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The Post Office Horizon IT Inquiry 25 June 2024
Tuesday, 25 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: Thank you. May I call Gareth Jenkins, please?
SIR WYN WILLIAMS: Yes.
GARETH IDRIS JENKINS (sworn)
Questioned by MR BEER
MR BEER: Good morning, Mr Jenkins. My name is Jason Beer
and I ask questions on behalf of the Inquiry. Can you
give us your full name, please?
A. My name is Gareth Idris Jenkins.
SIR WYN WILLIAMS: = Mr Beer, before you go any further, is it
appropriate for me to direct Mr Jenkins about
self-incrimination?
MR BEER: Yes, sir.
SIR WYN WILLIAMS: Mr Jenkins, I am sure you've been advised
but, under our law, a witness at a public inquiry has
the right to decline to answer a question put to him by
any of the lawyers involved in the Inquiry, or by me, if
there is that the answer to that question would
incriminate you. This legal principle is known in
shorthand form as the privilege against
self-incrimination. I've decided that fairness demands
that I remind you of that principle before you give your
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next three days to give evidence. Can we start, please,
with your witness statements.
A. Yes.
If we can start with the fifth witness statement,
please, which was, in fact, a witness statement you made
only yesterday. It's WITN00460500.
Yes.
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Have you got that witness statement in front of you?
I have indeed.
p>po>
It's three pages long and it consists of three pages of
corrections to your previous witness statements; is that
right?
That's correct, sir.
Is that your signature on the third page?
Itis.
Are the contents of that, your fifth witness, true to
the best of your knowledge and belief?
They are.
That. Can we go to your first witness statement, then,
please, which is WITN00460100. It's dated 6 February
2023 and is 15 pages long.
Yes.
prop
oP
Have you got that?
I have got that.
Is your signature on page 15?
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evidence. I must stress to you, however, that it is for
you to make it clear to me that, in respect of any
question put to you, it is your wish to rely upon the
privilege. If, therefore, any questions are put to you
by anyone who is asking you questions which you do not
wish to answer, on the ground that to answer such
a question might incriminate you, you must tell me
immediately after such question is put. At that point,
I will consider your objection to answering the question
and thereafter rule upon whether your objection should
be upheld.
I know that you are legally represented. No doubt,
if the issue relating to self-incrimination arises, your
lawyers will assist you and, if at any stage during the
questioning, you wish to consult your lawyers about the
privilege, you must tell me so that I can consider
whether that is appropriate. Do you understand all
that, Mr Jenkins?
Yes, I understand, sir.
‘SIR WYN WILLIAMS: = Thank you.
Yes, Mr Beer.
MR BEER: Thank you, sir.
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Mr Jenkins, you've made five witness statements to
the Inquiry. Thank you very much for making those
witness statements and for attending today and over the
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Itis.
Are the contents of that witness statement true to the
best of your knowledge and belief?
They are.
Thank you. Can we go to your second witness statement,
please, WITN00460200, dated 1 June 2023, which is
67 pages long; is that your signature on page 67?
Yes, it's actually slightly longer because it's got
an appendix at the end but that's my signature on
page 67, yes, sir.
I'm only dealing with the body of the statement rather
than the additions at the end, which are exhibit sheets,
essentially?
Right, yes.
With the corrections you made in statement 5 brought
into account, are the contents of that, your second
witness statement, true to the best of your knowledge
and belief?
Yes, they are.
Thank you. Can we deal with your third witness
statement, please, 21 March 2024, WITN00460300, 234
pages long.
Yes.
Is that your signature on page 234?
Itis.
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The Post Office Horizon IT Inquiry
With the corrections in statement 5 brought into
account, are the contents of that witness statement true
to the best of your knowledge and belief?
Yes, they are.
Thank you. Then, lastly, statement 4, 29 April 2024,
WITN00460400, 83 pages long. Is that your signature on
page 83 of the witness statement?
Itis.
With the corrections in statement 5 brought into
account, are the contents of that, your fourth witness
statement, true to the best of your knowledge and
belief?
They are.
Thank you very much.
They can be put to one side now. Any further
references I give you will come up on the screen.
Okay.
Those witness statements, all five of them, will be
uploaded to the Inquiry's website. They are
a substantial body of evidence and, therefore, I'm not
going to refer to all parts of them when asking you
questions. Additionally, you've exhibited to your
witness statement a very large number of documents and
you have been provided by the Inquiry with still further
documents over the last year and a half, and you and
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-- until you retired in 2015?
Correct.
Dealing briefly at the moment with the stages of your
career at ICL Fujitsu, so far as concerns us, from about
1996 to about 2000 did you work in the agent team?
That's correct, yes.
You were one of a team of 10 to 20 architects working on
the Horizon system; is that right?
Something like that, yes.
From about 2000 until retirement in 2015, you worked in
the Architecture and Design Team; is that right?
That's right, yes.
That was part of the Development Team; is that right?
It varied. At some points it was, at other points it
was a separate team, but the work was similar in those
respects. I --
It was part of the Development Team, I think, until it
merged with what was called the Requirements Department;
is that right?
Yes.
How many people were in the Architecture and Design
Team?
I can't remember the exact numbers but, again, it varied
alot. It started off with about 20 or 30, I think I've
got the figure in my witness statement, and, by the time
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your legal representatives have had access to the
Inquiry's Relativity database. I think all of that has
resulted in you seeing a very large volume of material;
is that right?
Indeed.
If, at any time, you want me to stop or to slow down
when considering a document, then please do say so.
Thank you.
Can I start with your background, please. I think you
graduated in 1973 from Cambridge University with
a degree in mathematics?
That's correct.
Upon graduation, you immediately worked for
International Computers Limited, ICL; is that right?
That's correct.
ICL became Fujitsu Services Limited in 2002?
Around then. I'm not sure exactly when that happened
but, yes, it changed its name in the early part of the
century.
I was taking that from your witness statement.
Yes, I wasn't 100 per cent sure of the date but that's
the best of my recollection.
You remained there for the whole of your professional
career, is that right --
That's correct.
I retired, it was down to something like about half
a dozen, that sort of number.
Were they all the same level or pay grade as you or was
there seniority within the department?
Different people were at different grades but that
wasn't necessarily reflected in terms of a management
structure as such.
Throughout your time, I think your role was a technical
or operational one, is that right --
Correct, yes.
-- not a managerial or supervisory role; is that right?
No, I never had any man-management responsibilities
during that time.
You tell us in your witness statement that from 2002 to
2008 you "took on the role of defining the technical
changes required by Project IMPACT and worked on the
implementation of the Bureau de Change and the
acceptance of credit cards"; is that right?
Among other things. So those were the main
developments. So I worked on IMPACT until that went
live in 2005, I think it was, then I worked on Bureau de
Change and credit card changes and a few other minor
things before I moved on to Horizon Online Requirements
Capture.
Did you move on to Horizon Online from about 2008?
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The Post Office Horizon IT Inquiry
It was around then, yes. I can't remember the exact
time.
Did you work on Horizon Online from 2008 to about 2015?
Yes.
You tell us in your witness statement that you "worked
with Post Office analysts in defining the technical
requirements for Horizon Online"; is that right?
Yes, that's true.
‘And that you "supported Post Office's requirements team
in specifying use cases for the counter functionality"?
That's correct, yes.
What does that mean?
The contractual definition of how Horizon Online was to
work was that the counters should look -- should operate
in the same way as it did on Legacy Horizon and,
therefore, it was decided that we needed to put in place
something that actually defined exactly what that was,
and the technique that was decided was that Post Office
would put together the use cases to define the various
activities that went on in a Post Office to define the
steps that people went through for doing -- from how do
you sell a stamp to how do you balance at the end of the
week or whatever. So --
Sorry to interrupt you, that's a use case, is it?
Each one of those would be a separate use case, yes.
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of your time was given over to fourth line support?
It was supposed to average out at about 10 per cent and
I think that's roughly what it ended up as.
Thank you.
In your first witness statement, you refer to ICL
introducing what's called a Distinguished Engineer
Scheme, correct?
Yes.
You tell us that you became a distinguished engineer in
the mid-1990s?
Yes, I can't remember exactly when.
You were one of about 100 other ICL employees who were
described as Distinguished Engineer; is that right?
That's correct, yes.
Is it right that was an honorific title conferred upon
you by ICL and Fujitsu?
Yes, it was. It didn't make any difference to what
I got paid, or anything like that, it was purely seen as
an honour and just recognition of that I had a fairly
senior design role and was respected within the company.
What was the process that led to you becoming
a Distinguished Engineer?
I think I was nominated by my manager who filled in
various complicated forms to justify why I should become
one.
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Sorry.
Did you then develop the implementation of those use
cases and then test them?
Not personally. There was a team who were developing
the counter, and I was acting as a guide to that team in
terms of interpreting what the use cases meant and
looking at how the code that they developed came out,
and I was responding to when queries came out of the
testing process as to "Should it work this way or should
it work that way", "Is this a problem or is that how
it's supposed to work", and reacting to things like
that.
You tell us that, during your time at Fujitsu, you were
a group of anywhere between 20 and 100 software
designers and developers who would provide fourth line
support for both Legacy Horizon and Horizon Online?
Yes, so the way fourth line support worked was that the
people who were doing the development were expected to
spend a small part of their time in actually supporting
the live service and the system under test, and so
that's what fourth line support was all about, and I did
that just like everyone else in the Development Team.
That was an adjunct to your main role?
Correct.
Although I'm sure the fraction varied, what proportion
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Was there any further training or qualification or
a particular professional experience that was required
before you could would be required before you could
become a Distinguished Engineer?
Not, as such, no.
So it was simply a title given to you by your own
company?
Yes, correct.
Did you acquire any level of management responsibility
as a result of the appointment?
No, people did try and persuade me that I ought to
manage some people and I resisted it and successfully.
I think you've told us that it didn't affect your pay?
Correct.
You tell us in your first witness statement that, from
about 2015 until August 2022, you were on a retainer
with Fujitsu as a consultant; is that right?
That's correct.
What was the nature of your consultancy with them? What
were you consulting about?
Itwas various things. I -- the expectation was that it
would amount to something like about half a dozen or
a dozen days a year and, for most of the period, it was
at that level. I don't think -- although I was on the
retainer until August 2022, I think the last time
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The Post Office Horizon IT Inquiry
I actually did any paid consultancy was just before
Covid lockdown in 2020, which is why they decided that,
since they hadn't been using me for a couple of years,
that they didn't need to retain me any further. The one
exception to that was the time when the Group Litigation
was happening in 2018/2019, when I was working a lot
more than that, probably an average of about one to two
days a week, for a period of about five or six months.
So did your retainer essentially come to an end at the
time of the publication of the Horizon Issues judgment,
which was December '19?
No, the retainer came to an end in 2022 but I didn't
actually do much retained work after —-
Okay.
The last few things were actually talking to the lawyers
about the consequences of the Horizon Issues judgment.
Other than the provision of information, assistance and
evidence in connection with the litigation concerning
the Horizon system, what work did you perform in this
consultancy?
I was called to go to a few meetings. A lot of it was
to do with the hangouts from prosecution. I wasn't
involved in any particular prosecutions as such but
there was quite a lot of work going on in the background
which -- talking to various lawyers. I got pulled in in
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certainly between 2015 and the Horizon Issues judgment
in December 2019, was given over to the provision of
Litigation Support?
Certainly in 2018 and 2019. I'm not sure it was direct
litigation, it was probably about half and half. As
I say, I can't remember the gory details of exactly what
I was doing when but there were a number of notes that
I produced which I wasn't quite sure what the background
was but, looking back at it now, I realise was actually
maybe in preparation for what eventually became the GLO.
Have you read the Horizon Issues judgment?
I skimmed through it at the time and I've looked at
various sections but I don't claim to have read every
word, I'm afraid.
In high level summary, would you agree that Mr Justice
Fraser concluded, firstly, that Legacy Horizon was not
remotely robust?
I accept that that's what he said.
Do you accept that Horizon Online was susceptible to
accounting flaws?
Um --
That's what he --
Again, that is what he said. I think he is maybe
putting it do strongly. I felt that Horizon Online was
and is -- because, after all, it is still the system
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2016 for a bug that had been found that was quite
serious, the Dalmellington bug, that I think you may
well be coming back to later on, and it was felt that
I could maybe help explain what the consequences of that
was to Post Office.
I spent -- there was a problem that Post Office
had -- again, I can't remember exact date now it's in my
witness statement -- when the -- there was a mismatch in
Post Office's back end accounts. They tried to do
a reconciliation against data they had from Fujitsu, and
I realised what the problem was. It was to do with the
fact that they were taking the accounts at different
times. One was taking what the cash positions were at
7.00 in the evening and the other was taking the cash
position at midnight and, therefore, this accounted for
the mismatch that they had in the accounts.
So it was various ad hoc, fairly self-contained
tasks, each of which lasted maybe two or three days.
There seems to be a fly --
Yes, there is, it's a bit of a pain.
-- buzzing around. I don't want you to be distracted.
No, I'm trying to ignore it.
If it becomes too much, we'll break and get rid of it.
Okay.
Would it be fair to say that the majority of this time,
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that's operating today -- doing a good job in terms of
the accounting, particularly with the monitoring that
was going on in terms of being able to detect things
when they'd occurred.
He concluded that subpostmasters were not informed of,
and were therefore oblivious to, a range of bugs, errors
and defects. Do you agree that that is a summary of
what he found?
That is certainly what he said, yes.
And, lastly, that those bugs, errors and defects could
result in, ie cause, discrepancies or shortfalls in the
branch accounts of subpostmasters, thereby corrupting
transactions, disrupting data processing and recording
transactions?
That was a possibility but I'm not sure that I, even
today, I understand what bugs actually did cause the
problems that people are -- that people have suffered
from.
Do I take it that you accept his first finding that
Legacy Horizon was not remotely robust?
I don't accept that finding.
You don't accept his finding that Horizon Online was
susceptible to accounting flaws?
There were some discrete bugs that caused problems to
the accounts but they were very discrete and I believe
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The Post Office Horizon IT Inquiry
they were all well controlled and managed at the time.
You don't accept his findings that bugs, errors and
defects could result in, ie cause, discrepancies or
shortfalls in branch accounts?
They could cause discrepancies in branch accounts but
not at the sort of levels that are being talked about
and, in general, the systems, I believe, were operating
as they should.
Robustly?
It depends exactly what you mean by "robust" but as long
as you're not saying "infallibly" then, yes, because
I think "robust" meant that there were mechanisms in
place that would monitor what was going on, detect
problems, and that they were then investigated and
resolved correctly.
Horizon, both Legacy and Online, were working well in
your view?
Most of the time, there were clearly problems during the
pilots in both cases and there were clearly individual
problems that affected individual branches, and I'm sure
we'll come on to those at some time but, in general,
then I felt that the systems were working well.
The judge got it wrong?
I wouldn't like to say that but I think there's
a difference in emphasis between ~- there were clearly
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and that was where the data, not only of transactions
but working data during the day, what had gone on when
people logged on, all sorts of things, was all recorded
in this message store.
Then the other part of Riposte was a development
environment that allowed applications to be built on
that and the application environment that caused the
human interface that the postmasters saw the branches,
and that bit of Riposte I had not very little
involvement with in the early days. I got more involved
in that when I moved on to Project IMPACT in 2003 or so
but, in the early days, my main interaction with Riposte
was to do with the message store, and --
Thank you. Then, the Oracle-based software. Can you
describe again briefly, as you've just done, what the
Oracle-based software was?
This was really an Oracle database and this was used to
communicate with Post Office's back-end systems where
they did their back-end accounting. So that was really
the boundary between what Fujitsu was doing, or ICL was
doing, and what Post Office was doing. So what was --
that was basically an overnight batch processing system,
so it would process through all the transactions, it
would produce files of transactions that had happened
during that day, which were then transmitted to Post
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problems and he identified a number of problems and
I won't dispute those problems happened but, on the
whole, I felt that the systems were working well.
Can I turn in more detail to your role in the
development and rollout of the Horizon system, and in --
No need to turn it up -- paragraphs 18 to 23 of your
first witness statement, you describe your roles and
responsibilities at ICL and then Fujitsu. So between
1996 and 2002, you tell us that your initial role with
Legacy Horizon was "to integrate Riposte and the Oracle
based software", yes?
That's correct, yes.
And that you helped develop an agent layer that would
allow those two types of software to communicate with
each other?
Correct.
Firstly, can you describe briefly what Riposte was?
Riposte was a -- well, let's step back one. There were
two aspects to Riposte and this was software that we had
bought in at Post Office's request from a company called
Escher in the United States. The bit of it that I was
primarily involved in was what was called the message
store, which was a way that all the data about what had
happen in a branch was being record.
So it's a sophisticated database, in crude terms,
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Office's back-end systems.
You say that you developed an agent layer; what was.
an agent layer?
What an agent layer was doing was it was reading data
from the message store, and we had copies of the message
store in the data centre, and extracting the relevant
transactions and other information that was of interest
to Post Office's back-end systems, and writing records
to the Oracle databases to reflect those transactions.
Then there was also a flow in the other direction,
for example, reference data was being generated by Post
Office and, by reference data, the simplest example is
what's the price of a stamp today because, obviously,
the price of stamps changes every now and again.
So, therefore, things like prices weren't actually
built into the code; we just knew that you needed to
sell a stamp and then, behind that, there would be a bit
of reference data that says, well, if you sell a stamp,
it's going to cost you whatever a stamp costs today,
£1.15 -- back in the day it was about 30p or something.
Given that the work started in 1996, what challenges
existed in ensuring that the communication by the agent
layer was enabled?
I'm not quite sure I understand the question.
Yes. You tell us in your witness statement that your
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role lasted between 1996 and 2002, which is
post-rollout?
Yes. So --
What took six years?
Right. The work changed a lot over time because, at the
beginning, back in 1996, the first application that was
rolled out was actually a Benefits Agency application
which, by 1999 -- '98/'99, had actually got dropped
because the Benefits Agency pulled out of the contract.
So a lot of --
Just stopping there, I wonder whether you mind slowing
down a little bit.
Sorry.
Although the shorthand writer hasn't said anything so
far, I can imagine --
Sorry.
-- that she wants to.
Yes.
So if you can just so down a little bit, please.
What did you know as to the reasons why the Benefits
Agency pulled out of the contract?
I'm not sure that I was really aware of the detail.
That was something that was taking place at levels way
above where I was working.
What were you told?
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You tell us that you moved away from the agent team and
took on the role of defining changes required by Project
Impact. Did the work of the agent team continue after
you left?
Oh, yes, there was a team there. Someone else took over
the role of Chief Designer within the agent team.
I think he actually took over that role about 2000,
something like that, and I was gradually moving on to
other things on the side. So it wasn't a sudden "Drop
this and do that"; it was more of an evolution than
a revolution.
In your role between 1996 and 2002, were you in any way
responsible for communicating with the Post Office team
as to their requirements?
Not so much with their requirements. That really
started with Project Impact but I certainly was working
with the Post Office team in terms of defining the
interfaces between how Fujitsu's agents were operating
and how they interacted. Initially, there was a box in
between us and the banks called the Network Banking
Engine which was provided by IBM so, initially, we
provided the interface into that. Then, later on, that
was replaced, after I was no longer involved, by
a direct interface to the banks.
Did you come into contact with Jeremy Folkes, the
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I can't remember now what I was told. I think they
decided they were going to do things differently. What
they eventually did was they paid people's benefits
directly into their bank accounts, rather than doing it
through special application with the Post Office.
Were you told anything to the effect that one of the
reasons why the Benefits Agency withdrew was a lack of
confidence in ICL --
I'm not sure that I was aware of that at the time.
-- and doubts over the integrity of the data that the
nascent system was producing?
I don't remember hearing that at the time.
Anyway, you continued in the role until 2002. Does that
mean that the agent layer required a continual level of
support and maintenance, even after rollout?
No, because there were few -- there was new
functionality. So the main thing I was doing in the
early 2000s was -- network banking was introduced into
the system in 2003 and, a few months later, the support
of debit cards was introduced. So the main work I was
doing with the agents then was supporting the changes
that were required because one of the things the agents
did was they interfaced between the data centres and the
banking systems, and that was clearly a fairly
significant development.
22
Infrastructure Assurance Team Leader from the Post
Office?
Not at that time but I did come across him a few years
later when he moved roles and he actually joint Escher
as one to their consultants. So I did come across
Jeremy in his role with Escher but I don't remember
coming across him when he was working with Post Office.
He told the Inquiry, it was back on 2 November 2022,
that "we", and by that he meant the Benefits Agency and
the Post Office Counters’ team "had been denied
viability of the application design".
I'm not quite sure what he meant by that.
He continued:
"When I say we had some visibility of risk areas,
what I mean is that the areas where we had raised formal
risks to the service provider at the start, such as
Riposte, in those cases, we did get more information
but, as far as the application design, in particular
EPOSS, we had been denied visibility."
I think that was something to do with the way the
contract had been negotiated between -- or ICL
management, as it was then, and Post Office, and DSS.
I wasn't involved in any of that but, as I understand
it, it was a PFI contract and part of that meant that
the customer that to treat the whole things as a black
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box but, as I say, this is hearsay, if you like, rather
than something I was directly involved in.
Where did the hearsay come from?
Just chat around the office. As I say, I wasn't
directly involved in all that but, clearly, people were
talking about -- I think I was aware that Post Office
did not have the right to see various design documents
that were being produced.
What do you mean that they were buying a black box?
That it was up to Fujitsu exactly how they designed the
application and the details of how the internal design
was done was something for Fujitsu or ICL to worry
about, and it wasn't something that Post Office would
get involved in.
Would a consequence of that, in relation, for example,
to EPOSS, mean that it would be difficult, if not
impossible, for the Post Office to ensure that there was
data integrity?
I don't think it went that far. There were certainly
joint test teams. There was a lot of testing going on.
There were Post Office testers involved in testing the
system to make sure it came up with the right output.
So I -- yeah.
He suggested that the fact that the Post Office had
purchased a black box and had no rights to see how the
25
banking engine and then also with Streamline for the
debit card payments. So that was something that wasn't
part of the black box.
Why was the black box being mentioned; why was it being
talked about?
Well, I don't think it was being talked about as such,
it was really -- I probably picked that up from Jeremy
Folkes' stuff. As I say, I was aware that there was
a PFI contract and that it meant that we didn't
necessarily need to share detailed design documents with
the customer because it was Fujitsu's intellectual
property.
Was that the usual way of working or an unusual way of
working?
I'd not worked on the contracts like that before.
Before, I'd been in an internal development role
actually producing products that were sold rather than
working as a client for a specific customer like that.
So you wouldn't know one way or another?
Correct.
In relation to your fourth line support role, you tell
us in your witness statement, it's the first witness
statement, at paragraph 25:
"I would only have been aware of bugs, errors and
defects specifically allocated to me by third line
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black box worked meant that it was difficult, if not
impossible to ensure data integrity within the Horizon
system; you disagree with that?
I would disagree with that, yes.
You say that the answer to that is that they were
entitled to participate in testing?
Yes, as I say, I wasn't really involved at that sort of
level at that time. I was just looking after making
sure that the agents worked, rather than worrying about
how the counter worked and things like that.
Were you conscious, and were those with whom you worked
conscious, that the nature of the contract was a PFI
contract and, therefore, the client had no rights, no
visibility, over of the way the system was built?
I think I was aware of that, yes.
What effect did it have on your work?
Nothing really, other than -- at that time I wasn't
having any real contact with the customer anyway.
I only started getting involved with the customer later
and it was really a case of -- and the main work I was
doing with the customer in the early 2000s was with
agreeing these banking specs and there I was working
very openly with the customer because they were their
specs that were defining the interfaces as to how
Horizon was going to interface with, initially, the
26
support or where I was asked to route the issue to the
correct person in fourth line support, or where I was
asked for specific input on the problem because of my
particular expertise."
Correct?
Yes, yes.
Within your roles in Legacy Horizon, did you have any
oversight of all bugs, errors and defects within the
system at any given time?
No.
So you couldn't, at any particular time, speak to the
existence or non-existence of bugs, errors and defects
in the system?
Not from my personal knowledge, no.
If you did not have knowledge of, or oversight of, all
bugs, errors and defects within the system at any given
time, who did?
I would have thought the SSC would and -- there was
an area called Customer Services, SSC was part of that.
There were also problem managers who would look at
specific incidents. Now, incidents could be to do with
bugs, errors and defects or, more commonly, they would
be operational issues, where a bit of the network went
down or connections to banks went down for a few hours
which clearly was -- caused fairly catastrophic effects
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at the time, and so their job was to manage these sort
of things. So I'd have thought that, if there was
an overall knowledge of how well the system was
behaving, it would be part of their role.
We've heard from a lot of people from the SSC, and
they've told us that there were between 20 and 30 people
at any one time working in the SSC -- sometimes working
shifts, some working at home, some working in the
office -- that they only knew about the bugs that they
were allocated on the stack and that it was correct that
there might be informal sharing of information by people
who were sitting next to each other or talking about it
at the water cooler but there was no formalised system
for sharing knowledge within the SSC; did you know that?
I didn't know that. They would obviously be able to
speak better about that sort of thing than I was.
I wasn't part of the SSC.
But when I asked you who may have oversight of all bugs,
errors and defects within the Horizon system, you
pointed to the SSC.
As part of that but there was also -- there was -- the
whole point of the Customer Services Directorate was to
actually manage the interface with Post Office,
including knowledge of what had been going on the
system, what sort of problems there were and things like
29
errors and defects?
Not as such but I did have a -- probably a better view
of them, particularly during the pilot phase of Horizon
Online because, during the pilot phase, there was
a project team in place that was managing the pilot and
taking very close monitoring of any issues that were
going on during the pilot, and I would often get called
in by that team to investigate particular problems
particularly ones -- those that affected the counter.
Are the pilot phase of Horizon Online was over, did you
have oversight of all bugs, errors and defects within
the Horizon Online system?
No.
Same questions: if not you, did anyone?
Again, I think it was something that Customer Services
were supposed to be monitoring and managing. Now,
whether they did -- had that sort of stand back
oversight role that you've described earlier, I can't
think of any one person that did actually have that sort
of role but I hadn't thought of it that way at the time.
Again, same questions: how would you generally become
aware of such bugs, errors and defects as you became
aware of in Horizon Online?
The PEAK system was working. It was the same PEAK
system that operated for both Legacy Horizon and Horizon
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that.
That's a day-to-day function. What I'm looking for, it
might be described as an all-seeing eye, but somebody
who took a step back and would be able to say, "We've
had these problems in the past with Horizon, these bugs,
errors and defects, and, at the moment, we're servicing
the existence of these possible bugs, errors and
defects"; was there any such person?
I can't immediately think of anyone who would have that
specific role.
When you were in fourth line support, how would you
generally become aware of such bugs, errors and defects
as you did become aware?
There was a system called PEAK and it had a predecessor
called PinICL, and the way that operated, that was
effectively a database of the various defects, and that
included those found during testing as well as those
during live, and what happened was that PEAKs or PinICLs
would be allocated to a particular person, and I think
you'd normally get an email saying, "You've had this
PEAK that's allocated to you", you could then log in to
the PEAK system, have a look at the PEAK and see what it
said and then decide what you needed to do with it next.
Again, same questions: within your various roles within
Horizon Online, did you have oversight of all bugs,
30
Online.
So for both Legacy Horizon and Horizon Online, you
became aware of things that might be bugs, errors and
defects through the PinICL and then the PEAK system?
There was that but there was also the problem management
system. So then when something was identified as being
a serious problem -- and I think we're probably going to
go on and talk about the receipts and payments mismatch
problem at some stage -- then I was often called in to
help -- well, firstly, analyse the problem and explain
that problem so that Fujitsu management could understand
what it was all about, and I often got involved in
explaining it to the equivalent people in Post Office
about what the impact of that was, and what could be
done to remedy it, both in terms of fixing the code but
also fixing whatever the business impact of the problem
was, which wouldn't necessarily be fixed directly just
because you'd fixed the code.
So, for you personally, there were two ways in which you
became aware of bugs, errors and defects in Horizon --
Yes.
~ firstly, through your role -- the '10 per cent of
your time’ role --
Yeah.
~- with fourth line support, and that would largely be
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happenstance, would it, ie which PEAKs were allocated to
you?
It would -- the 10 per cent wasn't just for the PEAKs.
So any time that I spent talking about serious incidents
and things like that, that was all part of what I saw as
the 10 per cent of the time.
In any event --
Yes.
-- in your role in fourth line support --
Yes --
-- it would be largely happenstance whether it was you
‘or somebody else, one of the other people performing
fourth line support, who had a particular bug, error or
defect allocated to them?
Yes, it was based really on the skills and what area the
problem had happened in.
If it was largely happenstance that you became aware of
a bug, error or defect, in both Legacy Horizon and
Horizon Online, how could you subsequently give full,
complete and accurate evidence about the existence or
non-existence of bugs, errors and defects in Horizon?
I was -- what I was aware of was the fact that bugs that
actually impacted the accounts were very rare, there was
good monitoring in place to detect them and they got
fixed shortly afterwards. So, in terms of what was
33
Well, we've talked about some of those already, so I'm
not quite sure what --
Did they always come to you?
Oh, no, no. I mean, they go to whoever was the relevant
person. So there were certain areas that -- normally,
they just went straight to the Development Teams and
stint get involved in things. I tended to get involved
if it was seen as being a broader issue or something
like that. Not necessarily me, there were other people,
also in particular areas, would get called with.
How many other people?
I'm not sure, sort of another half a dozen, a dozen,
something like that.
What were the circumstances in which you would get
called in?
It's a bit difficult to define, really. Certainly, when
we got on to things like Horizon Online, if it was seen
as having an impact on the accounts, then we realised
that that was a very serious problem and that I would be
getting involved in those, which is why I got involved
with what I see as the main serious issues in Horizon
Online. And I was involved --
Receipts and payments mismatch?
Receipts and payments mismatch, the local suspense issue
and Dalmellington, those are the ones that I see as
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actually there in the live system at any one time, it
was very rare for there to be bugs there that would
cause problems and, therefore, I was confident in the
way that the system was operating, that it was operating
correctly.
To give that kind of very confident answer to a court,
wouldn't you want to know of the existence of each of
the bugs and how they'd been resolved and whether, in
fact, there was any ongoing impact?
I didn't realise at the time that I needed to do that.
So at the time, no, I didn't think I needed to do that.
Obviously, with hindsight, I realised that maybe
I should have been doing more research but, at the time,
I felt that that was sufficient.
The "that" in that sentence, meaning a general
confidence in the system and the way that it operated?
Yes, and the processes that were in place to actually
control things.
So generally confidence in the system, plus processes
that you thought were working, allowed you confidently
to give a generalised views that right?
I think so, yes.
During your employment within Fujitsu, did any of your
roles entail any overall responsibility for monitoring,
identifying or fixing bugs, errors or defects?
34
being serious issues with Horizon Online, and I got
involved in all of them because they saw me being
helpful in terms of my expertise and background for
those particular cases.
That was my next question: why did they come to you?
Because I'd had experience of dealing with things like
that. I think it was felt that I was in a good position
of turning some of the technical jargon into something
that laypeople could understand better. Now, having
read my witness statement, you may disagree with that,
but it was felt that I was in a good position to be able
to actually explain the technical problems in a way that
could be understood and to do that, both in terms of
written notes and in meetings with the customer when
these problems occurred.
What was the threshold for you becoming involved?
I'm not sure. It's -- I would get involved by probably
a phone call or an email from someone, either in the SSC
or from problem management, and they'd say "Gareth, can
you come and give us a hand, look at this problem and
see what's going on".
For all the problems that didn't get referred to you,
where that trigger was not pressed, how did you become
aware of those, or didn't you?
Probably the answer is I didn't.
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When you started to become the man that the Post Office
relied on to give evidence in court, did anyone say, "We
need to make sure that Mr Jenkins knows about the things
that are not referred to him"?
No.
Did it occur to you, "I might need, before going to
court, to find out about the things that have not been
referred to me, that aren't these level of particular
seriousness or which have financial or economic
consequences"?
That didn't occur to me but, again, as I've said before,
I was confident -- and possibly wrongly so -- that when
problems did occur, they were quickly fixed and they
weren't left to sort of fester in the system, to have
a larger impact.
I think you've acknowledged it a couple of times
already, knowing what you know now, would you adopt the
same approach of relying on your confidence?
I think I'd have to say that, with hindsight, I would
have done things differently, yes.
What interactions did you have with the third line of
support, the SSC, in relation to identifying and
rectifying bugs, errors and defects?
I'm not quite sure exactly what you mean by that
question, sorry.
37
You've told us already that Escher was responsible for
provision of the Riposte software; is that right?
Correct, yes.
And that that comprised of two main parts: the message
store and the desktop counter; is that right?
Correct.
The latter of those, the desktop counter, was the basis
for the EPOS system?
Correct.
I think you went to Escher in Boston for a week in 1996;
is that right?
Yes, I think I went back there for two or three ad hoc
trips after that, but that was my initial -- that was,
effectively, my first week on the Post Office Account,
when I got sent to Boston for a week to learn about how
Riposte worked.
If you did not have anything to do with EPOSS, other
than indirectly, why did you go to Boston for a week in
1996?
Because of the -- that was talking more about how the
Riposte message store was working and, also, there was
specific interfaces that Riposte had that could be used
by the agents, so that was covered in the first week of
what I think was a three-week training course. It then
went on to how did the counter applications operate and
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Yes. What was the nature of your communication with
third line support?
Usually, either by exchange of emails or telephone
conversations, and things like that. The third line
support team were in a locked area, so it was actually
quite difficult to actually go and -- I did occasionally
go and visit them and talk to them at their desks and
things like that but, generally, that was a difficult
thing to do because of getting through the security
systems to actually get to where their desks were. So
it was normally done by sort of phone or email or in
meetings, if they came out of their area to our slightly
less secure areas.
Thank you. Can I turn to EPOSS and Riposte, please.
Yes.
In relation to the EPOSS aspects of Horizon, you tell
us, it's paragraph 21 of your second witness
statement -- no need to turn it up:
"In summary until around 2003 I do not recall having
anything to do with EPOSS other than indirectly when it
had an impact on my work with the agents. From around
2003 onwards, I began to gain technical expertise and
a practical understanding of how EPOSS operated.”
Is that --
Yes, I'd agree with that.
38
I wasn't particularly interested in that at the time, so
it was felt that, rather than stay in Boston for another
couple of weeks, I might as well come home. So I did.
So is the answer that you went to Boston to learn how
the EPOS system worked, in particular how it might
interact with the work you were undertaking?
No. I went to Boston to learn how Riposte worked, to --
and, therefore, how the agents could actually use it.
There may have been slight mention of how applications
could work in that first week but I think the detail of
that was really covered afterwards, and I just didn't
get involved in any of that.
In relation to the development of EPOSS before the
rollout of Legacy Horizon, we've heard evidence from
David McDonnell; did you know him?
Vaguely. I have a vague recollection of him.
He told the Inquiry:
"My understanding was that Gareth [that's you]
Jenkins worked alongside another Chief Architect under
Alan Ward."
Was that correct?
I certainly did have a dotted retail line relationship
to Alan Ward, who was the Chief Architect at that time.
I thought that David McDonnell actually suggested I was
the Chief Architect and he's certainly mistaken in that
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belief.
He continued:
"Gareth Jenkins’ responsibility was specifically to
the EPOSS counter system."
Is that correct?
That is not correct.
He said:
"As the Chief Architect, I would have expected him
to be much more involved in overseeing a lot of the
previous coding standards and methodologies, and things
like that, and certainly the design documents."
You've, I think, answered this question already:
were you the Chief Architect of Horizon?
No, I wasn't.
Who was the Chief Architect of Horizon?
Alan Ward was at that time and I know he was quite
involved in the development of EPOSS at that time
because there were quite a lot of changes being made and
he used to regularly fly off to Boston for a couple of
days almost every week, to actually work with Escher on
changes to EPOSS. Now, exactly what there was changes
were, I've no idea; I was just aware that it wasn't
a good idea to try and find him on a Monday and
a Tuesday because he was probably in Boston.
Okay, and if you could just slow down your evidence
41
methodology in place?
I have no idea.
Did you know whether or not there was unit testing
within the EPOSS team?
I don't know.
He says that those issues were critical and were known
to everyone in the building. You're telling us that —-
I would agree they were critical. As to being known to
everyone in the building, the other thing to remember is
that the EPOSS team was based in Feltham and I was based
in Bracknell. Yes, I used to visit Feltham a couple of
times a week but I wasn't, actually, based in the
building all the time so, therefore, I would have had
less knowledge of what was going on in the background.
So these rather important facts that he told us about,
you were entirely unaware of?
Correct, and I'd agree with him they are important
facts.
Were you aware of an EPOSS Task Force being set up by
ICL?
I don't think I was aware of it at the time. Obviously,
I'm aware of it now from the documents I've been shown
but I don't think I was aware of it at the time.
Can we look, please, at FUJ00080690. If we just look at
page 2, please, we can see this was originally dated
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slightly please.
Sorry.
He told us that there was or had been:
a lack of formalised sign-off designs, a lack
of discipline, a lack of professional qualification in
key positions and a total disengagement of the Chief
Architect, Gareth Jenkins, [that] there were poor coding
standards, no methodology in place and no unit testing.
The issues were critical, making the EPOSS product
unstable. They were known to everyone in the building.”
Taking those in turn, you've already told us that
you were not the Chief Architect of Horizon but, putting
that aside, in relation to EPOSS, did you know whether
or not there was an existence or a lack of formalised
sign-off designs.
I've no idea what they had. I know what we had in the
Agent Team and things were formally signed off, I had no
idea what sort of processes they were following in the
EPOSS Team.
Did you know whether or not there was a lack of
discipline and a lack of professional qualifications in
the EPOSS Team?
I wasn't close enough to it to know either way.
Did you know, one way or the other, whether they were
using poor coding and there was an absence of
42
18 September 1998 --
Yes.
-- and this finalised version is dated 14 May 2001.
Yes, I can see that.
If we go ~-
Yeah.
-- back to page 1., it's a "Report on EPOSS PinICL Task
Force" and it:
"... reports on the activities of the EPOSS PinICL
Task Force, which was in place between 19 August and
18 September 1998 to reduce to manageable levels the
EPOSS PinlCLs outstanding at that time."
You can see, although it's on the second page
described, I think, as a finalised version, the status
is still a draft.
Yes.
The distribution does not include you. It's to
Messrs Austin, Bennett and McDonnell, but then
"Library"; can you see that?
Yes, I can see that.
What was the nature of ICL's document library at this
time?
There was a document management system, I think -
I can't remember exactly when that became formalised.
I think Matthew Lenton may have described something
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about this when he appeared a couple of weeks ago and
there was a document management system to which all
documents were put and people could look at documents if
they wished to do so but, normally, you would only be
looking at documents that either you'd written yourself
‘or were needing -- being asked to review in that
library.
So you wouldn't --
I wouldn't have seen this document, unless someone
pointed it out and said, "What do you think of this
document?", and I'm not aware that they ever did.
So it wasn't used as a knowledge base for those at your
level to peruse or look at your leisure?
I suppose I could have done, if I'd got nothing better
to do, but I don't think I would have been particularly
interest in what was happening with EPOSS at that time.
I think you've seen this document subsequently --
Ive seen this document recently, yes.
-- and you know -- I'm not going to take you through it,
we've seen it many times -- it gives a very damning
account of the problems with EPOSS?
lagree.
Mr McDonnell told us in his evidence that he presented
this report to you; is that true?
I don't think he presented it to me. I think he
45
the gory details of it 'm afraid but I
He said that you were very defensive of it and said,
"No, there's nothing wrong with it as it is".
I think it was more a case of pragmatism, in that
I think he wanted to totally change the way that the
Escher software interfaced with the applications. And
I could understand why he felt that there may have been
a better way of doing it but I could also see that there
was no way that Escher was going to go and totally
rewrite their software when it was basically operating
and doing what it needed to do.
The fact that there was a better way did not
necessarily mean that it would be justifiable to
actually change it. So I think there may have been some
sort of conversation along those lines but, as I say,
it's a very long time ago and I can't really remember
the details but that's a vague memory I have of that
area.
He said that he tried to engage you to lend your
“political design weight" behind at least the cash
account being rewritten; is that correct?
I don't have any recollection of being involved with
anything to do with the cash account at that time.
He said that he was unable to engage you to get you on
his side and to lend your persuasive weight to persuade
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presented it to whoever commissioned it, which I think
I understand now is Terry Austin.
And that you "denied the issues pointblank and ran off
to hide in Bracknell, and avoided contact with the
team"?
I don't think that's correct. I was -- as I said
before, I was based in Bracknell, not in Feltham.
I don't think I was hiding there particularly. I don't
think I had any involvement with the EPOSS PinICL Task
Force.
He said that:
"We managed to get Gareth down to the counter team
twice."
Do you remember that?
I don't. I do remember having some involvement with him
with some issues with Logistics’ visa system, which
I think is something he moved on to work with after he
left -- was no longer with the counter team, but I don't
recall having anything to do with him in terms of EPOSS.
He said that his team tried to engage you in
a conversation about the missing API; do you remember
what that is?
I think that was to do with the LFS thing that
I mentioned previously. So I think that was in a role
that he took on after the EPOSS team. I can't remember
46
Terry Austin to rewrite the cash account; is that
correct?
I have no recollection of that and I can't see how
I would possibly have been able to persuade Terry that
it had something to do with the cash account when it was
nothing to do with my area.
Did you have what he describes as "political design
weight": a certain amount of power?
Probably not so much at that time. I think maybe later
‘on then I -- that could be said but, at that time, my
main role was to do with the way the agents worked,
which was a fairly small cog in the system. It was
a fairly central cog and, yes, I think people did tend
to listen to me when I had technical ideas, but I think
that's over-stretching things, what you've just read
out.
He said that you became evasive with him and he was
never able to persuade you to come back down to Feltham.
I just can't remember those sort of interactions. I've
described to the best of my recollection the only sort
of interaction that I might have had with him, and
that's a very, very vague memory, I'm sorry.
Leaving aside your involvement and role in the way that
Mr McDonnell has described, would you agree with,
looking back now, what he said about the EPOSS team in
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the late 1990s? He said the team was:
"... like the Wild West, there were no standards in
place, there were no design documents. The culture of
the Development Team was -- I wouldn't say it was
a holiday camp. It was a free format. There was no
structure, no discipline. It was crazy. I've never
seen anything like it.”
I wasn't close enough to actually form any opinion on
that, I'm afraid.
Do you remember going down to his team on at least
couple of occasions?
Not really. I -- as I say, the only recollection I have
is discussing issues to do with LFS, which was a later
role that he moved on to. I don't remember having any
real involvement with the EPOSS team at that sort of
time.
That can come down. Thank you.
If you'd been asked a question at rollout time, to
what extent does the EPOS system function well and
effectively; what would your answer have been?
I don't know.
You --
I mean, my answer would have been "I don't know".
You wouldn't know one way or the other?
Yeah,
49
Was that a surprise when you found this out in the
course of the Group Litigation?
That such serious problems had occurred and seemed to --
though again, with that, the problems did get fixed but
I was surprised in some of the cases how long it took to
fix them and there were certainly some fairly
inappropriate comments in some of the PEAKs in terms of
whether things should be fixed quickly or not, which
I certainly wouldn't have agreed with if I'd seen them
at the time. But then it wasn't my job to see them at
the time.
Was your surprise compounded by the fact that you had,
in the interim period, between the relevant events
happening with the data tree build failure and you
discovering them in 2018, you'd given evidence in
written witness statements, and on one occasion orally,
in court?
No, I didn't think it was a problem as far as that was
concermed because, at the times I was giving evidence
for, I believed that the EPOS system was stable and was
operating correctly. So the fact that there were
problems during the pilot and the rollout don't
necessarily mean that the problems carry on into the
system. I was confident in the way that problems were
being picked up and fixed and knew things were being put
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So if you were to give evidence about that, you wouldn't
be able to say one way or the other?
Correct.
If you were to give evidence later on about events that
were happening in 2000, you wouldn't be able to say
whether EPOSS was functioning well or not?
Not in 2000, no. I believe it had stabilised by the
time I did get involved with it later on but, back in --
what state it was in 2000, I don't know how stable it
was and, clearly, as part of the work I did in 2018,
I did find some fairly serious issues that had occurred
at that time. But --
What were the issues you found out in the course of the
Group Litigation --
Yeah, that's right, yes.
-- in 2018?
And those work ones that I'd not been aware of until
I came across them as part of the Group Litigation.
Can you, rather than me doing it on -- it'll be late on
Thursday -- can you summarise what those are now?
The main one I can think of is the data tree build issue
that came -- that came around. That's the one that sort
of sticks in my mind at the moment. You may find others
that you may wish to prompt me about but that's the one
that sticks in my mind.
50
into the system to actually manage the issues that are
being found early on.
We're going to come back to the kind of answer that
you've just given quite a lot over the course of the
next two or three days but, in the answer that you've
given just now, do you agree that you are focusing on
whether it can be shown that an issue had an impact in
the case that you are looking at --
Yes.
-- rather than giving evidence about the existence of
bugs, errors and defects within Horizon, how quickly
they manifested themselves to Fujitsu, how promptly the
Post Office was told about them and the extent to which
subpostmasters had themselves been informed?
Yes, I was primarily looking at what was happening in
a particular branch at a particular time.
Was that your mindset when you were giving evidence?
Yes, that's how I approached support, and I didn't see
the giving of evidence as being any different from what
I was doing in my day-to-day support job. What I'd been
asked to do in support, as saying this has happened,
should it have happened and, if not, what's gone wrong?
And I just approached things on the same sort of basis.
Thank you. Can we turn to the IMPACT Programme. You
tell us in paragraph 20 of your witness statement that
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The Post Office Horizon IT Inquiry
you became involved in Project IMPACT, as it was called.
That was the name given to it by the Post Office and it
was essentially the replacement of the back-end
accounting system. Is that --
Yes.
-- an overall description of it?
Yeah.
Given your role in the project, can you describe shortly
what Project IMPACT was designed to do, so far as the
back-end accounting system was concerned?
Post Office had a propriety in-house system called, if
I remember rightly, CBDB -- I can't remember what that
stands for -- where they used to process their accounts,
and they decided they wanted to go for a more industry
standard system and SAP was the industry standard, and
probably still is, for handling accounts, and so it
wanted to move on to that.
Now, CBDB worked on the basis that it would take the
information from the cash accounts that were signed off
each week and derive everything from that, which meant
that it was always about a week behind what was really
going on, whilst with an SAP system, they thought they
could get a much more realtime knowledge of what was
going on in the system. So with SAP they would know
what had happened yesterday and, therefore, be in a much
53
So, as the counters specialist, which is what you were,
you redesigned part of the Legacy Horizon system that
produced the accounts for the subpostmaster to sign off:
would that be fair?
I oversaw that. I think the main detail was done by
other designers but my main role was actually
identifying exactly what the output needed to be of the
system. So, yeah.
So you were the lead designer --
Yes.
-- of this part of the IMPACT Programme --
Correct.
-- ie that part of the programme which redesigned the
accounts for subpostmasters to sign off?
Yes.
Can we look, please, at POL00038878. If you look at the
foot of the page, you'll see it's dated 3 March 2004?
Right, yes.
If we go to the top of the first page, it's described as
"Branch Trading Reporting, Management and Control and
Transaction Management: Conceptual Design". Is,
essentially, this a design document for the IMPACT
Programme?
Not really. I'd calll it a requirements document. So
Post Office decided that the term "conceptual design"
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better position, particularly to control their cash
flow, because they saw the amount of cash flowing
through the post offices as being a fairly critical
measure because, obviously, cash had to be paid for, and
it was all to do with Treasury interest rates and things
like that that I didn't really understand.
But I understood that having a good handle on
exactly how much cash you had where made a big
difference in terms of Post Office finances.
Can we look at your first witness statement, please,
WITN00460100, at page 13, please. It'll come up on the
screen. At paragraphs 45 and 46 you say:
believe that ICL/Fujitsu was only involved in
one aspect of Project IMPACT, which was implementing
changes to Legacy Horizon that would enable it to
interface with the new back-end system. This was
implemented in two phases as part of the S60 release in
2004 and the S80 release in 2005. My involvement was to
design the changes which [Post Office] wanted.
"I remember that these phases of the work required
a major re-engineering of the accounting processes in
each [Post Office] branch, [for example] removing the
cash account and introducing the branch trading
statement."
That's correct, yes.
54
was what should be -- the document be called but, to me,
it was a requirements document. This was setting out
what Post Office wanted to happen and this was actually
written by Post Office, though aided by a Fujitsu
requirements analyst called Phil Boardman, who I believe
has been in front of the Inquiry a year or so ago. But
this --
And you: you contributed to this?
I was involved in the workshops doing it. I don't think
I wrote any of the text in there but I was involved in
commenting on it and helping put together the diagrams.
But it was basically understanding what Fujitsu wanted
to do, and my involvement was really a case of saying,
well, if you want to do that, is that practical? Would
it be better to do it in a slightly different way to
make it more practical from a (unclear) point of view?
Just scroll down. We see your name as a contributor.
Yes.
Are you saying you didn't contribute to this?
Well, I contributed ideas to it but I don't think
I actually wrote any of the words in it.
Can we go to page 22, please, and paragraph 6.7,
an "Overview". If we just read this together:
"This area of functions has the purpose of providing
mechanisms to make adjustments to branch accounts, to
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correct errors and ensure branch accounts align with the
Post Office Accounts within POLFS. Various mechanisms
are available to identify errors that require
adjustments, and the discrepancy management functions
may be initiated from various places across the
business. The main areas will be from within the
Branch, from [Post Office] clients or centrally via
distributing electronic transaction corrections. These
corrections will replace the current error notice
processes and should not involve any manual paperwork or
processing. They will be received and actioned via
Horizon and will be distributed more quickly,
potentially only days after an error is recorded.
"The analysis has also identified requirements to
more tightly control and police the use of the suspense
account within the branch accounts. Only a limited
subset of the existing suspense account products will be
retained. The contractual requirements for agents to
make good unknown errors in branch accounts will be used
instead."
What did you understand that second part of 6.7 to
mean?
I understood that they wanted to limit the use of the
suspense accounts. My understanding was that there were
a number of suspense accounts and postmasters could
57
of it altogether but I know they were keen to reduce its
usage and there was, indeed, some reduction on its
usage.
Given that reduction on usage, if there was
a discrepancy in a subpostmaster’s account, after
Project IMPACT, the subpostmaster would have to accept
it and pay it before they could roll over into the new
trading period, correct?
That is what I understood the Post Office wanted the
system to do, so yes.
And, if they didn't pay, the Post Office would, in the
language of this document, enforce contractual
requirements; did you understand that?
I didn't really consider that sentence particularly and
I'm not sure that I really understood what that actually
meant. And my focus was on what exactly was it I had to
actually implement in the way that Horizon worked, and
what I took from that was I had to simplify the menus
for the suspense accounts, which was actually just
a reference data change.
Given some of the suspense account products were to be
removed and the consequence of that would be for
subpostmasters to have to accept discrepancies and pay
them before they could roll over into new trading
periods, was there any consideration, to your knowledge,
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actually post money to the suspense accounts for some
sort of business reason which I never really did
understand, and they wanted to reduce the amount of
money that was being posted into the suspense accounts.
Now, exactly why they wanted to do that, that was part
of Post Office's business for trying to save money, and,
now, in what way it did that, I didn't really
understand.
Were you told why they wanted to "more tightly control
and police the use of the suspense account"?
Not in so many words. What I believe was behind a lot
of this was they were trying to reduce the number of
staff that they had in Chesterfield back office, which
were monitoring things like this. So they were trying
to actually automate things and reduce the flexibility
‘on the postmasters which I thought was a business
decision for Post Office and nothing for me to get
involved in.
Were you told that the suspense account was considered
by the Post Office to be a vehicle for postmasters to
hide fraud?
Ican't remember. There were various discussions about
behaviours of postmasters and things like that but --
and I know that Post Office were quite keen to get rid
of the suspense account. In fact, they didn't get rid
58
of the importance of the accuracy of the figures
produced by Horizon?
Well, I always felt it was important that the figures
produced by Horizon were accurate and I wasn't aware
there was any doubt or challenge to that at that stage.
So, therefore, I didn't see that as being an issue as
part of what we were doing here.
So is the answer: no, that issue didn't even arise, that
the change that we're making, the removal of this
facility, means that it is very important that the
accounts that are to be signed off by subpostmasters are
100 per cent accurate?
Yes, and I always felt that they should be 100 per cent
accurate.
Of course they should be but were you satisfied that
they were 100 per cent accurate the whole time?
I don't know that I'd actually thought it through in
those sort of the terms at the time.
We've heard evidence from Susan Harding, who told us
that the business drivers for the IMPACT Programme were
to reduce the costs to the business, increasing
accounting efficiency and reducing the losses to the
Post Office. Do you agree that they were the business
drivers that you were told about?
I can't remember the details of the drivers but,
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certainly, I know that Post Office were trying to reduce
their costs. I've not twigged so much about the
reducing losses but they were certainly trying to reduce
their costs on the back end.
Were you told that a business driver was to improve the
Post Office's debt recovery from subpostmasters?
I don't specifically remember that one but I can't say
that I hadn't seen it in a document.
You tell us in your first witness statement -- no need
to turn it up, it's paragraph 41 -- that the effect of
the project was to reduce staff costs?
Yes.
Is that what you were told, as the driver, or as being
the driver --
That's my memory --
-- namely: this is all about reducing the number of
people at Chesterfield or elsewhere that need to be
looking at suspense accounts, rather than the reduction
of losses and the improvement of debt recovery?
That's my memory but I can't be definitive because it's
an awfully long time ago now.
You tell us in your witness statement -- paragraph 43 of
your first witness statement -- that the decision to
remove the ability of subpostmasters to post
discrepancies to a suspense account was because the Post
61
account so, as far as I'm concerned, there wasn't
a local suspense account prior to IMPACT. But I think
I know what you're referring to.
Yes. What's the answer?
I didn't know how it was used or what it was used for.
I just assumed this was part of the business processes
that happened. I think I understood that, in order to
post something to local suspense account, you did need
to have permission. How that actually operated --
presumably through NBSC -- but exactly how that operated
I didn't know and it didn't really concern me,
particularly.
Do you remember being told by the Post Office that
subpostmasters “hid their discrepancies" in the suspense
account?
I can't remember, sorry.
Do you remember any evidence of subpostmasters hiding
their discrepancies in suspense accounts?
I don't think I would have seen any evidence of anything
like that, one way or the other.
Were you given any information as to why subpostmasters
might hide their discrepancies in suspense accounts?
