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The Post Office Horizon IT Inquiry
Thursday, 20 June 2024
(9.45 am)
MRBEER: Good morning, sir, can you see and hear us?
SIR WYN WILLIAMS: Yes, thank you very much.
MR BEER: Can I check that Mr Ward can see and hear us?
THE WITNESS:
I can, yes.
MR BEER: Thank you very much. May I recall Graham Ward, he
needs to be resworn, please.
SIR WYN WILLIAMS: Yes.
GRAHAM WARD (re-sworn)
Questioned by MR BEER
SIR WYN WILLIAMS: = Mr Ward, you may recall that, before you
A.
gave evidence on the last occasion, I gave you what I'll
call a direction about answering questions which the
answers to which might incriminate you. Do you remember
you doing that?
I recall that, yes.
SIR WYN WILLIAMS: Since a number of months have gone by,
A
I think it's appropriate that I remind you of that
before you answer questions this morning, all right. So
it will be in very similar terms, if not identical, to
the direction I gave you on the previous occasion when
you gave evidence. So, under our law, a witness at
a public inquiry has the right to decline to answer
a question put to him by any lawyer at the Inquiry, or,
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Yes, sir, I understand.
SIR WYN WILLIAMS: = Thank you. Over to you, Mr Beer.
MR BEER: Thank you.
A.
a
prop
Good morning, Mr Ward.
Good morning.
You gave evidence on 1 February 2024, and I want to ask
you some questions today about a single issue, namely
your involvement in changes made to Gareth Jenkins’
witness statement in the case of Noel Thomas; do you
understand?
Yes, I do.
You gave evidence about that issue on 1 February 2024.
The Inquiry is now in possession of material with which
we can further explore that issue. Can I recap in
general terms of where we were when you gave evidence on
the last occasion. We're dealing with events in 2006,
where you were the assistant Casework Manager in the
Security team; is that right?
I think in 2006 I was the Casework Manager.
Okay. That was a position you'd held since 2002?
Correct.
You told us on the last occasion that you were the
Casework Manager for the case of Noel Thomas and,
therefore, acted as the single point of contact between
the Post Office and Fujitsu in relation to Litigation
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20 June 2024
for that matter, by anyone else, if there is a risk that
the answer to that question would incriminate the
witness. This legal principle is known in shorthand
form as the privilege against self-incrimination.
I remind you that is for you to make it clear to me
in respect of any question put to you if you wish to
rely upon the privilege against self-incrimination. So
if any questions are put to you by any of the lawyers
who ask you questions, or by me, which you do not wish
to answer on the ground that to answer might incriminate
you, you must tell me immediately after any such
question is put to you. At that point I will consider
your objection to answering the question and,
thereafter, rule upon whether your objection should be
upheld.
Now, you're giving evidence remotely this morning.
Do you have the facility to take legal advice from
anyone should this issue arise.
A. Yes, I have, yes.
SIR WYN WILLIAMS: Fine. So should this issue arise and
should you wish to speak to the legal person who is
assisting you, you must tell me and then I will consider
whether that is appropriate, all right?
A. Okay.
‘SIR WYN WILLIAMS: So do you understand all that, Mr Ward?
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Support in that case.
A. That's correct.
Q. On the last occasion, we dealt with proposed changes and
changes made to a witness statement prepared by Gareth
Jenkins for the purpose of the prosecution of Noel
Thomas.
A. That's correct.
Q. Now, before I ask my questions of you, I think it's fair
to remind you of what you said on the last occasion
about this topic. Now, that's going to involve reading
a very significant part of the transcript of your.
evidence on the last occasion but it's important that
I put the questions that I'm about to ask you in the
context of that evidence, so that you can see and hear
what you said on the last occasion, okay?
A. Okay.
Q. Canwe look, please, at the transcript. It's
1NQ00001124. We can see, at the top left-hand side, if
we can just scroll in on -- zoom in on that, rather.
It's Thursday, 1 February 2024, and you gave evidence
and you swore an oath like you have on this occasion.
A. Okay.
Q. Can we go forward to page 40, please, and can we look in
the bottom right-hand corner, please, at internal
pagination 160, and scroll down once more. Thank you.
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This is partly picking it up mid-way through the topic,
or partway through the topic, but I had to pick
somewhere to start and this is a good place. It's
a gentle run in to the questions that matter. I'll read
it. It's me speaking, page 160, line 2:
"We're now in March 2006 and you're emailing the
Fujitsu email account in relation to a range of cases,
‘ARQs, statement request and assistance’, and you speak
about two attached files:
“Both of the above requests relate to cases where
the Post Office are being challenged about the accuracy
"You deal with Marine Drive and Torquay [Drive]
next, further down, if we scroll on, please. Then at
the bottom of the page, you say:
On a separate matter, I also require a witness
statement in [relation] to the following ARQs’, and then
there's one of the ones we've seen already, 401.
"Answer: Yes.
"Question: There's also 459 and 460, all of which
relate to Mr Thomas’ branch:
"We need the usual (leave out paragraphs H(b) and J
but we do need K) covering an analysis over the period
01/11/04 to 30/11/05. Penny -- you may recall this one
relates to nil transactions, my previous emails ...
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please see extract from a recent email below
in italics from Graham Ward ..."
"Then he extracts your email of 10 March that we
looked at a moment ago:
™... regarding providing a statement about nil
transactions and online banking. If you're able to put
something together for us, I'd be grateful. If you send
it back I'll arrange for Neneh or Penny to write into
a statement for your signature.’
"Then he cuts in what you had said in your 10 March
email; can you see that?"
“Answer: Yeah."
“Question:
italics:
"Can you add an extra paragraph in your statement
explaining how online banking transactions are processed
and the data downloaded and how nil transactions can
The important part is in bold in
occur."
"So this is Mr Pinder asking Mr Jenkins to put
something together for him or for us, for Fujitsu, in
‘order to address that issue. If we go up to page 1,
please, scroll down, please, we can see Mr Jenkins’
repl
e had a look at the ARQs and I think there is
sufficient info there to explain in most cases why there
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refer. Can you add an extra paragraph in your statement
explaining how online banking transactions are processed
and the data downloaded and how nil transactions can
occur?’
Then over the page, page 161:
"So five or six months has now passed and you're now
asking for a witness statement to address the things
that had been mentioned in the three emails that you
refer to there it; is that right?
“Answer: Sounds like it, yeah.
"Question: Can we go to FUJ00152582. Look at
page 3, please. This is 11 days later, you emailing
Penny Thomas about Mr Thomas' branch:
“These are the nil transactions you sent us and
will need to be produced and explained within your
(Brian's) statement.’
"You attach the 401 analysis and then the ARQ data
under the numbers 459 and 460, by which you have now got
these, yes?
“Answer: Yes.
"Question: If we go down to page 2 please. We can
see that, if we scroll down a little bit, in an email
that you wouldn't have known about at the time, Brian
Pinder of Fujitsu is forwarding that email to Gareth
Jenkins:
are zero ... transactions. I suggest the [that should
probably be ‘following') as a brief explanation.
"Three main reasons why zero transactions maybe
generated as part of the banking system.
"No financial effect;
"Declined by bank; or
“There has been some sort of system failure."
"He gives some examples:
"How do you want to play this? Do you want to add
in specific text to the witness statement to cover these
two codes or persuade [Post Office] that the generic
statement is okay perhaps with some clearer words?’
"Further up the page, please. She -- that's Neneh
Lowther -- says that she's updated your witness
statement -- Mr Jenkins’ witness statement. She's not
included the response below because she's not sure how
to fit it in. Could you help:
“Also I believe that Graham Ward is thinking that
‘system failures’ are drastic events."
"Is that true?
“Answer: Well, I just wanted them explained. I
didn't know whether they were drastic or not. It's just
from -- you know, and it's going back such a long, it's
so hard to sort of recall what I was thinking, but I'm
guessing that the first statement wasn't clear to me at
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The Post Office Horizon IT Inquiry
that time so I just wanted a bit more context around
what he meant by system failures.
"Question: Then scroll up, please. Mr Jenkins says
he's annotated it with revisions and doesn't feel able
to include the last two paragraphs which may make the
statement useless.
"Can we now look, please, at the draft that he had
previously provided. Can we start, please, with
FUJ00122204. Can we scroll down please. He says:
“There are three main reasons why a zero value
transaction may be generated ...'
"System failure is the third of them:
"Such failures are normal occurrences.’
"He then sets out in summary terms in substance the
same thing in the email we looked at, about response
codes; can you see that?
“Answer: Yeah. Yes, I can, yeah.
"Question: Would you agree that this is important
information that a zero value transaction may be shown
‘or may be generated, including by reason of a system
failure --
“Answer:
Yes. It is important, yeah.
"Question: I -- and that he is saying that such
failures are normal occurrences --
“Answer: Yeah.
"Question: You remember he said he didn't feel he
was able to include those --
“Answer: Yes, I do, yeah.
“Question: -- and that they may make the statement
useless?
"Answer: Yes.
“Question: What did you think the purpose of the
inclusion of those two paragraphs was?
“Answer: Well, these were two general paragraphs
that the Criminal Law Team had asked to be included on
statements that produced computer evidence. So it was,
to my mind, important to have them in there to say that
the system was operating properly and didn't affect the
information held on it.’
"Question: What did you take from the fact that he
thought that these bits, which I think on the original
were highlighted in yellow weren't true, or he wasn't
sure were true?
“Answer: Well, that would have been a concern,
obviously.
"Question: Sorry?
“Answer: That would have been a huge concern, if
he --
"Question: Why would it have been a huge concern?
“Answer: Because if he can't say that the system is
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"Question: -- and he's saying that there's a system
code that may identify them?
“Answer: Yeah, I don't know that I was tying in the
paragraphs beneath that with system failures. Maybe
that's just my ignorance of not knowing exactly what nil
transactions were.
“Question: Doesn't this explain it? His numbered
paragraph 3, some sort of system failure is linked to
the third bullet [attached] to this email?”
"Answer: I would like to think ..."
Sorry, if we just go back, please, to the previous
page:
linked to the third bullet at the bottom of
this page: response code with a value greater than 10
implies some sort of system failure.
“Answer: Yeah --
"Question: They're speaking about the same thing,
aren't they?
"Answer: Yeah, I can see that now, yeah.
"Question: Then if we go forward to page 3, please
those last two paragraphs, can you see the one beginning
‘No reason to believe that’ and --
“Answer: Yeah.
"Question: -- ‘any records to which I refer’?
“Answer: Yeah.
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operating properly, then, you know, there's a problem
isn't there? If this -- this wasn't the final statement
was it?
“Question: No.
“Answer: Oh, right.
"Question: What we'll see happens is that he
requests for them to be removed. They are removed and
then, in the end draft, they come back in.
“Answer: What the statement that was produced in
evidence?
"Question: Yes.
“Answer: I don't know anything about that.
"Question: He says:
"Can this be deleted? All I've done is interpret
the data ...’
"Answer: Yeah.
"Question: '... in the spreadsheets you've emailed
tome.’
"Would you have read this at the time, ie the
attachment to this email?
“Answer: I would like to think I would, yeah.
"Question: This being the attachment to the email
you got?
Answer: Yeah, I would have thought so, yeah.
"Question: Do you understand these or did you
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The Post Office Horizon IT Inquiry
understand these two paragraphs to be statements
speaking to the accuracy and reliability of Horizon
generally or about a system that had been used to
extract ARQ data?
“Answer: Horizon generally.
"Question: Hence your belief that these were
significant omissions --
“Answer: Yeah.
"Question: — -- or they would have been significant
omissions?
“Answer: Yeah.
“Question: Can we look, please, at FUJ00122210. If
we scroll down, on the 24th, ie the next day -- sorry,
scroll up, please:
"This statement needs more work ..
"You're emailing Neneh Lowther, Brian Pinder, Keith
Baines, Paul Dawkins and Diane Matthews:
"This statement needs more work. I've attached
a suggested draft with a number of comments (as
mentioned previously I think the "system failure normal
occurrence" line is potentially very damaging).’
"Firstly, why did you think the ‘system failure
normal occurrence’ line was potentially very damaging?
"Answer: Well, just for the reason that I've said
previously. I think I was just looking for a little
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"Question: That's not how it reads, is it?
"Answer: No, it's not.
"Question: You've gone straight to the effect of
what he says, ie it causes us, the Post Office, damage.
“Answer: Yeah, I can see how it looks now.
"Question: Again, is this one of those examples of
the way that you were thinking at the time: the
importance thing is to maintain, even in our
prosecutions, the line that Horizon has integrity and
produces reliable data?
“Answer: I wasn't trying to do that, no. I just
obviously had a closed mind to the way I put things
across but I really wasn't trying to -- you know, at the
end of the day, the truth is more important, and --
"Question: We don't see that kind of sentiment in
any of your email exchanges, do we?
“Answer: Well, no, maybe not, but I know the person
that I am.
"Question: I think we can delete 'maybe' from that
sentence and replace it with ‘definitely’.
“Answer: Okay.
"Question: Can we look, please, at POL00047895.
This is a copy of the marked-up witness statement,
marked up by you, forwarded by Ms Lowther to Mr Jenkins.
If we scroll down, please, and we keep reading -- sorry,
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bit -- it just wasn't clear to me exactly what he meant
by it and that may just be my ignorance of not knowing
about banking transactions and nil transactions but, you
know, I'm just offering a comment. II'm not trying to
lead him into saying anything in his statement, or
anything like that, I was trying to be helpful but
clearly I wasn't being. As I say, I can see here it
says it may be worth someone from our team taking
a statement directly from him.
"Question: Why did you think that was a good idea?
“Answer: I just thought it was getting a bit
confusing with his statement and I just thought maybe it
would be best for the Investigator dealing with the
investigation to actually, you know, deal with it
themselves.
"Question: Why would you be concerned if a person
with expertise from Fujitsu is giving technical
evidence, the effect of which was damaging? Wouldn't
you be pleased with that, as an Investigator or somebody
associated with an investigation, the true position was
being revealed?
“Answer: Well, yeah, when you word it like that,
yes, and I really wasn't trying to alter his statement
or make him say anything; I was just wanting, you know,
clarity on what he meant by ‘system failures’.
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if we just go back to the top, please. Then scroll down
slowly, please.
Remaining in the statement, in the second paragraph,
second line:
"I was asked to produce information relating to
nil" transactions’.
"Then if we go to the second page, please. Then the
paragraph beginning ‘There are three’, we see your
comments:
"There are three ..."
"Then you've added:
"If these are the main three reasons, what are the
rest?’.
"That's in the nature of a question both in terms of
the words used and the used of the question mark. So
that's clarificatory, isn't it?
“Answer: Yeah.
“Question: Yes?
“Answer: Yes, sorry.
"Question: So you're genuinely trying to find
something out, by the look of it there --
“Answer: Yeah.
"Question: -- why a zero transaction may be
generated as part of the banking system. Then we see
Mr Jenkins' own words:
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“Transaction has no financial effect. Transaction
has been declined by the bank.’
"Then we see system failure reason missing, don't
we; you've delete it, haven't you?
“Answer: No, I would not have deleted anything at
all.
“Question: Well, why doesn't it appear here?
“Answer: I don't know.
"Question: You've typed over it:
"This is a really poor choice of words which seems
to accept that failures in the system are normal and
therefore may well support the postmaster's claim that
the system is to blame for losses!
“Answer: No, I would not have typed over anything
or deleted anything at all. I just know the person that
I.am and I wouldn't have done that.
“Question: Well, you were concerned, we've seen, at
the emails that preceded this, with what Mr Jenkins was
proposing to say about system failures, weren't you?
“Answer: Yeah, I was concerned, yeah. I just
wanted clarity on it, as I said, but I would not have
typed over or deleted it.
"Question: This is the attachment to an email that
you sent to Neneh Lowther, who, in turn send it on to
Mr Jenkins?
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involved in an important statement in relation to the
prosecution of someone in a way that you'd ever done
before, as I've understood it. So can you try and rack
your memory, please, as to how this statement came to be
attached to an email you sent.
"Answer: Honestly, I just can't explain it at all,
no. I really can't.”
We can take that transcript down. That's where the
relevant exchanges end. So that's the entirety of the
evidence that you gave on the last occasion about the
issue of suggesting changes or actually making changes
to the witness statement of Gareth Jenkins in the case
of the prosecution of Noel Thomas.
Mr Ward, do you accept that, on the last occasion,
you, firstly, agreed that you sent an email on 24 March
2006 to Fujitsu that had, as an attachment to it,
a marked-up copy of Gareth Jenkins’ witness statement?
Yes, I do, yeah.
Do you agree that, on the last occasion, you denied
deleting or typing over the "system failure" reason, the
third reason for nil transactions that Mr Jenkins had
given?
Yeah.
Do you agree that, on the last occasion, you said that
you didn't know why that line had disappeared from the
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“Answer: Right.
"Question: Do you know where these words have come
from, then?
“Answer: Well, I'm sure I've -- I must have typed
the words, yeah. But I wouldn't have typed over ‘system
failure’.
"Question: Okay, if we move on. Next page, please.
We see that the paragraphs that were previously in
yellow, which Mr Jenkins said he didn't feel he could
say, have been deleted. Did you delete those then?
“Answer: No. I can't explain it at all. I would
not have written over or deleted anything from anybody's
statement. Absolutely not.
"Question: Can we move to FUJ00122217."
Then the Chairman intervenes:
"Well, before we do, since I think you've just
accepted that you attached this witness statement to
an email you sent, can you explain where there is
witness statement came from, so as to enable you to
attach it to an email?"
“Answer: No, I'm sorry, sir. I just cannot
remember, you know, this at all.
"The Chairman: Well, people's memory, of course, is
for them to tell me about, but this is a pretty
memorable event, is it not? This is you really becoming
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draft witness statement but that you knew that it wasn't
you that had deleted it because that just wasn't you?
Yes, I agree.
Now, the Inquiry is in possession of material that may
assist us in where the truth lies here and I want to
show you that material in a moment. Can we start,
please, however, with what I showed you on the last
occasion, the email. FUJ00122210. Thank you.
If we scroll down, please -- thank you.
So this is your email of 24 March 2006 at 11.37 in
the morning. So this is exactly the same one, exactly
the same copy that I showed you on the last occasion?
Okay.
Now, if we just read the two paragraphs of the witness
statement:
"This statement [Mr Jenkins' statement] needs more
work ... I've attached a suggested draft with a number
of comments (as previously mentioned I think the ‘system
failure ... normal occurrence' line is potentially very
damaging). It may be worth considering someone from our
team taking a statement directly from Gareth Jenkins
(where is he based?)
“Whilst there is some urgency with this, it is more
important to get it right and ensure we are not
embarrassed at court, which we certainly could be if we
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produced a statement accepting ‘system failures are
normal occurrences’."
Then the attached file, which you can see described
there, and then:
"Let me know what you think of the draft."
If we just scroll up, please, we can see Neneh
Lowther forwards that email on to Gareth Jenkins
directly, with the attachment that you had included,
yes?
Yes.
Now, on the last occasion, we looked at that attachment
as a separate document. I then went to another
document, I gave it the name POL00047895, another
version of it is FUJ00122211 -- neither of those need be
displayed at the moment -- and we looked at that in
an imaged copy, which is what this is here, it's
an image of an email?
Can we now, please, switch on our system at this end
to the original of this email.
We've got the original email. Can you see that on
your screen?
Yes, I can, yeah.
Can you see the email that we've just looked at, at the
foot of the page there, that's being displayed,
24 March, 11.37: exactly the same email. Yes?
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amendment and the time at which they made it and the
date on which they made it, yes; can you see that?
Yes, I can.
So, looking here -- that's it, if we hover above that
‘one -- we can see that that first amendment was made at
10.28 in the morning on 24 March 2006 and, would this be
right, by you? Nobody else that access to your account?
No, that would be me.
Then the third thing we can see is, on the right-hand
side, if there are any formatting changes, those appear
in comment boxes on the right-hand side, yes?
Yes.
Now, we can see, if we hovered above each amendment and
wrote down the times of them, take it from me the first
amendment was made at 10.21 in the morning, I think that
was the first one we were actually hovering over
there -- that's it -- at 10.21, and the last amendment,
if we hovered over it, was made at 11.13 am, so over the
course of 52 minutes.
If we just scroll down and hover again over each
amendment, we can see that they're all made by you.
Okay?
Yeah.
If we scroll to the second page and just pick any
amendment, please, operator, at random, and then the one
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Yes, I can, yeah.
We can see Neneh Lowther forwarding it at the top, just
as we've seen in the image of this email that we've
looked at. But, on this occasion, we can actually see
the attachment in the email, can't we --
Yes, we can, yeah.
-- just like when you're sitting at your computer?
Yes.
This is a more conventional format of an email which is
attaching a Word document and the difference is we can
now open the email attachment. So let's open that.
Thank you.
If we just scroll down to look at it. Thank you.
I think this will be the more conventional format of
a Word document that you, in your working life, would
have been used to seeing; would that be right?
Yes, it would, yeah.
Where amendments have been made to a Word document,
I think we can see three things: firstly, if it's
enabled -- and here it was -- the changes are tracked by
being put in red and underlined, yes? That's the first
thing we can see.
Yes, I can see that.
Then the second thing is, if we hover, as the operator
kindly has, above an amendment, we can see who made the
22
in the middle, thank you; then the middle of the page;
then do one at the bottom of the page; then over the
page, yes?
Yes.
All of the amendments made by you. So these were all
made by you, Graham C Ward. This isn't a case of
somebody else surreptitiously logging in to your system
and pretending to be you; these are amendments made by
you?
That's correct, yes.
Can we go back to page 1 and look at the substance,
then. The first thing you do in that second paragraph
is you're effectively writing in, to Mr Jenkins’ witness
statement, him exhibiting three ARQs; is that right? So
it says:
"Audit Record Queries (ARQs) 401, 459 and 460...
I was asked to produce information relating to ‘Nil’
transactions during the period specified. I have
produced three spreadsheets which I now produce as
exhibits GIJ01, GIJ02 and GIJ03."
Yes? So that's you writing into Mr Jenkins’
statement the exhibiting by him of the responses to
three ARQs, yes?
Yes.
Then scrolling down. Is this right: you effectively
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explain the format of those three ARQs?
Yes.
Okay, I've got no questions about that but, if we go to
the second page, please, and look at the second big
paragraph down. The one beginning "There are three
main". Originally the statement read:
"There are three main reasons why a zero value
transaction may be generated as part of the banking
system."
If we hover above the word "main", you deleted that,
didn't you?
Yeah.
Then you added in the words "if these are the main
reasons, what are the rest?" As we established on the
last occasion, that was you asking a clarificatory
question, correct?
That's correct, yeah.
Then the three reasons were set out in the witness
statement:
"[1] The transaction has no financial effect
(ie a balance enquiry or a PIN change).
"[2] The transaction has been declined by the Bank.
"[3] There has been some sort of System Failure.
Such failures are normal occurrences."
If we hover above those, you deleted those words,
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intention for it to be removed from that statement --
Let's put aside the intention issue for the moment,
Mr Ward. On the last occasion you denied deleting the
third reason: you said, "It's just not me. I know the
type of person I am". Do you agree that, in fact, you
did delete that third explanation from Mr Jenkins’
witness statement?
I can see that now, yes.
Can we turn to what you wrote after your deletion:
"This a really poor choice of words which seems to
accept that failures in the system are normal and
therefore me well support the postmaster's claim that
the system is to blame for the losses!!!"
Do you agree that discloses your motive for deleting
the third explanation?
No, I don't agree with that. I'm just reviewing
astatement. You know, I can see how it looks now,
I really can.
Never mind how it looks now. Do you agree that the
connection between the deletion of the words and what
was in your mind is shown by the explanation that you've
added in round brackets?
Yeah, well, I can agree that there's a connection, yes.
And that connection is: it needs to be deleted because
if it's left there, it might support the postmaster,
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didn't you?
Well, yeah, I mean, I've obviously put a line through it
but, as I said at the outset, what I was doing here was
reviewing this statement. My intention was not to
insist on anything being put in or removed. I'm just
reviewing it as I was asked to do.
In what way is reviewing a statement consistent with
putting a line through something and deleting it?
Well, it was -- I can't explain that. I really can't.
You agree that you deleted the words -- the third reason
that Mr Jenkins had given for a nil transaction value
appearing -- "There has been some sort of System
Failure, such failures are normal occurrences"; you
agree that you deleted those words?
I've put a line through it, yes, I can see, and it's
deleted, and that's what it says on there. But my
intention was absolutely not to have anything deleted
from that statement that Mr Jenkins wasn't happy with at
all. I was just trying to help him and to review
a statement.
Do you agree with this, Mr Ward: that, contrary to your
denial on the last occasion, both in answer to questions
from me and from the Chairman, you did delete the third
explanation?
I can see that I've deleted it, yes, but it was not my
26
Mr Thomas’, defence, agreed?
As I've said, you know, my intention was not for
anything to be deleted but I can see that, yes, that's
how it looks.
Do you agree that the information that you deleted was
material to the prosecution of Mr Jenkins (sic)?
Yes.
Do you agree that, by the time that you deleted it, you
knew that a prosecution had been commenced against him?
Yes, I do --
SIR WYN WILLIAMS: There may be some confusion. You said,
"Mr Jenkins", Mr Beer --
MR BEER: I'm so sorry.
‘SIR WYN WILLIAMS: — -- but we all know Mr Thomas --
MR BEER: Mr Thomas, I'm so sorry.
I'll ask the question again: did you know that, by
the time of your deletion, a prosecution had been
commenced by Mr Thomas?
Yes, I knew there was a prosecution against Mr Thomas.
Do you accept that, by your conduct, you caused to be
removed material information from Mr Jenkins' witness
statement at the time that a prosecution was afoot
against Mr Thomas?
No, I don't. I think the decision to remove that had to
have been Mr Jenkins' decision. I've made a comment and
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I've made a review and I accept that I shouldn't have
been doing that, but the final decision to make that
statement and for the -- you know, for what went in
there, that was for Mr Jenkins to decide.
You've agreed, I think, that your reason for deleting
that line from the statement was that it might support
the defendant's case that Horizon was to blame for the
losses that were being attributed to him, agreed?
Yes.
If we read on, as per the original witness statement, it
said:
“Each transaction has ... with it a response code
field, which identifies what has happened. Those values
are included (together with their descriptions) in the
Originally it said "ARQs" and you've added
"Spreadsheets produced”.
Then "In summary". I'm going to skip over the next
two paragraphs which deal with values of 1 or between 2
and 10, but the third one, which you do amend is:
"[A response code] RespCd with a value greater than
10 implies some sort of system failure -- The actual
value provides further information as to the nature of
the failure within the overall system."
So, rather oddly, you've left that in the witness
29
Why did you delete it?
As I've said, yes, it looks -- I've put a line through
it and I've put, you know, in brackets that I think it's
a poor choice of words but that is just me reviewing it.
I'm not, for one second, suggesting anything needs to be
removed from the finalised statement.
You didn't just say it was a poor choice of words. In
the brackets, you said that, if we leave those words in,
it "may well support the subpostmaster's claim that the
system is to blame for the losses". That's what was
motivating you, wasn't it?
No, I don't believe it was, no. I mean it's just a poor
choice of words.
Poor choice of words by who?
Well, by me, obviously.
Why, when you spent 52 minutes amending this witness
statement, did you select "a poor choice of words"?
Well, I don't know. I really don't know. I'm just
going to repeat what I've said. I mean, I haven't got
anything else I can add to it. I was trying to
genuinely help put a statement together for him.
This -- you know, back in 2006, Horizon integrity just
wasn't an issue for us at all and this was a fairly new
statement, as I said on my previous evidence, I think,
a banking transaction witness statement. So I was just
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statement, haven't you?
Yes.
Was that just a mistake by you, that it ought to have
been, if you were acting consistently with your earlier
deletion, to have been deleted as well, ie the mention
of a system failure?
No, not at all. It's not a mistake. I mean, there's
just a bit more context.
What does that mean, Mr Ward? You deleted the system
failure reason why zero transactions may be generated,
but left in an explanation of the response code values
relating to system failure?
Well, as I say, you know, going back 18 years, or
whatever it is now, I can't really remember what I would
have been thinking then but the fact that that paragraph
there has a little bit more information in it, you know,
made sense to me then.
What do you mean, that paragraph had a bit more
information, made sense to you?
Because it's got a value greater than 10 implies some
sort of system failure. There's a bit more information
than just saying "system failure". That is all I can
think that I would have been thinking at that time.
But you wanted the system failure reason deleted?
I didn't want it deleted, no.
30
trying to get the statement correct. That was my
intention and I'm really sorry for the way it comes
across, I really am, but I was trying to just do my job.
That last paragraph there, the one that says, "[Response
code] with a value greater than 10", you're not saying
to us that you left that in the witness statement
because you thought that that was a sufficient
explanation to a court and gave adequate disclosure to
a defendant and that that was, therefore, justification
for deleting the third reason from Mr Jenkins' list?
Well, I really don't know. But I just think there's
more context to it there. That's all I can say. I'm
sorry, it's such a long time ago. I just really just do
not remember this at all.
Can I suggest one explanation: that this was a rather
sloppy attempt at covering up, in criminal proceedings,
evidence of system faults within Horizon and that, if
you'd been pursuing your motive properly, you would have
also deleted that last paragraph that we've just read.
It's just a mistake by you that you haven't seen through
the task that you were setting for yourself.
No, that's absolutely not. I wouldn't agree there.
not trying to cover anything up at all. I'm just trying
to get a statement correct.
Your motive was that you didn't want to disclose, in the
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prosecution of Noel Thomas, information that suggested
that a fault in Horizon could have caused nil
transactions, agreed?
No, I don't agree.
Can we look, please, lastly, at the original email.
FUJ00122210. Look at your email if we just scroll down.
Thank you. You say:
"This statement needs more work ...”
That's the statement we've just read.
"... I've attached a suggested draft with a number
of comments ..."
Then you say:
(as previously mentioned, I think the 'system
failure ... normal occurrence’ line is potentially very
damaging)."
So the very line that you deleted, you recognised to
be "potentially very damaging”, agreed?
Yes, but I just wanted more context on it, as I've said.
You say that that line that you deleted was "potentially
very damaging". That, again, draws a direct line
between the reason for the deletion of the line and the
deletion of the line, doesn't it?
I can see that it looks that way, yes.
Well, it is that way, isn't it? That's the motive,
right there, in black and white: "I'm deleting it
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there were, rather --
In which case, you would have typed, Mr Ward, "Can
Ihave some more context, please, on what system
failures are?", rather than deleting “system failures"
from the witness statement and saying, three times, "We
need to delete this because it's damaging, it's
potentially embarrassing, and it would assist the
subpostmaster's defence".
I can see how you would say that, yes. I do understand
that but, as I've said, I don't recall finalising the
final statement either and that's why I'm suggesting
that somebody from the team should go and take the
statement directly.
Your motive was a desire that the Post Office was not
embarrassed at court by revealing that Horizon had
defects, system errors, wasn't it?
No, not at all. My desire was that the statement was
produced correctly. I was unaware that there were bugs,
errors and defects in the Horizon system.
Mr Jenkins was saying that there are defects in the
system, in his witness statement, and you were deleting
that information?
He said there were system failures.
And you wanted that deleted?
I didn't want it deleted, no.
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because it's potentially very damaging"?
There is no motive from me to remove anything because,
at the time, there was absolutely, in my head, no issues
with Horizon at all.
If we look at the second paragraph:
"Whilst there is some urgency with this, it is more
important to get it right and ensure we are not
embarrassed at court, which we certainly could be if we
produced a statement accepting ‘system failures are
normal occurrences'."
Again, that's the third occasion, one in the witness
statement itself, in your comment, and the other two in
the covering email, this email, that reveals what was
operating on your mind, agreed?
I think what I take from that is, it's more important to
get it right because I want to get the statement right.
I didn't think there were any issues with Horizon. We
weren't told there were any issues with Horizon. So the
idea that I'd be covering anything up just wouldn't have
been in my head at all.
Why did you say, "we need to ensure we're not
embarrassed at court, which we could be if we produced
a statement accepting ‘system failures are normal
occurrences"?
Because I wanted more context on what system failures
34
Why did you delete it?
I didn't delete it, as I've said to you.
In what sense is striking through --
lcan see --
-- a sentence in tracked changes and providing three
explanations why that should be removed not a case of
deletion?
I can see how it looks, I really can, and I'm sorry it
looks that way but I can assure you, my intention was
not for that to be deleted.
MR BEER: Mr Ward, they are the only questions that I ask
you.
Sir, do you have any questions?
‘SIR WYN WILLIAMS: No. Thank you very much.
MR BEER: Sir, that's all of the evidence from Mr Ward this
morning. Because he's remote, we need to take a break
now until we move to our next witness, who is live.
SIR WYN WILLIAMS: Yes. All right.
Well, thank you for returning to give evidence,
Mr Ward. That completes your evidence to the Inquiry.
So we'll now have a ten-minute break, Mr Beer?
MR BEER: Yes, I think probably 15, actually, to get the
screens out.
‘SIR WYN WILLIAMS: All right, fine. 15-minute break before
we resume. So that will be -- well --
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MR BEER: 10.50?
SIR WYN WILLIAMS: 10.50, yes.
(10.37 am)
(A short break)
(10.52 am)
MS HODGE: Good morning, sir, can you see and hear us?
SIR WYN WILLIAMS: Yes, thank you very much.
MS HODGE: Our next witness is Anthony Kearns.
SIR WYN WILLIAMS: Yes.
MS HODGE: Please can the witness be sworn.
ANTHONY PAUL KEARNS (sworn)
Questioned by MS HODGE
MS HODGE: Mr Kearns, as you know, my name is Ms Hodge and
I ask questions on behalf of the Inquiry. Please give
your full name.
A. Anthony Paul Kearns.
Q. You should have in front of you a witness statement
dated 9 May this year. Have you got that there, please?
A. Ihave.
Q. This is the second statement which you've provided to
the Inquiry; is that correct?
A. Itis.
Q. Itruns to 15 pages. Can I ask you, please, to turn to
page 14 of that statement.
A. Yes.
37
A. Itis.
Q. Thank you. Now, in terms of your roles and
responsibilities, you were previously employed as
an Assistant Secretary of the Communication Workers
Union between 1997 and 2002; is that right?
A. That's correct.
Q. Whilst employed in that role, your primary
responsibility was to promote the interests of CWU
members who were employed by Post Office Limited; is
that right?
A. Correct.
Q. This would have included post office counter clerks who
were employed at Crown Office branches, staff working in
cash centres and administration staff working in the
Post Office's back offices; is that right?
A. Correct.
Q. You say that, since 2002, you've been employed as the
Senior Deputy General Secretary of the Communication
Workers Union; is that right?
A. That's correct.
Q. You were elected to perform that role by the members of
the union; is that right?
A. Yes.
Q. Inyour statement, you say you've not had any direct
responsibility for Post Office matters since your
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Do you see your signature there at the end of the
statement?
It's actually not on this hard copy that I've got.
If you could just bear with us. We'll ensure that you
have a copy with your signature.
Yes.
Thank you. You can see you signature there at the end
of the statement dated 9 May this year?
(The witness nodded)
That's right?
Yes.
Thank you. Is the content of that statement true to the
best of your knowledge and belief?
Itis.
Thank you. That statement will stand as your evidence
to the Inquiry in Phases 5 and 6. I shall be asking you
some questions that seek to expand upon and clarify some
aspects of your evidence.
You first appeared before the Inquiry on 29 November
2022, when we were examining issues of relevance to
Phase 2; is that correct?
Correct.
I don't intend to revisit those issues with you, save to
the extent that they are relevant to the issues that
we're examining in Phases 5 and 6; is that clear?
38
appointment as Senior Deputy General Secretary; is that
right?
That's correct.
Who within the senior leadership of the Communication
Workers Union has direct had direct responsibility for
postal matters since 2002?
Andy Furey.
Thank you. II'd like, very briefly, to revisit some of
the evidence which you gave on the last occasion about
your role as a member of the Horizon Working Group
during 1999 to 2000. This was at a time when you were
employed as Assistant Secretary with responsibility for
Post Office employees; is that right?
Yes.
The Horizon Working Group had been established to
oversee the operational live trial and later the
national rollout of the Horizon system to the Post
Office Network; is that correct?
Correct.
You confirmed on the last occasion that you gave
evidence to the Inquiry that you were made aware of
technical issues being raised during the live trial: is
that right?
Correct.
You understood these to relate to balancing; is that
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right?
I was informed by Crown Office staff on visits that
I would make to local branches that some individuals
were experiencing difficulties with balancing, following
the introduction of the Horizon project.
Just to confirm, by "balancing", you mean whether the
money received in and paid out by the branch was
accurately recorded in the weekly financial accounts; is
that right?
Each counter clerk employed at a Crown Office is
responsibility for their own individual balance on
a Wednesday, the end of the balancing week, and that's
when that balance takes place.
I think you said on the last occasion that problems with
balancing had been reported to you before Horizon was
implemented; that's correct, is it not?
Yeah, we regularly had staff who reported difficulties
with balancing prior to, and subsequent to, the
introduction of Horizon.
But you said that, after the introduction of Horizon, it
was your perception at the time that the number of
people reporting problems had increased?
Yes.
Is that right? I think you've just confirmed that that
was information you obtained during your visits to local
41
managers would have had sufficient knowledge or
understanding to identify whether a balancing problem
was caused by the system or by the employee's
performance?
I couldn't say whether they were able to identify
specifically whether a misbalance, a loss or a gain, was
directly attributable to the system.
If you were not tracking the issue at a national level,
how would your local reps know whether they were dealing
with an isolated incident or an issue affecting several
branches or employees?
I think I made in my last -- in one of my statements or
the last time I gave evidence -- so we have a network of
representatives who operate at local branch level, sort
of area level, regional level, and then a national
executive, and what would happen if somebody was -- so
there was a process in place, a losses and gains
procedure, and what would happen is, if somebody was
considered by the Post Office to be falling foul of that
procedure, they would be called for interview.
They would talk to their local rep or their area rep
or their regional rep and ask for representation. So
dealing with those -- the idea of that system as the
idea all of the agreements and so the industrial
relations framework we had with the Post Office at the
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branches?
Correct.
Were these problems with balancing an issue that you
were recording or tracking at a national level within
the Communication Workers Union at the time?
No, we had a process, which I think I outline in my
witness statement, for how losses and gains or incorrect
balances were dealt with through a system losses and
gains procedure that was in place at the time and
subsequent to the Horizon project.
Weill come on shortly to that but just dealing firstly
with the issue of how the issue was being, let's say,
monitored, I think your evidence is it wasn't, at
a national level: is that fair? That is to say that you
weren't keeping records or you weren't tracking the
number of branches or the number of staff who were
having difficulties with balancing?
No, there was no facility or process for that.
Would it be fair to say that you were relying on those
local procedures to identify whether balancing problems
were caused by the system or by the performance of the
employee?
Yes, that would be dealt with through that losses and
gains procedure, at various levels.
Do you think that local representatives and branch
42
time, and still through to today, is to get these
matters dealt with, for want of a better phrase, at the
coalface, at the lowest common place you can deal with.
So people having local firsthand knowledge would be the
office rep; subsequent to that would be the area rep.
So if someone found themselves in difficulties over the
losses and gains procedure and was going to be called
for interview, they would contact their local rep or
their union branch and they would deal with the issue.
So those issues were dealt with predominantly by --
at a local level.
I understand the point you're making but I think that
the gist of my point is this: if it's not being looked
at at a national level, would those local reps and those
local branches would they be able to know that this is
something that was affecting more than one area, do you
think?
Yeah, we would have regular meetings of -- local reps
would meet regularly at branch level. Area reps,
regional reps, would get together and discuss the
problems that they were facing, how best to deal with
them.
So you would have expected that to have been discussed
at those -- at the branch level at the regional level,
if it had been something that was causing significant
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difficulties. Is that --
If those reps had a wide scale concern, yeah, I'd expect
them to discuss it with each other. Standard practice,
is sort of sharing, you know, "I've got this problem,
how have you dealt with that? I've got a new problem,
how have you dealt with that?" That's how reps sort of
interact and build up their knowledge.
Now, when you finished in your role as assistant
secretary, to whom did you hand over responsibility in
2002?
Andy Furey was elected, so it wasn't me handing over
responsibility. He was elected by the relationship --
Into the role of Assistant Secretary?
Into the role of Assistant Secretary.
Did you brief him on the knowledge you'd obtained during
your time as a member of the Horizon Working Group?
Andy Furey was an elected member of our national
executive, prior to being elected to that position, and,
given that his background was a -- he was directly
employed by the Post Office as a counter clerk, Crown
Office staff. He worked closely with me and would
attend a lot of national negotiations -- so, in reality,
there was no formal handover, insofar as he'd worked in
my department with me, for the previous five years. So
he was more than well aware and was involved in a lot of
45
Itis.
Are you referring here to cases where the accounting
discrepancies were shown by Horizon?
I'm referring to cases that our members would be called
for interview under the losses and gains procedure.
You said you were talking about your own personal
experience. Is that before Horizon was implemented or
after Horizon or both?
Both the losses and gains procedure is what was used to,
for want of a better phrase, measure the ability of
counter clerks to do their job. I was a counter clerk
before I was an elected representative and the losses
and gains procedure, in various formats -- it's been
rewritten a number of times -- is the measure that
individual counter clerks are held to see whether or not
they can do their job. Each individual counter clerk,
as I explained earlier, balances their stock on
a Wednesday evening, that would either balance, or it
would produce a loss or a gain, either of which, in the
eyes of the Post Office, losses and gains are considered
to be evidence of an inability to do the job to varying
degrees, and there can be a variety of reasons why
people record losses and gains, and then there was
a process to take people through to investigate why
those losses and gains have occurred, mostly designed to
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discussions about these matters up to that point.
So your evidence is you wouldn't have done a formal
handover; is that right?
That's correct.
But you think you would have discussed issues, including
issues with the balancing, with him, before he took over
that role?
Myself and Andy worked almost together on a daily basis
‘over number of years and anything I was aware of in my
role, he was aware of.
I'd like to move on, please, to a new topic, another
topic which concerns the support and the representation
which was available to members of the Communication
Workers Union if they were held accountable for
shortfalls shown by Horizon. Now, you address this at
paragraph 33 of your second witness statement, please,
if that could be shown on the screen. WITN06370200, at
page 7.
Paragraph 33, please. Thank you. This reads:
"The CWU has always provided strong and effective
representation for members accused of accounting
discrepancies."
Just pausing there, please. Is that assertion based
upon your personal experience of representing members of
the CWU?
46
be corrective.
Mr Kearns, I wonder if I could please ask you if you can
try to slow down in your answers, please, just to assist
‘our stenographer who is making a verbatim record of what
you're saying.
Apologies.
Thank you. Forgive me, coming back to the question,
please:
Is it your evidence that you have personal
experience of representing members of the Communication
Workers Union who were accused of accounting
discrepancies after Horizon was rolled out?
Me personally? No.
No. Are you aware of any specific cases in which
members were asked to account for shortfalls shown by
Horizon?
No.
Now, you have stated that your responsibilities relating
to the Post Office ceased in 2002. From where have you
obtained your knowledge of cases after that date?
I don't really have any detailed knowledge of cases
after that date because it wasn't my responsibility. It
wasn't my day job. I've paid a general interest to the
union structures and how it represents its members since
then because that's my job to sort of oversee partly how
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the union functions, but I don't have any firsthand
experience since I left that role in 2002 of individual
cases.
So would it be right to say that, as a general assertion
that you're making there, it's not one based on any
personal experience after 2002?
Apologies. General assertion, what?
Sorry, you're making a general assertion that the CWU
has always provided strong and effective representation
for members accused of accounting discrepancies. What
I've been trying to explore with you is the basis of
that assertion and I think what you accept is that,
after 2002, you had no personal experience of those
matters, and you don't have any information about any
individual cases; is that right?
I don't have any personal experience and I didn't deal
with any individual cases. My assertion about the CWU
dealing with them is that the rep structures that we had
in place to deal with those issues, it's changed but it
remains broadly the same, as in we have local reps,
branch reps, what used to be called regional reps are
now called territorial reps, who deal with those issues
‘on a day-to-day basis and that procedure remains largely
in place as does a losses and gains procedure that they
would work with.
49
correct?
That's correct. I was employed by the Post Office in
1978 and there was a losses and gains procedure in place
then and some of the papers sent to me show a losses and
gains procedure from -- I think it's 2013 and 2014.
A losses and gains procedure for directly employed
counter clerks, as we used to call them, by the Post
Office, has been in place for that length of time.
Would it be a fair summary to say that that policy
applied a threshold or number of thresholds below which
an accounting discrepancy would be treated as
a performance issue but above which it might be treated
as suspected theft; is that a fair summary?
No, that's not how the losses and gains procedure was
applied. The losses and gains procedure, if people fell
foul -- if individuals fell foul of that procedure, they
were given the opportunity to explain why they thought
that the Post Office would be saying to them "Your
performance is unacceptable, we need improvements,"
they'd be given deadlines, or a number of specific
occasions where they were allowed to misbalance before
more serious disciplinary action would ensue.
My experience is that mostly people would understand
the seriousness of the situation, for want of a better
phrase, apply themselves wore diligently to their job
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Now, before we come to the losses and gains procedure,
do you know what type of training union representatives
received to enable them to provide support to staff who
found themselves in this situation, where they're being
asked to account for discrepancies?
Yes. We would run what we would call schools,
educational classes every time -- more or less every
time a major agreement would change and we would get
reps together at varying levels, explain to them any
changes we'd negotiated in policies and procedures and
train them through what we would call basic skills -- we
now call them skills 1, skills 2 -- on how to be
an effective rep, how to engage with an individual who
might be having problems, how to represent that to the
employer. Yeah, we had an education and training
programme, designed to do just that.
Now, you go on to say at paragraph 33, that the:
"CWU collective agreements including the 'Losses and
Gains Procedure’ have been significant ensuring a fair
hearing for directly employed members."
You referred to that procedure in your evidence
before the Inquiry on the last occasion. I think you
recall it being in place at the time when you were
assistant secretary and you've said, just now, it's
something which has been updated over the years; is that
50
and were very unlikely to fall foul of that procedure to
the point of dismissal.
I think if we put to one side what might be
characterised as small discrepancies, in the order of £5
or £6, which would ordinarily be treated as
a performance matter -- is that fair --
Yes.
-- and if we consider a more substantial discrepancy, in
the order of several hundred pounds or possibly even
several thousand pounds, a discrepancy of that type,
would it not be referred to the Post Office to be
investigated as suspected criminal activity?
My experience was single large losses like that would be
dealt with outside of this process and would usually be
subject to a specific investigation.
So if Horizon was showing a substantial shortfall, which
a Post Office staff member could not explain, they would
not be helped by this procedure, would they? That is to
say that they would be in exactly the same position as
a subpostmaster who had a substantial shortfall which
they couldn't explain, would they not?
If, at the end of the week, an individual counter
clerk's balance, either or pre or post-Horizon, showed
up a significant amount of the amounts that you've
referred to, my experience is that that would be
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investigated by the Post Office Investigation Branch, as
it was then, or whatever its title is now.
Essentially, you, as the CWU, and that staff member,
would be reliant upon the Post Office investigating the
cause of the shortfall, would you not, and establishing
whether any fault lay within the system?
Yeah, the Post Office -- they would interview the
individual for their view of why such a loss occurred,
and then the Post Office would make its own
investigations.
Now, if we go back, please, to your statement at
paragraph 33, you go on to say that:
"The CWU has no record of any of our directly
employed members losing their jobs or being prosecuted
due to problems with Horizon."
What I want to ask you is this: does the CWU make
and retain records relating to the dismissal or the
prosecution of its employees -- of its members, forgive
me.
No.
If you don't have any record, or if you don't make and
retain such records, does it not follow that there might
well be directly employed members who have lost their
jobs or been prosecuted due to problems with Horizon, of
which you're not aware?
53
been the case; is that fair?
Yeah, we would assume our reps would tell us if they
were being asked by our members to assist them in such
cases.
You've also said earlier that you would have expected
these issues, accounting discrepancies, to be resolved
at a local level and that you didn't expect that to be
something that would be escalated to national level?
There are two separate things.
In what sense?
So I work at a Crown Office. I used to work at a Crown
Office and I work alongside people who on a Wednesday
night would do their balance and would misbalance more
regularly than the losses and gains procedure at the
time allowed for. So they would be interviewed by the
Post Office with their union rep or their local area
union rep and they would go through the losses and gains
process with the intention of rectifying their
performance on the job, so to speak.
There were regular occurrences. When I was a local
rep I used to deal with those cases on behalf of the
members, one or two a month. They're just dealt with at
local level and that's where it ends, and that's the
idea of that procedure, is to rectify those problems,
for want of a better phrase, at the coalface, so that
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A. That's possible.
Q. So would it not be more accurate to say that you don't
know whether, and, if so, how many, of your members have
lost their jobs or been prosecuted due to problems with
Horizon because this isn't something which you've
actively monitored?
So the statements I make, which is the CWU has no direct
record of any of our directly employed members losing
their jobs or being prosecuted due to problems with
Horizon is a statement of fact for -- as far as I'm
concerned. We don't have that record.
Because of the extensive network we have of reps and
the relationship we have between the national officials
and our local reps and regional reps, my belief is that
we would be made aware if individuals had come to our
reps at local level and said to us "We're losing our
jobs" or "We're being" -- let's take the issue of
prosecution. If any of our members were to be
prosecuted over that, we're fairly certain that they
would come to our reps through the process I've outlined
and, if -- if our reps thought that was a problem, they
would come to us but we don't have any record of that.
Now, I think what you've just said really is that you
make an assumption that that information would have
filtered its way up to national headquarters if that had
the individual counter clerk can prove that their doing
their job properly.
It's also true to say that, if our members were
being dismissed or prosecuted and our reps felt that
was, for want of a better phrase, unfair and wanted to
defend them and wanted our assistance in helping them do
that, they would come to us.
Are you saying that, at that stage, there would be some
record held centrally of a request for assistance or
that, effectively, you would have some records showing
that that request had been made?
Yeah, if they -- if somebody wanted us to help assist
them in representing a member, they would email -- back
to '99, write to us -- with details of the case, asking
us could we assist or was it possible to assist,
depending on the nature of the individual case.
But any record of that would have been in emails at the
time, which presumably you haven't gone back and checked
cover, have you?
Yeah, we asked our research department what documents
and I think our research department and Andy Furey's
department -- my successor in that previous role --
provided a number of documents to the Inquiry over the
last couple of years, with regards to what information
we have around Horizon. And we haven't come across --
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to my knowledge, we've not come across any
correspondence, emails or letters of that type.
Now, the final thing you say in paragraph 33 is this:
"There have been cases of actual theft amongst CWU
represented grades, but invariably when people are
caught out they are quick to admit to theft. In these
cases, the CWU is generally not involved as people
resign before being dismissed."
Now, again, are you speaking here from your personal
experience of dealing with cases of theft?
Yes.
On how many occasions were you called upon to deal with
cases of theft by CWU staff members while you worked as
the assistant secretary?
Not when I worked as assistant secretary but when
I worked as a local rep -- when I was a local rep --
back in Liverpool. When I worked as a local rep back in
Liverpool, I dealt with -- from memory, it's 30 years
ago -- from memory, three cases of individuals accused
of theft.
Was it your experience that members who were accused of
theft by the Post Office always admitted their guilt?
Of the three cases I remember dealing with, one didn't,
and we subsequently won that case in Employment
Tribunal. The Post Office had no evidence. One
57
prosecuting staff members and you've just referred now
to an incidence of that. You also stated that, prior to
Horizon, I think you'd represented a member of the CWU
who'd gone on to be prosecuted by the Post Office. In
which type of hearings would you be representing
individuals at that stage?
So the individual concerned showed to a £500 loss in
their weekly balance. They were then called to
interview by the Post Office investigation branch and
then allowed to have friend/witness in and the Post
Office investigation branch put it to them that a loss
of that figure, around 500, couldn't possibly have been
a discrepancy; it was theft. And the individual denied
it and we went through the process of them being
dismissed, me doing the appeal, and it was at the appeal
stage that the individual changed their position and
said that, in fact, they did steal the money.
So yeah, that's how that process is dealt with.
So, under the investigation process, the
individual's allowed to have a witness/friend, whatever
you want to call it, in the room with them,
predominantly to make sure that that interview is
conduct correctly, fair play, in line with rules. Yeah,
and so I've dealt with that case.
So you would have dealt with it and others in your
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individual -- I think I made this in my earlier
submission, one individual was accused of stealing £500,
who denied it, right up until the final interview and
then admitted it, and then resigned, and then was
subsequently prosecuted.
Were you involved in any cases of alleged theft after
Horizon was rolled out?
No.
Therefore, insofar as you make a general statement about
cases of theft, is it right to say that that wouldn't
apply to the period after 2002, of which you didn't have
any personal experience?
I have no experience after 2002. Sorry, maybe I'm
misunderstanding the question, sorry.
Sorry, it was badly phrased, so that's my fault. I'm
saying, insofar as you make a general statement about
cases of theft, it's right to say that that applies
prior to 2002 but not afterwards; is that fair?
I wasn't dealing with them after 2002 but, generally
what I say in my statement, generally, is the CWU
generally is not involved, as my experience is, if
people are guilty, then they resign rather than wait to
be dismissed. I've seen that, prior to 2002.
Thank you. Now, when you previously gave evidence you
said that you were aware of the Post Office practice of
58
position would have dealt with it at this stage of the
internal disciplinary hearing; is that right?
Yes.
And any appeal hearing --
Yes.
-- which followed. Did the CWU offer legal
representation to members against whom criminal
proceedings were brought by the Post Office?
CWU does not offer legal assistance to members for
criminal cases.
That's in any circumstances?
To the best of my knowledge and experience, yes.
You've been shown some statistics relating to the number
of prosecutions brought against subpostmasters,
assistants and Post Office employees in the decade
before and in the decade after Horizon was introduced;
is that right?
Correct.
Now, it's right to acknowledge that the records on which
these statistics are based are incomplete, particularly
insofar as they relate to the decade before Horizon was
implemented. But I think you accept, do you not, that,
on the basis of the data we do have, it tends to show
a substantial increase in the number of prosecutions
bought against Post Office employees after Horizon was
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rolled out; is that fair?
They appear to double: 2002 over 2001; 2003 over 2001;
drop back down again, 2004. So they fluctuate but it's
certainly true to say in -- so assuming we're (unclear)
enough to say the same thing, it says in 1999 for
employees, which are the people we were responsible for,
there were five, in 2001 there were six and then in 2002
there were 13, in 2003 there were 13, in 2004 that
dropped back down to seven, and then up to 11 in 2006
and so it fluctuates. But it is correct to say that, in
2002/2003, there were more than there were in 2001 and
1999.
Now, in your most recent statement, you say that you
were not aware at the time of the rise in prosecutions
and convictions of Post Office employees; is that right?
That's correct.
Do you think you should have been aware or that you
should have known about this in your role as assistant
secretary and subsequently as Senior Deputy General
Secretary of the union?
No, because, as I said earlier, they wouldn't get
reported to us --
Well --
-- at national level, sorry.
But I think you said the opposite. II think you said you
61
What you seem to be saying, essentially, is that you
were relying upon your local rep effectively to identify
if there was a system fault, were you not?
That is the system we have in place. As I explained
earlier, the idea of dealing with discrepancies or
even -- not just discrepancies in balancing, if you
like, on the counter but any discipline cases for any
reason -- insubordination, failure to attend for duty --
the whole system was set up to deal with those issues
quickly, at the point they occurred, and then there
would be a process you would go through where, in more
serious cases, there would be escalated up, in terms of
the Post Office, their managerial structure and, in the
case of the union, our representative structure. And
that's how the issues would be dealt with.
So, insofar as we would have no record of, let's say
in 1999, exactly how many individual members of the CWU
were interviewed under the losses and gains procedure,
we wouldn't have that record because they were dealt
with locally. So, in the same way, if somebody was
prosecuted, unless those individuals contacted us,
unless representatives contacted us, we would have no
record of that.
Okay, so, unless either the member themselves or the
local rep came to you and said, "I'm being prosecuted
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would have expected -- had members been prosecuted, you
would have expected that to have reached you at national
level because you would have been told that?
No, I would have expected, if our local reps thought
that they should have been involved, they thought
something wasn't right, I would have expected them to
have raised it with us at national level.
So your expectation --
So I've referred -- sorry, so I referred earlier to they
would email us or they would write us to saying "We've
got a problem here, can you assist?" and so I would say
“We have no record of that", that's why we wouldn't have
been aware of, what, 1999, five prosecutions, if I'm
reading this correctly; 2001, six prosecutions, if I'm
reading it correctly. We would only have been aware or
we would have been made aware if representatives who had
been dealing with those cases had contacted us,
basically to say, "I've been dealing with this case its
looks like they're going to dismiss them, it looks like
they're going to prosecute them, we don't think that's
fair, we don't think that's right, is there something we
can do can we talk about this?", so on and so forth.
I've no recollection of people coming to me in my
role as the Assistant Secretary at national level and
raising that type of complaint, if you like, or concern.
