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The Post Office Horizon IT Inquiry
Thursday, 13 June 2024
(9.45 am)
MR BLAKE: Good morning, sir, can you see and hear me?
SIR WYN WILLIAMS: Yes, I can, thank you.
MR BLAKE: Thank you very much. This morning we're going to
hear from Mr Andrew Parsons.
SIR WYN WILLIAMS: Yes.
ANDREW PAUL PARSONS (affirmed)
Questioned by MR BLAKE
MRBLAKE: Thank you. Can you give your full name, please?
A. Andrew Paul Parsons.
Q. Mr Parsons, you should have in front of you a bundle
containing your witness statement. Is that witness
statement dated 17 April 2024?
A. Itis.
Q. [tis a very lengthy witness statement, 557 pages in
length. Could I ask you to turn to the final
substantive page, page 557. Is that your signature?
A. Yes.
Q. Can you confirm that that statement is true to the best
of your knowledge and belief?
A. Itis.
Q. Thank you. That statement has the Unique Reference
Number WITN10390200 and that will be uploaded on the
Inquiry's website in due course. That sits alongside
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involved in the Castleton case. Was that something you
were aware of when you qualified?
A. I was aware of the Castleton case.
Q. Your main involvement in Horizon, I think, was from
April 2013; is that correct?
A. That's correct.
Q. When you first started working on those Horizon related
matters, as a senior associate, who did you report to
within Bond Dickinson?
A. Gavin Matthews.
Q. Thank you. In terms of the Post Office, who were your
main points of contact at that stage?
A. _ Initially it was Rodric Williams and then later Susan
Crichton.
Q. What was your view as to their competence and abilities?
They both seemed like experienced in-house lawyers.
Q. I'm going to start today by taking you to the Helen Rose
Report. That can be found at POL00022598, please. This
is a report that's well known to the Inquiry but I'll
take you very briefly to a couple of key paragraphs in
that report. The date of that is 12 June 2013, so soon
after your Horizon work began, and it's an investigation
into the Lepton branch.
If we could turn over the page, the subpostmaster in
this case had denied carrying out a transaction and
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1,172 exhibits, comprising 18 substantive bundles of
exhibits.
There's a large amount of paperwork today. I'm not
going to take you to hard copies -- I'm going to try to
deal with it all on screen -- but I will be taking
a note of my own in relation to a few matters as we go
along.
You are currently a partner at Womble Bond
Dickinson?
Yes.
You began your career there as a trainee, I think, in
2006 when it was Bond Pearce; is that correct?
Yes.
You qualified in September 2008 and joined the
Southampton office?
Yes.
You became a senior associate in 2012?
Yes.
You became a partner in 2016?
Yes.
We know from Phase 4 of this Inquiry that Bond Dickinson
was involved in civil actions against subpostmasters
from the early time when you were qualified as
a solicitor, so the early years of your qualification.
We heard from, for example, Stephen Dilley who was
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there was an investigation. Helen Rose has written this
report. If we scroll down, there's a section on
reviewing the data. She says there:
"The Fujitsu logs were requested for this branch,
but whilst waiting for these to arrive communications
took place with Gareth Jenkins at Fujitsu for more
details to gain an understanding what had occurred at
this branch."
Just pausing there, Gareth Jenkins, is that somebody
who you were aware of, even in broad terms, in April
2013, or thereabouts?
Thereabouts or shortly thereafter.
"Questions asked and extracts from various emails in
response."
We've seen this plenty of times, there are a set of
questions that Helen Rose has asked and answers that
have been provided by Gareth Jenkins. If we scroll over
the page, please. One of the key parts for this Inquiry
if we scroll down, she says:
"Question -- I can see where this transaction is and
now understand the reason behind it. My main concern is
that we use the basic ARQ logs for evidence in court and
if we don't know what extra reports to ask for then in
some circumstances we would not be giving a true
picture.
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"I know you are aware of all the Horizon integrity
issues and I want to ensure that the ARQ logs are used
and understood fully by our operational teams who have
to work with this data both interviews and in court."
If we scroll over the page she makes some
recommendations.
“Recommendations
"I do believe that the system has behaved as it
should and I do not see this scenario occurring
regularly and creating large losses. However, my
concerns are that we cannot clearly see what has
happened on the data available to us and this in itself
may be misinterpreted when giving evidence and using the
same data for prosecutions."
Now, you've set out in your witness statement why,
in your view, this wouldn't have changed the picture
very much. I think it's paragraph 84 of your witness
statement, I don't need to take you to it.
We can see that this report was sent to you. Could
we please turn to POL00190324. We have an email at the
bottom of the page, please, from Dave Posnett to Rodric
Williams. He says as follows:
"Rodric,
"Please find associated a report from our fraud
analyst, Helen Rose, in respect of Lepton SPSO. This
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3 July 2013, and he says:
"Andy -- can you take a look at this so you can give
me an overview on the phone sometime today."
He attaches there the Helen Rose Report.
I think you've said in your statement that you don't
recall receiving the report; is that correct?
I don't recall receiving the report, no.
Looking at this email, it is likely that you did receive
the Helen Rose Report on 3 July --
Yes.
-- and it is likely that you considered its contents?
Correct.
You would have seen the wording at the bottom, the
concerns that are raised by Dave Posnett?
I would have focused on the aspects of that report that
were talking about transaction reversals because that
was the same issue that had arisen in spot review
number 1, that I've looked at recently.
The report itself is not very long. It's four pages.
(The witness nodded)
So it's likely, isn't it, that you would have read the
report? I mean, it's actually three pages of text and
‘one page of front page?
Yes, I accept I would have read the report.
Yes. Moving on to the suspense account bug, I think at
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office doesn't feature as part of our Second Sight spot
reviews ..."
Just pausing there, by this stage, so summer of
2013, I think you were involved in those Second Sight
spot reviews; is that correct?
I was assisting Post Office with drafting the responses
to the spot reviews.
Thank you:
"... but the subject matter is Horizon (and indeed
Credence) related. Could I ask that you consider the
report and feed any comments back as it could be
a potential issue at some stage.
"In summary, the specifics concern a ‘system
reversal' of a transaction following a system failure.
This is normal practice, but the Horizon logs (and
Credence logs) indicate that the reversal is an
‘existing reversal’, implying that the reversal was
manually entered by the clerk/subpostmaster.
"I think there's a remote possibility that this
could be a problem in terms of using the data for
evidence/prosecution purposes, but nevertheless it is
still a possibility. Myself or Helen are happy to talk
through anything that requires explanation."
If we scroll up to the top of the first page,
please, we can see Rodric Williams sends it to you on
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that time it was the 14 bug or referred to the number 14
because of the number of branches that it was known to
have affected; is that correct?
Correct.
Could we please look at POL00296703. If we start at the
bottom of the first page, we can see an email from Ben
Thorp, was he in the Post Office Legal team?
He was a secondee from Bond Dickinson to the Post Office
Legal team.
Thank you. In fact, that's how he introduces himself at
the beginning of this email. He says:
"By way of a very brief introduction, my name is Ben
Thorp. I am a Bond Dickinson secondee (from the
Newcastle office) currently working with Rodric Williams
in [the Post Office's] Legal Team for the next few
weeks.
"We have received the attached query from business
regarding historical issues a very limited number of
branches had with Horizon. [The Post Office] intends to
refund any losses caused by these issues, but not seek
to recover any gains.
"Could you please review the letters and let Rodric
and me have any comments you may have, particularly in
the context of the spot reviews?
"If you would like to discuss anything arising from
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your review, please do give either Rodric or me a call."
If we scroll up we can see your response. You say:
"Ben, Rodric
"To be honest, I don't quite follow the logic of
Andy Winn's letters (I suspect this is just me and that
this just makes expect sense to the subpostmasters!).
"The risk here is that disclosing any form of
an error in Horizon could become problematic if it ends
up in the hands of the [Justice for Subpostmasters
Alliance]. However, we have no real option but to
disclose this issue and make right the error with the
[subpostmasters] that have been [affected]. To do
otherwise, risks damaging [the Post Office's]
credibility on Horizon and severe criticism from the
Fed.
"My [suggestion] therefore is to make sure that we
fully understand the root cause of this error before
going public. Hopefully, this will give us a good
explanation as to why this one error does not undermine
our general view that Horizon is otherwise robust.
"With that in mind, are you happy for me to speak
... to Simon Baker/Andy Winn to get some more
background/technical details?"
You say there "Hopefully, this will give us a good
explanation as to why this one error does not undermine
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was that something you were aware of, that the business
wasn't happy with certain language?
No, I had no instructions as to use of particular
language. I think it's a fairly ordinary thing for
lawyers to do to soften wording in letters.
You say:
"I don't think we should apologise in the letters.
I know this sounds hard but in apologising we are
admitting some degree of culpability. I think we should
maintain a more cold, procedural approach to correcting
what is effectively an accounting irregularity."
Is that, again, something you did, your own
initiative without instructions on that particular
matter?
These are my recommendations to Post Office.
You then say:
“In some circumstances it appears that [an] error
caused a transaction record from a former
[subpostmaster] at a branch to be carried over into the
records of a later [subpostmaster] at the same branch.
In my view this is a dangerous admission, as the
complete separation between [subpostmaster] records is
a cornerstone principle of ensuring Horizon's integrity.
Although this has happened and is completely
explainable, I don't think we ever want to expressly
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our general view that Horizon is otherwise robust"; were
you concerned, on reading that, that it was
a possibility that that general view could have been
undermined?
At this stage, I didn't understand the nature of the
error in hardly any detail. I was also only about two
months into working for Post Office in earnest, so my
understanding of Horizon was pretty limited, so I wanted
to understand more information before forming that view.
Can we please turn now to POL00144848. So letters by
this stage had been drafted and sent to you for review.
You are now responding to Rodric Williams and you say:
"I've reviewed the [subpostmaster] letters. I've
attached mark-ups of the two letters which show the
suggested amendments that should be made across all the
letters.”
You set out in bullet points the various amendments
that you've made. The first:
"To insert an opening paragraph that explains [the
Post Office's] investigation and highlights the fact
that we have sought to protect [subpostmasters] from any
harm in the interim period.
"To remove the word ‘problem’ and to replace with
the dramatic word: ‘issue’."
Just pausing there, was that your own initiative;
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document this."
Are you saying in that final bullet point that it's
such an important issue for Horizon that you don't think
that it should be documented?
I'm talking here in the context of these letters, which
are individual letters to go to individual
subpostmasters.
Why wouldn't you want to expressly document something
that is the cornerstone of ensuring Horizon's integrity?
We're talking here about these particular letters. This
isn't advice to suggest that the whole issue should not
be documented.
Why wouldn't you want to document it in those letters?
Because each letter was individual to each branch. Each
one was customised, so it dealt with the issue in that
individual branch.
Why wouldn't it matter? Why would you be concerned
about expressly documenting something? Is it because
you would be concerned about disclosure, for example, in
other cases?
Disclosure of this issue may have come out anyway
because the issue was documented in other documents.
What I'm talking about here is the individual letters,
each one was customised to each individual subpostmaster
to reflect their position and how it had impacted on
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them.
I'm not too sure how that answers the question that I've
just asked though, which is about disclosure in other
cases. Were you concerned that, by documenting it in
these particular cases, it would then be on record to be
disclosed in other matters? Was that a concern that you
had that is expressed in this bullet point?
If it had been documented in those letters then, yes, it
would have been disclosable in other matters but my
point being is there would have already been in
existence documents about this issue.
Was a concern that you had that, if you documented it,
it would then become disclosable in other matters?
I don't believe I gave it that level of thought.
You were, at this time, summer of 2013, concerned about
expressly documenting matters relating to Horizon
integrity?
Again, this is in the context of letters to individual
subpostmasters. It's not a general observation on how
Post Office should document problems in Horizon.
Can we please look at the letters. Can we turn to
POL00144849. Thank you. These are your amendments to
the letters. This is to a subpostmaster and it says:
"I am aware that you have communicated previously
with our Current Agents team in relation to
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Then we see you've changed the word "problem" to "issue"
and you've struck out the words "by the former
subpostmaster"; is that because, as you identified in
that previous email, that, at the cornerstone of
ensuring Horizon's integrity, was the separation between
subpostmasters accounts --
That's what I understood at the time.
-- and, thereby, by removing reference to the former
subpostmaster, it would not be clear to the person
reading this letter that that strict division between
subpostmasters' accounts had not, in fact, functioned on
that occasion?
I think it would have been possible for the
subpostmaster to have worked that out because it
mentions 2010; "TP8" is trading period 8, so they would
have known whether that happened whilst they were the
subpostmaster or not.
So why strike it out?
Because I didn't think it was relevant to this
particular subpostmaster.
It's not because you didn't think it was relevant. We
can go back to those bullet points if you want but you
said, in that final bullet point, that:
"It is my view this is a dangerous admission as
a complete separation between subpostmasters' records is
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2 unexplained discrepancies that have impacted your
branch. Thanks for alerting us to the issues."
So this is a letter where someone has already made
a complaint and it's responding to their specific
complaint?
That's what I understood, yes.
You've added this. You've added:
"In light of these discrepancies, Post Office has
thoroughly investigated your branch's records and,
whilst undertaking this investigation, we have ensured
that any known discrepancies have not been charged to
your account. I write now to confirm the outcome of our
investigations.”
What was the thorough investigation that had taken
place?
This was information provided to me by Andy Winn of Post
Office.
This was your insertion into a draft letter. What
investigations had you carried out that the Post Office
had thoroughly investigated the branch's records?
I had personally not carried out any investigations.
Were you, nevertheless, comfortable in inserting that
addition?
Those were my instructions from Andy Winn.
“Ican confirm", and then you speak about the gains.
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a cornerstone principle of ensuring Horizon's integrity.
Although this has happened and is completely
explainable, I don't think we ever want to expressly
document it."
Surely, by removing reference to "by the former
subpostmaster", you're making it less clear that that
separation had been violated?
I accept that.
If we scroll down, please, and, again, strike out the
word "problem", replace it with "issue", and then strike
out the apology at the end?
What was the problem, legally, with making
an apology?
I think sometimes apologies can be interpreted as
admissions and it's not -- I think it's pretty common
for lawyers to -- in letters, to consider whether the
apology is appropriate or not.
Post Office were, in this case, making an admission,
weren't they?
Yes.
There had been an issue or a problem, it had been
corrected and this was notification to the subpostmaster
that that had been corrected. What was the problem in
this particular case of apologising for that?
In my view, it leads people to consider that there was,
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as I say, an admission of legal fault when, in fact,
Post Office's view is, yes, there had been a problem but
it was being corrected through proper channels.
Was that something you did regularly on behalf of the
Post Office?
It would depend on the circumstances.
Are there other letters where you would have removed
apologies?
Possibly.
Could we please look at POL00144850. This is the other
attachment. This is the other amendment, made very
similar amendments. If we scroll down we can see
reference to that "thorough investigation".
Do you see, in terms of the thorough investigation,
is it likely that, in fact, the investigation was only
in relation to this particular issue that had been
identified, the 14 bug?
I can't now recall.
Do you recall any wider investigation that took place in
relation to these subpostmasters' branches investigating
their branch records, any wider than the identified
issue in this particular case?
I can't recall.
Would you accept that, reading that letter, it sounds as
though a thorough investigation has taken place that is
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same day, 27 June 2013, POL00144864. I think it's the
bottom email on that page. You email Rodric Williams,
you say:
"Rodric
"As discussed, please find attached a version of the
letter for those [subpostmasters] who are currently not
aware of the situation."
So there were letters going out to those who had
actually made specific complaints, those who knew about
the investigation, and then a third set of matters which
was to those who weren't already aware of the situation;
is that correct?
I can't now recall what that was a reference to.
Well, looking at this email, does it seem as though
there was a further set of letters to the subpostmasters
who were not currently aware of the situation?
My recollection is there were two versions of the
letters, one for those who had suffered a loss, and one
for those who had suffered a gain. I don't recall
whether there was a third version for another category.
Okay, well, let's have a look at the draft letter that's
attached to this tell that's sent in your name on
27 June 2013. That is at POL00144854. This is the
letter that was attached to your email. If we scroll
down, we can see it's informing a subpostmaster and it
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wider than simply one particular issue?
I can see how someone could read it that way but I also
think it's read in the context of looking at
a particular issue.
Where does it explain that a particular issue has been
thoroughly investigated?
Because it's targeting those specific discrepancies in
the accounts.
Did you draft it intentionally so that it was ambiguous
as to what the investigation had been into?
I don't believe so.
For example, why wouldn't it have said, "The Post Office
has thoroughly investigated this issue"? It says,
“investigated your branch's records". It's drafted in
quite a wide way, would you accept that?
I can see how you could read it that way. I don't
believe I gave it that level of thought at the time.
Can you see how the recipient may well read it that way?
I think they would have recognised that this was
investigating a particular discrepancy and that's what
was being investigated.
So it wasn't your intention to suggest a broader
investigation than, in fact, had taken place?
Correct.
Can we please turn to POL00144864. We're still on the
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says, "Branch discrepancies at", and it names the Post
Office:
"You may have been aware of 2 small value
unexplained discrepancies that have impacted your
branch.
"In light of these discrepancies, Post Office has
thoroughly investigate your branch's records and, whilst
undertaking this investigation, we have ensured that any
known discrepancies have not been charged to your
account. I write now to confirm the outcome of our
investigations."
It refers to a small value declaration that was
amended.
Looking at this, is this something you recall now;
does this assist?
It appears that the first paragraph has been changed.
This isn't a change; this is one that you sent
independently.
Mm.
You said, "Please find attached a version of the
letter", so it's a further letter to those who weren't
aware and it refers specifically to an issue in their
particular Post Office, doesn't it?
Correct.
Do you think it's fair to say that a reader of this
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letter will be under the impression that, in fact, there
are two small-value discrepancies and that this is
effectively a business as usual type correspondence, no
explanation, for example, of it affecting other
branches?
I couldn't comment on whether this was a business as
usual type correspondence for Post Office to send.
You were drafting the letters?
Mm-hm.
You were assisting the Post Office drafting the letters?
(The witness nodded)
If you were to read this and you're a subpostmaster, do
you think you might get the impression that you were the
only one affected by this discrepancy?
You might get that impression.
Do you think you might get the impression that, in fact,
it's only two small-value discrepancies that have
occurred?
In that branch, yes.
But you wouldn't have known about other branches, would
you?
Correct.
Again, was that the intention of this correspondence: to
suggest to the recipient of the correspondence that it
was only them that was affected and that it wasn't a big
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So the correspondence we saw before about the two
small-value unexplained discrepancies. Alongside those
small-value discrepancies, there were large ones?
That's my -- yeah, my distant understanding is there
were some larger ones, yes.
“However as it was any a few branches, Chesterfield
didn't see the pattern in the errors for over 12 months.
It was only as more issues were raised and no individual
branch-by-branch explanation could be found, that
someone (not sure who) realised that it could be
an error in Horizon affecting multiple branches.
"I presume that it then took time to engage Fujitsu;
investigate the technical causes and determine the
effect of the causes; etc."
So this is a bug that occurred in 2011 that was only
realised 12 months later; is that right?
That was -- I think that was my understanding at the
time, based on what Andy Winn had told me.
We're now in 2013, summer of 2013, and you say you
presume it took time to engage Fujitsu, so
a considerable further period has taken place before
subpostmasters have received any correspondence on the
issue or received that correspondence explaining the
issue?
That's my presumption at the time, though I just would
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deal?
I don't believe that was the intention.
Why in that correspondence not say to the recipients
"You are one of a number of branches that have been
affected by this issue"?
I don't believe we just -- I gave that any consideration
and the instruction was to draft a letter that was
focused on each individual branch and explain their
position.
Can we please turn to POL00144871. Same day, another
email between you and Rodric Williams. The bottom email
is Rodric Williams to you saying:
"When We discussed this yesterday, you mentioned
this might have been kicking around for [circa]
12 months.
"Can you give me a couple of bullet points on when
this first came up and what [the Post Office] did next?”
If we scroll up, we see your response. You say:
"Rodric
"The issue manifested in around 2011 and those
[subpostmasters] that suffered sizeable errors (ie ones
that were easy to spot) reported the issue immediately."
Pausing there, so there were subpostmasters who
experienced sizeable errors?
Yes.
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note that my understanding of this bug is it's nature
was that it was annually reoccurring. So it would only
come up once a year, which was part of the context of
this.
So it had happened twice before it was actually spotted?
Correct.
You say there:
“I presume that it then took time to engage Fujitsu;
investigate the technical causes", et cetera.
Were you aware of the extent to which Fujitsu had
been investigating the causes?
Not at this time.
So, again, if we refer back to those letters that I took
you to, where you referred to a thorough investigation,
in fact, you personally weren't aware of the extent of
the investigation?
I was working on the instructions provided to me by Andy
Winn.
Did you question those instructions?
I remembered speaking to Andy Winn and discussing the
matter but, beyond that, I can't remember the details of
those conversations.
So we're still in the summer of 2013, you now, by this
stage, know that there was this bug, not just that
subpostmasters' records couldn't be kept separate from
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a successor subpostmaster but it was also a bug that
went on for a year without anyone noticing and took even
more time to resolve; is that right?
Correct.
So summer 2013, I'm going to put new evidence of
suspense bug, you were concerned about its implications
for accounting integrity
Correct.
-- and you had, in an email raised concerns about
documenting that?
I'd raised concerns about documenting it in these
specific letters, not generally.
Can we please turn to POL00407496, please. Still in the
summer of 2013, 1 July 2013 now. Could we start on the
second page, the bottom of the second page. An email
from Simon Baker to Rodric Williams:
"Rod
"It would be helpful if we can show that Horizon
bugs were discussed openly in our court cases.
"We know that the Falkirk bug was discussed in the
Misra case, can you find out if there are any other
examples where bugs have been discussed in court."
That request is ultimately sent to you, and we can
see that and your answer, on page 1. So if we go to the
top of page 1, we can see, you say:
25
I don't think I meant any difference between those two
phrases.
Well, you were aware that, in that time, subpostmasters
had been raising problems with Horizon and that they
couldn't necessarily pinpoint that to a specific or
actual bug?
Yes.
"There are a number of cases handled by our paralegal
team that have been put on hold because
[a subpostmaster] has alleged problems with Horizon."
So there are also some that are now on hold because,
I think, Second Sight are investigating?
Correct.
"These cases are suspended pending Second Sight Report.
It may be that on closer inspection these cases reveal
a specific complaint about an error in Horizon however
we would need to undertake a deeper review of each case
to determine this.
"On Castleton:
"I have spoken to the lawyer had a conducted this
litigation which took place in 2007."
Can you assist us who it was that you spoke to?
I can't recall but I believe it would have been Stephen
Dilley.
"The case was principally about accounting records --
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“Other than the Castleton and Misra, we are not
aware of any litigation that has involved an allegation
of an actual bug in Horizon.
"However, this is based on anecdotal discussions
inside Bond Dickinson."
Just pausing there, who had you spoken to inside
Bond Dickinson?
I don't recall.
“Please bear in mind that we have handled [hundreds] of
cases over the last 5-10 years for [the Post Office] so
(absent a case-by-case review) it's impossible to say
for certain that no [subpostmaster] alleged a Horizon
bug.
"We are however confident that no case in the last
2 years has involved an allegation that there is
a specific flaw in Horizon."
Just pausing there, the first paragraph that I took
you to refers to an actual bug.
Mm-hm.
At the third paragraph, we're talking about a specific
flaw. Were those words quite carefully chosen, in that
what you're saying here is an actual bug that has been
referred to, for example, by name or that is known
about, rather than, for example, a wider problem with
Horizon?
26
the Horizon challenges by Castleton were generally
uncoordinated and piecemeal. It should be borne in mind
that Castleton was unrepresented so there was no logical
attack on Horizon."
You say:
"I'm still looking to Misra and will report back
soon."
So can I add here to my list of things in summer of
2013 that you knew about the Castleton case; you knew in
broad terms, although not the specifics, about the Misra
case; and you knew that other cases were on hold because
of Horizon challenges?
I think the other -- I knew both about those cases, and
I think the other cases were generally all paused
because the Second Sight work was going on.
You knew that they were paused because they were raising
concerns about the integrity of the Horizon system?
That's what it says there but I can't recall that now.
The second Sight Interim Report is then 8 July 2013.
I'm going to take you very briefly to that report. The
Inquiry has seen it many times. It is POLO0099063.
Thank you. If we turn to page 6, please. We see there
the bugs that are referred to as “defects" in the Second
Sight Report. The first is the receipts and payments
mismatch problem impacting 62 branches. The second is
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the local suspense account problem, that's the 14 branch
issue that you had already been dealing with?
I'd been drafting the letters on.
Yes. 6.10, there's also another bug, I think that's the
Callendar Square/Falkirk bug. It says:
"POL has informed us that it is disclosed, in
Witness Statements to English Courts, information about
‘one other subsequently-corrected defect or ‘bug’ in the
Horizon software."
That was, in fact, the issue that you were looking
into on behalf of Rodric Williams, wasn't it; you were
looking into whether there were other bugs that had been
disclosed in court cases?
Correct.
Misra was one you were going to come back to him on;
presumably you did come back to him on Misra?
Yes, I believe we had someone review the case.
Because I am going to add, we're in the summer of 2013,
8 July, at least three bugs known to you?
I knew of three bugs at that time.
Yes. Cartwright King's advice on Gareth Jenkins now.
That was dated 15 July 2013. You've dealt with it in
your witness statement, paragraph 87. Could we please
start with WBON0000133. If we can start on page 4,
please, bottom of page 4, 16 July 2013. Susan Crichton
29
"I do also have concerns from a civil point of view
over a couple of statements in the draft response."
So this is the draft response to the Criminal Cases
Review Commission that had been drafted by Cartwright
King. He says:
"In particular, where it states:
"He has done so both to [the Post Office] and, in
expert witness statements and oral evidence, to the
court. In particular he has: attested to the presence
of defect detection and rectification systems; the
robustness of the prosecution audit trail; and stated
that, in his expert opinion, Horizon accurately records
and processes all information submitted into the system.
The Second Sight Interim Report demonstrates that this
was not the case’."
So that's there a reference to Gareth Jenkins, isn't
it?
Yes.
Yes. Your supervising partner there is raising
acconcern about that being included in the letter to the
Criminal Cases Review Commission?
Yes.
He says:
"I consider this to be unhelpful, given that the
[Second Sight] report found there to be no systemic
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emails you and she says:
“Andy -- we received a letter from the [it should be
‘CCRC’, Criminal Cases Review Commission] yesterday
which I have asked Cartwright King to review. Their
advice feels odd to me as if given on a take it or leave
it basis and I am not comfortable that's particularly
useful in this context. Could we discuss, I am happy to
go to another firm that specialises in criminal law or
a barrister, somehow it feels as if there is a conflict
here which I am not sure I understand."
Over the page to page 3, please. There's advice
given by Gavin Matthews. So he was your supervising
partner, was he, at this stage?
Correct.
He says:
"I know that you are with Simon and Andy today so
I have taken an initial look at this for you."
So on 16 July, is "Andy" a reference to you? Were
you meeting with Susan Crichton on 16 July?
I think that is a reference to me but I don't recall
that meeting.
He says:
"I agree with you that I would expect the advice to
[be] more prescriptive, ie you need to say this in
response.
30
problems with Horizon.
"It shows the need for all [Post Office] letters
(criminal and civil) to contain a consistent message --
so that the right hand and the left hand know what they
are each doing."
Were you aware that that was the advice from your
firm: that there needed to be greater coordination
between the criminal and civil sides?
I was copied to this email.
Yes, So you were aware —-
I was aware of --
- not just from this email but perhaps from
conversations with your supervising partner or --
I don't believe before this point my firm had any
involvement in the criminal side, so there may have been
no conversations before this email was sent.
So, from this point on, the approach of your firm was,
and the advice to the Post Office was, that "We need to
coordinate more between the criminal and the civil
side"?
I think that is an early comment from Gavin, which will
have been the first time we've been asked to consider
the crossover between the civil and criminal side and,
as he goes on to say later down, he notes he's not
a criminal lawyer and he suggests that they get advice
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from a criminal barrister.
Can we turn, please, to the first page. There's another
email from Gavin Matthews. You were presumably at this
stage very much aware of the Gareth Jenkins issues
because you were meeting Susan Crichton that very day?
I think I had been informed a few days earlier that
there was something to do with Gareth Jenkins but
I wasn't fully aware of the issues until I received
a copy of the advice from Cartwright King.
Thank you. We will go through that advice shortly.
Gavin Matthews emails Susan Crichton and says:
"Susan
"thought I would give you my preliminary views on
this pending our call ..."
Were you involved in a call on that day? I know you
met her, I think, on the 16th. Do you recall a call the
next day?
No. At this time, I was mainly focused on looking at
the response to Second Sight, because their report had
just been published.
"1. [The Post Office] needs to look at the response to
the CCRC in the context of the overall strategic advice
received from [Cartwright King] (including their advice
regarding [Gareth Jenkins/Fujitsu]).
"2, If [the Post Office] suffers losses directly
33
Clarke Advice on Gareth Jenkins, entitled
"Prosecutions -- Expert Evidence". Could we please
start on page 5, paragraph 14, "Expert evidence relied
upon by [the Post Office] in prosecuting offences":
"For many years both [Royal Mail Group] and latterly
[the Post Office] has relied upon Dr Gareth Jenkins for
the provision of expert evidence as to the operation and
integrity of Horizon."
So you were aware at this stage that the Post Office
had been relying on Gareth Jenkins for a number of years
to provide expert evidence?
That's what I took from this advice, yes.
Paragraph 15:
"Dr Jenkins had provided many expert statements in
support of [the Post Office and Royal Mail Group]
prosecutions ..."
So lots more than one, a number of different expert
statements, is that what --
That's what it says there.
Was that your understanding?
Yes, having read those words.
Thank you, Could we turn to page 13, please. We have
the conclusion, paragraph 37:
"What does this all mean? In short, it means that
[and that should read 'Gareth Jenkins'] has not complied
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referable to [Gareth Jenkins'] failure to comply with
his obligations as an expert witness, there are 3
potential entities against whom [the Post Office] may
have an action -- [Gareth Jenkins, Fujitsu and
Cartwright King] ...
"4. Given that [Cartwright King] are potentially
liable to [the Post Office] for any failure on the part
of [Gareth Jenkins/Fujitsu], I do think it would be
sensible to get a criminal QC to oversee the strategic
advice being given [Cartwright King] -- I'm not saying
that [Cartwright King] have definitely done anything
wrong but they may have done and are trying to blame
[Gareth Jenkins/Fujitsu] so it is very important to
check that their tactical approach is now overseen by
someone completely unbiased."
We will see, in due course, that advice is sought
from that criminal QC. We'll look at that advice.
Could we please, first though, turn to WBONO0000770. If
we scroll down slightly, we can see that Martin Smith
sends Susan Crichton the Simon Clarke Advice on Gareth
Jenkins and, if we scroll up, please, we can see that
Susan Crichton sends you that advice and that's that
same day, 17 July 2013.
Can we please turn to the Advice and that is
POL00006357. This is Cartwright King's advice, the
34
with his duties to the court, the prosecution or the
defence."
Paragraph 38:
"The reasons as to why [Gareth Jenkins] failed to
comply with this duty are beyond the scope of this
review. The effects of that failure however must be
considered. I advise the following to be the position:
"[Gareth Jenkins] failed to disclose material known
to him but which undermines his expert opinion. This
failure is in breach of his duty as an expert witness.
“Accordingly [his] credibility as an expert witness
is fatally undermined; he should not be asked to provide
expert evidence in any current or future prosecution."
If we scroll over the page, please. We see there
that first bullet point on the page, it says:
"... not least by reason of [Gareth Jenkins']
failure, material which should have been disclosed to
defendants was not disclosed, thereby placing [the Post
Office] in breach of their duty as a prosecutor.
"By reason of that failure to disclose, there are
a number of now convicted defendants to whom the
existence of bugs should have been disclosed but was
not. Those defendants remain entitled to have
disclosure of that material notwithstanding their now
convicted status."
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The next bullet point:
"Further, there are also a number of current cases
where there has been no disclosure where there ought to
have been. Here we must disclose the existence of the
bugs to these defendants where the test for disclosure
is met."
A very serious advice, one that you presumably took
very seriously at that time?
I read it but this was within the remit of the criminal
lawyers to deal with.
It's not just dealing with the existence of bugs, that
we've already seen you were aware of throughout the
summer of 2013 but, by now, potential miscarriages of
justice. Was that not something that played on your
mind at all?
It was a serious matter but it looked like to me it was
being addressed by Cartwright King and then subsequently
Post Office understood the seriousness, which is why
they brought in Brian Altman.
There were the subpostmasters who had been convicted on
the back of that evidence. Presumably, irrespective of
your day job, you were concerned about that?
I could see the seriousness of the matter.
Can we turn to POL00083932, please. This then sets in
motion a number of different actions, one of which is
37
I don't believe this minute is a verbatim record of what
was said and so I suspect some of the context or wider
language used has been lost somewhere. I don't think it
would be unsurprising for me to have given Post Office
advice on what its civil disclosure duties might be, and
that's what's being given there.
Do you see the civil disclosure duty to be, if it isn't
produced, it's then available for disclosure;
not, then technically it isn't?
This is talking about the fact that in -- civil rules of
disclosure are attached to documents, which is
information that's recorded.
Can you see that it might be interpreted as advice that
people shouldn't be writing things down?
No.
Martin Smith has given evidence to this Inquiry and he
said that you also spoke at the beginning of the
meeting, after Rob King, and you raised concerns about
difficulties which could arise following circulation of
minutes. Do you recall advising of concerns about the
circulation of minutes?
I don't recall advising on minutes at all in these
meetings. These calls were set up by the criminal
lawyers and they were driving the process.
Could we please turn to POL00006799, please. This is
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this regular call regarding Horizon issues. Do you
recall those regular calls?
I recall the calls as a concept. I don't recall any of
the individual ones.
Here we have the first of those, which was presumably
significant in the sense that it was the very first.
19 July 2013, you are named as an attendee; do you
recall attending that first regular call?
I don't recall attending that call but I have no reason
to doubt that I was there.
There are two entries from you that are recorded in
these minutes. Can we please look at the first, which
is on page 2. It says:
"Andrew Parsons ... Commented on the need to limit
public debate on the Horizon issue as this may have
a detrimental impact on future litigation."
Over the page, please, to page 4, second entry on
page 4:
"Andrew Parsons ... Stated all lists and
spreadsheets should be sent to Rosie Gaisford for
[collection].
"Spoke about emails, written comms, etc ... If it's
produced it's then available for disclosure, if it's not
then technically it isn't."
Is that accurate?
38
a contemporaneous piece of advice from Cartwright King,
it's what we know as the "shredding advice" or what's
been referred to as the "shredding advice", disclosure,
the duty to record and retain material. Over the page,
please, it summarises the information that's been given
to Mr Clarke. It says:
“At some point following the conclusion of the third
conference call, which I understand to have taken place
‘on the morning of Wednesday, 31 July, it became unclear
as to whether and to what extent material was either
being retained centrally or disseminated."
If we scroll down, please, to point (iii) he
summarises the various bits of information that he has
received, and he says:
"Advice had been given to [the Post Office] which
I report as relayed to me verbatim:
"If it is not minuted it's not in the public domain
and therefore not disclosable.
"If it's produced it's available for disclosure --
if not minuted then technically it's not'."
Again, those are the words, in effect, that we saw
in those minutes a moment ago. This is
accontemporaneous document. It was drafted/written on
2 August 2013. That sounds very much like the advice
that's attributed to you in that first meeting; do you
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agree with that?
No, I think the wording is different between the two
documents and, as I say, I didn't produce those minutes,
and I didn't approve those minutes. I don't thin Simon
has been accurately recorded in them. To be clear,
I never advised Post Office that they should not minute
those calls and, until the suggestion that there was
some connection between what I had said and this advice
was raised in this Inquiry, I had no idea that there was
any connection with anything I'd done.
There is a body of evidence that the Inquiry has seen
that suggests that your advice to the Post Office was
not to keep a paper trail?
I disagree. I did not advise Post Office against
minuting those meetings.
There is some evidence that you advised caution in
minute taking; do you agree with that?
In the context of this, I did not advise Post Office not
to minute those calls.
Do you think that those who were present at meetings
with you could have got the impression, from the advice
that you were giving at those meetings, that they should
be careful about writing things down?
I think they would have got the impression that they
would be subject to disclosure duties, which is what I'd
41
"I'd be happy to have one of our insurance lawyers
to look over the D&O policy to see if [the Post Office]
is required to notify the insurers. If not, then we
might want to hold fire on this.
"I would recommend tweaking the first paragraph.
The current version suggests there are problems with
Horizon -- when at present there are no systemic
problems to report."
Over the page, please, can we go to page 1, there
comes a time when you've spoken to the lawyers who
looked over the D&O cover. You say as follows:
"I've spoken to one of our insurance lawyers
[regarding] the D&O cover.”
Itis the last three paragraphs I want to look at,
you say:
"The risk of notification is that it would look bad
for [the Post Office] if it ever became public knowledge
that [the Post Office] that notified its insurer.
"To reduce this risk, it is recommended that the
rather than sending a formal written notification, [the
Post Office] speaks to Chartis (renamed AIG) and
verbally notifies them so as not to leave a paper trail.
In our experience, AIG may be prepared to accept
a verbal notification.
"[The Post Office] should make expressly clear to
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advised them. Had I said something to the effect that
could have been interpreted to mean that they shouldn't
be taking minutes, I would have expected Martin Smith,
from Cartwright King, who was on those calls, to have
said something, and nothing was said.
That can come down. Thank you. Do you think that you
gave advice to the Post Office that they shouldn't write
things down because they would be disclosable?
No.
Could we please turn to POL00145716. This is an issue
we're going to come back to but, given your answer just
now, I would like to give you the opportunity to address
it. If we start on page 4, please, around the same
time, July 2013, 24 July, the bottom of page 4, Susan
Crichton emails you and says:
"Andy could you take a look at this ... draft letter
to go to our insurance broker regarding the Horizon
issue. I have not looked at it.”
Your response is above, you say:
"The letter does nothing more than put [the Post
Office's] insurers on notice of the Horizon issues.
It's very bland. My only hesitation is whether it is
strictly necessary to do. From PR perspective, it would
look bad if this got into the public domain -- sign of
guilt/concern from the Board.
42
AIG that the notification is subject to litigation
privilege (this should help protect disclosure under
[the Freedom of Information Act]).”
Are you not there, in July 2013, giving advice to
the Post Office that they shouldn't write something
down, that they should communicate it only verbally?
In the context of this insurance point but, earlier, we
were talking about the minutes of those calls.
My question was much broader earlier. I said to you
"Have you ever advised the Post Office’
In which case --
- "not to write something down", and here we are, July
2013, precisely the same period in which that advice is
attributed to you, doing exactly that, aren't you?
In which case, I apologise because I misunderstood your
question. I thought you were asking it in the context
of the minutes of the Horizon call.
So you are accepting that, in July 2013, at the same
period of time you did advise the Post Office not to
communicate in writing to their insurer, not to notify
their insurer, because that would become disclosable
but, for some reason, the minutes that are attributed to
you, regarding very similar advice, that those are
wrong, are they?
I don't accept it was very similar advice. The advice
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that was recorded in those minutes, which, as I said,
they're not verbatim minutes and I'm not sure of their
accuracy, simply records the position that documents
need to be disclosed if they're created.
This is talking about a different matter, which is
communications with the insurance company and, actually,
ultimately, off the back of this, a written notification
was provided to the insurers.
Yes, but your advice in July 2013, the same period in
which this first Horizon weekly call is taking place,
was "Don't notify something because it will be
disclosable”. Isn't that the advice you are giving in
relation to minutes on the 19 July 2013?
No. They are two separate pieces of advice in different
contexts where I say different things.
They are remarkably similar though, aren't they?
No, I don't believe they are. I think the first one is
talking about the disclosability of documents. It
doesn't say anything in that minute about me saying that
minutes should not be kept or documents should not be
produced. And then, we're now ten days later, talking
in a different context about insurance issues.
But it's the same point: that if you write things down
about Horizon, about problems with Horizon, it might
become disclosable.
45
describing the creation of new documents by my client
which are then potentially disclosable. The use of this
word suggests to me that the note is not an accurate
record of precisely what was said."
So I'll just repeat the words that are in the
minutes. It spoke about:
"... emails, written comms, etc.
“If it's produced, it's then available for
disclosure. If it's not, then technically it isn't."
Your explanation in your witness statement is "That
doesn't sound like me, I don't use the word ‘produced’
in that context"; is that right?
I generally don't. I consider it in the context of
running productions of documents.
That's quite an elaborate explanation, isn't it, that's
set out at paragraph 105?
No, I think it's also reflecting -- if you look at the
minute, it's clearly a short précis of what was said.
It doesn't stand to be a verbatim minute and, therefore,
I think there is probably some inaccuracy in the minute
taking.
Your basis for saying that the minute is inaccurate is,
amongst other things, that you don't use that word in
that context?
Amongst other things but, also, reading the minute as
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But that's correct.
You shouldn't do that?
Apologies, that is correct.
That is correct?
Well, that is the state of the law, if you write
documents down you create documents, they can become
disclosable.
Therefore, you shouldn't create such documents?
I disagree.
But that is, in fact, what you're advising in relation
to the insurance?
As I say, it depends on the context in which the
question is put.
Okay, let me take you to your explanation in your
witness statement. So it's WITN10390200.
Thank you, it's page 64, paragraph 105. You say as
follows:
"I do not understand the reference to ‘produced! in
the comment that is attributed to me. The word
‘produced’ is not a word I would ordinarily use in this
context. I think of the word ‘produced’ in the context
of running a ‘production’ of documents from a data room
(which is a technical eDiscovery process), which are
then given to the other side in civil litigation as part
of disclosure. I would not use this word when.
46
a whole, I think it's obvious that it's not a verbatim
minute.
Can we please turn to FUJ00081921. The context of this
email does not matter for now, it's a 2019 email, but
let's just have a look at that middle email. It's
an email from you. You say, as follows:
"Pete, Matthew, Dave
"As part of the Court process, the experts on both
sides have to meet to try to agree a joint statement on
the key issues in the case. This has resulted in them
producing 4 Joint Statements. These statements are
produced without the involvement of the legal teams,
hence why we haven't sent these over to [Fujitsu] for
comments before now."
Could we turn, please, to POL00253345. Thank you.
Another email from you, again context doesn't
matter. Turn over to the third page, please. There are
points there:
"The draft order also sets out our proposed
directions to the March 2019 trial. These split out
into four phases ..."
Then we look at Phase 3:
"... the experts produce their principal reports
into Horizon."
"Phase 4 ... supplemental reports are produced in
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light of anything coming out [of] the Common Issues
trial."
Can we please turn to POL00000444. It's coming up.
Your witness statement in the Alan Bates case, fourth
witness statement, if we scroll down. Can we please
turn to page 24, bottom of page 24 of your witness
statement in those proceedings, paragraph 117. In the
second half of that paragraph, if we scroll down
slightly, you say:
"To attempt to locate all of the training materials,
Post Office would need to contact all trainers since
2000 to understand what materials were produced and
where they were kept."
That's a witness statement to the court verified by
a statement of truth. Do you want to revisit that part
of your witness statement in these proceedings which
said that the word "produced" is not a word that you
would use in that kind of a context?
I think my statement says I would not ordinarily use
this word. I clearly have used that word on occasion.
Do you, therefore, want to revisit whether that minute
reflects the advice that you gave to the first of those
meetings, that, if it's produced, it's available for
disclosure; if it's not, then technically it isn't?
I still believe that that minute is not a full and
49
wasn't a name you mentioned at the beginning. He was
a criminal lawyer at the Post Office --
Yes.
-- and you're now liaising with him:
"Please find attached a draft holding letter to go
to the [Criminal Cases Review Commission]. This letter
probably needs to go from Paula.
"This letter just holds the current position until
we have spoken to Brian Altman tomorrow."
Brian Altman, criminal counsel, so we're now
liaising with Post Office's criminal lawyer, and making
reference to criminal counsel who is going, please,
advising on the Cartwright King processes, et cetera.
Yes.
Could we, please, have a quick look at that letter.
It's POL00099346. So this wasn't just a holding letter
in the sense of "We'll get back to you". There is some
substance in the response. Could we scroll down,
please. This is 23 July, you're meeting Brian Altman
the next day and it's in reference to the Criminal Cases
Review Commission, who wrote to the Post Office -- we've
seen that letter:
"This letter briefly explains the background to the
matters raised in your letter and steps currently being
taken by [the Post Office]. I anticipate being able to
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accurate record of what was said in that meeting.
I think you only have to read the minute to realise it's
not a verbatim record.
Q. Is it still your position, therefore, that you didn't
advise caution in relation to the creation of minutes
because of their potential disclosure?
A. I did not advise Post Office against minuting those
meetings.
MRBLAKE: Thank you, sir. I think that's an appropriate
time for our first morning break.
SIR WYN WILLIAMS: All right. Yes. What time shall we
resume?
MR BLAKE: 11.05.
SIR WYN WILLIAMS: Yes, 11.05 itis.
MR BLAKE: Thank you.
(10.56 am)
(A short break)
(11.06 am)
MR BLAKE: Thank you, sir. Can we please move on to
WBON0000777. We're still in July 2013, 23 July. If we
scroll down to the bottom of that first page, you are,
by this stage, involved in corresponding with the
Criminal Cases Review Commission. You say:
"Susan, Jarnail ..."
So now Susan Crichton and now Jarnail Singh, that
50
provide you with a more detailed response by the end of
this week."
That's because you're going to have a discussion,
I think, with Brian Altman and, hopefully, send
a further letter; is that right?
A. That was the intention.
Q. Yes.
“At the centre of [the Post Office's] business is an
IT system known as Horizon. The system is used by over
11,000 subpostmasters ... As you will be aware, [the
Post Office] has commissioned an independent firm of
forensic accountants (called Second Sight) ... The aim
of this report is to highlight any issues in Horizon ...
"This month Second Sight released an Interim Report
highlighting a number of issues that required further
investigation but also reached the interim conclusion
that there were no systemic problems with Horizon.
"The data stored on Horizon is sometimes used by
[the Post Office] in the prosecution of criminal
offences ... Historically [the Post Office] was
a division of the Royal Mail Group, however Post Office
was separated out ... on 1 April 2012 and each became
separate and unrelated organisations. Prior to
separation it was [Royal Mail Group] who conducted the
prosecution of criminal offences committed by
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subpostmasters and/or their clerks, however
post-separation [the Post Office] assumed the role of
prosecutor.
"We are now looking at Second Sight's findings in
detail and are also investigating whether those findings
have an impact on any historic or ongoing prosecutions.
I hope to be able to send you a more comprehensive
response on these matters by the end of this week.”
That letter ultimately went out.
Sir, I'm not going to take the witness to that
letter but, for your record, it is POLO0116112. There
is then a further letter that is sent, again for your
record POL00297998.
So I'm going to add to my list of things that
happened in the summer of 2013 that, by that stage, you
were also liaising with the CCRC on Post Office's
behalf.
A. I wouldn't accept that characterisation of it. We
drafted this one -- or I drafted this one letter, which
I think is a holding letter, sets out some very basic
background information. Other than that, we were
bringing in Brian Altman to advise on the CCRC approach.
Q. Okay, so let's change "liaising" to corresponding with
the CCRC. You were corresponding or were drafting
correspondence to the CCRC?
53
SIR WYN WILLIAMS: Who actually instructed Mr Altman; was it
the Post Office Legal team directly or was it Bond
Dickinson, or was it somebody else?
A. It was Bond Dickinson.
SIR WYN WILLIAMS: Right. Fine, thanks.
MR BLAKE: In fact if we turn to WBON0000393, at the bottom
of the page we see Mr Altman, on 2 August, so shortly
thereafter, sending Gavin Matthews, who was your
supervising partner, and Simon Richardson, who I think
ultimately became the Chair of Womble Bond Dickinson; is
that correct?
A. Correct.
Q. So two partners at Bond Dickinson, Mr Altman is sending
them his observations on the terms of reference and
interim review of Cartwright King's current processes.
So, very clearly, it was his view that they were the
instructing solicitors. In fact, he doesn't even copy
in the Post Office to that correspondence.
A. Bond Dickinson was Brian's instructing solicitors.
Q. Yes. If we scroll up, we can see Simon Richardson
sending that to you as well. He said, "You ought to
have this too", if you scroll up to the top, please.
Can we now, please, turn to POL00021981 and those
were the observations that were sent to you from
Mr Altman.
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I accept that I drafted this one letter.
That is correspondence, isn't it?
Yes.
Yes. Okay, and you were also, by that stage, liaising
with criminal counsel to take matters forward?
We were acting as a conduit, so that Post Office could
get advice from criminal counsel.
You were meeting with Brian Altman, discussing matters
relating to the Criminal Cases Review Commission with
Brian Altman; weren't you?
If we're talking July and August, I'm not sure if I ever
actually met Brian in that period.
Okay, let's turn back to that email, the covering email,
WBON0000777. It's the bottom email, you say:
"Please find draft holding letter ...
"This ... just holds the current position until we
have spoken to Brian Altman tomorrow."
The suggestion being that there was going to be
a meeting with Brian Altman the next day.
There was. I just can't recall whether I attended it or
not.
Okay. So July 2013, corresponding with CCRC, and
coordinating with Brian Altman KC?
I would say that we were acting as a conduit for Brian's
advice.
54
If we scroll over the page, the Inquiry has been
through this but I will just highlight a few matters
that are raised in those observations. Thank you. He
sets out there that he understand the terms of reference
are as follows. The first:
"To prepare by 5 August an interim review of
Cartwright King's current process ...
"(2) To review, and advise [the Post Office] in
writing on [a number of matters].”
The first is:
"Its strategy and process for reviewing past and
current criminal prosecutions in light of Second Sight's
Interim Report and/or the role of Gareth Jenkins and his
impact on any possible appeals;
p) Its response to the [Criminal Cases Review
Commission]."
So that is the further letter, further to your
holding letter:
"c) The identification of any flaws in the process
of, or from the evidence arising from, the review of
a statistically significant number of past prosecutions
in which Horizon has been an issue in the proceedings."
Then we have a third there:
"To review, and, if appropriate, to recommend
changes to, the existing investigations and conduct of
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future prosecutions by [the Post Office], including, if
appropriate, the investigative/prosecutorial role being
undertaken by another authority ..."
If we scroll down and over to page 3, please, we can
see there is a footnote at the bottom of page 3 and he
says as follows, footnote 4:
“It is for [the Post Office] and those instructing
me to determine whether or not it is only the efficacy
(ie effectiveness) of past prosecutions etc that I am
being asked to consider with the Board, or in fact the
potential safety of past convictions following [the Post
Office] prosecutions (ie whether, in my judgment, the
Court of Appeal is likely to 'think that the conviction
is unsafe’: section 2 of the Criminal Appeal Act). This
is an important distinction. If it is the latter then
the appropriate term is ‘safety of past convictions’.
I note in this regard of paragraph 24 of Simon Clarke's
Ishaq case review’, et cetera.
I don't need to read any more of that. But he says
there:
“It is for the Post Office and those instructing me
to determine.”
So it seems as though Bond Dickinson weren't just
providing a conduit but it was certainly Brian Altman's
understanding that Bond Dickinson at least had some
57
observations.
"Simon's and my view is that he shouldn't report on
the safety of past convictions for two reasons:
"[1] this is likely to involve a more significant
analysis of lots of cases, thereby delaying his report.
"[2] and potentially blurs the boundary between
[Brian Altman] and [Cartwright King's] respective roles.
"The terms of reference need to be finalised in time
for Brian's return from holiday."
It looks, from that email, that your supervising
partner was more than just a conduit for Brian Altman's
instructions; he was, in fact, advising on the scope of
Brian Altman's investigations, wasn't he?
It appears to a very limited extent there, yes, but
I would note that Susan Crichton would have been well
aware that Gavin and Simon were not criminal lawyers.
Technically correct but they were involved in the
instruction, and directing the instruction and
formulating the instruction of a criminal barrister?
They were -- as I say, at this time, I was working on
a different workstream. So I don't have full visibility
as to how they went about it but I accept that my firm
were the ones that instructed Brian, but my
recollection, it's distant and dim now, is that the
scope of the work was largely led by Brian, as
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input on the scope of that instruction. Would you
accept that?
At this time, I was primarily focused on dealing with
the response to Second Sight. This work was being
conducted by Gavin Matthews and Simon Richardson, so
I find it difficult to comment on exactly what the role
was. My understanding was that we were a conduit for
his advice.
Well, looking at this, does it seem as though, does it
appear to you, that, in fact, it was more than just
a conduit?
It appears from those words that that's what Brian
understood.
Could we please turn to POL00021980. An email from
Gavin Matthews, so your colleague is here advising on
the terms of reference:
"Dear All
"Please find attached two separate terms of
reference for Brian Altman QC as amended in response to
his observations document which I also attach for ease
of reference.
"Please note that [the Post Office] needs to decide
on the issue of whether he is to be asked to report to
the Board on the efficacy or safety of past
prosecutions ~- see footnote 4 on page 3 of Brian's
58
instructed by Post Office.
A barrister is instructed to carry out work. Here we
have a firm to solicitors who are instructing him,
advising on whether a criminal KC/QC looks into the
safety of convictions. That's what's happening here,
isn't it? A fair reading of this email: the instructing
firm is advising on whether a criminal silk is looking
into the safety of convictions or not?
I accept that that email expresses a view on that
question.
Is it that difficult to accept what I'm saying in that
respect?
I think the context is really important, that we were
instructing Brian largely because it made it
administratively more easy for Post Office, and I don't
think Post Office were expecting Gavin, Simon or I to
give them any advice on criminal law, because they knew
we weren't criminal lawyers. And I think that context
is really important. I think Susan would that have
had -- probably Susan, in the context here -- would have
read that as a practical view but I don't think she
would have been led by the advice she was getting from
WBD on criminal matters.
They're the instructing firm and they are there, very
senior partners -- so Gavin Matthews and you have Simon
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there, who, as we know, went on to become the Chair --
by that stage, 2013, was he a particularly senior
partner within the firm --
I think he was the client relationship partner for Post
Office.
- giving a view as to whether Mr Altman should be
reporting on the safety of past convictions?
I accept they were giving a view but I think the context
of what we were doing is very important.
Can we please turn to POL00298417. You're copied into
this email that we've just been looking at and, now, if
we scroll down, we're at 20 August 2013 and Rodric
Williams is, in fact, now corresponding with Susan
Crichton and you. So Gavin Matthews is not a recipient
of this email. Rodric Williams says as follows:
"All,
“I would like the [terms of reference] to include
that [Brian Altman QC] consider and advise on how we
satisfy the prosecutor's continuing duty of disclosure
when ‘issues’ with Horizon will continually be it
raised."
So he asks a series of questions that he would like
Brian Altman to be looking into. By way of example, we
can look at the third bullet point:
“Is there anything we can do to limit the need to
61
an opportunity to go back and check the position.
It wasn't so long ago. Are you able to recall, the
summer of 2013, receiving an email relating to the terms
of reference for Brian Altman? Is that likely something
that you would have been receiving and something that
you likely would have given an answer to?
I would have been copied in on various emails but, at
this time, the work around Brian's terms of reference
was being led by Gavin and Simon and not me.
Would you have read this email?
Yes, I suspect I would have read it.
Would you have been aware that the Post Office wanted to
change the terms of reference to look at the
prosecutor's continuing duty of disclosure?
I wasn't that close to the issues to have identified
those points.
Do you think that your firm were competent enough to be
dealing with issues relating to the prosecutor's duty of
disclosure?
As I said, we were acting as a conduit. So I would have
expected these types of issues to have been passed back
to Brian for him to consider.
What does a conduit involve, though? I mean, is it
simply a post box; is it something more than that?
Largely, we were acting as a way of getting instructions
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review all past prosecutions each time a disclosable
issues arises?"
Certainly, Rodric Williams, by 20 August, seemed to
think that you were a contact point for advising on the
terms of reference or assisting with the amending the
terms of reference.
I -- my distant memory is Gavin might have been on leave
for a few days.
So while your supervising partner was away, while you
were working on issues relating to Second Sight, having
been copied in to previous correspondence about Brian
Altman's terms of reference, you are now a sole point of
contact relating to those terms of reference?
Simon Richardson is also copied on this email.
Yes. But you are in the "To" column?
!am. Rodric would have known me more than he knew
Simon, which would have explained why he addressed it to
me and only copied Simon.
So can I add to my list of the summer of 2013 that, by
August 2013, you were involved with Brian Altman QC's
terms of reference?
I think that overstates the position. My recollection
is that I had very little involvement in the terms of
reference but I note that these documents were only sent
to me a couple of days ago and I've not had
62
up to Brian and answers back down again. On occasion,
I can see that views will have been expressed on points
but I think, again, the context is really important.
Post Office were fully aware that Simon, Gavin and I
were not criminal lawyers.
Do you think it is right for your firm to be assisting
in something that is outside of their competence?
It is outside of our core competence but instructing
counsel is something we understand and, of course, we
have the context of the whole situation, being involved
on the civil side.
So if your firm were involved in advising on whether
Brian Altman's terms of reference should include the
prosecutor's continuing duty of disclosure, do you think
that's something they could have advised on?
I don't -- personally -- I can't speak for Simon and
Gavin but I wouldn't fee! comfortable advising on that.
I can see a view may have been offered but, ultimately,
I think all questions were deferred to Brian to
consider.
What's the difference between a view of a lawyer and
advice from a lawyer?
I think one of them is offering perhaps some pragmatic
thoughts, as opposed to definitive advice on the
position.
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How would a client distinguish between pragmatic
thoughts and actual legal advice?
By the nature of the way it's given.
What do you mean by that?
If we go back to the last email, what you've got is
an email that something that says something to the
effect -- I haven't got it in front of me now -- that
says these are Simon's and Gavin's views and couple of
bullet points.
