 133/2
137/15 140/20 141/21
142/10 145/3 145/16
145/17 150/16 150/23)
151/20 161/25 167/23)
1714/3 171/22 174/2
201/10 201/16 208/15
209/22
historic [18] 99/9
121/1 121/16 121/20
122/10 123/4 123/7
123/12 124/1 136/5
136/13 136/21 137/4
155/14 156/15 156/17,
156/21 156/23
historical [2] 52/17
107/13
history [2] 44/16
196/2
hits [1] 140/19
hm [16] 93/7 97/1
97/1 107/4 123/1
124/9 140/8 143/5
157/11 163/20 170/1
170/6 171/12 180/15
181/10 198/10
HNG [7] 108/4
114/13 129/2 130/20
138/24 150/1 167/17
HNG-X [7] 108/4
114/13 129/2 130/20
138/24 150/1 167/17
Hodge [6] 52/5 90/7
90/24 91/1 192/1
212/10
Hoggard [1] 24/17
hold [4] 106/19
162/21 162/21 194/7
holds [3] 123/2 123/7
157/25
Hollingsworth [1]
22/5
Holmes [3] 206/23
207/23 208/2
Holmes' [1] 208/6
honest [7] 14/1 98/24I
132/19 133/2 145/24
146/4 146/7
hope [3] 25/4 174/8
191/4
hoping [1] 145/22
Horizon [81] 4/21
11/16 12/2 12/4 12/8
12/17 12/22 13/7
13/11 13/18 18/4
19/17 20/18 20/22
20/24 27/9 27/11
27/24 28/17 30/18
31/5 31/17 31/17
31/22 32/1 32/12
32/24 33/5 33/18
34/15 37/20 38/4 40/6
40/11 41/3 42/10
42/12 42/18 43/10
43/13 45/2 47/17 50/1
50/6 50/10 50/20
54/13 56/24 57/3 57/5
63/2 102/22 108/3
109/8 111/20 113/2
114/12 114/16 118/12]
122/18 124/7 124/7
129/2 130/1 130/18
135/2 135/10 135/16
138/23 149/25 150/1
160/16 165/12 166/7
181/1 181/5 181/7
181/17 182/16 194/4
201/11
Horizon IT [1] 41/3
hour [2] 57/24
134/23
hours [1] 116/3
house [1] 8/12
household [1] 6/15
how [53] 8/13 14/1
17/2 20/24 35/25 36/4
38/3 41/22 45/23
54/17 62/24 65/21
69/13 74/16 80/20
85/22 86/1 88/6 88/24
94/5 98/7 98/11
105/11 105/18 110/15}
118/11 124/10 133/11
137/11 139/13 140/5
142/25 143/14 145/15
145/17 146/11 149/6
149/16 160/3 162/14
162/22 163/10 172/7
173/9 177/12 187/25
190/24 195/4 196/19
197/18 198/13 208/12
209/18
however [9] 4/23
32/16 37/14 115/23
125/22 131/12 144/19]
150/3 176/16
HSD [1] 114/15
huge [7] 35/24 48/10
48/14 48/24 49/13
49/15 55/1
Hugh [5] 18/2 18/8
20/17 37/25 38/19
hypotheticals [1]
13/14
laccept [1] 185/22
l actually [3] 107/17
118/2 206/9
ladded [1] 107/24
l agree [5] 23/25
45/13 50/15 143/24
168/1
l already [1] 104/6
lalso [1] 191/11
lam [11] 7/14 70/21
72/5 79/6 82/6 87/15
96/17 98/10 129/18
145/24 181/2
l anticipate [1] 52/1
I appreciate [2]
28/14 114/17
lask [12] 1/21 2/6
4/2 72/17 89/8 91/1
91/10 115/15 115/23
188/23 191/25 200/25
lasked [1] 125/20
lassume [9] 27/8
27/16 64/25 67/2 84/9)
124/15 147/10 184/20}
209/20
I been [1] 4/15
I began [1] 59/21
I believe [37] 6/12
7/25 11/14 14/18
14/24 15/1 16/12
24/18 31/25 40/18
67/17 67/20 77/23
99/20 109/18 112/8
113/17 125/4 126/20
128/2 129/1 138/1
144/6 151/4 154/15
154/25 155/16 158/13}
160/4 162/2 163/24
165/10 179/18 186/9
203/15 206/9 206/9
I believed [1] 4/21
Ican [17] 18/16
25/25 35/18 55/19
55/21 59/12 86/14
90/20 132/11 134/15
141/4 152/20 191/15
192/21 193/6 206/22
208/12
Ican't [15] 6/23 7/20
7/25 8/18 8/22 17/3
31/6 64/20 89/5 100/9I
102/15 105/21 180/6
187/2 187/5
I cannot [2] 7/12 71/6
I check [1] 54/9
I clearly [1] 41/9
I come [1] 204/15
I commented [1]
116/21
I considered [1]
139/6
I consulted [1]
116/17
I copied [1] 37/6
I could [7] 1/25 26/22!
87/17 118/20 119/24
145/14 191/12
I couldn't [1] 186/1
I cover [1] 41/12
I did [16] 6/24 9/2
18/24 41/5 57/13
74/18 83/9 83/11
104/19 114/25 123/9
133/5 178/17 178/24
179/2 196/6
I didn't [13] 19/7 50/7
50/22 68/25 98/24
108/19 116/25 130/13}
179/10 180/4 186/7
186/19 192/12
Ido [7] 47/3 94/11
151/9 158/9 178/6
180/5 192/18
I don't [113] 9/2 11/8
12/6 13/13 14/1 14/9
18/20 19/13 21/9
23/13 23/15 23/16
25/3 25/4 25/5 30/20
32/9 34/2 36/21 40/12
40/15 41/10 47/22
50/2 50/22 50/22
51/14 55/24 55/24
56/7 57/13 60/13
60/18 61/15 63/19
63/19 64/9 64/10
65/16 71/2 71/5 73/24
74/17 75/16 76/8
76/20 79/11 80/20
80/20 80/23 80/23
83/9 83/11 83/16 84/7
84/13 85/15 86/5 86/6
88/12 88/21 89/5 89/7I
100/23 105/6 106/8
106/18 107/18 107/23}
108/10 111/20 114/24}
114/25 117/21 119/2
120/3 120/4 120/13
126/12 128/11 130/25]
133/1 133/5 133/22
134/17 136/22 137/8
139/19 145/24 150/14)
165/16 165/24 168/4
174/15 174/16 174/18)
178/24 179/4 181/22
181/25 186/16 186/25}
187/7 187/8 188/6
189/4 189/7 189/12
189/23 192/12 201/25)
210/1 210/22
(67) hearing... - I don't
I doubt [1] 48/1
I drop [4] 9/10
lever [4] 40/14 40/15
41/10 86/6
lexpect [1] 125/9
l explain [1] 188/3
I feel [1] 19/19
I felt [1] 63/21
I find [1] 7/3
I follow [1] 89/19
I found [1] 135/13
Igo [2] 122/12
136/24
I got [2] 57/18 86/15
I guess [6] 111/7
122/14 132/22 143/18}
144/2 174/25
Thad [13] 4/13 4/14
10/15 18/20 21/14
54/5 54/20 89/17
98/23 110/21 127/17
133/14 145/18
I hadn't [2] 28/10
28/11
Ihave [35] 1/23 2/7
21/19 32/5 37/10
39/13 44/4 52/4 57/19
64/18 70/5 72/21
73/25 87/1 90/7 93/18
115/12 117/18 120/2
125/22 131/9 131/12
135/1 150/8 152/19
175/16 178/7 180/21
180/24 188/16 189/12)
190/7 191/1 191/4
210/1
I haven't [1] 120/6
I hope [2] 25/4 191/4
linserted [2] 181/25
183/24
interrupted [1]
187/4
Ijust [12] 8/1 25/6
51/1 63/22 71/7 81/11
88/21 100/4 126/24
146/7 174/19 201/19
I knew [10] 18/25
48/10 58/1 71/7 98/22)
104/9 106/18 116/20
135/11 201/18
I know [13] 20/9
23/21 31/20 49/13
57/25 72/6 72/7 75/13,
78/22 102/5 108/6
120/13 149/20
Hook [2] 116/16
186/10
I make [2] 51/4
152/19
I may [17] 5/4 7/20
7/20 69/19 69/19 87/2
106/18 123/9 125/6
127/19 130/15 152/16)
180/4 188/18 189/3
201/3 205/12
I mean [75] 20/8
25/21 30/7 50/7 54/5
72/1 77/8 82/14 83/14
85/11 97/14 98/8
98/22 100/6 102/15
103/10 104/6 106/18
108/17 110/18 112/13)
116/15 119/23 120/1
120/6 128/15 128/25
129/7 130/12 130/15
130/16 132/19 133/4
135/11 135/13 136/8
136/22 139/4 141/4
142/6 143/18 143/21
145/4 145/16 145/24
146/4 146/6 150/13
150/14 150/18 152/11
157/18 158/12 172/25)
174/15 179/2 179/13
180/5 185/25 186/16
186/25 187/5 188/15
192/12 193/19 194/4
194/14 194/18 199/4
199/21 200/3 201/18
201/19 205/7 209/20
I mentioned [3]
101/19 105/23 209/9
I might [3] 77/2
108/17 196/6
I must [8] 61/7 71/5
114/24 174/15 179/10)
183/23 199/3 209/17
Ineed [1] 82/15
lokay [1] 124/2
lonly [1] 36/21
I paraphrased [1]
201/13
I pause [1] 122/19
I probably [7] 8/17
24/9 68/4 98/17
123/19 140/21 194/18)
I produced [2] 81/17
181/19
I propose [1] 1/11
I raised [1] 62/4
lreached [1] 192/13
lread [2] 23/14
116/22
I really [2] 86/16 89/6
I recall [8] 106/14
107/25 150/18 169/12)
186/25 190/8 200/19
204/6
I remember [4] 63/3
63/6 103/9 114/25
I said [3] 18/24
133/13 194/5
I saw [4] 116/21
I say [12] 11/17 12/13}
24/7 50/15 100/20
107/23 113/5 117/21
118/22 152/9 187/5
204/20
I see [9] 41/5 51/11
63/12 77/10 98/8
116/16 186/9 194/23
208/23
I sent [2] 24/4 126/8
I share [1] 138/16
I shortcut [1] 210/6
I should [4] 1/9 33/5
58/19 81/22
I shouldn't [1] 210/21
I simply [3] 48/18
63/3 74/18
Isit [1] 66/8
I spoke [1] 17/9
I spotted [1] 116/19
I still [1] 83/1
I submitted [1] 4/12
I suggest [2] 206/15
209/4
I suppose [12] 30/20
60/23 69/1 69/2
104/19 111/6 128/25
129/5 138/21 165/19
177/23 188/7
I suspect [15] 7/4 7/5
8/19 23/25 47/22
59/21 66/2 76/8 76/9
77/5 98/17 112/2
112/5 119/23 125/6
I take [3] 41/12 55/4
62/8
I then [3] 102/17
178/25 206/14
I think [244]
I thought [6] 19/5
44/2 59/14 70/6 78/24
146/4
I told [4] 144/7
I took [1] 123/10
I turned [1] 68/4
l understand [14]
2/17 2/23 3/10 3/16
4/3 7/18 19/9 22/13
43/18 51/10 72/24
73/5 82/21 164/22
I understood [2]
55/10 98/21
I undertook [1]
181/17
l uploaded [1] 123/22)
I vaguely [1] 189/3
I want [20] 6/4 9/24
14/19 24/6 24/7 52/11
58/5 58/8 69/12 75/15
76/2 79/12 81/20
83/17 85/16 85/24
122/22 184/17 193/11
201/1
I wanted [1] 63/7
Iwas [41] 4/16 4/19
4/21 8/19 11/6 26/21
53/18 53/25 53/25
54/20 56/7 57/15
59/19 88/15 93/11
100/16 105/13 105/20}
106/8 106/9 107/17
111/13 111/20 113/4
120/13 128/16 128/18}
129/8 130/14 133/22
133/22 139/5 145/2
146/4 148/24 179/15
180/7 190/9 195/14
197/25 198/3
I wasn't [11] 8/23
84/12 98/25 104/19
112/8 113/6 120/14
133/23 179/2 192/8
192/10
I were [1] 84/9
Iwill [17] 9/8 9/16
19/22 20/9 46/18
46/21 50/23 52/11
66/13 68/3 80/15
83/15 87/6 88/9
126/12 132/11 134/15}
I wonder [2] 152/18
162/3
I worked [1] 92/12
I would [34] 8/21
9/18 20/1 35/10 41/4
41/8 41/16 44/25 48/1
65/16 74/19 80/20
97/22 100/7 103/12
108/10 108/18 110/25}
111/2 112/15 112/22
118/22 119/25 127/5
127/7 128/20 130/25
133/13 141/18 145/25)
179/5 183/23 191/14
199/22
I wouldn't [2] 22/1
133/4
I write [1] 36/14
I wrote [1] 139/5
I'd [16] 4/5 4/11 4/13
5/3 48/23 94/18 100/6)
104/8 105/6 108/21
116/25 123/23 132/20
161/2 181/11 195/3
Ml [14] 1/20 2/21 5/13)
52/17 59/12 75/23
100/23 138/17 178/7
188/18 200/12 205/11
208/11 208/13
I'm [133] 3/13 4/8 5/1
5/2 5/25 7/5 12/24
12/24 14/2 16/13 23/2)
23/2 25/3 25/7 25/22
28/1 30/22 39/1 39/2
44/21 51/12 51/12
52/7 52/12 52/22 54/7,
56/10 56/17 56/18
60/24 62/24 62/24
62/24 64/4 64/22
65/12 67/13 69/9 70/4
70/4 74/19 76/8 78/12
82/22 87/10 89/1
89/24 90/4 91/20
94/11 94/13 96/15
96/21 97/13 98/12
99/8 100/2 100/6
100/20 103/8 103/22
105/13 108/3 111/13
112/4 112/8 112/15
112/16 116/24 116/25]
119/23 123/5 123/9
125/6 129/7 130/12
132/19 132/19 133/24)
136/7 136/18 139/11
142/23 143/2 143/9
145/4 145/5 145/6
145/14 145/16 145/18)
150/13 150/23 151/9
152/10 156/22 158/2
164/25 165/18 165/18)
166/23 167/24 170/12
174/10 174/10 174/10)
174/11 174/17 174/25)
175/1 177/14 178/25
179/15 180/18 183/17)
185/25 187/10 187/16)
188/8 190/17 192/9
193/7 195/14 195/22
196/6 199/3 204/7
204/11 205/22 206/11
209/17 209/18 210/18)
I've [27] 12/13 25/25
36/23 39/17 41/9
50/11 56/21 59/19
63/13 64/11 70/6
72/21 76/13 78/15
78/15 86/6 87/19
99/20 101/20 120/4
130/12 164/17 185/4
188/17 189/3 208/10
208/20
lan [3] 37/25 38/13
38/19
Ibbett [9] 137/14
137/16 138/4 169/13
170/3 176/5 188/7
205/25 206/25
idea [5] 56/14 64/11
72/21 72/21 98/23
identical [1] 170/19
identified [10] 105/24)
138/9 140/5 163/12
202/22 203/10 203/16I
204/11 204/12 205/15
identify [6] 38/16
94/2 109/7 161/21
163/22 165/6
ie [4] 32/14 32/21
42/25 150/6
ie if [4] 150/6
ie it [1] 32/21
ie that [2] 32/14
42/25
if [213]
immediate [2] 46/6
(68) I doubt - immediate
immediate... [1]
202/19
immediately [5]
134/6 136/7 137/5
140/24 178/3
imminence [1] 46/21
impact [4] 14/5 80/5
197/9 199/17
impartiality [1] 55/5
impediment [5]
57/15 57/17 57/24
63/12 88/14
implement [1]
109/23
implementation [3]
103/13 103/14 199/15}
implemented [1]
118/15
implementing [2]
47/18 197/7
implication [2]
156/18 174/21
imply [1] 186/19
important [4] 20/20
25/9 92/17 200/15
impossible [1] 204/3
impression [12] 60/9
60/14 60/19 60/22
65/14 66/8 78/19 83/6
83/24 84/4 86/15
186/3
improper [1] 182/4
improved [2] 30/9
30/14
inability [4] 62/4
inaccurate [1] 182/4
incident [4] 97/4 98/5I
98/13 172/4
incidents [7] 98/6
98/8 98/10 98/12
99/15 197/4 199/9
include [3] 52/19
79/16 142/17
included [7] 56/10
69/18 126/8 144/16
150/22 155/11 185/11
includes [3] 124/11
126/10 165/20
including [7] 19/22
91/7 127/25 163/11
186/10 197/23 203/24
inconsistency [2]
72/1 72/5
inconsistent [2] 72/4
139/21
incorp [1] 3/9
incorrect [7] 50/14
100/14 116/20 120/3
120/4 136/6 141/5
incorrectly [2] 120/8
176/20
incumbent [1] 50/17
indeed [9] 69/10
129/12 138/16 171/2
176/19 194/20 202/22)
203/12 204/2
independent [13]
39/7 39/14 39/22
39/24 40/2 40/8 40/10
57/16 57/23 58/3
63/23 72/6 78/23
index [1] 91/8
indicate [3] 42/25
148/2 163/16
indicated [1] 184/24
indicating [2] 52/8
162/21
indication [4] 42/11
47/5 196/18 198/13
indications [3] 42/9
43/23 47/8
indicative [2] 187/7
206/15
indirectly [2] 113/4
113/5
individual [5] 8/4
67/8 98/10 169/2
170/16
individuals [12]
38/17 38/20 109/7
109/13 110/9 111/23
202/6 202/15 202/24
203/16 205/18 209/6
inevitable [2] 72/10
86/13
inflated [1] 34/25
info [1] 124/3
inform [1] 114/8
information [79] 4/24)
12/20 13/17 34/16
34/18 34/19 38/15
38/18 39/21 42/13
44/8 46/1 46/3 67/11
70/5 74/19 79/2 88/9
89/5 94/10 109/1
109/8 110/10 110/13
110/16 111/17 112/11
117/10 117/22 118/10}
118/16 118/19 118/24}
119/10 119/20 119/22)
120/1 124/6 125/21
126/2 126/10 126/13
135/4 135/9 137/22
139/16 139/21 141/2
146/3 148/19 150/6
157/6 157/12 161/3
161/12 161/20 161/25)
162/3 163/25 164/9
165/2 178/18 178/20
178/25 180/23 181/4
181/15 181/20 181/24)
182/3 182/9 183/18
183/22 185/7 188/12
188/14 201/7 201/20
202/6
informed [3] 19/21
112/25 201/22
initial [7] 42/12 42/20
44/11 69/20 126/5
131/6 182/18
initially [5] 15/8 43/3
93/4 124/21 126/6
injected [2] 196/19
198/14
ink [2] 59/13 78/10
input [3] 178/22
202/17 207/22
inputs [1] 44/8
inquiry [25] 1/15 1/17
2/16 3/24 4/13 4/25
5/8 8/6 11/7 14/20
28/4 28/6 28/11 30/7
35/17 36/22 41/4
50/20 56/20 58/16
81/16 90/5 91/2
187/23 192/20
insert [3] 161/6
162/12 167/9
inserted [9] 153/14
162/22 180/17 181/20
181/24 181/25 183/24
196/4 198/14
insight [3] 58/25 59/1
61/11
insofar [2] 3/4 52/21
instances [2] 170/5
171/15
instead [4] 108/20
159/17 176/20 176/22
instruct [6] 45/21
63/5 63/7 63/14 63/22
78/25
instructed [5] 11/11
15/5 37/19 42/5 49/9
instructing [4] 59/24
62/18 63/4 143/6
instruction [5] 57/17
62/21 142/12 189/17
205/24
instructions [10]
4/22 33/1 34/11 69/14
82/6 97/7 97/11 97/13
97/19 97/22
integrity [21] 19/16
28/17 40/11 43/13
44/5 50/5 50/21
102/22 103/1 104/12
104/14 105/1 105/5
106/5 107/8 108/2
108/4 126/25 182/16
193/13 194/9
intellectual [1]
185/18
intellectually [1]
11/19
intended [1] 25/1
intense [1] 58/1
intention [1] 133/2
interact [2] 18/24
59/21
interacted [1] 86/16
interaction [2] 38/9
187/24
interchangeably [1]
5/13
interconnection [2]
61/2 71/17
interest [4] 67/19
130/4 145/25 146/7
interested [2] 60/4
200/13
interests [3] 75/6
80/14 80/22
internal [10] 16/12
20/13 45/13 55/1
92/25 95/25 97/18
101/23 113/20 130/23}
internally [3] 32/10
102/17 114/13
interpret [1] 132/21
interpretation [1]
121/21
interrelationship [1]
88/18
interrogation [1]
172/3
interrupt [1] 186/7
interrupted [1] 187/4
intertwined [2] 60/25
61/1
intervening [2] 9/4
57/4
interview [1] 11/2
into [52] 1/19 11/19
12/16 15/1 15/20
17/22 19/4 31/6 34/10}
37/6 44/8 44/15 45/12,
46/9 46/11 62/19
65/12 71/23 80/22
96/18 107/19 129/1
130/20 138/7 144/12
145/22 147/17 153/15)
154/7 154/17 154/21
155/9 159/25 161/7
162/23 167/9 176/9
177/12 17715 177/16
178/22 179/1 183/16
183/24 185/6 185/22
185/23 186/8 196/1
196/4 198/5 202/17
introduction [1]
156/6
investigate [4] 42/23
50/18 63/16 105/3
investigated [2] 60/7
192/11
investigating [2]
60/11 186/1
investigation [2]
11/24 188/12
investigations [1]
104/20
investigators [1]
10/24
invite [1] 45/20
inviting [2] 70/1 70/4
involve [1] 28/16
involved [25] 6/6 9/1
21/7 25/12 32/7 37/18
40/19 40/22 41/2
53/11 53/13 56/18
66/14 68/25 98/25
101/1 112/8 174/18
179/3 185/12 185/19
186/3 188/5 190/7
190/9
involvement [7]
15/24 24/3 24/18 53/4)
62/24 66/11 108/22
involves [2] 92/23
168/20
involving [1] 185/17
irrespective [1] 35/8
irretrievable [2]
133/21 156/8
irritation [1] 20/12
is [556]
is/was [1] 129/18
ish [4] 191/10
isn't [20] 26/9 43/14
55/24 59/7 69/3 82/4
84/21 98/4 125/5
136/9 142/22 143/10
143/16 158/12 158/16
159/23 169/25 173/3
199/22 207/21
issue [46] 32/22 34/4
43/13 44/19 44/22
44/22 44/22 47/14
50/9 50/18 53/19 56/4I
56/4 58/22 62/4 66/5
66/12 72/16 72/23
82/20 87/8 88/18
97/15 103/10 105/4
129/2 129/2 129/15
129/19 129/23 130/18}
137/11 138/10 144/15)
144/23 161/10 162/6
168/5 171/4 174/9
174/24 175/18 175/23}
176/18 195/7 200/10
issued [7] 15/11 18/3
31/21 33/8 33/10
33/11 34/25
issues [50] 30/18
31/5 31/17 31/17
32/18 40/3 40/4 44/17
48/18 49/23 52/15
52/19 54/11 54/13
54/18 54/24 55/2
55/11 55/17 56/24
57/2 57/5 60/16 61/1
61/3 63/2 71/18 79/12I
80/1 85/23 86/2 86/12
90/4 100/24 101/7
103/7 107/22 108/2
110/23 112/14 118/12)
135/24 147/1 160/16
(69) immediate... - issues
issues... [6] 164/15
185/17 195/10 203/2
204/8 205/8
issuing [1] 20/21
it [657]
it'll [2] 29/8 58/20
it's [129] 2/22 7/3 9/8
10/9 10/10 10/18
14/20 16/2 17/25
18/16 20/8 23/23 24/8
26/10 27/10 28/6
29/10 34/21 36/7
36/22 40/13 40/17
44/24 47/16 47/16
47/19 51/15 55/9 59/5)
59/5 63/11 68/17 69/2
69/13 70/9 72/10
72/13 74/18 76/19
76/21 77/3 77/8 78/14,
82/22 82/23 84/24
85/11 89/14 92/9
92/17 93/20 94/13
94/14 95/18 98/4
98/21 99/12 100/23
100/24 102/9 102/16
105/7 107/15 114/2
117/23 117/25 118/22)
120/3 120/7 126/18
126/18 127/14 127/15
129/5 134/18 135/14
139/10 139/11 141/6
141/9 143/10 143/18
143/22 143/23 143/24
144/10 145/20 146/7
150/23 152/25 153/13}
157/7 158/9 158/15
158/25 163/21 164/7
165/19 167/23 167/24}
170/17 170/18 170/21
171124 174/17 175/7
177/8 178/17 179/14
180/6 180/14 182/11
183/1 183/13 184/20
186/18 186/18 186/19
187/15 190/18 190/20}
194/4 194/11 196/8
196/13 198/2 198/3
205/23 206/17