62
because of a shortfall in Horizon which isn't my fault
it's the system at fault", you're saying that there
would be no record and you would have no awareness of
the fact of prosecutions being brought?
We would have no awareness at national level, no.
Now, given what you knew about problems with balancing
during the rollout of Horizon, do you think that the
bringing of prosecutions by the Post Office is something
which you ought to have been monitoring at a national
level?
We weren't aware of the prosecutions at national level,
so we wouldn't have been monitoring it.
But my point is you knew that the Post Office brought
prosecutions; is that not something which you should
have proactively been monitoring?
So let me just step back on we were aware of the Post
Office bringing prosecutions. At national level, we
don't have a record, we don't keep a record of the
prosecutions that the Post Office carries out. I think
the point I made in my statement is, usually, by the
time -- historically, by the time it got to that point,
we'd have individuals resigning, so we wouldn't have
a record of the prosecutions that the Post Office took
out against direct employees.
I understand what you're saying, which is you didn't
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have one. My question was: do you think you should have
had one, bearing in mind that you knew that there were
increased numbers of Post Office staff who were
complaining about problems with balancing?
No, because they were dealt with under the balancing
procedure.
I'd like to move on to another topic, please, which
concerns the CWU's representation of subpostmasters.
When you worked as an assistant secretary, the CWU did
not represent the interests of subpostmasters; is that
right?
No, that's correct.
Do you know why it was that subpostmasters were not
admitted as members of the CWU at that stage?
Because they were members of the National Federation of
SubPostmasters and that was -- so, within the Post
Office at the time, there were number of different
unions. There was the Post Office Engineering Union,
who were responsible for light and heat and vans: there
was the Communication Workers Union who were responsible
for directly employed Post Office staff working on Post
Office -- now Royal Mail -- issues as well; there was
the Communication Managers Association, who were
responsible for representing managers; and there was the
National Federation of SubPostmasters who were
65
employed staff, whereas my understanding at the time is
the contracts between the Post Office and subpostmasters
would remunerate subpostmasters based on the
transactions they did, which are two distinctly
different things. They're not aligned.
Now, there came a time when the CWU started to recruit
subpostmasters as members of the union. Do you recall
when efforts were first made to recruit subpostmasters?
Only from evidence that's been given to me in this and
from my involvement on the National Executive Council
for the union. I think that was around the 2014/2015.
Now, you've been shown a printout from the CWU website
which tends to indicate that the union were actively
recruiting subpostmasters in October 2011. That's
NFSP00001463, please.
Thank you very much. If you look at the very bottom
of the page, please, you can see this is from where it's
drawn, so www.cwu.org/postmasters, and the date is
3 October 2011. If we could just scroll down, please,
thank you. So, in that first box, it identifies the
Chairman of what was called the CWU Postmasters & Agents
section, and that's Mr Nippi Singh.
Mm.
A little further down, please. Thank you. There's
a further box which identifies Mark Baker as the Vice
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responsible for representing subpostmasters.
And 56, if you fell into one of those categories,
the recognition of the employer for anybody employed in
those categories were to -- within those unions. So the
reason we didn't represent them is because we didn't
have recognition agreements and they joined the National
Federation of SubPostmasters.
In your statement you say that you don't consider the
interests of subpostmasters and Post Office employees
necessarily to be aligned; is that right?
I did say that, yeah.
What do you mean by that?
Well, because subpostmasters -- so -- Crown Office
staff, Post Office staff, were directly employed
employees, of the Post Office. Subpostmasters, to my
knowledge/recollection, worked on a contractual basis as
private business people, for want of a better phrase,
and had a private contract with the Post Office. So
there were two distinct, different groups: one were
directly employed workers and the other were privately
employed -- private businesses, and directly engaged, if
you like, as agents by the Post Office. So two separate
interests.
So we would negotiate and argue, for example, for
increased wages and terms and conditions for directly
66
Chairman of the same section. So it appears that, by
this time in October 2011, the CWU had established
a separate section to represent the interests of
postmasters and agents. Do you think that's a fair --
Yeah.
-- inference from what we can see here? Do you recall
the circumstances in which these two individuals,
Mr Baker and Mr Singh, joined the Communication Workers
Union?
No, I wasn't involved in that but, from discussions,
I was -- so the final decision on allowing them -- or
setting up a subpostmaster section and actively trying
to recruit them was a decision of the National Executive
Council, of which I was a member. And my understanding
from memory, although I'm talking about nine, ten years
ago now, is that they had a sort of dissatisfaction with
the National Federation of SubPostmasters, then
a dissatisfaction with the direction that Post Office
was going, in a general sense, and my understanding was
they didn't have much faith in the National Federation
of SubPostmasters representing them, which is why they
approached us, and then we went "Well, if you're going
to approach us, then we're set up a section, we're going
to try to recruit more people from that cohort into the
union".
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Now, in your statement, you say that within of the roles
of the union is to regulate tension between its members;
is that right?
Between its members and the employer.
Well, between members and employer but between -- but
internally between members, as well; is that not right?
Do I say that in my statement?
If we go, please, to page 3, paragraph 8b. Thank you.
So in the preceding paragraph you describe the
objectives of the union and you go on to say here at
(b):
"[They are] To regulate the tensions between members
and their employers, and between members."
Yeah.
Do you consider that tensions existed or exist between
subpostmasters and Post Office employees, bearing in
mind what you said about their interests not necessarily
being aligned?
No. No, I don't think there's a tension. We can
represent and do represent separate groups of workers to
the employers who are not necessarily in the same
workplace, not necessarily in the same, if you like,
industry. So no, it's -- I don't believe that, no.
Thank you. Another related topic, please, which
concerns the relationship between the Communication
69
the years, we had -- we do have general discussions with
other unions and representative bodies about whether or
not there is common ground or there is the possibility
of us merging or are there any common interests.
So yeah, that approach -- or whether they approached
us or we approached them, I don't know because I was not
involved but I'm generally aware that a discussion took
place.
Thank you. Could we please bring up CWU00000076. Thank
you. As you can see, this is a report to the National
Executive Council on 18 June 2015, for consideration at
a meeting scheduled for 25 June. Were a member of the
NEC at this time?
Correct, I was.
Did you receive a copy of this report?
I would have done.
You would have read it, presumably, at the time?
Yes.
Now, to place this in context, can we please take a look
at the heading and introduction. So this report relates
to the NFSP, Post Office Limited and CWU. Under
“Introduction”, it reads:
“It is prudent for us to consider the challenges,
opportunities and options for the CWU given the
likelihood that the NFSP special conference next month
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Workers Union and the National Federation of
SubPostmasters. In your statement, you say, at the time
when you worked as assistant secretary, the two
organisations held equal status; is that fair?
They were both recognised by the employer, by the Post
Office, as having negotiating rights. So, yeah, equal
status insofar as they could both directly represent to
the Post Office the concerns of their members.
You said you would occasionally communicate on key
issues and priorities but you did not collaborate on
projects or member representation; is that right?
That's correct.
Now, there came a time when the Federation and the union
discussed a possible merger; do you recall that?
I don't.
It may assist you, please, if we --
Sorry, generally, yes. I think we were approached by
the then General Secretary, I think at the time was --
I think at the time was George Thomson, but it wasn't my
day job so that approach would have been through Andy
Furey and the then General Secretary, I think, Billy
Hayes. So only in the sense that we were also
approached once by the Society of Telecom Executives,
which was the managers in the -- in BT, where we also
have members and, over the years ~- excuse me -- over
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decides not to enter into a Memorandum of Understanding
with the Post Office in preference to a transfer of
engagements to us or the National Federation of Retail
Newsagents.”
This is a reference, is it not, to what later became
known as the Grant Framework Agreement, that was
concluded between the NFSP and the Post Office in July
of that year; are you aware of that?
am not. I'm not aware of that last point. As I say,
my understanding was, along with other unions over
a period of time, the NFSP had approached us, as well as
others, including the National Federation of Retail
Newsagents here, to understand or identify what scope
there was for the two organisations to come together,
but I wasn't aware of that -- of that other point, as
I say because that was no longer my area of
responsibility.
What this appears to suggest is that that approach, that
you say you received from the NFSP, seems to have come
at a time when they were also in negotiations with the
Post Office over a possible long-term partnership and
a funding arrangement: is that fair?
Yeah, I think that's fair. I mean, I referenced
discussions we'd had with other unions about potentially
merging with the CWU. But what happens is, if
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an organisation thinks there's a need to merge, for want
of a better phrase, they'll keep a number of options
open, they'll have discussions with a number of
partners, if you like, and then to a decision about
which they think is the possession, fit for them. So,
yeah, they were talking to us, talking to the National
Federation of Retail Newsagents and talking with the
Post Office, as I understand it, new arrangements which
led to the contract that you just referred to.
Now, it appears that it was the expectation of the CWU
that the NFSP would not enter into that agreement. Do
you know why that was their expectation at the time?
No, my sense for that, having been involved in
discussions with other unions over a period of time, is
you get a feel whether you're just, for want of a better
phase, as a bargaining chip for them to go somewhere
else, so they will say to whoever their preferred
partner is "These are offering us a better deal, we're
in discussions with this other group as well, so the
deal had better be good from you", whoever you are,
“because we've got other options".
Once you go through the sort of negotiation process
‘on that, which I have been involved in but not the
Federation, you start to get a feel about whether
they're serious about merging with you, or actually,
73
"The exclusivity accorded to the NFSP does not
appear to be consistent with particular legal
obligations, especially as it necessarily means that CWU
represented postmasters are excluded from arrangements
which determine their contractual undertakings.”
Do you consider that the CWU was hampered in its
ability effectively to represent the interests of
subpostmasters by reason of the fact that they were not
formally recognised by the Post Office for collective
bargaining purposes?
Yeah, I think -- so, in reaching out to anybody who
wants to be a member of any union or the CWU this say to
them "This is what we can do on your behalf", so we can
say to directly employed staff, "What we can do on your
behalf is go direct to the employer on pay, terms,
conditions, that directly affect you. We are recognised
by the employer to bargain on your behalf".
I believe -- my understanding, as of today, we still
don't have a recognition agreement with the Post Office
for our subpostmasters' section and, therefore, the
offer that you make to potential members, one of the
first questions they would ask is "What can you do on
our behalf", and we have to say to them "We're not
recognised by the Post Office to directly represent your
interests".
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they're keeping their options open in case what they
really want falls apart, and then they've got you as
a back-up.
Now, if we could move on, please, to page 3 and we see
this issue addressed in some more detail under the
heading "Relationship issues". Firstly, "With POL", the
first issue dealt with. That reads:
"There was an exchange of correspondence with POL in
October 2014. This followed receipt by us of legal
advice on the nature of POL's relationship with the NFSP_
following the removal of the Federation from the list of
accredited trade unions."
Just pausing there, do you know why it was that the
NFSP had been removed from the list of accredited trade
unions?
I don't know the specific reason that would have been
given by the CEO, no.
If we go on, please, to the second paragraph, it reads:
"We ... need to return to that correspondence in the
event of the merger process being terminated."
So that's presumably a reference to the possible
merger between the CWU and the NFSP.
I assume that -- I'm assuming that's what that refers
to.
The:
74
So, in answer, not being recognised by the Post
Office to directly represent their interests is
a hindrance to recruitment of that cohort, in my view.
Sorry.
Well, it may be a hindrance to recruitment, is it also
a hindrance to effective representation?
Insofar as you cannot directly go to the Post Office,
yes, it is.
Do you know the reasons which were given by the Post
Office for refusing to recognise the CWU --
No.
-- as representative?
I don't.
What, if any, steps has the union taken to address this?
I don't know. As I think I've said in my statements,
since 2002, not my day job. Andy Furey would be in the
frontline of making that representation to the Post
Office.
Now, in the second half of this page we can see the
heading "Relationship issues ... With the NFSP as
reconstituted under an MoU". It reads:
"We have received a copy of the much-discussed
proposed Memorandum of Understanding between [Post
Office Limited] and the NFSP. This is attached.
"The most salient points of this document can be
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summarised as follows ..."
We'll look at some of them now, please. The first
‘one summarising paragraph 2 of the draft MOU:
"The NFSP will reconstitute itself as a trade
association or similar organisation."
Are you able to explain, please, the distinction
between a trade union and a trade association?
Um --
What the significance of that would be in --
I understand what I know and believe a trade union to be
and what its purpose is, and a trade association or
similar organisation is there to protect the interests,
as I understand it, of the business or the business
owners, as opposed to all the workers who work in any
particular trade or business, which is why I suspect the
Certification Officer no longer includes the National
Federation of SubPostmasters as an accredited trade
union, because the Trade Union Certification Officer has
a strict set of criteria about what a trade union is,
and them not being listed as a trade union means that
they fall outside of that remit. So there is
a fundamental difference in protecting a business or
protecting a trade, than there is protecting directly
employed workers.
The second bullet point, please, states that:
77
subscription income paid by their members. This
document shows that had position for the Federation was
to cease and they were to be funded directly by
a payment from the employer or the Post Office.
Now, the document goes on to suggest that there were
likely to be some conditions attached to the grant of
this funding. If we can scroll down, please. Thank
you. So these are referenced as part of paragraph 6,
the first bullet point identifies paragraph 6 as
a review mechanism for the agreement and states:
"At paragraph 6c it says that the 'NFSP has not
engaged in activities which are actively detrimental to
the [Post Office]' -- but does not define what these
are."
The paragraph goes on to state that:
".., 'the Post Office acknowledges that the NFSP ...
must have freedom to undertake activities that protect
and represent their members’ views. In undertaking
these activities, the NFSP agree that it will not
introduce commercial risk to the [Post Office]'."
The author observes this a "very wide potential
prohibition". Then:
"... while [Post Office] remains publicly owned, the
proposed TTIP treaty ..."
Do you know what that is a reference to: the TTIP.
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"Under the MOU the, the [Post Office] (not [Post
Office Limited]) will provide funding of 'up to
£1.5 million’ per annum from 2015/16'."
It goes on to explain that the actual amount would
depend on the difference between the revenues derived
from the current membership model and the income stream
and what they actually received, but it goes on to state
at the bottom:
"In discussion, CWU representatives have described
adoption of the MOU as meaning an inevitable cessation
of subscription income -- and no one [perhaps it should
read ‘from’, rather than ‘form'] the NFSP has
disagreed."
So, essentially, a proposal to provide funding of up
to £1.5 million.
If we could go over the page, please, the second
bullet point there reads:
“PO will provide additional funding of no less than
£1 million per annum as a budget for grants to the
NFSP'. Thus the annual gross value of the MOU is up to
£2.5 million per annum."
Was a funding arrangement of this nature usual for
a trade union or trade organisation to your knowledge?
It's not usual for a trade union. Absolutely not.
Trade unions are almost predominantly funded by
78
treaty?
I think that was an international agreement around how
businesses transact standards that they had to operate
under, from memory.
".., [that] could be prayed in aid as the arbiter of
‘commercial risk' were the treaty to be ratified", it
suggests.
It goes on to say there are dispute management
procedures, which are reasonably transparent and have
a degree of independence but, in the final bullet point,
please:
"Paragraph 6's final subparagraph says ‘should the
NFSP disclose [Post Office] information that is
confidential or commercially sensitive (as defined in
the confidentiality agreement) or encouragement
[presumably was meant to read 'encourage’]
subpostmasters to take action which conflicts with their
contractual obligations, except where all other avenues
of dispute resolution have been exhausted, this will be
deemed a material breach of this agreement."
So, essentially, the NEC being notified there that
there's a new arrangement for funding to be made but
that funding will come with certain conditions; is that
fair?
That's my understanding of --
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Now, if we could turn to the following page, please, we
can see the overall conclusion reached by the CWU --
forgive me, if you scroll up a little bit, thank you.
So, as to the effect of these provisions, the report
provided:
"There can be no doubt that the MOU represents the
abandonment by the Federation of any meaningful
independence. Our relationship with them and the
employer would necessarily change as a consequence, as
the CWU would be the only organisation of standing able
to offer postmasters effective representation."
Now, reading that, it rather suggests that the CWU
believed at that time that the NFSP had compromised or
was going to compromise its independence in reaching
this agreement; is that fair?
That's fair.
And that the CWU believed that it was the only
organisation which could offer effective representation
to subpostmasters?
That was our view, yes.
Now, it's a related issue but I'd like to deal now,
please, with how the CWU responded to the emerging
scandal. If we can please bring up your witness
statement at page, that's WITN06370200.
Thank you. Page 10, please, paragraph 43, you say
81
which Andy Furey is a national officer -- I used to be
a national officer of the Postal Executive from '97 to
2002.
So those issues are dealt with not by the National
Executive Council but are dealt with by the industrial
executive that I don't sit on and is not part of my
responsibilities. So my statement was in response to
the specific question that I was asked by the Inquiry
Team: did I take any steps between 2009 and 2019 in
raising any concerns on the issue with those? And the
answer is no because, as I've just explained, the remit
for those was the then-Assistant Secretary couldn't --
Assistant Secretary, Andy Furey, and the postal
executive.
The role of Assistant Secretary was not as senior as
Deputy General Secretary, was it, in terms of hierarchy?
In terms of the internal hierarchy of the union,
correct.
Do you not think this was an issue which required the
involvement of more senior leadership?
No, because that isn't the structure. So the
responsibilities of the national officials are laid out
within the rule book. Mine is to assist the General
Secretary, and the Postal Assistant Secretaries and the
Postal Executive have sole authority over the industrial
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this:
"I did not take any steps between 2009 and 2019
(inclusive) in raising any concerns regarding the
integrity of the Horizon IT System with [Post Office
Limited], the Government, the Shareholder
Executive/UKGI, MPs, and peers or journalists as this
issue no longer formed part of my remit to do so.”
Now, just pausing there, for a minute, you've just
told us that, as a member of the NEC, you received
a report saying that the NFSP was compromised or was
compromising its independence; is that correct?
That's correct.
Do you not think that you had a duty to take forward
these issues on behalf of subpostmasters who were not
being effectively represented, in your view, by their
trade association?
So the question was: did I take any steps? The answer
was I didn't because it was not my job to do so. The
CWU structure, at national level, is we have a National
Executive Council, which I sit on, which is responsible
for finance, admin functions, things like whether or not
we agree to merge with another union to form a union,
industrial issues, day-to-day industrial issues, which
the Post Office and counter clerks are dealt with by
a separate executive called the Postal Executive, of
82
issues with the employers, Royal Mail, Post Office, et
cetera.
MS HODGE: Thank you, sir. I think the stenographer would
like a short break, please. I have very few further
questions for this witness but I think there may be
a couple of questions from the recognised legal
representatives.
SIR WYN WILLIAMS: Yes, that's fine. We will take a break
until 12.10.
10 MSHODGE: Thank you.
11 (12.00 noon)
12
(A short break)
13° (12.10 pm)
14 MSHODGE: Good afternoon, sir. Can you see and hear us?
15 SIRWYN WILLIAMS: Yes, thank you.
16 MSHODGE: Thank you, sir.
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24 Qa
25 A.
Mr Kearns, you've said in your statement and in your
evidence that you simply weren't aware that
subpostmasters and Post Office employees were being
prosecuted in reliance on data shown by Horizon; is that
right, at least for a substantial period of time with
which we're concerned?
Apart from when it became public, yes.
Do you recall when you first did become aware?
I don't recall, no.
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I wonder, please, if we could look, again, at that
report to the NEC dated 18 June 2015, that's
CWU00000076. This was the report we were looking at
just shortly before the break, insofar as it related to
the changes to the constitution of the National
Federation of SubPostmasters and its funding arrangement
with the Post Office. It also contained an update on
Horizon. We can see that, please, on the first page.,
under the heading "Horizon". It said this:
"As reported in LTB 269/15 ..."
Is that a reference to letter to branch, "LTB"?
"LTB", letter to branch.
... issued on 21 April, concern about the approach
adopted by [Post Office Limited] to the alleged problems
caused to postmasters by the Horizon operating system
has now been raised directly with the Prime Minister.
"There has been a pause in political activity on
this during the General Election period, but POL's lack
of engagement with the mediation process, the attempt to
suppress a report by Second Sight -- the company engaged
to investigate alleged shortcomings of Horizon -- and
continuing concerns of both CWU and NFSP postmasters
mean that the issue will not subside.”
Now, it goes on to read, please, over the page:
"The ‘Justice for Subpostmasters Alliance’
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quickly culminate in [Post Office Limited] terminating
the contract of one member and forcibly making the other
pay back his losses by deduction to pay."
Now, if we just step back for a minute, this is
obviously in a report to you as a member of the NEC --
that's correct -- bringing to your attention concerns
about Horizon; is that fair?
Yes, it references --
Concerns which the CWU shared at that stage, or by that
stage. These were concerns that affected both former
subpostmasters and current subpostmasters, some of whom
were members of the CWU at that time; isn't that right?
Yes, I mean -- well, we had a subpostmaster section. So
yes.
Given what you were being told in a report such as this,
should you have done more, do you think, to raise
awareness within Government and to lend your support to
the campaign to expose the failings of Horizon?
As I said before the break, that was not my area of
responsibility. Our rule book, which is -- under which
the CWU operates, that responsibility is the
responsibility of the Postal Executive and the officers
of the Postal Executive, in this case Andy Furey, to
deal with.
Would it be fair, do you think, to say that, in essence,
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organisation has been set up by mostly ex-postmasters
who believe that they have been unfairly treated.
However, the key individual in JFSA, Alan Bates, is not
currently in contact with the CWU parties’ branch."
This suggests at least that, at this stage, Mr Bates
hadn't approached the CWU directly for support for his
campaign; is that correct?
Yes, that's what it says, yes --
On the face of it, of what we have before us.
Yes.
prop
The second paragraph goes on to read:
"[Post Office Limited's] position has essentially
been based on the principle that the Horizon system
cannot go wrong. However, this is not what we, NFSP and
JFSA are saying. Our position is that however robust
a computer system there can be and have been problems."
What this appears to be is an acknowledgement by the
CWU that there have been problems with the Horizon
system; is that fair?
A. That's what that suggests, yes.
Q. Now, the final paragraph reads:
“Due to the collapse of the Mediation Scheme at
least two of our members will almost certainly now have
normal [Post Office] disciplinary action taken against
them (because they are stil serving), which will
86
the CWU left the group litigants to bear the burden of
challenging the integrity of Horizon?
A. Given that I had no involvement with that issue at that
time, I couldn't say I could agree with that statement.
I'm not in a position to agree with that statement
because I don't know what the executive and the officer
concerned were doing on a daily basis on this issue.
MS HODGE: Thank you.
Sir, I've no further questions for this witness.
Before the recognised legal representatives ask
their questions, is there anything you wish to ask, sir?
‘SIR WYN WILLIAMS: No, thank you. No.
MS HODGE: Forgive me, sir. If we just pause for one
minute.
SIR WYN WILLIAMS: Yes, (Pause)
MS HODGE: Sorry, sir, we've had a late request for
a further document to be put to the witness. It may be
that the way we can approach it is to let Mr Stein, if
you have questions, to go first.
I think the other representative is Ms Watt.
SIR WYN WILLIAMS: Yes.
MS HODGE: We can review the position in relation to that
document to ensure that the witness is given a fair
‘opportunity to review it before he is asked any
questions.
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‘SIR WYN WILLIAMS: Sorry, we're going to hear from Mr Stein
and then Ms Watt, and then review whether we need to ask
any more questions; is that it?
MS HODGE: Well, sir, yes. I mean, my proposal is that we
proceed with questions now whilst we review in the
background what the effect of this document is and then
we will perhaps see where we are in the next 15 minutes.
SIR WYN WILLIAMS: Yes, that's fine.
MS HODGE: Thank you.
MR STEIN: I Sir, I've no objection, of course, to us
proceeding in that way. The difficulty though is, if
the document is released and I need to see and it and
consider it, for the purpose of any further questions,
then I may beg an indulgence, which is to return to any
questions we may have arising out of that document.
But on that basis, sir, would you mind if I then go
ahead with our questions for Mr Kearns?
‘SIR WYN WILLIAMS: No, no, carry on.
MR STEIN: I'm very grateful.
Questioned by MR STEIN
MR STEIN: Mr Kearns, you're a longstanding employee of the
CWU, the Communication Workers Union, you're employed in
an elected position as the Senior Deputy General
Secretary of the CWU; is that correct?
A. That's correct.
89
Help us understand, with your own work within the
trade union movement, is that a normal arrangement with
a representative body working on behalf of, in this
case, subpostmasters?
A. No. I wasn't aware of that specific but, having
listened to what you said, I've never come across
a representative body/trade union, that has such clauses
in it. That doesn't sit comfortably people with me as
a trade unionist, that you could enter into that and
claim to be a representative body.
Q. It may be, in some ways, obvious but what's the problem
with entering into an agreement to not criticise the
employer of the people you represent; what's the
difficulty?
‘A. Well, you would take away your independence, you take
away your ability to challenge the direction that the
employer or the company is going in, because you think
it's detrimental to both the members you represent. In
the case of ourselves as the CWU, with recent examples
of Royal Mail, the service they're providing to the
customer, to the public. If you're unable to challenge
that, it strikes me that it's more like a business
partnership than it is a representative body for the
individuals that make up the organisation.
Q. Can I then elide that to a question that was asked by
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You may or may not know my name is Sam Stein,
I represent a large number of subpostmasters/mistresses
and employees working in branch offices of the Post
Office.
I've just got a couple of questions, using, first of
all, your experience, if may, as part of the trade union
movement. In the judgment, judgment number 3 in the
High Court -- I'm not sure if you have this but I'll
read out the relevant part -- a judgment by Mr Justice
Fraser, now Lord Justice Fraser, he said this at
paragraph 1120 of judgment 3 that:
"The National Federation of SubPostmasters is not
independent of the Post Office."
He went on to say:
"The Post Office also has a highly detailed funding
agreement with the NFSP that would entitle the Post
Office to claw back funds already paid to the NFSP if it
does anything that would damage the Post Office's
reputation, including supporting the subpostmasters in
this litigation."
So he was making the points, which is the NFSP is
not independent of the Post Office, there's a funding
agreement with the NFSP, allowing the Post Office to
claw back funds paid to the NFSP if the NFSP anything
that would damage the Post Office's reputation.
90
Ms Hodge that concerned and touched on collective
bargaining. Now, you refer to collective bargaining at
paragraph 7 of your statement, where you say you must
add that:
"The CWU has long called for union recognition, for
collective bargaining purposes, for subpostmasters but
POL has consistently refused to grant this.”
You've added in your evidence you still believe
that's the position today; is that correct?
That's my understanding of it.
Now, paragraph 11 says this:
"We engage in collective bargaining processes with
several employers on issues such as pay, terms and
conditions of employment.”
So Ms Hodge was seeking to establish with you what,
if you like, are the advantages of collective bargaining
on behalf of members of the CWU. You refer to it there
as being discussions with employers on issues such as
pay, terms and conditions of employment. What would be
the effect of having what I am going to call a shackle
‘on a representative body to not criticise the employer,
in relation to collective bargaining?
My view is that the shackle would be that you're not
able to effectively represent the members of that
organisation and because -- well, if you're restricted,
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for want of a better phrase, in criticism, such --
I give an example. You take the -- we had a major
industrial dispute with Royal Mail some years ago --
I understand not everybody likes this but we took major
industrial action which disrupted the service, partly
because we didn't think our members were being treated
with due respect, partly because -- the reason for that
was because the direction that Royal Mail was setting
out as a business, and therefore the industrial action
that we eventually took was, if you like, for want of
a better phrase, a protest against that, to defend our
members against job losses, so on and so forth.
If you're restricted from being able to make that
criticism then, well, you're not able to effectively
represent those individuals who make up that
organisation, is how I would see it.
Q. Now you've mentioned to Ms Hodge that the position of
Mr Furey. Mr Furey, if I've got it right, is the
Secretary to the CWU but also is the CWU's national
officer for postmasters, CWU members who are working in
Post Office branches and working in the wider Post
Office; is that correct?
A. That's correct.
Q. Right. So Mr Furey's title is, essentially, to deal
with all such matters in relation to CWU membership,
93,
A. Correct.
MR STEIN: Thank you, Mr Kearns.
‘SIR WYN WILLIAMS: Ms Watt?
Questioned by MS WATT
MS WATT: Good afternoon, can you hear and see me?
Thank you, Mr Kearns. I'm just diagonally behind
Mr Stein there. Yes, we have this problem every time
I speak. Thank you.
I have some questions for you on behalf of the
National Federation of SubPostmasters and I think we
actually spoke before when you were here the last time.
Your union would have had hundreds, perhaps, if not
thousands, of members working in what was then hundreds
of Crown Office branches using Horizon during the 2000s
when the scandal was emerging; that's correct, isn't it?
A. Yes, my recollection, from around 2000, I think we have
maybe 9,000/9,500 members. That's severely diminished
through the 2000s and to today because of --
So A lot of members --
Yeah.
- many, many members --
Yeah, thousands.
-- working in these Crown Office post offices?
Correct, yeah.
So you've accepted earlier this morning that there would
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subpostmasters, people employed in branches and working
within the Post Office itself; is that right?
Correct, his title is the Assistant Secretary, Clerical
Cash Handling so all those issues which includes Crown
Post Office staff and administrative staff in
employment --
Which is why, in your evidence, you've made it clear
that, since, I think, around 2002, that's not been your
direct area of responsibility, it's been Mr Furey's; is
that correct?
March 2002, to be specific.
I'm grateful. Then turning to Mr Furey, are you aware
that he has given evidence before select committees in
relation to the CWU subpostmaster branch employee
membership?
lam.
Given evidence at least on two occasions that I can find
on a quick search, is that right, and been interviewed
generally in regards the Post Office and actions taken
by the management of the Post Office and is quoted often
in the press?
Yes.
Fairly obviously, Mr Furey would be someone who could
take any other matters further if there were any other
questions to be asked by the Inquiry?
94
have been prosecutions of Crown Office employees, you
said the CWU didn't know anything about these
prosecutions because you didn't provide legal funding
for criminal representation and you've said, as
I understand it, you don't think you could would or
should have known about these prosecutions at the time;
is that correct?
Yeah, they were not raised with us at national level.
We were not aware of them. I mean, in terms of me
saying I was aware of them, I was aware of them because
I was handed a piece of paper that details prosecutions.
That's how I'm aware of them. I think also, in some of
the questions I was given in preparing my statement was
a question about what Legal Services the union offers to
its members, and we don't offer Legal Services for
criminal prosecutions.
But, as a generality, and this is over time -- and
I think Sir Alan Bates first raising of the point is
around 2003/2004, and then everything gathers momentum
over the years -- there were these increasing voices
about problems with Horizon and prosecutions and this
was being reporting in the media, so my question is how
‘or why could the CWU, even if you yourself in your role,
not understand that issues with Horizon and
prosecutions, given they were being talked about in the
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The Post Office Horizon IT Inquiry 20 June 2024
1 context of subpostmasters, might be able well be
2 involving your members, could also be affecting them?
3 A. AsI-say, from March 2002 -- so the period you refer to,
4 2003/2004 -- from March 2002, if such incidents
5 occurred, they would go to Andy Furey and his department
6 to deal with.
7 Q. I mean, I understand it wasn't you personally. I'm
8 talking about the union as a whole, looking at its
9 members and issues that were coming into the public
10 domain, were in the public domain. How is it that the
1 union itself couldn't understand that those issues might
12 be affecting their own members, even if they weren't
13 hearing about actual criminal prosecutions of their own
14 members?
15 A. I mean, I think the point I've made and tried to make is
16 that the union is made up of a number of sections and
17 those elected to the top of the union have completely
18 different responsibilities. So the responsibilities for
19 dealing with any issues that would arise for our members
20 directly employed by Crown Offices would go to and rest
21 with what I would call the Postal Executive, which is --
22 under our rule book, which has the sole responsibility
23 for dealing with those issues. So it's not that the
24 union in total would be aware of all of those issues
25 because it's not why -- everyone employed by the union
97
1 Q. Just to --
2 SIRWYN WILLIAMS: Let me just ask you, Mr Kearns. Clearly,
3 I understand what you're telling me about the
4 demarcation of responsibility but would you expect that
5 the relevant heads of the section which deals with Post
6 Office employees and subpostmasters would have had
7 information about the numbers of people who were either
8 been prosecuted or dismissed on the strength of
9 information from Horizon?
10 A. If that information somehow was given to them, either by
11 the Post Office or by our reps or members.
12 SIRWYN WILLIAMS: Well, when you say "somehow", were there
13 any processes in place, so far as you know -- perhaps
14 you don't know -- which would allow information such as
15 I've just suggested to you to go up the ladder, from the
16 local reps, where no doubt it will have started, to the
17 senior people at the head of the relevant section?
18 A. If those were issues of concern to our representatives
19 at local level, area level, regional level, they would
20 be passed up through briefings and meetings that our
21 executive and national officers would have with those
22 representatives on a regular basis. So, if those were
23 issues of concern, then, yes, that would be the process
24 through the procedure --
25 SIRWYN WILLIAMS: Without wishing to put words in your
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is not employed to deal with everything that the union
faces.
So individuals and elected groups are responsible
for specific, different aspects of the work we
undertake. So we have a nationally elected executive
that deals with all issues relating to our members
employed within the postal industry, which includes the
Post Office, and we have a Lead Assistant Secretary who
deal with various businesses, in this case my
responsibility up until March 2002, and then Andy
Furey's responsibility.
Q. So would it be fair to say that the CWU, whether it was
you or whether it was Andy Furey, but the CWU is joining
the list of a rather long line of people and
organisations who were simply incurious about Horizon?
A. No, I don't think that's fair to say.
Q. Well, you've said that you didn't know anything about it
and that, despite media coverage, no one was prompted to
look at the issue for CWU members. So I'm suggesting to
you that that is indeed being incurious?
A. Well, I don't think I said I didn’t know anything about
it. I also, on a number of occasions, I've been quite
specific about where the responsibility lies in a large
trade union like ours to deal with these issues on
a day-to-day basis.
98
mouth, is this a fair summary: that you would expect
that, if local representatives were concerned about
issues such as prosecutions or dismissal on the strength
of Horizon, they would have ensured that it went up the
ladder to more senior people?
A. That's a fair summary, yes.
SIR WYN WILLIAMS: Fine. All right.
Sorry, Ms Watt.
MS WATT: Thank you, sir.
Just picking up and following on from that and
earlier questions, you were referring in some evidence
with Ms Hodge to the former NFSP members, such as Mark
Baker, coming over to the CWU because they were
dissatisfied with the NFSP. I think it's fair to say
it's a matter of public record on their part --
certainly, at least, Mark Baker's part -- that this was
largely to do with the satisfaction about the way in
which the issues on Horizon were being dealt with by the
NFSP.
Now, even if it was the case, for instance, that the
Post Office wouldn't talk to the CWU about
subpostmasters at the time -- this is around 2011 --
because they only wanted to deal with the NFSP on
subpostmasters, surely any concerns being brought to the
CWU by Mark Baker and others about Horizon would have
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been another way that your union was alerted to problems
with Horizon that could be affecting your own Crown
Office members, and you could have raised it with the
Post Office then; would you accept that?
That would be the -- as I said earlier, that would -- if
Mark Baker has represented those to Andy Furey, who was
dealing with those issues in 2011, that would have been
a way of raising them with the Post Office, yes.
But it just never bubbled up to the relevant surface of
the CWU; is that where we're --
Sorry, it didn't bubble up?
Yeah, it didn't reach/go through those layers that you
described to the Chair there of how matters come up
through to the top of the CWU and perhaps then go to the
Post Office?
Well, again, I'm -- I know people might get fed up with
me repeating this but, after 2002, it wasn't my
responsibility, so I'm not aware of which issues bubbled
up, as you describe it, through that rep structure to
Andy Furey, and what then transpired after that.
Did the Postal Executive or the CWU ever bring issues
about Horizon concerns and Crown Office employees to the
Executive Council of the CWU, that you can recall?
Not that I can recall.
I've just got a couple more questions. I think you were
104
We heard that.
-- members of the CWU. They were the Communication
Managers Association.
Yes, we heard that. We have also heard much evidence
about the aggressive bullying and intimidating tactics
used by Investigators and Auditors and I just wanted to
ask what you have to say about that behaviour and what
the Inquiry has heard about the way in which Auditors
and Investigators operated?
So I only saw a snippet of one of the Post Office
investigation branches giving evidence. I've had
experience of the Post Office Investigation Branch, as
it was then in my day job, when I was a local rep.
Having represented people who have been accused of
theft, I do find their methods to be aggressive, I do
find their methods to be almost -- well, natural justice
is innocence until proven guilty; my experience of
sitting down alongside our members, facing the Post
Office Investigation Branch, is there's a strong belief
in the Post Office Investigation Branch where people are
guilty and they're there to ensure that there are
consequences to that.
I don't find it -- generally, my experience in the
past -- it's a long time since I've had any dealings
with Post Office Investigation Branch -- is I found them
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just discussing there, towards the end of your evidence,
about self-employed subpostmasters and collective
bargaining. I think you've been discussing and you'd
agree that self-employed subpostmasters running small
businesses are quite a different beast to large-scale
groups of employees such as postal workers on collective
bargaining; would you agree with that?
Yeah, they are different groups.
One final question. When I asked you questions on the
last time you appeared, you agreed it was likely that
Post Office employees, such as Auditors and others, were
or could have been members of the CWU. I think you'd
agree that would likely also include Investigators, as
well; would that be right?
When you say Investigators, you mean --
Those who carried out an investigation function. People
who were formerly counter clerks and then investigated
shortfalls and discrepancies and --
The Audit Team, you mean?
Yes.
Yes, a number of those were -- yeah --
Yeah, members?
-- members -- certain members of the Audit Team were
members of the CWU. Managers of the Audit Team were
not --
102
to be aggressive, not always -- I wouldn't trust them.
So, to the extent that any of those were your members,
is it something that you could or should or would now
provide training to your members in how to conduct
themselves?
Training to our members?
Well, members who are conducting those kind of
functions --
Our reps?
Yeah.
We -- as I said earlier, we provide training for our
reps.
Sorry, not your reps. The members who are actually
conducting themselves in this way. Do you consider the
CWU has an obligation to perhaps remind its members of
how to conduct themselves when carrying out their
functions?
Sorry, members of the investigation branch were not
members of the CWU, members of the Audit Team were.
Audit Team, yes.
I'm talking about -- we're talking about two different
things.
Two different things?
We had the investigation branch who sit down and accuse
people of theft or wrong doing. The Audit Team -- so
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the Audit Team -- predominantly in Crown Offices,
individual stocks and the office balance is conducted on
a Wednesday evening. Predominantly, Audit Teams would
arrive before the opening of business on a Thursday
morning and do a full audit. So they would audit all
the individual stocks and the whole office balance to
check that the closing balance that the office and the
individuals declared on a Wednesday night was, in fact,
accurate.
The staff who carried that out were CWU members but
they were not the ones who would be interviewing
individual members of staff and accusing them of, for
example, theft. That was the Post Office Investigation
Branch. Two separate bodies within the Post Office.
Q. But those individuals might have been the ones out in
the field dealing with subpostmasters. That's what the
evidence has heard; would you accept that?
A. The Audit Team?
Q. Yes, members of the Audit Team.
A. Yes.
MS WATT: Thank you. Those are all my questions. Thanks.
SIR WYN WILLIAMS: Right, Ms Hodge where are we with this
document?
MS HODGE: Sir, I don't think there's any need to share it
in the end. I think the questions were posed in a more
105
Q. Thank you for attending the Inquiry to give evidence
today. You have produced a written witness statement,
could I ask you to turn that up, please. That's in
front of you. Excellent. It should have the date in
the top right of 16 May 2024.
A. Yes, it does.
Q. Thank you. For the record, that Unique Reference Number
is WITN00550100. Now, before I go to your signature,
could I ask you to turn to page 24, please,
paragraph 91. It doesn't need to be shown on screen
you, on the first line, refer to "Jo Swenson's" -- well,
spelt with an "E", I understand you wish to correct that
to "Swinson", spelt with an "I"?
A. Yes, please. Spelling mistake, and it's the first of
two paragraphs 91, which is a numerical mistake.
Q. Can ask you to turn to page 41, please.
A. Yes.
Q. You should see paragraph 157 and then below that
a statement of truth with your signature?
A. That's my signature. Thank you.
Q. Can I ask, are the facts in that statement true to the
best of your knowledge and belief?
A. They are.
Q. That will stand as your evidence in the Inquiry and it
will be published shortly on the website. I'm going to
107
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general way.
‘SIR WYN WILLIAMS: Fine.
MS HODGE: So that concludes the questions from the
recognised legal representatives and the witness may be
released.
SIR WYN WILLIAMS: Yes, thank you, Mr Kearns, for
reappearing at the Inquiry and answering further
questions. I'm grateful to you.
So, is it sensible to break for lunch now?
MS HODGE: Sir, I think so, yes.
SIR WYN WILLIAMS: So we'll resume at 1.40?
MS HODGE: Yes, thank you.
SIR WYN WILLIAMS: All right, fine.
(12.41 pm)
(The Short Adjournment)
(1.40 pm)
MR STEVENS: Good afternoon, sir, can you see and hear me?
SIR WYN WILLIAMS: I can indeed.
MR STEVENS: Thank you, we are going to hear from Kay
Linnell.
SIR WYN WILLIAMS: Yes.
DR KAY CATHERINE SHEILA HILARY LINNELL (sworn)
Questioned by MR STEVENS
MR STEVENS: Please could you state your full name?
A. Kay Catherine Sheila Hilary Linnell.
106
ask you some questions about it but, before I do,
I understand that you'd like to make a statement?
A. Yes, please. Thank you.
Before I start, I'd like to say this is a good
‘opportunity to pay tribute to those who have worked very
hard behind the scenes to help the SPMs to right the
miscarriage of justice that has been brought to light.
There are many unsung and unseen heroes and I have been
personally supported very strongly by Howe+Co in this
matter and, before that, by Freeths in the High Court
litigation, and by other firms, such as Hudgells.
I would like to pay my respect and thanks to them,
because a lot of what they've done is unpaid and
unnoticed. Their support continues.
One other person I'd like to nominate for a special
vote of thanks, so to speak, on behalf of the SPMs and
myself is Barbara Jeremiah, my business partner.
I slightly blame her for becoming involved in this,
because Barbara believed in Jo Hamilton's innocence and
would not believe me until we got involved. Jo is our
local subpostmistress, or was, and Barbara has worked
tirelessly providing support, guidance and encouragement
to many subpostmasters in the very many years we've been
involved.
Barbara has been involved in almost 20 years and has
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never once wavered from her steadfast belief against
impossible odds. Barbara has never refused a request
for help from any SPM and has always been mindful of the
damage inflicted on them and their families by the
malicious, incompetent, coercive, controlling behaviour
of the shape-shifting Post Office.
We will continue to give support to SPMs in every
way we can, through accountancy, taxation, counselling
and advice, and any SPM who needs advice should contact
us until the money wrongly extracted from them, and the
damages to compensate them, have been paid in full.
The new Post Office team appear to be no better
organised than the old one through recent events but
I will not mention that. Thank you.
We are not going to cover any recent events, we'll look
at matters in the Inquiry's terms of reference. I'm
going to start with your background, please.
You qualified as a chartered accountant in 1979?
Correct.
You now work as forensic accountant?
That's correct.
When did you first start to act as a forensic
accountant?
Possibly in the late '80s/early '90s.
From that point the late '80s/early '90s, did you work
109
Could I start with your initial interaction, then, with
subpostmasters and the subpostmasters' cause. Could we,
please, bring up the witness statement at page 2,
paragraph 5. If we could have paragraph 5 at the top.
You say:
"I became involved in the Post Office treatment of
its subpostmasters in 2009 because of my local
postmistress, Jo Hamilton.”
You then refer to your business partner, saying she
used to drop into Jo's shop in South Warnborough to buy
her lunch on the way to court:
"One day in 2005, she found Jo in tears because of
ever increasing unexplained shortfalls in her business
accounts."
You go on to describe some aspects of the criminal
trial.
Can I just clarify, were you first made aware of Jo
Hamilton's case in 2009?
No, earlier than that, and I did try and get involved in
2009 but my real first involvement with Sir Alan was in
2012.
Thank you. So is it fair to say that you were aware of
some facts of the issues, you were aware of
Ms Hamilton's case before -- well, before you became
involved with Sir Alan but it's only at that later stage
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for a firm or on a self-employed basis?
I began engagement with fraud when I was a partner in
a small firm of chartered accountants in Derby and,
having discovered fraud, I applied to and joined the
Inland Revenue and ultimately became the board of Inland
Revenue's Chief Investigating and Prosecuting Accountant
and Head of Accounting Profession, prosecuting several
well-known figures. I then left HMRC, as it became, and
I set up the Joint Insolvency Monitoring Unit to monitor
insolvency practitioners.
I've also worked in the industry for Forte Plc as
Head of UK Taxation and then went back into the
profession with a small London firm of accountants and
I was then headhunted by Smith & Williamson to set up
a Southampton branch as a forensic accountant and
latterly by BDO. In about 2010, I set up my own
practice.
So when you were first engaged in or involved in matters
relating to subpostmasters, for whom were you working at
that stage.
I was working for myself. It was about 2012.
I think you mentioned BDO, you were employed by BDO?
Yes, I was the Forensic Director in Southampton.
What was the full name of BDO, sorry?
I think, at that stage, it was BDO LLP, I forget.
110
in 2012 when you became involved.
Yes. You could almost say I got my hands dirty from
2012 onwards but I was well aware of it much earlier
than that.
That can come down. Thank you.
You go on to say that your business partner
suggested that you spoke to Jo Hamilton in June 2012.
Yes, that's right.
At that point, I think, Ms Hamilton suggested that you
spoke to Sir Alan?
That's correct.
Now, had you heard of Sir Alan before that, before you
spoke to him?
Yes, indeed. Mrs Hamilton told me all about him,
regularly.
Can you recall your initial meeting with him?
I met Sir Alan outside James Arbuthnot's office in
a first meeting which we were going to have with James
Arbuthnot, and Ron Warmington and lan Henderson of
Second Sight.
So I'm going to come to that meeting shortly but that's,
effectively, the first -
That was my first physical meeting. I had had a couple
of telephone calls with him.
I just want to ask a few points about representation
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generally, starting with the JFSA. At paragraph 9 of
your statement, you say that JFSA is an unincorporated
affiliation with no constitution, rules or hierarchy,
but simply united by a common problem, which is to get
back the money wrongly taken by Post Office and attempt
to recover losses and damages caused by the Post Office
operation of the Horizon computer and support system in
the subpostmaster Post Office Network.
You say no hierarchy; was Sir Alan the chairman of
the JFSA?
In one way. He was effectively the person driving
a campaign and the SPMs that I met preferred that he led
the way for them. I don't think there's an officially
recognised hierarchy or structure where there's chairman
or secretary or treasurer, or anything like that.
How was decision making on behalf of the JFSA as
a whole, how did that decision making happen?
It happened at group meetings by show of hands.
When you first met Sir Alan in 2012, can you recall
roughly how many subpostmasters or former subpostmasters
formed part of the JFSA?
I don't know that information.
Do you know how the JFSA was funded at that time?
My understanding is it had no funding.
At that time, had you had any contact with the NFSP?
113
Prior to that meeting, had you had any experience or
dealing with either Ron Warmington or lan Henderson?
None whatsoever. I looked them up before meeting them
but I wasn't certain that they weren't people put up to
do a whitewash burial job by the Post Office.
So we can actually bring up your witness statement,
please, page 4. There you say:
"I was extremely suspicious of Second Sight, as they
had been nominated by [Post Office] as independent
forensic accountants, and I was concerned that their
access to documents and review of [Post Office's]
Horizon system might be a whitewash. I challenged them
at our meeting in 2012 but was satisfied with their
responses.”
Can I ask your recollection of how you challenged
them at that meeting?
I recall I asked them various questions about their
background and approach to what ended up being the spot
reviews of the cases.
Do you recall what they said to satisfy you?
Not precisely but I wanted to know what documents they
were going to look at, what level they were going to
look at in the IT support and whether they were going to
meet the complainants.
You said in your evidence then what ended up being the
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None whatsoever.
Let's go, then, to the meeting in July 2012, and I think
you say that that was with Sir Alan, Ron Warmington, lan
Henderson and Lord Arbuthnot?
Correct.
Before that meeting, what had you been told about the
purpose of it -- sorry, the purpose of the meeting?
I was told the purpose of the meeting was to consider
a mediation proposal put forward by the Post Office.
So did you say mediation proposal?
A mediation proposal put forward by the Post Office to
James Arbuthnot which he wanted JFSA to sign up to, to
try to resolve the -- I think it was 47 MP complaints
about SPMs.
Pausing there, there was obviously the Mediation Scheme,
which we'll come to after the Interim Report in 2013.
This in July 2012, prior to the Second Sight Interim
Report, was this still described to you as a mediation
proposal?
My recollection, which may not be that accurate at this
remove of time, but my recollection was there was
looking to be a mechanism to resolve the disputes,
effectively raised by the 47 SPMs complainants thorough
their MPs, and they wanted an initial external
independent forensic firm of accountants to look at it.
114
spot reviews. From your recollection, was the concept
of spot reviews discussed at that meeting?
Not to my recollection, no.
Do you recall, broadly, what the proposal from Second
Sight was?
I think the initial proposal was to pick several of the
47 cases and do an in-depth review of each of them to
try to find out what had gone wrong and whether the
complainant had any substance in what they were saying.
So, at that stage, a focus looking to specific cases
raised by MPs?
Yes.
Lord Arbuthnot produced a witness statement and gave
oral evidence to this Inquiry, the witness statement was
dated 12 March, and he recalls this meeting taking place
on 12 July 2012, and his evidence was that you and Alan
were satisfied and agreed to the appointment of Second
Sight at that meeting, with the caveat that you would be
able to double check that Second Sight were acting
independently; would you agree with that?
Yes, that's correct.
At that point, how did you envisage checking on Second
Sight's independence?
At that stage, I thought I would be acting as
an independent forensic accountant for JFSA and,
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The Post Office Horizon IT Inquiry
I believe at the time, I prepared a letter of engagement
and it was agreed I'd be paid a small fee for checking
their work and going round with them, just to see what
they were doing.
Let's look at that letter of engagement now. It's
exhibited to your witness statement at WITN00550101. Is
this the letter to which you were referring?
Yes, it is.
It's dated 6 July 2012, so shortly after the meeting
with Lord Arbuthnot and Second Sight?
16 July 2012.
16th, sorry, did I say the 6th? I do apologise. 16th.
If we could go down, please. We see "Scope of Our
Work", it says, well, firstly a sentence about acting as
expert accountant and --
Yes.
- refers to Second Sight. The second sentence says:
"The initial investigation would be in two parts,
the first being into current errors, the second to
investigate the historic cases which have been raised by
MPs and a number of cases you will recommend."
That's correct.
So is that broadly what Second Sight were suggesting at
this time, or at least your understanding of it, a look
at, in the first tranche, current cases and then more
117
before then?
I don't think I'd met Alwen Lyons before then and
I think I had seen rather than spoken to Paula Vennells.
There was a briefing day in the September of that year
when I definitely met them but I don't recall meeting
them before then.
The Interim Report is produced on 8 July 2013.
Yes.
Was this meeting before or after the Interim Report?
Unfortunately, I can't find the date but I believe it
was before the Interim Report was released.
But you're confident that it was 2013 and not 2012?
Yes.
We'll come back to that meeting, then, in due course.
Can I please ask for us to look at POLO0091028. If we
could go down, please, thank you. So we have an email
from Ronald Warmington to Mike Wood MP. You're not in
copy to this, so you wouldn't have seen it at the time,
presumably?
No.
Have you seen it for the first time when preparing for
the Inquiry?
That's correct, yes.
The second paragraph of that email says:
"The idea of carrying out a deep dive into Horizon
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historic ones in a second tranche?
A. That was my understanding.
Q. Atthis stage, was there any discussion, from your
recollection, of systemic errors or looking for systemic
errors?
A. No, not at all.
Q. That document can come down. Thank you.
If we could bring up the witness statement, please,
page 4, paragraph 15.
SIR WYN WILLIAMS: Before that comes up, Mr Stevens, can you
remind me to whom that letter was addressed? I saw that
it was on Ms Linnell's notepaper but it's "Dear sirs";
is there a --
MR STEVENS: Yes, the addressee is Justice for
Subpostmasters Alliance but, actually, sir, you are
quite right, the question I should ask, if it's
an unincorporated association, was to whom was that
letter sent?
A. It was sent to Alan Bates.
Q. There we are on the witness statement. So paragraph 15,
you refer to attending a meeting at Post Office with
Alwen Lyons and Paula Vennells. You say "I think in
around June or July 2013".
A. That's correct.
Q. Had you met with Alwen Lyons and/or Paula Vennells
118
is on hold until we have completed the Case Reviews.
Few of us think that sort of review will work well.
Some of us think it would probably turn out to be
a colossal and expensive disappointment (for those
seeking evidence of anomalies in Horizon). Those
pressing for such a Review now seem happy to wait to see
what the Case Reviews throw up."
Do you have any recollection, between the meeting
you had with Second Sight on 12 July and this meeting on
18 July, of any discussion about a deep dive review or
specific case reviews?
A. No, we only had the one meeting to start the process
off. I think it's referring to our first meeting.
Q. Atthis stage, you were happy with the case reviews
approach?
A. I think if you didn't approach it through case reviews,
you wouldn't know what anomalies you would be looking
for. You'd be checking 100 per cent of the system at
vast cost and it would take an enormous amount of time,
so I do agree with starting with the problems and then
working back to see what went wrong.
Q. Thank you, that document can come down.
Please can we bring up your witness statement at
page 11, paragraph 47. Thank you. Now, this is
something I've already touched on. You say here about
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the distinction between systems error and systemic
error. You say:
“It's worth noticing the difference between
a ‘systems error’, (that is an IT coding error that will
replicate an error of the entry of the same data and
processing of the transactions in the IT system) and
a systemic error’), that is one caused by incorrect
implementation and management of the subpostmaster
network using the Horizon computer accountancy system)."
Were those concepts, as you describe them there,
discussed with Second Sight in 2012?
I think the first time the words "systemic error" was
used was in a letter from Sir Alan to, I think, James
Arbuthnot, and the difference between Ron and lan's
definition of systemic errors and ours is theirs was
restricted solely to the computer system, whereas ours
saw it to be a complete system of administration,
training, implementation and management, using the
computer Horizon.
Do I take it from that, then, that there wasn't
a discussion with Horizon on the difference between
“systems error" and "systemic error” in 2012?
Not that I recall.
Could we look, please, at the Interim Report. It's
POL00099063. If we could go to page 22, please, so this
121
The JFSA were an alliance of people who had similar
problems with the Horizon system, who'd suffered
personal damage but had no information whatsoever. If
it could be taken to the next stage of taking it to the
court, the SPMs, JFSA, required evidence, and there was
no way of getting evidence from the Post Office, except
through MP complaints. So there was no other course of
action they could have taken at that stage, in my
personal opinion.
Just to be clear, that was your opinion at the time?
It was my opinion at the time and remains so.
In 2011, the Inquiry has seen letters of claim from
Shoosmiths starting or intimating actions and the
Inquiry has heard evidence of, in 2005, Post Office
considering that a group action may be on the horizon at
some stage. Why was that not a viable option for the
JFSA at the time? You've mentioned the evidential
concerns; were there any others?
There are two problems that JFSA faced: one is no
evidence or information; and the second is no funding.
So to get funding, you'd have to put a case together to
take to a litigation funder and, without any information
being extracted from the Post Office, it would be
impossible. It had already been tried and kept being
tried to get Freedom of Information requests, and the
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is an appendix to the Interim Report which sets out, it
says, the remit of the inquiry. It says:
"The remit of the Inquiry will be to consider and to
advise on whether there are any systemic issues and/or
concerns with the 'Horizon' system, including training
and support processes, giving evidence and reasons for
the conclusions reached."
Do you recall the first time you heard the inquiry
expressed in those terms was?
I think it was on the publishing of this report which
I didn't see in draft before it was published. I just
saw the final version.
Keeping at the time when the Second Sight review was
commissioned, so July 2012, what at that time was your
view of the Post Office's motivations for commissioning
that review?
Personal opinion is that they wanted to settle the MPs’
complaints and make it quiet.
What was that based on?
It was based on the attitude of the Post Office in
falling over themselves to provide information about
those particular cases and nothing else.
In your view at the time, what, if any, other options
were open to the JFSA to push forward with the
subpostmasters' concerns?
122
‘one I am familiar with is Jo Hamilton's, which came
about an inch thick with nearly every page redacted but
for one or two words. It was a document that must have
cost a lot of ink but it couldn't be used for litigation
because there was no information worth using.
So is it fair to say that the access to information
about the cases and the system, was absolutely
imperative to pursuing the subpostmasters' campaign?
It was critical because, without such information, it
would not have been possible to convince any lawyer
there was a case to be answered.
At this stage, to what extent had the JFSA sought out
assistance from other bodies, such as the NFSP?
I'm not aware of that, I'm afraid.