Do you think that nuance is understood by clients?
I think it would have been understood by Post Office,
yes.
I said I'd come back to the insurance notification issue
and I'm going to turn to that now but it's POL00021991.
Now, it's that bottom email that I'd like you to
look at but you can ignore the date there, because we're
still, actually, in the summer of 2013, is the document
that I want to take you to. You're forwarding this
particular document to David Oliver and Chris Aujard on
12 March 2014.
We can see there you're attaching a number of
different documents. One is a settlement presentation,
and we'll come to that settlement presentation, and you
say:
"This presentation is for a talk I gave to what was
65
insurers of those issues that are set out in this note.
I don't think it actually gives advice, say, on the
merits of the position or what needs to happen next, or
things like that, which you would traditionally expect
to see in a piece of legal advice.
If you were the insurer and you saw “Bond Dickinson" on
the top right-hand comer, you saw "Confidential &
Legally Privileged, Common Interest Privilege,
Litigation Privilege", was it not designed to look like
legal advice?
I don't believe it was designed to look like legal
advice.
What do you mean by common interest privilege there?
In the sense that, if there was a claim against Post
Office, which was an insured claim, then there may be
a common interest between Post Office and its insurers.
So the common interest there is between the Post Office
and the insurer?
That's what that reference was, from memory.
And was that designed to ensure that this document was
not disclosable because it was covered by common
interest privilege between Post Office and its insurer?
We considered that question and, on balance, I think we
thought it probably was privileged communication in its
nature to the insurers, but it could be challenged.
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at the time the Sparrow steering group.”
But it's the third one that I want to take you to
now “Insurances risks note":
"This note had the dual purpose of advising the
board (its contents were later reflected in a Board
paper) and acting as notification to [the Post Office's]
insurers -- hence why this doesn't look like
a traditional piece of legal advice."
You refer there to the contents being reflected in
the Board paper. Did you see the Board paper?
I have looked at that sentence again and I think that
sentence is wrong because I can't find any record of
that paper going to the Board.
Thank you. It doesn't look like a traditional piece of
legal advice. That's your words. Let's turn to it and
have a look at it. POL00021996.
So why do you say in that covering email that it
doesn't look like a piece of legal advice?
Just because of the way it was drafted. This note was
drafted to notify Post Office's insurers.
How would legal advice act as notification to
an insurer?
I don't think I'm suggesting that I -- that it was.
I -- what I'm trying to say here is this note was
drafted for the purpose of notifying Post Office
66
Was one of the reasons for adding "Common Interest
Privilege" at the top there to try and cover it in
a blanket of privilege?
It was to indicate that we thought there was -- common
interest privilege might apply to this document.
It doesn't say might be common interest privilege?
I think it's just a heading to a document. It's
designed to indicate to the reader that this document
could attract common interest privilege.
Or “is considered to attract common interest"?
No --
You wouldn't add it if you'd didn't think there was
a reasonable argument --
That's fair. At this point, my view is I thought this
document would attract common interest privilege but we
also thought that could be challenged later.
Can we please scroll down this document. We saw earlier
that email about concerns you had about notifying the
insurer in writing that it could become disclosable. So
the reason behind this being in the form that it is is
that that was an attempt to cloak it in privilege,
thereby not disclosing it?
The -- whether or not of the document is privileged
turns on its nature and the purpose for which it was
sent. I think lawyers, where they think a document is
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privileged, will often mark them as privileged but
marking a document as privileged doesn't make it
privileged.
But you intended to be covered by privilege. As in,
this letter, if it's not advice, if it's not legal
advice, it could have been written by the Post Office
and sent to the insurer?
It could have been written by the Post Office, yes.
It has been disguised here as Bond Dickinson advice,
covered by legal privilege, with the intention that,
should somebody ask the insurer for a copy or should the
Post Office be asked for a copy, they could say it was
legally privileged?
Would you mind scrolling back up to the top of the
document, please? So the top of this document refers to
common interest privilege and litigation privilege. It
doesn't refer to legal advice privilege.
Yes. Common interest privilege.
Mm.
What's the point you're making: that because it doesn't
say, “Legal advice privilege" that means that it's not
legal advice?
So I think your suggestion was that we were dressing it
up as legal advice to try to get it under the banner of
privilege. That wasn't what we were doing. This was
69
(even retrospectively) this previously undisclosed
information to subpostmasters' defence counsel. Post
Office is required to make these retrospective
disclosures where the additional information
(ie Dr Jenkins’ knowledge of historic, but now resolved,
problems with Horizon) may have undermined a prosecution
case or assisted with [the] accused's defence."
Reference there to prosecutions and convictions in
cases relating to Gareth Jenkins or where Gareth Jenkins
has provided evidence.
Could we please turn to POL00040025. So that's the
version that you sent colleagues or Chris Aujard and --
who was David Oliver?
He was part of the Mediation Scheme team at Post Office.
So you sent that in March 2014, as the notification.
But I want to look back now at the drafting process for
that document. We have here an email from Rodric
Williams to you and he says:
"Andy,
"Please find attached the ‘Horizon Risks' document,
which I have amended following input from Cartwright
King on the criminal law risks. Can you please check
that it will still serve the purpose of notifying
insurers of the grounds for potential claims?
"Once you are happy it does, I intend sending it to
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drafted as a notification to the insurer, my
understanding is, when you notify insurers, and I got it
this understanding from one of the insurance partners,
is that the forms of privilege that might apply are
litigation privilege and common interest privilege.
It says at the top of "Confidential & Legally
Privileged", doesn't that cover all forms of legal
privilege?
I think you're reading too much into those words.
Let's have a look at what it says, if we scroll down,
"Risks to Post Office", page 2, please, "Prosecutions &
Convictions":
"As noted above, where circumstances warrant, Post
Office prosecutes subpostmasters who have acted
criminally. The basis of these prosecutions is often
found in the transaction records recorded in Horizon.
As a result of Second Sight's investigation/Interim
Report, Post Office is reviewing all its criminal
prosecutions over the last three years to identify any
cases where a conviction may be unsafe.
“In particular, the expert evidence of one of Post
Office witnesses, Dr Gareth Jenkins of Fujitsu, may have
failed to disclose certain historic problems in the
Horizon system. Under the criminal prosecution
guidelines Post Office has an obligation to disclose,
70
our broker, under cover of the following email.
"Mark, Richard,
Please find attached a note from our solicitors
outlining the risks presented by the recent
investigation into "Horizon" IT system used in Post
Office branches."
So the proposed notification to the insurers is that
it's a note from our solicitors outlining risks.
I mean, that sounds quite a bit like legal advice,
doesn't it?
I think it -- I don't believe we considered it advice.
I drafted it simply to set out the facts and backgrounds
for the insurers.
Why couldn't you have drafted it on a piece of paper to
be sent by the Post Office on their own headed paper?
We could have done.
Again, I'll go back to it. Surely the purpose was to
add that level of privilege over it, wasn't it?
I'm not sure I gave it that level of thought as to
whether it would come from Post Office or from Womble
Bond Dickinson.
We saw that you gave it quite a lot of early thought
about problems that it would cause if it were disclosed.
Yes.
So surely you thought about who should be sending it and
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why?
A. Not in terms of who -- I don't believe I did, in terms
of who would write the note. I think it was just that
we were in the position to write it. We wrote the note
and, as it marked at the top, we considered it could be
subject to common interest privilege and litigation
privilege.
Q. "Can you please share this with our insurers so they
are aware of the circumstances which could potentially
give rise to claims against the policies we have with
them, preserving so far as possible, the legal privilege
attaching to the note’."
Doesn't the fact that it came from you strengthen
the claim for legal privilege and wasn't it intended to
do so?
A. On the first of your points, I guess there is something
in the fact that lawyers are considering legal risks
that makes it more likely that litigation is in
contemplation, which is one of the grounds you need to
claim litigation privilege. I don't recall any
discussion around whether the note should come directly
from Post Office or from my firm in the context of
making it more or less privileged.
Q. I mean, isn't really what's going on here that the
Notification to the insurers is being covered in LPP in
73
I don't -- and I accept that "Please find attached
a note from our solicitors", I think that probably
fairly describes what that document was.
Q. Okay. POLO00 --
SIR WYN WILLIAMS: Sorry, Mr Blake. Before we go any
further it may be that I'm being a bit slow but I just
want to understand the drafting process. The document
which was -- well, let me just ask the direct question:
who, so far as you are aware, Mr Parsons, produced the
very first draft of that document?
A. I created the first draft.
SIR WYN WILLIAMS: You did?
A. Yes.
SIR WYN WILLIAMS: Right. So then the sequence was that you
sent it to Mr Rodric Williams, who amended it, as I've
understood what's being said here, with the help of
Cartwright King in particular, so far as it related to
the criminal law risks? Yeah?
A. That's my best recollection, yes.
SIR WYN WILLIAMS: Well, that's what this appears to say,
this email.
A. Yes.
‘SIR WYN WILLIAMS: Which is what I was checking.
So the part of the document which deals with Gareth
Jenkins, this is what I was coming to, was that.
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order to prevent it from being disclosed?
A. I accept that we were asserting legal privilege over
this document, yes.
For that purpose?
Yes.
So that it wouldn't be disclosed?
Correct.
propre
In fact, although the draft email suggests that it's
a note from our solicitors, we can see there that itis
not only Bond Dickinson who are inputting but Cartwright
King and also Post Office themselves.
A. Correct.
Q. So to suggest that it was simply a note from the
solicitors, that wouldn't be right, would it? I mean,
the impression given in that draft covering email is
that "This is something we've received from Bond
Dickinson, here you go, here's a piece of legal advice
we've received". But, in truth, it was a document in
which a number of different people had input into, which
was put on your headed paper, in order to cloak it with
legal privilege.
A. We -- as I say, it was draft as a notification to the
insurers to give them the factual information to assess
whether there was insurance cover. I accept that we
considered that communication to be privileged. But
74
something which was in your original draft or was that
something which was added by Cartwright King/Mr Rodric
Williams?
MR BLAKE: Sir, before Mr Parsons answers that, could I take
you to the attachment to this email, because that
actually does address this issue or it may assist --
‘SIR WYN WILLIAMS: Sorry, Mr Blake.
MR BLAKE: Not at all.
‘SIR WYN WILLIAMS: I appreciate I was butting in but I just
wanted to get this sequence right in my mind.
MR BLAKE: Could we please look at the attachment, it's
POL00040026 and perhaps when this comes up, could we
also have it side by side with the version you sent
around in 2014, that's POL00021996. I can make very
clear, the version you sent around in 2014, in fact, was
not the version that was sent to the insurers --
A. Mm-hm.
Q. -- and we're going to see the difference between them.
So if we could turn to the second page of both of them
to the section on "Risks to Post Office", please. Thank
you. So they're very similar on the first paragraph,
although there's -- the difference is that there's now
reference -- or sorry, in the Cartwright King version
that was sent to you, it refers to 1 January 2010,
rather than over the last three years. So that's
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a change. The more significant change is in that second
paragraph. The version on the right-hand side says:
"Post Office has an obligation to consider whether
further disclosure should be made to defendants. It is
of concern to Post Office that the expert evidence of
‘one prosecution witness, Dr Gareth Jenkins, of Fujitsu,
may have to failed to disclose certain problems in the
Horizon system potentially relevant to a case.”
Acase.
The left-hand version says quite a lot more about
Gareth Jenkins and is perhaps more accurate. It says:
"In particular, the expert evidence of one
[prosecution] witness, Dr Gareth Jenkins of Fujitsu, may
have failed disclose certain historic problems in the
Horizon system."
Italso says:
"Post Office is required to make these retrospective
disclosures where additional information ... may have
undermined a prosecution case or assisted with
an accused's defence."
It doesn't refer there to a single case. The one on
the right-hand side very clearly gives the impression
that it's only one case that is affected. Do you recall
that insertion?
Just to check, my version is the one on the left?
77
POL00112856. So this is the notification from somebody
called Stuart Corney who was partner, Claims, Financial
Risks Division:
"Dear Sir/Madam,
"Please find attached details received of a new D&O
matter for your consideration. The notice concerns
challenges which have been made to the accounting system
used in the Post Office Network to monitor sub post
offices for any improper behaviour."
You'll see halfway down that paragraph, it says:
"A review of the Horizon system was undertaken and
whilst recommendations were made for improvements no
systemic problems were revealed which would call into
question the changes previously made against
subpostmasters. It is of concern to Post Office that
the expert evidence of one prosecution witness,
Dr Gareth Jenkins of Fujitsu, may have failed to
disclose certain problems in the Horizon system
potentially relevant to a case."
If we scroll over the page, we can see the Bond
Dickinson note, "Horizon Risks", that was sent -- if we
scroll down, scroll down, if we scroll over the page, we
can see, under “Prosecutions & Convictions" the version
is the version that only relates to Gareth Jenkins may
have failed to disclose certain problems relevant to
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Q. Well, the 2014 version that you circulated is the one on
the left.
Okay.
The one on the right-hand side is the one that was
circulated by Rodric Williams with a covering email that
said, "Please find attached the Horizon Risks document
oP
which I have amended following input from Cartwright
King", et cetera. It's not at all clear whether the one
‘on the left was the original version or some other
version but it certainly wasn't the version that went to
the insurers.
Do you recall there the -- in any way, reference to
Gareth Jenkins being amended?
A. I don't recall that change.
Q. Do you recall that the ultimate -- the final -- version
that was agreed was a version that only said that Gareth
Jenkins may have failed to disclose certain problems in
the Horizon system potentially relevant to a case?
A. I don't recall that change.
Q. Do you recall in broad terms discussing the changes, for
example, in response to Rodric Williams’ email,
discussing with Rodric Williams the various changes that
were being made to that document that had your header?
A. I don't recall discussing those changes with Rodric.
Q. Let's look at the final notification, that's
78
acase.
So it certainly suggests that the version that was
sent around to the insurers was not that version that
you sent around in 2014 and would you accept that that
version is highly misleading?
A. Yes, it appears that way, though I'm not sure I was
cognisant that that change had been made at that time.
SIR WYN WILLIAMS: Well, hang on a minute. This version,
the one that, on the face of it, looks as if it was sent
to the insurer, in respect of the heading "Prosecutions
& Convictions", is identical, is it not, to the one
which was sent to you by Mr Rodric Williams, under cover
of an email which drew your attention to the fact that
there'd been an amendment in relation to Gareth Jenkins?
A. laccept that a copy of it was sent to me. I don't now
recall being cognisant of that change or its importance.
‘SIR WYN WILLIAMS: All right. That's your answer to that.
Just to clear up where I started, the version that you
sent around in March 2014, which wasn't the version sent
to the insurer, was it the version, so far as you can
remember, which you had originally drafted?
A. I believe so.
‘SIR WYN WILLIAMS: Right.
A. I believe so but it did go through a few iterations.
SIR WYN WILLIAMS: That's your answer: you believe that your
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original draft contained the details, which we see in
what I'll call the 2014 document but, in fact, it was
amended in 2013 and something different, namely what's
‘on the screen, was sent to the insurers. Have I got
that straight now?
A. That appears to be the case.
SIR WYN WILLIAMS: Fine. Thank you.
MR BLAKE: Can we go back to the email from Rodric Williams.
It's POLO00040025. So this is the email that he sent you
with the version -- as the Chair has highlighted, is the
version that was ultimately sent to the insurers. If we
scroll down, he has sent it to you and he says:
"Please let me know if you have any comments on the
proposed email or approach generally."
Presumably you did correspond with him on this?
A. My distant memory is I think I responded briefly saying
the cover note looks okay, or something to that effect.
Q. Presumably, you would that have opened the attachment
and read it?
A. I presume so but I can't recall.
Q. Looking at it now, is that paragraph not crying out for
further detail?
A. It strikes me that now but I don't remember considering
that at the time.
Q. Given the significance of the advice on Gareth Jenkins
81
eventually reaches you but it's an email from Andy Holt
to Martin Edwards and the subject is "Information for
Paula's [one-to-one] with Chairman". So it seems as
though they are gathering information for a conversation
between Paula Vennells and the Chair.
If we scroll down, there is a section called
"Project Sparrow Update", so this looks like the
original draft that was proposed for that one-to-one and
it sets out an update on Project Sparrow:
"The improvement workstream has completed the 'as
is' experience for subpostmasters. The team are now
progressing with the ‘to be’ picture and identifying the
gaps and issues as well as the activities that will need
to get us to our future model.”
There's a reference to the Mediation Scheme, now
received 46 applications, final stages of appointing
Sir Anthony Hooper:
"The criminal case reviews continue with our
external firm of solicitors. They have completed
several sifts of past cases and have recommended
disclosure on 11. Brian Altman QC's review is also
progressing well and is expected to complete as planned
by the end of October.”
If we scroll up, please, we can see on page 4
a response from Mr Edwards to Mr Holt. He says as
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and the implications for criminal prosecutions, wasn't
it important to get that absolutely right, that section?
This is a notification to the insurers and so, yes, it's
important that it's accurate but it's also at a high
level of detail. So the insurers are aware of the
general issues that are in play.
Were you concerned when drafting this about the
potential disclosability of the information that's
provided and, therefore, seeking to minimise those
problems?
I was concerned about the disclosability of the
document, which is why we considered it to be
a privileged document. In terms of its content, though,
the version I produced was candid about the issues,
I felt.
Why in that earlier 2014 email did you say that it had
been summarised for the Board? Where did you get that
idea from?
So this insurance note was to the D&O insurers, the
Directors’ and Officers’ insurers, and I think in the
week or two before that I had provided Post Office with
an email of advice on directors’ duties and, looking
back now, I wonder if I got those two points confused.
Can we please turn to POL00123004. Can we start on the
bottom of page 4, please. We'll see that this
82
follows:
"Thanks very much for this. A few questions/
requests for further information ...
“Would be good to include a line on the review of
prosecutions policy -- ie just updating the Board that
work ... is progressing and they will see a paper at the
next ARC or Board. Following yesterday's discussion,
please can we confirm the arrangements?”
"2. I think we should have a few lines on
compensation policy.
"3. I think the criminal cases review process needs
more explanation. In particular, an explanation of the
implications of the 11 cases where disclosure has been
recommended (even if we don't want to include too much
on this in the text himself, useful for Paula to have in
her background notes). Can we also have an explanation
of the high level conclusions of the Brian Altman review
along the lines outlined by Rodric yesterday?"
If we scroll up we can see that Rodric responds
saying:
"Andy -- I've asked Andy P to ... respond to
Martin's points."
Then if we turn to the bottom of page 1, we can see
that you have responded substantively to those points
that have been made. So the bottom of page 1, please.
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We can see the questions there are slightly less bold
than the answers. I think in the original they would
have been in a different colour, perhaps:
"Draft answers to Martin's questions below -- too
much detail or not enough?"
So you are drafting for Andy Holt proposed answers
to those questions. The first one:
"Would be good to include a line on the prosecutions
policy ..."
You've drafted as follows:
"Brian Altman QC's review of the prosecution policy
is being finalised. The report was originally due on
31 October but should now be ready by 25 October. The
review will address the question of how [Post Office]
may wish to approach prosecutions in the future."
You say:
“ANDY -- I'm not sure what the Board process is for
the report. Hugh mentioned there might be
an extraordinary ExCo to review the report before it
goes to the [Audit and Risk Committee] or the Board.”
More answers, if we look at 3, where the request
was:
"I think the criminal cases review process needs
more explanation
You've put in there:
85
for the CEO that related to that underlying work?
I think this is just a factual summary of the status of
Brian's report and reflects what I understood his advice
to be.
Next question:
"Further to yesterday's discussion, please could we
also have some lines for background speaking notes on
the process", et cetera.
Then you say:
"ANDY/BELINDA -- thoughts on the below?
"Work is continuing on managing [Second Sight] out
of the scheme. In general, [Second Sight's] role is
gradually being reduced until they can be removed
entirely.”
You were involved at that stage by dealing with
Second Sight. Was that the main part of your work,
then?
Correct.
You have, in this email, answered a request in relation
to a briefing for the CEO, covering matters relating to
the criminal cases review process, for example. No
mention here of the Gareth Jenkins issue. Do you think
that that's something that might warrant inclusion in
an update to the CEO?
My understanding of this time is that everybody had been
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"Jarnail/[Cartwright King] to amend/complete."
But you have drafted a section on Brian Altman's
first review, which you say has now been received:
"This first review looked into [the Post Office's]
compliance with its prosecution duties in light of
Second Sight's findings -- in particular, it considered
[the Post Office's] legal duty to ensure that Second
Sight's findings were fully disclosed to any person who
is currently being or has previously been prosecuted by
[the Post Office]. Mr Altman concluded that [the Post
Office] is complying with its duties and that the
approach adopted by the prosecution team was
‘fundamentally sound’. This report gives [the Post
Office] good grounds to resist any formal external
review of his historic prosecutions (ie by the Criminal
Cases Review Commission)."
Now, earlier this morning you were very keen to
emphasise that you were effectively a conduit for Brian
Altman. Now, it certainly seems from this email that
you are, by this stage -- so October 2013 --
substantively involved in advice on a brief that would
go to the CEO of the Post Office.
This paragraph here is repeating the information I've
had from Brian.
Yes. Were you involved in advising or drafting advice
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briefed on the Gareth Jenkins issue.
Was it not so significant that it perhaps required quite
a significant update to the CEO?
Possibly, but that's also why the comment above says,
"This needs to be run past Jarnail and Cartwright King”.
In relation to the Criminal Cases Review Commission, did
you just see your job simply as repeating exactly what
Brian Altman told you?
Largely because I'm not a criminal lawyer, so I'm not in
a position, really, to amplify what he was saying.
Why instruct someone? Why be the instructing firm to
somebody if all you can do is parrot what they tell you
to the client?
So, again, the context here is that Post Office already
have retained criminal solicitors in Cartwright King.
The role of Brian Altman is to act as a second opinion
‘on Cartwright King's work. Post Office wanted that to
come from a QC, they weren't looking to instruct another
firm of solicitors to do it and so our role was to -- is
to facilitate them getting that advice.
Did you feel comfortable in answering these kinds of
questions from the Post Office?
In the sense that they were asking for a brief update of
what had happened, I felt able to provide that.
Could we please turn to POL00372551. This is the very
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same day as you're having this correspondence. If we
scroll down slightly, you can see an email from Paula
Vennells to Alice Perkins, so this is some form of
one-to-one:
"Hi Alice, don't worry about the lateness of this
note ..."
So that's actually very first thing on that day, its
12.47 am:
... lam clearing the [I think it must be
‘in-tray'] before signing out. I hope your weekend has.
been good despite the autumn rains.”
It says "A couple of updates", and then it updates
‘on Sir Anthony Hooper/Sparrow. Then it says as follows:
"My concern re Sparrow currently is our obligations
of disclosure re an unsafe witness (the representative
from Fujitsu made statements about no bugs, which later
could be seen to have been undermined by the [Second
Sight] Report). We do not think it is material but it
could be high profile. Martin E is briefed if you want
more detail. This is just in case."
So it seems as though her belief at that point was
that it was not material or not thought to be material.
If you could go back to the advice we looked at much
earlier today, please, and that's POL00145716. It's the
middle email. This is the advice that I took you to
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level?
Not as far as I was aware.
Could we please turn to POL00022002. This is the
presentation that you sent again in that 2014 email that
I referred to. It is dated 8 October 2013, so
approximate period to that Paula Vennells email to Alice
Perkins.
You've said in that earlier email that this was
a presentation that you gave to the Sparrow Committee;
is that right?
Yes.
If we turn over the page, please, your presentation says
as follows:
"Privilege -- a reminder
"Legal privilege = vital to success.
"Do not discuss any legal advice or anything to do
with [subpostmaster] settlements with:
“Anyone outside Post Office
"JFSA
"Second Sight
"Subpostmasters
"[The sponsoring department, the Department for
Business and Industrial Strategy/Members of Parliament]
"[Even] Your teams unless absolutely necessary."
Did you see legal advice covering things in
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much earlier today about notifying the insurer and you
said as follows:
"The risk of notification is that it would look bad
for [the Post Office] if it ever became public knowledge
that [the Post Office] had notified its insurer.
"To reduce this risk, it is recommended that rather
than sending a formal written notification, POL speaks
to ... and verbally notifies them so as not to leave
a paper trail."
We also saw the advice that is attributed to you in
that meeting, the first weekly Horizon meeting.
Could that approach that you took to not putting
things that are damaging in writing to weakening of the
Gareth Jenkins issue, as we saw in that final
notification, could that have been in some way
responsible for the CEO's lack of understanding of the
true gravity of the problem?
This is over a three-month period, where I'm not the one
advising Post Office on criminal law risks and I'm not
the one who is responsible for ensuring what information
goes to the CEO. As far as I was concerned, the CEO had
been briefed on these issues.
Could the obsession with covering things, blanketing
things, in legal professional privilege have been
responsible for that lack of understanding at Board
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privilege to be vital to the Post Office's success?
I think the -- in the context of this document, which is
discussing settlement criteria and what Post Office may
‘or may not be prepared to pay, keeping that type of
advice confidential is of paramount importance, and
I think that is the sort of advice that any lawyer would
give to a client in those circumstances.
Looking back at it now, do you think that that was in
some way responsible for a lack of information
transferring within the company?
No because this is talking about communications outside
of Post Office and then potentially down into teams.
I don't think anyone would have interpreted that as
somehow putting a block on information being passed up
to senior management.
It says, "Your teams unless absolutely necessary".
Yes.
"Don't discuss any legal advice", even with your own
team?
Yes, because --
Keep information clearly compartmentalised is what it's
advising, isn't it?
No, because this meeting of the steering group tended to
be more senior people and so the idea is that they will
have more junior staff underneath them, and there's a --
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that's not just advice that I'm providing, that is the
state of the law on legal advice privilege, which
provides that legal advice privilege doesn't extend to
the entire client organisation but only those groups
within the organisation who need to receive that advice.
Can we turn to page 14 of this document, please, still
with the presentation, "Settlement thresholds". You set
out here "Recommended threshold of proof", and "Risk:
"Where the nature of the complaint is that Horizon
inaccurately records data/transactions ...
"Risks
"Post Office should be slow to concede that Horizon
has any technical faults. To do so could open the
floodgates to a large number of claims. It will be
almost impossible to reverse this position if conceded."
Now, all those things that we've been going over
today, all those various bugs in the summer of 2013, the
suspense account bug, Castleton, Misra, all of those
issues that we've been discussing, how, by that stage,
could you still hold that position, could that still
fairly be the Post Office's approach?
So those three bugs that you just mentioned had all been
publicly disclosed, so they were out there. So this is
talking about us coming across any new defects in
Horizon during the course of the scheme. Reflecting on
93
When combined with the Andy Winn/Alan Lusher email in
the case of Ward which explicitly states that Fujitsu
can remotely change the figures in the branches without
the [subpostmasters'] knowledge or authority, the case
for a general stay is overwhelming.
"We ask that the Working Party considers this
request as a matter of urgency in order that we do not
prejudice our clients’ cases by omitting information
which is clearly of the utmost general significance.”
If we scroll to the first page, please, you provide
your view on this email. You say as follows:
"Belinda
“I have spoken to both Rodric and Simon Clarke at
[Cartwright King] about the email from Priti Singh at
Howe ...”
So Priti Singh is a lawyer at Howe who has made this
complaint:
"... and all three of us have similar thoughts on
the way to proceed.
"The only redactions made to the copies of the
reports sent to [subpostmasters] was to remove:
"1, The personal information of some of the
individuals named in the report ...
"2. Aheader in the document that said the document
was subject to legal privilege when it clearly was not
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this now, I think that sets the bar too high.
MR BLAKE: I'm going to address one more issue, sir, before
we take our second morning break. I appreciate time is
marching on --
SIR WYN WILLIAMS: That's fine.
MR BLAKE: -- but perhaps we can take a slightly later
lunch.
Can we please turn to POL00029707, page 3, please.
In the middle of page 3, we have an email from Steve
Darlington to Rob Wilson and Post Office Group and he
says as follows:
“As Priti has stated in her last sentence, we are
seeking a stay on the time limits on all cases under
review due to the implications of [the Post Office's]
non-disclosure of system-generation transactions and
Horizon integrity issues."
Do you remember who Steve Darlington was?
I think he was a lawyer acting for some of the
applicants in the scheme.
Yes, so it's a complaint from Howe+Co, following
disclosure of, amongst other things, the Helen Rose
Report. He says:
"The ‘Helen Rose Report is of critical significance
to all cases. The information contained within itis
a compelling case for such a stay in its own right.
94
"In light of this, I don't understand Howe+Co's
complaint that there is substantial missing material.
It is not suggested that [the Post Office] provides
an unredacted version of the report as (i) this is not
necessary and (ii) we do owe some duty of privacy to the
individuals involved. Instead, it is recommended that
[the Post Office] maintains its current position and
simply explains the redactions to the report."
So this is the Helen Rose Report that has been
redacted. You are here explaining why there have been
redactions that have been made to that report; is that
correct?
Yes, the redactions were made by Cartwright King,
though, not me.
Yes, and you are explaining why they have been made?
I'm explaining why -- Cartwright King's reasons for why
they were made.
You are suggesting an approach that the Post Office
should take in response to Howe+Co's complaint about the
redactions?
Yes.
That document had been disclosed to the individual in
the criminal context, it had been part of that criminal
disclosure arising from Cartwright King's review?
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I believe that's the case.
Yes. You say:
“In this vein, I have set out below a possible
response to [Howe+Co] to go from Chris. This response
is purposefully short in order to avoid any dialogue
with Howe on this matter. I do not believe this matter
needs to go through the [Working Group] because this is
about [the Post Office's] prosecution duties and not
scheme business. The response could, and in my view
should, be sent regardless of Steve Darlington's email
below as it is important that [the Post Office's]
position is clearly stated before Ron begins to escalate
Steve's views to the Working Group.”
Now, "I do not believe this matter needs to go
through the [Working Group] as this is about POL's
prosecution duties and not scheme business"; you've been
very clear throughout this morning to distinguish
between your involvement in civil and criminal matters.
Itis clear here that you are getting involved in
correspondence that relates to the Post Office's
prosecution duties.
So this is where we end up with the overlap between the
scheme and the fact that, within the scheme, there were
some subpostmasters who were convicted. My lookout from
here is to determine whether this is a matter for the
97
but in a different report. The concern was not with the
data's accuracy but that the presentation of the data
could be misleading if its limitation was not fully
understood. Putting this issue aside [and this is the
important part] the real (and confidential) reason that
the report was disclosed was because Helen's comment at
the bottom of page 3 suggests it was widely known that
there were problems with Horizon. This statement
(regardless of whether it is correct) could have been
used to attack Gareth Jenkins’ credibility as [the Post
Office's] Horizon expert as he had previously stated
that there were no problems with Horizon."
Then you go on to draft the response. If we scroll
down, please, your draft response says as follows:
"The version of the report sent to Ms Robinson was
redacted to protect the privacy and personal information
of the individuals named in the report. This was done
to ensure compliance with the Data Protection Act. All
material information in the report has been provided to
your client in full compliance with the Post Office's
legal duties."
Now, where you say “legal duties", do you mean in
relation to the prosecutor's duty of disclosure?
Yes.
So you are, in this draft email, proposing
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scheme to consider or not, and the scheme was not
considering Post Office's prosecution duties or
reconsidering the conduct of prosecutions. So
I think -- I don't accept that is me advising on
prosecution matters. I think that is me advising from
the perspective of the scheme.
You're advising on something that touches on the
prosecution's duty of disclosure aren't you?
I accept that but also, if you scroll up to the top of
this note, it says "I've spoken to both Rodric and Simon
Clarke at Cartwright King" so the criminal law input
would have come from Simon Clarke at Cartwright King.
But he's not sending any separate draft response. This
draft is coming from you, having taken others’ views?
Having taken Simon Clarke's views on the appropriate
approach on the criminal side.
You say:
"Just for background information, the material part
of the Helen Rose Report has nothing to do with her
comments about reversal data. [Second Sight] and Howe
are taking this point as evidence of a problem with the
integrity of Horizon. In fact, Helen's issue was that
the Credence data, although accurate, did not on its
face clearly distinguish between automated reversals and
user generated reversals. This information is available
98
correspondence that relates to the prosecutor's duty of
disclosure?
Having taken that from Simon Clarke at Cartwright King.
“We will therefore not be providing an unredacted copy
of the report.”
So that's a decision that you also came to or advice
to the clients that was encompassing others’ but also,
ultimately, your advice.
That was my advice, having discussed it with the
criminal lawyers.
"For the sake of good order, I note that [the Post
Office] disagrees with the statements in your email
about the integrity of data on Horizon and the safety of
convictions.
"I do not believe that this matter should delay the
submission of your clients' CQRs."
I want to look at the version of the Helen Rose
Report that was attached to Ms Maru-Singh's email, that
was being brought to your attention. I want to look at
it side by side with the unredacted version of the Helen
Rose Report. So could we bring up on screen
POL00022598, side by side with POL00147949. So that is
the original version of the Helen Rose Report and this
is the version -- the version that's about to come up on
screen, is the version that was sent as part of that
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complaint from Howe+Co, and this is the redacted version
and you've explained the redactions in your witness
statement.
I think it's paragraph 182 of your witness
statement. We don't need to turn that up.
So the author's name is redacted, Helen Rose, but,
if we turn over, please, on page 2 on both of them, we
see there the first redaction is to the branch details;
the second redaction is a username; but let's look at
that third redaction, please. The sentence on the
right-hand side, the real version, if we scroll down
sorry -- thank you -- it says:
"The Fujitsu logs were requested for this branch,
but whilst waiting for these to arrive communications
took place with Gareth Jenkins at Fujitsu for more
details to gain an understanding what had occurred at
this branch."
We then have the redacted version, which you say is
for data protection reasons, to the name of Gareth
Jenkins. We then have a look at question 1 and the
redactions that are made there. On the right-hand side,
the original:
"I am requesting Fujitsu logs for the Lepton
[branch] to look at a reversal", et cetera.
Then we have in brackets:
101
of the individuals named in the report. This was done
in order to ensure compliance with the Data Protection
Act..."
I mean, did you not apply your mind anyone in any
way to the redactions that had been made to that report
when drafting your email?
So the redactions were made by Cartwright King. They
told me they made them for data protection reasons.
Having looked at the report, it appeared to me that they
were redacting personal data, subject to that one extra
point around the mismarking of the document as
privileged. That's how I took the -- I took their view
on it.
You've said there, sticking with this email:
"Putting this issue aside, the real (and
confidential) [so nobody is being told] reason the
report was disclosed was because Helen's comment at the
bottom of page 3 suggests that it was widely known that
there were problems with Horizon. This statement ...
could have been used to attack Gareth Jenkins’
credibility ..."
Gareth Jenkins' name was redacted from that
particular version.
Again, you're going to have to take that up with
Cartwright King. I wasn't involved in the disclosure of
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"Gareth looked at the data at his end prior to me
receiving the Fujitsu logs."
We see there the name "Gareth" is redacted.
Now, how on earth could subpostmasters have attacked
Gareth Jenkins' credibility, as you've suggested was the
purpose for disclosing this, if Gareth Jenkins’ name was
redacted in that report?
I'm not suggesting that. This was redacted by
Cartwright King. I had no involvement in selecting
those redactions or the reasons for those redactions.
You would have to address those questions to Cartwright
King.
Well, let's look at your email. POL00029707. I think
you practice in data protection, don't you?
I do now.
Let's have a look at the covering email. POL00029707.
You make clear in that email:
"The only redactions made to the copies ... was to
remove:
"The personal information", et cetera.
If we scroll down, we can see your draft covering
letter to the complainant from Howe+Co. If we scroll
down to the bottom:
"The version of the report sent to Ms Robinson was
redacted to protect the privacy and personal information
102
this document or the redactions.
Why are you repeatedly drafting emails, sending
substantive comments to the Post Office, when you
weren't involved, where you were just a conduit for
information; why were you doing that? Why were you not
thinking through the consequences of the things that you
were advising?
So this is where we get to the crossover between the
scheme and the fact that some members of the -- some
applicants in the scheme were convicted. When those
crossover issues came up, as you can see here, I went
and spoke to the criminal lawyers. I feel like this
email faithfully represents the advice they gave to me
and I'm passing that advice back to Post Office.
I've noted down all those things that happened in the
summer of 2013, so we've got: suspense account bug that
was brought to your attention; concerns regarding the
integrity of Horizon; you had raised concerns regarding
the documenting of certain information; Castleton;
Misra; other cases on hold; Second Sight Report; three
bugs: you corresponded with the Criminal Cases Review
Commission, however you would like to put that.
You are here, in 2014, directly involved in advising
the Post Office in respect of a document that was.
disclosed following a criminal conviction and saying
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that "We don't need to unredact the redaction to Gareth
Jenkins' name", aren't you?
A. Following the advice of the criminal lawyers.
Q. Why in those circumstances wouldn't you have given it
a little more thought?
A. I wasn't advising on the prosecution disclosures. I'm
a civil lawyer. I don't have any experience of criminal
law. When these types of issues came up, I took the
lead from the criminal lawyers, particularly from Simon
Clarke, who is much more senior than I was.
Q. You were asked to unredact the Helen Rose Report. Your
advice to the client is "You don't need to unredact the
Helen Rose Report, those redactions were made for data
protection purposes". Why wouldn't you have satisfied
yourself that they were sufficient that they were
correct that they were fair?
A. Ihave no independent means of doing that because I'm
not a criminal lawyer. So I can't advise the client
independently on whether those redactions were
appropriate or not. The best I can do is go and speak
to the criminal lawyer who made those redactions and
seek his view.
Q. You knew the significance of the Gareth Jenkins issue;
you had read Cartwright King's advice; you knew that the
disclosure was being confidentially made for the purpose
105
MR BLAKE: Sir, that might be an appropriate moment but
I appreciate it is later in the day but if we could only
take the second break of the morning, so to 12.40.
SIR WYN WILLIAMS: Yes, and then how --
MR BLAKE: Then we can take lunch at 1.30 if that's
suitable.
SIR WYN WILLIAMS: So lunch at 1.30, all right. Fine.
MR BLAKE: Thank you, sir.
(12.28 pm)
(A short break)
(12.40 pm)
MR BLAKE: Thank you, sir.
Can we please turn to POL00146243. It's page 4 I'd
like to look at first, please, the bottom of page 4.
We're now on 2 September 2013. We have an email from
Alwen Lyons, the company secretary, to Hugh Flemington,
and she says:
“As per our conversation this morning. I would
appreciate if you would get external advice on any risks
in the Lessons Learned Review work. My concerns are
specifically around the Freedom of Information Act or
disclosure requirements for our criminal prosecutions
and civil actions."
If we scroll up, Hugh Flemington sends it to you.
"As discussed I've been asked for the advice per
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of disclosure. Do you think, looking back at all of
that, you really reflected enough on the job that you
were doing?
I think if I -- reflecting back on it now, I think there
was probably an original mistake by the criminal lawyers
in redacting Gareth Jenkins' name and not being more
transparent about his involvement and why they were
making the disclosures back at the beginning of 2013.
Why is it all the criminal lawyers’ fault? You were
here involved in matters touching on criminal law,
weren't you?
I've -- I hope I've tried to explain my involvement with
the criminal touch points but, as I've said, I'm not
a criminal lawyer, I don't know these rules and I can't
advise on them. What I'm trying to do here is helpfully
give Post Office the advice they need, acting, as
I say -- and I know you don't like this phrase -- but as
a conduit for the information from the criminal lawyers.
Should there have been a point where you said, "I'm
sorry but I can't act as a conduit any more, this is so
outside my area of expertise that I really can't assist
you?"
I didn't feel it at this point on this particular issue,
no. Having spoken to Simon Clarke he was clear to me he
thought those redactions were properly made.
106
email below. Would you mind reverting to me in the
first instance."
We have the response and that begins at the bottom
of page 2, please. Your response is as follows:
"Simon
"As discussed, please find below the high-level
advice on the terms of reference for the 'Lessons
Learned Review ...
“In general, the Post Office's desire to review past
activity and improve the future is understandable.
However, the nature and timing of the review presents
several risks to the Post Office ... and, critically,
cuts across number of ongoing activities.
"For these reasons, I would recommend that if the
review does need to take place at all, then it should be
deferred for 6-12 months so to first allow Second Sight
to be managed out in the Mediation Scheme to be
completed."
Then heading "Disclosure of The Review":
"Privilege -- This review will not be legally
privileged. This may make it difficult (if not
impossible) to resist publicly disclosing details of the
Review (as well as any documents and emails produced in
the course of preparing the review) if a Freedom of
Information Act request is made (by say the media, JFSA.
108
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or a subpostmaster).”
Still under 1, the second heading under 1:
“Criminal disclosure -- Should the review reveal any
concerns about Horizon or branch accounting processes
then Post Office may be obliged (under Criminal
Procedure Rules) to proactively pass this information to
subpostmasters involved in criminal prosecutions (both
ongoing and historic). In particular, recommendations
for change could be interpreted as highlighting historic
problems that would need to be disclosed."
Everything we've been talking about this morning,
you've been very concerned to distinguish between your
role as advising in relation to the civil matters only,
not criminal matters. What do you have to say about
a paragraph here where you are advising on criminal
disclosure?
So this is a very basic statement of the disclosure
duties that Post Office was under and I've taken that
from the advice that I've seen previous to this from
Cartwright King.
Are you advising the client in this email of the
implications of the Lessons Learned Review in respect of
criminal disclosure obligations?
Yes.
Thank you. Can we please now turn to POL00021865.
109
evidence of the [subpostmaster] putting the money in her
pocket?'. I don't believe we can win this battle in the
media.”
You have there a fair grasp, in broad terms, of the
criminal argument, don't you? The criminal law
arguments?
Ata very high level.
You then say:
"[The Post Office] could however start attacking the
postmasters credibility by calling out Thomas, Misra and
Hamilton ..."
Those are three people who have been convicted of
criminal offences.
as the liars and criminals that they are.”
Now, how could you say that, having, for example, by
this stage, received the advice on the reliability of
Gareth Jenkins?
On reflection, that language is too strong.
"They all admitted to [false accounting] and all
admitted to it again last night on Panorama. [The Post
Office's] language to date has been constrained (last
night it was ‘deliberate dishonest conduct’ which was
a generally way to put it). Perhaps some more punchy
language, combined with more specific details of the
[false accounting] might help rebalance public
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We'll come back to the 2013 period but I want to take
you now to a few events over subsequent years that may
be relevant to what occurred in 2013 and advice that you
gave. This relates to the Panorama broadcast and you
are providing Rodric Williams with your thoughts on the
confidentiality position following Panorama. You say as
follows:
"My thoughts below ...
"In short, my view is that [the Post Office] either
(i) does nothing but a bare denial of the allegations
and waits for the Criminal Cases Review Commission or
(ii) goes on a full attack -- with the former being my
strong preference. Any middle ground simply feeds the
fire and I don't believe that steady reasoned argument
or disclosure or further documents will assist in
changing the story."
Then there's a section on applicants and you say as
follows:
"I'm not convinced that responding to the
‘inappropriate theft charge’ allegation for each case
with a more detailed explanation of what happened would
be worthwhile. Our arguments are technical, rely on the
intricacies of the prosecution process and are based on
a range of evidence rather than a single smoking gun.
The man in the street will simply say: ‘where is the
110
perception."
Do you think that is appropriate advice to be
giving?
I don't think that is the advice I'm giving. If you
read the opening paragraph that you touched on, it makes
it very clear that my advice is that Post Office should
do something and wait for the CCRC. What I'm then
setting out below is the alternative proposition but
that wasn't the advice I was giving.
The advice you were giving is that there are two
options, the former is your strong preference but you
haven't ruled out the latter, have you?
No, I'm giving the client options and giving them what
my preference would be, which would be to do nothing and
wait for the CCRC.
Do you think that couldn't option was appropriate?
I think it was an option that Post Office could consider
but, as the top paragraph says, it wasn't what I would
recommend they do.
How is it advice relating to a legal position, rather
than, effectively, PR advice responding to the Panorama
programme?
Apologies. Could you put the question again?
Absolutely. You're looking there -- an option, although
admittedly one that wasn't your strong preference, was
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to attack the postmasters' credibility by attacking
Thomas, Misra and Hamilton. How is that legal advice
rather than, for example, PR advice, because it's
responding to the Panorama programme?
I think the Panorama programme -- and I haven't watched
it since that time because it was a long time ago -- did
stray into questions around legal responsibilities and
liabilities. So I accept there's a grey area here
between legal advice and PR advice.
If we scroll down, there's also comments there on Second
Sight. You say:
“For the reasons given above, I don't believe that
a substantive debate over [Second Sight's] views on the
‘inappropriate theft charge’ allegation would be.
successful. Whatever we think about them, the wider
perception is that they are independent experts and
credible."
Just pausing there, by 2015, what did you think of
them?
By this point, I had concerns about the quality of the
work they were producing.
Just the quality of the work?
lalso had concerns about -- that they seemed to be
leaning more towards the subpostmasters and ignoring
some of the points the Post Office was making.
113
of three criminal defendants, it seems once again to be
straying somewhat into the criminal sphere, doesn't it?
As I've explained, there are touchpoints between the
criminal areas and the Mediation Scheme and the civil
areas. Those points come into contact with each other
but I don't believe that I'm crossing the line into
advising on criminal law matters here. To the extent
that I refer to criminal matters, it's based on advice
I've received from the criminal lawyers.
"Bare denial of the allegations and wait for the CCRC",
though, I mean, that comes pretty close, doesn't it, to
advising in relation to how the company acts in respect
of the Criminal Cases Review Commission?
I think the status quo at that point is Post Office was
waiting for the CCRC, so I don't think that's telling
Post Office anything new.
As I said, I'm going to jump a number of years now, to
a few different periods. Let's move on a year, and go
to WBON0000465, please. This is 5 October 2016. Amy
Prime emails you. Who was Amy Prime?
She was a solicitor on my team.
She was, by that stage, a newly qualified solicitor,
wasn't she?
Correct.
I think we've seen her involvement in some other stages,
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You then say:
“If [the Post Office] wished to respond, I would
again recommend attacking their credibility and start
with disclosing the extract from their engagement terms
that says: ‘it is acknowledged that matters relating to
criminal law and procedure are outside Second Sight's
scope of expertise’."
Now, you've identified a couple of issues that you
had with the quality of Second Sight's work but how
could you attack their credibility?
In this sense, it was because Second Sight had accepted
in their engagement terms -- again, I'm doing this from
memory -- that they didn't have expertise in criminal
law and procedure, yet they had gone on to offer
opinions on those matters.
Looking back at this email, is it your view that the
advice that you were giving there and that the language
you were using about subpostmasters was not appropriate?
I accept that the comments about the three
subpostmasters named was inappropriate but I think it
all has to be read in the context of the top part of the
email where it says, "My strong preference is Post
Office does nothing and waits for the CCRC".
Reference to the CCRC there, reference to the
inappropriate theft charge, referring to the credibility
114
perhaps when she was just a trainee, but, by this stage,
she's qualified that year?
I believe so.
She says:
"Andy
"Please find below a draft email to Rod on the
Investigations Guideline -- would appreciate your
thoughts/comments on this."
Then she has below a draft that has been drafted:
"Rodric
"The below is not urgent but for you to consider as
and when you get a chance. Freeths have requested that
we provide them with Post Office's Investigation
Guidelines since 1998 (including any revisions to date).
In the earlier round of disclosure, we did not provide
the guidelines since we wished to confirm whether the
documents were covered by privilege. Brian Altman has
confirmed that they will not be covered by privilege and
as such the guidelines will, at some point, have to be
disclosed.
"We have reviewed both the most recent version of
the guidelines ... and the prior version ... Of note,
the 2013 version ... provides ‘Should the recent Second
Sight review be brought up by a subject or his
representative during a PACE interview the Security
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Manager should state: "I will listen to any personal
concerns or issues that you may have that with the
Horizon system during the course of this interview".
"Freeths will more than likely use this statement
afterwards an opportunity to confirm that Post Office
responded to postmasters using stock answers (a point
which has already been raised in relation to the
helpline) and further could be spun to show that Post
Office was not taking issues with Horizon seriously and
were trying to ignore any issues which were raised.
"Although we may face some criticism later on, we
are proposing to try and suppress the guidelines for as
long as possible on the grounds that the most recent
version is not relevant since it post-dates the
investigations complained of and it would require a full
disclosure exercise to piece together alll historic
revisions of the guidelines. We thought it would be
best to bring this to your attention early.”
You respond to Ms Prime the same day, let's have
a look at WBON0000467. Thank you, you respond as
follows:
"One addition below. Little tip -- try to always
spell out exactly what is required from the client (even
if that is nothing or a negative statement like below)."
So you're there providing a tip to the newly
117
Whilst, as I have said I do not recall this email, my
firm's records show that Amy had sent a draft for my
approval earlier that day which did not contain this
final paragraph. I responded to her adding it into her
draft though my purpose in doing so appears to have
simply been to make clear what action we required from
[the Post Office] on this point, rather than to consider
or build upon the substance of her email. Though
ill-expressed, having reviewed the relevant emails from
around this time I consider that [that document] and the
final paragraph in particular does not reflect the true
position, as there were in fact substantive legitimate
reasons for resisting disclosure of the investigation
guidelines at this early stage. My email should have
been better expressed to make that clear at the time.”
Let's take that down on the left-hand side and let's
concentrate on that paragraph. It's not just a poor
choice of words, is it? Even if you take out the words
in terms of legitimacy, so let's take out "that looks
legitimate", what you are saying here is that "We are
ultimately withholding a key document".
I mean, that's not a poor choice of words; that is
your acknowledgement at that time that there is a key
document, that it is okay to withhold that document for
as long as possible, isn't it?
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qualified solicitor. Were you her supervisor or were
you --
I'm not sure if I was formally her supervisor but she
was a lawyer in my team.
You're providing her with a tip to spell out exactly
what is required to the client.
If we scroll down, we can see on the second page,
the paragraph that you have then inserted that reads as
follows:
"For now, we'll too what we can to avoid disclosure
of these guidelines and try to do so in a way that looks
legitimate. However, we are ultimately withholding
a key document and this may attract some criticism from
Freeths. If you disagree with this approach, do let me
know. Otherwise, we'll adopt this approach until such
time as we sense the criticism is becoming serious."
Now, you've addressed this in your witness
statement. If we could perhaps keep that on screen but
also just bring up the witness statement on to screen,
page 235. Thank you very much. It's page 235, so the
explanation starts at paragraph 411.
412 you come to this particular document and let's
see the explanation is at 413 so that's over the page,
please. You say:
“Regrettably, this email is worded very poorly.
118
So we are advising Post Office here not to disclose this
category of documents. I think the reference there to
a key document is not referring to those two specific
versions we have but the broader category of
investigation guidelines, which is what the request was.
So the investigation guidelines, that is the guidelines
that led to people's investigation, subsequent
prosecution, conviction.
No, the -- the request was for investigation guidelines
in the broadest sense so it could have included any form
of investigation --
Okay, so not limited to criminal prosecutions but
including investigations that led to criminal
prosecutions?
Correct.
Including investigations that led to people wrongly
losing their jobs?
I -- yes, I guess so, but I wouldn't be able to draw
that line directly.
Investigations that led to people becoming bankrupt?
Yes.
And, irrespective of your reference to doing so in a way
that looks legitimate, you are saying there, you are
advising a client, that you can withhold what you
considered at the time to be a key document until the
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criticism is such that it's becoming serious.
So the context here is this is in the pre-action phase
of the litigation. No disclosure orders have yet been
made and the request that was made of us was for a broad
category of investigation guidelines. The two documents
we had were dated from August 2013 and 2016 and,
therefore, post-dated, in this sense, any prosecution
that Post Office had conducted because, as I understood
it, Post Office hadn't conducted any prosecutions after
July 13,
So, in that sense, I thought there -- looking at it
now, it's a very poorly worded email, I regret sending
it but, having looked at it again, I believe there were
legitimate grounds not to disclose those two documents
at that point in time, which is during pre-action.
What does it matter; what does it matter that you think
now about those documents? At the time that this
document -- this email is drafted, this letter is
drafted, you considered that it was a key document,
didn't you?
I considered the investigation guidelines, as
a category, a key document, yes.
Your advice to the client was "withhold until criticism
is so serious that you have to disclose", isn't it?
Withhold those two versions of the document, which is
121
"The most recent version is not relevant since it
post-dates the investigations complained of and it would
require a full disclosure exercise to piece together all
the historic versions of the guidelines."
Again, the context is important. This is during the
pre-action phrase of the litigation where a party is not
required to undertake a disclosure exercise.
Doesn't this show a mindset, a mindset that we have
already seen from 2013, not to record, not to disclose
or, if you're going to have to disclose something, hold
onto it to the very last moment until you absolutely
have to disclose it.
I think each of those has to be considered on its own
merits, in its own circumstances at the time. I think,
against that, I would weigh the fact that we advised
Post Office to run the Mediation Scheme, which itself is
a process that gave rise to lots of information being
provided to subpostmasters. So I think there are other
points on the other side of that equation.
Let's look at the same criticism but in different
circumstances. We're going to look at the Known Error
Log. Can we please turn to POL00245938, please. If you
could turn to page 5, there's a request that is sent to
the Post Office, I think it's by Tim McCormack,
although, slightly facetiously, it's entitled "AN
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the only two versions we had been provided at that time;
there the only two documents we'd been provided with
under that broad category of investigation guidelines.
For the reasons that are stated in this email, we
considered they weren't disclosable. That's not
retrospectively my position; that was my position at the
time. You said earlier the explanation for this began
at paragraph 411. I think it begins at paragraph 404
and it does set out the background.
But what does it matter now that you consider those
documents were not disclosable, if, at the time, you
thought not only are they disclosable, they are the key
documents?
No, no, apologies. Maybe I'm not being clear. The
email is poorly expressed but my belief at the time was
that those documents were not disclosable.
Your belief at that time was they were not disclosable?
Correct.
Where on earth in this correspondence does it say that?
How could anybody reading this get the impression that
your view was that they were not disclosable? How does
that paragraph -- how can that possibly be read as
suggesting that it wasn't disclosable?
So the explanation is in the paragraph above, where it
says:
122
Obody", or "A Nobody". If we turn to the top of page 5
he sends an email to the Post Office and he says as
follows:
"I thought I sent a reply to you but it doesn't seem
to have got through.
"I cannot talk to anybody about this because I have
signed off my branch accounts with the wrong figure and
I can go to prison for doing that. I haven't taken any
money. I want to know what errors to look for. I read
all this talk about errors in Horizon on the Internet.
I want to know what they are. You say you have that
information but you won't give me it so what is my
alternative. I don't have the sort of money to give to
you. Will you prosecute me for my accounts if I talk to
Mrs Bogard? Please tell me, surely you have to tell me
what these errors are?"
What he's doing there, what that email is designed
to do is to try to draw out of the Post Office
information about known errors because, if you were
a subpostmaster who had signed off your branch accounts,
you know there's a problem but you don't know what the
problem is, you want information from the Post Office to
tell you what are the problems; what are the known
errors that might explain my discrepancy?
Did you understand that to be the background or the
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picture to be painted here?
I can see those are the questions being asked but the
fact that it was sent from AN Obody made me doubt the
veracity of this request.
Absolutely. So it may not be somebody who is actually
having a problem but it poses a theoretical problem for
the Post Office to answer.
Let's go to page 1, and this is your advice on that
email. You respond to Rodric Williams, you say:
"Draft [business as usual] response attached. I've
gone for a very soft known. Although I'm 99% sure this
is a fictional case, we just can't take the risk.
"I've not made any express reference to the [Known
Error Log]. Even the phrase ‘known error’ could set
hares racing so I've avoided it entirely. I hope
however the key message (‘cart before horse’) still
comes across."
Were you still concerned, even at 2016, about
disclosing the fact that there was a Known Error Log?
So at this point in November 2016, the Group Litigation
is under way, Freeths are aware that there is a Known
Error Log. There is ongoing discussions around the
disclosure of a Known Error Log, so the fact that it
exists is out there with the claimants’ lawyers.
I think the response here is in the context of this
125
"Ben
"Please find attached the updated board report
addressing your points. The key points to note are:
"1. [Womble Bond Dickinson] are assessing the risk
over the weekend of the 93 high-risk [Known Errors
Logs]. By [a date] next week counsel will have reviewed
those KELs in detail and given a view on whether they
are likely to cause the Horizon trial to be
recommenced/the judgment delayed.
"2. In relation to the [circa] 14,000 other [Known
Error Logs] (ie those not used at the trial), the key
risk of reviewing the 14,000 ... is that the claimants
have not asked for the documents yet. If we review them
now, [the Post Office] will be required to disclose any
adverse documents uncovered. This is doing the
claimants’ work for them and may highlight new bugs in
Horizon that the [claimants] had previously decided not
to raise/overlooked. The advice of [Womble Bond
Dickinson] therefore is that the [Post Office] should
not review the 14,000 other Known Error Logs unless the
claimants ask for them or Tony's review highlights major
risks that warrant a wider review."
So your advice there is that you shouldn't look at
that wider body of error logs because there may be bugs
in there that are found that need to be disclosed?
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feeling like a fictional request, one improper request
for some improper purpose, and I don't think Post Office
should be required to provide extensive details in those
circumstances, where it feels like the request is
somehow being made as a, I don't know, a trial or
a joke.
What do you mean by set hares racing there?
Because I think the phrase "known error” conjures up
views in people's mind around the extent of problems
and, at this point in time, we had been told by Fujitsu
that the Known Error Log didn't contain any bugs that
affected Horizon -- sorry, didn't affect branch
accounting.
Let's fast forward to 2019. Can we please look at
POL00043147.
We're now in the thick of it in the litigation,
addressing the Known Error Log. An email from you to
Rodric Williams and others:
"Rod, Kate
"Bullets for comment. Below is a possible email to
I think that's Ben Foat, is it?
Yes.
. from Rod. Attached is an updated board report."