Not that I can remember. As I say, I wasn't that
interested in the whys. I was interested in what it was
that I was being asked to do in the system, not why it
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Office "took what I assumed to be a business decision to
remove this functionality". Was the only thing you were
told about the business decision that it was to reduce
staff costs?
I don't know that I would have taken too much notice as
to why they were doing things. My main focus on -- was
what was it they wanted changed in the system, not why
they were doing it.
Ms Harding told us that it was agreed during the design
of the IMPACT Programme that the suspense account would
be removed because, historically, it was used by
subpostmasters to hide discrepancies in their accounts.
Were you told that?
I can't remember explicitly, exactly, what I was told or
what I wasn't told.
What understanding did you have as to how the local
suspense account had worked historically?
We need to be careful here about terminology because one
of the things introduced here was something called the
"local suspense account".
I'm talking about at or before 2005, what was your
understanding as to how the local suspense account
worked? Not the --
That's where I'm getting confused. We introduced a new
concept as part of IMPACT called the local suspense
62
was being done.
You had no professional curiosity in that?
I mean, I went to a number of workshops about these
things and I sat through number of workshops, but
exactly what was discussed in them, because this is over
20 years ago now, I just can't remember the details. So
I may have been aware of some of those things at the
time, I just have no memory of it now, I'm afraid.
MR BEER: Thank you.
Sir, that's an appropriate moment for the morning
break. Can we break until 10.20 (sic), when we'll turn
to Mr Castleton's case.
SIR WYN WILLIAMS: 11.20, I think.
MRBEER: 11. Yes, quite right, sir.
SIR WYN WILLIAMS: All right then, 11.20.
(11.08 am)
(A short break)
(11.20 am)
MR BEER: Good morning, sir, can you see and hear us?
SIR WYN WILLIAMS: Yes, I can.
MR BEER: Thank you very much.
Mr Jenkins, thank you. Mr Jenkins, can we turn to
Lee Castleton’s case, please.
A. Yes.
Q. Can we start, please, by looking at FUJ00152573 and by
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going to page 13, please. Thank you. You can see here
a letter dated 18 November from Bond Pearce -- who were
the Post Office's solicitors in the case against
Mr Castleton -- addressed to Fujitsu; can you see that?
I can.
If we just read the first page in summary, it says to
Fujitsu, in relation to Mr Castleton’s branch at Marine
Drive:
"We act on behalf of the Post Office. [Between
those dates] Mr Castleton was a subpostmaster at the
Marine Drive Post Office. He was strictly responsible
for the safe custody of cash and stock and was obliged
to make good all losses caused through his own
negligence, carelessness or error and losses of any kind
caused by his assistants.
"Between [some dates] net losses of [£27,000-odd]
‘occurred at the [branch].”
He was suspended and then dismissed:
"The Post Office has now issued a claim against him
to try to recover these net losses. [He's] issued
a counterclaim for wrongful termination of his
contract."
Then 2, "Mr Castleton's defence":
"[His] case is that any shortfall is entirely the
fault of problems with the Horizon computer and
65
possible that they are not accurately recording all
transactions on the system’ and that there was no.
evidence whatsoever of any system problem."
Over the page:
"Please could you review W Mr Castleton's experts’
reports and prepare a formal report dealing with the
following points ...
"1. We need to explain to a judge who will know
nothing about Horizon exactly how it works [et cetera].
"2. Precisely what steps Fujitsu took to examine
the Horizon system at the Marine Drive [branch].
"3. Whether there have been any similar or serious
problems with the Horizon system at [Marine Drive] since
[his] suspension and dismissal.
"4. Whether you believe the suggestion put forward
by Mr Castleton's experts is likely to be correct ...
"5. If there have been any human errors in
recording the transactions, could an explanation be
that:
"(a) There was nothing wrong with Horizon because it
simply reflected the information entered onto it; but
"(b) If staff entered the wrong numbers into Horizon
there may have been no real loss (even though Horizon
would show a loss), because there could be human error
in accounting accurately recording transactions.
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accounting system at Marine Drive ... and that the [Post
Office] wrongly terminated his ... contract in respect
of which he suffered losses not exceeding £250,000."
Three documents are attached. In fact, the second
one has some attachments itself:
"Bentley Jennison [they were the authors of the
report in the second attachment] state that deficiencies
have probably been brought forward despite the fact that
they have been entered onto the suspense account entry.
They suspect this is because the Horizon system, despite
the suspense account entry, has failed to recognise the
entry on the daily snapshots. They have drawn this
conclusion through looking at the discrepancy of
[£3,500-odd] on 26 February 2004. They then suggest
this double accounting could have continued over
a number of weeks and that as such, [his] defence
‘appears to hold potential merit based on the limited
documentation’ they have so far reviewed ...
"Mr Castleton believes that if he can obtain further
documents, such as the daily snapshots, he will be able
to undertake a manual reconciliation of the cash account
in order to substantiate his belief that the losses are
not real but attributable to computer error. We attach
an email from Fujitsu to Richard Benton at the Post
Office dated 5 May in which Fujitsu state: ‘It is
66
"If so, would that be a likely explanation?
"6. Any other information you believe may be
relevant."
Then scroll down, please. Paragraph (4), "Duty to
the Court":
"As a result of the instruction you may be asked to
give evidence before the Court. Whilst the [Post
Office] will be liable to pay your fees, in preparing
your report and giving evidence, your overriding duty
will be to help the Court on the matters within your
expertise.
"You agree to meet the requirements of the Civil
Procedure Rules Part 35 [and a copy is enclosed] and
that your report will:
"1. Be addressed to the Court and not to the Post
Office ...
"2. Confirm that you understand your duty to the
Court and that you have complied and will continue to
with that duty.
"3. Contain a statement setting out the substance
of all material facts and instructions (whether written
or oral) on the basis on which your report is written.
This statement should summarise the facts and
instructions given to you which are material to the
opinions expressed in the report or upon which those
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opinions are based and if any of the facts are within
your own knowledge, which they are.
"4. Contain a chronology of relevant events;
"5. Contain a statement of Truth in the following
form [and gangs it's set out].
"6. You should note that proceedings for contempt
of Court may be brought against you if you make a false
statement and report verified by a Statement of Truth
without an honest belief it was true.
"7. It must contain a declaration that the report
has been prepared in accordance with the Code of
Guidance on Expert Evidence [which was also enclosed].
"8. Give ... qualifications.
"9. Give details of any literature or any other
material which you rely on in making the report.
"10. So who carried out any test or experiment
[et cetera].
"11. Give the qualifications of the person who
carried out any such tests [et cetera].
"12. Where there is a range of opinion on the
matters dealt with [that that change should be
summarised].
"13. Give reasons for your own opinion.
"14. Contain a summary of the conclusions reached
including any qualifications ...
69
"You confirmed that you:
"4. Are an independent party and not the client's
employee or agent, other than at the material time
Fujitsu was responsible for looking after the Horizon
system;
"2. Know of no reason why you should not act as
a witness for the Post Office in relation to the
dispute;
"3. Will advise us in writing immediately if [there
is] any conflict between your interest and the Post
Office's interests ..."
We are going to see in a moment that you commented
on some the passages from this letter. Was this letter
sent to you?
I've no recollection of that. I recognise the last bits
now as being what an expert's duties are, but the first
time I was made aware of what those were when I was
first put in touch with solicitors in 2020/2021, as part
of the police investigation into my conduct.
If the letter had -- you say you've got no recollection
whether or not it was sent to you?
I mean, I think I would have remembered if it had been
sent to me because I can see there that it's clearly set
out what the duties are and I wasn't aware of any of
those duties, until my solicitor pointed them out to me
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"Given the fundamental importance of meeting these
requirements, you should endeavour in your report to be
not only accurate but complete. You should mention all
matters which you regard as being material to the
opinions you express and draw the Court's attention to
any matter to which you are aware which might adversely
affect the validity of those opinions. This applies in
relation to the factual matters to which you refer and
also to the opinions which you express.
"You should not include in your report anything that
is suggested to you by anyone without forming your own
independent view.
"If, on reading the report of any other expert in
this matter, or for any reason, you consider, at any
stage, that any existing report of yours requires
correction or qualification you will immediately notify
us in writing."
Then (5):
"In performing all your duties for which the client
will pay, you will owe a duty to the client to act with
the professional standards of skill, care and diligence
adhered to by experienced and competent consultants
acting as expert witnesses.
"You will take reasonable care of any documents,
[et cetera]
70
when we first got engaged at the end of 2020.
When you are giving your answers, Mr Jenkins, you should
refrain, unless you're doing it deliberately, from
disclosing communications between your current solicitor
and you, which involve either the seeking of legal
advice by you or the provision of legal advice to you.
Okay, sorry.
Because, if you do that, you might be said to have
waived your privilege -- your legal professional
privilege in those -- and I or somebody else can ask you
about those.
Okay. I'm sorry.
So I'm trying to help here.
Yes, I understand.
If you wanted to give an answer of the kind that you've
just given, it would be without waiving privilege by
saying, "I only learnt that in 2020 or 2021".
Okay, yes.
Okay?
Yeah.
Itis, of course, open to you to waive privilege --
Yeah.
-- but I don't want you to do so accidentally.
No, I don't want to do so either.
Okay. You're reasoning that you didn't see this letter
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(18) Pages 69 - 72
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The Post Office Horizon IT Inquiry
because, if you had have seen the letter, you would have
learnt earlier than you say is the case about the
existence of an expert witness's duties?
Correct.
If you had received this letter, presumably you would
have read all of it?
I would certainly have skimmed through all of it, yes.
You wouldn't have read half the letter: the first page
but not the second page?
I don't think so. I don't recognise any of it.
You agree that Bond Pearce have set out here, just
reading it, the duties of an expert witness, what they
entail, very clearly, haven't they?
I agree, yes.
In a very easy-to-understand way, haven't they?
Yes.
Can we turn, please, to FUJ00154713. If we look at the
email at the foot of that page first, thank you, it's
an email dated 8 December 2005 about Marine Drive from
you to Brian Pinder?
Yes.
What was Brian Pinder's function at this time?
He was the Manager of the Security Team, I believe.
Just tell us what the Fujitsu Security Team did?
They were responsible for overall security, so making
73
following question, the answers are being directed back
to Graham ..."
Would you understand that to be Graham Ward?
I do now. I'm not sure I would have done at the time.
".., to formalise our response.”
Is that part in black there something that Mr Pinder
wrote?
I think so. Looking at that page, I think the bits that
I would have written is the "Brian" at the top and "This
is certainly true", which is a bit further down, I can't
see certain but that's my guess.
Trying to decode it, then, that second paragraph then,
after the word “Brian”, looks like it's Mr Pinder having
sent that to you and then you've cut it into your email
back?
Correct.
Then there's a part in lighter text, almost grey:
“If there have been human errors in recording the
transactions, could an explanation be that:
"(a) There was noting wrong with Horizon, because it
simply reflected the information entered on to it; but
Just stopping there. Is that likely to be what
Mr Pinder has included in his original email to you?
Yes, I believe so and I recognise that as being in the
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sure that the systems were secure, but they were also
involved with communicating with Post Office in terms of
providing what was called prosecution support or
litigation support. So they were providing things like
ARQ data and support of things like this.
Can we just see how this email works because it's
slightly difficult to understand which bit is you
speaking, which bit is Mr Pinder speaking and which bit
is the questions from the Bond Pearce letter of
18 November 2005. Okay?
Yes, and I suspect the original would have been slightly
easier to decode because it would have been --
Coloured?
-- multicoloured, yes.
Yes, we don't have the native version --
Yes, I understand that.
“Brian”, I think that's you writing, isn’t it?
I think it is.
Then the words in dark black or darker black:
"I have been asked by the Fraud Investigation Team
to answer several questions, to assist an enquiry
regarding a [Post Office] employees (subpostmaster)
alleging that the Horizon system may have lost his,
money. I can manage 5 of the 6 questions but wonder if
you could explain or provide an answer or opinion to the
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previous document which you showed me, yes.
One of the six questions --
Yes.
-- in the Bond Pearce letter --
Yes.
-- of 18 November. Then you reply, is this right:
"This is certainly true (ie Horizon simply reflects
the information entered into it)."
Correct. That would have been my comment.
So, in relation to if there have been human errors in
recording the transactions could an explanation be there
is nothing wrong with Horizon because it simply
reflected information entered into it, and you say,
"This is certainly true (ie Horizon simply reflects the
Horizon entered into it"?
Yeah, that is what I would have said at the time and
I stand by that today as well.
That is a possible explanation?
Yes.
Were you able to say that without investigation of the
facts of this case?
Yes, because Horizon is going to record what is actually
entered into it, whether that reflects what happened in
the real world, and if you do a typo when you put
information into Horizon, then it's going to accurately
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(19) Pages 73 - 76
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record that typo.
Then part (b) of the original question:
“If staff entered the wrong numbers into Horizon
there may have been no real loss (even though Horizon
would show a loss), because there could be a human error
in accurately recording transactions.”
Then scroll down. You say, I think, is this right:
“Again, this could be true. However if there is
some sort of misentering of data into Horizon, then
there would be another corresponding error which should
be picked up, eg as a stock error or some AP Client
being credited with an incorrect amount. Also, such
error should show up as part of the balancing process."
Again, you're there saying this could be
an explanation; is that right?
lam.
Then question 3 was:
"If so, would that be a likely explanation?"
You give quite a long reply, and you say:
"It is a possible explanation, but without doing
a detailed analysis of everything that has gone on in
the branch it is difficult to speculate as to what has
happened. Certainly the most likely explanation, is
misoperation or fraud. However I appreciate that that
is not sufficient for a prosecution. Without
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are --
Yeah, sure.
-- because they are, they're on the screen?
Yeah.
Why did you use them?
I don't know, is the simple answer.
Did they disclose the way you were thinking in December
2005, ie the most likely cause of what is being
described here is mistake by the subpostmaster or fraud
by the subpostmaster?
My feeling was that that was more likely than an error
in Horizon, yes. But I'm including the option of it
being a mistake.
But you can't say that without looking at the data, can
you?
Which is why I go on to say that I needed to look at the
data.
You say you appreciate that that is not sufficient for
a prosecution. Had you understood this to be a criminal
case?
Well, the fact that the request was coming from the
Security Team suggested that there probably was.
Did you, at this stage, understand the difference
between criminal and civil proceedings?
No.
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understanding what exactly is alleged (by [Post Office]
and the subpostmaster), I don't feel I can add anything
further."
So are you saying there, firstly, that you need to
see some underlying data in order to say what is likely
to have happened?
Yes.
Because, otherwise, it's mere speculation --
Correct.
-- ie the answers you've given to parts (a) and (b) are
speculation?
Yes.
You say that "It is certain that the most likely
explanation is misoperation or fraud". Why was it
certainly the case that the most likely explanation was
misoperation, ie by the subpostmaster, I think, or
fraud?
I'm not sure why I would have said that at the time.
I mean, looking back now, I think that's just one of
many different options but I accept those are the words
lused at the time. But I think I would stand by the
fact that I would need to look into exactly what had
happened.
Lots of people have said to me "I accept that they're
the words that I used at the time", and obviously they
78
Did you know that there were different types of courts,
some which tend to deal with money and some which tend
to deal with crime, sending people to prison and the
like?
Not really, no.
Did you understand that a prosecution tends to refer to
criminal cases?
I'm not sure I really thought about it. As I say, I'd
not really appreciated any real difference and so I was
probably using fairly loose language. After all, this
is an internal email.
There's then a part of the text which says, "I have
spoken with Dave Baldwin", et cetera.
Yes.
Is that paragraph again Mr Pinder?
That I would expect it to be, yes.
"I have spoken to Dave Baldwin on this and he
recommended I speak with you. I'll also be liaising
with him on my final response as we are fundamentally of
the opinion that Horizon does not 'eat money’ merely
accounts for its placement.”
Then you finish, I think this is you at the end
saying:
“Happy to discuss further if you want to look at
some more specific areas of Horizon."
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That sounds like me, yes.
The answer to the third question is an important one,
isn't it, because it says the answer to the first two
are mere speculation, without looking at the data?
Yes.
Can we go to the top of the page, please. Later that
day, Mr Pinder writes back to you, and says:
"Gareth
"[For your information}
"This is the response I intend to send to Graham re
your question if that's okay."
Then "Comments from Gareth Jenkins", question 1:
"If there had been human errors [then] (a) ..."
You can see your text is faithfully reproduced, yes?
Except that the last point has not been faithfully
reproduced.
No, no, just look at (a) to start with.
Yes.
That has been faithfully reproduced, hasn't it?
Yes.
Then look at (b), that's been faithfully reproduced,
hasn't it --
Yes.
-- your answer, yes?
Yes.
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I don't know, I think you'd have to ask Brian Pinder.
I'm asking you at the moment because what --
Yeah.
-- this is is an email to you, essentially saying, "Is
it okay if I send this as your response"?
I probably hadn't picked up the fact that it had taken
away the qualification that I had put in the original
email.
Do you read documents carefully?
I try to, yes.
You're saying you wouldn't have -- or you obviously
didn't pick this up at the time?
I clearly didn't pick that up on the time. Why he was
changing that to a "no comment" I wasn't particularly
clear. Perhaps I should have taken it up to him as to
why he was doing that but I assumed that he knew why --
what he wanted to respond, and unable -- maybe he felt
that I wasn't in a position to make the comment on that
last part. I just don't remember.
But you had, hadn't you?
I had commented on it, yes, but why he'd decided he
didn't want to pass that on, I don't know.
I'm not so much asking for his take; I'm asking why you
assented to this approach by not saying, "Well, hold on,
you've missed out an important qualifier"?
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Q. Then (c) -- or I'm going to calll it (c) -- the third
part of the question:
“If so, would that be a likely explanation?"
He has written:
"Not able to comment on this."
A. Yes.
The detailed and important answer you gave to the third
part of the question has been changed to "No comment",
hasn't it?
Yes.
2
Do you know why that was?
No.
It's an important qualifier to the answers to the first
two questions, isn't it?
I realise that now. I probably didn't appreciate that
at the time.
Q. Why not?
I don't know, is the simple answer.
Q. Can you think of a good reason why the careful
explanation you've given to question 3 has been changed
into "No comment"?
prop
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A. No, it may have been considered that it was just too
complicated an answer but --
Q. What's complicated about an answer "You need to look at
the data to give an accurate picture"?
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A. Perhaps I didn't realise at the time how important that
qualifier was.
Q. Can we go back to FUJ00152573.
SIR WYN WILLIAMS: Before we do, Mr Beer, I'm slightly
puzzled -- and it may just be me -- about how this email
the one that's on the screen, begins. "For your
information", and then this:
"This is the response I intend to send to Graham re
your question, if that's OK."
Now, to me, that reads as if Mr Pinder is going to
send this response to Graham, if it's okay with
Mr Jenkins, because it's the question that Mr Jenkins
has asked him. Am I misreading this?
MR BEER: No, that's exactly right, sir, I think.
‘SIR WYN WILLIAMS: I Is that consistent with the
interpretation that was given to the preceding emails,
which suggested that it was Mr Pinder who was seeking to
ask questions of Mr Jenkins, rather than Mr Jenkins
asking questions of Mr Pinder; do you see my point? It
may be that I'm just misunderstanding.
MR BEER: Sir, I think you may have misunderstood the first
email that we looked at, if we just go down to that.
SIR WYN WILLIAMS: Yes.
MR BEER: As I read this, there must have been an earlier
email that we haven't got in which Mr Pinder sent that
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first paragraph "I've been asked by the Fraud
Investigation Team", and then the second paragraph which
says, "If there have been human errors", if that's
marked, and then the paragraph at (a) if that can be
marked, and the paragraph at (b), and then Mr Jenkins
has replied in the darker text.
SIR WYN WILLIAMS: Yes. Well, that's as I understood what
you were explaining, and that did or could make sense,
but it's the juxtaposition of that with the beginning of
the next email that I'm struggling with. Anyway, I'm
sorry to interrupt your questioning of Mr Jenkins.
Maybe it'll all become clear to me.
MR BEER: I'll try, sir.
If we go back up to the top page, do you understand
that this is Mr Pinder saying to you everything below
the words "Comments from Gareth Jenkins" and including
the words "Comments from Gareth Jenkins" is what I,
Brian Pinder, are going to send to Graham —-
SIR WYN WILLIAMS: Yes, I do, but it relates to, and it's
just those three words "re your question", and it's the
other way around, isn't it, on the first two emails?
MR BEER: Sir, I think what that -- your -- I don't want to
give evidence here, but your —-
SIR WYN WILLIAMS: Maybe I should just ask Mr Jenkins.
What do you think ~
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A. Before we leave that, can we go down, please, to the --
my response to the third question?
Q. Yes, absolutely.
A. It starts -- again, it said, "It is a possible
explanation, but without detailed analysis it's
difficult to speculate". So I think what Brian had
interpreted from that, therefore, I wasn't going to
comment on it and that's why I would have been happy
with the "I'm not happy to comment". I suspect that is
probably what -- why I was happy with that being
replaced with "unable to comment" because I'm
speculating there and, therefore, it is not a definitive
answer.
Q. Doesn't that overlook completely --
A. But I accept the fact that the qualification would have
been useful information to have provided.
Q. Doesn't it completely overlook the fact that the main
point to question 3 is you need to look at the data?
A. Yes, yes, I accept that now. But that may well have
been why I was happy to allow the change to have been
made at the time.
Q. Okay. Can we go back, please, to FUJ00152573. This is,
if we just look at the foot of the page, Brian Pinder's
document -- if we go up, please -- addressed to Graham,
which is going to be Graham Ward. This is the response
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A. I think the "re your question" -- my understanding is
that Graham Ward had asked Brian Pinder six questions.
He'd identified one of those questions for me to respond
to, namely question 6, I think it was, and, therefore,
what he's saying is, "In response to your -- the
question that I've allocated to you, this is the answer
lintend to send to Graham Ward in response to that
specific question".
SIR WYN WILLIAMS: So your interpretation of the phrase
"your question" is not that you asked the question, it's
the question that he allocated to you?
A. Correct. That's how I understand it --
SIR WYN WILLIAMS: Right.
A. -- and that's how I would have understood it at the
time.
SIR WYN WILLIAMS: Fine. Well, then I follow. Thank you.
Sorry ~
MR BEER: So that should read, "I intend to send to Graham
the question that has been allocated to you, if that's
okay"?
A. That is how I've read it at the time, yes.
SIR WYN WILLIAMS: Fine. Then I do understand now. Thank
you.
MR BEER: Thank you.
Can we go back, please, to FUJ0015 —
86
of Mr Pinder. He says:
"In response to your email request dated 28 November
concerning the questions raised at paragraph (3) of the
above document ..."
The "above document" being the Bond Pearce letter
that we've looked at.
You will see the answer to question 1. Question 2,
it refers to, in the answer, a response from Anne
Chambers, which is attached. Then, if we scroll down,
please, to question 5, you'll see that the full question
in three parts is set out and the reply from Mr Pinder
is "Gareth Jenkins' response: attached".
If we go to page 3, please. So this was the
attachment to Mr Pinder's document.
A. Yes.
Q. Can you see that it's essentially his email back to you,
the "FYI" email --
A. Yes.
Q. -- including your signature block at the bottom, which
he did, in fact, include in his reply to you?
A. Yes.
Q. So the shortened reply has been sent back to the Post
Office?
You were able to comment, weren't you, whereas your
reply has gone back to the Post Office saying that
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you're not able to comment?
Yes.
Was the reason for that because it was thought that
an investigation of what the subpostmaster was saying
might not be in Fujitsu's best interests?
I don't know what was the reason for that change.
I would have been quite happy to investigate and look at
exactly what had happened in the branch and, in fact,
I believe, at some later stage, I did assist Anne in
doing some investigations there.
Was the reason for the different reply that
an investigation might reveal issues that Fujitsu didn't
really want to speak about?
Not that I'm aware of.
Thank you. That can come down.
I think you subsequently attended a conference on
6 June 2006 with representatives of Bond Pearce and
others; do you remember?
I remember seeing the documents about it and have vague
recollections of the meeting.
Let's look at the documents, please, POL00071427. We
can see this is an attendance note in the case of Lee
Castleton, dated 6 June 2006. We were previous looking,
to give you some context, at November and December --
Yes.
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there was a meeting and I met a couple of solicitors.
Had the guidance that Bond Pearce had given about the
provision of expert evidence by a Fujitsu employee been
forgotten by this stage?
I don't know whether it had been forgotten or what but
I don't remember any mention of it.
In any event, your recollection is that that wasn't gone
over again in the context of either you or Anne Chambers
giving evidence?
No.
Thank you. Can we turn -- this is 6 June 2006 -- to
three days later, to 9 June 2006. FUJ00154722, and look
at the email at the bottom part of the page. If we
scroll up just so we can see from and to, thank you.
From the solicitor at Bond Pearce, Stephen Dilley, to
Mr Pinder, copied to Graham Ward and Mandy Talbot. So
not you at this stage.
Yeah.
"... Iwould like to thank you and your team for finding
time to meet us on Tuesday."
That would be the date of the conference we just
looked at:
"We found the meeting to be really worthwhile,
helpful and productive. We will circulate a note of the
meeting shortly, just for everybody's record.
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-- 2005. This is at Fujitsu's HQ in Bracknell. In
attendance were, if we scroll down, solicitors, the
first three people, then Brian Pinder, Peter Sewell,
Andy -- I think that's Dunks --
Yes.
-- I think he's called "Dunce", Anne Chambers, Naomi
Ellis and you, a "Distinguished Engineer of Fujitsu"?
Yes.
I'm not going to go into the detail of this attendance
note. Do you recall any discussion in this meeting
about you or Anne Chambers giving evidence?
I think there was discussion about evidence being given
but I can't remember the details of it and I do know
that Anne eventually ended up giving evidence in the
case and I didn't.
You remember the second page of the Bond Pearce letter
and onto the third page of the Bond Pearce letter --
Yes.
-- an extensive explanation of the duties of an expert?
Yes.
Do you know what had happened to that?
No idea.
Were those issues discussed at this conference?
I have no recollection of any discussion of those there.
As I say, all I can vaguely remember is the fact that
90
"In the meantime, I attach a letter received on
7 June from Mr Castleton's solicitors. I have
highlighted the two paragraphs that I would like you to
have a quick look at. Basically they state the Horizon
system is equip with a facility via which its operating
software can be updated remotely via the connection to
the [Post Office's] head office and that the system
sometimes went offline when there are software updates.
They have therefore asked for documents relating to the
updating of the software of the system. My view is that
they are making a stab in the dark, but please could you
ask your team whether they would have or could obtain
any records of software updates?"
So this is a question about remote accessing of the
system.
Asort of remote access. I think I have explained
different types of remote access in one of my witness
statements.
We're going to come to that, probably tomorrow, but
a species of remote access?
Yes.
Now, if we look, please, at FUJ00152605, and if we
scroll down, please, and again, and again. We'll see
that email -- if we just scroll down a bit further,
we'll see the email we've just looked at.
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Yes.
Then if we scroll up, please, Brian Pinder sends that on
to you and Penny Thomas:
"I would like to run this by you first as I hope you
might be able to either answer the query (hopefully) or
point me in the right direction?"
Then up, please. Your reply of 9 June 2006, you
say:
"It is correct that we do update the software
remotely and that a software update could result in the
desktop being closed and restarted. However, even then
I don't see how it would result in losses as is being
claimed. Also software updates are relatively rare and
normally only take place between 20.00 and 01.00 and
again between 4.00 and 7.00 am with occasional
extensions at the weekends. This puts them well outside
the normal operational hours of Horizon.
"I think he is clutching at straws. However I guess
we do need to cover this is angle.
"I would expect the system to record details of all
software updates and when they took place at which bans.
However I don't know how long these are retained and
whether they are included in the Audit Trail so you can
check out the history for Marine Drive in 2004."
Then you suggest a place to start.
93
"Given this is a 'test' case and that the integrity
of the Horizon system is being challenged, my own
opinion is that this exercise should be completed by
an ‘expert’ from Fujitsu. However, it will obviously be
extremely time consuming as all the figures recorded
will need to be methodically and carefully analysed. It
is also important we complete the analysis and respond
formally to the points raised as soon as possible.
"My first question is:
"1. Is this is an exercise that Fujitsu could
undertake, possibly by Gareth perhaps, who would
presumably have a thorough understanding of the figures
recorded on both the transaction logs and the figures on
an office cash account?
"2. If the answer is yes, how soon could this
exercise be performed and a formal response prepared?
Will there be a cost..."
Then if we scroll up, please. We'll see there that
Mr Pinder forwards the email to you on 31 July, asking:
"Is this something you can provide?"
Yes.
Then if we scroll up to the top of the page, your reply
of 31 July:
"I guess it is the sort of analysis that I could do
if required. However it is fairly time consuming and
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In the provision of this information, which is
a reply about a species of remote access, had the
guidance in the Bond Pearce letter been drawn to your
attention about the provision of expert evidence?
No, I just had the question as shown in the email trail
that you are showing me.
So that letter of 18 November never made its way through
to you?
No, I'm sure that it couldn't have done because I would
have done things differently, not necessarily in this
case but certainly in later cases, if I'd been aware of
those responsibilities.
Can we move on, please, to FUJ00154727, and start with
page 2, please. An email from Mr Ward to Mr Pinder and
Mr Sewell; can you see that?
Yeah.
"Stephen Dilley (representing the Post Office) is asking
if it is possible that someone undertakes an analysis of
the figures recorded on transaction logs ... It appears
that the solicitors for Castleton are saying that
they've compared the transaction logs with the cash
accounts for week 42 themselves ... and that they don't
match. They conclude that Horizon is therefore only
recording half the [transactions].”
Then reading the second and third paragraph:
94
the problem is in adjusting my priorities to find the
time to do it. I don't know how many transactions are
involved and I would need copies of the cash account
before and after the period to carry out the analysis.
I might need to get hold of the reference data that was
current at that time (which is probably quite
difficult).
"Given the volume of the data, I would expect this
to take anything between 2 days and a week (it is
difficult to tell in advance given that I'll probably
need to feel my way), and I'll probably need help from
Penny in carrying out extracts from the relevant message
stores ...
"As for timescales, I can't spend more than a couple
of hours on it this week and probably can't start in
earnest until the week of 14 August [then] I'm on leave
“Anne Chambers might be able to do a similar
analysis (and she may well have some tools to help ...).
However, she's on leave this week."
So you're essentially expressing concerns about your
capacity.
Yes.
By this time, had any of the guidance that we saw in the
letter of 18 November 2005 been given to you about
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providing expert evidence?
I'm pretty sure it hadn't. I can't say definitively
because it's so long ago but, as I say, I think I would
have known if I had seen it.
Can we look, please, at FUJ00152290. If we scroll down,
please, you say there on 7 August to Mr Sewell, in
relation to the Castleton case and transaction logs,
second paragraph:
"I spoke with Anne this morning and we've agreed
that once the CP..."
Is that a change —-
Change proposal.
... is approved, that she will carry out the initial
analysis (based on transactions we get from Penny) then
we will review them together and I'll front up any
report we present to [the Post Office].”
Again, by this stage, we're now in August 2006, had
the guidance given in the 18 November 2005 letter been
provided to you?
Not that I'm aware of and I don't think that's the
letter that's referred to in an earlier email that's
mentioned in this email.
No, that's right.
I think that's a letter to somebody different.
Can we look, please, at FUJ00152292. 17 August 2006
97
calculations. I think what she sent there is
a spreadsheet that she put together and a note of what
she'd actually done and I then went through and checked
both her methodology and the conclusions she came to,
and then I think, at some later stage, I wrote it up in
a slightly different form than the form that she'd
passed it to me in.
Why were you going to, in your words, front it up, front
the report?
I can't remember now. That's clearly something we'd
agreed between us at the time but I can't remember what
the -- what was behind that at the time.
Can we turn to FUJ00122279, please, and scroll down
please. Thank you. An email of 2 August from
Mr Dilley, the solicitor, to Brian Pinder and others,
not including you, with the subject "First draft
Statement of Gareth Jenkins". He says to Mr Pinder:
"I refer to our previous correspondence and attach
the first [draft] of a... witness statement and Exhibit
for Gareth Jenkins. [It's] designed to:
“Explain what Horizon is; and
"Comment on Mr Castleton's allegations about the
Horizon system.
"I am preparing a second statement for Anne (to
follow shortly) which will deal with the call logs.
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now, about Marine Drive, from Anne Chambers to you. She
says:
"I've spent some time recalculating the CAP42 ..."
The Cash Account Period 42:
"... cash account for Marine Drive and addressing
the points in the letter from the solicitor. Hope it
makes sense to provide you with a starting point not
quite at the very beginning.
"Subsequent cash accounts, if needed, should be much
easier now I have the mappings set up and some idea of
what numbers need to go where.
“I'm now going to look at the loss made in week 42
and demonstrate that it was due to the difference
between system holdings and declared holdings.
"If this isn't at all what you wanted, please let me
know -- I don't really know what I'm doing!
"This hasn't had my full attention, lots of people
are on leave ... Also, yesterday I got my witness
statement which is (as I expect you found) full of
things I didn't say or do, including all those PowerHelp
calls."
So Ms Chambers had been asked by you to do the work
or it had been agreed by you that she should do the
work; is that right?
Yes, as I understand it, she did the initial
98
"[Can you] look at the first draft, make any changes
[you feel] are appropriate and also answer my questions
in bold italics. [He'll then revise the statement with
counsel.”
If that's scrolled up, please. It's forwarded to
you, for your information and action.
Yeah.
Can we look, please, at FUJ00122283. You reply the next
day at 3.30-ish and say:
"I've had a go through this. It isn't a complete
statement and I won't have time to sort out the
‘outstanding bits for a while. I think we probably need
to get the detailed analysis done before this can be
completed.
"I'm happy for you to send it as it is to Stephen if
you like but you may decide it isn't complete enough for
that. Also I may be able to research some of the areas
(such as auditing) that I'm claiming ignorance of if
that is required."
So you're essentially saying that "Here's
an incomplete statement, I haven't got a chance to
complete it yet" --
Yes.
-- "there's still some analysis work to be undertaken"?
Correct.
100
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Again, by this stage, had the letter of 18 November and
the expert duties points in it been drawn to your
attention?
No.
Thank you. That can come down. I think you were
subsequently informed by Mr Pinder that you wouldn't be
required to give evidence in Mr Castleton's case; is
that right?
That is what I understand from the documents I was
emailed. I certainly remember I didn't give evidence.
Do you remember Mr Pinder informing you directly that
you would not be required to give evidence in
Mr Castleton's case?
I've seen an email which effectively says that, yes.
Before the break can we just look at that, please.
FUJ00154733. I think this is, if we scroll down,
please, and again and again, and just go back to the
top, please. I think, again, as is or as was your
practice, you have cut into an email the contents of
Mr Pinder's email, and replied to it?
Yes.
So the first part of the text in the two lightly shaded
paragraphs is what Mr Pinder is saying; is that right?
That's my understanding of it and it makes sense reading
it that way.
101
I didn't need to be involved in the case any more and
therefore I could get on with my day job.
You, in fact, did have a continuing involvement in the
case because you answered some queries?
Yes.
But you didn't give evidence?
Correct.
The references to those, I'm not going to turn them up,
are FUJ00154747 and POL00069822.
In what capacity were you continuing to be involved
in the case?
I believe I was asked to do some further analysis. As
I say, I can't remember now what the details were but
Ive seen emails suggesting that I was asked some
specific questions which I responded to, and I think
I may have produced another paper as a result of some of
that investigation, but I can't remember now what I did
at the time. All I can go by is the emails that the
Inquiry has shown me.
That document can come down. Thank you.
You tell us in your witness statements that you
didn't see Anne Chambers' "Afterthoughts" document,
either at the time or until this Inquiry, essentially.
I've no memory of seeing that.
Given that the plan was that you should present the
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He says:
"Just been chasing Stephen up re your attendance and
any matters still outstanding for us [Post Office
Account], as follows; (my words)
"He states that although you [that's you,
Mr Jenkins] would probably make a good witness, it is
for evidential reasons that you cannot be called. To do
with evidence of ‘opinion’, ‘expert’ evidence and ‘real
evidence’, et cetera, et cetera (complicated legal
issues nothing to do with personalities)."
You say:
“Fine (I won't try and understand what this means! )"
Yes.
Was that the limit of the explanation that you received
as to why you were not being called as a witness in the
Lee Castleton case?
As far as I can remember, yes, I'm not aware of any
other briefing I got given.
Did you have an understanding of what the distinctions
drawn in this email between opinion and expert evidence
and real evidence were?
No, hence my comment about I won't try and understand
what this means.
Was that the end of it, so far as you were concerned?
Yeah. As far as I was concerned, it just meant that
102
evidence that constituted the work she had undertaken,
you were going to front up the report --
Yeah.
-- and then she had ended up giving evidence, rather
than you at trial, did you not discuss with her how that
came about?
I think it was really as part of this thing, that it was
a case of it had been decided that, because Anne had
done the original analysis and I think she had done the
analysis -- I think there may have been a call with her
back in 2004 because I think her analysis was partly
based on work that she'd actually done at the time and,
therefore, that was why she needed to give the evidence,
because she'd actually done the original analysis and,
therefore, me giving evidence, just reporting what she'd
told me, didn't really work.
So it was something like that, but I just don't
remember the details, and that was probably what I took
as being behind what was shown in the last email you
showed me.
Was that explained to you at the time, ie that Anne
Chambers is the one that's been selected to give
evidence because she could give some evidence of primary
facts, ie work that she had undertaken in answering
a Helpdesk query in 2004: that's why she's the witness
104
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of choice?
I think I may have heard that at some point but I just
can't remember the details, sorry.
Did you have any discussion with her about the wider
issues raised by her document?
What do you mean by --
She was critical of the process by which she had become
involved in the case --
Are you talking about the afterthoughts document?
Yes.
No.
Were you aware that she was an extremely reluctant
witness?
Yes, I think I was aware she was reluctant to be
a witness.
Why was she reluctant to be a witness?
I think it just took her outside her comfort zone.
I think that would apply to any person, really, going
before the legal process and she certainly didn't feel
very comfortable with it.
Did she raise with you her complaints about the manner
in which she had been pulled into the case?
No, I don't believe so.
Did she raise with you her complaints about the process
by which disclosure had been given?
105
-- just as a general topic, as a theme.
Okay.
In your witness statements provided to the Inquiry, on
a number of occasions you explain you were not the Chief
Architect for Horizon, correct --
Correct.
-- nor, indeed, a lead engineer for the Post Office
Account?
No.
You explain that you were not the only person involved
in the development of Horizon nor the maintenance of it
when it was up and running?
Correct.
Why did the Post Office rely on you specifically as its
expert witness?
I don't know, is the simple answer. I did have a fairly
good overview knowledge of the whole of Horizon because
of really going back to my role in the agent team,
because the whole point of the agents was to sit in the
middle and see the difference between what was happening
at the counter and what was happening at the back end
and, obviously, with the work I did on IMPACT, I got
a much more detailed knowledge of how the counter
operated. So, from that point of view, I probably was
one of the people who had a good overview knowledge of
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A. No, I think she may have mentioned something about
having something sprung on her about NT event logs being
different from logs, but that's the only vague
recollection I have, because I think she -- didn't she
have to go back about a month after the original trial
to present some further evidence or something?
Q. That's right. Is that something you spoke about at the
time with her?
A. I was aware that she had to go back and that she wasn't
happy with it, but not the gory details of it.
MR BEER: Thank you.
Sir, that's just coming up to 12.20 now, can we
break now until 12.35?
SIR WYN WILLIAMS: Yes, of course.
MR BEER: Thank you, sir.
(12.19 pm)
(A short break)
(12.35 pm)
MR BEER: Good afternoon, sir, can you see and hear us?
SIR WYN WILLIAMS: Yes, thank you.
MR BEER: Thank you.
Mr Jenkins, in your -- I'm going to turn to the
capacity in which you gave evidence in witness
statements and then orally in the Seema Misra case --
A. Yeah.
106
how the Horizon system worked. But! don't think I was
necessarily the only person.
Q. Was there anyone who was a better placed witness than
you?
A. Not necessarily. I think there was some email exchange
in early 2010, when there was -- other names did get
suggested to as to being able to get involved but, in
the end, it was me that got picked to actually get
involved.
Q. Did you ever discuss the role that you were performing
as a witness with anyone senior at Fujitsu?
A. They were clearly aware that I was being asked to do
these things and they accepted that it was something
that needed to be done and that I could probably do it
as well as others but I don't know that we had a formal
"Yes, this is something that needs to be part of your
job", but it sort of evolved, and then it did become,
effectively, part of my job, moving forward.
Q. Did you ever discuss with anyone senior at Fujitsu the
demands being placed upon you by the Post Office?
A. Yes, because I had to see how this scheduled in with the
work that I was doing, and it was felt that at the sort
of level that we thought was required of the work, then
it could be fitted in. But, clearly, now understanding
what maybe I should have been doing in terms of the role
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of an expert, then that would have been maybe
a different situation. It's difficult to speculate.
Was the focus on your capacity and the money that the
Post Office would be charged for the work that you did?
I don't think the money came into it because the Post
Office were paying for me regardless of what I did. So
it was really a case of they could pay for me to do
designs of new bits of the system or they could pay for
me to support prosecutions, and it was really up to
them. They were paying the same either way, so it
didn't really make any difference and certainly made no
difference to my salary.
So was the focus, then, on the issues of your
capacity --
Yes.
-- rather than the nature of the function that you were
being asked to perform?
Yes, I think that's probably fair.
During your involvement in the various criminal cases,
did you feel under any pressure placed upon you by the
Post Office or its lawyers publicly to refute any
suggestion by the defence that there were issues with
the reliability of Horizon?
There were certainly cases where they were trying to put
words into my mouth which I didn't want to say and
109
Mrs Misra, there was also a case to do with Mr Hosi
going on at the same sort of time, and she felt that it
was important that we had some sort of legal cover, for
want of a better word, of the way that it was being
approached.
And so she set up this meeting with David Jones
which lasted about an hour or so, something like that,
where basically what -- my memory coming out of that is,
“Well, just tell the truth and what happened, and get on
with it and we'll support you as you need it".
Was there any discussion there as to the capacity in
which you were giving evidence?
Not that I can recall.
Was there any discussion then as to the duties that you
may owe the court, given the nature of the evidence that
you were providing?
No, I don't believe so.
I think it's right, isn't it, that the Post Office and
its lawyers made a series of direct approaches to you on
a number of occasions?
Yes, they did, and I tried to forced them back into the
way that they should have been communicating with me,
they should have been communicating with me through
Penny and the Prosecution Support Team, and there were
a number of occasions where I was approached directly
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I think there are examples of emails where I've said,
"Well, I agree with what this defence statement is
saying and nothing really to add to it".
What do you think at the time, at that pressure being
placed upon you by the Post Office?
I just took it as being the way these things happened.
There was clearly, in some cases, it was -- things
seemed to be all happening last minute and I just
assumed that's how things happened in that sort of
environment.
Never mind the timing so much. II'm thinking more of
people were trying to put words in your mouth?
I wouldn't allow them to put words in my mouth unless
I agreed with them.
Did you raise that with anyone senior at Fujitsu?
I think I did -- well, I certainly had conversations
with David Jones back in February 2010.
He was a Post Office lawyer?
No, he was a Fujitsu lawyer.
Sorry, I meant a Fujitsu lawyer.
Yes, he was a Fujitsu lawyer. I think that was really
instigated by Penny, rather than myself. She felt that
Post Office were getting to be very demanding of Fujitsu
in general, and me -- and her to some extent -- in
particular, because not only was there the case for
110
and, in most of those cases, I then forwarded the emails
on to Penny and tried to get some sort of control back
on the process.
Can we just look at some examples of those, please,
Mr Jenkins. POLO0097138. If we scroll down, please.
There's an email underneath this one, no need to look at
it for now. You reply on 16 November to Rachael Panter:
do you remember who she was?
She was a lawyer working for Cartwright King, I believe.
You say:
"Rachael,
"Can't be you use the report I have already sent
you? There is no mention of the case on the report.
"You should really be addressing such requests
through Post Office rather than directly to myself.
"As far as I know there is no commercial cover in
place for me to spend any time on such activities (and
that includes the case of Nemesh Patel).”
Then, if we scroll up, please, James Davidson,
a Delivery Executive, says to Ms Panter, and you're
copied in:
"I am concerned at the engagement approach being
taken here, we are fully on board to support but all
approaches must come through Post Office by the correct
change process."
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Is this is an example of you pulling the Post Office
up on direct approaches to you?
Indeed it was, and if you notice on the previous email,
although I've been sent the email directly by Rachael
Panter, when I responded, I copied in both Penny Thomas.
and James Davidson, so they were aware of the fact that
I'd been approached.
What was the issue in your mind with a direct approach
from the Post Office?
I think -- well, there's two or three issues, really.
The main one was that I felt that the Prosecution
Support Team, namely Penny, needed to be aware of what
was going on and that we actually had a single point of
contact so that Fujitsu was aware of what Post Office
was requiring them to do in terms of legal processes,
and so on.
Why?
Just so that the right people knew what was going on.
And then there was separately the question of making
sure that Post Office was being charged correctly for
the use of time, and so on. Again, the charging didn't
really come down to anything to do with what I was being
paid or anything like that, but I needed to be able to
allocate my time so that it was being accounted for
correctly.
113
retain, to record and to disclose material?
I wasn't aware of that, no.
Was it in your mind that Fujitsu, as a third party to
a prosecution, might be required to disclose material to
a court?
No, I'd not thought of it that way at all. No.
Did you ever come to understand that you might owe
personal duties of disclosure to a court?
Only when it was explained to me in 2020 what an expert
needed to do.
Did you ever come to understand that Fujitsu may owe
duties of disclosure?
No, as far as I was -- understood it, the disclosure was
something that Post Office needed to worry about, not --
it wasn't something that affected me or Fujitsu.
What was your understanding of the Post Office's duties
of disclosure?
I didn't really understand what they were but I was
aware that there were -- that I was told that there had
been various hearings requesting various bits of
disclosure, which they seemed quite happy had gone to
say that they did not need to actually disclose the
things that they had been asked to disclose.
Was that in the Seema Misra case?
Yes. I wasn't concerned about the details; I was just
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Q. So just going back to the first reason you gave there,
or the first issue, why was it important that the
Fujitsu Prosecution Support Team were sighted on these
exchanges?
So that they knew what -- basically, so they knew what
was happening. It was their responsibility. There was
supposed to be a line of communication between the Post
Office Legal Department -- or not the Legal Department,
their investigators -- Jane Owens is the name that
I think of in that role -- and the Fujitsu team, to
actually know what was going on to coordinate the work
so as to be aware of what was happening and what was
going on.
What was the importance of that, though? Was it written
down somewhere that that's what had to occur?
I think it might have been but I wasn't aware of that
but it just felt that that was the right process for
doing things. I mean, my work had to be accounted for.
I had management telling me what I needed to do. Having
these odd requests out of the blue that were going to
take up time, I needed to make sure that people were
aware that these were happening and that my priorities
could be allocated correctly between the various demands
of my time.
Was it in your mind that a prosecutor has duties to
114
aware that such discussions were going on in the
abstract.
In any of those discussions, were the extent of Fujitsu
or your own duties of disclosure discussed?
No.
Can we move forwards, please, to FUJ00153986 and look at
page 8, please, and if we scroll down, please. That's
excellent. An email from Jane Owen on 16 November
2012 -- which is the same day we were looking at -- at
the moment to Penny Thomas, copied to Jayne Bradbury.
That's not a name that's familiar to me, do you --
I don't recognise the name at all, I'm afraid, sorry.
Anyway, Jane Owen, Security Manager in the Post Office,
says:
"Hi Penny ...
"Lam a little out of the loop with this now that
Ihave changed roles. I asked Mark about raising
an invoice (he has the budget) to cover the expert
witness requirements for one of Sharron’s cases ...
which I think the email below will relate to ... back in
April an order was raised ... but we were never invoiced
Do you know anything about that at all? Gareth has
been approached directly by an external solicitor and
Jayne will need to start discussions with our team
leaders on how we prevent this from happening going
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forward as it is clearly unacceptable that he be
‘ambushed in this way."
Did you feel like you were being "ambushed" by the
Post Office, that's the word?
I wouldn't have necessarily used that word but, clearly,
having this email out of the blue from Rachael Panter in
November when the last contact I had had about any of
these cases was about a month before that was a bit of
a surprise and, clearly, I felt that we needed to have
some sort of control as to how my work was to be
scheduled and how Post Office was managing this and
I see this as being Post Office trying to actually get
that -- some control put back in there.
But this is all about capacity and formalisation between
two business partners. It's not to do with the
substance of the evidence that you're to give or any
procedural duties that attach to it?
No, or sorry, yes. That's -- yes. Yes.
That's correct what --
That's correct what you said, yes.
Can we move forwards please to POL00229801.
Sorry, FUJ00229801. I think I said POL. Thank you.
If we can turn to page 3, please, and scroll down,
please. Thank you. This is an email exchange between
you and Angela van den Bogerd, can you see that, of the
117
in this way (though if you ask for formal help, it is
likely to be me who gets involved!)."
We saw the exchange of the previous November, where
there was an attempt at formality made. Had that
failed?
I'm not sure. I think what I -- it's a case of trying
to understand the amount of work involved. I've been
asked some specific questions. I probably spent about
half an hour or an hour replying to this email so
I thought it was simpler to just reply to the email and
then point out that this should really go through
official channels, and that is why I'd copied Penny in
on the response because I saw hers being the official
channel.
So I wasn't trying to be awkward; I thought let's
just answer the question because that's fairly
straightforward. If it was going to take me a long
amount of time, then I would have just said, "Let's get
this sorted out officially”.
Why was it outside your official remit?
Because my job was designing new changes to the system,
not answering questions from random people in Post
Office.
Why did you answer random questions from people in Post
Office?
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end of January 2013?
Yes, I see that. I don't understand the context yet
but, presumably, we'll get there.
To give you a bit of context, I'm not sure it's
completely necessary but if we just scroll down, please,
and scroll down still further, and again. Thank you.
This is about the Helen Rose Report. If you scroll up,
please, now.
When you say Helen Rose Report I'm aware of two Helen
Rose Reports. Are we talking about Lepton here?
Yes, I think so.
Okay.
If we scroll up to there. Thank you. I think Ms van
den Bogerd is asking you questions about it.
Yes. This looks again like an email from Angela van den
Bogerd to myself, where I've actually inserted with the
GIJ prefix my responses to her various questions.
Yes, and if we just scroll up, please. It's the second
paragraph of your reply. In the first paragraph you
say, "I've added replies with Gareth Idris Jenkins,
Gi".
Yes.
In the second paragraph, you say:
his is all outside of our official remit.
I probably shouldn't be doing this investigation for you
118
Because I felt I could actually answer them and I felt
that, if it did go through the official channels, it
would probably be me that would end up being asked about
them. I think at this stage, I may have already had
some sort of contact with Helen Rose about this but
I can't remember exactly the chronology.
By this time, you'd already raised a red flag, so to
speak, in November --
Yes.
-- about direct contact but you were perpetuating it
here?
Yes.
Do you adopt an informal "trying to help" approach?
I try to be helpful when I can, yes, but I'm aware that
I also need to try to put some sort of control in, which
is why I copied Penny on this to make her aware that
I was being asked these sort of questions.
Because, of course, you don't know what's going to be
done with what you said in your earlier email, do you,
ie the use to which it's going to be put?
No.
Can we move on. That can come down, please. You tell
us in your third witness statement a series of things --
I'm going to try and summarise them -- about your
approach when giving evidence. Firstly, would this be
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right, that you gave evidence without an understanding
that you might be an expert witness in the legal
sense —-
Correct.
-- and that you were, therefore, lacking in
understanding that you were subject to the duties
imposed upon an expert witness, including duties of
disclosure?
Correct.
You tell us in your witness statements that you lacked
that understanding in Ms Misra's case, that's
paragraphs 233 and 329 of your third witness statement.
Mr Allen's case, paragraph 619; and in Ms Sefton and
Ms Neald's case, paragraph 689.
Correct.
The second thing -- and, again, I'm trying to summarise
a large body of text here -- is this right: you say you
were never provided with written instructions to be
an expert witness in any case in which the Post Office
asked you to give evidence?
Correct.
That includes, Mr Thomas' case, paragraph 313;
Ms Misra's case, paragraph 329; Mr Allen's case,
paragraph 619; Ms Sefton and Ms Neald's case,
paragraphs 689; and Mr Ishaq's case, paragraphs 643 and
121
Office?
Well, they were certainly fairly chaotic, a number of
emails I was getting, and I was certainly aware that
I was getting asked the same question multiple times,
having already answered questions, and there was even
some occasions when I responded saying, "Well, here's
the email I sent to you yesterday answering the same
question". So, yes, I could see that it -- that there
was a lack of organisation, is maybe a polite way of
putting it, in terms of the way things were being
managed.
The email exchange that you had -- I'm not going to go
to it now, we'll go to it later -- when you asked for
guidance "What's expected of me as an expert witness”,
and you got a rather asinine reply, didn't you?
I can't remember that particular email but that doesn't
surprise me at all.
That one where "You've just got to tell the truth".
Yeah.
That one.
That's going back to -- that was Mr Thomas’ case
I believe, yes, yes.
Yes.
Yeah.
Were you concerned about that, the basic nature of the
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646?
Correct.
Thirdly, is this right: you say you were not informed on
how to interact with a defence expert or to prepare
a joint statement with another expert?
Correct.
That applied in both Ms Misra's case, paragraph 478, and
Mr Ishaq's case, paragraph 666?
Correct.
Then, fourthly: you say that you were never asked by the
Post Office to provide a witness statement that
contained an expert witness's declaration?
Correct.
That applied in Ms Misra's case, paragraphs 233, 466 and
483; Mr Allen's case, paragraph 619; Ms Sefton and
Ms Neald’s case, paragraph 689; and Mr Ishaq's case,
paragraph 669?
Correct.
You tell us in your witness statement, it's your third
witness statement, about circumstances in which you
asked for guidance in the run-up to Seema Misra's trial
as to what was expected of you as a witness.
Yes.
By that time, had you suffered from a lack of confidence
in the management of the requests coming from the Post
122
reply you got, the lack of guidance you received?
I just took it at face value, I think, rather than
questioning it. If I just had to tell truth then, well,
I'd do that anyway so that wasn't really telling me
anything new.
Why do we not see you asking any of your own managers at
Fujitsu for assistance in this regard, "I'm being
dragged into court proceedings here, please help me as
to what is required of me"?