I'd like to now, look, at the Second Sight investigation
itself. Please could we bring up POL00097402. This is
an email on 25 January 2013 from lan Henderson to Janet
Walker. Now, Janet Walker worked for Lord Arbuthnot,
then James Arbuthnot MP.
That's correct.
It says:
"Ron and I have discussed this.
“We both think it's an excellent idea for Alan and
Kay to be invited [referring to a meeting]. We are now
working quite closely with them and have almost daily
124
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contact."
Would you agree with that about the state of your
working relationship at January 2013?
Yes, I was going out to various meetings with SPMs with
Ron, and Alan and lan were also talking quite a lot so,
yes, I would agree with that.
At that stage did either Mr Henderson or Mr Warmington
communicate to you any of their views on what they'd
heard about the Horizon IT System?
As you've heard from them on Tuesday, you'll know that
they're not backward at telling their views about
things, so yes, they had.
What's your recollection of what they said?
My recollection was they found sufficient errors,
defects and problems that the complaints by the
subpostmasters through their MPs were generally being
found to be based on errors in the Horizon system.
At that stage, how satisfied were you with the work that
they had and were carrying out?
I was very satisfied that they were trying to do their
best to get information from Post Office to answer the
question we'd all been asking: why had these differences
occurred?
At that stage, January 2013, had either Mr Warmington or
Mr Henderson mentioned concern that there may have been
125
"Now systemic failures on the other hand are
different, and in my letter to James Arbuthnot
Now, pausing there, was that the letter to which you
referred earlier in your evidence as the first time you
recollect this issue arising?
Yes, that's my recollection.
He says:
"... where I first use the phrase, I have qualified
its context.
"This occurs in the first sentence of paragraph 2,
where I say ‘the weight that it adds to the systemic
failures with Post Office and the Horizon system’. It
is these systemic failures with Post Office and their
Horizon system that are the proven facts.”
Now, do you agree with that definition of system
errors and systemic failures.
Yes, I do.
Did you have any further discussion on that distinction
with any representatives of Second Sight following this
email?
No, I left this to Alan because he had some experience
in point of sales and software and, frankly, I'm too
old. I use pen and ink, really.
Before we move to look at the Interim Report itself, to
what extent were you aware of Fujitsu's involvement
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miscarriages of justice?
No, we didn't discuss criminal prosecutions or
miscarriage of justice. We were simply looking to try
to find out why the errors had occurred.
Please could we bring up POL00098315. If we can move
down the page, please. Thank you. We have an email
from Sir Alan to Ron Warmington on 12 May 2013.
I believe that data protection has covered up the email
address but I believe that's you in copy; is that right?
Yes, I was copied.
It's responding to quite a lengthy email from
Mr Warmington, which I don't need to take you to. As
you may expect, it's the "System Errors vs Systemic
Failures" that I want to deal with. It says:
"I think there may be, at times, confusion by others
‘over the referring of these two points. At its most
basic, system errors would to me be something like
an extra loop in the software code causing the false
result of a transaction, but as you rightly say, that
would affect every one of the 11,500 offices. Then at
the other end of the scale it might be something far
more complex resulting from a network communication
failure and an incomplete recovery of a transaction at
a particular office ..."
It goes on, and Sir Alan goes on to say:
126
during the -- sorry, I'll rephrase that.
To what extent were you aware of Fujitsu being
consulted by Post Office during the Second Sight
investigation?
I assumed, at this time, that Fujitsu held some of the
electronic evidence and data and they would have to be
asked by Post Office to produce it. I'm not aware of
any consultations.
So is it fair to say that was an assumption you made
because they operated the computer system but you had no
direct knowledge of Post Office contacting Fujitsu?
Not at that time, no.
At that time, had you heard of Gareth Jenkins?
No, I had not.
I said it would be before I move to the Interim Report
but, of course, I put off the question I was going to
ask earlier about a meeting with Paula Vennells and
Alwen Lyons. Could we please bring up your statement at
page 4, paragraph 15. Thank you.
So you refer to, again, this meeting in either June
or July 2013 and my understanding is that this was
before the Interim Report came out. That was your
evidence earlier.
Yes, that's correct, and I believe it was requested by
Post Office. We'd written and asked for a meeting
128
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I think on around the beginning of June 2013, and the
date was suggested by, I think, Paula Vennells.
Well, let's see if we're thinking about the same email.
Could we bring up POL00098418, please, and if we could
go to the bottom of the page, please. This is an email
from Sir Alan on 21 May 2013, and the last paragraph on
the page says:
"Would it be possible for Kay Linnell and I to meet
with you?"
Is that the email you were referring to?
Yes, and I think there's some subsequent emails where
she comes back and I think a date of 5 June was
suggested but that wasn't convenient. Yes, it's down
there at the bottom of the page.
So looking at this email, Sir Alan refers to you and who
you are, as a reminder. If we go down, he says that:
"The main purpose of the meeting is to ensure that
you have been receiving the full details of what has
been occurring with the Second Sight investigation.
Bearing in mind what has been discovered so far, I for
one am surprised that we haven't yet met to discuss the
implications."
Now, pausing there, at that stage, what had been
discovered so far that prompted an email from Sir Alan?
I should ask, sorry, did you and Sir Alan discuss this
129
spot cases.
Just pausing there, when you say "errors", can you
remember, putting yourself back to the time, what those
errors were which led you to believe this?
I can't remember which names the bugs had but --
Is it bugs that you're referring to?
It's bugs and everyone has called them bugs but they're
actually errors in the computer software programming
that, when you put in a certain series of transactions,
always cause a difference. And as the Post Office read
the contract, that it was always the subpostmaster's
fault or liability, whatever the circumstances, it was
clear to me that money had been taken wrongly, and also,
as in Jo's case, they had relied on the computer figures
to mount a prosecution, and I therefore felt at that
stage prosecutions might or probably were unsafe.
Was that, the prosecutions being unsafe --
Let me rephrase it. Who did you discuss your
concern that prosecutions may have been unsafe, other
than Sir Alan and, by way of this email, Paula Vennells?
Nobody, because it's a suspicion, not evidence and, as
forensic accountant, I have prosecuted people while
I was at HMRC/Inland Revenue, and I am aware of the
standard beyond reasonable doubt and the evidence
required to show criminal intent, none of which appeared
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before sending it?
Yes, we regularly discussed things and swapped drafts
and, as I recall, what had been discovered is there had
been substantial and important errors in the operation
of the computer, which had caused differences in
shortfalls in SPMs' accounts, and it was, at this stage,
we had, from the spot reviews, evidence that Horizon did
not operate perfectly and left differences.
It goes on to say, the final sentence of the paragraph:
"I have little doubt that it is now feasible to show
that many of the prosecutions that [Post Office] have
pressed home should never have taken place, and
I believe this is a view shared by Kay.”
Was that a view shared by you?
Very much so.
Again, so we're clear here, what was it at that stage
that led you to believe that it was feasible to show
that many prosecutions should not have taken place?
Bearing in mind I had personal knowledge of Jo
Hamilton's case and her case was taken to the doors of
the trial before a plea bargain, without any evidence
being given to Jo to check, as to how and why the errors
arose, when Second Sight started their spot reviews,
they also found that there were errors which hadn't been
disclosed to people who were prosecuted as part of the
130
to be present in Jo's case. But I was not aware of
sufficient evidence to take that anywhere else. It was
a suspicion.
The last question I'd like to ask on this email is the
use of the words:
"The main purpose of the meeting is to ensure that
you have been receiving the full details of what has
been occurring ...”
Do you know why Sir Alan used that turn of phrase?
We actually discussed this. It's a question, we
thought, of the Post Office being a former Government
organisation which had silos where, for example, the
Legal Department appeared to be completely separate from
the Operation and Management Department of the Post
Office Network and there appeared to be management
layers between them and the Board and the CEO. So Alan
and I wanted to make sure the people at the top knew
exactly what had been found.
If we then can go back to the meeting, which we had in
your witness statement, so if we could bring back page 4
of the witness statement, please, paragraph 15, it says
that:
"We asked to meet Paula Vennells as CEO to try to
get a reality check on the [Post Office] opposition to
recognising the plight that [Post Office] had caused
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[subpostmasters], to admit Horizon was not 100 per cent
perfect (as no computer system can be) and to get money
paid back to [subpostmasters as soon as possible].
You go on to say:
"At that stage, JFSA did not want a full public
exposure just proper care for SPMs in giving money back
wrongly taken and paying for losses and damages. We
were asking for substantial amounts but nothing compared
to their own bonuses published in great deal in the
[Post Office Limited] annual accounts."
There you don't refer to prosecutions. Did you not
discuss that with Paula Vennells at this meeting?
As far as I can recall, we discussed everything, and we
were slightly worried that they'd used no evidence at
all to mount criminal prosecutions without any idea of
whether there was a guilty mindset or not. But I didn't
refer to it there because I am not certain. I don't
have any notes of that meeting. I can't even find the
date of it, unfortunately.
From your recollection, what do you think you said to
Paula Vennells and Alwen Lyons about your concerns as to
criminal prosecutions?
I believe Sir Alan and I have always been concerned
about giving money back to subpostmasters who were in
dire financial straits, having had money taken away from
133
Not before it was published.
What did you understand the purpose of Second Sight
releasing the Interim Report to be and, just to be
clear, my question is before it was released?
Before it was released, I believe there was some
pressure, particularly from -- James Arbuthnot was my
MP, as well as Jo's, and I think there was some pressure
from the MP committee, led by James, to actually give
some sort of Interim Report as to what the Second Sight
investigation was finding. So, I believe they selected
a few cases, four or five, and produced, effectively,
a distilled analysis of them. Before they produced it,
I expected it a full in-depth analysis of them.
That purpose, so producing an interim distilled analysis
of four or a select number of the spot reviews, did you
think that was a -- what did you think of that as
an idea?
Not a bad idea because it might start the ball rolling
towards giving the money back, I thought, and as long as
it's only a stepping stone in their enquiries, it
wouldn't make any difference.
Was there any discussion, before the Interim Report was
published, as to what would happen to Second Sight's
investigation after it was published?
No, I don't believe there was a discussion, I think
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them, and the thought about prosecutions was something
we suspected but couldn't prove or worry about. As in
2013, so many years ago, we wanted the money given back
to people it had been taken off, and that still is
a primary concern. And, you know, I'm sorry to expand
on the answer but I recall that all we got from Paula
Vennells was her main purpose was to learn from the past
and build the brand and make it profitable, which is not
an answer to our questions at all.
Do you recall there being any discussion on, or proposal
put forward, by either Alwen Lyons or Paula Vennells
that went to concerns about either criminal prosecutions
or giving money back to subpostmasters as you requested?
No. None.
Thank you. That document can come down. Thank you.
Please could we -- actually, before we go to that,
the Interim Report, we know, is published on 8 July
2013. What, if any, involvement, did you have with
looking at or discussing drafts of the Interim Report
with Second Sight?
None whatsoever.
Did you have any discussion with representatives of
Second Sight more generally about the content of the --
not specific drafting but the content, the general
content, of the Interim Report before it was published?
134
there was an understanding that the Second Sight
investigation would continue until they'd finished the
subpostmasters' complaint cases, the ones from the MPs.
Sorry, I -
I beg your pardon.
I overcut you there. I was about to ask, you said
“until they'd finished the subpostmasters' complaint
cases", and then you say the ones from the MPs, as in
the cases referred by the MPs?
And I think they were augmented in some way by a few
added by Post Office as sample cases, from memory.
You referred to an understanding that Second Sight's
work would continue. When you say that understanding,
was that just your understanding or one shared by
others?
The original engagement of Second Sight was by the MPs,
countersigned by JFSA and Post Office were used by the
MPs as a vehicle to implement the contract and pay,
because the MPs did not have a budget. So my
understanding was the MPs were instructing Second Sight,
nobody else, and the MPs wanted an answer to their
queries.
Could we look now at the Interim Report, please. It's
POL00099063. If we could look at page 8. The
preliminary conclusions are very well known to the
136
(34) Pages 133 - 136
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Inquiry. We see there (a) "no evidence of system wide
(systemic) problems" and (b) referring to two incidents
of where “defects or 'bugs' in the Horizon system", and
it goes on to refer to two of the bugs that the Inquiry
has heard a lot about.
What do you think of, in particular, these two
preliminary conclusions at the time?
I was particularly disappointed by conclusion (a)
because I didn't think there was sufficient data for
Second Sight to reach that conclusion. I don't think
they should have opined at all on whether there were
systemic problems at that stage. I also found in my own
research, following them round, that they had found
problems across the system where one error would affect
many, many branches, and I was therefore disappointed.
Just taking that in stages. Firstly, you say
disappointed because you didn't think they had the
evidence to say that, the fact they've said, "We have so
far found", so saying, "we haven't found evidence of
a systemic problem", did that not reassure you?
Quite the opposite. It made me think that Post Office
had interfered with the report.
When you said that you felt you had seen evidence of
"system-wide (systemic) problems", do you recall, at the
time, what you thought those were?
137
remotely, prior to the issuing of the Interim Report?
Yes.
What were you told?
I was told it was possible to enter the system through
a backdoor and it was a systemic error.
Who told you that?
Well, believe it or not, I think it was Ron Warmington,
but I've certainly talked to Sir Alan about it and we
knew about the Bracknell and other parts of Fujitsu who
regularly made corrections to the live system.
So you spoke about it with Sir Alan and I think you said
Ron Warmington discussed it with you. At this stage, so
when the Interim Report was released, were you aware of
Gareth Jenkins as a person?
No, I'm still not aware of Gareth Jenkins at this stage.
You say in your statement -- we don't need to pull it
up -- that you thought the Interim Report could have
been much stronger with regard to the Post Office
Limited field of operation and systemic working errors,
and, in your oral evidence you've expressed frustration
about the report.
Did you discuss your feelings on the report with
either Mr Henderson or Mr Warmington at the time?
After the report was issued, yes.
What did you say to them?
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No, I can't recall. There was something to do with ATMs
but I don't know whether that -- and it was the Bank of
Ireland, but I'm sorry, my memory of that is very hazy.
I just remember being quite cross about this because
they shouldn't have put anything in without the evidence
to support it and, from what I'd seen of Ron Warmington
and lan Henderson, they were very thorough, so I don't
believe, on their own, they would have written that.
Just to be clear, you weren't involved in the drafting
process, so you don't have any direct knowledge of how
this report was drafted?
None whatsoever.
Can we turn to page 12, please. This is spot review 5,
which concerns the allegation that had been made by
Michael Rudkin, regarding what's now referred to in
shorthand as remote access. The Inquiry has seen this
a lot, I don't need to go through it in full. If we
could just look at the bottom of page 13, please,
saying:
"We are left with a conflict of evidence on this
issue and our enquiries are continuing, particularly in
light of the new information confirming that the meeting
‘on 19 August 2008 did in fact occur.”
Were you told anything about Fujitsu's ability to
access data or insert data into branch accounts
138
I was disappointed.
What was their response?
I don't exactly recall what they said, except that, you
know, they'd had to discuss the draft with Post Office
and clear it, which I still don't understand.
I want to now look, then, at what happens next in the
chronology. It's the Mediation Scheme. Were you
involved in any discussions with Post Office
representatives following the publication of the Interim
Report about what to do next, following its findings?
Yes, there were extensive discussions generally led
through James Arbuthnot and Alan Bates about how we
should go forward from the Interim Report because,
although I thought they'd carry on finishing the job, it
was clear they wanted to take a different line.
When you say it was clear they wanted to take
a different line, how did you come to learn of that?
When you say “they” do you mean Post Office?
Post Office, I'm sorry, I should say. Post Office
wanted to be seen, in my view, as reacting to the
Interim Report in a positive way.
Were you involved in the initial discussions as to the
establishment of what became the Mediation Scheme?
Yes, I was.
Who else was involved in those discussions?
140
(35) Pages 137 - 140
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Sir Alan Bates, Ron Warmington, Susan Crichton, lan
Henderson, James Arbuthnot; possibly some others.
So, on behalf on the Post Office, it was Susan Crichton?
Susan Crichton led the discussions.
And can you recall, in terms of dates, when those
discussions took place?
They were some time around August 2013.
What was your view of Susan Crichton's approach to the
issues in the Mediation Scheme?
She struck me as somebody who was trying to get to the
bottom of what had gone on and to put forward some
redress or remediation for the people who'd been caught
up in it.
The Working Group that oversaw the Mediation Scheme, do
you remember when that first became suggested as
an idea?
The Working Group was merely a part of the Mediation
Scheme, and I think it was called the Initial Complaints
and Interim Mediation Scheme, as it's supposed to be
a model where we tested whether complainants could get
redress, and I believe it started with a training
session in September 2013, which I attended with Julian
Wilson from the JFSA.
If we look at that now, if you can bring up your witness
statement, please, page 18, paragraph 66. So, as you
141
please -- actually, no, sorry, if we start on page 1.,
usually a good place to start. I think this is
exhibited to your witness statement as a presentation
given at this training day; is that correct?
That's correct. This is a copy of the slide deck.
Can we turn to page 11, please. So we see Bond
Dickinson at the top. Can we infer from that that it
would be Andy Parsons giving this part of the
presentation?
This is Andy Parsons' presentation.
We have "Possible remedies", I want to ask about two.
Can you recall what was said about compensation?
My recollection of this day is quite muddled, to be
honest. I have a feeling he said, if there is something
that's been done wrong, clearly the Post Office will
compensate you, or some wording like that. My notes are
also pretty fuzzy because I'm talking to people and
presenting as well. But I think it basically was that
they would pay compensation to people who had suffered,
if there was an error proved by Post Office.
I appreciate you say your memory is -- I think the words
were "quite muddled" but do you recall what was said
about “Support a criminal appeal"?
Again, if the evidence -- I think my recollection is
that Andy Parsons said, if there was a proven
143
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rightly say, it was attended by Julian Wilson and you
say:
"The training day was also attended by Second Sight,
and presentations were given by Susan Crichton, Angela
van den Bogerd and Andy Parsons."
Is this the first time you'd met Andy Parsons or had
you met him before then?
No, I think this was my first meeting with him.
Do you have any recollection of his approach to the
training session itself?
The training session was done in such a way to explain
the background to the way Post Office operated and its
structure and Andy Parsons gave some legal overview.
I forget the details precisely.
Angela van den Bogerd, was that your first dealing with
her or had you met her before?
No, this was my first dealing with her.
Again, the same question. What was her -- what was your
view of her -- sorry, I'll rephrase that.
What was your view of her approach to the training
day and the Mediation Scheme at that point?
Her approach was to tell us sufficient to understand how
the Network was managed by Post Office and the duties of
the subpostmaster.
Please can we look at WITN00550103, and page 11,
142
miscarriage of justice, they would support a criminal
appeal. Just as an aside, if I may, you would have
thought, if they'd known about Gareth Jenkins at this
stage, they would have actually told us in the briefing.
Can we look, please, at POL00022120. This is a document
titled "Overview of the Initial Complaint Review and
Mediation Scheme". Was this a document to which the
JFSA had input?
Yes, we had a lot of input.
Was it an agreed document?
In the end, yes. It was compromised in various parts
but it was generally agreed.
Throughout my questions today, I'll come back to this,
and there may be points where I ask you where there's
been compromise but I'm not going to ask you for the
whole of the drafting by committee. Could I look,
please, at page 5. We have “Frequently Asked Questions
about the Scheme", and at the bottom, "What if my case
involves a completed criminal prosecution or
conviction?" It says:
"You may put your case through the Scheme even if
you have already receive a police caution or have been
subject to a criminal prosecution or conviction.
"However, Post Office does not have the power to
reverse or overturn any criminal conviction -- only the
144
(36) Pages 141 - 144
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criminal courts have this power.
"If at any stage during the scheme, new information
comes to light that might reasonably be considered
capable of undermining the case for a prosecution or
assisting for the defence, Post Office has a duty to
notify you and your defence lawyers. You may then
choose whether to use that new information to appeal
your conviction or sentence."
You may have already answered my question. At this
stage were you aware of the advice of Simon Clarke,
dated 15 July 2013, which raised allegations that Gareth
Jenkins had breached his expert duties to the court?
A. I believe the Clarke Advice was only disclosed in March
2021, after the criminal appeal trials.
Q. At this time, were you aware of the substance of the
allegations, namely that Gareth Jenkins had produced
expert evidence in breach of his duties to the court?
A. No, I wasn't aware.
Q. Atthis stage, were you aware that Post Office was
conducting an internal investigation into past
convictions?
A. No, I wasn't aware.
MR STEVENS: Sir, that might be a good time to stop for
an afternoon break.
SIR WYN WILLIAMS: Yes, that's fine. What time shall we
145
as to the appropriateness of Belinda Crowe's appointment
as a person to provide secretarial support to the
Working Group.
A. I didn't know anything about Belinda Crowe, except she
was a Post Office employee. I'm not sure that anybody
else was able to afford the services of a secretariat to
manage the case flows and assist with the disclosure
exercise of Post Office, which was headed up by Angela
van den Bogerd's Investigation Team, and I just accepted
her as someone nominated to do a job. But what I wasn't
aware of, which is what those two paragraphs indicate,
that she was senior in Post Office and not just
a secretary or somebody, and that she seemed to be
chairing somebody -- well, some group of people who were
working against the disclosure and settlement of the
cases. It's disingenuous in terms of a mediation
scheme.
Q. With hindsight, with that knowledge now, do you have any
concerns as to whether or not it affected the Mediation
Scheme or disclosure within it?
A. I believe it affected the recording of the minutes and
the progress of cases through mediation, but nothing
else.
Q. You say recording of the minutes, is that because
Belinda Crowe took the minutes?
147
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resume?
MR STEVENS: Can we say 3.00, sir.
SIR WYN WILLIAMS: Yes, by all means.
MR STEVENS: § Thank you.
(2.47 pm)
(A short break)
(3.00 pm)
MR STEVENS: Sir, can you see and hear me?
SIR WYN WILLIAMS: Yes, I can. Thank you.
MR STEVENS: Thank you. I want to carry on with a few
points on the Mediation Scheme now. Can we please have
your witness statement on the screen, page 20. Go to
the page before, please. Thank you. At paragraph 76,
you refer to Belinda Crowe as being the appointed
administrator and acted as secretary to the Working
Group.
A. Correct.
Q. You say at 77:
"I was not aware at that time that [Post Office] had
a separate committee chaired by Belinda Crowe called
Project Sparrow which was only revealed after the High
Court trials. The fact that JFSA did not know about
this is typical of [Post Office Limited's] behind the
scenes obsession with secrecy and control."
At the time, at the time, did you have any concerns
146
A. Belinda Crowe was responsible for the minutes the case
administration and producing bundles of documents for
the cases we looked at, at an early stage, to make sure
the system was working properly.
Q._ I'm going to come back to the minutes later. So I won't
deal with it now. Could we look, please, at page 15 of
your statement. At paragraph 55, you referred to
minutes for the 30 January 2014 Working Group. You say:
"[Post Office] sought to narrow the terms of
reference and JFSA objected, Chris Aujard went away to
review the terms for [Post Office] and report back. He
did not report to any other Working Group meeting, and
to my recollection simply imposed the [Post Office] new
terms unilaterally to restrict the authority of the
Working Group that effectively further slowed up the
completion of cases and passing cases to mediation."
Can we bring up those minutes, please. That's
POL00026641. We see it's 30 January 2014.
A. Yes.
Q._ If we can just scroll down slightly, please. Thank you.
We see there's a discussion about the terms of
reference, and under "Action" it says:
“Alan Bates raised the issue of the scope of the
Working Group and whether the intention was that the
terms of reference would replace existing documentation
148
(37) Pages 145 - 148
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particularly but not limited to the ‘raising concerns
about Horizon’ documentation."
Secondly:
"Discussion then turned to the purpose set out for
the Working Group with the point being made that if the
terms of reference superseded previous documentation
then JFSA felt the terms of reference as drafted were
insufficiently broad."
Is that what you were referring to in your statement
as the challenge?
Yes, it was an attempt to narrow the terms of reference
that the Working Group could look at.
In what way was the attempt to narrow the terms of
reference?
Preparing the two sets of documentation, the first set,
prepared under Susan Crichton, was to embrace the
reasons for the differences.
The set of documentation, as I recall the new terms.
of reference prepared by Chris Aujard, or someone under
his direction, sought to limit anything the Working
Group looked at solely to the Horizon computer system.
We see there it says:
"Responding for Post Office Chris Aujard explained
that the terms of reference accurately reflected the
purpose of the Working Group as explained to him when he
149
that, once Susan Crichton left and Chris Aujard came,
there was this change of tone?
The change of tone was obvious. It's not always
reflected in the minutes by Belinda Crowe but, for
example, at the beginning of every meeting, Sir Anthony
Hooper would ask could the Post Office please explain
what has happened to this money, where are the suspense
account items, where has the money from subpostmasters
gone? And this is only referred to in two sets of
minutes, one in November 2014, and Chris Aujard says he
will ask his accounts team to answer what is a really
simple question, and it simply doesn't recur again.
But at the start of every Working Group meeting,
Sir Anthony Hooper asked that question and Chris Aujard
has simply blocked it and stopped anything happening
with regard to revealing it. It is clear to me that
he's there to close the scheme and close them down and
make sure that we don't see anything that damages the
Post Office brand. So, yes, it was a change of tone and
it came from Chris Aujard.
I'm going to look at suspense accounts later. Sticking
with the terms of reference, can we bring up, please,
POL00026656. So this is the notes of the meeting of
7 March 2014. So we previously were at the January
2014, we are now 7 March 2014. If we look down, please,
151
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had taken over the General Counsel and that his
understanding was that the Working Group's purpose was
narrower than Alan Bates had set out."
Pausing there, just as a slight detour, in your
statement you refer to a change of tone and approach for
the mediation when Chris Aujard replaced Susan Crichton.
Can you explain what you mean by the change of tone?
Yes, Susan Crichton was a lawyer, counsel for the Post
Office, who was tying to find out why differences had
occurred and it was under her instigation we got two
excellent investigators, Ron Warmington and lan
Henderson; it was under her instigation we had
a training day for people sitting on the Working Group
to understand the system. So it was kind of open
environment where access was given to documents to try
and find the true reason for things.
The second she disappeared without explanation and
Chris Aujard replaced her, we had someone who appeared
to be a litigation lawyer attempting to obstruct any
access to documentation, slow things down, narrow the
focus on to the narrowest of margins to limit damages
for the Post Office. That's how it appeared to me.
You appearing to be suggesting that direction came from
Chris Aujard. Was that anything he said or did that
made you think that, or was it just a timing matter
150
to "Terms of Reference”, it says:
"The Working Group discussed the revised terms of
reference. The reworked Clause 4.9 was agreed.
Clause 4.10.1 was agreed subject to the addition of the
phrase ‘and any associated issues’ after Horizon. It
was confirmed that the terms of reference allowed for
different lengths of mediation. It was agreed that the
Working Group should not have its own budget but would
use the process set at in Section 8 where funding was
required. The terms of reference were agreed.”
Now, the inclusion there of the "and any associated
issues in Horizon", was that addressing the concern you
had about the narrowing of the terms of reference?
It was supposed to make sure the previous issues were
still included in the Working Group remit.
Why did you say "supposed to"?
Well, I don't believe it did. I mean, for example, one
of the other things we discussed extensively was the
retention of documents required for the cases and, bear
in mind, we've got a lot more cases, we've got the 136
now, which is the 150 minus the ones the Post Office
‘objected to, and every time again we'd say, "Please
don't destroy any documents", and Chris Aujard would
say, "Well, if there are issues in those documents and
they're more than six years old, we'll probably have
152
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destroyed the documents". He made no effort to retain
documents.
Let's look at what you say on that in your witness
statement, please. It's page 16 of your witness
statement -- sorry, no, it's not. It's page 28.
Thank you. This is a section on concerns raised at
the Working Group meetings. We'll be coming back here
and I'm just going to deal with the paragraph 108 first,
and you say that:
"... Sir Anthony Hooper asked how the documents for
[subpostmasters] and other affected cases were being
preserved. He warned Chris Aujard not to destroy any
documents at all. Chris Aujard replied to Sir Anthony
Hooper that [Post Office Limited] would continue to
destroy documents following its usual six-year statute
of limitations document destruction policy."
Can we just look at some minutes on that, please,
starting with POL00026640.
Now, as happens with some of these meetings, we have
the standing agenda and attendees there. The date of
the document is on the second page, so 23 January.
Would that be 23rd January 2014?
Yes, it would. These were telephone calls. We only met
in person, I think, once a month.
Can we look at page 8, please under "AOB", It says:
153
documentation?
Well, they said they'd corresponded with their previous
head, covering Royal Mail, which separated in 2012, and
Royal Mail had stored some documents at Iron Mountain,
so presumably they told Royal Mail since 2012 and
earlier not to destroy documents. It didn't affect
really what the Post Office were doing with their own
documents. A lot of the cases being reviewed were
pre-2012, so that was relevant, but whether it was
complete, I can't say.
Can we bring up your witness statement, please, page 27,
paragraph 101. You discuss here a practice by JFSA of
retiring during discussion of individual cases, and by
“retiring”, do you know what I mean: not participating
in the discussion?
We left the room.
You left the room. It says:
"There was a development in the Working Group
meetings where the originally agreed terms for the
Mr Jenkins were unilaterally varied by [the Post Office]
when the Working Group attempted to discuss cases where
Second Sight had recommended mediation."
So this is Second Sight do the report, Second Sight
say, "We recommend mediation", and there were situations
where Post Office wanted to have a discussion as to
155
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"ACTION Post Office to reinforce the point that
files not to be destroyed -- Note to issue in Chris
Aujard’s name -- including letter to Royal Mail and
other relevant bodies.”
Do you recall that being discussed?
Yes, it was discussed at every meeting.
If we can go, please, to POL00026635, and if we can just
start at page 2, to date the document, Thursday,
6 February. If we go back to the front page, please, we
see that you're not in attendance at this meeting.
No.
Would you have reviewed the minutes?
Yes. I always reviewed the minutes when they came out.
Can we turn to page 5, please, and, if we can go to the
bottom of the page under 7. We have "Review of
outstanding actions", and reference number 28, it's the
point we went to earlier at AOB.
"Post Office to reinforce the point that files not
to be destroyed
It says:
"Update
"Correspondence issue to Royal Mail and from Royal
Mail to Iron Mountain.”
Was it not the case that Post Office were taking
steps or saying they were taking steps not to destroy
154
whether or not the Working Group actually recommended
mediation; is that a fair summary?
Yes, except Post Office had no authority to do that.
No authority to do what, sorry?
Well, at the point that -- the original terms of
reference, before Chris Aujard's version, was that, if
Second Sight, having reviewed the claim, the Post Office
Inquiry report and the CRR by Second Sight, if Second
Sight said it's a case fit to mediate, it should go
straight to mediation. Post Office had no right or
authority to interrupt the flow to mediation and have
a discussion at this point.
Can we look please at POL00022120. It's the same
document we went to earlier, just before the break about
criminal convictions. Can we turn to page 2. If we can
go down there, perfect, thank you. This is describing
the scheme, and the fourth paragraph down says:
“As a result of this investigation, Second Sight
will produce a Case Review summarising its findings and
a recommendation on whether the case is suitable for
mediation. A copy of this case review will be provided
to you."
Pausing there, this is aimed at an applicant
subpostmaster, is it, so the "you" is the applicant?
Yes, this briefing document is for the claimants to make
156
(39) Pages 153 - 156
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a claim, so it is to encourage them and explain how it
will work.
It then says:
"The Working Group will, however, take the final
decision on any cases that may not be suitable for
mediation."
That's correct, so any case that Second Sight have
rejected or can't make a decision about, the Working
Group should review. Ergo, it means that any case where
Second Sight say it's suitable for mediation should go
straight thorough.
Is it not the case that Second Sight would produce
a recommendation, which it was intended that the Working
Group would then consider and arrive at a final
decision?
No, it wasn't. The CRR, if it recommended mediation,
should go straight to mediation. It's only cases where
they didn't take a final decision.
Where did you get that understanding from, that that was
the proper interpretation of what the Working Group's
role was?
The Working Group will take a decision, a final
decision, on any cases that may not be suitable for
mediation, not on cases that are suitable for mediation.
That's what it says.
157
power to stop them.
The Working Group was chaired by Sir Anthony Hooper,
a previous Court of Appeal judge, yes?
Yes.
I think Sir Anthony Hooper was your recommendation?
Sir Anthony Hooper was Chairman of the Expert Witness.
Institute and I was his Vice Chairman. I knew him quite
well.
Was the purpose of appointing someone like Sir Anthony
Hooper, with a legal background, to assist with
resolving issues such as to whether a case should go for
mediation or not?
No, that wasn't the main purpose, the main purpose was
to find someone of great integrity and knowledge of the
resolution of disputes, to make sure that the process
produced by this mediation processing scheme was run
fairly. I mean, it was an absolute bonus, he had
substantial knowledge of criminal cases because he was
able to review files where Post Office said this wasn't
fit to mediate because this person was going to be
prosecuted or had a criminal conviction; Sir Anthony and
went and reviewed the files and, in every case, he said
"That's not true, they can go through".
I want to look at a few of the meetings where the issue
of whether or not to mediate came up. Can we start,
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If we turn to page 8 as well, please, and "Will my case
definitely be referred to mediation?" I think this is
a paragraph to which Sir Alan referred in his evidence
to the Inquiry. It says:
"If your case is suitable and you provide accurate,
detailed information to Second Sight, then this is
likely in most circumstances.
"However, the Working Group may consider that some
cases are not suitable for mediation. For example, if
there is insufficient information about a case or the
case is not one requiring resolution."
How does that work with your interpretation of the
role of the Working Group, if it's only going to decide
cases for mediation where Second Sight haven't made
a recommendation?
The Working Group was intended to process cases and make
sure they had the relevant information and inquiries
made before going to mediation. My understanding, when
this document was issued, is only in exceptional or
strange circumstances, when Second Sight, as competent
investigators, couldn't make a decision, or there was
anyone sufficient evidence, would the Working Group
consider the case. So it meant that the majority of
cases should have rolled through to mediation, and Post
Office, nor any other party around that table had the
158
please, with POL00026673. This is hopefully dated on
the first page, it's 16 June 2014. Could we go to
page 3, please, sorry, page 2. And if we could go down
to point 3 at the top of the document:
"Case M054 was discussed to inform a decision as to
whether the Working Group should recommend the case for
mediation. Second Sight had, in their final report,
recommended mediation."
It says:
"The following points were considered during the
course of the discussion:
"Regardless of a decision to recommend mediation by
the Working Group, either party had the right to decline
to mediate."
Did you disagree with that?
No, I think mediation has to be a consensual process.
It says:
"The extent to which case raises issues that had not
been previously explained to the satisfaction of the
applicant in the context of the benefit of mediation for
the applicant in terms of being able to 'move on’ after
mediation from the events being mediated."
What does that mean?
This is a particularly difficult case because it
involves someone who'd suffered, I believe, criminal
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conviction. I may be misremembering the number but
I think this is one where there was a criminal
conviction and there was strong opposition from Chris
Aujard in particular that you could mediate anything,
post a criminal conviction, but the financial loss was.
still there, whether they were convicted of something
criminal or not, and if their conviction was based on
some misinterpretation or some plea bargain under false
circumstances with limited disclosure, we all felt that
they should still have the opportunity to go face to
face and discuss the financial issues.
So was this a case where Second Sight had recommended
mediation, the JFSA were in favour of mediation but Post
Office were against mediation?
Yes, because there'd been a plea bargain in this case,
if 'm, again, interpreting the number correctly and
this individual had plea bargained to false accounting
to avoid a theft charge and going to prison. But
whether they'd actually done false accounting or not was
pretty dubious.
If we go to the bottom of the page, it says:
“It being apparent that the matter of whether the
Working Group should recommend M054 for mediation might
proceed to a vote, the Working Group agreed the test the
Chair should consider if called upon to use his casting
161
engaging in the debate and the vote at the time?
Yes.
Can we look, please, to POLO0026665. So we've got
a minute of the call on 26 June, which we see you're in
attendance at. Please can we go to page 8. So we have
M054, that's the case we were just discussing, and it
says:
"[The] Chair asked all parties to consider the steps
to be taken to inform applicant of the decision not to
mediate the case."
So it appears that that Sir Anthony Hooper had
decided against recommending mediation in this case; is
that correct?
That's correct.
"KL", I assume that's you?
Yes.
'.. faised a concern about sharing the Chair's decision
. The Chair noted this concern ..."
Then it says "AB", presumably that's Sir Alan?
Itis.
"... voiced concern about the additional time delay this
would cause the applicant, but agreed that the [Working
Group] should take time to consider how to proceed in
this case."
Can we scroll down, please. We see at the bottom
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vote as:
On the assumption that both parties approach
mediation in a genuine attempt to reconcile their
differences. Is it reasonably likely that the parties
will reach an agreed resolution of their issues'."
Then, over the page, it says:
"The Working Group moved on to a vote. Post Office
voted against ... JFSA voted for.
".., the Chair undertook to decide the matter and
provide the Working Group with his reasoned, written
decision.”
So, at this point, were the JFSA engaging in
a position where the Working Group were going to
determine whether or not to recommend a mediation in
circumstances where Second Sight had recommended
mediation?
Yes.
Why was that?
Because this is, I think, one of the first times this
occurs, and it was somewhat of a curveball because we'd
previously understood the scheme, if mediation was
recommended it would go through. Post Office strongly
objected and indicated they wouldn't take part in
a mediation.
So is your evidence this was being caught off guard but
162
"AB" again:
"AB queried the role of the [Working Group] in the
recommendation to mediate when [Second Sight] had
recommended mediation. It was noted that this was the
previously agreed process, and the one followed [in]
M054."
Do you recall the discussion that led to this
minute?
Yes. This is the point at which -- we objected, really,
to the intrusion of the Working Group committee into the
recommendations by Second Sight. It was clearly going
to cause delay and distress for the applicants when they
had cleared the hurdle of proving there was a dispute
that could be mediated.
When it was said, "It was noted that this was the
previously agreed process, and the one followed for
M054", at that stage, were you in agreement that M054
had followed a previously agreed process?
No. That's the point. Belinda Crowe has written this
minute. The first half of -- the first half of the
second sentence belongs with the first:
"AB queried the role of the Working Group in
recommendation to mediate when [Second Sight] has
recommended mediation, which was noted [was the previous
agreed process. Stop. This was different for the
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followed for M054]."
That can come down, thank you. I don't propose to take
you to minutes of other Working Group meetings but
I can, if you like. They showed, as you said earlier,
that JFSA, from then on, would leave the room or not
participate in discussions when the Working Group were
deciding whether or not to recommend a case for
mediation.
That's correct. I mean, the latter meetings were held
at Matrix Chambers, rather than Bond Dickinson Womble's
(sic) office but we left the room, and sometimes the
building, until they'd finished dealing with their
interference in the Scheme because, frankly, it was
a power the Working Group did not that have, whatever
Chris Aujard's explanation was when he joined Post
Office.
Was it a case that Sir Anthony tried to encourage the
JFSA to stay for that discussion?
He did but I don't criticise him for that. He simply
wanted a straightforward way forward for the claimants
who were being caught up in this battle.
Could you explain the basis on which, or the reasons
for, not participating in those discussions, other
than -- you've given evidence that it wasn't the agreed
process. Were there any further reasons for not
165
Office.
You say in your statement -- and we'll come to the email
shortly -- that you've now seen an extremely inaccurate
file note of that conversation. When did you first see
what you describe as the inaccurate file note?
In the papers for this Inquiry.
Before seeing what you describe as the filenote, would
you have recollected this conversation with Paula
Vennells?
Yes, I remember meeting her at the airport and bearding
her, if that's the correct phrase, with some sort of
encouragement for her to settle and at least face up to
the claimants and explain to them what had happened, and
pay them back their money.
Let's look at the note, actually. We'll go straight
there. It's POL00101367. It's an email from Paula
Vennells to Chris Aujard. It's on 17 September, so this
is made on the day of the meeting; is that right?
It's -- 17 September is when I saw her at Bonn airport.
Do you remember roughly what time the meeting was?
No, I can't. It was in the morning or around lunchtime,
at a guess.
But you would accept that this is a contemporaneous
account? I appreciate you dispute the accuracy of it
but it was made on the day of the meeting?
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participating in the discussion?
Not only was it not the agreed process; it was not what
had been advertised to the claimants when they made
an application to join the scheme. Once you joined
a scheme and the rules are set, you can't then do what
Post Office often did, which is slip change into some
‘other shape, so you do something different, you've got
the people on Board, so then suddenly they're not going
off to Clacton-on-Sea, they're off to Scarborough.
I want to move on, still in the time of the Working
Group but could we bring up your statement, please, at
paragraph 91, which is page 24.
Is this the second 91?
You're quite right; it is the second 91.
Apologies for that.
None needed. When it arrives on the screen, it is the
meeting with Paula Vennells.
Sorry -- yes, if we can go to the bottom of the
page, please.
So this refers to a meeting you had -- I think it's
a coincidental meeting where you bumped into Paula
Vennells at Bonn airport in Germany on 17 September
2014.
Yes, I was waiting for my flight by the gate and she
hove into view with two other people from the Post
166
Well, it appears Ms Vennells has sent an email on the
same day, yes.
It refers to just bumping into you at Bonn airport:
"... had a chat together. Off the record but of
course not really."
Do you know what that means or what would lead to
that impression?
Well, I did say that, I said, you know, “Paula can
I have a word off the record because I do think you need
to settle this because the subpostmasters need their
money back, and they ought to have some sort of
face-to-face explanation to explain why they've been
treated so badly for so long, and if you don't settle
this, you'll regret it”.
It says -- I'm not going to go through all of the
document, I think it's the fourth bullet point down:
"Can we get Angela to lead on mediations?
Particularly if we think we are unlikely to move our
position. Kay's view is that she is credible,
understandable (v important) and stands the best chance
of getting people on side or at least to feel they have
been listened to, even if they still disagree."
Now, taking it in stages, is Angela, in that bullet
point, referring to Angela van den Bogerd?
Definitely Angela van den Bogerd.
168
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Did you discuss Angela van den Bogerd in your meeting
with Paula Vennells?
Yes, we did, because she was getting to the bottom of
an investigation, which seemed to have been carried out
for the first time on any of the applicants’ cases, and
we were actually finding out why the differences had
‘occurred. So she was very thorough, easy to understand
in her explanations of how differences arose and, if you
cut her in half, she'd be Post Office through and
through.
Did you say that, about being Post Office through and
through?
No, I did not say that to Paula Vennells.
So the point that "Kay's view is she is credible,
understandable", is that a fair comment for Paula
Vennells to have made?
Concerning the investigation of differences in the
network, yes, but not generally.
She said:
"We should consider being more open to mediation on
the cases where more money was at stake not less.
Because this had a greater impact on those affected
(lost jobs, homes, etc) and therefore, they are the ones
who need to vent more. And who will benefit from us
allowing them to ‘yell’ at us (she thinks we're big
169
note, and I thought they could have been more
sympathetic than taking someone into her home and
interviewing her without anyone else present and
attempting to take her goods, which was prevented by her
mother.
I don't remember saying Jo had evidence that they
hadn't got at the time of prosecution. I probably did
say Jo should have had information disclosed by Post
Office that wasn't available at the time of prosecution.
This is a complete misrepresentation of what I said.
Would you have said, as part of the discussion
generally, about the fact of a guilty plea, whether or
not you agreed with that guilty plea? Would you have
mentioned that?
No, I don't believe we discussed prosecutions or guilty
pleas, as far as I recall. My notes of this
conversation have not been reduced to a file note at the
time. They were in passing at an airport.
Thank you. That document can come down.
I want to go back to one of the two points you
raised, and one of them I said I'd come back to. It's
page 28 of your statement, please, paragraph 107, and,
if we could go to the bottom, please. Thank you.
These are two of the concerns that you raised here.
We looked at 108 earlier; 107 is the question, "Where
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enough to take that).”
Where on earth has that come from?
That was about to be my question: from what was said --
or do you recall anything being said at the meeting that
would lead to this note being made?
No.
We then have, it says, "Jo Harrison (JA SPMR)". Now
that means presumably Jo Hamilton, James Arbuthnot,
subpostmaster?
Yes, I'm pretty certain it's Hamilton, not Harrison.
"_.. Kay intends to go into mediation with her -- she
thinks she needs looking after. Kay indicated that Jo
had done something wrong but feels sorry for her
Now, I'm going to pause there because I know you
dispute that. What is your recollection of what was
said about Jo Hamilton at this meeting?
My recollection is I said the system was such that Jo
had been muddled and concerned, very upset and had had
to roll over a difference which Angela had said, when we
discussed M035, that was a reason she couldn't get to
the bottom of the reasons for the difference because it
had been rolled forwards over so many periods.
I didn't feel sorry for Jo. I did say she might
have got out of her depth with the system but she didn't
have any documentation to check, which isn't in the
170
has the [subpostmasters'] money gone?" You say that
Sir Anthony Hooper asked that question regularly.
Yes, he did.
Now, you say at the end of that paragraph:
[Post Office] failed to provide any explanation or
figures at all."
That's in relation to "Where's the money gone?":
"Chris Aujard said he would get this information on
several occasions but [he] never did.”
I just want to look at a few of the meetings on this
issue and could we start, please, with POLO00026685.
This is a meeting on 16 September 2014. We see you're
in attendance. Could we look at page 6, please and, if
we go down to "Suspense account paper”, thank you.
So "Suspense account paper”. Now, you do say in
your witness statement that there are at least two types
of suspense account potentially relevant. What type of
suspense account was being discussed here?
We should be discussing what I would call the head
office suspense account, where differences were posted
in the main Post Office Limited accounting system, and
I would expect it to include things like the differences
‘on reconciling Camelot or Bank of Ireland control
accounts. But it must be that place where the
subpostmaster's money had gone and I know, talking to
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Ron and lan at the Working Group, they definitely
volunteered many times to go to Chesterfield, or
wherever the accounts were held, and have a look for
themselves to actually ascertain what had happened to
the money.
Chris Aujard, on many occasions, confirmed that
wasn't necessary, it was too complicated, they weren't
going to be paid for it, and he would produce a paper
from his accounts team asking the CFA. I've no idea
what this paper was but I don't believe it was
a substantial explanation.
But this part here where Post Office explained they
provided with a paper, you say you don't know what that
was?
No, I've never seen it.
"Post Office explained that this request was too broad
and they could not see how it linked to any case that
Second Sight investigating. Second Sight undertook to
provide their further specific question(s) in writing to
Post Office."
Could we look at the meeting on 17 October, which is
POL00040475. It is 18 October, as I say. Can we go to
page 2, please. This is referring back to the minutes
of 16 September meeting. This is:
“Referring to page 6, item 5 Second Sight had
173
Update on Part Two Report". So that's the Second Sight
Part Two Report.
Yes.
The Chair asks for an update on progress of various
matters and, at the bottom, we see:
"The Chair asked if Post Office was able to answer
the question on suspense accounts that had been posed
for several months. lan reported that the information
had not yet been provided. The Chair asked that this be
addressed as a matter of urgency and suggested that Post
Office arrange a meeting between Second Sight and Post
Office Finance staff to do so."
Now, the Inquiry has heard evidence, and there's
documentary evidence, on matters that happened
thereafter. My question to you is: were you involved at
all in this investigation into suspense accounts?
No, I was not.
Did Ron Warmington or lan Henderson tell you anything
following this meeting about that investigation?
"In about 2015 [I brought the paper to remind me] I was
told by lan Henderson that the amounts credited to the
profit and loss account of Post Office in 2010/11 was
£612,000; in 2011/12 was £207,000; in 2012/13 was
£234,000; and in 2013/14 was £104,000."
Can I ask you're reading from a document, is that a note
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written to Post Office with questions on the suspense
account but are yet to receive a response. The Chair
noted the complexity of the questions. He asked if
there was a surplus in the account would it be taken
into Post Office income. Post Office confirmed that it
would after 3 years. Post Office and Second Sight
agreed to clarify Second Sight's precise needs for
information.
"... The Chair asked Post Office for figures taken
into income from the suspense account to be broken down.
year by year."
Now, firstly, do you recall this conversation beyond
what's recorded in the minutes?
A. I remember a November 2014 minute where Chris Aujard
gave a specific undertaking, I can't remember the
wording, and that information was never followed up.
But I know, to my own -- from my own investigations that
there were amounts of over £1 million pounds taken to
the Post Office profit and loss account over a five-year
period.
Q. I think you have answered the question I was about to
ask on what came next, and we're going to jump forward
to 14 January, please. POL00043633. We see 14 January
2015. Can we go, please, to page 3, and to the bottom
of the page. Thank you. It's "Additional Agenda Item:
174
of a conversation that --
A. It's a note of a conversation I had and I highlighted it
in yellow so I could find it.
Q. So that's -- sorry, it's gone off my -- that was lan
Henderson who told you that?
A. That's correct.
Q._ Did you have any further involvement in investigating
suspense accounts?
A. There was no opportunity because the Mediation Working
Scheme was cancelled unilaterally by Post Office without
that question ever being answered.
Q._ I want to now turn to my final topic, what happened
thereafter, and the Group Litigation --
SIR WYN WILLIAMS: Before you do, am I right in thinking
that either Mr Henderson or Mr Warmington had in their
witness statement, when they gave evidence, figures
either identical to, or very similar to, the ones which
Ms Linnell has just referred to?
MR STEVENS: Sir, off the top of my head, I couldn't say
with confidence but, at the break, we'll double check
that point.
‘SIR WYN WILLIAMS: Okay, I don't think I'm imagining that,
that's all.
A. If it assists, they're in the published accounts.
SIR WYN WILLIAMS: Right. So there's a public record of
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them somewhere, anyway?
MR STEVENS: Yes.
SIR WYN WILLIAMS: Fine. Well, you needn't go researching
then, Mr Stevens.
MR STEVENS: Thank you. It shows a confidence in my memory.
Turning, then, to the litigation, please. I asked
earlier about the prospect of litigation in 2012 and my
understanding of your answer was that you need funding
for litigation —
A. Yes.
Q. -and, in order to get funding, you needed to have
sufficient information to show a basis to put forward
your claim?
A. Yeah, and a reasonable chance of success or no sensible
lawyer would take it on.
Q. I'm now going to ask you some questions about the
process of litigation but, remember, I'm not asking you
anything which would require you to provide privileged
information, unless you were in a position to waive it
and you wanted to waive it.
A. Thank you.
Once the Mediation Scheme had finished, so in 2015 --
A. Itwas abruptly ended by Post Office in 2015 and I had
a letter from Jane MacLeod out of the blue.
2
Q. - how easy or difficult was it for you to find legal
177
been able to process either, and the funders recognised
the importance of having after-the-event insurance for
people in our claimants’ position. So we had to put all
those four pieces in place before proceeding to
litigation.
Q. Just for the benefit of the public, when you say
“after-the-event insurer", do you mean an insurer who
would indemnify the claimants if the litigation was
unsuccessful and a costs order was made against them?
A. If you look at the case of Lee Castleton, it's very
clear. If you lose in a court and the court has the
power to award costs against you, it can have severe
financial implications. The purpose of after-the-event
insurance is to put an insurance policy in place so, if
you lose, the insurance policy coughs up and pays the
costs.
Q. So, as I understand it, you say the sort of essential
ingredients were: (a) Therium or a litigation funder;
(b) the after-the-event insurer; and (c) solicitors and
barristers who were prepared to take a portion of their
fees on a conditional fee basis, or a no-win-no-fee
basis?
A. Yes, and bearing in mind all are essential, so you could
take them all as one. There is no priority in that
listing. And to get the solicitors and barristers
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representation for the Group Litigation?
Sir Alan and I did several things at the end of the
Mediation Scheme. First of all, we had a look at the
evidence that had been produced by the Post Office and
Angela van den Bogerd. We also -- without wishing to
pierce privilege of mediation discussions -- had some
general feedback from those people who had been
fortunate enough to reach the mediation panel. And,
thirdly, we started putting together a panel of
potential lawyers who had experience in Group
Litigation.
We then went to several firms of lawyers and, as
happenstance would have it, we ended up with Freeths,
who also introduced us to litigation funders,
after-the-event insurers and counsel, Henderson
Chambers.
It's well known that the litigation was funded by
a litigation funder, Therium?
Therium were the funders, yes.
If you hadn't had funding by way of a funder such as
Therium, would the GLO claimants have been able to
pursue the litigation?
No, they wouldn't and if they hadn't had generous
solicitors and counsel, prepared to take a proportion on
a conditional fee/success arrangement, we wouldn't have
178
interested, you have to have sufficient evidence to
prove that something has been done wrong and there is
similarity across a group of claimants, so that there
are sufficient to actually put a force together to form
a group litigation group. Quite high hurdles to
overcome.
Just rounding this off, the information that you were
able to obtain and put forward to the solicitors and
barristers to get them interested, did that come from
the Mediation Scheme?
Yes. One of the things about going into the Mediation
Scheme -- because, normally, anything discovered in the
mediation is privileged and within the bubble of
mediation, but one of the things JFSA managed to
negotiate is any document disclosed in the mediation
would be usable by the claimant person. So yes, that's
where the data came from to enable litigation to take
place.
Before I ask you another question about the GLO, then,
to what extent, if at all, do you think the Mediation
Scheme fulfilled its purpose?
At least 85 or 90 per cent. Without the Mediation
Scheme, there wouldn't have been the volume and the
capacity of claimants to go forward because Post Office
has, throughout my involvement with them, deliberately
180
(45) Pages 177 - 180
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or otherwise withheld documents that are essential for
the defence of individuals or the prosecution of
aclaim.
Q. Can we look at page 31 of your statement.
SIR WYN WILLIAMS: So, again, Mr Stevens, sorry. But, if it
be the case that the Post Office was seeking to use the
Mediation Scheme as a sham, to use that word, in fact,
‘on your view of it, it had the opposite effect because
it provided you with the ammunition for the litigation
that followed?
A. Yes, that's exactly right.
‘SIR WYN WILLIAMS: Fine. Okay.
MR STEVENS: At paragraph 119 and 120, you say:
"The Freeths legal team put in place all the
necessary mechanisms and steps to cope with and respond
to the aggressive [Post Office] litigation strategy,
which in my view and the view of others, was primarily
designed to run the [Group Litigation] claimants out of
funding. Mr Justice Fraser refers to this in his
judgment by implication."
You go on to specify what you saw as the aggressive
litigation tactics by saying:
"[They] included limited and sporadic late
disclosure, contested costs applications and other
litigation ‘tricks’ such as [Post Office's] recusal
181
on the Horizon system, add huge legal costs to our side
and try and derail the whole process.
Q. Did you speak to other people in the claimant group
about the fact of the recusal application being made?
A. I certainly did because people wanted to understand what
it was.
Q. Can you summarise what the general feeling was within
the claimant group about the application having been
made?
A. I can only say this from my personal point of view.
I think there was some anger and frustration, as yet
another tactic by Post Office stopped the move slowly
towards redress, justice and some sort of conclusion as
to what had happened to them.
Q. The final question, or possibly questions, I ask is
about interaction with Government. Now, when Sir Alan
gave evidence, Mr Beer presented a series of letters
that he had sent to ministers and went through various
meetings. Did you have any interactions with Government
or Government Ministers in respect of the Horizon IT
System?
A. Sir Alan and I decided that he should write the letters.
We discussed the contents before they were sent. In
particular, I was a part of his issuing of a bill to,
I think, the Prime Minister at the time, Boris Johnson,
183
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application to derail the planned five trial
litigation.”
I want to just focus on one aspect of that, and
that's the recusal application. Were you in court when
the recusal application was announced?
A. Yes, I was.
What was your reaction to that?
A. Ithappened after lunch, in the middle of someone's
testimony. I think Mr de Garr Robinson stood up and
made the application. Fraser J insisted the witness was
completed before he dealt with it, which was kind,
because, otherwise, the witness would have been held
over indefinitely, and I think it was an absolutely
shocking result because it was the tactics of
a desperate, drowning man, as far as I could see, to
recuse a judge who had been no more than colourful in
his language and comparatives.
It was the handing down of this judgment that same
morning, and there were phrases in it which clearly the
Post Office and their Legal Team objected to, such as
"The Flat Earth Society", and things like that. And
I think it was absolutely disgraceful because there was
no bias that I could see in that judgment. However, I'm
not a lawyer, I'm a mere accountant. But I thought it
was a disgraceful tactic and designed to stop the trial
182
2
concerning the litigation costs of 46 million plus
interest.
MR STEVENS: Thank you.
Sir, before I -- famous last words, saying it was my
last question. If I may just have a moment to check
anote. (Pause)
Thank you, sir. I do actually have one further
question and it's going right back to the start of your
evidence, when you referred to working for a firm called
BDO.
A. Yes.
Q. We've heard evidence about Lee Castleton's civil case,
and an expert report being produced to Womble Bond
Dickinson, not disclosed in the hearing, by BDO Stoy
Hayward. Did you have any involvement in the Lee
Castleton case at all?
A. No, I really wasn't aware of Lee Castleton's case until
I met Alan Bates and we went into this process.
Q._I'mnot suggesting it's necessarily the same firm.
I just wanted --
A. It will be the same firm, because Stoy Hayward and BDO,
which was formerly BDO Binder Hamlyn, amalgamated at
some point but I wasn't involved in such high echelons
of the firm to know anything about that.