Then the email says as follows:
126
No, not quite, because these are -- these 14,000 KELs
are back versions of KELs. So the original -- the final
version has been disclosed already within the Group
Litigation. So these are only earlier versions of
documents that have already been put out there and so
they may contain more information about already
disclosed problems but I think it's unlikely they would
have contained existence of new bugs.
"This is doing the claimants’ work for them and may
highlight new bugs in Horizon that the claimants had
previously decided not to raise or overlooked."
Yes. There is a possibility of that, I accept that, but
the context is important: that these are back versions
of KELs that have already been disclosed.
Once again, is this a concern in relation to looking for
things or mentioning things just in case they had to be
disclosed?
Well, at this point we've already informed the claimants
that there are these 14,000 KELs and they can, of
course, request them and disclose them -- request them
and review them if they wanted to. Ina piece of
litigation like this, I don't think it was incumbent
upon Post Office to have to review those documents.
Were you concerned that, if you carry out too many
investigations at this stage, there would arise some
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information about the integrity of Horizon that would be
disclosable that you wouldn't want to be disclosed?
A. I think that the depth of information around Horizon was
massive. There were hundreds of thousands of documents
and I think, if you review more technical documents on
the system, there was always a possibility that it would
give rise to a new problem. That's just an inherent
risk in a pile of documents that big and, if that
happened, we would have to disclose it.
Q. That's looking about in the system but what about
discussing things with Fujitsu, for example? Were you
concerned about discussing things with Fujitsu, just in
case they gave you something that you might have to
disclose?
A. I don't recall that being a consideration in terms of us
being worried that Fujitsu would tell us that there was
something to be disclosed. In fact, we repeatedly asked
them for that type of information.
Q. So you were repeatedly asking Fujitsu for information,
and what -- is your concern that they weren't giving it
to you?
A. Well, for example, if you go back, and this is at the
end of - this is 2019 -- if you go back to the earlier
stages of the KEL, when we asked them about the KEL
originally and we asked them explicitly are there any
129
and could lean to lines and lines of questions, which
means -- and what we were trying to do here was move
this matter to a conclusion.
Q. Surely what you're doing there is very similar to what
we saw from 2013 onwards, which is: don't seek something
out, don't get hold of a document or information,
because you might have to disclose that and it might be
something that we don't like?
A. I don't see the dots that you're connecting there, I'm
afraid. As I say, you have to consider each of these
points in time as you look at them.
MR BLAKE: Sir, that might be an appropriate moment to take
our lunch, please.
‘SIR WYN WILLIAMS: Certainly.
MR BLAKE: Could we, please, therefore, come back at 2.15?
SIR WYN WILLIAMS: 2.15. Right. Very well, yeah, we'll
resume at 2.15.
MR BLAKE: Thank you very much.
(1.15 pm)
(The Short Adjournment)
(2.14 pm)
MR BLAKE: Good afternoon, sir, can you see and hear me?
SIR WYN WILLIAMS: Yes, I can, thank you.
MR BLAKE: Thank you. Mr Parsons, we're going to move on to
a few separate topics, the first of which is Second
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bugs that affect branch accounts within the KEL, they
told us there weren't any.
Let's look at POL00043169, please. We're still on the
KEL. Bottom of page 1, please, an email from you to
Catherine Emanuel, Rodric Williams and others:
"No more progress on the [Known Error Log] review
because I've asked Tony to turn his efforts to the
[Known Error Log] response letter that now urgently
needs to go out the door.
"He'll then circle back to the remaining KELs to be
reviewed of which there are about 15. We will then have
a shortlist of about 25 (I'm guessing) KELs that will
need [Fujitsu's] input. We are collating a list of all
the questions to [Fujitsu] on these 25 but before
sending that to [Fujitsu] we need to take a tactical
decision on whether that is a good idea, bearing in mind
that sometimes we ask [Fujitsu] a question and get
answers we don't like!"
Isn't that the opposite of what you've just told me
in respect of to your relationship with Fujitsu?
I wasn't concerned there that they would turn around and
say, "Look, there's some more bugs in the system". If
they'd have told us that, we'd have disclosed it. The
challenge at this stage was that the answers we'd get
from Fujitsu would be opaque or difficult to understand,
130
Sight. Can we start, please, with WBON0000767, so we'll
start on 12 July 2013. If we scroll down there, there's
an email from you to Susan Crichton and you say as
follows:
"Susan
"Had a quick chat with Gavin."
Who is Gavin; is that Gavin Matthews?
Correct.
What was his position?
He was my supervising partner.
Yes.
“Arbitration will probably end up as formal and
long-winded as court proceedings. We'd also lose
a degree [of] control -- the process and timing would be
controlled by the arbitrator. I'm not attracted to
this."
So they're discussing options: one is arbitration,
another is mediation? You come on now to address
mediation, and you say:
"Mediation is a definite possibility. I could
envisage a mediation between [the Post Office] and each
[subpostmaster] (with also [Second Sight] in the room --
and perhaps Shoosmiths?). This gives each
[subpostmaster] the opportunity to voice their views and
discuss [Second Sight's] findings. Having a mediator in
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the room would help equalise the imbalance of power.
Mediation would not commit [the Post Office] to any
‘outcome (unless one was agreed by both parties) and
could be conducted on our timetable. If the mediations
were run after [Second Sight's] final report, this may
help ensure that the report focuses on general themes
whilst leaving specific cases to be heard in the
subsequent mediation process.
"The risk in is that mediation is usually set up
with a view to reaching a resolution. As discussed
yesterday I doubt we will ever reach closure on these
cases. [The Post Office's] Comms Team would therefore
need a robust media strategy to explain why the
mediations will, in the majority of cases, fail to reach
consensus between [the Post Office] and the
[subpostmaster]. Otherwise, this may be spun as
a failure to close out this matter."
It seems as though there was a discussion the
previous day, then, about mediation; do you recall those
discussions?
I recall that during this period there were a number of
discussions about different ways of taking things
forward after the Second Sight Interim Report, of which
mediation was one of the possibilities.
Now, why would mediations in the majority of cases fail
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"The approach assumes that [the Post Office] is
liable and will offer settlements (and seems to hint at
cash settlements). I'm not sure where [Second Sight]
have got this idea from? Any hint that [the Post
Office] may be considering cash settlements would
encourage the toxic cases, encourage Shoosmiths and play
badly in the media. I think we need to put a stop to
this quickly."
Let's just unpack that paragraph, please. First of
all, cash settlements. It seems as though you're
surprised by the suggestion of cash settlements in the
summer of 2013. Why is that?
I think if -- I can't see Alan's email here but I think
the scheme that he was envisaging was more of
a compensation scheme, whereby there was a sort of
almost a presumption of liability and it was just then
about compensating people, whilst, at this stage, Post
Office wasn't -- their instructions weren't that they
weren't prepared to accept liability across a wide
piste.
What is the purpose of mediation if there isn't going to
be a financial settlement at the end of it?
There could possibly be a financial settlement at the
end of mediation but, as I say, I think Alan's proposal,
which is further down this email chain, wasn't
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to reach a consensus?
My understanding at this point in time is that there was
a large delta between Post Office's view of the world
and the subpostmasters' view of the world.
We know that it did go to mediation, ultimately. What
was the purpose of mediation, if there was this large
gulf that was unlikely to result in any resolution?
So the shape of this moved on, after this email, into
a slightly different shape of scheme, where the cases
would be reinvestigated first and then mediated, which
I thought would close the gap between the two parties
and give mediation more of a prospect of success.
Could we please turn to POL00191954. The same day, in
fact, 12 July. If we turn to page 4, we can see there
that Alan Bates has been in touch, addressing matters
have been discussed, and it comes to a point where you
are advising, if we turn to page 1, please -- he made
some suggestions on how the Mediation Scheme might be
conducted and then we have your advice to Susan Crichton
here. You say:
“Alan's approach seems similar to what we discussed
yesterday, however there are some critical differences:
"[Second Sight] seem to be being used as a weapon by
the [Justice for Subpostmasters Alliance] to force [the
Post Office] into settlement -- that is not their job.
134
a mediation proposal; it sort of assumed more of
a compensation scheme structure.
"Any hint that the Post Office may be considering cash
settlements would encourage the toxic cases ..."
Just pausing there, that's an expression we've seen
elsewhere. Can you see us with what "toxic cases" were?
I think that was Alan's choice of words to describe what
he saw as particularly difficult subpostmaster cases.
So they would be encouraged by the idea of cash
settlements:
"... encourage Shoosmiths and play badly in the
media. I think we need to puta stop to this quickly.”
Just reading that, what would be the -- I mean,
mediation would, at some stage, presumably, lead to some
cash payments to subpostmasters, wouldn't it?
Yes. But, as I said, I think Alan's email below isn't
really talking about a mediation-type structure; it's
talking more about a compensation scheme structure that
assumes liability. So they're two very different
concepts and I was concerned here with Post Office
conceding the liability point and assuming there would
be cash settlements in every case.
We're going to move on to December 2013. Can we please
turn to POL00327110. It's an email from you to Martin
Smith, Jarnail Singh and Rodric Williams:
136
(34) Pages 133 - 136
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"Martin, Jarnail, Rodric
"As discussed last week, below is our next thorny
question on the interaction between the mediation and
criminal prosecutions.
"We now have 4 cases in the scheme subject to live
criminal investigations/prosecutions. Thus far we have
refused to provide any details of these cases to the
Working Group. However, the Working Group are concerned
that as they have no oversight on these cases, there is
no way for them to validate that the applicant's
application to the scheme should remain suspended.
Underlying this is a general (and in my view
unwarranted) distrust by [Second Sight] and the [Justice
for Subpostmasters Alliance] of how [Post Office]
handles criminal cases."
We've spoken a lot today about how, in your view,
you had a very hands-off approach to the criminal cases.
How is it you formed the view that their distrust was
unwarranted?
I can't recall this particular email and what drove that
thought.
Presumably, you had a sufficient knowledge of how the
criminal cases were being addressed to write in an email
that it was an unwarranted distrust?
All my knowledge about the criminal cases was passed to
137
report."
So, by this stage, Second Sight were working on
a second report that addressed themes; is that correct?
That's correct.
"At the [Working Group] meeting on Friday [Second Sight]
hinted that their concern is not a comms failure between
branch and data centre (and therefore a failure to
record transactions to the audit log in the DC) but
rather it was where a third party system received the
transactions but there is a comms failure that stops the
transaction completing at the branch end ... They call
this the ‘one-sided’ transaction issue. The point is
not expressly drawn out in M014 but does come out more
clearly in M001 -- Castleton.”
You then say this:
"The variation on the comms theme is not directly
covered in the [Fujitsu] data integrity documents so we
may need to commission further work from [Fujitsu] once
we know for certain how [Second Sight] have
characterised this in their thematic report. On that
basis, I think sending more [information] at [Second
Sight] at this stage risks them asking more questions.
My preference is for a targeted attack on the [Second
Sight] report when we understand the specifics of their
position rather than be on the back foot in trying to
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me by the criminal lawyers. I never reviewed any of the
criminal cases myself.
But you didn't say "in Cartwright King's view it's
unwarranted". You had formed a view at this stage about
the trust that should be placed in the Post Office's
handling of criminal cases. How did you form that view?
Based on the information I'd seen from the criminal
lawyers.
Did you just assume that what they had told you was
correct, in that respect?
Yes, because I was relying on them to provide me with
that information.
Can we please turn to POL00201761. We're now in March
2014, 13 March and this is an email from yourself to
Rodric Williams. If we actually scroll down slightly,
at the bottom you can see there he is asking you, he
says:
"What are your thoughts on how we should feed to
[Second Sight Fujitsu's] response below on [Second
Sight's] M014 report?"
So that's a specific review that Second Sight are
conducting. If we scroll up, please, you say as
follows:
"Rodric
"I think we hold fire until we see the thematic
138
defend the entire Horizon comms infrastructure."
Second Sight were a firm of independent
investigators that had been instructed by the Post
Office to carry out that independent investigation. Is
the approach that you're taking here very similar to the
approach in litigation? A targeted attack on their
report. It does seem rather adversarial, doesn't it?
Yes, I accept that I adopted a reasonably adversarial
approach.
Was that based on instructions or was that the way that
you saw it should be approached?
Itwas a combination of my doubts at this point in the
quality of Second Sight's work and that was the general
direction and theme that Post Office were taking.
Who was setting that direction and theme, in your view?
The group of individuals I was talking to on a daily
basis about the scheme: so Rodric Williams, Belinda
Crowe and the other members of the Project Sparrow team.
When the scheme was set up, did anybody ever tell you,
for example, "This is intended to be like a truth and
reconciliation commission", or something along those
lines, "Where we're not to take an adversarial
approach"?
Don't recall any -- I don't recall anything along those
lines.
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Can we please turn to POL00305714. We're moving now
swiftly to the summer of 2014, 11 August, and there is
ameeting. Second Sight's draft Part 2 mediation
briefing report. It's a teleconference. Amongst the
participants you're listed there as the representative
from Bond Dickinson; do you recall that meeting?
No, I don't.
Let's have a look at the notes. The record of that
teleconference. Could we go perhaps and look at page 3,
please, the bottom half of page 3. Thank you:
“Lack of evidence
"Second Sight expressed concern that the character
of the conversation is one of litigants
antagonistic."
That's a fair reflection of the approach you've just
described, isn't it?
I think it waxed and waned so there was certainly
a period of time at the beginning where we were very
much looking to cooperate with Second Sight, provide as
much information as we could, particularly in the
individual cases. At times it became more adversarial
and at times we tried to row that back again because we
realised it had got too adversarial. So I think it
moved during the course of, what, the 18 months that the
scheme was running.
144
external legal advisor at the meeting. Were these
likely to have been your words or a summary of your.
words?
I don't recall this call and I think this document was
only sent to me a few days ago, so I haven't had
a chance to look into it.
"Post Office flagged the risk of straying into legal --
layer upon layer of legal argument/dangerous ground to
comment on contract -- applicants may rely on as legal
advice.
"Post Office suggested if there are areas Second
Sight are not qualified to investigate -- that might be
an issue for Post Office to look at. Had the scope been
criminal or contract, wouldn't have employed
accountants.
"Second Sight concerned late in the day to mention
‘out of scope. ‘Don't recall anyone raising this
previously’. ‘No one previously cried foul’.
"Post Office responded that this is not about crying
foul. Raising now as out of scope has first raised as
a material point."
You may not recall this exact meeting at which you
were attending but can you recall, in the summer of
2014, those kinds of real tensions between the Post
Office and Second Sight?
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"Second Sight claimed this is the antithesis of what the
CEO and Chair assured them would be the case."
Were you aware of any discussions or instructions
from the CEO and Chair about how the scheme should be
conducted?
I don't recall.
"Post Office reassured Second Sight that the
conversation is not antagonistic. Post Office expressed
concern about Second Sight not getting to the truth of
the case and not providing evidence.
"Post Office stated not trying to fetter Second
Sight independence or take things out, just want to get
the paper right. Post Office expressed concern that the
lack of evidence doesn't take things further. Post
Office concerned applicants may feel issues are more
widespread than they are.
"Second Sight claimed they report the truth, with
an objective to help the applicants.”
Scroll over:
"Post Office raised two examples of items that are
out of scope, et contract and criminal. ‘If you look at
criminal matters need to ask why and who are you doing
this for’.”
Just looking back at the attendees, there was nobody
from Cartwright King at this meeting. You were the only
142
Those issues around scope were points of tension. Post
Office thought that Second Sight were exceeding their
cope by including commentary on legal issues within
their reports, where Post Office had attempted to run
the scheme without advancing legal defences, certainly
during the investigation phase. But, alongside this,
there was also a lot of cooperation in terms of
providing information to Second Sight.
If we scroll up it's not just scope, there's the section
‘on "Lack of evidence", and it said there, penultimate
paragraph:
"Post Office expressed concern that the lack of
evidence doesn't take things further. Post Office
concerned applicants may feel issues are more widespread
than they are.”
Is that a concern that you recall at that time --
(No audible answer)
-- aconcern at the Post Office that Second Sight might
be giving the impression that things are more widespread
than Post Office thought them to be?
I don't recall the last bullet point being discussed
with me.
You were at this meeting, though?
As I say, I don't recall the meeting.
Do you remember that being a concern?
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I don't recall that idea coming up.
Can we please turn to POL00075810. Moving now to
16 October 2014. There's an email, the second email on
that page, please, if we scroll down, an email from you
to Anthony Hooper, the Chair of the Working Group, and
you say:
"On our last [Working Group] call you asked Post
Office to make clear which cases it considers are
suitable for mediation before the face-to-face meeting
tomorrow. You asked Belinda to ensure that this
information was copied to Second Sight so I have [copied
in] Ron and lan.
"Having carefully considered Second Sight's final
CRRs..."
Is that the questionnaires?
No, that's the Second Sight Report?
"... Post Office's position on mediation is set out
below. We will explain at the meeting tomorrow our
reasons for taking these positions."
So you've been asked to identify which cases you
consider are suitable for mediation and you have
responded to the Chair of the Working Group and we have
there set out the Post Office's position on mediation.
Can we please look at that. So if we scroll down
slightly: number 1, unsuitable; number 3, unsuitable;
145
so slightly so I can see the date. So October '14, at
this point the cases will all have been at different
stages, some will be waiting investigation, some will
have been investigated by Post Office, some will have
been investigated by Second Sight and some will probably
have gone through to mediation, so I think that's just
a snapshot in time of those cases.
Do you think that, in reality, by that stage of 2014,
this was a properly functioning scheme?
I think it began to break down -- well, the Working
Group began to break down around this time and towards
the end of 2014.
Was the Working Group was meant to determine which ones
were suitable and, at least on the face of this email,
it's not actually receiving any that the Post Office
considered to be suitable?
Well, as I say, this is a snapshot. How many cases are
there, about ten? There are 150 cases in the scheme.
Could we please turn to POL00141727, please. Still in
October, 31 October now, an email from you to Patrick
Bourke:
"Patrick
“In recent CRRs, I've noticed [Second Sight] using
language such as ‘[the Post Office] has failed to
disprove the applicant's assertion’ -- see paragraph 4.2
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number 5, currently minded to consider unsuitable; 17
unsuitable; 21 unsuitable; 29 unsuitable; et cetera,
et cetera, et cetera.
At that point, all of the cases were listed by
yourself as being unsuitable for mediation; do you
recall that?
I'm trying to think if there was any commonality in
those cases that led to that decision. Because this is
towards the end of 2014, the cases to which were
suitable tended to move through the scheme quicker, so
they may well have already passed through and what was
left were the ones which were more heavily contested,
where Post Office thought they were unsuitable. So the
fact that that list is nearly all unsuitable may be
a product of where we are in the scheme at that point in
time.
If we scroll up slightly:
"On our last [Working Group] call, you asked Post
Office to make clear which cases it considers are
suitable for mediation before the face-to-face meeting",
so you have been asked which are suitable and your
response is, in effect, all were unsuitable?
I suspect, at this point in time, these were the cases
that were pending decision on whether to go to
mediation. So by the end ~ if you can scroll up ever
146
attached for an example. This is building in
a presumption that the applicant is correct and that
[the Post Office] has to disprove the position, even
where the applicant has put forward no corroborating
evidence. This will lead to [the Post Office] losing
a lot of battles. I think this may be a point to raise
with [Second Sight] on our next call as it's not within
their gift to apply an evidential presumption in favour
of the applicants. If anything, the presumption should
go in [the Post Office's] favour given that (i) we are
notionally the defendant and (ii) no one has yet proved
a flaw in Horizon."
Again, real tensions in that period between the Post
Office and Second Sight, it seems?
Yes, there were tensions during this period. I would
just note that the way that Second Sight were asked to
produce their reports by the Working Group is they were
required to give an opinion where there was evidence and
then identify issues on which they didn't believe there
was sufficient evidence to offer an opinion. So the
concern here is they weren't using the structure that
was set by the Working Group.
They weren't, sorry?
Using the structure for their reports that was set by
the Working Group.
148
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I think Sir Anthony Hooper's evidence to the Inquiry was
that he wasn't particularly concerned by the paperwork
coming from Second Sight at this stage. Would you take
a different view?
I didn't see Sir Anthony Hooper's evidence and,
I apologise, I'm not quite sure what the context was for
his comment.
Is your evidence that you personally had concerns about
Second Sight's paperwork as at October 2014?
I had concerns at that point about the quality of the
work product they were producing.
Can we please turn to POL00176599. 7 November 2014,
this is an email that the Inquiry has seen before, it's
Martin Smith to you and others. He says:
"From a criminal perspective, we would advise as
a general rule against the disclosure of any documents
from a criminal file which have not previously been
disclosed to the defendant during the course of the
original proceedings. To do otherwise may well enable
the defendant or Second Sight to attempt to criticise
the way in which the prosecution was conducted or how
the Prosecution Policy was applied. Clearly such
arguments in a public arena would be uncomfortable for
[the Post Office]."
Did that raise any concerns for you?
149
Second Sight had been appointed as independent
investigators, they'd made a request to the Post Office
for information, and you, a lawyer, on Post Office's
behalf, have gone thorough that and reached the view
that it's what you might calll a fishing expedition in
litigation, and are addressing there which ones should
and shouldn't be answered.
As I said earlier, the adversarial nature of it waxed
and waned over time. Here I'm expressing concern about
some of the questions but my understanding is, actually,
that a good number of those questions -- I can't
remember the exact amounts -- were actually answered.
We can have a look -- I can take you, if you'd like,
to -- I may be able to take you to that document perhaps
tomorrow morning. But is your approach here
particularly adversarial, given that Second Sight had
been appointed as independent investigators?
No, I don't think so I'm just advising Post Office on
what I think is the relevance of the questions and, if
you look at the last part there, it says, "My guess is
this is going to take quite a lot of work to answer all
these questions", and, as I recall, it was quite a lot
of work but a lot of the questions were answered.
Well, let's have a look at that. Can we look at
POL00021863, please. Same month, December 2014, I think
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A. My recollection is that we, WBD, on the WBD side,
looking at it from the scheme perspective, were keen to
use the material in those files because we thought it
helped explain the cases, and Martin and Cartwright King
were pushing back against it. I think ultimately that
question was taken up to the Working Group and
Sir Anthony gave some directions on how to proceed.
Can we please now look at POL00214323. 9 December 2014.
Second Sight have provided a list of questions that they
are seeking answers to. You can say there there's an
attachment, "Second Sight Questions for [the Post
Office". This is an email from you to Belinda Crowe
and others and you say as follows:
"There are some sensible questions in here but there
is also a massive fishing expedition for information
that does not address issues raised by applicants.
highlighted all the questions that I think are just
fishing for info in blue. There are also a number of
questions that are outside the scope of the scheme.
Most telling is the fact that there are only a handful
of questions about Horizon; nearly all the questions are
about accounting practices."
I think you've accepted already that the approach
that the Post Office was taking was adversarial in
nature. Is this an example of that because, of course,
150
‘ve
we're in 29 December now. If we can turn to page 3
please, Belinda Crowe emails, she says:
"Mark/Paul/Andy Parsons -- would you be able to
prepare the schedule of questions to which Post Office
is not prepared to respond and the reasons why ~- it
would be that some of the text I have included in the
letter is best placed in the schedule.”
So there's a letter that's being prepared to Second
Sight in relation to the questions they've asked. If we
scroll up, please. There's a response from Mark
Underwood, he says:
"Hi Belinda,
“As requested please find attached a list of
questions we are not providing answers to, and the
reasons why.
"Andy -- there is one question I have highlighted.
Did we actually your send out the response with regards
to suspense accounts as I am unsure?
"In total we are not providing answers to 41 of the
1110 questions posed (37%). Splits by reason in the
table below ..."
He there sets out the table. So I think your
evidence just before was that you did provide answers to
lots of the questions. 37 per cent of those questions
you weren't answering, 25 per cent because you
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considered them to be fishing. Why even use "fishing"
as an expression in relation to your independent
investigators?
This is Mark Underwood's assessment of those questions.
I know that this -- these actually went through
a two-stage process, so I think this is version 1 of the
answers and then there was a discussion with Second
Sight, I recall, where they clarified some of the
questions. There was a discussion with the Working
Group where the Working Group advised that some of the
questions were too wide and a version 2 was produced
with a lot more answers.
Would you accept that's quite a high percentage of
questions not being answered at that stage?
At that stage, yes.
If we scroll up, we can see your response. You say:
“I've tried to flesh out some of the 'reasons' so
that it doesn't look like we are just stonewalling.
also think there are a few questions that we may be
able to answer or at least fudge an answer. I think it
would be better to try and answer a question than just
refuse entirely wherever possible."
So were you trying to push the Post Office to at
least answer some more questions.
If possible. From memory, some of the questions were
153
follows
If we scroll down.
"As explained to Second Sight previously,
subpostmasters can challenge any cash loss or
transaction correction in their branch in relation to
ATMs. In many circumstances, the information needed to
determine the cause of any discrepancy is only held by
a subpostmaster. There will therefore have been
occasions when a transaction correction against
a subpostmaster has been challenged and reversed -- this
is however standard operating practice."
Can you assist us with who would have inserted that
suggested form of words? If we scroll out again we can
see the reference. In your email, you referred to "may
be able to answer or at least fudge an answer", and, if
we scroll up we can see it says, "Note: I think we could
fudge the answer to this as follows". Does it suggest
that that proposed answer is coming from you?
It may have been but I was only provided this document
a couple of days ago so I haven't had a chance to
consider it.
Is it likely, given that you've used the word "fudge" in
a covering email on the same date, that that is in fact
coming from you?
I think that's possible, yes.
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very wide to the point where they were -- you know, it
would require disproportionate effort and what I was
trying to encourage Post Office to do was at least try
to answer a question, even if they couldn't provide
a full answer.
You asked to see the questions and, I think, the table,
and I can actually bring that on to screen, that is
POL00021864. Is this what you had in mind?
No, I had in mind the actual final version of the
answers that were sent at the end of January.
Well, this is attached to that email that I've just
taken you to, where you've used the words "fudging
an answer" and we can see 4.6d, for example, the
question is, Second Sight are asking Post Office:
“Any instance in the last 3 years in which Post
Office initially determined that a cash loss was
attributed to a subpostmaster but where it was
subsequently found that the subpostmaster was not
responsible for the loss."
The reasons for not providing an answer is:
“Request general information on the occurrence of
certain events, without reference to it being raised by
the applicants."
Somebody has inserted there:
“Note: I think we could fudge the answer to this as
154
Taking that as an example, why is it that that would
have been something that couldn't be answered by the
Post Office in response to a request from Second Sight?
So my recollection is that Post Office was only given by
the Working Group a very short period of time to
respond. I think it might have been a month, I may have
that wrong. And if you look at that question, it says,
“Any instance in the last 3 years in which Post Office
initially determined that a cash loss was attributed to
a subpostmaster". That is a very large period of time
to cover across 10,000 branches. So my view is that
I don't think it would have been practical to be able to
get to the bottom of that answer within the time
available.
Why wouldn't that have been the response? Why did you
feel a need to fudge an answer to your independent
investigators when the explanation could well have been,
as you've just said, "That is not reasonably practicable
in the time"?
Well, I think the answer that's given there is trying to
assist them in -- to give them a steer as to why this
information may not be relevant or needed but I'd have
to see the final version of the document to decide where
we actually ended up with this.
Is "fudging” a steer or is "“fudging" fudging?
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No, I think we couldn't answer the question because
there wasn't enough time. I think the answer given
there, which I'm just reading again now, is an attempt
to try to give a steer as to what Post Office's position
was.
Isn't it, yet again, taking a particularly adversarial
approach to the independent investigators?
Again, I don't know what time this document was --
sorry, I lost the date, I think you said it was 2014.
My recollection is that, after this, there was a meeting
with Second Sight to discuss the questions that couldn't
be answered to try to reframe them, narrow them, recast
them, if needed, so that Post Office could then answer
them so, yeah I accept that, to an extent, this is
adversarial but it's also -- as I say it waxes and wanes
and then there's periods of cooperation as well.
When in your view did it wane?
Well, for example, sitting down with Second Sight and
talking through these questions and trying to get to
a mutual position on them.
Could we please turn to POL00150460. We're still in
December 2014, the very end, 31 December 2014, and there
has been the Westminster Hall debate and the Post Office
is formulating a response to a case related to Members
of Parliament's queries. You're emailed by Melanie
157
King for review and I don't recall Cartwright King
raising anything in those reports that caused them to
question the safety of a conviction.
I'm going to move to the termination, proposed
termination, of Second Sight. Can we please look at
POL00022352. We're now in February 2015, 5 February
2015. Patrick Bourke emails you and he says:
"Dear Andy
"We spoke briefly.
"I would be grateful if [Bond Dickinson] could
produce a short bit of advice on the manner of
implementation and consequences of a future decision to
terminate Second Sight's engagement.
"The advice needs to cover (but should not be
limited to if other matters occur) the nature and extent
of [the Post Office's] ability to control access to, and
uses of, all and any information it has provided [Second
Sight]; the duration and effectiveness of that control
in particular with regard to the Part II report they are
preparing; and the legal and practically effects of the
30-day notice period which the letter of engagement
provides for.
“lam also interested in the effects, in legal and
practical terms, of a termination given that the letter
of engagement tries to make it clear that, although they
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Corfield, who, if we scroll down slightly, is emailing
you and Angela van den Bogerd and others. She says:
"On the criminal cases the main message to land now
that [Post Office] investigations are completed is our
view that there is nothing that undermines the safety of
convictions (but legal routes have of course never been
closed to people). This will be unpalatable in the
extreme to some and any meetings will certainly be made
public, so we need to be in a position where we can
release supporting, non-case specific documentation to
counter inevitable allegations as much as possible."
So, "On the criminal cases the main message to land
now that the [Post Office] Investigations are completed
is our view that there is nothing that undermines the
safety of convictions"; what investigations did you
understand that to be referring to?
I think that's a reference to the investigations through
the mediation scheme.
Having been somebody involved in the Mediation Scheme,
quite heavily in this period, is it your view that the
result of that mediation taking place was sufficient for
the Post Office to form a view that there's nothing that
undermines the safety of convictions?
Every case in the scheme -- sorry, the investigation
reports for every case in the scheme went to Cartwright
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are engaged by us, they in fact work to the [Working
Group]. You can imagine the sorts of arguments which
might be made."
Now, this is very shortly after the Select Committee
appearance of Second Sight and Paula Vennells. It seems
from this email, were you aware, that it was the
intention Post Office from this point to terminate the
contract with Second Sight and not to have a Part Two
Report?
I -- either shortly before or shortly after this,
I think I was provided with a -- I can't remember if it
was a Board paper or steering group paper about the
termination of Second Sight. So I was aware that that
was the direction of travel that Post Office were
heading in.
Were you aware that one of the reasons why they wanted
to terminate Second Sight at that point was before the
Part Two Report could be completed?
The second version of the Part Two Report, the first
version had already been produced by this point.
I don't remember it about stopping the Part Two Report.
I remember the concern was more about ensuring that
Second Sight focused on completing their investigations
into individual cases before they focused on the Part
Two Report.
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Shall we look at the advice that you gave? That's
POL00006364. It has "Bond Dickinson" on the final page,
6 February 2015. Is this is an advice that you wrote?
Yes.
If we scroll down, please, there's a section on
"Contract Termination", so:
"The contract between [Post Office] and [Second
Sight] is governed by the Engagement Letter dated 1 July
2014 and a Side Letter ..."
If we scroll over the page, please, to Second
Sight's position during the notice period. Here you're
addressing the position of Second Sight during that
30-day notice period. You say as follows:
"Under the [engagement letter, Second Sight] is
required to continue providing the Services until the
end of the 30-day notice period and is entitled to be
paid for any work done.
"There is however no converse obligation on Post
Office to keep asking [Second Sight] to do work during
the notice period or at any other time.
"[Second Sight] may try to argue that they have
a right to continue to work during the 30-day notice
period. We consider that this argument would be
difficult for [Second Sight] to advance. First, the
terms of the [letter] simply do not provide for this.
161
a significant consideration in the disbanding of the
Working Group that the effect of that would be to stop
Second Sight from carrying out any further work?
This advice was from the legal perspective on that
decision and, from a legal perspective, if Post Office
wanted a clean exit, then it seemed to me that they
needed to disband the Working Group as well.
Had you had discussions with the Post Office, their
intention was to end Second Sight's work and to prevent
them from being provided with any other instructions by
the Working Group?
No, that wasn't my understanding. My understanding is
they wanted to bring to an end the current arrangement
and replace it with a new arrangement that could see
Second Sight complete their work. I can't now recall
whether that explicitly included Part Two or not.
Let's look at the disbanding of the Working Group.
Let's look at POL00021908. There was a draft paper that
was circulated for the Sparrow subcommittee. We see
that if we scroll over the page on page 2, Mark Davies
is sending a first draft of that paper.
We then have, on page 1, your views. ll just take
you to a few passages from this email:
"Belinda
"A few thoughts below on the Sparrow paper. In
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Second, effectively [Second Sight] would be arguing that
there was a minimum guaranteed volume of work due to
them when no such guarantee was ever given. Third,
[Second Sight] are paid on an hourly rate so their pay
is not conditional on the completion of any work.
"One complicating factor is that the Services
include [Second Sight] ‘assisting with any reasonable
requests made by the Working Group and/or Post Office’.
Although the Working Group has no legal standing to
enforce the [Engagement Letter], decisions of the
Working Group can nevertheless influence [Second
Sight]'s work. If during the notice period the Working
Group were to direct [Second Sight] to complete some
work (within the scope of the services), then [Second
Sight] would be entitled to complete this work and
expect payment.
"To avoid this situation, we would therefore
recommend that in tandem with the termination of [Second
Sight], the Working Group is also disbanded so that it
cannot give any directions to [Second Sight]. This will
then enable Post Office to direct [Second Sight] to
immediately cease all work."
You've given in your witness statement a number of
reasons why it was a sensible idea to terminate the
Working Group. But, looking at this now, is
162
general, I agree with the idea of disbanding the
[Working Group] as (i) it offers no real value and (ii)
it is the source of much of the criticism of [Post
Office Limited]. However, I can see some challenges
with the other two limbs of proposal.”
Then you go on to address those two limbs. First is
Second Sight's role. You say:
“If [Second Sight] are independently contracted by
applicants then I cannot see how [the Post Office] can
dictate [Second Sight's] scope of work."
So one of the proposals was to let applicants
themselves appoint Second Sight; is that correct?
Yes.
Your view was that that was not sensible because the
Post Office would lose control?
Yes. In particular, in terms of timing, because the
great difficulty to this point was that Second Sight
were a long way behind schedule.
If we scroll down, we can see a second suggestion:
mediating all non-criminal cases. You say as follows:
"Mediating all non-criminal cases of course means
mediating lots of hopeless cases. Mediating
unmeritorious cases raises applicants’ expectations
unfairly and may in fact create greater animosity and
complaints (certainly that was my experience from M002).
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My recommendation would be for [Post Office] to take
a tougher line and only we date meritorious cases (even
if the bar for this is set low)."
Just pausing there, wasn't that the very purpose of
the Working Group itself, to vet those applications to
work out which were meritorious so they could go
forward?
That's what I expected at the outset, however, through
a series of decisions of the Working Group during the
course of 2014, Sir Anthony Hooper decide to take
an approach which lowered the bar on whether cases
should go to mediation or not.
Did you disagree then with Sir Anthony Hooper's
approach?
I did disagree with that decision, yes.
Aren't you here, though, suggesting, imposing a bar,
albeit a low bar?
The distinction here is that the Working Group were
prepared to put cases through to mediation where the
subpostmaster had been convicted. That created
a problem for Post Office because it had been advised by
its criminal lawyers not to mediate with anyone with
a conviction and that tension, in my view, was probably
the root cause of the Working Group breaking down at the
end of 2014.
165
Scheme did a lot of good.
Do you think, reflecting on it, you personally should
have taken a less adversarial approach?
Towards Second Sight? Yes, with hindsight I wish --
I think there were some points where we were fair in
criticising Second Sight but there were somewhere we
were too adversarial.
I'm going to move on now to the topic of remote access.
I will I'll go thorough a few documents and then we'll
take our afternoon break but then I'll stick with remote
access for the rest of the day. It's possible I might
move on to one other topic before we finish for the day.
Could we start, please, with POL00031456. So we're
starting 1 February 2015, and there are discussions with
Melanie Corfield and Mark Underwood. If we scroll down
slightly -- actually, let's start on page 3. Melanie
Corfield emails Rodric Williams.
"What would be the circumstances for [Post Office]
adding a transaction (we did so once in 2010 using
functionality)? I know [very] rare, strict authority
but would we need to ever do this?"
If we scroll up to page 2, there's an email from
you, if we scroll up slightly more, and you respond to
say:
"Mel
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We saw earlier that email where -- I know you said it
was just a snapshot, but a very high number of cases had
been deemed unsuitable by the Post Office. How do you
get from a position where you are determining that
a large number are unsuitable to saying, "Actually,
we'll mediate all non-criminal cases"?
So, again, I think you have to be careful with that list
because I feel it may not be a -- I think it may be
a subset of subpostmasters. I recognise some of the
numbers on those lists and I think number of them were
subpostmasters with convictions, though I can't remember
all the names and the numbers now. So I wouldn't draw
anything from that list. I think this is a proposal
here to say Post Office should be looking to mediate
meritorious cases even if the bar is low.
Reflecting now on all those emails and just your
recollection of the mediation process; do you think that
the process itself was doomed fail?
No, I don't believe so. I think people went into it
with good faith. I think the breakdown of -- I think
the relationship with Second Sight could have been
better -- between Post Office and Second Sight. I think
that could have been more collaborative. I think that
would have required more compromise on both sides to
reach that stage. But I still think that the Mediation
166
"Sorry -- we've never got any clarity of this point.
The reality is that the use of the manual balancing
process is so rare that there is no protocol for its
use.”
If we scroll up, we see more correspondence on the
issue. Page 1, the middle of page 1, and you're still
involved in this email chain: Mark Underwood to Melanie
Corfield and you. Mark Underwood says:
“It comes back to Andy's point about the question
being wrong.
Access’ can mean view ...
"The question is can transactions be edited
remotely -- to which the answer is no.
"Once a transaction is in, it cannot be removed or
edited in any way -- all that can happen is for
additional transactions to be put in to correct
mistakes -- all of which are visible to the
[subpostmaster]."
Now, we know now that that is wrong:
"If PV and MD [that's Paula Vennells and Mark
Davies] are still confused -- I would just send them the
below extract from the paper as I think it makes it
quite clear what can and cannot be done.
"Alternatively, we treat any questions about [remote
access] with the contempt they deserve -- why on earth
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would [Post Office] have a secret bunker in Bracknell
accessing [subpostmasters] accounts?"
Then it sets out there the issue and the response.
If we scroll up, we see a response from Melanie
Corfield, and she says:
"At one time our line was simply that there is no
remote access but for most people I think that sounded
unlikely given that you have to have [full] support etc.
It has a different meaning for different people.
I completely agree re showing contempt about the
allegations on this subject! It's a prime example,
actually, of our rigour and investigating allegations
that are in the realms of fantasy
What was your view on receiving those emails?
It appears to me that Mark Underwood has set out
factually what we understood the position to be at that
time. Admittedly that was wrong. The language around,
"and treat with contempt", I think is probably too
strong.
Did you think that at the time or were those the kinds
of emails that you would receive on the topic of remote
access?
I think at the time, people thought it was a very
unlikely possibility that remote access was the actual
cause of losses in branches. And at this time, going
169
balancing transaction process that allows [Fujitsu] to
input new transactions rather than edit old
transactions. Nevertheless, this will be a red rag to
Second Sight."
Why would it be a red rag to Second Sight?
Because they were concerned about anything around remote
access.
The suggestion here being not just old transactions can
be edited but that new transactions can be input.
Correct.
Thereby adding some substance to the allegation of
remote access, potentially?
It would -- it adds substance to the question of whether
it was possible or not. I don't think that would change
the question of whether remote access was actually
a probative cause of losses in branches.
If we scroll up, please. Rodric Williams to you, he
says:
"This is consistent with our responses/statements
about remote access isn't it, ie you can add data/inject
a balancing transaction, and if done ‘it is possible to
identify any data that has not been input directly by
staff in the branch'?"
Your response is at the top:
"Not quite -- we say that transactions entered by
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through the Mediation Scheme, determining the cause of
a loss in the branch is the central, central question.
So people generally thought, including myself, that
remote access was never going to really move forward
these cases, through the scheme.
Can we please turn to POL00312743. The bottom of
page 1, over into page 2. March 2015:
"All
"We've been through the prosecution file for M056 --
Wylie. There will be further documents to disclose
including the attached witness statement by Gareth
Jenkins. At the top of page 3, Jenkins states:
I also note a comment being made about it being
[possible] to remotely access the system. It is true
that such access is possible; however in an analysis of
data audited by the system, it is possible to identify
any data that has not been input directly by staff in
the branch. Any such change to data is very rare and
would be authorised by Post Office Limited. As I have
not had an opportunity to examine data related to this
branch, I cannot categorically say that this has not
happen in this case, but would suggest it is highly
unlikely’.”
You say as follows, you say:
“I'm pretty certain that Jenkins is referring to the
170
[subpostmasters] cannot be edited but we don't go on to
say that [Fujitsu] can input new transactions in
exceptional circumstances. This information would
therefore be entirely new news to [Second Sight]."
Were you, by this stage, quite concerned about the
information that had, so far, been disclosed about
remote access?
Yes. So when I first found out about the ability to
inject balancing transactions, was back in 2014. I'd
advised Post Office that they should give that
information to Second Sight and it's a point of regret
for me that I didn't press them to do that much sooner
than now.
In response to this issue being raised in March 2015,
are you aware of that information then being disclosed
to Second Sight?
I think it was provided to them the next month.
Can we please look at WBON0001024. If we could start
please on the bottom of page 3, onto page 4. We're now
in 2016, July 2016. You are emailing counsel, Anthony
de Garr Robinson, and you say, over that page:
"Your comments on the [letter of response] ...”
So, at this stage, on the letter of response to the
Group Litigation; is that right?
Correct.
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"are understood and very [helpful]. We'll rework
the general structure of the letter and then come back
to you to discuss specific points.
"Off the back of yesterday's call, (I think) I now
have a better grasp of the central tenants [sic] of our
case. I've tried to capture these below just to see if
it matches your thinking."
Then it’s at 2 you address remote access. So:
"The branch accounting system (including the role of
Horizon within the accounting system) is built around
the principle that the postmasters approve every
transaction that goes into their accounts:
"a. They (or their assistants) enter all
transactions conducted in branch; and
"b. They (or their assistants) approve any
transactions originating from [Post Office] (such as
transaction corrections).”
In brackets it says as follows:
"Note -- the issue of remote access is critical
here -- my understanding is that [Post Office] will not
use a balancing transaction without postmaster consent
in which case this complies with the above principle but
we need Deloitte to confirm this. Absolutely.”
Are you able to assist in whose words those are? Is
that your email or is that somebody inputting into your
173
Then you go on to identify what the issue is:
"The immediate concern is that this means that [the
Post Office's] historic statements about not being able
to edit or delete transactions appear, at least on face
value, to have been materially incorrect. This
therefore may bring into play:
(i) Allegations of deceit in that the Post Office
has made false statements;
(i) A basis for unwinding the settled cases; and
(iii) The possibility for some claimants to extend
their limitation deadline ..."
If you scroll down, you say:
"Once we have a much clearer picture, we may wish to
seek Brian Altman's advice on whether this issue causes
any concerns for criminal law/disclosure perspective.
We may also need to give consideration to whether to
inform the [Criminal Cases Review Commission]."
So, first of all, this is presumably quite
a significant moment for you, having been involved in
the issue of transaction corrections for quite a number
of years now?
The issue of balancing transactions.
The issue of super-users?
Sorry, yes, well, we were -- by this point, we'd seen -—-
I'd been provided with copies of Deloitte's earlier
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email?
A. I can't tell.
Q. Certainly by this stage, the summer of 2016, you
recognised the critical nature of that remote access
point?
A. Yes.
Q. POL00029990. We have an email from yourself to Jane
MacLeod, Rodric Williams and others. It's further to
some Deloitte investigations:
"Before tomorrow's steering group meeting I wanted
to give you a heads-up on the ‘remote access’ issues ...
"Deloitte has identified that a small number of
super-users at [Fujitsu] have the ability to delete and
edit transactions from the branch database. The [branch
database] is the central server on which all branch
transactions are recorded before being passed to other
servers ... This access is subject to strict controls
and Deloittes current understanding is that it would not
be possible to delete or edit transactions without
leaving a footprint in the audit trail. They also
believe that (i) this type of access is not unusual and
(ii) the likelihood of someone actually making such
changes is extremely low. This super-user access is
a separate, yet more extensive, process to the balancing
transaction process we previously knew about.”
174
reports and the Swift Review which pulled this issue
‘out. So this is further investigations by Deloitte.
Q. You've identified there under "Issues", slightly further
up, some civil issues.
A. Mm-hm.
Q. But then you refer also to seeking Brian Altman's advice
and the Criminal Cases Review Commission potentially
having to inform them. Is this, again, an example
where, although you are not, as you've said many times,
a criminal law expert, you are touching upon matters
that affect the criminal law potential appeals?
A. Here, yes, because I also recall that, a year earlier,
we'd already got Brian's advice on the remote access
issues.
MR BLAKE: Thank you.
Sir, I will be continuing with more questions on
remote access but perhaps that is an appropriate time to
take our mid-afternoon break.
SIR WYN WILLIAMS: Yes, by all means.
MR BLAKE: If we could come back at 3.35.
‘SIR WYN WILLIAMS: Certainly.
MR BLAKE: Thank you very much.
(3.18 pm)
(A short break)
(3.35 am)
176
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MR BLAKE: Thank you. Can we please turn to POL00245978,
pPrPoPro
The Post Office Horizon IT Inquiry
please, the bottom of the first page into the second
page, please. We're now on 27 November 2016 and you
have drafted a letter to Freeths in response to their
last substantive letter and you say as follows:
"The majority of this letter addresses legal and
procedural points. The key substantive area is
section 9 on remote access ...
"Following feedback from Deloitte, we cannot
definitively say that [the Post Office] (as distinct
from [Fujitsu]) never had the ability to change Horizon
data because Deloitte and the current staff at [Fujitsu]
just don't have enough knowledge of Old Horizon to
confirm this. This was a point made in an early draft
but it has now been removed.
"We have (I hope) now found a formulation of words
that avoids having to overtly throw [Fujitsu] to the
wolves and avoids any risk of waiving privilege in any
documents, but still gives us a fair story to tell."
What did you mean there by throwing Fujitsu to the
wolves?
I think this letter is addressing not just remote access
but the statements that Post Office had made
historically about remote access and the view was that
a lot of the previous incorrect statements about remote
177
securing the support of the right people internally
before issuing.
"As I'm the lucky man with the responsibility for
this as the [steering group] Chair, I must ask that we
get this properly reviewed by Mark Davies and also
Angela who I don't think are on this list. In
particular we need a full assessment and media plan
based on the worst case consequences in place before
sending."
Can you assist us with the position within the Post
Office, the concern at that time, regarding the letter
that was going to be sent to Freeths?
If it's the letter I'm thinking of, it was making
concessions that Post Office had previously made
incorrect statements about remote access, and that was
the concern.
There's reference here to Mark Davies.
Mm-hm.
Was he somebody you knew?
I knew of him. He was the Communications Director.
How involved was he in these kinds of issues, from what
you saw?
He would occasionally get involved in some of the legal
issues that were coming up in the scheme.
Is it a fair reading of this correspondence that there
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access were because that Fujitsu had given us incorrect
information or had given incorrect information to Post
Office.
Was that your view, was that the view of the Post
Office, or was it both?
Both.
You say:
"We have also toned down the admissions of making
incorrect statements, though they are still there.
I hope this might make it easier to get this letter
cleared through [the Group Executive] and [Fujitsu].”
So it seems Fujitsu are clearing the form of words
that go to Freeths; is that correct?
Where we were writing letters on technical issues then
that type of language would go past Fujitsu to get their
confirmation that they thought it was accurate.
If we scroll up, please, we have a response, from Rob
Houghton. He says:
"I personally think we overdo the response on access
and I've suggested some changes.”
If we scroll up again there is a response from
Thomas Moran, also of Post Office. He says:
"My overall conclusion is that could very well have
serious implications on the proceedings and we
absolutely have to make sure we are briefing and
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was real concern within the business at this stage about
this admission?
Yes, there was real concern about making this admission.
Could we, please, turn to POL00415440. This is actually
the day before that final email in the chain but it all
relates to the same issue, the same letter. It's from
you to counsel and you say:
"Rod has gone through the remote access section.
The content is broadly the same. He has reordered the
structure (which I like a lot) and toned down the 'mea
culpa’ (but I think this still works)."
Was that something the Post Office was doing, toning
down the mea culpa?
My recollection at this time is this letter does clearly
state that Post Office made incorrect statements about
remote access. There was some debate about the language
that was used then to describe that situation but
I don't recall that there was any real debate about the
direction the letter needed to go in.
If we look at POL00246005, at the bottom of that page.
The bottom of the page, please, this is 28 November:
"Please find attached the updated ‘remote access’
wording. The general direction of your comments was to
be less apologetic in on to and less repetitive, both of
which we've tried to accommodate in the attached.
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"The key issue is how far we want to go in accepting
that incorrect statements have been made in the past.
I believe that some of the drafting/tone changes are
coming out of us not having a settled view on this
issue", and you suggest a call.
So you say there the general direction of your
comments was to be less apologetic. Where in particular
was that coming from, in your view?
I can't now recall. We'd have sought comments on that
drafting from probably the people on this email chain.
Moving in to 2017 now. Could we turn to POL00249553.
We're now on to the drafting of the defence. So the
admission has been made to Freeths in November 2016.
We're now on to the defence, in the summer of 2017. You
are sending around the draft defence from counsel. If
we scroll down, paragraph 2, it says:
"Paragraph 50(2) -- do we say that POL previously
relied on incorrect statements from [Fujitsu] in
relation to remote access? This is basically dropping
[Fujitsu] in it.”
Same point, I think, as before, really. It seems as
though your view at that point was that Fujitsu were at
fault or were to blame in some way, or that it was
suggestive of that in the draft defence.
felt that Fujitsu were primarily responsible, not.
181
What is your view, though? We're here, we're years.
later now, we're in 2017, we're still debating on how
it's going to be phrased, the remote access issue. It's
clearly an important issue to the business. You've
placed a lot of blame with Fujitsu but is it your view
that the blame only lies with Fujitsu or that there was
a failure at the Post Office end to research the problem
properly?
My view is it primarily sat with Fujitsu. I think there
may -- there's probably some underlying problem with
Post Office not understanding the Horizon system in
enough detail across its organisation and I also, to
some degree, accept an accountability on my part,
because I feel I should have pushed harder on this issue
during the scheme.
Could we please turn to POL00249919. We're still in
July 2017 and you send an email to counsel:
"A quick note so that you're in the loop on my
meetings with [the Post Office] over the last few days
"Both the Postmaster Litigation Steering Group and
the Group Executive are comfortable with the defence [by
this stage]."
You say:
"I've briefed both the [Postmaster Litigation
183
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solely responsible, but primarily responsible, and there
was a -- I recall there was some debate around exactly
how we put that point in the draft defence.
Could we turn to WBON0000496, please. From Anthony
de Garr Robinson, you're copied in here, 10 July 2017.
Another version of the draft defence is circulated. If
we have a look at paragraph 60, he says:
the more I think about it, the more I think the
whole of paragraph 60 other than the first two sentences
ought to be deleted."
There's reference to mediation, et cetera, in there
that he doesn't want included. It's the final line or
final sentence there, he says:
"This seems to give us no excuse for not having
researched the problem properly before we said remote
alteration was not possible.”
Where do you consider the blame lies for
insufficient research? It seems as though his view
there was "us", being the Post Office, rather than
Fujitsu. Where do you think the blame lies for not
having researched the problem properly?
I don't -- I'm not sure whether Tony is using the word
"us" to mean Post Office or Fujitsu, or the collective
side of the case that was the Post Office side of the
case -- sorry, can you repeat the question?
182
Steering Group] and [the Group Executive] on what I saw
as the key risk areas as follows."
Then (2) is "Horizon integrity/remote access":
“Much more comfortable now we have Deloitte's work.
Deloitte's view is that it is unlikely that data
integrity/remote access is the true cause of problems.
"[The Post Office] has previously made false
statements and we admit this. Deny that they were known
to be false when made."
Then you say this:
"Both [the steering group and the Group Executive]
are very uncomfortable about this but understand the
tactical reasons for this approach.”
Can you assist us with what you meant there?
I recall that senior management at Post Office were
uncomfortable with making an admission that the previous
statements had been incorrect.
Who do you have in mind there?
I don't -- I can't place it to an individual because
I would have been, at that time, I think, getting a lot
of the feedback indirectly via the Legal Team and
I can't now recall these calls or meetings I had with
the GE at that time.
But the message that was coming to you from the Legal
Team is that the steering group and Group Executive were
184
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very uncomfortable about that?
Yes, and, actually, I can recall speaking to the
steering group about it and getting that sense directly
from them, as well.
"Much discussion about media comments and managing bad
publicity."
Do we understand, looking at all these documents
that we've been looking at this afternoon in relation to
remote access, that you were personally very involved in
the remote access issue from the legal side?
If you're talking about -- which period of time are you
talking about?
The documents we've been looking at, so let's say
2016/2017 period?
Yes.
There was a lot of focus on the wording --
(The witness nodded)
-- a lot of care was taken over how that was presented;
do you agree with that?
Correct.
It was a significant issue for the business as a whole,
the Post Office?
Err --
The admission?
I couldn't comment as to what they thought about it as
185
I think it's the person who has at least raised the
issue:
"_. and he has sent me the email chain below by way
of further background."
Ah, so, in fact, Sree is from the Post Office, he is
the Lead Branch Availability Manager, so he has raised
it with your firm:
“In summary, Post Office have exhausted all other
ways of cancelling this {transaction correction] and
I agree that there is no alternative but for [Fujitsu]
to manually remove it.
"Some key points:
"The [transaction correction] relates to a redundant
product that this branch never sold -- Post Office
reinstated the product and gave the branch permission to
sell it, but it was not possible for the branch to
accept the [transaction correction];
"Post Office cannot issue another [transaction
correction] to net the first one off for the same reason
"The [transaction correction] was issued due to
human error rather than a technical fault.”
Just pausing there, a transaction correction has
been issued in relation to this branch:
"The branch is a McColl's branch, so it's less
187
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a wider business issue. I can tell you they thought it
was important within the context of the litigation.
‘As we've seen, a lot of toing and froing and care taken
over the issue of remote access, in terms of how it
would affect the litigation.
Yes.
Could we please turn to POL00254632, please. Now, this
is a chain of emails. I appreciate that it's a document
you will only have seen this morning but I'd like your
assistance on it. Let's start on page 4, if we may. If
we scroll down, please -- actually, if we go to page 6,
just to have a look at how this issue comes in. There's
somebody from Information Services called Eleanor
Bradley, on page 6, if we scroll up, please. Thank you.
It's a discussion about an issue that has been
raised in a particular post office. If we please turn
to page 4, and the email from Jonathan Gribben to you.
So Jonathan Gribben was a Managing Associate in your
firm; is that correct?
Correct.
I'd like to just read this email. He says:
"Andy,
"I have spoken to Sree ..."
Now, was Sree the postmaster, do you recall?
I don't know.
186
likely that the claimants in the [Group Litigation] will
become aware of the issue and get the wrong end of the
stick; and
“In Sree's view the real risk to Post Office is not
fixing the issue -- as it's preventing the branch from
completing its trading period the branch may have been
incurring losses and in the circumstances Post Office
likely to have to pick those losses up.
"Are you happy for me to give Sree the green light
to have [Fujitsu] remove the [transaction correction]?”
So there has been an issue in a branch, it's
a McColl's branch, I think that's a chain branch, and it
seems as though they are holding off asking Fujitsu to
remove the transaction correction because of the ongoing
litigation and the issue of remote access; is that
right?
Yes, that appears what that's saying.
If we scroll up, we have your response, and you say:
"Can they not settle the [transaction correction]
centrally and then wipe it off the postmaster's
account?"
Were you, at this point, qualified to be making
suggestions as to how to correct an error in a branch's
accounts?
I knew enough about transaction corrections that there
188
(47) Pages 185 - 188
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were a couple of ways they could be processed through
the system. Where it refers to a "postmaster's account”
there, that doesn't mean the account on Horizon; that
means the account at FSC.
Why are you getting involved in the minutiae of
a postmaster's account?
Because it appears from the email below -- and I have to
say, I don't recall this email and, as you said earlier,
I only was passed it this morning -- it appears from the
email below that the solution being proposed is for
Fujitsu to manually delete or remove some data. That's
a version of remote access, it appears, and that's
a very key issue in the litigation.
If we scroll up, we see Angela van den Bogerd. She
says:
"No. I asked Sree last night when he rang me. The
issue is that the branch cannot process the [transaction
correction] at all.”
If we scroll up, we have your response, and you say
this:
"All,
"I think we (the legal team) need to take charge of
this process. Whatever documents are produced are
likely to be disclosable and I would like as far as
possible for this to be covered by privilege or have
189
Litigation". Just as, in the very early years, you were
advising in respect of, for example, the notification to
the insurer, "Let's not write that down; let's deal with
it, cover it in privilege as far as we can"?
I think in the context here and as I've said a number of
times, I think all of these decisions are context
specific. We are in the middle of a large piece of
litigation, an issue has arisen that is related to one
of the key issues in that litigation. I think it's
appropriate for any organisation to avail itself of
legal privilege to investigate that issue. To be clear,
that is not to say the issue wouldn't be brought to
light. I think it's possible for an organisation to
investigate something under privilege and then to make
decisions later, when it has the full facts, as to how
that then gets disclosed through the litigation process.