I thought I was being told what was required of me by
Post Office, so I didn't really understand that I wasn't
being told the right things. So I just trusted what
I was being asked by Post Office and didn't see the need
to involve my management. They were clearly aware I was
spending my time doing these things but I didn't feel
I needed any further guidance from them, in that
I thought what I am looking for is guidance about legal
things, therefore I'll probably get it better from the
lawyers that I'm talking to in Post Office than managers
in Fujitsu who know no more about the law than I do.
But you got no guidance from the Post Office?
Well, I realise that now. I thought I was getting some
sort of guidance but it probably wasn't really very good
guidance.
What sort of guidance did you think you were getting
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from the Post Office at the time?
Tell the truth to complete a witness statement.
Why do we not see you asking the lawyers at Fujitsu,
with whom you did correspond relatively frequently for
greater support and guidance on the role that you were
to perform?
I think that came after about 2010, sort of in
Mrs Misra's case, and I did seek guidance from David
Jones and I had that meeting with him in February and,
for a while, then he actually acted as a buffer between
me and Post Office lawyers, and so on. Then later on,
I was involved with Jean-Pierre (sic), who did give me
a bit of further guidance but not the true guidance that
maybe I should have had in terms of what an expert's
duties were.
Can we look, please, at FUJ00152866. If we scroll down,
please -- thank you -- an email exchange between you and
David Jennings. Who was Dave Jennings?
I'm not quite sure. Reading the context of that email,
I think he was someone within Customer Service but
I can't remember exactly what his role was. I don't
recall the name at all now, I'm afraid. This looks to
be to do with booking time and concerns about what time
I was charging to Post Office for activities in support
of Penny.
125
"It varies
"Where do you book the time ..."
You say:
"I have a code for prosecution support”, and you
give the codes.
"Does anyone else in Requirements ... do this
activity?"
You explain and say you're not sure how they book
their time:
"Is there anyone else who should cover this activity
as well/instead of you?"
You answer:
Should’, then probably Yes. ‘Could’, then
probably No!
What did you mean by that?
Well, I think what I was suggesting is that maybe
someone should be formally doing -- performing this sort
of role but I was also accepting the fact that I was
probably in the best position to actually do that but
I certainly didn't want it as full-time job because
I was enjoying myself doing the design work that was my
day job, if you like, so I was seeing this as something
that I was fitting in on the side between that. So
that's really what I was trying to summarise there.
This seems to be focused on the commercial aspects of
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So, again, this is one of those emails where you set out
his questions and then answer them?
Yes.
You say:
"Dave,
"In response to your questions ...”
Then his question is:
"I understand you act from time to time to support
our prosecution ... activity -- sort of an ‘expert
witness’ I suppose.
"I have a few initial questions on this ..."
Then, stopping there, he describes you as "sort of
an expert witness". Did you regard yourself as a sort
of expert witness?
Well, I was clearly an expert in how Horizon operated
and that's what I assume that meant. I didn't
understand what it's meaning was in the legal sense, and
didn't until about 2020.
He says:
"How frequent is this typically and how much notice
is there ..."
You say:
"It's ad hoc ... I tend to have various questions
from Penny a couple of times a month.
“How much effort ...
126
the arrangement, whether there's appropriate commercial
coverage in place --
Yes, I think that must have been Dave Jennings' role,
was looking at the commercials of it because I think he
comes back to say that I'd spent about a week on it over
the past year, or something like that.
Was there any equivalent set of exchanges over the basis
of which you were giving evidence or your status when
you were giving evidence?
I'm not quite sure what you mean by that?
Were there any exchanges internally with Fujitsu, to
your knowledge, over the status of your evidence?
Do you mean, in terms of whether I was an expert or not?
Not that I'm aware of. As I say, what usually happened
is if there was going to be some sort of engagement of
my time for a particular case, then they would arrange
with Post Office to have some sort of commercial cover
for a number of days of my time and, if necessary, that
would get extended so that I had something to put the
time against. But exactly how those -- I left that
really to Penny to sort out, as long as I had the time
code to book to on a Friday afternoon, then that was all
I was really worried about.
Can we look, lastly before the lunch break, at
POL00097123, and look at page 9, please, and scroll
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down, and scroll down. Thank you.
An email from Ms Jennings:
"The case [that's Patel] due for trial ... Can you
... please put this date in your diaries.”
Scroll up, please. You reply:
"... 'm not aware of this case or what might be
required of me.
"I'm not aware of any other outstanding cases which
I might be involved in.”
Scroll up. Reply from Sharron Jennings:
"... Gareth
"This is the one you supplied the expert report and
witness statement for the week before last. Apologies
for not explaining that properly in a previous email.
It was a blanket email for all witnesses! It is unclear
at this stage who will be required as witnesses and
which evidence will be accepted without the need for
attendance. I just thought if I let everyone know they
can pencil it in and then I can let you all know nearer
the time."
Again, there's a reference there to you supplying
an expert report. Did that trigger anything in you?
No, because as far as I was concerned, what an expert
report meant was a report by someone who understood what
Horizon was about.
129
MR BEER: Good afternoon, Mr Jenkins. We were dealing with
prop
the theme of the capacity in which you gave evidence in
criminal proceedings and your understanding of the
capacity in which you were giving evidence.
Yes.
Can we continue that theme, please --
Okay.
-- by looking at FUJ00152872 and if we look at the top
half of the page, please, we'll see this is an email
from you to Penny Thomas of 19 December 2009 with
an attachment which in fact follows this document, and
you say:
"Penny, I attach the expert witness statement with
my comments.”
What you do, essentially, is attach Charles
McLachlan's second report in the Seema Misra case with
your comments on it. In that first line of the email,
you say:
"I attach the Expert Witness statement with my
comments."
You understood that Mr McLachlan was an expert
witness?
Yes.
Did you understand you were an expert witness in the
equivalent capacity?
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Q. Okay. Then if we scroll up, please. You say:
"Thanks for the clarification ... If I am required
to go to court ... I need some more background on the
specific case and exactly what's being alleged.
I appreciate that is not covered by my statement, but if
I need to be an expert witness, I need to understand
what is happening.”
In what sense were you referring to yourself as
an expert witness there?
A. Again, as an expert on how Horizon operated.
Q. That's not quite how it reads, is it?
I just didn't understand the concept of an expert in the
legal sense because I've got no legal background or
training.
MR BEER: Thank you.
Sir, that's an appropriate moment. Can we take
a break until 2.00, please.
SIR WYN WILLIAMS: Yes. So we will take a break until 2.00
please. Thank you.
MRBEER: Thank you very much, sir.
(1.08 pm)
(The Short Adjournment)
(2.00 pm)
MR BEER: Good afternoon, sir. Can you see and hear us?
SIR WYN WILLIAMS: Yes, thank you.
130
Not in the terms I now understand the capacity to be.
We're going to see in a moment you prepared documents in
answer to his and you engaged in a joint discussion with
him.
Yes.
Did you understand you were performing a different
function than he was?
I was clearly in a -- at least, I certainly felt I was
in a different position because I was not independent in
the same way that he was, in that I was an employee of
Fujitsu and, therefore, was effectively part of the POL
prosecution team.
Did you think you were part of the POL prosecution team?
Yeah, I think I probably did, because that's how the POL
lawyers were treating me.
If we scroll forwards, please, to the report which
starts at page 4, you'll see his second report and then,
if we go over the page, please, to page 5, you'll see
there's an index. Just note for the moment -- we're
going to come back to it in a moment -- section 5 is "My
Duties to the Court". If we go over to page 6, please.
Youll see that he sets out, to start with, his
instructions; can you see that?
Yes, I can.
If we keep scrolling through this, if we do it at quite
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a slow pace, you'll see that he sets out his
qualifications?
Yes.
Then if we scroll on, please. These are all
qualifications and experience. Keep scrolling, keep
scrolling, and keep going, and keep going, and again.
Then at 1.3, he sets out the confidentiality of the
document, and he makes some caveats at paragraph 1.4:
"This report should not be read as expressing any
opinion on factual matters which depend on disputed
testimony of the witnesses of fact, or legal issues. It
... reflects my understanding of the position.”
Then, over the page, he then sets out at
paragraph 1.5 his sources of information, and scroll on,
please. A big list of the documents that he's been
given. Then over the page, and keep going. He then
sets out at point 6 of his introductory paragraphs the
scope of his work. He describes himself as an expert
witness, not as a witness of fact. He then sets out
what he's done; looked at the documents that have been
provided to him; what he hasn't done, in 1.2; what he
hasn't had access to, in 1.3; where he attended, in 1.4
and 1.5. Then scroll down. Then over the page and at
1.7 he says:
“I have prepared an independent and objective report
133
report and so I didn't think I was -- and I wasn't
independent, like he was.
Never mind the independence point, what about all of
things that he said as to all of his qualifications, his
experience, his instructions, the documents that he had
been shown, the scope of his report, the caveats within
it?
Yeah.
Did you think, "Hold on, I've done none of that"?
I probably realised I hadn't done any of that but
I didn't see that it was -- what I did was what I was
asked to do, which was provide a witness statement or,
at this stage, all I was doing was providing comments on
his report.
When you read this, and you thought, "Well, I've given
witness statements in the past, in the capacity as
somebody with expertise about Horizon, I've not included
any of these things in any of the documents I've
produced, should I have done so"?
That didn't occur to me at the time. Maybe it should
have done but it didn't.
You said a moment ago that you thought that you were
appearing or performing a function in a different
capacity. Did that actually occur to you at the time,
ie, you addressing your mind to the fact that you were
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addressed to the Court."
He sets out what his company’s fees are dependent on
or not dependent on, and then he describes the structure
of his report.
Then if we can go to page 35, please. He sets out
his duties to the court. He understands his overriding
duty is to the court and that he has complied with that
duty and will continue to do so. Then, if you just scan
to yourself what he says in paragraphs 2, 3, 4, 5 and 6,
and scroll on. These are very similar to the letter of
18 November 2005, aren't they?
Yes, I agree.
Then, over the page, please. The expert declaration
continues. Now, all of those parts that I've shown you,
you would have read?
I will probably have skimmed through them, yes.
You will have read them?
I will have read them, yes.
When you read them, did you think, "Hold on, I'm giving
evidence about the very same matters that Mr McLachlan
is giving evidence. I don't say any of these things in
my witness statements or documents."
No, because I thought I was in a different position
because I thought I was actually -- well, for a start
I was providing witness statements, not an independent
134
a witness from Fujitsu, therefore lacked independence
and, therefore, the nature of the documents that you
produced fell to be differently constructed?
I'm not sure that I actually analysed it that far.
I was basically doing what I'd been asked to do, which
‘was comment on the report and it then was suggested that
it was presented in terms of a witness statement. So
that's what I did.
Can we go forwards, please, to POL00029411. This is one
of Mr McLachlan's reports, it's 50 pages long, with very
lengthy exhibits to it, again in the Seema Misra case.
One is dated 4 October 2010. You were provided with
this report, weren't you?
Yes.
Did you read it?
I didn't necessarily read the introductory bits to it,
I was more concerned with the technical information that
was in there and commenting on that. I may have read
the whole lot, I can't remember now, but what I was
really interested in was the technical information in
the report rather than things like the expert
declaration and things like that because I didn't see
that was particularly relevant to what I was being asked
to do at the time.
Again, do you now remember that: that you skipped over
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The Post Office Horizon IT Inquiry
or were not interested in the parts of the documents
that set out an expert's duties and the like?
I can't -- sorry, I can't remember exactly what I did at
the time but, as I say, what I would have been
interested in and what I knew I was being asked to
address was the technical aspects of the report.
By this time, this is October 2010, so shortly before
the trial commenced, you were aware that this was
a criminal prosecution of Seema Misra?
Yes.
A serious matter?
Oh, yes.
Were you conscious of the seriousness of the matters,
certainly for her, by this stage?
Yes, I suppose I was.
You would, therefore, presumably have wished to
approached your duties conscientiously and with care?
Oh, yes.
Can we look, please, if we go over the page, again, the
index page, and then over the page, please, and again.
There's an introduction and, if we go over the page, and
again, he sets out a "Summary of findings". If we go to
page 20, please and read this together, section 4 of his
report is points of difference between him and you. He
says:
137
not relevant to the case. In my view, if Transaction
Corrections are incorrect or omitted then itis
necessary for the subpostmaster to be able to have the
evidence and training to contest them. The fact that
there is a process for Transaction Corrections means
that data entry errors are recognised as occurring. The
... system does not automatically provide the evidence
(in the form of vouchers) to enable the subpostmaster to
easily raise or contest Transaction Corrections. Nor
have the Post Office provided evidence that demonstrates
that the training of Misra equipped her to deal with
transaction corrections effectively."
Then another example, if we go over the page,
please:
"In relation to 2.2.1 ... Jenkins is of the view
that because the subpostmaster accepts the remittances
and has an opportunity to raise issues for correction
this is not relevant to the case. In my view, there is
testimony from other subpostmasters that the end-to-end
remittance process introduces incorrect data into
Horizon, and because I have had no opportunity to
investigate this, I am unable to include this as
a source of problems at West Byfleet."
So you engaged in a discussion with him --
Yes.
139
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25 June 2024
"I submitted my draft report to Gareth Jenkins, the
expert from Fujitsu instructed by the Post Office for
his review on 1 October 2010."
That's right, isn't it: he sent you a draft of his
report?
Yes.
"We then had an opportunity to discuss points of fact
and opinion over the phone. Jenkins was able to advise
me of some errors of fact based on his extensive
understanding of the Horizon system which I have not
sought to dispute and I have incorporated corrections
arising from these errors into this final report.
Jenkins also indicated some areas where he held
a different opinion and this section seeks to set out
explicitly where our opinions differ side by side. I am
relying on his annotations to my draft report to
faithfully represent this position for the convenience
of the court. I apologise if, any of the individuals
items I have inadvertently misrepresented him or omitted
comments of importance."
Then 4.2:
“In relation to 2.2.1 Transaction Corrections,
Jenkins is of the view that because the subpostmaster
accepts the Transaction Corrections and has
an opportunity to raise issues for correction this is
138
-- and he provided this document, which sets out his
views and yours, where they differ?
Yes.
You would have read this?
Yes, I would have done.
Again, did you not think that you were giving evidence
in the same capacity as Mr McLachlan?
Well, I didn't see it in quite the same way because,
again, I was there as an employee of Fujitsu and,
therefore, very much as part of the Horizon system,
whilst he was whereas a totally independent person. So
I didn't see it as being quite the same.
You were being treated as the expert from Fujitsu that
had been instructed by the Post Office, as he sets in
his report?
Yes, okay.
Can we go to page 27, please. He sets out the terms of
reference for this exercise.
Yes.
He sets out his instructions in point 1, point 2 his
qualifications, and it follows the same format as the
previous report. I'm not going to take you --
Yeah, yeah.
You would have read this, wouldn't you?
Yes, I probably would have skimmed through that because
140
(35) Pages 137 - 140
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I didn't think that was particularly relevant to the
technical things I was being asked to comment on but
I probably would have read through it.
Did you not understand that you were the subject of the
same duties as is set out over pages and pages in
Mr McLachlan's report?
No, I'd not understood that.
Did you ask anyone, "Am I subject to the same duties as
this other man keeps writing pages and pages about in
his reports?"
No, I didn't ask anyone. Perhaps I should have done but
I didn't.
Can we move on, please. FUJ00156248. It's an email of
1 October, that's the date, if you remember, that
Mr McLachlan said that he had sent you his report?
Yes.
From you to Jarnail Singh, Penny Thomas and then
Jean-Philippe -- who I think you mentioned earlier --
Jean-Philippe Prénovost; who was Mr Prénovost?
He was a lawyer within Fujitsu.
And Tom Lillywhite, who was Mr Lillywhite?
He was Penny's boss and Head of Security at that time,
so effectively the roles that Brian Pinder had earlier.
You say:
"Jarnail [third paragraph],
144
planned call with Mr McLachlan later that day?
Yes, clearly, yes.
You say you were reluctant to have the conversation
without guidance --
Yes.
-- further guidance?
Yes.
What guidance were you looking for: guidance about what?
What I should be saying, how I should conduct the
conversation, and so on. And I can't remember what
guidance, if any, I did actually receive but I think
I did have the call with Charles McLachlan later on that
afternoon.
Can I press you on what guidance you were looking for?
How I should approach things, so it was really a case of
I thought there were things in that document that we'd
already discussed before, and I thought we'd agreed that
they weren't relevant, and here they were coming back up
again. So it was a case of why is that happening?
So was it about the substance of what Mr McLachlan was
saying in the report?
Yes.
Rather than your role, the role that you were
performing, that you were seeking guidance?
No, it was the substance.
143
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25 June 2024
“As discussed, this is what I've received from
Charles McLachlan the defence expert in the West Byfleet
case.
"I'm concerned about the tone and some of the things
being attributed to me. I'm in the process of
annotating the document with my thoughts/comments.
"Charles [Mr McLachlan] spoke to me earlier this
morning and has arranged to discuss my views with me at
4.00 pm this afternoon. At this point ... I'm reluctant
to have that conversation without some further guidance.
"When I get to the end of the document, I'm happy to
pass on my annotated copy ...”
Then something else.
So you were asking Mr Singh, is that right, for
guidance on Mr McLachlan's report when you first saw it
and you got, in fact, 14 pages into it -~
Yes.
- is that right?
Yes.
It goes to the lawyer at the Post Office, Mr Singh, and
to Fujitsu Legal --
Yes.
-- Mr Prénovost; is that right?
Yes.
Was this a plea by you for some guidance before your
142
How could they each help you, the two lawyers, on the
substance of what he was saying?
It was really a case of why was he coming back with
things that I thought we'd already discussed and what
I should do about that, and how to approach that in
terms of discussing things with him, as far as I can
remember.
You tell us in your third witness statement at
paragraph 463, that Mr Singh did not reply to this
email.
Okay, I can't remember the detail at this point but
I clearly had researched it at the time I was writing
that witness statement.
Can you recall whether any guidance was forthcoming from
anyone else, including Mr Prénovost at Fujitsu?
I can't remember, I don't believe I've seen any emails
that suggest that: whether there were any phone calls or
not I just can't remember.
By the time you were sending this you hadn't finished
reading; you were a third of the way in?
Yes. I mean, the point was I'd received this probably
first thing in the morning, so I thought let's -- whilst
I'm reading it, then that gave people a chance to react
because I'd already established the fact that I -- that
Charles McLachlan wanted to talk to me at 4.00 this
144
(36) Pages 141 - 144
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The Post Office Horizon IT Inquiry
afternoon, therefore let's give people warning, so they
have a chance to say and -- see what they can do to help
me in preparation for that call later on this -- that
day.
Did you go back to Mr Singh or Mr Prénovost when you'd
finished reading the report?
I think at some point I sent an annotated copy of the
report out. I'm not sure exactly who to -- probably to
the same people. I can't remember the exact sequence of
the emails that --
That's the one we looked at earlier, the annotated
version of the report?
Yes, but I can't remember exactly who I sent it to and
what stage in the proceedings. No, I think the one we
looked at earlier was one from about two or three days
later.
Okay. You think on this day you sent an annotated
version out?
I believe so but I can't be 100 per cent sure.
Did you at any time ask anything about the duties of
an expert witness about which Mr McLachlan spoke
extensively in his report?
I doubt it. I was more concerned about the technical
detail rather than things like that, that I saw as being
administrative parts of the report.
145
concerned his instructions, the documents with which
he'd been provided, the scope of the work that he had
undertaken, the caveats to the work he had undertaken,
the limitations of it, and quite extensive passages
about the duties of an expert, that didn't trigger
anything at all with you?
No, I don't think it did.
Can we turn forwards, please, to FUJ00124313. This is
a document in a different case.
Yes.
This is concerning the prosecution of Kim Wylie, and
it's a document prepared by you, we can see the date,
19 February 2013; can you see that?
I can see that, yes.
So it’s two and a bit years later?
Yes.
What you do, if we just summarise what you do in this
report, it comments on essentially requests for
disclosure that were being made by the defence in
Ms Wylie's case. What you do is you set out passages
from an expert report by Michael Turner, and then you
comment on them?
That seems to be what this is doing, yes.
Okay. You say in the introduction "I have been asked to
report on the document "Report: Disclosure Requests
147
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Q. Did you chase Mr Prénovost to say, "Look I'm doing this,
I'm still doing this without any guidance, can I get
some help, please"?
I don't remember, I'm afraid.
Or did you just plough on?
I probably just ploughed on but I don't know.
Did you have an in-person meeting with Mr Singh,
Mr Longman and Mr Tatford about this?
The following week I did, yes.
I think we've got no note of that meeting; is that
right, so far as you know?
A. I don't remember seeing any note of that meeting.
I certainly haven't seen one as part of the Inquiry.
Q. I don't think you've got a recollection of what was
discussed at that meeting?
A. No, my main recollection is coming up to London to have
a meeting in barristers’ chambers, which is something
I'd never done before, and meeting -- I think that was
probably the first time I'd met all three of them, so --
though I'd spoken to them on the phone before that. But
exactly what was discussed at the meeting, I can't
really remember.
Q. Sois it the case that when you were being -- looking at
the matter generally -- sent these documents from
Mr McLachlan and you read the parts in them that
146
prop
oP
Computer Evidence" provided by the defence in the case
of [Kim Wylie].
"In order to do that, I have copied in the report
below in blue font and added my comments in black font."
Again, I don't think we've got the --
A. Yes, I appreciate that.
Q. We'll have to work our way through it:
"In summary, it would appear that the Defence expert
is looking for as much information as he can to carry
out a detailed analysis. I have no problem in him doing
that and I am happy to assist in such an analysis (as
I have done in the [past] with other defence experts),
since the data requested is proprietary to Horizon or
Horizon Online and is unlikely to be understood easily
without some guidance.
"Any such analysis is likely to require a lot of
time and effort to analyse and therefore incur
considerable cost and elapsed time."
Then 2, "Disclosure Requests Computer Evidence",
"Terms of Reference". Now, this is you setting out
passages from Mr Turner's report.
A. Yes, this is just a cut and paste of Mr Turner's report.
Q. You'll see that he sets out his instructions and then,
at 1.3, he sets out his qualifications. Over the page,
he annexes a CV in Appendix A -- I'm not going to look
148
(37) Pages 145 - 148
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The Post Office Horizon IT Inquiry
at that -- he sets out a statement of independence and
then underneath "Statement of Independence", you've
written:
"I note that the CV refers to another Horizon case,
R v Julia Richards, Winchester Crown Court. I have no
knowledge of that case.”
That's you, adding that in?
Yes.
Then back to him:
"I have made a declaration at the end of this is
report."
Then he continues. I'm not going to go through all
of this. The part that's indented is him and the part
that's not indented is you; is that right?
That's my belief, yes.
Can we go on to page 6, please, and scroll down,
“Expert's declaration", you'll see that Mr Turner had
set out the expert's declaration.
Yes.
Yes:
"I understand that my overriding duty is to the
court ...
"I have set out in my report what I understand from
those instructing me to be the questions in respect of
which my opinion as an expert is required.
149
doesn't it?
It means I'd seen something similar before, for example
in the case of Mr McLachlan but I hadn't really taken
much notice of it and I didn't really think any of that
applied to me, wrongly.
Is that what that means, you're saying?
That's --
's rather more than those five words set out?
That was what I think I felt at the time, that I'd seen
that sort of stuff in other reports but I didn't see
that any comment was required and I didn't realise that
it applied to me because I wasn't making such
declarations.
That's not what you say here, is it?
No.
You say it's standard stuff and "standard stuff" here,
would you agree, in context, means it's normal or usual?
What I meant by that was that I'd seen something similar
to that before, for example in Professor McLachlan's
reports.
So on your account, it indicates that it was something
with which you were familiar?
I had seen it before.
Therefore it was standard?
For independent experts' reports.
151
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"I have done my best ... to be accurate and complete
... All of the matters on which I have expressed an
opinion lie within my field of my expertise.
"I have drawn to the attention of the court all
matters, of which I'm aware, which might adversely
affect my opinion.
"Wherever I have no personal knowledge, I have
indicated the source of factual information.
"I have not included anything in this report which
has been suggested to me by anyone, including the
lawyers ... without forming my own independent view ...
“Where ... there is a range of reasonable opinion,
I have [set out] the extent of that range ...
"At the time of signing I [believe] it to be
accurate. I will notify those instructing me if...
I subsequently consider that the report requires any
correction or qualification.
"... this report will be evidence that I give under
oath ...
"I confirm that ... the facts in the report are
within my own knowledg
Then you've added, "Standard stuff. No comment
required", haven't you?
Yes.
In this context, "standard" means usual or normal,
150
So going back to paragraph 1 of this list, you
understood that his overriding duty was to the court,
yes?
Yes.
That's standard, usual stuff?
Yes.
Did you understand that your overriding duty was to the
court?
Well, I took "overriding duty to the court" being just
to tell the truth.
So the answer is, yes, you did understand that you had
an overriding duty to the court?
Yes.
Paragraph 2, you were familiar with that. That was
standard and usual, that the experts should set out in
their report the questions in respect of which the
expert's opinion was sought?
I'm not clear that I would necessarily have considered
all those points in detail when I wrote "standard stuff"
at the end. I was just commenting in general on
section 4 is an expert declaration and I'd seen expert
declarations before. So I'm not -- I doubt if I would
have gone through looking at each of those paragraphs in
detail and considering what they said. It was a case
of, yes, I'd seen an expert declaration at the end of
152
(38) Pages 149 - 152
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reports before and I saw that as a standard thing
without going into detail as to exactly what it said.
In relation to paragraph 3, which you regarded as
standard or usual, did you understand that your duty in
preparing documents was to be accurate and complete?
Well, yes, certainly it needed to be accurate and
complete but to say whether I took detailed note of
exactly what it was saying in there at the time, I think
it's unlikely. I think I just saw that as an expert
declaration and that comment was referring to that as
a section rather than to the individual words within it.
When you were preparing statements or reports that were
annexed to statements, did you understand that you were
under a duty to mention all matters which you regard
were relevant to the opinions which you expressed?
I don't know that I did understand that because I'm not
sure that I necessarily did.
When you provided statements to the court or reports
that were annexed to statements to the court, did you
understand you were under a duty to draw to the
attention of the court all matters which might adversely
affect your opinion?
No, I didn't understand that at the time.
You thought you were entitled to keep to yourself
matters that might adversely affect your opinion?
153
comments, then I would not change things but if I was
happy to agree with the comments and that it didn't
detract from what I was trying to say, then I was happy
to accept suggestions as to how my wording could be
improved.
We're going to come tomorrow to look, in some detail, at
the occasions when you changed your evidence as a result
of the suggestions made to you by others.
Yes.
In particular, lawyers.
Yes.
You didn't understand that you were under a duty not to
include in your documents suggestions made to you by
others?
No, I didn't understand that at the time.
Did you understand that you were under a duty to set out
a range of expert opinion in relation to a matter where
there was a range of expert opinion?
No, I'm not sure that necessarily applied but, no,
I certainly wasn't clear -- I wasn't aware of that duty.
Why do you say you're not sure that that necessarily
applied?
Well, you're talking about a range of opinion then I'm
not sure that there were cases where there was a range
of opinion, if --
155
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I was -- well, I was asked to comment on documents and
reports, and that was all I thought I needed to do, and
that's what I tried to do.
‘Answer the narrow question that was asked of you?
Yes --
You --
-- and no one had told me that I needed to do more than
that.
Did you understand yourself to be under a duty to
indicate in your documents submitted to courts where you
have no personal knowledge of a matter mentioned?
No, I wasn't aware that I had any need to do that.
You weren't aware that you had to indicate the source of
your information if it wasn't direct knowledge?
No.
Did you think, looking at number 6, that you were
permitted to include matters in your documents submitted
to the court -- if we go over the page -- which had been
suggested to you by anyone else, including the lawyers?
No, because, certainly as we've seen in some of the
cases, then there were comments made on my reports by
the lawyers, and I actually changed things there as
a result of some of those comments. So, therefore,
I didn't realise that there was anything wrong with
doing that. Obviously, if I disagreed with the
154
On all the matters that you gave evidence, the answers
were binary?
Well, okay, I certainly wasn't aware that I needed to
set out anything to do with a range.
In relation to the other matters mentioned in
paragraphs 8, 9 and 10, are your answers the same: that
you wouldn't be familiar with those duties --
No.
-- as applying to you?
No, all I thought I had to do was answer the questions
that I was being asked to answer and that they had --
obviously the answers had to be truthful.
None of these obligations can have been new to you,
because you wouldn't have described them as "standard
stuff", would you?
They weren't new to me but I don't think I'd taken in
the detail of them at all. I just -- as I said earlier,
the "standard stuff" was probably more to do with the
title of the section "Expert declaration", rather than
the details of the ten individual points within that.
You weren't saying the title is standard stuff; you're
saying the content is standard, aren't you?
The content is -- yes. But I hadn't really considered
in detail what the content actually was saying.
Why not?
156
(39) Pages 153 - 156
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Because I was concerned with the technicalities, so it
was the other bit -- I'm a technician, so I was more
concerned about the facts of how the system was working,
rather than the other -- the legal niceties, if you
like,
Well, both Messrs McLachlan and Turner were technical
experts too, weren't they?
Yes.
Did you think, "Well, hold on, I keep reading these
reports from other guys, and they keep saying this stuff
at the beginning and the end of their reports about the
duties that they're under. Does any of that apply to
me"?
Well, I wasn't producing reports; I was producing
a witness statement.
Do you think that's the answer to the question: because
the document on which you were typing or was being typed
for you, is headed up "Witness statement”, you needn't
have abided by any of these requirements?
It didn't occur to me that this would apply to me.
I clearly understand now that that's wrong but, I mean,
that was where I was at the time.
That can come down. Thank you.
You tell us in your third witness statement -- no
need to turn it up, it's paragraph 331 at page 110:
157
I think you acknowledge, or we'll find tomorrow that you
acknowledge, that the witness statements that you signed
presented a partial picture of what you understood about
Horizon's issues and faults because you were answering
only the narrow questions that you had been asked?
That's correct, yes.
How did you feel able to sign witness statements with
a declaration on them which presented only a partial
picture of what you understood about Horizon's issues
and faults?
I don't think I was being asked about Horizon's issues
and faults. What I was being asked to do was address
the questions in the reports that I was addressing.
You would know that witnesses, when they come to give
evidence, are asked to tell the truth and the whole
truth?
Yes.
Did you think you were only required to tell the truth
in your witness statements?
I was talking about the -- those aspects that related to
the Horizon system and I believe I did tell the truth
and the whole truth, as far as the Horizon system was
operating in the specific branches at the specific times
that I'd looked at data.
But you didn't feel under any compunction to volunteer
159
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"I knew that, like any other witness, I was required
to be truthful, although it would never have occurred to
me to be anything else. The approach that I took was
the one that I'd asked -- was asked to take by Post
Office lawyers, David Jones, a lawyer at Fujitsu, also
read at least some of my witness statements.”
You deal at length in that witness statement with
limited instructions you say you were given and your
limited understanding of an expert's duties. You were,
however, aware that you were being asked to produce
technical evidence on which a criminal prosecution was
based, weren't you?
Yes.
You would have been aware that the outcome for the
subpostmaster in question, the outcome that the Post
Office was seeking, was the criminal conviction of
a subpostmaster?
Yes.
You'd be aware of all of the consequences that such
a conviction would entail, including a possible term of
imprisonment?
Yes.
You signed a statement of truth on each of your witness
statements, didn't you, a declaration?
Yes.
158
information about other faults or system defects about
which you had not been asked?
I didn't think that they were relevant in those
particular cases.
Just expand on that. You're saying that you took
a conscious decision not to mention them because of your
own assessment of relevance?
Not a conscious decision. As far as I was concerned,
the system was behaving correctly in the branch at the
time and I'd seen nothing to show that it wasn't and,
therefore, other issues that I may have been aware of
were ones that had been -- that had gone on in the past,
or in the future, and had been fixed and did not apply
to the branch at the time that I was considering.
We'll come to the detail tomorrow but, in the light of
the answers you've just given, are you saying that, in
every case in which you provided a witness statement,
you had undertaken or caused to be undertaken a detailed
examination of the data relating to that branch?
I had undertaken an analysis of the data, not
necessarily a completely thorough analysis of it, but
what I felt at the time it was sufficient to show that
things were working okay at that time.
What about the generic witness statements that you
supplied later?
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Those, I think, were done at a much higher level. They
were giving a -- they were effectively saying that
Horizon was behaving as it should and that information
could be found from the audit trail to show what had
actually happened in the branch to look at any more
detailed question.
Can we look, please, at your third witness statement at
page 139. Again, we're going to deal with Ms Misra’s
case in detail tomorrow and on Thursday but can we look
at paragraph 404, please. You're dealing here with
Ms Misra's case, and you say:
"I have already explained that I had referred to the
event timeout/locking issues causing missing
transactions in Legacy Horizon and that Fujitsu had
drawn these to Mr Singh's attention. I don't believe
that [the Post Office] asked me whether it should
disclose these (or any other Horizon problems) to
Mrs Misra. I haven't seen any emails from around this
time which suggest that. I hadn't been involved in
responding to defence requests for disclosure in 2009,
nor the abuse of process application made by the defence
in February 2010. I don't think my email of 1 March
2010 is about disclosure at all."
So you say here you can't recall the Post Office
ever raising whether they, the Post Office, or you
161
and defects about Horizon of which you knew?
I didn't think I needed to do that because what
I thought I needed to worry about were ones that had
occurred at that particular branch at the time in
question.
Did you consider reflecting in your witness statements
or making qualifications in your witness statements, to
set out exactly what you had been asked to do and not
asked to do, and make clear that you had not been asked
about other issues?
That didn't occur to me, I'm afraid.
Looking back now, do you think that a reader of your
witness statements could reasonably gain the view that
you were setting out all that you knew about bugs,
errors and defects in Horizon?
I don't think I was ever asked to consider bugs, errors
and defects. What I was asked to do was comment on the
reports produced by Professor McLachlan.
We've seen you on a number of occasions provide
information through an informal channel, through emails,
to Post Office?
Yes.
Did you have any understanding or expectation of whether
that information provided informally would be disclosed
to the defence in the criminal prosecutions you were
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should disclose the issue of locking problems to
Ms Misra?
Correct.
By this time, you knew that, if you were to sign
a witness statement in Ms Misra's case, you would have
to sign a statement of truth on it?
Yes.
You knew that those statements were being used as
evidence in court to support a criminal prosecution?
I had sought guidance, I had said that, until we had
actually looked at the data, that I was not able to say
that there weren't any problems in Horizon and, when
we -- when I came to get -- see the data, which was in
early March, then there was a check done of the NT
events, which was the way that this event timeout
problem manifested itself and, therefore I was able to
include that as having been a problem in that branch.
By this time, you had got -- this is 2010 -- wider
knowledge of bugs, errors and defects in the Horizon
system than, in the event, was reflected in your witness
statements in the Seema Misra prosecution?
I'm not quite sure what you mean by that.
So, by March onwards, March 2010 onwards, when you made
witness statements in Seema Misra's case, you didn't
disclose in those witness statements all bugs, errors
162
involved in?
I didn't know what -- I didn't understand how the
process worked in that respect. I mean, clearly, if
someone had come back to me and said, "Well, in that
case you need to put something about it in your witness
statement", I would have done that, but no one did.
Did you think to include in your witness statements the
fact of your informal communications with both Post
Office and Fujitsu about the substance of the evidence
that you were to give?
No, that never occurred to me.
Or the detail of those communications?
No, I didn't think that was relevant.
What did you think was going to happen to the
information in those communications?
I didn't know what was going to happen to them. As
I say, if someone had told me that I needed to do
something about it, I would have done something about
it, but no one came back and said I needed to do
something formal about that -- that sort of exchange.
That document can come down. Thank you.
By the end of the Seema Misra trial, would you agree
that you have, by then, had a number of opportunities to
see whether the Post Office was adopting an approach of
seeking to tweak your evidence for its own interests?
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I didn't think that at the time. Having looked back at
things now, then I can understand that that may have
been happening but, at the time, I thought everything
that was happening was just a legitimate tidying up of
the statements to make them more readable.
Are you really saying, bearing in mind we're going to
look at these tomorrow, that you thought that what
happened in both the Hughie Thomas case and the Seema
Misra case was a tidying up exercise to make your
statements more readable?
And clarifying that, I don't think any of the changes
that were made actually changed the technical background
to what was happening. Yes, it changed the wording and
the way things were explained to some extent but
I think, in terms of they were still setting out the
facts as I understood them at the time.
I'm thinking more about the things that the Post Office
was trying to get you to include and, by the time we get
to October 2010, had you not formed the view that the
Post Office had tried to alter the substance of your
evidence, both in the Hughie Thomas case and in the
Seema Misra case and, in some cases, you'd resisted and
sometimes you'd not?
I'd not seen it that way. I mean, looking back it now,
can understand exactly what you're saying. But, at
165
some of the points he tried to press."
So, by this time, you had had the experience of
Graham Ward in the Hughie Thomas case seeking to press
amendments to your witness statement, hadn't you, back
in 2005?
Yeah, I mean, I was going to say that's about four or
five years earlier, so I probably wasn't really
conscious of that at this time.
Had you not remembered -- I mean, you didn't make
witness statements in many cases, I think it's 15
overall?
Yeah.
Had you not remembered Mr Ward being dissatisfied with
your use of language in a witness statement and making
a marked-up version for you suggesting parts being
deleted?
I probably didn't remember that in 2010, no.
But, in any event, here you say that Mr Tatford wanted
you essentially to harden up the case against Mrs Misra?
I'm saying that now, looking back at the email
exchanges. I wouldn't necessarily have put it in that
terms back in 2010.
Why not? A barrister saying, "Please include in your
witness statement’, if we just go back to what you said
at the foot of the page, 466:
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the time, I didn't see it as being anything strange or
unusual.
Can we look, please, at your witness statement, your
third witness statement, at paragraph 466, please, which
is on page 162. Scroll down, please. Thank you.
466, thank you. We're going to come back, again, to
the detail of this later, but you say, on that time and
date, you emailed a draft statement to Mr Tatford,
Mr Singh and Mr Longman. This is in Seema Misra's case.
Yes.
"I used the same template as I had for all my previous
statements. I specifically asked for their feedback as
to whether it was correct in terms of approach and
style. No one suggested that I needed to add any sort
of expert declaration to it. Mr Tatford made comments
on this draft which are visible at [and then you give
a reference]. He appeared to want me to make some
points more strongly in favour of the Post Office than
I had done. In particular, he wanted me to say it
looked as though Mrs Misra had stolen the money rather
than it was incompetence."
Then if we go forward to paragraph 468, which is
cover the page. You say:
"I think overall my responses to Mr Tatford's
comments demonstrate that I was not comfortable with
166
"In particular he wanted me to say it looked as
though Mrs Misra had stolen the money rather than it was
incompetence."
Yeah.
It doesn't take hindsight to realise that that is
a barrister asking you to harden up the case --
Yes, and I refused to do so --
I'm asking what effect this had upon you.
I don't know, I just assumed that this was normal
practice. I had no experience to compare it with.
Did it not make you feel uncomfortable?
Yes, it probably did make me feel uncomfortable, and
I resisted it.
Why did it make you feel uncomfortable?
Because he was trying to change what I was saying to say
what he wanted to say, rather than what I wanted to say.
Did this not cause you to think that there is a need for
caution here in my dealings with the Post Office, in
particular when giving evidence on behalf of the Post
Office, that their barrister is trying to get me to say
something that I can't and don't want to say?
No, I think it just made me make sure that I did stick
with my guns when I disagreed with what I was being
asked to do.
Again, did you not consider whether you ought expressly
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to qualify your statements to spell out what you were
saying about Horizon not being your complete knowledge
about Horizon integrity?
That didn't occur to me at the time.
As I've said, you later went on to produce so-called
generic statements --
Yes.
-- in a series of cases, essentially without access to
the complete underlying data?
Yes, because I saw those as being high-level statements.
I was expecting to get into more detail at some later
stage. As I say, when I first produced that, I had no
knowledge as to anything that was involved, and
I assumed that that was normal practice. Again, I now
understand that it wasn't and was probably totally
inappropriate but, at the time, I didn't realise that.
Did your experience in the Hughie Thomas case and the
Seema Misra case, and the approach of the Post Office in
particular in the Seema Misra case, not suggest to you
that you ought to proceed with extreme caution in
producing such generic statements?
I didn't realise at the time that anything was actually
improper or going wrong with what was happening. I did
get -- certainly in some of the cases -- with the
generic statement, I did actually seek guidance from
169
another ‘expert report’ and this time I want to actually
read your logs properly!"
You're writing here to Mr Dunks and Penny Thomas,
yes?
Yes.
Well-known colleagues?
Yes.
You're purposely using the term "expert report" by
putting it in inverted commas, aren't you?
Yes.
Was that what had been requested of you?
I can't remember exactly what had been requested of me
at that time.
But you're putting it in inverted to commas, like it's
aterm of art, yes?
I can't remember -- I tend to be fairly liberal with
inverted commas and capital letters, and things like
that, in my emails.
Isn't this is an indication that you realised that what
you were being asked to do was not simply give evidence
because you had expertise in an area, namely the Horizon
system, but you were being asked to provide an expert
report just like the ones we've read?
No, I don't think so. I think it was more to do with
the fact that it was a report as an expert on Horizon.
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Fujitsu lawyers as well as Post Office lawyers as to
whether this was the right thing to do and whether
I should carry on making those sort of statements, and
they seemed to be supporting what I was doing.
Or was it the seeming success of the approach in the
Misra case created a false sense of confidence for you
and for the Post Office; it resulted in a conviction,
after all?
I don't know that I considered it that way. Again, the
generic statement was about two years later, so I was
probably looking at that in isolation rather than
looking back as to what had happened before.
Can we just look back, please, to your attitude to
witness evidence in a different case by looking at
FUJ00083741. If we just scroll down, please. Can you
see that the email from Mr Dunks to you and Penny Thomas
of 28 October 2010 concerns Porters Avenue, which
I think is Mr Hosi's branch, yes?
Yes, I believe so.
“It looks as if everything has been sent at one time or
other. I can send all if wanted", et cetera.
Then I just want to see your reply. If we scroll
up, you say:
"Andy,
"Can you let me have them all. I've got to do
170
Someone who actually understood the Horizon system well.
Your evidence is that, although you say here that you've
got to do another "expert report", in inverted commas,
you didn't understand what that meant, ie the provision
of an expert report, or that it came with specific
duties?
That's correct.
By this time, you'd produced statements for use in
Hughie Thomas' case and earlier in the year in Seema
Misra's case?
Correct.
You say here:
"... this time I want to actually read your logs
properly!"
Have you not considered the logs properly in those
other cases?
I don't know that I -- I certainly had not read in --
been shown any logs to do with Mr Thomas’ case. I was
aware in Mrs Misra's case that there were some logs,
which I thought had been handled by Andy Dunks and, when
I listened to his evidence in court, I realised that
there was some things that he was saying that maybe
I should have looked into and I actually did some
investigation that evening as to what I had heard about
the logs and I realised that, actually, maybe in future,
172
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I should have actually taken more notice of what the
Helpdesk calls were involved, hence this comment here.
Q._ [twas a flippant comment, wasn't it?
A. I don't know that it was a flippant comment; it was more
a case of saying I'd learnt from the fact that I'd been
taken by surprise by some of the things that Andy was.
saying in Mrs Misra's case as to what he'd actually
found in the Helpdesk calls that I'd not been aware of
and realised that maybe I should have taken more notice
of those and, therefore, moving forward, I wanted to
learn from that.
MR BEER: Thank you.
Sir, can we break until 3.15, the afternoon break.
Thank you very much, sir.
(3.01 pm)
(A short break)
(3.15 pm)
MR BEER: Good afternoon, sir, can you continue to see and
hear us?
SIR WYN WILLIAMS: Yes, thank you.
MR BEER: Thank you.
Mr Jenkins, you've told us today that you were never
provided with written instructions as to the duties and
responsibilities of an expert witness in the cases in
which you were instructed —
173
I believe that Mr Tatford sent that information to one
of the Post Office Investigators, who then asked me
a slightly different question, rather than the full
question that Mr Tatford had intended for me to be
asked.
Q. That's certainly the case because we can see that on the
documents. We'll explore those tomorrow as we've
explored with other witnesses.
A. Yes, but I've no recollection of being asked to talk
about other bugs or that I would have considered
irrelevant anyway, by Mr Tatford or anyone else.
Q. I want to get your evidence clear on this: he says that
he made this clear, ie that any other problems or any
other bugs should be disclosed to you, and that he made
it very clear to you that you were under a duty to
provide frank disclosure of Horizon problems to the
defence expert. Are you saying that he is incorrect?
A. I'm saying that I had not understood that from him.
Q. Did you have a conversation with him about the extent to
which you needed to provide disclosure of Horizon
problems to the defence expert?
A. I've no recollection of such a discussion.
Q. By that, do you mean that it did not occur or that it
may have occurred but, because of the passage of time,
you no longer remember it?
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Correct.
- and that you've no recollection of anyone explaining
to you that you were subject to certain duties as
an expert or being given oral instructions as to what
those duties were?
Correct.
Have you read the witness statement of Warwick Tatford,
the prosecution barrister in the Seema Misra case?
have.
Did you listen to or watch his evidence or read the
transcript --
I was actually here for that particular event.
-- for that day. Can we look at his witness statement
to start with, please, WITN09610100, and page 5, please.
Second line down:
“At the time of the Misra case I ensured that the
Callendar Square bug was disclosed and made it very
clear to those instructing me that enquiries should be
made with Fujitsu about any other problems and any other
bugs should be disclosed. I made this clear also to
Gareth Jenkins, the expert instructed by the Crown, and
I made it very clear to Mr Jenkins that he was under
a duty to provide frank disclosure of Horizon problems
to the defence expert instructed in that case."
I don't believe we had that sort of conversation. Also,
174
I don't believe it would have occurred because, if it
had, I would have done something about it.
You appreciate there's a bit of reverse engineering
going on there --
Yes, I understand that, yes, but, as I say, I have no
recollection of it and, if I'd been told I needed to
disclose other problems in Horizon, then I would have
made efforts to find out about other problems in
Horizon, even though I thought that they would have been
irrelevant.
Hold on. A moment ago you said, "I wouldn't have told
the defence expert about problems in Horizon" because
you wouldn't have believed that they were relevant to
Seema Misra's case?
Well, that's right. So, therefore, if I'd been told
explicitly I should have done, then I would have done
something about it, but that's why I'm saying that would
not -- I don't believe that I was told that I needed to
do that.
So his evidence here is in error, is it?
I can't say categorically that -- I -- that is not my
understanding of what occurred at the time and I think
I would have behaved differently if I had been briefed
in the way that he suggests that he briefed me.
What do you remember about a conversation with
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Mr Tatford about the extent of your disclosure duties to
the defence expert?
I don't remember having any conversation along those
lines.
Can we turn to INQ00001094, and turn to page 17, please.
If we look at internal page 68, which is bottom right,
line three onwards. This is Mr Tatford giving evidence:
"You say in your statement -- I'm not going to turn
it up -- you took great pains in all your conversations
with Mr Jenkins to make sure he understood the duties of
an expert witness?
“Answer: Yes.
"Question: You explained it was his overriding to
assist the [that should be ‘court'] --
“Answer: Yes.
"Question: -- to give an opinion that was objective
and unbiased, and that that duty overrode any obligation
that he might feel to the party calling him: the Post
Office. You explained that it was his duty to disclose
anything that might undermine his position and that he
should be entirely open with both the Post Office, as
prosecutor, and Professor McLachlan, about any Horizon
problems?
“Answer: Oh, yes, because the -- I had asked
previously in my advice for Fujitsu to be contacted and
177
report?
"Answer: Because most of -- until the last
statement, all of those were responses to Professor
McLachlan. It is important to bear in mind that there
had been an abuse of process", et cetera.
Did Mr Tatford make clear to you the duties that he
spoke about?
I don't believe he did.
If we just go back to them, the previous page, bottom
right a duty "to give an opinion that was objective and
unbiased"; did he tell you that he have a duty to do
that?
I don't believe so.
Did he tell you that that duty overrode any obligation
that you might feel to the party calling you, the Post
Office?
I don't believe so.
Did he explain to you that it was your duty to disclose
anything that might undermine your position?
No, I don't believe so.
Did he explain to you that you should be entirely open
with the Post Office and the defence expert about any
Horizon problems?
I don't believe so.
That can come down. Thank you.
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to inform us of any problems and I saw Mr Jenkins as
an obvious route to doing that. That's how I saw
things. And it seemed to me particularly from the
feedback I was getting from the defence, that this
approach was working.
"Question: ... you've referred to ‘the defence’ ...
"Are you saying that [was a conversation] with
a colleague in chambers --
“Answer: No...
"It was perfectly clear to me that he found it
helpful to work with Mr Jenkins. It received to fit his
way of doing things because his way of approaching
things was to suggest hypotheses which needed somebody
to help him with. They needed to sit down together and
it's absolutely clear that they did that, from the
evidence they gave at the trial.
“Question: Before we get into the detail of the
communications between you, the Post Office and Fujitsu
and Mr Jenkins, if you were mindful of these expert
duties and the need to make them crystal clear in
somebody who did not enjoy functional independence from
the party that was calling them, and you explained them
to Mr Jenkins, how is it that every witness statement
which the Post Office sought to rely on from Mr Jenkins
omitted any of the necessary inclusions for an expert
178
Had you been made aware of your role, your formal
role, as a prosecution expert witness in the legal
sense, in respect of each of the Post Office's criminal
prosecutions and the legal duties that that role
entailed, how would you have sought to have done things
differently?
Well, I think it would have required an awful lot more
effort than was actually put into the various cases.
The best example I can think of is that there was
a whole team of us that did quite a lot of analysis of
previous bugs as part of the GLO proceedings in 2018,
and it required something of a similar degree of effort
to do that, if it had been understood that that was
required at the time.
Did that occur to you at the time, that, "We're putting
all this effort and money into defending the Post Office
in a civil claim for damages, we didn't do this when we
were prosecuting dozens of subpostmasters"?
No, that didn't occur to me at that time, no.
Quite striking, isn't it?
Looking back at it now, I can understand that but, as
I say, that was not something that occurred to me. As
I say, in all cases we were, or I was, responding to
specific requests to do specific bits of work and I was
being asked to do a lot more work in 2018 than I had
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been in previous cases.
In your witness statement, it's your third witness
statement, at paragraph 17, no need to turn it up, you
say you approached the various criminal cases where you
provided evidence in the same way as you approached
a problem in the day-to-day course of your work?
Yes.
That's something you've said in summary today as well -
Yes.
-- and that you focused on the question of what the data
in a given case might show about the specific branch?
Yes.
Rather than any other wider problems with Horizon?
Yes.
You also say that you didn't understand that other
issues within the Horizon system, including issues that
had affected other branches, might be regarded as
important by a court?
Correct.
You say that's all in the context that it is inevitable
that a system like Horizon would have bugs, errors and
defects in it?
Correct.
Are you saying that in determining what had caused
a particular issue at a branch, you would only consider
181
occurring, but some of which might only be discovered
long after the relevant event?
I felt that they would be visible at the time if you
looked at the events associated with the thing in the
branch. I think I later found out that there were some
cases where it wasn't that obvious until later but,
certainly, if you look at where I was coming from in
2010, then my experience was that, by looking at the
events and the message logs from the branch at the time,
then you would be able to detect if there'd been
a problem.
But I think, more generally, you knew that Horizon had
bugs within it, some of which you would know about but
some of which may only be discovered a while after they
had had an operative effect?
I'm not sure that that was the way I was looking at
things back in 2010.
Do you look at things differently now, then?
I am aware that there were a couple of bugs with Horizon
Online that did not manifest themselves immediately at
the time that they occurred but I'd not had that
experience of similar sort of occurrences on Legacy
Horizon.
So you thought your job was to provide an explanation as.
to whether something had gone wrong in a particular
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the data that you had been specifically provided with?
Including the information we were given about what was
happening at the time but, yes, that was basically what
we'd look at.
Would that data have been provided to you by the post
office or by Fujitsu?
Fujitsu.
If you'd been conducting a fourth-level review,
a service support review, which is how you described you
were approaching this task, would you have looked only
at data from within the branch?
Yes.
Not at any wider issues that had been identified
elsewhere in other branches, for example on that day or
in that week?
No, because each branch was effectively operating
independently. I mean, if it was a competence issue --
if there was some sort of central fault, say, for
example, the interfaces of the banks had gone down or
something like that then, obviously, that would affect
many branches but a particular -- most -- most issues
really affected a specific branch at a specific time,
and that was my -- where I was coming from.
I think at all times you knew that Horizon had bugs,
some of which would disclose themselves as they were
182
branch, by looking narrowly at the data relating to that
branch?
Yes.
If you concluded that the underlying cause of an issue
was a bug in Horizon, would you have had any hesitation
in saying so?
No.
If you believed that you didn't have sufficient
information to arrive at a view, you needed additional
information, would you have had any hesitation in saying
so?
I -- all I said was I could find no -- what I was
basically saying was I could see no sign of any
problems. So I never said that there weren't any
problems. AllI was saying was that I had not seen any
sign of any problems so, in effect, I was saying that
was the view that I was giving.
That's not really an answer to the question, if you
believed that you didn't have sufficient information to
arrive at a view, and that you needed more information
in order to do so, would you have had any hesitation in
saying so?
If I -- I'm not very good at hypotheticals, so it's
a case -- I felt that I had enough information to say
that there wasn't -- that I had been unable to see
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a problem.
So, in every case in which you gave a witness statement
or evidence, you thought that you had full and complete
information, upon which to say there were no problems
with Horizon?
I wouldn't go that far. I made it clear in some of the
cases with the generic witness statement that that was
just at a generic level and I was expecting to be asked
to look at specifics and, as it turned out, I wasn't
asked to look at specifics so I was giving a general
level statement of the general behaviour of Horizon, not
the specific case of exactly what had happened in that
branch. I was expecting to be asked to look at specific
data, because my understanding was that in order to
prosecute someone, then it was necessary to provide the
data.
If it was your view that there was more than one
explanation or possible explanation for an issue, and
one of those issues involved there being a bug, error or
defect, would you have had any hesitation in saying so?
I don't think so.
Did you understand that it was part of your duty to say
that "There were a range of possibilities here, and my
assessment is this is the most likely, this is the least
likely", for example?
185
wouldn't have been anyone doing anything at the branch
at the time and, therefore, I saw the thing as being
benign.
Can we look, please, at FUJ00083596, and start with
page 2, please. If we scroll down, it's an email from
you to Brian Orzel. Can you remind us of who he was?
Brian Orzel was part of the EPOSS Development Team and
he was the main interface between the EPOSS Team and
Escher in terms of how the EPOSS counter software
operated.