items [1] 205/8
iterations [2] 157/2
157/4
iterative [1] 195/5
its [10] 4/13 7/23
12/9 56/17 68/24
78/17 100/1 158/23
169/18 204/4
itself [5] 7/2 85/20
86/4 98/14 99/17
J
J10 [4] 162/16
J11 [4] 162/16
J14 [1] 163/16
J15 [1] 163/16
J9 [1] 162/16
James [7] 18/2 18/8
20/17 37/25 38/20
105/8 106/24
Jane [56] 8/8 58/6
58/23 59/9 59/18
59/22 60/1 60/10
60/22 61/7 62/2 64/4
64/5 66/2 66/9 66/13
66/23 67/12 67/25
68/6 69/9 70/11 72/6
72/18 73/13 73/16
75/22 76/10 77/1 77/1
77/5 77/6 77/6 77/19
77/9 77/10 77/13
77/21 78/1 78/7 78/12
78/14 78/16 78/18
78/19 79/17 82/3 82/4
82/12 82/19 82/23
83/7 85/2 85/9 86/3
86/15
Jane's [2] 69/19 86/7
January [8] 26/13
33/8 42/14 42/21
168/5 171/25 196/12
197/22
Jason [6] 151/17
179/23 182/1 203/5
204/9 204/12
Jay [9] 112/3 113/19
113/20 114/3 117/17
121/7 125/17 185/5
186/15
Jenkins [25] 103/1
105/9 106/1 106/15
107/21 108/2 109/14
110/7 111/10 112/6
128/1 128/10 184/18
193/13 197/23 201/1
201/23 202/2 202/4
203/22 206/2 206/24
208/9 208/15 208/19
Jenkins’ [2] 104/4
201/5
Jennison [1] 24/16
jiggle [1] 51/16
job [1] 109/15
jobs [1] 188/6
jocular [1] 25/4
John [39] 22/4 29/24
37/10 99/21 110/1
120/22 123/10 123/17)
123/22 125/7 127/7
127/12 127/17 129/14)
129/17 131/6 132/2
132/9 136/14 137/24
138/8 138/14 138/22
140/6 140/19 141/2
141/11 141/15 145/2
145/15 147/14 148/20)
149/13 149/15 149/16)
150/11 202/20 205/3
206/1
John' [4] 140/7
John's [2] 137/25
138/3
joined [3] 5/6 38/13
93/1
joining [2] 92/3 98/17]
joint [1] 40/18
Jonathan [3] 162/17
173/21 197/22
Jones [2] 22/4 29/24
Jonny [3] 173/18
173/20 174/17
jotting [1] 67/11
jottings [1] 77/8
journey [2] 11/22
61/9
JSimpkins338Q [2]
132/4 144/20
judge [7] 55/6 56/5
61/4 61/10 78/2 79/25
80/3
judgment [48] 15/23
17/11 18/4 18/23 20/4
20/5 20/10 20/14 21/1
21/20 21/25 22/17
23/10 23/22 23/23
24/24 25/8 25/13
25/24 26/4 26/13
26/20 26/24 27/6
27/23 28/1 34/22
52/20 52/20 52/25
54/11 54/19 54/25
54/25 55/11 55/17
55/20 57/8 60/16 61/1
61/3 71/19 80/2 85/6
85/21 85/23 86/2
86/11
judgments [3] 25/5
52/16 52/19
Julia [1] 187/12
Julian [1] 32/4
July [3] 14/23 102/11
126/8
jump [1] 120/12
June [2] 1/1 1/24
June 2024 [1] 1/1
just [122] 6/2 7/20
8/1 10/6 11/25 14/21
16/18 21/23 25/6
25/24 26/10 27/3 29/4
32/18 35/3 37/20 39/8
41/12 43/25 44/6 48/9
50/11 51/1 51/6 58/9
58/22 60/20 62/2 62/9
63/13 63/22 69/12
70/14 70/16 71/7
72/19 73/18 75/9 76/7,
81/11 81/24 84/24
87/1 87/2 87/7 88/21
89/9 89/24 91/20 94/8
97/10 100/4 100/23
104/8 105/13 106/22
109/10 110/17 113/7
115/9 116/3 116/10
117/4 117/9 120/3
120/7 125/11 125/13
126/24 132/12 132/14}
132/18 133/8 134/15
134/24 136/2 137/14
142/9 142/9 146/7
150/15 150/24 150/25
152/23 156/19 158/9
158/9 161/18 162/19
164/9 165/6 165/18
172/3 173/18 174/10
174/17 174/18 174/19}
179/14 180/16 180/19}
183/3 183/8 183/15
184/9 188/11 192/1
192/1 194/5 194/23
196/10 197/20 198/7
199/23 200/4 201/19
205/8 205/22 206/17
206/21 207/17 208/10)
Justice [6] 49/1
52/16 52/17 52/18
52/24 54/10
K
KC [3] 23/5 56/15
200/8
keep [6] 107/12
127/21 191/12 191/15]
197/17 206/13
keeping [1] 127/3
KEL [66] 118/9 119/8
119/13 120/17 121/2
121/16 121/20 121/22)
122/3 122/9 123/2
123/5 123/12 123/13
124/7 124/7 124/18
124/25 126/12 128/5
128/22 129/3 129/16
129/19 130/7 131/12
132/3 132/11 132/24
133/10 133/11 133/16}
134/11 134/16 135/7
138/8 138/11 138/14
138/16 138/17 138/23}
139/1 140/5 140/12
141/11 141/19 142/5
142/7 142/17 142/19
142/20 143/7 143/8
144/1 144/5 144/20
150/7 151/23 154/14
155/25 156/1 156/7
157/3 157/10 159/14
185/17
KELJSimpkins338Q
[4] 131/20
Kelly [4] 73/22
KELs [106] 97/25
98/9 117/23 120/14
121/23 121/24 121/25}
122/5 122/14 122/16
123/3 123/8 123/11
123/22 124/1 126/3
126/20 127/2 130/11
130/24 130/25 132/5
132/10 133/14 135/2
135/10 135/16 135/20}
136/1 136/6 136/13
136/19 136/21 137/4
138/13 138/18 138/20)
139/21 141/8 144/14
144/16 144/22 145/23)
146/8 146/12 146/15
146/23 146/25 147/9
147/11 147/18 148/11
148/14 148/17 148/22)
148/25 149/1 149/6
149/16 149/25 150/1
150/3 150/9 150/12
150/17 150/18 150/20)
150/20 151/2 151/20
152/4 152/10 152/14
153/23 154/2 154/5
154/16 154/18 154/20)
155/1 155/5 155/9
155/11 155/14 155/17)
156/2 156/5 156/6
156/10 156/12 156/12)
156/14 156/15 156/17I
156/19 156/19 156/20)
156/22 159/1 159/22
159/25 160/3 160/7
160/10 160/15 203/1
Kent [1] 91/25
kept [3] 19/21 58/25
92/20
key [6] 38/16 95/2
95/12 96/14 96/24
98/3
kind [27] 49/23 55/18
55/19 56/1 69/1 74/19
99/12 109/20 109/21
109/24 109/24 110/2
110/3 110/19 111/8
128/7 128/20 142/9
152/12 167/23 172/2
172/5 173/2 188/5
194/4 194/24 205/8
kitchen [2] 25/7 26/9
knees [1] 55/20
knew [20] 14/16
18/25 48/10 50/7 58/1
71/7 86/7 88/21 98/22I
104/6 104/9 106/18
110/22 116/20 119/6
135/11 175/21 177/21
192/9 201/18
knocking [1] 60/24
know [117] 7/21 8/1
11/8 11/22 13/13 14/1
14/9 19/7 19/13 20/1
20/9 23/5 23/13 23/15]
23/16 23/21 24/10
25/6 25/6 30/20 31/20)
32/9 34/16 44/15
48/18 49/7 49/13
49/15 49/20 50/3 50/7)
(70) issues... - know
K
51/1 55/24 55/24
55/25 56/7 57/25
60/13 60/18 61/15
64/10 71/1 71/7 72/6
72/7 TAI17 74/18
75/13 75/16 78/22
80/20 80/20 80/23
92/18 95/19 95/21
99/7 99/18 102/5
104/4 104/17 108/6
110/21 111/2 111/23
112/6 112/11 120/2
120/3 120/4 120/13
123/23 128/6 130/13
133/1 133/10 135/12
137/8 138/22 138/22
141/25 142/3 144/25
150/14 151/22 168/3
179/24 180/2 181/25
183/24 186/25 187/6
knowing [5] 20/8
62/24 102/10 142/4
173/5
knowledge [16] 3/22
8/2 8/2 14/3 56/19
88/10 88/12 91/18
111/20 119/6 152/13
161/3 161/7 180/25
182/5 201/11
known [17] 9/19 68/3
71/6 94/13 95/6 98/3
98/4 104/14 112/24
118/6 119/3 129/23
133/25 160/24 180/4
180/25 189/1
knows [2] 5/8 32/22
L
labelled [1] 165/3
lack [2] 57/10 152/13
lacked [1] 50/20
land [1] 14/8
language [3] 11/22
85/16 85/19
laptop [4] 106/16
107/10 129/10 184/11
laptops [1] 106/20
large [5] 24/9 61/3
92/11 92/15 114/17
largely [1] 178/17
laser [1] 20/9
last [15] 11/23 32/5
46/13 84/14 97/10
120/2 128/4 158/15
know... [86] 50/22
61/16 62/20 63/4 64/9
80/24 81/4 82/23 84/7
84/7 84/13 89/7 90/25
130/19 130/25 132/20)
145/11 149/16 149/20)
174/19 174/20 179/12)
192/17 200/18 207/16}
186/12
late [9] 26/24 48/13
49/12 112/23 112/25
122/25 140/14 158/5
158/11
later [27] 9/3 26/3
59/15 60/18 60/20
75/13 115/2 120/16
122/22 124/16 134/7
134/23 135/14 136/9
143/3 146/14 148/24
152/9 157/22 168/6
173/13 175/2 208/19
latest [2] 95/7 108/8
latterly [2] 166/21
186/6
71/18 79/25 189/1
lawyer [5] 8/21 59/7
112/4 113/21 125/18
lawyer-client [1] 8/21
lawyers [23] 26/12
26/17 67/10 83/1
109/2 111/5 118/17
121/9 124/17 131/23
136/21 139/2 139/22
155/2 157/24 158/8
163/16 168/6 173/14
179/8 180/11 188/20
190/1
lead [6] 19/22 24/25
53/13 175/13 184/19
206/3
leader [1] 54/1
leading [1] 158/2
Leads [1] 110/1
lean [1] 31/18
learn [1] 98/15
learned [1] 100/3
least [5] 7/12 12/1
47/17 191/20 194/12
leave [2] 73/1 178/8
leaves [1] 169/25
led [6] 15/24 67/25
82/12 85/9 196/25
198/21
Lee [4] 6/1 6/25
14/19 45/17
left [7] 21/12 34/8
36/9 64/4 64/22 83/21
84/8
Legacy [3] 124/7
130/1 130/18
legal [16] 36/3 52/14
52/23 60/8 80/7 80/18)
80/22 94/16 113/22
114/4 121/8 185/1
185/6 186/17 190/16
192/16
legally [2] 60/15
86/11
159/20 165/19 167/24,
169/17 179/11 181/13)
63/8 64/17 72/3 74/22
law [6] 5/23 7/23 14/8
lengthy [2] 79/12
116/10
Lenton [16] 51/7
51/19 90/22 90/23
90/25 91/3 96/21
107/6 148/1 152/20
153/9 191/25 198/9
200/21 210/16 212/8
Lenton's [1] 90/11
less [5] 47/11 187/15
191/2 200/7 209/24
let [13] 11/10 13/3
30/22 50/24 59/16
70/22 123/23 128/6
151/22 173/24 174/8
174/24 207/16
let's [19] 9/24 13/25
36/4 41/25 44/20 45/1
45/2 46/4 51/15 121/4
137/11 164/4 190/24
196/8 199/8
letter [8] 7/10 10/11
39/4 42/3 44/11 44/11
46/5 64/10
letters [1] 162/15
level [6] 46/20 50/7
97/22 98/12 103/25
109/21
liaise [1] 188/20
liaised [1] 182/18
liaising [1] 108/1
liaison [1] 101/1
lie [2] 173/24 174/8
light [2] 4/24 29/24
like [55] 4/3 4/5 4/11
5/3 9/9 20/1 24/17
26/1 36/8 49/19 62/19
63/1 69/24 70/12
94/18 99/13 100/13
103/25 108/21 109/16}
109/16 112/17 112/22]
119/4 120/9 123/24
125/3 126/1 132/3
133/1 133/10 136/8
140/24 141/24 145/20}
160/4 161/2 168/25
170/4 174/23 179/5
179/20 181/11 190/17I
191/11 191/14 194/19]
195/3 197/16 198/1
199/18 202/25 205/3
208/23 210/4
likely [7] 102/15
108/7 118/23 126/19
127/6 128/14 128/20
likes [1] 205/25
limited [15] 8/9 17/14
27/23 27/25 37/7
37/12 51/5 57/11 65/5
101/8 180/21 181/2
181/3 193/25 210/8
line [9] 2/25 3/15
33/1 77/14 82/10
14/10 16/2 27/3 34/19
lines [1] 3/4
link [1] 19/14
list [8] 28/8 28/8
36/11 105/6 147/23
172/18 203/18 206/3
listed [2] 110/19
169/16
listings [1] 47/4
lists [1] 147/2
literally [4] 172/23
litigate [1] 35/14
litigation [26] 5/20
6/14 6/20 7/2 7/11
9/11 9/16 9/17 25/1
53/21 53/23 86/22
87/17 88/6 108/22
111/12 161/5 179/7
200/16
little [12] 12/25 17/9
66/5 122/7 125/14
158/19 159/6 193/20
196/11 198/8 199/8
206/21
live [7] 155/11 156/2
156/10 157/1 164/16
168/21 169/23
LLP [1] 42/4
LN [1] 64/23
load [1] 150/24
loading [1] 184/11
local [9] 95/22 129/6
129/10 140/9 140/16
140/24 141/3 142/14
142/19
locate [3] 169/5
190/5 192/8
located [1] 114/10
location [4] 114/9
148/14 192/2 197/21
locations [1] 113/1
locked [2] 34/10
144/12
log [5] 98/3 98/4
118/6 168/24 168/25
logically [2] 130/16
142/9
logistical [1] 52/5
logistics [2] 58/3
89/15
logs [9] 112/24
114/15 163/13 165/3
168/7 169/5 169/6
169/23 171/1
long [17] 20/8 22/14
22/15 35/17 41/24
94/5 110/20 116/9
175/24 175/25 176/12
190/24 194/14 195/9
197/19 198/4 208/12
longer [18] 41/22
94/14 112/10 119/19
82/16 83/2 83/5 210/8
26/18 27/2 35/6 52/15)
188/19 188/22 189/16)
121/23 121/25 121/25)
122/3 130/21 132/4
133/10 133/11 133/17)
138/24 154/5 156/18
159/11 191/9
longstanding [2]
111/19 201/11
look [57] 9/24 10/17
14/19 16/2 20/16
21/10 27/3 28/2 29/21
36/4 36/6 36/25 39/9
41117 42/2 43/16
45/15 46/13 58/5 58/7
61/9 61/9 64/22 66/18)
69/15 97/16 100/11
100/19 106/22 116/5
116/16 117/4 117/9
121/4 134/13 137/11
141/10 144/8 146/18
149/10 161/15 163/14)
164/4 168/12 171/22
172/22 175/5 176/1
180/8 180/19 182/24
186/10 187/19 196/8
198/6 200/13 208/13
looked [19] 14/20
44/15 46/21 118/2
120/4 125/2 125/9
127/8 134/24 142/13
159/2 164/10 183/8
185/10 186/11 196/1
198/5 209/21 209/23
looking [20] 23/23
41/18 64/12 64/22
71/2 95/23 100/10
111/14 126/18 128/17
133/14 133/15 138/7
139/12 183/15 186/1
187/17 189/7 198/7
199/5
looks [6] 36/3 132/3
133/9 134/12 141/24
198/1
Lord [30] 52/17 58/4
58/4 61/5 62/5 62/14
62/18 62/21 64/24
66/1 66/7 74/25 75/14I
77122 78/24 78/25
79/1 79/4 79/6 79/11
79/21 80/6 80/8 80/10}
80/17 83/19 83/20
83/21 84/4 84/8
Lord Grabiner [15]
58/4 61/5 62/14 62/18)
62/21 74/25 75/14
79/1 79/11 79/21
83/19 83/20 83/21
84/4 84/8
Lord Grabiner's [2]
79/4 80/10
Lord Neuberger [6]
58/4 62/5 66/1 66/7
77122 78/24
Lord Neuberger's [1]
(71) know... - Lord Neuberger's
L
Lord Neuberger's...
[1] 64/24
lose [2] 79/23 80/5
loss [4] 77/6 77/13
77/16 80/10
losses [1] 86/13
lost [1] 48/23
lot [7] 32/18 33/25
57/23 106/15 107/10
107/19 188/2
lots [3] 44/16 44/16
106/20
low [3] 97/21 171/19
172/1
Lucy [9] 125/14
126/7 128/8 138/7
144/11 146/21 151/15)
183/5 184/6
lunch [4] 51/19 52/3
90/9 208/13
lurks [1] 34/24
MacLeod [20] 8/8
58/6 58/24 59/10
59/18 60/1 60/10
63/15 64/5 67/12
67/25 72/18 73/17
76/10 77/21 82/4
82/12 83/7 85/9 86/3
MacLeod's [3] 60/22
78/20 82/19
made [31] 1/16 2/5
4/20 5/16 19/12 20/10)
25/11 25/21 26/15
45/18 52/13 64/15
64/17 73/7 79/22
86/22 89/10 100/18
108/9 113/4 123/16
141/6 142/6 142/20
145/7 161/12 165/7
176/5 203/17 207/10
210/12
magic [1] 34/4
Mail [2] 18/6 18/7
mailbox [4] 101/9
101/14 101/18 101/24
main [1] 60/14
mainly [1] 103/6
major [1] 130/1
make [24] 2/19 4/4
4/14 7/10 35/7 38/20
51/4 51/18 52/13 65/5
68/1 82/12 116/8
133/3 134/8 145/6
148/21 152/19 157/22)
165/14 166/16 168/2
174/11 175/41
makes [3] 63/10
117/3 146/9
making [14] 24/24
38/23 73/3 76/14
85/19 86/9 90/3 98/9
141/4 142/1 142/3
143/2 157/4 183/18
manage [3] 98/7
98/11 137/18
managed [7] 135/1
138/14 148/8 166/20
168/16 168/20 169/6
management [12]
29/10 53/20 54/23
95/5 97/4 97/8 97/12
97/19 97/21 98/13
137/21 154/11
manager [21] 93/2
93/9 93/11 93/16
93/17 94/6 94/19
94/23 94/25 99/25
101/1 102/4 102/21
109/16 109/24 109/25)
131/2 137/16 137/17
139/8 190/4
Managers [1] 111/2
managing [1] 111/7
Mandy [37] 10/10
16/21 16/22 16/24
17/9 18/14 18/21
18/24 18/25 19/19
20/18 21/15 23/8
23/17 24/1 24/5 24/6
24/19 26/6 27/8 27/10
28/14 29/5 29/20
31/11 31/20 32/5 33/9)
34/19 36/9 37/4 38/5
38/9 38/13 47/24 48/2
50/23
Mandy's [1] 31/25
manual [1] 168/25
manually [1] 170/7
many [20] 6/13 8/11
20/24 32/2 64/18
73/21 100/5 110/25
149/6 149/16 160/3
162/14 173/9 179/13
185/10 186/10 188/4
193/19 194/23 209/18)
March [49] 8/7 15/2
34/13 36/5 36/9 37/6
42/15 42/21 46/2
52/20 54/11 54/12
54/13 55/2 55/6 56/6
56/8 56/9 56/11 56/16)
57/4 58/7 58/23 59/17
62/1 64/3 72/14 72/19)
73/17 79/15 79/16
83/17 83/23 84/17
84/25 89/13 120/16
121/7 123/4 123/16
123/21 155/7 155/13
155/15 155/22 156/11
176/2 177/25 180/22
March 2004 [1] 42/15)
March 2006 [4] 46/2
Marine [1] 14/22
mark [10] 73/13
99/21 110/14 125/7
127/7 127/17 172/19
172/21 202/21 206/1
mark-up [1] 73/13
Mason [1] 42/4
master [1] 170/18
match [1] 169/16
matching [1] 131/12
material [7] 12/12
53/4 59/18 124/22
127/25 182/6 202/25
materials [1] 127/22
MATHEW [3] 1/7
1/14 212/2
matter [11] 19/21
56/19 68/18 73/18
79/23 109/3 110/13
111/3 163/25 175/25
191/5
mattered [1] 186/16
matters [5] 8/4 20/17
52/5 70/22 203/21
Matthew [19] 90/21
90/23 91/3 107/6
114/7 121/12 125/19
131/8 134/25 140/3
142/16 146/22 148/1
151/16 158/22 166/3
196/22 198/9 212/8
may [75] 2/5 3/16 5/4
6/21 7/20 7/20 7/25
8/5 8/5 9/18 9/23
14/12 21/1 30/21
30/21 35/13 37/16
40/5 41/18 42/25
44/15 68/11 69/19
69/19 72/3 76/9 79/25
87/1 87/2 91/5 93/9
94/2 95/23 96/15
96/24 97/14 100/15
102/9 102/17 106/18
112/9 114/17 123/9
125/6 125/20 125/23
127/8 127/19 128/14
128/18 128/19 129/3
129/5 130/15 139/7
139/9 149/11 150/7
150/16 152/16 159/13}
161/11 164/7 165/25
175/10 177/16 180/4
182/1 188/18 189/3
192/13 201/3 205/12
205/13 208/23
maybe [7] 23/15 26/3
64/18 98/18 123/24
145/19 186/17
me [128] 4/20 7/16
9/8 9/20 10/16 11/10
11/20 11/21 13/3
18/17 19/2 19/4 19/4
20/9 20/9 20/12 22/2
24/1 24/4 24/5 25/7
26/1 28/10 28/12
28/13 30/23 36/22
36/22 36/23 40/12
40/24 41/14 50/24
54/23 57/7 58/2 59/11
59/15 59/16 60/23
63/11 66/8 66/24
67/10 67/12 67/12
68/2 68/6 68/6 69/2
69/9 72/7 78/17 80/25
81/5 81/7 82/6 82/24
84/6 84/14 85/17 87/6
89/9 93/18 94/1 101/9
101/19 101/21 102/8
102/10 102/17 102/18}
102/19 104/8 105/22
4111/9 115/23 117/19
117/23 117/23 119/1
120/6 123/11 125/13
126/2 127/19 127/20
128/6 128/15 128/20
1341/5 131/23 132/22
135/23 136/7 136/23
140/23 142/23 143/2
143/6 143/12 145/6
145/15 146/8 146/9
151/9 151/22 152/16
158/9 162/7 163/1
178/6 179/11 179/14
179/23 184/3 184/4
184/9 186/11 187/15
187/17 190/11 190/13
191/6 193/24 197/1
199/3 207/16
mean [96] 7/16 20/8
25/3 25/20 25/21 30/7
50/7 54/5 61/13 65/25
72/1 77/1 77/8 78/9
82/14 83/14 85/11
97/14 98/8 98/22
100/6 102/15 103/10
104/6 106/18 108/17
110/18 112/13 116/15]
119/23 120/1 120/6
120/8 121/20 128/15
128/25 129/7 129/10
130/12 130/15 130/16
132/17 132/19 133/4
133/17 135/11 135/13}
136/8 136/22 139/4
141/4 142/6 143/18
143/21 145/4 145/16
145/24 146/4 146/6
149/21 150/13 150/14]
150/18 152/11 152/23
157/18 158/12 167/5
172/20 172/25 174/15}
177/6 179/2 179/13
180/5 182/10 185/25
186/7 186/16 186/19
186/25 187/5 188/15
188/24 192/12 193/19}
194/4 194/14 194/18
199/4 199/21 200/3
201/18 201/19 205/7
209/20
meaning [3] 68/11
80/22 199/21
means [13] 64/9
66/20 67/22 90/13
120/9 121/22 121/24
127/3 150/13 150/15
168/22 172/22 173/3
meant [6] 49/4 49/5
49/10 49/11 132/14
133/25
mediate [1] 33/7
mediation [3] 26/12
26/16 104/21
meeting [15] 23/18
28/6 28/15 28/24
29/14 36/14 41/5
41/14 114/23 114/24
117/13 117/22 117/24)
118/25 119/1
meetings [2] 2/14
185/6
member [3] 101/17
113/22 185/5
members [5] 54/16
99/5 106/3 110/12
204/10
Membery [1] 209/25
memorable [1]
103/23
memory [7] 7/6 12/13}
15/1 41/9 103/5
193/14 194/16
mentally [1] 77/14
mention [2] 6/18
165/14
mentioned [10]
24/19 56/21 71/17
101/19 105/23 111/8
138/19 153/9 202/9
209/9
mentions [1] 116/19
merits [7] 22/17
24/11 27/18 30/9
30/15 83/7 83/24
message [1] 32/25
met [2] 41/9 44/4
method [7] 152/2
167/2 167/11 167/15
168/20 171/5 184/14
methodology [1]
167/12
methods [1] 167/3
Michael [3] 42/4
115/11 116/18
Microphone [1]
41/20
middle [8] 84/7 87/22
91/13 118/7 149/23
171/24 184/5 198/9
midway [1] 3/8
might [23] 31/23 35/5)
39/5 51/16 59/11 63/7I
71/22 77/2 88/15
106/22 108/17 160/22!