But here we have, "Hold off making that correction to
a branch, unrelated branch, because of the impact on the
Group Litigation". Do you think that was an appropriate
approach to take?
I do think that was an appropriate approach to take.
Does it make any difference for you that the Post Office
is owned by the Government, by the taxpayer, in how that
kind of litigation is conducted?
I still think Post Office was entitled to avail itself
191
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controlled their content.
"1. Asa first step, I would like Sree to copy all
emails on this topic (past and future) to Jonny."
So Jonny is a lawyer, is he?
Correct.
"Jonny, please then keep this somewhere separate and
safe. He should then be instructed to take no further
action for now.
"Second, I would like to escalate this to Pete and
Torstein at [Fujitsu] so that they can produce for us
a full (and privileged) note on what has happened and
why there is no alternative but to editing the data.
"Third, we can then make a decision on how to
proceed in light of the full facts.
"I understand that this is going to cause
‘operational problems and risks in this branch, but if
not handled properly this could be disastrous for the
Group Litigation.”
Doesn't this take us back to where we began today at
the very beginning; that your advice to the Post Office
is "Let's blanket this in privilege"? This is
a technical issue with a branch, not a claimant's
branch, a random branch that is affected that needs
a correction and your advice is, "Let's cover this in
privilege because it could be disastrous for the Group
190
of legal privilege.
Final document I'll take you to today, it's POL00276195.
It's an email from yourself to Ben Foat and Rodric
Williams in June 2019, and you're explaining to Ben Foat
about some of the history of the litigation and why
an overall advice had not been obtained. I'll read the
email. It says:
"The concern at the outset was that any early
settlement would be seen as conceding the [claimants']
arguments on the [subpostmaster] contracts and Horizon.
This would then possibly open up the floodgates to more
claims, so the plan was for Post Office to try to secure
some positive decisions in its favour before breaching
the topic of settlement.
"The strategy was to contest the Common Issues
trial, because based on the advice from Counsel, Post
Office should win on most points. When the Common
Issues expected to be resolved in [the Post Office's]
favour, either the [claimants'] funding would collapse
or they might walk away for a modest settlement that,
when viewed against a positive Common Issues judgment,
would not set a dangerous precedent. With this in mind,
before the [Common Issues] judgment was handed down we
had already agreed a mediator with Freeths and had begun
planning for settlement discussions.
192
(48) Pages 189 - 192
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"Further, Post Office had Deloitte review the
Horizon system out at the outset of the litigation and
they advised that Horizon was robust and extremely
unlikely to be the cause of shortfalls in branches.
This therefore gave us a back-up plan in case [the]
resolution didn't come immediately in the wake of
a Common Issues judgment. Deloitte gave us a degree of
confidence in winning the Horizon trial, and that might
then cause the [Claimants'] funding to collapse or
a modest settlement would be possible.
“If this didn't work, then the next step was to
‘thin the herd’. By this we meant identifying subgroups
of Claimants whose claims could be defeated on
a technicality or legal point. For example, trying to
strike out all of the time-barred claims. By ‘thinning
the herd’ you undermine the economics of the group.
Less claimants means less damages which makes the
funder's return on investment lower to the point where
they would prefer to settle rather than invest more
money."
It's this final substantive paragraph that I'd like
to focus on. You say:
"The strategy was never to seek an outright win
through the Court process, for that would mean
ultimately defending 500+ individual claims in 500+
193
if you look at the balance of the advice we gave on
disclosure to Post Office, it was actually to err on the
side of giving more disclosure and being generous with
disclosure.
MR BLAKE: Sir, that might be an appropriate moment to break
for the day.
SIR WYN WILLIAMS: Yes.
MR BLAKE: I have, at most, one hour left, and then we have
questioning from Core Participants, which shouldn't be
more than around an hour and a half, at most two hours.
So we have plenty of time tomorrow.
SIR WYN WILLIAMS: That's fine. I'd be grateful, Mr Blake,
if you'd just send me a rough breakdown of what we
expect with the Core Participants, so that I am au fait
of what's likely to occur, if you would?
MR BLAKE: Absolutely.
SIR WYN WILLIAMS: But yes, let's call it a day for today,
and we will resume again at 9.45 tomorrow.
MR BLAKE: Thank you very much, sir.
(4.03 pm)
(The hearing adjourned until 9.45 am the following day)
195
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separate trials (because the cases turn on their own
facts and the utility of dealing with them as a group
gradually erodes as more ‘group issues’ are resolved and
you are left with individual issues). Even if Post
Office's legal case was perfect, securing a full
resolution through the Courts would take years and be
massively disproportionately expensive. Hence, the
above plan to build leverage and air cover through the
Court process to force a settlement or collapse of the
litigation."
Does that explain the approach that you took to
disclosure throughout these years, that you would never
see a final trial, so no one would ultimately look under
the various rocks that had been placed over these pieces
of information?
No, I don't ever recall thinking like that.
Was it a strategy to delay disclosure of important
documents, just like we saw in relation to that Amy
Prime email that you inputted into: delay, delay, delay
disclosure until the moment at which you're becoming
criticised and then you can provide it and, if that
strategy worked, you would never have to provide certain
information because the plan was never to hear the full
trial until the end?
No. I think you've referred to one outlier email and,
194
INDEX
ANDREW PAUL PARSONS (affirmed) ....
Questioned by MR BLAKE ....
196
(49) Pages 193 - 196
MR BLAKE: [31] 1/3
1/5 1/10 50/9 50/13
50/15 50/19 55/6 76/4
76/8 76/11 81/8 94/2
94/6 107/1 107/5
107/8 107/12 131/12
131/15 131/18 131/22
131/24 176/15 176/20
176/22 177/1 195/5
195/8 195/16 195/19
SIR WYN WILLIAMS:
[29] 1/4 1/7 50/11
50/14 55/1 55/5 75/5
75/12 75/14 75/20
75/23 76/7 76/9 80/8
80/17 80/23 80/25
81/7 94/5 107/4 107/7I*
131/14 131/16 131/23)
176/19 176/21 195/7
195/12 195/17
43 [1] 121/10
“44 [1] 147/4
‘Access’ [1] 168/11
‘as [1] 83/10
‘assisting [1] 162/7
‘bug’ [1] 29/8
"Can [1] 73/8
‘cart [1] 125/16
‘CCRC’ [1] 30/3
‘deliberate [1] 111/22!
"Don't [4] 143/17
‘existing [1] 6/17
‘fundamentally [1]
86/13
"Gareth [1] 35/25
"group [1] 194/3
"He [1] 31/7
"Helen [1] 94/23
"Horizon [1] 71/20
IE] 170/13
‘Lalso [1] 170/13
‘If [3] 40/17 40/19
142/21
‘in [1] 89/10
‘in-tray' [1] 89/10
‘inappropriate [2]
110/20 113/14
‘issue’ [1] 10/24
‘issues’ [1] 61/20
‘it [2] 114/5 171/21
"known [1] 125/14
‘Lessons [1] 108/7
"Mark [1] 72/2
‘mea [1] 180/10
"No [1] 143/18
‘one [1] 139/12
‘one-sided’ [1]
139/12
‘Please [1] 72/3
‘problem’ [1] 10/23
‘produced’ [4] 46/18
46/20 46/21 47/11
‘production’ [1]
46/22
‘reasons’ [1] 153/17
‘remote [2] 174/11
180/22
's [1] 162/12
‘safety [1] 57/16
"Should [1] 116/23
"system [1] 6/13
‘thin [1] 193/12
‘think [1] 57/13
‘thinning [1] 193/15
to [1] 83/12
‘where [1] 110/25
“[A) 11713
1
1 April [1] 52/22
1 February [1]
167/14
1 January [1] 76/24
1 July [2] 25/14
161/8
1,172 [1] 2/1
1.15 [1] 131/19
1.30 [2] 107/5 107/7
10 July [1] 182/5
10,000 [1] 156/11
10.56 [1] 50/16
105 [2] 46/16 47/16
11 [2] 83/21 84/13
11 August [1] 141/2
11,000 [1] 52/10
11.05 [2] 50/13 50/14
11.06 [1] 50/18
1110 [1] 152/20
117 [1] 49/7
12 [1] 23/7
12 July [2] 132/2
134/14
12 June [1] 3/21
12 March [1] 65/20
12 months [2] 22/15
23/16
12.28 [1] 107/9
12.40 [2] 107/3
107/11
12.47 [1] 89/8
13 [1] 35/22
13 June 2024 [1] 1/1
13 March [1] 138/14
14 [6] 8/1 8/1 17/17
29/1 35/3 93/6
14,000 [5] 127/10
127/12 127/20 128/1
128/19
15 [2] 35/13 130/11
15 July [1] 29/22
150 [1] 147/18
16 July [3] 29/25
30/18 30/19
16 October [1] 145/3
16th [1] 33/16
47 [1] 146/1
47 April [1] 1/14
47 July [1] 34/23
18 [2] 2/1 141/24
182 [1] 1041/4
19 July [2] 38/7
45/13
1998 [1] 116/14
2
2 August [2] 40/24
55/7
2 September [1]
107/15
2 unexplained [1]
14/1
2 years [1] 26/15
2.14 [1] 131/21
2.15 [3] 131/15
131/16 131/17
20 August [2] 61/12
62/3
2000 [1] 49/12
2006 [1] 2/12
2007 [1] 27/21
2008 [1] 2/14
2010 [3] 15/15 76/24
167/19
2011 [2] 22/20 23/15
2012 [2] 2/17 52/22
2013 [54] 3/5 3/21
4/11 6/4 7/1 13/15
19/1 19/23 23/19
23/19 24/23 25/5
25/14 25/14 28/9
28/19 29/18 29/22
29/25 34/23 37/13
38/7 40/24 42/14 44/4
44/13 44/18 45/9
45/13 50/20 53/15
54/22 61/2 61/12
62/19 62/20 63/3
65/17 81/3 86/20 91/5)
93/17 104/16 106/8
107/15 110/1 110/3
116/23 121/6 123/9
131/5 132/2 135/12
136/23
2014 [29] 65/20
71/15 76/14 76/15
78/1 80/4 80/19 81/2
82/16 91/4 104/23
138/14 141/2 143/24
145/3 146/9 147/8
147/12 149/9 149/12
150/8 151/25 157/9
157/22 157/22 161/9
165/10 165/25 172/9
2015 [7] 113/18
159/6 159/7 161/3
167/14 170/7 172/14
2016 [10] 2/19
115/19 121/6 125/18
125/20 172/20 172/20}
174/3 177/3 181/13
2016/2017 [1] 185/14
2017 [6] 181/11
181/14 182/5 183/2
183/17 185/14
2019 [5] 48/4 48/20
126/14 129/23 192/4
2024 [2] 1/1 1/14
21 [4] 146/2
23 July [2] 50/20
51/19
235 [2] 118/20
118/20
24 [3] 49/6 49/6
57/17
24 July [4] 42/14
25 [3] 130/12 130/14
152/25
25 October [1] 85/13
27 June [2] 19/1
19/23
27 November [1]
177/13
28 November [1]
180/21
29 [1] 146/2
29 December [1]
152/1
3
3 July [2] 7/1 7/9
3 years [2] 154/15
156/8
3.18 [1] 176/23
3.35 [2] 176/20
176/25
30-day [4] 159/21
161/13 161/16 161/22
31 December [1]
157/22
31 July [1] 40/9
31 October [2] 85/13
147/20
37 [2] 35/23 152/20
37 per cent [1]
152/24
38 [4] 36/3
4
4.03 [1] 195/20
4.2 [1] 147/25
4.6d [1] 154/13
404 [1] 122/8
41 [1] 152/19
411 [2] 118/21 122/8
412 [1] 118/22
413 [1] 118/23
46 [1] 83/16
5
5 August [1] 56/6
5 February [1] 159/6
5 October [1] 115/19
5-10 years [1] 26/10
50 [4] 181/17
500 [2] 193/25
193/25
557 [1] 1/18
557 pages [1] 1/16
6
6 February [1] 161/3
6-12 months [1]
108/16
6.10 [1] 29/4
60 [2] 182/7 182/9
62 [1] 28/25
64 [1] 46/16
7
7 November [1]
149/12
8
8 July [2] 28/19
29/19
8 October [1] 91/5
84 [4] 5/17
87 [1] 29/23
9 December [1]
150/8
9.45 [3] 1/2 195/18
195/21
93 [1] 127/5
99 [1] 125/11
A
abilities [1] 3/15
ability [4] 159/16
172/8 174/13 177/11
able [12] 51/25 53/7
63/2 88/24 120/18
151/14 152/3 153/20
155/15 156/12 173/24)
175/3
about [135] 7/16 10/6
12/10 12/18 12/19
12/23 13/3 13/11
13/15 14/25 19/9
21/20 23/1 25/6 25/9
25/11 26/20 26/24
27/16 27/25 28/9
28/10 28/13 28/17
29/7 31/20 37/22
38/22 39/10 39/18
39/20 41/23 44/8 45/5I
45/18 45/19 45/22
45/24 45/24 47/6
59/22 62/11 68/18
68/18 72/23 72/25
77/10 82/7 82/11
82/14 89/5 89/16 90/1
92/11 93/24 95/14
(60) MR BLAKE: - about
A
about... [79] 96/20
97/8 97/15 98/20
100/13 100/24 106/7
109/4 109/11 109/14
113/15 113/20 113/23)
114/18 114/19 121/17)
124/6 124/10 124/19
125/18 128/6 129/1
129/10 129/10 129/12)
129/24 130/11 130/12)
133/19 133/22 135/17
136/17 136/18 137/16}
137/25 138/4 140/17
142/4 142/9 143/19
147/18 149/8 149/10
150/21 150/22 151/9
160/12 160/21 160/22)
168/9 168/24 169/10
170/13 171/6 171/20
172/5 172/6 172/8
174/25 175/3 177/24
177/25 179/15 180/1
180/3 180/15 180/16
180/18 182/8 184/12
185/1 185/3 185/5
185/11 185/12 185/25
186/15 188/25 192/5
above [7] 42/19
70/13 88/4 113/12
122/24 173/22 194/8
absent [1] 26/11
absolutely [9] 82/2
91/24 92/16 112/24
123/11 125/5 173/23
178/25 195/16
accept [29] 7/24 16/8
17/24 18/15 43/23
44/25 53/18 54/1 58/2
59/22 60/9 60/11 61/8
74/2 74/24 75/1 80/4
80/15 98/4 98/9 113/8
114/19 128/12 135/19)
140/8 153/13 157/14
183/13 187/17
accepted [2] 114/11
150/23
accepting [2] 44/18
181/1
access [40] 159/16
167/8 167/11 168/25
169/7 169/22 169/24
170/4 170/14 170/15
171/7 171/12 171/15
171/20 172/7 173/8
173/19 174/4 174/17
174/21 174/23 176/13}
176/17 177/8 177/22
177/24 178/1 178/19
179/15 180/8 180/16
181/19 183/3 184/3
184/6 185/9 185/10
186/4 188/15 189/12
access’ [2] 174/11
180/22
accessing [1] 169/2
accommodate [1]
180/25
Accordingly [1]
36/11
account [11] 7/25
14/12 20/10 29/1
93/18 104/16 188/21
189/2 189/3 189/4
189/6
accountability [1]
183/13
accountants [2]
52/12 143/15
accounting [11]
11/11 25/7 27/25 79/7
109/4 111/19 111/25
126/13 150/22 173/9
173/10
accounts [11] 15/6
15/11 18/8 124/7
124/14 124/20 130/1
152/18 169/2 173/12
188/24
accuracy [2] 45/3
99/2
accurate [7] 38/25
47/3 50/1 77/11 82/4
98/23 178/16
accurately [2] 31/12
41/5
accused's [2] 71/7
77/20
acknowledged [1]
114/5
acknowledgement
[1] 119/23
across [7] 10/15
93/24 108/13 125/17
135/19 156/11 183/12)
act [9] 44/3 57/14
66/21 88/16 99/18
103/3 106/20 107/21
108/25
acted [1] 70/14
acting [7] 54/6 54/24
63/20 63/25 66/6
94/18 106/16
action [6] 34/4 119/6
121/2 121/15 123/6
190/8
actions [3] 2/22
37/25 107/23
activities [2] 83/13
108/13
activity [1] 108/10
acts [1] 115/12
actual [7] 26/3 26/18
26/22 27/6 65/2 154/9
169/24
actually [28] 7/22
19/9 24/5 45/6 54/12
55/1 65/17 67/2 76/6
89/7 125/5 138/15
147/15 151/10 151/12
152/17 153/5 154/7
156/24 166/5 167/16
169/12 171/15 174/22
180/4 185/2 186/11
195/2
add [7] 28/8 29/18
53/14 62/19 68/12
72/18 171/20
added [3] 14/7 14/7
76/2
adding [4] 68/1 119/4I
167/19 171/11
addition [2] 14/23
117/22
additional [3] 71/4
77/18 168/16
address [9] 42/12
76/6 85/14 94/2
102/11 132/18 150/16
164/6 173/8
addressed [5] 37/17
62/17 118/17 137/23
139/3
addresses [1] 177/6
addressing [6]
126/17 127/3 134/15
151/6 161/12 177/22
adds [1] 171/13
adjourned [1] 195/21
Adjournment [1]
131/20
administratively [1]
60/15
admission [9] 11/21
15/24 16/18 17/1
180/2 180/3 181/13
184/16 185/24
admissions [2] 16/15]
178/8
admit [1] 184/8
admitted [2] 111/19
111/20
admittedly [2] 112/25]
169/17
admitting [1] 11/9
adopt [1] 118/15
adopted [2] 86/12
140/8
advance [1] 161/24
advancing [1] 144/5
adversarial [12]
140/7 140/8 140/22
141/21 141/23 150/24
151/8 151/16 157/6
157/15 167/3 167/7
adverse [1] 127/15
advice [133] 12/11
29/21 30/5 30/11
30/23 32/6 32/18
32/25 33/9 33/10
33/22 33/23 34/10
34/16 34/17 34/20
34/22 34/24 34/25
35/1 35/12 37/7 39/5
39/13 40/1 40/2 40/3
40/15 40/24 41/8
41/12 41/21 42/7 44/4
44/13 44/23 44/25
44/25 45/9 45/12
45/14 49/22 54/7
54/25 58/8 60/17
60/22 64/22 64/24
65/2 66/8 66/15 66/18
66/21 67/2 67/5 67/10)
67/12 69/5 69/6 69/9
69/17 69/21 69/22
69/24 72/9 72/11
7A4I17 81/25 82/22
86/21 86/25 87/3
88/20 89/23 89/25
90/10 91/16 91/25
92/5 92/6 92/18 93/1
93/2 93/3 93/5 100/6
100/8 100/9 104/13
104/14 105/3 105/12
105/24 106/16 107/19}
107/25 108/7 109/19
110/3 111/16 112/2
112/4 112/6 112/9
112/10 112/20 112/21
113/2 113/3 113/9
113/9 114/17 115/8
121/23 125/8 127/18
127/23 134/19 143/10}
159/11 159/14 161/1
161/3 163/4 175/14
176/6 176/13 190/20
190/24 192/6 192/16
195/1
advise [12] 36/7
41/14 41/18 44/19
50/5 50/7 53/22 56/8
61/18 105/18 106/15
149/15
advised [10] 41/6
41/16 42/1 44/10
64/15 123/15 153/10
165/21 172/10 193/3
advising [31] 39/20
39/22 46/10 51/13
58/15 59/12 60/4 60/7,
62/4 64/12 64/17 66/4,
86/25 90/19 92/22
98/4 98/5 98/7 104/7
104/23 105/6 109/13
109/15 109/21 115/7
115/12 120/1 120/24
134/17 151/18 191/2
advisor [1] 143/1
affect [4] 126/12
130/1 176/11 186/5
affected [8] 8/3 9/12
21/14 21/25 22/5
77/23 126/12 190/23
affecting [2] 21/4
23/11
affirmed [2] 1/8
196/2
afraid [1] 131/10
after [9] 3/22 39/18
121/9 133/5 133/23
134/8 157/10 160/4
160/10
afternoon [4] 131/22
167/10 176/18 185/8
afterwards [1] 117/5
again [33] 11/12
13/18 16/9 21/23
24/13 40/21 48/16
53/12 64/1 64/3 66/11
72/17 88/14 91/4
103/24 111/20 112/23)
114/3 114/12 115/1
121/13 123/5 128/15
141/22 148/13 155/13}
157/3 157/6 157/8
166/7 176/8 178/21
195/18
against [12] 2/22
34/3 41/14 50/7 67/14
73/10 79/14 123/15
149/16 150/5 155/9
192/21
Agents [1] 13/25
ago [6] 40/22 62/25
63/2 113/6 143/5
155/20
agree [8] 30/23 41/1
41/17 48/9 164/1
169/10 185/19 187/10}
agreed [3] 78/16
133/3 192/24
Ah [1] 187/5
AIG [3] 43/21 43/23
44/1
aim [1] 52/12
air [1] 194/8
Alan [3] 49/4 95/1
134/15
Alan's [5] 134/21
135/13 135/24 136/7
136/16
albeit [1] 165/17
alerting [1] 14/2
Alice [3] 89/3 89/5
91/6
all [74] 2/5 5/1 10/15
28/14 31/13 32/2
35/24 37/15 38/19
39/22 49/10 49/11
50/11 58/17 61/16
62/1 64/19 70/7 70/18
76/8 78/8 80/17 88/12I
93/16 93/17 93/18
93/22 94/13 94/24
95/18 99/18 104/15
106/1 106/9 107/7
108/15 111/19 111/19)
114/21 117/16 123/3
(61) about... - all
A
all... [33] 124/10
130/13 135/10 137/25)
146/4 146/14 146/22
147/2 150/17 150/21
151/21 159/17 162/22)
164/20 164/21 166/6
166/12 166/16 168/15
168/17 170/8 173/13
174/15 175/18 176/19)
180/5 185/7 187/8
189/18 189/21 190/2
191/6 193/15
allegation [5] 26/2
26/15 110/20 113/14
171/11
allegations [6]
110/10 115/10 158/11
169/11 169/12 175/7
alleged [2] 26/12
27/10
Alliance [3] 9/10
134/24 137/14
allow [1] 108/16
allows [1] 171/1
almost [2] 93/15
135/16
along [4] 2/7 84/18
140/21 140/24
alongside [3] 1/25
23/2 144/6
already [18] 13/10
14/3 19/11 29/2 37/12)
88/14 117/7 123/9
128/3 128/5 128/6
128/14 128/18 146/11
150/23 160/20 176/13
192/24
also [51] 10/6 18/2
25/1 27/11 29/4 31/1
37/2 39/17 47/17
47/25 48/19 52/16
53/5 53/16 54/4 58/20
62/14 68/16 74/11
76/13 77/16 82/4
83/21 84/16 87/7 88/4
90/10 98/9 100/6
100/7 113/10 113/23
118/19 132/13 132/22
144/7 150/15 150/18
153/19 157/15 159/23}
162/19 170/13 174/20}
175/16 176/6 176/12
178/8 178/22 179/5
183/12
alteration [1] 182/16
alternative [4] 112/8
124/13 187/10 190/12)
Alternatively [1]
168/24
although [13] 11/24
16/2 28/10 74/8 76/22)
98/23 112/24 117/11
123/25 125/11 159/25)
162/9 176/9
Altman [30] 37/19
51/9 51/10 51/19 52/4
53/22 54/8 54/10
54/17 54/19 54/23
55/1 55/7 55/13 55/25)
58/19 59/7 61/6 61/18
61/23 62/20 63/4
83/21 84/17 85/11
86/10 86/19 88/8
88/16 116/17
Altman's [8] 57/24
59/11 59/13 62/12
64/13 86/2 175/14
176/6
always [2] 117/22
129/6
Alwen [1] 107/16
am [19] 1/2 8/13
13/24 29/18 30/6 30/7)
30/10 50/16 50/18
57/9 62/16 89/8 89/9
101/23 152/18 159/23)
176/25 195/14 195/21
ambiguous [1] 18/9
amend [1] 86/1
amend/complete [1]
86/1
amended [7] 20/13
58/19 71/21 75/15
78/7 78/13 81/3
amending [1] 62/5
amendment [2]
17/11 80/14
amendments [4]
10/15 10/17 13/22
17/12
amongst [4] 47/23
47/25 94/21 141/4
amount [1] 2/3
amounts [1] 151/12
amplify [1] 88/10
Amy [4] 115/19
115/20 119/2 194/18
analysis [2] 59/5
170/15
analyst [1] 5/25
Andrew [6] 1/6 1/8
1/11 38/14 38/19
196/2
Andy [25] 7/2 9/5
9/22 14/16 14/24
23/18 24/17 24/20
30/2 30/16 30/18
42/16 71/19 83/1
84/21 84/21 85/6
85/17 87/10 95/1
116/5 152/3 152/16
159/8 186/22
Andy's [1] 168/9
ANDY/BELINDA [1]
87/10
anecdotal [1] 26/4
Angela [3] 158/2
179/6 189/14
animosity [1] 164/24
annually [1] 24/2
another [11] 19/20
22/10 29/4 30/8 33/2
48/16 57/3 88/18
132/18 182/6 187/18
answer [28] 25/24
42/11 63/6 80/17
80/25 125/7 144/17
151/21 153/20 153/20
153/21 153/24 154/4
154/5 154/13 154/20
154/25 155/15 155/15}
155/17 155/18 156/13}
156/16 156/20 157/1
157/2 157/13 168/13
answered [7] 87/19
151/7 151/12 151/23
153/14 156/2 157/12
answering [2] 88/21
152/25
answers [18] 4/16
13/2 64/1 76/4 85/2
85/4 85/6 85/21 117/6
130/18 130/24 150/10}
152/14 152/19 152/23
153/7 153/12 154/10
antagonistic [2]
141/14 142/8
Anthony [10] 83/17
89/13 145/5 149/1
149/5 150/7 165/10
165/13 172/20 182/4
anticipate [1] 51/25
antithesis [1] 142/1
any [103] 6/11 8/20
8/21 8/23 9/7 10/6
10/21 14/11 14/21
17/19 17/21 20/8 22/6
23/6 23/22 25/21 26/2
27/1 32/14 34/7 36/13
38/3 41/10 52/13 53/6
56/14 56/19 57/19
60/17 66/12 70/19
73/20 75/5 78/12 79/9
81/13 86/8 86/14
91/16 92/6 92/18
93/13 93/24 97/5
98/13 103/4 105/7
106/20 107/19 108/23}
109/3 110/13 116/14
117/1 117/10 120/10
121/7 121/9 124/8
125/13 126/11 127/14
129/25 130/2 133/2
134/7 135/4 136/3
137/7 138/1 140/24
142/3 146/7 147/15
149/16 149/25 154/15}
155/4 155/7 156/8
158/8 159/17 161/17
161/20 162/5 162/7
162/20 163/3 163/10
168/1 168/15 168/24
170/17 170/18 171/22)
173/15 175/15 177/18}
177/18 180/18 191/10
191/22 192/8
anybody [3] 122/20
124/6 140/19
anyone [6] 25/2
91/18 92/13 103/4
143/17 165/22
anything [14] 6/23
8/25 34/11 41/10
45/19 49/1 61/25
91/16 115/16 140/24
148/9 159/2 166/13
171/16
anyway [1] 12/21
apologetic [2] 180/24
181/7
apologies [5] 16/14
17/8 46/3 112/23
122/14
apologise [3] 11/7
44/15 149/6
apologising [2] 11/8
16/24
apology [3] 16/11
16/13 16/17
Appeal [2] 57/13
57/14
appeals [2] 56/14
176/11
appear [2] 58/10
175/4
appearance [1]
160/5
appeared [1] 103/9
appears [13] 11/17
20/16 58/12 59/14
75/20 80/6 81/6 119/5
169/15 188/17 189/7
189/9 189/12
applicant [2] 148/2
148/4
applicant's [2]
137/10 147/25
applicants [12] 94/19]
104/10 110/17 142/15)
142/18 143/9 144/14
148/9 150/16 154/23
164/9 164/11
applicants' [1]
164/23
application [1]
137/11
applications [2]
83/16 165/5
applied [1] 149/22
apply [4] 68/5 70/4
103/4 148/8
appoint [1] 164/12
appointed [2] 151/1
151/17
appointing [1] 83/16
appreciate [6] 76/9
94/3 107/2 107/19
116/7 186/8
approach [31] 11/10
32/17 34/14 53/22
81/14 85/15 86/12
90/12 93/21 96/19
98/16 118/14 118/15
134/21 135/1 137/17
140/5 140/6 140/9
140/23 141/15 150/23)
151/15 157/7 165/11
165/14 167/3 184/13
191/20 191/21 194/11
approached [1]
140/11
appropriate [17]
16/17 50/9 56/24 57/2I
57/16 98/15 105/20
107/1 112/2 112/16
114/18 131/12 176/17)
191/10 191/19 191/21
195/5
approval [1] 119/3
approve [3] 41/4
173/11 173/15
approximate [1] 91/6
April [4] 1/14 3/5
4/10 52/22
arbitration [2] 132/12)
132/17
arbitrator [1] 132/15
ARC [1] 84/7
are [208]
area [3] 106/21 113/8
177/17
areas [4] 115/4 115/5
143/11 184/2
aren't [5] 44/14 45/16
98/8 105/2 165/16
arena [1] 149/23
argue [1] 161/21
arguing [1] 162/1
argument [5] 68/13
110/14 111/5 143/8
161/23
argument/dangerous
[1] 143/8
arguments [5]
110/22 111/6 149/23
160/2 192/10
arise [2] 39/19
128/25
arisen [2] 7/17 191/8
arises [1] 62/2
arising [3] 8/25 56/20
96/25
around [26] 22/14
22/20 42/13 63/8
73/21 76/14 76/15
80/3 80/4 80/19
103/11 107/21 113/7
119/10 125/22 126/9
(62) all... - around
A
around... [10] 129/3
130/21 144/1 147/11
169/17 171/6 173/10
181/15 182/2 195/10
ARQ [2] 4/22 5/2
arrangement [2]
163/13 163/14
arrangements [1]
84/8
arrive [2] 4/5 101/14
as [254]
Asa [1] 70/17
aside [2] 99/4 103/15
ask [10] 1/17 4/23
6/10 69/11 75/8 95/6
127/21 130/17 142/22)
179/4
asked [27] 4/13 4/16
13/3 30/4 32/22 36/12)
57/10 58/23 69/12
84/21 105/11 107/25
125/2 127/13 129/17
129/24 129/25 130/7
145/7 145/10 145/20
146/18 146/21 148/16)
152/9 154/6 189/16
asking [8] 44/16
88/23 129/19 138/16
139/22 154/14 161/19
188/13
asks [1] 61/22
aspects [1] 7/15
asserting [1] 74/2
assertion’ [1] 147/25
assess [1] 74/23
assessing [1] 127/4
assessment [2]
153/4 179/7
assist [10] 20/15
27/22 76/6 106/21
110/15 155/12 156/21
173/24 179/10 184/14}
assistance [1]
186/10
assistants [2] 173/13
173/15
assisted [2] 71/7
77N9
assisting [4] 6/6
21/10 62/5 64/6
associate [3] 2/17
3/8 186/18
associated [1] 5/24
assume [1] 138/9
assumed [2] 53/2
136/1
assumes [2] 135/1
136/19
assuming [1] 136/21
assured [1] 142/2
at [275]
at page 3 [1] 141/9
ATMs [1] 155/6
attach [1] 58/20
attached [24] 8/17
10/14 19/5 19/22
19/24 20/20 39/11
51/5 58/18 71/20 72/3)
75/1 78/6 79/5 100/18
125/10 126/24 127/2
148/1 152/13 154/11
170/11 180/22 180/25)
attaches [1] 7/4
attaching [2] 65/21
73/12
attachment [5] 17/11
76/5 76/11 81/18
150/11
attack [8] 28/4 99/10
103/20 110/12 113/1
114/10 139/23 140/6
attacked [1] 102/4
attacking [3] 111/9
113/1 114/3
attempt [4] 49/10
68/21 149/20 157/3
attempted [1] 144/4
attended [1] 54/20
attendee [1] 38/7
attendees [1] 142/24
attending [3] 38/8
38/9 143/23
attention [4] 80/13
100/19 104/17 117/18)
attested [1] 31/9
attract [4] 68/9 68/10
68/15 118/13
attracted [1] 132/15
attributed [7] 40/25
44/14 44/22 46/19
90/10 154/17 156/9
au [1] 195/14
audible [1] 144/17
audit [4] 31/11 85/20
139/8 174/20
audited [1] 170/16
August [9] 40/24
54/11 55/7 56/6 61/12
62/3 62/20 121/6
141/2
August 2013 [1]
121/6
Aujard [2] 65/19
71/12
author's [1] 101/6
authorised [1]
170/19
authority [3] 57/3
95/4 167/20
automated [1] 98/24
autumn [1] 89/11
avail [2] 191/10
191/25
Availability [1] 187/6
available [8] 5/12
38/23 39/8 40/19 47/8
49/23 98/25 156/14
avoid [3] 97/5 118/10
162/17
avoided [1] 125/15
avoids [2] 177/17
177/18
aware [37] 3/2 3/3
4/10 5/1 11/1 13/24
19/7 19/11 19/16 20/3}
20/22 24/10 24/15
26/2 27/3 32/6 32/10
32/11 33/4 33/8 35/9
37/12 52/10 59/16
63/12 64/4 73/9 75/9
82/5 91/2 125/21
142/3 160/6 160/13
160/16 172/15 188/2
away [2] 62/9 192/20
back [46] 6/11 15/22
24/13 28/6 29/15
29/16 37/21 42/11
45/7 51/17 54/13 63/1
63/21 64/1 65/5 65/13
69/14 71/16 72/17
81/8 82/23 89/23 92/8
104/14 106/1 106/4
106/8 110/1 114/16
128/2 128/13 129/22
129/23 130/10 131/15}
139/25 141/22 142/24
150/5 168/9 172/9
173/2 173/4 176/20
190/19 193/5
background [9] 9/23
51/23 53/21 84/16
87/7 98/18 122/9
124/25 187/4
background/technicaI
1 [1] 9/23
backgrounds [1]
72/12
bad [4] 42/24 43/16
90/3 185/5
badly [2] 135/7
136/11
Baker [2] 9/22 25/16
Baker/Andy [1] 9/22
balance [2] 67/23
195/1
balancing [7] 168/2
171/1 171/21 172/9
173/21 174/24 175/22
bankrupt [1] 120/20
banner [1] 69/24
bar [6] 94/1 165/3
165/11 165/16 165/17]
166/15
bare [2] 110/10
115/10
barred [1] 193/15
barrister [4] 30/9
33/1 59/19 60/2
based [8] 23/18 26/4
110/23 115/8 138/7
140/10 179/8 192/16
basic [3] 4/22 53/20
109/17
basically [1] 181/19
basis [6] 30/6 47/22
70/15 139/21 140/17
175/9
Bates [2] 49/4 134/15
battle [1] 1141/2
battles [1] 148/6
be [240]
be’ [1] 83/12
bear [1] 26/9
bearing [1] 130/16
became [8] 2/17 2/19
40/9 43/17 52/22
55/10 90/4 141/21
because [75] 7/16
8/2 12/14 12/18 12/22,
15/3 15/14 15/19
15/21 18/7 27/9 27/11
28/11 28/15 28/16
29/18 33/5 33/19 42/8)
44/15 44/21 45/11
50/6 52/3 60/14 60/17
65/16 66/12 66/19
67/21 69/20 76/5 88/9)
92/11 92/20 92/23
97/7 99/6 103/17
105/17 113/3 113/6
114/11 121/8 124/6
124/19 126/8 127/24
128/1 130/7 131/7
138/11 141/22 146/8
150/3 150/25 152/25
157/1 164/14 164/16
165/21 166/8 171/6
176/12 177/12 178/1
183/14 184/19 188/14)
189/7 190/25 191/18
192/16 194/1 194/23
become [8] 9/8 13/13)
44/21 45/25 46/6 61/1
68/19 188/2
becoming [4] 118/16
120/20 121/1 194/20
been [162] 4/17 9/12
10/3 10/11 13/8 13/9
13/10 14/11 15/13
16/7 16/21 16/21
16/23 17/2 17/16 18/5]
18/10 20/3 20/9 20/16}
22/4 22/14 24/11
25/22 26/22 27/4 27/9)
27/23 29/2 29/3 29/12
31/4 32/15 32/22
32/22 33/6 33/20
35/10 36/17 36/22
37/3 37/4 37/20 39/3
40/3 40/5 40/15 41/5
42/2 56/1 56/22 59/15
60/22 61/11 62/7
62/11 63/5 63/7 63/12
63/21 64/2 64/18
65/11 69/6 69/8 69/9
79/7 80/7 80/14 82/17)
84/13 84/25 85/3 86/3
86/9 87/25 89/11
89/17 90/15 90/22
90/24 93/16 93/19
93/22 96/10 96/11
96/12 96/16 96/23
96/24 97/16 99/9
99/19 103/5 103/20
106/19 107/25 109/11
109/12 111/12 111/21
116/9 117/7 119/6
119/15 121/3 122/1
122/2 126/10 128/3
128/5 128/14 134/15
134/16 140/3 143/2
143/13 145/20 146/21
147/2 147/4 147/5
149/17 151/1 151/17
155/8 155/10 155/19
156/2 156/6 156/12
156/15 156/17 157/23)
158/6 158/19 160/20
165/20 165/21 166/3
166/21 166/23 170/9
170/17 171/22 172/6
175/5 175/19 175/25
177/15 181/2 181/13
184/17 184/20 185/8
185/13 186/15 187/24)
188/6 188/11 192/6
194/14
before [34] 9/17 10/9
23/1 23/21 24/5 32/14I
32/16 48/14 75/5 76/4
82/21 85/19 89/10
94/2 97/12 125/16
130/14 145/9 146/20
149/13 152/23 160/10}
160/17 160/24 167/12)
174/10 174/16 179/2
179/8 180/5 181/21
182/15 192/13 192/23}
began [6] 2/11 3/22
122/7 147/10 147/11
190/19
beginning [6] 8/11
39/17 51/1 106/8
141/18 190/20
begins [3] 97/12
108/3 122/8
begun [1] 192/24
behalf [4] 17/4 29/11
53/17 151/4
behaved [1] 5/8
behaviour [1] 79/9
behind [3] 4/21 68/20
164/18
being [60] 13/10 17/3
18/21 31/20 34/10
37/17 39/6 40/11
(63) around... - being
B
being... [52] 51/24
51/25 54/18 57/2
57/10 58/4 63/9 64/10
66/9 68/20 73/25 74/1
75/6 75/16 78/13
78/23 80/16 85/12
86/9 87/13 92/14
100/19 103/16 105/25}
106/6 110/12 122/14
123/17 125/2 126/5
129/15 129/16 134/23
137/23 144/21 144/25}
146/5 152/8 153/14
154/22 163/10 168/10
170/13 170/13 171/8
172/14 172/15 174/16}
175/3 182/19 189/10
195/3
belief [4] 1/21 89/21
122/15 122/17
believe [32] 5/8
13/14 18/11 18/17
22/2 22/6 27/23 29/17
32/14 39/1 45/17
49/25 67/11 72/11
73/2 80/22 80/24
80/25 97/1 97/6 97/14
100/15 110/14 111/2
113/12 115/6 116/3
121/13 148/19 166/19}
174/21 181/3
BELINDA [8] 87/10
95/12 140/17 145/10
150/12 152/2 152/12
163/24
below [25] 85/4
87/10 97/3 97/11
108/1 108/6 110/8
112/8 116/6 116/9
116/11 117/22 117/24
126/20 136/16 137/2
138/19 145/18 152/21
163/25 168/22 173/6
187/3 189/7 189/10
Ben [8] 8/6 8/12 9/3
126/21 126/22 127/1
192/3 192/4
best [5] 1/20 75/19
105/20 117/18 152/7
better [4] 119/15
153/21 166/22 173/5
between [36] 11/22
15/5 15/10 15/25
22/11 27/1 32/8 32/19
32/23 41/2 41/8 59/6
64/21 65/1 67/16
67/17 67/22 76/18
83/5 97/18 97/22
98/24 104/8 109/12
113/9 115/3 132/21
133/15 134/3 134/11
137/3 139/6 143/24
148/13 161/7 166/22
beyond [2] 24/21
36/5
big [2] 21/25 129/8
bit [3] 72/9 75/6
159/11
bits [1] 40/13
BLAKE [5] 1/9 75/5
76/7 195/12 196/4
blame [6] 34/12
181/23 182/17 182/20)
183/5 183/6
bland [1] 42/22
blanket [2] 68/3
190/21
blanketing [1] 90/23
block [1] 92/14
blue [1] 150/18
blurs [1] 59/6
board [17] 42/25
57/10 58/24 66/5 66/5)
66/10 66/10 66/13
82/17 84/5 84/7 85/17
85/20 90/25 126/24
127/2 160/12
body [2] 41/11
127/24
Bogard [1] 124/15
Bogerd [2] 158/2
189/14
bold [1] 85/1
Bond [26] 2/8 2/12
2/21 3/9 8/8 8/13 26/5
26/7 55/2 55/4 55/10
55/13 55/19 57/23
57/25 67/6 69/9 72/21
74/10 74/16 79/20
127/4 127/18 141/6
159/10 161/2
borne [1] 28/2
both [20] 3/16 5/4
28/13 31/7 35/5 48/8
76/19 95/13 98/10
101/7 109/7 116/21
133/3 166/24 178/5
178/6 180/24 183/21
183/25 184/11
bottom [31] 5/21
7/13 8/6 19/2 22/11
25/15 29/25 42/14
49/6 50/21 54/14 55/6
57/5 65/15 82/25
84/23 84/25 99/7
102/23 103/18 107/14}
108/3 130/4 138/16
141/10 156/13 170/6
172/19 177/2 180/20
180/21
boundary [1] 59/6
Bourke [2] 147/21
159/7
box [1] 63/24
brackets [2] 101/25
173/18
Bracknell [1] 169/1
Bradley [1] 186/14
branch [55] 3/23 4/4
4/8 11/19 11/20 12/14
12/16 14/2 17/21 20/1
20/5 21/19 22/8 23/9
23/9 29/1 101/8
101/13 101/17 101/24
109/4 124/7 124/20
126/12 130/1 139/7
139/11 155/5 170/2
170/18 170/21 173/9
173/14 174/14 174/14
174/15 187/6 187/14
187/15 187/16 187/24
187/25 187/25 188/5
188/6 188/11 188/12
188/12 189/17 190/16
190/22 190/23 190/23}
191/18 191/18
branch’ [1] 171/23
branch's [5] 14/9
14/20 18/14 20/7
188/23
branches [14] 8/2
8/19 17/20 21/5 21/20
22/4 23/6 23/11 28/25
95/3 156/11 169/25
171/16 193/4
branches' [1] 72/6
breach [2] 36/10
36/19
breaching [1] 192/13
break [11] 50/10
50/17 94/3 107/3
107/10 147/10 147/11
167/10 176/18 176/24
195/5
breakdown [2]
166/20 195/13
breaking [1] 165/24
Brian [41] 37/19 51/9
51/10 51/19 52/4
53/22 54/8 54/10
54/12 54/17 54/19
54/23 57/24 58/12
58/19 59/7 59/11
59/13 59/23 59/25
60/14 61/18 61/23
62/11 62/20 63/4
63/22 64/1 64/13
64/19 83/21 84/17
85/11 86/2 86/18
86/24 88/8 88/16
116/17 175/14 176/6
Brian's [7] 54/24
55/19 58/25 59/9 63/8
87/3 176/13
brief [3] 8/12 86/21
88/23
briefed [4] 88/1
89/19 90/22 183/25
briefing [3] 87/20
141/4 178/25
briefly [5] 3/20 28/20
51/23 81/16 159/9
bring [6] 100/21
117/18 118/19 154/7
163/13 175/6
bringing [1] 53/22
broad [6] 4/10 28/10
78/20 111/4 121/4
122/3
broadcast [1] 110/4
broader [3] 18/22
44/9 120/4
broadest [1] 120/10
broadly [1] 180/9
broker [2] 42/17 72/1
brought [5] 37/19
100/19 104/17 116/24}
191/12
bug [18] 7/25 8/1
17/17 23/15 24/1
24/24 25/1 25/6 25/20)
26/3 26/13 26/18
26/22 27/6 29/4 29/5
93/18 104/16
bugs [20] 25/19
25/22 28/23 29/12
29/19 29/20 36/22
37/5 37/11 89/16
93/17 93/22 104/21
126/11 127/16 127/24}
128/8 128/10 130/1
130/22
build [2] 119/8 194/8
building [1] 148/1
built [1] 173/10
bullet [11] 10/17 12/2
13/7 15/22 15/23
22/16 36/15 37/1
61/24 65/9 144/21
Bullets [1] 126/20
bundle [1] 1/12
bundles [1] 2/1
bunker [1] 169/1
business [13] 8/17
11/1 21/3 21/6 52/8
91/23 97/9 97/16
125/10 180/1 183/4
185/21 186/1
but [172] 2/5 3/19 4/5]
6/9 6/15 6/21 8/20
9/10 11/8 13/9 15/22
17/2 18/2 21/20 24/21
25/1 27/23 28/18
30/20 32/12 33/7
34/12 36/9 36/22 37/9)
37/13 37/16 38/9
42/11 44/7 44/22 45/9)
45/23 46/1 46/10
47/25 48/4 52/16
53/11 56/2 57/19
57/24 59/14 59/17
59/22 59/23 60/21
61/8 62/15 62/24 63/7)
64/3 64/8 64/17 64/18
65/14 65/16 66/2
67/25 68/15 69/1 69/4I
71/5 71/16 74/10
74/18 74/25 75/6 76/9I
78/10 80/24 81/2
81/20 81/23 82/4 83/1
85/13 86/2 88/4 89/18
93/4 94/6 98/9 98/13
99/1 99/2 100/7 101/6I
101/9 101/14 106/13
106/17 106/20 107/1
107/2 110/14 110/10
112/8 112/41 112/18
114/9 114/20 115/6
116/1 116/11 118/3
118/18 120/4 120/12
120/18 121/13 122/10]
122/15 123/20 124/4
124/12 124/21 125/2
125/6 128/7 128/12
129/10 130/14 135/13I
135/24 136/16 138/3
139/8 139/10 139/13
143/23 144/6 150/14
151/10 151/15 151/23I
154/17 155/19 156/22I
157/15 158/6 159/14
162/25 166/2 166/25
167/6 167/10 167/21
169/7 170/22 171/9
172M 173/22 176/6
176/17 177/15 177/19]
177/23 180/5 180/11
180/17 182/1 183/5
184/12 184/24 186/9
187/10 187/16 190/12I
190/16 191/17 195/17I
butting [1] 76/9
c
call [21] 9/1 33/14
33/15 33/16 38/1 38/8I
38/9 40/8 44/17 45/10I
79/13 81/2 139/11
143/4 145/7 146/18
148/7 151/5 173/4
181/5 195/17
called [4] 52/12 79/2
83/6 186/13
Callendar [1] 29/5
calling [4] 111/10
calls [8] 38/2 38/3
39/23 41/7 41/19 42/4I
44/8 184/22
came [5] 22/17 73/13
100/6 104/11 105/8
can [154] 1/3 1/4
1/10 1/20 3/18 4/20
5/19 6/25 7/2 7/2 8/6
9/2 10/10 13/21 13/21
14/25 15/22 16/14
17/12 18/2 18/16
18/18 18/25 19/25
22/10 22/16 25/13
(64) being... - can
Cc
can... [127] 25/18
25/21 25/23 25/25
27/22 28/8 29/24 33/2
34/19 34/21 34/24
37/24 38/12 39/13
42/6 43/9 46/6 48/3
49/3 49/5 50/19 55/20)
55/23 57/4 61/10
61/24 61/25 62/19
64/2 64/18 65/16
65/21 68/17 71/22
74/9 76/14 79/20
79/23 80/20 81/8
82/24 82/24 83/24
84/8 84/16 84/19
84/23 85/1 87/13
88/12 89/2 93/6 94/6
94/8 95/3 102/21
104/11 105/20 107/5
107/13 109/25 111/2
118/7 118/10 120/24
122/22 123/22 124/8
125/2 126/14 128/19
131/22 131/23 132/1
134/14 136/6 136/23
138/13 138/16 141/1
143/23 145/2 145/24
146/25 147/1 149/12
150/8 150/10 151/13
151/13 151/24 152/1
153/16 154/7 154/13
155/4 155/12 155/13
155/16 158/9 159/5
160/2 162/11 164/4
164/9 164/19 168/11
168/12 168/15 168/23
170/6 171/8 171/9
171/20 172/2 172/18
177/1 179/10 182/25
184/14 185/2 186/1
188/19 190/10 190/13}
191/4 194/21
can't [25] 17/18
17/23 19/13 24/21
27/23 28/18 54/20
64/16 66/12 81/20
105/18 106/14 106/20
106/21 125/12 135/13
137/20 151/11 160/11
163/15 166/11 174/2
181/9 184/19 184/22
cancelling [1] 187/9
candid [1] 82/14
cannot [11] 5/11
124/6 162/20 164/9
168/14 168/23 170/21
172/1 177/9 187/18
189/17
capture [1] 173/6
care [2] 185/18 186/3
career [1] 2/11
careful [2] 41/23
166/7
carefully [2] 26/21
145/13
carried [3] 11/19
14/19 14/21
carry [3] 60/2 128/24
140/4
carrying [2] 3/25
163/3
Cartwright [45]
29/21 30/4 31/4 33/9
33/23 34/5 34/6 34/10
34/11 34/25 37/17
40/1 42/4 51/13 55/15)
56/7 59/7 71/21 74/10)
75/17 76/2 76/23 78/7
86/1 88/5 88/15 88/17)
95/14 96/14 96/17
96/25 98/11 98/12
100/3 102/9 102/11
103/7 103/25 105/24
109/20 138/3 142/25
150/4 158/25 159/1
case [55] 3/1 3/3
3/25 16/18 16/24
17/22 25/21 26/11
26/11 26/14 27/17
27/25 28/9 28/11
29/17 44/11 44/15