MR STEVENS: Thank you.
184
(46) Pages 181 - 184
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The Post Office Horizon IT Inquiry
Sir, those are the questions I have.
Now, Ms Linnell is represented by Mr Stein and would
he like to ask questions in re-examination under Rule
10(2) which, subject to your approval, I think, is open
to them. I think if we are doing that, though, first,
I will check if there are other Core Participants who
wish to ask questions?
No, sir. I think Mr Stein has two questions.
‘SIR WYN WILLIAMS: Literally two, Mr Stein?
MR STEIN: Two topics, sir.
MR STEVENS: Sorry.
‘SIR WYN WILLIAMS: No, I'm just concerned about the
shorthand writer, that's all. If you're going to be
literally a few minutes, I'm sure she'd prefer to finish
but, if it's more than that, we'll ask her which she'd
prefer.
MR STEIN: Our shorthand-writer is confirming that if it's
a few minutes then to go ahead, and it will be, sir.
‘SIR WYN WILLIAMS: Fine.
Questioned by MR STEIN
MR STEIN: I Sir, the reference in Mr Warmington's statement
to the suspense account monies is his statement
WITNO01050200, page 7, paragraph 12, and the figure of
£612,000 is given. You'll recall I asked him questions
about that matter, and he referred to other sums.
185
A. The feeling among people I spoke to who were SPMs is
that the National Federation of SubPostmasters were no
more than part of Post Office and not to be trusted.
MR STEIN: I Sir, thank you.
SIR WYN WILLIAMS: Well, first of all, should I be calling
you "Dr Linnell"?
THE WITNESS: You could, sir.
‘SIR WYN WILLIAMS: Well, hidden amongst your witness
statement was a reference to you becoming a doctor in
2024. So, Dr Linnell, thank you very much for your
witness statement and thank you very much for giving
evidence before me this afternoon.
THE WITNESS: § Thank you, sir.
MR STEVENS: Thank you, sir.
I apologise for repeatedly saying "Ms Linnell" all
the way through.
THE WITNESS: No, no, I'm happy.
‘SIR WYN WILLIAMS: I I'd just like everybody to know that I do
read the lines of the witness statement, Mr Stevens.
That's all.
Thank you very much, everyone.
9.45 tomorrow, yes?
MR STEVENS: Yes, sir. Thank you.
(4.06 pm)
(The hearing adjourned until 9.45 am the following day)
187
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SIR WYN WILLIAMS: Yes.
MR STEIN: Ms Linnell, just two topics, as mentioned to
Sir Wyn.
You were asked a question by Mr Stevens about your
first joining meetings of the JFSA and we all know from
the ITV drama that the meetings were sometimes at
village halls -- Fenny Compton, famously, otherwise at
Kineton on occasions.
Now, regarding funding, which is what you were asked
by Mr Stevens, how broke were the subpostmasters that
you met at these meetings?
A. Very broke and in "minus red land", as my friend used to
call it, with lots of credit card and other debts
hanging around them.
Q. Sometimes, in relation to your support of
subpostmasters/mistresses working with Mrs Jeremiah, you
were helping them try and make their way through the
mess that had been made of their finances. That needed,
on occasions, to get things like bank statements, which
aren't necessarily free; how did you manage to do that?
A. Barbara and I paid for them.
Q. Another question asked by Mr Stevens was regarding the
JFSA and whether it engaged with the National Federation
of SubPostmasters. Was there any desire amongst the
people that you met at the JFSA to engage with the NFSP?
186
INDEX
GRAHAM WARD (re-sworn) ....
Questioned by MR BEER .
ANTHONY PAUL KEARNS (sworn) ... 37
Questioned by MS HODGE .. 37
Questioned by MR STEIN .... 89
Questioned by MS WATT .. 95
DR KAY CATHERINE SHEILA HILARY LINNELL 106
(sworn)
Questioned by MR STEVENS . 106
Questioned by MR STEIN .... 185
188
(47) Pages 185 - 188
MR BEER: [10] 1/3
1/5 117 3/3 28/13
28/15 36/11 36/15
36/22 37/1
MR STEIN: [9] 89/10
89/19 89/21 95/2
185/10 185/17 185/21
186/2 187/4
MR STEVENS: [18]
106/17 106/19 106/24
118/14 145/23 146/2
146/4 146/8 146/10
176/19 17/2 177/5
181/13 184/3 184/25
185/11 187/14 187/23
MS HODGE: [18]
37/6 37/8 37/10 37/13
84/3 84/10 84/14
84/16 88/8 88/13
88/16 88/22 89/4 89/9
105/24 106/3 106/10
106/12
MS WATT: [3] 95/5
100/9 105/21
SIR WYN WILLIAMS:
[52] 1/4 1/9 1/12
1/18 2/20 2/25 3/2
28/11 28/14 36/14
36/18 36/24 37/2 37/7
37/9 84/8 84/15 88/12
88/15 88/21 89/1 89/8
89/18 95/3 99/2 99/12
99/25 100/7 105/22
106/2 106/6 106/11
106/13 106/18 106/21
118/10 145/25 146/3
146/9 176/14 176/22
176/25 17/3 181/5
181/12 185/9 185/12
185/19 186/1 187/5
187/8 187/18
THE WITNESS: [4]
116 187/7 187/13
187/17
"Declined [1] 8/6
‘definitely’ [1] 15/20
‘encourage’ [1] 80/16
‘following’ [1] 8/2
‘form’ [1] 78/12
‘from’ [1] 78/12
‘Horizon’ [1] 122/5
"How [1] 8/9
[A] 16/5
‘Lwas [1] 16/5
‘I've [1] 7/24
NE [1] 16/12
‘Justice [1] 85/25
‘Losses [1] 50/18
"maybe' [1] 15/19
‘move [1] 160/21
"NFSP [1] 79/11
‘Nil’ [1] 24/17
‘No [2] 8/5 10/22
"On [2] 5/16 162/2
‘PO [1] 78/18
‘raising [1] 149/1
‘should [1] 80/12
"Such [1] 9/13
"system [9] 8/19
13/22 14/25 18/5
20/18 21/1 33/13 34/9)
34/23
"systemic [1] 121/7
"systems [1] 121/4
‘the [2] 79/16 127/11
‘There [4] 8/7 9/10
16/8 16/10
‘These [1] 6/14
‘This [3] 13/15 13/18
17/10
"Three [1] 8/3
‘Transaction [1] 17/1
‘tricks' [1] 181/25
‘up [1] 78/2
‘We [1] 5/22
‘yell’ [1] 169/25
[Ay 13/21
va" [6] 5/12 7/2 9/11
12/15 13/15 16/10
"80s [2] 109/24
109/25
"80s/early [2] 109/24
109/25
"90s [2] 109/24
109/25
"97 [1] 83/2
"99 [1] 56/14
‘Also [1] 8/18
‘and [1] 152/5
‘any [4] 10/24
"ARQs [1] 5/8
‘Both [1] 5/10
‘bugs’ [1] 137/3
"Can [2] 7/15 12/14
‘commercial [1] 80/6
0
01/11/04 [1] 5/24
04 [1] 5/24
05 [1] 5/24
1
1 February [3] 3/6
3/12 4/20
1 million [2] 78/19
174/18
1.40 [2] 106/11
106/16
1.5 million [4] 78/15
1.5 million’ [1] 78/3
10 [7] 10/14 29/20
29/22 30/20 32/5
81/25 185/4
10 March [2] 7/3 7/10
10.21 [2] 23/15 23/17
10.28 [1] 23/6
10.37 [1] 37/3
10.50 [2] 37/1 37/2
10.52 [1] 37/5
100 [2] 120/18 133/41
104 [1] 155/12
104,000 [1] 175/24
107 [2] 171/22
171/25
108 [2] 153/8 171/25
11 [6] 61/9 92/11
120/24 142/25 143/6
175/22
11 days [1] 6/12
11,500 [1] 126/20
11.13 am [1] 23/18
11.37 [2] 20/10 21/25
1120 [1] 90/11
119 [1] 181/13
12 [5] 116/15 116/16
138/13 175/23 185/23
12 July [1] 120/9
42 May [1] 126/7
12.00 [1] 84/11
12.10 [2] 84/9 84/13
12.41 [1] 106/14
120 [1] 181/13
13 [4] 61/8 61/8
138/18 175/23
136 [4] 152/20
14 [2] 37/24 175/24
14 January [2]
174/23 174/23
15 [7] 36/22 85/10
118/9 118/20 128/19
132/21 148/6
415 July [1] 145/11
15 minutes [1] 89/7
15 pages [1] 37/23
15-minute [1] 36/24
150 [4] 152/21
157 [4] 107/18
16 [1] 153/4
46 July [1] 117/11
16 June [1] 160/2
16 May [1] 107/5
16 September [2]
172/12 173/24
16' [1] 78/3
160 [2] 4/25 5/5
161 [1] 6/5
16th [2] 117/12
117/12
17 [4] 166/22
17 October [1]
173/21
17 September [2]
167/17 167/19
18 [2] 71/11 141/25
18 July [1] 120/10
18 June 2015 [1]
85/2
18 October [1]
173/22
18 years [1] 30/13
19 August [1] 138/23
1978 [4] 51/3
1979 [1] 109/18
1997 [1] 39/5
1999 [5] 40/11 61/5
61/12 62/13 63/17
2
2.47 [1] 146/5
2.5 million [1] 78/21
20 [1] 146/12
20 June 2024 [1] 1/1
20 years [1] 108/25
2000 [2] 40/11 95/16
2000s [2] 95/14
95/18
2001 [5] 61/2 61/2
61/7 61/11 62/14
2002 [24] 3/20 39/5
39/17 40/6 45/10
48/19 49/2 49/6 49/13)
58/11 58/13 58/18
58/19 58/23 61/2 61/7,
76/16 83/3 94/8 94/11
97/3 97/4 98/10
101/17
2002/2003 [1] 61/11
2003 [3] 61/2 61/8
61/11
2003/2004 [2] 96/19
97/4
2004 [4] 61/3 61/8
96/19 97/4
2005 [2] 111/12
123/14
2006 [8] 3/16 3/19
5/6 19/16 20/10 23/6
31/22 61/9
2008 [1] 138/23
2009 [5] 82/2 83/9
1411/7 111/18 111/20
2010 [1] 110/16
2010/11 [1] 175/22
2011 [6] 67/14 67/19
68/2 100/22 101/7
123/12
2011/12 [1] 175/23
2012 [20] 110/21
111/21 112/1 112/3
112/7 113/19 114/2
114/17 115/13 116/16}
117/9 117/11 119/12
121/11 121/22 122/14}
155/3 155/5 155/9
(77/7
2012/13 [1] 175/23
2013 [17] 51/5
114/16 118/23 119/7
119/12 124/17 125/3
125/24 126/7 128/21
129/1 129/6 134/3
134/18 141/7 141/22
145/11
2013/14 [1] 175/24
2014 [13] 51/5 74/9
148/8 148/18 151/10
151/24 151/25 151/25)
153/22 160/2 166/23
172/12 174/14
2014/2015 [1] 67/11
2015 [7] 67/11 71/11
85/2 174/24 175/20
177/22 177/23
2015/16' [1] 78/3
2019 [2] 82/2 83/9
2021 [1] 145/14
2022 [1] 38/20
2024 [6] 1/1 3/6 3/12
4/20 107/5 187/10
207,000 [1] 175/23
21 [1] 85/13
21 May [1] 129/6
22 [1] 121/25
23 January [1]
153/21
234,000 [1] 175/24
23rd January [1]
153/22
24 [2] 107/9 166/12
24 March [4] 19/15
20/10 21/25 23/6
24th [1] 13/13
25 January [1]
124/17
25 June [1] 71/12
26 June [1] 163/4
269/15 [1] 85/10
27 [4] 155/11
28 [3] 153/5 154/16
171/22
29 November [1]
38/19
3
3 October [1] 67/19
3 years [1] 174/6
3.00 [2] 146/2 146/7
30 January [2] 148/8
148/18
30 years [1] 57/18
30/11/05 [1] 5/24
34 [1] 181/4
33 [5] 46/16 46/19
50/17 53/12 57/3
4
4.06 [1] 187/24
4.10.1 [4] 152/4
4.9 [1] 152/3
40 [4] 4/23
401 [3] 5/18 6/17
24/16
41 [4] 107/16
43 [4] 81/25
(48) MR BEER: - 43
4
459 [3] 5/20 6/18
24/16
46 million [1] 184/1
460 [3] 5/20 6/18
24/16
47 [4] 114/13 114/23
116/7 120/24
5
5 June [1] 129/12
500 [3] 58/2 59/7
59/12
52 [2] 23/19 31/16
55 [1] 148/7
6
6 February [1] 154/9
6 July [1] 117/9
6's [1] 80/12
612,000 [2] 175/23
185/24
66 [1] 141/25
6c [4] 79/11
6th [1] 117/12
7
7 March [2] 151/24
151/25
76 [1] 146/13
77 [4] 146/18
8
8 July [2] 119/7
134/17
85 [1] 180/22
8b [1] 69/8
9
9 May [2] 37/18 38/8
9,000/9,500 [1] 95/17
9,500 [1] 95/17
9.45 [3] 1/2 187/22
187/25
90 per cent [1]
180/22
91 [5] 107/10 107/15
166/12 166/13 166/14}
A
AB [4] 163/19 164/1
164/2 164/22
abandonment [1]
81/7
ability [4] 47/10 75/7
91/16 138/24
able [19] 7/6 9/4 11/2
43/5 44/15 77/6 81/10
92/24 93/13 93/14
97/1 116/19 147/6
159/19 160/21 175/6
178/21 179/1 180/8
about [133] 1/14 3/7
3/12 4/10 4/13 5/9
5/11 6/13 6/23 7/5
9/15 10/17 12/12 13/3)
14/3 17/19 18/24
19/10 25/3 40/9 46/1
47/6 49/14 49/17 58/9)
58/16 61/18 62/22
64/6 65/4 68/15 69/17
71/2 72/24 73/4 73/24
73/25 77/19 85/13
87/7 96/2 96/6 96/14
96/21 96/25 97/8
97/13 98/15 98/17
98/21 98/23 99/3 99/7,
100/2 100/17 100/21
100/25 101/22 102/2
103/5 103/7 103/8
104/21 104/21 108/1
110/16 110/21 112/14)
112/25 114/6 114/14
115/17 117/14 120/10}
120/25 122/21 124/2
124/7 125/2 125/9
125/11 128/17 129/3
133/21 133/24 134/1
134/2 134/12 134/23
136/6 137/5 138/4
138/24 139/8 139/9
139/11 139/21 140/10)
140/12 143/11 143/12)
143/23 144/3 144/18
146/22 147/4 148/21
149/2 152/13 156/14
157/8 158/10 163/17
163/21 169/11 170/3
170/16 171/12 174/21
175/19 175/20 177/7
177/16 180/11 180/19)
183/4 183/8 183/16
184/12 184/24 185/12)
185/25 186/4
above [7] 5/10 22/25
23/4 23/13 25/10
25/25 51/12
abruptly [1] 177/23
absolute [1] 159/17
absolutely [8] 18/13
26/17 32/22 34/3
78/24 124/7 182/13
182/22
accept [10] 17/11
19/14 27/11 28/20
29/1 49/12 60/22
101/4 105/17 167/23
accepted [3] 18/17
95/25 147/9
accepting [3] 21/1
34/9 34/23
access [7] 23/7
115/11 124/6 138/16
138/25 150/15 150/20)
accorded [1] 75/1
account [17] 5/7 23/7
48/15 50/5 151/8
167/24 172/14 172/15)
172/17 172/18 172/20}
174/2 174/4 174/10
174/19 175/22 185/22
accountable [1]
46/14
accountancy [2]
109/8 121/9
accountant [9]
109/18 109/20 109/23}
110/6 110/15 116/25
117/15 131/22 182/24
accountants [4]
110/3 110/13 114/25
115/10
accounting [10]
46/21 47/2 48/11
49/10 51/11 55/6
110/7 161/17 161/19
172/21
accounts [14] 41/8
111/14 130/6 133/10
138/25 151/11 151/21
172/24 173/3 173/9
175/7 175/16 176/8
176/24
accredited [3] 74/12
74/14 77/17
accuracy [3] 5/11
13/2 167/24
accurate [4] 54/2
105/9 114/20 158/5
accurately [2] 41/8
149/24
accuse [1] 104/24
accused [7] 46/21
48/11 49/10 57/19
57/21 58/2 103/14
accusing [1] 105/12
acknowledge [1]
60/19
acknowledgement
[1] 86/17
acknowledges [1]
79/16
across [7] 15/13 32/3}
56/25 57/1 91/6
137/14 180/3
act [1] 109/22
acted [2] 3/24 146/15
acting [4] 30/4
116/19 116/24 117/14
action [9] 51/22
80/17 86/24 93/5 93/9
123/8 123/15 148/22
154/1
actions [3] 94/19
123/13 154/16
actively [4] 54/6
67/13 68/12 79/12
activities [3] 79/12
79/17 79/19
activity [2] 52/12
85/17
actual [4] 29/22 57/4
78/4 97/13
actually [25] 14/14
19/11 22/4 23/16
36/22 38/3 73/25 78/7
95/11 104/13 115/6
118/15 131/8 132/10
134/16 135/8 143/1
144/4 156/1 161/19
167/15 169/6 173/4
180/4 184/7
add [6] 6/1 7/15 8/9
31/20 92/4 183/1
added [6] 16/11
25/13 27/22 29/16
92/8 136/11
addition [1] 152/4
additional [3] 78/18
163/21 174/25
address [5] 6/7 7/21
46/15 76/14 126/9
addressed [3] 74/5
118/11 175/10
addressee [1] 118/14!
addressing [1]
152/12
adds [1] 127/11
adequate [1] 32/8
adjourned [1] 187/25
Adjournment [1]
106/15
admin [1] 82/21
administration [3]
39/14 121/17 148/2
administrative [1]
94/5
administrator [1]
146/15
admit [2] 57/6 133/1
admitted [3] 57/22
58/4 65/14
adopted [1] 85/14
adoption [1] 78/10
advantages [1] 92/16]
advertised [1] 166/3
advice [6] 2/17 74/10
109/9 109/9 145/10
145/13
advise [1] 122/4
affect [5] 11/13 75/16)
126/20 137/14 155/6
affected [5] 87/10
147/19 147/21 153/11
169/22
affecting [5] 43/10
44/16 97/2 97/12
101/2
affiliation [1] 113/3
afford [1] 147/6
afoot [1] 28/22
afraid [1] 124/14
after [34] 2/11 27/9
41/20 47/8 48/12
48/20 48/22 49/6
49/13 58/6 58/11
58/13 58/19 60/16
60/25 101/17 101/20
114/16 117/9 119/9
135/24 139/24 145/14)
146/21 152/5 160/21
170/12 174/6 178/15
179/2 179/7 179/13
179/19 182/8
afternoon [5] 84/14
95/5 106/17 145/24
187/12
afterwards [1] 58/18
again [18] 15/6 23/20
28/16 33/20 34/11
57/9 61/3 85/1 101/16
128/20 130/16 142/18}
143/24 151/12 152/22)
161/16 164/1 181/5
against [19] 2/4 2/7
28/9 28/19 28/23 60/7
60/14 60/25 64/24
86/24 93/11 93/12
109/1 147/15 161/14
162/8 163/12 179/9
179/12
agenda [2] 153/20
174/25
agents [3] 66/22
67/21 68/4
aggressive [5] 103/5
103/15 104/1 181/16
181/21
ago [6] 7/4 32/13
57/19 68/16 93/3
134/3
agree [28] 9/18 19/19)
19/24 20/3 26/10
26/14 26/21 27/5
27/14 27/16 27/19
27/23 28/5 28/8 32/22)
33/4 79/19 82/22 88/4
88/5 102/4 102/7
102/13 116/20 120/20)
125/2 125/6 127/15
agreed [28] 19/15
28/1 29/5 29/8 33/3
33/17 34/14 102/10
116/17 117/2 144/10
144/12 152/3 152/4
152/7 152/10 155/19
161/24 162/5 163/22
164/5 164/16 164/18
164/25 165/24 166/2
171/13 174/7
agreement [13] 50/8
72/6 73/11 75/19
79/10 80/2 80/15
80/20 81/15 90/16
90/23 91/12 164/17
agreements [3]
43/24 50/18 66/6
ahead [2] 89/17
185/18
aid [1] 80/5
(49) 459 - aid
A
aimed [1] 156/23
airport [5] 166/22
167/10 167/19 168/3
17118
Alan [38] 86/3 96/18
111/20 111/25 112/10}
112/12 112/17 113/9
113/19 114/3 116/16
118/19 121/13 124/23)
125/5 126/7 126/25
127/21 129/6 129/15
129/24 129/25 131/20}
132/9 132/16 133/23
139/8 139/11 140/12
141/1 148/23 150/3
158/3 163/19 178/2
183/16 183/22 184/18
alerted [1] 101/1
aligned [3] 66/10
67/5 69/18
all [66] 1/20 2/23
2/25 5/20 12/14 17/6
17/15 18/11 18/22
19/6 23/21 24/5 24/5
26/19 28/14 30/7
30/22 31/23 32/12
32/14 32/23 34/4
34/20 35/17 36/15
36/18 36/24 43/24
77/14 80/18 90/6
93/25 94/4 97/24 98/6
100/7 105/5 105/21
106/13 112/14 118/6
125/22 133/15 134/6
134/9 137/11 146/3
153/13 161/9 163/8
168/15 172/6 175/16
176/23 178/3 179/3
179/23 179/24 180/20)
181/14 184/16 185/13
186/5 187/5 187/15
187/20
allegation [1] 138/14
allegations [2]
145/11 145/16
alleged [3] 58/6
85/14 85/21
alliance [2] 118/15
123/1
Alliance’ [1] 85/25
allow [1] 99/14
allowed [5] 51/21
55/15 59/10 59/20
152/6
allowing [3] 68/11
90/23 169/25
almost [7] 46/8 78/25
86/23 103/16 108/25
112/2 124/25
along [1] 72/10
alongside [2] 55/12
103/18
already [6] 5/18
90/17 120/25 123/24
144/22 145/9
also [27] 5/16 5/20
32/19 55/5 56/3 59/2
70/22 70/24 72/20
76/5 85/7 90/15 93/19)
96/12 97/2 98/22
102/13 103/4 110/11
125/5 130/24 131/13
137/12 142/3 143/17
178/5 178/14
alter [1] 14/23
although [2] 68/15
140/14
always [10] 46/20
49/9 57/22 104/1
109/3 131/10 131/11
133/23 151/3 154/13
Alwen [6] 118/22
118/25 119/2 128/18
133/21 134/11
am [17] 1/2 15/18
17/16 23/18 27/5 32/3
37/3 37/5 72/9 92/20
94/16 124/1 129/21
131/23 133/17 176/14)
187/25
amalgamated [1]
184/22
amend [1] 29/20
amending [1] 31/16
amendment [8]
22/25 23/1 23/5 23/13
23/15 23/17 23/21
23/25
amendments [3]
22/18 24/5 24/8
ammunition [1]
181/9
among [1] 187/1
amongst [3] 57/4
186/24 187/8
amount [3] 52/24
78/4 120/19
amounts [4] 52/24
133/8 174/18 175/21
analysis [5] 5/23
6/17 135/12 135/13
135/14
Andy [21] 40/7 45/11
45/17 46/8 56/21
70/20 76/16 83/1
83/13 87/23 97/5
98/10 98/13 101/6
101/20 142/5 142/6
142/13 143/8 143/10
143/25
Angela [10] 142/4
142/15 147/8 168/17
168/23 168/24 168/25)
169/1 170/19 178/5
anger [1] 183/11
annotated [1] 9/4
announced [1] 182/5
annual [2] 78/20
133/10
annum [3] 78/3 78/19}
78/21
anomalies [2] 120/5
120/17
another [10] 21/12
21/13 46/11 65/7
69/24 82/22 101/1
180/19 183/12 186/22
answer [16] 1/20
1/24 2/2 2/10 2/10
26/22 76/1 82/17
83/11 125/21 134/6
134/9 136/21 151/11
175/6 177/8
answered [4] 124/11
145/9 174/21 176/11
answering [3] 1/14
2/13 106/7
answers [2] 1/15
48/3
Anthony [16] 37/8
37/11 37/16 151/5
151/14 153/10 153/13
159/2 159/5 159/6
159/9 159/21 163/11
165/17 172/2 188/6
any [111] 1/25 2/6
2/8 2/8 2/11 15/16
23/10 23/24 34/17
34/18 36/13 39/24
48/14 48/21 49/1 49/5
49/14 49/14 49/16
49/17 50/9 53/6 53/13)
53/21 54/8 54/18
54/22 56/17 57/1 58/6
58/12 60/4 60/11 63/7
63/7 71/4 75/12 76/14
77/14 81/7 82/2 82/3
82/17 83/9 83/10
88/24 89/3 89/13
89/14 94/24 94/24
97/19 99/13 100/24
103/24 104/2 105/24
109/3 109/9 109/15
113/25 115/1 116/9
118/3 120/8 120/10
122/4 122/23 123/18
123/22 124/10 125/8
127/18 127/19 128/8
130/21 133/15 133/18}
134/10 134/18 134/22
135/21 135/22 138/10
140/8 142/9 144/25
145/2 146/25 147/18
148/12 150/19 152/5
152/11 152/23 153/12
157/5 157/7 157/9
157/23 158/25 165/25)
169/5 170/25 172/5
173/17 176/7 180/15
183/19 184/15 186/24)
anybody [3] 66/3
75/11 147/5
anybody's [1] 18/12
anyone [4] 2/1 2/18
158/22 171/3
anything [37] 12/12
14/5 14/6 14/24 17/5
17/14 17/15 18/12
26/5 26/17 28/3 31/5
31/20 32/23 34/2
34/19 46/9 88/11
90/18 90/24 96/2
98/17 98/21 113/15
138/5 138/24 147/4
149/20 150/24 151/15)
151/18 161/4 170/4
175/18 177/18 180/12}
184/24
anyway [1] 177/1
anywhere [1] 132/2
AOB [2] 153/25
154/17
apart [2] 74/2 84/23
Apologies [3] 48/6
49/7 166/15
apologise [2] 117/12
187/15
apparent [1] 161/22
appeal [8] 59/15
59/15 60/4 143/23
144/2 145/7 145/14
159/3
appear [5] 17/7 23/10)
61/2 75/2 109/12
appeared [7] 38/19
102/10 131/25 132/13}
132/15 150/18 150/22
appearing [2] 26/12
150/23
appears [6] 68/1
72/18 73/10 86/17
163/11 168/1
appendix [1] 122/1
applicant [6] 156/23
156/24 160/20 160/21
163/9 163/22
applicants [1] 164/12
applicants’ [1] 169/5
application [7] 166/4
182/1 182/4 182/5
182/10 183/4 183/8
applications [1]
181/24
applied [3] 51/10
51/15 110/4
applies [1] 58/17
apply [2] 51/25 58/11
appointed [1] 146/14
appointing [1] 159/9
appointment [3] 40/1
116/17 147/1
appreciate [2]
143/21 167/24
approach [15] 68/23
70/20 71/5 72/18
85/13 88/18 115/18
120/15 120/16 141/8
142/9 142/20 142/22
150/5 162/2
approached [7]
68/22 70/17 70/23
71/5 71/6 72/11 86/6
appropriate [2] 1/19
2/23
appropriateness [1]
147/1
approval [1] 185/4
April [1] 85/13
arbiter [1] 80/5
Arbuthnot [13]
112/19 114/4 114/12
116/13 117/10 121/14)
124/18 124/19 127/2
135/6 140/12 141/2
170/8
Arbuthnot's [1]
112/17
are [119] 2/8 5/11 6/2
6/14 7/16 8/1 8/19
9/10 9/13 9/24 12/7
16/8 16/10 16/12
16/12 17/11 20/24
21/1 22/20 23/10 24/8}
25/5 25/7 25/13 25/14)
25/24 26/13 27/11
29/14 34/7 34/9 34/23}
35/4 35/20 36/11
38/24 47/2 47/15
47/20 48/14 49/21
55/9 56/8 57/5 57/6
57/9 58/22 60/20
60/20 61/6 67/4 69/12
69/21 71/4 72/8 73/18)
73/20 75/4 75/16 77/6I
78/25 79/8 79/12
79/14 80/8 80/9 82/24
83/4 83/5 83/22 86/15]
86/25 89/7 92/16
93/20 94/12 98/3
102/5 102/8 103/20
103/21 104/7 104/13
105/21 105/22 106/19
107/21 107/23 108/8
109/15 118/15 118/20)
122/4 123/19 124/24
127/1 127/14 129/16
136/25 138/20 138/21
143/16 151/7 151/25
152/24 157/24 158/9
166/5 168/18 169/23
171/24 172/16 174/2
179/23 180/4 181/1
185/1 185/5 185/6
area [10] 43/15 43/21
44/5 44/16 44/19
55/16 72/16 87/19
94/9 99/19
aren't [2] 10/18
(60) aimed - aren't
A
aren't... [1] 186/20
argue [1] 66/24
arise [3] 2/18 2/20
97/19
arising [2] 89/15
127/5
arose [2] 130/23
169/8
around [15] 9/1
56/25 59/12 67/11
80/2 94/8 95/16 96/19
100/22 118/23 129/1
141/7 158/25 167/21
186/14
ARQ [2] 6/17 13/4
ARQs [6] 7/24 24/14
24/16 24/23 25/1
29/16
ARQs' [1] 5/17
arrange [2] 7/8
175/11
arrangement [6]
72/22 78/22 80/22
85/6 91/2 178/25
arrangements [2]
73/8 75/4
arrive [2] 105/4
157/14
arrives [1] 166/16
as [248]
ascertain [1] 173/4
aside [2] 27/2 144/2
ask [43] 2/9 3/6 4/8
4/13 28/16 36/11
37/14 37/23 43/22
48/2 53/16 75/22
88/10 88/11 89/2 99/2
103/7 107/3 107/9
107/16 107/21 108/1
112/25 115/15 118/16
119/15 128/17 129/25}
132/4 136/6 143/11
144/14 144/15 151/6
151/11 174/22 175/25
177/16 180/19 183/15}
185/3 185/7 185/15
asked [31] 11/10
16/5 24/17 26/6 48/15
50/5 55/3 56/20 83/8
88/24 91/25 94/25
102/9 115/17 128/7
128/25 132/23 144/17)
151/14 153/10 163/8
172/2 174/3 174/9
175/6 175/9 177/6
185/24 186/4 186/9
186/22
asking [9] 6/7 7/19
25/15 38/16 56/14
125/22 133/8 173/9
177/17
asks [1] 175/4
aspect [1] 182/3
aspects [3] 38/18
98/4 111/15
assertion [6] 46/23
49/4 49/7 49/8 49/12
49/17
assist [12] 20/5 35/7
48/3 55/3 56/12 56/15
56/15 62/11 70/16
83/23 147/7 159/10
assistance [4] 56/6
56/9 60/9 124/13
assistance’ [1] 5/8
assistant [19] 3/17
39/4 40/12 45/8 45/13
45/14 50/24 57/14
57/15 61/18 62/24
65/9 70/3 83/12 83/13
83/15 83/24 94/3 98/8
assistants [1] 60/15
assisting [2] 2/22
145/5,
assists [1] 176/24
associated [3] 14/20
152/5 152/11
association [7] 65/23)
77/5 77/7 77/11 82/16
103/3 118/17
assume [3] 55/2
74/23 163/15
assumed [1] 128/5
assuming [2] 61/4
74/23
assumption [3]
54/24 128/9 162/2
assure [1] 36/9
at [341]
at page 8 [2] 136/24
153/25
ATMs [4] 138/1
attach [2] 6/17 18/20
attached [10] 5/9
10/9 13/18 18/17 19/5)
20/17 21/3 33/10
76/24 79/6
attaching [1] 22/10
attachment [8] 12/20
12/22 17/23 19/16
21/8 21/11 22/5 22/11
attempt [6] 32/16
85/19 113/5 149/11
149/13 162/3
attempted [1] 155/21
attempting [2]
150/19 171/4
attend [2] 45/22 63/8
attendance [3]
154/10 163/5 172/13
attended [3] 141/22
142/1 142/3
attendees [1] 153/20
attending [2] 107/1
118/21
attention [1] 87/6
attitude [1] 122/20
attributable [1] 43/7
attributed [1] 29/8
audit [13] 24/16
102/19 102/23 102/24]
104/19 104/20 104/25
105/1 105/3 105/5
105/5 105/18 105/19
Auditors [3] 102/11
103/6 103/8
augmented [1]
136/10
August [2] 138/23
1441/7
Aujard [18] 148/10
149/19 149/23 150/6
150/18 150/24 151/1
151/10 151/14 151/20
152/23 153/12 153/13
161/4 167/17 172/8
173/6 174/14
Aujard's [3] 154/3
156/6 165/15
author [1] 79/21
authority [5] 83/25
148/14 156/3 156/4
156/11
available [2] 46/13
171/19
avenues [1] 80/18
avoid [1] 161/18
award [1] 179/12
aware [49] 40/21
45/25 46/9 46/10
48/14 53/25 54/15
58/25 61/14 61/17
62/13 62/15 62/16
64/11 64/16 71/7 72/8
72/9 72/15 84/18
84/24 91/5 94/12 96/9
96/10 96/10 96/12
97/24 101/18 111/17
111/22 111/23 112/3
124/14 127/25 128/2
128/7 131/23 132/1
139/13 139/15 145/10}
145/15 145/18 145/19)
145/22 146/19 147/11
184/17
awareness [3] 64/3
64/5 87/17
away [4] 91/15 91/16
133/25 148/10
back [48] 7/8 8/23
10/11 12/8 16/1 24/11
30/13 31/22 39/15
48/7 53/11 56/13
56/18 57/17 57/17
61/3 61/9 64/16 74/3
87/3 87/4 90/17 90/24
110/12 113/5 119/14
120/21 129/12 131/3
132/19 132/20 133/3
133/6 133/24 134/3
134/13 135/19 144/13}
148/5 148/11 153/7
154/9 167/14 168/11
171/20 171/21 173/23}
184/8
backdoor [1] 139/5
background [6]
45/19 89/6 109/17
115/18 142/12 159/10}
backward [1] 125/11
bad [1] 135/18
badly [2] 58/15
168/13
Baines [1] 13/17
Baker [5] 67/25 68/8
100/13 100/25 101/6
Baker's [1] 100/16
balance [10] 25/21
41/11 41/13 47/18
52/23 55/13 59/8
105/2 105/6 105/7
balances [2] 42/8
477
balancing [15] 40/25
41/4 41/6 41/12 41/15)
41/18 42/3 42/17
42/20 43/2 46/6 63/6
64/6 65/4 65/5
ball [1] 135/18
bank [5] 8/6 25/22
138/2 172/23 186/19
bank.' [1] 17/2
banking [8] 6/2 7/6
7/16 8/4 14/3 16/24
25/8 31/25
Barbara [6] 108/17
108/19 108/21 108/25}
109/2 186/21
bargain [4] 75/17
130/21 161/8 161/15
bargained [1] 161/17
bargaining [10]
73/16 75/10 92/2 92/2
92/6 92/12 92/16
92/22 102/3 102/7
barristers [3] 179/20
179/25 180/9
based [10] 20/22
46/23 49/5 60/20 67/3)
86/13 122/19 122/20
125/17 161/7
basic [2] 50/11
126/17
basically [2] 62/18
143/18
basis [14] 46/8 49/11
49/23 60/23 66/16
88/7 89/16 98/25
99/22 110/1 165/22
177/12 179/21 179/22)
Bates [9] 86/3 86/5
96/18 118/19 140/12
141/1 148/23 150/3
184/18
battle [1] 165/21
BDO [9] 110/16
110/22 110/22 110/24I
110/25 184/10 184/14)
184/21 184/22
be [216]
bear [3] 38/4 88/1
152/19
bearding [1] 167/10
bearing [5] 65/2
69/16 129/20 130/19
179/23
beast [1] 102/5
became [9] 72/5
84/23 110/5 110/8
111/6 111/24 112/1
140/23 141/15
because [84] 8/16
11/25 20/2 27/24
30/20 32/7 34/1 34/2
34/16 34/25 35/6
36/16 48/22 48/25
54/5 54/12 61/21 62/3}
63/19 64/1 65/5 65/15
66/5 66/13 71/6 72/16
73/21 77/18 82/18
83/11 83/21 86/25
88/6 91/17 92/25 93/6
93/7 93/8 95/18 96/3
96/10 97/25 100/13
100/23 108/13 108/19)
4111/7 111/12 124/5
124/9 127/21 128/10
131/21 133/17 135/18)
136/19 137/9 137/17
138/4 140/13 143/17
147/24 159/18 159/20)
160/24 161/15 162/19)
162/20 165/13 168/9
168/10 169/3 169/22
170/14 170/21 176/9
180/12 180/24 181/8
182/12 182/14 182/22)
183/5 184/21
become [1] 84/24
becoming [3] 18/25
108/18 187/9
been [136] 6/8 8/7
11/19 11/22 11/24
13/3 13/9 17/2 18/10
22/16 22/18 25/22
25/23 26/12 28/9
28/17 28/25 29/2 30/4I
30/5 30/15 30/23
32/18 34/20 39/17
40/15 41/15 44/23
44/25 47/13 49/11
50/19 50/25 51/8
53/24 54/4 55/1 56/11
56/17 57/4 59/12
60/13 61/17 62/1 62/3
62/5 62/13 62/15
(61) aren't... - been
B
been... [88] 62/16
62/17 62/18 64/9
64/12 64/15 67/9
67/12 70/20 73/13
73/23 74/14 74/16
80/19 85/16 85/17
86/1 86/2 86/13 86/16
86/18 94/8 94/9 94/18
96/1 98/22 99/8 101/1
101/7 102/3 102/12
103/14 105/15 108/7
108/8 108/23 108/25
109/3 109/11 114/6
115/9 117/20 123/24
124/10 125/22 125/25
129/18 129/19 129/20}
129/23 130/3 130/4
130/24 131/13 131/19
132/7 132/8 132/18
133/23 134/4 138/14
139/18 141/12 143/15}
144/15 144/22 160/19
161/15 166/3 168/12
168/22 169/4 170/18
170/22 171/1 171/17
175/7 175/9 178/4
178/7 178/21 179/1
180/2 180/23 182/12
182/16 183/8 186/18
BEER [6] 1/11 3/2
28/12 36/21 183/17
188/4
before [68] 1/12 1/20
4/8 18/16 19/3 36/24
38/19 41/15 46/6 47/7
47/12 50/1 50/22
51/21 57/8 60/16
60/21 85/4 86/9 87/19
88/10 88/24 94/13
95/11 105/4 107/8
108/1 108/4 108/10
111/24 111/24 112/12)
112/12 114/6 115/3
118/10 119/1 119/2
119/6 119/9 119/11
122/11 127/24 128/15)
128/22 130/1 130/21
134/16 134/25 135/1
135/4 135/5 135/12
135/22 142/7 142/16
146/13 156/6 156/14
158/18 167/7 176/14
179/4 180/19 182/11
183/23 184/4 187/12
beg [2] 89/14 136/5
began [1] 110/2
beginning [5] 10/21
16/8 25/5 129/1 151/5
behalf [13] 37/14
55/21 75/13 75/15
75/17 75/23 82/14
91/3 92/17 95/9
108/16 113/16 141/3
behaviour [2] 103/7
109/5
behind [3] 95/6 108/6
146/23
being [69] 5/11 12/22
14/7 14/21 21/24
22/21 26/5 29/8 40/22
42/12 44/13 45/18
50/4 50/23 53/14 54/9)
54/17 55/3 56/4 57/8
59/14 63/25 64/4
69/18 74/20 76/1
77/20 80/21 82/15
84/19 87/15 92/18
93/6 93/13 96/22
96/25 98/20 100/18
100/24 115/18 115/25)
117/19 123/23 123/24}
125/16 128/2 130/22
131/17 132/11 134/10)
138/4 146/14 149/5
153/11 154/5 155/8
160/21 160/22 161/22)
162/25 165/21 169/11
169/20 170/4 170/5
172/18 176/11 183/4
184/13
belief [6] 13/6 38/13
54/14 103/19 107/22
109/1
believe [30] 8/18
10/22 31/12 69/23
75/18 77/10 86/2 92/8
108/20 117/14 119/10
126/8 126/9 128/24
130/13 130/17 131/4
133/23 135/5 135/10
135/25 138/8 139/7
141/21 145/13 147/21
152/17 160/25 171/15)
173/10
believed [3] 81/13
81/17 108/19
Belinda [8] 146/14
146/20 147/1 147/4
147/25 148/1 151/4
164/19
belongs [1] 164/21
below [4] 7/1 8/16
51/10 107/18
beneath [1] 10/4
benefit [3] 160/20
169/24 179/6
best [7] 14/13 38/13
44/21 60/12 107/22
125/21 168/20
better [13] 44/2
47/10 51/24 55/25
56/5 66/17 73/2 73/15
73/18 73/20 93/1
93/11 109/12
between [30] 3/24
27/20 29/19 33/21
39/5 54/13 67/2 69/2
69/4 69/5 69/5 69/6
69/12 69/13 69/15
69/25 72/7 74/22
76/23 77/7 78/5 82/2
83/9 120/8 121/1
121/3 121/14 121/21
132/16 175/11
beyond [2] 131/24
174/12
bias [1] 182/23
ig [2] 25/4 169/25
bill [1] 183/24
Billy [1] 70/21
Binder [4] 184/22
Binder Hamlyn [1]
184/22
bit [9] 6/22 9/1 14/1
14/11 30/8 30/16
30/18 30/21 81/3
bits [1] 11/16
black [1] 33/25
blame [5] 17/13
27/13 29/7 31/10
108/18
blocked [1] 151/15
blue [4] 177/24
board [3] 110/5
132/16 166/8
bodies [4] 71/2
105/14 124/13 154/4
body [5] 91/3 91/7
91/10 91/23 92/21
body/trade [1] 91/7
Bogerd [6] 142/5
142/15 168/24 168/25]
169/1 178/5
Bogerd's [1] 147/9
bold [1] 7/13
Bond [3] 143/6
165/10 184/13
Bonn [3] 166/22
167/19 168/3
bonus [1] 159/17
bonuses [1] 133/9
book [3] 83/23 87/20
97/22
Boris [1] 183/25
both [11] 16/14 26/22)
47/8 47/9 70/5 70/7
85/22 87/10 91/18
124/23 162/2
bottom [20] 4/24
5/15 10/13 24/2 67/16
78/8 129/5 129/14
138/18 141/11 144/18
154/15 161/21 163/25}
166/18 169/3 170/21
171/23 174/24 175/5
bought [1] 60/25
box [2] 67/20 67/25
boxes [1] 23/11
brackets [3] 27/22
31/3 31/8
Bracknell [1] 139/9
branch [26] 5/21
6/13 41/7 42/25 43/14)
44/9 44/19 44/24
49/21 53/1 59/9 59/11
85/11 85/12 86/4 90/3,
94/14 103/12 103/19
103/20 103/25 104/18
104/24 105/14 110/15)
138/25
branches [11] 39/13
41/3 42/1 42/16 43/11
44/15 93/21 94/1
95/14 103/11 137/15
brand [2] 134/8
151/19
breach [2] 80/20
145/17
breached [1] 145/12
break [14] 36/16
36/21 36/24 37/4 84/4
84/8 84/12 85/4 87/19)
106/9 145/24 146/6
156/14 176/20
Brian [2] 6/23 13/16
Brian's [1] 6/16
brief [2] 8/2 45/15
briefing [3] 119/4
144/4 156/25
briefings [1] 99/20
briefly [1] 40/8
bring [17] 71/9 81/23
101/21 111/3 115/6
118/8 120/23 124/16
126/5 128/18 129/4
132/20 141/24 148/17)
151/22 155/11 166/11
bringing [3] 64/8
64/17 87/6
broad [2] 149/8
173/16
broadly [3] 49/20
116/4 117/23
broke [2] 186/10
186/12
broken [1] 174/10
brought [7] 60/8
60/14 64/4 64/13
100/24 108/7 175/20
BT [1] 70/24
bubble [2] 101/11
180/13
bubbled [2] 101/9
101/18
budget [3] 78/19
136/19 152/8
bugs [6] 35/18 131/5
131/6 131/7 131/7
137/4
build [2] 45/7 134/8
building [1] 165/12
bullet [8] 10/9 10/13
77/25 78/17 79/9
80/10 168/16 168/23
bullying [1] 103/5
bumped [1] 166/21
bumping [1] 168/3
bundles [1] 148/2
burden [1] 88/1
burial [1] 115/5
business [12] 66/17
77/13 77/13 7/15
77/22 91/22 93/9
105/4 108/17 111/9
111/13 112/6
businesses [4] 66/21
80/3 98/9 102/5
but [155] 4/12 5/2
5/23 8/24 14/3 14/6
15/13 15/17 17/21
18/5 18/24 20/1 22/4
25/3 26/3 26/16 26/25]
28/3 28/14 29/2 29/20)
30/11 30/15 30/24
31/4 32/3 32/11 33/18)
35/10 36/9 41/20
42/11 44/12 46/5 49/1
49/19 51/12 54/22
56/17 57/5 57/15
58/18 58/19 60/22
61/3 61/10 61/25 63/7
64/13 68/10 69/5 69/5I
70/10 70/19 71/7
72/15 72/25 73/23
78/7 79/13 80/10
80/22 81/21 83/5 84/5I
85/18 89/16 90/8 91/5
91/11 92/6 93/4 93/19
96/17 98/13 99/4
101/9 101/17 105/10
105/15 108/1 109/13
111/20 111/25 112/3
112/21 113/4 114/21
115/4 115/13 115/21
118/12 118/15 119/5
119/10 119/12 123/3
124/2 124/4 126/9
126/19 128/10 128/16)
129/13 131/5 1314/7
132/1 133/8 133/16
134/2 134/6 134/24
138/2 138/3 139/8
143/18 143/22 144/12!