(72) Lord Neuberger's... - might
might... [11] 170/4
172/7 174/7 174/10
181/7 194/20 194/24
194/25 196/6 205/1
209/4
mind [16] 12/1 21/4
26/19 30/21 30/22
33/1 34/11 68/5 80/21
81/12 122/8 130/17
134/5 139/8 157/18
167/24
minds [1] 88/20
mine [1] 64/19
Minister [2] 73/22
75/4
minor [1] 118/12
minute [7] 81/4
152/23 190/11 191/2
191/10 191/16 191/18}
minute-ish [1]
191/10
minutes [11] 51/5
51/13 51/15 51/17
73/18 75/23 87/9
149/4 190/20 191/12
191/15
misconceived [2]
39/6 39/16
missed [1] 125/22
missing [1] 174/16
mistake [6] 19/12
20/10 25/6 25/21
25/22 26/22
mistress [1] 4/8
mix [1] 205/6
mm [22] 93/7 94/11
95/17 96/15 97/1 97/1
107/4 108/14 112/13
123/1 124/9 131/24
140/8 143/5 157/11
163/20 170/1 170/6
171/12 180/15 181/10)
198/10
mm-hm [16] 93/7
97/1 97/1 107/4 123/1
124/9 140/8 143/5
157/11 163/20 170/1
170/6 171/12 180/15
181/10 198/10
modifications [1]
162/13
modify [2] 162/11
166/8
Mohammed [1]
93/24
moment [3] 87/3
101/20 178/9
Monday [4] 57/5 67/3
82/17 183/10
money [1] 32/13
month [2] 35/23
42/19
months [8] 36/5 47/5
120/16 124/16 136/9
175/2 196/24 198/17
mood [2] 54/21 55/2
more [32] 7/5 20/20
21/7 26/1 40/4 44/13
55/20 55/21 57/18
58/1 74/4 83/3 93/16
108/18 128/20 136/1
146/3 150/23 151/11
153/9 173/5 174/14
175/21 185/16 188/2
188/10 193/24 194/2
200/7 204/13 205/10
209/24
Morgan [2] 23/5 23/5
morning [9] 1/3 1/4
41/19 51/24 51/25
70/17 90/5 147/13
210/20
most [6] 36/15
103/12 103/24 104/7
156/3 157/18
motivation [3] 60/11
60/15 86/9
motivations [3]
60/19 86/14 86/18
motive [1] 60/22
move [9] 14/19 34/21
51/2 74/21 108/21
134/18 161/2 184/1
195/3
moved [2] 19/6
142/23
moving [2] 32/6
207/5
MP [1] 73/23
Mr [120] 1/5 1/8 1/16
4/11 4/15 14/22 15/3
15/6 15/11 19/15
24/15 24/20 26/12
26/17 28/20 28/22
30/2 30/5 30/6 30/8
31/19 35/25 37/21
41/23 41/25 45/3 45/9
45/22 46/2 49/1 49/5
51/7 51/7 51/17 51/19)
52/7 52/14 52/16
52/18 52/24 53/22
54/10 72/22 73/6
73/10 73/19 80/25
87/15 89/22 90/2
90/11 90/13 90/25
96/21 107/16 108/2
109/14 112/6 112/12
125/17 132/17 135/8
140/11 141/14 141/7
142/3 142/20 147/21
148/21 149/23 152/20)
153/9 154/22 164/6
165/25 167/4 168/17
169/13 169/13 169/14)
170/3 170/3 170/3
170/10 171/18 171/25)
172/20 173/13 174/2
174/13 176/5 178/8
186/15 191/10 191/16
191/22 191/24 191/25)
198/24 199/19 200/5
200/8 200/18 200/21
201/5 201/23 202/2
202/4 202/9 203/22
205/16 206/2 210/7
210/7 210/16 210/20
210/20 210/21 212/4
212/12
Mr Beer [1] 52/14
Mr Beezer [6] 1/5
1/16 51/17 80/25
87/15 90/2
Mr Castleton [16]
4/11 4/15 14/22 15/3
15/6 15/11 24/20 30/6}
31/19 35/25 37/21
41/23 41/25 45/22
46/2 49/5
Mr Castleton's [7]
19/15 24/15 26/12
26/17 28/20 28/22
30/2
Mr Cavender [3]
72/22 73/6 73/10
Mr Cavender's [1]
73/19
Mr Coyne [1] 205/16
Mr Davidson [1]
107/16
Mr de Garr [1] 200/8
Mr Dilley [2] 30/8
45/3
Mr Dilley's [2] 30/5
45/9
Mr Godeseth [5]
112/12 169/14 170/3
202/9 210/7
Mr Ibbett [3] 169/13
170/3 176/5
Mr Jay [2] 125/17
186/15
Mr Jenkins [8] 108/2
109/14 112/6 201/23
202/2 202/4 203/22
206/2
Mr Jenkins’ [1] 201/5I
Mr Justice [2] 49/1
52/16
Mr Justice Fraser [3]
52/18 52/24 54/10
Mr Lenton [9] 51/7
51/19 90/25 96/21
152/20 153/9 191/25
200/21 210/16
Mr Lenton's [1]
90/11
Mr Newsome [3]
140/11 141/1 141/7
Mr Parker [17] 164/6
165/25 167/4 169/13
170/3 170/10 171/18
172/20 173/13 174/2
174/13 198/24 200/5
200/18 210/7 210/20
210/21
Mr Parker's [4]
168/17 171/25 178/8
199/19
Mr Parsons [2] 53/22,
210/20
Mr Simpkins [5]
132/17 135/8 142/20
147/21 148/21
Mr Simpkins’ [1]
149/23
Mr Simpson [1]
142/3
Mr Stein [1] 191/22
Mr Stein's [2] 191/10
191/16
MR STEVENS [6] 1/8
51/7 52/7 89/22 90/13)
212/4
Ms [34] 52/5 63/15
87/3 87/8 87/9 87/11
87/13 89/23 90/7
90/24 91/1 123/15
127/22 128/3 128/12
129/14 147/21 153/13}
153/18 158/20 184/4
192/1 193/8 193/9
195/21 200/23 200/24}
212/6 212/10 212/14
212/16
Ms Bremner [7]
127/22 128/3 128/12
129/14 147/21 158/20}
184/4
Ms Hodge [6] 52/5
90/7 90/24 91/1 192/1
212/10
Ms MacLeod [1]
63/15
Ms Page [11] 87/8
87/9 87/11 87/13
89/23 193/8 193/9
195/21 200/23 212/6
212/14
Ms Price [1] 87/3
Ms Prime [1] 123/15
Ms Prime's [2]
153/13 153/18
MSC [11] 166/18
167/7 167/8 169/15
169/18 170/15 170/16}
170/18 170/18 170/25
173/18
MSCs [1] 170/11
much [18] 8/17 21/23
41/22 45/12 45/23
51/4 90/2 98/12
114/11 187/8 187/15
187/23 193/24 200/20}
205/11 206/22 210/16
210/23
Muir [2] 179/23 182/1
multiple [3] 64/19
95/21 202/15
multiplicity [2] 204/5
209/5
music [2] 54/21 55/2
must [24] 11/14 12/7
19/20 24/19 29/9
32/16 32/25 39/18
41/6 57/13 57/24
59/19 61/7 71/5 84/10
114/24 174/15 179/10)
183/23 197/15 199/3
199/19 200/6 209/17
mute [1] 41/21
muted [1] 41/20
mutual [1] 77/25
my [87] 3/16 4/6 4/6
4/6 4/17 4/22 4/25 7/6
7/13 8/22 11/6 11/10
15/1 20/12 20/12
20/13 24/2 24/5 24/18}
25/21 25/22 26/19
26/22 26/22 27/25
28/7 30/8 30/14 31/25
32/5 37/6 44/2 47/4
52/8 55/25 56/19
57/20 59/8 59/16 60/8}
60/13 60/18 62/24
66/8 68/4 70/4 70/21
76/21 78/12 78/16
80/21 81/12 85/11
86/10 86/15 86/24
87/2 88/10 90/25
94/25 99/6 99/8 100/3I
105/7 116/15 121/21
126/14 139/10 152/13}
167/18 168/4 172/25
173/8 178/11 178/16
182/5 182/11 185/3
186/2 186/2 186/9
188/3 190/14 191/25
193/11 200/21 208/22)
myself [3] 3/14 78/12
116/24
name [7] 1/13 6/15
21/12 90/25 91/2
131/10 187/3
named [5] 6/17
111/23 121/14 131/14)
164/18
namely [1] 133/11
names [4] 37/16
113/18 192/17 192/18)
narrative [1] 65/12
nature [3] 38/10
42/16 103/22
navigate [1] 14/4
near [1] 86/13
necessarily [8] 60/25)
100/7 112/15 119/3
(73) might... - necessarily
N
necessarily... [4]
119/15 134/1 183/18
202/12
necessary [2] 87/23
166/15
need [39] 14/2 14/13
15/20 20/4 21/24
39/11 39/24 40/3 40/9
51/5 52/3 52/6 55/8
56/13 65/19 66/4
66/13 69/9 71/22 74/9
75/18 82/10 82/15
83/1 83/5 84/24 95/11
102/19 115/24 138/17)
138/21 159/5 162/12
172/12 183/9 190/18
191/5 200/13 206/2
needed [4] 62/19
113/6 172/5 173/2
needs [6] 34/6
100/15 197/15 199/19
200/6 206/3
needs-must [2]
199/19 200/6
negative [2] 32/13
55/3
negotiation [1] 40/5
nerves [1] 17/17
nervous [3] 63/20
75/3 76/14
Neub [1] 58/25
Neuberger [10] 58/4
59/1 61/11 62/5 65/23
66/1 66/7 77/22 78/24
80/8
Neuberger's [1]
64/24
neutral [2] 72/8
76/18
never [9] 7/20 7/25
49/6 49/11 68/25
78/15 78/15 150/25
177/4
new [12] 7/22 28/12
36/22 40/12 57/21
57/23 108/21 131/18
159/17 160/18 161/2
176/23
Newport [1] 181/16
news [6] 18/5 18/24
27/6 27/7 68/14 68/17,
Newsome [23]
109/15 111/7 112/3
113/19 114/3 117/16
117/20 118/21 119/25
121/8 125/17 137/24
138/4 139/8 140/2
140/11 141/1 141/7
142/12 198/20 205/24
206/24 207/13
next [14] 26/16 34/11
34/18 51/3 66/18
82/17 90/21 112/22
119/11 149/20 178/11
207/11 208/2 208/18
NHS [1] 93/12
night [1] 67/3
nine [4] 169/8 169/25
170/4 171/6
no [144] 5/24 6/23
6/24 8/19 9/15 11/6
12/13 17/24 18/16
21/19 21/22 22/1
22/11 27/1 28/8 28/18
28/25 29/15 31/20
32/14 33/7 33/7 36/19)
36/21 37/22 40/12
40/14 41/1 41/4 41/9
45/25 47/5 48/1 48/9
48/16 48/21 48/22
49/22 49/22 54/6 54/9
55/4 55/7 57/6 63/17
63/19 63/23 64/11
65/11 65/16 67/10
68/23 72/21 72/21
76/4 76/13 76/18
79/22 82/21 82/21
82/21 83/9 83/14
83/16 84/2 84/2 84/24
85/21 87/6 93/18
96/15 101/19 105/17
106/6 106/14 106/18
107/17 107/23 112/10}
112/21 118/5 118/18
119/9 119/10 119/19
119/21 120/13 121/22)
121/25 121/25 122/3
128/11 130/21 132/4
133/10 133/11 133/17)
134/18 135/13 136/8
138/24 139/19 140/19)
143/2 143/9 143/24
145/24 146/7 146/7
146/9 154/5 156/4
156/12 156/18 159/11
165/16 166/7 172/3
173/1 174/15 177/12
179/13 180/1 181/22
182/3 182/17 186/16
188/15 189/7 189/20
189/23 190/3 197/5
197/8 199/11 199/16
199/24 200/19 200/20;
201/18 201/25 202/3
203/19 210/13
nobody [1] 197/7
nodding [2] 14/25
203/2
non [2] 67/18 185/20
non-disclosure [1]
185/20
Non-Executive [1]
67/18
none [1] 58/21
Nor [1] 50/15
normal [4] 48/16
49/23 188/6 194/24
normally [2] 92/10
92/11
not [276]
note [68] 21/11 21/16
23/13 24/4 28/6 29/3
36/17 37/24 40/16
40/17 41/15 43/16
43/19 56/9 58/8 58/12
58/25 59/3 59/7 59/16
62/8 64/3 64/23 64/24
68/1 69/4 69/5 69/8
69/9 69/12 69/14
69/21 70/24 71/13
72/8 72/21 73/5 75/25
76/6 76/21 77/22
77/23 77/24 78/10
79/3 79/5 79/14 79/17,
80/25 81/4 81/24
82/13 83/14 83/15
83/18 83/19 84/3
84/16 85/10 87/1
87/16 142/6 150/3
156/4 176/16 205/23
207/6 207/17
notebook [1] 58/13
notepaper [1] 81/1
notes [9] 2/13 2/13
2/15 59/5 59/6 59/8
79/9 81/17 82/2
nothing [3] 29/12
57/25 58/19
noticed [1] 100/12
notify [1] 137/2
notion [1] 39/15
November [29] 10/19
16/10 16/21 21/11
24/3 26/11 26/17
31/12 33/7 35/22
46/15 47/13 49/1 49/6
49/8 93/1 112/25
113/9 114/1 117/14
122/25 151/1 153/25
155/3 155/7 155/22
159/23 180/14 184/5
now [95] 1/20 2/12
2/21 3/19 4/16 5/1
7/12 14/19 23/5 23/9
26/5 26/7 29/19 34/12
34/23 35/14 39/6 40/7
52/16 53/6 58/11 60/7
61/16 65/21 66/8
66/18 75/24 76/2 76/7
79/6 79/7 81/20 90/9
97/2 98/2 100/9
114/22 115/10 115/22
116/2 116/8 116/16
117/9 117/13 118/16
119/17 120/6 121/22
122/7 123/3 123/14
126/18 128/9 135/7
135/25 136/2 136/18
137/11 138/4 138/25
142/12 142/15 142/18}
144/21 147/14 148/19
149/4 149/18 151/5
152/6 152/19 156/14
157/2 157/22 159/6
159/22 161/15 162/15)
163/21 167/3 169/4
175/2 177/24 179/15
179/17 181/6 181/20
183/6 183/12 185/4
187/5 188/18 191/17
200/14 210/19
nucleus [1] 57/2
number [22] 1/18
6/13 18/1 29/21 33/24)
66/5 84/21 112/24
116/13 146/14 150/17,
151/20 160/15 160/18}
170/12 171/7 171/11
172/6 185/9 193/25
203/22 210/17
number 1 [1] 29/21
number 2 [3] 18/1
33/24 66/5
numbers [3] 43/8
45/5 162/16
numerous [1] 28/7
NVQ [1] 94/13
[e)
observation [1]
89/10
obsolete [3] 95/9
122/2 122/3
obtain [7] 22/19
39/24 40/9 102/11
106/12 179/7 181/4
obtained [10] 91/24
108/5 109/8 110/9
120/22 122/11 141/1
148/19 178/25 179/22}
obtaining [3] 38/15
45/23 110/12
obviously [20] 31/8
40/19 59/6 64/10 81/3)
88/5 92/10 92/14
103/7 103/11 104/25
110/21 110/22 116/2
117/4 141/20 186/19
193/23 201/18 209/19}
occasion [4] 125/18
168/15 178/6 194/2
occasionally [1]
100/12
occasions [5] 28/7
109/20 153/17 177/1
196/3
occur [1] 136/7
occurred [5] 84/12
136/3 136/18 136/23
162/14
OCP [3] 166/21 167/7I
167/8
OCPs [2] 196/18
198/12
October [5] 8/7
104/10 146/20 160/6
181/14
off [18] 10/11 19/4
24/6 41/12 58/22 59/3
61/11 81/16 168/4
168/18 168/22 170/19)
173/18 176/17 176/19}
186/2 197/8 210/19
offer [3] 26/15 26/15
70/11
offering [2] 174/11
174/25
office [126] 6/1 6/5
6/7 6/10 6/12 6/24 7/2
7/14 7/23 8/9 8/11
8/14 8/17 8/19 8/23
8/24 9/2 9/13 9/18
9/20 10/10 10/12
10/15 11/5 11/12
11/12 11/15 14/23
15/2 15/5 15/16 17/14)
18/11 27/8 27/14 31/9)
31/18 32/10 32/11
32/13 32/16 32/19
33/6 34/1 34/9 35/19
36/10 37/14 37/19
38/14 40/3 47/21
49/25 50/18 53/25
55/12 55/13 58/20
58/21 60/2 63/16 65/5
65/9 68/23 70/23
72/23 TAIT 79/22
79/24 80/4 80/4 80/9
80/11 80/13 85/22
86/1 86/10 88/1 88/11
88/22 93/5 93/11
93/17 94/6 94/20
94/23 95/1 95/7 96/13}
99/11 99/12 99/17
101/2 101/8 101/15
102/3 102/7 102/13
102/25 104/3 104/5
104/21 105/2 105/8
105/15 108/20 108/24I
109/17 109/19 109/23}
113/1 114/8 114/12
117/11 139/16 158/23)
166/8 175/14 180/11
180/22 181/2 189/10
189/14 194/1 202/16
203/20
Office's [25] 17/17
28/16 29/23 60/11
109/2 111/5 111/11
111/24 115/3 118/17
124/17 131/23 136/21
137/22 139/2 139/22
155/2 157/24 158/8
163/16 165/8 168/6
173/14 179/8 189/25
offices [2] 109/20
181/15
official [1] 67/16
(74) necessarily... - official
[e)
often [9] 17/2 92/21
109/15 110/17 118/13)
162/22 177/12 207/17)
207/20
Oglesby [2] 22/5
29/25
Oh [3] 55/24 55/25
136/12
okay [21] 10/17
39/13 39/14 54/22
66/10 73/20 82/21
82/25 91/23 94/15
109/15 122/21 123/14)
124/2 138/19 145/9
167/10 167/14 192/17
198/3 208/16
old [4] 92/19 121/23
121/24 155/25
OLIVER [2] 200/24
212/16
on [391]
once [12] 26/6 33/10
33/11 41/10 138/23
138/24 141/18 141/22)
149/22 153/9 164/25
166/9
one [77] 2/22 16/12
19/20 24/16 28/8
30/24 33/14 36/2
36/22 40/15 41/17
44/20 48/10 50/12
51/6 56/7 59/11 59/12)
59/13 59/15 60/14
64/4 70/23 72/9 77/2
77/8 83/17 87/8 93/16
95/11 95/14 95/25
97/2 98/7 104/7
105/22 111/18 117/4
125/1 125/3 125/5
127/15 134/15 142/25
142/25 144/18 161/24}
163/1 164/19 167/17
169/17 169/23 169/25
172/19 172/21 172/23
173/6 175/10 179/15
183/3 188/3 190/11
190/19 191/1 191/10
194/2 194/3 197/13
198/3 199/24 201/10
203/22 204/3 204/11
206/3 209/25 210/2
one's [1] 175/8
ones [6] 30/3 110/10
122/16 156/25 157/1
186/10
ongoing [1] 189/21
Online [4] 40/6 124/7
150/1 165/12
only [40] 3/4 22/10
35/21 36/21 36/23
44/7 47/8 48/1 59/3
61/11 68/17 86/14
86/16 101/17 102/5
103/6 104/25 105/8
106/9 107/24 110/9
118/20 118/21 119/13)
119/24 122/9 123/2
123/7 138/23 141/4
156/2 159/19 166/10
169/8 169/17 179/13
192/10 194/3 194/19
210/4
operated [1] 8/14
operating [3] 182/6
182/8 182/13
operation [3] 113/2
130/20 182/8
operational [2]
130/21 166/23
Operations [1]
179/21
opinion [7] 50/14
74/2 112/14 120/15
131/2 142/10 185/3
opportunity [5] 4/5
4/16 5/1 174/24 178/7
optional [2] 139/16
139/18
options [1] 73/2
or [177] 2/13 7/21 8/2
12/16 12/19 12/21
13/9 13/10 13/17
13/17 13/22 13/23
14/12 14/13 14/17
21/6 21/18 24/17
24/25 26/8 27/8 27/11
27/23 29/11 31/4
33/12 34/6 35/5 37/11
37/16 37/18 38/3
42/19 43/10 45/1
47/16 48/7 48/20
50/25 51/8 51/13
51/19 52/3 55/5 56/4
56/6 58/17 58/20
60/17 61/15 61/18
62/20 63/16 64/11
65/10 66/12 67/8
70/12 71/24 73/18
76/11 76/19 77/20
78/20 78/25 80/19
81/4 83/3 83/25 84/5
84/14 85/19 86/22
92/11 92/21 93/17
94/1 94/9 94/16 95/15
96/24 98/5 98/7 98/18
100/17 100/18 102/2
103/13 104/21 104/22)
105/10 106/1 106/4
107/2 107/21 109/16
110/4 111/2 1141/5
116/24 117/20 117/24)
118/3 118/11 118/25
120/9 125/7 127/7
128/14 129/11 130/11
130/15 130/24 132/12)
132/23 133/6 133/24
134/2 138/23 143/14
146/8 148/10 148/22
150/15 152/11 152/23
153/24 154/2 154/2
155/7 155/22 156/2
156/24 157/2 159/15
161/7 161/11 162/11
162/21 166/8 166/8
167/3 167/7 170/16
170/19 171/4 172/4
172/24 173/9 173/25
175/16 175/24 177/9
178/19 178/19 180/7
181/25 182/7 182/8
183/9 183/12 183/13
189/10 189/17 189/22)
190/2 191/17 192/8
198/1 199/6 200/2
200/7 200/17 202/1
203/23 205/14 209/24
oral [1] 90/5
order [10] 19/24
48/25 56/5 111/17
172/24 176/17 176/23
181/24 196/3 201/7
organisation [3] 58/2
92/10 101/24
organising [1] 58/6
orient [1] 180/19
orientate [1] 81/22
original [14] 95/17
125/12 126/16 126/22
142/24 147/23 155/13
158/19 161/17 168/13
175/8 176/18 196/24
198/17
originally [5] 99/9
126/9 154/22 176/17
204/13
osmosis [1] 88/11
other [67] 19/16 31/4
32/18 32/21 32/23
33/18 36/23 41/11
47/5 50/4 50/19 53/11
53/13 58/20 76/13
88/15 88/18 92/24
93/25 96/5 99/12
99/22 101/8 101/21
102/5 102/6 103/19
103/24 105/3 105/10
106/12 108/9 110/11
110/18 111/22 112/12
112/16 113/15 114/15}
116/20 117/1 117/25
121/8 122/16 126/13
128/16 142/8 142/25
145/4 147/11 154/20
156/12 157/10 163/3
164/23 177/16 185/10
188/20 192/11 192/16}
194/22 196/12 197/23
201/16 203/19 209/11
209/25
other's [1] 204/22
others [5] 88/17
108/23 114/6 192/13
192/15
otherwise [2] 55/5
92/12
ought [4] 12/20 13/21
105/11 174/3
ounce [1] 19/11
our [34] 7/15 16/12
25/6 25/9 33/1 34/11
34/23 41/19 42/12
42/20 45/19 57/20
72/7 73/3 74/4 75/3
75/4 75/19 76/2 77/23)
79/2 90/21 115/13
115/21 126/21 128/4
146/24 152/24 184/1
187/24 190/18
ourselves [2] 81/22
180/19
out [53] 9/10 10/20
13/14 14/7 16/17 34/4}
35/18 42/21 44/3
45/18 48/18 48/21
49/22 52/16 57/17
58/4 58/15 59/6 63/23
67/13 70/8 70/22
70/25 71/10 73/2
74/12 79/7 80/9 87/19)
87/24 88/7 89/18
95/24 103/4 120/3
120/12 132/11 134/15}
135/14 147/17 150/5
163/12 164/17 169/4
170/20 171/13 172/24
174/1 174/5 182/8
184/20 194/20 204/8
outcome [1] 55/14
outcomes [2] 65/23
66/7
outlined [1] 181/18
output [1] 204/22
outset [1] 4/6
outside [1] 101/24
outstanding [1]
125/23
over [30] 4/24 10/4
30/17 31/5 34/15 47/2
54/7 58/1 69/4 69/9
76/19 80/22 82/10
82/15 83/2 83/5 100/1
101/20 104/25 108/2
115/22 116/3 116/10
127/22 144/4 150/24
186/11 187/1 187/12
187/24
overall [2] 19/15
25/23
overcoming [1]
22/16
overinflated [1] 36/1
overlap [3] 8/8 11/3
97/14
overnight [2] 197/8
199/24
oversee [1] 102/2
oversight [14] 9/12
9/15 17/20 40/20 54/3}
54/5 185/1 186/14
186/20 186/21 187/8
187/20 187/22 188/1
overstated [1]
145/20
overstating [2] 19/8
19/10
overtly [1] 167/22
overwritten [1]
159/17
own [6] 27/5 73/1
86/7 99/14 119/4
139/18
owned [2] 99/16
101/9
ownership [1] 68/5
Pp
page [101] 1/25 2/8
3/8 3/15 7/8 16/3
16/20 24/23 25/10
28/19 29/17 32/3 36/6
36/25 42/8 46/23 47/2I
47/6 55/9 56/13 69/15)
69/16 70/3 72/12