48/10 49/4 57/18 71/7
77/8 77/9 77/19 77/21
77/23 78/18 79/19
80/1 81/6 83/18 89/20
94/25 95/2 95/4 97/1
110/20 125/12 128/16)
129/13 136/22 142/2
142/10 157/24 158/10)
158/24 158/25 170/22)
173/6 173/22 179/8
182/24 182/25 193/5
194/5
case’ [1] 31/15
cases [87] 12/20
13/4 13/5 25/19 26/10
27/8 27/14 27/15
28/11 28/13 28/14
29/13 30/3 31/3 31/21
37/2 50/23 51/6 51/20
54/9 56/15 59/5 70/20
71/9 83/20 84/11
84/13 85/23 86/16
87/21 88/6 94/13
94/24 95/8 104/20
104/21 110/11 115/13)
133/7 133/12 133/14
133/25 134/9 135/6
136/4 136/6 136/8
137/5 137/7 137/9
137/15 137/17 137/23)
137/25 138/2 138/6
141/21 145/8 145/20
146/4 146/8 146/9
146/19 146/23 147/2
147/17 147/17 147/18
150/4 158/3 158/12
160/24 164/20 164/21
164/22 164/23 165/2
165/11 165/19 166/2
166/6 166/15 170/5
175/9 175/17 176/7
194/1
cash [11] 135/3
135/5 135/10 135/11
136/3 136/9 136/15
136/22 154/16 155/4
156/9
Castleton [10] 3/1
3/3 26/1 27/19 28/1
28/3 28/9 93/18
104/19 139/14
categorically [1]
170/21
category [6] 19/20
120/2 120/4 121/5
121/22 122/3
Catherine [1] 130/5
cause [12] 9/17
72/23 127/8 155/7
165/24 169/25 170/1
171/16 184/6 190/15
193/4 193/9
caused [3] 8/20
11/18 159/2
causes [5] 23/13
23/14 24/9 24/11
175/14
caution [2] 41/16
50/5
CCRC [12] 33/22
53/16 53/22 53/24
53/25 54/22 112/7
112/15 114/23 114/24]
115/10 115/15
cease [1] 162/22
cent [2] 152/24
152/25
central [4] 170/2
170/2 173/5 174/15
centrally [2] 40/11
188/20
centre [2] 52/8 139/7
CEO [9] 86/22 87/1
87/20 87/24 88/3
90/21 90/21 142/2
142/4
CEO's [1] 90/16
certain [13] 11/2
26/12 70/23 77/7
77/14 78/17 79/18
79/25 104/19 139/19
154/22 170/25 194/22I
certainly [12] 57/24
62/3 78/10 80/2 86/19
131/14 141/17 144/5
158/8 164/25 174/3
176/21
cetera [11] 24/9
51/13 57/18 78/8 87/8
101/24 102/20 146/2
146/3 146/3 182/11
chain [7] 135/25
168/7 180/5 181/10
186/8 187/3 188/12
Chair [9] 55/10 61/1
81/10 83/5 142/2
142/4 145/5 145/22
179/4
Chairman [1] 83/3
challenge [2] 130/24
155/4
challenged [3] 67/25
68/16 155/10
challenges [4] 28/1
28/12 79/7 164/4
chance [3] 116/12
143/6 155/20
change [14] 20/17
53/23 63/13 77/1 77/1
78/14 78/19 80/7
80/16 95/3 109/9
170/18 171/14 177/11
changed [3] 5/16
15/1 20/16
changes [8] 56/25
78/20 78/22 78/24
79/14 174/23 178/20
181/3
changing [1] 110/16
channels [1] 17/3
character [1] 141/12
characterisation [1]
53/18
characterised [1]
139/20
charge [2] 114/25
189/22
charge’ [2] 110/20
113/14
charged [2] 14/11
20/9
Chartis [1] 43/21
chat [4] 132/6
check [4] 34/14 63/1
71/22 77125
checking [1] 75/23
Chesterfield [1] 23/6
choice [3] 119/18
119/22 136/7
chosen [1] 26/21
Chris [3] 65/19 71/12
97/4
circa [2] 22/14
127/10
circle [1] 130/10
circulated [4] 78/1
78/5 163/19 182/6
circulation [2] 39/19
39/21
circumstances [14]
4/24 11/17 17/6 70/13)
73/9 92/7 105/4
123/14 123/21 126/4
155/6 167/18 172/3
188/7
civil [17] 2/22 31/1
32/3 32/8 32/19 32/23
39/5 39/7 39/10 46/24
64/11 97/18 105/7
107/23 109/13 115/4
176/4
claim [4] 67/14 67/15
73/14 73/20
claimant's [1] 190/22
claimants [9] 127/12
127/17 127/21 128/10)
128/18 175/10 188/1
193/13 193/17
claimants' [6] 125/24
127/16 128/9 192/9
192/19 193/9
claimed [2] 142/1
142/17
claims [8] 71/24
73/10 79/2 93/14
192/12 193/13 193/15}
193/25
clarity [1] 168/1
Clarke [9] 34/20 35/1
40/6 95/13 98/11
98/12 100/3 105/10
106/24
Clarke's [2] 57/17
98/15
clean [1] 163/6
clear [20] 15/9 16/6
41/5 43/25 76/15 78/8)
80/18 97/17 97/19
102/17 106/24 112/6
119/6 119/15 122/14
145/8 146/19 159/25
168/23 191/11
cleared [1] 178/11
clearer [1] 175/13
clearing [2] 89/9
178/12
clearly [14] 5/11
47/18 49/20 55/16
77/22 92/21 95/9
95/25 97/12 98/24
139/14 149/22 180/14I
183/4
clerk [1] 6/18
clerk/subpostmaster
[1] 6/18
clerks [1] 53/1
client [15] 47/1 61/4
65/1 88/13 92/7 93/4
99/20 105/12 105/18
109/21 112/13 117/23)
118/6 120/24 121/23
clients [2] 65/10
100/7
clients’ [2] 95/8
100/16
cloak [2] 68/21 74/20
(65) can... - cloak
Cc
115/11 133/17 134/11
closed [1] 158/7
closer [1] 27/15
closure [1] 133/11
Co [4] 94/20 97/4
101/14 102/22
Co's [2] 96/2 96/20
cognisant [2] 80/7
80/16
cold [4] 11/10
collaborative [1]
166/23
collapse [3] 192/19
193/9 194/9
collating [1] 130/13
colleague [1] 58/15
colleagues [1] 71/12
collection [1] 38/21
collective [1] 182/23
colour [1] 85/3
column [1] 62/15
combination [1]
140/12
combined [2] 95/1
111/24
come [22] 12/21 24/3
29/15 29/16 42/6
42/11 65/13 65/23
72/20 73/21 88/18
98/12 100/24 110/1
115/5 118/22 131/15
132/18 139/13 173/2
176/20 193/6
comes [7] 43/10
76/12 115/11 125/17
134/16 168/9 186/12
comfortable [6]
14/22 30/6 64/17
88/21 183/22 184/4
coming [13] 49/1
49/3 75/25 93/24
98/14 145/1 149/3
155/18 155/24 179/24
181/4 181/8 184/24
comment [12] 21/6
32/21 46/19 58/6 88/4
99/6 103/17 126/20
143/9 149/7 170/13
185/25
commentary [1]
144/3
Commented [1]
38/14
comments [14] 6/11
8/23 48/14 81/13
98/20 104/3 113/10
114/19 116/8 172/22
180/23 181/7 181/9
185/5
commission [17]
30/3 31/4 31/21 50/23
close [4] 63/15
86/16 88/6 104/22
110/11 115/13 139/18)
140/21 175/17 176/7
commissioned [1]
52/11
commit [1] 133/2
committed [1] 52/25
Committee [3] 85/20
91/9 160/4
common [22] 16/15
49/1 67/8 67/13 67/16
67/17 67/21 68/1 68/4
69/16 69/18 70/5 73/6
192/15 192/17 192/21
192/23 193/7
commonality [1]
146/7
comms [7] 38/22
47IT 133/12 139/6
139/10 139/16 140/1
communicate [2]
44/6 44/20
communicated [1]
13/24
communication [2]
67/24 74/25
communications [5]
4/5 45/6 92/11 101/14
179/20
company [4] 45/6
92/10 107/16 115/12
compartmentalised
[4] 92/21
compelling [1] 94/25
compensating [1]
135/17
compensation [4]
84/10 135/15 136/2
136/18
competence [3] 3/15
64/7 64/8
competent [1] 63/17
complainant [1]
102/22
complained [2]
117/15 123/2
complaint [9] 14/4
14/5 27/16 93/9 94/20
95/17 96/3 96/20
101/1
complaints [2] 19/9
164/25
complete [7] 11/22
15/25 83/22 86/1
162/13 162/15 163/15)
completed [6] 83/10
83/19 108/18 158/4
158/13 160/18
completely [4] 11/24
16/2 34/15 169/10
completing [3]
139/11 160/23 188/6
51/6 51/21 54/9 56/16
68/6 68/9 68/10 68/15
completion [1] 162/5
compliance [4] 86/5
99/18 99/20 103/2
complicating [1]
162/6
complied [1] 35/25
complies [1] 173/22
comply [2] 34/1 36/5
complying [1] 86/11
comprehensive [1]
53/7
comprising [1] 2/1
compromise [1]
166/24
concede [1] 93/12
conceded [1] 93/15
conceding [2] 136/21
192/9
concentrate [1]
119/17
concept [1] 38/3
concepts [1] 136/20
concern [29] 4/21
6/13 13/6 13/12 31/20
42/25 77/5 79/15
89/14 99/1 128/15
129/20 139/6 141/12
142/9 142/13 144/12
148/21 151/9 160/22
175/2 179/11 179/16
180/1 180/3 192/8
concerned [23] 10/2
12/17 12/19 13/4
13/15 25/6 37/22 82/7I
82/11 90/21 109/12
125/18 128/24 129/12
130/21 136/20 137/8
142/15 143/16 144/14
149/2 171/6 172/5
concerns [21] 5/11
7/14 25/9 25/11 28/17
31/1 39/18 39/20
68/18 79/6 104/17
104/18 107/20 109/4
113/20 113/23 117/2
149/8 149/10 149/25
175/15
concessions [1]
179/14
concluded [1] 86/10
conclusion [5] 35/23
40/7 52/16 131/3
178/23
conclusions [1]
84/17
conditional [1] 162/5
conduct [2] 56/25
98/3
conduct’ [1] 111/22
conducted [11]
27/20 52/24 58/5
121/8 121/9 133/4
134/19 142/5 149/21
144/16 144/18 144/25)
173/14 191/24
conducting [1]
138/22
conduit [12] 54/6
54/24 57/24 58/7
58/11 59/11 63/20
63/23 86/18 104/4
106/18 106/20
conference [1] 40/8
confidence [1] 193/8
confident [1] 26/14
confidential [5] 67/7
confidentiality [1]
110/6
confidentially [1]
105/25
confirm [9] 1/20
14/12 14/25 20/10
84/8 116/16 117/5
173/23 177/14
confirmation [1]
178/16
confirmed [1] 116/18
conflict [1] 30/9
confused [2] 82/23
168/21
conjures [1] 126/8
connecting [1] 131/9
connection [2] 41/8
41/10
consensus [2]
133/15 134/1
consent [1] 173/21
consequences [3]
104/6 159/12 179/8
consider [23] 6/10
16/16 16/25 31/24
32/22 47/13 57/10
61/18 63/22 64/20
77/3 98/1 112/17
116/11 119/7 119/10
122/10 131/10 145/21
146/1 155/21 161/23
182/17
considerable [1]
23/21
consideration [5]
22/6 79/6 129/15
163/1 175/16
considered [17] 7/11
36/7 67/23 68/10
72/11 73/5 74/25
82/12 86/6 120/25
121/19 121/21 122/5
123/13 145/13 147/16}
153/1
considering [5]
73/17 81/23 98/2
135/5 136/3
considers [3] 95/6
145/8 146/19
consistent [2] 32/3
171/19
70/6 92/5 99/5 103/16)
constrained [1]
111/21
contact [5] 3/12
49/11 62/4 62/13
1415/5
contain [4] 32/3
119/3 126/11 128/6
contained [3] 81/1
94/24 128/8
containing [1] 1/13
contemplation [1]
73/19
contemporaneous
[2] 40/1 40/23
contempt [3] 168/25
169/10 169/18
content [3] 82/13
180/9 190/1
contents [3] 7/11
66/5 66/9
contest [1] 192/15
contested [1] 146/12
context [40] 8/24
12/5 13/18 18/3 24/3
30/7 33/22 39/2 41/18)
44/7 44/16 45/22
46/12 46/21 46/21
47/12 47/13 47/24
48/3 48/16 49/18
60/13 60/18 60/20
61/8 64/3 64/10 73/22
88/14 92/2 96/24
114/21 121/2 123/5
125/25 128/13 149/6
186/2 191/5 191/6
contexts [1] 45/15
continually [1] 61/20
continue [3] 83/18
161/15 161/22
continuing [5] 61/19
63/14 64/14 87/11
176/16
contract [6] 142/21
143/9 143/14 160/8
161/6 161/7
contracted [1] 164/38
contracts [1] 192/10
control [4] 132/14
159/16 159/18 164/15}
controlled [2] 132/15
190/1
controls [1] 174/17
conversation [4]
83/4 107/18 141/13
142/8
conversations [3]
24/22 32/13 32/16
converse [1] 161/18
convicted [7] 36/21
36/25 37/20 97/24
104/10 111/12 165/20)
conviction [6] 57/13
70/20 104/25 120/8
159/3 165/23
(56) close - conviction
Cc
convictions [14]
57/11 59/3 60/5 60/8
61/7 70/12 71/8 79/23
80/11 100/14 158/6
158/15 158/23 166/11
convictions’ [1]
57/16
convinced [1] 110/19
cooperate [1] 141/19
cooperation [2]
144/7 157/16
coordinate [1] 32/19
coordinating [1]
54/23
coordination [1] 32/7
cope [1] 144/3
copied [9] 32/9 61/10
62/11 62/14 62/18
63/7 145/11 145/11
182/5
copies [4] 2/4 95/20
102/18 175/25
copy [7] 33/9 55/17
69/11 69/12 80/15
100/4 190/2
core [3] 64/8 195/9
195/14
Corfield [5] 158/1
167/15 167/17 168/8
169/5
corner [1] 67/7
cornerstone [4]
11/23 12/9 15/4 16/1
Corney [1] 79/2
correct [48] 2/12 3/5
3/6 6/5 7/6 7/12 8/3
8/4 18/24 19/12 20/24
21/22 24/6 25/4 25/8
27/13 29/14 30/14
46/1 46/3 46/4 55/11
55/12 59/17 74/7
74/12 87/18 96/13
99/9 105/16 115/24
120/15 122/18 132/8
138/10 139/3 139/4
148/2 164/12 168/16
171/10 172/25 178/13}
185/20 186/19 186/20
188/23 190/5
corrected [4] 16/22
16/23 17/3 29/8
correcting [1] 11/10
correction [14] 155/5
155/9 187/9 187/13
187/17 187/19 187/21
187/23 188/10 188/14}
188/19 189/18 190/24}
191/17
corrections [3]
173/17 175/20 188/25}
correspond [1] 81/15]
corresponded [1]
104/21
correspondence [18]
21/3 21/7 21/23
21/24 22/3 23/1 23/22
23/23 53/25 54/2
55/18 62/11 89/1
97/20 100/1 122/19
168/5 179/25
corresponding [5]
50/22 53/23 53/24
54/22 61/13
corroborating [1]
148/4
could [113] 1/17 3/24
5/19 6/10 6/11 6/20
8/5 8/22 9/8 10/3
17/10 18/2 18/16 23/9)
23/10 25/14 29/23
30/7 34/18 35/2 35/22
37/23 39/19 39/25
41/21 42/2 42/10
42/16 48/15 51/15,
51/18 54/6 58/14
64/15 67/25 68/9
68/16 68/19 69/6 69/8)
69/12 71/11 72/16
73/5 73/9 76/4 76/11
76/12 76/19 87/6
88/25 89/17 89/19
89/23 90/12 90/15
90/23 91/3 93/13
93/20 93/20 97/9 99/3)
99/9 100/21 102/4
103/20 107/2 109/9
1411/9 111/15 112/17
112/23 114/10 117/8
118/18 120/10 122/20)
123/23 125/14 131/1
131/15 132/20 133/4
134/13 135/23 141/9
141/20 147/19 154/25)
155/16 156/17 157/13}
157/21 159/10 160/18)
163/14 165/6 166/21
166/23 167/13 172/18)
176/20 178/23 180/4
181/11 182/4 183/16
186/7 189/1 190/17
190/25 193/13
couldn't [10] 21/6
24/25 27/5 72/14
112/16 154/4 156/2
157/1 157/11 185/25
counsel [12] 51/10
51/12 54/5 54/7 64/9
71/2 127/6 172/20
180/7 181/15 183/17
192/16
counter [1] 158/11
couple [9] 3/20 22/16
31/2 62/25 65/8 89/12
114/8 155/20 189/1
course [13] 1/25
34/16 64/9 93/25
108/24 117/3 128/20
141/24 149/18 150/25)
158/6 164/21 165/10
court [13] 4/22 5/4
25/19 25/22 29/13
31/9 36/1 48/8 49/14
57/13 132/13 193/24
194/9
Courts [2] 29/7 194/6
cover [13] 43/11
43/13 68/2 70/7 72/1
74/24 80/12 81/17
156/11 159/14 190/24
191/4 194/8
covered [8] 67/21
69/4 69/10 73/25
116/17 116/18 139/17]
189/25
covering [10] 54/13
66/17 74/15 78/5
87/20 90/23 91/25
102/16 102/21 155/23
CQRs [1] 100/16
create [3] 46/6 46/8
164/24
created [3] 45/4
75/11 165/20
creating [1] 5/10
creation [2] 47/1
50/5
Credence [3] 6/10
6/16 98/23
credibility [10] 9/14
36/11 99/10 102/5
103/21 111/10 113/1
114/3 114/10 114/25
credible [1] 113/17
Crichton [13] 3/14
29/25 30/19 33/5
33/11 34/20 34/22
42/15 50/25 59/15
61/14 132/3 134/19
cried [1] 143/18
criminal [120] 30/3
30/8 31/3 31/21 32/3
32/8 32/15 32/19
32/23 32/25 33/1 34/9
34/17 37/9 39/23
50/23 51/2 51/6 51/10
51/11 51/12 51/20
52/19 52/25 54/5 54/7
54/9 56/12 56/15
57/14 59/16 59/19
60/4 60/7 60/17 60/18
60/23 64/5 70/18
70/24 71/22 75/18
82/1 83/18 84/11
85/23 86/15 87/21
88/6 88/9 88/15 90/19)
96/24 96/24 97/18
98/11 98/16 100/10
104/12 104/21 104/25]
105/3 105/7 105/9
105/18 105/21 106/5
106/9 106/10 106/13
106/14 106/18 107/22}
109/3 109/5 109/7
109/14 109/15 109/23}
110/11 111/5 111/5
111/13 114/6 114/13
115/1 115/2 115/4
115/7 115/8 115/9
115/13 120/12 120/13
137/4 137/6 137/15
137/17 137/23 137/25}
138/1 138/2 138/6
138/7 142/21 142/22
143/14 149/15 149/17)
158/3 158/12 164/20
164/21 165/22 166/6
175/15 175/17 176/7
176/10 176/11
criminally [1] 70/15
criminals [1] 111/14
criteria [1] 92/3
critical [4] 94/23
134/22 173/19 174/4
critically [1] 108/12
ise [1] 149/20
ised [1] 194/21
ising [1] 167/6
criticism [8] 9/14
117/11 118/13 118/16)
121/1 121/23 123/20
164/3
crossing [1] 115/6
crossover [3] 32/23
104/8 104/11
Crowe [3] 140/18
150/12 152/2
CRRs [2] 145/14
147/23
erying [2] 81/21
143/19
culpa [1] 180/13
culpa’ [1] 180/11
culpability [1] 11/9
current [13] 13/25
36/13 37/2 43/6 51/8
54/16 55/15 56/7
56/12 96/8 163/13
174/18 177/12
currently [8] 2/8 8/14
19/6 19/16 51/24 86/9}
89/14 146/1
customised [2]
12/15 12/24
cuts [4] 108/13
D
daily [1] 140/16
damages [1] 193/17
damaging [2] 9/13
90/13
dangerous [4] 11/21
15/24 143/8 192/22
Darlington [2] 94/10
94/17
Darlington's [1]
97/10
data [32] 4/3 5/4 5/12
5/14 6/20 46/22 52/18I
93/10 98/20 98/23
99/2 99/18 100/13
101/19 102/1 102/14
103/2 103/8 103/10
105/13 139/7 139/17
170/16 170/17 170/18)
170/20 171/20 171/22)
177/12 184/5 189/11
190/12
data's [1] 99/2
data/inject [1] 171/20
data/transactions [1]
93/10
database [2] 174/14
174/15
date [9] 3/21 65/16
111/21 116/14 127/6
147/1 155/23 157/9
165/2
dated [6] 1/14 29/22
91/5 121/6 121/7
161/8
dates [2] 117/14
123/2
Dave [3] 5/21 7/14
48/7
David [2] 65/19 71/13
Davies [4] 163/20
168/21 179/5 179/17
day [27] 19/1 22/10
33/5 33/15 33/17
34/23 37/22 51/20
54/19 89/1 89/7 107/2I
117/19 119/3 133/19
134/13 143/16 159/21
161/13 161/16 161/22)
167/11 167/12 180/5
195/6 195/17 195/21
days [7] 33/6 45/21
62/8 62/25 143/5
155/20 183/19
DC [1] 139/8
de [2] 172/21 182/5
de Garr [2] 172/21
182/5
deadline [1] 175/11
deal [4] 2/5 22/1
37/10 191/3
dealing [6] 29/2
37/11 58/3 63/18
87/15 194/2
deals [1] 75/24
dealt [2] 12/15 29/22
Dear [3] 58/17 79/4
159/8
debate [6] 38/15
113/13 157/23 180/16)
180/18 182/2
debating [1] 183/2
deceit [1] 175/7
(67) convictions - deceit
D
December [6] 136/23
150/8 151/25 152/1
157/22 157/22
December 2014 [1]
151/25
decide [3] 58/22
156/23 165/10
decided [2] 127/17
128/11
decision [8] 100/6
130/16 146/8 146/24
159/12 163/5 165/15
190/13
decisions [5] 162/10
165/9 191/6 191/15
192/13
declaration [1] 20/12
deemed [1] 166/3
deeper [1] 27/17
defeated [1] 193/13
defect [2] 29/8 31/10
defects [2] 28/23
93/24
defence [11] 36/2
71/2 71/7 77/20
181/12 181/14 181/15
181/24 182/3 182/6
183/22
defences [1] 144/5
defend [1] 140/1
defendant [3] 148/11
149/18 149/20
defendants [6] 36/18
36/21 36/23 37/5 77/4
115/1
defending [1] 193/25
deferred [2] 64/19
108/16
definite [4] 132/20
definitely [1] 34/11
definitive [1] 64/24
definitively [1]
177/10
degree [4] 11/9
132/14 183/13 193/7
delay [5] 100/15
194/17 194/19 194/19}
194/19
delayed [1] 127/9
delaying [1] 59/5
delete [4] 174/13
174/19 175/4 189/11
deleted [1] 182/10
Deloitte [8] 173/23
174/9 174/12 176/2
177/9 177/12 193/1
193/7
Deloitte's [3] 175/25
184/4 184/5
Deloittes [1] 174/18
delta [1] 134/3
demonstrates [1]
31/14
den [2] 158/2 189/14
denial [2] 110/10
115/10
denied [1] 3/25
Deny [1] 184/8
department [2] 91/22
91/22
depend [1] 17/6
depends [1] 46/12
depth [1] 129/3
describe [2] 136/7
180/17
described [1] 141/16
describes [1] 75/3
describing [1] 47/1
deserve [1] 168/25
designed [5] 67/9
67/11 67/20 68/8
124/17
desire [1] 108/9
despite [1] 89/11
detail [8] 10/6 53/5
81/22 82/5 85/5 89/20)
127/7 183/12
detailed [2] 52/1
110/21
details [11] 4/7 9/23
24/21 79/5 81/1 101/8)
101/16 108/22 111/24)
126/3 137/7
detection [1] 31/10
determine [7] 23/13
27/18 57/8 57/22
97/25 147/13 155/7
determined [2]
154/16 156/9
determining [2]
166/4 170/1
detrimental [1] 38/16
dialogue [1] 97/5
Dickinson [25] 2/9
2/21 3/9 8/8 8/13 26/5
26/7 55/3 55/4 55/10
55/13 55/19 57/23
57/25 67/6 69/9 72/21
74/10 74/17 79/21
127/4 127/19 141/6
159/10 161/2
dictate [1] 164/10
did [45] 3/8 7/8 11/12
17/4 18/9 22/17 24/19)
29/16 41/14 41/18
44/19 50/7 66/10 73/2
75/12 80/24 81/15
82/16 82/17 88/6
88/21 91/25 98/23
103/4 113/6 113/18
116/15 119/3 124/25
134/5 138/6 138/9
140/19 149/25 152/17)
152/23 156/15 157/17)
158/15 165/13 165/15)
167/1 167/19 169/20
177/20
didn't [19] 10/5 15/19
15/21 23/7 41/3 41/4
50/4 68/12 106/23
114/13 121/20 126/11
126/12 138/3 148/19
149/5 172/12 193/6
193/11
difference [5] 27/1
64/21 76/18 76/22
191/22
differences [1]
134/22
different [22] 35/17
37/25 41/2 45/5 45/14}
45/15 45/22 59/21
65/22 74/19 81/3 85/3
99/1 115/18 123/20
133/22 134/9 136/19
147/2 149/4 169/9
169/9
difficult [6] 58/6
60/11 108/21 130/25
136/8 161/24
ulties [1] 39/19
culty [1] 164/17
Dilley [2] 2/25 27/24
dim [1] 59/24
direct [3] 75/8 162/13
162/21
directing [1] 59/18
direction [6] 140/14
140/15 160/14 180/19}
180/23 181/6
directions [3] 48/20
150/7 162/20
directly [9] 33/25
55/2 73/21 104/23
120/19 139/16 170/17]
171/22 185/3
Director [1] 179/20
directors’ [2] 82/20
82/22
disagree [5] 41/14
46/9 118/14 165/13
165/15
disagrees [1] 100/12
disastrous [2]
190/17 190/25
disband [1] 163/7
disbanded [1] 162/19
disbanding [3] 163/1
163/17 164/1
disclosability [3]
45/18 82/8 82/11
disclosable [21] 13/9
13/13 40/18 42/8
44/21 45/12 45/25
46/7 47/2 62/1 67/21
68/19 122/5 122/11
122/12 122/16 122/17]
122/21 122/23 129/2
189/24
disclose [23] 9/11
36/8 36/20 37/4 70/23
70/25 77/7 77/14
78/17 79/18 79/25
120/1 121/14 121/24
123/9 123/10 123/12
127/14 128/20 129/9
129/14 131/7 170/10
disclosed [30] 13/6
29/6 29/13 36/17
36/18 36/22 45/4
72/23 74/1 74/6 86/8
93/23 96/23 99/6
103/17 104/25 109/10}
116/20 127/25 128/3
128/7 128/14 128/17
129/2 129/17 130/23
149/18 172/6 172/15
191/16
disclosing [6] 9/7
68/22 102/6 108/22
114/4 125/19
disclosure [59]
12/19 12/21 13/3
36/24 37/3 37/5 38/23,
39/5 39/7 39/8 39/11
40/3 40/19 41/25 44/2)
46/25 47/9 49/24 50/6)
61/19 63/14 63/19
64/14 77/4 83/21
84/13 89/15 94/15
94/21 96/25 98/8
99/23 100/2 103/25
105/25 106/1 107/22
108/19 109/3 109/16
109/17 109/23 110/15)
116/15 117/16 118/10}
119/13 121/3 123/3
123/7 125/23 149/16
175/15 194/12 194/17I
194/20 195/2 195/3
195/4
disclosures [4] 71/4
77/18 105/6 106/8
discrepancies [12]
14/1 14/8 14/11 18/7
20/1 20/4 20/6 20/9
21/2 21/17 23/2 23/3
discrepancy [4]
18/20 21/14 124/24
155/7
discuss [7] 8/25 30/7
91/16 92/18 132/25
157/11 173/3
discussed [13] 19/5
22/13 25/19 25/20
25/22 100/9 107/25
108/6 133/10 134/16
134/21 137/2 144/21
discussing [10]
24/20 54/8 78/20
78/22 78/24 92/3
93/19 129/11 129/12
132/17
discussion [9] 52/3
73/21 84/7 87/6
133/18 153/7 153/9
185/5 186/15
discussions [8] 26/4
125/22 133/20 133/22!
142/3 163/8 167/14
192/25
disguised [1] 69/9
dishonest [1] 111/22
disproportionate [1]
154/2
disproportionately
[1] 194/7
disprove [2] 147/25
148/3
disseminated [1]
40/11
distant [4] 23/4 59/24
62/7 81/16
distinct [1] 177/10
distinction [2] 57/15
165/18
distinguish [4] 65/1
97/17 98/24 109/12
distrust [3] 137/13
137/18 137/24
division [3] 15/10
52/21 79/3
do [95] 5/8 5/9 9/1
9/12 11/5 17/14 17/19}
20/25 21/12 21/16
31/1 33/7 33/16 34/8
38/1 38/7 39/7 39/20
40/25 41/17 41/20
42/6 42/23 46/2 46/18)
49/15 49/21 61/25
63/17 64/6 64/14 65/4
65/10 66/17 67/13
73/15 77/23 78/12
78/15 78/20 87/22
88/12 88/19 89/18
91/16 91/16 92/8
93/13 94/17 95/7 96/6I
97/6 97/14 98/19
99/22 100/15 102/15
105/20 106/1 106/15
109/14 112/2 112/7
112/14 112/16 112/19)
118/11 118/14 119/1
124/18 126/7 131/2
133/19 141/6 144/25
146/5 147/8 149/19
154/3 161/19 161/25
166/3 166/17 167/2
167/21 172/12 181/17)
182/17 182/20 184/18)
185/7 185/19 186/24
191/19 191/21
document [61] 12/1
12/8 12/13 13/20 16/4I
40/23 58/20 65/17
65/19 67/20 68/5 68/7I
68/8 68/15 68/17
68/23 68/25 69/2
(58) December - document
D
document... [43]
69/15 69/15 71/17
71/20 74/3 74/18 75/3,
75/7 75/10 75/24 78/6
78/23 81/2 82/12
82/13 92/2 93/6 95/24)
95/24 96/23 103/11
104/1 104/24 118/13
118/22 119/10 119/21
119/24 119/24 120/3
120/25 121/18 121/19
121/22 121/25 131/6
143/4 151/14 155/19
156/23 157/8 186/8
192/2
documentation [1]
158/10
documented [5] 12/4
12/12 12/22 13/8
13/12
documenting [6]
12/18 13/4 13/16
25/10 25/11 104/19
documents [42]
12/22 13/11 39/11
41/3 45/3 45/18 45/20)
46/6 46/6 46/8 46/22
47/1 47/14 62/24
65/22 108/23 110/15
116/17 120/2 121/5
121/14 121/17 122/2
122/11 122/13 122/16)
127/13 127/15 128/5
128/23 129/4 129/5
129/8 139/17 149/16
167/9 170/10 177/19
185/7 185/13 189/23
194/18
does [30] 9/19 9/25
18/5 19/14 20/15
35/24 42/20 48/4 58/9
58/9 63/23 71/25 76/6
108/15 110/10 114/23
119/11 121/16 121/16
122/9 122/10 122/19
122/21 139/13 140/7
150/16 155/17 180/14
191/22 194/11
doesn't [30] 6/1
20/23 45/19 47/11
47/19 48/16 55/17
66/7 66/14 66/18 68/6
69/2 69/17 69/20 70/7,
72/10 73/13 77/21
93/3 115/2 115/11
123/8 124/4 140/7
142/14 144/13 153/18)
182/12 189/3 190/19
doing [17] 32/5 44/14
61/9 69/25 104/5
105/17 106/3 114/12
119/5 120/22 124/8
124/17 127/15 128/9
131/4 142/22 180/12
domain [2] 40/17
42/24
don't [103] 4/23 5/18
7/5 7/7 9/4 11/7 11/25)
12/3 13/14 16/3 18/11
18/16 19/19 22/2 22/6
26/8 27/1 30/20 32/14
38/3 38/9 39/1 39/3
39/22 41/4 44/25
45/11 45/17 47/11
47/13 47/23 57/19
59/21 60/15 60/21
64/16 66/23 67/2
67/11 72/11 73/2
73/20 75/1 78/14
78/19 78/24 80/15
81/23 84/14 89/5
92/13 92/18 96/2 98/4
101/5 102/14 105/1
105/7 105/12 106/14
106/17 110/14 111/2
111/5 112/4 113/12
115/6 115/15 124/13
124/21 126/2 126/5
128/22 129/15 130/18)
131/5 131/6 131/8
131/9 140/24 140/24
141/7 142/6 143/4
144/21 144/24 145/1
151/18 156/12 157/8
159/1 160/21 166/19
171/14 172/1 177/13
179/6 180/18 182/22
184/19 186/25 189/8
194/16
done [10] 31/7 34/11
34/12 41/10 72/16
99/17 103/1 161/17
168/23 171/21
doomed [1] 166/18
door [1] 130/9
dots [1] 131/9
doubt [3] 38/10 125/3)
133/11
doubts [1] 140/12
down [62] 4/2 4/19
16/9 17/12 19/25
32/24 34/19 39/14
40/12 41/23 42/6 42/8)
44/6 44/12 45/23 46/6
49/5 49/8 50/21 51/18)
57/4 61/12 64/1 68/17)
70/10 79/10 79/22
79/22 81/12 83/6 89/2
92/12 99/14 101/11
102/21 102/23 104/15)
113/10 118/7 119/16
132/2 135/25 138/15
145/4 145/24 147/10
147/11 155/2 157/18
158/1 161/5 164/19
165/24 167/15 175/12)
178/8 180/10 180/13
181/16 186/11 191/3
192/23
Dr [7] 35/6 35/14
70/22 71/5 77/6 77/13
79/17
Dr Gareth [5] 35/6
70/22 77/6 77/13
79/17
Dr Jenkins [1] 35/14
draft [38] 14/18 18/9
19/21 22/7 31/2 31/3
42/16 48/19 51/5
54/15 74/8 74/15
74/22 75/10 75/11
76/1 81/1 83/8 85/4
98/13 98/14 99/13
99/14 99/25 102/21
116/6 116/9 119/2
119/5 125/10 141/3
163/18 163/21 177/14
181/15 181/24 182/3
182/6
drafted [20] 10/11
18/14 31/4 40/23
53/19 53/19 54/1
66/19 66/20 66/25
70/1 72/12 72/14
80/21 85/10 86/2
116/9 121/18 121/19
177/4
drafted/written [1]
40/23
drafting [15] 6/6 21/8
21/10 29/3 53/24
71/16 75/7 82/7 85/6
86/25 103/6 104/2
181/3 181/10 181/12
drafting/tone [1]
181/3
dramatic [1] 10/24
draw [3] 120/18
124/18 166/12
drawn [1] 139/13
dressing [1] 69/23
drew [1] 80/13
driving [1] 39/24
dropping [1] 181/19
drove [1] 137/20
dual [1] 66/4
due [6] 1/25 34/16
85/12 94/14 162/2
187/21
duration [1] 159/18
during [17] 93/25
116/25 117/3 121/15
123/5 133/21 141/24
144/6 148/15 149/18
161/11 161/12 161/19]
161/22 162/12 165/9
183/15
duties [13] 36/1 39/5
41/25 82/22 86/5
86/11 97/8 97/16
97/21 98/2 99/21
99/22 109/18
duty [14] 36/5 36/10
36/19 39/7 40/4 61/19)
63/14 63/18 64/14
86/7 96/6 98/8 99/23
100/1
E
each [16] 12/14
12/14 12/14 12/24
12/24 22/8 27/17 32/5}
52/22 62/1 110/20
115/5 123/13 131/10
132/21 132/23
earlier [19] 33/6 44/7
44/9 68/17 82/16
86/17 89/24 90/1 91/8
116/15 119/3 122/7
128/4 129/23 151/8
166/1 175/25 176/12
189/8
early [9] 2/23 2/24
32/21 72/22 117/18
119/14 177/14 191/1
192/8
earnest [1] 10/7
earth [3] 102/4
122/19 168/25
ease [1] 58/20
easier [1] 178/10
easy [2] 22/22 60/15
economics [1]
193/16
eDiscovery [1] 46/23
edit [4] 171/2 174/14
174/19 175/4
edited [4] 168/12
168/15 171/9 172/1
editing [1] 190/12
Edwards [2] 83/2
83/25
effect [7] 23/14 40/21
42/1 65/7 81/17
146/22 163/2
effectively [5] 11/11
21/3 86/18 112/21
162/1
effectiveness [2]
57/9 159/18
effects [3] 36/6
159/20 159/23
efficacy [2] 57/8
58/24
effort [1] 154/2
efforts [1] 130/7
either [5] 9/1 40/10
110/9 160/10 192/19
elaborate [1] 47/15
Eleanor [1] 186/13
else [1] 55/3
elsewhere [1] 136/6
email [136] 5/20 7/8
8/6 8/11 15/4 19/2
19/2 19/14 19/24
22/11 22/11 25/9
25/15 32/9 32/12
32/16 33/3 48/4 48/4
48/5 48/6 48/16 54/13)
54/13 54/14 58/14
59/10 60/6 60/9 61/11
61/15 62/14 63/3
63/10 65/5 65/6 65/15
66/17 68/18 71/17
72/1 74/8 74/15 75/21
76/5 78/5 78/21 80/13
81/8 81/9 81/14 82/16I
82/22 83/1 86/19
87/19 89/2 89/25 91/4
91/6 91/8 94/9 95/1
95/11 95/14 97/10
99/25 100/12 100/18
102/13 102/16 102/17)
103/6 103/14 104/13
107/15 108/1 109/21
114/16 114/22 116/6
118/25 119/1 119/8
119/14 121/12 121/18)
122/4 122/15 124/2
124/17 125/9 126/17
126/20 126/25 130/4
132/3 134/8 135/13
135/25 136/16 136/24}
137/20 137/23 138/14)
145/3 145/3 145/4
147/14 147/20 149/13)
150/12 154/11 155/14)
155/23 160/6 163/23
166/1 167/22 168/7
173/25 174/1 174/7
180/5 181/10 183/17
186/17 186/21 187/3
189/7 189/8 189/10
192/3 192/7 194/19
194/25
emailed [1] 157/25
emailing [2] 158/1
172/20
emails [19] 4/13 30/1
33/11 38/22 42/15
A7IT 63/7 104/2
108/23 115/20 119/9
152/2 159/7 166/16
167/17 169/14 169/21
186/8 190/3
Emanuel [1] 130/5
emphasise [1] 86/18
employed [1] 143/14
enable [2] 149/19
162/21
encompassing [1]
100/7
encourage [5] 135/6
135/6 136/4 136/11
154/3
encouraged [1]
136/9
end [23] 16/11 52/1
(59) document... - end
E
end... [21] 53/8 83/23
97/22 102/1 129/23
132/12 135/22 135/24}
139/11 146/9 146/25
147/12 154/10 157/22)
161/16 163/9 163/13
165/25 183/7 188/2
194/24
ended [1] 156/24
ends [1] 9/8
enforce [1] 162/10
engage [3] 23/12
23/20 24/8
engaged [1] 160/1
engagement [8]
114/4 114/12 159/13
159/21 159/25 161/8
161/14 162/10
English [1] 29/7
enough [7] 63/17
85/5 106/2 157/2
177/13 183/12 188/25
ensure [7] 5/2 67/20
86/7 99/18 103/2
133/6 145/10
ensured [2] 14/10
20/8
ensuring [6] 11/23
12/9 15/5 16/1 90/20
160/22
enter [1] 173/13
entered [2] 6/18
171/25
entire [2] 93/4 140/1
entirely [4] 87/14
125/15 153/22 172/4
entities [1] 34/3
entitled [6] 35/1
36/23 123/25 161/16
162/15 191/25
entries [1] 38/11
entry [1] 38/17
envisage [1] 132/21
envisaging [1]
135/14
equalise [1] 133/1
equation [1] 123/19
erodes [1] 194/3
err [2] 185/23 195/2
error [24] 9/8 9/11
9/17 9/19 9/25 10/6
11/17 23/11 27/16
123/21 125/14 125/19)
125/22 125/23 126/8
126/11 126/17 127/11
127/20 127/24 130/6
130/8 187/22 188/23
error’ [1] 125/14
errors [9] 22/21
22/24 23/7 124/9
124/10 124/16 124/19)
124/24 127/5
escalate [2] 97/12
190/9
et [12] 24/9 51/13
57/18 78/8 87/8
101/24 102/20 142/21
146/2 146/3 146/3
182/11
et cetera [6] 51/13
78/8 102/20 146/2
146/3 182/11
etc [5] 23/14 38/22
47/7 57/9 169/8
even [17] 4/10 25/2
55/17 71/1 84/14
91/24 92/18 117/23
119/18 125/14 125/18)
148/3 153/1 154/4
165/2 166/15 194/4
events [2] 110/2
154/22
eventually [1] 83/1
ever [12] 11/25 16/3
43/17 44/10 54/11
90/4 133/11 140/19
146/25 162/3 167/21
194/16
every [4] 136/22
158/24 158/25 173/11
everybody [1] 87/25
Everything [1]
109/11
evidence [35] 4/22
5/13 6/21 25/5 31/8
35/2 35/3 35/7 35/11
36/13 37/21 39/16
41/11 41/16 56/20
70/21 71/10 77/5
77/12 79/16 98/21
110/24 111/1 141/11
142/10 142/14 144/10)
144/13 148/5 148/18
148/20 149/1 149/5
149/8 152/23
evidence/prosecutio
n[4] 6/21
evidential [1] 148/8
exact [2] 143/22
151/12
exactly [6] 44/14
58/6 88/7 117/23
118/5 182/2
examine [1] 170/20
example [23] 2/25
12/19 18/12 21/4
26/23 26/24 61/23
78/21 87/21 111/15
113/3 129/11 129/22
140/20 148/1 150/25
154/13 156/1 157/18
169/11 176/8 191/2
193/14
examples [2] 25/22
142/20
exceeding [1] 144/2
exceptional [1] 172/3I
ExCo [1] 85/19
excuse [1] 182/14
Executive [5] 178/11
183/22 184/1 184/11
184/25
exercise [3] 117/16
123/3 123/7
exhausted [1] 187/8
exhibits [2] 2/1 2/2
existence [5] 13/11
36/22 37/4 37/11
128/8
existing [1] 56/25
exists [1] 125/24
exit [1] 163/6
expect [5] 9/6 30/23
67/4 162/16 195/14
expectations [1]
164/23
expected [5] 42/3
63/21 83/22 165/8
192/18
expecting [1] 60/16
expedition [2] 150/15}
151/5
expensive [1] 194/7
experience [4] 43/23
83/11 105/7 164/25
experienced [2] 3/16
22/24
expert [19] 31/8
31/12 34/2 35/2 35/3
35/7 35/11 35/14
35/17 36/9 36/10
36/11 36/13 70/21
77/5 77/12 79/16
99/11 176/10
expertise [2] 106/21
114/13
expertise’ [1] 114/7
experts [3] 48/8
48/23 113/16
explain [8] 18/5 22/8
106/12 124/24 133/13
145/18 150/4 194/11
explainable [2] 11/25
16/3
explained [4] 62/17
101/2 115/3 155/3
explaining [5] 23/23
96/11 96/16 96/17
192/4
explains [3] 10/19
51/23 96/9
explanation [18] 6/23}
9/19 9/25 21/4 23/9
46/14 47/10 47/15
84/12 84/12 84/16
85/24 110/21 118/21
118/23 122/7 122/24
156/17
explicitly [3] 95/2
129/25 163/16
express [1] 125/13
expressed [9] 13/7
64/2 119/9 119/15
122/15 141/12 142/8
142/13 144/12
expresses [1] 60/9
expressing [1] 151/9
expression [2] 136/5
153/2
expressly [7] 11/25
12/8 12/18 13/16 16/3}
43/25 139/13
extend [2] 93/3
175/10
extensive [2] 126/3
174/24
extent [8] 24/10
24/15 40/10 59/14
115/7 126/9 157/14
159/15
external [4] 83/19
86/14 107/19 143/1
extra [2] 4/23 103/10
extract [2] 114/4
168/22
extracts [1] 4/13
extraordinary [1]
85/19
extreme [1] 158/8
extremely [2] 174/23
193/3
F
face [9] 80/9 98/24
117/11 145/9 145/9
146/20 146/20 147/14]
175/4
facetiously [1]
123/25
facilitate [1] 88/20
fact [40] 8/10 10/20
15/11 17/1 17/15
18/23 21/1 21/16
24/15 29/10 39/10
46/10 55/6 55/17
57/10 58/10 59/12
61/13 73/13 73/17
74/8 76/15 80/13 81/2
97/23 98/22 104/9
119/12 123/15 125/3
125/19 125/23 129/17
134/14 146/14 150/20
155/23 160/1 164/24
187/5
factor [1] 162/6
facts [4] 72/12
190/14 191/15 194/2
factual [2] 74/23 87/2
factually [1] 169/16
fail [3] 133/14 133/25
166/18
failed [9] 36/4 36/8
70/23 77/7 77/14
78/17 79/17 79/25
147/24
failure [12] 6/14 34/1
34/7 36/6 36/10 36/17I
36/20 133/17 139/6
139/7 139/10 183/7
fair [9] 20/25 60/6
68/14 105/16 111/4
141/15 167/5 177/19
179/25
fairly [3] 11/4 75/3
93/21
fait [1] 195/14
faith [1] 166/20
faithfully [1] 104/13
Falkirk [2] 25/20 29/5
false [5] 111/19
111/25 175/8 184/7
184/9
fantasy [1] 169/13
far [14] 73/11 75/9
75/17 80/20 90/21
91/2 137/6 172/6
181/1 189/24 191/4
fast [1] 126/14
fatally [1] 36/12
fault [4] 17/1 106/9
181/23 187/22
faults [1] 93/13
favour [4] 148/8
148/10 192/13 192/19)
feature [1] 6/1
February [4] 159/6
159/6 161/3 167/14
Fed [1] 9/15
feed [2] 6/11 138/18
feedback [2] 177/9
184/21
feeds [1] 110/13
feel [9] 64/17 88/21
104/12 106/23 142/15)
144/14 156/16 166/8
183/14
feeling [1] 126/1
feels [3] 30/5 30/9
126/4
felt [3] 82/15 88/24
181/25
fetter [1] 142/11
few [18] 2/6 8/15
23/6 33/6 56/2 62/8
80/24 84/2 84/9 110/2I
115/18 131/25 143/5
153/19 163/23 163/25]
167/9 183/19
fictional [2] 125/12
126/1
figure [1] 124/7
figures [1] 95/3
file [2] 149/17 170/9
files [1] 150/3
final [21] 1/17 12/2
15/23 78/15 78/25
83/16 90/14 119/4
119/11 128/2 133/5
(60) end... - final
F
154/9 156/23 161/2
180/5 182/12 182/13
192/2 193/21 194/13
finalised [2] 59/8
85/12
financial [3] 79/2
135/22 135/23
find [19] 5/24 19/5
20/20 25/21 51/5
54/15 58/6 58/18
66/12 71/20 72/3 75/1
127/2 152/13 180/22
86/6 86/8 132/25
fine [5] 55/5 81/7
94/5 107/7 195/12
finish [1] 167/12
fire [3] 43/4 110/14
138/25
firm [20] 30/8 32/7
32/14 32/17 52/11
73/22 83/19 88/11
88/19 140/2 186/19
187/7
firm's [1] 119/2
first [53] 3/7 6/24 8/6
10/18 20/16 22/17
26/17 28/24 32/22
33/2 34/18 36/15 38/5
38/6 38/8 38/12 40/25
43/5 45/10 45/17
49/22 50/10 50/21
56/5 56/10 73/16
75/10 75/11 76/21
85/7 86/3 86/4 89/7
90/11 95/10 101/8
107/14 108/2 108/16
131/25 134/10 135/9
143/20 160/19 161/24)
163/21 164/6 172/8
175/18 177/2 182/9
187/19 190/2
fishing [5] 150/15
150/18 151/5 153/1
153/1
fixing [1] 188/5
flagged [1] 143/7
flaw [3] 26/16 26/21
148/12
flaws [1] 56/19
Flemington [2]
107/16 107/24
flesh [1] 153/17
floodgates [2] 93/14
192/11
Foat [3] 126/22 192/3
192/4
focus [2] 185/16
final... [10] 145/13
78/6 79/5 108/6 116/6
findings [5] 53/4 53/5)
59/22 60/3 60/7 60/24,
61/3 63/17 64/6 64/12
193/22
33/18 58/3 160/23
160/24
focuses [1] 133/6
follow [1] 9/4
following [15] 6/14
71/21 72/1 78/7 84/7
94/20 104/25 105/3
110/6 177/9 195/21
follows [33] 5/22
89/13 90/2 91/13
94/11 95/11 99/14
108/4 110/7 110/18
117/21 118/9 124/3
126/25 132/4 138/23
150/13 155/1 155/17
173/18 177/5 184/2
foot [1] 139/25
footnote [3] 57/5
57/6 58/25
footnote 4 [1] 57/6
footprint [1] 174/20
for' [1] 142/23
force [2] 134/24
194/9
forensic [1] 52/12
form [8] 9/7 68/20
89/3 120/10 138/6
formal [4] 43/20
86/14 90/7 132/12
formally [1] 118/3
formed [2] 137/18
138/4
former [6] 11/18 15/2
15/8 16/5 110/12
112/11
forming [1] 10/9
forms [2] 70/4 70/7
157/24
formulation [1]
177/16
forward [6] 54/5
126/14 133/23 148/4
165/7 170/4
forwarding [1] 65/18
foul [1] 143/20
foul' [1] 143/18
found [8] 3/18 23/9
31/25 70/16 127/25
154/18 172/8 177/16
four [2] 7/19 48/21
four pages [1] 7/19
fourth [1] 49/4
fraud [1] 5/24
Freedom [3] 44/3
107/21 108/24
Freeths [9] 116/12
focused [6] 7/15 22/8
36/7 39/19 40/7 57/11
43/11 46/17 48/6 56/5
57/6 61/15 84/1 85/10)
161/13 164/20 170/24;
155/13 158/22 178/12)
formulating [2] 59/19)
117/4 118/14 125/21
177/4 178/13 179/12
181/13 192/24
Friday [1] 139/5
froing [1] 186/3
front [3] 1/12 7/23
65/7
FSC [1] 189/4
fudge [6] 153/20
155/22 156/16
fudging [4] 154/12
FUJ00081921 [1]
48/3
Fujitsu [58] 4/4 4/6
23/12 23/20 24/8
34/13 48/13 70/22
77/6 77/13 79/17
89/16 95/2 101/13
101/15 101/23 102/2
1741/1 172/2 174/13
177/20 178/1 178/11
182/20 182/23 183/5
183/6 183/9 187/10
188/10 188/13 189/11
190/10
Fujitsu's [2] 130/13
138/19
full [15] 1/10 49/25
59/21 99/20 110/12
117/15 123/3 154/5
169/8 179/7 190/11
190/14 191/15 194/5
194/23
fully [6] 5/3 9/17 33/8
64/4 86/8 99/3
functionality [1]
167/20
functioned [1] 15/11
functioning [1] 147/9
funder's [1] 193/18
funding [2] 192/19
193/9
further [28] 19/15
20/21 23/21 37/2 52/5
52/15 53/12 56/17
56/17 75/6 77/4 81/22}
84/3 87/6 110/15
117/8 135/25 139/18
142/14 144/13 163/3
170/10 174/8 176/2
176/3 187/4 190/7
193/1
future [8] 36/13
38/16 57/1 83/14
154/25 155/15 155/17]
156/25 156/25 156/25
24/10 33/24 34/4 34/8
126/10 129/11 129/12
129/16 129/19 130/14
130/15 130/17 130/20
130/25 139/17 139/18
177/11 177/12 177/17]
178/12 178/15 181/18
181/20 181/22 181/25)
85/15 108/10 159/12
190/3
G
101/16
gains [2] 8/21 14/25
Gaisford [1] 38/20
gap [1] 134/11
gaps [1] 83/13
Gareth [50] 4/6 4/9
33/7 33/24 34/1 34/4
34/8 34/13 34/20 35/1
35/6 35/10 36/4 36/8
36/16 56/13 70/22
71/9 71/9 75/24 77/6
77/11 77/13 78/13
78/16 79/17 79/24
80/14 81/25 87/22
88/1 90/14 99/10
101/15 101/19 102/1
102/3 102/5 102/6
103/20 103/22 105/1
105/23 106/6 111/17
170/11
Garr [2] 172/21 182/5
gathering [1] 83/4
gave [19] 13/14
18/17 22/6 42/7 49/22,
65/25 72/19 72/22
91/9 104/13 110/4
123/17 129/13 150/7
161/1 187/15 193/5