144/15 147/10 147/22)
149/1 151/4 151/13
152/8 155/9 161/1
161/5 161/13 161/18
162/25 163/22 165/3
165/11 165/19 166/11
167/23 167/25 168/4
169/18 170/13 170/24I
172/9 172/24 173/10
173/12 174/2 174/17
176/20 177/17 180/14I
181/5 182/24 184/23
185/15
buy [1] 111/10
(62) been... - call
Cc
called [15] 43/20
44/7 47/4 49/21 49/22)
57/12 59/8 67/21
82/25 92/5 131/7
141/18 146/20 161/25)
184/9
calling [1] 187/5
calls [2] 112/24
153/23
came [14] 18/19 19/4
63/25 67/6 70/13
124/1 128/22 150/23
151/1 151/20 154/13
159/25 174/22 180/17)
Camelot [1] 172/23
campaign [4] 86/7
87/18 113/12 124/8
can [181] 1/3 1/5 1/5
1/6 3/14 3/14 4/14
4/17 4/18 4/19 4/23
4/23 6/1 6/3 6/11 6/21
7/11 7/17 7/22 9/7 9/8
9/9 9/16 9/17 10/19
10/21 13/12 14/7 15/5)
15/19 15/22 18/14
18/18 19/3 19/8 20/6
21/3 21/6 21/18 21/20
21/22 21/23 22/1 22/2
22/4 22/6 22/10 22/19
22/22 22/23 22/25
23/2 23/3 23/5 23/9
23/13 23/21 24/11
26/15 26/25 27/8 27/9
27/17 27/18 27/23
28/3 30/22 31/20
32/12 32/15 33/5
33/23 35/2 35/9 36/4
36/8 36/8 36/9 37/6
37/10 37/23 38/7 44/3
47/16 47/22 48/2 56/1
62/11 62/22 62/22
67/17 68/6 69/19
71/10 71/19 75/13
75/13 75/14 75/22
76/19 76/25 79/7 81/2
81/6 81/23 84/14 85/8
86/16 88/18 88/22
91/25 94/17 95/5
101/23 101/24 106/17)
106/18 107/16 107/21
109/8 111/17 112/5
112/16 113/19 115/6
115/15 118/7 118/10
119/15 120/22 120/23}
126/5 131/2 132/19
133/2 133/13 134/15
138/13 141/5 141/24
142/25 143/6 143/7
143/12 144/5 146/2
146/8 146/9 146/11
148/17 148/20 150/7
151/22 153/17 153/25}
154/7 154/7 154/14
154/14 155/11 156/13)
156/15 156/15 159/23)
159/25 163/3 163/5
163/25 165/2 165/4
166/18 168/8 168/17
171/19 173/22 174/24)
175/25 179/12 181/4
183/7 183/10
can't [17] 11/25
18/11 19/6 19/7 22/5
26/9 26/9 30/14
119/10 131/5 133/18
138/1 155/10 157/8
166/5 167/21 174/15
cancelled [1] 176/10
cannot [3] 18/21 76/7I
86/14
capable [1] 145/4
capacity [1] 180/24
card [1] 186/13
care [1] 133/6
carried [3] 102/16
105/10 169/4
carries [1] 64/19
carry [3] 89/18
140/14 146/10
carrying [3] 104/16
119/25 125/19
case [72] 3/9 3/23
4/1 19/12 24/6 29/7
35/2 36/6 55/1 56/14
56/16 57/24 59/24
62/18 63/14 74/1
87/23 91/4 91/19 98/9
100/20 111/18 111/24)
120/1 120/7 120/11
120/14 120/16 123/21
124/11 130/20 130/20)
131/14 132/1 144/18
144/21 145/4 147/7
148/1 154/24 156/9
156/19 156/20 156/21
157/7 157/9 157/12
158/1 158/5 158/10
158/11 158/23 159/11
159/22 160/5 160/6
160/18 160/24 161/12)
161/15 163/6 163/10
163/12 163/24 165/7
165/17 173/17 179/10)
181/6 184/12 184/16
184/17
cases [62] 5/7 5/10
7/25 47/2 47/4 48/14
48/20 48/21 49/3
49/15 49/17 55/4
55/21 57/4 57/7 57/10
57/13 57/19 57/23
58/6 58/10 58/17
60/10 62/17 63/7
63/12 115/19 116/7
116/10 117/20 117/21
117/25 122/22 124/7
131/1 135/11 136/3
136/8 136/9 136/11
147/16 147/22 148/3
148/16 148/16 152/19)
152/20 153/11 155/8
155/13 155/21 157/5
157/17 157/23 157/24
158/9 158/14 158/16
158/24 159/18 169/5
169/21
Casework [3] 3/17
3/19 3/23
cash [2] 39/14 94/4
casting [1] 161/25
Castleton [2] 179/10
184/16
Castleton's [2]
184/12 184/17
categories [2] 66/2
66/4
CATHERINE [3]
106/22 106/25 188/14
caught [4] 57/6
141/12 162/25 165/21
cause [5] 53/5 111/2
131/10 163/22 164/12
caused [9] 28/20
33/2 42/21 43/3 85/15)
113/6 121/7 130/5
132/25
causes [1] 15/4
causing [2] 44/25
126/18
caution [1] 144/22
caveat [1] 116/18
cease [1] 79/3
ceased [1] 48/19
cent [3] 120/18 133/1
180/22
centrally [1] 56/9
centres [1] 39/14
CEO [3] 74/17 132/16}
132/23
certain [7] 54/19
80/23 102/23 115/4
131/9 133/17 170/10
certainly [7] 20/25
34/8 61/4 86/23
100/16 139/8 183/5
Certification [2]
77/16 77/18
cessation [1] 78/10
cetera [1] 84/2
CFA [1] 173/9
Chair [10] 101/13
161/25 162/9 163/8
163/18 174/2 174/9
175/4 175/6 175/9
Chair's [1] 163/17
chaired [2] 146/20
159/2
chairing [1] 147/14
chairman [9] 18/15
18/23 26/23 67/21
68/1 113/9 113/14
159/6 159/7
challenge [3] 91/16
91/21 149/10
challenged [3] 5/11
115/12 115/15
challenges [1] 71/23
challenging [1] 88/2
Chambers [2] 165/10
178/16
chance [2] 168/20
177/14
change [9] 25/21
50/8 81/9 150/5 150/7,
151/2 151/3 151/19
166/6
changed [2] 49/19
59/16
changes [10] 3/8 4/3
4/4 19/11 19/11 22/20)
23/10 36/5 50/10 85/5)
characterised [1]
52/4
charge [1] 161/18
chartered [2] 109/18
110/3
chat [1] 168/4
check [9] 1/5 105/7
116/19 130/22 132/24}
170/25 176/20 184/5
185/6
checked [1] 56/18
checking [3] 116/22
117/2 120/18
Chesterfield [1]
173/2
Chief [1] 110/6
chip [1] 73/16
choice [7] 17/10
27/10 31/4 31/7 31/13)
31/14 31/17
choose [1] 145/7
Chris [21] 148/10
149/19 149/23 150/6
150/18 150/24 151/1
151/10 151/14 151/20
152/23 153/12 153/13}
154/2 156/6 161/3
165/15 167/17 172/8
173/6 174/14
chronology [1] 140/7
circumstances [7]
60/11 68/7 131/12
158/7 158/20 161/9
162/15
civil [4] 184/12
Clacton [1] 166/9
Clacton-on-Sea [1]
166/9
claim [9] 17/12 27/12
31/9 91/10 123/12
156/7 157/1 177/13
181/3
claimant [3] 180/16
183/3 183/8
claimants [9] 156/25
165/20 166/3 167/13
178/21 179/8 180/3
180/24 181/18
claimants' [1] 179/3
clarificatory [2]
16/16 25/15
clarify [3] 38/17
111/17 174/7
clarity [2] 14/25
17/21
Clarke [2] 145/10
145/13
classes [1] 50/7
Clause [2] 152/3
152/4
Clause 4.10.1 [1]
152/4
Clause 4.9 [1] 152/3
clauses [1] 91/7
claw [2] 90/17 90/24
clear [15] 2/5 8/25
14/1 38/25 94/7
123/10 130/16 131/13)
135/4 138/9 140/5
140/15 140/16 151/16
179/11
cleared [1] 164/13
clearer [1] 8/12
clearly [5] 14/7 99/2
143/15 164/11 182/19)
Clerical [1] 94/3
clerk [5] 41/10 45/20
47/11 47/16 56/1
clerk's [1] 52/23
clerks [6] 39/12
47/11 47/15 51/7
82/24 102/17
close [2] 151/17
151/17
closed [1] 15/12
closely [2] 45/21
124/25
closing [1] 105/7
Co [1] 108/9
coalface [2] 44/3
55/25
code [7] 10/2 10/14
29/12 29/21 30/11
32/5 126/18
codes [2] 8/11 9/16
coding [1] 121/4
coercive [1] 109/5
cohort [2] 68/24 76/3
coincidental [1]
166/21
collaborate [1] 70/10
collapse [1] 86/22
collective [10] 50/18
75/9 92/1 92/2 92/6
92/12 92/16 92/22
102/2 102/6
colossal [1] 120/4
(53) called - colossal
Cc
colourful [1] 182/16
come [31] 12/8 18/2
42/11 50/1 54/15
54/20 54/22 56/7
56/25 57/1 72/14
72/19 80/23 91/6
101/13 112/5 112/21
114/16 118/7 119/14
120/22 134/15 140/17)
144/13 148/5 165/2
167/2 170/2 171/19
171/21 180/9
comes [4] 32/2
118/10 129/12 145/3
comfortably [1] 91/8
coming [5] 48/7
62/23 97/9 100/13
153/7
commenced [2] 28/9
28/18
comment [5] 14/4
23/11 28/25 34/12
169/15
comments [4] 13/19
16/9 20/18 33/11
commercial [1]
79/20
commercially [1]
80/14
commissioned [1]
122/14
commissioning [1]
122/15
committee [4] 135/8
144/16 146/20 164/10)
committees [1]
94/13
common [4] 44/3
71/3 71/4 113/4
communicate [2]
70/9 125/8
communication [13]
39/4 39/18 40/4 42/5
46/13 48/10 65/20
65/23 68/8 69/25
89/22 103/2 126/22
company [2] 85/20
91/17
comparatives [1]
182/17
compared [1] 133/8
compensate [2]
109/11 143/16
compensation [2]
143/12 143/19
competent [1]
158/20
complainant [1]
116/9
complainants [3]
114/23 115/24 141/20)
complaining [1] 65/4
complaint [4] 62/25
136/3 136/7 144/6
complaints [5]
114/13 122/18 123/7
125/15 141/18
complete [3] 121/17
155/10 171/10
completed [3] 120/1
144/19 182/11
completely [2] 97/17
132/13
completes [1] 36/20
completion [1]
148/16
complex [1] 126/22
complexity [1] 174/3
complicated [1]
173/7
compromise [2]
81/14 144/15
compromised [3]
81/13 82/10 144/11
compromising [1]
82/11
Compton [1] 186/7
computer [13] 11/11
22/7 86/16 113/7
121/9 121/16 121/19
128/10 130/5 131/8
131/14 133/2 149/21
concept [1] 116/1
concepts [1] 121/10
concern [15] 11/19
11/22 11/24 45/2
62/25 85/13 99/18
99/23 125/25 131/19
134/5 152/12 163/17
163/18 163/21
concerned [13]
14/16 17/17 17/20
54/11 59/7 84/22 88/7
92/1 100/2 115/10
133/23 170/18 185/12)
concerning [2]
169/17 184/1
concerns [23] 46/12
65/8 69/25 70/8 82/3
83/10 85/22 87/6 87/9
87/10 100/24 101/22
122/5 122/25 123/18
133/21 134/12 138/14)
146/25 147/19 149/1
153/6 171/24
concluded [1] 72/7
concludes [1] 106/3
conclusion [4] 81/2
137/8 137/10 183/13
conclusions [3]
122/7 136/25 137/7
conditional [2]
178/25 179/21
conditions [6] 66/25
75/16 79/6 80/23
92/14 92/19
conduct [4] 28/20
59/23 104/4 104/16
conducted [1] 105/2
conducting [3] 104/7
104/14 145/20
conference [1] 71/25
confidence [2]
176/20 177/5
confident [1] 119/12
confidential [1]
80/14
confidentiality [1]
80/15
confirm [1] 41/6
confirmed [5] 40/20
41/24 152/6 173/6
1741/5
confirming [2]
138/22 185/17
conflict [1] 138/20
conflicts [1] 80/17
confusing [1] 14/12
confusion [2] 28/11
126/15
connection [3] 27/20
27/23 27/24
consensual [1]
160/16
consequence [1]
81/9
consequences [1]
103/22
consider [18] 2/12
2/22 52/8 66/8 69/15
71/23 75/6 89/13
104/14 114/8 122/3
157/14 158/8 158/23
161/25 163/8 163/23
169/20
consideration [1]
71/11
considered [4] 43/19
47/20 145/3 160/10
considering [2]
20/20 123/15
consistent [2] 26/7
75/2
consistently [2] 30/4
92/7
constitution [2] 85/5
113/3
consultations [1]
128/8
consulted [1] 128/3
contact [6] 3/24 44/8
86/4 109/9 113/25
125/1
contacted [3] 62/17
63/21 63/22
contacting [1]
128/11
contained [1] 85/7
contemporaneous
[1] 167/23
content [4] 38/12
134/23 134/24 134/25}
contents [1] 183/23
contested [1] 181/24
context [11] 4/14 9/1
30/8 32/12 33/18
34/25 35/3 71/19 97/1
127/9 160/20
continue [4] 109/7
136/2 136/13 153/14
continues [1] 108/14
continuing [2] 85/22
138/21
contract [5] 66/18
73/9 87/2 131/11
136/18
contracts [1] 67/2
contractual [3] 66/16
75/5 80/18
contrary [1] 26/21
control [2] 146/24
172/23
controlling [1] 109/5
convenient [1]
129/13
conventional [2]
22/9 22/14
conversation [6]
167/4 167/8 171/17
174/12 176/1 176/2
convicted [1] 161/6
conviction [9] 144/20)
144/23 144/25 145/8
159/21 161/1 161/3
161/5 161/7
convictions [3] 61/15)
145/21 156/15
convince [1] 124/10
cope [1] 181/15
copied [1] 126/10
copy [12] 15/23
19/17 20/12 21/16
38/3 38/5 71/15 76/22,
119/18 126/9 143/5
156/21
Core [1] 185/6
corner [1] 4/24
correct [66] 3/21 4/2
AIT 24/10 25/16 25/17)
32/1 32/24 37/21
38/21 38/22 39/6
39/11 39/16 39/20
40/3 40/18 40/19
40/24 41/16 42/2 46/4
51/1 51/2 60/18 61/10)
61/16 65/12 70/12
71/14 82/11 82/12
83/18 86/7 87/6 89/24,
89/25 92/9 93/22
93/23 94/3 94/10 95/1
95/15 95/24 96/7
107/12 109/19 109/21
112/11 114/5 116/21
117/22 118/24 119/23
124/20 128/24 143/4
143/5 146/17 157/7
163/13 163/14 165/9
167/11 176/6
corrections [1]
139/10
corrective [1] 48/1
correctly [5] 35/18
59/23 62/14 62/15
161/16
corresponded [1]
155/2
correspondence [4]
57/2 74/8 74/19
154/22
cost [2] 120/19 124/4
costs [6] 179/9
179/12 179/16 181/24)
183/1 184/1
coughs [1] 179/15
could [77] 8/17 18/9
20/25 33/2 34/8 34/22)
38/4 46/17 48/2 52/17
56/15 67/19 70/7 71/9I
74/4 78/16 80/5 81/1
81/18 85/1 88/4 91/9
94/23 96/5 96/23 97/2
101/2 101/3 102/12
104/3 106/24 107/3
107/9 111/41 111/2
4111/4 112/2 117/13
118/8 119/16 121/24
121/25 123/4 123/8
124/16 126/5 128/18
129/4 129/4 132/20
134/16 136/23 136/24I
138/18 139/17 141/20)
144/16 148/6 149/12
151/6 160/2 160/3
161/4 164/14 165/22
166/11 171/1 171/23
172/11 172/13 173/17
173/21 176/3 179/23
182/15 182/23 187/7
couldn't [11] 43/5
52/21 59/12 83/12
88/4 97/11 124/4
134/2 158/21 170/20
176/19
Council [6] 67/10
68/14 71/11 82/20
83/5 101/23
counsel [4] 150/1
150/8 178/15 178/24
counselling [1] 109/8I
counter [13] 39/12
41/10 45/20 47/11
47/11 47/15 47/16
51/7 52/22 56/1 63/7
82/24 102/17
countersigned [1]
136/17
couple [5] 56/24 84/6
90/5 101/25 112/23
(64) colourful - couple
Cc
course [8] 18/23
23/19 89/10 119/14
123/7 128/16 160/11
168/5
court [16] 20/25 32/8
34/8 34/22 35/15 90/8)
108/10 111/11 123/5
145/12 145/17 146/22)
159/3 179/11 179/11
182/4
courts [1] 145/1
cover [3] 8/10 32/23
109/15
coverage [1] 98/18
covered [1] 126/8
covering [5] 5/23
32/16 34/13 34/19
155/3
credible [2] 168/19
169/14
credit [1] 186/13
credited [1] 175/21
Crichton [8] 141/1
141/3 141/4 142/4
149/16 150/6 150/8
151/41
Crichton's [1] 141/8
criminal [28] 11/10
32/16 52/12 60/7
60/10 96/4 96/16
97/13 111/15 126/2
131/25 133/15 133/22
134/12 143/23 144/1
144/19 144/23 144/25)
145/1 145/14 156/15
159/18 159/21 160/25
161/2 161/5 161/7
criteria [1] 77/19
critical [1] 124/9
criticise [3] 91/12
92/21 165/19
criticism [2] 93/1
93/14
cross [1] 138/4
Crowe [7] 146/14
146/20 147/4 147/25
148/1 151/4 164/19
Crowe's [1] 147/1
Crown [15] 39/13
41/2 41/10 45/20
55/11 55/11 66/13
94/4 95/14 95/23 96/1
97/20 101/2 101/22
105/1
CRR [2] 156/8 157/16
culminate [1] 87/1
current [4] 78/6
87/11 117/19 117/25
currently [1] 86/4
curveball [1] 162/20
customer [1] 91/21
cut [1] 169/9
cuts [1] 7/10
CWU [75] 39/8 46/20
46/25 49/8 49/17
50/18 53/3 53/13
53/16 54/7 57/4 57/7
57/13 58/20 59/3 60/6)
60/9 63/17 65/9 65/14
67/6 67/12 67/21 68/2
71/21 71/24 72/25
73/10 74/22 75/3 75/6)
75/12 76/10 78/9 81/2
81/10 81/12 81/17
81/22 82/19 85/22
86/4 86/6 86/18 87/9
87/12 87/21 88/1
89/22 89/24 91/19
92/5 92/17 93/19
93/20 93/25 94/14
96/2 96/23 98/12
98/13 98/19 100/13
100/21 100/25 101/10)
101/14 101/21 101/23)
102/12 102/24 103/2
104/15 104/19 105/10)
CWu's [2] 65/8 93/19
CWwuU00000076 [2]
71/9 85/3
D
daily [3] 46/8 88/7
124/25
damage [5] 15/4
90/18 90/25 109/4
123/3
damages [5] 109/11
113/6 133/7 150/21
151/18
damaging [9] 13/21
13/23 14/18 20/20
33/15 33/17 33/20
34/1 35/6
data [15] 6/3 6/17
TINT 12/15 13/4 15/10
60/23 84/20 121/5
126/8 128/6 137/9
138/25 138/25 180/17)
date [11] 23/2 48/20
48/22 67/18 107/4
119/10 129/2 129/12
133/19 153/20 154/8
dated [7] 37/18 38/8
85/2 116/15 117/9
145/11 160/1
dates [1] 141/5
Dawkins [1] 13/17
day [23] 13/13 15/14
48/23 49/23 49/23
70/20 76/16 82/23
82/23 98/25 98/25
103/13 111/12 119/4
142/3 142/21 143/4
143/13 150/13 167/18)
167/25 168/2 187/25
days [1] 6/12
de [1] 182/9
deadlines [1] 51/20
deal [26] 5/13 14/14
29/19 44/3 44/9 44/21
49/16 49/19 49/22
55/21 57/12 63/9
73/18 73/20 81/21
87/24 93/24 97/6 98/1
98/9 98/24 100/23
126/14 133/9 148/6
153/8
dealing [20] 3/16
14/13 42/11 43/9
43/23 49/18 57/10
57/23 58/19 62/17
62/18 63/5 97/19
97/23 101/7 105/16
115/2 142/15 142/17
165/12
dealings [1] 103/24
deals [2] 98/6 99/5
dealt [23] 4/3 42/8
42/23 44/2 44/10 45/5
45/6 52/14 55/22
57/18 59/18 59/24
59/25 60/1 63/15
63/19 65/5 74/7 82/24
83/4 83/5 100/18
182/11
Dear [4] 118/12
debate [1] 163/1
debts [1] 186/13
decade [3] 60/15
60/16 60/21
decide [3] 29/4
158/13 162/9
decided [2] 163/12
183/22
decides [1] 72/1
deciding [1] 165/7
decision [20] 28/24
28/25 29/2 68/11
68/13 73/4 113/16
113/17 157/5 157/8
157/15 157/18 157/22
157/23 158/21 160/5
160/12 162/11 163/9
163/17
deck [1] 143/5
declared [1] 105/8
decline [2] 1/24
160/13
declined [2] 17/2
25/22
deduction [1] 87/3
deemed [1] 80/20
deep [2] 119/25
120/10
defects [5] 35/16
35/19 35/20 125/15
137/3
defence [5] 28/1 35/8
145/5 145/6 181/2
defend [2] 56/6 93/11
defendant [1] 32/9
defendant's [1] 29/7
define [1] 79/13
defined [1] 80/14
definitely [4] 119/5
158/2 168/25 173/1
definition [2] 121/15
127/15
degree [1] 80/10
degrees [1] 47/22
delay [2] 163/21
164/12
delete [9] 15/19 17/4
18/10 26/23 27/6 31/1
35/6 36/1 36/2
deleted [28] 12/14
17/5 17/15 17/22
18/10 18/12 20/2
25/10 25/25 26/10
26/14 26/16 26/17
26/25 27/24 28/3 28/5)
28/8 30/5 30/9 30/24
30/25 32/19 33/16
33/19 35/24 35/25
36/10
deleting [9] 19/20
26/8 27/3 27/14 29/5
32/10 33/25 35/4
35/21
deletion [7] 27/9
27/20 28/17 30/5
33/21 33/22 36/7
deliberately [1]
180/25
demarcation [1] 99/4
den [7] 142/5 142/15
147/9 168/24 168/25
169/1 178/5
denial [1] 26/22
denied [4] 19/19 27/3
58/3 59/13
department [7] 45/24
56/20 56/21 56/22
97/5 132/13 132/14
depend [1] 78/5
depending [1] 56/16
depth [3] 116/7
135/13 170/24
Deputy [5] 39/18
40/1 61/19 83/16
89/23
derail [2] 182/1 183/2
Derby [1] 110/3
derived [1] 78/5
describe [6] 69/9
101/19 111/15 121/10}
167/5 167/7
described [4] 21/3
78/9 101/13 114/18
describing [1]
156/16
descriptions [1]
29/14
designed [4] 47/25
50/16 181/18 182/25
desire [3] 35/14
35/17 186/24
desperate [1] 182/15
despite [1] 98/18
destroy [5] 152/23
153/12 153/15 154/25)
155/6
destroyed [3] 153/1
154/2 154/19
destruction [1]
153/16
detail [1] 74/5
detailed [3] 48/21
90/15 158/6
details [5] 56/14
96/11 129/18 132/7
142/14
determine [2] 75/5
162/14
detour [1] 150/4
detrimental [2] 79/12
91/18
development [1]
155/18
diagonally [1] 95/6
iane [1] 13/17
Dickinson [3] 143/7
165/10 184/14
did [82] 11/7 11/15
12/25 13/22 14/10
18/10 26/23 27/6
28/16 31/1 31/17
34/21 36/1 45/9 45/15
59/17 60/6 65/9 66/11
67/4 70/10 71/15 82/2I
82/17 83/9 84/24
101/21 109/22 109/25}
111/19 113/17 114/10)
116/22 117/12 125/7
127/18 129/25 130/7
131/18 133/5 133/11
134/18 134/22 135/2
135/15 135/16 136/19)
137/20 138/23 139/22
139/25 140/17 146/22!
146/25 148/12 150/24)
152/16 152/17 157/19)
160/15 165/14 165/19}
166/6 167/4 168/8
169/1 169/3 169/11
169/13 170/23 171/7
172/3 172/9 175/18
176/7 178/2 180/9
183/3 183/5 183/19
184/15 186/20
didn't [40] 8/22 11/1
11/13 18/9 19/25
25/11 26/1 30/25 31/7
32/25 34/17 35/25
36/2 49/16 55/7 57/23}
58/11 64/25 66/5 66/5I
68/20 82/18 93/6 96/2
96/3 98/17 98/21
(65) course - didn't
D
101/12 120/16 122/11
126/2 133/16 137/9
137/17 147/4 155/6
difference [10] 22/10
77/22 78/5 121/3
135/21 170/19 170/21
differences [11]
125/22 130/5 130/8
149/17 150/9 162/4
169/6 169/8 169/17
172/20 172/22
different [15] 65/17
102/5 102/8 104/21
104/23 127/2 140/15
140/17 152/7 164/25
166/7
difficult [2] 160/24
177/25
difficulties [5] 41/4
41/17 42/17 44/6 45/1
difficulty [2] 89/11
91/14
diligently [1] 51/25
diminished [1] 95/17
dire [1] 133/25
direct [10] 33/20
39/24 40/5 40/5 54/7
64/24 75/15 94/9
128/11 138/10
direction [7] 1/14
1/22 68/18 91/16 93/8)
149/20 150/23
directly [27] 14/9
20/21 21/8 35/13 43/7
45/19 50/20 51/6
53/13 53/23 54/8
65/21 66/14 66/20
66/21 66/25 70/7
75/14 75/16 75/24
76/2 76/7 77/23 79/3
85/16 86/6 97/20
Director [1] 110/23
dirty [1] 112/2
disagree [2] 160/15
168/22
disagreed [1] 78/13
disappeared [2]
19/25 150/17
disappointed [4]
137/8 137/15 137/17
140/1
disappointment [1]
120/4
disciplinary [3] 51/22)
60/2 86/24
discipline [1] 63/7
disclose [2] 32/25
80/13
didn't... [13] 101/11
157/18 170/23 170/24}
121/14 121/21 131/10)
66/19 67/5 97/18 98/4
disclosed [5] 130/25
145/13 171/8 180/15
184/14
discloses [1] 27/14
disclosure [6] 32/8
147/7 147/15 147/20
161/9 181/24
discovered [5] 110/4
129/20 129/24 130/3
180/12
discrepancies [10]
46/22 47/3 48/12
49/10 50/5 52/4 55/6
63/5 63/6 102/18
discrepancy [4]
51/11 52/8 52/10
59/13
discuss [13] 44/20
45/3 126/2 129/21
129/25 131/18 133/12)
139/22 140/4 155/12
155/21 161/11 169/1
discussed [20] 44/23
46/5 70/14 76/22
116/2 121/11 124/22
130/2 132/10 133/13
139/12 152/2 152/18
154/5 154/6 160/5
170/20 171/15 172/18)
183/23
discussing [5] 102/1
102/3 134/19 163/6
172/19
discussion [21] 71/7
78/9 118/3 120/10
121/21 127/18 134/10)
134/22 135/22 135/25)
148/21 149/4 155/13
155/15 155/25 156/12)
160/11 164/7 165/18
166/1 171/11
discussions [17]
46/1 68/10 71/1 72/24
73/3 73/14 73/19
92/18 140/8 140/11
140/22 140/25 141/4
141/6 165/6 165/23
178/6
disgraceful [2]
182/22 182/25
disingenuous [1]
147/16
dismiss [1] 62/19
dismissal [3] 52/2
53/17 100/3
dismissed [5] 56/4
57/8 58/23 59/15 99/8
displayed [2] 21/15
21/24
dispute [6] 80/8
80/19 93/3 164/13
167/24 170/15
disputes [2] 114/22
159/15
disrupted [1] 93/5
dissatisfaction [2]
68/16 68/18
dissatisfied [1]
100/14
distilled [2] 135/12
135/14
distinct [1] 66/19
distinction [3] 77/6
121/1 127/18
distinctly [1] 67/4
istress [1] 164/12
dive [2] 119/25
120/10
do [130] 1/15 2/9
2/17 2/25 3/9 3/11
5/23 8/9 8/9 11/3
12/25 15/11 15/16
18/2 18/16 19/14
19/18 19/19 19/24
24/2 24/12 26/6 26/21
27/5 27/14 27/19 28/5)
28/8 28/10 28/20
29/20 30/18 32/3
32/13 35/9 36/13 38/1
42/25 44/16 47/11
47/16 47/21 50/2
50/16 55/13 56/6
60/22 60/23 61/17
62/22 64/7 65/1 65/13}
66/12 67/7 68/4 68/6
69/7 69/15 69/20
70/14 71/1 73/11
74/13 75/6 75/13
75/14 75/22 76/9
79/25 82/7 82/13
82/18 83/19 84/24
87/16 87/25 100/17
103/15 103/15 104/14
105/5 108/1 113/23
115/5 115/20 116/4
116/7 117/12 120/8
120/20 121/20 122/8
125/20 127/15 127/17
132/9 133/20 134/10
137/6 137/24 138/1
140/10 140/18 141/14
142/9 143/22 147/10
147/18 154/5 155/14
155/23 156/3 156/4
164/7 166/5 166/7
167/20 168/6 168/9
170/4 172/15 174/12
175/12 176/14 179/7
180/20 184/7 186/20
187/18
doctor [1] 187/9
document [32] 21/12
21/13 22/10 22/15
22/18 76/25 79/2 79/5
88/17 88/23 89/6
89/12 89/15 105/23
118/7 120/22 124/3
134/15 144/5 144/7
144/10 153/16 153/21
154/8 156/14 156/25
158/19 160/4 168/16
documentary [1]
175/14
documentation [8]
148/25 149/2 149/6
155/1 170/25
documents [18]
56/20 56/23 115/11
115/21 148/2 150/15
152/19 152/23 152/24}
153/1 153/2 153/10
153/13 153/15 155/4
155/6 155/8 181/1
does [12] 30/9 49/24
53/16 53/22 60/9 75/1
79/13 90/18 107/6
144/24 158/12 160/23}
doesn't [7] 9/4 10/7
17IT 33/22 91/8
107/10 151/12
doing [10] 1/16 26/3
29/2 56/1 59/15 88/7
104/25 117/4 155/7
185/5
domain [2] 97/10
97/10
don't [73] 10/3 12/12
15/15 17/3 17/8 27/16}
28/24 31/12 31/18
31/18 32/11 33/4
35/10 38/23 48/21
49/1 49/14 49/16
53/21 53/21 54/2
54/11 54/22 62/20
62/21 64/18 64/18
66/8 69/19 69/23
70/15 71/6 74/16
75/19 76/13 76/15
83/6 84/25 88/6 96/5
96/15 98/16 98/21
99/14 103/23 105/24
113/13 113/22 119/2
119/5 126/12 133/11
133/17 135/25 137/10
138/2 138/7 138/10
138/17 139/16 140/3
140/5 151/18 152/17
152/23 165/2 165/19
168/13 171/6 171/15
173/10 173/13 176/22}
done [12] 12/14
17/16 19/2 46/2 71/16}
87/16 108/13 142/11
143/15 161/19 170/13}
180/2
doors [1] 130/20
double [3] 61/2
116/19 176/20
doubt [4] 81/6 99/16
130/10 131/24
171/19 175/25 180/15}
149/15 149/18 150/20)
down [48] 4/25 5/14
6/21 6/22 7/22 9/9
13/13 15/25 16/1 19/8)
20/9 22/13 23/14
23/20 24/25 25/5 33/6
48/3 61/3 61/9 67/19
67/24 79/7 103/18
104/24 112/5 117/13
118/7 119/16 120/22
126/6 129/13 129/16
134/15 148/20 150/20)
151/17 151/25 156/16)
156/17 160/3 163/25
165/2 168/16 171/19
172/14 174/10 182/18)
downloaded [2] 6/3
TNT
DR [4] 106/22 187/6
187/10 188/14
Dr Linnell [2] 187/6
187/10
draft [10] 9/7 12/8
13/19 20/1 20/17 21/5)
33/10 77/3 122/11
140/4
drafted [2] 138/11
149/7
drafting [3] 134/24
138/9 144/16
drafts [2] 130/2
134/19
drama [1] 186/6
drastic [2] 8/19 8/22
drawn [1] 67/18
draws [1] 33/20
Drive [2] 5/13 5/13
driving [1] 113/11
drop [2] 61/3 111/10
dropped [1] 61/9
drowning [1] 182/15
dubious [1] 161/20
due [7] 53/15 53/24
54/4 54/9 86/22 93/7
119/14
during [13] 24/18
40/11 40/22 41/25
45/15 64/7 85/18
95/14 128/1 128/3
145/2 155/13 160/10
duties [3] 142/23
145/12 145/17
duty [3] 63/8 82/13
145/5
E
each [7] 23/13 23/20
29/12 41/10 45/3
47/16 116/7
earlier [22] 30/4
47/17 55/5 58/1 61/21
62/9 63/5 95/25
100/11 101/5 104/11
111/19 112/3 127/4
128/17 128/23 154/17)
(66) didn't... - earlier
E
earlier... [5] 155/6
156/14 165/4 171/25
(77/7
early [3] 109/24
109/25 148/3
earth [2] 170/2
182/21
easy [2] 169/7
177/25
echelons [1] 184/23
education [1] 50/15
educational [1] 50/7
effect [9] 8/5 14/18
15/3 17/1 25/20 81/4
89/6 92/20 181/8
effective [6] 46/20
49/9 50/13 76/6 81/11
81/18
effectively [13] 24/13
24/25 56/10 63/2 75/7,
82/15 92/24 93/14
112/22 113/11 114/23
135/11 148/15
effort [1] 153/1
efforts [1] 67/8
either [18] 35/11
47/18 47/19 52/23
63/24 99/7 99/10
115/2 125/7 125/24
128/20 134/11 134/12)
139/23 160/13 176/15)
176/17 179/1
elected [10] 39/21
45/11 45/12 45/17
45/18 47/12 89/23
97/17 98/3 98/5
Election [1] 85/18
electronic [1] 128/6
elide [1] 91/25
else [12] 2/1 23/7
24/7 31/20 73/17
122/22 132/2 136/21
140/25 147/6 147/23
17113
email [51] 5/7 6/22
6/24 7/1 7/3 7/11 9/15)
10/9 12/20 12/22
15/16 17/23 18/18
18/20 19/5 19/15 20/8)
20/10 21/7 21/17
21/19 21/20 21/23
21/25 22/3 22/5 22/9
22/11 33/5 33/6 34/13,
34/13 56/13 62/10
119/16 119/24 124/17
126/6 126/8 126/11
127/20 129/3 129/5
129/10 129/15 129/24}
131/20 132/4 167/2
167/16 168/1
emailed [1] 12/17
emailing [3] 5/6 6/12
13/16
emails [6] 5/25 6/8
17/18 56/17 57/2
129/11
embarrassed [4]
20/25 34/8 34/22
35/15
embarrassing [1]
35/7
embrace [1] 149/16
emerging [2] 81/22
95/15
employed [32] 39/3
39/7 39/9 39/13 39/17
40/12 41/10 45/20
50/20 51/2 51/6 53/14
53/23 54/8 65/21 66/3)
66/14 66/20 66/21
67/1 75/14 77/24
89/22 94/1 97/20
97/25 98/1 98/7 102/2
102/4 110/1 110/22
employee [4] 42/22
89/21 94/14 147/5
employee's [1] 43/3
employees [18]
40/13 43/11 53/18
60/15 60/25 61/6
61/15 64/24 66/9
66/15 69/16 84/19
90/3 96/1 99/6 101/22
102/6 102/11
employer [12] 50/15
66/3 69/4 69/5 70/5
75/15 75/17 79/4 81/9
91/13 91/17 92/21
employers [5] 69/13
69/21 84/1 92/13
92/18
employment [4]
57/24 92/14 92/19
94/6
enable [3] 18/19 50/3
180/17
enabled [1] 22/20
encourage [2] 157/1
165/17
encouragement [3]
80/15 108/22 167/12
end [14] 12/8 15/14
19/9 21/18 38/1 38/7
41/12 52/22 102/1
105/25 126/21 144/11
172/4 178/2
ended [4] 115/18
115/25 177/23 178/13)
ends [1] 55/23
engage [3] 50/13
92/12 186/25
engaged [5] 66/21
79/12 85/20 110/18
186/23
engagement [5]
85/19 110/2 117/1
117/5 136/16
engagements [1]
72/3
engaging [2] 162/12
163/1
Engineering [1]
65/18
enormous [1] 120/19
enough [3] 61/5
170/1 178/8
enquiries [2] 135/20
138/21
enquiry [1] 25/21
ensue [1] 51/22
ensure [8] 20/24 34/7I
34/21 38/4 88/23
103/21 129/17 132/6
ensured [1] 100/4
ensuring [1] 50/19
enter [4] 72/1 73/11
91/9 139/4
entering [1] 91/12
entirety [1] 19/9
entitle [1] 90/16
entry [1] 121/5
environment [1]
150/15
envisage [1] 116/22
equal [2] 70/4 70/6
Ergo [1] 157/9
error [10] 121/1
121/2 121/4 121/5
121/12 121/22 121/22
137/14 139/5 143/20
error’ [2] 121/4 121/7
errors [19] 35/16
35/19 117/19 118/4
118/5 121/15 125/14
125/17 126/4 126/13
126/17 127/16 130/4
130/22 130/24 131/2
131/4 131/8 139/19
escalated [2] 55/8
63/12
especially [1] 75/3
essence [1] 87/25
essential [3] 179/17
179/23 181/1
essentially [6] 53/3
63/1 78/14 80/21
86/12 93/24
establish [1] 92/15
established [3] 25/14I
40/15 68/2
establishing [1] 53/5
establishment [1]
140/23
et [1] 84/1
etc [1] 169/23
even [9] 15/8 52/9
63/6 96/23 97/12
100/20 133/18 144/21
168/22
evening [2] 47/18
105/3
event [7] 18/25 74/20
178/15 179/2 179/7
179/13 179/19
events [4] 3/16
109/13 109/15 160/22}
events." [1] 8/19
eventually [1] 93/10
ever [4] 19/2 101/21
111/13 176/11
every [11] 50/7 50/7
95/7 109/7 124/2
126/20 151/5 151/13
152/22 154/6 159/22
everybody [2] 93/4
187/18
everyone [3] 97/25
131/7 187/21
everything [3] 96/19
98/1 133/13
evidence [84] 1/13
1/23 2/16 3/6 3/12
3/15 4/12 4/14 4/20
11/11 12/10 14/18
19/10 31/24 32/17
36/15 36/19 36/20
38/15 38/18 40/9
40/21 42/13 43/13
46/2 47/21 48/9 50/21
57/25 58/24 67/9
84/18 92/8 94/7 94/13
94/17 100/11 102/1
103/4 103/11 105/17
107/1 107/24 115/25
116/14 116/16 120/5
122/6 123/5 123/6
123/14 123/20 127/4
128/6 128/23 130/7
130/21 131/21 131/24}
132/2 133/14 137/1
137/18 137/19 137/23
138/5 138/20 139/20
143/24 145/17 158/3
158/22 162/25 165/24}
171/6 175/13 175/14
176/16 178/4 180/1
183/17 184/9 184/12
187/12
evidential [1] 123/17
ex [1] 86/1
ex-postmasters [1]
86/1
exactly [10] 10/5
14/1 20/11 20/11
21/25 52/19 63/17
132/18 140/3 181/11
examination [1]
185/3
examining [2] 38/20
38/25
example [7] 66/24
93/2 105/13 132/12
151/5 152/17 158/9
examples [3] 8/8
15/6 91/19
excellent [3] 107/4
124/23 150/11
except [5] 80/18
123/6 140/3 147/4
156/3
exceptional [1]
158/19
exchange [1] 74/8
exchanges [2] 15/16
19/9
excluded [1] 75/4
exclusivity [1] 75/1
excuse [1] 70/25
executive [22] 43/16
45/18 67/10 68/13
71/11 82/6 82/20
82/25 82/25 83/2 83/5I
83/6 83/14 83/25
87/22 87/23 88/6
97/21 98/5 99/21
101/21 101/23
Executive/UKGI [1]
82/6
Executives [1] 70/23
exercise [1] 147/8
exhausted [1] 80/19
exhibited [2] 117/6
143/3
exhibiting [2] 24/14
24/22
exhibits [1] 24/20
exist [1] 69/15
existed [1] 69/15
existing [1] 148/25
expand [2] 38/17
134/5
expect [6] 45/2 55/7
99/4 100/1 126/13
172/22
expectation [3] 62/8
73/10 73/12
expected [7] 44/23
55/5 62/1 62/2 62/4
62/6 135/13
expensive [1] 120/4
experience [23]
46/24 47/7 48/10 49/2
49/6 49/13 49/16
51/23 52/13 52/25
57/10 57/21 58/12
58/13 58/21 60/12
90/6 103/12 103/17
103/23 115/1 127/21
178/10
experiencing [1]
41/4
expert [5] 117/15
145/12 145/17 159/6
184/13
expertise [1] 14/17
explain [20] 7/25
10/7 18/11 18/18 19/6)
25/1 26/9 50/9 51/17
(67) earlier... - explain
E
explain... [11] 52/17
52/21 77/6 78/4
142/11 150/7 151/6
157/1 165/22 167/13
168/12
explained [10] 6/15
8/21 47/17 63/4 83/11
149/23 149/25 160/19}
173/12 173/16
explaining [2] 6/2
7/16
explanation [13] 8/2
26/24 27/6 27/15
27/21 30/11 32/8
32/15 150/17 165/15
168/12 172/5 173/11
explanations [2] 36/6)
169/8
explore [2] 3/14
49/11
expose [1] 87/18
exposure [1] 133/6
expressed [2] 122/9
139/20
extensive [2] 54/12
140/11
extensively [1]
152/18
extent [7] 38/24
104/2 124/12 127/25
128/2 160/18 180/20
external [1] 114/24
extra [3] 6/1 7/15
126/18
extract [2] 7/1 13/4
extracted [2] 109/10
123/23
extracts [1] 7/3
extremely [2] 115/8
167/3
eyes [1] 47/20
F
face [6] 86/9 161/10
161/11 167/12 168/12)
168/12
faced [1] 123/19
faces [1] 98/2
facility [2] 2/17 42/18
facing [2] 44/21
103/18
fact [14] 11/15 27/5
30/15 54/10 59/17
64/4 75/8 105/8
137/18 138/23 146/22)
171/12 181/7 183/4
facts [3] 107/21
111/23 127/14
failed [1] 172/5
failings [1] 87/18
failure [22] 9/12 9/21
10/8 10/15 13/20
13/22 17/3 19/20
20/19 25/23 26/13
29/22 29/24 30/6
30/10 30/12 30/21
30/22 30/24 33/14
63/8 126/23
failure’ [1] 18/6
failure. [1] 8/7
failures [21] 9/2 9/13
9/24 10/4 17/11 17/19)
21/1 25/24 26/13
27/11 34/9 34/23
34/25 35/4 35/4 35/23)
126/14 127/1 127/12
127/13 127/16
failures’ [2] 8/19
14/25
fair [33] 4/8 42/14
42/19 50/19 51/9
51/13 52/6 55/1 58/18
59/23 61/1 62/21 68/4
70/4 72/22 72/23
80/24 81/15 81/16
86/19 87/7 87/25
88/23 98/12 98/16
100/1 100/6 100/14
111/22 124/6 128/9
156/2 169/15
fairly [4] 31/23 54/19
94/23 159/17
faith [1] 68/20
fall [2] 52/1 77/21
falling [2] 43/19
122/21
falls [4] 74/2
false [4] 126/18
161/8 161/17 161/19
familiar [1] 124/1
families [1] 109/4
famous [1] 184/4
famously [1] 186/7
far [9] 54/10 99/13
126/21 129/20 129/24}
133/13 137/19 171/16)
182/15
fault [7] 33/2 53/6
58/15 63/3 64/1 64/2
131/12
faults [1] 32/17
favour [1] 161/13
feasible [2] 130/10
130/17
February [4] 3/6 3/12
4/20 154/9
fed [4] 101/16
Federation [20]
65/15 65/25 66/7
68/17 68/20 70/1
70/13 72/3 72/12 73/7
73/24 74/11 77/17
79/2 81/7 85/6 90/12
95/10 186/23 187/2
fee [4] 117/2 178/25
179/21 179/21
fee/success [1]
178/25
feedback [1] 178/7
feel [7] 9/4 11/4 18/9
73/15 73/24 168/21
170/23
feeling [3] 143/14
183/7 187/1
feelings [1] 139/22
feels [1] 170/13
fees [1] 179/21
fell [3] 51/15 51/16
66/2
felt [5] 56/4 131/15
137/23 149/7 161/9
Fenny [1] 186/7
few [10] 84/4 112/25
120/2 135/11 136/10
146/10 159/24 172/10
185/14 185/18
field [3] 29/13 105/16
139/19
figure [2] 59/12
185/23
figures [5] 110/8
131/14 172/6 174/9
176/16
file [4] 21/3 167/4
167/5 171/17
filenote [1] 167/7
files [5] 5/9 154/2
154/18 159/19 159/22
filtered [1] 54/25
final [19] 12/2 29/2
35/11 57/3 58/3 68/11
80/10 80/12 86/21
102/9 122/12 130/9
157/4 157/14 157/18
157/22 160/7 176/12
183/15
finalised [1] 31/6
finalising [1] 35/10
finance [2] 82/21
175/12
finances [1] 186/18
financial [8] 8/5 17/1
25/20 41/8 133/25
161/5 161/11 179/13
find [14] 16/20 94/17
103/15 103/16 103/23
116/8 119/10 126/4
133/18 150/9 150/16
159/14 176/3 177/25
finding [2] 135/10
169/6
findings [2] 140/10
156/19
fine [11] 2/20 36/24
84/8 89/8 100/7 106/2
106/13 145/25 177/3
181/12 185/19
finish [1] 185/14
finished [5] 45/8
136/2 136/7 165/12
177/22
finishing [1] 140/14
firm [8] 110/1 110/3
110/13 114/25 184/9
184/19 184/21 184/24)
firms [2] 108/11
178/12
first [55] 8/25 22/21
23/5 23/14 23/16
24/12 38/19 67/8
67/20 74/7 75/22 77/2
79/9 84/24 85/8 88/19
90/5 96/18 107/11
107/14 109/22 110/18}
111/17 111/20 112/18}
112/22 112/23 113/19}
117/19 117/25 119/21
120/13 121/12 122/8
127/4 127/8 127/10
141/15 142/6 142/8
142/15 142/17 149/15}
153/8 160/2 162/19
164/20 164/20 164/21
167/4 169/5 178/3
185/5 186/5 187/5
firsthand [2] 44/4
49/1
firstly [8] 13/22 19/15}
22/19 42/11 74/6
117/14 137/16 174/12}
fit [4] 8/17 73/5 156/9
159/20
five [7] 6/6 45/24
61/7 62/13 135/11
174/19 182/1
Flat [1] 182/21
flight [1] 166/24
flow [4] 156/11
flows [1] 147/7
fluctuate [1] 61/3
fluctuates [1] 61/10
focus [3] 116/10
150/21 182/3
follow [1] 53/22
followed [8] 60/6
74/9 164/5 164/16
164/18 165/1 174/16
181/10
following [13] 5/17
41/4 74/11 81/1
100/10 127/19 137/13}
140/9 140/10 153/15
160/10 175/19 187/25
follows [1] 77/1
foot [1] 21/24
force [1] 180/4
forcibly [1] 87/2
forensic [8] 109/20
109/22 110/15 110/23}
114/25 115/10 116/25]
131/22
forget [2] 110/25
142/14
forgive [4] 48/7 53/18)
81/3 88/13
form [3] 2/4 82/22
180/4
formal [2] 45/23 46/2
formally [1] 75/9
format [3] 22/9 22/14
25/1
formats [1] 47/13
formatting [1] 23/10
formed [2] 82/7
113/21
former [4] 87/10
100/12 113/20 132/11
formerly [2] 102/17
184/22
Forte [1] 110/11
forth [2] 62/22 93/12
fortunate [1] 178/8
forward [14] 4/23
10/20 82/13 114/9
114/11 122/24 134/11
140/13 141/11 165/20)
174/22 177/12 180/8
180/24
forwarded [1] 15/24
forwarding [2] 6/24
22/2
forwards [2] 21/7
170/22
foul [4] 43/19 51/16
51/16 52/1
found [12] 44/6 50/4
103/25 111/12 125/14)
125/17 130/24 132/18)
137/12 137/13 137/19}
137/19
four [3] 135/11
135/15 179/4
fourth [2] 156/17
168/16
framework [2] 43/25
72/6
frankly [2] 127/22
165/13
Fraser [4] 90/10
90/10 181/19 182/10
Fraser J [1] 182/10
fraud [2] 110/2 110/4
free [1] 186/20
freedom [2] 79/17
123/25
Freeths [3] 108/10
178/13 181/14
Frequently [1]
144/17
friend [3] 59/10
59/20 186/12
friend/witness [1]
59/10
front [3] 37/17 107/4
154/9
frontline [1] 76/17
frustration [2]
139/20 183/11
(68) explain... - frustration
F
FUJ00122204 [1] 9/9
FUJ00122210 [3]
13/12 20/8 33/6
FUJ00122211 [1]
21/14
FUJ00122217 [1]
18/14
FUJ00152582 [1]
6/11
Fujitsu [10] 3/25 5/7
128/2 128/5 128/11
139/9
Fujitsu's [2] 127/25
138/24
fulfilled [1] 180/21
full [10] 37/15 105/5
129/18 132/7 133/5
135/13 138/17
function [1] 102/16
functions [4] 49/1
82/21 104/8 104/17
fundamental [1]
77/22
113/23 178/17
funder [4] 123/22
178/18 178/20 179/18
funders [3] 178/14
178/19 179/1
funding [21] 72/22
78/2 78/14 78/18
78/22 79/7 80/22
80/23 85/6 90/15
90/22 96/3 113/24
123/20 123/21 152/9
177/8 177/11 178/20
181/19 186/9
funds [2] 90/17 90/24I
Furey [16] 40/7 45/11
45/17 70/21 76/16
83/1 83/13 87/23
93/18 93/18 94/12
94/23 97/5 98/13
101/6 101/20
Furey's [4] 56/21
93/24 94/9 98/11
further [18] 3/14 5/14
8/13 29/23 67/24
67/25 84/4 88/9 88/17
89/13 94/24 106/7
127/18 148/15 165/25)
173/19 176/7 184/7
fuzzy [1] 143/17
G
gain [2] 43/6 47/19
gains [22] 42/7 42/9
42/24 43/17 44/7 47/5)
47/9 47/13 47/20
47/23 47/25 49/24
6/24 7/20 14/17 19/16
106/24 109/11 110/24)
funded [4] 78/25 79/3
50/1 50/19 51/3 51/5
51/6 51/14 51/15
55/14 55/17 63/18
Gareth [13] 3/8 4/4
6/24 19/12 19/17
20/21 21/7 128/13
139/14 139/15 144/3
145/11 145/16
Garr [1] 182/9
gate [1] 166/24
gathers [1] 96/19
gave [20] 1/13 1/13
1/22 1/23 3/6 3/12
3/15 4/20 19/10 21/13
32/8 40/9 40/20 43/13
58/24 116/13 142/13
174/15 176/16 183/17)
general [24] 3/15
11/9 39/18 40/1 48/23
49/4 49/7 49/8 58/9
58/16 61/19 68/19
70/18 70/21 71/1
83/16 83/23 85/18
89/23 106/1 134/24
150/1 178/7 183/7
generality [1] 96/17
generally [17] 13/3
13/5 57/7 58/19 58/20
58/21 70/17 71/7
94/19 103/23 113/1
125/16 134/23 140/11
144/12 169/18 171/12)
generated [6] 8/4
9/11 9/20 16/24 25/8
30/10
generic [1] 8/11
generous [1] 178/23
gentle [1] 5/4
genuine [1] 162/3
genuinely [2] 16/20
31/21
George [1] 70/19
Germany [1] 166/22
get [31] 20/24 32/1
32/24 34/7 34/16
34/16 36/22 44/1
44/20 50/8 61/21
73/15 73/24 101/16
111/19 113/4 123/21
123/25 125/21 132/24}
133/2 141/10 141/20
157/19 168/17 170/20)
172/18 177/11 179/25
180/9 186/19
getting [4] 14/11
123/6 168/21 169/3
GIJ01 [1] 24/20
G1J02 [1] 24/20
GIJ03 [1] 24/20
gist [1] 44/13
give [6] 36/19 37/14
93/2 107/1 109/7
135/8
given [25] 19/22
26/11 45/19 51/17
88/23 94/13 94/17
96/13 96/25 99/10
130/22 134/3 142/4
143/4 150/15 165/24
185/24
gives [1] 8/8
giving [10] 2/16
14/17 103/11 122/6
133/6 133/24 134/13
135/19 143/8 187/11
GLO [2] 178/21
180/19
go [76] 4/23 6/11
16/1 16/7 24/11 25/3
35/12 50/17 53/11
53/12 55/17 63/11
69/8 69/10 73/16
73/22 74/18 75/15
76/7 78/16 86/14
88/19 89/16 97/5
97/20 99/15 101/12
101/14 107/8 111/15
112/6 114/2 117/13
119/16 121/25 129/5
129/16 132/19 133/4
134/16 138/17 140/13
146/12 154/7 154/9
154/14 156/9 156/16
157/10 157/17 159/11
159/23 160/2 160/3
161/10 161/21 162/22)
163/5 166/18 167/15
168/15 170/11 171/20
171/23 172/14 173/2
173/22 174/24 177/3
180/24 181/21 185/18I
goes [11] 78/4 78/7
79/5 79/15 80/8 85/24
86/11 126/25 126/25
130/9 137/4
going [46] 4/10 8/23
29/18 30/13 31/19
44/7 62/19 62/20
68/19 68/22 68/23
81/14 89/1 91/17
92/20 106/19 107/25
109/15 109/17 112/18}
112/21 115/22 115/22
115/23 117/3 125/4
128/16 144/15 148/5
151/21 153/8 158/13
158/18 159/20 161/18}
162/13 164/11 166/8
168/15 170/14 173/8
174/22 177/16 180/11
184/8 185/13
gone [11] 1/18 15/3
56/18 59/4 116/8
141/11 151/9 172/1
172/7 172/25 176/4
51/20 64/6 67/9 71/24
74/17 76/9 87/15 88/3
6/21 7/21 10/11 10/20
good [13] 1/3 3/4 3/5
5/3 14/10 37/6 73/20
84/14 95/5 106/17
108/4 143/2 145/23
goods [1] 171/4
got [27] 6/18 12/23
21/20 25/3 30/20
31/19 37/18 38/3 45/4
45/5 62/11 64/21
73/21 74/2 90/5 93/18)
101/25 108/20 112/2
134/6 150/10 152/20
152/20 163/3 166/7
170/24 171/7
Government [6] 82/5
87/17 132/11 183/16
183/19 183/20
grades [1] 57/5
Graham [6] 1/7 1/10
7/2 8/18 24/6 188/2
grant [3] 72/6 79/6
92/7
grants [1] 78/19
grateful [4] 7/7 89/19
94/12 106/8
great [2] 133/9
159/14
greater [5] 10/14
29/21 30/20 32/5
169/22
gross [1] 78/20
ground [2] 2/10 71/3
group [63] 40/10
40/15 45/16 73/19
88/1 113/18 123/15
141/14 141/17 146/16)
147/3 147/14 148/8
148/12 148/15 148/24
149/5 149/12 149/21
149/25 150/13 151/13}
152/2 152/8 152/15
153/7 155/18 155/21
156/1 157/4 157/9
157/14 157/22 158/8
158/13 158/16 158/22
159/2 160/6 160/13
161/23 161/24 162/7
162/10 162/13 163/23
164/2 164/10 164/22
165/3 165/6 165/14
166/11 173/1 176/13
178/1 178/10 180/3
180/5 180/5 181/18
183/3 183/8
Group's [2] 150/2
157/20
groups [5] 66/19
69/20 98/3 102/6
102/8
guard [1] 162/25
guess [1] 167/22
guessing [1] 8/25
guidance [1] 108/22
guilt [1] 57/22
guilty [7] 58/22
103/17 103/21 133/16I
171/42 171/13 171/15]
H
had [182] 5/2 6/8
7/10 7/24 9/7 11/10
13/3 15/12 19/16
19/21 19/25 20/2 21/8)
26/11 28/9 28/17
28/24 30/18 35/15
39/24 40/5 40/15
41/15 41/17 41/22
42/6 43/1 43/25 44/25
45/2 49/13 49/18
50/15 52/20 54/15
54/25 56/11 57/25
62/1 62/16 62/17 65/2I
66/18 68/2 68/16 71/1
72/11 72/24 73/20
74/14 79/2 80/3 81/13}
82/13 87/13 88/3
88/16 93/2 95/12 99/6I
103/11 103/24 104/24)
112/12 112/23 112/23)
113/24 113/25 113/25)
114/6 115/1 115/1
115/9 116/8 116/9
118/25 119/3 120/9
120/12 123/1 123/3
123/24 124/12 125/12)
125/19 125/22 125/24)
126/4 127/21 128/10
128/13 128/14 129/23)
130/3 130/3 130/5
130/7 130/19 1341/5
131/13 131/14 132/12)
132/18 132/19 132/25)
133/25 134/4 137/13
137/17 137/22 137/23)
138/14 140/4 141/11
142/6 142/16 143/19
144/8 144/9 145/12
145/16 146/19 150/1
150/3 150/9 150/12
150/18 152/13 155/4
155/22 156/3 156/10
158/17 158/25 159/17)
159/21 160/7 160/13
160/18 161/12 161/17)
162/15 163/11 164/3
164/13 164/18 166/3
166/20 167/13 168/4
169/6 169/22 170/13
170/18 170/18 170/18)
170/19 170/22 171/6
171/8 172/25 173/4
173/25 175/7 175/9
176/2 176/15 177/22
177/23 178/3 178/4
178/6 178/7 178/10
178/20 178/23 179/3
181/8 182/16 183/14
183/18 186/18
(59) FUJ00122204 - had
H
hadn't [5] 86/6
130/24 171/7 178/20
178/23
half [4] 76/19 164/20
164/20 169/9
halls [1] 186/7
Hamilton [7] 111/8
112/7 112/9 112/14
170/8 170/10 170/16
Hamilton's [5]
108/19 111/18 111/24
124/1 130/20
Hamlyn [1] 184/22
hampered [1] 75/6
hand [6] 4/18 4/24
23/9 23/11 45/9 127/1
handed [1] 96/11
handing [2] 45/11
182/18
Handling [1] 94/4
handover [2] 45/23
46/3
hands [2] 112/2
113/18
hanging [1] 186/14
happen [4] 43/16
43/18 113/17 135/23
happened [9] 29/13
113/18 151/7 167/13
173/4 175/14 176/12
182/8 183/14
happening [1]
151/15
happens [4] 12/6
72/25 140/6 153/19
happenstance [1]
178/13
happy [4] 26/18
120/6 120/14 187/17
hard [3] 8/24 38/3
108/6
Harrison [2] 170/7
170/10
has [70] 1/24 6/6 8/7
15/9 17/1 17/2 22/25
25/20 25/22 25/23
26/12 29/12 29/13
30/16 40/5 46/20 49/9
50/25 51/8 53/13 54/7,
76/14 77/18 78/12
79/11 85/16 85/17
86/1 86/12 90/15 91/7
92/5 92/7 94/13 97/22
101/6 103/8 104/15
105/17 108/7 108/21
108/25 108/25 109/2
109/3 123/12 123/14
126/8 129/18 129/20
1314/7 132/7 137/5
138/16 145/5 151/7
151/8 151/15 160/16
164/19 164/23 168/1
170/2 172/1 175/13
176/18 179/11 180/2
180/25 185/8
have [264]
haven't [9] 17/4 30/1
31/19 32/20 56/18
56/25 129/21 137/19
158/14
having [13] 42/17
44/4 50/14 70/6 73/13
91/5 92/20 103/14
110/4 133/25 156/7
179/2 183/8
Hayes [1] 70/22
Hayward [2] 184/15
184/21
hazy [1] 138/3
he [66] 1/7 7/3 7/10
8/8 9/2 9/7 9/9 9/14
9/23 11/1 11/1 11/4
11/15 11/17 11/23
11/25 12/6 12/13 14/1
14/25 15/4 18/9 18/9
20/22 35/23 45/12
45/19 45/21 45/25
46/6 46/10 88/24
90/10 90/14 90/21
94/13 113/11 113/12
114/12 116/15 127/7
127/21 129/16 143/14)
148/11 149/25 150/24)
151/10 153/1 153/12
159/17 159/18 159/22)
165/15 165/19 165/19)
172/3 172/8 172/9
173/8 174/3 182/11
183/18 183/22 185/3
185/25
he'd [1] 45/23
he's [4] 9/4 10/1
36/16 151/17
head [8] 34/3 34/20
99/17 110/7 110/12
155/3 172/19 176/19
headed [1] 147/8
headhunted [1]
110/14
heading [4] 71/20
74/6 76/20 85/9
headquarters [1]
54/25
heads [1] 99/5
hear [10] 1/3 1/5 4/14
37/6 84/14 89/1 95/5
106/17 106/19 146/8
heard [14] 103/14
103/4 103/4 103/8
105/17 112/12 122/8
123/14 125/9 125/10
128/13 137/5 175/13
184/12
hearing [6] 50/20
60/2 60/4 97/13
184/14 187/25
hearings [1] 59/5
heat [1] 65/19
held [10] 3/20 11/14
46/14 47/15 56/9 70/4
128/5 165/9 173/3
182/12
help [7] 8/17 26/19
31/21 56/12 91/1
108/6 109/3
helped [1] 52/18
helpful [1] 14/6
helping [2] 56/6
186/17
Hence [1] 13/6
Henderson [15]
112/19 114/4 115/2
124/17 125/7 125/25
138/7 139/23 141/2
150/12 175/18 175/21
176/5 176/15 178/15
her [31] 108/18 109/1
111/11 111/13 130/20
134/7 142/16 142/16
142/17 142/18 142/19]
142/20 142/22 147/10
150/10 150/12 150/18}
167/10 167/11 167/12,
167/19 169/8 169/9
170/11 170/13 170/24
171/2 171/3 1711/4
171/4 185/15
here [21] 14/7 17/7
20/5 21/16 22/20 23/4
26/3 47/2 57/9 62/11
68/6 69/10 72/13
95/11 120/25 130/16
153/7 155/12 171/24
172/18 173/12
heroes [1] 108/8
hidden [1] 187/8
hierarchy [5] 83/16
83/17 113/3 113/9
113/14
high [5] 90/8 108/10
146/21 180/5 184/23
highlighted [2] 11/17
176/2
highly [4] 90/15
HILARY [3] 106/22
106/25 188/14
him [23] 1/25 7/20
14/5 14/9 14/24 24/14
24/22 26/19 28/9 29/8
31/21 45/15 46/6
112/13 112/14 112/16
112/24 142/7 142/8
149/25 159/7 165/19
185/24
hindrance [3] 76/3
76/5 76/6
hindsight [1] 147/18
his [26] 10/7 14/5
14/12 14/23 35/21
45/19 86/6 87/3 94/3
97/5 116/16 142/9
145/12 145/17 149/20}
150/1 151/11 158/3
159/7 161/25 162/10
173/9 181/19 182/17
183/24 185/22
historic [2] 117/20
118/1
historically [1] 64/21
HMRC [2] 110/8
131/23
HMRC/inland [1]
131/23
HODGE [8] 37/12
37/13 92/1 92/15
93/17 100/12 105/22
188/8
hold [1] 120/1
home [2] 130/12
171/2
homes [1] 169/23
honest [1] 143/14
Honestly [1] 19/6
Hooper [10] 151/6
151/14 153/10 153/14}
159/2 159/5 159/6
159/10 163/11 172/2
hopefully [1] 160/1
horizon [83] 13/2
13/5 15/9 29/7 31/22
32/17 33/2 34/4 34/17
34/18 35/15 35/19
40/10 40/15 40/17
41/5 41/15 41/19
41/20 42/10 45/16
46/15 47/3 47/7 47/8
48/12 48/16 52/16
52/23 53/15 53/24
54/5 54/10 56/25 58/7,
59/3 60/16 60/21
60/25 64/1 64/7 82/4
84/20 85/8 85/9 85/15
85/21 86/13 86/18
87/7 87/18 88/2 95/14,
96/21 96/24 98/15
99/9 100/4 100/18
100/25 101/2 101/22
113/7 115/12 119/25
120/5 121/9 121/19
121/21 123/2 123/15
125/9 125/17 127/12
127/14 130/7 133/1
137/3 149/21 152/5
152/12 183/1 183/20
Horizon’ [1] 149/2
hove [1] 166/25
hover [5] 22/24 23/4
23/20 25/10 25/25
hovered [2] 23/13
23/18
hovering [1] 23/16
how [62] 6/2 6/3 7/16
7/17 8/16 15/1 15/5
19/4 27/17 27/19 28/4
35/9 36/8 42/7 42/12
43/9 44/21 45/5 45/6
45/6 48/24 48/25
50/12 50/13 50/14
51/14 54/3 57/12
59/18 63/15 63/17
80/2 81/22 93/16
96/12 96/22 97/10
101/13 104/4 104/16
113/16 113/17 113/20)
113/23 115/15 116/22)
125/18 130/22 138/10}
140/12 140/17 142/22)
150/22 153/10 157/1
158/12 163/23 169/8
173/17 177/25 186/10}
186/20
Howe [1] 108/9
however [8] 20/7
86/3 86/14 86/15
144/24 157/4 158/8
182/23
Hudgells [1] 108/11
huge [3] 11/22 11/24
183/1
hundred [1] 52/9
hundreds [2] 95/12
95/13
hurdle [1] 164/13
hurdles [1] 180/5
l accept [1] 29/1
lagree [1] 20/3
also [3] 5/16 98/22
137/12
always [1] 154/13
lam [8] 15/18 17/16
27/5 72/9 92/20 94/16
131/23 133/17
I apologise [1]
187/15
I applied [1] 110/4
l appreciate [2]
143/21 167/24
lask [12] 4/8 37/14
37/23 107/3 107/9
107/16 107/21 115/15}
144/14 175/25 180/19)
183/15
l asked [4] 102/9
115/17 177/6 185/24
lassume [1] 74/23
lassumed [1] 128/5
lattended [1] 141/22
Ibe [1] 187/5
I became [1] 111/6
I beg [1] 136/5
I began [1] 110/2
I believe [15] 8/18
75/18 117/1 119/10
126/8 126/9 128/24
130/13 133/23 135/5
135/10 141/21 145/13)
(60) hadn't - believe
I believe... [2] 147/21
160/25
I brought [1] 175/20
I can [30] 1/6 9/17
10/19 14/7 15/5 21/22)
22/1 22/23 23/3 26/15
26/25 27/8 27/17
27/23 28/3 30/22
31/20 32/12 33/23
35/9 36/4 36/8 36/9
94/17 101/24 106/18
133/13 146/9 165/4
183/10
Ican't [10] 18/14
26/9 30/14 119/10
131/5 133/18 138/1
155/10 167/21 174/15)
I certainly [1] 183/5
I challenged [1]
115/12
I could [5] 48/2 88/4
176/3 182/15 182/23
I couldn't [3] 43/5
88/4 176/19
I dealt [1] 57/18
I decided [1] 183/22
I definitely [1] 119/5
I did [7] 66/11 82/2
111/19 168/8 169/13
170/23 178/2
I didn't [12] 30/25
34/17 35/25 36/2
49/16 82/18 98/21
122/11 133/16 137/9
147/4 170/23
Ido [13] 3/11 19/18
28/10 35/9 103/15
103/15 108/1 117/12
120/20 127/17 168/9
184/7 187/18
I don't [45] 10/3
12/12 17/8 27/16
28/24 31/12 31/18
33/4 35/10 38/23
48/21 49/1 49/16
69/19 69/23 70/15
71/6 74/16 76/13
76/15 83/6 84/25 88/6
98/16 98/21 103/23
105/24 113/13 113/22)
119/2 119/5 126/12
135/25 137/10 138/2
138/7 138/17 140/3
152/17 165/2 165/19
171/6 171/15 173/10
176/22
l expected [1] 135/13
l explained [2] 47/17
63/4
I first [1] 127/8
I for [1] 129/20
I forget [2] 110/25
142/14
I found [1] 103/25
I gave [4] 1/13 1/22
21/13 43/13
I give [1] 93/2
Igo [1] 107/8
I got [1] 112/2
had [8] 5/2 88/3
112/23 119/3 128/14
130/19 176/2 177/23
Ihave [17] 2/19
24/18 35/3 37/19
58/13 73/23 84/4 95/9)
108/8 124/22 127/8
130/10 131/22 133/23}
143/14 168/9 185/1
I haven't [1] 31/19
I highlighted [4]
176/2
I just [18] 8/21 14/11
14/12 15/11 17/15
17/20 18/21 19/6
32/11 32/13 33/18
103/6 111/17 112/25
138/4 147/9 172/10
184/20
I knew [1] 159/7
I know [7] 15/17 27/4
77/10 101/16 170/14
172/25 174/17
left [2] 49/2 127/21
Hook [1] 144/16
I looked [1] 115/3
I made [3] 43/12 58/1
64/20
I make [1] 54/7
I may [4] 89/14 144/2
161/1 184/5
I mean [13] 26/2
31/12 31/19 72/23
87/13 89/4 96/9 97/7
97/15 152/17 155/14
159/17 165/9
Imet [3] 112/17
113/12 184/18
I move [1] 128/15
I must [1] 18/4
I need [1] 89/12
I now [1] 24/19
lonly [4] 103/10
1 outline [1] 42/6
lovercut [1] 136/6
I paid [1] 186/21
I please [1] 119/15
I prepared [1] 117/1
I probably [1] 171/7
I put [3] 4/13 15/12
128/16
[really [10] 14/23
15/13 19/7 26/9 27/18
31/18 32/3 32/11 36/8)
184/17
I recall [7] 1/7 1/17
115/17 130/3 134/6
149/18 171/16
I recap [1] 3/14
refer’ [1] 10/24
l referenced [1]
72/23
I referred [1] 62/9
I remember [3] 57/23
167/10 174/14
I remind [2] 1/19 2/5
l represent [1] 90/2
Iright [1] 176/14
I said [13] 17/21 26/3
31/24 61/21 87/19
98/21 101/5 104/11
128/15 168/8 170/17
171/10 171/21
I saw [2] 118/11
167/19
I say [10] 14/7 30/13
58/20 69/7 72/9 72/16
97/3 117/12 127/11
173/22
I set [2] 110/9 110/16
I shall [1] 38/16
I should [3] 118/16
129/25 140/19
I shouldn't [1] 29/1
I showed [1] 20/7
I sit [1] 82/20
I slightly [1] 108/18
I speak [1] 95/8
I spoke [1] 187/1
I start [2] 108/4 111/1
I still [1] 140/5
I suggest [2] 8/1
32/15
I suspect [1] 77/15
I take [4] 34/15 82/17
83/9 121/20
I then [3] 21/12 91/25)
110/8
I therefore [1] 131/15)
I think [107] 1/19
3/19 4/8 7/24 11/16
13/20 13/25 15/19
18/16 20/18 22/14
22/19 23/15 28/24
29/5 31/3 31/24 33/13
34/15 36/22 41/14
41/24 42/6 42/13
43/12 44/12 49/12
50/22 51/5 52/3 54/23
56/21 58/1 59/3 60/22
61/25 61/25 64/19
67/11 70/17 70/18
70/19 70/21 72/23
75/11 76/15 80/2 84/3
84/5 88/20 94/8 95/10
95/16 96/12 96/18
97/15 100/14 101/25
102/3 102/12 105/25
106/10 110/22 112/9
114/2 114/13 116/6
118/22 119/3 120/13
120/16 121/12 121/13
122/10 126/15 129/1
129/2 129/11 129/12
135/7 135/25 136/10
139/7 139/11 141/18
142/8 143/2 143/18
143/21 143/24 153/24}
158/2 159/5 160/16
161/2 162/19 166/20
168/16 174/21 182/9
182/13 182/22 183/11
183/25 185/4 185/5
185/8
I thought [5] 116/24
135/19 140/14 1741/1
182/24
l understand [12] 3/1
44/12 64/25 73/8
77/10 93/4 96/5 97/7
99/3 107/12 108/2
179/17
luse [1] 127/23
lused [2] 55/21 83/1
I want [13] 3/6 20/5
34/16 53/16 126/14
140/6 143/11 146/10
159/24 166/10 171/20
176/12 182/3
I wanted [3] 34/25
115/21 132/17
I was [58] 3/19 10/3
13/25 14/6 14/24
17/20 24/17 26/3 26/6}
26/19 31/20 31/25
32/3 35/18 41/2 46/9
47/11 47/12 51/2
55/20 57/16 68/11
68/14 71/6 71/14 83/8
96/10 96/10 96/11
103/13 110/2 110/14
110/21 110/23 112/3
114/8 115/8 115/10
125/4 125/20 126/10
128/16 131/23 132/1
136/6 137/8 137/15
139/4 140/1 140/24
146/19 159/7 166/24
174/21 175/17 175/20}
182/6 183/24
I wasn't [10] 14/7
15/11 58/19 72/15
91/5 115/4 145/18
145/22 147/10 184/23
I will [4] 2/12 2/22
109/14 185/6
I won't [1] 148/5
I wonder [2] 48/2
85/1
I work [2] 55/11
55/12
I worked [3] 57/15
57/16 57/17
I would [22] 10/10
12/21 12/21 12/24
17/5 17/14 17/24
18/11 30/14 30/23
41/3 62/4 62/6 62/11
7116 93/16 97/21
108/12 116/24 125/6
172/19 172/22
I wouldn't [4] 17/16
18/5 32/22 104/1
I'd [16] 7/7 34/19
40/8 45/2 46/11 65/7
81/21 108/4 108/15
117/2 119/2 124/15
132/4 138/6 171/21
187/18
ll [8] 1/13 5/4 7/8
28/16 90/8 128/1
142/19 144/13
I'm [73] 4/13 8/24
14/4 14/4 18/4 18/21
26/5 27/16 28/13
28/15 29/18 31/5
31/18 32/2 32/12
32/22 32/23 33/25
35/11 36/8 47/4 54/10
58/13 58/15 62/13
62/14 63/25 68/15
71/7 72/9 74/23 88/5
89/19 90/8 94/12 95/6
96/12 97/7 98/19
101/16 101/18 104/21
106/8 107/25 109/16
112/21 124/14 124/14I
127/22 128/7 134/5
138/3 139/15 140/19
143/17 144/15 147/5
148/5 151/21 153/8
161/16 168/15 170/10
170/14 176/22 177/16I
1777 182/23 182/24I
184/19 185/12 185/14I
187/17
I've [50] 12/14 13/18
13/24 18/4 19/3 20/17I
25/3 26/2 26/15 26/25I
28/2 28/25 29/1 31/2
31/2 31/3 31/19 33/10
33/18 35/10 36/2 38/3I
45/4 45/5 48/23 49/11
54/20 58/23 59/24
62/9 62/18 62/23
76/15 83/11 88/9
89/10 90/5 91/6 93/18
97/15 98/22 99/15
101/25 103/11 103/24I
110/11 120/25 139/8
173/9 173/15
lan [13] 112/19 114/3
115/2 124/17 125/5
138/7 141/14 150/11
173/14 175/8 175/18
175/21 176/4
lan's [1] 121/14
idea [13] 14/10 34/19
43/23 43/24 55/24
(61) I believe... - idea
idea... [8] 63/5
119/25 124/23 133/15)
135/17 135/18 141/16)
173/9
identical [2] 1/21
176/17
identifies [4] 29/13
67/20 67/25 79/9
identify [6] 10/2
42/20 43/2 43/5 63/2
72/13
ie [5] 12/19 13/13
15/4 25/21 30/5
ie it [4] 15/4
ie the [3] 12/19 13/13
30/5
if [211]
ignorance [2] 10/5
14/2
image [2] 21/17 22/3
imaged [1] 21/16
imagining [1] 176/22
immediately [1] 2/11
impact [1] 169/22
imperative [1] 124/8
implement [1]
136/18
implementation [2]
121/8 121/18
implemented [3]
41/16 47/7 60/22
implication [1]
181/20
implications [2]
129/22 179/13
implies [3] 10/15
29/22 30/20
importance [2] 15/8
179/2
important [12] 4/12
7/13 9/18 9/22 11/12
15/14 19/1 20/24 34/7)
34/15 130/4 168/20
imposed [1] 148/13
impossible [2] 109/2
123/24
impression [1] 168/7
improvements [1]
51/19
inability [1] 47/21
inaccurate [2] 167/3
167/5
inch [1] 124/2
incidence [1] 59/2
incident [1] 43/10
incidents [2] 97/4
137/2
include [4] 9/5 11/2
102/13 172/22
included [7] 8/16
11/10 21/8 29/14
39/12 152/15 181/23
includes [3] 77/16
94/4 98/7
including [7] 9/20
46/5 50/18 72/12
90/19 122/5 154/3
inclusion [2] 11/8
152/11
inclusive [1] 82/3
income [5] 78/6
78/11 79/1 174/5
174/10
incompetent [1]
109/5
incomplete [2] 60/20
126/23
incorrect [2] 42/7
121/7
increase [1] 60/24
increased [3] 41/22
65/3 66/25
increasing [2] 96/20
111/13
incriminate [3] 1/15
2/2 2/10
incrimination [2] 2/4
2/17
incurious [2] 98/15
98/20
indeed [3] 98/20
106/18 112/14
indefinitely [1]
182/13
indemnify [1] 179/8
independence [6]
80/10 81/8 81/14
82/11 91/15 116/23
independent [5]
90/13 90/22 114/25
115/9 116/25
independently [1]
116/20
indicate [2] 67/13
147/11
indicated [2] 162/23
170/12
individual [23] 41/11
47/15 47/16 49/2
49/15 49/17 50/13
52/22 53/8 56/1 56/16
58/1 58/2 59/7 59/13
59/16 63/17 86/3
105/2 105/6 105/12
155/13 161/17
individual's [1] 59/20
individuals [14] 41/3
51/16 54/15 57/19
59/6 63/21 64/22 68/7
91/24 93/15 98/3
105/8 105/15 181/2
indulgence [1] 89/14
industrial [8] 43/24
82/23 82/23 83/5
83/25 93/3 93/5 93/9
industry [3] 69/23
98/7 110/11
inevitable [1] 78/10
infer [1] 143/7
inference [1] 68/6
inflicted [1] 109/4
info [1] 7/25
inform [2] 160/5
163/9
information [45] 9/19
11/14 16/5 24/17 28/5
28/21 29/23 30/16
30/19 30/21 33/1
35/22 41/25 49/14
54/24 56/24 80/13
99/7 99/9 99/10 99/14
113/22 122/21 123/3
123/20 123/22 123/25I
124/5 124/6 124/9
125/21 138/22 145/2
145/7 158/6 158/10
158/17 171/8 172/8
174/8 174/16 175/8
177/12 177/19 180/7
informed [1] 41/2
ingredients [1]
179/18
initial [8] 111/1
112/16 114/24 116/6
117/18 140/22 141/18I
144/6
ink [2] 124/4 127/23
Inland [3] 110/5
110/5 131/23
innocence [2] 103/17]
108/19
input [2] 144/8 144/9
INQ00001124 [1]
4/18
inquiries [1] 158/17
inquiry [32] 1/24 1/25
3/13 20/4 36/20 37/14
37/21 38/16 38/19
40/21 50/22 56/23
83/8 94/25 103/8
106/7 107/1 107/24
116/14 119/22 122/2
122/3 122/8 123/12
123/14 137/1 137/4
138/16 156/8 158/4
167/6 175/13
Inquiry's [1] 109/16
insert [1] 138/25
insist [1] 26/5
insisted [1] 182/10
insofar [8] 45/23
58/9 58/16 60/21
63/16 70/7 76/7 85/4
insolvency [2] 110/9
110/10
instance [1] 100/20
instigation [2]
150/10 150/12
Institute [1] 159/7
instructing [1]
136/20
insubordination [1]
63/8
insufficient [1]
158/10
insufficiently [1]
149/8
insurance [4] 179/2
179/14 179/14 179/15}
insurer [3] 179/7
179/7 179/19
insurers [1] 178/15
integrity [5] 15/9
31/22 82/4 88/2
159/14
intend [1] 38/23
intended [2] 157/13
158/16
intends [1] 170/11
intent [1] 131/25
intention [9] 26/4
26/17 27/1 27/2 28/2
32/2 36/9 55/18
148/24
interact [1] 45/7
interaction [2] 111/1
183/16
interactions [1]
183/19
interest [2] 48/23
184/2
interested [2] 180/1
180/9
interests [11] 39/8
65/10 66/9 66/23 68/3
69/17 71/4 75/7 75/25)
76/2 77/12
interfered [1] 137/22
interference [1]
165/13
interim [25] 114/16
114/17 119/7 119/9
119/11 121/24 122/1
127/24 128/15 128/22)
134/17 134/19 134/25}
135/3 135/9 135/14
135/22 136/23 139/1
139/13 139/17 140/9
140/13 140/21 141/19
internal [4] 4/24 60/2
83/17 145/20
internally [1] 69/6
international [1] 80/2
interpret [1] 12/14
interpretation [2]
157/20 158/12
interpreting [1]
161/16
interrupt [1] 156/11
intervenes [1] 18/15
interview [7] 43/20
44/8 47/5 53/7 58/3
59/9 59/22
interviewed [3] 55/15
63/18 94/18
interviewing [2]
105/11 171/3
intimating [1] 123/13
intimidating [1]
103/5
into [30] 7/8 14/5
24/21 45/13 45/14
66/2 68/24 72/1 73/11
91/9 91/12 97/9
110/12 111/10 117/19)
119/25 138/25 145/20}
164/10 166/6 166/21
166/25 168/3 170/11
171/2 174/5 174/10
175/16 180/11 184/18}
introduce [1] 79/20
introduced [2] 60/16
178/14
introduction [5] 41/5
41/19 41/20 71/20
71/22
intrusion [1] 164/10
invariably [1] 57/5
investigate [3] 47/24
85/21 117/20
investigated [3]
52/12 53/1 102/17
investigating [4]
53/4 110/6 173/18
176/7
investigation [30]
14/14 14/20 52/15
53/1 59/9 59/11 59/19
102/16 103/11 103/12!