73/16 76/20 76/22
77/4 77/15 79/19 82/2I
84/21 87/8 87/9 87/11
87/13 87/19 89/23
91/10 91/13 94/22
97/16 101/4 109/11
113/25 121/5 123/20
125/13 131/4 131/5
131/25 134/22 137/13)
137/13 139/25 141/14)
142/11 144/9 144/9
146/20 147/23 149/11
149/14 149/24 151/13)
151/14 152/15 158/17)
158/18 162/6 162/8
163/1 163/15 164/6
166/1 168/13 168/13
169/11 171/23 171/24I
173/15 175/7 176/2
178/5 181/12 181/13
183/2 183/2 184/2
184/3 184/5 193/8
193/9 195/21 196/9
196/10 197/20 198/6
200/23 212/6 212/14
page 1 [9] 16/20 32/3
72/12 123/20 137/13
144/9 171/23 176/2
184/3
page 10 [2] 158/18
198/6
page 18 [2] 46/23
109/11
page 2 [11] 16/3 77/4
79/19 134/22 144/9
(75) often - page 2
P
page 2... [6] 147/23
152/15 162/6 164/6
175/7 183/2
page 3 [11] 28/19
29/17 42/8 70/3 94/22
101/4 121/5 151/13
151/14 196/9 197/20
page 32 [1] 1/25
page 4 [7] 47/6 69/15
73/16 87/19 125/13
146/20 181/12
Page 41 [1] 2/8
page 5 [5] 7/8 55/9
82/2 168/13 181/13
page 51 [1] 91/10
page 6 [3] 36/25
97/16 168/13
page 7 [1] 56/13
page 9 [3] 36/6
158/17 178/5
pages [5] 55/20 91/7
116/10 158/17 194/19
Pages 9 [1] 158/17
paid [1] 42/18
Panaech [4] 10/7
10/8 10/9 10/18
panel [1] 7/23
paper [1] 70/7
papers [3] 24/6 56/7
56/8
para [1] 62/3
paragraph [20] 7/8
10/22 28/19 39/9
45/15 47/7 55/9 56/10
56/13 72/14 87/22
94/24 97/16 101/5
109/11 164/14 165/20
176/7 180/20 183/8
paragraph 12 [1] 7/8
paragraph 14 [2]
28/19 56/13
paragraph 2.1.2 [1]
47/7
paragraph 47 [1]
109/11
paragraph 8 [2]
94/24 101/5
paragraph 9 [1] 55/9
paragraphs [2] 2/1
181/13
paraphrased [1]
201/13
Parker [27] 109/25
164/1 164/6 165/25
167/4 169/13 170/3
170/10 171/18 172/20}
173/13 174/2 174/13
175/1 177/11 178/1
196/12 198/8 198/12
198/24 199/6 200/5
200/18 206/1 210/7
210/20 210/21
Parker's [8] 110/3
168/17 171/25 178/8
190/14 199/19 209/20;
209/21
Parsons [11] 53/13
53/22 55/18 61/24
69/17 70/15 72/13
73/17 175/8 197/24
210/20
Parsons' [2] 53/6
53/9
Parsons's [2] 54/3
70/9
part [28] 2/12 12/9
21/2 23/1 24/9 24/10
26/15 28/23 33/8
34/12 34/13 39/16
46/2 73/25 77/15
94/19 94/25 99/9
99/10 101/1 132/7
143/24 152/13 155/13)
172/24 196/1 202/18
203/17
Participants [1] 76/3
particular [10] 10/25
30/2 74/25 87/15
103/4 124/25 133/10
145/18 176/18 202/9
particularly [7]
100/21 104/20 185/15)
186/6 187/16 187/21
209/22
Particulars [1] 10/21
parties [4] 34/6 92/24)
101/8 105/3
partisan [1] 71/2
partly [2] 89/3 204/20
partner [13] 5/16
5/18 8/20 9/11 9/15
9/20 10/13 17/19
25/21 53/16 53/25
54/2 175/9
partner's [1] 54/9
parts [3] 6/21 58/15
61/3
pass [2] 102/8 104/2
passage [1] 159/2
passed [2] 57/18
102/17
passing [2] 40/13
44/13
past [1] 89/4
pasted [1] 135/4
paucity [1] 70/4
Paul [1] 11/1
pause [4] 10/3 26/5
87/5 122/19
pausing [2] 39/8 75/9
pay [4] 34/7 40/3
80/9 88/24
PEAK [15] 100/15
100/19 131/13 131/16)
151/23 153/20 172/24)
172/25 175/16 175/20}
176/16 176/19 176/23}
177/13 197/10
PEAK/KEL [1]
151/23
PEAKs [17] 97/25
98/22 98/23 100/11
114/15 138/9 138/16
139/2 144/13 151/20
157/8 172/19 172/21
173/6 197/4 199/10
202/25
PEAKs/KELs [1]
151/20
Pearce [18] 5/6 5/8
5/16 6/4 6/12 6/19
10/7 12/9 12/14 15/5
15/9 16/6 25/12 26/6
28/8 38/19 48/4 48/7
Pearce/Womble [1]
6/4
peer [3] 92/25 204/21
206/7
peeved [1] 18/22
pen [5] 64/13 64/13
64/13 64/17 64/19
pens [1] 64/18
penultimate [2]
10/22 176/21
people [57] 9/17
11/13 11/21 16/13
53/11 53/13 55/19
70/8 79/2 88/11 88/15
88/23 92/17 93/25
95/18 95/23 99/23
101/21 102/5 102/6
102/6 102/7 102/9
105/7 105/8 105/10
105/14 105/22 106/10}
106/19 110/4 110/18
110/19 111/8 111/17
111/19 112/17 117/1
127/17 178/18 188/4
192/11 192/16 196/12
197/23 201/6 201/10
202/19 203/19 203/24
204/17 204/22 204/25)
205/9 207/24 210/18
210/21
per [1] 145/20
perceived [2] 61/4
61/4
perceiving [1] 62/25
perception [1] 74/6
perfect [2] 29/17
206/22
perfectly [4] 102/9
104/9 108/7 127/4
perform [1] 204/4
performed [2] 162/13}
203/24
performing [1]
202/24
perhaps [10] 103/23
106/22 108/18 109/10}
118/23 120/8 157/23
188/10 190/19 196/10}
period [10] 7/14 8/10
8/25 9/11 9/23 42/19
89/14 96/12 110/20
185/24
periodically [1] 18/25
permanent [1]
176/14
permanently [4] 93/8
93/10 159/17 177/4
permission [3] 52/22
177/9 191/7
permissions [1]
175/21
person [16] 44/7
53/14 57/7 61/13
61/14 61/19 62/7
86/16 101/19 186/18
187/3 187/12 192/10
200/16 204/3 206/4
personal [3] 8/22
186/19 191/5
personally [6] 4/12
63/7 83/9 110/25
112/21 196/6
personnel [1] 203/23
perspective [2]
54/23 154/11
persuaded [1] 62/19
Pete [27] 109/15
111/7 112/3 113/19
114/3 114/7 117/16
117/20 118/21 119/25}
121/8 123/23 124/3
125/17 125/19 137/24}
138/4 138/7 139/8
139/12 140/2 140/10
142/12 198/20 205/24}
206/24 207/12
Peters [2] 189/13
189/13
phase [4] 4/13 4/14
4/15 14/21
Phase 4 [3] 4/13 4/15I
14/21
philosophy [1] 91/25
phone [3] 45/17
85/12 174/17
phrase [4] 57/22 72/5]
203/23 204/8
PIC [1] 76/24
pick [1] 45/17
picked [3] 88/9
170/25 208/24
picking [2] 25/12
88/15
picture [9] 7/20 7/25
14/14 35/18 55/19
55/21 59/13 76/24
76/25
pill [4] 35/21
PinICL [1] 153/20
place [13] 7/13 7/23
19/6 19/8 39/17 41/8
78/2 95/11 107/12
115/1 119/16 143/16
143/20
placed [4] 4/18 12/24
96/18 205/2
places [3] 95/22
133/18 172/6
plain [1] 69/8
plan [6] 26/18 26/19
63/20 63/24 196/24
198/17
planks [1] 60/14
planned [1] 4/14
planning [1] 168/21
play [2] 36/16 111/11
playing [2] 3/13 21/2
please [196] 1/13
1/22 1/25 2/6 2/8 2/21
2/23 3/3 3/7 3/8 3/15
7/7 718 7/16 9/25 10/1
10/18 16/3 16/3 16/20
20/1 21/10 22/3 25/10)
26/2 28/2 28/19 29/16I
29/17 32/3 34/12 36/6I
36/25 37/5 37/23 42/8
42/9 46/14 46/23 47/6)
58/10 61/23 64/1 64/3}
65/17 66/18 66/20
69/15 69/15 70/3
72/12 73/15 73/16
74/21 76/5 76/5 76/19I
77/4 79/13 79/19
81/21 82/2 84/14
84/15 87/18 89/10
90/22 91/2 91/10
91/22 92/7 94/8 94/18
94/20 94/22 97/16
97/17 101/4 106/23
108/21 109/10 109/12)
112/22 113/24 113/25)
115/10 115/15 115/21
115/23 116/5 119/11
121/4 121/5 121/15
123/20 125/12 125/13)
125/14 126/2 126/5
127/20 129/13 129/20)
129/22 131/4 131/25
133/8 134/13 134/22
137/13 137/15 138/2
139/25 141/10 141/12)
141/15 142/11 146/18)
146/20 147/22 147/23}
149/10 149/11 149/13)
149/14 149/19 149/24)
150/3 151/12 151/13
151/13 152/15 152/18}
152/24 153/8 153/18
158/14 158/18 158/18)
160/5 161/2 161/15
161/16 162/3 162/5
162/9 162/25 163/1
163/10 163/14 164/4
164/6 166/2 166/19
(76) page 2... - please
Pp
please... [42] 168/12
168/14 168/19 169/11
170/9 170/14 171/22
171/23 171/24 173/15
175/5 175/7 175/12
176/1 178/4 178/5
178/9 178/11 178/13
179/7 180/8 180/19
181/12 183/1 183/2
183/3 184/1 184/23
191/15 196/10 197/17
198/6 206/17 206/20
207/2 207/11 208/1
208/4 208/8 208/14
208/17 208/18
plough [1] 52/3
plus [1] 111/9
pm [8] 70/15 90/16
90/18 153/2 153/4
193/2 193/4 210/25
POID [1] 10/24
point [59] 7/10 16/25
18/19 18/20 19/5
19/19 20/8 21/6 21/9
23/4 23/12 24/22 27/3
27/4 30/23 33/3 35/8
40/14 41/14 45/9
45/18 46/3 48/11
48/25 49/2 49/16
52/12 52/13 57/8 61/6
63/25 65/11 65/22
68/4 70/25 71/20 72/2I
75/13 80/12 80/15
81/20 83/3 86/8 88/13,
98/9 104/2 107/6
108/13 116/8 128/17
129/1 143/2 145/6
153/23 157/4 157/22
159/20 164/17 210/12)
pointless [1] 48/22
points [11] 21/24
64/23 79/13 83/16
94/8 115/18 116/14
116/18 129/23 176/8
188/16
poison [1] 35/21
POL [11] 4/20 18/7
65/4 66/3 66/4 114/13
164/19 164/20 167/19)
202/1 203/14
POL's [2] 66/6
166/14
POL-TC [4] 167/19
POL00006397 [1]
79/14
POL00022969 [1]
73/15
POL00069612 [1]
43/16
POL00069955 [1]
46/14
POL00070480 [1]
21/10
POL00070496 [1]
16/3
POL00070850 [1]
37/23
POL00070910 [1]
29/16
POL00071202 [1]
36/6
POL00081490 [1]
42/2
POL00119895 [1]
28/2
POL00142517 [1]
10/2
POL00142534 [1]
10/18
POL00330036 [1]
74/21
POL00416040 [1]
200/14
policy [1] 130/23
pondered [1] 25/25
pondering [1] 86/6
portrayed [2] 85/22
86/1
posing [1] 209/10
position [13] 19/11
34/1 49/21 52/14
52/23 65/15 72/4
74/16 76/16 82/19
86/7 159/5 202/15
positive [4] 54/20
54/20 54/21 169/9
possibility [4] 65/25
66/6 139/1 174/25
possible [28] 16/16
42/12 43/23 47/8
47/16 47/19 55/14
65/23 66/7 73/8 102/9)
102/16 108/7 117/18
117/19 117/25 118/23}
127/4 128/25 129/3
129/5 130/16 141/6
141/9 150/23 166/10
191/15 207/15
possibly [22] 65/22
100/10 100/20 112/3
118/25 119/2 120/7
128/14 133/15 146/3
156/18 157/9 157/17
170/17 170/19 179/14)
180/18 187/13 189/3
194/22 199/21 200/3
post [151] 6/1 6/5 6/7
6/10 6/12 6/24 7/2
7/14 7/23 8/9 8/11
8/14 8/17 8/19 8/23
8/24 9/2 9/12 9/18
9/20 10/9 10/12 10/15
11/5 11/12 11/12
11/15 14/23 15/2 15/5)
15/16 17/14 17/17
18/11 26/23 26/23
27/8 27/14 28/16
29/23 31/9 31/18
32/10 32/11 32/13
32/16 32/19 33/6 34/1
34/9 35/19 36/10
37/14 37/19 38/14
40/2 47/20 49/25
50/18 55/12 55/13
58/20 58/21 60/2
60/10 63/16 65/5 65/9
68/23 70/22 72/23
74/6 79/22 79/24 80/3
80/4 80/9 80/11 80/13
85/22 86/1 86/10 88/1
93/5 93/11 93/16 94/6
94/19 94/22 95/1 95/7
96/13 99/11 99/12
99/17 101/2 101/8
101/15 102/3 102/7
102/13 102/25 104/3
104/4 104/21 105/2
105/8 105/15 108/20
108/23 109/2 109/17
109/18 109/23 111/5
111/11 111/24 113/1
114/8 114/12 115/3
117/11 118/17 124/17I
131/23 136/21 137/22
139/2 139/16 139/22
155/2 157/24 158/8
158/23 163/15 165/8
166/8 166/10 168/6
173/14 175/14 179/8
180/11 180/22 181/2
181/15 189/14 189/25I
194/1 202/16 203/20
post-post-set [1]
26/23
potential [7] 18/12
18/15 21/8 27/4 30/19
46/6 50/9
potentially [7] 45/8
56/4 114/9 148/14
157/16 161/1 189/7
PR [5] 77/11 77/12
77/16 78/11 78/14
practical [1] 172/17
practically [1] 204/3
practice [3] 5/23
24/23 25/4
practised [1] 5/20
practitioner [6] 12/24
13/3 13/9 13/16 13/20}
14/3
pre [3] 54/24 55/2
209/24
pre-8 March [1] 55/2
pre-Common [1]
54/24
pre-written [1]
209/24
precision [1] 8/19
predecessor [1]
153/20
prefer [3] 51/13
132/12 132/18
preference [1]
176/13
prefers [1] 70/13
prejudice [1] 24/21
preparation [3] 23/22)
112/19 178/11
prepare [2] 38/22
82/7
prepared [7] 10/24
16/16 23/11 24/13
44/12 164/11 180/3
preparing [11] 23/14
37/11 41/4 41/7 56/20)
56/24 57/3 69/6 83/2
83/4 203/9
present [3] 41/6
93/13 101/11
presented [1] 36/8
presently [1] 113/5
preserved [1] 92/19
press [1] 82/25
pressed [2] 51/14
129/14
pressing [1] 174/21
pressure [2] 74/4
86/22
pressurised [1]
207/19
presumably [24]
11/15 17/11 18/6
22/16 27/14 31/11
58/25 59/3 62/5 64/17
65/18 68/14 76/24
107/12 117/13 124/2
132/14 140/7 144/19
155/14 166/15 177/8
180/17 193/20
pretty [4] 18/22
114/11 116/25 139/11
prevarication [2]
63/5 63/21
previous [11] 95/8
119/18 136/4 153/17
159/10 159/16 159/18
167/18 168/17 177/1
207/7
previously [8] 93/22
93/23 135/20 136/1
138/19 144/1 152/7
157/15
Price [1] 87/3
primarily [1] 5/25
Prime [8] 55/18
61/24 114/2 121/6
122/13 123/4 123/15
123/25
Prime's [2] 153/13
153/18
principal [2] 95/25
110/10
principle [3] 96/14
147/10 204/21
printed [2] 37/1
76/20
prior [5] 6/25 54/18
75/11 175/5 176/10
Private [1] 16/15
privilege [1] 58/17
privileged [10] 16/15
48/22 163/18 165/14
167/20 168/8 168/24
169/20 171/15 175/4
privileges [1] 163/5
proactive [2] 9/19
14/8
probably [32] 8/17
9/9 11/6 11/17 11/17
22/12 24/9 25/19 44/3
45/12 67/10 68/4 84/4
85/11 88/10 94/14
98/17 99/22 100/2
106/1 108/3 112/2
113/19 120/22 122/13}
123/19 140/21 179/1
188/2 188/7 194/18
198/1
problem [11] 3/10
34/14 34/22 43/6
43/25 47/16 131/10
131/17 141/23 145/12)
150/19
problems [8] 27/11
35/25 42/10 42/12
42/25 43/24 46/6 47/8
procedural [4] 71/20
71/22 72/2 72/10
procedure [5] 98/13
147/3 165/5 165/21
181/18
procedures [3] 97/23)
132/7 163/8
proceeding [1] 74/10
proceedings [24] 6/3
6/18 10/20 11/4 11/5
12/22 19/23 20/22
34/4 34/25 42/6 53/3
53/7 54/17 57/11
57/14 88/19 189/22
190/2 201/3 201/24
202/18 203/7 206/16
proceeds [1] 135/3
process [25] 14/4
77/25 88/1 95/2 95/12)
96/24 98/3 98/4 98/6
98/11 107/6 147/4
166/17 166/24 184/25)
186/4 195/4 196/1
196/3 197/14 204/16
206/6 206/8 206/12
209/13
processes [8] 97/15
97/23 103/14 130/10
147/18 163/7 164/18
200/11
processing [1]
102/24
(77) please... - processing
Pp
Procurator [1]
189/10
produce [3] 92/15
196/25 198/18
produced [9] 10/25
12/2 81/17 102/25
114/16 169/8 169/16
181/19 203/13
product [1] 131/18
professional [1]
91/21
progress [3] 100/18
107/13 206/10
project [3] 137/16
137/16 137/17
promote [1] 72/11
prompted [3] 100/10
151/6 187/19
pronunciation [1]
155/18
Proofs [1] 38/21
proper [3] 8/21 86/19
197/14
properly [5] 4/22
182/7 182/8 182/13
199/2
property [1] 185/18
proposal [2] 133/7
166/24
propose [2] 1/11
79/12
proposed [2] 182/22
183/7
proposing [1] 168/21
proposition [3] 35/10
38/24 56/4
proprietary [1] 118/9
prose [1] 194/24
prosecuted [1] 11/13
prosecutes [1] 13/10
prosecutions [3]
11/16 12/11 14/13
prospects [1] 75/19
proud [1] 6/16
proved [2] 107/11
141/19
proven [1] 144/15
provide [33] 31/9
38/17 42/5 102/12
105/13 108/20 109/4
112/6 119/9 124/17
125/20 126/2 127/25
134/9 137/10 144/20
148/7 149/19 151/1
151/25 155/15 160/6
160/9 165/1 173/25
181/6 181/24 189/5
192/19 196/23 198/16
199/25 207/4
provided [48] 37/14
56/7 75/24 76/4 111/1
112/20 117/10 118/19}
118/24 119/5 119/22
120/16 120/22 120/24}
121/1 123/11 124/21
125/8 126/9 126/19
127/4 136/5 136/20
139/22 144/3 153/25
154/14 155/2 155/6
155/21 156/2 156/3
156/11 157/13 157/19)
160/23 161/4 168/23
174/14 178/1 178/14
179/6 179/23 180/11
180/16 189/25 194/1
207/6
provides [3] 95/6
118/7 208/2
providing [15]
111/15 112/13 118/16)
119/20 139/15 142/14)
143/13 143/15 146/5
179/16 182/18 193/12)
201/21 202/25 203/4
proving [2] 32/13
198/16
publicity [1] 35/5
published [2] 3/25
4
pulling [1] 20/19
purely [2] 27/23
27/25
purported [1] 142/18
purpose [9] 22/16
45/5 52/18 60/8 95/17
95/18 95/25 113/11
176/18
purposes [5] 16/16
33/13 52/17 96/5
189/18
pursue [6] 11/11
12/3 15/6 31/2 33/24
78/20
pursuing [6] 11/13
11/16 29/23 30/6 31/5)
31/19
push [1] 72/8
pushed [1] 71/16
pushing [1] 70/23
put [15] 7/23 19/4
27/19 31/6 39/11 43/1
43/12 45/25 74/4
86/22 88/13 105/20
178/20 192/19 193/21
putting [6] 20/11
22/18 84/21 152/3
183/15 193/15
QC [3] 3/16 49/1 62/4
qualification [1]
94/12
qualifications [3]
94/9 94/16 112/5
qualified [1] 5/4
quantum [1] 80/9
queried [1] 116/23
queries [4] 146/14
147/14 151/5 202/1
query [11] 140/1
141/11 149/12 154/23}
158/5 163/17 166/5
168/16 175/3 176/1
177124
querying [2] 134/38
171/9
question [40] 11/10
11/18 12/14 12/17
12/25 22/10 23/18
46/14 53/14 54/22
59/17 80/21 83/17
86/6 100/2 104/25
121/17 123/15 126/14
130/13 136/24 137/9
141/17 146/6 148/10
149/18 162/10 162/19}
166/5 173/18 175/10
190/7 190/20 191/1
191/7 192/10 194/15
199/5 202/10 205/2
questioned [13] 1/8
87/13 90/24 100/6
191/24 193/9 200/24
212/4 212/6 212/10
212/12 212/14 212/16
questioning [1]
210/8
questionnaire [6]
115/4 115/14 122/8
122/25 158/7 158/24
questions [50] 4/2
5/3 39/12 41/13 84/5
87/2 87/6 89/8 91/1
91/21 94/18 111/15
111/18 138/7 141/7
146/25 147/2 147/24
148/4 153/19 163/3
164/15 165/2 174/14
178/19 178/19 178/20
178/24 179/5 189/12
190/14 190/17 190/24
191/9 191/11 191/14
191/22 192/2 200/21
200/25 201/1 201/4
201/7 203/1 207/9
209/3 209/10 209/11
210/13 210/17
quite [29] 7/3 19/1
26/24 33/10 43/12
44/3 57/23 63/6
102/20 109/18 110/20
112/4 122/22 125/6
126/19 152/10 168/6
179/15 185/12 187/2
187/5 187/8 187/18
193/14 194/5 195/8
197/19 207/20 209/17]
quote [1] 158/25
quotes [2] 56/2 85/2
R
raise [7] 14/12 46/7
100/15 116/14 136/24}
138/17 188/17
raised [18] 20/7
47/14 47/17 49/20
50/9 55/4 56/17 62/4
75/12 121/17 123/15
138/10 150/4 150/6
158/7 174/14 176/17
176/23
raises [1] 46/5
raising [3] 128/9
135/24 150/20
ran [1] 116/10
randomly [1] 205/8
range [1] 131/10
rapidly [1] 57/16
rare [1] 166/13
rarely [1] 164/25
rather [14] 22/17
25/1 70/23 97/22
99/16 103/15 108/15
121/23 122/4 128/21
129/2 142/4 156/17
194/25
rational [1] 44/4
re [2] 2/18 85/21
re-read [1] 2/18
reached [1] 192/13
read [22] 1/19 2/18
2/25 3/11 3/16 11/6
21/23 23/14 34/2
34/10 82/6 116/22
120/3 120/10 132/14
140/7 144/19 165/6
179/17 181/13 194/11
194/16
reading [9] 30/8
30/14 30/23 45/12
56/20 59/20 60/24
71/5 7118
reads [9] 62/19 83/19)
87/22 97/17 119/12
121/11 125/18 180/20
183/6
real [4] 46/1 65/22
65/25 66/6
realisation [1] 197/1
realisation/remembe
ring [1] 197/1
realistically [1] 170/4'
really [36] 12/24 19/3
23/2 27/22 36/2 44/6
45/10 63/6 68/3 78/13)
79/4 85/8 85/13 85/14
86/16 89/1 89/6 98/4
98/25 105/21 106/9
114/24 119/24 132/20}
133/1 139/10 146/13
179/13 188/7 190/20
193/23 194/5 195/5
199/18 201/18 210/1
reason [22] 33/24
96/8 100/9 106/8
108/11 118/22 122/2
142/4 143/10 143/11
143/13 143/19 143/22!