193/7 195/1
Gavin [19] 3/10 30/12
32/21 33/3 33/11 55/8
58/5 58/15 59/16
60/16 60/25 61/14
62/7 63/9 64/4 64/17
132/6 132/7 132/7
Gavin's [1] 65/8
GE [1] 184/23
general [18] 9/20
10/1 10/3 13/19 82/6
87/12 95/5 95/9 108/9)
133/6 137/12 140/13
149/16 154/21 164/1
173/2 180/23 181/6
generally [7] 25/12
28/1 28/14 47/13
81/14 111/23 170/3
generated [1] 98/25
generation [1] 94/15
generous [1] 195/3
get [29] 9/22 21/13
21/15 21/16 32/25
34/9 51/17 54/7 69/24
76/10 82/2 82/17
83/14 104/8 107/19
116/12 122/20 130/17}
130/24 131/6 142/12
156/13 157/19 166/4
178/10 178/15 179/5
gain [3] 4/7 19/19
4/17 29/21 31/16 33/4
179/23 188/2
gets [1] 191/16
getting [8] 60/22
63/25 88/20 97/19
142/9 184/20 185/3
189/5
gift [1] 148/8
give [26] 1/10 7/2 9/1
9/18 9/24 22/16 33/13
42/12 60/17 73/10
74/23 92/7 106/16
124/12 124/13 129/7
134/12 148/18 156/21
157/4 162/20 172/10
174/11 175/16 182/14)
188/9
given [31] 30/5 30/12
31/24 34/6 34/10 39/4I
39/6 39/16 40/5 40/15
42/11 46/24 63/6 65/3)
74/15 81/25 105/4
113/12 127/7 148/10
151/16 155/22 156/4
156/20 157/2 159/24
162/3 162/23 169/8
178/1 178/2
gives [5] 67/2 77/22
86/13 132/23 177/19
giving [17] 4/24 5/13
41/22 44/4 45/12 61/6)
61/8 112/3 112/4
112/9 112/10 112/13
112/13 114/17 129/20)
144/19 195/3
go [45] 2/6 12/6
15/22 25/24 30/8
33/10 42/17 43/9 51/5)
51/7 63/1 65/5 72/17
74/17 75/5 80/24 81/8)
86/22 89/23 97/4 97/7I
97/14 99/13 105/20
115/18 124/8 125/8
129/22 129/23 130/9
134/5 141/9 146/24
148/10 164/6 165/6
165/12 167/9 172/1
175/1 178/13 178/15
180/19 181/1 186/11
goes [5] 32/24 85/20
90/21 110/12 173/12
going [38] 1/5 2/4 2/4
3/17 9/18 19/8 25/5
28/15 28/20 29/15
29/18 42/11 51/12
52/3 53/10 53/14
54/18 65/14 66/13
73/24 76/18 93/16
94/2 103/24 115/17
123/10 123/21 131/24I
135/21 136/23 151/21
159/4 167/8 169/25
170/4 179/12 183/3
190/15
gone [5] 114/14
(61) final... - gone
G
gone... [4] 125/11
147/6 151/4 180/8
good [13] 1/3 9/18
9/24 84/4 85/8 86/14
89/11 100/11 130/16
131/22 151/11 166/20)
167/1
got [14] 41/21 41/24
42/24 65/5 65/7 70/2
81/4 82/23 104/16
124/5 135/4 141/23
168/1 176/13
governed [1] 161/38
Government [1]
191/23
gradually [2] 87/13
194/3
grasp [2] 111/4 173/5I
grateful [2] 159/10
195/12
gravity [1] 90/17
great [1] 164/17
greater [2] 32/7
164/24
green [1] 188/9
grey [1] 113/8
Gribben [2] 186/17
186/18
ground [2] 110/13
143/8
grounds [5] 71/24
73/19 86/14 117/13
121/14
group [65] 35/5
35/15 52/21 52/24
66/1 92/23 94/10 97/7
97/13 97/15 125/20
128/3 137/8 137/8
139/5 140/16 145/5
145/7 145/22 146/18
147/11 147/13 148/17)
148/22 148/25 150/6
153/10 153/10 156/5
160/2 160/12 162/8
162/9 162/11 162/13
162/19 162/25 163/2
163/7 163/11 163/17
164/2 165/5 165/9
165/18 165/24 172/24}
174/10 178/11 179/4
183/21 183/22 184/1
184/1 184/11 184/11
184/25 184/25 185/3
188/1 190/18 190/25
191/19 193/16 194/2
groups [1] 93/4
guarantee [1] 162/3
guaranteed [1] 162/2
guess [3] 73/16
120/18 151/20
guessing [1] 130/12
Guideline [1] 116/7
guidelines [17] 70/25
116/14 116/16 116/19)
116/22 117/12 117/17)
118/11 119/14 120/5
120/6 120/6 120/9
121/5 121/21 122/3
123/4
guilt [1] 42/25
guilt/concern [1]
42/25
gulf [1] 134/7
gun [1] 110/24
had [124] 3/25 4/7
7/17 8/19 10/11 11/3
12/25 13/7 13/8 13/12
14/14 14/19 14/20
14/21 15/11 16/7
16/21 16/21 16/23
17/2 17/16 18/10
18/23 19/8 19/18
19/19 23/18 24/5
24/10 25/9 26/6 27/4
27/20 29/2 29/12
29/17 31/4 32/14 33/6
33/19 35/10 35/14
37/20 40/15 41/8 41/9)
42/1 57/25 60/20
62/23 62/25 66/4
68/18 74/19 78/23
80/7 80/21 82/16
82/21 86/24 87/25
88/24 90/5 90/21
93/22 96/23 96/24
99/11 101/16 102/9
103/5 104/18 105/24
113/20 113/23 114/9
114/11 114/14 119/2
121/6 121/8 122/1
124/20 126/10 127/17,
128/10 128/16 132/6
137/17 137/22 138/4
138/9 140/3 141/23
143/5 143/13 144/4
149/8 149/10 151/1
151/16 154/8 154/9
155/20 160/20 163/8
163/8 165/20 165/21
166/2 170/20 172/6
177/11 177/23 178/1
178/2 179/14 184/17
184/22 192/6 192/24
192/24 193/1 194/14
hadn't [1] 121/9
half [3] 49/8 141/10
195/10
halfway [1] 79/10
Hall [1] 157/23
Hamilton [2] 111/11
113/2
hand [10] 32/4 32/4
67/7 77/2 77/10 77/22
78/4 101/11 101/21
119/16
handed [1] 192/23
handful [4] 150/20
handled [3] 26/9 27/8]
190/17
handles [1] 137/15
handling [1] 138/6
hands [2] 9/9 137/17
hands-off [1] 137/17
hang [1] 80/8
happen [3] 67/3
168/15 170/22
happened [11] 5/12
11/24 15/16 16/2 24/5
53/15 88/24 104/15
110/21 129/9 190/11
happening [1] 60/5
happy [7] 6/22 9/21
11/2 30/7 43/1 71/25
188/9
hard [2] 2/4 11/8
harder [1] 183/14
hardly [1] 10/6
hares [2] 125/15
126/7
harm [1] 10/22
has [94] 1/23 4/1
4/16 5/8 5/11 11/24
14/3 14/8 16/2 17/25
18/5 18/13 20/6 20/16
23/21 26/2 26/15
26/22 27/10 28/21
29/6 31/7 31/9 35/6
35/25 37/3 39/3 39/16
40/13 41/5 41/11
48/10 52/11 56/1
56/22 69/9 70/25
71/10 77/3 81/10
81/12 83/10 84/13
86/3 86/9 89/10 93/13)
94/12 95/16 96/10
98/19 99/19 111/21
114/21 116/9 116/9
116/17 117/7 123/13
128/3 134/15 143/20
147/24 148/3 148/4
148/11 149/13 154/24
155/10 157/23 159/17)
161/2 162/9 169/9
169/15 170/17 170/21
171/22 174/12 175/8
177/15 180/8 180/9
181/13 184/7 186/15
187/1 187/3 187/6
187/23 188/11 190/11
191/8 191/15
have [295]
haven't [7] 48/13
65/7 112/12 113/5
124/8 143/5 155/20
having [22] 35/21
62/10 89/1 98/14
98/15 100/3 100/9
103/9 106/24 111/15
119/9 121/13 125/6
132/25 145/13 158/19}
175/19 176/8 177/17
181/4 182/14 182/21
he [83] 5/22 7/1 7/4
8/7 8/8 8/10 8/11
30/12 30/13 30/15
30/22 31/5 31/9 31/23
32/24 32/24 32/25
36/12 39/16 40/12
40/13 40/14 51/1
55/17 55/21 56/3 56/4
57/5 57/19 58/23 59/2,
59/12 59/13 61/2 61/4,
61/22 61/22 62/16
62/17 71/14 71/18
81/9 81/12 81/12
83/25 88/10 94/10
94/18 94/22 99/11
106/24 106/24 124/2
124/2 132/10 134/17
135/14 136/8 138/16
138/16 149/2 149/14
152/11 152/22 159/7
171/17 178/18 178/22)
179/19 179/20 179/21
179/23 180/9 182/7
182/12 182/13 186/21
187/3 187/5 187/6
189/16 190/4 190/7
He'll [1] 130/10
he's [3] 32/24 98/13
124/17
headed [2] 72/15
74/20
header [2] 78/23
95/24
heading [5] 68/7
80/10 108/19 109/2
160/15
heads [1] 174/11
hear [4] 1/3 1/6
131/22 194/23
heard [2] 2/25 133/7
hearing [1] 195/21
heavily [2] 146/12
158/20
held [1] 155/7
Helen [16] 3/17 4/1
4/16 5/25 6/22 7/4 7/9
94/21 96/10 98/19
100/17 100/20 100/23}
101/6 105/11 105/13
Helen's [3] 98/22
99/6 103/17
help [6] 44/2 75/16
111/25 133/1 133/6
142/18
helped [1] 150/4
helpful [2] 25/18
173/1
helpfully [1] 106/15
helpline [1] 117/8
hence [3] 48/13 66/7
194/7
her [13] 33/16 84/16
89/21 94/12 98/19
111/1 115/25 118/1
118/3 118/5 119/4
119/4 119/8
herd’ [2] 193/12
193/16
here [60] 9/7 12/5
12/10 12/23 26/22
28/8 30/10 37/4 38/5
44/12 58/15 60/2 60/5)
60/20 66/24 69/9
7117 73/24 74/17
75/16 86/23 87/22
88/14 93/8 96/11
97/19 97/25 104/11
104/23 106/10 106/15)
109/15 113/8 115/7
119/20 120/14 121/2
125/1 125/25 131/2
134/20 135/13 136/20)
140/5 148/21 150/14
151/9 151/15 161/11
165/16 165/18 166/14)
171/8 173/20 176/12
179/17 182/5 183/1
191/5 191/17
here's [1] 74/17
hesitation [1] 42/22
Hi [2] 89/5 152/12
high [9] 82/4 84/17
89/19 94/1 108/6
111/7 127/5 153/13
166/2
high-level [1] 108/6
high-risk [1] 127/5
highlight [4] 52/13
56/2 127/16 128/10
highlighted [3] 81/10
150/17 152/16
highlighting [2]
52/15 109/9
highlights [2] 10/20
127/21
highly [2] 80/5
170/22
him [8] 29/15 29/16
36/9 51/4 60/3 63/22
81/15 179/20
himself [2] 8/10
84/15
hindsight [1] 167/4
hint [3] 135/2 135/4
136/3
hinted [1] 139/6
his [22] 31/12 34/2
36/1 36/9 36/10 36/11
55/14 55/16 56/13
58/8 58/20 59/5 86/15
87/3 102/1 105/22
106/7 116/24 130/7
132/9 149/7 182/18
historic [10] 53/6
(62) gone... - historic
H
historic... [9] 70/23
71/5 77/14 86/15
109/8 109/9 117/16
123/4 175/3
historical [1] 8/18
historically [2] 52/20
177124
history [1] 192/5
hm [5] 21/9 26/19
76/17 176/5 179/18
hold [10] 27/9 27/11
28/11 43/4 93/20
104/20 123/10 131/6
138/25 191/17
holding [6] 51/5
51/16 53/20 54/15
56/18 188/13
holds [2] 51/8 54/16
holiday [1] 59/9
Holt [3] 83/1 83/25
85/6
honest [1] 9/4
Hooper [4] 83/17
89/13 145/5 165/10
Hooper's [3] 149/1
149/5 165/13
Hooper/Sparrow [1]
89/13
hope [6] 53/7 89/10
106/12 125/15 177/16}
178/10
hopefully [3] 9/18
9/24 52/4
hopeless [1] 164/22
Horizon [94] 3/4 3/7
3/22 5/1 6/9 6/15 8/19
9/8 9/14 9/20 10/1
10/8 12/3 13/16 13/20}
23/11 25/18 26/3
26/12 26/16 26/25
27/4 27/10 27/16 28/1
28/4 28/12 28/17 29/9
31/12 32/1 35/8 38/1
38/15 42/17 42/21
43/7 44/17 45/10
45/24 45/24 48/24
52/9 52/13 52/17
52/18 56/22 61/20
70/16 70/24 71/6 72/5
77/8 77/15 78/6 78/18
79/11 79/18 79/21
90/11 93/9 93/12
93/25 94/16 98/22
99/8 99/11 99/12
100/13 103/19 104/18
109/4 117/3 117/9
124/10 126/12 127/8
127/17 128/10 129/1
129/3 140/1 148/12
150/21 173/10 177/11
177/13 183/11 184/3
189/3 192/10 193/2
193/3 193/8
Horizon's [4] 11/23
12/9 15/5 16/1
horse’ [1] 125/16
Houghton [1] 178/18
hour [2] 195/8
195/10
hourly [1] 162/4
hours [1] 195/10
house [1] 3/16
how [49] 8/10 12/25
13/2 13/19 18/2 18/16
18/18 59/22 61/18
65/1 66/21 85/14
93/19 102/4 103/12
107/4 111/15 112/20
113/2 114/9 115/12
122/20 122/21 122/22)
134/18 137/14 137/16)
137/18 137/22 138/6
138/18 139/19 142/4
147/17 149/21 150/7
164/9 166/3 179/21
181/1 182/3 183/2
185/18 186/4 186/12
188/23 190/13 191/15
191/23
Howe [10] 94/20
95/15 95/16 96/2
96/20 97/4 97/6 98/20
101/1 102/22
however [21] 5/10
9/10 23/6 26/4 26/14
27/16 36/6 52/21 53/1
104/22 108/11 111/9
118/12 125/16 134/22)
137/8 155/11 161/18
164/4 165/8 170/15
Hugh [3] 85/18
107/16 107/24
human [1] 187/22
hundreds [2] 26/9
129/4
l accept [16] 7/24
16/8 54/1 59/22 60/9
61/8 74/2 74/24 75/1
80/15 98/9 113/8
114/19 128/12 140/8
157/14
ladd [2] 28/8 62/19
I adopted [1] 140/8
l agree [3] 30/23
164/1 187/10
lalso [6] 18/2 58/20
113/23 153/19 176/12)
183/12
lam [12] 8/13 13/24
29/18 30/6 30/7 30/10
57/9 62/16 89/9
101/23 152/18 159/23}
l anticipate [1] 51/25
I apologise [2] 44/15
149/6
l appreciate [4] 76/9
94/3 107/2 186/8
lask [2] 1/17 6/10
lasked [1] 189/16
l attended [1] 54/20
I believe [7] 27/23
80/22 80/24 97/1
116/3 121/13 181/3
lean [17] 4/20 14/25
18/2 18/16 64/2 64/18
76/14 105/20 124/8
125/2 131/23 147/1
151/13 154/7 164/4
185/2 186/1
Ican't [21] 17/18
17/23 19/13 24/21
27/23 28/18 64/16
66/12 81/20 105/18
106/14 106/20 135/13
137/20 160/11 163/15}
166/11 174/2 181/9
184/19 184/22
I cannot [3] 124/6
164/9 170/21
I clearly [1] 49/20
I completely [1]
169/10
I consider [3] 31/24
47/13 119/10
I considered [1]
121/21
I could [2] 37/23
132/20
I couldn't [2] 21/6
185/25
I created [1] 75/11
I did [5] 41/14 41/18
50/7 73/2 165/15
I didn't [7] 10/5 15/19
41/3 41/4 106/23
149/5 172/12
I disagree [2] 41/14
46/9
Ido [11] 5/8 5/9 31/1
34/8 46/18 97/6 97/14
100/15 102/15 119/1
191/21
I don't [77] 5/18 7/7
9/4 11/7 11/25 13/14
16/3 18/11 18/16
19/19 22/2 22/6 26/8
27/1 30/20 32/14 38/3
38/9 39/1 39/3 39/22
41/4 44/25 45/17
47/11 57/19 59/21
60/15 60/21 64/16
66/23 67/2 67/11 73/2
73/20 75/1 78/14
78/19 78/24 80/15
81/23 92/13 96/2 98/4
105/7 106/14 110/14
111/2 112/4 113/12
115/6 115/15 124/13
126/5 128/22 129/15
131/9 140/24 141/7
142/6 143/4 144/21
144/24 145/1 151/18
156/12 157/8 159/1
160/21 166/19 171/14}
179/6 180/18 182/22
186/25 189/8 194/16
I doubt [1] 133/11
I drafted [3] 53/19
54/1 72/12
lever [1] 54/11
l expected [1] 165/8
I feel [3] 104/12
166/8 183/14
I felt [3] 82/15 88/24
181/25
I find [1] 58/6
first [1] 172/8
I gave [5] 13/14
18/17 22/6 65/25
72/19
I generally [1] 47/13
I got [3] 70/2 81/4
82/23
I guess [2] 73/16
120/18
Ihad [12] 11/3 14/21
33/6 41/8 41/9 62/23
82/21 102/9 113/20
149/10 154/9 184/22
I have [20] 27/20
30/4 30/17 38/9 42/18)
66/11 71/21 78/7
95/13 97/3 105/17
119/1 124/6 145/11
152/6 152/16 170/19
186/23 189/7 195/8
I haven't [5] 65/7
113/5 124/8 143/5
155/20
I hope [6] 53/7 89/10
106/12 125/15 177/16}
178/10
lintend [1] 71/25
I just [4] 23/25 54/20
75/6 76/9
I knew [4] 28/13
29/20 179/20 188/25
I know [7] 5/1 30/16
33/15 106/17 153/5
166/1 167/20
like [4] 180/10
Host [1] 157/9
I may [2] 151/14
156/6
I mean [9] 7/22 63/23
72/9 73/24 74/14
103/4 115/11 119/22
136/13
I meant [1] 27/1
I might [1] 167/11
I misunderstood [1]
44/15
I must [1] 179/4
I never [2] 41/6 138/1
I note [3] 57/17 62/24I
100/11
I now [1] 173/4
lonly [1] 189/9
I personally [1]
178/19
I presume [3] 23/12
24/8 81/20
I produced [1] 82/14
Iread [2] 37/9 124/9
I really [1] 106/21
I recall [6] 38/3
133/21 151/22 153/8
182/2 184/15
I received [1] 33/8
I recognise [1] 166/9
Irefer [1] 115/8
I referred [1] 91/5
lregret [1] 121/12
I remember [1]
160/22
I remembered [1]
24/20
I report [1] 40/16
I responded [2]
81/16 119/4
I said [8] 42/1 44/9
45/1 63/20 65/13
115/17 136/16 151/8
I saw [1] 184/1
I say [12] 17/1 41/3
45/15 46/12 59/20
74/22 106/17 131/10
135/24 144/24 147/17)
157/15
Isent [1] 124/4
I should [1] 183/14
I started [1] 80/18
I still [3] 49/25
166/25 191/25
I suspect [4] 9/5 39/2)
63/11 146/23
I take [1] 76/4
I talk [1] 124/14
I think [152] 2/11
5/17 6/4 6/19 7/5 7/25
11/4 11/9 15/13 16/14I
16/15 18/19 19/1
23/17 27/12 28/14
29/4 30/20 32/21 33/6
33/16 41/2 41/24
45/17 46/21 47/17
47/20 48/1 49/19 50/2)
50/9 52/4 53/20 55/9
60/13 60/18 60/19
61/4 61/8 62/22 64/3
64/19 64/23 65/11
66/11 67/23 68/7
68/25 69/23 70/9
72/11 73/3 75/2 81/16)
82/20 84/9 84/11 85/2
85/23 87/2 89/9 92/2
(63) historic... - 1 think
I think... [90] 92/6
94/1 94/18 98/4 98/5
101/4 102/13 106/4
112/17 113/5 114/20
115/14 115/25 120/2
122/8 123/13 123/14
123/18 123/24 125/25
126/8 126/22 128/7
129/3 129/5 135/7
135/13 135/13 135/24
136/7 136/12 136/16
138/25 139/21 141/17)
141/23 143/4 147/6
147/10 148/6 149/1
150/5 150/17 150/23
151/19 151/25 152/22)
153/6 153/20 154/6
154/25 155/16 155/25
156/6 156/20 157/1
157/2 157/9 158/17
160/11 166/7 166/8
166/10 166/13 166/19
166/20 166/20 166/22)
166/23 167/5 168/22
169/7 169/18 169/23
172/17 173/4 177/22
180/11 181/21 182/8
182/8 183/9 184/20
188/12 189/22 191/5
191/6 191/9 191/13
194/25
I thought [5] 44/16
68/14 121/11 124/4
134/11
Ito [1] 60/16
I took [7] 24/13 26/17
35/12 89/25 103/12
103/12 105/8
I understand [3]
30/10 40/8 190/15
l understood [4] 14/6
15/7 87/3 121/8
I want [10] 5/2 43/14
65/18 66/2 71/16
100/17 100/19 110/1
124/9 124/11
I wanted [2] 10/8
174/10
I was [27] 3/3 6/6
10/6 24/17 32/9 32/11
33/18 38/10 58/3
59/20 75/23 75/25
76/9 80/6 82/11 90/21
91/2 105/10 112/9
118/3 136/20 138/11
140/16 154/2 155/19
160/11 160/13
I wasn't [5] 33/8
63/15 103/25 105/6
130/21
I went [1] 104/11
I will [5] 2/5 56/2
117/1 167/9 176/16
I wish [1] 167/4
I wonder [1] 82/23
I would [27] 7/15
7/24 30/23 33/13 42/3
42/12 43/5 46/20
46/25 49/19 54/24
59/15 61/17 63/7
63/11 63/20 107/18
108/14 112/18 114/2
148/15 159/10 168/21
184/20 189/24 190/2
190/9
I wouldn't [4] 53/18
64/17 120/18 166/12
I write [2] 14/12
20/10
I'd [16] 25/11 29/3
41/10 41/25 43/1
65/13 65/15 107/13
138/7 156/22 172/9
175/25 186/9 186/21
193/21 195/12
lil [9] 3/19 47/5 72/17)
81/2 163/22 167/9
167/10 192/2 192/6
I'm [61] 2/3 2/4 3/17
12/5 12/23 13/2 25/5
28/6 28/20 34/10 45/2
53/10 53/14 54/11
60/11 65/14 66/23
66/24 72/19 75/6 80/6
85/17 88/9 88/9 90/18
90/19 93/1 94/2 96/17
102/8 104/14 105/6
105/17 106/13 106/15)
106/19 110/19 112/4
1412/7 112/13 114/12
115/6 115/17 118/3
122/14 125/11 130/12)
131/9 132/15 135/3
146/7 149/6 151/9
151/18 157/3 159/4
167/8 170/25 179/3
179/13 182/22
I've [31] 7/18 10/13
10/13 13/2 43/12
62/25 75/15 84/21
86/23 98/10 104/15
106/12 106/12 106/13)
107/25 109/18 109/19)
115/3 115/9 125/10
125/13 125/15 130/7
147/23 150/16 153/17)
154/11 173/6 178/20
183/25 191/5
lan [1] 145/12
idea [9] 41/9 82/18
92/24 130/16 135/4
136/9 145/1 162/24
164/1
identical [1] 80/11
identification [1]
56/19
identified [7] 15/3
17/17 17/21 63/15
114/8 174/12 176/3
identify [6] 70/19
145/20 148/19 170/16}
171/22 175/1
identifying [2] 83/12
193/12
ie [9] 22/21 30/24
57/9 57/12 71/5 84/5
86/15 127/11 171/20
ie by [1] 86/15
ie Dr Jenkins' [1]
7115
ie effectiveness [1]
57/9
ie just [1] 84/5
ie ones [1] 22/21
ie those [1] 127/11
ie whether [1] 57/12
ie you [1] 30/24
if [210]
ignore [2] 65/16
117/10
ignoring [1] 113/24
ii [7] 96/6 110/12
148/11 159/19 164/2
174/22 175/9
iii [2] 40/12 175/10
1 [1] 119/9
ill-expressed [1]
119/9
imagine [1] 160/2
imbalance [1] 133/1
immediate [1] 175/2
immediately [3]
22/22 162/22 193/6
impact [4] 38/16 53/6
56/14 191/18
impacted [3] 12/25
14/1 20/4
impacting [1] 28/25
implementation [1]
159/12
implications [6] 25/6
82/1 84/13 94/14
109/22 178/24
implying [1] 6/17
importance [2] 80/16
92/5
important [16] 12/3
34/13 57/15 60/13
60/19 61/9 64/3 82/2
82/4 97/11 99/5 123/5
128/13 183/4 186/2
194/17
imposing [1] 165/16
impossible [3] 26/11
93/15 108/22
impression [10] 21/1
21/13 21/15 21/16
41/21 41/24 74/15
77/22 122/20 144/19
improper [3] 79/9
126/1 126/2
improve [1] 108/10
improvement [1]
83/10
improvements [1]
79/12
inaccuracy [1] 47/20
inaccurate [1] 47/22
inaccurately [1]
93/10
inappropriate [2]
114/20 114/25
include [6] 61/17
64/13 84/4 84/14 85/8)
162/7
included [5] 31/20
120/10 152/6 163/16
182/12
including [9] 33/23
57/1 116/14 120/13
120/16 144/3 170/3
170/11 173/9
inclusion [1] 87/23
incorrect [10] 175/5
177/25 178/1 178/2
178/9 179/15 180/15
181/2 181/18 184/17
incumbent [1]
128/22
incurring [1] 188/7
indeed [1] 6/9
independence [1]
142/12
independent [10]
52/11 105/17 113/16
140/2 140/4 151/1
151/17 153/2 156/16
157/7
independently [3]
20/18 105/19 164/8
indicate [3] 6/16 68/4
68/8
indirectly [1] 184/21
individual [16] 12/6
12/6 12/14 12/16
12/23 12/24 13/18
22/8 23/8 38/4 96/23
141/21 160/24 184/19}
193/25 194/4
individuals [5] 95/23
96/7 99/17 103/1
140/16
Industrial [1] 91/23
inevitable [1] 158/11
influence [1] 162/11
info [1] 150/18
inform [2] 175/17
176/8
information [68] 10/9
14/16 29/7 31/13
39/12 40/5 40/13 44/3,
53/21 71/2 71/4 74/23)
77/18 82/8 83/2 83/4
84/3 86/23 90/20 92/9
92/14 92/21 94/24
95/8 95/22 98/18
98/25 99/16 99/19
102/20 102/25 104/5
104/19 106/18 107/21
108/25 109/6 123/17
124/12 124/19 124/22)
128/6 129/1 129/3
129/18 129/19 131/6
138/7 138/12 139/21
141/20 144/8 145/11
150/15 151/3 154/21
155/6 156/22 159/17
172/3 172/6 172/11
172/15 178/2 178/2
186/13 194/15 194/23)
informed [3] 29/6
33/6 128/18
informing [1] 19/25
infrastructure [1]
140/1
inherent [1] 129/7
al [1] 30/17
initially [3] 3/13
154/16 156/9
initiative [2] 10/25
41/13
inject [2] 171/20
172/9
input [11] 58/1 74/21
74/19 78/7 98/11
130/13 170/17 171/2
171/9 171/22 172/2
inputted [1] 194/19
inputting [2] 74/10
173/25
Inquiry [10] 2/21 3/19}
4/18 28/21 39/16 41/9)
41/11 56/1 149/1
149/13
Inquiry's [1] 1/25
insert [1] 10/19
inserted [3] 118/8
154/24 155/12
inserting [1] 14/22
insertion [2] 14/18
77124
inside [2] 26/5 26/6
inspection [1] 27/15
instance [3] 108/2
154/15 156/8
Instead [1] 96/7
instruct [2] 88/11
88/18
instructed [6] 55/1
59/23 60/1 60/2 140/3
190/7
instructing [10]
55/17 55/19 57/7
57/21 60/3 60/6 60/14
60/24 64/8 88/11
instruction [5] 22/7
58/1 59/18 59/18
59/19
(64) I think... - instruction
instructions [11]
11/3 11/13 14/24
24/17 24/19 59/12
63/25 135/18 140/10
142/3 163/10
insufficient [1]
182/18
insurance [11] 42/17
43/1 43/12 44/7 45/6
45/22 46/11 65/13
70/3 74/24 82/19
Insurances [1] 66/3
insured [1] 67/15
insurer [16] 43/18
44/20 44/21 66/22
67/6 67/18 67/22
68/19 69/7 69/11 70/1
80/10 80/20 90/1 90/5
191/3
insurers [24] 42/21
43/3 45/8 66/7 66/20
67/1 67/16 67/25 70/2
71/24 72/7 72/13 73/8
73/25 74/23 76/16
78/11 80/3 81/4 81/11
82/3 82/5 82/19 82/20
integrity [17] 5/1
11/23 12/9 13/17 15/5)
16/1 25/7 28/17 35/8
94/16 98/22 100/13
104/18 129/1 139/17
184/3 184/6
integrity/remote [2]
184/3 184/6
intend [1] 71/25
intended [3] 69/4
73/14 140/20
intends [1] 8/19
intention [7] 18/22
21/23 22/2 52/6 69/10
160/7 163/9
intentionally [1] 18/9
interaction [1] 137/3
interest [15] 67/8
67/13 67/16 67/17
67/22 68/1 68/5 68/6
68/9 68/10 68/15
69/16 69/18 70/5 73/6
interested [1] 159/23
interim [10] 10/22
28/19 31/14 52/14
52/16 55/15 56/6
56/13 70/17 133/23
internally [1] 179/1
Internet [1] 124/10
interpreted [5] 16/14
39/13 42/2 92/13
109/9
interview [2] 116/25
117/13
interviews [1] 5/4
into [38] 3/23 10/7
11/19 14/18 18/10
29/11 29/12 31/13
42/24 48/21 48/24
60/4 60/8 61/10 61/23
70/9 72/5 74/19 79/13
86/4 92/12 113/7
115/2 115/5 115/6
119/4 134/8 134/25
143/6 143/7 160/24
166/19 170/7 173/12
173/25 175/6 177/2
194/19
intricacies [1] 110/23
introduces [1] 8/10
introduction [1] 8/12
invest [1] 193/19
investigate [6] 20/7
23/13 24/9 143/12
191/11 191/14
investigated [8] 14/9
14/20 18/6 18/13
18/14 18/21 147/4
147/5
investigating [6]
17/20 18/20 24/11
27/12 53/5 169/12
investigation [33]
3/22 4/1 10/20 14/10
14/14 17/13 17/14
17/15 17/19 17/25
18/10 18/23 19/10
20/8 24/14 24/16
52/16 70/17 72/5
116/13 119/13 120/5
120/6 120/7 120/9
120/11 121/5 121/21
122/3 140/4 144/6
147/3 158/24
investigation/Interim
[1] 70/17
investigations [21]
14/13 14/19 14/21
20/11 56/25 59/13
116/7 117/15 120/13
120/16 120/20 123/2
128/25 137/6 158/4
158/13 158/15 158/17)
160/23 174/9 176/2
investigations/prose
cutions [1] 137/6
investigative [1] 57/2)
investigative/prosec
utorial [1] 57/2
investigators [6]
140/3 151/2 151/17
153/3 156/17 157/7
investment [1]
193/18
involve [2] 59/4
63/23
involved [28] 2/22
3/1 6/4 26/2 26/15
33/15 50/22 59/17
62/20 64/10 64/12
86/21 86/25 87/15
96/7 97/19 103/25
104/4 104/23 106/10
109/7 158/19 168/7
175/19 179/21 179/23}
185/9 189/5
involvement [9] 3/4
32/15 48/12 62/23
97/18 102/9 106/7
106/12 115/25
irregularity [1] 11/11
irrespective [2]
37/21 120/22
is [603]
is' [1] 83/11
Ishaq [1] 57/18
isn't [23] 7/21 12/11
20/17 31/16 38/24
39/7 39/9 45/12 47/9
47/15 49/24 54/2 60/6
73/24 92/22 119/25
121/24 130/19 135/21
136/16 141/16 157/6
171/20
issue [78] 6/12 7/17
9/11 12/3 12/11 12/15)
12/21 12/22 13/11
15/1 16/10 16/21
17/16 17/22 18/1 18/4
18/5 18/13 20/22 22/5
22/20 22/22 23/23
23/24 29/2 29/10
38/15 42/10 42/18
56/22 58/23 65/13
76/6 87/22 88/1 90/14
94/2 98/22 99/4
103/15 105/23 106/23}
139/12 143/13 168/6
169/3 172/14 173/19
175/1 175/14 175/20
175/22 175/23 176/1
180/6 181/1 181/5
183/3 183/4 183/14
185/10 185/21 186/1
186/4 186/12 186/15
187/2 187/18 188/2
188/5 188/11 188/15
189/13 189/17 190/22)
191/8 191/11 191/12
issued [2] 187/21
187/24
issues [52] 5/2 8/18
8/20 14/2 23/8 33/4
33/8 38/1 42/21 45/22
48/10 49/1 52/13
52/15 62/2 62/10
63/15 63/18 63/21
67/1 82/6 82/14 83/13
90/22 93/19 94/16
104/11 105/8 114/8
117/2 117/9 117/10
142/15 144/1 144/3
144/14 148/19 150/16
174/11 176/3 176/4
176/14 178/14 179/21
179/24 191/9 192/15
192/18 192/21 192/23}
193/7 194/4
issues' [1] 194/3
issuing [1] 179/2
it [525]
it's [119] 3/22 5/17
7/19 7/21 7/22 11/4
12/2 13/19 14/4 15/21
16/15 16/15 18/3 18/7}
18/14 19/1 19/25
20/21 20/25 21/17
24/1 26/11 37/11
38/22 38/23 38/23
39/8 39/8 40/2 40/17
40/19 40/19 40/20
42/22 45/23 46/15
46/16 47/8 47/8 47/9
47IN7 47/18 48/1 48/1
48/4 48/5 49/3 49/23
49/23 49/24 50/2
51/16 51/20 54/14
59/24 65/3 65/14
65/15 66/2 68/7 68/7
69/5 69/5 69/21 72/8
74/8 76/11 77/23 78/8)
81/9 82/3 82/4 82/4
83/1 89/24 92/21
94/20 101/4 107/13
113/3 115/8 118/20
119/17 121/1 121/12
123/24 123/25 128/7
136/17 136/24 138/3
141/4 144/9 147/15
148/7 149/13 151/5
157/15 167/11 169/11
172/11 173/8 174/8
179/13 180/6 182/12
183/3 183/3 186/8
186/15 187/1 187/25
188/5 188/11 191/9
191/13 192/2 192/3
193/21
items [1] 142/20
iterations [1] 80/24
its [29] 7/11 25/6
39/5 43/18 56/11
56/15 66/5 67/16
67/22 67/24 68/24
70/18 80/16 82/13
86/5 86/11 89/7 90/5
94/25 96/8 98/23 99/3,
123/13 123/14 165/22}
168/3 183/12 188/6
192/13
itself [7] 5/12 7/19
123/16 165/5 166/18
191/10 191/25
qa
Jane [1] 174/7
January [2] 76/24
154/10
Jarnail [6] 50/24
50/25 86/1 88/5
136/25 137/1
Jenkins [42] 4/6 4/9
4/17 29/21 31/16 33/4)
33/7 33/24 34/4 34/8
34/13 34/21 35/1 35/6I
35/10 35/14 36/4 36/8
56/13 70/22 71/9 71/9
75/25 77/6 77/11
77/13 78/13 78/17
79/17 79/24 80/14
81/25 87/22 88/1
90/14 101/15 101/20
105/23 111/17 170/12)
170/12 170/25
Jenkins’ [11] 34/1
35/25 36/16 71/5
99/10 102/5 102/6
103/20 103/22 105/2
106/6
Jenkins/Fujitsu [3]
33/24 34/8 34/13
JFSA [2] 91/19
108/25
job [4] 37/22 88/7
106/2 134/25
jobs [1] 120/17
joined [4] 2/14
joint [2] 48/9 48/11
joke [1] 126/6
Jonathan [2] 186/17
186/18
Jonny [3] 190/3
190/4 190/6
judgment [5] 57/12
127/9 192/21 192/23
193/7
duly [31] 7/1 7/9
25/14 28/19 29/19
29/22 29/25 30/18
30/19 34/23 38/7 40/9
42/14 42/14 44/4
44/12 44/18 45/9
45/13 50/20 50/20
51/19 54/11 54/22
121/10 132/2 134/14
161/8 172/20 182/5
183/17
July 2013 [2] 44/4
44/18
jump [4] 115/17
June [5] 1/1 3/21
19/1 19/23 192/4
junior [1] 92/25
just [86] 4/9 6/3 9/5
9/6 10/25 13/3 22/6
23/25 24/24 26/6
26/17 32/12 33/20
37/11 42/11 47/5 48/5
51/8 51/16 54/16
54/20 56/2 57/23
58/10 59/11 61/11
66/19 68/7 73/3 75/6
(65) instructions - just
J
just... [56] 75/8 76/9
77/25 80/18 84/5 87/2
88/7 89/20 93/1 93/22
98/18 104/4 113/18
113/22 116/1 118/19
119/17 125/12 128/16)
129/7 129/12 130/19
135/9 135/16 136/5
136/13 138/9 141/15
142/12 142/24 144/9
147/6 148/16 150/17
151/18 152/23 153/18}
153/21 154/11 156/18)
157/3 163/22 165/4
166/2 166/16 168/21
171/8 173/6 177/13
177/22 186/12 186/21
187/23 191/1 194/18
195/13
justice [4] 9/9 37/14
134/24 137/13
Justice for [2] 9/9
134/24
K
Kate [1] 126/19
KC [2] 54/23 60/4
KC/QC [1] 60/4
keen [2] 86/17 150/2
keep [5] 41/13 92/21
118/18 161/19 190/6
keeping [1] 92/4
KEL [4] 129/24
129/24 130/1 130/4
128/2 128/14 128/19
130/10 130/12
kept [3] 24/25 45/20
49/13
key [20] 3/20 4/18
48/10 118/13 119/21
119/23 120/3 120/25
125/16 127/3 127/11
177/7 181/1 184/2
187/12 189/13 191/9
kicking [1] 22/14
kind [2] 49/18 191/24
kinds [4] 88/21
143/24 169/20 179/21
King [36] 30/4 31/5
33/9 33/23 34/5 34/6
34/10 34/11 37/17
39/18 40/1 42/4 51/13
71/22 74/11 75/17
76/2 76/23 78/8 86/1
88/5 88/15 95/14
96/14 98/11 98/12
100/3 102/9 102/12
103/7 103/25 109/20
142/25 150/4 159/1
159/1
KELs [7] 127/7 128/1I,_
121/19 121/22 122/12
King's [10] 29/21
34/25 55/15 56/7 59/7)
88/17 96/17 96/25
105/24 138/3
King/Mr Rodric [1]
76/2
knew [15] 19/9 28/9
28/9 28/11 28/13
28/16 29/20 60/17
62/16 105/23 105/24
174/25 179/19 179/20)
188/25
know [29] 2/21 4/23
5/1 11/8 24/24 25/20
30/16 32/4 33/15 40/2
61/4 81/13 106/14
106/17 118/15 124/9
124/11 124/21 124/21
126/5 134/5 139/19
153/5 154/1 157/8
166/1 167/20 168/19
186/25
knowledge [8] 1/21
43/17 71/5 90/4 95/4
137/22 137/25 177/13)
known [30] 3/19 8/2
14/11 15/16 20/9
21/20 26/23 29/19
36/8 52/9 62/16 99/7
103/18 123/21 124/19)
124/23 125/11 125/13)
125/19 125/21 125/23)
126/8 126/11 126/17
127/5 127/10 127/20
130/6 130/8 184/8
lack [7] 90/16 90/25
92/9 141/11 142/14
144/10 144/12
land [2] 158/3 158/12
language [11] 11/2
11/4 39/3 111/18
111/21 111/24 114/17)
147/24 169/17 178/15)
180/16
large [9] 2/3 5/10
23/3 93/14 134/3
134/6 156/10 166/5
191/7
largely [4] 59/25
60/14 63/25 88/9
larger [1] 23/5
last [20] 26/10 26/14
43/14 65/5 70/19
76/25 94/12 111/20
111/21 123/11 137/2
144/21 145/7 146/18
151/20 154/15 156/8
177/5 183/19 189/16
late [1] 143/16
lateness [1] 89/5
later [13] 3/13 11/20
23/16 32/24 45/21
107/2 117/11 183/2
191/15
latter [2] 57/15
112/12
latterly [1] 35/5
law [17] 30/8 46/5
60/17 71/22 75/18
90/19 93/2 98/11
105/8 106/10 111/5
114/6 114/14 115/7
law/disclosure [1]
175/15
lawyer [17] 27/20
32/25 51/2 51/11
94/18 95/16 105/7
118/4 151/3 190/4
lawyers [24] 3/16
11/5 16/16 37/10
39/24 43/1 43/10
43/12 59/16 60/18
64/5 68/25 73/17
100/10 104/12 105/3
105/9 106/5 106/18
115/9 125/24 138/1
138/8 165/22
lawyers’ [1] 106/9
layer [2] 143/8 143/8
lead [4] 105/9 136/14
148/5 187/6
leads [1] 16/25
lean [1] 131/1
leaning [1] 113/24
Learned [3] 107/20
108/8 109/22
least [10] 29/19
36/16 57/25 147/14
153/20 153/24 154/3
155/15 175/4 187/1
leave [4] 30/5 43/22
62/7 90/8
leaving [2] 133/7
174/20
led [8] 59/25 60/22
63/9 120/7 120/13
120/16 120/20 146/8
left [9] 32/4 77/10
77/25 78/2 78/9
119/16 146/12 194/4
195/8
left-hand [2] 77/10
119/16
legal [65] 8/7 8/9
8/15 17/1 48/12 55/2
65/2 66/8 66/15 66/18
66/21 67/5 67/10
67/11 69/5 69/10
69/17 69/21 69/22
69/24 70/7 72/9 73/11
73/14 73/17 74/2
74/17 74/21 86/7
66/5 68/16 89/16 94/6
175/15 176/10 176/11
64/21 64/22 88/9 92/6
105/18 105/21 106/14
90/24 91/15 91/16
95/25 99/21 99/22
112/20 113/2 113/7
113/9 143/1 143/7
143/8 143/9 144/3
144/5 158/6 159/20
159/23 162/9 163/4
163/5 177/6 179/23
189/22 191/11 192/1
193/14 194/5
legally [5] 16/12 67/8
69/13 70/6 108/20
legitimate [5] 118/12
121/14
length [1] 1/17
lengthy [1] 1/16
Lepton [3] 3/23 5/25
101/23
less [10] 16/6 73/23
85/1 167/3 180/24
180/24 181/7 187/25
193/17 193/17
Lessons [2] 107/20
109/22
let [6] 8/22 46/14
75/8 81/13 118/14
164/11
let's [33] 19/21 48/5
53/23 54/13 66/15
70/10 78/25 101/9
102/13 102/16 115/18}
117/19 118/22 119/16}
119/16 119/19 123/20}
125/8 126/14 130/3
135/9 141/8 151/24
163/17 163/18 167/16}
185/13 186/10 190/21
190/24 191/3 191/3
195/17
letter [60] 12/14 14/3
14/18 15/10 17/24
19/6 19/21 19/24
20/21 20/21 21/1 22/7,
30/2 31/20 42/16
42/20 51/5 51/6 51/8
51/15 51/16 51/22
51/23 51/24 52/5 53/9)
53/11 53/12 53/19
53/20 54/1 54/15
56/17 56/18 69/5
102/22 121/18 130/8
152/7 152/8 159/21
159/24 161/8 161/9
161/14 161/25 162/10}
172/22 172/23 173/2
177/4 177/5 177/16
177/22 178/10 179/11
179/13 180/6 180/14
180/19
letters [29] 8/22 9/5
91/25 92/18 93/2 93/3
184/21 184/24 185/10)
legitimacy [1] 119/19)
119/12 119/20 120/23)
10/10 10/13 10/14
10/16 11/5 11/7 12/5
12/6 12/10 12/13
12/23 13/8 13/18
13/21 13/23 16/16
17/7 19/8 19/15 19/18)
21/8 21/10 24/13
25/12 29/3 32/2
178/14
level [9] 13/14 18/17
72/18 72/19 82/5
84/17 91/1 108/6
111/7
leverage [1] 194/8
liabilities [1] 113/8
liability [4] 135/16
135/19 136/19 136/21
liable [2] 34/7 135/2
liaising [5] 51/4
51/11 53/16 53/23
54/4
liars [1] 111/14
lies [3] 182/17
182/20 183/6
light [9] 14/8 20/6
49/1 56/12 86/5 96/2
188/9 190/14 191/13
like [39] 3/16 8/25
37/16 40/24 42/12
47/11 61/17 61/22
65/15 66/7 66/14
66/18 67/4 67/9 67/11
72/9 83/7 104/12
104/22 106/17 107/14)
117/24 126/1 126/4
128/22 130/18 131/8
140/20 151/13 153/18}
180/10 186/9 186/21
189/24 190/2 190/9
193/21 194/16 194/18)
likelihood [1] 174/22
likely [17] 7/8 7/11
7/21 17/15 57/13 59/4I
63/4 63/6 73/18 117/4I
127/8 143/2 155/22
188/1 188/8 189/24
195/15
limbs [2] 164/5 164/6
limit [2] 38/14 61/25
limitation [2] 99/3
175/11
limited [7] 8/18 10/8
59/14 120/12 159/15
164/4 170/19
limits [1] 94/13
line [7] 84/4 85/8
115/6 120/19 165/2
169/6 182/12
lines [7] 84/9 84/18
87/7 131/1 131/41
140/22 140/25
list [10] 28/8 53/14
62/19 130/13 146/14
150/9 152/13 166/7
(66) just... - list
L
179/6
listen [1] 117/1
igants [1] 141/13
litigation [37] 26/2
27/21 38/16 44/1
73/6 73/18 73/20
121/3 123/6 125/20
126/16 128/4 128/22
140/6 151/6 172/24
183/21 183/25 186/2
186/5 188/1 188/15
189/13 190/18 191/1
191/8 191/9 191/16
191/19 191/24 192/5
193/2 194/10
little [3] 62/23 105/5
117/22
live [4] 137/5
local [1] 29/1
locate [1] 49/10
log [10] 123/22
130/6 130/8 139/8
logic [1] 9/4
logical [1] 28/3
logs [12] 4/4 4/22 5/2
6/15 6/16 101/13
101/23 102/2 127/6
long [7] 7/19 63/2
113/6 117/13 119/25
132/13 164/18
long-winded [1]
132/13
look [73] 7/2 8/5
13/21 17/10 19/21
30/17 33/21 34/17
38/12 42/16 42/24
43/2 43/14 43/16
A7INT 48/5 48/22
51/15 61/24 63/13
65/16 66/7 66/14
66/16 66/18 67/9
67/11 70/10 71/16
76/11 78/25 85/21
90/3 100/17 100/19
101/9 101/20 101/24
102/13 102/16 107/14}
117/20 123/20 123/21
124/9 126/14 127/23
130/3 130/22 131/11
141/8 141/9 142/21
143/6 143/13 145/24
150/8 151/13 151/20
151/24 151/24 153/18}
156/7 159/5 161/1
163/17 163/18 172/18}
list... [2] 166/13
listed [2] 141/5 146/4
lists [2] 38/19 166/10
46/24 67/9 69/16 70/5
125/14 125/19 125/22)
125/23 126/11 126/17)
127/11 127/20 127/24)
180/20 182/7 186/12
194/13 195/1
looked [10] 7/18
37/16 42/18 43/11
66/11 86/4 89/23
102/1 103/9 121/13
19/14 20/14 28/6
29/10 29/12 33/18
53/4 58/9 60/7 61/11
61/23 81/21 82/22
88/18 92/8 106/1
142/24 150/2 162/25
166/14 185/7 185/8
185/13
lookout [1] 97/24
looks [8] 59/10 60/4
80/9 81/17 83/7
loop [4] 183/18
lose [2] 132/13
164/15
losing [2] 120/17
148/5
154/19 155/4 156/9
170/2
losses [7] 5/10 8/20
33/25 169/25 171/16
188/7 188/8
lost [2] 39/3 157/9
lot [17] 72/22 77/10
137/16 144/7 148/6
153/12 167/1 177/25
180/10 183/5 184/20
185/16 185/18 186/3
lots [5] 35/17 59/5
low [4] 165/3 165/17
166/15 174/23
lower [1] 193/18
lowered [1] 165/11
LPP [4] 73/25
lucky [1] 179/3
lunch [4] 94/7 107/5
107/7 131/13
Lusher [1] 95/1
Lyons [1] 107/16
M001 [1] 139/14
Mo02 [1] 164/25
M014 [2] 138/20
139/13
MO056 [1] 170/9
MacLeod [1] 174/8
Madam [1] 79/4
made [50] 10/15
10/18 14/3 17/11 19/9)
60/14 77/4 78/23 79/7
79/12 79/14 80/7
looking [31] 7/8 18/3
112/24 114/16 121/11
128/15 129/10 141/19)
118/11 119/19 120/23)
loss [6] 19/18 154/16
151/21 151/22 151/23)
123/17 152/24 164/22)
84/25 89/16 95/16
95/20 96/12 96/14
96/16 96/18 101/21
102/18 103/5 103/7
103/8 105/13 105/21
121/4 121/4 125/3
125/13 126/5 134/17
151/2 158/8 160/3
162/8 170/13 175/8
180/15 181/2 181/13
184/7 184/9
Mail [4] 35/5 35/15
52/21 52/24
main [6] 3/4 3/12
4/21 87/16 158/3
158/12
mainly [1] 33/18
maintain [1] 11/10
maintains [1] 96/8
major [1] 127/21
majority [3] 133/14
133/25 177/6
make [19] 9/11 9/16
43/25 69/2 71/3 76/14
77/17 102/17 108/21
119/6 119/15 145/8
146/19 159/25 178/10
178/25 190/13 191/14
191/22
makes [6] 5/5 9/6
73/18 112/5 168/22
193/17
making [15] 16/6
16/12 16/18 51/11
69/20 73/23 106/8
113/25 174/22 178/8
179/13 180/3 184/16
188/22 191/17
man [2] 110/25 179/3
managed [1] 108/17
management [2]
92/15 184/15
Manager [2] 117/1
187/16
managing [3] 87/11
185/5 186/18
manifested [1] 22/20
manner [1] 159/11
manual [1] 168/2
manually [3] 6/18
187/11 189/11
many [7] 28/21 35/5
35/14 128/24 147/17
155/6 176/9
March [8] 48/20
65/20 71/15 80/19
138/13 138/14 170/7
172/14
March 2015 [1] 170/7I
marching [1] 94/4
mark [13] 10/14 69/1
152/3 152/10 153/4
105/25 106/25 108/25
177/14 177/23 179/14
163/20 167/15 168/7
168/8 168/20 169/15
179/5 179/17
mark-ups [1] 10/14
Mark/Paul/Andy [1]
152/3
marked [1] 73/5
marking [1] 69/2
Martin [9] 34/19
136/24 137/1 149/14
150/4
Martin's [2] 84/22
85/4
Maru [1] 100/18
massive [2] 129/4
150/15
massively [1] 194/7
matches [1] 173/7
material [13] 36/8
36/17 36/24 40/4
40/10 89/18 89/22
89/22 96/3 98/18
99/19 143/21 150/3
materially [1] 175/5
materials [2] 49/10
49/12
matter [21] 6/9 11/14
12/17 24/21 37/16
37/23 45/5 48/4 48/17
79/6 95/7 97/6 97/6
97/14 97/25 100/15
121/16 121/16 122/10}
131/3 133/17
matters [28] 2/6 3/8
13/6 13/9 13/13 13/16}
19/10 51/24 53/8 54/5)
54/8 56/2 56/9 60/23
87/20 97/18 98/5
106/10 109/13 109/14}
114/5 114/15 115/7
115/8 134/15 142/22
159/15 176/10
Matthew [1] 48/7
Matthews [10] 3/10
30/12 33/3 33/11 55/8
58/5 58/15 60/25
61/14 132/7
may [67] 5/13 8/23
12/21 18/18 20/3
27/15 32/15 34/3
34/12 38/15 43/23
64/18 67/15 70/20
70/22 71/6 75/6 76/6
77/7 77/13 77/18
78/17 79/17 79/24
85/15 92/3 92/4
108/21 109/5 110/2
4117/2 117/11 118/13
125/5 127/16 127/24
128/6 128/9 133/5
133/16 135/5 136/3
139/18 142/15 143/9
143/22 144/14 146/11
39/16 42/3 83/2 89/19)
146/14 148/6 149/19
151/14 153/19 155/14)
155/19 156/6 156/22
161/21 164/24 166/8
166/8 175/6 175/13
175/16 183/10 186/10)
188/6
Maybe [1] 122/14
McColl's [2] 187/25
188/12
McCormack [1]
123/24
MD [1] 168/20
me [59] 1/3 7/3 8/23
9/1 9/5 9/21 14/16
22/16 23/18 24/17
30/5 30/20 37/16 39/4I
40/16 45/19 46/14
46/19 47/3 47/11 57/8
57/21 62/16 62/18
62/25 63/9 65/7 75/8
80/15 81/13 81/23
96/15 98/4 98/5 102/1
103/8 103/9 104/13
106/24 108/1 118/14
124/12 124/14 124/15)
124/15 125/3 130/19
131/22 138/1 138/11
143/5 144/22 163/6
169/15 172/12 187/3
188/9 189/16 195/13
mea [1] 180/13
mean [20] 7/22 35/24
42/2 63/23 65/4 67/13)
7219 73/24 74/14
99/22 103/4 115/11
119/22 126/7 136/13
168/11 177/20 182/23}
189/3 193/24
meaning [1] 169/9
means [9] 35/24
69/21 105/17 131/2
164/21 175/2 176/19
189/4 193/17
meant [4] 27/1
147/13 184/14 193/12!