You say:
"Brian,
"You've obviously cracked the technology to enable
a list of PinICLs to be extracted to a file. How is it
done? Alternatively, can you generate a list of the
current Escher Development PinICLs into a file for me
please. We need to go through an exercise of checking
all outstanding PinICLs (at least the Bs and Cs) ..."
Is that a categorisation of their severity?
Yes.
"... $0 as to factor them into [I don't know what this
is] M1R/S10 drops .
What were they?
They were -- I can't remember exactly what they were but
I mean we're talking about 2000/2001 sort of timescale,
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I didn't understand that, no.
Thank you. Can we turn, then, to a separate topic:
bugs, errors or defects. Can we start with some general
questions, please. We've heard some evidence about
bugs, errors or defects that Fujitsu believed could be
lived with, ie did not believe disrupted the system to
a material extent, and we've heard some evidence that
bugs were not investigated for their root cause.,
including where bugs were caused by Riposte and were
believed to be the possibility of Escher. Were you
aware of that?
I was aware that things had not been always thoroughly
investigated but I did not believe that such things had
actually caused a direct impact on the branch accounts
at the time.
What investigations did you carry out to satisfy
yourself that they, the bug did not have an impact on
branch accounts?
I -- there were a number of cases in the early 2000s
where there were unexpected events occurring and, in
those cases, I looked at what was actually happening.
I mean, some of them were to do with the correspondence
servers, others were to do with the branches and, in the
cases I looked at, I couldn't see that there was -- they
were mainly happening out of hours and, therefore, there
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in terms of when they were. There was a whole load of S
releases that started with S10 and worked up to S60 and
$80, which we've talked about before in terms of IMPACT,
and so on.
So they are updates, effectively?
So they're updates, yes.
"My belief is that many of them can be ‘lived with’ in
which case they need to be downgraded to D (or at the
highest C)", et cetera.
If you knew that there were Riposte issues that
could only be explored fully by reproduction or by
investigation by Escher, which you tell us about in your
witness statement, how could you be confident that
PinICLs of this kind could be lived with?
By looking at the effects that they had at the time, and
looking at the details of the individual PinICLs.
What do you mean by "looking at the effects"?
Looking at what the description of what had actually
happened at the time, whatever was in the detail of the
individual PinICLs.
Didn't that need, in order to be done to a satisfactory
state, reproduction of the fault or investigation by
Escher itself?
Not necessarily. It was a case of looking to see
exactly what the problem was and what was behind it to
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see whether it was something that -- what the impact of
the problem was.
Can we go to page 1, please. He replies:
"As to the PinICLs themselves, I think it makes good
sense to postpone them from last minute fix releases,
but given the amount of money we pay for support, when
we have a full regression cycle like (presumably) $10,
I would want them ALL fixed, including the D priorities.
No exceptions. Chris ...”
I think that's Chris Wannell?
Correct.
"... has the final say."
So he appears to disagree with you and says he wants
them all fixed but says the final call is for Chris
Wannell?
Yes.
What would Chris Wannell say?
He was the manager who had the managerial interface with
Escher and did the negotiations with Escher. I'm not
sure what his exact role was.
Are you able to recall what happened with these bugs, in
particular, did Fujitsu live with them as you suggest or
were fixes found by Escher that applied?
I think some were lived with and some were fixed but
I can't remember which ones.
189
Escher?
Not in all cases, I don't think. In some cases, yes it
would need to be done but, in others, then it would be
fairly clear from the description of it as to whether
this was -- what the harm was that it was causing.
But it was the case that Mr Orzel's suggestion that they
all be fixed was not carried into effect?
I suspect not but I can't actually remember all the
details.
Thank you. Can we move on to 2005, please.
FUJ00086315. Thank you. We're in August 2005, an email
to you from Martin McConnell; can you recall who Martin
McConnell was?
He was one of the developers in the first Development
Team --
I'm so sorry. It's from Mark Scardifield copied to
Martin McConnell to you.
Mark was the -- was the Development Manager in charge of
the EPOSS team at that time and Martin McConnell was one
of his developers.
It's about a PEAK PC0121925 and release S80, shared SU
Cash declaration after -- what does the rest of it mean,
after "mig [greater than] TP"?
I can't remember exactly what that meant but, with the
introduction of IMPACT, one of the changes was to
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Were there simply some bugs, then, even where the root
cause were unknown that Fujitsu and you were willing to
live with?
It depended on exactly what the impact of it was, and
that would have been done by a bug-by-bug evaluation,
and this starts like the start of a process where
an investigation was done into the individual PEAKs and
PinICLs to see exactly what the issue was, and I seem to
remember there was a later email which identified at
least one, that was an enhancement request, so it wasn't
exactly a bug, as such, it was just something that it
would be nice if the Riposte software did something
differently.
So what was the outcome here?
That some things got fixed and some didn't but I can't
remember the details of the individual cases.
The ones that didn't get fixed, was that without
an investigation of the root cause?
There would have been an investigation as to what the
systems were and whether that was something that was
likely to cause harmful effects in the system but
exactly the details of such investigations, clearly
I don't remember that at this stage.
In order to say that there were no harmful effects,
didn't that require the bug to be reproducible by
190
actually migrate from branches producing a cash account
each week to producing a trading period every month. So
it was -- so the software had to be able to support both
working in the old way against the cash account and
then, when some reference data was changed for a branch,
it then started working and producing monthly trading
periods.
So this is about, again, after S80 migration; is that
right?
It's -- this was during the testing of the S80 software
so, in other words, before it had gone live, and it was
saying that the software on that particular test rig was
configured that it was working in the branch trading
mode, as opposed to the cash account mode, is how
I would --
Mr Scardifield says in summary:
"Martin can see evidence of two different types of
failure. Firstly a failure of Message Port to alert
counter code when a new transaction has been inserted
into message store. And secondly a Riposte query
failing. My suspicion is that something (and I think we
have now eliminated archiving because there is no trace
in the Event Log) is hogging CPU time and the Riposte
errors are a secondary effect. There is some evidence
for this because at about the time of the second
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failure, BUSY.EXE has logged an event, which it does
when there is a sudden change in system resources ...
"Needless to say this problem(s) cannot be
reproduced at will.
"we have run out of ideas on this one so any
thoughts appreciated.”
Is this is an instance of a Riposte problem arising
which wasn't reproducible and which Fujitsu didn't
understand?
This was a system issue, and I believe we decided in the
end that there was some configuration had been set up
incorrectly on that particular test rig, which was
the -- the underlying cause of the problem. We were
unable to reproduce it. We did change some
configuration parameters, so as to make the -- if it
were to reoccur, to make the effects -- make it much
less likely to happen but I don't think we ever found
any evidence of that actually occurring in a live
system.
In relation to a separate issue, you tell us in your
witness statement, your second witness statement, that
the impact of the Riposte lock had been much wider than
you had previously realised, and it was only by doing
work in 2018/2019, that you realised the full scope of
the Riposte lock issue, and that you became aware it
193
Right. The data tree, it --
You're starting far too high up. I'm starting much
lower down in my level of understanding. So a node
contains data --
Yes. Okay, yes.
-- and a data tree is a structure of nodes?
Yes.
It's a hierarchical structure of connected nodes?
Correct.
There is a root node, which has child nodes to it --
Correct.
-- and each of which children can have further children?
Correct.
Each node can be connected to one or more child nodes?
Correct.
The root node has no parent?
Correct.
Aside from the root node, each node can only have one
parent node?
Correct.
Legacy Horizon created summary accounts by building data
trees and harvesting the information?
I'm not sure I'd have used the term "harvesting" in that
case but I think that's a reasonable word to use.
In Legacy Horizon, transaction data was stored as
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wasn't just the Callendar Square branch that had
suffered from discrepancies, but other branches where
there were counter occurrences of the timeout waiting
for the lock problem. Okay? I'm reading directly from
your witness statement.
Yeah, yeah.
Okay. Would you accept that there may have been impact
arising from problems which weren't investigated at the
time but which may have been discovered with further
contemporary investigation and support?
I think a lot of effort was put into investigating this
particular problem and it was not possible to reproduce
the issue, and we did make some configuration changes to
the way in which the software worked to protect against
the fact that -- that the system performance could cause
issues.
Can I turn; that can come down, thank you -- to the
first bug that I want to look at, data tree build
failure.
Okay.
Can we start with some building blocks, this is for more
my benefit than anyone's: in summary, a node is a unit
of data structure that contains data?
Um...
That's not a very good start!
194
a message or messages in Riposte?
Correct.
When Legacy Horizon generated reports or prepared
accounts, it would scan the message store for relevant
transactions.
Correct.
The relevant messages identified by Horizon would be
stored in one of the nodes of the data tree?
One or more of the nodes of the data tree. There
would -- there would be number of different relevant
nodes it would be stored under.
So the data tree in these circumstances was used to
populate and to organise the data for Horizon to produce
accounting reports?
Correct.
You say in your second witness statement -- it's
paragraph 36, no need to turn it up -- that Legacy
Horizon would reuse the data tree once it had been built
with new messages being added; is that right?
Correct.
Therefore, an example, would you agree, of a data tree
build failure is where Legacy Horizon missed a node such
as a node containing payments in, resulting in the
accounts being inaccurate?
There were different sort of errors at different times
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and, as time went on, more protection was put in to
check against things like that. So I think --
That would be an example, sorry, to --
That was an example back in around 2000, and I think
checks and balances were then put in place to detect
such problems, should they occur in the future.
Now, the Inquiry is aware that Fujitsu came to know
about data tree build failures and that they could lead
to discrepancies very early on in the life of Legacy
Horizon. I think you know that there were such data
tree build failures identified in KELs in 1999 and 2000?
I'm aware of that now. I think I only became aware of
that when I looked at the stuff in 2018.
Can we look, please, at FUJ00056677 -- sorry, before we
get to that, I should just explore that last answer.
How is it that you only became aware of the KELs and the
PinICLs of 1999 and 2000 when you came to look at it
nearly two decades later?
Because I hadn't been involved in EPOSS at that time, as
we discussed this morning. So those were issues when
I was -- didn't have any responsibility or connection
with EPOSS in around the year 2000 or so. However, as
part of the GLO, then I was asked to look at some of the
PEAKs from that area and, in general, I relied on the
information that the SSC came up with at that time. But
197
addressed but [Post Office] are concerned that the cause
is still unknown and this will affect this and other
outlets."
If we go over the page, please, five lines in:
"Steve Warwick believes that this may be an isolated
incident
Then about five lines further on:
“I will monitor progress of the incident which is
now with the EPOSS Development teams for investigation.
Five lines on:
"I have talked with development [referenced] this
problem. It is seen as a one-off. No fault can be
found ..."
Then over the page, three lines in:
"no further occurrences have been reported from
Dungannon or similar ..."
Then nothing on that page.
Next page, please: nothing on that page. Next page,
please, the middle of the page:
"The problem is currently back with Development for
further investigation.”
Development, who would that refer to?
That would be the EPOSS Development team, so I think
Steve Warwick's name was mentioned earlier and he was
the main designer and would almost certainly have been
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I-- as a side effect of that, I became aware that there
had been those problems back in about the year 2000 that
I was not aware of until that time.
When you became involved in data tree build failure
issues in between those times, ie '99/2000 versus
2018/2019, did you not access PinICLs and KELs --
Yes.
-- that we're going to look at?
Yes, I could have looked at the things at the time, it's
just I had no reason to, which is why I wasn't aware of
the problems until 2018, or so.
This is a PinICL PC0033128, raised, I think, on
10 November 1999 -- can we see that --
Yes.
-- the date that it's opened, relating to losses, we can
see on the left-hand side, at branches in Dungannon; can
you see that?
I can see that, yes.
I think, if you read the body of the PinICL:
"Outlet has a discrepancy [about six or seven lines
in] of £43,000 after balancing [stock units] and doing
office snapshot.
"... Steve Warwick development is investigating why
this misbalance occurred.
"Immediate impact of this weeks balance has been
198
the person who would have been looking after this
particular incident.
Then over the page. Just over halfway down:
"The similar occurrence is currently an incident
I am investigating if the similarities are such that we
can add this into the problem."
Then over the page -- sorry, I should have read the
bottom of that last page:
"Discussed this issue at XDMF ..."
Is that some sort of conference?
I've no idea. I don't recognise that term. I'm
guessing the "ME" stands for management forum but I'm
just speculating.
Something like that?
Yeah.
It's thought that a similar incident has, over the page,
occurred at Yate Sodbury. So that's a different FAD
code given there, so a different branch, to the value of
£52,000, "the problem will remain open".
Then four lines on:
"A further occurrence has arisen at Appleby in
Westmoreland at [just under £10,000].
"Chased call with Development and spoke with Martin
McConnell. [He] has made extensive investigations on
the issue [and is] unable to recreate the fault.
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"Escalated to Chris Wannell (Development) who will
discuss options with Martin and Steve."
At the foot of the page:
a diagnostic fix was being prepared and was to
be submitted to the next Release Management Forum to
authorise release into the live estate."
Then, if we carried on reading -- I'm not going to
carry on reading ~- it's reported that a fix was applied
in 2000 by C14.
Yes, I believe so.
In your statement, you say that the effects of locking
errors were more widespread when you were considering
the Callendar Square bug, yes?
Yes, but I'm not sure that was necessarily a locking
error that was the root cause for that.
You say, in your statement, that that reflects the
nature of fourth line support, where not every PinICL on
the same or a similar issue was referred back to the
person who may have dealt with the same or similar
issues previously?
Correct.
Was that a function of the way that third line support
was arranged?
Yes, but, I mean, I suspect what you're saying is this
particular PinICL refers to other occurrences and
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supposedly fixed as a result of the investigations that
we've just read on that PinICL?
That was my understanding, yes.
Secondly, issue 2, or 2.1, arose as a result of testing
and didn't affect the live estate?
And I think that reflects the email you took me to of
a few minutes ago, yes.
Then, thirdly, issue 2.2 describes a single incident
involving what is said by Fujitsu to be a transient
discrepancy that was itself fixed in 2006?
I believe that was a separate problem introduced by some
new software later on. I think in my witness statement
I described those as three different issues, and I was
disagreeing slightly with the way that the Fujitsu
corporate statement was laying that issue out.
Let's look at your witness statement, it's the second
witness statement, the one ending in "0200" at page 11,
please. Page 11, paragraph 35, you say:
“All three categories of this problem [that's the
data tree build failure] concern the data server
component in Riposte but I believe each problem was
completely different from the other. The first category
seems to have occurred in 1999-2000. I do not believe
I was aware of this first category at the time."
Now, I have looked at the PinICLs for that first
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I think the reason for that was it was felt they could
provide additional information to help diagnose the
problem.
When slow running issues became noticed in 2006, was any
connection made between this series of issues that we've
just looked at in this PinICL and those slow running
issues?
No, because I believe that the issues that were found
back in 2000 had been resolved and sorted out at that
time and the issues that were occurring in 2006 was
a different problem, it was to do with the fact that,
when we moved from a weekly cash account, then, for
a week's worth of transactions you've got a certain
amount of data. When you move to a monthly branch
trading period, then you've got four or five times as
much transactions, and that's why performance again
became an issue in 2005, because of the fact that there
was just so much more data being processed in terms of
producing the data tree, as it then -- as it was then
operating.
So Fujitsu's corporate statement to this Inquiry splits
the data build tree failures into three issues. Can
I see whether what you're saying essentially mirrors
that, that the classification is as follows:
Firstly, issue 1 happened in 1999 and 2000 and was
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category -- just for the transcript reference, I believe
they are FUJ00062016, FUJ00066601 and FUJ00086553 , and
I can't see your name on any of them and, therefore,
1am not going to ask you questions about them, okay?
Thank you because I wouldn't know much about them.
"The second category [you continue] occurred in
2005-2006. I believe that I was aware of this second
category at the time."
So let's look at that, the second category of data
tree build failure, by looking at PEAK PC0121925, which
is POLO0028867. Look at the top of the page, you'll see
it should be raised on 13 June. Yes, if you just look
under “Progress Narrative"?
Yeah.
Date raised, call open 13 June 2005. If we scroll down
a little bit:
[Post Office] have raised the following incident:
"A cash declaration was made in “stock balancing"
for the amount displayed on the snapshot. When the cash
variance was checked afterwards a gain of [£45-odd] was
displayed’."
Can I clarify there, please, that when we're talking
about Post Office has raised that, if you look slightly
above it talks about "E2E". So E2E was end-to-end
testing, so this was a test rig and this was a Post
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Office testers on a test rig have identified this
problem. This wasn't a problem from a live branch.
Got it. So is this Post Office staff embedded in the
test rig?
Correct.
Okay.
So it was one of the stages of testing that was done,
was the Post Office staff would do their own independent
testing of new software before it went live. So this is
June 2005. So IMPACT S80 didn't actually go into live
estate until about August/September time.
If we carry on reading, over the page, please, I think
we see, if we scroll on to 4 July, stop there -- thank
you -- 4 July, middle paragraph of Martin McConnell's
third entry. If that can be highlighted, it's
two-thirds of the way down the page:
“After spending more than a week on this I don't
know there is anything more that can be done because:
"4. The code is dependent on Escher's Notify
mechanism, which MAY itself beholdant [sic] of perhaps
some NT or other system failure.
"2. We cannot reproduce this at will with any
defined or prescribed pattern.
"3. We can recommend a course of action to allow
a clerk to get a fresh rebuild of the tree if he/she
205
I think we changed the configuration parameters to
increase the buffering, so that if the counter
application was a bit slow in processing the messages
that were being picked up, then there was a larger
buffer of messages that could be buffered up to allow
things to catch up. I'm probably not explaining that
very well.
No, I think that's sufficient. More importantly, were
you able to tell if the problems that had been
identified in this test environment ever emerged and
affected the live estate?
I don't believe we ever saw any sign of a problem like
this on the live estate and I think we did find some
problems with the way that that particular test rig had
been set up at the time.
Can we turn to your second witness statement at page 15,
please. You say on page 15, at the foot of the page, at
paragraph 51:
I do not know whether the problems identified
in the test environment ever emerged and affected live
data in actual branches, or whether the fix rolled out
for the second PEAK proved to be effective. In the
absence of further documents, I cannot say whether these
problems had an actual impact on branch accounts."
Was that the case at the time?
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finds anything odd, simply by logging off and on again
the dataserver tree will automatically refresh."
So what role did Martin McConnell perform?
He was one of the developers and, in fact, he was the
expert on the data tree build. You probably recognise
his name from 2000.
So he is saying that he's not sure anything more can be
done and, in any event, a solution is to turn the
machine off and on again?
Yes, but I think we did actually do more than just that.
If we go forward to page 3, please. If we scroll down,
please, and look at his entry at the foot of the page,
I'm not going to read all of the technical explanation
to start with but, just at the end of that paragraph,
he's referring to a second occurrence of the fault and
he is saying:
"... this second occurrence is a different category
and perhaps MORE disturbing. I am not able to tell
whether:
"1, Asilent feature has occurred within Riposte.
"2. The failure has occurred within Riposte and
notified to us.
"3. Riposte is behaving okay but EPOSS has failed
within the loop.”
So what was done?
206
Yes, as I say, as part of the investigation into the
problem that we were looking at before, the testers
found another reproducible occurrence of the thing and
we found a genuine bug in the code that was then fixed,
I think it was in August from memory, and that fix went
in place where we found that the notification mechanism
had been accidentally switched off in the code and that
problem did get fixed, and there was some further
documentation about that.
You say:
"Reflecting on the PEAKs now, and with the benefit
of hindsight, I believe there were probably other
processes on the test rig counter that slowed down
Riposte and made it very unpredictable."
You say:
"As [you] mentioned in [the] Test Report, it is
possible that these processes were caused by the testing
environment and would not have occurred in actual
branches."
That was my view, yes, at the time as well.
Was that hypothesis tested in the live environment?
I'm not aware of seen any such issues happening the live
environment.
That's an answer to a different question.
Okay.
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Was what had been observed in the test environment
tested in the live estate?
I'm not quite sure how you could test that in the live
estate, so --
Actively looked for?
It would -- the simple answer is I don't know.
Would failures in the data tree build cause Legacy to
produce inaccurate accounting reports?
It could do in the short-term. However, if the -- if it
missed a transaction one time, then it -- there should
be a corresponding failure the other way the next time
the —- a report was produced.
Should be or would be?
Certainly should be. I'm not -- I can't guarantee that
it would be.
Would the failure to build the data tree have an effect
on the accuracy of ARQ data?
No.
Why not?
Because the ARQ data was a record of the transactions as
recorded in the message store, not how they were built
up into a report.
Thank you. Can we turn to the third issue or 2.2, as
Fujitsu call it in their statement.
Yeah.
209
declaration done on counter 2 ... the [postmaster]
declared [£1,200-odd] and the system declared
a [negative] value of [£1,400-odd]. Moments later the
[postmaster] logs on to counter 1 and declared
[£1,200-odd] cash once again. This time the system
calculated a [negative] of [£93-odd], which is roughly
what the postmaster expected, even though no
transactions had been done between these two
declarations."
Then skipping over a paragraph:
"It would appear that when working out the cash
[declarations] on counter 2 the system has used an old
‘data tree’ (the one it used at the earlier trial
balance) rather than creating a new one, so the
discrepancies were wrongly calculated. It wasn't until
the [postmaster] later moved to counter 1 that a new
‘data tree’ was produced and the discrepancies were
calculated correctly."
Can we summarise subsequently, rather than reading
it all, is it right that a fix was developed and
released later in 2006?
Correct, and I can't remember the exact -- why this
problem introduced, but I believe that the data tree was
actually being used for a new purpose as part of
a change that was made at around that time and, as
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That can come down from the screen. Thank you.
I think that this is demonstrated through a PEAK.
If we can look at FUJ00086456. Thank you. This should
be PEAK PC0132133. Itis. You can see that it's
raised, by looking in the narrative, on 10 February
2006.
Yes.
If we see the summary:
[Postmaster] states that she had a discrepancy that
seemed to become greater over the course of 20 minutes.
Then a few minutes later the discrepancy vanished and
normal figures remained normal.
[She] noticed this on daily cash report previews.
"... Referred by NBSC.
"Discrepancy was at its highest £1,000 shortage.
But [postmaster] insists within minutes the cash balance
preview stated that the balance was fine and the
discrepancy was gone."
If we go forwards, please, over the page. Thank
you. Just stop there and scroll down to David Seddon's
entry at the foot of the page. He says he can see that:
"on 4 February the [postmaster] made numerous
cash declarations [on a stock unit], the [postmaster]
was declaring all sorts of figures and getting different
[variations]. What does stick out though is the cash
210
a result of this problem, then a different mechanism was
used, rather than reusing, effectively, a copy of the
data tree. And I think that gets referred to later in
this PEAK.
So the whole bit of software that was actually
calculating these cash levels was changed to not use the
data tree any more, because of the problems that was
identified in this PEAK.
Thank you. Can we look at an email concerning this
problem, FUJ00086462. This is an email exchange
involving Anne Chambers, you, Graham Welsh and John
Burton. What did Graham Welsh do?
Graham Welsh was in Customer Services. I can't remember
his exact role but he was one of the people that used to
liaise with Post Office, and he was a fairly senior
manager at the time.
John Burton?
He was a Programme Manager and, at that time, he was
probably my direct line manager.
This exchange details problems in the scanning and
building of the data tree during balance?
I think this is relating not to the problem we've just
looked at and this isn't looking at a bug as such; it
was more to do with the fact that, because branches had
moved to the branch trading statement and therefore were
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building up four or five weeks' worth of transactions,
it was taking an awfully long time to actually produce
reports.
So it was -- in huge branches, it was taking up to
an hour to do that and what Anne is reporting the fact
that she was getting complaints from postmasters as to
how long it was taking.
Now, we had always made it clear to Post Office that
‘one of the consequences of moving from a weekly cash
account to a monthly branch trading statement meant that
it was would take longer to balance, if you only
balanced once a month. So it was something that we'd
anticipated at the time and, as a result of this,
I think I did do some further investigations to see was
there anything we could do to improve the performance.
And I think that's what this email exchange is to do
with.
I see. Can we look from page 2, then, please, and
scroll down, please, an email from Kimberley Yip to
Graham Welsh and Dave Hulbert, with a heading, "Horizon
System Performance". Second paragraph:
"I have been contacted again by the [Post Office]
Service Line to obtain an update on progress on the
current Horizon system performance issues.
"One particular branch has been escalated to me ...
213
19.10 when the counter end-of-day processes were
running.
“Anne also provided me with some recommendations
which I have passed on to the branch, and I will ask FS.
FS?
I assume Fujitsu Services but I'm not sure.
"... to do a similar exercise to the one above
(ie provide timings) when the next TP rollover is
completed, 14 June, to see if there are any significant
improvements. I have been told about another branch so.
1am hoping to do a similar exercise. In both cases the
rollover times do seem excessive and my worry is that
these are not isolated incidents. So in terms of the
time it is taking branches to complete the balance
process, can [it probably is Fujitsu] provide me with
details on what constitutes an acceptable length of
time, for example if it takes 4 hours then this is
reasonable, or if it's more than 5 hours then it needs
investigating. This will then give me a better
understanding of what I should be passing on to
[Fujitsu] or if I should be passing on the
recommendations to implement."
Then if we scroll up, please.
“Anne, can you please comment ..."
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and the last rollover timings have been sent to me by
Anne Chambers, see below:
“From 17.00 the branch started printing the daily
reports and this continued until 18.30. They then
declared stamps and cash, and pressed the balance report
at 18.37. The trial balance was not printed until 21.12
(ie over 2.5 hours later). Much of this time the system
was processing the month's transactions. There is a gap
between about 19.30 and 20.05 where it may have been
waiting for input from the [postmaster], but I can't be
certain.
“After the trial balance, the report was abandoned,
presumably because the [postmaster] needed to check and
resolve the discrepancies. At 21.27 cash and stamps
were redeclared (with some variation from the original),
and at 21.28 the balance report button was pressed
again. The second Trial Balance was printed at 22.58
(1.5 hours later) and the Final Balance at 23.04.
"I've looked at what was going on during the balance
report production.
"There was nothing out of the ordinary, apart from
the very large number of transactions being processed
(about 40,000). The number of transactions processed
per second was rather less than we sometimes see but not
significantly so, apart from the period 19.00 until
214
Scroll up, and scroll up again. Anne Chambers'
reply -- you're not copied in yet:
"I've looked at many branches now, and they range
from very slow to horrifically slow when rolling over
stock units. It does vary depending on the particular
process followed at each branch, and if you break it
down into various components each may appear to be
(just) within 4 times as long as the weekly rollover
used to be, but the impact on the [postmasters] is
horrible.
"There have been some piecemeal changes to try to
improve certain areas, but most of these have made
little improvement, and overall, may have been a waste
of effort.
".., there are two main problems:
"1. The balancing process repeatedly scans and
rebuilds the data tree. This was identified as
a problem at least 6 months ago, and improvements to
this are, I think, what Gareth is proposing.
"Counters are inadequate for the applications now
being run on them and do run generally slowly at times.
This hasn't really been fully investigated, and is
really difficult to quantify or prove that is
happening -- the only evidence is what the [postmaster]
reports. It is however adding to customer
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dissatisfaction and could get worse even if we improve
balancing.
"I am not at all happy about fobbing postmasters off
and telling them that the system is working as designed
when it is plainly inadequate for the job. I am also
very unhappy that it has taken six months even to get to
the point of starting to consider whether [Post Office]
will pay for improvements.
"I too would like guidance on when 2nd and 3rd line
support should investigate further. Our current
response has to be 'yes we know balancing is very slow,
it is being investigated’ -- what else can we say?"
Was it the case that subpostmasters were being
fobbed off?
I have to take Anne's word for that. I didn't have
direct contact with postmasters.
And being told that the system was working as designed,
when, in fact, it was inadequate for the job at hand?
We had made it clear, as part of the changes to IMPACT,
that one of the consequences of moving from a one-week
cash account period to a four or five-week branch
trading period was that balancing would take
a significant -- ie four or five times as long, unless
they did intermediate balancing in the weeks in between.
Would you agree with the view that she expresses here
217
Correct.
If we scroll up, please. You're included on this chain.
Mr Burton replies:
"I have reviewed Gareth's [your] feasibility report
and costings this morning ... [Your] report is based on
a great deal of prototyping work that has been done over
the last few months -- of the order of 100 man-days.
The work looked at a number of options, and has homed in
on the one that gave the best improvements ...
"The report should go into [Post Office] next week.
It'll then be up to them if they want to pay us to do
the work. If they decide to go ahead, we're looking at
a likely delivery date of first calendar quarter in
2007. That would give around 2 years of useful life
before being overtaken by [Horizon Online].
"I understand your frustration at having to deal
with irate postmasters and having to tell them that the
system is working to ... spec. We can only hope that
[the Post Office] do agree to funding this work, so that
you have something positive to say."
Was anything done?
I honestly can't remember. Until I saw this email, I'd
forgotten about the fact that I'd even done some further
investigations into it and I don't believe the report
has been made available to me to even know what I was
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that the system was inadequate for the job: plainly
inadequate for the job?
Clearly, it was causing problems for the postmasters but
what we were responding to is what Post Office had
actually asked us to do, and we had warned them that
there would be performance implications if they carried
‘on, made the changes as had been proposed, and suggested
that we could investigate improving the performance but
that would require additional cost to actually do that.
You say in your witness statement that you wouldn't view
this category of problem as a recurrence of the first
category of the data tree build failure that we saw; is
that right?
Correct. This was just things going slowly, not
actually going wrong. They were just going very slowly.
And, clearly, I can understand the postmasters weren't
happy with that but they were actually coming up with
the right answer, but just very slowly.
So where it says in her numbered paragraph 1 "The
balancing process repeatedly scans and rebuilds the data
tree", that's not connected to either the first, second
or third categories of data tree --
No.
-- build failure that we looked at earlier; is that
right?
218
suggesting.
On the third category of the data tree build failure,
when you were -- or indeed anyone else in Development
who was looking at that -- was examining it, would you
look into knowledge repositories within Fujitsu to see
whether there had been similar problems in the past?
Not necessarily. I think we relied on the fact that
people knew what had been looked at in the past.
Was there a system in place at Fujitsu that allowed
technicians to ensure that, when they were looking at
a problem, they could investigate whether a related,
prior problem existed?
There probably was a simple way of doing that. I can't
remember one.
The Inquiry has heard evidence that the PinICL system,
and the PEAK system that followed it and, indeed, the
KEL database, were searchable; is that right?
Yes, they were searchable. I'm not sure that I was very
good at knowing how to search it. If I wanted to search
for things, I would tend to talk to someone in the SSC,
“can you find information about this sort of thing?”
So in 2006, if a technician had searched for "data tree
build" or “data tree build failure" --
They probably could have found the PEAKs from 2000 if
they had applied the right sort of search criteria, yes.
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Q. So they could have found evidence of earlier problems,
allowing a potentially fuller picture --
A. Yes.
Q. --to have emerged?
A. Yes.
Q. Was that kind of search ever done routinely by fourth
line support?
A. I don't know, is the simple answer.
Q. Did you ever do that kind of search?
A. I don't think I would have needed to, in the sort of
fourth line support that I needed to do. It was
something that maybe would have been done more by the
actual developers, rather than the designers.
Q. You tell us, as a final reflection in your second
witness statement, that you are:
"struck by the lack of support that was afforded
to subpostmasters when they got into difficulties and
that there would have been a real benefit in having
a team whose function it was to have sight of all issues
across the different levels of support who could have
drawn together the PEAKs and had oversight of what
frontline support were fielding, and who understood the
practical ramifications of issues upon those who worked
in the branches and ensured that monitoring was
working.”
221
A. Only if they came from live because a lot of faults were
identified from test systems and things like that, and
some things were identified internally. So there were
a number of issues that were identified by SMC, who were
effectively second line support, that would then be able
to raise them through to be investigated by third line
support without involving the actual postmasters.
Q. Just like it would be reasonable to expect that, when
you were investigating a current problem, you might
search the PEAKs or the PinICLs or the KEL database for
the existence of past problems of a similar kind, if you
were giving evidence in court, you could use those
facilities to search for issues or problems of a kind
suggested by the subpostmaster, couldn't you?
A. Yes, I guess I could have done.
Q. But you didn't?
A. Ididn't.
MR BEER: Sir, it is just coming up to 4.30. That would be
an appropriate moment to break. It's been a long day.
SIR WYN WILLIAMS: Yes.
MR BEER: Weare reconvening tomorrow at 10.05.
‘SIR WYN WILLIAMS: All right. I'll see you all tomorrow at
10.05.
Mr Jenkins, I'm sure you wouldn't, but I should just
tell you that it's not appropriate for you to discuss
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Is that right?
A. That is how I see things now, looking back from
2023/2024. It was not something that had occurred to me
at the time. Perhaps it should have done but it is
certainly becoming very clear now, from what I've seen,
both with the GLO and with the work that's been done for
the Inquiry.
Q. Fourth line support was really the final stage in the
process on very difficult problems that couldn't be
fixed by the earlier lines of support, correct?
A. Correct.
Q. There went the problems that the SSC couldn't understand
or didn't have the skill to remedy?
A. Not necessarily. If a code change was needed, it had to
go to fourth line support because they were the only
people who actually had access to changing the code.
All third line support could do, and earlier lines of
support could do, was actually identify avoidance
actions or where people had been following incorrect
process, and that sort of thing. If there was actually
a bug in the code that needed fixing, then it had to go
to fourth line support.
Q. For problems to get to fourth line support, they would
have had to have got through the HSH or the NBSC, and
through to the SSC; is that right?
222
your evidence during the adjournments. All right? So
that obviously applies with greater significance when
you go home for the evening.
A. Yes.
SIR WYN WILLIAMS: Fine.
MR BEER: Thank you very much, sir.
(4.28 pm)
(The hearing adjourned until 10.05 am the following day)
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INDEX
GARETH IDRIS JENKINS (sworn) .....
Questioned by MR BEER ..
225
(57) Pages 225 - 225
MR BEER: [30] 1/3
1/5 119 1/16 2/22 64/9
64/14 64/19 64/21
84/14 84/21 84/24
85/13 85/22 86/18
86/24 106/11 106/15
106/19 106/21 130/15
130/20 130/24 131/1
173/12 173/18 173/21
223/18 223/21 224/6
SIR WYN WILLIAMS:
[26] 1/4 1/6 1/13
1/17 2/20 64/13 64/15
64/20 84/4 84/15
84/23 85/7 85/19
85/24 86/9 86/13
86/16 86/22 106/14
106/20 130/18 130/25
173/20 223/20 223/22
224/5
"40 [1] 32/22
49 [4] 13/14
"98 [1] 21/8
"98/99 [1] 21/8
"99 [2] 21/8 198/5
"99/2000 [1] 198/5
"A[1] 204/18
"Acash [1] 204/18
‘ambushed’ [1] 117/2
‘appears [1] 66/17
Could’ [1] 127/13
‘court’ [1] 177/14
‘data [2] 211/13
211/17
‘eat [1] 80/20
"expert [2] 126/9
171/11
"expert [2] 95/4
102/8
‘It [1] 66/25
‘lived [1] 188/7
‘opinion’ [1] 102/8
‘real [1] 102/8
"Should' [1] 127/13
test’ [1] 95/1
‘the [1] 178/6
‘yes [4] 217/11
= and [1] 110/24
-- that [1] 198/8
oO.
01.00 [1] 93/14
0200 [1] 203/17
1
1 June [1] 4/6
4 March [1] 161/22
1 October [2] 138/3
141/14
1,000 [1] 210/15
1,200-odd [2] 211/2
211/5
1,400-odd [1] 211/3
1.08 [1] 130/21
1.15 [1] 20/20
1.2 [1] 133/21
1.3 [3] 133/7 133/22
148/24
1.4 [2] 133/8 133/22
1.5 [2] 133/14 133/23
1.5 hours [1] 214/18
1.7 [1] 133/24
10 [4] 7/7 33/3 69/16
156/6
10 February [1]
210/5
10 November [1]
198/13
10 per cent [2] 11/2
33/6
10,000 [4] 200/22
10.05 [3] 223/21
223/23 224/8
10.20 [1] 64/11
100 [8] 6/21 10/14
11/12 60/12 60/13
60/16 145/19 219/7
11 [4] 64/14 69/18
203/17 203/18
11.08 [1] 64/16
11.20 [3] 64/13 64/15
64/18
110 [4] 157/25
12 [1] 69/20
12.19 [1] 106/16
12.20 [4] 106/12
12.35 [2] 106/13
106/18
13 [3] 54/11 65/1
69/23
13 June [2] 204/12
204/15
139 [1] 161/8
14 [2] 69/24 96/16
14 June [1] 215/10
14 May 2001 [1] 44/3
14 pages [1] 142/16
15 [4] 3/25 167/10
207/16 207/17
15 pages [1] 3/21
16 November [2]
112/7 116/8
162 [1] 166/5
17 [2] 177/5 181/3
17 August [1] 97/25
17.00 [1] 214/3
18 [1] 18/6
18 November [8]
65/2 74/10 76/6 94/7
96/25 97/18 101/1
134/11
18 September [2]
44/1 44/11
18.30 [1] 214/4
18.37 [4] 214/6
19 August [1] 44/10
19 December [1]
131/10
19 February [1]
147/13
19.00 [1] 214/25
19.10 [1] 215/1
19.30 [4] 214/9
1973 [1] 6/10
1990s [2] 11/10 49/1
1996 [8] 7/5 18/9
20/21 21/1 21/6 23/12
39/10 39/19
1998 [2] 44/1 44/11
1999 [5] 21/8 197/11
197/17 198/13 202/25)
1999-2000 [1] 203/23
2
2 August [1] 99/14
2 November [1] 24/8
2 years [1] 219/14
2.00 [3] 130/17
130/18 130/23
2.4 [1] 203/4
2.2 [2] 203/8 209/23
2.2.1 [2] 138/22
139/15
2.5 hours [1] 214/7
20 [7] 7/7 7/24 10/14
29/6 52/25 137/23
210/10
20 years [1] 64/6
20.00 [1] 93/14
20.05 [1] 214/9
2000 [18] 7/5 7/10
23/7 50/5 50/7 50/9
197/4 197/11 197/17
197/22 198/2 198/5
201/9 202/9 202/25
203/23 206/6 220/24
2000/2001 [1] 187/25
2000s [3] 22/18
26/21 186/19
2001 [2] 44/3 187/25
2002 [6] 6/16 8/14
18/9 21/1 22/13 23/12
2003 [4] 19/11 22/19
38/19 38/22
2004 [6] 54/18 55/17
66/14 93/24 104/11
104/25
2005 [16] 8/21 54/18
62/21 73/19 74/10
79/8 90/1 96/25 97/18
134/11 167/5 191/10
191/11 202/17 204/15
205/10
2005-2006 [1] 204/7
2006 [14] 89/17
89/23 91/11 91/12
93/7 97/17 97/25
202/4 202/10 203/10
204/7 210/6 211/21
220/22
2007 [4] 219/14
2008 [3] 8/15 8/25
9/3
2009 [2] 131/10
161/20
2010 [16] 108/6
110/17 125/7 136/12
137/7 138/3 161/22
161/23 162/18 162/23}
165/19 167/17 167/22)
170/17 183/8 183/17
2012 [1] 116/9
2013 [2] 118/1
147/13
2015 [5] 7/1 7/10 9/3
12/16 15/1
2016 [1] 14/1
2018 [8] 15/4 50/10
50/16 51/15 180/11
180/25 197/13 198/11
2018/2019 [3] 13/6
193/24 198/6
2019 [5] 13/6 15/2
15/4 193/24 198/6
2020 [5] 13/2 72/1
72/17 115/9 126/18
2020/2021 [1] 71/18
2021 [2] 71/18 72/17
2022 [4] 12/16 12/25
13/12 24/8
2023 [2] 3/21 4/6
2023/2024 [1] 222/3
2024 [4] 1/1 4/21 5/5
222/3
21 [1] 38/17
21 March [1] 4/21
21.12 [1] 214/6
21.27 [1] 214/14
21.28 [1] 214/16
22 [1] 56/22
22.58 [1] 214/17
23 [1] 18/6
23.04 [1] 214/18
233 [2] 121/12
122/14
234 [2] 4/21 4/24
25 [1] 27/23
25 June 2024 [1] 1/1
250,000 [1] 66/3
26 February [1]
66/14
27 [4] 140/17
27,000-odd [1] 65/16
28 November [1]
88/2
28 October [1]
170/17
29 April [1] 5/5
2nd [1] 217/9
3
3 March [1] 55/17
3,500-odd [1] 66/14
3.01 [1] 173/15
3.15 [2] 173/13
173/17
3.30-ish [1] 100/9
30 [2] 7/24 29/6
30p [1] 20/20
31 July [2] 95/19
95/23
313 [4] 121/22
329 [2] 121/12
121/23
331 [1] 157/25
35 [3] 68/13 134/5
203/18
36 [1] 196/17
3rd [1] 217/9
4
4 February [1]
210/22
4 hours [1] 215/18
4 July [1] 205/13
4 October 2010 [1]
136/12
4.00 [2] 93/15 144/25
4.00 pm [1] 142/9
4.2 [1] 138/21
4.28 [1] 224/7
4.30 [1] 223/18
40,000 [1] 214/23
404 [1] 161/10
41 [1] 61/10
42 [3] 94/22 98/4
98/12
43 [1] 61/22
43,000 [1] 198/21
45 [1] 54/12
45-odd [1] 204/20
46 [1] 54/12
463 [1] 144/9
466 [4] 122/14 166/4
166/6 167/25
468 [1] 166/22
478 [1] 122/7
483 [1] 122/15
5
5 hours [1] 215/19
5 May [1] 66/25
50 pages [1] 136/10
54 [1] 207/18
52,000 [1] 200/19
6
6 February [1] 3/20
6 June [3] 89/17
89/23 91/11
6.7 [2] 56/22 57/21
619 [3] 121/13
121/24 122/15
(68) MR BEER: - 619
6
643 [1] 121/25
646 [1] 122/1
666 [1] 122/8
669 [1] 122/17
67 [2] 4/7 4/10
67 pages [1] 4/7
68 [1] 177/6
689 [3] 121/14
121/25 122/16
7
7 August [1] 97/6
7 June [1] 92/2
7.00 [2] 14/14 93/15
8
8 December [1]
73/19
83 [1] 5/7
83 pages [1] 5/6
9
9 June [2] 91/12 93/7
9.45 [1] 1/2
93-odd [1] 211/6
A
abandoned [1]
214/12
abided [1] 157/19
ability [1] 61/24
able [29] 16/3 29/15
30/4 36/11 48/4 48/18
50/2 50/5 66/20 76/20
82/5 88/24 89/1 93/5
96/18 100/17 108/7
113/23 138/8 139/3
159/7 162/11 162/16
183/10 189/21 192/3
206/18 207/9 223/5
about [192] 1/14 2/15
7/4 7/5 7/10 7/24 8/1
8/25 9/3 10/21 11/2
11/12 12/16 12/20
12/22 13/7 13/8 13/16)
15/5 17/6 18/23 20/20
23/7 25/6 25/13 26/9
27/5 27/6 29/9 29/12
29/16 32/8 32/12
32/14 33/4 33/20 35/1
37/3 37/7 39/15 39/20
43/15 45/1 46/21
48/25 50/1 50/4 50/24;
52/10 52/13 53/21
58/22 60/24 61/2
61/16 62/3 62/18
62/21 64/3 67/9 72/11
73/2 73/19 80/8 82/24
84/5 89/13 89/19
90/11 90/12 91/2
92/14 94/2 94/4 96/21
96/25 98/1 99/22
102/22 104/6 105/4
105/9 105/21 105/24
106/1 106/2 106/5
106/7 111/7 115/14
115/25 116/17 116/22)
117/7 117/8 117/14
118/7 118/10 118/14
119/8 120/3 120/5
120/10 120/24 122/20)
123/25 124/17 124/20)
125/7 125/23 126/18
128/5 128/23 129/25
134/20 135/3 135/17
141/9 142/4 143/8
143/20 144/5 145/15
145/20 145/21 145/23)
146/8 147/5 155/23
157/3 157/11 159/3
159/9 159/11 159/20
160/1 160/1 160/24
161/23 163/1 163/3
163/10 163/14 164/5
164/9 164/18 164/18
164/20 165/17 167/6
169/2 169/3 170/10
172/24 174/19 175/10)
175/19 176/2 176/8
176/12 176/17 176/25)
177/1 177/22 179/7
179/22 181/11 182/2
183/13 186/4 187/25
188/3 188/12 191/21
192/8 192/25 197/8
198/2 198/20 199/7
204/4 204/5 204/23
204/24 205/11 208/9
214/9 214/23 215/11
217/3 219/23 220/21
above [5] 21/24 88/4
88/5 204/24 215/8
absence [2] 42/25
207/23
absolutely [2] 87/3
178/15
abstract [1] 116/2
abuse [2] 161/21
1791/5,
accept [14] 15/18
15/19 16/19 16/21
16/22 17/2 59/6 59/23
78/20 78/24 87/15
87/19 155/4 194/7
acceptable [1]
215/17
acceptance [1] 8/18
accepted [2] 108/13
129/17
accepting [1] 127/18
accepts [2] 138/24
139/16
access [9] 6/1 92/16
92/17 92/20 94/2
133/22 169/8 198/6
222/16
accessing [1] 92/14
accidentally [2]
72/23 208/7
accordance [1]
69/11
account [42] 4/16 5/2!