103/19 103/20 103/25)
104/18 104/24 105/13)
117/18 124/15 128/4
129/19 135/10 135/24}
136/2 145/20 147/9
156/18 169/4 169/17
175/16 175/19
investigations [2]
53/10 174/17
Investigator [2]
14/13 14/19
investigators [6]
102/13 102/15 103/6
103/9 150/11 158/21
invited [1] 124/24
involve [1] 4/10
involved [25] 19/1
45/25 57/7 58/6 58/21
62/5 68/10 71/7 73/13}
73/23 108/18 108/20
108/24 108/25 110/18}
1411/6 111/19 111/25
112/1 138/9 140/8
140/22 140/25 175/15)
184/23
involvement [10] 3/8
67/10 83/20 88/3
111/20 127/25 134/18)
176/7 180/25 184/15
(62) idea... - involvement
involves [2] 144/19
160/25
involving [1] 97/2
Ireland [2] 138/3
172/23
Iron [2] 154/23 155/4
is [406]
isn't [10] 12/2 16/16
24/6 33/24 54/5 64/1
83/21 87/12 95/15
170/25
isolated [1] 43/10
issue [34] 2/18 2/20
3/7 3/12 3/14 7/21
19/11 27/2 31/23 42/3
42/12 42/12 43/8
43/10 44/9 51/12
54/17 74/5 74/7 81/21
82/7 83/10 83/19
85/23 88/3 88/7 98/19)
127/5 138/21 148/23
154/2 154/22 159/24
172/11
issued [3] 85/13
139/24 158/19
issues [51] 34/3
34/17 34/18 38/20
38/23 38/24 40/22
44/10 46/5 46/6 49/19)
49/22 55/6 63/9 63/15
65/22 70/10 74/6
76/20 82/14 82/23
82/23 83/4 84/1 92/13
92/18 94/4 96/24 97/9
97/11 97/19 97/23
97/24 98/6 98/24
99/18 99/23 100/3
100/18 101/7 101/18
101/21 111/23 122/4
141/9 152/12 152/14
152/24 159/11 160/18}
161/11
issues' [2] 152/5
162/5
issuing [2] 139/1
183/24
it [474]
it's [101] 1/19 4/8
4/12 4/17 4/20 5/3 5/5
8/22 8/23 8/23 15/2
21/16 22/19 26/15
27/4 27/25 30/7 30/20
31/3 31/12 32/13
32/20 34/1 34/15 35/6
35/6 38/3 44/13 47/13
49/5 49/19 50/24 51/5
56/3 57/18 58/17
60/19 61/3 64/2 67/17
69/23 78/24 81/21
91/18 91/22 94/9
97/23 97/25 100/14
100/15 103/24 107/14)
111/25 117/5 117/9
118/12 118/16 120/13)
121/3 121/24 124/23
126/11 126/13 129/13)
1314/7 131/21 132/10
135/20 136/23 140/7
141/19 147/16 148/18)
151/3 153/4 153/5
153/5 154/16 156/9
156/13 157/10 157/17)
158/13 160/2 166/20
167/16 167/16 167/17)
167/19 168/16 170/10)
171/21 174/25 176/2
176/4 178/17 179/10
184/8 184/19 185/15
185/17
italics [2] 7/2 7/14
item [2] 173/25
174/25
item 5 [1] 173/25
items [1] 151/38
its [26] 48/24 53/2
53/9 53/18 53/18
54/25 62/18 69/2 69/4
75/6 77/11 81/14
82/11 85/6 96/15 97/8
104/15 111/7 126/16
127/9 140/10 142/12
152/8 153/15 156/19
180/21
itself [7] 34/12 77/4
94/2 97/11 124/16
127/24 142/10
ITV [1] 186/6
J
JA [1] 170/7
James [11] 112/17
112/18 114/12 121/13)
124/19 127/2 135/6
135/8 140/12 141/2
170/8
Jane [1] 177/24
Janet [2] 124/17
124/18
January [10] 124/17
125/3 125/24 148/8
148/18 151/24 153/21
153/22 174/23 174/23)
Jenkins [25] 4/5 6/25
7/19 9/3 15/24 17/18
17/25 18/9 19/12
19/21 20/21 21/7
26/11 26/18 28/6
28/12 29/4 35/20
128/13 139/14 139/15)
144/3 145/12 145/16
155/20
Jenkins’ [12] 3/8
7/22 8/15 16/25 19/17
20/16 24/13 24/21
27/6 28/21 28/25
32/10
Jeremiah [2] 108/17
186/16
JFSA [33] 86/3 86/15
113/1 113/2 113/10
113/16 113/21 113/23}
114/12 116/25 122/24
123/1 123/5 123/17
123/19 124/12 133/5
136/17 141/23 144/8
146/22 148/10 149/7
155/12 161/13 162/8
162/12 165/5 165/18
180/14 186/5 186/23
186/25
Jo [18] 107/11
108/19 108/20 111/8
111/12 111/17 112/7
124/1 130/19 130/22
170/7 170/8 170/12
170/16 170/17 170/23}
171/6 171/8
Jo's [4] 111/10
131/14 132/1 135/7
job [17] 32/3 47/11
47/16 47/21 48/23
48/25 51/25 55/19
56/2 70/20 76/16
82/18 93/12 103/13
115/5 140/14 147/10
jobs [6] 53/14 53/24
54/4 54/9 54/17
169/23
Johnson [1] 183/25
join [1] 166/4
joined [5] 66/6 68/8
110/4 165/15 166/4
joining [2] 98/13
186/5
Joint [1] 110/9
journalists [1] 82/6
judge [2] 159/3
182/16
judgment [7] 90/7
90/7 90/9 90/11
181/20 182/18 182/23
Julian [2] 141/22
142/1
July [14] 72/7 114/2
114/17 116/16 117/9
117/11 118/23 119/7
120/9 120/10 122/14
128/21 134/17 145/11
July 2012 [1] 122/14
July 2013 [4] 128/21
jump [4] 174/22
June [11] 1/1 71/11
71/12 85/2 112/7
118/23 128/20 129/1
129/12 160/2 163/4
just [122] 4/19 8/21
8/22 9/1 10/5 10/11
13/24 13/25 14/1 14/2
14/4 14/11 14/12
14/24 15/11 16/1
17/15 17/20 18/16
18/21 19/6 20/2 20/14}
21/6 21/23 22/2 22/7
22/13 23/20 23/24
26/5 26/19 27/4 27/16
30/3 30/8 30/22 31/4
31/7 31/12 31/18
31/22 31/25 32/3
32/11 32/13 32/13
32/19 32/20 32/23
33/6 33/9 33/18 34/19)
38/4 41/6 41/24 42/11
46/23 48/3 50/16
50/24 54/23 55/22
59/1 63/6 64/16 67/19
73/9 73/15 74/13 82/8
82/8 83/11 85/4 87/4
88/13 90/5 95/6 99/1
99/2 99/15 100/10
101/9 101/25 102/1
103/6 111/17 112/25
117/3 122/11 123/10
131/2 133/6 135/3
136/14 137/16 138/4
138/9 138/18 144/2
147/9 147/12 148/20
150/4 150/25 153/8
153/17 154/7 156/14
163/6 168/3 172/10
176/18 179/6 180/7
182/3 184/5 184/20
185/12 186/2 187/18
justice [10] 90/9
90/10 103/16 108/7
118/14 126/1 126/3
144/1 181/19 183/13
justification [1] 32/9
K
Kay [9] 106/19
106/22 106/25 124/24,
129/8 130/13 170/11
170/12 188/14
Kay's [2] 168/19
169/14
Kearns [13] 37/8
37/11 37/13 37/16
48/2 84/17 89/17
89/21 95/2 95/6 99/2
106/6 188/6
keep [3] 15/25 64/18
73/2
keeping [3] 42/15
TAM 122/13
Keith [1] 13/16
kept [1] 123/24
key [2] 70/9 86/3
kind [4] 15/15 104/7
150/14 182/11
kindly [1] 22/25
Kineton [1] 186/8
KL [1] 163/15
knew [9] 20/1 28/9
28/19 64/6 64/13 65/2,
132/17 139/9 159/7
know [74] 8/22 8/23
10/3 12/1 12/12 14/4
14/14 14/24 15/13
15/17 17/8 17/15 18/2I
18/22 19/25 21/5 27/4)
27/117 28/2 28/14
28/16 29/3 30/13
30/16 31/3 31/18
31/18 31/22 32/11
37/13 43/9 44/15 45/4I
50/2 54/3 65/13 71/6
73/12 74/13 74/16
76/9 76/15 77/10
79/25 88/6 90/1 96/2
98/17 98/21 99/13
99/14 101/16 113/22
113/23 115/21 120/17)
125/10 132/9 134/5
134/17 138/2 140/4
146/22 147/4 155/14
168/6 168/8 170/14
172/25 173/13 174/17)
184/24 186/5 187/18
knowing [2] 10/5
14/2
knowledge [18]
38/13 43/1 44/4 45/7
45/15 48/20 48/21
57/1 60/12 66/16
78/23 107/22 128/11
130/19 138/10 147/18)
159/14 159/18
knowledge/recollecti
on [1] 66/16
known [9] 2/3 6/23
61/18 72/6 96/6 110/8
136/25 144/3 178/17
L
lack [1] 85/18
ladder [2] 99/15
100/5
laid [4] 83/22
land [1] 186/12
language [1] 182/17
large [4] 52/13 90/2
98/23 102/5
large-scale [1] 102/5
largely [2] 49/23
100/17
last [36] 1/13 3/16
3/22 4/3 4/9 4/12 4/15]
9/5 10/21 19/10 19/14I
19/19 19/24 20/7
20/12 21/11 23/17
25/15 26/22 27/3 32/4I
32/19 40/9 40/20
41/14 43/12 43/13
50/22 56/24 72/9
95/11 102/10 129/6
132/4 184/4 184/5
lastly [1] 33/5
late [4] 88/16 109/24
(63) involves - late
L
181/23
later [6] 6/12 40/16
72/5 111/25 148/5
151/21
latter [1] 165/9
latterly [1] 110/16
law [2] 1/23 11/10
lawyer [6] 1/25
124/10 150/8 150/19
177/15 182/24
178/10 178/12
lay [1] 53/6
layers [2] 101/12
132/16
lead [5] 14/5 98/8
168/6 168/17 170/5
leadership [2] 40/4
83/20
learn [2] 134/7
140/17
least [10] 84/21 86/5
86/23 94/17 100/16
117/24 167/12 168/21
172/16 180/22
leave [3] 5/22 31/8
165/5
led [8] 73/9 113/12
130/17 131/4 135/8
140/11 141/4 164/7
Lee [4] 179/10
left [15] 4/18 27/25
88/1 110/8 127/21
130/8 138/20 151/1
155/16 155/17 165/11
left-hand [1] 4/18
legal [20] 2/3 2/17
2/21 60/6 60/9 74/9
75/2 84/6 88/10 96/3
96/14 96/15 106/4
132/13 142/13 159/10
177/25 181/14 182/20}
183/1
lend [1] 87/17
length [1] 51/8
lengths [1] 152/7
lengthy [1] 126/11
less [3] 50/7 78/18
169/21
let [5] 21/5 64/16
88/18 99/2 131/18
let's [10] 22/11 27/2
42/12 54/17 63/16
114/2 117/5 129/3
153/3 167/15
letter [12] 85/11
85/12 117/1 117/5
4117/7 118/11 118/18
121/13 127/2 127/3
late... [2] 109/25
lawyers [4] 2/8 145/6
184/12 184/15 184/17)
29/25 30/11 32/6 49/2
154/3 177/24
letters [4] 57/2
level [29] 42/4 42/14
43/8 43/14 43/15
43/15 44/11 44/14
44/19 44/24 44/24
64/5 64/10 64/11
64/17 82/19 96/8
99/19 99/19 99/19
115/22
levels [2] 42/24 50/9
liability [1] 134/12
lies [2] 20/5 98/23
life [1] 22/15
light [4] 65/19 108/7
138/22 145/3
like [41] 4/21 6/10
10/10 12/21 14/6
14/22 22/7 40/8 46/11
52/13 62/19 62/19
62/25 63/7 65/7 66/22
69/22 73/4 81/21
82/21 84/4 91/22
92/16 93/10 98/24
108/2 108/4 108/12
108/15 113/15 124/15)
126/17 132/4 143/16
159/9 165/4 172/22
182/21 185/3 186/19
187/18
likelihood [1] 71/25
likely [5] 79/6 102/10
102/13 158/7 162/4
likes [4] 93/4
limit [2] 149/20
150/21
tions [1] 153/16)
limited [14] 39/9
71/21 76/24 78/2 82/5
85/14 87/1 133/10
139/19 149/1 153/14
161/9 172/21 181/23
Limited's [2] 86/12
146/23
line [23] 5/5 13/21
13/23 15/9 16/4 19/25
20/19 26/2 26/8 26/15
29/6 31/2 33/14 33/16
33/19 33/20 33/21
33/22 59/23 98/14
107/11 140/15 140/17)
lines [1] 187/19
linked [3] 10/8 10/13
173/17
Linnell [11] 106/20
106/22 106/25 129/8
176/18 185/2 186/2
187/6 187/10 187/15
188/14
Linnell's [1] 118/12
list [4] 32/10 74/11
123/12 183/17 183/22)
54/16 55/7 55/8 55/23
61/24 62/3 62/7 62/24
74/14 98/14
listed [1] 77/20
listened [2] 91/6
168/22
listing [1] 179/25
literally [2] 185/9
185/14
litigants [1] 88/1
litigation [29] 3/25
90/20 108/11 123/22
124/4 150/19 176/13
177/16 177/7 177/9
177/17 178/1 178/11
178/22 179/5 179/8
179/18 180/5 180/17
181/9 181/16 181/18
181/22 181/25 182/2
184/1
little [6] 6/22 13/25
30/16 67/24 81/3
130/10
live [4] 36/17 40/16
40/22 139/10
Liverpool [2] 57/17
57/18
LLP [1] 110/25
local [32] 41/3 41/25
42/20 42/25 43/9
43/14 43/21 44/4 44/8
44/11 44/14 44/15
44/18 49/20 54/14
54/16 55/7 55/16
55/20 55/23 57/16
57/16 57/17 62/4 63/2
63/25 99/16 99/19
100/2 103/13 108/21
111/7
locally [1] 63/20
logging [1] 24/7
London [1] 110/13
long [8] 8/23 32/13
72/21 92/5 98/14
103/24 135/19 168/13
long-term [1] 72/21
longer [3] 72/16
77/16 82/7
longstanding [1]
89/21
look [55] 4/17 4/23
6/11 7/24 9/7 13/12
15/22 16/21 22/13
24/11 25/4 33/5 33/6
34/5 67/16 71/19 77/2
85/1 98/19 109/15
114/25 115/22 115/23
117/5 117/24 119/15
121/24 124/15 127/24
136/23 136/24 138/18!
140/6 141/24 142/25
144/5 144/16 148/6
149/12 151/21 151/25}
153/3 153/17 153/25
156/13 159/24 163/3
178/14 178/17 178/18)
173/3 173/21 178/3
179/10 181/4
looked [11] 7/4 9/15
21/11 21/15 21/23
22/4 44/13 115/3
148/3 149/21 171/25
looking [12] 13/25
116/10 118/4 120/17
126/3 129/15 134/19
170/12
loop [1] 126/18
Lord [5] 90/10 114/4
Lord Arbuthnot [4]
114/4 116/13 117/10
124/18
Lord Justice [1]
90/10
lose [2] 179/11
179/15
losing [3] 53/14 54/8
54/16
loss [8] 43/6 47/19
174/19 175/22
losses [30] 17/13
47/23 47/25 49/24
50/1 51/3 51/4 51/6
51/14 51/15 52/13
55/14 55/17 63/18
87/3 93/12 113/6
133/7
lost [3] 53/23 54/4
169/23
lot [11] 45/22 45/25
95/19 108/13 124/4
125/5 137/5 138/17
144/9 152/20 155/8
lots [1] 186/13
lowest [1] 44/3
Lowther [6] 8/14
13/16 15/24 17/24
21/7 22/2
LTB [3] 85/10 85/11
85/12
lunch [3] 106/9
111/11 182/8
lunchtime [1] 167/21
Lyons [6] 118/22
118/25 119/2 128/18
133/21 134/11
M035 [1] 170/20
M054 [7] 160/5
161/23 163/6 164/6
167/15 172/10 172/13)
23/4 85/3 97/8 114/22,
looks [10] 15/5 27/17
27/19 28/4 31/2 33/23
36/8 36/9 62/19 62/19}
116/13 117/10 124/18}
53/8 59/7 59/11 161/5)
27/13 29/8 31/10 42/7,
42/8 42/23 43/17 44/7
47/5 47/9 47/12 47/20
164/17 164/17 165/1
MacLeod [1] 177/24
made [49] 3/8 4/4
22/18 22/25 23/1 23/2I
23/5 23/15 23/18
23/21 24/5 24/6 24/8
28/25 29/1 30/17
30/19 40/21 43/12
54/15 56/11 58/1
62/16 64/20 67/8
80/22 94/7 97/15
97/16 111/17 128/9
137/21 138/14 139/10)
149/5 150/25 153/1
158/14 158/18 166/3
167/18 167/25 169/16
170/5 179/9 182/10
183/4 183/9 186/18
Mail [11] 65/22 84/1
91/20 93/3 93/8 154/3
154/22 154/23 155/3
155/4 155/5
main [13] 8/3 9/10
16/12 25/6 25/7 25/10
25/13 129/17 132/6
134/7 159/13 159/13
172/21
maintain [1] 15/8
major [3] 50/8 93/2
93/4
majority [1] 158/23
make [33] 2/5 9/5
11/4 14/24 29/2 41/3
53/9 53/16 53/21 54/7
54/24 58/9 58/16
59/22 75/21 91/24
93/13 93/15 97/15
108/2 122/18 132/17
134/8 135/21 148/3
151/18 152/14 156/25)
157/8 158/16 158/21
159/15 186/17
making [10] 19/11
44/12 48/4 49/5 49/8
76/17 87/2 90/21
113/16 113/17
malicious [1] 109/5
man [1] 182/15
manage [2] 147/7
186/20
managed [2] 142/23
180/14
management [6]
80/8 94/20 121/8
121/18 132/14 132/15)
Manager [3] 3/17
3/19 3/23
managerial [1] 63/13
managers [6] 43/1
65/23 65/24 70/24
102/24 103/3
many [17] 54/3 57/12
63/17 95/21 95/21
108/8 108/23 108/23
(64) late... - many
many... [9] 113/20
130/11 130/18 134/3
137/15 137/15 170/22)
173/2 173/16
March [15] 5/6 7/3
7/10 19/15 20/10
21/25 23/6 94/11 97/3
97/4 98/10 116/15
145/13 151/24 151/25)
March 2002 [3] 94/11
97/4 98/10
margins [1] 150/21
Marine [1] 5/13
mark [6] 16/15 67/25
100/12 100/16 100/25
101/6
marked [3] 15/23
15/24 19/17
marked-up [1] 15/23
material [6] 3/13 20/4I
20/6 28/6 28/21 80/20)
Matrix [1] 165/10
matter [11] 2/1 5/4
5/16 52/6 100/15
108/10 150/25 161/22
162/9 175/10 185/25
matters [12] 39/25
40/6 44/2 46/1 49/14
93/25 94/24 101/13
109/16 110/18 175/5
175/14
Matthews [1] 13/17
may [51] 1/7 1/12
5/24 9/5 9/11 9/19
9/20 10/2 11/4 14/2
14/8 16/23 17/12 20/4}
20/20 25/8 28/11
30/10 31/9 37/18 38/8
70/16 76/5 84/5 88/17,
89/14 89/15 90/1 90/1
90/6 91/11 106/4
107/5 114/20 123/15
125/25 126/7 126/13
126/15 129/6 131/19
144/2 144/14 144/21
145/6 145/9 157/5
157/23 158/8 161/1
184/5
maybe [6] 8/3 10/4
14/12 15/17 58/13
95/17
me [53] 2/5 2/9 2/11
2/22 5/5 8/25 14/1
18/24 21/5 23/8 23/14}
26/23 27/4 27/12
30/17 31/4 31/15 34/2
45/11 45/21 45/24
48/7 48/13 51/4 53/19
59/15 62/23 64/16
67/9 70/25 81/3 88/13
91/8 91/22 95/5 96/9
99/2 99/3 101/17
106/17 108/20 112/14)
118/11 126/17 131/13)
131/18 137/21 141/10)
146/8 150/22 151/16
175/20 187/12
me.' [1] 12/18
mean [25] 26/2 30/7
30/9 30/18 31/12
31/19 41/6 66/12
72/23 85/23 87/13
89/4 96/9 97/7 97/15
102/15 102/19 140/18)
150/7 152/17 155/14
159/17 160/23 165/9
179/7
meaning [1] 78/10
meaningful [1] 81/7
means [6] 75/3 77/20
146/3 157/9 168/6
170/8
meant [5] 9/2 14/1
14/25 80/16 158/23
measure [2] 47/10
47/14
mechanism [2] 79/10}
114/22
mechanisms [1]
181/15
media [2] 96/22
98/18
mediate [8] 156/9
159/20 159/25 160/14}
161/4 163/10 164/3
164/23
mediated [2] 160/22
164/14
mediation [75] 85/19
86/22 114/9 114/10
114/11 114/15 114/18)
140/7 140/23 141/9
141/14 141/17 141/19)
142/21 144/7 146/11
147/16 147/19 147/22)
148/16 150/6 152/7
155/22 155/24 156/2
156/10 156/11 156/21
157/6 157/10 157/16
157/17 157/24 157/24)
158/2 158/9 158/14
158/18 158/24 159/12)
159/16 160/7 160/8
160/12 160/16 160/20)
160/22 161/13 161/13}
161/14 161/23 162/3
162/14 162/16 162/21
162/24 163/12 164/4
164/24 165/8 169/20
170/11 176/9 177/22
178/3 178/6 178/8
180/10 180/11 180/13}
180/14 180/15 180/20)
180/22 181/7
mediations [1]
168/17
meet [4] 44/19
115/24 129/8 132/23
meeting [57] 71/12
112/16 112/18 112/21
112/23 114/2 114/6
114/7 114/8 115/1
115/3 115/13 115/16
116/2 116/15 116/18
117/9 118/21 119/5
119/9 119/14 120/8
120/9 120/12 120/13
124/24 128/17 128/20
128/25 129/17 132/6
132/19 133/12 133/18
138/22 142/8 148/12
151/5 151/13 151/23
154/6 154/10 166/17
166/20 166/21 167/10
167/18 167/20 167/25)
169/1 170/4 170/16
172/12 173/21 173/24
175/11 175/19
meetings [15] 44/18
99/20 113/18 125/4
153/7 153/19 155/19
159/24 165/3 165/9
172/10 183/19 186/5
186/6 186/11
member [15] 40/10
45/16 45/17 52/17
53/3 56/13 59/3 63/24
68/14 70/11 71/12
75/12 82/9 87/2 87/5
members [82] 39/9
39/21 46/13 46/21
46/24 47/4 48/10
48/15 48/24 49/10
50/20 53/14 53/18
53/23 54/3 54/8 54/18
55/3 55/22 56/3 57/13)
57/21 59/1 60/7 60/9
62/1 63/17 65/14
65/15 67/7 69/2 69/4
69/5 69/6 69/12 69/13,
70/8 70/25 75/21 79/1
86/23 87/12 91/18
92/17 92/24 93/6
93/12 93/20 95/13
95/17 95/19 95/21
96/15 97/2 97/9 97/12
97/14 97/19 98/6
98/19 99/11 100/12
101/3 102/12 102/22
102/23 102/23 102/24
103/2 103/18 104/2
104/4 104/6 104/7
104/13 104/15 104/18}
104/19 104/19 105/10
105/12 105/19
members’ [1] 79/18
membership [3] 78/6
93/25 94/15
memorable [1] 18/25
Memorandum [2]
72/1 76/23
memory [10] 18/23
19/4 57/18 57/19
68/15 80/4 136/11
138/3 143/21 177/5
mention [2] 30/5
109/14
mentioned [10] 6/8
13/20 20/18 33/13
93/17 110/22 123/17
125/25 171/14 186/2
mere [1] 182/24
merely [1] 141/17
merge [2] 73/1 82/22
merger [3] 70/14
74/20 74/22
merging [3] 71/4
72/25 73/25
mess [1] 186/18
met [14] 112/17
113/12 113/19 118/25}
119/2 119/5 129/21
142/6 142/7 142/16
153/23 184/18 186/11
186/25
methods [2] 103/15
103/16
Michael [1] 138/15
mid [1] 5/1
mid-way [1] 5/1
middle [3] 24/1 24/1
182/8
might [20] 1/15 2/10
27/25 29/6 50/14
51/12 52/3 53/22 97/1
97/11 101/16 105/15
115/12 126/21 131/16}
135/18 145/3 145/23
161/23 170/23
Mike [1] 119/17
million [5] 78/15
78/19 78/21 174/18
184/1
million’ [1] 78/3
mind [12] 11/12
15/12 27/19 27/21
34/14 65/2 69/17
89/16 129/20 130/19
152/20 179/23
mindful [1] 109/3
mindset [1] 133/16
Mine [1] 83/23
Minister [2] 85/16
183/25
ministers [2] 183/18
183/20
minus [2] 152/21
186/12
minute [9] 36/21
36/24 82/8 87/4 88/14
163/4 164/8 164/20
174/14
minutes [20] 23/19
31/16 89/7 147/21
147/24 147/25 148/1
148/5 148/8 148/17
151/4 151/10 153/17
154/12 154/13 165/3
173/23 174/13 185/14I
185/18
misbalance [3] 43/6
51/21 55/13
miscarriage [3]
108/7 126/3 144/1
miscarriages [1]
126/1
misinterpretation [1]
161/8
misremembering [1]
161/1
misrepresentation
[1] 171/10
missing [1] 17/3
mistake [5] 30/3 30/7
32/20 107/14 107/15
mistresses [2] 90/2
186/16
misunderstanding
[1] 58/14
Mm [1] 67/23
model [2] 78/6
141/20
moment [5] 7/4 20/6
21/15 27/2 184/5
momentum [1] 96/19
money [21] 41/7
59/17 109/10 113/5
131/13 133/2 133/6
133/24 133/25 134/3
134/13 135/19 151/7
151/8 167/14 168/11
169/21 172/14 172/7
172/25 173/5
monies [1] 185/22
monitor [1] 110/9
monitored [2] 42/13
54/6
monitoring [4] 64/9
64/12 64/15 110/9
month [3] 55/22
71/25 153/24
months [3] 1/18 6/6
175/18
more [50] 4/25 9/1
13/15 13/18 15/14
20/16 20/23 22/9
22/14 30/8 30/16
30/18 30/21 32/12
33/8 33/18 34/6 34/15]
34/25 35/3 44/16
45/25 50/7 51/22 52/8)
54/2 55/13 61/11
63/11 68/24 74/5
83/20 87/16 89/3
91/22 100/5 101/25
105/25 117/25 126/22)
134/23 152/20 152/25)
169/20 169/21 169/24I
(65) many... - more
more... [4] 171/1
182/16 185/15 187/3
morning [14] 1/3
1/20 2/16 3/4 3/5
20/11 23/6 23/15
36/16 37/6 95/25
105/5 167/21 182/19
most [5] 7/25 61/13
76/25 126/16 158/7
mostly [3] 47/25
51/23 86/1
mother [1] 171/5
motivating [1] 31/11
motivations [1]
122/15
motive [6] 27/14
32/18 32/25 33/24
34/2 35/14
MoU [6] 76/21 77/3
78/1 78/10 78/20 81/6
mount [2] 131/15
133/15
Mountain [2] 154/23
155/4
mouth [1] 100/1
move [12] 18/7 18/14
36/17 46/11 65/7 74/4
126/5 127/24 128/15
166/10 168/18 183/12
moved [1] 162/7
movement [2] 90/7
91/2
MP [6] 114/13 119/17
123/7 124/19 135/7
135/8
MPs [13] 82/6 114/24
116/11 117/21 125/16
136/3 136/8 136/9
136/16 136/18 136/19)
136/20 136/21
MPs' [1] 122/17
Mr [102] 1/5 1/11
1/12 2/25 3/2 3/4 5/21
6/13 7/19 7/19 7/22
8/15 9/3 15/24 16/25
17/18 17/25 18/9
19/14 19/21 20/16
24/13 24/21 26/11
26/18 26/21 27/3 27/6
28/1 28/6 28/12 28/12
28/14 28/15 28/18
28/19 28/21 28/23
28/25 29/4 30/9 32/10)
35/2 35/20 36/11
36/15 36/20 36/21
37/13 48/2 67/22 68/8
68/8 84/17 86/5 88/18
89/1 89/17 89/20
89/21 90/9 93/18
93/18 93/24 94/9
94/12 94/23 95/2 95/6
95/7 99/2 106/6
106/23 118/10 125/7
125/7 125/24 125/25
126/12 139/23 139/23)
155/20 176/15 176/15)
177/4 181/5 181/19
182/9 183/17 185/2
185/8 185/9 185/20
185/21 186/4 186/10
186/22 187/19 188/4
188/10 188/17 188/19)
Mr Baker [1] 68/8
Mr Bates [1] 86/5
MR BEER [6] 1/11
3/2 28/12 36/21
183/17 188/4
Mr de Garr [1] 182/9
Mr Furey [4] 93/18
93/18 94/12 94/23
Mr Furey's [2] 93/24
94/9
Mr Henderson [4]
125/7 125/25 139/23
176/15
Mr Jenkins [14] 7/19
9/3 15/24 17/18 17/25)
18/9 19/21 26/11
26/18 28/6 28/12 29/4
35/20 155/20
Mr Jenkins’ [10] 7/22
8/15 16/25 20/16
24/13 24/21 27/6
28/21 28/25 32/10
Mr Justice [2] 90/9
181/19
Mr Kearns [9] 37/13
48/2 84/17 89/17
89/21 95/2 95/6 99/2
106/6
Mr Nippi Singh [1]
67/22
Mr Pinder [1] 7/19
Mr Singh [1] 68/8
Mr Stein [6] 88/18
89/1 95/7 185/2 185/8)
185/9
MR STEVENS [9]
106/23 118/10 177/4
181/5 186/4 186/10
186/22 187/19 188/17,
Mr Thomas [5] 28/14
28/15 28/18 28/19
28/23
Mr Thomas' [3] 5/21
6/13 28/1
Mr Ward [12] 1/5
1/12 2/25 3/4 19/14
26/21 27/3 30/9 35/2
36/11 36/15 36/20
Mr Warmington [5]
125/7 125/24 126/12
139/23 176/15
Mr Warmington's [1]
185/21
Mrs [2] 112/14
186/16
Mrs Hamilton [1]
112/14
Mrs Jeremiah [1]
186/16
Ms [23] 15/24 37/12
37/13 88/20 89/2 92/1
92/15 93/17 95/3 95/4
100/8 100/12 105/22
111/24 112/9 118/12
168/1 176/18 185/2
186/2 187/15 188/8
188/12
Ms Hamilton [1]
112/9
Ms Hamilton's [1]
111/24
Ms Hodge [6] 37/13
92/1 92/15 93/17
100/12 105/22
Ms Linnell [4] 176/18
185/2 186/2 187/15
Ms Linnell's [1]
118/12
Ms Lowther [1]
15/24
Ms Vennells [1]
168/1
Ms Watt [4] 88/20
89/2 95/3 100/8
much [14] 1/4 1/7
36/14 37/7 67/16
68/20 76/22 103/4
112/3 130/15 139/18
187/10 187/11 187/21
much-discussed [1]
76/22
muddled [3] 143/13
143/22 170/18
must [7] 2/11 2/22
18/4 79/17 92/3 124/3
172/24
my [129] 4/8 5/25
10/5 11/12 14/2 26/4
26/16 26/25 28/2
31/24 32/1 32/3 34/3
34/20 35/17 36/9
37/13 42/6 43/12
43/12 44/13 45/24
46/9 48/22 48/23
48/25 49/17 51/23
52/13 52/25 54/14
56/22 57/1 58/1 58/15
58/20 58/21 60/12
62/23 64/1 64/13
64/20 65/1 66/15 67/1
67/10 68/14 68/19
69/7 70/19 72/10
72/16 73/13 75/18
76/3 76/15 76/16
80/25 82/7 82/18 83/6
83/7 87/19 89/4 90/1
92/10 92/23 95/16
96/13 96/22 98/9
101/17 103/13 103/17}
103/23 105/21 107/20}
108/12 108/17 110/16)
4111/7 111/20 112/2
112/23 113/24 114/20}
114/21 116/3 118/2
123/8 123/11 125/14
127/2 127/6 128/21
135/4 135/6 136/19
137/12 138/3 140/20
142/8 142/17 143/13
143/16 143/24 144/13}
144/18 145/9 148/13
158/1 158/18 166/24
170/3 170/17 171/16
174/17 174/17 175/15}
176/4 176/12 176/19
177/5 177/7 180/25
181/17 183/10 184/4
186/12
myself [3] 46/8
108/17 110/21
N
name [7] 21/13 37/13)
37/15 90/1 106/24
110/24 154/3
namely [2] 3/7
145/16
names [1] 131/5
narrow [4] 148/9
149/11 149/13 150/20}
narrower [1] 150/3
narrowest [1] 150/21
narrowing [1] 152/13)
national [46] 40/17
42/4 42/14 43/8 43/15)
44/14 45/17 45/22
54/13 54/25 55/8
61/24 62/2 62/7 62/24,
64/5 64/9 64/11 64/17
65/15 65/25 66/6
67/10 68/13 68/17
68/20 70/1 71/10 72/3
72/12 73/6 77/16
82/19 82/19 83/1 83/2,
83/4 83/22 85/5 90/12
93/19 95/10 96/8
99/21 186/23 187/2
nationally [1] 98/5
natural [1] 103/16
nature [5] 16/14
29/23 56/16 74/10
78/22
nearly [1] 124/2
NEC [5] 71/13 80/21
82/9 85/2 87/5
necessarily [8] 66/10
69/17 69/21 69/22
75/3 81/9 184/19
186/20
necessary [2] 173/7
181/15
need [21] 5/22 5/23
6/15 21/14 34/21 35/6
36/16 51/19 73/1
74/19 89/2 89/12
105/24 107/10 126/12)
138/17 139/16 168/9
168/10 169/24 177/8
needed [3] 166/16
177/11 186/18
needn't [1] 177/3
needs [10] 1/8 13/15
13/18 20/16 27/24
31/5 33/8 109/9
170/12 174/7
negotiate [2] 66/24
180/15
negotiated [1] 50/10
negotiating [1] 70/6
negotiation [1] 73/22
negotiations [2]
45/22 72/20
neither [1] 21/14
Neneh [6] 7/8 8/13
13/16 17/24 21/6 22/2)
network [9] 40/18
43/13 54/12 113/8
121/9 126/22 132/15
142/23 169/18
never [9] 27/19 91/6
101/9 109/1 109/2
130/12 172/9 173/15
174/16
new [11] 31/23 45/5
46/11 73/8 80/22
109/12 138/22 145/2
145/7 148/13 149/18
Newsagents [3] 72/4
72/13 73/7
next [12] 5/14 13/13
18/7 29/18 36/17 37/8)
71/25 89/7 123/4
140/6 140/10 174/22
NFSP [34] 71/21
71/25 72/7 72/11
72/19 73/11 74/10
74/14 74/22 75/1
76/20 76/24 77/4
78/12 79/16 79/19
80/13 81/13 82/10
85/22 86/14 90/16
90/17 90/21 90/23
90/24 90/24 100/12
100/14 100/19 100/23}
113/25 124/13 186/25]
NFSP' [1] 78/20
NFSP00001463 [1]
67/15
night [2] 55/13 105/8
nil [14] 5/25 6/3 6/14
7/5 TINT 10/5 14/3
16/6 19/21 26/11 33/2I
nine [1] 68/15
Nippi [1] 67/22
no [144] 12/4 15/2
15/11 15/17 17/1 17/5}
(66) more... - no
N
no... [138] 17/14
18/11 18/21 19/7 23/8)
25/3 25/20 27/16
28/24 30/7 30/25
31/12 31/12 32/22
33/4 34/2 34/3 35/17
35/25 36/14 42/6
42/18 42/18 45/23
48/13 48/14 48/17
49/13 51/14 53/13
53/20 54/7 57/25 58/8
58/13 61/21 62/4
62/12 62/23 63/16
63/22 64/3 64/3 64/5
64/5 65/5 65/12 68/10
69/19 69/19 69/23
69/23 72/16 73/13
74/17 76/11 77/16
78/11 78/18 81/6 82/7
83/11 83/21 84/25
88/3 88/9 88/12 88/12
89/10 89/18 89/18
91/5 98/16 98/18
99/16 109/12 111/19
113/3 113/9 113/24
116/3 118/6 119/20
120/12 123/3 123/6
123/7 123/19 123/20
124/5 126/2 127/21
128/10 128/12 128/14}
133/2 133/14 134/14
135/25 137/1 138/1
139/15 142/8 142/17
143/1 145/18 145/22
153/1 153/5 154/11
156/3 156/4 156/10
157/16 159/13 160/16
164/19 167/21 169/13}
170/6 171/15 173/9
173/15 175/17 176/9
177/14 178/23 179/21
179/21 179/24 182/16)
182/23 184/17 185/8
185/12 187/2 187/17
187/17
nobody [3] 23/7
131/21 136/21
nodded [1] 38/9
Noel [5] 3/9 3/23 4/5
19/13 33/1
nominate [1] 108/15
nominated [2] 115/9
147/10
none [7] 114/1 115/3
131/25 134/14 134/21
138/12 166/16
noon [1] 84/11
nor [1] 158/25
normal [15] 9/13
9/24 13/20 13/23
17/11 20/19 21/2
25/24 26/13 27/11
33/14 34/10 34/23
86/24 91/2
normally [1] 180/12
not [223]
note [10] 154/2 167/4
167/5 167/15 170/5
171/14 171/17 175/25
176/2 184/6
noted [5] 163/18
164/4 164/15 164/24
174/3
notepaper [1] 118/12
notes [4] 133/18
143/16 151/23 171/16)
nothing [3] 122/22
133/8 147/22
noticing [1] 121/3
notified [1] 80/21
notify [1] 145/6
November [3] 38/19
151/10 174/14
now [111] 2/16 3/13
4/8 4/10 5/6 6/6 6/6
6/18 9/7 10/19 15/5
20/4 20/14 21/11
21/18 22/11 23/13
24/19 27/8 27/17
27/19 30/14 36/17
36/21 39/2 45/8 46/15
48/18 49/22 50/1
50/12 50/17 50/24
53/2 53/11 54/23 57/3)
57/9 58/24 59/1 60/19)
61/13 64/6 65/22 67/6
67/12 68/16 69/1
70/13 71/19 73/10
74/4 76/19 77/2 79/5
81/1 81/12 81/21
81/21 82/8 85/16
85/24 86/21 86/23
87/4 89/5 90/10 92/2
92/11 93/17 100/20
104/3 106/9 107/8
109/20 112/12 117/5
120/6 120/24 124/15
124/18 124/24 127/1
127/3 127/15 129/23
130/10 136/23 138/15)
140/6 141/24 146/11
147/18 148/6 151/25
152/11 152/21 153/19)
167/3 168/23 170/7
170/14 172/4 172/15
174/12 175/13 176/12)
177/16 183/16 185/2
186/9
number [28] 1/18
13/19 20/17 33/10
41/21 42/16 42/16
46/9 47/14 51/10
51/20 56/23 60/13
60/24 65/17 73/2 73/3
90/2 90/7 97/16 98/22
102/21 107/7 117/21
135/15 154/16 161/1
161/16
number 28 [1]
154/16
number 3 [1] 90/7
numbered [1] 10/7
numbers [3] 6/18
65/3 99/7
numerical [1] 107/15
[e)
oath [1] 4/21
objected [5] 148/10
152/22 162/23 164/9
182/20
objection [3] 2/13
2/14 89/10
objectives [1] 69/10
obligation [1] 104/15
obligations [2] 75/3
80/18
observes [1] 79/21
obsession [1] 146/24
obstruct [1] 150/19
obtain [1] 180/8
obtained [3] 41/25
45/15 48/20
obvious [2] 91/11
151/3
obviously [7] 11/20
15/12 26/2 31/15 87/5
94/23 114/15
occasion [25] 1/13
1/22 3/16 3/22 4/3 4/9
4/12 4/15 4/21 19/10
19/14 19/19 19/24
20/8 20/12 21/11 22/4
25/15 26/22 27/3
34/11 40/9 40/20
41/14 50/22
occasionally [1] 70/9
occasions [8] 51/21
57/12 94/17 98/22
172/9 173/6 186/8
186/19
occur [2] 6/4 138/23
occur." [1] 7/18
occurred [8] 47/25
53/8 63/10 97/5
125/23 126/4 150/10
169/7
occurrence [1] 13/21
occurrence’ [3]
13/23 20/19 33/14
occurrences [4] 9/24
25/24 26/13 55/20
occurrences' [3]
21/2 34/10 34/24
occurrences.” [1]
9/13
occurring [2] 129/19
132/8
occurs [2] 127/10
162/20
October [6] 67/14
67/19 68/2 74/9
173/21 173/22
oddly [1] 29/25
odds [1] 109/2
off [11] 120/13
128/16 134/4 162/25
166/9 166/9 168/4
168/9 176/4 176/19
180/7
offer [6] 60/6 60/9
75/21 81/11 81/18
96/15
offering [2] 14/4
73/18
offers [1] 96/14
office [238]
Office's [6] 39/15
90/18 90/25 115/11
122/15 181/25
officer [6] 77/16
77/18 83/1 83/2 88/6
93/20
officers [2] 87/22
99/21
offices [6] 39/15 90/3)
95/23 97/20 105/1
126/20
officially [1] 113/13
officials [2] 54/13
83/22
often [2] 94/20 166/6
Oh [4] 12/5
okay [14] 2/24 3/20
4/15 4/16 4/22 8/12
15/21 18/7 20/13
23/22 25/3 63/24
176/22 181/12
old [3] 109/13 127/23
152/25
omissions [2] 13/7
13/10
on [260]
on' [1] 160/21
once [8] 4/25 70/23
73/22 109/1 151/1
153/24 166/4 177/22
one [62] 5/18 5/24
10/21 15/6 20/11 23/5]
23/16 23/25 24/2 25/5)
29/20 31/5 32/4 32/15)
34/11 43/12 44/16
49/5 52/3 55/22 57/23)
57/25 58/2 65/1 65/2
66/2 66/19 75/21 77/3)
78/11 87/2 88/13
98/18 102/9 103/10
108/15 109/13 111/12}
113/11 120/12 121/7
123/19 124/1 124/3
126/20 129/21 136/14}
137/14 151/10 152/17}
158/11 161/2 162/19
164/5 164/16 171/20
171/21 179/24 180/11
180/14 182/3 184/7
ones [9] 5/18 105/11
105/15 118/1 136/3
136/8 152/21 169/23
176/17
online [3] 6/2 7/6
7/16
only [21] 36/11 62/15
67/9 70/22 81/10
81/17 100/23 103/10
111/25 120/12 135/20)
144/25 145/13 146/21
151/9 153/23 157/17
158/13 158/19 166/2
183/10
onwards [1] 112/3
open [8] 22/11 22/11
73/3 74/1 122/24
150/14 169/20 185/4
opening [1] 105/4
operate [3] 43/14
80/3 130/8
operated [3] 103/9
128/10 142/12
operates [1] 87/21
operating [4] 11/13
12/1 34/14 85/15
operation [4] 113/7
130/4 132/14 139/19
operational [1] 40/16
operator [2] 22/24
23/25
opined [1] 137/11
opinion [4] 122/17
123/9 123/10 123/11
opportunities [1]
71124
opportunity [5] 51/17I
88/24 108/5 161/10
176/9
opposed [1] 77/14
opposite [3] 61/25
137/21 181/8
opposition [2]
132/24 161/3
option [1] 123/16
options [5] 71/24
73/2 73/21 74/1
122/23
or [207]
oral [2] 116/14
139/20
order [5] 7/21 52/4
52/9 177/11 179/9
ordinarily [1] 52/5
organisation [11]
73/1 77/5 77/12 78/23}
81/10 81/18 86/1
91/24 92/25 93/16
132/12
organisations [3]
70/4 72/14 98/15
organised [1] 109/13
(67) no... - organised
[e)
original [7] 11/16
21/19 21/20 29/10
33/5 136/16 156/5
originally [3] 25/6
29/16 155/19
other [38] 34/12 45/3
66/20 71/2 72/10
72/15 72/24 73/14
73/19 73/21 80/18
87/2 88/20 94/24
94/24 108/11 108/15
122/23 123/7 124/13
126/21 127/1 131/19
139/9 148/12 152/18
153/11 154/4 158/25
165/3 165/23 166/7
166/25 181/24 183/3
185/6 185/25 186/13
others [9] 59/25
72/12 100/25 102/11
123/18 126/15 136/15
141/2 181/17
otherwise [3] 181/1
182/12 186/7
ought [3] 30/3 64/9
168/11
our [57] 1/23 14/8
15/8 20/20 21/18
36/17 37/8 45/17 47/4
48/4 53/13 54/8 54/14
54/15 54/16 54/18
54/20 54/21 55/2 55/3
56/3 56/4 56/6 56/20
56/21 62/4 63/14
75/20 75/23 81/8
81/20 86/15 86/23
87/20 89/17 93/6
93/11 97/19 97/22
98/6 99/11 99/18
99/20 103/18 104/6
104/9 104/11 108/20
115/13 117/13 120/13)
134/9 138/21 168/18
179/3 183/1 185/17
ours [3] 98/24 121/15]
121/16
ourselves [1] 91/19
out [39] 5/22 9/14
16/21 25/18 36/23
41/7 48/12 57/6 58/7
61/1 64/19 64/24
75/11 83/22 89/15
90/9 93/9 102/16
104/16 105/10 105/15
116/8 119/25 120/3
122/1 124/12 125/4
125/19 126/4 128/22
149/4 150/3 150/9
154/13 169/4 169/6
170/24 177/24 181/18}
outline [1] 42/6
outlined [1] 54/20
outset [1] 26/3
outside [3] 52/14
77/21 112/17
outstanding [1]
154/16
over [46] 3/2 5/23 6/5
17/9 17/14 17/22 18/5)
18/12 19/20 23/16
23/18 23/18 23/20
24/2 29/18 44/6 45/9
45/11 46/6 46/9 50/25
54/19 56/19 56/23
61/2 61/2 70/25 70/25
72/10 72/21 73/14
78/16 83/25 85/24
96/17 96/20 100/13
122/21 126/16 150/1
162/6 170/19 170/22
174/18 174/19 182/13)
overall [2] 29/24 81/2
overcome [1] 180/6
overcut [1] 136/6
oversaw [1] 141/14
oversee [2] 40/16
48/25
overturn [1] 144/25
overview [2] 142/13
144/6
own [16] 16/25 41/11
47/6 53/9 91/1 97/12
97/13 101/2 110/16
133/9 137/12 138/8
152/8 155/7 174/17
174/17
owned [1] 79/23
owners [1] 77/14
Pp
page [85] 4/23 5/5
5/15 6/5 6/5 6/12 6/21
7/21 8/13 10/12 10/14
10/20 16/7 18/7 21/24
23/24 24/1 24/2 24/3
24/11 25/4 37/24
46/18 67/17 69/8 74/4
76/19 78/16 81/1
81/24 81/25 85/8
85/24 107/9 107/16
111/3 115/7 118/9
120/24 121/25 124/2
126/6 128/19 129/5
129/7 129/14 132/20
136/24 138/13 138/18
141/25 142/25 143/1
143/6 144/17 146/12
146/13 148/6 153/4
153/5 153/21 153/25
154/8 154/9 154/14
154/15 155/11 156/15)
158/1 160/2 160/3
160/3 161/21 162/6
163/5 166/12 166/19
171/22 172/13 173/23
173/25 174/24 174/25]
181/4 185/23
page 1 [3] 7/21 24/11
143/1
Page 10 [1] 81/25
page 11 [3] 120/24
142/25 143/6
page 12 [1] 138/13
page 13 [1] 138/18
page 14 [1] 37/24
page 15 [1] 148/6
page 16 [1] 153/4
page 160 [1] 5/5
page 161 [1] 6/5
page 18 [1] 141/25
page 2 [6] 6/21 111/3
154/8 156/15 160/3
173/23
page 20 [1] 146/12
page 22 [4] 121/25
page 24 [2] 107/9
166/12
page 27 [1] 155/11
page 28 [2] 153/5
171/22
page 3 [6] 6/12 10/20
69/8 74/4 160/3
174/24
page 31 [1] 181/4
page 4 [4] 115/7
118/9 128/19 132/20
page 40 [1] 4/23
page 41 [1] 107/16
page 5 [2] 144/17
154/14
page 6 [2] 172/13
173/25
page 7 [2] 46/18
185/23
page 8 [2] 158/1
163/5
pages [1] 37/23
pagination [1] 4/25
paid [10] 41/7 48/23
79/1 90/17 90/24
109/11 117/2 133/3
173/8 186/21
panel [2] 178/8 178/9
paper [7] 96/11
172/14 172/15 173/8
173/10 173/13 175/20
papers [2] 51/4 167/6I
paragraph [58] 6/1
7/15 10/8 16/3 16/8
24/12 25/5 30/15
30/18 32/4 32/19 34/5)
46/16 46/19 50/17
53/12 57/3 69/8 69/9
74/18 77/3 79/8 79/9
79/11 79/15 80/12
81/25 86/11 86/21
90/11 92/3 92/11
107/10 107/18 111/4
111/4 113/1 118/9
118/20 119/24 120/24]
127/10 128/19 129/6
130/9 132/21 141/25
146/13 148/7 153/8
155/12 156/17 158/3
166/12 171/22 172/4
181/13 185/23
paragraph 101 [1]
155/12
paragraph 108 [1]
153/8
paragraph 11 [1]
92/11
paragraph 1120 [1]
90/11
paragraph 119 [1]
181/13
paragraph 12 [1]
185/23
paragraph 15 [4]
118/9 118/20 128/19
132/21
paragraph 157 [1]
107/18
paragraph 2 [2] 77/3
127/10
paragraph 3 [1] 10/8
paragraph 33 [5]
46/16 46/19 50/17
53/12 57/3
paragraph 47 [1]
120/24
paragraph 5 [2]
111/4 111/4
paragraph 55 [1]
148/7
paragraph 6 [2] 79/8
79/9
Paragraph 6's [1]
80/12
paragraph 66 [1]
141/25
paragraph 6c [1]
79/11
paragraph 7 [1] 92/3
paragraph 76 [1]
146/13
paragraph 8b [1]
69/8
paragraph 9 [1]
113/1
paragraph 91 [2]
107/10 166/12
paragraphs [12] 5/22)
9/5 10/4 10/21 11/8
11/9 13/1 18/8 20/14
29/19 107/15 147/11
paragraphs 91 [1]
107/15
pardon [1] 136/5
Parsons [5] 142/5
142/6 142/13 143/8
143/25
Parsons' [1] 143/10
part [23] 4/11 7/13
8/4 16/24 25/8 79/8
82/7 83/6 90/6 90/9
100/15 100/16 113/21
130/25 141/17 143/8
162/23 171/11 173/12
175/1 175/2 183/24
187/3
Participants [1]
185/6
participate [1] 165/6
participating [3]
155/14 165/23 166/1
particular [7] 75/2
77/15 122/22 126/24
137/6 161/4 183/24
particularly [7] 60/20
135/6 137/8 138/21
149/1 160/24 168/18
parties [3] 162/2
162/4 163/8
parties’ [1] 86/4
partly [4] 5/1 48/25
93/5 93/7
partner [5] 73/18
108/17 110/2 111/9
112/6
partners [1] 73/4
partnership [2] 72/21
91/23
parts [3] 117/18
139/9 144/11
partway [1] 5/2
party [2] 158/25
160/13
passed [2] 6/6 99/20
passing [2] 148/16
171/18
past [3] 103/24 134/7
145/20
Paul [4] 13/17 37/11
37/16 188/6
Paula [19] 118/22
118/25 119/3 128/17
129/2 131/20 132/23
133/12 133/21 134/6
134/11 166/17 166/21
167/8 167/16 168/8
169/2 169/13 169/15
pause [5] 85/17
88/13 88/15 170/14
184/6
pausing [9] 46/23
74/13 82/8 114/15
127/3 129/23 131/2
150/4 156/23
pay [10] 75/15 87/3
87/3 92/13 92/19
108/5 108/12 136/18
143/19 167/14
paying [1] 133/7
payment [1] 79/4
pays [1] 179/15
peers [1] 82/6