media [7] 108/25
111/3 133/13 135/7
136/12 179/7 185/5
mediate [3] 165/22
166/6 166/14
mediated [1] 134/10
mediating [4] 164/20
164/21 164/22 164/22)
mediation [42] 71/14
83/15 108/17 115/4
123/16 132/18 132/19}
132/20 132/21 133/2
133/8 133/9 133/19
133/24 134/5 134/6
134/12 134/18 135/21
135/24 136/1 136/14
136/17 137/3 141/3
145/9 145/17 145/21
(67) list... - mediation
mediation... [14]
145/23 146/5 146/20
146/25 147/6 158/18
158/19 158/21 165/12)
165/19 166/17 166/25)
170/1 182/11
mediations [3] 133/4
133/14 133/25
mediator [2] 132/25
192/24
meet [1] 48/9
meeting [25] 30/19
30/21 33/5 39/18
40/25 50/1 51/19 54/8
54/19 90/11 90/11
92/23 139/5 141/3
141/6 142/25 143/1
143/22 144/23 144/24)
145/9 145/18 146/20
157/10 174/10
meetings [9] 39/23
41/15 41/20 41/22
49/23 50/8 158/8
183/19 184/22
Mel [1] 167/25
Melanie [5] 157/25
167/15 167/16 168/7
169/4
members [4] 91/23
104/9 140/18 157/24
memory [5] 62/7
67/19 81/16 114/13
153/25
mention [2] 87/22
143/16
mentioned [4] 22/13
51/1 85/18 93/22
mentioning [1]
128/16
mentions [1] 15/15
meritorious [3] 165/2
165/6 166/15
merits [2] 67/3
123/14
message [5] 32/3
125/16 158/3 158/12
184/24
met [3] 33/16 37/6
54/12
mid [1] 176/18
mid-afternoon [1]
176/18
middle [6] 48/5 89/25
94/9 110/13 168/6
191/7
might [32] 21/13
21/15 21/16 22/14
39/5 39/13 43/4 45/24
62/7 68/5 68/6 70/4
85/18 87/23 107/1
111/25 124/24 129/13)
131/7 131/7 131/12
151/5 156/6 160/3
193/8 195/5
mind [14] 9/21 26/9
28/2 37/15 69/14
76/10 103/4 108/1
126/9 130/16 154/8
154/9 184/18 192/22
minded [1] 146/1
mindset [2] 123/8
123/8
minimise [1] 82/9
minimum [1] 162/2
41/17 41/19 45/19
47/18 47/19 47/20
47/22 47/25 48/2
49/21 49/25 50/2 80/8
minuted [2] 40/17
40/20
minutes [17] 38/12
39/20 39/21 39/22
40/22 41/3 41/4 42/3
44/8 44/17 44/22 45/1
45/2 45/13 45/20 47/6
50/5
minutiae [1] 189/5
minuting [2] 41/15
50/7
miscarriages [1]
37/13
misinterpreted [1]
5/13
misleading [2] 80/5
99/3
mismarking [1]
103/11
mismatch [1] 28/25
Misra [10] 25/21 26/1
28/6 28/10 29/15
29/16 93/18 104/20
111/10 113/2
missing [1] 96/3
mistake [1] 106/5
mistakes [1] 168/17
misunderstood [1]
44/15
Mm [7] 20/19 21/9
26/19 69/19 76/17
176/5 179/18
Mm-hm [5] 21/9
26/19 76/17 176/5
179/18
model [1] 83/14
modest [2] 192/20
193/10
moment [7] 40/22
107/1 123/11 131/12
175/19 194/20 195/5
money [4] 111/1
124/9 124/13 193/20
monitor [1] 79/8
month [5] 52/14
134/18 143/12 144/18)
167/11 178/10 192/20)
minute [15] 39/1 41/6)
90/18 151/25 156/6
172/17
months [6] 10/7
22/15 23/7 23/16
108/16 141/24
Moran [1] 178/22
more [74] 4/6 9/22
10/9 11/10 23/8 25/3
30/24 32/19 35/17
42/20 52/1 53/7 57/19
58/10 59/4 59/11
60/15 62/16 63/24
73/18 73/23 77/1
77/10 77/11 84/12
85/21 85/24 89/20
92/24 92/25 94/2
101/15 105/5 105/10
106/6 106/20 110/21
111/23 111/24 113/24
117/4 128/6 129/5
130/6 130/22 134/12
135/14 136/1 136/18
139/13 139/21 139/22
141/21 142/15 144/14
144/19 146/12 153/12
153/24 160/22 166/23
166/24 167/23 168/5
174/24 176/16 182/8
182/8 184/4 192/11
193/19 194/3 195/3
195/10
morning [13] 1/3 1/5
40/9 50/10 86/17 94/3,
97/17 107/3 107/18
109/11 151/15 186/9
189/9
most [8] 116/21
117/13 123/1 150/20
169/7 192/17 195/8
195/10
motion [1] 37/25
move [10] 50/19
115/18 131/2 131/24
136/23 146/10 159/4
167/8 167/12 170/4
moved [2] 134/8
141/24
moving [4] 7/25
141/1 145/2 181/11
Mr [22] 1/6 1/9 1/12
40/6 55/1 55/7 55/13
55/25 61/6 75/5 75/9
75/15 76/2 76/4 76/7
80/12 83/25 83/25
86/10 131/24 195/12
196/4
Mr Altman [6] 55/1
55/7 55/13 55/25 61/6
86/10
Mr Andrew [1] 1/6
MR BLAKE [5] 1/9
75/5 76/7 195/12
196/4
Mr Clarke [1] 40/6
Mr Edwards [1]
83/25
Mr Holt [1] 83/25
Mr Parsons [4] 1/12
75/9 76/4 131/24
Mr Rodric [2] 75/15
80/12
Mrs [1] 124/15
Mrs Bogard [1]
124/15
Ms [4] 99/15 100/18
102/24 117/19
Ms Maru-Singh's [1]
100/18
Ms Prime [1] 117/19
Ms Robinson [2]
99/15 102/24
much [24] 1/5 5/17
33/4 40/24 44/9 70/9
84/2 84/14 85/5 89/23
90/1 105/10 118/20
131/18 141/19 141/20)
158/11 164/3 172/12
175/13 176/22 184/4
185/5 195/19
multiple [1] 23/11
must [4] 36/6 37/4
89/9 179/4
mutual [1] 157/20
my [91] 2/6 4/21 5/10
8/12 9/16 10/7 11/15
11/21 13/9 14/24
15/24 16/25 19/17
23/4 23/4 23/17 23/25)
24/1 28/8 32/14 33/13
42/22 44/9 47/1 49/19)
53/14 57/12 58/7 59/2
59/22 59/23 62/7
62/19 62/22 68/14
70/1 73/22 75/19
76/10 77/25 81/16
87/25 89/14 97/9
97/24 100/9 106/12
106/21 107/20 110/8
110/9 110/12 112/6
112/14 114/22 115/21
118/4 119/1 119/2
119/5 119/14 122/6
122/6 122/15 124/7
124/12 124/14 124/24]
132/10 134/2 137/12
137/25 139/23 140/12)
150/1 151/10 151/20
156/4 156/11 157/10
163/12 163/12 164/25)
165/1 165/23 173/20
178/23 180/14 183/9
183/13 183/18
myself [3] 6/22 138/2
170/3
N
name [12] 1/10 8/12
19/22 26/23 51/1
101/6 101/19 102/3
102/6 103/22 105/2
106/6
named [5] 38/7 95/23}
99/17 103/1 114/20
namely [1] 81/3
names [2] 20/1
166/12
narrow [1] 157/12
nature [11] 10/5 24/1
65/3 67/25 68/24 93/9I
108/11 150/25 151/8
159/15 174/4
nearly [2] 146/14
150/21
necessarily [1] 27/5
necessary [4] 42/23
91/24 92/16 96/6
need [35] 5/18 27/17
30/24 32/2 32/18
38/14 45/4 49/11
57/19 59/8 61/25
73/19 83/13 93/5
101/5 105/1 105/12
106/16 108/15 109/10)
127/25 130/13 130/15}
133/13 135/7 136/12
139/18 142/22 156/16)
158/9 167/21 173/23
175/16 179/7 189/22
needed [6] 32/7
155/6 156/22 157/13
163/7 180/19
needs [12] 33/21
51/7 58/22 67/3 84/11
85/23 88/5 97/7 97/14)
130/9 159/14 190/23
negative [1] 117/24
net [1] 187/19
Network [1] 79/8
never [11] 41/6 138/1
158/6 168/1 170/4
177/11 187/14 193/23)
194/12 194/22 194/23)
nevertheless [4]
6/21 14/22 162/11
171/13
new [14] 25/5 47/1
79/5 93/24 115/16
127/16 128/8 128/10
129/7 163/14 171/2
171/9 172/2 172/4
Newcastle [1] 8/14
newly [2] 115/22
117/25
news [1] 172/4
next [14] 8/15 22/17
33/17 37/1 51/20
54/19 67/3 84/7 87/5
127/6 137/2 148/7
172/17 193/11
night [3] 111/20
111/22 189/16
no [67] 7/7 9/10 11/3
(68) mediation... - no
N
no... [64] 11/3 21/3
23/8 26/12 26/14 28/3
31/25 32/16 33/18
37/3 38/9 39/15 41/2
41/9 42/9 43/7 45/14
45/17 47/17 52/17
68/11 79/12 87/21
89/16 92/11 92/23
99/12 102/9 105/17
106/24 112/13 120/9
121/3 122/14 122/14
128/1 130/6 137/9
137/10 141/7 144/17
145/16 148/4 148/11
151/18 154/9 157/1
161/18 162/3 162/9
163/12 164/2 166/19
168/3 168/13 169/6
182/14 187/10 189/16)
190/7 190/12 194/13
194/16 194/25
nobody [3] 103/16
124/1 142/24
nodded [3] 7/20
21/11 185/17
non [5] 94/15 158/10
164/20 164/21 166/6
non-case [1] 158/10
non-criminal [3]
164/20 164/21 166/6
non-disclosure [1]
94/15
normal [1] 6/15
not [249]
not' [1] 40/20
note [35] 2/6 24/1
47/3 57/17 58/22
59/15 62/24 66/3 66/4
66/19 66/24 67/1 72/3
72/8 73/3 73/4 73/21
74/9 74/13 75/2 79/21
81/17 82/19 89/6
98/10 100/11 116/22
127/13 148/16 154/25
155/16 170/13 173/19}
183/18 190/11
note’ [1] 73/12
noted [2] 70/13
104/15
notes [4] 32/24 84/16
87/7 141/8
nothing [10] 42/5
42/20 98/19 110/10
112/14 114/23 117/24}
158/5 158/14 158/22
notice [9] 42/21 79/6
159/21 161/11 161/13)
161/16 161/20 161/22)
162/12
noticed [1] 147/23
noticing [1] 25/2
notification [21]
16/22 43/16 43/20
43/24 44/1 45/7 65/13
66/6 66/21 70/1 71/15)
72/7 73/25 74/22
78/25 79/1 82/3 90/3
90/7 90/15 191/2
notified [2] 43/18
90/5
notifies [2] 43/22
90/8
notify [5] 43/3 44/20
45/11 66/20 70/2
notifying [4] 66/25
68/18 71/23 90/1
notionally [1] 148/11
notwithstanding [1]
36/24
November [5] 125/20
149/12 177/3 180/21
181/13
November 2016 [1]
125/20
now [112] 4/21 5/15
10/10 10/12 14/12
17/18 19/13 20/10
20/14 23/19 24/23
25/14 27/11 28/18
29/21 34/14 36/21
36/24 37/13 42/12
45/21 48/4 48/14
50/25 50/25 51/4
51/10 53/4 55/23
59/24 61/11 61/13
62/12 65/7 65/14
65/15 66/3 71/5 71/16
76/22 80/15 81/5
81/21 81/23 82/23
83/11 83/15 85/13
86/3 86/17 86/19 92/8)
93/16 94/1 97/14
99/22 102/4 102/15
106/4 107/15 109/25
110/2 111/15 114/8
115/17 118/10 118/17)
121/12 121/17 122/10)
126/16 127/14 130/8
132/18 133/25 137/5
138/13 141/1 143/20
145/2 147/20 150/8
152/1 157/3 158/3
158/13 159/6 160/4
162/25 163/15 166/12)
166/16 167/8 168/19
168/19 172/13 172/19)
173/4 175/21 177/3
177/15 177/16 181/9
181/11 181/12 181/14)
183/2 184/4 184/22
186/7 186/24 190/8
nuance [1] 65/10
number [33] 1/24
7/18 8/1 8/2 8/18 22/4
27/8 35/10 35/17
36/21 37/2 37/25
52/15 56/9 56/21
65/21 74/19 93/14
108/13 115/17 133/21
145/25 145/25 146/1
150/18 151/11 162/23}
166/2 166/5 166/10
174/12 175/20 191/5
number 1 [2] 7/18
145/25
number 14 [1] 8/1
number 3 [1] 145/25
number 5 [1] 146/1
numbers [2] 166/10
166/12
[e)
objective [1] 142/18
obligation [3] 70/25
77/3 161/18
obligations [3] 34/2
89/14 109/23
obliged [1] 109/5
Obody [2] 124/1
125/3
observation [1]
13/19
observations [5]
55/14 55/24 56/3
58/20 59/1
obsession [1] 90/23
obtained [1] 192/6
obvious [1] 48/1
occasion [3] 15/12
49/20 64/1
occasionally [1]
179/23
occasions [1] 155/9
occur [2] 159/15
195/15
occurred [5] 4/7
21/18 23/15 101/16
110/3
occurrence [1]
154/21
occurring [1] 5/9
October [11] 83/23
85/13 85/13 86/20
91/5 115/19 145/3
147/1 147/20 147/20
149/9
October '14 [1] 147/1
odd [1] 30/5
off [9] 45/7 124/7
124/20 137/17 173/4
187/19 188/13 188/20}
191/17
offences [4] 35/4
52/20 52/25 111/13
offer [3] 114/14
135/2 148/20
offered [1] 64/18
offering [1] 64/23
offers [1] 164/2
office [267]
Office’ [1] 162/8
Office's [36] 8/15
9/13 10/20 17/2 42/21
51/11 52/8 53/16 66/6
66/20 86/4 86/7 92/1
93/21 94/14 97/8
97/11 97/20 98/2
99/11 99/20 108/9
111/21 116/13 133/12
134/3 138/5 145/17
145/23 148/10 151/3
157/4 159/16 175/3
192/18 194/5
Officers’ [1] 82/20
offices [1] 79/9
often [2] 69/1 70/15
okay [11] 19/21
46/14 53/23 54/4
54/13 54/22 75/4 78/3
81/17 119/24 120/12
old [3] 171/2 171/8
177/13
Oliver [2] 65/19
71/13
omitting [1] 95/8
on [364]
once [8] 24/3 71/25
115/1 128/15 139/18
167/19 168/14 175/13}
one [73] 4/18 7/23
9/19 9/25 12/15 12/24
18/1 19/18 19/18
20/17 21/14 22/4 29/8)
29/15 35/17 37/7
37/25 43/1 43/12
45/17 53/19 53/19
54/1 64/23 65/22 66/2
68/1 70/3 70/21 73/19
77/6 7/12 77/21
77/23 77/25 78/1 78/4,
78/4 78/8 79/16 80/9
80/11 83/3 83/3 83/8
83/8 85/7 89/4 89/4
90/18 90/20 94/2
103/10 112/25 117/22}
126/1 132/17 133/3
133/24 141/13 143/18}
148/11 152/16 160/16
162/6 164/11 167/12
169/6 187/19 191/8
194/13 194/25 195/8
ones [8] 22/21 23/3
23/5 38/4 59/23
146/12 147/13 151/6
ongoing [5] 53/6
108/13 109/8 125/22
188/14
only [37] 10/6 17/15
21/14 21/17 21/25
23/8 23/15 24/2 42/22
44/6 50/2 57/8 62/18
62/24 74/10 77/23
78/16 79/24 93/4
95/20 102/18 107/2
109/13 122/1 122/2
122/12 128/4 142/25
143/5 150/20 155/7
155/19 156/4 165/2
183/6 186/9 189/9
onto [2] 123/11
172/19
onwards [1] 131/5
opaque [1] 130/25
open [2] 93/13
192/11
opened [1] 81/18
opening [2] 10/19
112/5
openly [1] 25/19
operating [1] 155/11
operation [1] 35/7
operational [2] 5/3
190/16
opinion [5] 31/12
36/9 88/16 148/18
148/20
opinions [1] 114/15
opportunity [5] 42/12I
63/1 117/5 132/24
170/20
opposed [1] 64/24
opposite [1] 130/19
option [4] 9/10
112/16 112/17 112/24]
options [3] 112/11
112/13 132/17
or [133] 4/11 4/12
6/22 8/1 9/1 15/17
16/17 16/21 23/23
26/23 27/5 29/8 30/5
30/8 32/13 36/1 36/13
39/2 40/2 40/11 45/20
53/1 53/6 53/19 53/24I
54/20 55/2 55/3 56/13}
56/20 57/8 57/10
58/24 60/8 60/16 62/5
67/3 67/3 68/10 68/23}
69/11 71/7 71/9 71/12)
72/20 73/22 73/23
76/1 76/6 76/23 77/19
78/9 80/16 81/14
81/17 82/21 84/7 85/5
85/20 86/9 86/25
89/22 91/16 92/4 95/4I
98/1 98/2 100/6
102/10 104/1 105/20
107/21 109/1 109/4
110/11 110/15 110/15)
116/24 117/2 117/24
118/1 119/8 123/10
124/1 124/25 126/5
127/21 128/11 128/16)
130/25 131/6 140/10
140/21 142/3 142/12
143/2 143/14 149/20
149/21 153/20 155/4
155/15 156/22 156/25
160/10 160/12 161/20)
(69) no... -or
[e)
175/4 178/2 178/5
182/23 182/23 183/6
192/20 193/9 193/14
194/9
oral [1] 31/8
order [7] 48/19 74/1
74/20 95/7 97/5
100/11 103/2
orders [1] 121/3
ordinarily [2] 46/20
49/19
ordinary [1] 11/4
93/5 183/12 191/10
191/13
organisations [1]
52/23
original [10] 76/1
78/9 81/1 83/8 85/2
100/23 101/22 106/5
128/2 149/19
originally [3] 80/21
85/12 129/25
originating [1]
173/16
other [40] 12/20
12/22 13/3 13/6 13/9
13/13 17/7 17/10
17/11 21/4 21/20
25/21 26/1 28/11
28/13 28/14 29/8
29/12 46/24 47/23
47/25 53/21 78/9
94/21 104/20 115/5
115/25 123/18 123/19}
127/10 127/20 140/18)
159/15 161/20 163/10
164/5 167/12 174/16
182/9 187/8
others [6] 126/18
130/5 149/14 150/13
158/2 174/8
others’ [2] 98/14
100/7
otherwise [6] 9/13
9/20 10/1 118/15
133/16 149/19
ought [3] 37/3 55/21
182/10
our [48] 5/3 5/24 6/1
9/20 10/1 13/25 14/12
20/10 25/19 27/8
33/14 42/17 43/1
43/12 43/23 48/19
50/10 64/8 72/1 72/3
72/8 73/8 74/9 75/2
or... [26] 162/8
163/16 165/12 168/14}
169/20 171/14 173/13}
173/15 173/25 174/19}
181/23 181/23 182/12)
184/22 189/11 189/25)
organisation [5] 93/4
83/14 83/18 88/19
89/14 94/3 95/8
107/18 107/22 110/22)
131/13 133/4 137/2
145/7 145/18 146/18
148/7 158/4 158/14
167/10 169/6 169/12
171/19 173/5 176/18
out [69] 3/25 5/15
10/17 12/21 14/19
14/21 15/2 15/14
15/18 16/9 16/11 19/8
25/21 47/16 48/19
48/20 49/1 52/22 53/9)
53/20 56/4 60/2 67/1
72/12 81/21 83/9
87/11 89/10 93/8
93/23 97/3 108/17
111/10 112/8 112/12
117/23 118/5 119/18
119/19 122/9 124/18
125/24 128/5 128/24
130/9 131/6 133/17
139/13 139/13 140/4
142/12 142/21 143/17)
143/20 145/17 145/23)
152/17 152/22 153/17,
155/13 163/3 165/6
169/3 169/15 172/8
176/2 181/4 193/2
193/15
outcome [3] 14/12
20/10 133/3
outlier [1] 194/25
outlined [1] 84/18
outlining [2] 72/4
72/8
outright [1] 193/23
outset [3] 165/8
192/8 193/2
outside [7] 64/7 64/8
91/18 92/11 106/21
114/6 150/19
over [43] 3/24 4/17
5/5 11/19 23/7 26/10
30/11 31/2 36/14
38/17 40/4 43/2 43/9
43/11 48/13 48/17
52/9 56/1 57/4 70/19
72/18 74/2 76/25
79/20 79/22 90/18
91/12 93/16 101/7
110/2 113/13 118/23
127/5 142/19 151/9
161/10 163/20 170/7
172/21 183/19 185/18)
186/4 194/14
overall [3] 33/22
178/23 192/6
overdo [1] 178/19
overlap [1] 97/22
overlooked [2]
127/18 128/11
oversee [1] 34/9
overseen [1] 34/14
oversight [1] 137/9
overstates [1] 62/22
overtly [1] 177/17
overview [1] 7/3
overwhelming [1]
95/5
owe [1] 96/6
own [9] 2/6 10/25
11/12 72/15 92/18
94/25 123/13 123/14
194/1
owned [1] 191/23
P
PACE [1] 116/25
page [100] 1/18 1/18
3/24 4/18 5/5 5/21
6/24 7/23 7/23 8/6
19/2 25/15 25/15
25/24 25/25 28/22
29/24 29/25 30/11
30/11 33/2 35/3 35/22,
36/14 36/15 38/13
38/17 38/17 38/18
40/4 42/13 42/14 43/9
43/9 46/16 48/17 49/6
49/6 50/21 55/7 56/1
57/4 57/5 58/25 70/11
76/19 79/20 79/22
82/25 83/24 84/23
84/25 91/12 93/6 94/8
94/9 95/10 99/7 101/7
103/18 107/13 107/14
108/4 118/7 118/20
118/20 118/23 123/23
124/1 125/8 130/4
134/14 134/17 141/9
141/10 145/4 152/1
161/2 161/10 163/20
163/20 163/22 167/16}
167/22 168/6 168/6
170/7 170/7 170/12
172/19 172/19 172/21
177/2 177/3 180/20
180/21 186/10 186/11
186/14 186/17
page 1 [12] 25/24
25/25 43/9 84/23
84/25 125/8 130/4
134/17 163/22 168/6
168/6 170/7
page 13 [1] 35/22
page 14 [1] 93/6
page 2 [7] 38/13
70/11 101/7 108/4
163/20 167/22 170/7
page 235 [2] 118/20
118/20
page 24 [2] 49/6 49/6
page 3 [12] 30/11
57/4 57/5 58/25 94/8
94/9 99/7 103/18
141/10 167/16 170/12
172/19
page 4 [14] 29/24
29/25 38/17 38/18
42/13 42/14 82/25
83/24 107/13 107/14
186/17
page 5 [3] 35/3
123/23 124/1
page 557 [1] 1/18
page 6 [3] 28/22
186/11 186/14
page 64 [1] 46/16
pages [3] 1/16 7/19
7/22
paid [2] 161/17 162/4
painted [1] 125/1
Panorama [6] 110/4
110/6 111/20 112/21
113/4 113/5
paper [18] 41/13
43/22 66/6 66/10
66/10 66/13 72/14
72/15 74/20 84/6 90/9)
142/13 160/12 160/12)
163/18 163/21 163/25]
168/22
paperwork [3] 2/3
149/2 149/9
paragraph [42] 5/17
10/19 20/16 26/17
26/20 29/23 35/3
35/13 35/23 36/3 43/5)
46/16 47/16 49/7 49/8
57/17 76/21 77/2
79/10 81/21 86/23
101/4 109/15 112/5
112/18 118/8 118/21
119/4 119/11 119/17
122/8 122/8 122/22
122/24 135/9 144/11
147/25 181/16 181/17,
182/7 182/9 193/21
paragraph 105 [1]
46/16
paragraph 117 [1]
49/7
paragraph 14 [1]
35/3
Paragraph 15 [1]
35/13
paragraph 182 [1]
101/4
paragraph 2 [1]
181/16
paragraph 24 [1]
57/17
paragraph 37 [1]
35/23
Paragraph 38 [1]
36/3
paragraph 4.2 [1]
147/25
paragraph 404 [1]
134/14 172/19 186/10)
122/18
paragraph 411 [2]
118/21 122/8
Paragraph 50 [1]
181/17
paragraph 60 [2]
182/7 182/9
paragraph 84 [1]
517
paragraph 87 [1]
29/23
paragraphs [2] 3/20
43/14
paralegal [1] 27/8
paramount [1] 92/5
Parliament [1] 91/23
Parliament's [1]
157/25
parrot [1] 88/12
Parsons [11] 1/6 1/8
1/11 1/12 38/14 38/19)
75/9 76/4 131/24
152/3 196/2
part [24] 6/1 24/3
34/7 46/24 48/8 49/15]
71/14 75/24 87/16
96/24 98/18 99/5
100/25 114/21 141/3
151/20 159/19 160/8
160/18 160/19 160/21
160/24 163/16 183/13}
Part 2 [1] 141/3
participants [3]
141/5 195/9 195/14
particular [32] 11/3
11/13 12/10 13/5
15/20 16/24 17/16
17/22 18/1 18/4 18/5
18/20 20/23 31/6 31/9)
65/19 70/21 75/17
77/12 84/12 86/6
103/23 106/23 109/8
118/22 119/11 137/20)
159/19 164/16 179/7
181/7 186/16
particularly [9] 8/23
30/6 61/2 105/9 136/8I
141/20 149/2 151/16
157/16
parties [2] 133/3
134/11
partner [12] 2/8 2/19
30/13 31/19 32/13
55/9 59/11 61/3 61/4
62/9 79/2 132/10
partners [3] 55/13
60/25 70/3
parts [1] 4/18
party [3] 95/6 123/6
139/9
pass [1] 109/6
passages [1] 163/23
passed [6] 63/21
92/14 137/25 146/11
(70) or... - passed
Pp
passed... [2] 174/16
189/9
passing [1] 104/14
past [15] 56/11 56/21
57/9 57/11 57/16
58/24 59/3 61/7 62/1
83/20 88/5 108/9
178/15 181/2 190/3
Patrick [3] 147/20
147/22 159/7
pattern [1] 23/7
PAUL [4] 1/8 1/11
152/3 196/2
Paula [7] 51/7 83/5
84/15 89/2 91/6 160/5
168/20
Paula's [1] 83/3
paused [2] 28/14
28/16
pausing [10] 4/9 6/3
10/25 22/23 26/6
26/17 113/18 136/5
165/4 187/23
pay [2] 92/4 162/4
payment [1] 162/16
payments [2] 28/24
136/15
Pearce [1] 2/12
pending [3] 27/14
33/14 146/24
penultimate [1]
144/10
people [16] 16/25
39/14 74/19 92/24
111/12 120/16 120/20)
135/17 158/7 166/19
169/7 169/9 169/23
170/3 179/1 181/10
people's [2] 120/7
126/9
per [4] 107/18 107/25]
152/24 152/25
percentage [1]
153/13
perception [2] 112/1
113/16
perfect [1] 194/5
perhaps [14] 32/12
64/23 76/12 77/11
85/3 88/2 94/6 111/23,
116/1 118/18 132/23
141/9 151/14 176/17
period [27] 10/22
15/15 23/21 44/13
44/19 45/9 54/12
90/18 91/6 110/1
133/21 141/18 148/13)
148/15 156/5 156/10
158/20 159/21 161/11
161/13 161/16 161/20}
161/23 162/12 185/11
185/14 188/6
periods [2] 115/18
157/16
Perkins [2] 89/3 91/7
permission [1]
187/15
person [3] 15/9 86/8
187/1
personal [6] 95/22
99/16 102/20 102/25
103/10 117/1
personally [7] 14/21
24/15 64/16 149/8
167/2 178/19 185/9
perspective [7]
42/23 98/6 149/15
150/2 163/4 163/5
175/15
Pete [2] 48/7 190/9
phase [5] 2/21 48/22
48/25 121/2 144/6
Phase 3 [1] 48/22
Phase 4 [1] 2/21
phases [1] 48/21
phone [1] 7/3
phrase [4] 106/17
123/6 125/14 126/8
phrased [1] 183/3
phrases [1] 27/2
pick [1] 188/8
picture [5] 4/25 5/16
83/12 125/1 175/13
piece [11] 40/1 66/8
66/14 66/18 67/5
72/14 74/17 117/16
123/3 128/21 191/7
piecemeal [1] 28/2
pieces [2] 45/14
194/14
pile [1] 129/8
pinpoint [1] 27/5
piste [1] 135/20
place [14] 4/6 14/15
17/19 17/25 18/23
23/21 27/21 40/8
45/10 101/15 108/15
158/21 179/8 184/19
placed [4] 138/5
152/7 183/5 194/14
placing [1] 36/18
plan [5] 179/7 192/12
193/5 194/8 194/23
planned [1] 83/22
planning [1] 192/25
play [4] 82/6 135/6
136/11 175/6
played [1] 37/14
please [151] 1/10
3/18 4/18 5/20 5/21
5/24 6/25 8/5 8/22 9/1
10/10 13/21 16/9
17/10 18/25 19/5
20/20 22/10 25/13
25/13 26/9 28/22
29/23 29/25 30/11
33/2 34/18 34/21
34/24 35/2 35/22
36/14 37/24 38/12
38/17 39/25 39/25
40/5 40/12 42/10
42/13 43/9 48/3 48/15)
48/17 49/3 49/5 50/19)
51/5 51/12 51/15
51/19 54/15 55/22
55/23 57/4 58/14
58/18 58/22 61/10
68/17 69/15 70/11
71/11 71/20 71/22
73/8 75/1 76/11 76/20
78/6 79/5 81/13 82/24
82/25 83/24 84/8
84/25 87/6 88/25
89/24 91/3 91/12 93/6
94/8 94/8 95/10 99/14
101/7 101/10 107/13
107/14 108/4 108/6
109/25 115/19 116/6
118/24 123/22 123/22
124/15 126/14 127/2
130/3 130/4 131/13
131/15 132/1 134/13
134/17 135/9 136/23
138/13 138/22 141/1
141/10 145/2 145/4
145/24 147/19 147/19]
149/12 150/8 151/25
152/2 152/10 152/13
157/21 159/5 161/5
161/10 167/13 170/6
171/17 172/18 172/19}
177/1 177/2 177/3
178/17 180/4 180/21
180/22 182/4 183/16
186/7 186/7 186/11
186/14 186/16 190/6
plenty [2] 4/15
195/11
pm [6] 107/9 107/11
131/19 131/21 176/23
195/20
pocket [1] 111/2
point [62] 12/2 13/7
13/10 15/23 31/1
32/14 32/17 36/15
37/1 40/7 40/12 44/7
45/23 61/24 62/4
62/12 68/14 69/20
89/21 98/21 103/11
106/19 106/23 113/20
115/14 116/19 117/6
119/7 121/15 125/20
126/10 128/18 134/2
134/16 136/21 139/12
140/12 143/21 144/21
146/4 146/15 146/23
147/2 148/6 149/10
154/1 160/7 160/17
160/20 164/17 168/1
168/9 172/11 174/5
175/24 177/14 181/21
181/22 182/3 188/22
193/14 193/18
points [25] 3/12
10/17 15/22 22/16
48/18 63/16 64/2 65/9
73/16 82/23 84/22
84/24 106/13 113/25
115/5 123/19 127/3
127/3 131/11 144/1
167/5 173/3 177/7
187/12 192/17
POL [3] 29/6 90/7
181/17
POL's [1] 97/15
POLO000 [1] 75/4
POL00000444 [1]
49/3
POL00006357 [1]
34/25
POL00006364 [1]
161/2
POL00006799 [1]
39/25
POL00021863 [1]
151/25
POL00021864 [1]
154/8
POL00021865 [1]
109/25
POL00021908 [1]
163/18
POL00021980 [1]
58/14
POL00021981 [1]
55/23
POL00021991 [1]
65/14
POL00021996 [2]
66/16 76/14
POL00022002 [1]
91/3
POL00022352 [1]
159/6
POL00022598 [2]
3/18 100/22
POL00029707 [3]
94/8 102/13 102/16
POL00029990 [1]
174/7
POL00031456 [1]
167/13
POL00040025 [2]
71/11 81/9
POL00040026 [1]
76/12
POL00043147 [1]
126/15
POL00043169 [1]
130/3
POL00075810 [1]
145/2
POL00083932 [1]
37/24
POL00099063 [1]
28/21
POL00099346 [1]
51/16
POL00112856 [1]
79/1
POL00116112 [1]
53/11
POL00123004 [1]
82/24
POL00141727 [1]
147/19
POL00144848 [1]
10/10
POL00144849 [1]
13/22
POL00144850 [1]
17/10
POL00144854 [1]
19/23
POL00144864 [2]
18/25 19/1
POL00144874 [1]
22/10
POL00145716 [2]
42/10 89/24
POL00146243 [1]
107/13
POL00147949 [1]
100/22
POL00150460 [1]
157/21
POL00176599 [1]
149/12
POL00190324 [1]
5/20
POL00191954 [1]
134/13
POL00201764 [1]
138/13
POL00214323 [1]
150/8
POL00245938 [1]
123/22
POL00245978 [1]
17/1
POL00246005 [1]
180/20
POL00249553 [1]
181/11
POL00249919 [1]
183/16
POL00253345 [1]
48/15
POL00254632 [1]
186/7
POL00276195 [1]
192/2
POL00296703 [1]
POL00297998 [1]
53/13
POL00298417 [1]
61/10
POL00305714 [1]
8/5)
(71) passed... - POL00305714
Pp
POL00305714... [1]
141/1
POL00312743 [1]
170/6
POL00327110 [1]
136/24
POL00372551 [1]
88/25
POL00407496 [1]
25/13
POL00415440 [1]
180/4
policies [1] 73/10
policy [6] 43/2 84/5
84/10 85/9 85/11
149/22
poor [2] 119/17
119/22
poorly [3] 118/25
121/12 122/15
posed [1] 152/20
poses [1] 125/6
position [35] 12/25
22/9 36/7 45/3 50/4
51/8 54/16 62/22 63/1
64/25 67/3 73/4 88/10
93/15 93/20 96/8
97/12 110/6 112/20
119/12 122/6 122/6
132/9 139/25 145/17
145/23 148/3 157/4
157/20 158/9 161/11
161/12 166/4 169/16
179/10
positions [1] 145/19
positive [2] 192/13
192/21
Posnett [2] 5/21 7/14
possibilities [1]
133/24
possibility [8] 6/19
6/22 10/3 128/12
129/6 132/20 169/24
175/10
possible [23] 15/13
56/14 73/11 97/3
117/13 119/25 126/20}
153/22 153/25 155/25
158/11 167/11 170/14}
170/15 170/16 171/14}
171/21 174/19 182/16)
187/16 189/25 191/13}
193/10
possibly [5] 17/9
88/4 122/22 135/23
192/11
post [307]
post-dated [1] 121/7
post-dates [2]
117/14 123/2
post-separation [1]
53/2
postmaster [4]
186/24
postmaster's [3]
188/20 189/2 189/6
postmasters [3]
111/10 117/6 173/11
postmasters' [1]
113/1
potential [8] 6/12
34/3 37/13 50/6 57/11
71/24 82/8 176/11
potentially [10] 34/6
47/2 59/6 73/9 77/8
78/18 79/19 92/12
171/12 176/7
power [1] 133/1
PR [4] 42/23 112/21
113/3 113/9
practicable [1]
156/18
practical [3] 60/21
156/12 159/24
practice [3] 6/15
102/14 155/11
practices [1] 150/22
pragmatic [2] 64/23
65/1
pre [3] 121/2 121/15
123/6
pre-action [3] 121/2
121/15 123/6
precedent [1] 192/22
precisely [2] 44/13
47/4
prefer [1] 193/19
preference [6]
110/13 112/11 112/14)
112/25 114/22 139/23)
prejudice [1] 95/8
preliminary [1] 33/13
prepare [2] 56/6
152/4
prepared [6] 43/23
92/4 135/19 152/5
152/8 165/19
preparing [2] 108/24
159/20
prescriptive [1]
30/24
presence [1] 31/9
present [2] 41/20
43/7
presentation [8]
65/22 65/23 65/25
91/4 91/9 91/12 93/7
99/2
presented [2] 72/4
185/18
presents [1] 108/11
preserving [1] 73/11
press [1] 172/12
presumably [10]
173/21 183/21 183/25)
practically [1] 159/20
29/16 33/3 37/7 37/21
38/5 81/15 81/18
presume [4] 23/12
23/20 24/8 81/20
presumption [5]
23/25 135/16 148/2
148/8 148/9
pretty [4] 10/8 16/15
115/11 170/25
prevent [2] 74/1
163/9
preventing [1] 188/5
previous [6] 15/4
62/11 109/19 133/19
177/25 184/16
71/1 79/14 86/9 99/11
149/17 155/3 174/25
179/14 181/17 184/7
previously’ [1]
143/18
primarily [4] 58/3
181/25 182/1 183/9
prime [5] 115/20
115/20 117/19 169/11
194/19
principal [1] 48/23
principally [1] 27/25
principle [4] 11/23
16/1 173/11 173/22
prior [3] 52/23 102/1
116/22
prison [1] 124/8
Priti [3] 94/12 95/14
95/16
privacy [3] 96/6
99/16 102/25
privilege [50] 44/2
67/8 67/9 67/13 67/22
68/2 68/3 68/5 68/6
68/9 68/15 68/21 69/4
69/10 69/16 69/16
69/17 69/18 69/21
69/25 70/4 70/5 70/5
70/8 72/18 73/6 73/7
73/11 73/14 73/20
74/2 74/21 90/24
91/14 91/15 92/1 93/2
93/3 95/25 108/20
116/17 116/18 177/18
189/25 190/21 190/25}
191/4 191/11 191/14
192/1
privileged [15] 67/8
67/24 68/23 69/1 69/1
69/2 69/3 69/13 70/7
73/23 74/25 82/13
103/12 108/21 190/11
proactively [1] 109/6
probably [12] 47/20
51/7 60/20 67/24 75/2I
106/5 132/12 147/5
136/14 137/22 175/18}
previously [14] 13/24
127/17 128/11 143/18
165/23 169/18 181/10
183/10
probative [1] 171/16
problem [22] 6/20
15/1 16/10 16/12
16/21 16/23 17/2
26/24 28/25 29/1
90/17 98/21 124/21
124/22 125/6 125/6
129/7 165/21 182/15
182/21 183/7 183/10
problematic [1] 9/8
problems [27] 13/20
27/4 27/10 32/1 43/6
43/8 45/24 52/17
70/23 71/6 72/23 77/7
77/14 78/17 79/13
79/18 79/25 82/10
99/8 99/12 103/19
109/10 124/23 126/9
128/7 184/6 190/16
procedural [2] 11/10
(77/7
procedure [3] 109/6
114/6 114/14
proceed [3] 95/19
150/7 190/14
proceedings [6] 49/7
49/16 56/22 132/13
149/19 178/24
process [29] 39/24
46/23 48/8 56/7 56/11
56/19 71/16 75/7
84/11 85/17 85/23
87/8 87/21 110/23
123/17 132/14 133/8
153/6 166/17 166/18
168/3 171/1 174/24
174/25 189/17 189/23}
191/16 193/24 194/9
processed [1] 189/1
processes [4] 31/13
51/13 55/15 109/4
produce [5] 41/3
48/23 148/17 159/11
190/10
produced [16] 38/23
39/8 40/19 45/21 47/8
48/12 48/25 49/12
49/17 49/23 75/9
82/14 108/23 153/11
160/20 189/23
producing [3] 48/11
113/21 149/11
product [4] 146/15
149/11 187/14 187/15}
productions [1]
47/14
professional [1]
90/24
profile [1] 89/19
programme [3]
112/22 113/4 113/5
progress [1] 130/6
progressing [3]
83/12 83/22 84/6
Project [3] 83/7 83/9
140/18
proof [1] 93/8
proper [1] 17/3
properly [7] 106/25
147/9 179/5 182/15
182/21 183/8 190/17
proposal [4] 135/24
136/1 164/5 166/13
proposals [1] 164/11
proposed [8] 48/19
72/7 81/14 83/8 85/6
155/18 159/4 189/10
proposing [2] 99/25
117/12
proposition [1] 112/8
prosecute [1] 124/14
prosecuted [1] 86/9
prosecutes [1] 70/14
prosecuting [1] 35/4
prosecution [27]
6/21 31/11 36/1 36/13}
52/19 52/25 70/24
71/6 77/6 77/13 77/19)
79/16 85/11 86/5
86/12 97/8 97/16
97/21 98/2 98/5 105/6I
110/23 120/8 121/7
149/21 149/22 170/9
prosecution's [1]
98/8
prosecutions [30]
5/14 35/2 35/16 53/6
56/12 56/21 57/1 57/9I
57/12 58/25 62/1
70/11 70/15 70/19
71/8 79/23 80/10 82/1
84/5 85/8 85/15 86/15]
98/3 107/22 109/7
120/12 120/14 121/9
137/4 137/6
prosecutor [2] 36/19
53/3
prosecutor's [6]
61/19 63/14 63/18
64/14 99/23 100/1
prosecutorial [1]
57/2
prospect [1] 134/12
protect [4] 10/21
44/2 99/16 102/25
protection [6] 99/18
101/19 102/14 103/2
103/8 105/14
protocol [1] 168/3
proved [1] 148/11
provide [16] 35/11
36/12 52/1 88/24
95/10 116/13 116/15
126/3 137/7 138/11
141/19 152/23 154/4
161/25 194/21 194/22!
(72)
POL00305714... - provide
P
provided [19] 4/17
14/16 24/17 35/14
45/8 71/10 82/9 82/21
99/19 122/1 122/2
123/18 150/9 155/19
159/17 160/11 163/10
172/17 175/25
provides [4] 93/3
96/4 116/23 159/22
providing [12] 57/24
93/1 100/4 110/5
117/25 118/5 142/10
144/8 152/14 152/19
154/20 161/15
provision [1] 35/7
précis [1] 47/18
public [9] 9/18 38/15
40/17 42/24 43/17
90/4 111/25 149/23
158/9
publicity [1] 185/6
publicly [2] 93/23
108/22
published [1] 33/20
pulled [4] 176/1
punchy [1] 111/23
purpose [13] 66/4
66/25 68/24 71/23
72/17 74/4 102/6
105/25 119/5 126/2
134/6 135/21 165/4
purposefully [1] 97/5
purposes [2] 6/21
105/14
push [1] 153/23
pushed [1] 183/14
pushing [1] 150/5
put [16] 25/5 27/9
42/20 46/13 74/20
85/25 104/22 111/23
112/23 128/5 135/7
136/12 148/4 165/19
168/16 182/3
putting [5] 90/12
92/14 99/4 103/15
111/1
PV [1] 168/20
Q
QC [6] 34/9 34/17
58/19 60/4 61/18
88/18
QC's [3] 62/20 83/21
85/11
qualification [1] 2/24
qualified [8] 2/14
2/23 3/2 115/22 116/2
118/1 143/12 188/22
quality [5] 113/20
113/22 114/9 140/13
149/10
queries [1] 157/25
query [1] 8/17
question [30] 4/20
13/2 24/19 44/9 44/16
46/13 60/10 67/23
75/8 79/14 85/14 87/5
101/20 112/23 130/17)
137/3 150/6 152/16
153/21 154/4 154/14
156/7 157/1 159/3
168/9 168/12 170/2
171/13 171/15 182/25)
Questioned [2] 1/9
196/4
questioning [1]
195/9
questionnaires [1]
145/15
questions [45] 4/13
4/16 61/22 64/19 84/2
85/1 85/4 85/7 88/22
102/11 113/7 125/2
130/14 131/1 139/22
150/9 150/11 150/14
150/17 150/19 150/21
150/21 151/10 151/11
151/19 151/22 151/23)
152/4 152/9 152/14
152/20 152/24 152/24)
153/4 153/9 153/11
153/14 153/19 153/24)
153/25 154/6 157/11
157/19 168/24 176/16)
quick [3] 51/15 132/6
183/18
quicker [1] 146/10
quickly [2] 135/8
136/12
quite [19] 9/4 18/15
26/21 47/15 72/9
72/22 77/10 88/2
128/1 149/6 151/21
151/22 153/13 158/20)
168/23 171/25 172/5
175/18 175/20
quo [4] 115/14
Ro
racing [2] 125/15
126/7
rag [2] 171/3 171/5
rains [1] 89/11
raise [4] 127/18
128/11 148/6 149/25
raise/overlooked [1]
127/18
raised [20] 7/14 23/8
25/9 25/11 39/18 41/9
51/24 56/3 61/21
104/18 117/7 117/10
142/20 143/20 150/16)
154/22 172/14 186/16)
187/1 187/6
raises [1] 164/23
raising [6] 27/4 28/16
31/19 143/17 143/20
159/2
random [1] 190/23
rang [1] 189/16
range [1] 110/24
rare [3] 167/20 168/3
170/18
rate [1] 162/4
rather [15] 26/24
43/20 76/25 90/6
110/24 112/20 113/3
119/7 139/9 139/25
140/7 171/2 182/19
187/22 193/19
re [3] 89/14 89/15
169/10
reach [4] 133/11
133/14 134/1 166/25
reached [2] 52/16
151/4
reaches [1] 83/1
reaching [1] 133/10
read [23] 7/21 7/24
18/2 18/3 18/16 18/18
21/12 35/21 35/25
37/9 50/2 57/19 60/21
63/10 63/11 81/19
105/24 112/5 114/21
122/22 124/9 186/21
192/6
reader [2] 20/25 68/8
reading [10] 10/2
15/10 17/24 47/25
60/6 70/9 122/20
136/13 157/3 179/25
reads [1] 118/8
ready [1] 85/13
real [11] 9/10 99/5
101/11 103/15 143/24
148/13 164/2 180/1
180/3 180/18 188/4
realise [1] 50/2
realised [3] 23/10
23/16 141/23
reality [2] 147/8
168/2
really [10] 60/13
60/19 64/3 73/24
88/10 106/2 106/21
136/17 170/4 181/21
realms [1] 169/13
reason [10] 4/21
36/16 36/20 38/9
44/22 68/20 99/5
103/16 152/20 187/19!
reasonable [2] 68/13
162/7
reasonably [2] 140/8
156/18
reasoned [1] 110/14
reasons [18] 36/4
59/3 68/1 96/17
101/19 102/10 103/8
108/14 113/12 119/13}
122/4 145/19 152/5
152/15 154/20 160/16}
162/24 184/13
reassured [1] 142/7
rebalance [1] 111/25
recall [64] 7/6 7/7
17/18 17/19 17/23
19/13 19/19 20/14
26/8 27/23 28/18
30/20 33/16 38/2 38/3)
38/3 38/8 38/9 39/20
39/22 54/20 63/2
73/20 77/23 78/12
78/14 78/15 78/19
78/20 78/24 80/16
81/20 119/1 129/15
133/19 133/21 137/20}
140/24 140/24 141/6
142/6 143/4 143/17
143/22 143/23 144/16
144/21 144/24 145/1
146/6 151/22 153/8
159/1 163/15 176/12
180/18 181/9 182/2
184/15 184/22 185/2
186/24 189/8 194/16
recast [1] 157/12
receipts [1] 28/24
receive [3] 7/8 93/5
169/21
received [15] 8/17
23/22 23/23 30/2 33/8}
33/23 40/14 74/16
74/18 79/5 83/16 86/3}
111/16 115/9 139/9
receiving [7] 7/6 7/7
63/3 63/5 102/2
147/15 169/14
recent [6] 72/4
116/21 116/23 117/13}
123/1 147/23
recently [1] 7/18
recipient [3] 18/18
21/24 61/14
recipients [1] 22/3
recognise [1] 166/9
recognised [2] 18/19
174/4
recollection [9]
19/17 59/24 62/22
75/19 150/1 156/4
157/10 166/17 180/14)
recommenced [1]
127/19
recommenced/the [1]}
127/19
recommend [6] 43/5
56/24 108/14 112/19
114/3 162/18
recommendation [1]
165/1
recommendations
[5] 5/6 5/7 11/15
79/12 109/8
recommended [6]
43/19 83/20 84/14
90/6 93/8 96/7
reconciliation [1]
140/21
reconsidering [1]
98/3
record [13] 11/18
13/5 39/1 40/4 47/4
50/1 50/3 53/11 53/13}
66/12 123/9 139/8
141/18
recorded [6] 38/11
39/12 41/5 45/1 70/16)
174/16
records [15] 11/20
11/22 14/9 14/20
15/25 17/21 18/14
20/7 24/25 27/25
31/12 45/3 70/16
93/10 119/2
recover [1] 8/21
rectification [1]
31/10
red [2] 171/3 171/5
redacted [10] 96/11
99/16 101/1 101/6
101/18 102/3 102/7
102/8 102/25 103/22
redacting [2] 103/10
106/6
redaction [4] 101/8
101/9 101/10 105/1
redactions [17]
95/20 96/9 96/12
96/14 96/21 101/2
101/21 102/10 102/10)
102/18 103/5 103/7
104/1 105/13 105/19
105/21 106/25
reduce [2] 43/19 90/6)
reduced [1] 87/13
redundant [1] 187/13)
refer [6] 24/13 66/9
69/17 77/21 115/8
176/6
referable [1] 34/1
reference [44] 1/23
15/8 16/5 17/13 19/13}
30/18 30/20 31/16
46/18 51/12 51/20
55/14 56/4 58/16
58/19 58/21 59/8
61/17 62/5 62/6 62/12I
62/13 62/21 62/24
63/4 63/8 63/13 64/13
67/19 71/8 76/23
78/12 83/15 108/7
114/24 114/24 120/2
120/22 125/13 154/22!
155/14 158/17 179/17)
182/11
referred [8] 8/1 24/14!
26/23 28/23 40/3 91/5
(73) provided - referred
R
194/25
referring [4] 114/25
120/3 158/16 170/25
refers [6] 20/12
20/22 26/18 69/15
76/24 189/2
reflect [2] 12/25
119/11
reflected [3] 66/5
66/9 106/2
reflecting [5] 47/17
93/25 106/4 166/16
167/2
reflection [2] 111/18
141/15
reflects [2] 49/22
87/3
reframe [1] 157/12
refund [1] 8/20
refuse [1] 153/22
refused [1] 137/7
regard [2] 57/17
159/19
regarding [9] 8/18
33/24 38/1 42/17
43/13 44/23 104/17
104/18 179/11
regardless [2] 97/10
99/9
regards [1] 152/17
regret [2] 121/12
172/11
Regrettably [1]
118/25
regular [3] 38/1 38/2
38/8
regularly [2] 5/10
17/4
reinstated [1] 187/15
reinvestigated [1]
134/10
related [7] 3/7 6/10
75/17 87/1 157/24
170/20 191/8
relates [6] 79/24
97/20 100/1 110/4
180/6 187/13
relating [10] 13/16
54/9 62/10 62/13 63/3,
63/18 71/9 87/20
112/20 114/5
relation [23] 2/6
13/25 17/16 17/20
45/13 46/10 50/5
80/14 87/19 88/6
99/23 109/13 115/12
117/7 127/10 128/15
152/9 153/2 155/5
181/19 185/8 187/24
194/18
relationship [3] 61/4
referred... [2] 155/14
130/20 166/21
relayed [1] 40/16
release [1] 158/10
released [1] 52/14
relevance [1] 151/19
relevant [11] 15/19
15/21 77/8 78/18
79/19 79/25 110/3
117/14 119/9 123/1
156/22
reliability [1] 111/16
relied [3] 35/3 35/6
181/18
rely [2] 110/22 143/9
relying [2] 35/10
138/11
remain [2] 36/23
137/11
remaining [1] 130/10
remarkably [1] 45/16
remember [10] 24/21
80/21 81/23 94/17
144/25 151/12 160/11
160/21 160/22 166/11
remembered [1]
24/20
reminder [1] 91/14
remit [1] 37/9
remote [35] 6/19
167/8 167/10 168/24
169/7 169/21 169/24
170/4 171/6 171/12
171/15 171/20 172/7
173/8 173/19 174/4
176/13 176/17 177/8
179/15 180/8 180/16
181/19 182/15 183/3
184/3 184/6 185/9
185/10 186/4 188/15
189/12
remotely [3] 95/3
168/13 170/14
remove [7] 10/23
95/21 102/19 187/11
188/10 188/14 189/11
removed [4] 17/7
87/13 168/14 177/15
removing [2] 15/8
16/5
renamed [1] 43/21
reoccurring [1] 24/2
reordered [1] 180/9
repeat [2] 47/5
182/25
repeatedly [3] 104/2
129/17 129/19
repeating [2] 86/23
88/7
repetitive [1] 180/24
replace [3] 10/23
16/10 163/14
reply [1] 124/4
report [84] 3/8 3/18
177/22 177/24 177/25)
3/19 3/21 4/2 5/19
5/24 6/11 7/4 7/6 7/7
7/9 7/15 7/19 7/22
28/20 28/24 31/14
31/25 33/19 40/16
43/8 52/13 52/14
70/18 85/12 85/18
85/19 86/13 87/3
89/18 94/22 95/23
99/17 99/19 100/5
102/7 102/24 103/1
103/5 103/9 103/17
126/24 127/2 133/5
133/6 133/23 138/20
139/1 139/3 139/20
139/24 140/7 141/4
160/9 160/18 160/19
160/21 160/25
Report' [1] 94/23
reported [1] 22/22
reporting [1] 61/7
reports [10] 4/23
48/23 48/25 95/21
144/4 148/17 148/24
158/25 159/2 176/1
representative [3]
89/15 116/25 141/5
represents [1]
104/13
request [18] 25/23
85/21 87/19 95/7
108/25 120/5 120/9
121/4 123/23 125/4
126/1 126/1 126/4
128/20 128/20 151/2
154/21 156/3
requested [4] 4/4
101/13 116/12 152/13
requesting [1]
101/23
requests [2] 84/3
162/8
require [3] 117/15
123/3 154/2
required [14] 43/3
52/15 71/3 77/17 88/2
117/23 118/6 119/6
123/7 126/3 127/14
148/18 161/15 166/24
requirements [1]
107/22
requires [1] 6/23
research [2] 182/18
183/7
researched [2]
182/15 182/21
resist [2] 86/14
7/24 27/14 28/6 28/19
56/13 58/23 59/2 59/5)
96/5 96/9 96/10 96/12
98/19 99/1 99/6 99/15)
100/18 100/21 100/23
104/20 105/11 105/13
142/17 145/16 159/19}
108/22
resisting [1] 119/13
134/7 193/6 194/6
resolve [1] 25/3
resolved [3] 71/5
192/18 194/3
respect [9] 5/25
60/12 80/10 104/24
138/10 191/2
respective [1] 59/7
respond [8] 84/21
114/2 117/19 117/20
125/9 152/5 156/6
167/23
responded [6] 81/16
84/24 117/6 119/4
143/19 145/22
responding [5] 10/12
14/4 110/19 112/21
113/4
responds [1] 84/19
response [49] 4/14
9/2 22/18 30/25 31/2
31/3 33/19 33/21
42/19 51/18 52/1 53/8)
56/15 58/4 58/19
78/21 83/25 96/20
97/4 97/4 97/9 98/13
99/13 99/14 108/3
108/4 125/10 125/25
130/8 138/19 146/22
152/10 152/17 153/16
156/3 156/15 157/24
169/3 169/4 171/24
172/14 172/22 172/23}
177/4 178/17 178/19
178/21 188/18 189/19}
responses [2] 6/6
171/19
responses/statement
s [1] 171/19
responsibilities [1]
113/7
responsibility [1]
179/3
responsible [8]
90/16 90/20 90/25
92/9 154/19 181/25
182/1 182/1
rest [1] 167/11
result [3] 70/17 134/7I
158/21
resulted [1] 48/10
resume [3] 50/12
131/17 195/18
retain [1] 40/4
retained [2] 40/11
88/15
retrospective [2]
71/3 77/17
retrospectively [2]
71/1 122/16
resolution [4] 133/10
109/22 115/12 130/20)
return [2] 59/9
193/18
reveal [2] 27/15
109/3
revealed [1] 79/13
reversal [4] 6/16 6/17
98/20 101/24
reversal’ [2] 6/14
6/17
reversals [3] 7/16
98/24 98/25
reverse [1] 93/15
reversed [1] 155/10
reverting [1] 108/1
review [69] 7/17 8/22
9/1 10/11 26/11 27/17
29/17 30/3 30/4 31/4
31/21 36/6 50/23 51/6I
51/21 54/9 55/15 56/6
56/8 56/15 56/20
56/24 57/18 62/1
79/11 83/21 84/4
84/11 84/17 85/11
85/14 85/19 85/23
86/3 86/4 86/15 86/16I
87/21 88/6 94/14
96/25 104/21 107/20
108/9 108/11 108/15
108/19 108/20 108/23)
108/24 109/3 109/22
110/11 115/13 116/24I
127/13 127/20 127/21
127/22 128/21 128/23)
129/5 130/6 138/21
159/1 175/17 176/1
176/7 193/1
Review' [1] 108/8
reviewed [7] 10/13
116/21 119/9 127/6
130/11 138/1 179/5
reviewing [4] 4/3
56/11 70/18 127/12
reviews [5] 6/2 6/5
6/7 8/24 83/18
revisions [2] 116/14
417/17
revisit [2] 49/15
49/21
rework [1] 173/1
Richard [1] 72/2
Richardson [4] 55/9
55/20 58/5 62/14
right [30] 9/11 23/16
25/3 32/4 47/12 50/11
52/5 55/5 64/6 67/7
74/14 75/14 76/10
77/2 77/22 78/4 80/17
80/23 82/2 91/10
94/25 101/11 101/21
107/7 131/16 142/13
161/22 172/24 179/1
188/16
right-hand [6] 67/7
7712 77/22 78/4
(74) referred... - right-hand
R
right-hand... [2]
101/11 101/21
rigour [1] 169/12
rise [3] 73/10 123/17
129/7
risk [16] 9/7 43/16
43/19 85/20 90/3 90/6)
125/12 127/4 127/5
127/12 129/8 133/9
143/7 177/18 184/2
188/4
risks [20] 9/13 66/3
70/11 71/22 72/4 72/8
73/17 75/18 76/20
78/6 79/3 79/21 90/19
93/8 93/11 107/19
108/12 127/22 139/22)
190/16
Risks' [1] 71/20
Rob [3] 39/18 94/10
178/17
Robinson [4] 99/15
102/24 172/21 182/5
robust [4] 9/20 10/1
133/13 193/3
robustness [1] 31/11
rocks [1] 194/14
Rod [5] 25/17 116/6
126/19 126/24 180/8
Rodric [47] 3/13 5/21
5/23 6/25 8/14 8/22
9/1 9/3 10/12 19/2
19/4 22/11 22/12
22/19 25/16 29/11
61/12 61/15 62/3
62/16 71/17 75/15
76/2 78/5 78/21 78/22
78/24 80/12 81/8
84/18 84/19 95/13
98/10 110/5 116/10
125/9 126/18 130/5
136/25 137/1 138/15
138/24 140/17 167/17)
171/17 174/8 192/3
role [10] 53/2 56/13
57/2 58/6 87/12 88/16
88/19 109/13 164/7
173/9
roles [1] 59/7
Ron [2] 97/12 145/12
room [3] 46/22
132/22 133/1
root [2] 9/17 165/24
Rose [16] 3/17 4/1
4/16 5/25 7/4 7/9
94/21 94/23 96/10
98/19 100/17 100/21
100/23 101/6 105/11
105/13
Rosie [1] 38/20
rough [1] 195/13
round [1] 116/15
routes [1] 158/6
row [1] 141/22
Royal [4] 35/5 35/15
52/21 52/24
rule [1] 149/16
ruled [41] 112/12
rules [3] 39/10
106/14 109/6
run [4] 88/5 123/16
133/5 144/4
running [3] 46/22
47/14 141/25
s
safe [1] 190/7
safety [11] 57/11
58/24 59/3 60/5 60/8
61/7 100/13 158/5
158/15 158/23 159/3
said [41] 7/5 15/23
18/12 20/20 39/2
39/17 41/8 42/1 42/5
42/15 44/9 45/1 47/4
47/18 49/17 50/1
55/21 63/20 65/13
75/16 78/6 78/16 90/2
91/8 95/24 103/14
106/13 106/19 115/17)
119/1 122/7 136/16
144/10 151/8 156/18
157/9 166/1 176/9
182/15 189/8 191/5
sake [1] 100/11
same [22] 5/14 7/17
11/20 19/1 22/10
34/23 42/13 44/13
44/18 45/9 45/23 89/1
117/19 123/20 134/13)
151/25 155/23 180/6
180/6 180/9 181/21
187/19
sat [1] 183/9
satisfied [1] 105/14
satisfy [1] 61/19
saw [15] 23/1 40/21
67/6 67/7 68/17 72/22
90/10 90/14 131/5
136/8 140/11 166/1
179/22 184/1 194/18
say [105] 9/2 9/24
10/12 11/6 11/16 17/1
19/3 20/25 22/3 22/18)
23/19 24/7 25/25
26/11 28/5 30/24
32/24 41/3 42/19
43/11 43/15 45/15
45/19 46/12 46/16
48/6 49/9 50/23 54/14
54/24 59/20 65/24
66/17 66/24 67/2 68/6
69/12 69/21 74/22
75/20 82/16 85/16
86/3 87/9 95/11 97/2
98/17 99/22 101/18
106/17 108/25 109/14]
110/6 110/17 110/25
111/8 111/15 113/11
114/1 118/24 122/19
124/11 125/9 130/22
131/10 132/3 132/19
134/20 135/24 138/3
138/22 139/15 144/24
145/6 147/17 150/10
150/13 153/16 157/15}
161/13 164/7 164/20
166/14 167/24 170/21
170/24 170/24 171/25)
172/2 172/21 175/12
177/5 177/10 178/7
180/7 181/6 181/17
183/24 184/10 185/13
188/18 189/8 189/19
191/12 193/22
saying [15] 12/2
22/12 26/22 34/10
45/19 47/22 60/11
81/16 84/20 88/10
104/25 119/20 120/23
166/5 188/17
says [77] 4/3 4/19
5/22 7/1 8/11 13/23
18/13 20/1 28/18 29/5
30/1 30/15 30/22 31/5)
31/23 33/11 35/19
36/15 38/13 40/6
40/14 42/15 49/19
57/6 57/19 61/15 65/6
65/8 70/6 70/10 71/18
77/2 77/10 77/11
77/16 79/10 81/12
83/25 88/4 89/12
89/13 91/12 92/16
94/11 94/22 98/10
99/14 101/12 107/17
112/18 114/5 114/22
116/4 122/25 124/2
126/25 138/17 149/14
151/20 152/2 152/11
155/16 156/7 158/2
159/7 168/8 169/5
171/18 173/18 178/18}
178/22 181/16 182/7
182/13 186/21 189/15}
192/7
scenario [1] 5/9
schedule [3] 152/4
152/7 164/18
scheme [45] 71/14
83/15 87/12 93/25
94/19 97/9 97/16
97/23 97/23 98/1 98/1
98/6 104/9 104/10
108/17 115/4 123/16
134/9 134/18 135/14
135/15 136/2 136/18
137/5 137/11 140/17
140/19 141/25 142/4
144/5 146/10 146/15
147/9 147/18 150/2
150/19 158/18 158/19}
158/24 158/25 167/1
170/1 170/5 179/24
183/15
scope [14] 36/5 58/1
59/12 59/25 114/7
142/21 143/13 143/17]
143/20 144/1 144/9
150/19 162/14 164/10}
screen [7] 2/5 81/4
100/21 100/25 118/18
118/19 154/7
scroll [77] 4/2 4/17
4/19 5/5 6/24 9/2 16/9)
17/12 19/24 22/18
34/19 34/21 36/14
40/12 49/5 49/8 50/21
51/18 55/20 55/22
56/1 57/4 61/12 68/17
70/10 79/20 79/22
79/22 79/22 81/12
83/6 83/24 84/19 89/2
95/10 98/9 99/13
101/11 102/21 102/22)
107/24 113/10 118/7
132/2 138/15 138/22
142/19 144/9 145/4
145/24 146/17 146/25)
152/10 153/16 155/2
155/13 155/16 158/1
161/5 161/10 163/20
164/19 167/15 167/22)
167/23 168/5 169/4
471/17 175/12 178/17,
178/21 181/16 186/11
186/14 188/18 189/14)
189/19
scrolling [1] 69/14
second [148] 6/1 6/4
25/15 25/15 27/12
27/14 28/15 28/19
28/23 28/25 31/14
31/25 33/19 38/17
49/8 52/12 52/14 53/4)
56/12 58/4 62/10
70/17 76/19 77/1 86/6
86/7 87/11 87/12
87/16 88/16 89/17
91/20 94/3 98/20
101/9 104/20 107/3
108/16 109/2 113/10
113/13 114/6 114/9
114/11 116/23 118/7
131/25 132/22 132/25}
133/5 133/23 134/23
135/3 137/13 138/19
138/19 138/21 139/2
139/3 139/5 139/19
139/21 139/23 140/2
140/13 141/3 141/12
141/19 142/1 142/7
142/9 142/11 142/17
143/11 143/16 143/25)
144/2 144/8 144/18
145/3 145/11 145/13
145/16 147/5 147/23
148/7 148/14 148/16
149/3 149/9 149/20
150/9 150/11 151/1
151/16 152/8 153/7
154/14 155/3 156/3
157/11 157/18 159/5
159/13 159/17 160/5
160/8 160/13 160/17
160/19 160/23 161/7
161/10 161/12 161/14)
161/19 161/21 161/24)
162/1 162/1 162/4
162/7 162/11 162/13
162/14 162/18 162/20)
162/21 163/3 163/9
163/15 164/7 164/8
164/10 164/12 164/17
164/19 166/21 166/22)
167/4 167/6 171/4
171/5 172/4 172/11
172/16 177/2 190/9
secondee [2] 8/8
8/13
secret [1] 169/1
secretary [1] 107/16
section [11] 4/2
57/14 76/20 82/2 83/6
86/2 110/17 144/9
161/5 177/8 180/8
section 2 [1] 57/14
section 9 [1] 177/8
secure [1] 192/12
securing [2] 179/1
194/5
Security [1] 116/25
see [85] 1/3 4/20 5/9
5/11 5/19 6/25 8/6 9/2)
15/1 17/12 17/14 18/2)
18/16 18/18 19/25
22/18 23/7 25/24
25/25 28/22 34/16
34/19 34/21 36/14
37/23 39/7 39/13 43/2
55/7 55/20 57/5 58/25
64/2 64/18 65/21
66/10 67/5 74/9 76/18
79/10 79/20 79/23
81/1 82/25 83/24 84/6I
84/19 84/23 85/1 88/7
89/2 91/25 101/8
102/3 102/21 104/11
118/7 118/23 125/2
131/9 131/22 134/14
135/13 136/6 138/16
138/25 147/1 147/25
149/5 153/16 154/6
154/13 155/14 155/16
156/23 163/14 163/19)
164/4 164/9 164/19
168/5 169/4 173/6
189/14 194/13
(75) right-hand... - see
Ss
seek [5] 8/20 105/22
131/5 175/14 193/23
seeking [4] 82/9
94/13 150/10 176/6
seem [5] 19/14 58/9
124/4 134/23 140/7
seemed [4] 3/16 62/3
113/23 163/6
seems [16] 57/23
83/3 86/19 89/21
115/1 133/18 134/21
135/2 135/10 148/14
160/5 178/12 181/21
182/14 182/18 188/13
seen [17] 4/15 7/13
28/21 37/12 41/11
51/22 89/17 109/19
115/25 123/9 136/5
138/7 149/13 175/24
186/3 186/9 192/9
Select [1] 160/4
selecting [1] 102/9
sell [1] 187/16
send [7] 21/7 52/4
53/7 152/17 168/21
183/17 195/13
sending [15] 43/20
55/8 55/13 55/21
71/25 72/25 90/7
98/13 104/2 121/12
130/15 139/21 163/21
179/9 181/15
sends [5] 6/25 34/20
34/22 107/24 124/2
senior [8] 2/17 3/8
60/25 61/2 92/15
92/24 105/10 184/15
sense [11] 9/6 38/6
51/17 67/14 88/23
114/11 118/16 120/10
121/7 121/11 185/3
sensible [4] 34/9
150/14 162/24 164/14}
sent [47] 5/19 10/11
19/22 20/17 25/23
32/16 38/20 48/13
53/12 55/24 62/24
68/25 69/7 71/12
71/15 72/15 75/15
76/13 76/15 76/16
76/24 79/21 80/3 80/4}
80/9 80/12 80/15
80/19 80/19 81/4 81/9
81/11 81/12 91/4
95/21 97/10 99/15
100/25 102/24 119/2
123/23 124/4 125/3
143/5 154/10 179/12
187/3
sentence [5] 66/11
66/12 94/12 101/10
182/13
sentences [1] 182/9
separate [9] 24/25
45/14 52/23 58/18
98/13 131/25 174/24
190/6 194/1
separated [1] 52/22
separation [6] 11/22
15/5 15/25 16/7 52/24
53/2
September [2] 2/14
107/15
sequence [2] 75/14
76/10
series [2] 61/22
165/9
serious [6] 37/7
37/16 118/16 121/1
121/24 178/24
seriously [2] 37/8
117/9
seriousness [2]
37/18 37/23
serve [1] 71/23
server [1] 174/15
servers [1] 174/17
services [4] 161/15
162/6 162/14 186/13
set [23] 4/15 5/15
10/17 19/10 19/15
39/23 47/16 67/1
72/12 93/7 97/3 122/9
125/14 126/7 133/9
140/19 145/17 145/23)
148/22 148/24 165/3
169/15 192/22
sets [8] 37/24 48/19
53/20 56/4 83/9 94/1
152/22 169/3
setting [2] 112/8
140/15
settle [2] 188/19
193/19
settled [2] 175/9
181/4
settlement [13]
65/22 65/23 92/3 93/7)
134/25 135/22 135/23)
192/9 192/14 192/20
192/25 193/10 194/9
settlements [9]
91/17 135/2 135/3
135/5 135/10 135/11
136/4 136/10 136/22
several [2] 83/20
108/12
severe [1] 9/14
shall [2] 50/11 161/41
shape [2] 134/8
134/9
share [1] 73/8
she [18] 4/3 4/19 5/5
30/1 60/21 60/22
107/17 115/21 115/22)
115/23 116/1 116/4
116/9 118/3 152/2
158/2 169/5 189/14
she's [1] 116/2
Shoosmiths [3]
132/23 135/6 136/11
short [10] 35/24
47/18 50/17 97/5
107/10 110/9 131/20
156/5 159/11 176/24
shortfalls [1] 193/4
shortlist [1] 130/12
shortly [6] 4/12 33/10
55/7 160/4 160/10
160/10
should [58] 1/12 5/9
10/15 11/7 11/9 12/4
12/11 13/20 28/2 30/2
35/25 36/12 36/17
36/22 38/20 41/6
41/22 43/25 44/2 44/6
45/20 45/20 61/6
64/13 69/11 69/11
72/25 73/21 77/4 84/9
85/13 93/12 96/20
97/10 100/15 106/19
108/15 109/3 112/6
117/1 119/14 126/3
127/19 137/11 138/5
138/18 140/11 142/4
148/9 151/6 159/14
165/12 166/14 167/2
172/10 183/14 190/7
192/17
shouldn't [10] 39/14
42/2 42/7 44/5 46/2
46/8 59/2 127/23
151/7 195/9
show [5] 10/14 25/18
117/8 119/2 123/8
showing [1] 169/10
shows [1] 32/2
shredding [2] 40/2
40/3
sic [1] 173/5
side [25] 32/15 32/20
32/23 46/24 64/11
76/13 76/13 77/2
77/22 78/4 98/16
100/20 100/20 100/22}
100/22 101/11 101/21
119/16 123/19 150/1
161/9 182/24 182/24
185/10 195/3
sided’ [1] 139/12
sides [3] 32/8 48/9
166/24
sifts [1] 83/20
Sight [107] 6/1 6/4
27/12 27/14 28/15
28/19 28/24 31/14
31/25 33/19 52/12
52/14 58/4 62/10
87/11 87/16 89/18
91/20 98/20 104/20
108/16 113/11 114/11
116/24 132/1 132/22
133/23 134/23 135/3
137/13 138/19 138/21
139/2 139/5 139/19
139/22 139/24 140/2
141/12 141/19 142/1
142/7 142/9 142/12
142/17 143/12 143/16
143/25 144/2 144/8
144/18 145/11 145/16)
147/5 147/23 148/7
148/14 148/16 149/3
149/20 150/9 150/11
151/1 151/16 152/9
153/8 154/14 155/3
156/3 157/11 157/18
159/5 159/18 160/5
160/8 160/13 160/17
160/23 161/8 161/12
161/14 161/19 161/21
161/24 162/1 162/4
162/7 162/12 162/13
162/15 162/19 162/20}
162/21 163/3 163/15
164/8 164/12 164/17
166/21 166/22 167/4
167/6 171/4 171/5
172/4 172/11 172/16
Sight's [21] 53/4
56/12 70/17 86/6 86/8
87/12 113/13 114/6
114/9 132/25 133/5
138/20 140/13 141/3
145/13 149/9 159/13
161/11 163/9 164/7
164/10
sign [1] 42/24
signature [1] 1/18
signed [2] 124/7
124/20
significance [4]
81/25 94/23 95/9
105/23
significant [9] 38/6
56/21 59/4 77/1 88/2
88/3 163/1 175/19
185/21
signing [1] 89/10
silk [1] 60/7
similar [9] 17/12
44/23 44/25 45/16
76/21 95/18 131/4
134/21 140/5
Simon [26] 9/22
25/16 30/16 34/20
41/4 55/9 55/20 57/17)
58/5 59/16 60/16
60/25 62/14 62/17
62/18 63/9 64/4 64/16
95/13 98/10 98/12
98/15 100/3 105/9
106/24 108/5
Simon's [2] 59/2 65/8)
simply [12] 18/1 45/3
63/24 72/12 74/13
88/7 96/9 110/13
110/25 119/6 161/25
169/6
since [6] 49/11 113/6
116/14 116/16 117/14)
123/1
Singh [4] 50/25 95/14
95/16 136/25
Singh's [4] 100/18
single [2] 77/21
110/24
sir [22] 1/3 50/9
50/19 53/10 76/4 79/4
83/17 89/13 94/2
107/1 107/8 107/12
131/12 131/22 149/1
149/5 150/7 165/10
165/13 176/16 195/5
195/19
Sir Anthony [7]
83/17 89/13 149/1
149/5 150/7 165/10
165/13
Sir/Madam [1] 79/4
sits [1] 1/25
sitting [1] 157/18
situation [6] 19/7
19/11 19/16 64/10
162/17 180/17
sizeable [2] 22/21
22/24
slightly [15] 34/19
49/9 85/1 89/2 94/6
123/25 134/9 138/15
145/25 146/17 147/1
158/1 167/16 167/23
176/3
slow [2] 75/6 93/12
small [7] 20/3 20/12
21/2 21/17 23/2 23/3
174/12
small-value [4] 21/2
21/17 23/2 23/3
Smith [5] 34/19
39/16 42/3 136/25
149/14
smoking [1] 110/24
snapshot [3] 147/7
147/17 166/2
so [245]
soft [1] 125/11
soften [1] 11/5
software [1] 29/9
sold [1] 187/14
sole [1] 62/12
solely [1] 182/1
solicitor [4] 2/24
115/21 115/22 118/1
solicitors [11] 55/17
55/19 60/3 72/3 72/8
74/9 74/14 75/2 83/19)
88/15 88/19
(76) seek - solicitors
Ss
solution [1] 189/10
some [76] 4/24 5/5
6/12 9/22 11/9 11/17
23/5 27/11 39/2 40/7
41/8 41/16 44/22
47/20 51/17 53/20
57/25 64/23 78/9 87/7
89/3 90/15 92/9 94/18
95/22 96/6 97/24
104/9 104/9 111/23
113/25 115/25 116/19
117/11 118/13 126/2
128/25 130/22 134/18)
134/22 136/14 136/14}
147/3 147/3 147/4
147/5 150/7 150/14
151/10 152/6 153/8
153/10 153/17 153/24
153/25 158/8 162/13
164/4 166/9 167/5
171/11 174/9 175/10
176/4 178/20 179/23
180/16 181/3 181/23
182/2 183/10 183/13
187/12 189/11 192/5
192/13
somebody [11] 4/9
55/3 69/11 79/1 88/12)
125/5 154/24 158/19
173/25 179/19 186/13}
somehow [3] 30/9
92/14 126/5
someone [7] 14/3
18/2 23/10 29/17
34/15 88/11 174/22
something [40] 3/1
11/1 11/12 12/8 12/18
17/4 20/14 33/7 37/14}
42/1 42/5 44/5 44/12
45/11 63/4 63/5 63/24)
64/7 64/9 64/15 65/6
65/6 73/16 74/16 76/1
76/2 81/3 81/17 87/23}
98/7 112/7 123/10
129/13 129/17 131/5
131/8 140/21 156/2
180/12 191/14
sometime [1] 7/3
sometimes [3] 16/14
52/18 130/17
somewhat [1] 115/2
somewhere [3] 39/3
167/6 190/6
soon [2] 3/21 28/7
sooner [1] 172/12
sorry [12] 75/5 76/7
76/23 101/12 106/20
126/12 148/23 157/9
158/24 168/1 175/24
182/25
sort [4] 92/6 124/13
135/15 136/1
sorts [1] 160/2
sought [3] 10/21
34/16 181/9
sound [1] 47/11
sound’ [1] 86/13
sounded [1] 169/7
sounds [4] 11/8
17/24 40/24 72/9
source [1] 164/3
Southampton [1]
2/15
Sparrow [9] 66/1
83/7 83/9 89/13 89/14
91/9 140/18 163/19
163/25
speak [4] 9/21 14/25
64/16 105/20
speaking [3] 24/20
87/7 185/2
speaks [2] 43/21
90/7
specialises [1] 30/8
specific [15] 14/4
18/7 19/9 25/12 26/16
26/20 27/5 27/16
111/24 120/3 133/7
138/21 158/10 173/3
191/7
specifically [2] 20/22
107/21
specifics [3] 6/13
28/10 139/24
spell [2] 117/23
118/5
sphere [1] 115/2
split [1] 48/20
Splits [1] 152/20
spoke [6] 27/22
38/22 39/17 47/6
104/12 159/9
spoken [11] 26/6
27/20 43/10 43/12
51/9 54/17 95/13
98/10 106/24 137/16
186/23
sponsoring [1] 91/22
spot [6] 6/1 6/5 6/7
TINT 8/24 22/22
spotted [1] 24/5
spreadsheets [1]
38/20
SPSO [1] 5/25
spun [2] 117/8
133/16
Square [1] 29/5
Square/Falkirk [1]
29/5
Sree [6] 186/23
186/24 187/5 188/9
189/16 190/2
Sree's [1] 188/4
staff [4] 92/25 170/17
171/23 177/12
stage [38] 3/12 6/3
6/12 10/5 10/11 24/24
30/13 33/4 35/9 50/22,
53/15 54/4 61/2 86/20
87/15 93/19 111/16
115/22 116/1 119/14
128/25 130/24 135/17]
136/14 138/4 139/2
139/22 147/8 149/3
153/6 153/14 153/15
166/25 172/5 172/23
174/3 180/1 183/23
stages [4] 83/16
115/25 129/24 147/3
stand [4] 47/19
standard [1] 155/11
standing [1] 162/9
start [16] 3/17 8/5
25/14 29/24 29/24
35/3 42/13 82/24
111/9 114/3 132/1
132/2 167/13 167/16
172/18 186/10
started [2] 3/7 80/18
starting [1] 167/14
starts [1] 118/21
state [4] 46/5 93/2
117/1 180/15
stated [7] 31/11
38/19 94/12 97/12
99/11 122/4 142/11
statement [30] 1/13
1/14 1/16 1/20 1/23
5/15 5/18 7/5 29/23
46/15 47/10 48/9 49/4
49/5 49/7 49/14 49/15
49/16 49/19 99/8
101/3 101/5 103/19
109/17 117/4 117/24
118/18 118/19 162/23
170/11
statements [21] 29/7
31/2 31/8 35/14 35/18
48/11 48/11 89/16
100/12 171/19 175/3
175/8 177/23 177/25
178/9 179/15 180/15
181/2 181/18 184/8
184/17
states [3] 31/6 95/2
170/12
statistically [1] 56/21
status [3] 36/25 87/2
115/14
stay [3] 94/13 94/25
95/5
steady [1] 110/14
steer [3] 156/21
156/25 157/4
steering [10] 66/1
92/23 160/12 174/10
179/4 183/21 184/1
184/11 184/25 185/3
step [2] 190/2 193/11
Stephen [2] 2/25
27/23
steps [1] 51/24
Steve [3] 94/9 94/17
97/10
Steve's [1] 97/13
stick [2] 167/10
188/3
sticking [1] 103/14
still [28] 6/22 18/25
24/23 25/13 28/6
49/25 50/4 50/20
65/17 71/23 93/6
93/20 93/20 109/2
125/16 125/18 130/3
147/19 157/21 166/25}
168/6 168/21 177/19
178/9 180/11 183/2
183/16 191/25
stock [1] 117/6
stonewalling [1]
153/18
stop [3] 135/7 136/12
163/2
stopping [1] 160/21
stops [1] 139/10
stored [1] 52/18
story [2] 110/16
177/19
straight [1] 81/5
strategic [2] 33/22
34/9
strategy [7] 56/11
91/23 133/13 192/15
193/23 194/17 194/22)
Strategy/Members
[1] 91/23
stray [1] 113/7
straying [2] 115/2
143/7
street [1] 110/25
strengthen [1] 73/13
strict [3] 15/10
167/20 174/17
strictly [1] 42/23
strike [4] 15/18 16/9
16/10 193/15
strikes [1] 81/23
strong [6] 110/13
111/18 112/11 112/25]
114/22 169/19
struck [1] 15/2
structure [7] 136/2
136/17 136/18 148/21
148/24 173/2 180/10
Stuart [1] 79/2
sub [1] 79/8
subcommittee [1]
163/19
subgroups [1]
193/12
subject [11] 6/9
41/25 44/1 73/6 83/2
95/25 103/10 116/24
137/5 169/11 174/17
submission [1]
100/16
submitted [1] 31/13
subpostmaster [36]
3/24 6/18 10/13 11/19
11/20 11/22 12/24
13/23 15/3 15/9 15/14
15/17 15/20 16/6
16/22 19/25 21/12
25/1 26/12 27/10
91/17 109/1 111/1
124/20 132/22 132/24)
133/16 136/8 154/17
154/18 155/8 155/10
156/10 165/20 168/18)
192/10
subpostmasters [37]
2/22 9/6 9/9 9/12
10/21 12/7 13/19 15/6)
19/6 19/15 22/21
22/23 23/22 27/3
37/20 52/10 53/1
70/14 79/15 83/11
91/21 95/21 97/24
102/4 109/7 113/24
114/18 114/20 123/18)
134/24 136/15 137/14I
155/4 166/9 166/11
169/2 172/1
subpostmasters'’ [7]
15/11 15/25 17/20
24/25 71/2 95/4 134/4I
subsequent [3]
110/2 120/7 133/8
subsequently [3]
29/8 37/17 154/18
subsequently-correc
ted [1] 29/8
subset [1] 166/9
substance [4] 51/18
119/8 171/11 171/13
substantial [1] 96/3
substantive [8] 1/18
2/1 104/3 113/13
119/12 177/5 177/7
193/21
substantively [2]
84/24 86/21
success [3] 91/15
92/1 134/12
successful [1]
113/15
successor [1] 25/1
such [13] 12/3 46/8
94/25 116/19 118/15
121/1 147/24 149/22
162/3 170/15 170/18
173/16 174/22
suffered [3] 19/18
19/19 22/21
suffers [1] 33/25
sufficient [4] 105/15
137/22 148/20 158/21
suggest [7] 12/11
(77) solution - suggest
Ss
suggest... [6] 18/22
21/24 74/13 155/17
170/22 181/5
suggested [6] 10/15
96/4 102/5 143/11
155/13 178/20
suggesting [5] 66/23
96/19 102/8 122/23
165/16
suggestion [7] 9/16
41/7 54/18 69/23
135/11 164/19 171/8
suggestions [2]
134/18 188/23
suggestive [1]
181/24
suggests [8] 32/25
41/12 43/6 47/3 74/8
80/2 99/7 103/18
suitable [8] 107/6
145/9 145/21 146/10
146/20 146/21 147/14
147/16
summarised [1]
82/17
summarises [2] 40/5
40/13
summary [4] 6/13
87/2 143/2 187/8
summer [20] 6/3
13/15 23/19 24/23
25/5 25/14 28/8 29/18
37/13 53/15 62/19
63/3 65/17 93/17
104/16 135/12 141/2
143/23 174/3 181/14
super [3] 174/13
174/23 175/23
super-user [1]
174/23
super-users [2]
174/13 175/23
supervising [7]
30/12 31/19 32/13
55/9 59/10 62/9
132/10
supervisor [2] 118/1
118/3
supplemental [1]
48/25
support [3] 35/15
169/8 179/1
supporting [1]
158/10
suppress [1] 117/12
sure [15] 9/16 13/2
23/10 30/10 45/2
54/11 72/19 80/6
85/17 118/3 125/11
135/3 149/6 178/25
182/22
surely [5] 16/5 72/17
72/25 124/15 131/4
surprised [1] 135/11
Susan [18] 3/13
29/25 30/19 33/5
33/11 33/12 34/20
34/22 42/14 50/24
50/25 59/15 60/19
60/20 61/13 132/3
132/5 134/19
suspect [4] 9/5 39/2
63/11 146/23
suspended [2] 27/14
137/11
suspense [6] 7/25
25/6 29/1 93/18
104/16 152/18
Swift [1] 176/1
swiftly [1] 141/2
system [27] 5/8 6/14
28/17 31/13 52/9 52/9)
70/24 72/5 77/8 77/15)
78/18 79/7 79/11
79/18 94/15 117/3
129/6 129/10 130/22
139/9 170/14 170/16
173/9 173/10 183/11
189/2 193/2
system-generation
[1] 94/15
systemic [4] 31/25
43/7 52/17 79/13
systems [1] 31/10
T
table [3] 152/21
152/22 154/6
tactical [3] 34/14
130/15 184/13
take [47] 2/4 3/20
5/18 7/2 28/20 30/5
42/16 46/14 53/10
54/5 65/18 66/2 76/4
94/3 94/6 96/20
103/24 107/3 107/5
108/15 110/1 119/16
119/18 119/19 125/12)
130/15 131/12 140/22)
142/12 142/14 144/13)
149/3 151/13 151/14
151/21 163/22 165/1
165/10 167/10 176/18)
189/22 190/7 190/19
191/20 191/21 192/2
194/6
taken [17] 14/14
17/25 18/23 23/21
30/17 40/8 51/25
98/14 98/15 100/3
109/18 124/8 150/6
154/12 167/3 185/18
186/3
taking [16] 2/5 3/17
41/17 42/3 45/10
47/21 98/21 117/9
133/22 140/5 140/14
145/19 150/24 156/1
157/6 158/21
talk [5] 6/22 65/25
124/6 124/10 124/14
talking [20] 7/16 12/5}
12/10 12/23 26/20
39/10 44/8 45/5 45/18}
45/21 54/11 92/11
93/24 109/11 136/17
136/18 140/16 157/19!