5/10 39/14 45/21
47/21 47/23 48/1 48/5
54/23 57/16 57/17
58/10 58/19 58/25
59/5 59/21 61/25
62/10 62/17 62/20
62/22 63/1 63/2 63/8
63/15 66/9 66/11
66/21 95/14 96/3 98/4
98/5 102/4 107/8
151/21 192/1 192/4
192/14 202/12 213/10
217/21
accounted [3] 14/15
113/24 114/18
accounting [13]
15/20 16/2 16/23
19/19 53/4 53/10
54/21 60/22 66/1
66/15 67/25 196/14
209/8
accounts [39] 14/9
14/12 14/16 16/12
16/25 17/4 17/5 22/4
33/23 35/18 53/13
53/16 53/19 55/3
55/14 56/25 57/1 57/2
57/16 57/19 57/24
57/25 58/1 58/4 59/19
60/11 61/18 62/12
63/18 63/22 80/21
94/22 98/9 186/14
186/18 195/21 196/4
196/24 207/24
accuracy [2] 60/1
209/17
accurate [11] 33/20
60/4 60/12 60/14
60/16 70/3 82/25
150/1 150/15 153/5
153/6
accurately [4] 67/1
67/25 76/25 77/6
acknowledge [2]
159/1 159/2
acknowledged [1]
37/16
acquire [1] 12/9
across [6] 24/3 24/5
24/7 50/18 57/5
221/20
act [4] 65/9 70/20
71/6 126/8
acted [1] 125/10
acting [2] 10/5 70/23
action [2] 100/6
205/24
actioned [1] 57/11
actions [1] 222/19
Actively [1] 209/5
activities [4] 9/20
44/9 112/17 125/24
activity [3] 126/9
127/7 127/10
actual [5] 207/21
207/24 208/18 221/13}
223/7
actually [91] 4/8 9/17
10/19 13/1 13/13
13/15 15/9 16/16
20/15 21/7 21/8 23/7
24/4 27/17 29/23
31/19 33/23 34/1
34/17 36/12 38/5 38/6
38/10 40/8 40/24
41/20 43/12 47/14
49/8 52/1 55/6 56/3
56/21 58/1 58/15
59/15 59/17 59/19
60/17 63/9 76/22 99/3)
104/12 104/14 108/8
113/13 114/11 115/22}
117/12 118/16 120/1
125/10 127/19 134/24}
135/24 136/4 143/11
154/22 156/24 161/5
162/11 165/12 169/22)
169/25 171/1 172/1
172/13 172/23 172/25
173/1 173/7 174/12
180/8 186/14 186/21
188/18 191/8 192/1
193/18 205/10 206/10)
211/24 212/5 213/2
218/5 218/9 218/15
218/17 222/16 222/18
222/20
ad [3] 14/17 39/12
126/23
ad hoc [3] 14/17
39/12 126/23
add [4] 78/2 110/3
166/14 200/6
added [4] 118/20
148/4 150/22 196/19
adding [2] 149/7
216/25
additional [3] 184/9
202/2 218/9
Additionally [1] 5/22
additions [1] 4/12
address [2] 137/6
159/12
addressed [5] 65/4
68/15 87/24 134/1
199/1
addressing [4] 98/5
112/14 135/25 159/13}
adhered [1] 70/22
adjourned [1] 224/8
Adjournment [1]
130/22
adjournments [1]
224/1
adjunct [1] 10/23
adjusting [1] 96/1
adjustments [2]
56/25 57/4
administrative [1]
145/25
adopt [2] 37/17
120/13
adopting [1] 164/24
advance [1] 96/10
adversely [4] 70/6
150/5 153/21 153/25
advice [3] 72/6 72/6
177/25
advise [2] 71/9 138/8
advised [1] 1/17
affect [8] 12/13 70/7
150/6 153/22 153/25
182/20 199/2 203/5
affected [7] 17/20
31/9 115/15 181/17
182/22 207/11 207/20)
afforded [1] 221/16
afraid [8] 15/14 47/1
49/9 64/8 116/12
125/22 146/4 163/11
after [28] 2/8 13/13
15/25 22/15 23/3
23/23 26/8 39/13
46/17 46/25 57/13
59/5 71/4 75/13 80/10
96/4 106/5 125/7
170/8 183/2 183/14
191/22 191/23 192/8
198/21 200/1 205/17
214/12
afternoon [9] 106/19
128/22 130/24 131/1
142/9 143/13 145/1
173/13 173/18
afterthoughts [2]
103/22 105/9
afterwards [3] 33/25
40/11 204/20
again [53] 7/23 14/7
15/23 19/15 20/14
30/24 31/15 31/21
37/11 51/4 77/8 77/14)
80/15 87/4 91/8 92/23)
92/23 93/15 97/17
101/1 101/17 101/17
101/18 113/21 118/6
118/15 121/16 126/1
129/21 130/10 133/6
136/11 136/25 137/19}
137/20 137/22 140/6
140/9 143/19 148/5
161/8 166/6 168/25
169/14 170/9 192/8
202/16 206/1 206/9
211/5 213/22 214/17
216/1
(59) 643 - again
A
against [10] 1/23
14/10 65/3 65/19 69/7}
128/20 167/19 192/4
194/14 197/2
Agency [5] 21/7 21/9
21/21 22/7 24/9
agent [13] 7/5 18/13
20/2 20/3 20/4 20/22
22/14 23/1 23/3 23/6
42/17 71/3 107/18
agents [10] 22/21
22/22 23/18 26/9
38/21 39/23 40/8
48/11 57/18 107/19
ago [10] 45/1 47/16
56/6 61/21 64/6 97/3
135/22 176/11 203/7
216/18
agree [20] 15/15 16/7
38/25 43/8 43/17
45/22 48/24 52/6
60/23 68/12 73/11
73/14 110/2 134/12
151/17 155/2 164/22
196/21 217/25 219/19}
agreed [7] 51/9 62/9
97/9 98/23 99/11
110/14 143/17
agreeing [1] 26/22
ahead [1] 219/12
aided [1] 56/4
Alan [3] 40/20 40/23
41/16
alert [1] 192/18
align [4] 57/4
all [104] 2/17 5/18
5/21 6/2 8/3 10/21
15/25 17/1 18/23 19/3}
19/3 19/23 25/5 28/8
28/15 29/18 30/3
30/25 31/11 32/12
33/5 36/2 36/22 43/13
45/2 54/5 61/16 64/15
65/13 67/1 68/21 70/3
70/19 73/6 73/7 80/10)
85/12 90/25 93/20
95/5 98/15 98/20
103/18 110/8 112/23
115/6 116/12 116/22
117/14 118/24 123/17)
125/22 128/22 129/15)
129/19 133/4 134/14
135/3 135/4 135/13
146/19 147/6 149/12
150/2 150/4 152/19
153/14 153/21 154/2
156/1 156/10 156/17
158/19 161/23 162/25)
163/14 166/11 170/8
170/21 170/25 177/9
179/3 180/16 180/23
181/20 182/24 184/12)
184/15 187/18 189/8
189/14 191/2 191/7
191/8 203/19 206/13
210/24 211/20 217/3
221/19 222/17 223/22
223/22 224/1
all-seeing [1] 30/3
allegations [1] 99/22
alleged [2] 78/1
130/4
alleging [1] 74/23
Allen's [3] 121/13
121/23 122/15
allocate [1] 113/24
allocated [10] 27/25
29/10 30/19 30/21
33/1 33/14 86/6 86/11
86/19 114/23
allow [5] 18/14 87/20
110/13 205/24 207/5
allowed [3] 19/6
34/20 220/9
allowing [1] 221/2
almost [3] 41/20
75/17 199/25
along [2] 47/15 177/3
alongside [1] 40/19
already [13] 35/1
37/17 39/1 41/12
42/11 112/12 120/4
120/7 123/5 143/17
144/4 144/24 161/12
also [30] 20/10 27/1
28/20 29/21 32/5
32/16 35/10 39/21
47/8 57/14 69/12 70/9)
74/1 77/12 80/18
93/13 95/7 98/18
100/2 100/17 111/1
120/15 127/18 138/13)
158/5 174/20 174/25
181/15 215/3 217/5
alter [1] 165/20
Alternatively [1]
187/15
although [8] 10/25
12/24 21/14 44/13
102/5 113/4 158/2
172/2
altogether [1] 59/1
always [6] 35/3 53/21
60/3 60/13 186/12
213/8
am [24] 1/2 1/17
64/16 64/18 77/16
84/13 93/15 99/24
112/22 116/16 124/17,
130/2 138/15 139/22
141/8 148/11 183/19
200/5 204/4 206/18
215/12 217/3 217/5
224/8
ambushed [1] 117/3
amendments [1]
167/4
Among [1] 8/19
amount [10] 12/22
48/8 54/2 58/3 77/12
119/7 119/18 189/6
202/14 204/19
analyse [2] 32/10
148/17
analysed [2] 95/6
136/4
analysis [22] 57/14
77/21 87/5 94/18 95/7
95/24 96/4 96/19
97/14 100/13 100/24
103/12 104/9 104/10
104/11 104/14 148/10}
148/11 148/16 160/20
160/21 180/10
analyst [1] 56/5
analysts [1] 9/6
Andy [4] 90/4 170/24
172/20 173/6
Angela [2] 117/25
118/15
angle [1] 93/19
Anne [19] 88/8 89/9
90/6 90/11 90/14 91/8
96/18 97/9 98/1 99/24
103/22 104/8 104/21
212/11 213/5 214/2
215/3 215/25 216/1
Anne's [1] 217/15
annexed [2] 153/13
153/19
annexes [1] 148/25
annotated [4] 142/12
145/7 145/11 145/17
annotating [1] 142/6
annotations [1]
138/16
another [13] 27/19
35/12 40/2 40/19
77/10 103/16 122/5
139/13 149/4 171/1
172/3 208/3 215/11
answer [50] 1/19
1/21 2/6 2/6 26/5 34/6
36/25 40/4 49/20
49/23 52/3 52/5 60/8
63/4 72/15 74/21
74/25 79/6 81/2 81/3
81/24 82/7 82/18
82/23 82/24 86/6
87/13 88/7 88/8 93/5
95/15 100/2 107/16
119/16 119/24 120/1
126/2 127/12 132/3
152/11 154/4 156/10
156/11 157/16 184/18I
197/15 208/24 209/6
218/18 221/8
answered [3] 41/12
103/4 123/5
answering [5] 2/9
104/24 119/22 123/7
159/4
answers [8] 72/2
75/1 78/10 82/13
156/1 156/6 156/12
160/16
anticipated [1]
213/13
any [158] 1/13 1/20
2/2 2/4 2/14 5/15 6/6
8/12 11/17 12/1 12/9
13/1 13/4 13/23 23/12}
24/23 26/18 28/7 28/9)
28/11 28/16 29/7 30/8)
31/6 31/19 33/4 33/7
34/1 34/9 34/23 34/24
40/12 46/9 47/22 49/8
49/14 52/19 56/10
56/21 57/10 59/25
60/5 63/17 63/19
63/21 65/14 65/24
67/3 67/12 67/17 68/2
69/1 69/14 69/14
69/16 69/19 69/25
70/6 70/13 70/14
70/14 70/15 70/24
71/10 71/24 73/10
80/9 90/10 90/24 91/6
91/7 92/13 96/24
97/15 100/1 102/3
102/17 103/1 105/4
105/18 109/11 109/20}
109/21 111/11 111/14}
112/17 116/3 117/7
117/16 121/19 124/6
124/16 128/7 128/11
129/8 133/9 134/21
135/10 135/18 135/18
138/18 143/11 144/14]
144/16 144/17 145/20)
146/2 146/12 148/16
150/16 151/4 151/11
154/12 157/12 157/19}
158/1 159/25 161/5
161/17 161/18 162/12)
163/23 165/11 166/14)
167/18 172/18 174/19}
174/19 175/13 175/13}
17713 177/17 177/22
178/1 178/25 179/14
179/22 181/13 182/13}
184/5 184/10 184/13
184/14 184/15 184/16
184/21 185/20 193/5
193/18 197/21 202/4
204/3 205/22 206/8
207/12 208/22 212/7
215/10
anyone [20] 2/5 30/9
31/14 37/2 70/11
108/3 108/11 108/19
110/15 127/6 127/10
141/8 141/11 144/15
150/10 154/19 174/2
175/11 187/14 220/3
anyone's [1] 194/22
anything [34] 11/18
21/14 22/6 38/20
39/17 46/19 47/23
49/7 63/19 70/10 78/2
96/9 113/22 113/23
116/22 124/5 129/22
145/20 147/6 150/9
154/24 156/4 158/3
166/1 169/13 169/22
177/20 179/19 187/1
205/18 206/1 206/7
213/15 219/21
anyway [6] 22/13
26/18 85/10 116/13
124/4 175/11
anywhere [1] 10/14
AP [4] 77/11
apart [2] 214/21
214/25
API [4] 46/21
Apologies [1] 129/13
apologise [1] 138/18
appear [3] 148/8
211/11 216/7
appeared [2] 45/1
166/17
appearing [1] 135/23
appears [2] 94/19
189/13
appendix [2] 4/9
148/25
Appleby [1] 200/21
application [9] 19/7
21/6 21/7 22/5 24/11
24/18 25/11 161/21
207/3
applications [5] 19/6
39/25 40/9 47/6
216/20
applied [9] 122/7
122/14 151/5 151/12
155/19 155/22 189/23)
201/8 220/25
applies [2] 70/7
224/2
apply [4] 105/18
157/12 157/20 160/13}
applying [1] 156/9
appointment [1]
12/10
appreciate [6] 77/24
79/18 82/15 130/5
148/6 176/3
appreciated [2] 80/9
193/6
approach [14] 37/18
83/24 112/22 113/8
120/13 120/25 143/15}
144/5 158/3 164/24
166/13 169/18 170/5
178/5
approached [9]
(60) against - approached
A
approached... [9]
52/18 52/23 111/5
111/25 113/7 116/23
137/17 181/4 1814/5
approaches [3]
111/19 112/24 113/2
approaching [2]
178/12 182/10
appropriate [8] 1/14
2/17 64/10 100/2
128/1 130/16 223/19
223/25
approved [1] 97/13
April [2] 5/5 116/21
Architect [9] 40/19
40/23 40/25 41/8
41/13 41/15 42/7
42/12 107/5
architects [1] 7/7
Architecture [2] 7/11
7/21
archiving [1] 192/22
are [92] 2/4 2/12 3/16
3/18 4/2 4/4 4/12 4/16
4/19 5/2 5/4 5/10 5/13)
5/19 16/17 17/6 31/10
35/25 37/4 43/17
50/20 52/1 52/6 52/8
56/19 57/3 60/11
60/11 66/4 66/22 67/1
68/24 69/1 69/1 69/2
70/6 71/2 71/12 71/16
71124 72/2 75/1 78/4
78/10 78/20 79/1 79/3,
80/19 81/4 85/18 92/8
92/11 93/13 93/22
93/23 94/6 94/20 96/2
98/18 100/2 103/9
105/9 110/1 112/23
118/10 133/4 134/2
134/10 139/2 139/6
150/20 156/6 159/15
160/16 165/6 166/16
175/17 178/7 181/24
188/5 189/21 192/24
199/1 200/5 204/2
215/10 215/14 216/15
216/19 216/20 221/15
223/21
area [9] 28/19 33/15
38/5 38/12 47/18 48/6
56/24 171/21 197/24
areas [10] 24/14
24/15 35/5 35/10
38/13 57/6 80/25
100/17 138/13 216/12)
aren't [4] 37/8 134/11
156/22 171/9
arise [1] 60/8
arisen [1] 200/21
arises [1] 2/13
arising [3] 138/12
193/7 194/8
arose [1] 203/4
around [13] 6/17 9/1
14/21 25/4 38/19
38/21 50/22 85/21
161/18 197/4 197/22
211/25 219/14
ARQ [3] 74/5 209/17
209/20
arrange [1] 128/16
arranged [2] 142/8
201/23
arrangement [1]
128/1
arrive [2] 184/9
184/20
art [1] 171/15
as [295]
aside [3] 42/13 48/23
195/18
asinine [1] 123/15
ask [12] 1/10 72/10
83/1 84/18 85/24
92/12 119/1 141/8
141/11 145/20 204/4
215/4
asked [67] 28/1 28/3
29/18 45/6 49/18
52/21 63/25 68/6
74/20 84/13 85/1 86/2
86/10 92/9 98/22
103/12 103/14 108/12)
109/17 115/23 116/17)
119/8 120/3 120/17
121/20 122/10 122/21
123/4 123/13 124/13
135/12 136/5 136/23
137/5 141/2 147/24
154/1 154/4 156/11
158/4 158/4 158/10
159/5 159/11 159/12
159/15 160/2 161/16
163/8 163/9 163/9
163/16 163/17 166/12)
168/24 171/20 171/22)
175/2 175/5 175/9
177/24 180/25 185/8
185/10 185/13 197/23}
218/5
asking [14] 2/5 5/21
83/2 83/23 83/23
84/19 94/17 95/19
118/14 124/6 125/3
142/14 168/6 168/8
aspect [1] 54/14
aspects [5] 18/19
38/16 127/25 137/6
159/20
assented [1] 83/24
assessment [2]
160/7 185/24
assist [5] 2/14 74/21
89/9 148/11 177/14
assistance [2] 13/17
124/7
assistants [1] 65/15
associated [1] 183/4
assume [2] 126/16
215/7
assumed [6] 62/1
63/6 83/16 110/9
168/9 169/14
Assurance [1] 24/1
at [426]
at page 110 [1]
157/25
at page 9 [1] 128/25
attach [7] 66/23 92/1
99/18 117/17 131/13
131/15 131/19
attached [3] 66/4
88/9 88/12
attachment [3] 66/7
88/14 131/11
attachments [1] 66/5
attempt [1] 119/4
attendance [5] 89/22
90/2 90/9 102/2
129/18
attended [2] 89/16
133/22
attending [1] 2/25
attention [7] 70/5
94/4 98/17 101/3
150/4 153/21 161/15
attitude [1] 170/13
attributable [1] 66/23
attributed [1] 142/5
audit [2] 93/23 161/4
auditing [1] 100/18
August [11] 12/16
12/25 44/10 96/16
97/6 97/17 97/25
99/14 191/11 205/11
208/5
August/September
[1] 205/11
Austin [3] 44/18 46/2
48/1
authorise [1] 201/6
authors [1] 66/6
automate [1] 58/15
automatically [2]
139/7 206/2
available [2] 57/3
219/25
Avenue [1] 170/17
average [2] 11/2 13/7
avoidance [1] 222/18
avoided [1] 46/4
aware [79] 21/22
22/9 25/6 26/15 27/8
27/24 30/12 30/13
31/22 31/23 32/3
32/20 33/17 33/22
36/24 41/22 43/19
43/21 43/22 43/23
45/11 50/17 60/4 64/7
70/6 71/17 71/24
89/14 94/11 97/20
102/17 105/12 105/14}
106/9 108/12 113/6
113/12 113/14 114/12
114/16 114/22 115/2
115/19 116/1 118/9
120/14 120/16 123/3
124/14 128/14 129/6
129/8 137/8 150/5
154/12 154/13 155/20}
156/3 158/10 158/14
158/19 160/11 172/19}
173/8 180/1 183/19
186/11 186/12 193/25
197/7 197/12 197/12
197/16 198/1 198/3
198/10 203/24 204/7
208/22
away [2] 23/1 83/7
awful [1] 180/7
awfully [2] 61/21
213/2
awkward [1] 119/15
back [76] 14/3 14/9
15/9 18/18 19/18
19/19 20/1 20/8 20/20
21/6 24/8 30/4 31/17
39/12 44/7 48/18
48/25 50/8 52/3 53/3
53/10 54/16 58/13
61/4 75/1 75/15 78/19)
81/7 84/3 85/14 86/25)
87/22 88/16 88/22
88/25 101/17 104/11
106/5 106/9 107/18
107/21 110/17 111/21
112/2 114/1 116/20
117/13 123/21 128/5
132/20 143/18 144/3
145/5 149/9 152/1
163/12 164/4 164/19
165/1 165/24 166/6
167/4 167/20 167/22
167/24 170/12 170/13}
179/9 180/21 183/17
197/4 198/2 199/20
201/18 202/9 222/2
back-end [7] 19/18
19/19 20/1 20/8 53/3
53/10 54/16
background [8] 6/9
13/24 15/8 36/3 43/14
130/3 130/13 165/12
balance [15] 9/22
198/25 210/16 210/17,
211/14 212/21 213/11
214/5 214/6 214/12
214/16 214/17 214/18
214/19 215/15
balanced [1] 213/12
balances [1] 197/5
balancing [9] 77/13
198/21 204/18 216/16)
217/2 217/11 217/22
217/24 218/20
Baldwin [2] 80/13
80/17
bank [1] 22/4
banking [5] 22/18
22/24 23/20 26/22
27/1
banks [4] 23/20
23/24 28/24 182/19
bans [1] 93/21
barrister [4] 167/23
168/6 168/20 174/8
barristers’ [1] 146/17)
base [1] 45/12
based [15] 18/11
19/14 19/16 33/15
43/10 43/10 43/12
46/7 66/17 69/1 97/14
104/12 138/9 158/12
219/5
basic [1] 123/25
basically [9] 19/22
47/10 56/12 92/4
111/8 114/5 136/5
182/3 184/13
basis [5] 39/7 52/23
53/18 68/22 128/7
batch [1] 19/22
be [247]
bear [1] 179/4
bearing [1] 165/6
became [17] 6/16
11/9 15/10 31/22 32/3)
32/20 33/17 44/24
48/17 53/1 193/25
197/12 197/16 198/1
198/4 202/4 202/17
because [113] 4/8
15/25 17/11 20/13
21/5 21/9 22/16 22/22I
26/23 27/11 28/3 31/4I
32/18 36/2 36/6 38/9
39/20 41/18 41/24
51/19 54/2 54/4 61/20}
61/25 62/11 62/18
64/5 66/10 67/20
67/24 71/23 72/8 73/1
74/6 74/12 75/20
76/12 76/22 77/5 78/8I
79/3 81/3 83/2 84/12
87/11 89/3 94/9 97/3
103/4 104/8 104/11
104/14 104/23 106/4
107/17 107/19 108/21
109/5 110/25 119/13
119/16 119/21 120/1
120/18 127/20 128/4
129/23 130/13 132/9
132/14 134/23 134/24)
136/22 138/23 139/16
139/21 140/8 140/25
(61) approached... - because
B
because... [35]
144/24 151/12 153/16)
154/20 156/14 157/1
157/16 159/4 160/6
163/2 168/15 169/10
171/21 175/6 175/24
176/1 176/12 177/24
178/12 179/2 182/16
185/14 192/22 192/25)
197/19 202/8 202/17
204/5 205/18 209/20
212/7 212/24 214/13
222/15 223/1
become [11] 11/24
12/4 30/12 30/13
31/21 36/23 37/1
85/12 105/7 108/17
210/10
becomes [1] 14/23
becoming [3] 11/21
36/16 222/5
been [169] 1/17 5/24
13/3 14/1 24/10 24/19}
24/21 27/16 27/24
29/24 34/8 34/13 37/7
40/9 42/3 43/22 45/15)
A7IT 47/14 48/4 49/18
49/20 49/23 50/17
52/14 52/20 56/6 64/7
66/8 66/9 67/12 67/17,
67/23 69/11 71/22
74/11 74/12 74/20
75/18 76/9 76/10 77/4
81/13 81/15 81/19
81/21 82/8 82/20
82/22 84/24 85/1 85/3
86/19 87/8 87/16
87/20 87/20 88/22
89/7 91/3 91/5 94/3
94/11 96/25 97/18
98/22 98/23 101/2
102/2 104/8 104/10
104/22 105/22 105/25
108/25 109/1 111/22
111/23 113/4 113/7
114/16 115/20 115/23)
116/23 119/7 128/3
133/15 133/20 135/6
136/5 137/4 140/14
147/2 147/24 150/10
154/18 156/13 158/14
159/5 160/2 160/11
160/12 160/13 161/19)
162/17 163/8 163/9
165/3 170/20 171/11
171/12 172/18 172/20}
173/5 173/8 176/6
176/9 176/15 176/23
179/5 180/1 180/13
181/1 182/1 182/5
182/8 182/13 183/10
184/25 186/12 187/1
190/5 190/19 192/19
193/11 193/22 194/7
194/9 196/18 197/19
198/2 198/25 199/15
199/25 200/1 202/9
207/9 207/15 208/7
209/1 211/8 213/22
213/25 214/1 214/9
215/11 216/11 216/13)
216/22 218/7 219/6
219/25 220/6 220/8
221/12 221/18 222/6
222/19 223/19
BEER [6] 1/8 1/9
1/13 2/21 84/4 225/4
before [43] 1/13 1/25
8/23 12/3 12/3 13/1
27/15 27/16 37/6
37/11 40/13 46/7 59/7,
59/24 62/21 68/7 84/4
87/1 96/4 100/13
101/15 105/19 117/8
128/24 129/13 137/7
142/25 143/17 146/18)
146/20 151/2 151/19
151/23 152/22 153/1
170/12 178/17 188/3
192/11 197/14 205/9
208/2 219/15
began [1] 38/22
beginning [4] 21/6
85/9 98/8 157/11
begins [1] 84/6
behalf [3] 1/10 65/9
168/19
behaved [1] 176/23
behaving [4] 29/4
160/9 161/3 206/23
behaviour [1] 185/11
behaviours [1] 58/23
behind [7] 20/17
47/20 53/21 58/11
99/12 104/19 188/25
beholdant [1] 205/20
being [108] 16/3 17/6
18/24 20/11 25/8 27/4
27/4 27/6 32/6 35/8
36/1 36/2 41/18 43/8
43/19 45/6 47/21
47/22 51/25 51/25
52/2 52/19 54/3 58/4
60/6 61/13 63/13
63/25 64/1 70/4 71/16
75/1 75/25 77/12 79/8)
79/13 87/10 88/5
90/12 93/11 93/12
95/2 102/15 104/19
106/2 108/7 108/12
108/20 109/17 110/4
110/6 111/4 112/22
113/20 113/22 113/24}
117/3 117/12 119/13
120/3 120/17 123/10
124/7 124/10 124/12
124/13 130/4 136/23
137/5 140/12 140/13
141/2 142/5 145/24
146/23 147/19 152/9
156/11 157/17 158/10}
159/11 159/12 162/8
166/1 167/13 167/15
168/23 169/2 169/10
171/20 171/22 174/4
175/9 180/25 185/19
187/2 196/19 196/24
201/4 202/18 207/4
211/24 214/22 216/21
217/12 217/13 217/17
219/15
belief [10] 3/17 4/3
4/18 5/3 5/12 41/1
66/22 69/9 149/15
188/7
believe [45] 16/25
17/7 50/7 54/13 56/5
58/11 67/15 68/2
73/23 75/25 89/9
103/12 105/23 111/17]
112/9 123/22 144/16
145/19 150/14 159/21
161/15 170/19 174/25}
175/1 176/1 176/18
179/8 179/13 179/17
179/20 179/24 186/6
186/13 193/10 201/10}
202/8 203/11 203/21
203/23 204/1 204/7
207/12 208/12 211/23
219/24
believed [6] 51/20
176/13 184/8 184/19
186/5 186/10
believes [2] 66/19
199/5
below [4] 85/15
116/20 148/4 214/2
benefit [3] 194/22
208/11 221/18
benefits [6] 21/7 21/9I
21/20 22/3 22/7 24/9
benign [1] 187/3
Bennett [1] 44/18
Bentley [1] 66/6
Benton [1] 66/24
best [12] 3/17 4/3
4/17 5/3 5/11 6/22
48/20 89/5 127/19
150/1 180/9 219/9
better [12] 29/16
31/2 36/9 45/14 47/8
47/12 54/1 56/15
108/3 111/4 124/18
215/20
between [41] 10/14
15/1 17/25 18/8 19/20
21/1 22/23 23/12
23/18 23/20 24/21
29/6 44/10 51/13 65/9
65/16 71/10 72/4
79/24 93/14 93/15
96/9 98/14 99/11
102/20 107/20 114/7
114/23 117/14 117/24
125/10 125/17 127/23}
137/24 178/18 187/8
198/5 202/5 211/8
214/9 217/24
big [2] 54/8 133/15
binary [1] 156/2
bit [22] 14/20 18/21
19/9 20/17 21/12
21/19 28/23 35/16
TAIT 74/8 74/8 75/10
92/24 117/8 118/4
125/13 147/15 157/2
176/3 204/16 207/3
212/5
bits [7] 71/15 75/8
100/12 109/8 115/20
136/16 180/24
black [10] 24/25 25/9
25/25 26/1 27/3 27/4
74/19 74/19 75/6
148/4
blanket [1] 129/15
block [1] 88/19
blocks [1] 194/21
blue [3] 114/20 117/6
148/4
board [1] 112/23
Boardman [1] 56/5
body [4] 4/11 5/20
121/17 198/19
Bogerd [3] 117/25
118/14 118/16
bold [1] 100/3
Bond [11] 65/2 73/11
7AI9 76/4 88/5 89/17
90/16 90/17 91/2
91/15 94/3
book [3] 127/2 127/8
128/22
booking [1] 125/23
boss [1] 141/22
Boston [8] 39/10
39/15 39/18 40/2 40/4
40/7 41/19 41/24
both [20] 10/16 17/16
17/19 31/25 32/2
32/15 33/18 36/13
95/13 99/4 113/5
122/7 157/6 164/8
165/8 165/21 177/21
192/3 215/12 222/6
bottom [5] 88/19
91/13 177/6 179/9
200/8
bought [1] 18/20
boundary [1] 19/20
box [7] 23/19 25/1
25/9 25/25 26/1 27/3
27/4
Bracknell [4] 43/11
46/4 46/7 90/1
Bradbury [1] 116/10
branch [53] 16/12
17/4 17/5 18/24 52/16I
54/22 54/23 55/20
56/25 57/1 57/7 57/16)
57/19 65/7 65/17
67/11 77/22 89/8
160/9 160/14 160/19
161/5 162/17 163/4
170/18 181/11 181/25)
182/11 182/16 182/22)
183/5 183/9 184/1
184/2 185/13 186/14
186/18 187/1 192/5
192/13 194/1 200/18
202/14 205/2 207/24
212/25 213/10 213/25I
214/3 215/4 215/11
216/6 217/21
branches [17] 17/20
19/8 159/23 181/17
182/14 182/21 186/23)
192/1 194/2 198/16
207/21 208/19 212/24I
213/4 215/15 216/3
221/24
break [15] 14/23
64/11 64/11 64/17
101/15 106/13 106/17I
128/24 130/17 130/18)
173/13 173/13 173/16)
216/6 223/19
Brian [17] 73/20
73/22 74/17 75/9
75/13 83/1 85/18 86/2
87/6 87/23 90/3 93/2
99/15 141/23 187/6
187/7 187/12
briefed [2] 176/23
176/24
briefing [1] 102/18
briefly [3] 7/3 18/17
19/15
broader [1] 35/8
brought [5] 4/15 5/1
5/9 66/8 69/7
Bs [1] 187/18
budget [1] 116/18
buffer [2] 125/10
207/5
buffered [1] 207/5
buffering [1] 207/2
bug [17] 14/1 14/2
33/13 33/18 174/17
184/5 185/19 186/17
190/5 190/5 190/11
190/25 194/18 201/13)
208/4 212/23 222/21
bugs [45] 16/6 16/10
16/16 16/24 17/2
27/24 28/8 28/12
28/16 28/22 29/9
(62) because... - bugs
B
bugs... [34] 29/18
30/5 30/7 30/12 30/25)
31/11 31/22 32/3
32/20 33/21 33/22
34/2 34/8 34/25 37/23
52/11 162/19 162/25
163/14 163/16 174/20}
175/10 175/14 180/11
181/21 182/24 183/13)
183/19 186/3 186/5
186/8 186/9 189/21
190/1
build [18] 50/21
51/14 194/18 196/22
197/8 197/11 198/4
202/22 203/20 204/10)
206/5 209/7 209/16
218/12 218/24 220/2
220/23 220/23
building [8] 42/10
43/7 43/9 43/13
194/21 195/21 212/21
213/1
built [5] 19/6 20/16
26/14 196/18 209/21
Bureau [2] 8/17 8/21
Burton [3] 212/12
212/17 219/3
business [13] 32/16
57/6 58/2 58/6 58/16
60/20 60/21 60/23
61/5 62/1 62/3 63/6
117/15
BUSY.EXE [1] 193/1
but [231]
button [1] 214/16
buying [1] 25/9
buzzing [1] 14/21
Byfleet [2] 139/23
142/2
Cc
calculated [3] 211/6
211/15 211/18
calculating [1] 212/6
calculations [1] 99/1
calendar [1] 219/13
call [13] 1/5 36/18
55/24 82/1 99/25
104/10 143/1 143/12
145/3 189/14 200/23
204/15 209/24
called [24] 7/18 11/6
13/21 18/20 18/22
23/20 28/19 30/14
30/15 31/7 32/9 35/10)
35/15 53/1 53/11 56/1
56/5 62/19 62/25 74/3
90/6 102/7 102/15
169/5
Callendar [3] 174/17
194/1 201/13
calling [3] 177/18
178/22 179/15
calls [4] 98/21
144/17 173/2 173/8
Cambridge [1] 6/10
came [19] 10/7 10/8
13/12 25/22 38/12
50/18 50/22 50/22
99/4 104/6 109/5
125/7 162/13 164/19
172/5 197/7 197/17
197/25 223/1
camp [1] 49/5
can [181] 1/3 1/10
2/16 3/1 3/4 3/19 4/5
4/20 5/15 6/9 18/4
18/17 19/14 21/15
21/19 36/19 38/14
43/24 43/25 44/4
44/13 44/19 44/20
49/17 50/19 50/20
50/21 52/7 52/24 53/8)
54/10 55/16 56/22
63/23 64/11 64/19
64/20 64/22 64/25
65/1 65/4 65/5 66/19
71/23 72/10 73/17
74/6 74/24 78/2 79/14
81/6 81/14 82/19 84/3
85/4 86/25 87/1 87/22
88/16 89/15 89/22
90/25 91/11 91/14
92/6 93/23 94/13
94/15 95/20 97/5
97/25 99/13 100/1
100/8 100/13 101/5
101/15 102/17 103/18)
103/20 106/12 106/19)
111/13 112/4 116/6
117/21 117/23 117/25)
120/14 120/22 120/22)
125/16 128/24 129/3
129/19 129/19 130/16)
130/24 131/6 132/23
132/24 134/5 136/9
137/19 140/17 141/13)
143/14 144/6 144/14
145/2 146/2 147/8
147/12 147/13 147/14)
148/9 149/16 156/13
157/23 161/7 161/9
164/21 165/2 165/25
166/3 170/13 170/15
170/21 170/25 173/13)
173/18 174/13 175/6
177/5 179/25 180/9
180/21 186/2 186/3
187/4 187/6 187/15
188/7 189/3 191/10
191/12 192/17 194/17)
194/17 194/21 195/12)
195/14 195/18 197/14)
198/13 198/15 198/16)
198/18 199/12 200/6
202/22 204/22 205/15
205/18 205/24 206/7
207/16 209/23 210/1
210/3 210/4 210/21
211/19 212/9 213/18
215/16 215/25 217/12
218/16 219/18 220/21
can't [64] 7/23 9/1
11/11 14/7 15/6 22/1
30/9 31/18 44/24
46/25 47/16 48/3
48/19 53/12 58/22
60/25 61/7 61/20
62/14 63/16 64/6
75/10 79/14 90/13
96/14 96/15 97/2
99/10 99/11 103/13
103/17 105/3 112/12
120/6 123/16 125/21
136/19 137/3 137/3
143/10 144/11 144/16
144/18 145/9 145/13
145/19 146/21 161/24
168/21 171/12 171/16
176/21 187/24 189/25]
190/15 191/8 191/24
204/3 209/14 211/22
212/13 214/10 219/22
220/13
cannot [4] 102/7
193/3 205/22 207/23
CAP42 [1] 98/3
capacity [14] 96/22
103/10 106/23 109/3
109/14 111/11 117/14]
131/2 131/4 131/25
132/1 135/16 135/24
140/7
capital [1] 171/17
Capture [1] 8/24
card [2] 8/22 27/2
cards [2] 8/18 22/20
care [3] 70/21 70/24
137/17
career [2] 6/24 7/4
careful [2] 62/18
82/19
carefully [2] 83/9
95/6
carelessness [1]
65/14
carried [5] 69/16
69/19 191/7 201/7
218/6
carry [8] 51/23 96/4
97/13 148/9 170/3
186/16 201/8 205/12
carrying [1] 96/12
Cartwright [1] 112/9
case [113] 9/24 9/25
26/20 47/4 52/8 56/13)
64/12 64/23 65/3
65/24 73/2 76/21
78/15 79/20 89/22
90/15 94/11 95/1 97/7
101/7 101/13 102/16
103/1 103/4 103/11
104/8 105/8 105/22
106/24 109/7 110/25
4111/1 112/13 112/18
115/24 119/6 121/11
121/13 121/14 121/19}
121/22 121/23 121/23
121/24 121/25 122/7
122/8 122/14 122/15
122/16 122/16 123/21
125/8 128/16 129/3
129/6 130/4 131/16
136/11 139/1 139/18
142/3 143/15 143/19
144/3 146/23 147/9
147/20 148/1 149/4
149/6 151/3 152/24
160/17 161/9 161/11
162/5 162/24 164/5
165/8 165/9 165/21
165/22 166/9 167/3
167/19 168/6 169/17
169/18 169/19 170/6
170/14 172/9 172/10
172/18 172/19 173/5
173/7 174/8 174/16
174/24 175/6 176/14
181/11 184/24 185/2
185/12 188/8 188/24
191/6 195/24 207/25
217/13
cases [39] 9/10 9/19
10/3 10/6 17/19 24/17,
36/4 51/5 80/7 94/11
109/19 109/24 110/7
112/1 116/19 117/8
129/8 154/21 155/24
160/4 165/22 167/10
169/8 169/24 172/16
173/24 180/8 180/23
181/1 181/4 183/6
185/7 186/19 186/21
186/24 190/16 191/2
191/2 215/12
cash [38] 14/13
14/14 47/20 47/23
48/1 48/5 53/19 54/1
54/2 54/4 54/8 54/23
65/12 66/21 94/21
95/14 96/3 98/4 98/5
98/9 191/22 192/1
192/4 192/14 202/12
204/18 204/19 210/13)
210/16 210/23 210/25)
211/5 211/11 212/6
213/9 214/5 214/14
217/21
Castleton [7] 65/4
65/10 66/19 89/23
94/20 97/7 102/16
Castleton's [10]
64/12 64/23 65/7
65/23 67/5 67/16 92/2
99/22 101/7 101/13
catastrophic [1]
28/25
catch [1] 207/6
categorically [1]
176/21
categories [2]
203/19 218/22
categorisation [1]
187/19
category [10] 203/22
203/24 204/1 204/6
204/8 204/9 206/17
218/11 218/12 220/2
cause [17] 16/11
16/16 17/3 17/5 34/3
79/8 168/17 184/4
186/8 190/2 190/18
190/21 193/13 194/15}
199/1 201/15 209/7
caused [10] 16/24
19/7 28/25 65/13
65/15 160/18 181/24
186/9 186/14 208/17
causing [3] 161/13
191/5 218/3
caution [2] 168/18
169/20
caveats [3] 133/8
135/6 147/3
CBDB [2] 53/12
53/18
cent [9] 6/21 11/2
32/22 33/3 33/6 60/12
60/13 60/16 145/19
central [2] 48/13
182/18
centrally [1] 57/7
centre [1] 20/6
centres [1] 22/23
century [1] 6/19
certain [8] 35/5 48/8
75/11 78/13 174/3
202/13 214/11 216/12
certainly [42] 15/1
15/4 16/9 23/16 25/19)
35/16 40/22 40/25
41/11 51/6 51/9 61/1
61/3 73/7 75/10 76/7
76/14 77/23 78/15
94/11 101/10 105/19
109/11 109/24 110/16
123/2 123/3 127/20
132/8 137/14 146/13
153/6 154/20 155/20
156/3 169/24 172/17
175/6 183/7 199/25
209/14 222/5
cetera [11] 67/9
69/17 69/19 70/25
80/13 102/9 102/9
150/21 170/21 179/5
188/9
(63) bugs... - cetera
Cc
chain [1] 219/2
challenge [1] 60/5
challenged [1] 95/2
challenges [1] 20/21
chambers [12] 88/9
90/6 90/11 91/8 96/18
98/1 98/22 104/22
146/17 178/8 212/11
214/2
Chambers’ [2]
103/22 216/1
chance [3] 100/21
144/23 145/2
change [18] 8/17
8/22 47/5 47/14 59/20
60/9 69/21 87/20 89/6
97/11 97/12 112/25
155/1 168/15 193/2
193/14 211/25 222/14}
changed [13] 6/18
21/5 62/7 82/8 82/20
116/17 154/22 155/7
165/12 165/13 192/5
207/1 212/6
changes [18] 8/16
8/22 20/14 22/21 23/2
41/18 41/21 41/21
54/15 54/19 100/1
119/21 165/11 191/25
194/13 216/11 217/19}
218/7
changing [2] 83/14
222/16
channel [2] 119/14
163/20
channels [2] 119/12
120/2
chaotic [1] 123/2
charge [1] 191/18
charged [2] 109/4
113/20
charging [2] 113/21
125/24
Charles [5] 131/15
142/2 142/7 143/12
144/25
chase [1] 146/1
Chased [1] 200/23
chasing [1] 102/2
chat [4] 25/4
check [4] 93/24
162/14 197/2 214/13
checked [2] 99/3
204/20
checking [1] 187/17
checks [1] 197/5
Chesterfield [2]
58/13 61/17
Chief [10] 23/6 40/19
40/23 40/25 41/8
41/13 41/15 42/6
42/12 107/4
child [2] 195/10
195/14
children [2] 195/12
195/12
choice [1] 105/1
Chris [5] 189/9
189/10 189/14 189/17)
201/1
chronology [2] 69/3
120/6
C114 [1] 201/9
circulate [1] 91/24
circumstances [3]
35/14 122/20 196/12
civil [3] 68/12 79/24
180/17
claim [3] 15/13 65/19
180/17
claimed [1] 93/13
claiming [1] 100/18
clarification [1]
130/2
clarify [1] 204/22
clarifying [1] 165/11
classification [1]
202/24
clear [21] 2/2 83/15
85/12 152/18 155/20
163/9 174/18 174/20
174/22 175/12 175/13)
175/15 178/10 178/15)
178/20 179/6 185/6
191/4 213/8 217/19
222/15
clearly [27] 17/18
17/19 17/25 22/24
25/5 28/25 50/10
71/23 73/13 83/13
99/10 108/12 108/24
110/7 117/14 117/5
117/9 124/14 126/15
132/8 143/2 144/12
157/21 164/3 190/22
218/3 218/16
clerk [1] 205/25
client [5] 26/13 27/18
70/19 70/20 77/11
client's [1] 71/2
clients [1] 57/7
close [3] 31/6 42/23
49/8
closed [1] 93/11
clutching [1] 93/18
code [15] 10/7 20/16
32/15 32/18 69/11
127/4 128/22 192/19
200/18 205/19 208/4
208/7 222/14 222/16
222/21
codes [1] 127/5
coding [3] 41/10 42/7
42/25
cog [2] 48/12 48/13
colleague [1] 178/8
colleagues [1] 171/6
Coloured [1] 74/13
come [35] 5/16 13/9
17/21 23/25 24/3 24/5
25/3 35/3 36/5 36/20
40/3 48/18 49/17 52/3
54/11 89/15 92/19
101/5 103/20 112/24
113/22 115/7 115/11
120/22 132/20 155/6
157/23 159/14 160/15}
164/4 164/21 166/6
179/25 194/17 210/1
comes [1] 128/5
comfort [1] 105/17
comfortable [2]
105/20 166/25
coming [13] 14/3
24/7 79/21 106/12
111/8 122/25 143/18
144/3 146/16 182/23
183/7 218/17 223/18
commas [4] 171/9
171/14 171/17 172/3
commenced [1]
137/8
comment [25] 76/9
82/5 82/8 82/21 83/14
83/18 87/8 87/9 87/11
88/24 89/1 99/22
102/22 136/6 141/2
147/22 150/22 151/11
153/10 154/1 163/17
173/2 173/3 173/4
215/25
commented [2]
71/12 83/21
commenting [3]
56/11 136/18 152/20
comments [18] 51/7
81/12 85/16 85/17
131/14 131/17 131/20}
135/13 138/20 142/6
147/18 148/4 154/21
154/23 155/1 155/2
166/15 166/25
commercial [4]
112/16 127/25 128/1
128/17
commercials [1]
128/4
commissioned [1]
46/1
commonly [1] 28/22
communicate [2]
18/14 19/18
communicating [4]
23/13 74/2 111/22
111/23
communication [3]
20/22 38/1 114/7
communications [5]
72/4 164/8 164/12
164/15 178/18
company [3] 11/20
12/7 18/20
company's [1] 134/2
compare [1] 168/10
compared [1] 94/21
competence [1]
182/17
competent [1] 70/22
complaints [3]
105/21 105/24 213/6
complete [14] 33/20
70/3 95/7 100/10
100/16 100/22 125/2
150/1 153/5 153/7
169/2 169/9 185/3
215/15
completed [3] 95/3
100/14 215/10
completely [5] 87/14
87/17 118/5 160/21
203/22
complicated [4]
11/24 82/23 82/24
102/9
complied [2] 68/18
134/7
component [1]
203/21
components [1]
216/7
compounded [1]
51/12
comprised [1] 39/4
compunction [1]
159/25
computer [4] 65/25
66/23 148/1 148/19
Computers [1] 6/14
concept [2] 62/25
130/12
conceptual [2] 55/21
55/25
concern [2] 63/11
203/20
concerned [17]
51/19 53/10 63/1
102/24 102/25 112/22}
115/25 123/25 129/23
136/17 142/4 145/23
147/1 157/1 157/3
160/8 199/1
concerning [4] 13/18
88/3 147/11 212/9
concerns [4] 7/4
96/21 125/23 170/17
conclude [1] 94/23
concluded [3] 15/16
16/5 184/4
conclusion [1] 66/13
conclusions [2]
69/24 99/4
conduct [2] 71/19
143/9
conducting [1] 182/8
conference [4] 89/16
90/23 91/21 200/10
conferred [1] 11/15
confidence [6] 22/8
34/16 34/19 37/18
122/24 170/6
confident [5] 34/3
34/6 37/12 51/24
188/13
confidentiality [1]
133/7
confidently [1] 34/20
configuration [4]
193/11 193/15 194/13)
207/1
configured [1]
192/13
confirm [2] 68/17
150/20
confirmed [1] 71/1
conflict [1] 71/10
confused [1] 62/24
connected [3] 195/8
195/14 218/21
connection [4] 13/18
92/6 197/21 202/5
connections [1]
28/24
conscientiously [1]
137/17
conscious [6] 26/11
26/12 137/13 160/6
160/8 167/8
consequence [2]
25/15 59/22
consequences [6]
13/16 14/4 37/10
158/19 213/9 217/20
consider [10] 2/9
2/16 59/14 70/14
150/16 163/6 163/16
168/25 181/25 217/7
considerable [1]
148/18
consideration [1]
59/25
considered [7] 58/19
82/22 152/18 156/23
170/9 172/15 175/10
considering [4] 6/7
152/24 160/14 201/12)
consistent [1] 84/15
consists [1] 3/10
constituted [1] 104/1
constitutes [1]
215/17
constructed [1]
136/3
consult [1] 2/15
consultancy [3]
12/19 13/1 13/20
consultant [1] 12/17
consultants [2] 24/5
70/22
(64) chain - consultants
Cc
consulting [1] 12/20
consuming [2] 95/5
95/25
contact [8] 23/25
26/18 46/4 113/14
117/7 120/5 120/10
217/16
contacted [2] 177/25
213/22
contain [5] 68/20
69/3 69/4 69/10 69/24
contained [2] 14/17
122/12
containing [1]
196/23
contains [2] 194/23
195/4
contemporary [1]
194/10
contempt [1] 69/6
content [3] 156/22
156/23 156/24
contents [6] 3/16 4/2
4/16 5/2 5/10 101/19
contest [2] 139/4
139/9
context [8] 89/24
91/8 118/2 118/4
125/19 150/25 151/17,
181/20
continual [1] 22/14
continue [6] 23/3
68/18 131/6 134/8
173/18 204/6
continued [5] 22/13
24/13 41/2 66/15
214/4
continues [2] 134/14
149/12
continuing [2] 103/3
103/10
contract [9] 21/9
21/21 24/21 24/24
26/12 26/13 27/9
65/22 66/2
contracts [1] 27/15
contractual [3] 9/13
57/18 59/12
contribute [1] 56/19
contributed [2] 56/8
56/20
contributor [1] 56/17
control [9] 34/18
54/1 55/20 57/15 58/9
112/2 117/10 117/13
120/15
controlled [1] 17/1
convenience [1]
138/17
conversation [10]
46/21 47/15 142/10
143/3 143/10 174/25
175/19 176/25 177/3
178/7
conversations [3]
38/4 110/16 177/9
conviction [3] 158/16
158/20 170/7
cooler [1] 29/13
coordinate [1]
114/11
copied [9] 91/16
112/21 113/5 116/10
119/12 120/16 148/3
191/16 216/2
copies [2] 20/5 96/3
copy [4] 68/13
142/12 145/7 212/2
corporate [2] 202/21
203/15
correct [86] 3/13
6/12 6/15 6/25 7/2 7/6
8/10 9/11 10/24 11/7
11/14 12/8 12/14
12/18 18/12 18/16
27/20 28/2 28/5 29/10
39/3 39/6 39/9 40/21
41/5 41/6 43/17 46/6
47/21 48/2 50/3 54/25
55/12 57/1 59/8 67/16)
73/4 75/16 76/9 78/9
86/12 93/9 100/25
103/7 107/5 107/6
107/13 112/24 117/19)
117/20 121/4 121/9
121/15 121/21 122/2
122/6 122/9 122/13
122/18 159/6 162/3
166/13 172/7 172/11
174/1 174/6 181/19
181/23 189/11 195/9
195/11 195/13 195/15)
195/17 195/20 196/2
196/6 196/15 196/20
201/21 205/5 211/22
218/14 219/1 222/10
222/11
correction [4] 70/16
138/25 139/17 150/17)
corrections [13] 3/11
4/15 5/1 5/9 57/8 57/9
138/11 138/22 138/24}
139/2 139/5 139/9
139/12
correctly [8] 17/15
34/5 51/21 113/20
113/25 114/23 160/9
211/18
correspond [1] 125/4
correspondence [2]
99/18 186/22
corresponding [2]
77/10 209/11
corrupting [1] 16/12
cost [4] 20/19 95/17
148/18 218/9
costings [1] 219/5
costs [6] 20/19 60/21
61/2 61/4 61/11 62/4
could [80] 12/3 12/3
14/4 16/10 17/3 17/5
28/21 30/21 32/11
32/14 33/19 36/9
36/13 39/22 40/8
40/10 41/25 45/3
45/14 47/7 47/8 48/10
53/23 57/25 59/7
59/24 66/15 67/5
67/18 67/24 74/25
75/19 76/11 77/5 77/8
77/14 85/8 92/11
92/12 93/10 95/10
95/15 95/24 103/2
104/23 108/14 108/24
109/7 109/8 114/23
120/1 123/8 144/1
155/4 161/4 163/13
184/12 184/13 186/5
188/11 188/13 188/14
194/15 197/8 198/9
202/1 207/5 209/3
209/9 213/15 217/1
218/8 220/11 220/24
221/1 221/20 222/17
222/18 223/12 223/15]
couldn't [6] 28/11
94/9 186/24 222/9
222/12 223/14
counsel [1] 100/4
counter [22] 9/10
10/5 26/10 31/9 39/5
39/7 39/25 41/4 46/12
46/18 107/21 107/23
187/9 192/19 194/3
207/2 208/13 211/1
211/4 211/12 211/16
215/1
counterclaim [1]
65/21
counters [3] 9/14
55/1 216/20
Counters' [1] 24/10
couple [11] 13/3
37/16 40/3 41/19
43/11 45/1 49/11 91/1
96/14 126/24 183/19
course [11] 39/24
50/13 51/2 52/4 60/15
72/21 106/14 120/18
181/6 205/24 210/10
court [35] 34/6 37/2
37/7 51/17 68/5 68/7
68/10 68/15 68/18
69/7 111/15 115/5
115/8 124/8 130/3
132/21 134/1 134/6
134/7 138/18 149/5
149/22 150/4 152/2
152/8 152/9 152/12
153/18 153/19 153/21
154/18 162/9 172/21
181/18 223/12
Court's [1] 70/5
courts [2] 80/1
154/10
cover [6] 93/19 111/3
112/16 116/18 127/10}
128/17
coverage [1] 128/2
covered [3] 39/23
40/11 130/5
Covid [1] 13/2
CP [1] 97/10
CPU [1] 192/23
cracked [1] 187/13
crazy [1] 49/6
created [2] 170/6
195/21
creating [1] 211/14
credit [2] 8/18 8/22
credited [1] 77/12
crime [1] 80/3
criminal [12] 79/19
79/24 80/7 109/19
131/3 137/9 158/11
158/16 162/9 163/25
180/3 181/4
criteria [1] 220/25
critical [5] 42/9 43/6
43/8 54/3 105/7
Crown [2] 149/5
174/21
crude [1] 18/25
crystal [1] 178/20
Cs [1] 187/18
culture [1] 49/3
curiosity [1] 64/2
current [7] 57/9 72/4
96/6 187/16 213/24
217/10 223/9
currently [2] 199/20
200/4
custody [1] 65/12
customer [14] 24/25
26/18 26/19 26/21
26/23 27/11 27/18
28/19 29/22 31/15
36/14 125/20 212/13
216/25
cut [3] 75/14 101/19
148/22
CV [2] 148/25 149/4
cycle [1] 189/7
D
daily [4] 66/12 66/20
210/13 214/3
Dalmellington [2]
14/2 35/25
damages [1] 180/17
damning [1] 45/20
dark [2] 74/19 92/11
darker [2] 74/19 85/6
data [85] 14/10 16/13
18/23 19/1 19/2 20/4
20/6 20/11 20/12
20/18 22/10 22/23
25/18 26/2 50/21
51/14 59/20 74/5 77/9I
78/5 79/14 79/17 81/4I
82/25 87/18 96/5 96/8)
139/6 139/20 148/13
159/24 160/19 160/20)
162/11 162/13 169/9
181/10 182/1 182/5
182/11 184/1 185/14
185/16 192/5 194/18
194/23 194/23 195/1
195/4 195/6 195/21
195/25 196/8 196/9
196/12 196/13 196/18)
196/21 197/8 197/10
198/4 202/14 202/18
202/19 202/22 203/20)
203/20 204/9 206/5
207/21 209/7 209/16
209/17 209/20 211/23}
212/3 212/7 212/21
216/17 218/12 218/20)
218/22 220/2 220/22
220/23
database [6] 6/2
18/25 19/17 30/16
220/17 223/10
databases [1] 20/9
dataserver [1] 206/2
date [10] 6/21 14/7
91/21 129/4 141/14
147/12 166/8 198/15
204/15 219/13
dated [11] 3/20 4/6
43/25 44/3 55/17 65/2
66/25 73/19 88/2
89/23 136/12
dates [2] 65/10 65/16
Dave [6] 80/13 80/17
125/18 126/5 128/3
213/20
David [8] 40/15 40/24!
110/17 111/6 125/8
125/18 158/5 210/20
Davidson [2] 112/19
113/6
day [22] 19/2 19/25
20/20 30/2 30/2 52/20)
52/20 81/7 100/9
103/2 116/9 127/22
143/1 145/4 145/17
174/13 181/6 181/6
182/14 215/1 223/19
224/18
days [14] 3/1 12/23
13/8 14/18 19/10
19/12 41/20 52/5
57/13 91/12 96/9
128/18 145/15 219/7
de [2] 8/17 8/21
deal [9] 4/20 80/2
(65) consulting - deal
D
deal... [7] 80/3 99/25
139/11 158/7 161/8
219/6 219/16
dealing [6] 4/11 7/3
36/6 67/6 131/1
161/10
dealings [1] 168/18
dealt [2] 69/21
201/19
debit [2] 22/20 27/2
debt [2] 61/6 61/19
decades [1] 197/18
December [6] 13/11
15/2 73/19 79/7 89/24
131/10
decide [3] 30/23
100/16 219/12
decided [10] 1/24
9/16 9/18 13/2 22/2
53/14 55/25 83/21
104/8 193/10
decision [6] 58/17
61/23 62/1 62/3 160/6
160/8
declaration [17]
69/10 122/12 134/13
136/22 149/10 149/17)
149/18 152/21 152/25)
153/10 156/19 158/24
159/8 166/15 191/22
204/18 211/1
declarations [5]
151/13 152/22 210/23
211/9 211/12
declared [5] 98/14
211/2 211/2 211/4
214/5
declaring [1] 210/24
decline [1] 1/19
decode [2] 74/12
75/12
defect [3] 33/14
33/18 185/20
defects [30] 16/7
16/10 17/3 27/25 28/8)
28/12 28/16 28/22
29/19 30/6 30/8 30/12
30/16 31/1 31/11
31/22 32/4 32/20
33/21 34/25 37/23
52/11 160/1 162/19
163/1 163/15 163/17
181/22 186/3 186/5
defence [20] 65/23
66/16 109/22 110/2
122/4 142/2 147/19
148/1 148/8 148/12
161/20 161/21 163/25
174/24 175/17 175/21
176/12 177/2 178/4
179/22
defence’ [1] 178/6
defending [1] 180/16
defensive [1] 47/2
deficiencies [1] 66/7
define [3] 9/19 9/20
35/16
defined [2] 9/17
205/23
defining [5] 8/15 9/6
23/2 23/17 26/24
definition [1] 9/13
definitive [2] 61/20
87/12
definitively [1] 97/2
degree [2] 6/11
180/12
deleted [1] 167/16
deliberately [1] 72/3
delivery [2] 112/20
219/13
demanding [1]
110/23
demands [3] 1/24
108/20 114/23
demonstrate [2]
98/13 166/25
demonstrated [1]
210/2
demonstrates [1]
139/10
den [3] 117/25
118/14 118/15
denied [3] 24/10
24/19 46/3
department [4] 7/18
8/4 114/8 114/8
depend [1] 133/10
depended [1] 190/4
dependent [3] 134/2
134/3 205/19
depending [1] 216/5
depends [1] 17/10
derive [1] 53/20
describe [4] 18/7
18/17 19/15 53/8
described [12] 11/13
30/3 31/18 44/14
44/25 48/20 48/24
55/19 79/9 156/14
182/9 203/13
describes [5] 48/7
126/12 133/18 134/3
203/8
description [3] 53/6
188/18 191/4
design [18] 7/11 7/21
11/20 24/11 24/18
25/7 25/11 27/10
41/11 47/20 48/7 49/3
54/19 55/21 55/22
55/25 62/9 127/21
designed [5] 25/10
53/9 99/20 217/4
217/17
designer [3] 23/6
55/9 199/25
designers [3] 10/15
55/6 221/13
designing [1] 119/21
designs [3] 42/4
42/15 109/8
desks [2] 38/7 38/10
desktop [3] 39/5 39/7]
93/11
despite [2] 66/8
66/10
detail [20] 18/4 21/22
40/10 55/5 90/9
144/11 145/24 152/19!
152/24 153/2 155/6
156/17 156/24 160/15}
161/9 164/12 166/7
169/11 178/17 188/19]
detailed [10] 27/10
77/21 82/7 87/5
100/13 107/23 148/10
153/7 160/18 161/6
details [21] 15/6
25/11 47/1 47/17
60/25 64/6 69/14
90/13 93/20 103/13
104/18 105/3 106/10
115/25 156/20 188/16
190/16 190/22 191/9
212/20 215/17
detect [5] 16/3 17/13
33/24 183/10 197/5
determining [1]
181/24
detract [1] 155/3
develop [2] 10/2
18/13
developed [3] 10/7
20/2 211/20
developers [5] 10/15
191/14 191/20 206/4
221/13
developing [1] 10/4
development [26]
7/13 7/17 10/18 10/22
18/5 19/5 22/25 27/16)
35/6 40/13 41/17 49/4
107/11 187/7 187/16
191/14 191/18 198/23}
199/9 199/11 199/20
199/22 199/23 200/23
201/1 220/3
developments [1]
8/20
diagnose [1] 202/2
diagnostic [1] 201/4
diagrams [1] 56/11
ies [1] 129/4
did [198] 7/5 8/25 9/3
9/15 10/2 10/21 12/9
12/11 13/1 13/9 13/19)
16/16 19/19 21/20
22/3 22/23 23/3 23/25
24/3 24/5 24/17 25/3
25/7 26/16 28/7 28/15
28/17 29/14 30/13
30/25 31/2 31/10
31/14 31/17 31/19
34/23 35/3 36/5 36/23
37/2 37/6 37/13 37/21
38/6 39/17 39/18
39/25 40/3 40/15
40/22 42/13 42/20
42/24 43/3 45/11
47/12 48/7 48/13 50/8!