144/25 145/18 162/22)
182/3 188/23 193/18
193/21 197/13 209/4
reasonable [2]
170/12 191/19
reasonably [1] 18/25
reasoning [2] 197/6
199/14
reasons [9] 35/4
50/11 58/18 71/22
95/14 99/9 171/23
176/11 197/13
reassurance [1] 31/9
rebooting [1] 23/19
recall [67] 7/12 18/14
25/15 28/14 29/13
31/8 31/16 32/7 33/3
36/20 37/18 59/23
65/8 66/10 67/7 67/25
71/6 75/16 76/10
76/15 78/10 102/24
104/10 106/14 107/20)
107/25 114/25 117/21
118/16 119/20 124/19)
125/20 128/9 128/11
129/25 144/5 150/18
151/3 151/18 158/7
159/13 160/3 162/1
162/16 169/6 169/12
178/2 178/22 179/7
179/10 179/16 180/6
181/21 186/25 189/4
189/9 189/24 190/8
192/6 200/19 202/13
204/6 205/20 205/24
206/6 206/7 210/1
receipt [1] 42/17
receipts [1] 101/7
receive [7] 46/17
146/14 149/5 151/5
165/25 188/25 189/16
received [17] 43/18
46/4 102/6 102/6
121/13 122/24 124/16
131/6 132/9 140/1
141/10 147/21 151/23)
175/2 177/24 181/14
200/5
receiving [1] 36/20
recent [3] 108/19
156/3 157/19
recently [8] 2/15 11/7I
28/3 36/21 36/24
75/24 76/4 186/25
recipient [1] 107/2
recipients [1] 115/11
recognised [2] 94/14
190/16
recognises [1] 75/5
(78) Procurator - recognises
R
recognition [1]
176/13
recollect [1] 174/16
recollection [10]
79/7 88/17 105/7
114/22 116/15 151/8
168/10 186/9 189/2
193/12
recommencement [1]
7/21
recommend [1]
71/11
recommendation [2]
70/11 73/3
recommendations
[2] 23/4 70/21
recommended [1]
73/7
recommending [1]
7415
reconstructing [2]
60/5 60/23
record [7] 1/19 98/5
98/7 102/19 127/3
167/13 196/3
recorded [6] 101/10
142/8 166/9 172/8
17718 1814/5
recording [1] 170/7
records [6] 47/9 67/2
92/19 162/21 162/21
197/11
recovered [1] 135/5
recovery [4] 7/5 11/8
12/10 12/15
recruited [1] 93/12
rectified [1] 25/22
rectify [1] 26/22
rectifying [1] 25/13
recusal [42] 4/8 6/2
9/3 51/3 52/12 52/20
53/4 56/10 56/14
56/21 56/22 57/12
58/6 60/2 60/11 61/2
63/1 63/18 65/10
66/12 71/19 72/11
73/24 74/2 76/11
76/16 78/20 79/22
79/24 80/6 80/8 80/11
80/13 80/19 82/7
82/20 83/7 83/25 85/3
85/24 86/21 89/15
recuse [4] 71/16
71/25 72/3 77/18
recused [1] 56/5
recusing [1] 61/10
red [4] 78/10
redacted [3] 58/16
58/17 58/24
redaction [1] 58/19
redactions [1] 58/21
redrafting [1] 183/12
refer [7] 40/4 52/18
70/19 97/2 147/14
149/13 183/23
reference [18] 1/18
28/20 131/14 134/19
138/17 152/16 152/19)
153/8 161/18 162/4
164/22 164/24 173/20)
175/19 178/4 178/7
199/23 200/12
referenced [1]
168/17
references [2]
131/16 144/13
referred [13] 38/14
62/1 114/4 136/1
151/20 154/14 154/16)
154/22 165/1 167/17
167/17 171/18 185/4
referring [31] 10/11
23/8 28/15 49/16
61/18 62/14 62/17
64/7 64/24 65/19 76/7
81/23 81/25 95/20
98/11 101/11 126/25
137/8 150/22 166/19
167/4 167/7 167/15
167/20 167/22 168/1
170/21 182/11 195/15)
195/16 205/13
refers [8] 36/17
38/12 43/21 43/25
46/24 69/4 73/21
182/13
reflect [4] 26/25
42/15 119/15 130/9
reflected [1] 117/19
refresh [2] 14/21
160/7
refusing [1] 52/22
regarded [2] 156/23
195/18
regarding [2] 85/6
181/4
regards [1] 128/7
regret [1] 4/17
regular [2] 150/19
152/24
regularised [1] 26/7
regularly [3] 17/3
98/24 164/22
regulatory [1] 6/22
reiterate [1] 4/6
rejected [1] 26/16
relate [7] 22/10 58/21
97/19 103/6 122/17
164/15 192/2
related [12] 38/4
100/11 100/23 103/10;
103/13 124/6 126/12
130/19 144/14 144/22)
153/19 157/8
relates [4] 114/16
158/6 161/3 163/17
relating [29] 7/10
9/25 18/3 19/16 20/17
40/5 97/8 97/11
102/21 103/14 104/12
106/5 107/7 117/22
124/18 124/22 124/25)
126/10 130/10 146/25}
151/25 153/23 157/6
162/5 163/3 168/7
168/16 195/10 195/23
relation [22] 18/4
18/11 30/2 37/20
52/15 53/22 108/15
114/12 119/7 130/23
135/7 138/11 152/4
159/1 162/6 162/9
163/6 184/14 184/19
189/5 189/13 196/15
relations [1] 68/23
relationship [12] 6/5
7/15 8/18 8/22 9/10
9/13 9/15 9/20 10/15
16/24 17/6 87/16
relatively [4] 28/3
88/6 185/9 209/14
release [7] 130/1
130/2 131/10 141/22
144/15 144/23 145/13
released [1] 141/18
relevance [2] 58/17
130/21
relevant [23] 12/11
38/17 40/3 52/21
69/13 87/25 88/13
105/25 106/16 113/2
114/9 119/16 125/11
127/23 139/15 144/13
152/21 162/5 163/7
169/5 169/25 175/16
176/16
reliability [2] 12/17
13/18
relied [5] 11/15 12/22
42/6 197/3 199/9
relies [1] 13/6
reluctance [2]
150/11 150/15
rely [3] 25/2 142/18
158/25
relying [1] 50/1
remain [2] 5/18 93/13
remained [2] 48/20
78/2
remedial [5] 157/14
160/24 172/5 172/6
173/2
remember [28] 12/7
17/3 22/6 40/17 44/10
47/22 50/22 50/25
63/3 63/6 71/5 87/24
88/6 100/9 103/9
105/21 114/24 114/25]
127/16 166/23 168/4
187/2 187/5 187/8
189/8 193/22 196/5
204/7
remembered [1]
198/25
remembering [3]
26/10 197/1 199/6
remote [12] 161/4
161/25 162/5 163/3
163/7 164/16 168/5
169/23 195/3 195/7
195/18 195/23
remove [2] 166/8
176/24
removed [1] 176/10
removing [1] 176/14
reparation [1] 178/14
repeat [2] 97/10
124/3
rephrase [3] 11/10
30/23 59/16
replaced [1] 187/9
reply [2] 49/5 126/6
report [33] 11/2 16/8
20/24 39/5 39/22
39/25 40/2 40/8 40/10)
40/10 43/18 44/12
46/13 46/15 47/13
47/20 48/3 48/7 48/9
48/12 48/12 48/17
48/20 48/22 48/23
49/4 49/8 49/24 50/9
151/21 154/17 203/5
204/9
reporting [4] 97/8
97/11 97/19 97/21
reports [16] 23/20
24/15 24/20 24/22
37/13 102/25 103/15
103/25 108/3 108/4
193/13 193/15 193/22)
194/9 203/5 203/6
repositories [1] 97/2
repository [7] 95/4
96/8 96/22 99/14
133/14 133/16 135/20
represent [1] 67/18
representative [1]
41/2
representatives [2]
40/23 190/16
reputation [1] 146/11
request [20] 34/12
34/13 110/15 124/17
125/24 151/3 161/12
161/17 161/19 161/22)
161/25 162/4 164/9
164/12 168/14 175/8
179/12 181/14 183/25}
184/11
requested [4] 165/4
168/7 181/24 183/16
requests [14] 19/19
102/2 102/7 102/21
109/1 109/3 125/12
137/21 161/20 163/23}
179/14 185/7 188/25
207/18
require [3] 38/18
148/15 172/18
required [5] 113/1
114/8 138/24 167/1
181/19
requires [1] 169/2
research [2] 147/17
147/20
reservation [1]
150/23
reservations [3]
150/8 150/14 150/16
resided [1] 135/12
resolved [2] 15/21
175/18
resource [2] 188/3
188/10
respect [4] 8/24
28/22 37/14 182/7
respective [1] 38/22
respond [5] 102/2
147/21 159/5 173/13
207/18
Responded [1] 209/3)
responding [3] 20/11
195/10 206/16
response [28] 37/7
46/6 70/14 70/16
125/22 126/5 131/6
132/1 132/9 137/10
140/1 141/10 147/12
147/22 149/4 149/23
151/2 154/23 157/15
159/6 165/2 165/25
166/5 170/9 171/22
174/13 176/1 207/14
responses [5] 109/4
147/20 147/24 152/3
185/7
responsibilities [1]
40/20
responsibility [6]
12/19 13/19 14/11
53/16 95/1 186/23
responsible [4]
99/18 111/4 111/25
180/23
responsive [4]
161/22 163/22 164/11
195/5
rest [3] 56/23 116/22
178/17
result [1] 199/5
results [4] 169/9
171/18 172/12 174/3
resume [3] 90/14
192/24 210/19
retain [1] 190/5
retained [4] 95/9
96/9 159/18 159/21
retainers [1] 8/4
(79) recognition - retainers
R
retaining [1] 189/17
retention [2] 130/23
192/2
retrievable [11]
134/2 134/3 149/1
149/2 152/8 152/10
153/24 154/2 154/5
154/15 154/21
retrieval [2] 182/12
184/10
retrieve [5] 135/1
138/14 144/18 154/19}
173/5
retrieved [11] 132/25
134/10 135/8 135/16
136/20 147/11 148/11
148/15 148/16 148/23
152/5
retrospective [1]
172/2
return [2] 172/17
178/8
reveal [1] 132/22
reversals [1] 163/11
review [13] 42/12
42/20 47/4 115/16
116/9 117/1 189/19
196/18 198/12 204/21
204/22 206/7 207/3
reviewed [2] 46/19
120/10
reviewers [1] 92/25
reviewing [1] 177/13
reviews [1] 92/23
Riby [1] 10/12
Richard [3] 23/5 23/5
196/15
Richardson [1] 9/22
rid [4] 26/19 33/11
35/1 35/25
right [129] 2/23 10/4
11/5 11/14 16/4 26/14}
33/9 38/11 39/14
40/18 51/4 51/11
51/15 51/19 56/16
56/25 57/15 63/13
64/12 77/3 81/6 81/8
82/20 87/21 90/1 91/5
92/1 92/5 93/2 93/6
93/14 94/9 95/10
95/16 96/12 97/5 97/6
97/9 101/23 103/2
104/15 108/16 110/8
110/11 112/24 113/13}
113/16 113/21 115/4
117/7 120/19 121/2
124/11 124/25 134/1
134/21 136/12 137/25)
145/19 146/16 147/15
147/18 149/7 149/8
153/21 156/8 156/16
160/11 160/12 160/25
161/8 161/13 161/14
162/24 163/21 163/23)
164/2 164/12 166/25
168/9 169/4 169/19
169/21 170/7 170/23
170/24 171/2 171/7
171/14 173/17 176/5
177/18 178/10 180/12)
181/10 183/11 184/16)
185/2 185/13 185/19
191/3 191/13 191/16
191/18 192/4 192/15
192/24 193/17 195/2
195/20 195/24 196/8
198/4 199/8 200/4
200/20 201/9 201/13
202/8 202/24 203/19
204/2 204/13 204/16
205/17 205/19 209/7
210/14 210/23
rights [5] 165/15
165/22 167/21 171/15)
185/18
Riposte [1] 130/19
risk [4] 16/12 70/25
78/2 78/13
risks [1] 74/10
RM [1] 18/5
Robinson [1] 200/8
robust [2] 32/1 32/12
robustness [1] 4/21
role [32] 16/14 20/2
92/9 93/2 93/13 94/5
94/19 94/23 94/25
99/24 101/1 104/4
108/25 111/10 111/21
137/15 169/24 172/24)
176/10 176/14 176/14)
176/24 177/2 177/3
177/9 177/12 178/13
178/16 190/4 201/5
201/16 204/4
roles [2] 109/14
113/18
Roll [2] 196/15
196/15
room [2] 87/7 121/15
Rose [1] 29/25
rough [2] 196/25
198/18
route [1] 72/9
routed [1] 176/21
row [1] 118/6
Royal [2] 18/6 18/7
rule [1] 147/3
run [4] 53/12 91/7
169/14 169/17
running [1] 49/3
runs [1] 2/1
s
$80 [1] 138/23
$90 [4] 129/24
131/18 141/18 144/15
SA [2] 59/3 61/11
safely [1] 121/13
safety [1] 88/4
said [59] 2/15 17/4
17/13 18/24 23/22
35/4 41/4 43/23 49/15
60/17 66/10 67/2 67/7
67/25 68/2 68/8 69/23
73/6 75/4 75/21 76/10
76/13 76/15 82/14
82/15 82/18 84/5
85/13 85/13 122/9
123/2 125/4 128/4
132/6 132/20 133/9
133/13 140/20 140/22
145/11 152/7 154/6
154/9 155/20 159/3
173/19 173/24 174/17
174/19 177/6 187/1
187/11 194/5 199/7
199/22 200/9 201/5
203/16 209/13
sale [1] 42/17
salient [1] 83/16
same [28] 5/14 18/7
20/19 24/7 37/7 46/25
58/10 64/2 66/19
84/15 89/14 105/22
115/11 126/20 132/21
134/23 135/23 137/12
138/10 138/11 143/11
143/23 155/25 184/8
198/11 198/16 199/21
208/19
sample [5] 196/18
196/24 197/10 198/12
198/17
sat [4] 35/21 36/2
104/8 127/18
saving [1] 154/7
saw [8] 36/21 62/9
78/11 116/21 168/17
187/10 198/11 199/19}
say [118] 1/9 3/5 5/1
6/6 6/23 7/11 8/21 9/5
11/17 12/13 14/10
14/12 16/21 17/8
19/19 19/25 20/21
22/2 23/8 24/7 24/9
25/3 33/5 37/9 39/8
43/2 50/13 50/15
50/22 53/2 54/20 55/9
55/23 56/10 56/12
57/19 58/19 59/12
60/1 60/10 61/11 62/3)
62/16 63/23 64/20
70/20 72/3 82/12 85/9
86/3 94/24 95/10 97/7
97/22 98/21 100/7
100/20 100/23 101/5
102/15 102/24 107/9
107/23 108/12 108/17
110/8 110/10 113/5
115/20 116/12 117/21
117/25 118/22 120/2
123/16 127/9 129/10
129/16 129/21 131/1
132/1 138/6 139/4
140/11 144/10 148/24)
150/2 152/4 152/9
152/22 154/13 155/8
155/24 159/8 159/12
161/5 164/14 169/14
169/16 169/24 171/6
173/7 173/16 173/22
176/7 176/25 179/2
179/3 182/2 183/4
183/23 184/5 186/13
187/5 195/14 203/22
204/20 205/1
saying [47] 11/23
11/25 19/2 20/13
22/13 27/9 27/10 29/5)
30/7 30/11 33/21
33/23 44/21 65/22
66/2 66/9 66/13 68/6
69/9 71/9 72/5 76/17
77/20 82/22 82/22
82/25 85/17 85/18
85/24 103/21 103/22
134/17 136/18 140/5
141/21 141/24 142/23}
143/9 145/16 167/18
170/2 173/8 174/10
175/20 186/20 198/24,
206/2
says [82] 2/24 3/4 3/9
3/15 10/22 18/1 20/16)
21/12 21/13 24/6
25/10 29/22 30/16
31/6 32/4 34/19 36/13}
37/5 37/5 39/9 39/20
39/23 40/8 42/10
43/21 44/1 45/15
58/23 58/25 59/13
61/12 62/11 64/4 64/7
64/23 65/4 65/18
67/14 67/21 70/10
72/15 72/22 73/21
75/17 76/24 77/9
77/16 78/5 82/10
84/16 85/2 100/15
123/4 128/3 131/7
131/19 134/12 134/24}
140/2 141/16 142/15
146/21 149/24 151/15}
155/5 156/12 156/23
158/21 160/19 166/2
167/5 170/10 171/3
171/25 172/11 173/1
173/3 175/9 175/15
196/17 198/9 207/13
scale [2] 18/18 204/4
scan [2] 115/9 184/7
schedule [1] 82/17
scheduled [1] 28/20
Scheme [1] 104/21
scope [1] 174/4
Scotland [1] 189/11
Scottish [1] 189/1
screen [3] 10/5 44/19
64/3
screen-freezing [1]
44/19
screenshot [1]
124/11
scribbled [2] 59/5
59/6
scribbles [2] 76/8
85/12
scribbling [2] 67/13
68/3
scripts [2] 190/5
192/3
scroll [27] 10/6 76/19)
76/21 123/20 125/14
127/20 129/13 131/25)
138/2 139/25 142/11
146/19 151/13 153/17)
158/18 161/16 162/9
162/25 166/1 169/11
170/9 171/3 196/9
198/5 198/8 208/1
208/4
search [9] 133/18
155/12 169/17 170/12)
170/25 171/5 171/11
172/13 172/15
searchable [4] 147/9
148/11 148/13 148/17)
searched [1] 127/5
searches [4] 155/11
169/15 171/13 174/5
searching [1] 169/8
sec [1] 134/15
second [26] 2/5 3/3
3/8 3/21 4/1 4/7 6/2
21/12 55/8 65/22
76/22 81/20 104/22
107/5 113/25 115/17
126/9 153/23 159/9
165/11 167/17 176/7
184/11 191/8 191/25
206/14
secondly [2] 176/19
189/21
section [5] 47/12
162/5 165/6 181/11
183/6
section 6.2 [1] 47/12
sections [2] 116/23
207/8
security [4] 175/13
179/20 180/23 180/24I
see [89] 2/1 9/3
16/10 16/15 16/18
17/25 21/11 26/3
28/19 36/8 41/5 42/20
46/24 51/11 58/11
58/12 58/23 59/23
62/2 63/12 64/22
65/11 69/18 73/13
(80) retaining - see
Ss
see... [65] 77/8 77/10
81/23 82/3 83/18
84/16 87/7 90/19
91/13 98/8 107/5
116/16 116/22 118/3
120/4 127/11 129/22
131/4 131/5 131/25
132/11 133/23 134/15}
134/19 135/23 137/13)
138/3 140/1 141/15
142/12 147/22 147/23
149/15 149/23 150/10}
152/2 152/12 153/5
153/13 157/10 160/10
161/17 162/15 163/18
168/13 169/5 173/15
173/25 175/7 180/14
184/5 185/10 186/9
190/25 193/5 194/23
196/11 198/9 199/23
207/2 207/9 208/2
208/23 209/5 209/13
seeing [2] 35/12
186/25
seek [3] 80/11 80/13
127/11
seeking [4] 78/22
130/14 158/23 158/25
seem [2] 101/11
117/19
seemed [4] 86/12
86/18 88/13 128/15
seems [23] 12/9
12/12 20/3 69/4 70/12)
88/14 89/25 108/6
118/23 127/4 127/6
128/12 128/14 128/20
129/3 129/23 130/12
130/16 172/1 174/21
196/14 196/15 210/7
Seemungal [4]
206/24 207/23 208/14
209/1
seen [20] 7/20 8/1
21/18 21/19 28/6
28/10 28/11 32/19
32/25 36/24 52/6
56/21 57/22 74/3
76/17 110/25 112/15
178/16 185/4 205/10
send [4] 49/9 117/1
140/4 150/24
sending [2] 10/11
149/4
senior [6] 57/7 104/7
109/24 110/5 110/7
185/5