185/11 185/12
tandem [1] 162/18
targeted [2] 139/23
140/6
targeting [1] 18/7
taxpayer [1] 191/23
team [17] 8/7 8/9
8/15 13/25 27/9 55/2
71/14 83/11 86/12
92/19 115/21 118/4
133/12 140/18 184/21
184/25 189/22
teams [5] 5/3 48/12
91/24 92/12 92/16
technical [10] 9/23
23/13 24/9 46/23
93/13 110/22 129/5
178/14 187/22 190/22
technicality [1]
193/14
technically [6] 38/24
39/9 40/20 47/9 49/24
59/17
teleconference [2]
141/4 141/9
tell [10] 19/22 88/12
124/15 124/15 124/23}
129/16 140/19 174/2
177/19 186/1
telling [2] 115/15
150/20
ten [2] 45/21 147/18
tenants [1] 173/5
tended [2] 92/23
146/10
tension [2] 144/1
165/23
tensions [3] 143/24
148/13 148/15
term [1] 57/16
terminate [4] 159/13
160/7 160/17 162/24
termination [6] 159/4
159/5 159/24 160/13
161/6 162/18
terms [36] 3/11 4/10
6/20 17/14 28/10
55/14 56/4 58/16
58/18 59/8 61/17 62/5
62/6 62/12 62/13
62/21 62/23 63/3 63/8
63/13 64/13 73/2 73/2I
78/20 82/13 108/7
111/4 114/4 114/12
119/19 129/15 144/7
159/24 161/25 164/16}
186/4
test [4] 37/5
text [3] 7/22 84/15
152/6
than [34] 17/21 18/1
18/23 26/1 26/24
35/17 42/20 43/20
53/21 58/10 59/11
62/16 63/24 76/25
85/2 90/7 105/10
110/24 112/21 113/3
117/4 119/7 139/25
142/16 144/15 144/20}
153/21 171/2 172/13
182/9 182/19 187/22
193/19 195/10
thank [36] 1/4 1/5
1/10 1/23 3/11 6/8
8/10 13/22 28/22
33/10 35/22 42/6
46/16 48/15 50/9
50/15 50/19 56/3
66/14 76/20 81/7
101/12 107/8 107/12
109/25 117/20 118/20}
131/18 131/23 131/24}
141/10 176/15 176/22)
177/1 186/14 195/19
thanks [3] 14/2 55/5
84/2
that [1207]
that I [4] 195/14
that's [80] 3/6 3/19
8/10 14/6 15/7 18/20
19/21 19/22 23/4
23/25 28/18 29/1 29/4I
30/6 31/16 34/22
35/12 35/19 39/6
39/12 40/5 40/25 46/1
47/15 47/15 49/14
50/9 52/3 58/12 60/5
64/15 66/15 67/19
68/14 71/11 75/19
75/20 76/14 76/25
78/25 80/17 80/25
82/8 87/23 88/4 89/7
89/24 93/1 94/5 97/1
100/6 100/24 103/12
107/5 115/15 118/23
119/22 122/5 126/22
129/7 129/10 136/5
138/21 139/4 141/15
145/16 147/6 152/8
153/13 155/25 156/20}
158/17 161/1 165/8
168/20 188/12 188/17)
189/11 189/12 195/12)
theft [3] 110/20
113/14 114/25
their [52] 3/15 12/25
14/4 17/21 20/22 22/8}
30/4 33/19 33/23
34/14 36/19 36/24
44/20 44/21 45/2
48/23 50/6 53/1 64/7
72/15 103/12 114/3
114/4 114/10 114/12
120/17 132/24 134/25)
135/18 137/18 139/6
139/20 139/24 140/6
144/2 144/4 148/8
148/17 148/24 155/5
160/23 162/4 163/8
163/15 173/12 173/13}
173/15 175/11 177/4
178/15 190/1 194/1
them [59] 13/1 21/25
41/5 42/1 43/22 48/10
55/14 60/17 64/23
69/1 73/11 74/23
76/18 76/19 88/20
90/8 92/25 101/7
103/8 106/15 112/13
113/15 113/19 116/13)
127/13 127/16 127/21
128/9 128/20 128/20
128/20 128/21 129/18)
129/24 129/25 131/11
137/10 138/11 139/22)
142/2 144/20 153/1
156/21 156/21 157/12)
157/12 157/13 157/14I
157/20 159/2 162/3
163/10 166/10 168/21
172/12 172/17 176/8
185/4 194/2
thematic [2] 138/25
139/20
theme [3] 139/16
140/14 140/15
themes [2] 133/6
139/3
themselves [2] 74/11
164/12
then [96] 3/13 4/23
11/16 13/5 13/8 13/13)
14/25 15/1 16/10
19/10 23/12 24/8
28/19 37/17 37/24
38/23 38/24 39/8 39/9
40/20 43/3 45/21
46/24 47/2 47/8 47/9
48/22 49/24 53/12
56/23 57/15 67/15
75/14 84/23 87/9
87/17 89/12 89/13
92/12 99/13 101/18
101/20 101/25 107/4
107/5 108/15 108/19
109/5 110/17 111/8
4112/7 114/1 116/9
118/8 126/25 130/10
130/11 133/19 134/10)
134/19 135/16 139/15}
148/19 153/7 157/13
(78) suggest... - then
T
then... [31] 157/16
162/14 162/21 163/6
163/22 164/6 164/9
165/13 167/9 167/10
169/3 172/15 173/2
173/8 175/1 176/6
178/14 180/17 184/3
184/10 188/20 190/6
190/7 190/13 191/14
191/16 192/11 193/9
193/11 194/21 195/8
theoretical [1] 125/6
there [235]
there'd [1] 80/14
there's [30] 2/3 4/2
6/19 29/4 30/11 33/2
76/22 76/22 83/15
92/25 110/17 113/8
113/10 123/23 124/21
130/22 132/2 144/9
145/3 150/10 152/8
152/10 157/16 158/22
161/5 167/22 179/17
182/11 183/10 186/12)
thereabouts [2] 4/11
4/12
thereafter [2] 4/12
55/8
thereby [5] 15/8
36/18 59/5 68/22
171/11
therefore [18] 9/16
40/18 46/8 47/19
49/21 50/4 82/9 100/4
121/7 127/19 131/15
133/12 139/7 155/8
162/17 172/4 175/6
193/5
these [60] 4/5 8/20
11/15 12/5 12/10 13/5
13/22 14/8 17/20 20/6)
25/11 27/14 27/15
37/5 38/12 39/22
39/23 48/11 48/13
48/20 49/16 53/8
62/24 63/21 65/8
70/15 71/3 77/17
88/21 90/22 101/14
105/8 106/14 108/14
118/11 124/16 128/1
128/1 128/4 128/13
128/19 130/14 131/10}
133/11 137/7 137/9
143/1 145/19 146/23
151/22 153/5 157/19
170/5 173/6 179/21
184/22 185/7 191/6
194/12 194/14
they [132] 3/16 15/15
15/16 16/19 18/19
27/4 28/16 28/16 32/4,
32/25 34/12 37/19
39/24 41/6 41/22
41/24 41/24 42/2 42/7
42/8 44/5 44/6 44/24
45/14 45/16 45/16
45/17 46/6 49/13
55/16 59/17 59/20
59/22 60/17 60/24
61/8 64/15 68/25
69/12 73/8 83/4 83/19
84/6 85/2 87/13 88/12
88/18 88/23 92/24
93/23 96/16 96/18
103/7 103/8 103/9
104/13 105/15 105/15)
105/16 106/7 106/16
111/14 111/19 112/19}
113/16 113/21 113/23)
114/13 114/14 116/18)
122/5 122/12 122/12
122/17 122/21 124/11
127/7 128/6 128/7
128/16 128/19 128/21
129/13 129/20 130/1
130/21 135/18 136/9
137/9 138/9 139/11
142/16 142/17 144/15)
146/11 146/13 148/17,
148/19 148/21 148/23)
149/11 150/9 153/8
154/1 154/4 159/19
159/25 160/1 160/16
160/24 161/21 163/6
163/13 165/6 168/25
171/6 172/10 173/13
173/15 174/20 178/9
178/16 184/8 185/25
186/1 188/13 188/19
189/1 190/10 192/20
193/3 193/19
they'd [2] 130/23
151/2
they're [6] 45/2 45/4
60/24 76/21 132/17
136/19
they've [1] 152/9
thick [1] 126/16
thin [1] 41/4
thing [2] 11/4 89/7
things [27] 28/8
39/14 41/23 42/8
45/15 45/23 47/23
47/25 53/14 67/4
90/13 90/23 90/24
91/25 93/16 94/21
104/6 104/15 128/16
128/16 129/11 129/12)
133/22 142/12 142/14)
144/13 144/19
think [212]
thinking [4] 104/6
173/7 179/13 194/16
third [12] 19/10
19/20 26/20 40/7
48/17 56/23 61/24
66/2 101/10 139/9
162/3 190/13
this [512]
Thomas [3] 111/10
113/2 178/22
thorny [1] 137/2
thorough [7] 14/14
17/13 17/14 17/25
24/14 151/4 167/9
thoroughly [5] 14/9
14/20 18/6 18/13 20/7
Thorp [2] 8/7 8/13
those [108] 3/7 6/4
12/13 13/8 14/24
15/22 18/7 19/6 19/8
19/9 19/11 19/18
19/19 20/21 22/20
23/2 24/13 24/19
24/22 26/21 27/1
28/13 35/21 36/23
38/2 38/5 40/21 40/22
41/3 41/4 41/7 41/15
41/19 41/20 41/22
42/4 44/8 44/23 45/1
49/7 49/22 50/7 53/5
55/23 56/3 57/7 57/21
58/12 62/13 63/16
67/1 70/9 78/24 82/9
82/23 84/24 85/7 92/7
93/4 93/16 93/17
93/18 93/22 102/10
102/10 102/11 104/10
104/15 105/4 105/13
105/19 105/21 106/25}
111/12 114/15 115/5
120/3 121/14 121/17
121/25 122/10 122/16
123/13 125/2 126/3
127/7 127/11 128/23
133/19 140/21 140/24
143/24 144/1 146/8
147/7 150/3 151/11
152/24 153/4 159/2
164/6 165/5 166/10
166/16 169/14 169/20}
173/24 188/8
though [27] 13/3
17/25 19/14 23/25
34/18 45/16 57/23
58/9 63/23 80/6 82/13
83/4 89/21 96/15
115/11 119/5 119/8
133/18 135/10 144/23}
165/16 166/11 178/9
181/22 182/18 183/1
188/13
thought [29] 13/14
18/17 33/13 44/16
67/24 68/4 68/14
68/16 72/19 72/22
72/25 89/22 105/5
106/25 117/17 121/11
122/12 124/4 134/11
137/21 144/2 144/20
146/13 150/3 169/23
170/3 178/16 185/25
186/1
thoughts [9] 64/24
65/2 87/10 95/18
110/5 110/8 116/8
138/18 163/25
thoughts/comments
[1] 116/8
thousands [1] 129/4
three [13] 7/22 29/19
29/20 43/14 70/19
76/25 90/18 93/22
95/18 104/20 111/12
114/19 115/1
three pages [1] 7/22
three years [2] 70/19
76/25
threshold [1] 93/8
thresholds [1] 93/7
through [27] 6/23
17/3 33/10 56/2 80/24}
97/7 97/15 104/6
124/5 146/10 146/11
147/6 153/5 157/19
158/17 165/8 165/19
170/1 170/5 170/9
178/11 180/8 189/1
191/16 193/24 194/6
194/8
throughout [3] 37/12
97/17 194/12
throw [1] 177/17
throwing [1] 177/20
Thursday [1] 1/1
Thus [1] 137/6
Tim [4] 123/24
time [78] 2/23 8/1
13/15 15/7 18/17
23/12 23/18 23/20
23/25 24/8 24/12 25/3)
27/3 29/20 32/22
33/18 37/8 42/14
43/10 44/19 50/10
50/11 58/3 59/8 59/20
62/1 63/8 66/1 80/7
81/24 87/25 94/3
94/13 113/6 113/6
118/16 119/10 119/15)
119/23 120/25 121/15}
121/17 122/1 122/7
122/11 122/15 122/17)
123/14 126/10 131/11
134/2 141/18 144/16
146/16 146/23 147/7
147/11 151/9 156/5
156/10 156/13 156/19)
157/2 157/8 161/20
169/6 169/17 169/20
169/23 169/25 176/17,
179/11 180/14 184/20}
184/23 185/11 193/15)
195/11
time-barred [1]
193/15
times [6] 4/15 28/21
141/21 141/22 176/9
191/6
timetable [1] 133/4
timing [3] 108/11
132/14 164/16
tip [3] 117/22 117/25
118/5
today [11] 2/3 3/17
7/3 30/16 89/24 90/1
93/17 137/16 190/19
192/2 195/17
together [2] 117/16
123/3
toing [1] 186/3
told [9] 23/18 88/8
103/8 103/16 126/10
130/2 130/19 130/23
138/9
tomorrow [7] 51/9
54/17 145/10 145/18
151/15 195/11 195/18
tomorrow's [1]
174/10
tone [1] 181/3
toned [2] 178/8
180/10
toning [1] 180/12
Tony [2] 130/7
182/22
Tony's [1] 127/21
too [13] 13/2 55/22
70/9 84/14 85/4 94/1
111/18 118/10 128/24I
141/23 153/11 167/7
169/18
took [18] 4/6 17/19
23/12 23/20 24/8
24/13 25/2 26/17
27/21 35/12 37/7
89/25 90/12 101/15
103/12 103/12 105/8
194/11
top [15] 6/24 25/25
55/22 67/7 68/2 69/14
69/15 70/6 73/5 98/9
112/18 114/21 124/1
170/12 171/24
topic [5] 167/8
167/12 169/21 190/3
192/14
topics [1] 131/25
Torstein [1] 190/10
total [1] 152/19
touch [2] 106/13
134/15
touched [1] 112/5
touches [1] 98/7
touching [2] 106/10
176/10
touchpoints [1]
115/3
tougher [1] 165/2
(79) then... - tougher
T
towards [4] 113/24
146/9 147/11 167/4
toxic [3] 135/6 136/4
136/6
TP8 [1] 15/15
trading [2] 15/15
188/6
traditional [2] 66/8
66/14
traditionally [1] 67/4
trail [5] 31/11 41/13
43/22 90/9 174/20
i" inee [2] 2/11 116/1
ers [1] 49/11
training [1] 49/10
transaction [30] 3/25
4/20 6/14 7/16 11/18
70/16 139/11 139/12
155/5 155/9 167/19
168/14 171/1 171/21
173/12 173/17 173/21
174/25 175/20 187/9
187/13 187/17 187/18}
187/21 187/23 188/10)
188/14 188/19 188/25
189/17
transactions [20]
93/10 94/15 139/8
139/10 168/12 168/16
171/2 171/3 17118
171/9 171/25 172/2
172/9 173/14 173/16
174/14 174/16 174/19
175/4 175/22
transferring [1]
92/10
transparent [1] 106/7I
travel [1] 160/14
tray’ [1] 89/10
treat [2] 168/24
169/18
trial [9] 48/20 49/2
126/5 127/8 127/11
192/16 193/8 194/13
194/24
trials [1] 194/1
tried [5] 106/12
141/22 153/17 173/6
180/25
tries [1] 159/25
true [6] 1/20 4/24
90/17 119/11 170/14
184/6
trust [1] 138/5
truth [5] 49/15 74/18
140/20 142/9 142/17
try [14] 2/4 48/9 68/2
69/24 117/12 117/22
118/11 124/18 153/21
154/3 157/4 157/12
161/21 192/12
trying [13] 34/12
66/24 106/15 117/10
131/2 139/25 142/11
146/7 153/23 154/3
turn [66] 1/17 3/24
5/20 10/10 13/21
18/25 22/10 25/13
28/22 33/2 34/18
34/24 35/22 37/24
39/25 42/10 48/3
48/15 48/17 49/3 49/6
54/13 55/6 55/23
58/14 61/10 65/14
66/15 71/11 76/19
82/24 84/23 88/25
91/3 91/12 93/6 94/8
101/5 101/7 107/13
109/25 123/22 123/23)
124/1 130/7 130/21
134/13 134/14 134/17)
136/24 138/13 141/1
145/2 147/19 149/12
152/1 157/21 170/6
177/1 180/4 181/11
182/4 183/16 186/7
186/16 194/1
turns [1] 68/24
tweaking [1] 43/5
twice [1] 24/5
two [36] 10/6 10/14
19/17 21/2 21/17 23/1
27/1 38/11 41/2 45/14
55/13 58/18 59/3
82/21 82/23 112/10
120/3 121/5 121/14
121/25 122/1 122/2
134/11 136/19 142/20)
153/6 160/8 160/18
160/19 160/21 160/25)
163/16 164/5 164/6
182/9 195/10
two hours [1] 195/10
type [7] 21/3 21/7
92/4 129/18 136/17
174/21 178/15
types [2] 63/21 105/8
U
ultimate [1] 78/15
ultimately [13] 25/23
45/7 53/9 55/10 64/18
81/11 100/8 118/12
119/21 134/5 150/5
193/25 194/13
unbiased [1] 34/15
unclear [1] 40/9
uncomfortable [4]
149/23 184/12 184/16)
185/1
uncoordinated [1]
28/2
uncovered [1]
127/15
under [18] 21/1 44/2
156/20 157/19 193/14)
69/24 70/24 72/1
79/23 80/12 94/13
109/2 109/2 109/5
109/18 122/3 125/21
161/14 176/3 191/14
194/13
underlying [3] 87/1
137/12 183/10
undermine [3] 9/19
9/25 193/16
undermined [5] 10/4
36/12 71/6 77/19
89/17
undermines [4] 36/9
158/5 158/14 158/23
underneath [1] 92/25
understand [19] 4/21
9/17 10/5 10/9 30/10
40/8 46/18 49/12 56/4
64/9 75/7 96/2 124/25
130/25 139/24 158/16
184/12 185/7 190/15
understandable [1]
108/10
understanding [21]
AIT 10/8 23/4 23/17
24/1 35/20 57/25 58/7
70/2 70/3 87/25 90/16
90/25 101/16 134/2
151/10 163/12 163/12
173/20 174/18 183/11
understood [13] 5/3
14/6 15/7 37/18 58/13
65/10 65/11 75/16
87/3 99/4 121/8
169/16 173/1
undertake [2] 27/17
123/7
undertaken [2] 57/3
79/11
undertaking [2]
14/10 20/8
Underwood [5]
152/11 167/15 168/7
168/8 169/15
Underwood's [1]
153/4
undisclosed [1] 71/1
unexplained [3] 14/1
20/4 23/2
unfairly [1] 164/24
unhelpful [1] 31/24
Unique [1] 1/23
unless [4] 91/24
92/16 127/20 133/3
unlikely [6] 128/7
134/7 169/8 169/24
184/5 193/4
unlikely’ [1] 170/23
unmeritorious [1]
164/23
unpack [1] 135/9
unpalatable [1] 158/7I
unredact [3] 105/1
105/11 105/12
unredacted [3] 96/5
100/4 100/20
unrelated [2] 52/23
191/18
unrepresented [1]
28/3
unsafe [2] 70/20
89/15
unsafe' [1] 57/14
unsuitable [12]
145/25 145/25 146/1
146/2 146/2 146/2
146/5 146/13 146/14
146/22 166/3 166/5
unsure [1] 152/18
unsurprising [1] 39/4)
until [14] 33/8 41/7
51/8 54/16 87/13
118/15 120/25 121/23
123/11 138/25 161/15}
194/20 194/24 195/21
unusual [1] 174/21
unwarranted [4]
137/13 137/19 137/24}
138/4
unwinding [1] 175/9
up [61] 6/24 9/2 9/9
22/17 22/18 24/3
34/21 39/23 49/3
55/20 55/22 64/1
69/14 69/24 76/12
80/18 83/24 84/19
92/14 97/22 98/9
100/21 100/24 101/5
103/24 104/11 105/8
107/24 116/24 118/19}
126/8 132/12 133/9
138/22 140/19 144/9
145/1 146/17 146/25
150/6 152/10 153/16
155/16 156/24 167/22
167/23 168/5 169/4
171/17 174/11 176/4
178/17 178/21 179/24}
186/14 188/8 188/18
189/14 189/19 192/11
193/5
update [5] 83/7 83/9
87/24 88/3 88/23
updated [3] 126/24
127/2 180/22
updates [2] 89/12
89/12
updating [1] 84/5
uploaded [1] 1/24
upon [6] 35/4 35/6
119/8 128/23 143/8
176/10
ups [1] 10/14
urgency [1] 95/7
urgent [1] 116/11
urgently [1] 130/8
us [29] 5/12 9/18
9/24 14/2 27/22 29/6
83/14 93/24 95/18
121/4 129/15 129/16
130/2 130/23 136/6
155/12 160/1 177/19
178/1 179/10 181/4
182/14 182/19 182/23)
184/14 190/10 190/19}
193/5 193/7
use [15] 4/22 11/3
46/20 46/25 47/2
47/11 47/23 49/18
49/19 117/4 150/3
153/1 168/2 168/4
173/21
used [14] 5/2 39/3
49/20 52/9 52/18 72/5
79/8 99/10 103/20
127/11 134/23 154/12)
155/22 180/17
useful [2] 30/7 84/15
user [2] 98/25 174/23}
username [1] 101/9
users [2] 174/13
175/23
uses [1] 159/17
using [9] 5/13 6/20
114/18 117/6 147/23
148/21 148/24 167/19)
182/22
usual [3] 21/3 21/7
125/10
usually [1] 133/9
utility [1] 194/2
utmost [1] 95/9
Vv
validate [1] 137/10
value [8] 20/3 20/12
21/2 21/17 23/2 23/3
164/2 175/5
van [2] 158/2 189/14
variation [1] 139/16
various [7] 4/13
10/17 40/13 63/7
78/22 93/17 194/14
vein [1] 97/3
Vennells [5] 83/5
89/3 91/6 160/5
168/20
veracity [1] 125/4
verbal [1] 43/24
verbally [3] 43/22
44/6 90/8
verbatim [6] 39/1
40/16 45/2 47/19 48/1
50/3
verified [1] 49/14
version [57] 19/5
19/20 20/20 43/6
71/12 76/13 76/15
76/16 76/23 77/2
77/10 77/25 78/1 78/9
78/10 78/10 78/15
(80) towards - version
Vv
version... [40] 78/16
79/23 79/24 80/2 80/3
80/5 80/8 80/18 80/19
80/20 81/10 81/11
82/14 96/5 99/15
100/17 100/20 100/23)
100/24 100/24 100/25)
101/1 101/11 101/18
102/24 103/23 116/21
116/22 116/23 117/14}
123/1 128/3 153/6
153/11 154/9 156/23
160/19 160/20 182/6
189/12
versions [8] 19/17
120/4 121/25 122/1
123/4 128/2 128/4
128/13
very [70] 1/5 1/16
3/20 5/17 7/19 8/12
8/18 17/11 28/20 33/4
33/5 34/13 37/7 37/8
38/6 40/24 42/22
44/23 44/25 53/20
55/16 59/14 60/24
61/9 62/23 75/10
76/14 76/21 77/22
84/2 86/17 88/25 89/7
97/17 109/12 109/17
111/7 112/6 118/20
118/25 121/12 123/11
125/11 131/4 131/16
131/18 136/19 137/17)
140/5 141/18 154/1
156/5 156/10 157/22
160/4 165/4 166/2
167/20 169/23 170/18)
173/1 176/22 178/23
184/12 185/1 185/9
189/13 190/20 191/1
195/19
vet [1] 165/5
via [4] 184/21
view [62] 3/15 5/16
9/20 10/1 10/3 10/9
11/21 15/24 16/25
17/2 31/1 55/16 59/2
60/9 60/21 61/6 61/8
64/18 64/21 68/14
95/11 97/9 103/12
105/22 110/9 114/16
122/21 127/7 133/10
134/3 134/4 137/12
137/16 137/18 138/3
138/4 138/6 140/15
149/4 151/4 156/11
157/17 158/5 158/14
158/20 158/22 164/14)
165/23 168/11 169/14
177/24 178/4 178/4
181/4 181/8 181/22
182/18 183/1 183/5
183/9 184/5 188/4
viewed [1] 192/21
65/8 97/13 98/14
98/15 113/13 126/9
132/24 163/22
violated [1] 16/7
lity [4] 59/21
le [1] 168/17
vital [2] 91/15 92/1
voice [1] 132/24
volume [1] 162/2
Ww
wait [3] 112/7 112/15
115/10
waiting [4] 4/5
101/14 115/15 147/3
waits [2] 110/11
114/23
waiving [1] 177/18
wake [1] 193/6
walk [1] 192/20
wane [1] 157/17
waned [2] 141/17
151/9
wanes [1] 157/15
want [26] 5/2 11/25
12/8 12/13 15/22 16/3
43/4 43/14 49/15
49/21 65/18 66/2
71/16 75/7 84/14
89/19 100/17 100/19
110/1 124/9 124/11
124/22 129/2 142/12
181/1 182/12
wanted [9] 10/8
63/12 76/10 88/17
128/21 160/16 163/6
163/13 174/10
Ward [1] 95/2
warrant [3] 70/13
87/23 127/22
was [452]
wasn't [30] 11/2
18/22 21/25 29/11
33/8 51/1 51/16 59/13
63/2 63/15 69/25
72/18 73/14 78/10
80/19 82/1 103/25
105/6 112/9 112/18
112/25 115/23 122/23}
130/21 135/18 135/25)
149/2 157/2 163/12
165/4
watched [1] 113/5
waxed [2] 141/17
151/8
waxes [1] 157/15
way [27] 8/12 18/2
18/15 18/16 18/18
61/23 63/25 65/3
66/19 78/12 80/6
90/15 92/9 95/19
<
<.
views [10] 33/13 64/2
103/5 111/23 118/11
120/22 125/21 137/10
140/10 148/16 149/21
164/18 168/15 181/23}
187/3
ways [3] 133/22
187/9 189/1
WBD [3] 60/23 150/1
150/1
WBON0000133 [1]
29/24
WBON0000393 [1]
55/6
WBON0000465 [1]
115/19
WBON0000467 [1]
117/20
WBON0000496 [1]
182/4
WBON0000767 [1]
132/1
WBON0000770 [1]
34/18
WBON0000777 [2]
50/20 54/14
WBON0001024 [1]
172/18
we [451]
we'd [7] 122/2
130/23 130/24 132/13
175/24 176/13 181/9
we'll [12] 34/17 51/17
65/23 82/25 110/1
118/10 118/15 131/16
132/1 166/6 167/9
173/1
we're [37] 1/5 12/10
18/25 23/19 24/23
26/20 29/18 42/11
45/21 50/20 51/10
54/11 61/12 65/16
76/18 107/15 123/21
126/16 130/3 131/24
136/23 138/13 140/22
141/1 152/1 157/21
159/6 167/13 172/19
177/3 181/12 181/14
183/1 183/1 183/2
183/2 183/16
we've [21] 4/15 32/22I
37/12 51/21 61/11
74/16 74/18 93/16
93/19 104/16 109/11
115/25 128/18 136/5
137/16 168/1 170/9
180/25 185/8 185/13
186/3
weakening [1] 90/13
weapon [1] 134/23
website [1] 1/25
Wednesday [1] 40/9
week [5] 52/2 53/8
82/21 127/6 137/2
weekend [2] 89/10
12715
weekly [2] 45/10
90/11
weeks [1] 8/16
weigh [1] 123/15
well [34] 3/19 18/18
19/14 19/21 27/3 46/5)
55/21 58/9 59/15 75/8)
75/20 78/1 80/8 83/13}
83/22 102/13 108/23
128/18 129/22 131/16}
146/11 147/10 147/17]
149/19 151/24 154/11
156/17 156/20 157/16}
157/18 163/7 175/24
178/23 185/4
went [9] 25/2 53/9
59/22 61/1 78/10
104/11 153/5 158/25
166/19
were [223]
weren't [18] 16/19
19/11 20/21 24/15
54/10 57/23 60/18
88/18 104/4 106/11
122/5 129/20 130/2
135/18 135/19 148/21
148/23 152/25
Westminster [1]
157/23
what [135] 3/15 4/7
4/23 5/11 11/11 12/23
14/6 14/14 14/18 15/7}
16/12 16/23 18/10
18/20 19/13 22/17
23/18 26/22 28/18
32/4 35/12 35/18
35/19 35/24 39/1 39/5
40/2 40/10 41/8 41/25
46/10 47/4 47/18
49/12 50/1 50/11 58/6)
58/12 60/11 61/9
63/23 65/4 65/5 65/25)
66/24 67/3 67/13
67/19 69/25 70/10
75/3 75/20 75/23
75/25 81/2 85/17 87/3,
88/7 88/10 88/12
88/24 90/20 92/3
92/21 101/16 106/15
109/14 110/3 110/21
112/7 112/13 112/18
113/18 117/23 118/6
118/10 119/6 119/20
120/5 120/24 121/16
121/16 122/10 124/9
124/11 124/12 124/16
124/17 124/17 124/21
124/23 124/23 126/7
129/10 129/20 130/19}
131/2 131/4 131/4
132/9 134/5 134/21
135/21 136/6 136/7
136/13 137/20 138/9
138/18 141/24 142/1
146/11 149/6 151/5
151/19 154/2 154/8
157/4 157/8 158/15
165/8 167/18 168/23
169/14 169/16 175/1
177/20 179/21 183/1
184/1 184/14 185/25
188/17 190/11 195/13}
what's [9] 39/6 40/2
60/5 64/21 69/20
73/24 75/16 81/3
195/15
Whatever [2] 113/15
189/23
when [36] 2/12 2/23
3/2 3/7 5/13 17/1
22/13 22/16 43/7
43/10 46/25 61/20
70/2 76/12 82/7 95/1
95/25 103/6 104/3
104/10 105/8 116/1
116/12 129/24 139/24)
140/19 155/9 156/17
157/17 162/3 172/8
184/9 189/16 191/15
192/17 192/21
where [65] 4/20 14/3
17/7 18/5 24/14 25/22)
31/6 37/3 37/3 37/5
45/15 49/13 68/25
70/13 70/20 71/4 71/9I
77/18 80/18 82/17
84/13 85/21 90/18
93/9 97/22 99/22
104/4 104/8 106/19
109/15 114/22 122/19)
122/24 123/6 126/4
134/9 134/16 135/3
139/9 140/22 141/18
144/4 146/13 146/15
148/4 148/18 153/8
153/10 154/1 154/12
154/17 156/23 158/9
165/19 166/1 166/4
167/5 176/9 178/14
181/7 182/17 182/20
189/2 190/19 193/18
whereby [1] 135/15
wherever [1] 153/22
whether [37] 15/16
16/16 19/20 21/6
29/12 40/10 42/22
49/21 53/5 54/20 57/8
57/12 58/23 60/4 60/7
61/6 64/12 68/23
72/20 73/21 74/24
77/3 78/8 97/25 99/9
105/19 116/16 127/7
130/16 146/24 163/16
165/11 171/13 171/15)
175/14 175/16 182/22)
which [112] 10/14
12/5 13/3 19/10 24/3
(81) version... - which
Ww
which... [107] 24/10
27/21 30/4 30/10
32/21 36/9 36/17
37/18 37/25 38/5
38/12 39/11 39/19
40/8 40/15 41/25
44/11 44/13 44/15
45/1 45/5 45/10 46/12
46/23 46/23 47/2
49/16 53/19 56/22
58/20 62/17 67/4
67/15 68/24 71/21
73/9 73/19 74/19
74/19 75/8 75/23
75/24 76/1 76/2 78/7
79/7 79/13 80/12
80/13 80/19 80/21
81/1 82/12 86/3 89/16
92/2 93/2 95/2 95/9
101/18 111/22 112/14}
117/7 117/10 119/3
120/5 121/15 121/25
123/16 130/11 1314/1
131/5 131/25 133/23
134/10 135/25 143/22)
145/8 145/20 146/9
146/12 146/19 146/21
147/13 148/19 149/17)
149/21 151/6 152/4
154/15 156/8 157/3
159/21 160/2 165/6
165/11 168/13 168/17
173/22 174/15 176/1
180/10 180/25 185/11
193/17 194/20 195/9
while [2] 62/9 62/9
whilst [9] 4/5 14/10
15/16 20/7 79/12
101/14 119/1 133/7
135/17
who [58] 2/25 3/8
3/11 4/10 5/3 19/6
19/8 19/9 19/11 19/16
19/18 19/19 20/21
22/23 23/10 26/6
27/22 37/20 41/20
42/4 43/10 51/12
51/21 52/24 55/1 55/8
55/9 60/3 61/1 70/14
71/13 72/25 73/2 73/3
74/10 75/9 75/15 79/2
86/8 90/20 93/5 94/17,
95/16 97/24 105/10
105/21 111/12 115/20}
124/20 125/5 132/7
140/15 142/22 155/12)
158/1 179/6 184/18
187/1
whole [5] 12/11 48/1
64/10 182/9 185/21
whom [2] 34/3 36/21
whose [2] 173/24
193/13
why [52] 5/15 9/19
9/25 12/8 12/13 12/17
12/17 15/18 18/12
22/13 36/4 37/18 48/13
62/17 66/7 66/17
72/14 73/1 82/12
82/16 88/4 88/11
88/11 96/11 96/16
96/17 96/17 104/2
104/5 104/5 105/4
105/14 106/7 106/9
133/13 133/25 135/12)
142/22 152/5 152/15
153/1 156/1 156/15
156/15 156/21 160/16)
162/24 168/25 171/5
189/5 190/12 192/5
wide [4] 18/15
135/19 153/11 154/1
widely [2] 99/7
103/18
wider [9] 17/19 17/21
18/1 26/24 39/2
113/15 127/22 127/24)
186/1
widespread [3]
142/16 144/14 144/19)
will [57] 1/24 2/5 9/18)
9/24 21/1 28/6 32/21
33/10 34/16 45/11
52/10 56/2 61/20 64/2
69/1 71/23 83/13 84/6
85/14 92/24 93/14
100/4 108/20 110/15
110/25 116/18 116/19)
4117/1 117/4 124/14
127/6 127/14 130/11
130/12 132/12 133/11
133/14 135/2 145/18
147/2 147/3 147/3
147/4 147/5 148/5
155/8 158/7 158/8
162/20 167/9 170/10
171/3 173/20 176/16
186/9 188/1 195/18
Williams [31] 3/13
5/22 6/25 8/14 10/12
19/2 22/11 22/12
25/16 29/11 61/13
61/15 62/3 71/18
75/15 76/3 78/5 78/22
80/12 81/8 110/5
125/9 126/18 130/5
136/25 138/15 140/17)
167/17 171/17 174/8
192/4
Williams’ [1] 78/21
Wilson [1] 94/10
win [3] 111/2 192/17
193/23
winded [1] 132/13
Winn [7] 9/22 14/16
14/24 23/18 24/18
24/20 95/1
Winn's [1] 9/5
Winn/Alan [1] 95/1
winning [1] 193/8
wipe [1] 188/20
wish [3] 85/15 167/4
175/13
wished [2] 114/2
116/16
withhold [4] 119/24
120/24 121/23 121/25]
withholding [2]
118/12 119/21
within [17] 3/9 37/9
61/3 92/10 93/5 94/24
97/23 128/3 130/1
144/3 148/7 156/13
162/14 173/10 179/10
180/1 186/2
without [8] 11/13
25/2 48/12 95/3 144/5
154/22 173/21 174/19!
WITN10390200 [2]
1/24 46/15
witness [32] 1/13
1/13 1/16 5/15 5/17
7/20 21/11 29/7 29/23
31/8 34/2 36/10 36/11
46/15 47/10 49/4 49/5
49/6 49/14 49/16
53/10 77/6 77/13
79/16 89/15 101/2
101/4 118/17 118/19
162/23 170/11 185/17]
witnesses [1] 70/22
wolves [2] 177/18
177/21
Womble [5] 2/8 55/10}
72/20 127/4 127/18
won't [1] 124/12
wonder [1] 82/23
word [17] 10/23
10/24 15/1 16/10
46/19 46/20 46/21
46/25 47/3 47/11
47/23 49/17 49/17
49/20 49/20 155/22
182/22
worded [2] 118/25
121/12
wording [5] 7/13
11/5 41/2 180/23
185/16
words [19] 15/2
26/21 35/21 40/21
47/5 58/12 66/15 70/9
119/18 119/18 119/22)
136/7 143/2 143/3
154/12 155/13 173/24
177/16 178/12
work [40] 3/22 5/4
28/15 58/4 59/25 60/2
63/8 84/6 87/1 87/11
87/16 88/17 107/20
113/21 113/22 114/9
127/16 128/9 139/18
140/13 149/11 151/21
151/23 160/1 161/17
161/19 161/22 162/2
162/5 162/12 162/14
162/15 162/22 163/3
163/9 163/15 164/10
165/6 184/4 193/11
worked [2] 15/14
194/22
working [43] 3/7 8/14I
10/7 24/17 59/20
62/10 95/6 97/7 97/13)
97/15 137/8 137/8
139/2 139/5 145/5
145/7 145/22 146/18
147/10 147/13 148/17)
148/22 148/25 150/6
153/9 153/10 156/5
160/1 162/8 162/9
162/11 162/12 162/19}
162/25 163/2 163/7
163/11 163/17 164/2
165/5 165/9 165/18
165/24
works [1] 180/11
workstream [2]
59/21 83/10
world [2] 134/3 134/4
worried [1] 129/16
worry [1] 89/5
worst [1] 179/8
worthwhile [1]
110/22
would [175] 4/24
7/13 7/15 7/21 7/24
8/25 12/17 12/19 13/5
13/9 13/10 13/13 15/9}
15/13 15/15 17/6 17/7}
17/24 18/15 18/19
21/20 23/25 24/2
25/18 27/17 27/23
30/23 33/13 34/8 39/4,
41/24 41/25 42/3 42/8
42/12 42/23 43/5
43/16 44/21 46/20
46/25 49/11 49/18
49/19 54/24 58/1
59/15 59/15 60/19
60/20 60/22 61/17
61/22 62/16 62/17
63/5 63/6 63/7 63/10
63/11 63/12 63/20
65/1 65/11 66/21 67/4)
68/15 69/14 72/20
72/23 73/3 74/14
79/13 80/4 81/18 84/4
85/2 85/8 86/21 90/3
92/6 92/13 98/12
102/11 104/22 107/18}
107/19 108/1 108/14
109/10 110/21 112/14}
112/14 112/18 113/14
1414/2 116/7 117/15
117/17 123/2 123/15
128/7 128/25 129/1
129/6 129/9 129/16
130/21 130/25 132/14I
133/1 133/2 133/12
133/25 134/10 134/11
135/5 136/4 136/9
136/13 136/14 136/21
142/2 148/15 149/3
149/15 149/23 152/3
152/6 153/13 153/21
154/2 155/12 156/1
156/12 159/10 161/23)
162/1 162/15 162/17
163/2 164/15 165/1
166/24 167/18 167/21
168/21 169/1 169/21
170/19 170/22 171/5
171/13 171/14 172/3
174/18 178/15 179/23)
184/20 186/5 189/24
190/2 190/9 192/9
192/11 192/19 192/22)
193/10 193/19 193/24I
194/6 194/12 194/13
194/22 195/15
wouldn't [20] 5/16
12/8 12/13 12/17
18/12 21/20 53/18
64/17 68/12 74/6
74/14 105/4 105/14
120/18 129/2 136/15
143/14 156/15 166/12)
191/12
write [11] 14/12
20/10 42/7 44/5 44/12)
45/23 46/5 73/3 73/4
137/23 191/3
writing [7] 39/14
41/23 44/20 56/9
68/19 90/13 178/14
written [9] 4/1 38/22
40/23 43/20 45/7 47/7
69/6 69/8 90/7
wrong [9] 34/12
44/24 66/12 124/7
156/7 168/10 168/19
169/17 188/2
wrongly [1] 120/16
wrote [3] 51/21 73/4
161/3
Wylie [1] 170/10
Y
yeah [4] 23/4 75/18
131/16 157/14
year [5] 24/3 25/2
115/18 116/2 176/12
years [16] 2/24 26/10
26/15 35/5 35/10
70/19 76/25 110/2
115/17 154/15 156/8
175/21 183/1 191/1
(82) which... - years
Y
years... [2] 194/6
194/12
yes [93] 1/4 1/7 1/19
2/10 2/13 2/16 2/18
2/20 7/10 7/24 7/25
13/8 14/6 16/20 17/2
21/19 22/25 23/5 27/7
29/4 29/17 29/21
31/18 31/19 31/22
32/10 35/12 35/21
45/9 50/11 50/14 51/3)
51/14 52/7 54/3 54/4
55/20 59/14 62/15
63/11 65/12 69/8
69/18 72/24 74/3 74/5
75/13 75/19 75/22
80/6 82/3 86/25 91/11
92/17 92/20 94/20
96/14 96/16 96/22
97/2 99/24 107/4
109/24 120/18 120/21
121/22 126/23 128/12
131/23 132/11 136/16}
138/11 140/8 148/15
153/15 155/25 161/4
164/13 164/16 165/15
167/4 172/8 174/6
175/24 176/12 176/19}
180/3 185/2 185/15
186/6 188/17 195/7
195/17
yesterday [5] 22/13
30/3 84/18 133/11
134/22
yesterday's [3] 84/7
87/6 173/4
yet [6] 114/14 121/3
127/13 148/11 157/6
174/24
you [682]
you'd [3] 68/12
151/13 195/13
You'll [1] 79/10
you're [32] 16/6
21/12 26/22 46/10
51/4 51/19 52/3 61/10
65/18 65/21 69/20
70/9 89/1 98/7 103/24
112/24 117/25 118/5
123/10 131/4 131/9
135/10 140/5 141/5
157/25 161/11 168/6
182/5 183/18 185/11
192/4 194/20
you've [32] 5/15 7/5
10/18 14/7 14/7 15/1
15/2 29/22 43/10 65/5)
85/10 85/25 91/8
97/16 101/2 102/5
103/14 109/12 114/8
118/17 130/19 141/15)
145/20 150/23 154/12
155/22 156/18 162/23}
176/3 176/9 183/4
194/25
your [161] 1/10 1/13
1/18 1/21 2/11 2/24
3/4 3/11 3/15 3/22
5/15 5/16 5/17 7/5 9/1
9/2 10/25 11/12 13/22
14/1 14/9 14/12 14/18)
18/14 18/22 19/22
19/24 20/4 20/7 20/9
22/18 25/24 29/23
30/12 31/19 32/6
32/13 32/17 35/20
37/14 37/22 41/12
42/11 42/19 44/15
45/9 46/14 46/14
47/10 47/10 47/22
49/4 49/6 49/16 50/4
51/24 53/11 53/12
55/8 56/17 58/15
59/10 62/9 63/17 64/6
64/12 66/15 69/23
73/16 74/20 76/1
78/23 79/6 80/13
80/17 80/25 80/25
87/16 88/7 89/10
91/12 91/24 92/16
92/18 95/11 97/18
99/14 99/20 100/8
100/12 100/16 100/19)
101/2 101/4 102/13
102/21 103/4 103/6
104/17 105/11 108/4
109/12 110/5 112/11
112/25 114/16 116/7
117/18 118/17 119/23)
120/22 121/23 122/17,
122/21 124/20 125/8
127/3 127/23 129/20
130/20 134/19 137/16)
138/18 140/15 143/2
143/2 146/21 149/8
151/15 152/17 152/22)
153/2 153/16 155/14
156/16 157/17 158/20)
162/23 163/22 164/14)
166/16 169/14 171/24)
172/22 173/7 173/25
173/25 178/4 180/23
181/6 181/8 181/22
183/1 183/5 186/9
186/18 187/7 188/18
189/19 190/20 190/24}
yourself [5] 105/15
138/14 146/5 174/7
192/3
(83) years... - yourself