50/10 50/11 51/4
57/21 58/2 58/7 59/13
62/16 63/8 73/24 79/5
79/7 79/23 80/1 80/6
85/8 88/20 89/9 98/25
102/19 103/3 103/17
104/5 105/4 105/21
105/24 107/14 107/16
107/22 108/6 108/10
108/17 108/19 109/4
109/6 109/20 110/15
110/16 111/21 115/7
115/11 115/22 117/3
119/24 120/2 124/25
125/4 125/8 125/12
126/13 127/15 129/22
131/24 132/6 132/13
132/14 134/19 135/9
135/11 135/24 136/8
136/15 137/3 140/6
141/4 141/8 143/11
143/12 144/9 145/5
145/20 146/1 146/5
146/7 146/9 147/7
152/7 152/11 153/4
153/13 153/16 153/17
153/19 154/9 154/16
155/16 157/9 159/7
159/18 159/21 160/13
163/6 163/23 164/6
164/7 164/14 168/11
168/12 168/14 168/17
168/22 168/25 169/17
169/23 169/25 172/23
174/10 175/19 175/23
178/15 178/21 179/6
179/8 179/11 179/14
179/18 179/21 180/10
180/15 183/20 185/22
186/6 186/13 186/16
186/17 189/19 189/22
190/12 193/14 194/13
198/6 206/3 206/10
207/13 208/8 212/12
213/14 217/24 221/9
didn't [114] 11/17
12/13 13/4 13/12 27/9
29/15 34/10 34/11
36/22 36/24 36/25
37/11 40/11 51/18
52/18 54/6 56/19 58/7
58/25 59/11 59/14
60/6 60/8 63/5 63/11
63/11 72/25 82/15
83/12 83/13 83/22
84/1 89/12 90/15
98/20 101/10 103/1
103/6 103/22 104/16
105/19 106/4 109/11
109/25 113/21 115/18)
123/15 124/11 124/13)
124/15 126/16 126/18}
127/20 130/12 135/1
135/11 135/20 135/21
136/16 136/22 140/8
140/12 141/1 141/11
141/12 147/5 151/4
151/10 151/11 153/23)
154/24 155/2 155/12
155/15 157/20 158/24}
159/25 160/3 162/24
163/2 163/11 164/2
164/2 164/13 164/16
165/1 166/1 167/9
167/17 169/4 169/16
169/22 172/4 180/17
180/19 181/15 184/8
184/19 186/1 188/21
190/15 190/17 190/25
193/8 197/21 203/5
205/10 217/15 222/13}
223/16 223/17
differ [2] 138/15
140/2
difference [10] 11/17
17/25 54/9 79/23 80/9)
98/13 107/20 109/11
109/12 137/24
different [35] 8/5 8/5
14/12 52/19 56/15
78/20 80/1 89/11
92/17 97/24 99/6
106/3 109/2 132/6
132/9 134/23 135/23
138/14 147/9 170/14
175/3 192/17 196/10
196/25 196/25 200/17)
200/18 202/11 203/13
203/22 206/17 208/24
210/24 212/1 221/20
differently [8] 22/2
37/20 94/10 136/3
176/23 180/6 183/18
190/13
difficult [13] 25/16
26/1 35/16 38/6 38/8
TAIT 77122 87/6 96/7
96/10 109/2 216/23
222/9
difficulties [1] 221/17I
diligence [1] 70/21
Dilley [3] 91/15 94/17)
99/15
direct [41] 1/14 15/4
23/24 111/19 113/2
113/8 120/10 154/14
186/14 212/19 217/16
(66) deal... - direct
D
directed [1] 75/1
direction [2] 20/10
93/6
directly [10] 22/4
25/2 25/5 32/17
101/11 111/25 112/15}
113/4 116/23 194/4
Directorate [1] 29/22
disagree [4] 26/3
26/4 36/10 189/13
disagreed [2] 154/25
168/23
disagreeing [1]
203/14
discipline [3] 42/5
42/21 49/6
disclose [12] 79/7
115/1 115/4 115/22
115/23 161/17 162/1
162/25 176/7 177/19
179/18 182/25
disclosed [4] 163/24
174/17 174/20 175/14}
disclosing [1] 72/4
disclosure [17]
105/25 115/8 115/12
115/13 115/17 115/21
116/4 121/8 147/19
147/25 148/19 161/20
161/23 174/23 175/16}
175/20 177/1
discovered [3] 183/1
183/14 194/9
discovering [1]
51/15
discrepancies [14]
16/11 17/3 17/5 59/23
61/25 62/12 63/14
63/18 63/22 194/2
197/9 211/15 211/17
214/14
discrepancy [9] 57/4
59/5 66/13 198/20
203/10 210/9 210/11
210/15 210/18
discrete [2] 16/24
16/25
discuss [8] 80/24
104/5 108/10 108/19
138/7 142/8 201/2
223/25
discussed [10] 64/5
90/23 116/4 142/1
143/17 144/4 146/15
146/21 197/20 200/9
discussing [2] 49/13
144/6
discussion [9] 90/10
90/12 90/24 105/4
111/11 111/14 132/3
139/24 175/22
discussions [4]
58/22 116/1 116/3
116/24
disengagement [1]
42/6
dismissal [1] 67/14
dismissed [1] 65/18
displayed [1] 204/19
displayed’ [1] 204/21
dispute [3] 18/2 71/8
138/11
disputed [1] 133/10
disrupted [1] 186/6
disrupting [1] 16/13
dissatisfaction [1]
217/1
dissatisfied [1]
167/13
distinctions [1]
102/19
distinguished [6]
11/6 11/9 11/13 11/22
12/4 90/7
distracted [1] 14/21
distributed [1] 57/12
puting [1] 57/8
distribution [1] 44/17
disturbing [1] 206/18
do [184] 2/5 2/17 6/7
9/21 9/22 13/13 13/22
14/9 14/11 15/19
15/24 16/7 16/19
19/13 22/2 23/10
24/20 25/9 28/21
30/23 34/10 34/11
36/13 38/9 38/19
38/20 39/17 45/4
45/10 45/15 46/14
46/15 46/19 46/21
46/23 47/11 47/23
48/5 48/6 48/11 49/10
49/13 52/6 52/21 53/9)
54/5 56/13 56/14
56/15 58/5 59/10
60/23 63/13 63/17
63/25 72/8 72/23
72/24 75/4 76/24
82/11 83/9 84/4 84/19)
85/14 85/19 85/25
86/22 89/18 90/10
90/13 90/21 93/9
93/19 95/24 96/2
96/18 98/20 98/22
98/23 101/11 102/7
102/10 103/12 105/6
108/12 108/14 109/7
110/4 111/1 112/8
113/15 113/22 114/19}
115/10 116/11 116/22)
117/15 120/13 120/19)
124/4 124/6 124/20
125/3 125/23 127/2
127/6 127/19 128/13
131/15 132/25 134/8
135/12 136/5 136/24
136/25 144/5 145/2
147/17 147/17 147/20
148/3 154/2 154/3
154/7 154/12 155/21
156/4 156/10 156/18
157/16 159/12 163/2
163/8 163/9 163/12
163/17 164/17 164/19)
168/7 168/24 170/2
170/25 171/20 171/24
172/3 172/18 175/23
176/19 176/25 179/11
180/13 180/17 180/24
180/25 183/18 184/21
186/22 186/23 188/17
202/11 203/23 205/8
206/10 207/19 209/9
212/12 212/24 213/5
213/14 213/15 213/16
215/8 215/12 215/13
216/21 218/5 218/9
219/11 219/19 221/9
221/11 222/17 222/18
document [34] 6/7
44/21 44/23 45/2 45/9
45/11 45/17 45/18
55/22 55/24 56/1 56/2
59/12 61/8 76/1 87/24
88/4 88/5 88/14
103/20 103/22 105/5
105/9 131/11 133/8
140/1 142/6 142/11
143/16 147/9 147/12
147/25 157/17 164/21
documentation [1]
208/9
documentation’ [1]
66/18
documents [35] 5/23
5/25 25/7 27/10 41/11
43/22 45/3 45/3 45/5
49/3 66/4 66/20 70/24
83/9 89/19 89/21 92/9
101/9 132/2 133/15
133/20 134/22 135/5
135/18 136/2 137/1
146/24 147/1 153/5
154/1 154/10 154/17
155/13 175/7 207/23
does [12] 9/12 22/13
44/17 49/19 80/20
127/6 139/7 157/12
191/22 193/1 210/25
216/5
doesn't [5] 87/14
87/17 123/16 151/1
168/5
doing [47] 9/21 10/18
15/7 16/1 19/20 19/21
19/21 20/4 22/4 22/17I
22/21 26/21 34/13
47/8 47/11 50/19
52/20 56/9 60/7 62/6
62/8 72/3 77/20 83/16
89/10 98/16 108/22
108/25 114/18 118/25}
124/15 127/17 127/21
135/13 136/5 146/1
146/2 147/23 148/10
154/25 170/4 178/2
178/12 187/1 193/23
198/21 220/13
don't [106] 12/24
14/21 15/13 16/21
16/22 17/2 22/12 24/6}
25/19 27/6 43/5 43/21
43/23 45/15 45/25
46/6 46/8 46/8 46/15
46/18 47/22 49/14
49/21 49/23 50/9
51/22 56/9 56/20
60/17 61/7 62/5 63/19)
72/23 72/24 73/10
73/10 74/15 78/2 79/6
82/18 83/1 83/19
83/22 85/22 89/6 91/5)
91/6 93/12 93/22
94/22 96/2 97/20
98/16 104/17 105/23
107/16 108/1 108/15
109/5 111/17 116/12
118/2 120/18 125/21
134/21 144/16 146/4
146/6 146/12 146/14
147/7 148/5 153/16
156/16 159/11 161/15}
161/22 163/16 165/11
168/9 168/21 170/9
171/24 172/17 173/4
174/25 176/1 176/18
177/3 179/8 179/13
179/17 179/20 179/24}
185/21 187/21 190/23}
191/2 193/17 200/11
205/17 207/12 209/6
219/24 221/8 221/10
done [58] 19/15
25/12 32/15 37/20
38/11 45/14 55/5 64/1
75/4 94/9 94/10 99/3
100/13 104/9 104/9
104/12 104/14 108/14}
120/19 133/20 133/21
135/9 135/10 135/19
135/21 140/5 141/11
146/18 148/12 150/1
161/1 162/14 164/6
164/18 166/19 176/2
176/16 176/16 180/5
187/15 188/21 190/5
190/7 191/3 205/7
205/18 206/8 206/25
211/1 211/8 219/6
219/21 219/23 221/6
221/12 222/4 222/6
223/15
dotted [1] 40/22
double [1] 66/15
doubt [4] 2/12 60/5
145/23 152/22
doubts [1] 22/10
down [60] 6/6 8/1
21/12 21/19 28/24
28/24 41/25 46/12
48/18 49/10 49/17
56/17 68/4 75/10 77/7
84/22 87/1 88/9 89/15
90/2 92/23 92/24 97/5I
99/13 101/5 101/16
103/20 112/5 113/22
114/15 116/7 117/23
118/5 118/6 120/22
125/16 129/1 129/1
133/23 149/16 157/23}
164/21 166/5 170/15
174/15 178/14 179/25)
182/19 187/5 194/17
195/3 200/3 204/15
205/16 206/11 208/13}
210/1 210/20 213/19
216/7
downgraded [1]
188/8
dozen [5] 8/2 12/22
12/23 35/12 35/12
dozens [1] 180/18
draft [9] 44/15 99/16
99/19 100/1 138/1
138/4 138/16 166/8
166/16
dragged [1] 124/8
draw [2] 70/5 153/20
drawn [7] 66/12 94/3
101/2 102/20 150/4
161/15 221/21
Drive [9] 65/8 65/11
66/1 67/11 67/13
73/19 93/24 98/1 98/5I
driver [3] 61/5 61/13
61/14
drivers [3] 60/20
60/24 60/25
Drop [1] 23/9
dropped [1] 21/8
drops [1] 187/22
DSS [1] 24/22
due [2] 98/13 129/3
Dunce [1] 90/6
Dungannon [2]
198/16 199/16
Dunks [4] 90/4
170/16 171/3 172/20
during [19] 2/14 8/13
10/13 17/18 19/2
19/25 30/17 30/18
31/3 31/4 31/7 34/23
51/22 62/9 109/19
192/10 212/21 214/19)
224/1
duties [38] 70/19
71/16 71/24 71/25
73/3 73/12 90/19
(67) directed - duties
D
duties... [31] 101/2
111/14 114/25 115/8
115/12 115/16 116/4
ATIN7 1241/6 121/7
125/15 132/21 134/6
137/2 137/17 141/5
141/8 145/20 147/5
156/7 157/12 158/9
172/6 173/23 174/3
4174/5 177/1 177/10
178/20 179/6 180/4
duty [28] 68/4 68/9
68/17 68/19 70/20
134/7 134/8 149/21
152/2 152/7 152/9
152/12 153/4 153/14
153/20 154/9 155/12
155/16 155/20 174/23}
175/15 177/17 177/19}
179/10 179/11 179/14]
179/18 185/22
EO
E2E [2] 204/24
204/24
each [19] 9/25 14/18
18/15 29/12 34/7
53/20 54/22 144/1
152/23 158/23 180/3
182/16 192/2 195/12
195/14 195/18 203/21
216/6 216/7
earlier [19] 31/18
73/2 84/24 97/21
120/19 141/18 141/23}
142/7 145/11 145/15
156/17 167/7 172/9
199/24 211/13 218/24}
221/1 222/10 222/17
early [10] 6/18 19/10
19/12 22/18 26/21
52/2 108/6 162/14
186/19 197/9
earnest [1] 96/16
easier [2] 74/12
98/10
easily [2] 139/9
148/14
easy [1] 73/15
economic [1] 37/9
effect [10] 22/6 26/16
61/10 168/8 183/15
184/16 191/7 192/24
198/1 209/16
effective [1] 207/22
effectively [13] 30/16
39/14 49/20 101/14
108/18 132/11 139/12
141/23 161/2 182/16
188/5 212/2 223/5
effects [7] 28/25
188/15 188/17 190/21
190/24 193/16 201/11
efficiency [1] 60/22
effort [7] 126/25
148/17 180/8 180/12
180/16 194/11 216/14)
efforts [1] 176/8
eg [1] 77/11
eg as [1] 77/11
either [11] 36/18 38/3
42/23 45/5 72/5 72/24
91/8 93/5 103/23
109/10 218/21
elapsed [1] 148/18
electronic [1] 57/8
eliminated [1] 192/22
Ellis [4] 90/7
else [13] 10/22 23/5
33/12 72/10 127/6
127/10 142/13 144/15)
154/19 158/3 175/11
217/12 220/3
elsewhere [2] 61/17
182/14
email [69] 30/20
36/18 38/11 66/24
73/18 73/19 74/6
75/14 75/24 80/11
83/4 83/8 84/5 84/22
84/25 85/10 88/2
88/16 88/17 91/13
92/24 92/25 94/5
94/14 95/19 97/21
97/22 99/14 101/14
101/19 101/20 102/20)
104/19 108/5 112/6
113/3 113/4 116/8
116/20 117/6 117/24
118/15 119/9 119/10
120/19 123/7 123/12
123/16 125/17 125/19)
129/2 129/14 129/15
1341/9 131/17 141/13
144/10 161/22 167/20)
170/16 187/5 190/9
191/11 203/6 212/9
212/10 213/16 213/19)
219/22
emailed [2] 101/10
166/8
emails [14] 38/3
84/16 85/21 103/14
103/18 110/1 112/1
123/3 126/1 144/16
145/10 161/18 163/20)
171/18
embedded [1] 205/3
emerged [3] 207/10
207/20 221/4
emphasis [1] 17/25
employee [4] 71/3
91/3 132/10 140/9
employees [2] 11/12
74/22
employment [1]
34/23
enable [3] 54/15
139/8 187/13
enabled [1] 20/23
enclosed [2] 68/13
69/12
end [34] 4/9 4/12
9/22 13/9 13/12 14/9
19/18 19/19 20/1 20/8}
53/3 53/10 54/16 61/4
72/1 80/22 102/24
107/21 108/8 118/1
120/3 139/19 139/19
142/11 149/10 152/20
152/25 157/11 164/22
193/11 204/24 204/24)
206/14 215/1
endeavour [1] 70/2
ended [3] 11/3 90/14
104/4
ending [1] 203/17
enforce [1] 59/12
engage [3] 46/20
47/19 47/24
engaged [3] 72/1
132/3 139/24
engagement [2]
112/22 128/15
engine [2] 23/21 27/1
engineer [7] 11/6
11/9 11/13 11/22 12/4]
90/7 107/7
engineering [2]
54/21 176/3
enhancement [1]
190/10
enjoy [1] 178/21
enjoying [1] 127/21
enough [4] 42/23
49/8 100/16 184/24
enquiries [1] 174/18
enquiry [1] 74/21
ensure [4] 25/17 26/2!
57/1 220/10
ensured [2] 174/16
221/24
ensuring [1] 20/22
entail [3] 34/24 73/13
158/20
entailed [1] 180/5
entered [9] 66/9
67/21 67/22 75/21
76/8 76/13 76/15
76/23 77/3
entirely [4] 43/16
65/24 177/21 179/21
entitled [2] 26/6
153/24
entry [7] 66/9 66/11
66/12 139/6 205/15
206/12 210/21
environment [9] 19/6
19/7 110/10 207/10
207/20 208/18 208/21
208/23 209/1
EPOS [4] 39/8 40/5
49/19 51/20
EPOSS [38] 24/19
25/16 38/14 38/16
38/20 38/23 39/17
40/13 41/4 41/17
41/21 42/9 42/13
42/19 42/22 43/4
43/10 43/19 44/7 44/9
44/12 45/16 45/21
46/9 46/19 46/25
48/25 49/15 50/6
187/7 187/8 187/9
191/19 197/19 197/22}
199/9 199/23 206/23
equip [1] 92/5
equipped [1] 139/11
equivalent [3] 32/13
128/7 131/25
error [15] 33/13
33/18 57/9 57/13
65/14 66/23 67/24
77/5 77/10 77/11
77/13 79/11 176/20
185/19 201/15
errors [42] 16/6
16/10 17/2 27/24 28/8}
28/12 28/16 28/22
29/19 30/6 30/7 30/12
31/1 31/11 31/22 32/3
32/20 33/21 34/25
37/23 52/11 57/1 57/3)
57/19 67/17 75/18
76/10 81/13 85/3
138/9 138/12 139/6
162/19 162/25 163/15
163/16 181/21 186/3
186/5 192/24 196/25
201/12
escalated [2] 201/1
213/25
Escher [17] 18/21
24/4 24/6 39/1 39/10
41/20 47/6 47/9
186/10 187/9 187/16
188/12 188/23 189/19}
189/19 189/23 191/1
Escher's [1] 205/19
essentially [14] 4/13
13/9 53/3 55/22 83/4
88/16 96/21 100/20
103/23 131/15 147/18
167/19 169/8 202/23
established [1]
144/24
estate [7] 201/6
203/5 205/11 207/11
207/13 209/2 209/4
et [11] 67/9 69/17
69/19 70/25 80/13
102/9 102/9 150/21
170/21 179/5 188/9
et cetera [9] 67/9
69/17 70/25 80/13
102/9 102/9 150/21
170/21 188/9
evaluation [1] 190/5
evasive [1] 48/17
even [14] 16/15
22/15 60/8 67/23 77/4I
93/11 123/5 176/9
190/1 211/7 217/1
217/6 219/23 219/25
evening [3] 14/14
172/24 224/3
event [12] 33/7 91/7
106/2 161/13 162/15
162/20 167/18 174/12)
183/2 192/23 193/1
206/8
events [7] 50/4 51/13
69/3 162/15 183/4
183/9 186/20
eventually [3] 15/10
22/3 90/14
ever [13] 45/11
108/10 108/19 115/7
115/11 161/25 163/16)
193/17 207/10 207/12)
207/20 221/6 221/9
every [8] 15/13 20/14
41/20 160/17 178/23
185/2 192/2 201/17
everybody's [1]
91/25
everyone [5] 10/22
42/10 43/7 43/9
129/18
everything [5] 53/20
77/21 85/15 165/3
170/20
evidence [98] 2/1 3/1
5/20 13/18 33/20 37/2I
40/14 41/25 45/23
50/1 50/4 51/15 51/19
52/10 52/17 52/19
60/19 63/17 63/19
67/3 68/7 68/9 69/12
85/23 90/11 90/12
90/14 91/3 91/9 94/4
97/1 101/7 101/10
101/12 102/8 102/8
102/20 102/21 103/6
104/1 104/4 104/13
104/15 104/23 104/23)
106/6 106/23 111/12
111/15 117/16 120/25)
121/1 121/20 128/8
128/9 128/12 129/17
131/2 131/4 134/20
134/21 139/4 139/7
139/10 140/6 148/1
148/19 150/18 155/7
156/1 158/11 159/15
162/9 164/9 164/25
165/21 168/19 170/14)
171/20 172/2 172/21
(68) duties... - evidence
E
evidence... [17]
174/10 175/12 176/20)
177/7 178/16 181/5
185/3 186/4 186/7
192/17 192/24 193/18)
216/24 220/15 221/1
223/12 224/1
evidence' [1] 102/9
evidential [1] 102/7
evolution [1] 23/10
evolved [1] 108/17
exact [7] 7/23 9/1
14/7 145/9 189/20
211/22 212/14
exactly [42] 6/17
9/17 11/11 15/6 17/10
25/10 37/24 41/21
44/24 54/8 55/7 58/5
59/16 62/14 63/10
64/5 67/9 78/1 78/22
84/14 89/8 120/6
125/21 128/20 130/4
137/3 145/8 145/13
146/21 153/2 153/8
163/8 165/25 171/12
185/12 187/24 188/25
190/4 190/8 190/11
190/22 191/24
examination [1]
160/19
examine [1] 67/10
examining [1] 220/4
example [16] 20/11
20/12 25/15 54/22
113/1 139/13 151/2
151/19 180/9 182/14
182/19 185/25 196/21
197/3 197/4 215/18
examples [2] 110/1
112/4
exceeding [1] 66/3
excellent [1] 116/8
Except [1] 81/15
exception [1] 13/5
exceptions [1] 189/9
excessive [1] 215/13
exchange [10] 38/3
108/5 117/24 119/3
123/12 125/17 164/20}
212/10 212/20 213/16
exchanges [4] 114/4
128/7 128/11 167/21
Executive [1] 112/20
exercise [8] 95/3
95/10 95/16 140/18
165/9 187/17 215/8
215/12
exhibit [2] 4/12 99/19
exhibited [1] 5/22
exhibits [1] 136/11
existed [2] 20/22
220/12
existence [10] 28/12
28/12 30/7 33/20
33/21 34/7 42/14
52/10 73/3 223/11
existing [2] 57/17
70/15
expand [1] 160/5
expect [5] 80/16
93/20 96/8 98/19
223/8
expectation [2]
12/21 163/23
expected [5] 10/18
41/8 122/22 123/14
211/7
expecting [3] 169/11
185/8 185/13
experience [9] 12/2
36/6 133/5 135/5
167/2 168/10 169/17
183/8 183/22
experienced [1]
70/22
experiment [1] 69/16
expert [75] 69/12
70/13 70/23 73/3
73/12 90/19 91/3 94/4
97/1 101/2 102/20
107/15 109/1 115/9
116/18 121/2 121/7
121/19 122/4 122/5
122/12 123/14 126/13)
126/14 126/15 128/13)
129/12 129/22 129/23)
130/6 130/9 130/10
130/12 131/13 131/19)
131/21 131/24 133/18)
134/13 136/21 138/2
140/13 142/2 145/21
147/5 147/21 148/8
149/25 152/21 152/21
152/25 153/9 155/17
155/18 156/19 166/15)
171/8 171/22 171/25
172/3 172/5 173/24
174/4 174/21 174/24
175/17 175/21 176/12)
177/2 177/11 178/19
178/25 179/22 180/2
206/5
expert's [7] 71/16
125/14 137/2 149/17
149/18 152/17 158/9
expertise [7] 28/4
36/3 38/22 68/11
135/17 150/3 171/21
experts [4] 67/16
148/12 152/15 157/7
experts’ [2] 67/5
151/25
explain [11] 14/4
32/10 36/12 67/8
74/25 99/21 107/4
107/10 127/8 179/18
179/21
explained [8] 92/16
104/21 115/9 161/12
165/14 177/13 177/19}
178/22
explaining [5] 32/13
85/8 129/14 174/2
207/6
explanation [20]
67/18 68/1 75/19
76/11 76/18 77/15
77/18 77/20 77/23
78/14 78/15 82/3
82/20 87/5 90/19
102/14 183/24 185/18
185/18 206/13
explicitly [3] 62/14
138/15 176/16
explore [2] 175/7
197/15
explored [2] 175/8
188/11
express [2] 70/5 70/9I
expressed [3] 68/25
150/2 153/15
expresses [1] 217/25I
expressing [2] 96/21
133/9
expressly [1] 168/25
extended [1] 128/19
extensions [1] 93/16
extensive [4] 90/19
138/9 147/4 200/24
extensively [1]
145/22
extent [9] 49/19
52/13 110/24 116/3
150/13 165/14 175/19}
177/1 186/7
external [1] 116/23
extracted [1] 187/14
extracting [1] 20/6
extracts [1] 96/12
extreme [1] 169/20
extremely [2] 95/5
105/12
eye [1] 30/3
F
fa 124/2
facilities [1] 223/13
facility [2] 60/10 92/5
fact [43] 3/5 14/12
25/24 33/22 34/9
47/12 51/12 51/21
58/25 66/4 66/8 78/22
79/21 83/6 87/15
87/17 88/20 89/8
90/25 103/3 113/6
127/18 131/11 133/11
133/19 135/25 138/7
138/9 139/4 142/16
144/24 164/8 171/25
173/5 194/15 202/11
202/17 206/4 212/24
213/5 217/18 219/23
220/7
factor [1] 187/21
facts [10] 43/15
43/18 68/21 68/23
69/1 76/21 104/24
150/20 157/3 165/16
factual [3] 70/8
133/10 150/8
FAD [1] 200/17
failed [3] 66/11 119/5
206/23
failing [1] 192/21
failure [17] 51/14
192/18 192/18 193/1
194/19 196/22 198/4
203/20 204/10 205/21
206/21 209/11 209/16
218/12 218/24 220/2
220/23
failures [4] 197/8
197/11 202/22 209/7
fair [3] 14/25 55/4
109/18
fairly [17] 11/19
14/17 22/24 28/25
48/12 48/13 50/11
51/6 54/3 80/10 95/25)
107/16 119/16 123/2
171/16 191/4 212/15
fairness [1] 1/24
faithfully [5] 81/14
81/15 81/19 81/21
138/17
false [2] 69/7 170/6
familiar [4] 116/11
151/22 152/14 156/7
far [21] 7/4 21/15
24/18 25/19 51/18
53/9 63/1 66/18
102/17 102/24 102/25
112/16 115/13 129/23}
136/4 144/6 146/11
159/22 160/8 185/6
195/2
fault [6] 65/25 182/18
188/22 199/12 200/25
206/15
faults [5] 159/4
159/10 159/12 160/1
223/1
favour [1] 166/18
feasibility [1] 219/4
feature [1] 206/20
February [8] 3/20
66/14 110/17 125/9
147/13 161/22 210/5
210/22
feedback [2] 166/12
178/4
feel [14] 78/2 96/11
100/2 105/19 109/20
117/3 124/15 159/7
159/25 168/11 168/12
168/14 177/18 179/15)
feeling [1] 79/11
fees [2] 68/8 134/2
fell [1] 136/3
felt [26] 14/3 15/24
17/22 18/3 34/14 36/7I
36/11 40/2 47/7 60/3
60/13 83/17 108/22
110/22 111/2 113/11
114/17 117/9 120/1
120/1 132/8 151/9
160/22 183/3 184/24
202/1
Feltham [4] 43/10
43/11 46/7 48/18
fester [1] 37/14
few [11] 8/22 13/15
13/21 22/16 22/19
24/3 28/24 126/11
203/7 210/11 219/7
field [1] 150/3
fielding [1] 221/22
fifth [2] 3/4 3/16
figure [1] 7/25
figures [8] 60/1 60/3
94/19 95/5 95/12
95/13 210/12 210/24
file [2] 187/14 187/16
files [1] 19/24
filled [1] 11/23
final [7] 80/19 138/12
189/12 189/14 214/18)
221/14 222/8
finalised [2] 44/3
44/14
finances [1] 54/9
financial [1] 37/9
find [10] 37/7 41/23
50/11 50/23 96/1
159/1 176/8 184/12
207/13 220/21
finding [4] 16/19
16/21 16/22 91/19
findings [2] 17/2
137/22
finds [1] 206/1
fine [5] 86/16 86/22
102/12 210/17 224/5
finish [1] 80/22
finished [2] 144/19
145/6
first [48] 3/19 11/5
12/15 16/19 18/7 21/6)
27/22 39/14 39/23
40/10 54/10 55/19
61/9 61/23 65/6 71/16
71/18 72/1 73/8 73/18}
81/3 82/13 84/21 85/1
85/21 90/3 93/4 95/9
99/16 99/19 100/1
101/22 114/1 114/2
118/19 131/17 142/15)
144/22 146/19 169/12!
(69) evidence... - first
F
first... [8] 191/14
194/18 203/22 203/24}
203/25 218/11 218/21
219/13
firstly [8] 15/16 18/17
32/10 32/22 78/4
120/25 192/18 202/25
fit [1] 178/11
‘ed [1] 108/24
ing [1] 127/23
five [12] 2/23 5/18
13/8 151/8 167/7
199/4 199/7 199/10
202/15 213/1 217/21
217/23
five-week [1] 217/21
fix [7] 51/6 189/5
201/4 201/8 207/21
208/5 211/20
fixed [19] 32/17
32/18 33/25 37/13
51/4 51/8 51/25
160/13 189/8 189/14
189/24 190/15 190/17)
191/7 203/1 203/10
208/4 208/8 222/10
fixes [1] 189/23
fixing [4] 32/15 32/16
34/25 222/21
flag [1] 120/7
flaws [2] 15/20 16/23
flexibility [1] 58/15
flippant [2] 173/3
173/4
flow [2] 20/10 54/2
flowing [1] 54/2
fly [2] 14/19 41/19
fobbed [1] 217/14
fobbing [1] 217/3
focus [4] 59/16 62/6
109/3 109/13
focused [2] 127/25
181/10
focusing [1] 52/6
Folkes [1] 23/25
Folkes' [1] 27/8
follow [2] 86/16
99/25
followed [2] 216/6
220/16
following [8] 42/18
67/7 69/4 75/1 146/9
204/17 222/19 224/8
follows [4] 102/4
131/11 140/21 202/24
font [2] 148/4 148/4
foot [8] 55/17 73/18
87/23 167/25 201/3
206/12 207/17 210/21
Force [4] 43/19 44/8
44/10 46/10
forced [1] 111/21
forgotten [3] 91/4
91/5 219/23
form [6] 1/23 49/8
69/5 99/6 99/6 139/8
formal [7] 24/15 67/6
95/16 108/15 119/1
164/20 180/1
formalisation [1]
117/14
formalise [1] 75/5
formalised [4] 29/13
42/4 42/14 44/24
formality [1] 119/4
formally [3] 42/17
95/8 127/17
format [2] 49/5
140/21
formed [1] 165/19
forming [2] 70/11
150/11
forms [1] 11/24
forthcoming [1]
144/14
forum [2] 200/12
201/5
forward [7] 66/8
67/15 108/18 117/1
166/22 173/10 206/11
forwarded [2] 100/5
112/1
forwards [7] 95/19
116/6 117/21 132/16
136/9 147/8 210/19
found [21] 14/1 16/8
30/17 50/13 51/1 52/2
91/23 98/19 161/4
173/8 178/10 183/5
189/23 193/17 199/13}
202/8 208/3 208/4
208/6 220/24 221/1
four [6] 167/6 200/20
202/15 213/1 217/21
217/23
fourth [19] 5/10
10/15 10/17 10/21
11/1 27/21 28/2 30/11
32/25 33/9 33/13
182/8 201/17 221/6
221/11 222/8 222/15
222/22 222/23
fourthly [1] 122/10
fraction [1] 10/25
frank [2] 174/23
175/16
Fraser [1] 15/16
fraud [7] 58/21 74/20
77124 78/14 78/17
79/9 85/1
free [1] 49/5
frequent [1] 126/20
frequently [1] 125/4
fresh [1] 205/25
Friday [1] 128/22
front [6] 3/8 56/6
97/15 99/8 99/8 104/2
frontline [1] 221/22
frustration [1]
219/16
FS [2] 215/4 215/6
FUJ00056677 [1]
197/14
FUJ00062016 [1]
204/2
FUJ00066601 [1]
204/2
FUJ00080690 [1]
43/24
FUJ00083596 [1]
187/4
FUJ00083741 [1]
170/15
FUJ00086315 [1]
191/11
FUJ00086456 [1]
210/3
FUJ00086462 [1]
212/10
FUJ00086553 [1]
204/2
FUJ00122279 [1]
99/13
FUJ00122283 [1]
100/8
FUJ00124313 [1]
147/8
FUJ0015 [1] 86/25
FUJ00152290 [1]
97/5
FUJ00152292 [1]
97/25
FUJ00152573 [3]
64/25 84/3 87/22
FUJ00152605 [1]
92/22
FUJ00152866 [1]
125/16
FUJ00152872 [1]
131/8
FUJ00153986 [1]
116/6
FUJ00154713 [1]
73/17
FUJ00154722 [1]
91/12
FUJ00154727 [1]
94/13
FUJ00154733 [1]
101/16
FUJ00154747 [1]
103/9
FUJ00156248 [1]
141/13
FUJ00229801 [1]
117/22
Fujitsu [76] 6/16 7/4
10/13 11/16 12/17
14/10 18/8 19/20
25/10 25/12 32/11
34/23 52/12 54/13
56/4 56/12 65/4 65/7
66/24 66/25 67/10
71/4 73/24 89/12 90/7,
91/3 95/4 95/10
108/11 108/19 110/15}
110/19 110/20 110/21
110/23 113/14 114/3
114/10 115/3 115/11
115/15 116/3 124/7
124/20 125/3 128/11
132/11 136/1 138/2
140/9 140/13 141/20
142/21 144/15 158/5
161/14 164/9 170/1
174/19 177/25 178/18
182/6 182/7 186/5
189/22 190/2 193/8
197/7 203/9 203/14
209/24 215/7 215/16
215/22 220/5 220/9
Fujitsu's [5] 23/18
27/11 89/5 90/1
202/21
full [10] 1/11 33/19
88/10 98/17 98/19
127/20 175/3 185/3
189/7 193/24
full-time [1] 127/20
fuller [1] 221/2
fully [3] 112/23
188/11 216/22
function [8] 30/2
49/19 73/22 109/16
132/7 135/23 201/22
221/19
functional [1] 178/21
functionality [3] 9/10
22/17 62/2
functioning [1] 50/6
functions [2] 56/24
57/4
fundamental [1] 70/1
fundamentally [1]
80/19
funding [1] 219/19
further [28] 1/13 5/15
5/24 12/1 13/4 66/19
75/10 78/3 80/24
92/24 103/12 106/6
118/6 124/16 125/13
142/10 143/6 194/9
195/12 199/7 199/15
199/21 200/21 207/23}
208/8 213/14 217/10
219/23
future [3] 160/13
172/25 197/6
FYI [1] 88/17
G
gain [3] 38/22 163/13
204/20
gangs [1] 69/5
gap [1] 214/38
Gareth [23] 1/5 1/7
1/12 36/19 40/18 41/3)
42/7 46/12 81/8 81/12
85/16 85/17 88/12
95/11 99/17 99/20
116/22 118/20 129/11
138/1 174/21 216/19
225/2
Gareth's [1] 219/4
gave [10] 82/7
106/23 114/14 121/1
131/2 144/23 156/1
178/16 185/2 219/9
general [10] 17/7
17/21 34/15 107/1
110/24 152/20 185/10)
185/11 186/3 197/24
generalised [1]
34/21
generally [7] 30/12
31/21 34/19 38/8
146/24 183/12 216/21
generate [1] 187/15
generated [2] 20/11
196/3
generic [7] 160/24
169/6 169/21 169/25
170/10 185/7 185/8
genuine [1] 208/4
get [52] 14/23 24/17
25/14 30/20 31/7 35/7I
35/7 35/10 35/14
36/17 36/22 38/10
40/12 46/12 47/24
50/8 51/4 53/23 58/17I
58/24 58/25 96/5
97/14 100/13 103/2
108/6 108/7 108/8
111/9 112/2 117/12
118/3 119/18 124/18
128/19 142/11 146/2
162/13 165/18 165/18)
168/20 169/11 169/24)
175/12 178/17 190/17)
197/15 205/25 208/8
217/1 217/6 222/23
gets [2] 119/2 212/3
getting [12] 26/19
35/20 38/9 62/24
110/23 123/3 123/4
124/22 124/25 178/4
210/24 213/6
GlJ [2] 118/17 118/21
give [43] 1/11 1/25
3/1 5/16 33/19 34/6
34/21 36/20 37/2 50/1
50/4 68/7 69/13 69/14I
69/18 69/23 72/15
77/19 82/25 85/23
89/24 101/7 101/10
101/12 103/6 104/13
104/22 104/23 117/16)
118/4 121/20 125/12
(70) first... - give
G
give... [11] 127/5
145/1 150/18 159/14
164/10 166/16 171/20
177/16 179/10 215/20
219/14
given [40] 11/1 12/6
15/2 20/21 28/9 28/16
51/15 52/4 52/6 53/2
53/8 59/4 59/21 63/21
68/24 70/1 72/16
78/10 82/20 84/16
90/12 91/2 95/1 96/8
96/10 96/25 97/18
102/18 103/25 105/25
111/15 133/16 135/15
158/8 160/16 174/4
181/11 182/2 189/6
200/18
gives [1] 45/20
giving [25] 51/19
52/10 52/17 52/19
68/9 72/2 90/11 90/14
91/9 104/4 104/15
111/12 120/25 128/8
128/9 131/4 134/19
134/21 140/6 161/2
168/19 177/7 184/17
185/10 223/12
GLO [4] 15/10 180/11
197/23 222/6
go [64] 1/13 3/19 4/5
13/21 32/8 35/4 38/6
38/7 39/18 44/5 47/9
53/14 55/19 56/22
79/16 81/6 84/3 84/22
85/14 86/25 87/1
87/22 87/24 88/13
90/9 98/11 100/10
101/17 103/18 106/5
106/9 119/11 120/2
123/12 123/13 130/3
132/18 132/21 134/5
136/9 137/19 137/21
137/22 139/13 140/17
145/5 149/12 149/16
154/18 166/22 167/24)
179/9 185/6 187/17
189/3 199/4 205/10
206/11 210/19 219/10
219/12 222/15 222/21
224/3
goes [1] 142/20
going [82] 5/21 13/24
16/3 17/13 20/19 22/2
25/20 26/25 29/24
31/7 32/7 36/21 37/6
43/14 45/19 47/9
49/10 52/3 53/22
53/24 65/1 71/12
76/22 76/25 82/1
84/10 85/18 87/7
87/25 90/9 92/19
98/12 99/8 103/8
104/2 105/18 106/22
107/18 111/2 113/13
113/18 114/1 114/11
114/13 114/20 116/41
116/25 119/17 120/18)
120/20 120/24 123/12)
123/21 128/15 132/2
132/20 133/6 133/6
133/16 140/22 148/25)
149/12 152/1 153/2
155/6 161/8 164/14
164/16 165/6 166/6
167/6 169/23 176/4
177/8 198/8 201/7
204/4 206/13 214/19
218/14 218/15 218/15
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77/21 88/25 91/7
115/21 152/23 160/12)
182/19 183/25 192/11
210/18
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16/1 33/24 36/7 36/11
41/23 54/7 57/19
64/19 65/13 82/19
102/6 106/19 107/17
107/25 124/23 130/24}
131/1 173/18 184/23
189/4 194/25 220/19
gory [3] 15/6 47/1
106/10
got [43] 3/8 3/23 3/24
4/8 7/25 11/18 13/25
17/23 19/10 21/8
32/12 33/24 35/17
35/20 36/1 39/15
45/14 71/20 72/1
84/25 98/18 100/21
102/18 107/22 108/8
123/15 123/18 124/1
124/21 130/13 142/16)
146/10 146/14 148/5
162/18 170/25 172/3
190/15 202/13 202/15)
205/3 221/17 222/24
grade [1] 8/3
grades [1] 8/5
gradually [1] 23/8
graduated [1] 6/10
graduation [1] 6/13
Graham [17] 75/2
75/3 81/10 84/8 84/11
85/18 86/2 86/7 86/18)
87/24 87/25 91/16
167/3 212/11 212/12
212/13 213/20
great [2] 177/9 219/6
greater [4] 125/5
191/23 210/10 224/2
grey [1] 75/17
ground [1] 2/6
group [5] 10/14 13/5
50/14 50/18 51/2
guarantee [1] 209/14
guess [4] 75/11
93/18 95/24 223/15
guessing [1] 200/12
guidance [34] 69/12
91/2 94/3 96/24 97/18
122/21 123/14 124/1
124/16 124/17 124/21
124/23 124/24 124/25
125/5 125/8 125/13
125/13 142/10 142/15]
142/25 143/4 143/6
143/8 143/8 143/11
143/14 143/24 144/14
146/2 148/15 162/10
169/25 217/9
guide [1] 10/5
guns [1] 168/23
guys [1] 157/10
H
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31/20 61/8 83/6 83/20
97/2 135/10 144/19
151/3 156/23 161/19
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73/8 94/24 119/9
131/9
halfway [1] 200/3
hand [3] 36/20
198/16 217/18
handle [1] 54/7
handled [1] 172/20
handling [1] 53/16
hangouts [1] 13/22
happen [5] 18/24
56/3 164/14 164/16
193/17
happened [26] 6/17
18/2 19/24 30/18
33/16 52/21 52/22
53/25 63/7 76/23
77/23 78/6 78/23 89/8
90/21 110/6 110/9
111/9 128/14 161/5
165/8 170/12 185/12
188/19 189/21 202/25]
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45/16 50/5 51/14
52/15 107/20 107/21
110/8 114/6 114/12
114/22 116/25 130/7
143/19 165/3 165/4
165/13 169/23 182/3
186/21 186/25 208/22)
216/24
happenstance [3]
33/1 33/11 33/17
happy [15] 80/24
87/8 87/9 87/10 87/20
89/7 100/15 106/10
115/21 142/11 148/11
155/2 155/3 217/3
218/17
harden [2] 167/19
168/6
Harding [2] 60/19
62/9
harm [14] 191/5
harmful [2] 190/21
190/24
harvesting [2]
195/22 195/23
has [56] 1/18 6/2
48/24 52/21 56/6
56/24 57/14 65/19
66/5 66/11 69/11
75/24 77/21 77/22
81/15 81/19 82/4 82/8)
82/20 84/13 85/6
86/19 88/22 88/25
103/19 114/25 116/18}
116/22 134/7 138/24
139/17 142/8 150/10
170/20 189/12 192/19}
193/1 195/10 195/16
198/20 198/25 200/16
200/21 200/24 204/23
206/20 206/21 206/23,
211/12 213/25 217/6
217/11 219/6 219/8
219/25 220/15
hasn't [8] 21/14
81/19 81/22 82/9
98/17 133/21 133/22
216/22
have [297]
haven't [7] 73/13
73/15 84/25 100/21
146/13 150/23 161/18}
having [19] 26/18
35/18 36/9 38/19
46/15 46/19 49/14
54/7 75/13 106/2
114/19 117/6 123/5
162/17 165/1 177/3
219/16 219/17 221/18
he [169] 15/18 15/22
15/23 15/23 16/5 16/8
16/9 18/1 23/7 24/4
24/4 24/7 24/8 24/9
24/12 24/13 25/24
40/17 41/2 41/7 41/16
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43/15 45/1 45/23
45/25 45/25 46/11
46/17 46/17 46/20
46/25 47/2 47/5 47/7
47/19 47/19 47/24
47/24 48/7 48/17
48/17 48/25 49/1
49/14 65/11 65/18
66/3 66/19 66/20
73/23 80/17 82/4
83/13 83/16 83/16
83/17 83/17 83/21
86/11 88/1 88/20
93/18 99/17 102/1
102/5 110/18 110/19
110/21 116/18 117/1
125/10 125/20 126/12)
126/19 128/4 132/7
132/10 132/22 133/1
133/7 133/8 133/13
133/16 133/18 133/19)
133/21 133/21 133/22)
133/24 134/2 134/3
134/5 134/6 134/7
134/9 135/2 135/4
135/5 137/22 137/24
138/4 138/13 140/1
140/11 140/14 140/17)
140/20 141/15 141/20)
141/22 144/2 144/3
147/2 147/3 148/9
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149/1 149/12 166/17
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168/15 168/16 172/22)
174/22 175/12 175/13}
175/14 175/17 176/24}
176/24 177/10 177/18}
177/20 178/10 179/6
179/8 179/11 179/11
179/14 179/18 179/21
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189/13 189/13 189/18)
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205/25 206/4 206/4
206/7 206/16 210/21
210/21 212/14 212/15]
212/18 212/18
he'd [4] 83/21 86/3
147/2 173/7
He'll [1] 100/3
he's [8] 40/25 65/20
86/5 90/6 133/15
133/20 206/7 206/15
he/she [1] 205/25
head [2] 92/7 141/22
headed [1] 157/18
heading [1] 213/20
hear [5] 1/3 64/19
106/19 130/24 173/19}
heard [8] 29/5 40/14
60/19 105/2 172/24
186/4 186/7 220/15
hearing [2] 22/12
224/18
hearings [1] 115/20
hearsay [2] 25/1 25/3)
held [1] 138/13
Helen [4] 118/7 118/9)
118/9 120/5
help [14] 14/4 32/10
68/10 72/13 96/11
96/19 119/1 120/13
124/8 144/1 145/2
146/3 178/14 202/2
(71) give... - help
H
Helpdesk [3] 104/25
173/2 173/8
helped [1] 18/13
helpful [4] 36/3 91/24
120/14 178/11
helping [1] 56/11
hence [2] 102/22
173/2
her [18] 99/4 104/5
104/10 104/11 105/4
105/5 105/17 105/17
105/21 105/24 106/2
106/8 110/24 118/17
120/16 137/14 139/11
218/19
here [29] 60/7 62/18
62/19 65/1 72/13
73/11 79/9 85/23
112/23 118/10 120/11
121/17 124/8 143/18
151/14 151/16 161/10}
161/24 167/18 168/18
171/3 172/2 172/12
173/2 174/12 176/20
185/23 190/14 217/25)
here's [2] 100/20
123/6
hers [4] 119/13
hesitation [4] 184/5
184/10 184/21 185/20)
Hi [1] 116/15
hid [1] 63/14
hide [4] 46/4 58/21
62/12 63/22
hiding [2] 46/8 63/17
hierarchical [1]
195/8
high [3] 15/15 169/10
195/2
high-level [1] 169/10
higher [1] 161/1
highest [2] 188/9
210/15
highlighted [2] 92/3
205/15
him [31] 1/19 24/3
24/7 37/4 40/15 40/16
41/8 41/23 43/17
46/15 46/19 48/17
48/21 65/19 80/19
83/15 84/13 125/9
132/4 133/21 137/24
138/19 139/24 144/6
148/10 149/9 149/13
175/18 175/19 177/18
178/14
himself [1] 133/18
hindsight [4] 34/12
37/19 168/5 208/12
his [70] 16/19 16/22
17/2 24/6 45/23 46/20)
47/25 49/10 65/13
65/15 65/21 65/24
66/2 66/16 66/22
67/14 74/23 75/24
83/23 88/16 88/20
125/21 126/2 126/7
132/3 132/17 132/22
133/1 133/14 133/17
133/18 134/2 134/4
134/6 134/6 135/4
135/4 135/5 135/6
135/14 137/23 138/3
138/4 138/9 138/16
140/1 140/15 140/20
140/20 141/10 141/15)
145/22 147/1 148/23
148/24 152/2 172/21
174/10 174/13 176/20)
177/13 177/19 177/20}
178/11 178/12 189/20)
191/20 206/6 206/12
212/14
historically [2] 62/11
62/17
history [1] 93/24
hoc [3] 14/17 39/12
126/23
hogging [1] 192/23
hold [7] 66/17 83/24
96/5 134/19 135/9
157/9 176/11
holdings [2] 98/14
98/14
holiday [1] 49/5
home [3] 29/8 40/3
224/3
homed [1] 219/8
honest [1] 69/9
honestly [1] 219/22
honorific [1] 11/15
honour [1] 11/19
hope [3] 93/4 98/6
219/18
hopefully [1] 93/5
hoping [1] 215/12
Horizon [142] 7/8
8/23 8/25 9/3 9/7 9/13
9/15 10/16 10/16
13/10 13/16 13/19
15/1 15/11 15/16
15/19 15/24 16/20
16/22 17/16 18/5
18/10 26/2 26/25 28/7I
29/19 30/5 30/25 31/3
31/10 31/12 31/23
31/25 31/25 32/2 32/2
32/20 33/18 33/19
33/21 35/17 35/21
36/1 38/16 40/14
41/13 41/15 42/12
52/11 54/15 55/2
57/12 59/17 60/2 60/4
65/25 66/10 67/9
67/11 67/13 67/20
67/22 67/23 71/4
74/23 75/20 76/7
76/12 76/14 76/15
76/22 76/25 77/3 77/4
77/9 79/12 80/20
80/25 92/4 93/17
94/23 95/2 99/21
99/23 107/5 107/11
107/17 108/1 109/23
126/15 129/25 130/10}
135/17 138/10 139/21
140/10 148/13 148/14
149/4 159/21 159/22
161/3 161/14 161/17
162/12 162/19 163/1
163/15 169/2 169/3
171/21 171/25 172/1
174/23 175/16 175/20
176/7 176/9 176/12
177/22 179/23 181/13
181/16 181/21 182/24)
183/12 183/19 183/23
184/5 185/5 185/11
195/21 195/25 196/3
196/7 196/13 196/18
196/22 197/10 213/20
213/24 219/15
Horizon's [3] 159/4
159/9 159/11
horrible [1] 216/10
horrifically [1] 216/4
Hosi [1] 111/1
Hosi's [1] 170/18
hour [4] 111/7 119/9
119/9 213/5
hours [8] 28/24
93/17 96/15 186/25
214/7 214/18 215/18
215/19
house [1] 53/11
how [92] 7/21 9/13
9/21 9/22 10/7 10/10
23/18 23/19 25/10
25/11 25/25 26/10
26/24 29/3 30/11
31/21 33/19 34/8
35/11 36/23 38/23
39/15 39/20 39/25
40/4 40/5 40/7 40/8
40/9 48/3 50/9 51/5
52/11 52/12 52/18
54/8 62/16 62/22 63/5)
63/9 63/10 67/9 74/6
84/1 84/5 86/12 86/14
86/21 93/12 93/22
95/15 96/2 104/5
107/23 108/1 108/21
110/9 116/25 117/10
117/11 122/4 126/15
126/20 126/20 126/25}
127/8 128/20 130/10
130/11 132/14 143/9
143/15 144/1 144/5
155/4 157/3 159/7
164/2 178/2 178/23
180/5 182/9 187/9
187/14 188/13 192/14}
197/16 209/3 209/21
213/7 220/19 222/2
however [13] 2/1
77/8 77/24 93/11
93/18 93/22 95/4
95/25 96/20 158/10
197/22 209/9 216/25
HQ [1] 90/1
HSH [1] 222/24
huge [1] 213/4
Hughie [5] 165/8
165/21 167/3 169/17
172/9
Hulbert [1] 213/20
human [8] 19/8 67/17
67/24 75/18 76/10
77/5 81/13 85/3
hypotheses [1]
178/13
hypothesis [1]
208/21
hypotheticals [1]
184/23
laccept [5] 15/18
78/20 78/24 87/15
87/19
l actually [5] 13/1
56/21 136/4 154/22
172/23
lagree [4] 45/22
73/14 110/2 134/12
l agreed [1] 110/14
lalso [1] 120/15
l always [2] 60/3
60/13
Lam [17] 1/17 77/16
99/24 112/22 116/16
124/17 130/2 138/15
139/22 148/11 183/19}
200/5 204/4 206/18
215/12 217/3 217/5
I apologise [1]
138/18
l appreciate [3]
77124 130/5 148/6
I approached [1]
52/18
lask [1] 1/10
lasked [2] 29/18
116/17
lassume [2] 126/16
215/7
l assumed [3] 62/1
83/16 169/14
l attach [3] 92/1
131/13 131/19
I became [1] 198/1
I began [1] 38/22
I believe [24] 17/7
50/7 54/13 56/5 58/11
73/23 75/25 89/9
103/12 112/9 123/22
145/19 159/21 170/19)
175/1 193/10 201/10
202/8 203/11 203/21
204/1 204/7 208/12
211/23
I believed [1] 51/20
Icall [4] 1/5
I came [2] 50/18
162/13
I can [26] 2/16 21/15
44/4 44/20 50/21
63/23 64/20 65/5
71/23 74/24 78/2
90/25 102/17 103/18
111/13 120/14 132/24}
144/6 147/14 165/2
165/25 170/21 180/9
180/21 198/18 218/16
I can't [54] 7/23 9/1
11/11 14/7 15/6 22/1
30/9 31/18 44/24
46/25 47/16 48/3
53/12 58/22 60/25
61/7 61/20 62/14
63/16 75/10 90/13
96/14 97/2 99/10
99/11 103/13 103/17
120/6 123/16 125/21
136/19 137/3 137/3
143/10 144/11 144/16)
145/9 145/13 146/21
168/21 171/12 171/16)
176/21 187/24 189/25]
190/15 191/8 191/24
204/3 209/14 211/22
212/13 214/10 220/13
I cannot [1] 207/23
I certainly [11] 23/16
40/22 51/9 101/10
110/16 127/20 132/8
146/13 155/20 156/3
172/17
I clarify [4] 204/22
I clearly [3] 83/13
144/12 157/21
I confirm [1] 150/20
I considered [1]
170/9
I copied [2] 113/5
120/16
I could [13] 14/4
45/14 47/7 47/8 95/24
103/2 108/14 120/1
123/8 184/12 184/13
198/9 223/15
I couldn't [1] 186/24
I described [1]
203/13
I did [29] 10/21 24/3
24/5 31/2 38/6 40/3
50/8 50/10 50/11 89/9
103/17 107/16 107/22!