sense [4] 63/11
117/3 194/8 196/16
sensitive [1] 85/14
sensitivity [2] 34/24
72/24
sent [24] 11/6 12/10
12/13 19/23 24/4
24/21 28/3 28/12
36/11 36/22 36/23
42/13 42/13 70/15
73/6 73/13 74/15 80/2
102/17 115/2 126/8
132/5 133/8 146/23
sentence [6] 77/9
97/17 101/6 159/9
165/19 167/24
separate [8] 39/24
40/7 117/20 126/22
141/12 142/22 143/9
170/19
separately [2] 118/25
156/3
September [15]
24/18 42/3 43/17
44/10 125/16 126/6
128/3 131/7 141/16
144/10 158/5 158/11
158/20 206/19 207/12'
sequential [1] 49/11
series [4] 79/23 81/9
86/13 170/19
serious [1] 88/3
serve [1] 23/1
served [6] 15/11
15/13 15/24 49/6 49/6
203/6
server [2] 106/16
107/11
service [6] 111/2
166/20 168/16 168/20)
169/6 189/11
services [3] 99/13
180/21 181/3
session [1] 210/15
sessions [1] 191/18
set [45] 16/17 19/23
19/24 20/1 20/4 20/5
20/14 21/20 22/5 22/8
24/6 24/13 24/24 25/8)
26/4 26/13 26/18
26/19 26/23 27/20
29/11 30/3 30/10
30/13 52/16 63/20
65/19 70/22 71/10
74/12 79/7 79/23
104/10 104/17 106/9
106/25 125/2 125/8
126/20 126/20 132/4
138/12 144/16 150/22)
155/1
set-aside [1] 30/13
sets [2] 10/20 35/18
setting [6] 13/14
22/17 25/4 67/3 73/2
107/7
settle [11] 33/12
33/21 34/5 35/2 35/3
35/13 35/16 35/19
88/2 88/25 89/3
settlement [4] 27/1
35/19 87/23 88/14
several [8] 2/13 93/4
117/5 120/16 130/20
136/8 151/5 152/4
Seymour [1] 49/1
shall [5] 26/5 26/7
100/7 173/24 173/25
share [5] 106/16
107/11 138/16 139/1
139/6
shared [2] 99/13
138/13
shareholder [5]
67/22 67/22 68/16
68/22 68/24
Shareholding [1]
67/19
SharePoint [14]
104/11 104/14 104/18)
105/5 105/12 105/16
105/19 106/5 106/25
107/19 107/23 126/21
126/24 133/15
shares [1] 106/20
she [59] 17/9 17/12
19/1 19/2 19/8 19/10
19/21 19/23 24/5
31/23 32/22 62/12
62/16 62/19 62/20
67/2 68/2 68/20 69/2
69/7 69/7 69/8 69/23
70/13 72/7 73/13
74/12 78/22 78/22
78/23 78/24 79/1 79/4
79/5 82/14 82/15
82/18 82/22 83/4 83/9
85/12 85/16 85/18
86/5 101/20 128/14
128/18 146/21 147/2
147/12 149/12 151/15
153/23 155/5 155/20
156/10 156/11 158/21
159/3
She'll [1] 85/13
she's [4] 66/24 66/25
82/25 85/23
sheer [1] 204/4
short [14] 51/22
89/17 90/17 91/20
134/7 143/3 153/3
188/16 190/19 191/17]
191/23 193/3 193/11
209/24
shortcut [1] 210/6
shortfall [1] 15/6
shortfalls [1] 87/25
shorthand [2] 78/12
196/14
shortlist [1] 207/24
shortly [9] 2/21 4/2
29/3 89/11 94/3 98/17,
123/14 142/13 149/3
should [42] 1/9 1/24
2/25 3/2 3/5 3/11 3/16
33/5 38/16 42/15
42/17 42/20 45/5
45/16 58/19 60/2
63/16 65/10 72/24
72/25 73/2 74/16 80/8
81/22 83/25 84/10
86/21 91/4 91/7 91/13
106/4 110/16 131/20
132/23 134/9 134/20
140/4 140/7 144/19
174/4 175/21 183/19
shouldn't [5] 84/11
84/20 89/6 131/1
210/21
show [8] 17/19 32/17
42/17 74/18 89/9
94/20 151/9 162/3
showed [1] 36/17
showing [2] 124/12
195/17
shown [4] 24/4
138/15 144/22 186/11
shows [1] 28/10
shut [1] 145/22
sic [4] 49/1
side [2] 26/6 207/17
Sight [2] 104/22
126/10
sign [5] 38/23 54/21
168/18 168/22 197/7
sign-off [1] 168/18
signature [4] 2/3
2/10 91/14 91/15
signed [2] 183/9
184/8
significance [1]
193/24
significant [7] 6/8
6/10 6/15 17/14 43/13)
80/1 150/17
signs [1] 54/21
similar [3] 38/10
170/20 178/16
Simon [1] 9/22
Simpkins [31] 99/21
110/1 120/22 123/10
123/17 125/7 127/7
127/12 129/14 131/6
132/9 132/17 135/8
136/14 137/24 141/11
141/15 142/20 145/2
145/15 147/14 147/21
148/20 148/21 149/13}
149/15 150/11 154/22)
202/21 205/3 206/1
Simpkins’ [1] 149/23
simply [21] 1/11
22/18 25/2 35/3 41/14)
48/18 63/3 70/22
72/25 74/18 88/2
108/17 110/17 111/14}
130/11 141/6 143/2
150/25 165/18 174/8
199/24
Simpson [1] 142/3
since [17] 2/18 21/19
31/11 32/5 86/5 94/7
96/19 99/20 101/20
121/24 127/18 129/4
138/16 145/3 165/20
180/5 180/22
single [4] 95/4 96/8
177/13 191/7
sink [2] 25/7 26/9
sir [41] 1/3 1/9 41/18
41/21 51/2 51/12
51/20 51/24 52/10
81/9 81/14 87/1 87/6
87/9 87/12 89/8 89/11
89/21 90/7 90/15
90/19 90/21 152/16
153/1 153/5 153/7
178/6 190/10 190/13
190/18 191/1 191/4
191/11 191/14 192/23)
193/1 193/5 195/24
200/25 210/13 210/24I
sit [4] 1/11 53/22
66/8 74/6
site [12] 102/14
104/11 106/10 106/25)
107/7 107/19 107/24
123/23 126/21 126/24)
127/1 133/15
sitting [2] 55/19
70/12
situation [2] 34/3
34/9
six [9] 3/4 48/15
105/10 109/7 124/16
194/19 202/22 203/16
207/24
six pages [1] 194/19
size [1] 40/15
Slaughter [1] 40/5
sledge [2] 25/14
25/15
sledgehammer [4]
25/23 26/8 26/20
27/22
slide [1] 174/24
slight [2] 64/18
199/18
slightly [8] 10/6
69/16 70/13 103/11
138/2 196/13 198/15
198/19
slow [1] 195/22
small [9] 42/24 43/8
44/3 47/10 48/19 94/8)
111/8 162/15 185/9
SMC [2] 150/6
150/19
snapshot [1] 49/18
so [474]
softening [2] 199/18
200/1
(81) see... - softening
Ss
software [4] 130/2
144/23 145/12 185/18)
sole [1] 188/9
solely [3] 99/5
102/13 117/16
solicitor [9] 5/4 5/21
10/7 10/14 12/14 14/7
17/1 38/21 53/10
solicitor's [2] 22/18
25/2
Solicitor-client [1]
17/1
solicitors [4] 18/9
45/17 49/7 189/2
solution [2] 103/13
157/8
some [90] 5/3 6/14
7/4 8/8 9/25 11/4
11/11 12/12 13/14
14/20 18/17 22/12
24/25 34/4 34/20 38/9
42/11 42/25 43/23
48/9 49/2 53/12 56/7
57/1 58/5 59/18 60/6
63/21 79/25 88/7
91/20 94/2 94/8 94/18
97/14 104/25 109/20
111/23 121/8 122/22
123/17 124/21 127/11
127/21 127/25 129/7
131/9 132/6 134/8
135/24 135/25 136/1
139/20 141/20 143/21
147/17 148/7 150/10
150/25 152/9 153/10
154/1 162/15 168/6
169/4 169/14 171/13
176/3 177/16 179/5
180/8 182/22 183/7
183/24 184/21 186/5
186/8 186/20 187/6
188/15 188/16 190/16)
191/11 191/14 192/11
194/12 196/7 197/21
201/1 201/4
somebody [17] 92/9
92/21 93/20 93/23
102/16 109/17 119/5
119/9 120/1 120/7
142/6 168/22 169/1
172/22 173/6 183/25
187/2
someone [14] 14/15
35/3 81/3 84/20 88/24
137/19 139/7 175/17
183/12 187/10 187/12)
194/12 205/1 205/3
something [32]
24/17 25/3 29/9 49/5
49/19 62/25 68/24
70/7 71/6 80/19 88/19)
100/13 100/25 102/17
109/16 109/16 116/24)
119/4 119/6 120/9
128/9 128/13 134/4
135/10 154/10 160/4
164/17 194/10 194/10)
198/2 204/24 209/9
sometimes [4] 70/13
110/11 118/12 204/24)
somewhat [1] 103/23
somewhere [3] 9/9
135/14 140/25
soon [1] 73/8
sorry [34] 3/14 4/8
5/2 11/10 17/25 23/3
27/10 29/1 30/22 33/6
53/18 72/17 76/9
76/22 81/21 84/23
97/10 117/16 122/19
134/15 136/10 138/2
140/7 157/3 158/18
166/24 167/10 186/7
187/4 190/11 195/24
203/2 206/21 210/20
sort [14] 34/2 63/24
64/13 84/4 88/17
89/17 165/19 194/9
196/13 196/16 197/15)
197/17 197/25 200/1
sorted [1] 34/23
sought [2] 123/17
163/25
sound [5] 133/1
140/24 160/13 164/12)
170/3
sounding [1] 145/20
sounds [11] 51/20
102/15 102/18 119/4
121/3 123/24 126/1
171/8 174/23 177/14
197/16
source [2] 120/5
148/8
sources [1] 106/12
South [2] 61/16
61/17
Southampton [1]
53/25
spanning [1] 114/13
speak [8] 20/18 48/7
51/9 51/16 65/23 66/1
66/7 86/15
speaking [3] 48/1
66/2 67/12
spec [1] 37/11
specific [10] 8/4
13/23 97/18 98/10
100/9 115/18 136/11
148/21 186/18 207/9
specifically [16] 9/13
92/21 92/22 107/16
111/13 111/21 117/6
121/17 130/25 137/8
151/11 167/8 186/14
188/23 200/19 201/15)
specifications [1]
92/16
specified [1] 181/22
specifies [1] 183/14
speculating [1] 129/7I
speculative [1] 32/22
speed [3] 24/2 57/18
59/20
Spencefield [1]
181/16
spent [1] 131/9
split [2] 204/7 204/9
SPM [1] 163/13
spoke [2] 17/9 41/10
spoken [8] 16/21
32/5 52/4 72/17 104/8
127/7 127/19 128/21
sporadically [1] 17/3
spot [1] 116/24
spotted [1] 116/19
square [13] 10/12
124/18 125/21 126/11
127/23 128/6 129/2
129/16 130/18 138/8
146/23 148/1 154/23
Square’ [1] 129/19
SSC [34] 96/22 97/4
97/18 98/16 99/3 99/5
99/9 99/18 99/25
106/4 109/25 110/2
119/5 120/1 120/21
122/16 128/21 133/15}
135/14 140/25 150/7
154/7 165/1 169/24
175/3 175/21 176/9
176/14 177/2 196/2
200/5 200/10 205/2
209/22
SSC's [2] 126/22
155/10
SSC-specific [1]
97/18
staff [3] 95/19 110/18
161/6
stage [35] 6/11 11/3
19/14 21/20 25/12
27/8 27/15 28/21 39/1
39/3 49/25 54/4 56/18
60/3 60/10 65/14
66/10 66/13 66/15
67/8 71/3 77/22 78/19
82/19 83/6 98/20
102/20 130/22 133/20}
133/24 134/17 135/11
165/22 168/3 208/15
staged [1] 63/10
stages [5] 22/9 39/5
65/4 185/12 185/14
stake [1] 32/18
stamp [1] 42/17
stand [1] 103/4
standalone [1] 49/11
standard [2] 179/19
179/24
standing [1] 27/21
stands [3] 3/24
166/20 166/24
start [6] 5/3 9/24
13/25 51/19 54/13
108/1
started [6] 50/19
53/23 57/6 102/21
130/15 154/7
Starter [1] 166/4
state [7] 1/13 36/16
91/2 148/12 164/21
164/24 177/4
stated [4] 145/14
158/3 174/2 177/1
statement [75] 1/22
2/1 2/5 2/12 2/18 3/21
3/25 4/1 4/3 4/7 4/12
TIT 17/13 22/18 25/2
35/17 43/2 53/2 55/8
56/12 79/8 85/25 91/5)
91/7 91/11 91/14
91/17 94/21 94/24
97/3 100/14 101/5
102/24 108/25 109/7
109/10 112/7 116/8
116/14 120/2 136/23
140/18 152/11 161/4
179/1 179/6 179/8
179/16 179/18 179/19
179/20 179/22 180/2
180/9 180/10 180/20
181/6 181/11 182/4
182/10 182/20 183/16
184/7 184/13 184/24
188/4 193/14 206/19
207/3 207/7 209/6
209/14 209/23 210/4
210/17
statements [23] 1/16
10/25 22/4 22/6 22/8
24/12 30/1 30/12
33/15 38/22 39/18
90/3 111/24 124/21
128/1 176/4 178/14
178/23 203/4 203/12
203/25 209/16 210/10)
states [5] 117/9
151/21 163/4 166/6
166/12
status [2] 152/14
159/13
statuses [1] 122/14
stay [3] 132/12
132/18 134/20
staying [1] 136/2
stays [1] 132/15
steer [1] 72/23
Stein [3] 191/22
191/24 212/12
Stein's [2] 191/10
191/16
step [7] 26/25 34/11
54/8 78/6 78/14 78/15
78/17
Stephen [24] 16/4
21/12 21/16 24/8
26/11 29/20 32/3
33/14 35/17 36/11
37/2 38/12 38/19 39/4I
40/16 42/3 43/19
44/18 48/5 109/25
164/1 177/11 178/1
190/13
stepped [1] 35/21
steps [4] 19/22 69/11
106/3 163/21
Steve [10] 110/3
173/17 174/25 196/12)
198/8 198/12 199/6
206/1 209/20 209/20
STEVENS [6] 1/8
51/7 52/7 89/22 90/13
212/4
stick [1] 194/20
still [16] 23/11 34/8
34/24 47/14 47/16
49/2 83/1 83/5 89/14
96/19 96/20 121/22
125/23 148/18 172/1
199/25
stopped [1] 9/7
store [1] 104/11
stored [10] 96/17
97/20 101/10 105/18
106/4 107/8 113/13
114/14 114/20 129/10)
storing [1] 107/18
Stoy [1] 42/4
straight [3] 30/20
52/3 74/17
strategy [11] 28/23
32/6 35/6 36/5 38/3
38/3 38/16 45/16
45/22 46/8 75/3
streams [2] 6/13 6/17I
strikes [1] 120/6
structure [2] 53/20
68/6
structured [2] 65/21
195/8
struggle [2] 67/21
68/21
struggling [1] 166/23
stuck [1] 79/24
studies [1] 91/25
stuff [2] 9/19 83/1
stuffed [1] 19/3
subject [13] 3/19
90/8 103/1 109/3
110/13 111/2 138/17
163/25 166/17 178/8
196/14 196/16 200/18)
submitted [2] 4/12
158/24
subpostmaster [4]
4/8 14/22 32/24 161/8
subpostmasters [8]
(82) software - subpostmasters
Ss
subpostmasters... [8]
12/20 13/10 13/21
13/23 13/23 32/22
50/5 108/23
subsequently [5] 5/8
15/5 15/21 42/5
193/23
subsite [1] 127/1
substance [3] 21/25
23/24 71/13
substantial [2] 80/6
112/24
substantive [4] 22/24)
24/3 68/25 72/14
substantively [1]
86/17
subtask [1] 170/23
subtasks [1] 170/13
success [1] 75/20
successful [1] 7/22
such [23] 4/25 10/13
17/23 28/15 74/5
92/23 95/4 95/14 96/7
98/12 105/8 112/12
115/22 127/17 150/7
151/18 159/16 166/16
170/22 182/8 202/20
202/25 203/5
sufficient [4] 14/3
116/12 186/20 187/20}
suggest [6] 30/24
37/16 96/7 206/15
208/22 209/4
suggested [5] 26/12
142/14 168/23 171/19)
176/21
suggesting [4] 31/2
33/16 174/7 183/17
suggestion [1] 133/3
suggests [3] 11/20
39/5 140/15
suitable [1] 37/17
summaries [1] 42/14
summarise [1] 115/6
summarising [2]
47/7 115/14
summary [2] 7/1
109/5
Summerhayes [1]
32/4
superseded [8] 95/8
122/4 123/13 138/24
156/1 156/4 156/20
156/24
supplemental [2]
151/21 204/9
supplemented [1]
8/3
supplied [5] 131/21
184/10 184/11 184/15)
184/18
supply [2] 120/20
150/15
supplying [1] 150/8
support [20] 22/8
24/13 27/20 30/3
30/13 85/24 97/4
99/13 111/24 166/16
169/20 172/3 197/1
197/3 197/4 197/7
198/21 198/23 199/10)
199/15
supported [1] 184/25
supporting [2]
111/11 137/21
suppose [12] 30/20
60/23 69/1 69/2
104/19 111/6 128/25
129/5 138/21 165/19
177/23 188/7
sure [64] 12/24 16/13
28/1 39/1 44/21 63/13
87/10 89/1 94/4 94/11
94/13 96/15 96/23
97/13 97/21 99/8
100/2 100/6 100/20
105/13 108/3 111/13
112/4 112/9 112/15
116/25 116/25 123/1
123/9 125/6 130/12
132/19 132/20 133/22)
133/25 136/7 145/4
145/14 145/15 145/17,
145/17 145/18 145/25)
151/9 152/19 158/2
165/18 167/14 167/24)
171/4 174/10 177/15
179/15 180/18 185/25)
187/10 187/16 188/8
188/13 193/7 195/14
196/6 199/3 208/11
Surely [1] 73/2
surprise [1] 55/1
surprised [1] 170/12
suspect [17] 7/4 7/5
8/19 23/25 47/22
59/21 66/2 76/8 76/9
77/5 98/17 112/2
112/5 119/23 125/6
130/15 175/19
suspended [1] 15/3
switch [4] 176/9
177/2 177/4 177/6
sworn [3] 1/7 90/22
212/2
symptoms [2] 98/5
157/7
system [47] 4/21
12/17 12/23 13/7
13/19 18/4 19/17
23/19 27/9 27/12
32/12 32/20 37/13
41/3 42/10 42/15
42/16 43/6 44/6 50/6
50/10 50/20 114/15
118/14 122/1 128/24
138/23 151/24 153/20}
160/25 164/16 166/20
168/21 169/8 180/25
181/1 181/4 181/5
181/7 181/18 182/5
182/6 182/12 182/13
182/16 193/16 193/21
system-wide [1]
118/14
systems [6] 37/15
164/19 165/9 167/1
167/5 172/1
TO
tab [1] 25/13
table [17] 35/18
117/9 118/6 135/2
135/10 135/12 140/21
140/23 140/25 148/18}
154/22 156/7 164/10
195/9 195/17 197/25
198/4
table’ [2] 154/38
155/10
tag [2] 172/4 173/1
take [33] 4/5 6/19
6/20 14/8 26/7 32/25
38/21 39/11 41/12
41/19 45/10 51/12
51/13 51/15 51/17
55/4 62/8 66/2 66/4
78/17 90/9 106/3
121/4 134/13 146/18
152/20 152/23 171/22
190/24 191/2 191/9
205/12 205/22
taken [10] 3/19 19/22
58/13 73/12 74/16
80/15 139/9 157/14
160/24 174/24
taking [4] 4/16 5/1
60/21 200/7
Talbot [17] 10/10
16/22 16/24 18/14
21/15 23/8 23/17 27/9
27/10 28/15 29/20
31/11 31/20 36/9 37/4
38/13 47/24
talk [3] 55/14 75/9
197/10
talking [16] 9/5 24/14
30/19 32/23 33/13
40/7 53/18 59/24 61/8
98/12 128/16 133/21
151/11 167/16 195/22
197/25
talks [1] 167/25