pen [1] 127/23
(68) original - pen
Pp
Penny [3] 5/24 6/13
718
people [46] 41/22
44/4 47/23 47/24
51/15 51/23 55/12
57/5 57/7 58/22 61/6
62/23 66/17 68/24
91/8 91/13 94/1 98/14
99/7 99/17 100/5
101/16 102/16 103/14
103/20 104/25 115/4
123/1 130/25 131/22
132/17 134/4 141/12
143/17 143/19 147/14}
150/13 166/8 166/25
168/21 178/7 179/3
183/3 183/5 186/25
187/1
people's [1] 18/23
per [7] 29/10 78/3
78/19 78/21 120/18
133/1 180/22
per annum [3] 78/3
78/19 78/21
perception [1] 41/21
perfect [2] 133/2
156/16
perfectly [1] 130/8
perform [1] 39/21
performance [6]
42/21 43/4 51/12
51/19 52/6 55/19
perhaps [7] 8/12
78/11 89/7 95/12
99/13 101/14 104/15
period [9] 5/23 24/18
58/11 72/11 73/14
84/21 85/18 97/3
174/20
periods [1] 170/22
person [12] 2/21
14/16 15/17 17/15
27/5 108/15 113/11
139/14 147/2 153/24
159/20 180/16
personal [13] 46/24
47/6 48/9 49/6 49/13
49/16 57/9 58/12
122/17 123/3 123/9
130/19 183/10
personally [3] 48/13
97/7 108/9
persuade [1] 8/11
phase [2] 38/21
73/16
Phase 2 [1] 38/21
Phases [2] 38/16
38/25
Phases 5 [2] 38/16
38/25
phrase [13] 44/2
47/10 51/25 55/25
56/5 66/17 73/2 93/1
93/11 127/8 132/9
152/5 167/11
phrased [1] 58/15
phrases [1] 182/19
physical [1] 112/23
pick [3] 5/2 23/24
116/6
picking [2] 5/1
100/10
piece [1] 96/11
pieces [1] 179/4
pierce [1] 178/6
PIN [1] 25/21
Pinder [3] 6/24 7/19
13/16
place [24] 5/3 41/13
4219 43/17 44/3 49/19)
49/24 50/23 51/3 51/8
63/4 71/8 71/19 99/13
116/15 130/12 130/18)
141/6 143/2 172/24
179/4 179/14 180/18
181/14
planned [1] 182/1
play [2] 8/9 59/23
plea [6] 130/21 161/8
161/15 161/17 171/12)
171/13
pleas [1] 171/16
please [138] 1/8 4/17
4/23 4/24 5/14 6/12
6/21 7/1 7/22 7/22
8/13 9/3 9/7 9/8 9/9
10/11 10/20 13/12
13/14 15/22 15/25
16/1 16/2 16/7 18/7
19/4 20/7 20/9 21/6
21/18 23/25 25/4 33/5
35/3 37/10 37/14
37/18 37/23 46/11
46/16 46/19 46/23
48/2 48/3 48/8 53/11
65/7 67/15 67/17
67/19 67/24 69/8
69/24 70/16 71/9
71/19 74/4 74/18 77/2
77/6 77/25 78/16 79/7,
80/11 81/1 81/22
81/23 81/25 84/4 85/1
85/8 85/24 106/24
107/3 107/9 107/14
107/16 108/3 109/17
111/3 115/7 117/13
118/8 119/15 119/16
120/23 121/24 121/25)
124/16 126/5 126/6
128/18 129/4 129/5
132/21 134/16 136/23)
138/13 138/18 141/25)
142/25 143/1 143/6
144/5 144/17 146/11
146/13 148/6 148/17
148/20 151/6 151/22
151/25 152/22 153/4
153/17 153/25 154/7
154/9 154/14 155/11
156/13 158/1 160/1
160/3 163/3 163/5
171/22 171/23 172/11
174/24 177/16
pleased [1] 14/19
plight [1] 132/25
plus [1] 184/1
pm [6] 84/13 106/14
106/16 146/5 146/7
187/24
point [39] 2/12 3/24
44/12 44/13 46/1 52/2
63/10 64/13 64/20
64/21 72/9 72/15
77/25 78/17 79/9
80/10 96/18 97/15
109/25 112/9 116/22
127/22 142/21 149/5
154/1 154/17 154/18
156/5 156/12 160/4
162/12 164/9 164/19
168/16 168/24 169/14)
176/21 183/10 184/23
points [8] 76/25
90/21 112/25 126/16
144/14 146/11 160/10}
171/20
POL [3] 74/6 74/8
92/7
POL's [2] 74/10
85/18
POL00022120 [2]
144/5 156/13
POL00026635 [1]
154/7
POL00026640 [1]
153/18
POL00026641 [1]
148/18
POL00026656 [1]
151/23
POL00026665 [1]
163/3
POL00026673 [1]
160/1
POL00026685 [1]
172/11
POL00040475 [1]
173/22
POL00043633 [1]
174/23
POL00047895 [2]
15/22 21/13
POL00091028 [1]
119/15
POL00097402 [1]
124/16
POL00098315 [1]
126/5
163/25 166/11 166/19}
172/13 173/23 174/23
POL00098418 [1]
129/4
POL00099063 [2]
121/25 136/24
POL00101367 [1]
167/16
police [1] 144/22
policies [1] 50/10
policy [4] 51/9
153/16 179/14 179/15}
political [1] 85/17
poor [7] 17/10 27/10
31/4 31/7 31/12 31/14)
31/17
portion [1] 179/20
posed [2] 105/25
175/7
position [18] 3/20
14/20 45/18 52/19
59/16 60/1 79/2 86/12
86/15 88/5 88/22
89/23 92/9 93/17
162/13 168/19 177/19)
179/3
positive [1] 140/21
possession [3] 3/13
20/4 73/5
possibility [1] 71/3
possible [10] 54/1
56/15 70/14 72/21
74/21 124/10 129/8
133/3 139/4 143/11
possibly [5] 52/9
59/12 109/24 141/2
183/15
post [227]
post-Horizon [1]
52/23
postal [12] 40/6
82/25 83/2 83/13
83/24 83/25 87/22
87/23 97/21 98/7
101/21 102/6
posted [1] 172/20
postmaster [1] 27/25
postmaster's [2]
17/12 27/12
postmasters [9]
67/18 67/21 68/4 75/4
81/11 85/15 85/22
86/1 93/20
postmistress [1]
111/8
potential [3] 75/21
79/21 178/10
potentially [10] 13/21
13/23 20/19 33/14
33/17 33/19 34/1 35/7,
72/24 172/17
pounds [3] 52/9
52/10 174/18
power [5] 144/24
145/1 159/1 165/14
179/12
practice [4] 45/3
58/25 110/17 155/12
practitioners [1]
110/10
prayed [1] 80/5
pre [2] 52/23 155/9
pre-2012 [1] 155/9
preceded [1] 17/18
preceding [1] 69/9
precise [1] 174/7
precisely [2] 115/21
142/14
predominantly [5]
44/10 59/22 78/25
105/1 105/3
prefer [2] 185/14
185/16
preference [1] 72/2
preferred [2] 73/17
113/12
preliminary [2]
136/25 137/7
prepared [6] 4/4
117/1 149/16 149/19
178/24 179/20
preparing [3] 96/13
119/21 149/15
present [2] 132/1
171/3
presentation [3]
143/3 143/9 143/10
presentations [1]
142/4
presented [1] 183/17
presenting [1]
143/18
preserved [1] 153/12
press [1] 94/21
pressed [1] 130/12
pressing [1] 120/6
pressure [2] 135/6
135/7
presumably [8]
56/18 71/17 74/21
80/16 119/19 155/5
163/19 170/8
pretending [1] 24/8
pretty [4] 18/24
143/17 161/20 170/10}
prevented [1] 171/4
previous [11] 1/22
5/25 10/11 31/24
45/24 56/22 149/6
152/14 155/2 159/3
164/24
previously [14] 9/8
13/20 13/25 18/8
20/18 33/13 39/3
58/24 151/24 160/19
162/21 164/5 164/16
164/18
primarily [1] 181/17
primary [2] 39/7
134/5
(69) Penny = primary
P
Prime [2] 85/16
183/25
principle [2] 2/3
86/13
printout [1] 67/12
prior [8] 41/18 45/18
58/18 58/23 59/2
prison [1] 161/18
private [3] 66/17
66/18 66/21
privately [1] 66/20
privilege [3] 2/4 2/7
178/6
privileged [2] 177/18
180/13
proactively [1] 64/15
probably [6] 8/2
36/22 120/3 131/16
152/25 171/7
problem [10] 12/1
43/2 45/4 45/5 54/21
62/11 91/11 95/7
113/4 137/20
problems [26] 41/14
41/22 42/3 42/20
44/21 50/14 53/15
53/24 54/4 54/9 55/24,
64/6 65/4 85/14 86/16
86/18 96/21 101/1
120/20 123/2 123/19
125/15 137/2 137/12
137/14 137/24
procedure [25] 42/9
42/24 43/18 43/20
44/7 47/5 47/9 47/13
49/23 49/24 50/1
50/21 51/3 51/5 51/6
51/14 51/15 51/16
52/1 52/18 55/14
55/24 63/18 65/6
99/24
Procedure’ [1] 50/19
procedures [3] 42/20
50/10 80/9
proceed [3] 89/5
161/24 163/23
proceeding [2] 89/11
179/4
proceedings [2]
32/16 60/8
process [31] 42/6
42/18 43/17 47/24
52/14 54/20 55/18
59/14 59/18 59/19
63/11 73/22 74/20
85/19 99/23 120/12
138/10 152/9 158/16
159/15 160/16 164/5
164/16 164/18 164/25
165/25 166/2 177/17
179/1 183/2 184/18
processed [2] 6/2
7/16
processes [3] 92/12
99/13 122/6
processing [2] 121/6
159/16
produce [8] 16/5
24/17 24/19 47/19
128/7 156/19 157/12
173/8
produced [18] 6/15
11/11 12/9 21/1 24/19
29/17 34/9 34/22
35/18 107/2 116/13
119/7 135/11 135/12
145/16 159/16 178/4
184/13
produces [1] 15/10
producing [2] 135/14
148/2
profession [2] 110/7
110/13
profit [2] 174/19
175/22
profitable [1] 134/8
programme [1] 50/16
programming [1]
131/8
progress [2] 147/22
175/4
prohibition [1] 79/22
project [3] 41/5
42/10 146/21
projects [1] 70/11
promote [1] 39/8
prompted [2] 98/18
129/24
proper [2] 133/6
157/20
properly [5] 11/13
12/1 32/18 56/2 148/4
proportion [1]
178/24
proposal [9] 78/14
89/4 114/9 114/10
114/11 114/19 116/4
116/6 134/10
propose [1] 165/2
proposed [3] 4/3
76/23 79/24
proposing [1] 17/19
prosecute [1] 62/20
prosecuted [16]
53/14 53/24 54/4 54/9
54/19 56/4 58/5 59/4
62/1 63/21 63/25
84/20 99/8 130/25
131/22 159/21
prosecuting [3] 59/1
110/6 110/7
prosecution [18] 4/5
19/2 19/13 28/6 28/9
28/17 28/19 28/22
33/1 53/18 54/18
131/15 144/19 144/23
145/4 171/7 171/9
181/2
prosecutions [34]
15/9 60/14 60/24
61/14 62/13 62/14
64/4 64/8 64/11 64/14
64/17 64/19 64/23
96/1 96/3 96/6 96/11
96/16 96/21 96/25
97/13 100/3 126/2
130/11 130/18 131/16
131/17 131/19 133/11
133/15 133/22 134/1
134/12 171/15
prospect [1] 177/7
protect [2] 77/12
79/17
protecting [3] 77/22
77/23 77/23
protection [1] 126/8
protest [1] 93/11
prove [3] 56/1 134/2
180/2
proved [1] 143/20
proven [3] 103/17
127/14 143/25
provide [14] 50/3
78/2 78/14 78/18 96/3
104/4 104/11 122/21
147/2 158/5 162/10
172/5 173/19 177/18
provided [10] 9/8
37/20 46/20 49/9
56/23 81/5 156/21
173/13 175/9 181/9
provides [1] 29/23
providing [4] 7/5
36/5 91/20 108/22
proving [1] 164/13
provisions [1] 81/4
prudent [1] 71/23
public [9] 1/24 84/23
91/21 97/9 97/10
100/15 133/5 176/25
179/16
publication [1] 140/9
publicly [1] 79/23
published [9] 107/25
122/11 133/9 134/17
134/25 135/1 135/23
135/24 176/24
publishing [1]
122/10
pull [1] 139/16
purpose [20] 4/5
11/7 77/11 89/13
114/7 114/7 114/8
129/17 132/6 134/7
135/2 135/14 149/4
149/25 150/2 159/9
159/13 159/13 179/13}
180/21
purposes [2] 75/10
92/6
pursue [1] 178/22
pursuing [2] 32/18
124/8
push [1] 122/24
put [36] 1/25 2/6 2/8
2/12 4/13 7/6 7/19
15/12 22/21 26/2 26/5}
26/15 27/2 31/2 31/3
31/21 52/3 59/11
88/17 99/25 114/9
114/11 115/4 123/21
128/16 131/9 134/11
138/5 141/11 144/21
177/12 179/3 179/14
180/4 180/8 181/14
putting [3] 26/8
131/3 178/9
Qo
qualified [2] 109/18
127/18
queried [2] 164/2
164/22
queries [2] 24/16
136/22
question [42] 1/25
2/2 216 2/12 2/13
16/14 16/15 25/16
28/16 48/7 58/14 65/1
82/17 83/8 91/25
96/14 96/22 102/9
118/16 125/22 128/16}
132/4 132/10 135/4
142/18 145/9 151/12
151/14 170/3 171/25
172/2 173/19 174/21
175/7 175/15 176/11
180/19 183/15 184/5
184/8 186/4 186/22
Questioned [12] 1/11
37/12 89/20 95/4
106/23 185/20 188/4
188/8 188/10 188/12
188/17 188/19
questions [51] 1/14
1/20 2/8 2/9 3/7 4/8
4/13 5/4 25/3 26/22
36/11 36/13 37/14
38/17 75/22 84/5 84/6
88/9 88/11 88/19
88/25 89/3 89/5 89/13)
89/15 89/17 90/5
94/25 95/9 96/13
100/11 101/25 102/9
105/21 105/25 106/3
106/8 108/1 115/17
134/9 144/13 144/17
174/1 174/3 177/16
183/15 185/1 185/3
185/7 185/8 185/24
quick [2] 57/6 94/18
quickly [2] 63/10
87/1
quiet [1] 122/18
quite [13] 98/22
102/5 118/16 124/25
125/5 126/11 137/21
138/4 143/13 143/22
159/7 166/14 180/5
quoted [1] 94/20
R
rack [1] 19/3
raise [1] 87/16
raised [14] 40/22
62/7 85/16 96/8 101/3
114/23 116/11 117/20)
145/11 148/23 153/6
163/17 171/21 171/24I
raises [1] 160/18
raising [5] 62/25 82/3}
83/10 96/18 101/8
random [1] 23/25
range [1] 5/7
rather [11] 4/19
29/25 32/15 35/1 35/4
58/22 78/12 81/12
98/14 119/3 165/10
ratified [1] 80/6
re [3] 1/10 185/3
188/2
re-examination [1]
185/3
re-sworn [2] 1/10
188/2
reach [4] 101/12
137/10 162/5 178/8
reach/go [1] 101/12
reached [3] 62/2 81/2
122/7
reaching [2] 75/11
81/14
reacting [1] 140/20
reaction [1] 182/7
read [15] 5/4 12/19
20/14 25/6 29/10
32/19 33/9 71/17
78/12 80/16 85/24
86/11 90/9 131/10
187/19
reading [6] 4/10
15/25 62/14 62/15
81/12 175/25
reads [8] 15/1 46/19
71/22 TAIT 74/18
76/21 78/17 86/21
real [1] 111/20
reality [2] 45/22
132/24
really [24] 14/23
15/13 17/10 18/25
19/7 26/9 27/10 27/18)
30/14 31/18 32/2 32/3
32/11 32/13 36/8
48/21 54/23 74/2
(70) Prime - really
R
really... [6] 127/23
151/11 155/7 164/9
168/5 184/17
reappearing [1]
106/7
reason [20] 9/20
10/22 13/24 17/3
19/20 19/21 26/10
27/4 29/5 30/10 30/24,
32/10 33/21 63/8 66/5
74/16 75/8 93/7
150/16 170/20
reasonable [2]
131/24 177/14
reasonably [3] 80/9
145/3 162/4
reasoned [1] 162/10
reasons [13] 8/3 9/10
16/12 25/7 25/14
25/18 47/22 76/9
122/6 149/17 165/22
165/25 170/21
reassure [1] 137/20
recall [39] 1/7 1/12
1/17 5/24 8/24 35/10
50/23 67/7 68/6 70/14
84/24 84/25 101/23
101/24 112/16 113/19}
115/17 115/20 116/4
119/5 121/23 122/8
130/3 133/13 134/6
134/10 137/24 138/1
140/3 141/5 143/12
143/22 149/18 154/5
164/7 170/4 171/16
174/12 185/24
recalls [1] 116/15
recap [1] 3/14
receipt [1] 74/9
receive [3] 71/15
144/22 174/2
received [6] 41/7
50/3 72/19 76/22 78/7I
82/9
receiving [2] 129/18
132/7
recent [5] 7/1 61/13
91/19 109/13 109/15
recognise [1] 76/10
recognised [11]
33/16 70/5 75/9 75/16
75/24 76/1 84/6 88/10)
106/4 113/14 179/1
recognising [1]
132/25
recognition [4] 66/3
66/6 75/19 92/5
recollect [1] 127/5
recollected [1] 167/8
recollection [20]
62/23 66/16 95/16
114/20 114/21 115/15)
116/1 116/3 118/4
120/8 125/13 125/14
127/6 133/20 142/9
143/13 143/24 148/13)
170/15 170/17
recommend [7]
117/21 155/24 160/6
160/12 161/23 162/14)
165/7
recommendation [6]
156/20 157/13 158/15)
159/5 164/3 164/23
recommendations
[1] 164/11
recommended [9]
155/22 156/1 157/16
160/8 161/12 162/15
162/22 164/4 164/24
recommending [1]
163/12
reconcile [1] 162/3
reconciling [1]
172/23
reconstitute [1] 77/4
reconstituted [1]
76/21
record [23] 24/16
47/23 48/4 53/13
53/21 54/8 54/11
54/22 56/9 56/17
62/12 63/16 63/19
63/23 64/3 64/18
64/18 64/23 100/15
107/7 168/4 168/9
176/25
recorded [2] 41/8
174/13
recording [3] 42/4
147/21 147/24
records [6] 10/24
42/15 53/17 53/22
56/10 60/19
recover [1] 113/6
recovery [1] 126/23
recruit [4] 67/6 67/8
68/13 68/24
recruiting [1] 67/14
recruitment [2] 76/3
76/5
rectify [1] 55/24
rectifying [1] 55/18
recur [1] 151/12
recusal [4] 181/25
182/4 182/5 183/4
recuse [1] 182/16
red [2] 22/21 186/12
redacted [1] 124/2
redress [3] 141/12
141/21 183/13
reduced [1] 171/17
refer [14] 6/1 6/9
92/2 92/17 97/3
107/11 111/9 118/21
128/20 133/11 133/17]
137/4 146/14 150/5
refer' [1] 10/24
reference [25] 72/5
74/21 79/25 85/11
107/7 109/16 148/10
148/22 148/25 149/6
149/7 149/11 149/14
149/19 149/24 151/22
152/1 152/3 152/6
152/10 152/13 154/16
156/6 185/21 187/9
referenced [2] 72/23
79/8
references [1] 87/8
referred [18] 50/21
52/11 52/25 59/1 62/9
62/9 73/9 127/4 136/9
136/12 138/15 148/7
151/9 158/2 158/3
176/18 184/9 185/25
referring [14] 47/2
47/4 100/11 117/7
120/13 124/24 126/16
129/10 131/6 137/2
149/9 168/24 173/23
173/25
refers [6] 74/23
117/17 129/15 166/20
168/3 181/19
reflected [2] 149/24
151/4
refused [2] 92/7
109/2
refusing [1] 76/10
regard [2] 139/18
151/16
regarding [5] 7/5
82/3 138/15 186/9
186/22
Regardless [1]
160/12
regards [2] 56/24
94/19
regional [7] 43/15
43/22 44/20 44/24
49/21 54/14 99/19
regret [1] 168/14
regular [3] 44/18
55/20 99/22
regularly [7] 41/17
44/19 55/14 112/15
130/2 139/10 172/2
regulate [2] 69/2
69/12
reinforce [2] 154/1
154/18
rejected [1] 157/8
relate [4] 5/10 5/21
40/25 60/21
related [3] 69/24
81/21 85/4
relates [2] 5/25 71/20
relating [8] 16/5
24/17 30/12 48/18
53/17 60/13 98/6
110/19
relation [10] 3/25 5/7
5/17 19/1 88/22 92/22,
93/25 94/14 172/7
186/15
relations [1] 43/25
relationship [8]
45/12 54/13 69/25
74/6 74/10 76/20 81/8)
125/3
released [6] 89/12
106/5 119/11 135/4
135/5 139/13
releasing [1] 135/3
relevance [1] 38/20
relevant [10] 19/9
38/24 90/9 99/5 99/17)
101/9 154/4 155/9
158/17 172/17
reliability [1] 13/2
reliable [1] 15/10
reliance [1] 84/20
reliant [1] 53/4
relied [1] 131/14
rely [1] 2/7
relying [2] 42/19 63/2
Remaining [1] 16/3
remains [4] 49/20
49/23 79/23 123/11
remediation [1]
141/12
remedies [1] 143/11
remember [16] 1/15
11/1 18/22 30/14
32/14 57/23 131/3
131/5 138/4 141/15
167/10 167/20 171/6
174/14 174/15 177/17
remind [6] 1/19 2/5
4/9 104/15 118/11
175/20
reminder [1] 129/16
remit [6] 77/21 82/7
83/11 122/2 122/3
152/15
remote [2] 36/16
138/16
remotely [2] 2/16
139/1
removal [1] 74/11
remove [3] 28/24
34/2 114/21
removed [8] 12/7
12/7 26/5 27/1 28/21
31/6 36/6 74/14
remunerate [1] 67/3
rep [18] 43/21 43/21
43/22 44/5 44/5 44/8
49/18 50/13 55/16
55/17 55/21 57/16
57/16 57/17 63/2
63/25 101/19 103/13
repeat [1] 31/19
repeatedly [1] 187/15
repeating [1] 101/17
rephrase [3] 128/1
131/18 142/19
replace [2] 15/20
148/25
replaced [2] 150/6
150/18
replicate [1] 121/5
replied [1] 153/13
reply [1] 7/23
report [47] 71/10
71/15 71/20 81/4
82/10 85/2 85/3 85/20)
87/5 87/15 114/16
114/18 119/7 119/9
119/11 121/24 122/1
122/10 127/24 128/15)
128/22 134/17 134/19)
134/25 135/3 135/9
135/22 136/23 137/22)
138/11 139/1 139/13
139/17 139/21 139/22)
139/24 140/10 140/13)
140/21 148/11 148/12)
155/23 156/8 160/7
175/1 175/2 184/13
reported [5] 41/15
41/17 61/22 85/10
175/8
reporting [2] 41/22
96/22
represent [16] 50/14
65/10 66/5 68/3 69/20
69/20 70/7 75/7 75/24
76/2 79/18 90/2 91/13}
91/18 92/24 93/15
representation [14]
43/22 46/12 46/21
49/9 60/7 65/8 70/11
76/6 76/17 81/11
81/18 96/4 112/25
178/1
representative [10]
47/12 63/14 71/2
76/12 88/20 91/3 91/7
91/10 91/23 92/21
representatives [15]
42/25 43/14 50/2
62/16 63/22 78/9 84/7I
88/10 99/18 99/22
100/2 106/4 127/19
134/22 140/9
represented [7] 57/5
59/3 75/4 82/15 101/6I
103/14 185/2
representing [7]
46/24 48/10 56/13
59/5 65/24 66/1 68/21
represents [2] 48/24
81/6
reps [26] 43/9 44/14
44/18 44/19 44/20
45/2 45/6 49/20 49/21
(71) really... - reps
R
reps... [17] 49/21
49/22 50/9 54/12
54/14 54/14 54/16
54/20 54/21 55/2 56/4
62/4 99/11 99/16
104/9 104/12 104/13
reputation [2] 90/19
90/25
request [6] 5/8 56/9
56/11 88/16 109/2
173/16
requested [2] 128/24
134/13
requests [3] 5/10
12/7 123/25
require [2] 5/16
177/18
required [5] 83/19
123/5 131/25 152/10
152/19
requiring [1] 158/11
research [3] 56/20
56/21 137/13
researching [1]
177/13
resign [2] 57/8 58/22
resigned [1] 58/4
resigning [1] 64/22
resolution [4] 80/19
158/11 159/15 162/5
resolve [2] 114/13
114/22
resolved [1] 55/6
resolving [1] 159/11
RespCd [1] 29/21
respect [4] 2/6 93/7
108/12 183/20
respond [1] 181/15
responded [1] 81/22
responding [2]
126/11 149/23
response [10] 8/16
9/15 10/14 29/12
29/21 30/11 32/4 83/7
140/2 174/2
responses [2] 24/22
115/14
responsibilities [6]
39/3 48/18 83/7 83/22
97/18 97/18
responsibility [19]
39/8 39/25 40/5 40/12
41/11 45/9 45/12
48/22 72/17 87/20
87/21 87/22 94/9
97/22 98/10 98/11
98/23 99/4 101/18
responsible [8] 61/6
65/19 65/20 65/24
66/1 82/20 98/3 148/1
rest [3] 16/13 25/14
97/20
restrict [1] 148/14
restricted [3] 92/25
93/13 121/16
result [3] 126/19
156/18 182/14
resulting [1] 126/22
resume [3] 36/25
106/11 146/1
resworn [1] 1/8
Retail [3] 72/3 72/12
73/7
retain [3] 53/17 53/22)
153/1
retention [1] 152/19
retiring [2] 155/13
155/14
return [2] 74/19
89/14
returning [1] 36/19
revealed [2] 14/21
146/21
revealing [2] 35/15
151/16
reveals [1] 34/13
Revenue [2] 110/5
131/23
Revenue's [1] 110/6
revenues [1] 78/5
reverse [1] 144/25
review [22] 26/19
29/1 79/10 88/22
88/24 89/2 89/5
115/11 116/7 120/2
120/6 120/10 122/13
122/16 138/13 144/6
148/11 154/15 156/19)
156/21 157/9 159/19
reviewed [5] 154/12
154/13 155/8 156/7
159/22
reviewing [5] 26/4
26/6 26/7 27/16 31/4
reviews [11] 115/19
116/1 116/2 120/1
120/7 120/11 120/14
120/16 130/7 130/23
135/15
revised [1] 152/2
revisions [1] 9/4
revisit [2] 38/23 40/8
reworked [1] 152/3
rewritten [1] 47/14
right [73] 1/20 1/24
2/23 3/18 4/24 6/9
12/5 18/1 20/24 22/16
23/7 23/9 23/11 24/14
24/25 33/25 34/7
34/16 34/16 36/18
36/24 38/10 39/5
39/10 39/15 39/19
39/22 40/2 40/13
40/23 41/1 41/9 41/24
46/3 49/4 49/15 58/3
58/10 58/17 60/2
60/17 60/19 61/15
62/6 62/21 65/11
66/10 69/3 69/6 70/11
84/21 87/12 93/18
93/24 94/2 94/18
100/7 102/14 105/22
106/13 107/5 108/6
112/8 118/16 126/9
156/10 160/13 166/14)
167/18 176/14 176/25)
181/11 184/8
right-hand [3] 4/24
23/9 23/11
rightly [2] 126/19
142/1
rights [1] 70/6
rise [1] 61/14
risk [2] 2/1 79/20
risk' [1] 80/6
Robinson [1] 182/9
robust [1] 86/15
role [18] 39/7 39/21
40/10 45/8 45/13
45/14 46/7 46/10 49/2
56/22 61/18 62/24
83/15 96/23 157/21
158/13 164/2 164/22
roles [2] 39/2 69/1
roll [4] 170/19
rolled [5] 48/12 58/7
61/1 158/24 170/22
rolling [1] 135/18
rollout [2] 40/17 64/7
Ron [14] 112/19
114/3 115/2 121/14
124/22 125/5 126/7
138/6 139/7 139/12
141/1 150/11 173/1
175/18
Ronald [1] 119/17
room [5] 59/21
155/16 155/17 165/5
165/11
roughly [2] 113/20
167/20
round [3] 27/22
117/3 137/13
rounding [1] 180/7
Royal [11] 65/22 84/1
91/20 93/3 93/8 154/3
154/22 154/22 155/3
155/4 155/5
Rudkin [1] 138/15
rule [5] 2/14 83/23
87/20 97/22 185/3
rules [3] 59/23 113/3
166/5
run [4] 5/4 50/6
159/16 181/18
running [1] 102/4
runs [1] 37/23
So
said [81] 4/9 4/15
7/10 11/1 13/24 17/21
18/9 19/24 26/3 27/4
28/2 28/11 29/11
29/16 31/2 31/8 31/19
31/24 33/18 35/10
35/23 36/2 41/14
41/20 47/6 50/24
54/16 54/23 55/5
58/25 59/17 61/21
61/25 61/25 63/25
69/17 70/9 76/15
84/17 85/9 87/19
90/10 91/6 96/2 96/4
98/17 98/21 101/5
104/11 115/20 115/25}
125/13 128/15 133/20
136/6 137/18 137/23
139/11 140/3 143/12
143/14 143/22 143/25}
150/24 155/2 156/9
159/19 159/22 164/15}
165/4 168/8 169/19
170/3 170/4 170/16
170/17 170/19 171/10}
171/11 171/21 172/8
sales [1] 127/22
salient [1] 76/25
Sam [1] 90/1
same [20] 9/15 10/17
20/11 20/12 21/25
49/20 52/19 61/5
63/20 68/1 69/21
69/22 121/5 129/3
142/18 156/13 168/2
182/18 184/19 184/21
sample [1] 136/11
satisfaction [2]
100/17 160/19
satisfied [4] 115/13
116/17 125/18 125/20}
satisfy [1] 115/20
save [1] 38/23
saw [6] 103/10
118/11 121/17 122/12)
167/19 181/21
say [127] 5/15 11/12
11/25 14/7 14/24
17/19 18/10 30/13
31/7 32/12 33/7 33/12
33/19 34/21 35/9
39/17 39/24 42/12
42/14 42/19 43/5 49/4
50/17 51/9 52/19
53/12 54/2 56/3 57/3
58/10 58/17 58/20
61/4 61/5 61/10 61/13
62/11 62/18 63/16
66/8 66/11 69/1 69/7
69/10 70/2 72/9 72/16)
72/19 73/17 75/12
75/14 75/23 80/8
81/25 87/25 88/4
90/14 92/3 97/3 98/12
98/16 99/12 100/14
102/15 103/7 108/4
111/5 111/22 112/2
112/6 113/2 113/9
114/3 114/10 115/7
117/12 118/22 120/25}
121/2 124/6 126/19
126/25 127/11 128/9
130/9 131/2 133/4
136/8 136/13 137/16
137/18 139/16 139/25)
140/16 140/18 140/19)
142/1 142/2 143/21
146/2 146/18 147/24
148/8 152/16 152/22
152/24 153/3 153/9
155/10 155/24 157/10}
167/2 168/8 169/11
169/13 170/23 171/8
172/1 172/4 172/15
173/13 173/22 176/19}
179/6 179/17 181/13
183/10
saying [27] 9/23 10/1
14/5 30/22 32/5 35/5
35/20 48/5 51/18 56/8)
58/16 62/10 63/1 64/2
64/25 82/10 86/15
96/10 111/9 116/9
137/19 138/19 154/25)
171/6 181/22 184/4
187/15
says [45] 8/14 9/3 9/9]
12/13 14/8 15/4 24/15)
26/16 32/4 61/5 79/11
80/12 86/8 92/11
117/14 117/17 119/24)
122/2 122/2 124/21
126/14 127/7 129/7
129/16 132/21 144/20)
148/22 149/22 151/10)
152/1 153/25 154/20
155/17 156/17 157/3
157/25 158/4 160/9
160/17 161/21 162/6
163/7 163/19 168/15
170/7
scale [3] 45/2 102/5
126/21
scandal [2] 81/23
95/15
Scarborough [1]
166/9
scenes [2] 108/6
146/24
scheduled [1] 71/12
scheme [31] 86/22
114/15 140/7 140/23
141/9 141/14 141/18
141/19 142/21 144/7
144/18 144/21 145/2
146/11 147/17 147/20)
151/17 156/17 159/16)
162/21 165/13 166/4
166/5 176/10 177/22
(72) reps... - scheme
Ss
scheme... [6] 178/3
180/10 180/12 180/21
180/23 181/7
schools [1] 50/6
scope [3] 72/13
117/13 148/23
screen [5] 21/21
46/17 107/10 146/12
166/16
screens [1] 36/23
scroll [22] 4/19 4/25
5/14 6/22 7/22 9/3 9/9
13/13 13/14 15/25
16/1 20/9 21/6 22/13
23/20 23/24 33/6
67/19 79/7 81/3
148/20 163/25
scrolling [1] 24/25
Sea [1] 166/9
search [1] 94/18
second [83] 16/3
16/4 16/7 22/24 23/24
24/12 25/4 25/4 31/5
34/5 37/20 46/16
74/18 76/19 77/25
78/16 85/20 86/11
112/20 114/17 115/8
116/4 116/17 116/19
116/22 117/10 117/17
417/17 117/19 117/23}
118/1 119/24 120/9
121/11 122/13 123/20)
124/15 127/19 128/3
129/19 130/23 134/20}
134/23 135/2 135/9
135/23 136/1 136/12
136/16 136/20 137/10
142/3 150/17 153/21
155/22 155/23 155/23}
156/7 156/8 156/8
156/18 157/7 157/10
157/12 158/6 158/14
158/20 160/7 161/12
162/15 164/3 164/11
164/21 164/23 166/13}
166/14 173/18 173/18)
173/25 174/6 174/7
175/1 175/11
Secondly [1] 149/3
secrecy [1] 146/24
secretarial [1] 147/2
secretariat [1] 147/6
Secretaries [1] 83/24
secretary [29] 39/4
39/18 40/1 40/12 45/9
45/13 45/14 50/24
57/14 57/15 61/19
61/20 62/24 65/9 70/3
70/18 70/21 83/12
83/13 83/15 83/16
83/24 89/24 93/19
94/3 98/8 113/15
146/15 147/13
section [11] 67/22
68/1 68/3 68/12 68/23
75/20 87/13 99/5
99/17 152/9 153/6
Section 8 [1] 152/9
sections [1] 97/16
Security [1] 3/18
see [84] 1/3 1/5 4/14
4/18 6/22 7/1 7/11
7/22 9/16 10/19 10/21
12/6 14/7 15/5 15/15
16/8 16/24 17/3 18/8
21/3 21/6 21/20 21/23
22/2 22/4 22/19 22/22
22/23 22/25 23/2 23/5)
23/9 23/13 23/21
26/15 26/25 27/8
27/17 28/3 33/23 35/9)
36/4 36/8 37/6 38/1
38/7 47/15 67/17 68/6)
71/10 74/4 76/19 81/2
84/14 85/8 89/7 89/12
93/16 95/5 106/17
107/18 117/3 117/13
120/6 120/21 122/11
129/3 137/1 143/6
146/8 148/18 148/21
149/22 151/18 154/10)
163/4 163/25 167/4
172/12 173/17 174/23}
175/5 182/15 182/23
seeing [2] 22/16
167/7
seek [1] 38/17
seeking [3] 92/15
120/5 181/6
seem [2] 63/1 120/6
seemed [2] 147/13
169/4
seems [3] 17/10
27/10 72/19
seen [15] 5/18 17/17
22/3 32/20 58/23
119/3 119/18 119/21
123/12 137/23 138/6
138/16 140/20 167/3
173/15
select [3] 31/17
94/13 135/15
selected [1] 135/10
self [5] 2/4 2/7 102/2
102/4 110/1
self-employed [2]
102/2 102/4
self-incrimination [2]
2/4 2/7
send [2] 7/7 17/24
sending [1] 130/1
senior [10] 39/18
40/1 40/4 61/19 83/15
83/20 89/23 99/17
100/5 147/12
sense [7] 30/17
30/19 36/3 55/10
68/19 70/22 73/13
sensible [2] 106/9
177/14
sensitive [1] 80/14
sent [11] 6/14 17/24
18/18 19/5 19/15 51/4
118/18 118/19 168/1
183/18 183/23
sentence [8] 15/20
36/5 117/14 117/17
127/10 130/9 145/8
164/21
sentiment [1] 15/15
separate [10] 5/16
21/12 55/9 66/22 68/3
69/20 82/25 105/14
132/13 146/20
separated [1] 155/3
September [7] 119/4
141/22 166/22 167/17]
167/19 172/12 173/24
series [2] 131/9
183/17
serious [3] 51/22
63/12 73/25
seriousness [1]
51/24
service [2] 91/20
93/5
services [3] 96/14
96/15 147/6
serving [1] 86/25
session [3] 141/22
142/10 142/11
set [14] 25/18 63/9
68/23 77/19 86/1
110/9 110/14 110/16
149/4 149/15 149/18
150/3 152/9 166/5
sets [4] 9/14 122/1
149/15 151/9
setting [3] 32/21
68/12 93/8
settle [4] 122/17
167/12 168/10 168/13}
settlement [1]
147/15
seven [1] 61/9
several [10] 43/10
52/9 52/10 92/13
110/7 116/6 172/9
175/8 178/2 178/12
severe [1] 179/12
severely [1] 95/17
shackle [2] 92/20
92/23
shall [2] 38/16
145/25
sham [1] 181/7
shape [2] 109/6
166/7
shape-shifting [1]
109/6
share [1] 105/24
shared [4] 87/9
130/13 130/14 136/14}
Shareholder [1] 82/5
sharing [2] 45/4
163/17
she [21] 8/13 111/9
111/12 129/12 141/10}
147/4 147/12 147/13
150/17 166/24 168/19}
169/3 169/7 169/14
169/19 169/25 170/11
170/12 170/20 170/23}
170/24
she'd [3] 169/9
185/14 185/15
she's [3] 8/14 8/15
8/16
SHEILA [3] 106/22
106/25 188/14
shifting [1] 109/6
shocking [1] 182/14
Shoosmiths [1]
123/13
shop [1] 111/10
short [5] 37/4 84/4
84/12 106/15 146/6
shortcomings [1]
85/21
shortfall [4] 52/16
52/20 53/5 64/1
shortfalls [5] 46/15
48/15 102/18 111/13
130/6
shorthand [4] 2/3
138/16 185/13 185/17}
shorthand-writer [1]
185/17
shortly [6] 42/11 85/4I
107/25 112/21 117/9
167/3
should [44] 2/14 2/18)
2/20 2/21 8/1 35/12
36/6 37/17 61/17
61/18 62/5 64/14 65/1
78/11 87/16 96/6
104/3 107/4 107/18
109/9 118/16 129/25
130/12 130/18 137/11
140/13 140/19 152/8
156/9 157/9 157/10
157/17 158/24 159/11
160/6 161/10 161/23
161/25 163/23 169/20}
171/8 172/19 183/22
187/5
shouldn't [2] 29/1
138/5
show [8] 20/6 51/4
60/23 113/18 130/10
130/17 131/25 177/12}
showed [5] 20/7
20/12 52/23 59/7
165/4
showing [2] 52/16
56/10
shown [10] 9/19
27/21 46/15 46/17
47/3 48/15 60/13
67/12 84/20 107/10
shows [2] 79/2 177/5
sic [2] 28/6 165/11
side [6] 4/18 23/10
23/11 52/3 168/21
183/1
Sight [52] 85/20
112/20 114/17 115/8
116/5 116/18 116/19
117/10 117/17 117/23)
120/9 121/11 122/13
124/15 127/19 128/3
129/19 130/23 134/20)
134/23 135/2 135/9
136/1 136/16 136/20
137/10 142/3 155/22
155/23 155/23 156/7
156/8 156/9 156/18
157/7 157/10 157/12
158/6 158/14 158/20
160/7 161/12 162/15
164/3 164/11 164/23
173/18 173/18 173/25)
174/6 175/1 175/11
Sight's [4] 116/23
135/23 136/12 174/7
sign [1] 114/12
signature [6] 38/1
38/5 38/7 107/8
107/19 107/20
signature." [1] 7/9
significance [1] 77/9
significant [6] 4/11
13/7 13/9 44/25 50/19)
52/24
silos [1] 132/12
similar [5] 1/21 77/5
77/12 123/1 176/17
similarity [1] 180/3
Simon [1] 145/10
simple [1] 151/12
simply [8] 84/18
98/15 113/4 126/3
148/13 151/12 151/15}
165/19
since [12] 1/18 3/20
18/16 39/17 39/25
40/6 48/24 49/2 76/16)
94/8 103/24 155/5
Singh [2] 67/22 68/8
single [3] 3/7 3/24
52/13
sir [77] 1/3 3/1 18/21
36/13 36/15 37/6 84/3I
84/14 84/16 88/9
88/11 88/13 88/16
89/4 89/10 89/16
96/18 100/9 105/24
106/10 106/17 111/20}
(73) scheme... - sir
Soo
sir... [55] 111/25
113/9 113/19 114/3
118/15 121/13 126/7
126/25 129/6 129/15
129/24 129/25 131/20)
132/9 133/23 139/8
139/11 141/1 145/23
146/2 146/8 151/5
151/14 153/10 153/13
158/3 159/2 159/5
159/6 159/9 159/21
163/11 163/19 165/17)
172/2 176/19 178/2
183/16 183/22 184/4
184/7 185/1 185/8
185/10 185/18 185/21
186/3 187/4 187/7
187/13 187/14 187/23}
Sir Alan [27] 96/18
111/20 111/25 112/10}
112/12 112/17 113/9
113/19 114/3 121/13
126/7 126/25 129/6
129/15 129/24 129/25)
131/20 132/9 133/23
139/8 139/11 141/1
158/3 163/19 178/2
183/16 183/22
Sir Anthony [11]
151/5 151/14 153/10
153/13 159/2 159/5
159/6 159/9 159/21
165/17 172/2
Sir Wyn [1] 186/3
sirs [1] 118/12
sit [4] 82/20 83/6
91/8 104/24
sitting [3] 22/7
103/18 150/13
situation [2] 50/4
51/24
situations [1] 155/24
six [5] 6/6 61/7 62/14
152/25 153/15
six-year [1] 153/15
skills [3] 50/11 50/12
50/12
skip [1] 29/18
slide [1] 143/5
slight [1] 150/4
slightly [3] 108/18
133/14 148/20
slip [1] 166/6
sloppy [1] 32/16
slow [2] 48/3 150/20
slowed [1] 148/15
slowly [2] 16/2
183/12
small [5] 52/4 102/4
110/3 110/13 117/2
Smith [1] 110/14
112/10 112/12 112/17)
snippet [1] 103/10
so [225]
Society [2] 70/23
182/21
software [3] 126/18
127/22 131/18
sole [2] 83/25 97/22
solely [2] 121/16
149/21
solicitors [4] 178/24
179/19 179/25 180/8
some [63] 3/7 8/7 8/8
8/12 10/8 10/15 20/23)
25/23 26/12 28/11
29/22 30/20 34/6 35/3
38/17 38/17 40/8 41/3
51/4 56/8 56/10 60/13)
74/5 77/2 79/6 87/11
91/11 93/3 95/9 96/12
100/11 108/41 111/15
111/23 120/3 123/16
127/21 128/5 129/11
135/5 135/7 135/9
136/10 141/2 1441/7
141/11 142/13 143/16)
147/14 153/17 153/19)
155/4 158/8 161/8
161/8 166/6 167/11
168/11 177/16 178/6
183/11 183/13 184/23
somebody [10] 14/19)
24/7 35/12 43/16
43/18 56/12 63/20
141/10 147/13 147/14)
somehow [2] 99/10
99/12
someone [12] 14/8
19/2 20/20 44/6 94/23
147/10 149/19 150/18)
159/9 159/14 160/25
171/2
someone's [1] 182/8
something [24] 7/7
7/20 16/21 26/8 44/16
44/25 50/25 54/5 55/8
62/6 62/21 64/8 64/14
104/3 120/25 126/17
126/21 134/1 138/1
143/14 161/6 166/7
170/13 180/2
sometimes [3]
165/11 186/6 186/15
somewhat [1] 162/20
somewhere [3] 5/3
73/16 177/1
soon [1] 133/3
sorry [45] 10/11
11/21 13/13 15/25
16/19 18/21 28/13
28/15 32/2 32/13 36/8)
49/8 58/13 58/14
58/15 61/24 62/9
70/17 76/4 88/16 89/1
100/8 101/11 104/13
104/18 110/24 114/7
117/12 128/1 129/25
134/5 136/4 138/3
140/19 142/19 143/1
153/5 156/4 160/3
166/18 170/13 170/23
176/4 181/5 185/11
sort [20] 8/7 8/24
10/8 10/15 25/23
26/12 29/22 30/21
43/14 45/4 45/6 48/25)
68/16 73/22 120/2
135/9 167/11 168/11
179/17 183/13
sought [3] 124/12
148/9 149/20
Sounds [1] 6/10
South [1] 111/10
Southampton [2]
110/15 110/23
Sparrow [1] 146/21
speak [6] 2/21 5/8
55/19 95/8 108/16
183/3
speaking [4] 5/5
10/17 13/2 57/9
special [2] 71/25
108/15
specific [15] 8/10
48/14 51/20 52/15
74/16 83/8 91/5 94/11
98/4 98/23 116/10
120/11 134/24 173/19]
174/15
specifically [1] 43/6
specified [1] 24/18
specify [1] 181/21
Spelling [1] 107/14
spelt [2] 107/12
107/13
spent [1] 31/16
SPM [2] 109/3 109/9
SPMR [1] 170/7
SPMs [10] 108/6
108/16 109/7 113/12
114/14 114/23 123/5
125/4 133/6 187/1
SPMs' [1] 130/6
spoke [6] 95/11
112/7 112/10 112/13
139/11 187/1
spoken [1] 119/3
sporadic [1] 181/23
spot [8] 115/18 116/1
116/2 130/7 130/23
131/1 135/15 138/13
spreadsheets [3]
12/17 24/19 29/17
staff [22] 39/13 39/14
41/2 41/17 42/16
45/21 50/3 52/17 53/3
57/13 59/1 65/3 65/21
66/14 66/14 67/1
75/14 94/5 94/5
stage [36] 56/8 59/6
87/9 87/10 110/20
116/24 118/3 120/14
123/4 123/8 123/16
124/12 125/7 125/18
125/24 129/23 130/6
130/16 131/16 133/5
144/4 145/2 145/10
145/19 148/3 164/17
stages [2] 137/16
168/23
stake [1] 169/21
stand [2] 38/15
107/24
standard [2] 45/3
131/24
standards [1] 80/3
standing [2] 81/10
153/20
stands [1] 168/20
73/24 108/4 109/17
109/22 111/1 120/12
135/18 143/1 143/2
151/13 154/8 159/25
172/11 184/8
started [5] 67/6
99/16 130/23 141/21
178/9
starting [4] 113/1
120/20 123/13 153/18
state [4] 78/7 79/15
106/24 125/2
stated [2] 48/18 59/2
statement [139] 3/9
4/4 5/8 5/17 6/1 6/7
7/5 7/9 7/15 8/10 8/12)
8/15 8/15 8/25 9/6
11/4 12/2 12/9 13/15
13/18 14/5 14/9 14/12)
14/23 15/23 16/3
18/13 18/17 18/19
19/1 19/4 19/12 19/17
20/1 20/15 20/16
20/16 20/21 21/1
24/14 24/22 25/6
25/19 26/4 26/7 26/18)
26/20 27/1 27/7 27/17,
28/22 29/3 29/6 29/10
30/1 31/6 31/17 31/21
31/24 31/25 32/1 32/6)
32/24 33/8 33/9 34/9
34/12 34/16 34/23
35/5 35/11 35/13
35/17 35/21 37/17
37/20 37/24 38/2 38/8
38/12 38/15 39/24
42/7 46/16 53/11
54/10 58/9 58/16
58/20 61/13 64/20
105/10 105/12 175/12)
59/16 60/1 65/14 86/5)
110/25 111/25 116/10)
137/12 139/12 139/15}
start [17] 5/3 9/8 20/6)
66/8 69/1 69/7 70/2
81/24 83/7 84/17 88/4I
88/5 92/3 96/13 107/2I
107/19 107/21 108/2
1411/3 113/2 115/6
116/13 116/14 117/6
118/8 118/20 120/23
128/18 132/20 132/21
139/16 141/25 143/3
146/12 148/7 149/9
150/5 153/4 153/5
155/11 166/11 167/2
171/22 172/16 176/16)
181/4 185/21 185/22
187/9 187/11 187/19
statement.’ [1] 6/16
statements [6] 11/11
13/1 43/12 54/7 76/15)
186/19
states [2] 77/25
79/10
statistics [2] 60/13
60/20
status [2] 70/4 70/7
statute [1] 153/15
stay [1] 165/18
steadfast [1] 109/1
steal [1] 59/17
stealing [1] 58/2
Stein [11] 88/18 89/1
89/20 90/1 95/7 185/2
185/8 185/9 185/20
188/10 188/19
stenographer [2]
48/4 84/3
step [2] 64/16 87/4
stepping [1] 135/20
steps [8] 76/14 82/2
82/17 83/9 154/25
154/25 163/8 181/15
STEVENS [9] 106/23
118/10 177/4 181/5
186/4 186/10 186/22
187/19 188/17
Sticking [1] 151/21
still [13] 44/1 75/18
86/25 92/8 114/18
134/4 139/15 140/5
152/15 161/6 161/10
166/10 168/22
stock [1] 47/17
stocks [2] 105/2
105/6
stone [1] 135/20
stood [1] 182/9
stop [4] 145/23 159/1
164/25 182/25
stopped [2] 151/15
183/12
stored [1] 155/4
Stoy [2] 184/14
184/21
straight [5] 15/3
156/10 157/11 157/17
(74) sir... - straight
Ss
straightforward [1]
165/20
straits [1] 133/25
strange [1] 158/20
strategy [1] 181/16
stream [1] 78/6
strength [2] 99/8
100/3
strict [1] 77/19
strikes [1] 91/22
striking [1] 36/3
strong [4] 46/20 49/9
103/19 161/3
stronger [1] 139/18
strongly [2] 108/9
162/22
struck [1] 141/10
structure [7] 63/13
63/14 82/19 83/21
structures [2] 48/24
49/18
subject [4] 52/15
144/23 152/4 185/4
submission [1] 58/2
subparagraph [1]
80/12
subpostmaster [9]
52/20 68/12 87/13
94/14 113/8 121/8
142/24 156/24 170/9
subpostmaster's [4]
31/9 35/8 131/11
172/25
subpostmasters [63]
60/14 65/8 65/10
65/13 65/16 65/25
66/1 66/7 66/9 66/13