(72) Helpdesk - I did
I did... [16] 109/6
110/16 125/8 135/11
136/8 137/3 143/11
143/12 146/9 153/16
159/21 168/22 169/23)
169/25 186/13 213/14
I didn't [51] 13/12
29/15 34/10 34/11
36/25 51/18 52/18
54/6 58/7 59/14 60/6
63/5 63/11 84/1 90/15
98/20 101/10 103/1
109/25 115/18 124/11
124/15 126/16 135/1
135/11 136/16 136/22
140/8 140/12 141/1
141/11 141/12 151/4
151/10 151/11 153/23
154/24 155/15 160/3
163/2 164/2 164/2
164/13 164/16 165/1
166/1 169/16 169/22
186/1 217/15 223/17
I disagreed [2]
154/25 168/23
Ido [9] 38/19 46/15
75/4 85/19 86/22
90/13 124/20 203/23
207/19
I don't [96] 12/24
14/21 15/13 16/21
22/12 24/6 25/19 27/6
43/5 43/21 43/23
45/15 45/25 46/6 46/8
46/8 46/15 46/18
47/22 49/14 49/21
49/23 50/9 56/9 56/20)
60/17 61/7 62/5 63/19)
72/23 72/24 73/10
73/10 78/2 79/6 82/18
83/1 83/22 85/22 89/6
91/5 91/6 93/12 93/22
96/2 97/20 98/16
105/23 107/16 108/1
108/15 109/5 111/17
116/12 118/2 125/21
134/21 144/16 146/4
146/6 146/12 147/7
148/5 153/16 156/16
159/11 161/15 161/22)
163/16 165/11 168/9
170/9 171/24 172/17
173/4 174/25 176/1
176/18 177/3 179/8
179/13 179/17 179/20
179/24 185/21 187/21
190/23 191/2 193/17
200/11 205/17 207/12
209/6 219/24 221/8
221/10
I doubt [2] 145/23
152/22
lensured [1] 174/16
lexpect [1] 98/19
I felt [12] 15/24 17/22
18/3 34/14 113/11
1417/9 120/1 120/1
151/9 160/22 183/3
184/24
I first [1] 169/12
I follow [1] 86/16
I get [2] 142/11 146/2
I give [2] 5/16 150/18
Igo [1] 79/16
I got [9] 11/18 13/25
19/10 35/20 36/1
39/15 98/18 102/18
107/22
I guess [3] 93/18
95/24 223/15
I had [34] 11/19 19/9
42/17 46/9 48/14
59/16 59/18 83/7
83/21 97/4 108/21
114/19 117/7 125/9
128/21 151/23 154/12)
156/10 160/20 161/12)
162/10 162/10 166/11
166/19 168/10 169/12)
172/24 175/18 176/23)
177/24 180/25 184/15)
184/25 198/10
I hadn't [7] 31/20
61/8 135/10 151/3
156/23 161/19 197/19)
Ihave [46] 3/9 3/24
40/16 43/2 47/17 48/3
49/12 74/20 80/12
80/17 90/24 92/2
92/16 98/10 106/4
112/12 116/17 126/11
127/4 133/25 138/10
138/11 138/19 139/21
147/24 148/3 148/10
148/12 149/5 149/23
150/1 150/2 150/4
150/7 150/7 150/9
150/13 161/12 174/9
176/5 199/11 203/25
213/22 215/11 217/15)
219/4
I haven't [2] 100/21
161/18
I honestly [1] 219/22
I hope [1] 93/4
lintend [4] 81/10
84/8 86/7 86/18
Ijust [22] 40/14
48/19 52/23 63/6 64/6
64/8 83/19 94/5
104/17 105/2 110/6
110/8 124/2 124/3
124/12 129/18 130/12)
144/18 153/9 156/17
168/9 170/22
I keep [1] 157/9
I knew [2] 137/5
158/1
I know [8] 2/12 41/16
42/16 58/24 59/1 61/1
63/3 112/16
I later [1] 183/5
Ileft [1] 128/20
Ilet [1] 129/18
I listened [1] 172/21
I looked [3] 186/21
186/24 197/13
I made [3] 174/20
174/22 185/6
I may [7] 64/7 100/17
103/16 105/2 120/4
136/18 160/11
I mean [17] 24/15
35/4 49/23 64/3 71/22
78/19 114/18 144/21
157/21 164/3 165/24
167/6 167/9 182/17
186/22 187/25 201/24
I meant [2] 110/20
151/18
I mentioned [1]
46/24
I met [1] 91/1
I might [5] 37/6 40/3
48/21 96/5 129/9
I misreading [1]
84/13
I moved [2] 8/23
19/11
I must [1] 2/1
I necessarily [1]
153/17
I need [3] 130/3
130/6 130/6
I needed [18] 34/10
34/11 79/16 113/23
114/19 114/21 124/16
154/2 154/7 156/3
163/2 163/3 164/17
164/19 166/14 176/6
176/18 221/11
I never [3] 8/12 58/2
184/14
I note [1] 149/4
I now [2] 132/1
169/14
l often [1] 32/12
1 only [3] 26/19 72/17
197/12
lor [1] 72/10
lought [4] 12/11
l oversaw [1] 55/5
I press [1] 143/14
I probably [13] 27/7
82/15 83/6 107/24
118/25 119/8 132/14
135/10 140/25 141/3
146/6 167/7 167/17
I produced [1] 15/8
Iread [1] 84/24
I realise [3] 15/9
82/15 124/22
l realised [4] 14/11
34/12 172/21 172/25
I really [2] 59/15 80/8
I recognise [2] 71/15
75/25
refer [1] 99/18
I refused [1] 168/7
Irelied [1] 197/24
I remember [3] 53/12
54/20 89/19
Iremind [1] 1/25
lresisted [2] 12/12
168/13
I responded [2]
103/15 123/6
retired [1] 8/1
I said [4] 46/6 117/22
156/17 184/12
Isat [1] 64/4
I saw [9] 33/5 119/13
145/24 153/1 169/10
178/1 178/2 187/2
219/22
I say [21] 15/6 24/14
25/1 25/4 26/7 27/8
47/15 49/12 63/23
80/8 90/25 97/3
103/13 128/14 137/4
164/17 169/12 176/5
180/22 180/23 208/1
I see [7] 35/21 35/25
117/12 118/2 202/23
213/18 222/2
I seem [1] 190/8
I send [1] 83/5
I sent [3] 123/7 145/7
145/13
I should [21] 11/24
34/13 83/15 85/24
108/25 125/14 141/11
143/9 143/9 143/15
144/5 170/3 172/23
173/1 173/9 176/16
197/15 200/7 215/21
215/22 223/24
I skimmed [1] 15/12
I speak [1] 80/18
I specifically [1]
166/12
I spent [2] 14/6 33/4
I spoke [1] 97/9
I stand [1] 76/17
I start [1] 6/9
I subject [1] 141/8
I submitted [1] 138/1
I subsequently [1]
150/16
I suppose [3] 45/14
126/10 137/15
I suspect [4] 74/11
87/9 191/8 201/24
I take [1] 16/19
Itend [2] 126/23
171/16
I tended [1] 35/7
I then [2] 99/3 112/1
I think [164] 6/2 6/9
TAT 7/24 8/8 8/21
11/3 11/23 12/13
12/25 14/2 15/23
17/12 17/24 22/1 23/7I
24/20 25/6 26/15
30/19 31/15 32/7
34/22 36/7 37/16
37/19 39/10 39/12
39/24 40/10 41/12
44/14 44/23 44/25
45/17 45/25 46/1
46/17 46/23 46/24
47/4 47/5 47/14 48/9
48/13 48/14 55/5 63/2
63/7 64/13 71/22
74/17 74/18 75/8 75/8
77/7 78/16 78/19
78/21 80/22 83/1
84/14 84/21 85/22
86/1 86/4 87/6 89/16
90/4 90/6 90/12 92/16I
93/18 97/3 97/24 99/1
99/5 100/12 101/5
101/46 101/18 103/15I
104/7 104/9 104/10
104/11 105/2 105/14
105/17 105/18 106/4
108/5 109/18 110/1
110/46 110/21 111/18I
113/40 114/10 114/16I
116/20 117/22 118/11
118/13 119/6 120/4
124/2 125/7 125/20
127/16 128/3 128/4
132/14 141/18 143/11
145/7 145/14 146/10
146/18 151/9 153/8
153/9 159/1 161/1
165/15 166/24 167/10I
168/22 170/18 171/24I
176/22 180/7 182/24
183/5 183/12 189/4
189/10 189/24 192/21
194/11 195/24 197/2
197/4 197/10 197/12
198/12 198/19 199/23I
202/1 203/6 203/12
205/12 206/10 207/1
207/8 207/13 208/5
210/2 212/3 212/22
213/14 213/16 216/19
220/7
I thought [19] 40/24
58/16 119/10 119/15
124/10 124/17 124/22I
134/23 134/24 143/16I
143/17 144/4 144/22
154/2 156/10 163/3
165/3 172/20 176/9
(73) I did... -l thought
I too [4] 217/9
I took [5] 59/18
104/18 152/9 153/7
158/3
Itried [2] 111/21
154/3
I try [2] 83/10 120/14
I turn [3] 18/4 38/14
194/17
I understand [15]
2/19 16/16 20/24
24/23 46/2 72/14
74/16 86/12 98/25
101/9 126/8 149/21
149/23 176/5 219/16
l understood [6] 54/7
57/23 59/9 63/7 85/7
165/16
lused [4] 43/11
78/21 78/25 166/11
I want [4] 171/1
172/13 175/12 194/18
I wanted [3] 168/16
173/10 220/19
I was [164] 6/20 10/5
10/8 11/23 12/24 13/6
13/21 15/7 18/21
21/22 21/24 22/1 22/9
22/17 22/20 23/8
23/23 25/2 25/6 26/8
26/15 26/20 26/22
27/8 28/1 28/2 29/16
32/9 33/22 33/22 34/3
35/22 36/7 36/11
37/12 40/24 41/22
43/10 43/21 43/23
46/6 46/7 46/8 51/5
51/19 51/24 52/15
52/20 56/9 56/10
62/14 63/24 63/25
71/17 71/17 80/9
87/10 87/20 101/9
102/25 103/12 103/14
105/14 106/9 108/1
108/12 108/22 111/25}
113/22 115/13 115/18)
115/25 120/17 123/3
123/3 123/4 124/10
124/13 124/14 124/22)
125/12 125/24 126/15)
127/16 127/18 127/18)
127/21 127/22 127/23}
127/24 128/13 128/23)
129/23 132/8 132/8
132/9 134/23 134/24
134/25 135/1 135/11
135/13 136/5 136/17
136/19 136/23 137/5
137/15 140/9 141/2
144/12 152/20 154/1
154/1 155/1 155/3
155/3 156/11 157/1
157/2 157/14 157/22
158/1 159/11 159/12
159/13 159/20 160/8
160/14 162/11 162/16)
163/16 163/17 166/25)
167/6 168/15 168/23
169/11 170/4 170/10
172/18 174/12 176/18)
178/4 180/23 180/24
182/23 183/7 183/16
184/12 184/15 184/16)
185/8 185/10 185/13
186/12 197/21 197/23)
198/3 203/13 203/24
204/7 219/25 220/18
I wasn't [32] 6/21
13/22 15/8 24/23 25/4
26/7 26/17 29/17 40/1
41/14 42/23 43/12
49/8 60/4 62/15 63/23
71/24 83/14 83/18
87/7 114/16 115/2
115/25 119/15 124/11
135/1 151/12 154/12
155/20 157/14 185/9
198/10
I went [3] 39/12 40/7
64/3
I will [6] 2/9 134/16
134/18 150/15 199/8
215/4
I won't [4] 18/2
100/11 102/12 102/22)
I wonder [1] 21/11
I worked [2] 8/20
8/21
I would [50] 26/4
27/24 28/18 31/7
35/19 36/17 37/19
41/8 43/8 43/13 45/15)
48/4 62/5 63/19 71/22
73/7 75/4 75/9 76/16
78/18 78/21 78/22
86/14 87/8 89/7 91/19
92/3 93/4 93/20 94/9
96/3 96/8 97/3 119/18
137/4 140/5 152/18
152/22 155/1 164/6
164/18 175/10 176/2
176/7 176/16 176/23
189/8 192/15 220/20
221/10
I wouldn't [9] 17/24
45/9 49/4 110/13
117/5 167/21 176/11
185/6 204/5
I wrote [3] 56/10 99/5
152/19
I'd [46] 27/15 27/16
29/2 36/6 37/19 38/25)
43/17 45/14 50/17
51/9 52/20 55/24
60/17 80/8 94/11
113/7 115/6 119/12
124/4 128/5 136/5
141/7 144/21 144/24
146/18 146/19 146/20
151/2 151/9 151/18
152/21 152/25 156/16
158/4 159/24 160/10
165/24 173/5 173/5
173/8 176/6 176/15
183/21 195/23 219/22
219/23
VIL[7] 80/18 85/13
96/10 96/11 97/15
124/18 223/22
I'm [124] 4/11 5/20
6/17 10/25 14/22 15/4
15/14 16/15 17/20
20/24 21/22 22/9
24/12 30/2 35/1 35/12
36/17 37/24 43/22
45/11 45/19 47/1
48/22 49/9 59/15
62/21 62/24 63/1 64/8
72/12 72/13 75/4
78/18 79/12 80/8 82/1
83/2 83/23 83/23 84/4
84/20 85/10 85/10
87/9 87/11 89/14 90/9
94/9 96/16 97/2 97/20
98/12 98/16 100/15
100/18 102/17 103/8
106/22 110/11 116/12
118/4 118/9 119/6
120/14 120/24 121/16
123/12 124/7 124/19
125/19 125/22 128/10
128/14 129/6 129/8
134/19 136/4 140/22
142/4 142/5 142/9
142/11 144/23 145/8
146/1 146/2 146/4
148/25 149/12 150/5
152/18 152/22 153/16
155/19 155/23 157/2
162/22 163/11 165/17
167/20 168/8 175/18
176/17 177/8 183/16
184/23 189/19 191/16
194/4 195/2 195/23
197/12 200/11 200/12
201/7 201/14 206/13
207/6 208/22 209/3
209/14 215/7 220/18
223/24
I've [41] 1/24 7/24
15/12 37/11 41/22
42/16 43/22 45/18
48/19 49/6 61/2 71/15
85/1 86/6 86/21 98/3
100/10 101/14 103/14
103/24 110/1 113/4
118/16 118/20 119/7
130/13 134/14 135/9
135/15 135/17 135/18
142/1 144/16 169/5
170/25 175/9 175/22
200/11 214/19 216/3
222/5
IBM [4] 23/21
ICL [13] 6/14 6/16 7/4)
11/5 11/12 11/16 18/8}
19/20 22/8 24/21
25/12 43/20 54/13
ICL's [1] 44/21
ICL/Fujitsu [1] 54/13
idea [8] 41/22 41/23
42/16 42/18 43/2
90/22 98/10 200/11
ideas [3] 48/14 56/20
193/5
identified [16] 18/1
32/6 57/14 86/3
182/13 190/9 196/7
197/11 205/1 207/10
207/19 212/8 216/17
223/2 223/3 223/4
identify [2] 57/3
222/18
identifying [3] 34/25
37/22 55/7
IDRIS [4] 1/7 1/12
118/20 225/2
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33/1 55/13 76/7 76/14)
78/10 78/16 79/8
104/21 104/24 120/20)
135/25 172/4 175/13
186/6 198/5 214/7
215/9 217/23
ie by [1] 78/16
ie cause [2] 16/11
17/3
ie did [1] 186/6
ie four [1] 217/23
ie Horizon [2] 76/7
76/14
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ie provide [1] 215/9
ie that [3] 55/13
104/21 175/13
ie the [4] 78/10 79/8
120/20 172/4
ie which [1] 33/1
ie work [1] 104/24
if [216] 1/20 2/4 2/13
2/14 3/4 6/6 14/23
20/18 21/19 25/1
25/16 26/1 28/15 29/2
31/14 33/17 35/8
35/17 38/12 39/17
41/25 43/24 44/5 45/3
45/14 49/18 50/1 50/4)
51/9 52/22 53/11
55/16 55/19 56/14
56/23 59/4 59/11 65/6
66/19 67/17 67/22
68/1 69/1 69/7 70/13
71/9 71/20 71/22 72/8)
72/15 73/1 73/5 73/17
74/24 75/18 76/10
76/24 77/3 77/8 77/18)
80/24 81/11 81/13
82/3 83/5 84/9 84/10
84/11 84/22 85/3 85/3
85/4 85/14 86/19
87/23 87/24 88/9
88/13 90/2 91/13
92/22 92/22 92/24
93/2 94/11 94/18
95/15 95/18 95/22
95/25 97/4 97/5 98/9
98/15 100/5 100/15
100/18 101/16 112/5
112/19 113/3 116/7
117/23 118/5 118/7
118/13 118/18 119/1
119/17 120/2 124/3
125/16 127/22 128/15)
128/18 129/18 130/1
130/2 130/5 131/8
132/16 132/18 132/21
132/25 132/25 133/4
134/5 134/8 137/19
137/21 137/22 138/18)
139/1 139/13 141/14
143/11 147/17 150/15}
152/22 154/14 154/18)
154/25 155/1 155/25
157/4 162/4 164/3
164/17 166/22 167/24I
170/15 170/20 170/21
170/22 176/1 176/6
176/15 176/23 177/6
178/19 179/9 180/13
182/8 182/17 182/18
183/3 183/7 183/10
184/4 184/8 184/18
184/23 185/17 187/5
188/10 190/12 193/15)
198/19 199/4 200/5
201/7 204/12 204/15
204/23 205/12 205/13}
205/15 205/25 206/11
206/11 207/2 207/9
209/9 209/9 210/3
210/8 210/19 213/11
215/10 215/18 215/19)
215/22 215/24 216/6
217/1 218/6 219/2
219/11 219/12 220/19}
220/22 220/24 222/14I
222/20 223/1 223/11
ignorance [1] 100/18
ignore [1] 14/22
imagine [1] 21/15
Immediate [1] 198/25]
immediately [6] 2/8
6/13 30/9 70/16 71/9
183/20
impact [37] 8/16 8/20)
19/11 23/3 23/16
32/14 32/16 34/9
35/18 37/15 38/21
(74) too - impact
I
impact... [26] 52/7
52/24 53/1 53/9 54/14,
55/11 55/22 59/6
60/20 62/10 62/25
63/2 107/22 186/14
186/17 188/3 189/1
190/4 191/25 193/22
194/7 198/25 205/10
207/24 216/9 217/19
impacted [1] 33/23
implement [2] 59/17
215/23
implementation [2]
8/17 10/2
implemented [1]
54/17
implementing [1]
54/14
implications [1]
218/6
importance [4] 60/1
70/1 114/14 138/20
important [14] 43/15
43/17 60/3 60/10 81/2)
82/7 82/13 83/25 84/1
95/7 111/3 114/2
179/4 181/18
importantly [1] 207/8
imposed [1] 121/7
impossible [2] 25/17
26/2
imprisonment [1]
158/21
improper [1] 169/23
improve [4] 61/5
213/15 216/12 217/1
improved [1] 155/5
improvement [2]
61/19 216/13
improvements [4]
215/11 216/18 217/8
219/9
improving [1] 218/8
inaccurate [2]
196/24 209/8
inadequate [5]
216/20 217/5 217/18
218/1 218/2
inadvertently [1]
138/19
inappropriate [2]
51/7 169/16
incident [7] 199/6
199/8 200/2 200/4
200/16 203/8 204/17
incidents [4] 28/21
28/21 33/4 215/14
include [10] 44/17
70/10 88/20 139/22
154/17 155/13 162/17)
164/7 165/18 167/23
included [6] 30/17
75/24 93/23 135/17
150/9 219/2
includes [2] 112/18
121/22
including [16] 29/24
69/25 79/12 85/16
88/19 98/20 99/16
121/7 144/15 150/10
154/19 158/20 181/16)
182/2 186/9 189/8
inclusions [1] 178/25
incompetence [2]
166/21 168/3
incomplete [1]
100/21
incorporated [1]
138/11
incorrect [5] 77/12
139/2 139/20 175/17
222/19
incorrectly [1]
193/12
increase [1] 207/2
increasing [1] 60/21
incriminate [2] 1/22
2/17
incrimination [3]
1/15 1/24 2/13
incur [1] 148/17
indeed [7] 3/9 6/5
59/2 107/7 113/3
220/3 220/16
indented [2] 149/13
149/14
independence [5]
135/3 136/1 149/1
149/2 178/21
independent [10]
70/12 71/2 132/9
133/25 134/25 135/2
140/11 150/11 151/25)
205/8
independently [1]
182/17
index [2] 132/19
137/20
indicate [2] 154/10
154/13
indicated [2] 138/13
150/8
indicates [1] 151/21
indication [1] 171/19
indirectly [2] 38/20
39/18
individual [8] 17/19
17/20 153/11 156/20
188/16 188/20 190/7
190/16
individuals [1]
138/18
industry [2] 53/14
53/15
inevitable [1] 181/20
infallibly [4] 17/11
inform [1] 178/1
informal [4] 29/11
120/13 163/20 164/8
informally [1] 163/24
information [40]
13/17 20/7 24/17
29/11 53/19 63/21
67/21 68/2 75/21 76/8
76/13 76/25 81/9 84/7
87/16 94/1 100/6
133/14 136/17 136/20
148/9 150/8 154/14
160/1 161/3 163/20
163/24 164/15 175/1
182/2 184/9 184/10
184/19 184/20 184/24]
185/4 195/22 197/25
202/2 220/21
informed [4] 16/5
52/14 101/6 122/3
informing [1] 101/11
Infrastructure [1]
24/1
initial [5] 18/9 39/13
97/13 98/25 126/11
initially [3] 23/19
23/21 26/25
initiated [1] 57/5
input [2] 28/3 214/10
1INQ00001094 [1]
177/15
inquiry [16] 1/10 1/18
1/20 2/24 5/24 24/8
40/17 56/6 103/19
103/23 107/3 146/13
197/7 202/21 220/15
222/7
Inquiry's [2] 5/19 6/2
inserted [2] 118/16
192/19
insists [1] 210/16
instance [1] 193/7
instead [2] 57/20
127/11
instigated [1] 110/22
instructed [5] 138/2
140/14 173/25 174/21
174/24
instructing [3]
149/24 150/15 174/18}
instruction [1] 68/6
instructions [11]
68/21 68/24 121/18
132/23 135/5 140/20
147/1 148/23 158/8
173/23 174/4
integrate [1] 18/10
integrity [5] 22/10
25/18 26/2 95/1 169/3)
intellectual [1] 27/11
intend [4] 81/10 84/8
86/7 86/18
intended [1] 175/4
interact [2] 40/6
122/4
interacted [1] 23/19
interaction [2] 19/12
48/21
interactions [2]
37/21 48/19
interest [4] 20/7
45/16 54/5 71/10
interested [6] 40/1
63/24 63/24 136/20
137/1 137/5
interests [3] 71/11
89/5 164/25
interface [8] 19/8
23/22 23/24 26/25
29/23 54/16 187/8
189/18
interfaced [2] 22/23
47/6
interfaces [4] 23/18
26/24 39/22 182/19
interim [1] 51/13
intermediate [1]
217/24
internal [4] 25/11
27/16 80/11 177/6
internally [2] 128/11
223/3
International [1] 6/14
interpretation [2]
84/16 86/9
interpreted [1] 87/7
interpreting [1] 10/6
interrupt [2] 9/24
85/11
into [59] 4/16 5/1 5/9
20/16 22/4 22/18
23/22 23/25 36/8
51/23 52/1 58/4 59/7
59/24 67/22 71/19
75/14 76/8 76/13
76/15 76/23 76/25
77/3 77/9 78/22 82/21
90/9 101/19 105/22
109/5 109/25 111/21
124/8 138/12 139/20
142/16 153/2 169/11
172/23 178/17 180/8
180/16 187/16 187/21
190/7 191/7 192/20
194/11 200/6 201/6
202/22 205/10 208/1
209/22 216/7 219/10
219/24 220/5 221/17
introduced [6] 22/18
22/20 62/19 62/24
203/11 211/23
introduces [1]
139/20
introducing [2] 11/6
54/23
introduction [3]
137/21 147/24 191/25}
introductory [2]
133/17 136/16
inverted [4] 171/9
171/14 171/17 172/3
investigate [6] 31/8
89/7 139/22 217/10
218/8 220/11
investigated [6]
17/14 186/8 186/13
194/8 216/22 223/6
investigated’ [1]
217/12
investigating [5]
194/11 198/23 200/5
215/20 223/9
investigation [18]
71/19 74/20 76/20
85/2 89/4 89/12
103/17 118/25 172/24I
188/12 188/22 190/7
190/18 190/19 194/10}
199/9 199/21 208/1
investigations [7]
89/10 186/16 190/22
200/24 203/1 213/14
219/24
investigators [2]
114/9 175/2
invoice [1] 116/18
invoiced [1] 116/21
involve [3] 57/10
72/5 124/14
involved [50] 1/20
13/23 18/22 19/10
23/23 24/23 25/2 25/5I
25/14 25/21 26/7
26/19 32/12 35/7 35/7I
35/20 35/20 35/22
36/2 36/16 36/17
40/12 41/9 41/17
47/22 50/8 53/1 54/13
56/9 56/10 58/18 74/2
96/3 103/1 103/10
105/8 107/10 108/7
108/9 119/2 119/7
125/12 129/9 161/19
164/1 169/13 173/2
185/19 197/19 198/4
involvement [9]
19/10 46/9 46/15
48/23 49/15 54/18
56/13 103/3 109/19
involving [3] 203/9
212/11 223/7
irate [1] 219/17
irrelevant [2] 175/11
176/10
is [408]
ish [1] 100/9
Ishaq's [3] 121/25
122/8 122/16
isn't [12] 74/17 81/3
82/14 85/21 98/15
100/10 100/16 111/18)
138/4 171/19 180/20
(75) impact... - isn't
isn't... [1] 212/23
isolated [2] 199/5
215/14
isolation [1] 170/11
issue [29] 2/13 28/1
35/8 35/24 50/21 52/7
60/6 60/8 113/8 114/2
162/1 181/25 182/17
184/4 185/18 190/8
193/10 193/20 193/25
194/13 200/9 200/25
201/18 202/17 202/25
203/4 203/8 203/15
209/23
issued [2] 65/19
65/20
issues [55] 13/10
13/16 15/1 15/11
28/23 31/6 35/21 36/1
42/9 43/6 46/3 46/16
49/13 50/11 50/13
52/1 89/12 90/23
102/10 105/5 109/13
109/22 113/10 133/11
138/25 139/17 159/4
159/9 159/11 160/11
161/13 163/10 181/16}
181/16 182/13 182/21
185/19 188/10 194/16
197/20 198/5 201/20
202/4 202/5 202/7
202/8 202/10 202/22
203/13 208/22 213/24
221/19 221/23 223/4
223/13
it [605]
it'll [4] 50/19 54/11
85/12 219/11
it's [81] 3/6 3/10 3/20
4/8 4/8 10/11 14/7
14/20 18/25 20/19
27/22 35/16 36/17
38/17 44/7 44/13
44/17 47/16 55/17
55/19 61/10 61/20
69/5 71/23 73/18 74/6
75/13 76/25 78/8
82/13 84/11 84/12
85/9 85/19 85/20
86/10 87/5 88/16 97/3,
99/20 100/5 109/2
111/18 117/15 118/4
118/18 119/6 120/20
122/19 126/17 126/23}
136/10 141/13 147/12
147/15 151/8 151/16
151/17 153/9 157/25
167/10 171/14 178/15}
181/2 184/23 187/5
191/16 191/21 192/10}
195/8 196/16 198/9
198/15 200/16 201/8
203/16 205/15 210/4
215/19 223/19 223/25
italics [1] 100/3
items [1] 138/19
its [11] 6/18 59/1
59/2 80/21 92/5 94/7
107/14 109/21 111/19)
164/25 210/15
itself [5] 66/5 162/16
188/23 203/10 205/20)
J
James [2] 112/19
113/6
Jane [3] 114/9 116/8
116/13
January [1] 118/1
jargon [1] 36/8
Jarnail [2] 141/17
141/25
Jason [1] 1/9
Jayne [2] 116/10
116/24
Jean [3] 125/12
141/18 141/19
Jean-Philippe [2]
141/18 141/19
Jean-Pierre [1]
125/12
Jenkins [47] 1/5 1/7
1/9 1/12 1/14 1/17
2/18 2/23 37/3 40/19
42/7 64/22 64/22 72/2
81/12 84/12 84/12
84/18 84/18 85/5
85/11 85/16 85/17
85/24 99/17 99/20
102/6 106/22 112/5
118/20 131/1 138/1
138/8 138/13 138/23
139/15 173/22 174/21
174/22 177/10 178/1
178/11 178/19 178/23)
178/24 223/24 225/2
Jenkins' [2] 41/3
88/12
Jennings [4] 125/18
125/18 129/2 129/10
Jennings’ [1] 128/3
Jennison [1] 66/6
Jeremy [3] 23/25
24/6 27/7
job [15] 16/1 29/1
51/10 52/20 103/2
108/17 108/18 119/21
127/20 127/22 183/24I
217/5 217/18 218/1
218/2
John [2] 212/11
212/17
joint [4] 24/4 25/20
122/5 132/3
Jones [4] 110/17
111/6 125/9 158/5
judge [2] 17/23 67/8
judgment [4] 13/10
13/16 15/1 15/11
Julia [1] 149/5
July [4] 95/19 95/23
205/13 205/14
June [12] 1/1 4/6
89/17 89/23 91/11
91/12 92/2 93/7
204/12 204/15 205/10
215/10
just [124] 10/22
11/19 13/1 19/15
20/16 21/11 21/19
25/4 26/8 32/17 33/3
35/6 40/11 41/22
41/25 43/24 48/15
48/19 52/4 52/6 52/23)
56/17 56/23 59/19
63/6 64/6 64/8 65/6
72/16 73/11 73/24
74/6 75/23 78/19
81/17 82/22 83/19
84/5 84/20 84/22
85/20 85/24 87/23
91/14 91/21 91/25
92/24 92/25 94/5
101/15 101/17 102/2
102/25 104/15 104/17
105/2 105/17 106/12
107/1 110/6 110/8
111/9 112/4 113/18
114/1 114/17 115/25
118/5 118/18 119/10
119/16 119/18 123/18}
124/2 124/3 124/12
129/18 130/12 132/19}
134/8 144/18 146/5
146/6 147/17 148/22
152/9 152/20 153/9
156/17 160/5 160/16
165/4 167/24 168/9
168/22 170/13 170/15}
170/22 171/23 179/9
185/8 190/11 194/1
197/15 198/10 200/3
200/13 200/22 202/6
202/18 203/2 204/1
204/12 206/10 206/14
210/20 212/22 216/8
218/14 218/15 218/18)
223/8 223/18 223/24
Justice [1] 15/15
justifiable [1] 47/13
justify [1] 11/24
juxtaposition [1]
85/9
K
keen [2] 58/24 59/1
keep [9] 132/25
133/5 133/5 133/6
133/6 133/16 153/24
157/9 157/10
keeps [1] 141/9
KEL [2] 220/17
223/10
KELs [3] 197/11
197/16 198/6
key [1] 42/6
Kim [2] 147/11 148/2
Kimberley [1] 213/19
kind [9] 34/6 52/3
65/14 72/15 188/14
221/6 221/9 223/11
223/13
King [1] 112/9
knew [17] 20/16 29/9
51/25 83/16 113/18
114/5 114/5 137/5
158/1 162/4 162/8
163/1 163/14 182/24
183/12 188/10 220/8
know [76] 2/12 21/20
27/19 29/14 29/15
34/7 37/17 40/15
41/16 42/13 42/16
42/20 42/23 42/24
43/3 43/5 45/19 49/21
49/23 49/24 50/9
53/24 58/24 59/1
60/17 61/1 62/5 63/3
63/5 63/11 67/8 71/6
79/6 80/1 82/11 82/18
83/1 83/22 89/6 90/13
90/21 91/5 93/22 96/2,
98/16 98/16 107/16
108/15 112/16 114/11
116/22 120/18 124/20
129/18 129/19 146/6
146/11 153/16 159/14)
164/2 164/16 168/9
170/9 172/17 173/4
183/13 187/21 197/7
197/10 204/5 205/18
207/19 209/6 217/11
219/25 221/8
knowing [2] 37/17
220/19
knowledge [28] 3/17
4/3 4/17 5/3 5/11
28/14 28/15 29/3
29/14 29/24 43/14
45/12 53/23 59/25
69/2 107/17 107/23
107/25 128/12 149/6
150/7 150/21 154/11
154/14 162/19 169/2
169/13 220/5
known [6] 1/22 42/10:
43/6 43/8 97/4 171/6
knows [1] 37/3
L
lack [11] 22/7 42/4
42/4 42/5 42/14 42/20
42/21 122/24 123/9
124/1 221/16
lacked [2] 121/10
136/1
lacking [1] 121/5
language [3] 59/12
80/10 167/14
large [4] 5/23 6/3
121/17 214/22
largely [3] 32/25
33/11 33/17
larger [2] 37/15
207/4
last [16] 5/25 12/25
13/15 71/15 81/15
83/19 104/19 110/8
117/7 129/13 179/2
189/5 197/15 200/8
214/1 219/7
lasted [3] 14/18 21/1
111/7
lastly [3] 5/5 16/10
128/24
late [2] 49/1 50/19
later [38] 14/3 22/19
23/22 24/4 26/19 48/9I
49/13 50/4 50/8 81/6
89/9 91/12 94/11 99/5
123/13 125/11 143/1
143/12 145/3 145/16
147/15 160/25 166/7
169/5 169/11 170/10
183/5 183/6 190/9
197/18 203/12 210/11
211/3 211/16 211/21
212/3 214/7 214/18
latter [1] 39/7
law [2] 1/18 124/20
lawyer [8] 110/18
110/19 110/20 110/21
112/9 141/20 142/20
158/5
lawyers [19] 1/20
2/14 2/15 13/15 13/25
109/21 111/19 124/19)
125/3 125/11 132/15
144/1 150/11 154/19
154/22 155/10 158/5
170/1 170/1
layer [6] 18/13 20/2
20/3 20/4 20/23 22/14
laying [1] 203/15
laypeople [1] 36/9
lead [3] 55/9 107/7
197/8
Leader [1] 24/1
leaders [1] 116/25
learn [4] 39/15 40/4
40/7 173/11
learnt [3] 72/17 73/2
173/5
least [8] 47/20 49/10
132/8 158/6 185/24
187/18 190/10 216/18)
leave [4] 87/1 96/16
96/20 98/18
(76) isn't... - leave
L
Leaving [1] 48/23
led [1] 11/21
Lee [3] 64/23 89/22
102/16
left [5] 23/4 37/14
46/18 128/20 198/16
left-hand [1] 198/16
Legacy [22] 9/15
10/16 15/16 16/20
17/16 18/10 28/7
31/25 32/2 33/18
40/14 54/15 55/2
161/14 183/22 195/21
195/25 196/3 196/17
196/22 197/9 209/7
legal [21] 1/22 6/1
72/5 72/6 72/9 102/9
105/19 111/3 113/15
114/8 114/8 121/2
124/17 126/17 130/13)
130/13 133/11 142/21
157/4 180/2 180/4
legally [1] 2/12
legitimate [1] 165/4
leisure [1] 45/13
lend [2] 47/19 47/25
length [2] 158/7
215/17
lengthy [1] 136/11
Lenton [1] 44/25
Lepton [1] 118/10
less [4] 38/13 43/14
193/17 214/24
let [4] 98/15 129/18
129/19 170/25
let's [8] 18/18 89/21
119/15 119/18 144/22
145/1 203/16 204/9
letter [23] 65/2 71/13
71/13 71/20 72/25
73/1 73/5 73/8 74/9
76/4 88/5 90/16 90/17,
92/1 94/3 94/7 96/25
97/18 97/21 97/24
98/6 101/1 134/10
letters [1] 171/17
level [15] 8/3 12/9
12/24 15/15 22/14
26/8 37/8 45/13
108/23 161/1 169/10
182/8 185/8 185/11
195/3
levels [5] 17/6 21/23
44/11 212/6 221/20
LFS [2] 46/23 49/13
liable [1] 68/8
ise [4] 212/15
ising [1] 80/18
liberal [1] 171/16
library [3] 44/19
44/21 45/7
lie [1] 150/3
life [2] 197/9 219/14
light [1] 160/15
lighter [4] 75/17
lightly [4] 101/22
like [64] 7/9 8/1
10/11 10/22 11/18
12/22 17/24 20/15
23/8 25/1 26/10 27/15
27/18 29/25 33/5 35/9
35/13 35/17 36/6 38/4
38/8 41/11 49/2 49/7
54/6 58/14 58/23
63/20 74/4 74/5 75/13
80/4 81/1 91/19 92/3
93/4 100/16 104/17
111/7 113/23 117/3
118/15 127/22 128/6
135/2 136/21 136/22
137/2 145/24 157/5
158/1 171/14 171/17
171/23 181/21 182/20)
189/7 190/6 197/2
200/14 207/12 217/9
223/2 223/8
likely [18] 67/16 68/1
75/23 77/18 77/23
78/5 78/13 78/15 79/8)
79/11 82/3 119/2
148/16 185/24 185/25)
190/21 193/17 219/13)
Lillywhite [2] 141/21
141/21
limit [2] 57/23 102/14
tions [1] 147/4
limited [6] 6/14 6/16
57/16 66/17 158/8
158/9
line [33] 10/15 10/17
10/21 11/1 27/21
27/25 28/2 30/11
32/25 33/9 33/13
37/21 38/2 38/4 40/22
114/7 131/17 174/15
177/7 201/17 201/22
212/19 213/23 217/9
221/7 221/11 222/8
222/15 222/17 222/22
222/23 223/5 223/6
lines [10] 47/15
177/4 198/20 199/4
199/7 199/10 199/14
200/20 222/10 222/17)
list [4] 133/15 152/1
187/14 187/15
listen [2] 48/14
174/10
listened [1] 172/21
literature [1] 69/14
litigation [8] 13/5
13/18 15/3 15/5 50/14
50/18 51/2 74/4
little [6] 19/9 21/12
21/19 116/16 204/16
216/13
live [21] 8/21 10/20
30/18 34/1 189/22
190/3 192/11 193/18
201/6 203/5 205/2
205/9 205/10 207/11
207/13 207/20 208/21
208/22 209/2 209/3
223/1
lived [3] 186/6
188/14 189/24
load [1] 188/1
local [7] 35/24 62/16
62/20 62/22 62/25
63/2 63/8
lock [3] 193/22
193/25 194/4
lockdown [1] 13/2
locked [1] 38/5
locking [4] 161/13
162/1 201/11 201/14
log [2] 30/21 192/23
logged [2] 19/3 193/1
logging [1] 206/1
Logistics' [1] 46/16
logs [15] 94/19 94/21
95/13 97/7 99/25
106/2 106/3 171/2
172/13 172/15 172/18}
172/19 172/25 183/9
211/4
London [1] 146/16
long [21] 3/10 3/21
AIT 4/22 5/6 17/10
47/16 51/5 61/21
77/19 93/22 97/3
119/17 128/21 136/10
183/2 213/2 213/7
216/8 217/23 223/19
longer [5] 4/8 23/23
46/18 175/25 213/11
Longman [2] 146/8
166/9
look [72] 9/14 28/20
30/22 36/20 43/24
43/24 45/3 45/13
54/10 55/16 55/16
73/17 78/22 79/16
80/24 81/17 81/21
82/24 87/18 87/23
89/7 89/21 91/12 92/4
92/22 97/5 97/25
98/12 100/1 100/8
101/15 112/4 112/6
116/6 125/16 128/24
128/25 131/8 137/19
146/1 148/25 155/6
161/5 161/7 161/9
165/7 166/3 170/13
174/13 177/6 182/4
183/7 183/18 185/9
185/10 185/13 187/4
194/18 197/14 197/17
197/23 198/8 203/16
204/9 204/11 204/12
204/23 206/12 210/3
212/9 213/18 220/5
looked [29] 15/12
84/22 88/6 91/22
92/25 133/20 145/11
145/15 159/24 162/11
165/1 166/20 168/1
172/23 182/10 183/4
186/21 186/24 197/13
198/9 202/6 203/25
209/5 212/23 214/19
216/3 218/24 219/8
220/8
looking [51] 10/7
15/9 26/8 30/2 45/5
48/25 52/8 52/15
61/18 64/25 66/13
71/4 75/8 78/19 79/14)
81/4 89/23 116/9
124/17 128/4 131/8
143/8 143/14 146/23
148/9 152/23 154/16
163/12 165/24 167/20
170/11 170/12 170/14}
180/21 183/8 183/16
184/1 188/15 188/16
188/17 188/18 188/24,
200/1 204/10 208/2
210/5 212/23 219/12
220/4 220/10 222/2
looks [4] 75/13
118/15 125/22 170/20}
loop [2] 116/16
206/24
loose [1] 80/10
loss [5] 67/23 67/24
77/4 77/5 98/12
losses [11] 60/22
61/3 61/19 65/13
65/14 65/16 65/20
66/3 66/22 93/12
198/15
lost [1] 74/23
lot [19] 7/24 13/6
13/21 13/24 21/5
21/10 25/20 29/5 41/9
41/18 52/4 58/11
136/19 148/16 180/7
180/10 180/25 194/11
223/1
lots [2] 78/24 98/17
lower [1] 195/3
lunch [1] 128/24
MAR [1] 187/22
MAR/S10 [1] 187/22
machine [1] 206/9
made [42] 2/23 3/5
4/15 41/18 54/8 71/17
87/21 94/7 98/12
109/11 111/19 119/4
147/19 149/10 154/21
155/8 155/13 161/21
162/23 165/12 166/15}
168/22 174/17 174/19)
174/20 174/22 175/13)
175/14 176/8 180/1
185/6 200/24 202/5
204/18 208/14 210/22!