task [4] 70/7 170/16
176/24 188/9
tasked [1] 137/17
tasks [4] 170/20
202/25 203/24 204/18
TC [2] 166/14 167/19
team [39] 6/20 8/12
9/11 9/16 9/17 10/14
15/8 20/13 54/1 54/1
54/2 54/5 54/6 55/1
55/11 55/13 56/23
57/3 83/4 85/15 92/21
99/13 110/1 111/8
111/16 113/22 179/21
185/6 192/16 196/2
200/5 201/6 202/20
203/17 203/23 204/10)
204/17 204/21 205/18)
teams [2] 6/22
110/14
technical [11] 92/11
92/15 151/7 151/17
161/13 195/1 202/17
203/2 203/9 207/22
210/7
technology [2] 94/10
180/23
telephone [4] 21/14
43/17 66/20 72/18
tell [12] 19/4 45/19
59/11 59/15 80/25
82/6 85/15 109/12
137/7 140/15 149/22
158/9
telling [4] 67/12 69/2
77/21 172/14
tells [1] 98/7
templated [1] 179/20
tempo [4] 78/6 78/15
78/17 85/16
temporarily [1] 93/5
ten [8] 51/5 51/12
73/18 105/7 169/16
190/20 191/12 191/15)
tended [1] 13/18
tenders [1] 7/22
tense [1] 101/11
tenure [1] 102/20
term [3] 25/15 92/8
114/10
termed [1] 7/24
terminology [3]
122/6 123/14 153/10
terms [25] 5/13 26/14
38/18 38/24 53/20
95/19 96/16 103/23
104/19 104/24 109/19}
109/22 111/6 111/14
111/22 113/7 130/25
136/23 145/20 188/11
191/4 194/6 201/16
209/18 210/6
test [6] 1/10 10/3
22/17 35/7 35/14
103/25
testers [1] 100/15
testing [1] 100/13
text [5] 64/14 144/18
147/10 148/2 148/13
than [33] 22/18 25/2
32/18 35/6 36/23
44/13 47/11 70/23
76/13 93/16 97/23
99/16 103/15 106/12
108/15 111/22 121/23)
122/4 128/21 129/2
142/4 153/9 156/17
174/14 175/21 187/23)
188/20 191/2 191/10
194/2 194/25 201/16
204/13
thank [124] 1/9 1/15
1/17 1/24 2/8 3/7 3/19)
3/24 4/5 7/9 10/6 10/9I
16/20 29/16 29/17
51/4 51/20 52/10
61/21 65/17 69/15
69/16 74/22 76/23
79/19 81/14 82/2 87/5I
87/12 87/14 89/8
89/21 89/23 90/2 90/6I
90/7 90/15 90/20
90/21 91/20 93/1
93/13 94/2 94/15
94/22 97/24 98/15
100/22 106/23 107/20)
108/1 108/21 110/8
113/25 115/10 117/2
121/5 121/13 122/7
123/20 125/12 125/15)
128/3 129/13 138/3
141/14 144/8 144/9
146/19 149/3 149/12
149/13 151/12 151/14)
152/24 153/1 153/6
153/7 158/17 158/20
160/5 161/18 162/4
162/8 162/9 162/19
162/25 163/1 164/5
164/7 166/2 168/12
168/14 169/13 175/7
176/2 180/9 183/1
184/22 188/16 190/10)
192/22 192/23 193/1
193/8 193/10 195/2
200/20 200/22 200/23}
200/25 201/15 203/4
204/15 205/11 206/14I
206/21 206/22 207/12I
207/21 208/1 210/13
210/14 210/16
thanks [5] 73/21
89/19 132/3 193/6
210/23
Tharigq [1] 93/23
that [1274]
that I [3] 128/15
132/21 187/10
that's [140] 10/4
10/16 11/24 12/6
16/13 16/22 17/11
18/6 19/5 20/5 20/12
20/14 23/2 23/3 23/9
26/14 28/10 29/17
30/5 31/24 34/23 38/6I
(83) subpostmasters... - that's
T
that's... [118] 38/11
39/6 39/14 40/12
40/18 43/12 45/3 51/2
53/14 56/16 56/19
56/20 57/9 57/14
58/22 60/5 60/8 60/16
60/18 61/18 62/5 64/5
64/14 64/24 65/18
66/5 66/8 66/14 66/14
67/14 68/2 69/5 69/10
72/1 72/4 72/4 76/4
78/10 78/17 79/5
79/15 81/11 81/12
82/4 82/18 83/22
84/20 85/16 86/2
86/16 87/21 89/12
89/19 93/18 96/15
102/15 103/8 110/41
116/11 120/19 122/22}
124/11 127/2 129/7
130/1 130/14 131/2
134/4 134/12 135/11
142/22 143/9 148/5
148/25 149/18 153/22}
157/4 158/20 159/2
159/23 160/2 160/18
166/20 166/24 170/11
170/21 170/24 171/2
171/23 173/8 176/2
180/16 185/19 185/25I
186/9 186/9 186/22
187/6 187/17 188/15
190/23 191/3 191/19
194/5 194/13 195/24
195/25 198/24 199/20}
201/20 203/19 204/6
204/23 205/2 205/7
206/22 209/8 209/12
theft [3] 12/21 13/10
13/22
their [27] 12/5 38/22
44/6 44/11 44/12
44/13 44/14 49/20
55/20 60/14 60/19
73/1 99/14 106/20
109/14 109/19 113/18
118/13 148/13 151/2
163/16 188/5 188/9
192/17 192/18 193/24I
208/5
them [72] 5/13 9/14
18/23 20/18 34/4
38/23 39/12 42/23
45/18 45/19 45/21
50/7 55/19 57/1 57/9
67/13 68/7 70/23
71/16 72/8 98/24
102/8 102/10 103/8
103/22 105/20 105/21
108/9 110/4 113/11
120/22 120/23 122/4
123/24 124/21 124/24]
125/2 127/19 131/22
131/23 132/5 137/2
137/7 137/10 138/19
142/25 144/7 144/19
146/5 149/22 149/22
150/15 150/25 151/25)
152/4 152/7 154/7
155/23 172/14 172/23)
173/5 189/3 192/8
193/15 193/21 194/1
194/3 194/11 194/14
194/16 195/19 206/10)
themselves [4]
109/19 175/4 176/9
177/2
then [115] 3/7 5/11
6/7 7/11 8/3 9/3 16/2
23/4 23/17 23/20 24/6
32/3 32/20 36/10
36/25 38/18 40/1 40/4
41/25 47/6 51/17
51/19 52/11 58/4
58/24 58/24 61/11
61/12 61/23 62/9 64/1
64/13 65/4 68/14 69/4
70/9 70/14 70/19
70/22 78/5 79/15
79/22 80/2 80/10
82/10 83/20 84/8 85/5)
89/18 90/2 100/14
100/19 102/7 102/17
103/8 111/16 116/19
116/20 116/24 125/9
126/22 127/5 128/3
130/20 131/19 135/3
137/5 137/6 138/21
139/6 142/7 147/2
148/16 154/17 155/4
155/17 158/5 158/9
164/14 166/12 168/22)
169/23 170/17 170/22)
171/13 172/7 173/22
176/7 178/25 180/5
188/8 191/17 191/17
191/22 193/25 194/11
195/2 196/21 197/10
197/18 198/14 198/19)
199/13 200/4 205/15
206/6 206/14 208/1
208/3 208/8 208/14
208/18 208/25 209/19)
209/25
theory [2] 42/15
129/5
there [201] 6/17 6/21
13/1 13/19 14/7 14/18
16/10 16/19 17/25
23/8 23/13 26/4 26/18
26/19 26/23 26/25
27/1 27/11 29/6 30/1
31/20 32/14 32/18
33/3 33/8 34/24 35/21
36/10 38/9 39/3 39/8
39/13 39/14 41/6
42/11 43/6 44/3 44/16
46/1 47/16 48/16
48/22 49/22 50/4
50/19 53/9 53/11
53/12 55/14 57/4 57/6
58/15 58/23 59/11
60/8 60/21 60/24 63/5)
63/15 63/19 63/21
63/24 64/11 65/8 71/1
71/9 71/23 71/24 72/5
75/9 75/10 75/10
76/22 77/24 78/1 78/2
79/21 80/10 80/12
80/18 84/2 84/5 84/7
84/9 84/11 84/12
84/20 86/20 88/22
91/13 93/16 93/25
95/11 96/19 96/25
97/14 97/17 97/18
99/20 101/5 101/21
102/18 103/20 104/25
105/21 108/18 111/23
114/4 116/24 118/20
119/7 121/14 122/14
124/24 125/1 125/3
125/4 126/12 128/5
128/22 129/4 129/15
129/18 135/15 135/19
136/19 138/8 138/18
138/19 141/20 142/7
143/1 146/8 148/25
149/25 150/16 150/19}
150/20 153/10 153/14
154/4 156/4 156/12
156/23 157/25 159/13
160/10 160/10 160/19)
162/20 164/17 165/3
165/14 166/7 169/16
170/4 172/3 173/1
173/3 175/23 177/15
178/24 181/25 182/3
186/25 187/7 187/20
187/22 188/2 188/10
189/24 191/6 193/18
193/21 194/8 194/8
195/7 195/15 196/15
198/11 199/16 199/23
199/23 199/24 200/1
200/13 200/16 201/5
202/15 202/19 203/19)
204/13 204/20 204/24
206/6 208/22 209/8
209/19 209/20 210/4
210/9
there's [41] 3/9 4/3
7/24 13/3 14/11 16/4
19/3 19/14 27/4 28/8
28/20 30/11 30/24
34/25 36/8 36/10 39/3
52/5 56/16 65/25 66/6
68/14 82/3 82/16
84/19 87/6 87/7 87/22
103/23 106/8 127/21
137/24 152/12 170/15}
170/17 193/25 194/3
194/3 195/16 198/4
199/3
thereby [1] 38/23
therefore [13] 42/18
80/6 88/2 96/3 100/16)
125/2 126/16 126/21
130/6 138/12 145/3
150/8 173/4
these [45] 22/9 27/24
42/24 43/8 44/25 47/3)
52/9 58/12 59/7 63/8
69/1 76/8 85/24 87/20)
103/4 103/14 104/3
110/8 117/6 123/6
147/14 150/6 153/24
154/14 155/6 155/9
155/21 156/1 156/4
156/11 157/3 160/22
162/17 163/15 167/1
167/5 168/23 193/22
194/9 194/21 201/10
202/24 203/24 204/18
209/15
they [109] 3/23 4/9
8/11 9/17 12/16 12/18
14/10 14/14 18/7
18/11 24/18 30/3 39/5}
42/4 42/24 43/23 44/5)
44/11 44/12 44/14
48/20 49/8 50/3 55/23)
57/21 57/21 60/4
65/10 71/20 72/9 74/2
75/1 75/7 76/13 76/14,
76/17 86/14 92/21
95/20 99/11 99/14
101/12 102/8 103/6
103/10 103/11 103/17,
103/19 103/23 108/6
108/7 108/8 110/2
110/3 110/10 113/13
114/20 115/6 122/3
122/15 123/24 124/14}
125/9 125/9 127/8
127/18 128/17 133/24}
137/9 138/10 138/17
144/16 145/11 146/6
146/24 147/12 148/13}
150/4 151/22 151/24
152/5 153/24 154/17
155/13 155/14 157/6
157/12 157/12 159/15}
162/16 164/8 165/23
167/9 168/19 172/18
175/21 179/3 181/23
190/24 192/9 194/19
194/20 194/20 196/2
196/3 198/25 200/6
204/14 205/9
they'd [2] 44/23
145/1
they'll [1] 149/22
they're [20] 34/2
39/13 60/25 67/11
77/5 77/7 85/14 92/18
96/9 97/22 128/24
156/18 168/25 183/14)
194/5 194/13 194/14
194/15 194/18 194/23)
they've [2] 154/6
177/18
thing [7] 34/19 71/4
127/15 143/23 174/15]
188/3 194/22
things [13] 44/25
52/9 54/6 67/12 68/6
92/23 103/25 116/20
142/22 143/9 176/15
190/21 199/4
think [309]
think' [1] 72/25
thinking [3] 35/13
44/25 198/3
third [5] 3/15 45/15
62/2 148/7 164/14
Thirdly [4] 147/5
this [431]
THOMAS [3] 1/7 1/14
212/2
thorough [1] 68/21
thoroughly [1] 18/24
those [79] 2/15 2/19
2/21 3/20 9/2 10/14
11/16 12/11 13/16
14/4 21/24 22/7 24/20)
30/1 30/12 35/6 36/5
38/20 44/2 48/19
49/22 52/19 52/22
55/18 56/1 56/1 58/16
61/2 79/2 86/17 87/25I
88/4 89/8 92/7 92/14
92/17 94/2 98/2 101/9
101/24 105/13 105/22)
108/5 109/3 109/12
109/13 111/13 111/18)
411/18 111/22 116/21
118/1 120/20 120/21
120/24 133/18 148/16)
150/5 150/15 150/22
154/20 156/24 159/15}
159/19 163/12 163/23)
165/22 171/18 179/17)
189/13 193/15 199/4
200/6 200/12 200/21
201/16 204/15 208/24I
210/21
though [11] 46/4
116/10 122/22 128/12)
142/22 143/9 143/21
145/19 146/10 168/1
168/25
thought [18] 19/5
33/3 34/3 40/14 40/15]
44/2 59/14 61/17 65/9)
70/6 78/24 83/7 83/9
122/23 128/15 128/18)
141/22 146/4
thread [1] 128/16
(84) that's... - thread
T
threatened [1] 20/20
three [9] 30/12 47/4
47/9 84/5 89/17
118/20 159/13 173/13
207/3
three-week [1] 89/17
through [17] 1/11
34/3 35/16 35/24
39/12 43/1 43/12
50/11 67/21 68/15
777 77/13 77/16
127/21 173/6 179/14
208/20
throughout [6] 5/20
7/14 35/16 101/14
185/24 210/18
throw [1] 88/3
throwing [1] 170/13
thrown [1] 171/411
Thursday's [1]
115/12
tick [2] 173/3 173/4
nt [1] 207/19
time [102] 4/19 8/14
8/18 8/20 8/25 9/23
11/18 11/22 12/1 12/6
12/15 14/6 16/5 18/7
18/21 19/1 19/6 19/7
20/8 21/18 22/14
22/15 32/13 37/18
41/11 41/18 41/19
44/9 48/2 48/16 48/22
49/22 51/2 51/14
53/12 56/3 56/19
56/21 57/6 58/10
58/11 59/4 59/17
63/11 63/11 63/15
66/19 70/18 71/24
76/8 79/1 84/6 84/15
86/19 98/21 99/20
101/14 104/20 106/17)
106/21 107/22 110/20)
110/22 112/10 112/18}
113/22 116/13 119/7
119/16 120/14 120/24}
122/22 122/23 123/6
128/10 129/4 130/10
130/13 130/19 131/9
133/3 133/5 134/5
134/7 135/15 143/3
148/15 153/7 166/18
168/6 168/23 180/4
180/7 187/14 187/16
187/17 190/17 190/21
194/16 195/8 205/23
207/19
timed [1] 116/2
timeline [2] 10/17
26/14
times [9] 7/15 10/14
32/2 61/17 100/4
162/14 173/9 182/6
193/25
timetable [1] 51/7
timetabling [1] 52/1
timing [7] 62/2 69/2
69/3 69/11 69/12
70/15 74/20
tip [1] 80/22
title [2] 109/15
169/18
today [13] 1/5 1/15
5/18 5/25 82/16
115/25 183/9 185/5
186/11 190/21 201/4
207/14 210/15
together [1] 204/18
toing [1] 48/16
told [24] 18/14 24/5
27/3 31/16 49/7 55/16
77/1 77/5 77/6 77/19
77/10 107/16 111/10
111/13 111/20 113/6
123/24 124/24 128/12)
135/24 136/14 144/7
201/15 202/1
Tolhurst [1] 73/22
Tom [13] 21/14 25/11
39/10 43/22 44/2
45/16 67/2 67/14
67/14 67/16 67/21
68/4 68/20
tomorrow [2] 65/6
210/19
tone [3] 85/6 85/14
85/21
too [5] 20/1 39/7
45/12 61/5 143/9
took [12] 19/6 19/7
41/8 53/12 59/4 115/1
123/10 163/21 175/17)
175/23 175/25 176/12)
tool [3] 165/11
167/17 172/8
Tool' [1] 164/23
tools [4] 165/7 167/3
167/8 188/11
top [14] 36/8 37/2
115/10 139/25 142/11
153/14 164/6 166/1
168/4 173/15 184/2
184/3 186/2 208/16
topic [11] 11/19 51/6
60/7 87/23 108/21
112/22 161/2 178/11
184/1 184/23 193/11
topics [4] 60/24 61/2
63/8 161/24
Torstein [9] 105/9
106/1 110/5 168/15
206/1 206/18 207/7
207/9 209/14
Torstein's [2] 207/2
209/19
total [2] 42/20 160/18
totality [1] 88/10
totally [1] 99/8
touch [1] 27/17
towards [2] 74/8 82/3)
TPS [1] 164/19
TPS/POL [1] 164/19
trace [1] 120/5
track [2] 131/9
206/13
tracked [2] 206/10
207/10
trail [4] 197/3 197/8
199/9 199/16
train [2] 50/19 197/19]
training [2] 94/10
94/16
tramlines [1] 21/12
tranche [2] 56/8
151/2
transaction [13]
42/14 42/16 42/19
47/4 114/14 161/6
163/10 163/13 165/11
166/9 166/15 196/19
198/13
transactions [9]
42/22 43/10 101/10
163/11 163/18 166/11
167/16 181/5 196/4
transcriber [2]
152/17 190/19
transcribing [1] 2/15
transcript [1] 58/9
translate [1] 170/14
transparent [1] 146/1
transpired [4] 125/1
152/9 202/18 205/15
transpires [2] 148/24
151/1
treat [2] 5/13 35/14
trepidatious [2] 60/5
76/13
trial [19] 11/1 35/23
46/21 47/10 48/15
49/18 54/13 55/2
55/11 55/17 56/24
57/2 57/5 63/2 77/12
77/16 80/1 160/17
187/24
trials [3] 78/3 79/23
86/13
tried [4] 33/7 35/16
83/15 164/17
trigger [1] 14/7
triggered [1] 154/1
triviality [1] 118/13
trouble [1] 172/1
true [10] 3/21 91/17
96/15 116/11 140/18
145/3 185/25 200/10
205/7 209/12
truly [1] 5/2
truth [1] 91/14
try [8] 33/21 34/19
35/2 45/22 46/3 49/2
54/8 72/3
trying [13] 14/2 18/2
24/2 34/17 35/3 35/7
59/20 74/7 131/9
145/6 197/10 204/7
209/18
turn [38] 1/21 1/25
2/6 3/7 3/8 3/13 3/14
6/4 10/2 16/19 24/23
25/10 28/19 29/16
29/17 32/3 36/6 42/8
44/3 46/23 52/11
61/23 64/1 72/12
73/15 73/15 76/4
76/19 77/3 79/6 79/19}
81/20 91/10 101/4
109/10 113/24 131/4
160/5
turned [4] 12/1 58/3
68/4 80/21
turning [1] 55/20
turns [1] 29/12
two [45] 1/16 5/25
19/9 24/10 38/5 38/10}
43/17 60/24 61/2
62/23 63/10 64/23
77/5 79/13 84/14 90/3
90/3 102/25 108/3
113/15 116/10 124/10)
138/9 142/22 144/14
144/21 146/14 146/23
148/4 154/4 164/17
165/6 172/7 175/2
176/15 181/13 191/18
194/3 199/4 204/11
205/11 208/4 209/10
210/6 210/21
two pages [1] 116/10
two paragraphs [1]
181/13
two-staged [1] 63/10
type [1] 169/5
typed [5] 2/15 64/2
76/5 79/8 84/19
types [4] 35/6 110/23
194/6 195/18
typical [2] 209/4
209/15
typing [1] 87/20
U
UKGI [2] 67/16 73/25
ultimately [1] 111/6
um [14] 94/11 95/17
104/6 117/15 127/10
143/18 167/14 182/23}
183/21 186/22 188/22}
192/18 192/18 195/12}
unavoidable [1]
202/2
unbelievably [1]
44/17
uncertainty [1] 132/6
uncomfortable [6]
85/6 85/8 85/14 85/18
85/22 86/1
under [8] 19/19 42/9
63/2 88/1 110/4 162/6
170/20 176/8
underlined [1] 82/3
underlying [2]
143/17 157/7
undermine [1] 13/18
undermined [1]
13/17
underpinned [2] 12/5
14117
understand [34] 2/17)
2/23 3/10 3/16 4/3
7/18 19/9 22/13 43/18
45/25 51/10 58/16
72/24 73/5 74/25
80/12 82/21 98/19
101/23 104/24 113/12!