66/15 67/2 67/3 67/7
67/8 67/14 68/17
68/21 69/16 70/2 75/8
77/17 80/17 81/19
82/14 84/19 85/6
85/25 87/11 87/11
90/2 90/12 90/19 91/4,
92/6 94/1 95/10 97/1
99/6 100/22 100/24
102/2 102/4 105/16
108/23 110/19 111/2
111/7 113/20 113/20
118/15 125/16 133/1
133/3 133/24 134/13
151/8 153/11 168/10
186/10 186/16 186/24
187/2
subpostmasters'’ [7]
75/20 111/2 122/25
124/8 136/3 136/7
172/1
subpostmasters/mistI
resses [2] 90/2
straight... [1] 167/15
101/19 113/14 142/13}
186/16
subpostmistress [1]
108/21
subscription [2]
78/11 79/1
subsequent [4]
41/18 42/10 44/5
129/11
subsequently [3]
57/24 58/5 61/19
subside [1] 85/23
substance [4] 9/14
24/11 116/9 145/15
substantial [9] 52/8
52/16 52/20 60/24
84/21 130/4 133/8
159/18 173/11
success [2] 177/14
178/25
successor [1] 56/22
such [32] 2/11 8/23
9/23 25/24 26/13
32/13 53/8 53/22 55/3
87/15 91/7 92/13
92/18 93/1 93/25 97/4
99/14 100/3 100/12
102/6 102/11 108/11
120/6 124/9 124/13
142/11 159/11 170/17)
178/20 181/25 182/20)
184/23
suddenly [1] 166/8
suffered [3] 123/2
143/19 160/25
sufficient [11] 7/25
32/7 43/1 125/14
132/2 137/9 142/22
158/22 177/12 180/41
180/4
suggest [4] 8/1 32/15)
72/18 79/5
suggested [11]
13/19 20/17 33/1
33/10 99/15 112/7
112/9 129/2 129/13
141/15 175/10
suggesting [7] 19/11
31/5 35/11 98/19
117/23 150/23 184/19)
suggests [4] 80/7
81/12 86/5 86/20
suitable [7] 156/20
157/5 157/10 157/23
157/24 158/5 158/9
summarise [1] 183/7
summarised [1] 77/1
summarising [2]
77/3 156/19
summary [7] 9/14
29/18 51/9 51/13
100/1 100/6 156/2
sums [1] 185/25
superseded [1]
149/6
support [21] 4/1
17/12 27/12 27/25
29/6 31/9 46/12 50/3
86/6 87/17 108/14
108/22 109/7 113/7
115/23 122/6 138/6
143/23 144/1 147/2
186/15
supported [1] 108/9
supporting [1] 90/19
supposed [3] 141/19
152/14 152/16
suppress [1] 85/20
sure [13] 8/16 11/18
18/4 59/22 90/8
132/17 147/5 148/3
151/18 152/14 158/17]
159/15 185/14
surely [1] 100/24
surface [1] 101/9
surplus [1] 174/4
surprised [1] 129/21
surreptitiously [1]
24/7
Susan [9] 141/1
141/3 141/4 141/8
142/4 149/16 150/6
150/8 151/1
suspect [1] 77/15
suspected [3] 51/13
52/12 134/2
suspense [13] 151/7
151/21 172/14 172/15}
172/17 172/18 172/20
174/1 174/10 175/7
175/16 176/8 185/22
suspicion [2] 131/21
132/3
suspicious [1] 115/8
swapped [1] 130/2
Swenson's [1]
107/11
Swinson [1] 107/13
switch [1] 21/18
swore [1] 4/21
sworn [7] 1/10 37/10
37/11 106/22 188/2
188/6 188/15
sympathetic [1]
171/2
system [91] 8/4 8/7
9/2 9/12 9/20 10/1
10/4 10/8 10/15 11/13}
11/25 13/3 13/20
16/24 17/3 17/11
17/13 17/19 19/20
21/18 24/7 25/9 25/23
26/12 27/11 27/13
29/22 29/24 30/6 30/9
30/12 30/21 30/22
30/24 31/10 32/17
34/25 35/3 35/4 35/16)
35/19 35/21 35/23
40/17 42/8 42/21 43/3
43/7 43/23 53/6 63/3
63/4 63/9 64/2 82/4
85/15 86/13 86/16
86/19 113/7 115/12
120/18 121/6 121/9
121/16 121/17 122/5
123/2 124/7 125/9
133/2 137/1 137/3
137/14 137/24 139/4
139/10 148/4 149/21
172/21 183/1 183/21
system’ [1] 127/12
system-wide [1]
137/24
systemic [18] 118/4
118/4 121/1 121/12
121/15 121/22 122/4
126/13 127/1 127/11
127/13 127/16 137/2
139/5 139/19
systems [2] 121/1
121/22
T
table [1] 158/25
tactic [2] 182/25
183/12
tactics [3] 103/5
181/22 182/14
take [40] 2/17 11/15
19/8 23/14 34/15
35/12 36/16 47/24
54/17 71/19 80/17
82/2 82/13 82/17 83/9)
84/8 91/15 91/15 93/2,
94/24 120/19 121/20
123/22 126/12 132/2
140/15 140/16 157/4
157/18 157/22 162/23}
163/23 165/2 170/1
171/4 177/15 178/24
179/20 179/24 180/17}
taken [18] 76/14
86/24 94/19 113/5
123/4 123/8 130/12
130/18 130/20 131/13}
133/7 133/25 134/4
150/1 163/9 174/4
174/9 174/18
takes [1] 41/13
taking [9] 14/8 20/21
116/15 123/4 137/16
154/24 154/25 168/23}
171/2
talk [3] 43/21 62/22
100/21
talked [2] 96/25
139/8
talking [11] 47/6
68/15 73/6 73/6 73/7
125/17 126/13 126/17
127/14 127/15 128/10)
150/14 170/17 170/24)
137/12 137/20 137/24}
97/8 104/21 104/21
125/5 143/17 172/25
task [1] 32/21
taxation [2] 109/8
110/12
team [21] 3/18 11/10
14/8 20/21 35/12 83/9)
102/19 102/23 102/24)
104/19 104/20 104/25}
105/1 105/18 105/19
109/12 147/9 151/11
173/9 181/14 182/20
Teams [1] 105/3
tears [1] 111/12
technical [2] 14/17
40/22
Telecom [1] 70/23
telephone [2] 112/24
153/23
tell [6] 2/11 2/22
18/24 55/2 142/22
175/18
telling [2] 99/3
125/11
ten [2] 36/21 68/15
ten years [1] 68/15
tends [2] 60/23 67/13
tension [2] 69/2
69/19
tensions [2] 69/12
69/15
term [1] 72/21
terminated [1] 74/20
terminating [1] 87/1
terms [37] 1/21 3/15
9/14 16/14 39/2 63/12I
66/25 75/15 83/16
83/17 92/13 92/19
96/9 109/16 122/9
141/5 147/16 148/9
148/11 148/14 148/21
148/25 149/6 149/7
149/11 149/13 149/18)
149/24 151/22 152/1
152/2 152/6 152/10
152/13 155/19 156/5
160/21
territorial [1] 49/22
test [1] 161/24
tested [1] 141/20
testimony [1] 182/9
text [1] 8/10
than [28] 10/14 29/21
30/20 30/22 32/5 35/4I
44/16 45/25 55/14
58/22 61/11 77/23
78/12 78/18 91/23
109/13 111/19 112/4
119/3 131/20 150/3
152/25 165/10 165/24I
171/2 182/16 185/15
187/3
thank [86] 1/4 1/7 3/2
3/3 4/25 20/8 20/9
(75) straight... - thank
T
thank... [79] 22/12
22/13 24/1 33/7 36/14
36/19 37/7 38/7 38/12
38/15 39/2 40/8 46/19
48/7 58/24 67/16
67/20 67/24 69/8
69/24 71/9 71/9 79/7
81/3 81/25 84/3 84/10
84/15 84/16 88/8
88/12 89/9 95/2 95/6
95/8 100/9 105/21
106/6 106/12 106/19
4107/1 107/7 107/20
108/3 109/14 111/22
112/5 118/7 119/16
120/22 120/24 126/6
128/19 134/15 134/15
146/4 146/9 146/10
146/13 148/20 153/6
156/16 165/2 171/19
171/23 172/14 174/25]
17715 177/21 184/3
184/7 184/25 187/4
187/10 187/11 187/13}
187/14 187/21 187/23
thanks [3] 105/21
108/12 108/16
that [1008]
that I [2] 36/11
121/23
that' [1] 10/22
that's [118] 4/2 4/7
4/10 8/13 10/5 15/1
16/14 16/16 19/8 19/9}
21/24 22/21 23/4
23/17 24/10 24/21
25/17 26/16 28/3
31/10 32/12 32/22
33/9 33/24 34/11
35/11 36/15 38/10
39/6 39/20 40/3 41/12
41/16 45/6 46/4 48/25
51/2 51/14 54/1 55/23
55/23 58/15 59/18
60/11 61/16 62/12
62/20 62/21 63/15
65/12 67/9 67/14
67/22 68/4 70/12
72/23 74/21 74/23
80/25 81/16 81/24
82/12 84/8 85/2 86/8
86/20 87/6 89/8 89/25
92/9 92/10 93/23 94/8
95/15 95/17 96/12
98/16 100/6 105/16
107/3 107/20 109/21
112/8 112/11 112/21
116/21 117/22 118/24]
119/23 124/20 126/9
127/6 128/24 143/5
143/15 145/25 148/17]
150/22 157/7 157/25
159/23 163/6 163/14
163/15 163/19 164/19)
165/9 167/11 172/7
175/1 176/4 176/6
176/23 180/16 181/11
182/4 185/13 187/20
theft [15] 51/13 57/4
57/6 57/10 57/13
57/20 57/22 58/6
58/10 58/17 59/13
103/15 104/25 105/13)
161/18
their [79] 29/14 41/11
43/21 43/21 43/22
44/8 44/9 45/7 47/11
47/16 47/17 51/25
53/8 53/14 53/23 54/4)
54/9 55/13 55/16
55/16 55/18 56/1 56/2
57/22 59/8 59/16
63/13 69/13 69/17
70/8 73/12 73/17 74/1
75/5 76/2 79/1 79/18
80/17 82/15 88/11
97/12 97/13 100/15
103/15 103/16 104/16)
108/14 109/4 114/24
115/10 115/13 115/17)
117/3 125/8 125/11
125/16 125/20 127/13)
130/23 133/9 135/20
136/21 138/8 140/2
155/2 155/7 160/7
161/7 162/3 162/5
165/12 167/14 168/10)
173/19 176/15 179/20)
182/20 186/17 186/18)
theirs [1] 121/15
them [91] 8/21 9/12
10/2 11/12 12/7 18/24
23/14 44/22 45/3
49/18 50/3 50/9 50/11
50/12 51/7 51/18 55/3)
56/6 56/6 56/13 58/19)
59/11 59/14 59/21
62/6 62/19 62/20 66/5)
68/11 68/13 68/21
71/6 73/5 73/16 75/13
75/23 77/2 77/20 81/8
86/25 96/9 96/10
96/10 96/12 97/2
99/10 101/8 103/25
104/1 105/12 108/12
109/4 109/10 109/11
113/13 115/3 115/3
115/12 115/16 115/17)
116/7 117/3 119/5
119/6 121/10 124/25
125/10 131/7 132/16
134/1 135/12 135/13
137/13 139/25 151/17)
157/1 159/1 167/13
167/14 169/25 171/21
177/1 179/9 179/24
180/9 180/25 183/14
185/5 186/14 186/17
186/21
themselves [10]
14/15 44/6 50/4 51/25}
63/24 104/5 104/14
104/16 122/21 173/4
then [117] 2/22 5/14
5/17 6/5 6/17 7/3 7/10
9/3 9/14 10/20 12/1
12/8 16/1 16/7 16/7
16/11 16/24 17/3 18/3}
18/10 18/15 21/3 21/4
21/12 22/24 23/9
23/25 24/1 24/2 24/2
24/12 24/25 25/13
25/18 29/18 30/15
30/17 33/12 43/15
47/23 48/25 51/4 53/2
53/9 58/4 58/4 58/4
58/22 59/8 59/10 61/7
61/9 63/10 68/17
68/22 68/23 70/18
70/21 73/4 74/2 79/22
83/12 89/2 89/2 89/6
89/14 89/16 91/25
93/14 94/12 95/13
96/19 98/10 99/23
101/4 101/14 101/20
102/17 103/13 107/18}
110/8 110/12 110/14
111/1 111/9 114/2
115/25 117/25 119/1
119/2 119/6 119/14
120/20 121/20 124/19}
126/20 132/19 136/8
140/6 142/7 145/6
149/4 149/7 157/3
157/14 158/6 162/6
163/19 165/5 166/5
166/8 170/7 177/4
177/6 178/12 180/19
185/18
then-Assistant [1]
83/12
there [182] 2/1 6/9
7/24 7/25 7/25 11/12
12/2 16/21 18/18
20/23 21/4 21/24
23/10 23/17 25/5 25/7
25/23 26/12 26/16
27/25 28/11 28/19
29/4 30/16 32/4 32/12
32/22 33/25 34/2 34/3
34/6 34/17 34/18 35/1
35/18 35/20 35/23
37/18 38/1 38/7 42/18
43/17 45/23 46/23
47/22 47/23 49/5 51/3)
53/22 55/9 55/20 56/8
57/4 61/7 61/7 61/8
61/8 61/11 61/11
62/21 63/3 63/10
63/12 64/2 65/2 65/17
65/18 65/19 65/22
65/24 66/19 67/6
70/13 71/3 71/3 71/4
72/14 74/8 74/13
77/12 77/21 7/23
78/17 79/5 80/8 80/21
81/6 82/8 84/5 85/17
86/16 86/18 88/11
92/17 94/24 95/7
95/25 96/20 99/12
101/13 102/1 103/21
103/21 108/8 114/15
114/15 114/21 115/7
118/3 118/13 118/20
119/4 121/10 121/20
122/4 123/5 123/7
123/18 123/19 124/5
124/11 125/25 126/15)
127/3 129/14 129/23
130/3 130/24 131/2
132/15 133/11 133/16}
133/17 134/10 135/5
135/7 135/22 135/25
136/1 136/6 137/1
137/9 137/11 138/1
140/11 143/14 143/20}
143/25 144/14 149/22
150/4 151/2 151/17
152/11 152/24 153/20}
155/18 155/24 156/16
156/23 158/10 158/21
161/2 161/3 161/6
164/13 165/25 167/16}
170/14 172/16 174/4
174/18 176/9 179/24
180/2 180/3 180/23
182/19 182/22 183/11
185/6 186/24
there'd [1] 161/15
there's [22] 5/18 5/20
10/1 12/1 27/23 30/7
30/21 32/11 67/24
69/19 73/1 80/22
90/22 103/19 105/24
113/13 113/14 129/11
144/14 148/21 175/13
176/25
thereafter [3] 2/14
175/15 176/13
therefore [10] 3/24
17/12 27/12 32/9 58/9}
75/20 93/9 131/15
137/15 169/23
Therium [4] 178/18
178/19 178/21 179/18}
these [40] 6/19 8/10
11/9 11/16 12/25 13/1
13/6 16/12 18/2 24/5
24/8 25/13 40/25 42/3)
44/1 46/1 55/6 57/6
60/20 68/7 73/18 79/8)
79/13 79/19 81/4
82/14 87/10 95/23
96/2 96/6 96/20 98/24
125/22 126/16 127/13)
137/6 153/19 153/23
171/24 186/11
they [155] 8/22 10/18
11/4 12/7 12/8 13/9
23/1 23/2 36/11 38/24I
43/5 43/9 43/20 43/21
44/8 44/9 44/15 44/21
46/14 47/16 49/24
51/16 51/17 51/21
52/17 52/18 52/19
52/21 52/21 53/7
54/19 54/21 55/2
55/15 55/17 56/7
56/12 56/13 57/6
58/22 59/8 59/17
60/21 61/2 61/3 61/21
62/5 62/5 62/9 62/10
63/10 63/19 65/5
65/15 66/6 67/4 68/16)
68/20 68/21 69/12
70/5 70/7 71/5 72/20
73/5 73/6 73/17 74/1
75/8 75/22 77/21 78/7I
79/3 80/3 86/2 86/25
96/8 96/25 97/5 97/12I
99/19 100/4 100/13
100/23 102/8 103/2
105/5 105/11 107/23
114/24 115/4 115/8
115/20 115/21 115/22)
115/23 116/9 117/4
122/17 123/8 125/12
125/13 125/14 125/19)
125/20 128/6 128/10
130/24 131/14 135/10)
135/12 136/10 137/11
137/13 137/17 138/5
138/7 138/8 140/3
140/15 140/16 140/18)
141/7 143/19 144/1
144/4 154/13 154/25
155/2 155/5 157/18
158/17 159/23 161/6
161/10 162/23 164/12)
165/4 166/3 168/11
168/21 168/22 169/23)
171/1 171/6 171/18
173/1 173/7 173/12
173/17 176/16 178/23}
178/23 181/23 183/23)
they'd [11] 51/20
125/8 133/14 136/2
136/7 140/4 140/14
144/3 155/2 161/19
165/12
they'll [2] 73/2 73/3
they're [17] 10/17
23/21 50/4 55/22
62/19 62/20 67/5
73/25 74/1 91/20
103/21 125/11 131/7
152/25 166/8 166/9
176/24
(76) thank... - they're
T
they've [4] 74/2
108/13 137/18 168/12)
thick [1] 124/2
thing [9] 9/15 10/17
15/8 22/22 22/24 23/9)
24/12 57/3 61/5
things [19] 6/7 15/12
22/19 55/9 67/5 82/21
104/22 104/23 125/12)
130/2 150/16 150/20
152/18 172/22 178/2
180/11 180/14 182/21
186/19
think [156] 1/19 3/19
4/8 7/24 10/10 11/7
11/16 12/21 13/20
13/22 13/25 14/10
15/19 18/16 20/18
21/5 22/14 22/19
23/15 28/24 29/5
30/23 31/3 31/24
32/11 33/13 34/15
34/17 36/22 41/14
41/24 42/6 42/13
42/25 43/12 44/12
44/17 46/5 49/12
50/22 51/5 52/3 54/23,
56/21 58/1 59/3 60/22
61/17 61/25 61/25
62/20 62/21 64/7
64/19 65/1 67/11 68/4,
69/19 70/17 70/18
70/19 70/21 72/23
73/5 75/11 76/15 80/2
82/13 83/19 84/3 84/5
87/16 87/25 88/20
91/17 93/6 94/8 95/10)
95/16 96/5 96/12
96/18 97/15 98/16
98/21 100/14 101/25
102/3 102/12 105/24
105/25 106/10 110/22)
110/25 112/9 113/13
114/2 114/13 116/6
118/22 119/2 119/3
120/2 120/3 120/13
120/16 121/12 121/13)
122/10 124/23 126/15}
129/1 129/2 129/11
129/12 133/20 135/7
135/16 135/16 135/25}
136/10 137/6 137/9
137/10 137/17 137/21
139/7 139/11 141/18
142/8 143/2 143/18
143/21 143/24 150/25)
153/24 158/2 159/5
160/16 161/2 162/19
166/20 168/9 168/16
168/18 174/21 176/22)
180/20 182/9 182/13
182/22 183/11 183/25)
185/4 185/5 185/8
15/7 30/15 30/23
129/3 176/14
thinks [3] 73/1
169/25 170/12
third [13] 9/12 10/9
10/13 19/21 23/9
26/10 26/23 27/4 27/6
27/15 29/20 32/10
34/11
thirdly [1] 178/9
this [277]
Thomas [11] 3/9 3/23}
4/6 6/13 19/13 28/14
28/15 28/18 28/19
28/23 33/1
Thomas’ [3] 5/21
6/13 28/1
Thomson [1] 70/19
thorough [4] 114/23
138/7 157/11 169/7
those [72] 10/21 11/2
11/8 15/6 18/10 21/14
23/10 25/1 25/25
25/25 26/14 29/13
31/8 38/23 42/19
43/23 44/10 44/14
44/14 44/24 45/2
47/25 49/13 49/19
49/22 55/21 55/24
62/17 63/9 63/21 66/2
66/4 66/4 83/4 83/10
83/12 93/15 94/4
97/11 97/17 97/23
97/24 99/18 99/21
99/22 101/6 101/7
101/12 102/16 102/21
104/2 104/7 105/15
105/21 108/5 120/4
120/5 121/10 122/9
122/22 131/3 137/25
140/25 141/5 147/11
148/17 152/24 165/23)
169/22 178/7 179/4
185/1
though [2] 89/11
185/5
thought [19] 11/16
12/24 14/11 14/12
32/7 51/17 54/21 62/4
62/5 116/24 132/11
134/1 135/19 137/25
139/17 140/14 144/3
171/1 182/24
thousand [1] 52/10
thousands [2] 95/13
95/22
three [16] 6/8 9/10
16/10 16/12 22/19
24/14 24/19 24/23
25/1 25/5 25/7 25/18
35/5 36/5 57/19 57/23
three’ [1] 16/8
thinking [7] 8/18 8/24)
threshold [1] 51/10
thresholds [1] 51/10
through [46] 5/1 5/2
26/2 26/8 26/15 31/2
32/20 36/3 42/8 42/23
44/1 47/24 50/11
54/20 55/17 59/14
63/11 70/20 73/22
95/18 99/20 99/24
101/12 101/14 101/19}
109/8 109/13 120/16
123/7 125/16 138/17
139/4 140/12 144/21
147/22 158/24 159/23
162/22 168/15 169/9
169/10 169/11 169/12)
183/18 186/17 187/16
throughout [2]
144/13 180/25
throw [1] 120/7
Thursday [4] 1/1
4/20 105/4 154/8
Thus [1] 78/20
time [95] 6/23 9/1
12/19 15/7 23/1 28/8
28/17 28/22 30/23
32/13 34/3 40/11
41/21 42/5 42/9 43/13)
44/1 45/16 50/7 50/8
50/23 51/8 55/15
56/18 61/14 64/21
64/21 65/17 67/1 67/6
68/2 70/2 70/13 70/18
70/19 71/13 71/17
72/11 72/20 73/12
73/14 81/13 84/21
87/12 88/4 95/7 95/11
96/6 96/17 100/22
102/10 103/24 113/23
113/25 114/21 117/1
117/24 119/18 119/21
120/19 121/12 122/8
122/13 122/14 122/23
123/10 123/11 123/17
127/4 128/5 128/12
128/13 131/3 137/7
137/25 139/23 141/7
142/6 145/15 145/23
145/25 146/19 146/25}
146/25 152/22 163/1
163/21 163/23 166/10
167/20 169/5 171/7
171/9 171/18 183/25
times [6] 23/14 35/5
47/14 126/15 162/19
173/2
timing [1] 150/25
tirelessly [1] 108/22
title [3] 53/2 93/24
94/3
titled [1] 144/6
today [7] 3/7 44/1
75/18 92/9 95/18
107/2 144/13
together [12] 7/7
7/20 29/14 31/21
44/20 46/8 50/9 72/14;
123/21 168/4 178/9
180/4
told [16] 3/22 34/18
62/3 82/9 87/15
112/14 114/6 114/8
138/24 139/3 139/4
139/6 144/4 155/5
175/21 176/5
tomorrow [1] 187/22
tone [5] 150/5 150/7
151/2 151/3 151/19
too [3] 127/22 173/7
173/16
took [7] 46/6 64/23
71/7 93/4 93/10 141/6)
147/25
top [11] 4/18 16/1
22/2 97/17 101/14
107/5 111/4 132/17
143/7 160/4 176/19
topic [8] 4/10 5/1 5/2
46/11 46/12 65/7
69/24 176/12
topics [2] 185/10
186/2
Torquay [1] 5/13
total [1] 97/24
touched [2] 92/1
120/25
towards [3] 102/1
135/19 183/13
tracked [2] 22/20
36/5
tracking [3] 42/4
42/15 43/8
trade [23] 74/12
74/14 77/4 77/7 77/7
77/10 77/11 77/15
T7IN7 77/18 77/19
77120 77/23 78/23
78/23 78/24 78/25
82/16 90/6 91/2 91/7
91/9 98/24
train [1] 50/11
training [14] 50/2
50/15 104/4 104/6
104/11 121/18 122/5
141/21 142/3 142/10
142/11 142/20 143/4
150/13
tranche [2] 117/25
118/1
transact [1] 80/3
transaction [12] 9/11
9/19 16/23 17/1 25/8
25/20 25/22 26/11
29/12 31/25 126/19
126/23
transactions [19]
5/25 6/2 6/3 6/14 7/6
7/16 7/17 8/1 8/3 10/6
14/3 14/3 19/21 24/18)
30/10 33/3 67/4 121/6I
131/9
transactions’ [1]
16/6
transcript [3] 4/11
4/17 19/8
transfer [1] 72/2
transparent [1] 80/9
transpired [1] 101/20
treasurer [1] 113/15
treated [6] 51/11
51/12 52/5 86/2 93/6
168/13
treatment [1] 111/6
treaty [3] 79/24 80/1
80/6
trial [6] 40/16 40/22
111/16 130/21 182/1
182/25
trials [2] 145/14
146/22
Tribunal [1] 57/25
tribute [1] 108/5
tried [4] 97/15 123/24)
123/25 165/17
true [10] 8/20 11/17
11/18 14/20 38/12
56/3 61/4 107/21
150/16 159/23
trust [1] 104/1
trusted [1] 187/3
truth [3] 15/14 20/5
107/19
try [11] 19/3 48/3
68/24 111/19 114/13
116/8 126/3 132/23
150/15 183/2 186/17
trying [16] 14/4 14/6
14/23 15/11 15/13
16/20 26/19 31/20
32/1 32/3 32/23 32/23
49/11 68/12 125/20
141/10
TTIP [2] 79/24 79/25
Tuesday [1] 125/10
turn [15] 17/24 27/9
37/23 81/1 107/3
107/9 107/16 120/3
132/9 138/13 143/6
154/14 156/15 158/1
176/12
turned [1] 149/4
turning [2] 94/12
177/16
two [46] 5/9 8/11 9/5
10/21 11/8 11/9 13/4
20/14 29/19 34/12
55/9 55/22 66/19
66/22 67/4 68/7 70/3
72/14 86/23 94/17
104/21 104/23 105/14)
107/15 117/18 123/19)
124/3 126/16 137/2
(77) they've - two
T
137/6 143/11 147/11
149/15 150/10 151/9
172/16 175/1 175/2
185/8 185/9 185/10
186/2
two paragraphs [3]
10/21 13/1 147/11
tying [2] 10/3 150/9
type [7] 27/5 50/2
172/17
typed [6] 17/9 17/14
17/22 18/4 18/5 35/2
types [1] 172/16
typical [1] 146/23
U
UK [1] 110/12
UKGI [1] 82/6
ultimately [1] 110/5
Um [1] 77/8
unable [1] 91/21
unacceptable [1]
51/19
unaware [1] 35/18
unclear [1] 61/4
under [23] 1/23 6/18
71/21 74/5 76/21 78/1
150/10 150/12 153/25
154/15 161/8 185/3
underlined [1] 22/21
undermining [1]
145/4
understand [29] 2/25
3/1 3/10 12/25 13/1
35/9 44/12 51/23
64/25 72/13 73/8
77/10 77/13 91/1 93/4
96/5 96/24 97/7 97/11
99/3 107/12 108/2
135/2 140/5 142/22
150/14 169/7 179/17
183/5
understandable [2]
168/20 169/15
understanding [23]
43/2 67/1 68/14 68/19
72/1 72/10 75/18
76/23 80/25 92/10
113/24 117/24 118/2
128/21 136/1 136/12
136/13 136/14 136/20
150/2 157/19 158/18
177/18
understood [3] 19/3
40/25 162/21
two... [17] 137/4
166/25 171/20 171/24)
52/10 57/2 59/5 62/25)
typing [1] 19/20
47/5 59/19 63/18 65/5
80/4 85/9 87/20 97/22
148/22 149/16 149/19}
undertake [2] 79/17
98/5
undertaking [2]
79/18 174/15
undertakings [1]
75/5
undertook [2] 162/9
173/18
unexplained [1]
111/13
unfair [1] 56/5
unfairly [1] 86/2
unfortunately [2]
119/10 133/19
unilaterally [3]
unincorporated [2]
113/2 118/17
39/22 40/5 42/5 44/9
46/14 48/11 48/24
61/20 63/14 65/18
65/20 67/7 67/11
69/10 70/1 70/13
75/12 76/14 77/7
77/10 77/18 77/18
77/19 77/20 78/23
78/24 82/22 82/22
97/8 97/11 97/16
97/17 97/24 97/25
98/1 98/24 101/1
unionist [1] 91/9
71/2 72/10 72/24
73/14 74/12 74/15
78/25
Unique [1] 107/7
Unit [1] 110/9
united [1] 113/4
unless [4] 63/21
63/22 63/24 177/19
unlikely [2] 52/1
168/18
unnoticed [1] 108/14
unpaid [1] 108/13
unsafe [3] 131/16
131/17 131/19
unseen [1] 108/8
unsuccessful [1]
179/9
unsung [1] 108/38
until [13] 36/17 58/3
84/9 98/10 103/17
108/20 109/10 120/1
136/2 136/7 165/12
184/17 187/25
up [78] 5/1 7/21 8/13
9/3 13/14 15/23 15/24
19/17 21/6 32/16
32/23 34/19 45/7 46/1
148/14 155/20 176/10)
union [55] 39/5 39/19)
49/1 50/2 55/16 55/17
67/13 68/9 68/25 69/2
83/17 89/22 90/6 91/2
91/7 92/5 95/12 96/14
unions [9] 65/18 66/4)
63/9 63/12 68/12
91/24 93/15 97/16
98/10 99/15 99/20
100/4 100/10 101/9
101/19 107/3 110/9
110/14 110/16 111/3
114/12 115/3 115/4
115/6 115/18 115/25
118/8 118/10 120/7
120/23 124/16 126/5
126/8 128/18 129/4
147/8 148/15 148/17
182/9
update [4] 85/7
154/21 175/1 175/4
updated [2] 8/14
50/25
upheld [1] 2/15
upon [8] 2/7 2/14
38/17 46/24 53/4
57/12 63/2 161/25
upset [1] 170/18
urgency [3] 20/23
34/6 175/10
us [51] 1/3 1/5 3/22
6/14 7/7 7/20 15/4
20/5 31/23 32/6 37/6
56/7 56/12 56/14
56/15 61/22 62/7
62/10 62/10 62/17
63/21 63/22 68/22
74/9 82/9 84/14 86/9
89/10 91/1 96/8
109/10 119/15 120/2
120/3 142/22 144/4
169/24 169/25 178/14
usable [1] 180/16
use [8] 127/8 127/23
132/5 145/7 152/9
161/25 181/6 181/7
used [18] 13/3 16/15
16/15 22/16 47/9
49/21 51/7 55/11
55/21 83/1 103/6
111/10 121/13 124/4
132/9 133/14 136/17
186/12
useless [2] 9/6 11/5
using [5] 90/5 95/14
121/9 121/18 124/5
usual [4] 5/22 78/22
78/24 153/15
usually [3] 52/14
52/24 54/25 58/3 61/9
68/23 71/9 74/3 78/14
78/20 81/3 81/23 86/1
101/11 101/13 101/16
139/17 141/13 141/24
151/22 155/11 159/25)
165/21 166/11 167/12
174/16 178/13 179/15}
38/4 54/16 54/22 55/2
68/23 71/4 71/6 71/23
72/3 72/11 73/6 73/18
Vv
10/14 25/7 26/11
29/21 29/23 30/20
32/5 78/20
values [3] 29/13
29/19 30/11
van [7] 142/5 142/15
147/9 168/24 168/25
169/1 178/5
vans [1] 65/19
varied [1] 155/20
variety [1] 47/22
various [8] 42/24
47/13 98/9 115/17
125/4 144/11 175/4
183/18
varying [2] 47/21
50/9
vast [1] 120/19
vehicle [1] 136/18
Vennells [19] 118/22
118/25 119/3 128/17
129/2 131/20 132/23
133/12 133/21 134/7
167/9 167/17 168/1
169/2 169/13 169/16
vent [1] 169/24
verbatim [1] 48/4
version [3] 21/14
122/12 156/6
very [37] 1/4 1/7 1/21
4/11 13/21 13/23
20/19 33/14 33/16
33/17 33/20 34/1
36/14 37/7 40/8 52/1
67/16 67/16 79/21
84/4 89/19 108/5
108/9 108/23 125/20
130/15 136/25 138/3
138/7 169/7 170/18
176/17 179/10 186/12
187/10 187/11 187/21
viable [1] 123/16
Vice [2] 67/25 159/7
view [20] 53/8 76/3
81/20 82/15 92/23
122/15 122/23 130/13}
130/14 140/20 141/8
142/19 142/20 166/25}
168/19 169/14 181/8
181/17 181/17 183/10}
views [3] 79/18 125/8)
125/11
village [1] 186/7
visits [2] 41/2 41/25
voiced [1] 163/21
voices [1] 96/20
volume [1] 180/23
volunteered [1]
173/2
64/20 143/2
value [10] 9/10 9/19
134/11 166/17 166/22}
vote [5] 108/16
161/24 162/1 162/7
163/1
voted [2] 162/8 162/8
vs [4] 126/13
Ww
wages [1] 66/25
wait [2] 58/22 120/6
waiting [1] 166/24
waive [2] 177/19
177/20
Walker [2] 124/18
124/18
want [33] 3/6 8/9 8/9
20/5 30/25 32/25
34/16 35/25 44/2
47/10 51/24 53/16
55/25 56/5 59/21
66/17 73/1 73/15 74/2I
93/1 93/10 112/25
126/14 133/5 140/6
143/11 146/10 159/24)
166/10 171/20 172/10)
176/12 182/3
wanted [27] 8/21 9/1
17/21 30/24 33/18
34/25 35/24 56/5 56/6I
56/12 100/23 103/6
114/12 114/24 115/21
122/17 132/17 134/3
136/21 140/15 140/16)
140/20 155/25 165/20}
177/20 183/5 184/20
wanting [1] 14/24
wants [1] 75/12
Ward [18] 1/5 1/7
1/10 1/12 2/25 3/4 7/2
8/18 19/14 24/6 26/21
27/3 30/9 35/2 36/11
36/15 36/20 188/2
Warmington [16]
112/19 114/3 115/2
119/17 125/7 125/24
126/7 126/12 138/6
139/7 139/12 139/23
141/1 150/11 175/18
176/15
Warmington's [1]
185/21
Warnborough [1]
111/10
warned [1] 153/12
was [497]
wasn't [40] 8/25
41/17 12/2 14/1 14/7
14/23 15/11 15/13
20/1 20/2 26/18 31/11
31/23 35/16 42/13
45/11 48/22 48/23
58/19 62/6 68/10
70/19 72/15 91/5 97/7
101/17 115/4 121/20
129/13 145/18 145/22)
(78) two... - wasn't
Ww
wasn't... [9] 147/10
157/16 159/13 159/19)
165/24 171/9 173/7
184/17 184/23
Watt [6] 88/20 89/2
95/3 95/4 100/8
188/12
wavered [1] 109/1
way [34] 5/1 15/7
15/12 19/2 26/7 32/2
33/23 33/24 36/9
54/25 63/20 88/18
89/11 100/17 101/1
101/8 103/8 104/14
106/1 109/8 111/11
113/11 113/13 123/6
131/20 136/10 140/21
142/11 142/12 149/13
165/20 178/20 186/17)
187/16
ways [1] 91/11
we [383]
we'd [7] 50/10 64/22
72/24 125/22 128/25
152/22 162/20
we'll [15] 12/6 36/21
38/4 42/11 77/2
106/11 109/15 114/16)
119/14 152/25 153/7
167/2 167/15 176/20
185/15
we're [20] 3/16 5/6
34/21 38/25 54/16
54/17 54/19 61/4
68/23 68/23 73/18
75/23 84/22 89/1
101/10 104/21 129/3
130/16 169/25 174/22)
we've [17] 5/18 17/17
21/20 21/23 22/3 22/3
32/19 33/9 57/1 62/10)
73/21 88/16 108/23
152/20 152/20 163/3
184/12
website [2] 67/12
107/25
Wednesday [5] 41/12)
47/18 55/12 105/3
105/8
week [2] 41/12 52/22
weekly [2] 41/8 59/8
weight [1] 127/11
well [73] 8/21 11/9
11/19 13/24 14/22
15/17 17/7 17/12
17/17 18/4 18/16
18/23 26/2 26/9 27/12)
27/23 30/5 30/13 31/9
31/15 31/18 32/11
33/24 36/19 36/25
45/25 53/23 61/23
65/22 66/13 68/22
69/5 69/6 72/11 73/19)
76/5 87/13 89/4 91/15)
92/25 93/14 97/1
98/17 98/21 99/12
101/16 102/14 103/16)
104/7 107/11 110/8
111/24 112/3 117/14
120/2 129/3 135/7
136/25 139/7 143/18
147/14 152/17 152/24}
155/2 156/5 158/1
159/8 168/1 168/8
17713 178/17 187/5
187/8
well-known [1] 110/8:
went [16] 21/12 29/3
59/14 68/22 90/14
100/4 110/12 120/21
134/12 148/10 154/17)
156/14 159/22 178/12)
183/18 184/18
were [243]
weren't [11] 11/17
17/19 34/18 42/15
42/15 64/11 84/18
97/12 115/4 138/9
173/7
what [197]
what's [5] 91/11
91/13 125/13 138/15
174/13
whatever [5] 30/14
53/2 59/20 131/12
165/14
whatsoever [5] 114/1
115/3 123/3 134/21
138/12
when [72] 1/22 3/15
14/22 22/7 31/16
38/20 40/11 41/13
45/8 50/23 55/20 57/5)
57/15 57/15 57/16
57/17 58/24 65/9 67/6)
67/8 70/3 70/13 72/20
84/23 84/24 95/11
95/15 99/12 102/9
102/15 103/13 104/16)
109/22 110/2 110/18
112/1 113/19 119/5
119/21 122/13 130/23)
131/2 131/9 136/13
137/23 139/13 140/16)
140/18 141/5 141/15
149/25 150/6 154/13
155/21 158/18 158/20)
164/3 164/12 164/15
164/23 165/6 165/15
166/3 166/16 167/4
167/19 170/19 176/16)
179/6 182/4 183/16
184/9
where [61] 3/15 3/17
5/10 18/2 18/18 19/8
20/5 20/22 22/18 47/2
48/19 50/4 51/21
55/23 63/11 67/17
70/24 80/18 89/7 92/3,
98/23 99/16 101/10
103/20 105/22 113/14]
127/8 127/11 129/11
132/12 137/3 137/14
141/20 144/14 144/14
150/15 151/7 151/8
152/9 155/19 155/21
155/25 157/9 157/17
157/19 158/14 159/19}
159/24 161/2 161/12
162/13 162/15 166/21
169/21 170/2 171/25
172/20 172/24 173/12I
174/14 180/17
Where's [1] 172/7
whereas [2] 67/1
121/16
wherever [1] 173/3
whether [43] 2/14
2/23 8/22 41/6 42/20
43/2 43/5 43/6 43/9
47/15 53/6 54/3 71/2
71/5 73/15 73/24
82/21 89/2 98/12
98/13 115/23 116/8
122/4 133/16 137/11
138/2 141/20 145/7
147/19 148/24 155/9
156/1 156/20 159/11
159/25 160/6 161/6
161/19 161/22 162/14
165/7 171/12 186/23
which [149] 1/14
1/15 2/9 3/13 5/20
6/18 9/5 10/24 11/16
14/18 17/10 18/9
20/25 21/3 21/16 22/9
23/1 23/2 24/19 27/10
29/13 29/19 29/20
34/8 34/22 35/2 37/20
40/9 42/6 46/12 46/13)
47/19 48/14 50/25
51/10 51/12 52/5
52/16 52/20 53/25
54/5 54/7 56/18 58/11
59/5 60/6 60/19 61/6
64/1 64/9 64/14 64/25
65/7 67/4 67/13 67/25
68/7 68/14 68/21
69/24 70/24 73/5 73/8
73/23 75/5 76/9 77/15)
79/12 80/9 80/17
81/18 82/20 82/20
82/23 83/1 83/19
84/22 86/25 87/9
87/20 87/20 89/14
90/21 93/5 94/4 94/7
97/21 97/22 98/7 99/5
99/14 100/18 101/18
103/8 107/15 112/18
113/4 114/12 114/16
114/20 117/7 117/20
122/1 122/10 124/1
126/12 127/3 130/5
130/24 131/4 131/5
131/25 132/12 132/19
134/8 138/14 140/5
141/22 144/7 145/11
146/21 147/8 147/11
152/21 155/3 157/13
158/3 160/18 163/4
164/9 164/24 165/22
166/6 166/12 169/4
170/19 170/25 171/4
173/21 176/17 177/18}
181/17 182/11 182/19}
184/22 185/4 185/15
186/9 186/19
while [3] 57/13 79/23
131/22
whilst [4] 20/23 34/6
39/7 89/5
white [1] 33/25
whitewash [2] 115/5
115/12
who [75] 2/9 2/21
17/24 22/25 31/14
36/17 39/9 39/12 40/4
41/17 42/16 43/14
48/4 48/11 49/22 50/3)
50/13 52/20 53/23
55/12 57/21 58/3
62/16 65/3 65/19
65/20 65/23 65/25
69/21 75/11 77/14
82/14 86/2 93/15
93/20 94/23 98/8
98/15 99/7 101/6
102/16 102/17 103/14,
104/7 104/13 104/24
105/10 105/11 108/5
109/9 123/1 129/15
130/25 131/18 133/24,
139/6 139/9 140/25
141/10 143/19 147/14}
150/9 150/18 165/21
169/24 169/24 176/5
178/7 178/10 178/14
179/7 179/20 182/16
185/6 187/1
who'd [4] 59/4 123/2
141/12 160/25
whoever [2] 73/17
73/20
whole [6] 63/9 97/8
105/6 113/17 144/16
183/2
whom [6] 45/9 60/7
87/11 110/19 118/11
118/17
why [41] 7/25 8/3
9/10 11/24 13/22
14/10 14/16 16/23
17/7 19/25 25/7 30/10}
31/1 31/16 34/21
35/11 36/1 36/6 47/22
47/24 51/17 53/8
62/12 65/13 68/21
73/12 74/13 77/15
94/7 96/23 97/25
123/16 125/22 126/4
130/22 132/9 150/9
152/16 162/18 168/12)
169/6
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137/1 137/24
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2/22 6/15 22/14 36/25]
38/15 73/17 77/4 78/2I
78/18 79/19 80/19
80/23 84/8 85/23
86/23 86/25 89/7
99/16 107/24 107/25
109/7 109/14 117/21
120/2 121/4 122/3
143/15 151/11 156/19)
156/21 157/2 157/4
157/22 158/1 162/5
169/24 184/21 185/6
185/18
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110/14
Wilson [2] 141/23
142/1
win [1] 179/21
wish [6] 2/6 2/9 2/21
88/11 107/12 185/7
wishing [2] 99/25
178/5
withheld [4] 181/1
within [18] 6/15
29/24 32/17 40/4 42/4
53/6 65/16 66/4 69/1
83/23 87/17 91/1 94/2I
98/7 105/14 147/20
180/13 183/7
without [11] 99/25
123/22 124/9 130/21
133/15 138/5 150/17
171/3 176/10 178/5
180/22
WITN00550100 [1]
107/8
WITN00550101 [1]
117/6
WITN00550103 [1]
142/25
WITN01050200 [1]
185/23
WITN06370200 [2]
46/17 81/24
witness [68] 1/23 2/3
3/9 4/4 5/16 6/7 8/10
8/14 8/15 15/23 18/17
18/19 19/12 19/17
20/1 20/14 24/13
25/18 27/7 28/21
29/10 29/25 31/16
(79) wasn't... - witness
Ww
witness... [45] 31/25
32/6 34/11 35/5 35/21
36/17 37/8 37/10
37/17 38/9 42/7 46/16
59/10 59/20 81/23
84/5 88/9 88/17 88/23
106/4 107/2 111/3
115/6 116/13 116/14
117/6 118/8 118/20
120/23 132/20 132/21
141/24 143/3 146/12
153/3 153/4 155/11
159/6 172/16 176/16
182/10 182/12 187/8
187/11 187/19
Womble [1] 184/13
Womble's [1] 165/10
won [1] 57/24
won't [1] 148/5
wonder [2] 48/2 85/1
Wood [1] 119/17
word [7] 14/22 22/10
22/15 22/18 25/10
168/9 181/7
wording [2] 143/16
174/16
words [24] 8/12
16/15 16/25 17/10
18/2 18/5 25/13 25/25
26/10 26/14 27/10
27/20 31/4 31/7 31/8
31/13 31/14 31/17
99/25 121/12 124/3
132/5 143/21 184/4
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13/18 20/17 33/8
49/25 55/11 55/11
55/12 77/14 91/1 98/4,
109/20 109/25 117/3
117/14 120/2 125/18
136/13 157/2 158/12
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45/23 46/8 57/13
57/15 57/16 57/17
65/9 66/16 70/3 108/5
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39/19 40/5 42/5 46/14,
48/11 65/20 66/20
68/8 69/20 70/1 77/14
77124 89/22 102/6
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39/13 39/14 40/10
40/15 45/16 65/21
90/3 91/3 93/20 93/21
94/1 95/13 95/23
110/19 110/21 120/21
124/25 125/3 139/19
141/14 141/17 146/15}
147/3 147/15 148/4
148/8 148/12 148/15
148/24 149/5 149/12
149/20 149/25 150/2
150/13 151/13 152/2
152/8 152/15 153/7
155/18 155/21 156/41
157/4 157/8 157/13
157/20 157/22 158/8
158/13 158/16 158/22)
159/2 160/6 160/13
161/23 161/24 162/7
162/10 162/13 163/22)
164/2 164/10 164/22
165/3 165/6 165/14
166/10 173/1 176/9
184/9 186/16
workplace [1] 69/22
worried [1] 133/14
worry [1] 134/2
worth [4] 14/8 20/20
121/3 124/5
would [235]
wouldn't [22] 6/23
14/18 17/16 18/5
32/22 34/19 46/2
58/10 61/21 62/12
63/19 64/12 64/22
100/21 104/1 119/18
120/17 135/21 162/23)
178/23 178/25 180/23)
write [4] 7/8 56/14
62/10 183/22
writer [2] 185/13
185/17
writing [3] 24/13
24/21 173/19
written [7] 18/12
107/2 128/25 138/8
162/10 164/19 174/41
wrong [7] 86/14
104/25 116/8 120/21
143/15 170/13 180/2
wrongly [4] 109/10
113/5 131/13 133/7
wrote [2] 23/14 27/9
www.cwu.org [1]
67/18
www.cwu.org/postm
asters [1] 67/18
Wyn [1] 186/3
Y
yeah [65] 6/10 7/12
9/17 9/17 9/22 9125
10/3 10/16 10/19
10/19 10/23 10/25
11/3 12/16 12/21
12/24 12/24 13/8
13/11 14/22 15/5
16/17 16/22 17/20
17/20 18/5 19/18
19/23 21/22 22/1 22/6
22/17 23/23 25/12
25/17 26/2 27/23
41/17 44/18 45/2
50/15 53/7 55/2 56/12
56/20 59/18 59/23
66/11 68/5 69/14 70/6
71/5 72/23 73/6 75/11
95/20 95/22 95/24
96/8 101/12 102/8
102/21 102/22 104/10
177/14
year [8] 37/18 38/8
72/8 119/4 153/15
174/11 174/11 174/19]
years [16] 30/13
45/24 46/9 50/25
56/24 57/18 68/15
70/25 71/1 93/3 96/20
108/23 108/25 134/3
152/25 174/6
yellow [3] 11/17 18/9
176/3
yes [180] 1/4 1/6 1/9
117 2/19 2/19 3/1
3/11 5/19 6/19 6/20
9/17 9/22 11/3 11/6
12/11 14/23 16/18
16/19 19/18 20/3 21/9
21/10 21/22 21/25
22/1 22/6 22/8 22/17
22/21 22/23 23/2 23/3
23/11 23/12 24/3 24/4
24/10 24/21 24/23
24/24 25/2 26/15
26/25 27/8 27/23 28/3
28/7 28/10 28/19 29/9)
30/2 31/2 33/18 33/23
35/9 36/18 36/22 37/2
37/7 37/9 37/25 38/6
38/11 39/23 40/14
41/23 42/23 50/6 52/7
57/11 60/3 60/5 60/12
70/17 71/18 76/8
81/20 84/8 84/15
84/23 86/8 86/8 86/10
86/20 87/8 87/13
87/14 88/15 88/21
89/4 89/8 94/22 95/7
95/16 99/23 100/6
101/8 102/20 102/21
103/4 104/20 105/19
105/20 106/6 106/10
106/12 106/21 107/6
107/14 107/17 108/3
110/23 112/2 112/8
112/14 116/12 116/21
117/8 117/16 118/14
119/8 119/13 119/23
125/4 125/6 125/12
126/10 127/6 127/17
128/24 129/11 129/13
130/2 139/2 139/24
140/11 140/24 144/9
144/11 145/25 146/3
146/9 148/19 149/11
150/8 151/19 153/23
154/6 154/13 156/3
156/25 159/3 159/4
161/15 162/17 163/2
163/16 164/9 166/18
166/24 167/10 168/2
169/3 169/18 170/10
172/3 175/3 17/2
177/10 178/19 179/23}
180/11 180/16 181/11
182/6 184/11 186/1
187/22 187/23
yet [4] 129/21 174/2
175/9 183/11
you [835]
you'd [11] 3/20 19/2
32/18 45/15 59/3
102/3 102/12 108/2
120/18 123/21 142/6
you'll [3] 125/10
168/14 185/24
you're [35] 2/16 5/6
6/6 7/6 13/16 16/20
22/7 24/13 32/5 44/12,
48/5 49/5 49/8 53/25
64/2 64/25 68/22
73/15 89/21 89/22
91/21 92/23 92/25
93/13 93/14 99/3
119/12 119/17 131/6
154/10 163/4 166/14
172/12 175/25 185/13}
you've [37] 12/17
15/3 16/11 17/4 17/9
18/16 27/21 29/5
29/16 29/25 37/20
39/17 39/24 41/24
50/24 52/24 54/5
54/23 55/5 59/1 60/13)
67/12 82/8 84/17 92/8,
93/17 94/7 95/25 96/4,
98/17 102/3 123/17
125/10 139/20 165/24}
166/7 167/3
your [178] 2/13 2/14
3/8 4/11 6/1 6/15 7/3
7/9 7/10 7/15 8/14
13/6 15/16 16/8 19/4
20/10 21/21 22/7
22/15 23/7 24/7 26/21
27/9 27/14 27/21
28/17 28/20 29/5 30/4I
32/18 32/25 33/6
34/12 34/14 35/14
36/20 37/15 38/1 38/5)
38/13 38/15 38/18
39/2 39/7 39/24 39/25)
40/10 41/21 41/25
42/13 43/9 45/8 45/16
46/2 46/16 46/24 47/6
48/3 48/9 48/18 48/20)
50/21 51/18 53/11
54/3 57/9 57/21 59/25)
61/13 61/18 62/8 63/2,
66/8 69/1 70/2 75/13
75/14 75/17 75/24
78/23 81/23 82/15
84/17 84/17 87/6
87/17 90/6 91/1 91/15]
91/16 92/3 92/8 94/7
94/8 95/12 96/23 97/2
99/25 101/1 101/2
102/1 104/2 104/4
104/13 106/24 107/8
107/19 107/22 107/24I
109/17 111/1 111/9
112/6 112/16 113/2
115/6 115/15 115/25
116/1 117/6 117/24
118/3 120/23 122/14
122/23 123/10 125/2
125/13 127/4 128/18
128/22 131/18 132/20)
133/20 133/21 136/5
136/14 139/16 139/20}
139/22 141/8 141/24
142/15 142/18 142/20)
143/3 143/21 144/21
145/6 145/8 146/12
148/7 149/9 150/4
153/3 153/4 155/11
158/5 158/12 159/5
162/25 166/11 167/2
169/1 170/15 171/22
172/16 177/8 177/13
181/4 181/8 182/7
184/8 185/4 186/4
186/15 187/8 187/10
yourself [3] 32/21
96/23 131/3
z
zero [7] 8/1 8/3 9/10
9/19 16/23 25/7 30/10)
zoom [1] 4/19
(80) witness... - zoom