113/20 114/19 121/20)
132/17 133/20 164/22)
167/4 167/15 167/20
172/20 182/10 182/15)
194/25
understandably [1]
17/9
understanding [22]
18/18 18/20 24/10
28/7 30/8 31/25 32/1
56/14 69/13 80/17
86/8 86/10 86/18 99/6I
99/8 130/9 130/22
163/17 173/1 173/8
180/5 182/11
understood [7] 53/1
55/10 68/5 98/21
152/7 163/22 164/11
undertake [1] 181/3
undertook [1] 181/17)
undoubtedly [1]
148/20
unfairness [4] 71/20
71/22 72/2 72/10
unfamiliar [1] 92/7
unfavourable [1]
55/12
unilaterally [2] 33/12
34/7
Unique [1] 1/18
University [1] 91/25
Unix [1] 176/21
unknown [2] 84/6
84/6
unless [6] 33/12 34/5
34/6 142/6 173/6
202/2
unlike [1] 194/22
unlikely [2] 75/7
102/18
unpack [2] 12/25
13/3
unrelated [1] 100/25
unsafe [1] 89/4
(85) threatened - unsafe
U
unsuccessfully [1]
190/9
unsure [2] 70/21
74/20
unsurprisingly [1]
159/7
until [7] 37/12 53/4
94/1 102/11 161/5
179/10 211/1
untutored [1] 73/1
unusual [3] 78/17
103/11 194/5
unwelcome [1] 68/17
up [89] 2/22 3/14 7/7
10/6 19/3 24/2 25/13
28/11 36/15 37/23
45/5 45/17 54/24 55/9)
56/13 57/18 57/23
58/8 59/20 65/19 67/3,
70/14 73/1 73/13
75/13 75/16 77/2
79/23 81/21 81/22
83/18 84/15 87/18
88/9 88/15 89/11
100/21 104/10 104/17)
106/9 106/25 107/7
107/18 109/10 113/24}
115/9 119/3 123/20
125/24 126/5 127/20
127/21 129/13 130/5
131/25 133/14 139/25)
141/6 142/11 149/12
150/21 159/6 169/11
170/9 170/13 170/25
171/11 173/23 173/25)
175/10 176/24 179/1
189/7 190/21 196/10
196/11 200/13 204/7
205/9 205/14 206/3
206/18 206/21 208/1
208/4 208/8 208/14
208/18 208/24
update [1] 100/18
updated [7] 79/16
100/16 100/17 119/14}
121/24 155/25 159/16)
updates [2] 100/12
110/25
upload [1] 123/16
uploaded [3] 121/14
123/22 126/20
upon [2] 20/12
142/19
upstairs [1] 104/8
urgency [2] 20/11
62/25
urgent [6] 55/14 63/2
63/12 82/22 115/22
147/12
us [25] 36/15 40/17
42/13 49/7 49/9 65/21
69/7 70/11 71/2 90/19
107/11 107/12 109/12,
111/15 118/20 153/5
153/25 154/15 155/6
155/21 170/14 192/19)
193/5 197/20 199/5
use [24] 5/13 25/18
32/1 37/12 49/14 95/4
165/12 166/14 166/17)
168/24 170/7 170/11
172/8 173/4 177/17
182/5 189/18 197/2
198/21 198/25 203/23)
used [24] 12/2 68/9
94/13 96/3 97/3
101/14 118/11 153/11
171/16 172/14 172/24,
173/5 173/9 177/8
177/13 179/20 181/1
190/1 190/5 200/7
204/8
useful [2] 96/4
100/19
user [3] 163/18 168/8)
172/7
users [4] 169/24
175/4 176/9 176/11
using [9] 25/15 54/8
92/17 92/18 95/18
156/17 196/2 197/14
200/10
usual [5] 1/10 24/23
25/4 197/3 198/23
usually [1] 17/22
utterly [1] 44/5
Vv
vacated [1] 23/15
vague [1] 98/23
vaguely [1] 189/3
valid [5] 120/9 122/4
150/6 150/18 150/25
valuable [2] 157/13
160/23
various [18] 2/13
92/3 93/25 95/22
99/15 99/22 105/1
105/3 110/13 110/14
1411/1 112/14 122/14
95/7 95/9 95/22 108/8
119/18 121/23 122/4
156/1 156/3 156/4
156/5 156/20 156/24
157/19 157/20 159/10}
159/18
very [42] 17/14 18/5
20/2 26/16 27/6 27/7
34/11 34/18 36/21
41/24 42/24 47/10
51/4 55/12 74/9 75/18
76/3 80/1 89/2 90/2
98/9 112/23 114/10
116/9 116/9 127/6
142/13 153/14 161/16
164/25 166/13 173/15}
188/16 194/14 196/23
200/20 205/11 206/22
207/19 209/24 210/16
210/23
via [4] 101/9 131/10
164/21 189/13
view [32] 3/16 3/17
29/23 30/5 30/9 30/11
30/14 31/18 32/16
33/18 44/14 60/2
62/20 67/5 67/8 68/20
71/13 73/2 78/1 78/3
78/20 79/4 79/21
80/10 86/3 108/13
139/7 139/9 139/18
145/4 145/16 145/17
views [9] 67/9 71/1
71/4 71/7 75/1 78/4
78/23 78/24 83/24
igorous [1] 89/3
virtual [3] 111/8
202/20 204/10
Vishian [1] 93/20
ility [1] 86/24
visit [1] 38/20
voices [3] 57/22
57/23 84/6
volume [2] 92/20
114/17
volumes [2] 92/11
92/15
195/9 196/12 197/23 IW
198/4 203/21
vastly [1] 34/25
vein [1] 9/10
veins [1] 34/2
verbatim [5] 56/1
59/5 59/7 81/15 83/15
version [22] 64/2
70/10 76/5 79/15
92/18 95/20 96/20
108/13 108/17 108/19)
119/14 119/15 122/17)
123/13 131/18 155/25)
159/17 159/20 194/4
208/3 208/16 208/21
versions [18] 2/14
waiting [3] 82/23
128/4 128/18
walk [1] 33/12
want [39] 6/4 9/8
9/24 14/19 18/17 22/1
24/6 24/7 46/8 52/11
57/21 58/5 58/8 65/4
65/13 66/1 66/6 69/12
70/11 71/2 72/7 72/9
74/2 75/7 75/15 76/2
79/12 81/20 83/17
83/18 85/15 85/16
85/24 88/24 122/22
132/22 184/17 193/11
201/1
wanted [23] 4/14
25/14 34/16 34/18
34/21 35/19 38/9
45/25 57/21 58/2 63/3)
63/7 63/22 69/7 78/24
79/2 79/4 79/5 79/17
81/11 86/10 108/19
109/23
wanting [3] 49/2
100/11 191/9
wants [4] 20/24 72/6
74/12 190/23
warned [1] 78/7
warning [2] 78/12
78/17
was [519]
wasn't [45] 8/17 8/23
9/20 26/18 43/10
43/12 44/13 47/17
53/6 53/9 54/22 63/20
63/24 64/10 68/14
83/12 84/2 84/12
98/25 99/10 104/19
108/18 112/8 113/6
116/9 120/14 125/1
125/3 125/8 126/15
132/4 133/23 140/24
143/15 143/19 144/1
145/17 177/21 179/2
186/3 186/20 187/20
192/8 192/10 203/18
waters [1] 14/4
wavelength [1] 69/19
way [35] 15/1 25/7
30/23 34/17 35/16
35/24 52/8 62/22 63/2,
67/10 68/19 69/11
70/23 72/9 77/7 77/13
77/16 84/7 88/1 89/3
100/5 100/23 112/16
130/12 132/21 139/10
140/14 145/14 159/16
165/20 177/12 198/6
202/13 206/15 209/15)
ways [5] 8/11 129/7
143/21 187/6 188/15
WBD [23] 111/16
112/5 117/21 118/24
119/25 125/8 126/19
127/4 135/24 162/18
173/21 175/3 178/21
181/22 184/10 184/12)
187/24 202/1 203/1
207/7 207/8 207/14
207/18
WBON0001499 [1]
69/15
WBON0001511 [1]
87/18
WBON0001734 [1]
58/10
WBON0001735 [1]
58/10
WBON0001737 [1]
81/23
WBON0001739 [1]
61/23
WBON0001745 [1]
64/1
WBON0001747 [2]
3/3 64/2
WBON0001749 [1]
66/19
WBON0001751 [1]
2/22
WBON0001752 [2]
3/7 66/20
WBON0001776 [1]
81/21
WBON0001792 [1]
84/15
WBON0001795 [1]
84/16
WBON0001888 [1]
3/13
WBON0001899 [1]
76/5
WBON0001900 [1]
76/6
we [429]
we'd [5] 18/22 33/7
46/2 77/22 204/7
we'll [19] 42/1 51/2
51/17 51/18 52/3
58/11 58/12 59/16
60/20 66/18 122/6
123/14 136/2 158/19
178/8 191/8 191/22
192/24 210/19
we're [26] 1/5 1/10
2/17 9/5 11/23 15/1
20/13 22/7 24/14
33/13 35/14 51/14
61/8 61/9 66/3 82/23
83/1 84/24 100/24
103/7 115/9 134/18
137/12 151/11 152/17)
195/22
we've [24] 16/18
17/13 24/8 32/2 35/1
35/2 43/25 44/10 61/5I
65/21 76/17 135/24
142/23 159/23 164/9
165/6 174/1 174/18
178/16 185/4 185/10
186/10 194/1 209/23
weakness [1] 32/17
website [14] 4/1
96/22 97/3 97/7 97/24)
98/16 98/19 99/1 99/3
99/19 100/1 100/8
133/16 140/25
Wednesday [2] 1/1
116/3
week [3] 89/17 115/2
128/4
weekend [3] 57/4
69/5 69/10
(86) unsuccessfully - weekend
Ww
weeks [2] 146/14
186/12
welcome [1] 68/14
well [90] 5/8 13/3
13/25 17/2 18/18
18/25 20/16 21/23
27/3 32/8 33/23 35/13
36/4 39/25 41/25
44/20 45/1 46/4 50/2
52/2 59/16 66/2 72/3
74/6 75/15 76/9 78/22
79/6 79/16 87/10 90/2
93/6 95/9 96/15 99/12,
100/20 101/8 102/5
103/6 103/6 103/22
104/9 104/25 108/6
116/21 117/17 120/13}
123/9 125/6 127/8
127/19 128/19 135/22)
136/22 137/5 137/11
140/19 141/4 141/24
143/9 145/2 145/18
148/24 149/22 150/4
150/7 150/16 153/12
156/22 157/1 164/10
165/18 168/20 175/13
181/7 182/1 188/5
190/23 191/3 194/11
196/8 197/13 198/4
199/8 199/21 200/4
200/20 201/19 209/17,
210/14
went [6] 50/12 78/25
119/23 119/24 125/9
173/6
were [210] 4/18 5/16
6/16 8/24 9/1 10/21
10/23 11/3 11/7 11/10}
11/11 11/13 11/15
12/10 17/15 18/7 22/5
22/7 25/11 25/12
27/11 30/3 31/8 32/7
33/8 39/10 40/19
40/22 41/2 41/13 43/2
43/5 44/3 44/16 44/17
44/22 45/8 48/25 49/3)
49/8 49/25 50/3 50/4
50/4 50/5 50/12 50/19
53/2 53/11 53/12
54/17 55/13 55/21
56/3 56/22 56/24 57/1
60/4 63/4 63/20 68/8
68/24 69/14 71/3
71/21 73/12 76/7
76/13 76/14 77/20
77120 77/23 79/17
81/12 81/24 84/5 84/9
85/18 86/14 88/11
88/22 89/4 93/8 98/23
99/3 99/9 100/8
102/13 103/10 103/16)
103/17 103/19 103/23
104/17 105/18 105/24)
106/15 108/6 108/8
109/13 110/1 110/2
110/19 111/10 111/14)
1412/1 112/25 113/3
113/8 113/8 113/12
113/13 115/2 116/3
118/1 120/11 120/24
122/17 127/18 128/4
128/13 128/17 132/7
133/7 133/21 135/19
136/10 138/10 139/5
144/14 145/10 145/11
145/22 146/1 146/8
148/25 149/1 149/1
150/4 150/20 150/25
151/6 151/24 152/10
153/24 154/2 154/2
155/6 155/14 155/21
156/6 156/11 157/3
157/19 157/23 160/11
160/15 160/18 160/19)
161/5 161/21 161/21
161/22 162/13 162/16)
163/12 165/22 165/22)
167/8 167/8 168/19
172/2 174/13 175/22
181/23 183/17 183/19)
188/5 189/15 190/5
192/6 192/9 195/10
198/7 200/5 200/6
200/10 200/10 201/21
202/1 202/6 202/15
202/19 202/24 203/13
203/13 203/16 203/19)
203/20 204/9 204/14
204/17 205/9 206/11
206/12 207/18 209/19)
209/25 210/4 210/10
weren't [11] 9/13
28/22 34/16 36/18
84/11 107/15 186/13
201/15 201/22 202/20
205/8
West [1] 130/5
Wharton [2] 115/11
116/19
what [217]
what's [12] 12/6
18/11 23/3 30/22
34/14 38/6 51/7 79/4
86/2 97/24 149/20
183/16
whatever [5] 8/2 35/5)
52/7 166/17 199/6
whatsoever [1] 12/13)
when [66] 4/23 6/6
8/24 9/7 9/13 11/6
11/16 19/5 24/3 24/5
28/12 28/25 36/21
52/4 56/3 57/5 59/21
62/16 64/7 86/20 89/9)
93/1 98/10 98/15 99/1
100/16 103/8 104/2
108/1 108/12 111/14
113/5 116/16 117/25
120/10 120/10 126/19}
126/19 129/10 132/17)
138/16 139/4 139/6
144/4 146/25 152/20
152/22 155/25 156/11
162/11 167/5 168/6
171/18 173/1 177/1
177/16 177/21 182/13
186/13 193/20 194/11
195/7 195/8 196/3
196/9 201/21
where [38] 2/24
11/11 35/7 37/5 40/7
41/6 50/4 53/22 56/17
89/1 95/11 109/11
113/13 114/20 122/10
123/6 135/8 135/12
136/2 141/1 148/19
149/11 153/18 164/25)
166/13 167/25 170/18
170/22 173/23 179/22
187/1 190/25 192/9
197/8 197/21 199/16
207/8 207/22
whereas [4] 74/7
98/6 98/10 103/14
whether [56] 12/19
13/20 23/18 42/19
48/20 50/20 51/18
52/2 60/2 60/17 61/18
63/16 65/9 66/12 67/7
70/12 74/25 78/20
83/25 96/24 100/2
100/17 100/18 117/24
118/3 120/5 120/25
126/3 128/5 128/22
129/1 129/15 132/23
133/24 134/8 134/20
135/23 138/8 144/25
146/8 148/10 148/22
150/14 152/11 152/13
154/1 172/23 178/22
180/6 181/25 185/25
187/9 188/8 189/9
189/22 190/20
which [155] 6/2 7/8
9/1 15/24 16/18 17/1
18/23 18/23 26/24
31/2 31/18 34/5 35/24
36/1 36/7 36/15 40/2
42/22 48/11 49/1 56/6
57/6 57/16 58/15
58/16 58/25 70/24
71/19 76/2 81/10
87/16 95/5 96/12
96/22 97/2 97/20
98/13 99/10 100/11
101/15 101/24 103/25}
104/11 105/18 105/24
107/10 108/22 110/23
111/25 113/2 113/7
113/12 114/9 114/11
114/16 115/6 116/6
116/18 118/10 118/13}
123/2 123/4 124/13
125/4 126/10 126/21
126/24 129/22 131/14
131/16 131/17 131/20}
132/22 134/4 134/13
135/16 135/20 136/4
136/19 137/9 138/9
138/11 138/18 140/22}
141/16 142/14 142/24}
144/3 144/17 147/6
148/16 149/12 150/20}
151/6 152/7 153/20
154/18 154/20 154/22)
155/4 155/11 156/6
156/7 156/15 157/14
157/25 158/1 159/2
160/15 160/20 161/2
161/3 161/22 163/12
163/22 164/1 164/8
164/9 164/20 164/23
164/24 165/7 166/22
167/3 168/17 169/8
170/2 170/10 170/25
171/14 171/15 171/23}
172/4 173/2 174/13
175/10 178/25 178/25}
180/10 181/1 182/7
184/14 185/4 187/11
187/14 188/17 188/17,
189/25 191/9 194/1
194/1 195/16 198/7
205/25 206/14
whichever [1] 51/13
while [6] 75/4 81/12
115/9 125/20 172/13
206/17
whilst [5] 63/10
81/15 83/14 152/19
189/15
Whitaker's [1] 11/1
White [1] 24/16
who [74] 8/6 9/21
12/15 13/21 16/11
23/5 37/16 38/17 44/7
47/23 54/17 55/16
63/4 63/5 63/8 63/9
63/14 63/21 68/4
73/13 80/3 81/4 84/8
88/11 88/23 88/25
92/7 93/19 93/21
93/24 93/25 99/18
101/17 101/19 104/6
104/9 105/5 105/11
105/21 105/22 105/24)
106/24 109/13 109/17,
110/22 110/23 111/2
111/4 111/25 114/3
120/20 120/22 137/17,
151/17 173/20 175/12}
186/16 190/23 191/9
192/8 193/7 195/18
201/6 202/4 202/6
202/16 202/20 203/13
203/16 203/19 203/20)
203/24 205/9 207/23
who's [1] 88/24
whoever [1] 78/25
whole [7] 23/24
32/20 78/16 117/1
122/3 150/24 170/19
wholly [1] 164/20
whom [7] 109/7
110/9 110/15 118/19
119/22 137/19 179/24)
why [60] 6/10 7/12
10/12 10/16 22/2 36/7I
43/5 53/9 60/22 61/8
61/8 62/21 68/20 69/2
75/18 86/10 99/7
100/8 100/20 104/17
106/7 112/6 112/11
120/3 128/23 130/14
132/20 138/22 141/11
142/3 142/7 142/17
143/1 143/7 143/7
143/13 143/14 143/15)
143/20 143/21 143/25)
144/6 145/1 145/11
151/22 165/17 171/9
173/9 175/17 175/23
175/24 176/12 179/12)
184/17 192/6 193/18
193/22 194/20 201/22!
202/4
wide [1] 118/14
wider [3] 20/6 21/7
33/4
will [83] 4/1 7/4 9/3
9/8 9/16 19/22 20/9
23/19 26/3 26/21
32/17 32/20 32/21
39/21 39/24 39/25
40/1 40/3 40/8 42/23
44/3 46/13 46/18
46/21 50/23 52/1
52/11 57/22 59/5
65/11 65/20 66/3 66/4
66/6 66/13 67/21 68/2
68/3 73/24 74/1 74/2
74/4 74/6 74/10 79/22I
80/2 80/5 80/5 80/9
80/15 81/16 82/7
82/14 82/15 83/15
84/3 85/13 85/17 87/6
88/9 89/11 90/13
107/11 114/11 119/15)
122/19 126/12 127/11
132/11 134/15 136/25)
149/3 162/7 167/1
175/20 190/18 191/2
191/9 191/16 191/17
191/18 192/25 206/6
willingness [1] 52/8
WIP [1] 107/13
wired [2] 25/7 62/24
wish [1] 73/4
(87) weeks - wish
Ww
wished [1] 27/14
within [35] 8/11
10/15 15/8 55/16
86/24 96/17 99/18
102/7 104/21 105/7
109/4 110/15 111/4
119/1 126/16 127/1
135/14 140/23 140/25)
149/4 156/7 164/20
170/15 182/9 190/21
197/4 199/9 202/16
202/22 204/16 204/21
204/25 205/2 205/18
207/19
without [11] 20/22
24/21 79/24 102/10
119/9 161/7 175/4
176/10 177/13 185/25
189/7
WITN00530100 [1]
94/21
WITN09510100 [2]
1/18 7/8
witness [55] 1/22 2/5
AIT 4/12 7/7 10/25
17/13 22/4 22/6 22/8
22/18 22/19 24/12
24/25 25/2 30/1 30/12
33/15 35/17 38/22
39/18 43/2 53/2 55/8
56/12 85/25 90/3
90/21 90/22 91/5
101/4 111/24 112/1
112/7 112/19 178/12
178/14 179/8 179/19
184/7 188/4 191/1
193/13 201/23 202/5
202/17 203/4 203/12
203/25 207/2 209/16
209/23 210/3 210/10
210/16
witness's [1] 94/20
witnesses [9] 22/22
24/25 38/25 112/12
202/7 202/20 203/13
210/5 210/7
Womble [47] 5/11
5/18 6/4 40/17 48/8
53/20 54/16 55/1
55/10 55/12 55/16
56/23 57/2 57/20 73/6
81/1 109/2 109/4
113/8 114/2 115/2
120/11 120/17 120/25}
121/6 121/9 123/22
124/13 136/4 136/11
137/2 138/13 140/4
140/15 144/3 146/15
149/5 149/18 151/6
153/11 161/17 175/9
177/24 179/16 182/19)
188/20 201/7
won't [1] 76/3
wonder [2] 152/18
162/3
Woodward [2] 10/9
10/19
word [7] 32/1 52/13
52/13 68/9 80/15
156/17 184/8
wording [9] 25/18
179/5 180/8 182/19
183/7 197/17 198/15
199/19 200/7
words [6] 19/2 27/5
88/18 122/16 179/24
183/24
work [48] 4/13 6/13
6/14 6/14 6/14 6/17
6/19 6/21 6/22 6/23
6/24 8/20 8/23 8/24
9/2 9/7 9/10 9/18
12/10 17/2 21/4 44/12
44/14 44/24 45/14
48/21 54/3 54/5 54/6
54/7 54/9 64/4 87/19
93/12 97/7 97/11
97/13 97/18 97/22
98/25 105/1 107/13
118/11 178/17 196/7
197/5 199/11 201/2
worked [15] 54/17
92/3 92/12 93/4 94/1
99/20 101/15 101/20
101/21 109/17 109/18)
137/19 174/1 203/20
209/15
working [10] 9/14
16/24 57/1 92/14
109/19 110/4 129/4
180/25 192/16 204/17)
works [2] 93/21
93/24
worried [1] 187/16
worry [1] 19/16
worth [2] 24/11 26/10)
would [163] 8/3 8/12
8/21 8/25 9/12 9/18
10/12 12/18 14/2 14/5)
14/6 14/7 14/18 17/22
20/1 21/18 21/24
23/21 24/9 25/18
31/18 35/8 35/10
39/11 40/14 41/4 41/8)
41/14 41/16 43/15
44/25 45/4 45/14
45/24 46/19 47/23
48/1 48/17 48/18
48/20 49/23 50/19
54/9 55/18 63/23
65/16 68/5 68/21
74/19 74/24 75/7
76/17 77/10 80/20
88/3 88/23 89/3 94/15)
95/10 95/14 95/25
96/2 96/8 97/22 98/2
98/6 99/11 99/14
99/16 100/7 101/23
102/8 103/12 105/15
105/24 108/7 108/10
108/12 108/18 110/8
110/8 110/11 110/17
110/25 111/2 111/17
111/21 112/15 112/22
114/20 116/12 118/21
118/22 119/3 119/5
119/25 120/20 120/21
122/16 125/24 127/5
127/7 128/20 130/7
130/20 130/25 132/12
132/18 132/21 133/13
133/17 133/25 134/7
136/3 136/3 136/18
139/1 140/23 141/18
142/3 142/9 144/16
145/10 145/13 145/25
146/10 148/15 148/16
150/3 150/21 151/25
154/10 156/24 157/6
157/8 157/12 172/18
175/24 179/3 179/5
183/23 186/16 187/25
188/2 188/10 190/14
190/17 191/6 191/11
191/14 192/19 195/19!
199/22 200/1 200/11
201/6 202/12 204/2
204/22 205/2 205/3
205/6 209/13
wouldn't [11] 22/1
98/14 101/25 102/18
117/23 125/10 130/6
133/4 133/19 136/19
142/7
wrapped [1] 190/21
Wright [6] 99/21
110/1 125/7 127/8
202/21 206/1
write [2] 36/14 71/6
writes [1] 134/9
writing [2] 68/7
192/19
written [7] 1/17 62/21
64/14 108/6 148/1
194/24 209/24
wrong [11] 14/17
23/2 49/12 49/13
49/15 55/25 61/4 82/6
116/24 137/4 178/7
wrongly [2] 150/4
150/7
wrote [3] 39/4 132/18]
139/5
Y
yeah [164] 9/6 11/14
13/8 23/25 31/1 33/20
36/12 44/21 53/18
61/25 66/17 66/24
71/12 71/15 73/20
73/20 76/22 77/13
78/8 84/20 85/1 86/25)
89/20 91/6 91/12
93/10 96/7 96/11 99/6
101/3 104/6 106/1
107/1 108/10 108/17
110/6 110/11 113/23
116/15 117/12 117/18}
121/3 122/5 124/12
127/1 128/14 130/3
130/12 130/14 130/16}
131/3 132/19 135/11
135/18 136/12 136/17I
136/22 137/1 137/20
138/5 139/24 142/2
143/13 143/18 143/18
144/2 145/5 146/17
147/25 150/13 151/4
151/19 154/12 154/25}
157/14 157/1 157/11
157/21 158/2 158/2
158/4 158/12 158/15
160/2 160/19 161/9
162/2 163/20 163/24
165/10 167/25 168/11
168/25 169/3 169/7
169/10 169/12 169/12
169/22 170/6 170/8
170/15 170/24 171/2
171/10 171/12 171/17}
171/21 171/21 172/10
173/8 174/6 174/19
174/23 175/1 177/14
177/14 182/14 183/25}
185/21 186/12 187/5
188/15 190/7 190/8
194/4 194/13 194/18
195/6 195/12 195/20
196/6 196/7 196/20
197/12 197/16 200/3
201/12 201/14 201/19)
202/11 202/14 202/19
202/23 203/11 203/15)
204/1 204/10 204/14
204/19 204/23 205/7
205/10 206/5 206/9
206/10 206/10 206/13,
207/20 207/20 207/25
208/7 209/12 209/17
year [1] 7/21
years [19] 6/13 7/4
9/3 9/4 9/5 9/24 18/16}
22/7 36/23 40/13 60/6
100/5 110/22 130/20
175/17 193/19 197/2
198/22 199/1
yellow [3] 58/15
115/18 207/8
yes [270]
yes/no [1] 63/23
yesterday [2] 52/14
79/11
yet [8] 18/3 44/14
75/1 76/3 108/19
131/12 157/25 173/17)
you [899]
you'd [12] 2/14 4/3
26/1 46/4 59/17
126/16 135/20 152/6
152/7 153/17 164/10
173/4
you'll [2] 2/1 71/23
you're [48] 1/20
10/19 14/25 16/18
20/2 22/13 22/19 27/3I
34/7 35/7 37/24 40/7
41/21 45/12 49/15
53/15 54/22 59/23
62/25 68/17 68/18
70/1 82/21 94/5 95/10)
98/9 103/20 105/15
107/2 134/1 135/7
138/3 139/12 143/1
145/19 148/2 157/4
158/2 162/20 167/10
170/2 174/7 186/20
189/5 195/14 195/15
203/2 205/12
you've [41] 1/16 2/18
6/2 6/17 19/2 22/6
24/4 44/15 63/1 64/2
68/8 76/6 79/8 85/15
96/25 101/15 109/14
113/7 128/12 139/22
148/1 148/7 153/14
160/6 160/22 164/8
169/14 169/17 179/17
184/24 186/11 192/1
195/4 198/14 200/7
201/4 202/4 203/16
203/17 204/11 210/12I
your [150] 1/13 1/17
2/3 2/10 2/12 2/18
3/21 3/21 3/24 4/2
5/20 7/7 8/2 12/1
14/13 15/24 16/20
16/24 17/6 17/13
18/18 21/2 22/19
24/23 27/5 27/22
28/21 29/13 31/18
35/12 36/4 41/12 43/2I
44/9 50/24 51/12
52/19 53/2 55/8 56/12)
56/14 57/10 57/11
58/5 58/8 58/9 58/25
61/24 63/13 63/14
69/14 69/17 69/20
70/14 70/16 71/10
71/13 72/18 78/19
79/7 79/8 80/17 82/25I
83/12 91/2 91/4 91/10}
91/14 91/18 91/21
93/19 94/19 94/23
97/2 99/24 101/1
101/4 102/3 102/20
102/24 103/5 107/15
108/22 108/25 108/25)
109/7 109/10 109/13
(88) wished - your
Y
your... [62] 115/24
115/25 116/8 116/13
118/17 123/20 125/22)
126/5 126/15 127/14
130/22 131/2 131/25
132/6 133/8 134/4
137/3 137/12 137/14
139/12 139/18 140/1
141/11 141/16 144/8
147/24 149/15 152/3
153/9 153/12 153/14
153/19 154/9 156/7
159/6 161/3 161/4
161/11 164/5 164/8
170/25 171/11 176/1
176/4 177/10 178/13
184/24 186/8 190/4
191/22 192/5 193/12
193/13 193/15 202/12)
203/23 204/13 205/12
207/23 209/3 210/12
210/16
yours [1] 58/13
yourself [3] 20/3
123/6 147/17
Zz
zero [2] 42/20 57/24
zip [1] 126/9
(89) your... - zip