211/25 213/8 216/12
217/19 218/7 219/25
main [20] 8/19 10/23
19/12 22/17 22/20
26/20 35/21 39/4
48/11 50/21 55/5 55/6)
57/6 62/6 87/17
113/11 146/16 187/38
199/25 216/15
mainly [1] 186/25
maintenance [2]
22/15 107/11
major [1] 54/21
majority [1] 14/25
make [32] 2/2 11/17
25/22 37/3 56/16
56/25 57/19 65/13
69/7 83/18 85/8 100/1
102/6 109/11 114/21
120/16 163/9 165/5
165/9 166/17 167/9
168/11 168/12 168/14}
168/22 177/10 178/20)
179/6 193/15 193/16
193/16 194/13
makes [4] 98/7
101/24 133/8 189/4
making [12] 2/24
26/8 42/9 60/9 69/15
73/25 92/11 113/19
151/12 163/7 167/14
170/3
man [4] 8/12 37/1
141/9 219/7
man-days [1] 219/7
man-management [1]
8/12
manage [5] 12/12
29/1 29/23 52/1 74/24I
manageable [1]
44/11
managed [3] 17/1
46/12 123/11
management [17]
8/6 8/12 12/9 24/22
32/5 32/11 36/19
44/23 45/2 55/20
55/21 57/4 114/19
122/25 124/14 200/12)
201/5
manager [8] 11/23
73/23 116/13 189/18
191/18 212/16 212/18)
212/19
managerial [2] 8/11
189/18
managers [3] 28/20
124/6 124/19
(77) Leaving - managers
M
managing [3] 31/5
31/16 117/11
Mandy [1] 91/16
manifest [1] 183/20
manifested [2] 52/12
162/16
manner [1] 105/21
manual [2] 57/10
66/21
many [10] 7/21 35/11
45/20 58/11 78/20
96/2 167/10 182/21
188/7 216/3
mappings [1] 98/10
March [6] 4/21 55/17
161/22 162/14 162/23}
162/23
Marine [9] 65/7 65/11
66/1 67/11 67/13
73/19 93/24 98/1 98/5)
Mark [3] 116/17
191/16 191/18
marked [3] 85/4 85/5
167/15
Martin [9] 191/12
191/12 191/17 191/19
192/17 200/23 201/2
205/14 206/3
match [1] 94/23
material [9] 6/3 68/21
68/24 69/15 70/4 71/3
115/1 115/4 186/7
mathematics [1]
6/11
matter [6] 70/6 70/14
137/11 146/24 154/11
155/17
matters [16] 68/10
69/21 70/4 70/8 102/3
133/10 134/20 137/13
150/2 150/5 153/14
153/21 153/25 154/17)
156/1 156/5
Matthew [1] 44/25
may [48] 1/5 14/2
29/18 36/10 40/9 44/3,
44/25 47/7 47/14
50/23 50/24 57/5 64/7
66/25 67/23 68/2 68/6
69/7 74/23 77/4 82/22
84/5 84/20 84/21
87/19 96/19 100/16
100/17 103/16 104/10)
105/2 106/1 111/15
115/11 120/4 136/18
160/11 165/2 175/24
183/14 194/7 194/9
199/5 201/19 205/20
214/9 216/7 216/13
maybe [19] 14/4
14/18 15/10 15/23
34/12 48/9 83/17
85/12 85/24 108/25
109/1 123/9 125/14
127/16 135/20 172/22)
172/25 173/9 221/12
McConnell [6]
191/12 191/13 191/17)
191/19 200/24 206/3
McConnell's [1]
205/14
McDonnell [5] 40/15
40/24 44/18 45/23
48/24
McLachlan [17]
131/21 134/20 140/7
141/15 142/2 142/7
143/1 143/12 143/20
144/25 145/21 146/25)
151/3 157/6 163/18
177/22 179/4
McLachlan's [5]
131/16 136/10 141/6
142/15 151/19
me [112] 1/14 1/20
2/2 2/7 2/16 6/6 12/11
13/3 13/4 27/25 35/9
36/2 37/8 37/11 45/25)
48/14 50/19 50/24
56/1 58/17 63/11
71/23 71/25 76/1
78/24 81/1 84/5 84/10)
85/12 86/3 93/6 94/6
98/15 99/7 103/19
104/15 104/16 104/20)
108/8 109/6 109/7
109/9 110/24 111/22
111/23 112/17 114/19)
115/9 115/15 116/11
119/2 119/17 120/3
123/14 123/17 124/4
124/8 124/9 124/10
125/11 125/12 129/7
132/15 135/20 138/9
142/5 142/7 142/8
144/25 145/3 149/24
150/10 150/15 151/5
151/12 154/7 156/16
157/13 157/20 157/20)
158/3 161/16 163/11
164/4 164/11 164/17
166/17 166/19 168/1
168/12 168/20 168/22)
169/4 170/25 171/12
174/18 175/2 175/4
176/24 178/3 178/10
180/19 180/22 187/16)
203/6 213/25 214/1
215/3 215/16 215/20
219/25 222/3
mean [34] 9/12 17/10
22/14 24/15 25/9
25/16 35/4 37/24
47/13 49/23 51/23
57/22 64/3 71/22
78/19 105/6 114/18
127/15 128/10 128/13}
144/21 157/21 162/22
164/3 165/24 167/6
167/9 175/23 182/17
186/22 187/25 188/17
191/22 201/24
meaning [2] 34/15
126/17
means [8] 60/10
102/12 102/23 139/5
150/25 151/2 151/6
151/17
meant [17] 10/6
17/12 24/9 24/12
24/24 26/1 27/9 53/20
59/16 102/25 110/20
126/16 129/24 151/18}
172/4 191/24 213/10
meantime [1] 92/1
measure [1] 54/4
mechanism [3]
205/20 208/6 212/1
mechanisms [3]
17/12 56/25 57/2
meet [2] 68/12 91/20
meeting [15] 70/1
89/20 90/10 91/1
91/23 91/25 111/6
125/9 146/7 146/10
146/12 146/15 146/17)
146/18 146/21
meetings [3] 13/21
36/14 38/12
memory [8] 47/17
48/22 61/15 61/20
64/8 103/24 111/8
208/5
mention [6] 40/9 70/3}
91/6 112/13 153/14
160/6
mentioned [9] 27/4
46/24 97/22 106/1
141/18 154/11 156/5
199/24 208/16
menus [1] 59/18
mere [2] 78/8 81/4
merely [1] 80/20
merged [1] 7/18
merit [1] 66/17
message [14] 18/22
19/4 19/13 20/5 20/5
39/4 39/21 96/12
183/9 192/18 192/20
196/1 196/4 209/21
messages [5] 196/1
196/7 196/19 207/3
207/5
Messrs [2] 44/18
157/6
Messrs Austin [1]
44/18
Messrs McLachlan
[1] 157/6
met [2] 91/1 146/19
methodically [1] 95/6
methodologies [1]
41/10
methodology [3]
42/8 43/1 99/4
MF [1] 200/12
Michael [1] 147/21
mid [1] 11/10
mid-1990s [1] 11/10
middle [3] 107/20
199/19 205/14
midnight [1] 14/15
mig [1] 191/23
might [33] 2/7 29/11
30/3 32/3 37/6 40/3
40/5 48/21 63/22 70/6)
72/8 89/5 89/12 93/5
96/5 96/18 114/16
115/4 115/7 121/2
129/6 129/9 150/5
153/21 153/25 177/18}
177/20 179/15 179/19}
181/11 181/17 183/1
223/9
migrate [1] 192/1
migration [1] 192/8
mind [11] 21/11
50/23 50/25 110/11
113/8 114/25 115/3
135/3 135/25 165/6
179/4
mindful [1] 178/19
mindset [1] 52/17
minor [1] 8/22
minute [2] 110/8
189/5
minutes [4] 203/7
210/10 210/11 210/16
mirrors [1] 202/23
misbalance [1]
198/24
misentering [1] 77/9
mismatch [5] 14/8
14/16 32/8 35/23
35/24
misoperation [3]
77124 78/14 78/16
Misra [24] 106/24
111/1 115/24 131/16
136/11 137/9 139/11
161/18 162/2 162/21
164/22 165/9 165/22
166/20 167/19 168/2
169/18 169/19 170/6
174/8 174/16
Misra's [15] 121/11
121/23 122/7 122/14
122/21 125/8 161/8
161/11 162/5 162/24
166/9 172/10 172/19
173/7 176/14
misreading [1] 84/13
misrepresented [1]
138/19
missed [3] 83/25
196/22 209/10
missing [2] 46/21
161/13
mistake [2] 79/9
79/13
mistaken [1] 40/25
misunderstanding
[1] 84/20
misunderstood [1]
84/21
mode [2] 192/14
192/14
moment [14] 7/3
30/6 50/23 64/10
71/12 83/2 116/10
130/16 132/2 132/19
132/20 135/22 176/11
223/19
Moments [1] 211/3
Monday [1] 41/23
money [11] 58/1 58/4
58/6 74/24 80/2 109/3
109/5 166/20 168/2
180/16 189/6
money' [1] 80/20
monitor [2] 17/13
199/8
monitoring [7] 16/2
31/6 31/16 33/24
34/24 58/14 221/24
month [5] 106/5
117/8 126/24 192/2
213/12
month's [1] 214/8
monthly [3] 192/6
202/14 213/10
months [5] 13/8
22/19 216/18 217/6
219/7
more [61] 13/7 18/4
19/10 23/10 24/17
28/22 34/13 39/20
41/9 47/4 53/14 53/23)
56/16 57/12 57/15
58/9 79/11 80/25
96/14 103/1 107/23
110/11 124/20 130/3
136/17 145/23 151/8
154/7 156/18 157/2
161/5 165/5 165/10
165/17 166/18 169/11
171/24 173/1 173/4
173/9 180/7 180/25
183/12 184/20 185/17)
194/21 195/14 196/9
197/1 201/12 202/18
205/17 205/18 206/7
206/10 206/18 207/8
212/7 212/24 215/19
221/12
morning [9] 1/3 1/9
64/10 64/19 97/9
142/8 144/22 197/20
(78) managing - morning
morning... [1] 219/5
most [12] 12/23
17/18 77/23 78/13
78/15 79/8 112/1
179/2 182/21 182/21
185/24 216/12
mouth [3] 109/25
110/12 110/13
move [9] 8/25 53/17
94/13 116/6 117/21
120/22 141/13 191/10}
202/14
moved [9] 8/23 19/11
23/1 24/4 46/17 49/14,
202/12 211/16 212/25
moving [5] 23/8
108/18 173/10 213/9
217/20
MR [134] 1/8 1/9 1/13
1/14 1/17 2/18 2/21
2/23 15/15 37/3 45/23
48/24 64/12 64/22
64/22 65/4 65/7 65/10)
65/23 66/19 67/5
67/16 72/2 74/8 75/6
75/13 75/24 80/15
81/7 84/4 84/10 84/12
84/12 84/17 84/18
84/18 84/19 84/25
85/5 85/11 85/15
85/24 88/1 88/11
88/14 91/16 92/2
94/14 94/14 94/15
95/19 97/6 99/15
99/17 99/22 101/6
101/7 101/11 101/13
101/20 101/23 102/6
106/22 111/1 112/5
121/13 121/22 121/23)
121/25 122/8 122/15
122/16 123/21 131/1
131/21 134/20 136/10)
140/7 141/6 141/15
141/19 141/21 142/7
142/14 142/15 142/20}
142/23 143/1 143/20
144/9 144/15 145/5
145/5 145/21 146/1
146/7 146/8 146/8
146/25 148/21 148/22)
149/17 151/3 161/15
166/8 166/9 166/9
166/15 166/24 167/13)
167/18 170/16 170/18}
171/3 172/18 173/22
174/22 175/1 175/4
175/11 .177/1 177/7
177/10 178/1 178/11
178/19 178/23 178/24}
179/6 191/6 192/16
219/3 223/24 225/4
Mr Allen's [3] 121/13
121/23 122/15
MR BEER [5] 1/8
1/13 2/21 84/4 225/4
Mr Burton [1] 219/3
Mr Castleton [3] 65/4I
65/10 66/19
Mr Castleton's [9]
64/12 65/7 65/23 67/5)
67/16 92/2 99/22
101/7 101/13
Mr Dilley [1] 99/15
Mr Dunks [2] 170/16
171/3
Mr Hosi [1] 111/4
Mr Hosi's [1] 170/18
Mr Ishaq's [3] 121/25
122/8 122/16
Mr Jenkins [29] 1/9
1/14 1/17 2/18 2/23
37/3 64/22 64/22 72/2
84/12 84/12 84/18
84/18 85/5 85/11
85/24 102/6 106/22
112/5 131/1 173/22
174/22 177/10 178/1
178/11 178/19 178/23)
178/24 223/24
Mr Justice [1] 15/15
Mr Lillywhite [1]
141/21
Mr Longman [2]
146/8 166/9
Mr McDonnell [2]
45/23 48/24
Mr McLachlan [10]
131/21 134/20 140/7
141/15 142/7 143/1
143/20 145/21 146/25)
151/3
Mr McLachlian's [3]
136/10 141/6 142/15
Mr Orzel's [1] 191/6
Mr Pinder [20] 74/8
75/6 75/13 75/24
80/15 81/7 84/10
84/17 84/19 84/25
85/15 88/1 88/11
91/16 94/14 95/19
99/17 101/6 101/11
101/23
Mr Pinder's [2] 88/14
101/20
Mr Prénovost [5]
141/19 142/23 144/15)
145/5 146/1
Mr Scardifield [1]
192/16
Mr Sewell [2] 94/15
97/6
Mr Singh [6] 142/14
142/20 144/9 145/5
146/7 166/9
Mr Singh's [1]
161/15
Mr Tatford [10] 146/8}
166/8 166/15 167/18
175/1 175/4 175/11
177/1 177/7 179/6
Mr Tatford's [1]
166/24
Mr Thomas' [3]
121/22 123/21 172/18
Mr Turner [1] 149/17
Mr Turner's [2]
148/21 148/22
Mr Ward [2] 94/14
167/13
Mrs [8] 111/1 125/8
161/18 166/20 167/19}
168/2 172/19 173/7
Mrs Misra [5] 111/1
161/18 166/20 167/19]
168/2
Mrs Misra's [3] 125/8
172/19 173/7
Ms [20] 62/9 98/22
112/20 118/13 121/11
121/13 121/14 121/23
121/24 121/24 122/7
122/14 122/15 122/16
129/2 147/20 161/8
161/11 162/2 162/5
Ms Chambers [1]
98/22
Ms Harding [1] 62/9
Ms Jennings [1]
129/2
Ms Misra [1] 162/2
Ms Misra's [7]
121/11 121/23 122/7
122/14 161/8 161/11
162/5
Ms Neald's [3]
121/14 121/24 122/16
Ms Panter [1] 112/20
Ms Sefton [3] 121/13
121/24 122/15
Ms van [1] 118/13
Ms Wylie's [1]
147/20
much [34] 1/4 2/24
5/14 13/13 14/23
23/15 41/9 48/9 53/23
53/25 54/8 61/2 62/5
64/21 83/23 98/9
107/23 110/11 126/20
126/25 130/20 140/10}
148/9 151/4 161/1
173/14 193/16 193/22
195/2 202/16 202/18
204/5 214/7 224/6
multicoloured [1]
74/14
multiple [1] 123/4
must [7] 2/1 2/7 2/16
69/10 84/24 112/24
128/3
my [122] 1/9 1/12 4/9
6/22 7/25 11/23 14/7
19/12 28/3 28/14 36/3}
36/5 36/10 38/21
39/13 39/14 40/18
48/6 48/10 48/20
49/23 50/23 50/25
51/10 52/20 54/18
55/6 56/13 57/24
59/16 61/15 61/20
62/6 71/19 71/25
75/11 76/9 79/11
80/19 84/19 86/1 87/2
92/10 92/17 95/2 95/9)
96/1 96/11 98/17
98/18 100/2 101/24
102/4 102/22 103/2
107/18 108/18 109/12}
109/25 110/13 111/8
113/24 114/18 114/22)
114/24 117/10 118/17,
119/21 124/14 124/15}
127/21 128/16 128/18)
130/5 131/14 131/19
132/20 133/12 134/22}
138/1 138/16 139/1
139/18 142/6 142/8
142/12 146/16 148/4
149/15 149/21 149/23}
149/25 150/1 150/3
150/3 150/6 150/11
150/21 154/21 155/4
158/6 161/22 166/11
166/24 168/18 168/23}
171/18 176/21 177/25}
182/23 183/8 185/14
185/23 188/7 192/21
194/22 195/3 203/3
203/12 208/20 212/19
215/13
myself [4] 110/22
112/15 118/16 127/21
N
name [13] 1/9 1/11
1/12 6/18 53/2 56/17
114/9 116/11 116/12
125/22 199/24 204/3
206/6
namely [4] 61/16
86/4 113/12 171/21
names [1] 108/6
Naomi [1] 90/6
narrative [2] 204/13
210/5
narrow [2] 154/4
159/5
narrowly [1] 184/1
nascent [1] 22/11
native [1] 74/15
nature [9] 12/19
26/12 38/1 44/21
109/16 111/15 123/25]
136/2 201/17
NBSC [3] 63/10
210/14 222/24
Neald's [3] 121/14
121/24 122/16
nearer [1] 129/19
nearly [1] 197/18
necessarily [21] 8/6
27/10 32/17 35/9
47/13 51/23 94/10
108/2 108/5 117/5
136/16 152/18 153/17)
155/19 155/21 160/21
167/21 188/24 201/14)
220/7 222/14
necessary [5] 118/5
128/18 139/3 178/25
185/15
need [45] 13/4 18/6
27/10 37/3 37/6 38/18I
61/9 61/17 62/18 63/8
67/8 78/4 78/22 82/24
87/18 93/19 95/6 96/3}
96/5 96/11 96/11
98/11 100/12 103/1
111/10 112/6 115/22
116/24 120/15 124/13)
129/17 130/3 130/6
130/6 154/12 157/25
164/5 168/17 178/20
181/3 187/17 188/8
188/21 191/3 196/17
needed [40] 9/16
20/16 30/23 34/10
34/11 47/11 55/7
79/16 98/9 104/13
108/14 113/12 113/23}
114/19 114/21 115/10)
115/14 117/9 124/16
153/6 154/2 154/7
156/3 163/2 163/3
164/17 164/19 166/14)
175/20 176/6 176/18
178/13 178/14 184/9
184/20 214/13 221/10)
221/11 222/14 222/21
needing [1] 45/6
Needless [1] 193/3
needn't [1] 157/18
needs [2] 108/16
215/19
negative [2] 211/3
211/6
negligence [1] 65/14
negotiated [1] 24/21
negotiations [1]
189/19
Nemesh [1] 112/18
net [2] 65/16 65/20
network [3] 22/18
23/20 28/23
never [15] 8/12 48/18)
49/6 58/2 94/7 110/11
116/21 121/18 122/10)
135/3 146/18 158/2
164/11 173/22 184/14I
(79) morning... - never
N
new [17] 22/16 54/16
59/7 59/24 62/24
109/8 119/21 124/5
156/13 156/16 192/19
196/19 203/12 205/9
211/14 211/16 211/24
next [13] 3/1 29/12
30/23 36/5 52/5 85/10)
100/8 199/18 199/18
201/5 209/11 215/9
219/10
nice [1] 190/12
niceties [1] 157/4
no [157] 2/12 8/12
12/5 12/11 13/12
14/22 18/6 22/16
23/23 25/25 26/13
26/13 28/10 28/14
29/13 31/13 34/11
35/4 35/4 37/5 38/18
40/7 41/14 41/22 42/8
42/8 42/16 42/17 43/2
46/18 47/3 47/9 48/3
49/2 49/3 49/5 49/6
50/7 51/18 60/8 61/9
64/2 64/8 67/2 67/23
71/6 71/15 71/20
72/24 77/4 79/25 80/5)
81/17 81/17 82/8
82/12 82/21 82/22
83/14 84/14 90/22
90/24 91/10 94/5 94/9
97/23 101/4 102/22
103/24 105/11 105/23}
106/1 107/9 109/11
110/19 111/17 112/6
112/13 112/16 115/2
115/6 115/6 115/13
116/5 117/18 120/21
124/20 124/21 127/14
129/23 130/13 134/23}
139/21 141/7 141/11
143/25 145/14 146/10)
146/16 147/7 148/10
149/5 150/7 150/22
151/15 153/23 154/7
154/11 154/12 154/15)
154/20 155/15 155/19
155/19 156/8 156/10
157/24 164/6 164/11
164/13 164/19 166/14
167/17 168/10 168/22)
169/12 171/24 174/2
175/9 175/22 175/25
176/5 178/9 179/20
180/19 180/19 181/3
182/16 184/7 184/12
184/13 185/4 186/1
189/9 190/24 192/22
195/16 196/17 198/10}
199/12 199/15 200/11
202/8 207/8 209/18
211/7 218/23
node [10] 194/22
195/3 195/10 195/14
195/16 195/18 195/18)
195/19 196/22 196/23}
nodes [7] 195/6
195/8 195/10 195/14
196/8 196/9 196/11
nominated [1] 11/23
non [2] 28/12 33/21
non-existence [2]
28/12 33/21
none [2] 135/9
156/13
nor [4] 107/7 107/11
139/9 161/21
normal [7] 93/17
150/25 151/17 168/9
169/14 210/12 210/12)
normally [5] 30/20
35/5 38/11 45/4 93/14)
not [255]
note [10] 69/6 89/22
90/10 91/24 99/2
132/19 146/10 146/12)
149/4 153/7
notes [2] 15/7 36/14
nothing [14] 26/17
45/14 47/3 48/6 58/17
67/9 67/20 76/12
102/10 110/3 160/10
199/17 199/18 214/21
notice [7] 57/9 62/5
113/3 126/20 151/4
173/1 173/9
noticed [2] 202/4
210/13
notification [1] 208/6
notified [1] 206/22
notify [3] 70/16
150/15 205/19
noting [1] 75/20
November [17] 24/8
65/2 74/10 76/6 88/2
89/24 94/7 96/25
97/18 101/1 112/7
116/8 117/7 119/3
120/8 134/11 198/13
now [70] 5/15 14/7
15/9 20/14 22/1 28/21
31/16 36/9 37/17
41/21 43/22 46/2
48/25 50/20 52/6
53/18 58/5 58/7 61/21
64/6 64/8 65/19 71/16
75/4 78/19 82/15
84/10 86/22 87/19
92/22 97/17 98/1
98/10 98/12 99/10
103/13 103/17 106/12)
106/13 108/24 112/7
116/16 118/8 123/13
124/22 125/22 132/1
134/14 136/19 136/25)
148/20 157/21 163/12)
165/2 165/24 167/20
169/14 180/21 183/18
192/22 197/7 197/12
199/9 203/25 208/11
213/8 216/3 216/20
222/2 222/5
NT [3] 106/2 162/14
205/21
number [24] 5/23 8/2
15/7 18/1 57/25 58/12
61/16 64/3 64/4 66/16
107/4 111/20 111/25
123/2 128/18 154/16
163/19 164/23 186/19}
196/10 214/22 214/23}
219/8 223/4
number 6 [1] 154/16
numbered [1] 218/19
numbers [4] 7/23
67/22 77/3 98/11
numerous [1] 210/22
(e)
oath [4] 150/19
objection [2] 2/9 2/10)
objective [3] 133/25
177/16 179/10
obligation [2] 177/17
179/14
obligations [1]
156/13
obliged [1] 65/12
oblivious [1] 16/6
observed [1] 209/1
obtain [3] 66/19
92/12 213/23
obvious [2] 178/2
183/6
obviously [14] 20/13
29/15 34/12 43/21
54/4 78/25 83/11 95/4
107/22 154/25 156/12
182/20 187/13 224/2
occasion [1] 51/16
occasional [1] 93/15
occasionally [1] 38/6
occasions [7] 49/11
107/4 111/20 111/25
123/6 155/7 163/19
occur [13] 37/6 37/11
37/13 114/15 135/20
135/24 157/20 163/11
169/4 175/23 180/15
180/19 197/6
occurred [21] 16/4
36/15 50/11 51/3
65/17 158/2 163/4
164/11 175/24 176/1
176/22 180/22 183/21
198/24 200/17 203/23
204/6 206/20 206/21
208/18 222/3
occurrence [5] 200/4
200/21 206/15 206/17
208/3
occurrences [4]
183/22 194/3 199/15
201/25
occurring [5] 139/6
183/1 186/20 193/18
202/10
October [6] 136/12
137/7 138/3 141/14
165/19 170/17
October 2010 [1]
137/7
odd [9] 65/16 66/14
114/20 204/20 206/1
211/2 211/3 211/5
211/6
off [16] 7/24 41/19
42/4 42/15 42/17 46/3
53/19 55/3 55/14
60/11 199/12 206/1
206/9 208/7 217/3
217/14
office [142] 9/6 9/18
9/20 14/5 14/6 19/21
20/12 22/5 23/13
23/17 24/2 24/7 24/10
24/22 25/4 25/6 25/13)
25/17 25/21 25/24
29/9 29/23 32/13 37/1
39/14 52/13 53/2
53/11 54/9 54/19
54/22 55/25 56/3 56/4)
57/2 57/7 58/13 58/17
58/20 58/24 59/9
59/11 60/23 61/1 62/1
63/13 65/9 65/11
65/19 66/2 66/25 68/8
68/16 71/7 74/2 74/22,
78/1 88/23 88/25 92/7,
94/17 95/14 97/16
102/3 107/7 107/14
108/20 109/4 109/6
109/21 110/5 110/18
110/23 111/18 112/15}
112/24 113/1 113/9
113/14 113/20 114/8
115/14 116/13 117/4
117/11 117/12 119/23
119/25 121/19 122/11
123/1 124/11 124/13
124/19 124/21 125/1
125/11 125/24 128/17
138/2 139/10 140/14
142/20 158/5 158/16
161/16 161/24 161/25}
163/21 164/9 164/24
165/17 165/20 166/18}
168/18 168/20 169/18}
170/1 170/7 175/2
177/19 177/21 178/18}
178/24 179/16 179/22)
180/16 182/6 198/22
199/1 204/17 204/23
205/1 205/3 205/8
212/15 213/8 213/22
217/7 218/4 219/10
219/19
Office's [13] 9/9 14/9
18/20 19/18 20/1 20/8)
58/6 61/6 65/3 71/11
92/7 115/16 180/3
offices [1] 54/3
official [5] 118/24
119/12 119/13 119/20)
120/2
officially [1] 119/19
offline [1] 92/8
often [3] 31/7 32/9
32/12
Oh [5] 23/5 35/4
137/12 137/18 177/24I
OK [1] 84/9
okay [33] 5/17 13/14
14/24 41/25 72/7
72/12 72/18 72/19
72/25 74/10 81/11
83/5 84/11 86/20
87/22 107/2 118/12
130/1 131/7 140/16
144/11 145/17 147/24I
156/3 160/23 194/4
194/7 194/20 195/5
204/4 205/6 206/23
208/25
old [2] 192/4 211/12
omitted [3] 138/19
139/2 178/25
on [306]
once [4] 97/10
196/18 211/5 213/12
one [84] 5/15 7/7 8/9
9/25 11/12 11/25 13/4I
13/7 14/13 18/18 22/6)
22/22 24/5 27/19 29/7I
31/19 33/12 34/1
42/24 49/24 50/2
50/21 50/22 50/24
51/16 54/14 61/7
62/18 63/20 66/5 76/2
78/19 81/2 84/6 86/3
92/17 104/22 107/25
112/6 113/11 116/19
123/18 123/20 126/1
129/12 136/9 136/12
145/11 145/14 145/15)
146/13 154/7 158/4
164/6 164/19 166/14
170/20 175/1 185/17
185/19 190/10 191/14I
191/19 191/25 193/5
195/14 195/18 196/8
196/9 199/12 203/17
205/7 206/4 209/10
211/13 211/14 212/14I
213/9 213/25 215/8
217/20 217/20 219/9
220/14
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ones [8] 31/9 35/25
50/17 160/12 163/3
171/23 189/25 190/17
ongoing [1] 34/9
Online [24] 8/23 8/25
9/3 9/7 9/13 10/16
15/19 15/24 16/22
17/16 30/25 31/4
31/10 31/12 31/23
32/1 32/2 33/19 35/17
35/22 36/1 148/14
183/20 219/15
only [39] 3/6 4/11
19/1 26/19 27/24 29/9
45/4 48/20 49/12
54/13 57/13 57/16
62/2 70/3 72/17 93/14,
94/23 106/3 107/10
108/2 110/25 115/9
159/5 159/8 159/18
181/25 182/10 183/1
183/14 188/11 193/23
195/18 197/12 197/16}
213/11 216/24 219/18
222/15 223/1
onto [3] 66/9 67/21
90/17
onwards [4] 38/22
162/23 162/23 177/7
open [5] 72/21
177/21 179/21 200/19)
204/15
opened [1] 198/15
openly [1] 26/23
operate [2] 9/14
39/25
operated [10] 30/15
31/25 34/16 38/23
63/9 63/10 107/24
126/15 130/10 187/10
operating [11] 16/1
17/7 23/18 34/4 34/4
47/10 51/21 92/5
159/23 182/16 202/20
operational [3] 8/9
28/23 93/17
operative [1] 183/15
opinion [23] 49/8
69/20 69/23 74/25
80/20 95/3 102/20
133/10 138/8 138/14
149/25 150/3 150/6
150/12 152/17 153/22)
153/25 155/17 155/18
155/23 155/25 177/16
179/10
opinions [7] 68/25
69/1 70/5 70/7 70/9
138/15 153/15
opportunities [1]
164/23
opportunity [4] 138/7I
138/25 139/17 139/21
opposed [1] 192/14
option [1] 79/12
options [3] 78/20
201/2 219/8
or [214] 1/20 6/6 7/24
8/3 8/3 8/9 8/11 9/23
10/9 10/10 11/18 12/1
12/1 12/22 13/8 14/18)
16/11 17/3 19/11
19/20 20/20 24/21
25/12 27/13 27/119
28/1 28/2 28/12 28/15
28/22 28/24 29/12
30/18 33/12 33/13
33/18 33/20 34/25
34/25 35/8 36/18
36/19 36/24 37/9 37/9)
38/3 38/11 38/11
39/12 42/3 42/14
42/14 42/20 42/24
43/3 45/6 45/13 49/24
50/2 50/6 51/8 52/5
56/6 57/7 57/10 60/5
61/13 61/17 62/14
62/21 63/5 63/20
65/14 67/12 68/22
68/25 69/14 69/16
70/14 70/16 71/3
71/21 72/6 72/10
72/17 74/3 74/19
74/25 74/25 77/11
77/24 78/14 78/16
79/9 82/1 83/11 85/8
90/11 91/5 91/8 92/12
93/5 98/20 98/23
101/18 103/23 106/6
109/8 109/21 111/7
113/10 113/23 114/2
114/8 115/15 116/4
117/16 117/18 119/9
122/4 128/6 128/8
128/13 129/6 130/13
133/11 134/3 134/22
135/12 135/23 137/1
138/19 139/2 139/9
144/17 145/5 145/15
146/5 148/13 150/17
150/25 151/17 153/4
153/12 153/18 157/17)
159/1 160/1 160/13
160/18 161/17 161/25)
163/7 163/23 164/12
166/1 167/6 169/23
170/5 170/20 172/5
174/4 174/10 174/10
175/10 175/11 175/13}
175/23 180/23 182/6
182/14 182/19 185/3
185/18 185/19 186/3
186/5 188/8 188/11
188/22 189/22 195/14)
196/1 196/3 196/9
197/21 197/22 198/11
198/20 199/16 201/18}
201/19 202/15 203/4
205/21 205/23 207/21
209/13 209/23 213/1
215/19 215/22 216/23
217/21 217/23 218/22
220/3 220/23 222/13
222/19 222/24 223/10
223/10 223/13
Oracle [5] 18/10
19/14 19/16 19/17
20/9
Oracle-based [2]
19/14 19/16
oral [2] 68/22 174/4
orally [2] 51/16
106/24
order [10] 63/7 66/22
78/5 116/21 148/3
184/21 185/14 188/21
190/24 219/7
ordinary [1] 214/21
organisation [1]
123/9
organise [1] 196/13
original [8] 74/11
75/24 77/2 83/7 104/9
104/14 106/5 214/15
originally [1] 43/25
Orzel [2] 187/6 187/7
Orzel's [1] 191/6
other [67] 7/14 8/19
8/22 11/12 13/17
14/14 18/15 19/5 20/7I
20/10 23/9 26/17
29/12 33/12 35/9
35/11 38/20 39/17
42/24 43/9 49/24 50/2
55/6 63/20 68/2 69/14
70/13 71/3 85/21
102/18 108/6 129/8
139/19 141/9 148/12
151/10 156/5 157/2
157/4 157/10 158/1
160/1 160/11 161/17
163/10 170/21 172/16}
174/19 174/19 175/8
175/10 175/13 175/14
176/7 176/8 181/13
181/15 181/17 182/14
192/11 194/2 199/2
201/25 203/22 205/21
208/12 209/11
others [8] 50/23
89/18 99/15 108/15
155/8 155/14 186/23
191/3
otherwise [1] 78/8
ought [3] 12/11
168/25 169/20
our [10] 1/18 38/12
75/5 99/18 116/24
118/24 126/9 138/15
148/7 217/10
out [81] 10/7 10/8
11/2 21/7 21/9 21/21
37/7 38/12 45/10
48/16 50/13 51/1 56/2
68/20 69/5 69/16
69/19 71/24 71/25
73/11 83/25 88/11
93/24 96/4 96/12
97/13 100/11 111/8
114/20 116/16 117/6
119/11 119/19 126/1
128/21 132/22 133/1
133/7 133/13 133/17
133/19 134/2 134/5
137/2 137/22 138/14
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148/23 148/24 149/1
149/18 149/23 150/13
151/8 152/15 155/16
156/4 163/8 163/14
165/15 169/1 176/8
183/5 185/9 186/16
186/25 193/5 202/9
203/15 207/21 210/25)
211/11 214/21
outcome [3] 158/14
158/15 190/14
Outlet [4] 198/20
outlets [1] 199/3
output [2] 25/22 55/7
outside [4] 93/16
105/17 118/24 119/20}
outstanding [5]
44/12 100/12 102/3
129/8 187/18
over [50] 2/25 5/25
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23/5 23/7 26/14 31/10)
48/15 52/4 59/7 59/24
64/5 66/15 67/4 91/8
128/5 128/7 128/12
132/18 132/21 133/13}
133/16 133/23 134/13
136/25 137/19 137/20
137/21 138/8 139/13
141/5 148/24 154/18
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200/16 205/12 210/10)
210/19 211/10 214/7
216/4 219/6
over-stretching [1]
48/15
overall [7] 29/3 34/24
53/6 73/25 166/24
167/11 216/13
overlook [2] 87/14
87/17
overnight [1] 19/22
overriding [8] 68/9
134/6 149/21 152/2
152/7 152/9 152/12
177/13
overrode [2] 177/17
179/14
oversaw [1] 55/5
overseeing [1] 41/9
oversight [7] 28/8
28/15 29/18 30/25
31/11 31/18 221/21
overtaken [1] 219/15
overview [3] 56/23
107/17 107/25
owe [4] 70/20 111/15
115/7 115/11
Owen [2] 116/8
116/13
Owens [1] 114/9
own [13] 12/6 65/13
69/2 69/23 70/11 95/2I
116/4 124/6 150/11
150/21 160/7 164/25
205/8
Pp
pace [1] 133/1
page [88] 3/14 3/25
AIT 4/10 4/24 5/7
43/25 44/7 44/13
54/11 55/17 55/19
56/22 65/1 65/6 67/4
73/8 73/9 73/18 75/8
81/6 85/14 87/23
88/13 90/16 90/17
91/13 94/14 95/22
116/7 117/23 128/25
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149/16 154/18 157/25]
161/8 166/5 166/23
167/25 174/14 177/5
177/6 179/9 187/5
189/3 199/4 199/14
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199/18 199/19 200/3
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201/3 203/17 203/18
204/11 205/12 205/16
206/11 206/12 207/16I
207/17 207/17 210/19
210/21 213/18
page 1 [2] 44/7 189/3
page 11 [2] 203/17
203/18
page 13 [2] 54/11
65/1
page 139 [1] 161/8
page 15 [3] 3/25
207/16 207/17
page 162 [1] 166/5
page 17 [1] 177/5
page 2 [4] 43/25
(81) ones - page 2
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page 2... [3] 94/14
187/5 213/18
page 20 [1] 137/23
page 22 [1] 56/22
page 234 [1] 4/24
page 27 [1] 140/17
page 3 [2] 117/23
206/11
page 35 [1] 134/5
page 4 [1] 132/17
page 5 [2] 132/18
174/14
page 6 [2] 132/21
149/16
page 67 [2] 4/7 4/10
page 68 [1] 177/6
page 8 [1] 116/7
page 83 [1] 5/7
pages [12] 3/10 3/10
3/21 4/7 4/22 5/6
136/10 141/5 141/5
141/9 141/9 142/16
paid [5] 11/18 13/1
22/3 54/4 113/23
pain [1] 14/20
pains [1] 177/9
Panter [4] 112/7
112/20 113/5 117/6
paper [1] 103/16
paperwork [1] 57/10
paragraph [49] 27/23
38/17 52/25 56/22
61/10 61/22 68/4
75/12 80/15 85/1 85/2
85/4 85/5 88/3 94/25
97/8 118/19 118/19
118/23 121/13 121/14
121/22 121/23 121/24}
122/7 122/8 122/15
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133/14 141/25 144/9
152/1 152/14 153/3
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166/22 181/3 196/17
203/18 205/14 206/14,
207/18 211/10 213/21
218/19
paragraph 1 [2]
152/1 218/19
paragraph 1.4 [1]
133/8
paragraph 1.5 [1]
133/14
paragraph 17 [1]
181/3
Paragraph 2 [1]
152/14
paragraph 20 [1]
52/25
paragraph 21 [1]
38/17
paragraph 25 [1]
27123
paragraph 3 [1]
153/3
paragraph 313 [1]
121/22
paragraph 329 [1]
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paragraph 331 [1]
157/25
paragraph 35 [1]
203/18
paragraph 36 [1]
196/17
paragraph 404 [1]
161/10
paragraph 41 [1]
61/10
paragraph 43 [1]
61/22
paragraph 463 [1]
144/9
paragraph 466 [1]
166/4
paragraph 468 [1]
166/22
paragraph 478 [1]
122/7
paragraph 51 [1]
207/18
paragraph 6.7 [1]
56/22
paragraph 619 [2]
121/13 122/15
paragraph 666 [1]
122/8
paragraph 669 [1]
122/17
paragraph 689 [2]
121/14 122/16
paragraphs [12] 18/6
54/12 92/3 101/23
121/12 121/25 121/25)
122/14 133/17 134/9
152/23 156/6
paragraphs 18 [1]
18/6
paragraphs 233 [2]
121/12 122/14
paragraphs 45 [1]
54/12
paragraphs 643 [1]
121/25
paragraphs 689 [1]
121/25
paragraphs 8 [1]
156/6
parameters [2]
193/15 207/1
parent [2] 195/16
195/19
part [51] 6/18 7/13
TINT 10/19 19/5 24/24
27/3 28/19 29/4 29/17
29/21 33/5 50/10
50/18 54/17 55/2
55/11 55/13 57/21
58/5 60/7 62/25 63/6
68/13 71/18 75/6
75/17 77/2 77/13
80/12 82/2 82/8 83/19
91/13 101/22 104/7
108/16 108/18 132/11
132/13 140/10 146/13}
149/13 149/13 180/11
185/22 187/7 197/23
208/1 211/24 217/19
partial [2] 159/3
159/8
participate [1] 26/6
particular [37] 12/2
13/23 24/18 28/4
28/11 30/19 31/8
33/13 35/10 36/4 37/8
40/5 52/16 52/16
110/25 123/16 128/16
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182/21 183/25 189/22
192/12 193/12 194/12
200/2 201/25 207/14
213/25 216/5
particularly [13] 16/2
31/3 31/9 40/1 45/15
46/8 54/1 59/14 63/12
83/14 136/23 141/1
178/3
partly [1] 104/14
partners [1] 117/15
parts [9] 5/21 39/4
78/10 88/11 134/14
137/1 145/25 146/25
167/15
party [5] 71/2 115/3
177/18 178/22 179/15}
pass [2] 83/22
142/12
passage [1] 175/24
passages [4] 71/13
147/4 147/20 148/21
passed [2] 99/7
215/4
passing [2] 215/21
215/22
past [8] 30/5 128/6
135/16 148/12 160/12
220/6 220/8 223/11
paste [1] 148/22
Patel [2] 112/18
129/3
pattern [1] 205/23
pay [12] 8/3 12/13
59/7 59/11 59/23 68/8
70/20 109/7 109/8
189/6 217/8 219/11
paying [2] 109/6
109/10
payments [5] 27/2
32/8 35/23 35/24
196/23
PC0033128 [1]
198/12
PC0121925 [2]
191/21 204/10
PC0132133 [1] 210/4
PEAK [15] 30/14
30/21 30/22 30/22
31/24 31/24 32/4
191/21 204/10 207/22)
210/2 210/4 212/4
212/8 220/16
PEAKs [10] 30/18
33/1 33/3 51/7 190/7
197/24 208/11 220/24,
221/21 223/10
Pearce [11] 65/2
73/11 74/9 76/4 88/5
89/17 90/16 90/17
91/2 91/15 94/3
pencil [1] 129/19
Penny [20] 93/3
96/12 97/14 110/22
111/24 112/2 113/5
113/12 116/10 116/15}
119/12 120/16 125/25]
126/24 128/21 131/10}
131/13 141/17 170/16}
171/13
Penny's [1] 141/22
people [37] 7/21 8/5
9/21 10/18 12/11
12/12 16/17 16/17
19/3 25/5 29/5 29/6
29/11 32/13 33/12
35/9 35/11 45/3 48/13
61/17 78/24 80/3 90/3
98/17 107/25 110/12
113/18 114/21 119/22)
119/24 144/23 145/1
145/9 212/14 220/8
222/16 222/19
people's [1] 22/3
per [10] 6/21 11/2
32/22 33/3 33/6 60/12
60/13 60/16 145/19
214/24
perfectly [1] 178/10
perform [4] 13/19
109/17 125/6 206/3
performance [7]
194/15 202/16 213/15)
213/21 213/24 218/6
218/8
performed [1] 95/16
performing [7] 33/12
70/19 108/10 127/17
132/6 135/23 143/24
perhaps [7] 83/15
84/1 95/11 141/11
205/20 206/18 222/4
period [11] 12/23
13/8 51/13 59/8 96/4
98/4 192/2 202/15
214/25 217/21 217/22I
periods [2] 59/25
192/7
permission [1] 63/9
permitted [1] 154/17
perpetuating [1]
120/10
person [13] 28/2
30/8 30/19 31/19 35/5I
69/18 105/18 107/10
108/2 140/11 146/7
200/1 201/19
personal [4] 28/14
115/8 150/7 154/11
personalities [1]
102/10
personally [2] 10/4
32/19
persuade [4] 12/11
47/25 48/4 48/18
persuasive [1] 47/25
peruse [1] 45/13
Peter [1] 90/3
PFI [3] 24/24 26/12
27/9
phase [3] 31/3 31/4
31/10
phases [2] 54/17
54/20
Phil [4] 56/5
Philippe [2] 141/18
141/19
phone [5] 36/18
38/11 138/8 144/17
146/20
phrase [1] 86/9
pick [2] 83/12 83/13
picked [6] 27/7 51/25
77/11 83/6 108/8
207/4
picture [4] 82/25
159/3 159/9 221/2
piecemeal [1] 216/11
Pierre [1] 125/12
pilot [6] 31/3 31/4
31/5 31/7 31/10 51/22I
pilots [1] 17/19
Pinder [28] 73/20
74/8 75/6 75/13 75/24I
80/15 81/7 83/1 84/10)
84/17 84/19 84/25
85/15 85/18 86/2 88/1
88/11 90/3 91/16 93/2I
94/14 95/19 99/15
99/17 101/6 101/11
101/23 141/23
Pinder's [4] 73/22
87/23 88/14 101/20
PinICL [12] 30/15
32/4 44/7 44/9 46/9
198/12 198/19 201/17
201/25 202/6 203/2
220/15
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PinICLs [14] 30/18
44/12 187/14 187/16
187/18 188/14 188/16
188/20 189/4 190/8
197/17 198/6 203/25
223/10
place [18] 9/16 17/13
21/23 31/5 33/24
34/17 42/8 43/1 44/10
49/3 93/14 93/21
93/25 112/17 128/2
197/5 208/6 220/9
placed [4] 108/3
108/20 109/20 110/5
placement [1] 80/21
places [1] 57/5
plainly [2] 217/5
218/1
plan [1] 103/25
planned [1] 143/1
plea [1] 142/25
please [125] 1/5 1/11
3/1 3/5 3/20 4/6 4/21
6/7 6/9 21/19 38/14
42/1 43/24 43/25
54/10 54/11 55/16
56/22 64/23 64/25
65/1 67/5 68/4 73/17
81/6 86/25 87/1 87/22
87/24 88/10 88/13
89/21 92/11 92/22
92/23 93/2 93/7 94/13}
94/14 95/18 97/5 97/6
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99/14 100/5 100/8
101/15 101/17 101/18}
112/4 112/5 112/19
116/6 116/7 116/7
117/21 117/23 117/24}
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133/4 133/15 134/5
134/13 136/9 137/19
137/20 137/23 139/14
140/17 141/13 146/3
147/8 149/16 161/7
161/10 166/3 166/4
166/5 167/23 170/13
170/15 174/14 174/14)
177/5 186/4 187/4
187/5 187/17 189/3
191/10 197/14 199/4
199/18 199/19 203/18)
204/22 205/12 206/11
206/12 207/17 210/19
213/18 213/19 215/24
215/25 219/2
plough [1] 146/5
ploughed [1] 146/6
plus [1] 34/19
pm [8] 106/16 106/18
130/21 130/23 142/9
173/15 173/17 224/7
point [22] 2/8 29/22
56/16 81/15 84/19
87/18 93/6 98/7 105/2
107/19 107/24 113/13}
119/11 133/17 135/3
140/20 140/20 142/9
144/11 144/21 145/7
217/7
point 6 [1] 133/17
pointblank [1] 46/3
pointed [3] 29/20
45/10 71/25
points [12] 7/14 7/14
67/7 95/8 98/6 101/2
137/24 138/7 152/19
156/20 166/18 167/1
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132/11 132/13 132/14)
POL00028867 [1]
204/11
POL00029411 [1]
136/9
POL00038878 [1]
55/16
POL00069822 [1]
103/9
POL00071427 [1]
89/21
POL00097123 [1]
128/25
POL00097138 [1]
112/5
POL00229801 [1]
117/21
POLFS [1] 57/2
police [3] 57/15
58/10 71/19
polite [1] 123/9
political [2] 47/20
48/7
poor [2] 42/7 42/25
populate [1] 196/13
Port [1] 192/18
Porters [1] 170/17
position [12] 14/15
36/7 36/11 54/1 83/18)
127/19 132/9 133/12
134/23 138/17 177/20}
179/19
positions [2] 14/13
42/6
positive [1] 219/20
possibilities [1]
185/23
possibility [2] 16/15
186/10
possible [11] 30/7
67/1 76/18 77/20 87/4
94/18 95/8 158/20
185/18 194/12 208/17
possibly [3] 37/12
48/4 95/11
post [154] 9/6 9/9
9/18 9/20 14/5 14/6
14/9 18/20 19/18
19/21 19/25 20/8
20/11 21/2 22/5 23/13)
23/17 24/1 24/7 24/10
24/22 25/6 25/13
25/17 25/21 25/24
29/23 32/13 37/1
39/14 52/13 53/2
53/11 54/3 54/9 54/19)
54/22 55/25 56/3 56/4
57/2 57/7 58/1 58/6
58/17 58/20 58/24
59/9 59/11 60/23 61/1
61/6 61/24 61/25 63/8
63/13 65/3 65/9 65/11
65/19 66/1 66/24 68/7
68/15 71/7 71/10 74/2
74/22 78/1 88/22
88/25 92/7 94/17
97/16 102/3 107/7
107/14 108/20 109/4
109/5 109/21 110/5
110/18 110/23 111/18}
112/15 112/24 113/1
113/9 113/14 113/20
114/7 115/14 115/16
116/13 117/4 117/11
117/12 119/22 119/24
121/19 122/11 122/25I
124/11 124/13 124/19}
124/21 125/1 125/11
125/24 128/17 138/2
139/10 140/14 142/20}
158/4 158/15 161/16
161/24 161/25 163/21
164/8 164/24 165/17
165/20 166/18 168/18}
168/19 169/18 170/1
170/7 175/2 177/18
177/21 178/18 178/24
179/15 179/22 180/3
180/16 182/5 199/1
204/17 204/23 204/25I
205/3 205/8 212/15
213/8 213/22 217/7
218/4 219/10 219/19
post-rollout [1] 21/2
posted [1] 58/4
postmaster [11]
210/9 210/16 210/22
210/23 211/1 211/4
211/7 211/16 214/10
214/13 216/24
postmasters [13]
19/8 57/25 58/16
58/20 58/23 213/6
216/9 217/3 217/16
218/3 218/16 219/17
223/7
postpone [1] 189/5
potential [1] 66/17
potentially [2] 57/13
221/2
power [1] 48/8
PowerHelp [1] 98/20
practical [4] 38/23
56/14 56/16 221/23
practice [3] 101/19
168/10 169/14
pragmatism [1] 47/4
preceding [1] 84/16
Precisely [1] 67/10
predecessor [1]
30/14
prefix [1] 118/17
preparation [2] 15/10)
145/3
prepare [2] 67/6
122/4
prepared [7] 69/11
95/16 132/2 133/25
147/12 196/3 201/4
preparing [4] 68/8
99/24 153/5 153/12
prescribed [1]
205/23
present [3] 97/16
103/25 106/6
presented [6] 45/23
45/25 46/1 136/7
159/3 159/8
press [3] 143/14
167/1 167/3
pressed [3] 36/23
214/5 214/16
pressure [2] 109/20
110/4
presumably [7]
63/10 73/5 95/12
118/3 137/16 189/7
214/13
pretty [1] 97/2
prevent [1] 116/25
preview [1] 210/17
previews [1] 210/13
previous [13] 3/11
41/10 76/1 89/23
99/18 113/3 119/3
129/14 140/22 166/11
179/9 180/11 181/1
previously [4] 46/24
177/25 193/23 201/20
price [2] 20/13 20/14
prices [1] 20/15
primarily [2] 18/22
52/15
primary [1] 104/23
principle [2] 1/22
1/25
printed [2] 214/6
214/17
printing [1] 214/3
prior [2] 63/2 220/12
priorities [3] 96/1
114/22 189/8
prison [1] 80/3
privilege [7] 1/23 2/4
2/16 72/9 72/10 72/16
72/21
probably [57] 13/7
15/5 27/7 31/2 32/7
36/17 36/25 41/24
48/9 53/16 66/8 79/22
80/10 82/15 83/6
87/10 92/19 96/6
96/10 96/11 96/15
100/12 102/6 104/18
107/24 108/14 109/18)
118/25 119/8 120/3
124/18 124/23 127/13)
127/14 127/19 132/14)
134/16 135/10 140/25}
141/3 144/21 145/8
146/6 146/19 156/18
167/7 167/17 168/12
169/15 170/11 206/5
207/6 208/12 212/19
215/16 220/13 220/24I
problem [54] 10/10
14/6 14/11 28/3 28/20)
32/5 32/7 32/9 32/10
32/11 32/16 33/16
35/19 36/19 36/20
51/18 67/3 96/1
148/10 162/16 162/17)
181/6 183/11 185/1
188/25 189/2 193/3
193/7 193/13 194/4
194/12 199/12 199/20)
200/6 200/19 202/3
202/11 203/11 203/19
203/21 205/2 205/2
207/12 208/2 208/8
211/23 212/1 212/10
212/22 216/18 218/11
220/11 220/12 223/9
problems [63] 16/17
16/24 17/14 17/18
17/20 18/1 18/1 18/2
29/25 30/5 31/8 34/3
36/12 36/15 36/22
37/13 45/21 51/3 51/4
51/22 51/23 51/24
65/25 67/13 139/23
161/17 162/1 162/12
174/19 174/23 175/13}
175/16 175/21 176/7
176/8 176/12 177/23
178/1 179/23 181/13
184/14 184/15 184/16
185/4 194/8 197/6
198/2 198/11 207/9
207/14 207/19 207/24
212/7 212/20 216/15
218/3 220/6 221/1
222/9 222/12 222/23
223/11 223/13
(83) PinICLs - problems
P
procedural [1]
117/17
Procedure [1] 68/13
proceed [1] 169/20
proceedings [6] 69/6
79/24 124/8 131/3
145/14 180/11
process [24] 10/9
11/21 19/23 53/13
77/13 105/7 105/19
105/24 112/3 112/25
114/17 139/5 139/20
142/5 161/21 164/3
179/5 190/6 215/16
216/6 216/16 218/20
222/9 222/20
processed [3]
202/18 214/22 214/23
processes [10] 34/17
34/19 42/18 54/21
57/10 63/6 113/15
208/13 208/17 215/1
processing [5] 16/13
19/22 57/11 207/3
214/8
produce [6] 19/24
158/10 169/5 196/13
209/8 213/2
produced [13] 15/8
25/8 55/3 60/2 60/4
103/16 135/19 136/3
163/18 169/12 172/8
209/12 211/17
producing [9] 22/11
27/17 157/14 157/14
169/21 192/1 192/2
192/6 202/19
product [1] 42/9
production [1]
214/20
productive [1] 91/24
products [3] 27/17
57/17 59/21
professional [7] 6/23
12/2 42/5 42/21 64/2
70/21 72/9
Professor [4] 151/19
163/18 177/22 179/3
Professor
McLachlan [2]
163/18 177/22
Professor
McLachlan's [1]
151/19
programme [7] 52/24)
55/11 55/13 55/23
60/20 62/10 212/18
progress [3] 199/8
204/13 213/23
project [11] 8/16
19/11 23/2 23/16 31/5)
53/1 53/8 53/9 54/14
59/6 61/11
prompt [1] 50/24
promptly [1] 52/12
properly [4] 129/14
1741/2 172/14 172/15
property [1] 27/12
proportion [1] 10/25
proposal [1] 97/12
proposed [1] 218/7
proposing [1] 216/19
proprietary [1]
148/13
propriety [1] 53/11
prosecute [1] 185/15
prosecuting [1]
180/18
prosecution [20]
13/22 74/3 77/25
79/19 80/6 111/24
113/11 114/3 115/4
126/9 127/4 132/12
132/13 137/9 147/11
158/11 162/9 162/21
174/8 180/2
prosecutions [4]
13/23 109/9 163/25
180/4
prosecutor [2]
114/25 177/22
protect [1] 194/14
protection [1] 197/1
prototyping [1] 219/6I
prove [1] 216/23
proved [1] 207/22
provide [17] 10/15
74/25 95/20 98/7
122/11 135/12 139/7
163/19 171/22 174/23}
175/16 175/20 183/24}
185/15 202/2 215/9
215/16
provided [21] 5/24
23/21 23/22 87/16
97/19 107/3 121/18
133/21 136/12 139/10)
140/1 147/2 148/1
153/18 160/17 163/24}
173/23 181/5 182/1
182/5 215/3
provider [1] 24/16
providing [7] 56/24
74/3 74/4 97/1 111/16)
134/25 135/13
provision [8] 13/17
15/2 39/2 72/6 91/3
94/1 94/4 172/4
Prénovost [6] 141/19
141/19 142/23 144/15)
145/5 146/1
public [1] 1/18
publication [1] 13/10
publicly [1] 109/21
pulled [4] 13/25 21/9
21/21 105/22
pulling [1] 113/41
purchased [1] 25/25
purely [1] 11/18
purpose [2] 56/24
211/24
purposely [1] 171/8
put [29] 1/19 2/3 2/4
2/8 5/15 9/16 9/19
45/3 51/25 56/11
67/15 71/18 76/24
83/7 99/2 109/24
110/12 110/13 117/13
120/15 120/20 128/19}
129/4 164/5 167/21
180/8 194/11 197/1
197/5
puts [1] 93/16
putting [6] 15/24
42/12 123/10 171/9
171/14 180/15
puzzled [1] 84/5
Qo
qualification [6] 12/1
42/5 70/16 83/7 87/15
150/17
qualifications [10]
42/21 69/13 69/18
69/25 133/2 133/5
135/4 140/21 148/24
163/7
qualifier [3] 82/13
83/25 84/2
qualify [1] 169/1
quantify [1] 216/23
quarter [1] 219/13
queries [2] 10/8
103/4
query [3] 93/5 104/25}
192/20
question [55] 1/19
1/21 2/3 2/7 2/8 2/9
20/24 36/5 37/25
41/12 49/18 75/1 77/2
77/17 81/2 81/11
81/12 82/2 82/8 82/20
84/9 84/12 85/20 86/1
86/4 86/6 86/8 86/10
86/10 86/11 86/19
87/2 87/18 88/7 88/7
88/10 88/10 92/14
94/5 95/9 113/19
119/16 123/4 123/8
126/7 154/4 157/16
158/15 161/6 163/5
175/3 175/4 181/10
184/18 208/24
Questioned [2] 1/8
225/4
questioning [3] 2/15
85/11 124/3
questions [37] 1/10
2/4 2/5 5/22 30/24
31/14 31/21 74/9
74/21 74/24 76/2
82/14 84/18 84/19
86/2 86/3 88/3 100/2
103/15 118/14 118/17]
119/8 119/22 119/24
120/17 123/5 126/2
126/6 126/11 126/23
149/24 152/16 156/10
159/5 159/13 186/4
204/4
quick [1] 92/4
quickly [4] 37/13
51/8 52/11 57/12
quite [29] 13/24 14/1
15/8 20/24 24/12 35/2)
37/24 38/6 41/16
41/18 52/4 58/24
64/14 77/19 89/7 96/6)
98/8 115/21 125/19
128/10 130/11 132/25]
140/8 140/12 147/4
162/22 180/10 180/20}
209/3
R
Rachael [4] 112/7
112/11 113/4 117/6
raise [7] 105/21
105/24 110/15 138/25
139/9 139/17 223/6
raised [12] 24/15
88/3 95/8 105/5
116/21 120/7 198/12
204/12 204/15 204/17,
204/23 210/5
raising [2] 116/17
161/25
ramifications [1]
221/23
ran [1] 46/3
random [2] 119/22
119/24
range [11] 16/6 69/20
150/12 150/13 155/17
155/18 155/23 155/24)
156/4 185/23 216/3
rare [3] 33/23 34/2
93/13
rates [1] 54/5
rather [35] 4/11 22/4
25/1 26/9 27/17 40/2
43/15 50/19 52/10
61/18 84/18 104/4
109/16 110/22 112/15)
123/15 124/2 136/21
143/23 145/24 151/8
153/11 156/19 157/4
166/20 168/2 168/16
170/11 175/3 181/13
211/14 211/19 212/2
214/24 221/13
re [6] 54/21 81/10
84/8 85/20 86/1 102/2
re-engineering [1]
54/21
reached [1] 69/24
react [1] 144/23
reacting [1] 10/11
read [37] 15/11 15/13}
36/10 48/15 56/23
65/6 73/6 73/8 83/9
84/24 86/18 86/21
133/9 134/15 134/17
134/18 134/19 135/15)
136/15 136/16 136/18)
137/23 140/4 140/24
141/3 146/25 158/6
171/2 171/23 172/13
172/17 174/7 174/10
198/19 200/7 203/2
206/13
readable [2] 165/5
165/10
reader [1] 163/12
reading [15] 20/4
70/13 73/12 94/25
101/24 125/19 144/20)
144/23 145/6 157/9
194/4 201/7 201/8
205/12 211/19
reads [2] 84/10
130/11
real [9] 26/18 49/15
66/23 67/23 76/24
77/4 80/9 102/21
221/18
realise [10] 15/9
34/10 82/15 84/1
124/22 151/11 154/24I
168/5 169/16 169/22
realised [10] 14/11
34/12 35/18 135/10
171/19 172/21 172/25)
173/9 193/23 193/24
really [62] 19/17
19/19 21/22 23/15
26/7 26/17 26/20 27/7
33/15 35/16 40/11
47/16 49/12 53/21
54/6 55/24 56/13 58/2
58/7 59/14 59/15
63/11 80/5 80/8 80/9
89/13 91/23 98/16
104/7 104/16 105/18
107/18 109/7 109/9
109/11 110/3 110/21
112/14 113/10 113/22!
115/18 119/11 124/4
124/11 124/23 127/24I
128/21 128/23 136/20)
143/15 144/3 146/22
151/3 151/4 156/23
165/6 167/7 182/22
184/18 216/22 216/23)
222/8
realtime [1] 53/23
reason [10] 58/2
70/14 71/6 82/19 89/3
(84) procedural - reason
R
reason... [5] 89/6
89/11 114/1 198/10
202/1
reasonable [5] 70/24
150/12 195/24 215/19)
223/8
reasonably [1]
163/13
reasoning [1] 72/25
reasons [4] 21/20
22/7 69/23 102/7
rebuild [1] 205/25
rebuilds [2] 216/17
218/20
recalculating [1]
98/3
recall [9] 38/19 46/19
90/10 111/13 125/22
144/14 161/24 189/21
191/12
receipts [3] 32/8
35/23 35/24
receive [1] 143/11
received [8] 57/11
73/5 92/1 102/14
124/1 142/1 144/21
178/11
recently [1] 45/18
recognise [7] 66/11
71/15 73/10 75/25
116/12 200/11 206/5
recognised [1] 139/6
recognition [1] 11/19
recollection [17]
6/22 40/16 47/22 48/3
48/20 49/12 71/15
71/20 90/24 91/7
106/4 146/14 146/16
174/2 175/9 175/22
176/6
recollections [1]
89/20
recommend [1]
205/24
recommendations
[2] 215/3 215/23
recommended [1]
80/18
reconciliation [2]
14/10 66/21
reconvening [1]
223/21
record [7] 18/24
76/22 77/1 91/25
93/20 115/1 209/20
recorded [6] 19/3
57/13 94/19 95/5
95/13 209/21
recording [8] 16/13
67/1 67/18 67/25
75/18 76/11 77/6
94/24
records [2] 20/8
92/13
recover [1] 65/20
recovery [2] 61/6
61/19
recreate [1] 200/25
rectifying [1] 37/23
recurrence [1]
218/11
red [1] 120/7
redeclared [1]
214/15
redesigned [2] 55/2
55/13
reduce [10] 44/11
58/3 58/12 58/15 59/1
60/21 61/1 61/3 61/11
62/3
reducing [3] 60/22
61/3 61/16
reduction [3] 59/2
59/4 61/18
refer [6] 5/21 11/5
70/8 80/6 99/18
199/22
reference [11] 20/11
20/12 20/18 59/20
96/5 129/21 140/18
148/20 166/17 192/5
204/1
referenced [1]
199/11
references [2] 5/16
103/8
referred [9] 36/22
37/4 37/8 97/21
161/12 178/6 201/18
210/14 212/3
referring [4] 63/3
130/8 153/10 206/15
refers [3] 88/8 149/4
201/25
reflect [1] 20/9
reflected [5] 8/6
67/21 75/21 76/13
162/20
reflecting [2] 163/6
208/11
reflection [1] 221/14
reflects [6] 76/7
76/14 76/23 133/12
201/16 203/6
refrain [1] 72/3
refresh [1] 206/2
refused [1] 168/7
refute [1] 109/21
regard [4] 70/4 124/7
126/13 153/14
regarded [2] 153/3
181/17
regarding [1] 74/22
regardless [1] 109/6
regression [1] 189/7
regularly [1] 41/19
relate [1] 116/20
related [2] 159/20
220/11
relates [1] 85/19
relating [6] 2/13 92/9
160/19 184/1 198/15
212/22
relation [17] 25/15
27/21 37/22 38/16
40/13 42/13 65/7 70/8
71/7 76/10 97/7
138/22 139/15 153/3
155/17 156/5 193/20
relationship [1]
40/22
relatively [2] 93/13
125/4
Relativity [1] 6/2
release [5] 54/17
54/18 191/21 201/5
201/6
released [1] 211/21
releases [2] 188/2
189/5
relevance [1] 160/7
relevant [19] 20/6
35/4 51/13 68/3 69/3
96/12 136/23 139/1
139/18 141/1 143/18
153/15 160/3 164/13
176/13 183/2 196/4
196/7 196/10
reliability [1] 109/23
relied [3] 37/2 197/24
220/7
reluctant [5] 105/12
105/14 105/16 142/9
143/3
rely [4] 2/3 69/15
107/14 178/24
relying [2] 37/18
138/16
remain [1] 200/19
remained [2] 6/23
210/12
remedy [2] 32/15
222/13
remember [81] 7/23
9/1 11/11 14/7 15/6
22/1 22/12 24/6 43/9
44/24 46/14 46/15
46/21 46/25 47/16
48/19 49/10 49/14
53/12 53/12 54/20
58/22 60/25 61/7
62/14 63/13 63/16
63/17 63/23 64/6
83/19 89/18 89/19
90/13 90/16 90/25
91/6 99/10 99/11
101/10 101/11 102/17]
103/13 103/17 104/18
105/3 112/8 120/6
123/16 125/21 136/19}
136/25 137/3 141/14
143/10 144/7 144/11
144/16 144/18 145/9
145/13 146/4 146/12
146/22 167/17 171/12
171/16 175/25 176/25}
177/3 187/24 189/25
190/9 190/16 190/23
191/8 191/24 211/22
212/13 219/22 220/14,
remembered [3]
71/22 167/9 167/13
remind [2] 1/25
187/6
remit [2] 118/24
119/20
remittance [1]
139/20
remittances [1]
139/16
remote [5] 92/14
92/16 92/17 92/20
94/2
remotely [4] 15/17
16/20 92/6 93/10
removal [1] 60/9
remove [2] 61/24
62/2
removed [2] 59/22
62/11
removing [1] 54/22
reoccur [1] 193/16
repeatedly [2] 216/16)
218/20
replace [1] 57/9
replaced [2] 23/23
87/11
replacement [1] 53/3
replied [2] 85/6
101/20
replies [3] 118/20
189/3 219/3
reply [21] 76/6 77/19
88/11 88/20 88/22
88/25 89/11 93/7 94/2
95/22 100/8 112/7
118/19 119/10 123/15}
124/1 129/5 129/10
144/9 170/22 216/2
replying [1] 119/9
report [87] 44/7
45/24 66/7 67/6 68/9
68/14 68/22 68/25
69/8 69/10 69/15 70/2,
70/10 70/13 70/15
97/16 99/9 104/2
112/12 112/13 118/7
118/9 129/12 129/22
129/24 129/24 131/16}
132/16 132/17 133/9
133/25 134/4 135/1
135/6 135/14 136/6
136/13 136/21 137/6
137/24 138/1 138/5
138/12 138/16 140/15}
140/22 141/6 141/15
142/15 143/21 145/6
145/8 145/12 145/22
145/25 147/18 147/21
147/25 147/25 148/3
148/21 148/22 149/11
149/23 150/9 150/16
150/18 150/20 152/16
171/8 171/23 171/25
172/3 172/5 179/1
208/16 209/12 209/22
210/13 214/5 214/12
214/16 214/20 219/4
219/5 219/10 219/24
report’ [1] 171/1
reported [2] 199/15
201/8
reporting [3] 55/20
104/15 213/5
reports [24] 44/9
67/6 118/10 136/10
141/10 151/10 151/20)
151/25 153/1 153/12
153/18 154/2 154/21
157/10 157/11 157/14)
159/13 163/18 196/3
196/14 209/8 213/3
214/4 216/25
repositories [1]
220/5
represent [1] 138/17
representatives [2]
6/1 89/17
represented [1] 2/12
representing [1]
94/17
reproduce [3] 193/14)
194/12 205/22
reproduced [5] 81/14
81/16 81/19 81/21
193/4
reproducible [3]
190/25 193/8 208/3
reproduction [2]
188/11 188/22
request [4] 18/20
79/21 88/2 190/10
requested [3] 148/13
171/11 171/12
requesting [1]
115/20
requests [8] 112/14
114/20 122/25 147/18)
147/25 148/19 161/20)
180/24
require [4] 57/3
148/16 190/25 218/9
required [26] 8/16
12/2 12/3 22/14 22/22I
23/2 54/20 95/25
100/19 101/7 101/12
108/23 115/4 124/9
124/10 129/7 129/16
(85) reason... - required
R
required... [9] 130/2
149/25 150/23 151/11
158/1 159/18 180/7
180/12 180/14
requirements [17]
7/18 8/23 9/7 9/9
23/14 23/15 55/24
56/2 56/5 57/14 57/18
59/13 68/12 70/2
116/19 127/6 157/19
requires [2] 70/15
150/16
requiring [1] 113/15
research [2] 34/13
100/17
researched [1]
144/12
resisted [3] 12/12
165/22 168/13
resolve [1] 214/14
resolved [3] 17/15
34/8 202/9
resources [1] 193/2
respect [6] 2/2 66/2
149/24 152/16 164/3
180/3
respected [1] 11/20
respects [1] 7/16
respond [3] 83/17
86/3 95/7
responded [3]
103/15 113/5 123/6
responding [4] 10/8
161/20 180/23 218/4
response [17] 75/5
80/19 81/10 83/5 84/8
84/11 86/5 86/7 87/2
87/25 88/2 88/8 88/12
95/16 119/13 126/6
217/11
responses [3]
118/17 166/24 179/3
responsibilities [4]
8/12 18/8 94/12
173/24
responsibility [5]
12/9 34/24 41/3 114/6)
197/21
responsible [5]
23/13 39/1 65/11 71/4,
73/25
rest [1] 191/22
restarted [1] 93/11
result [13] 12/10
16/11 17/3 68/6 93/10
93/12 103/16 154/23
155/7 203/1 203/4
212/1 213/13
resulted [2] 6/3
170/7
resulting [1] 196/23
retail [1] 40/22
retain [2] 13/4 115/1
retained [3] 13/13
57/18 93/22
retainer [4] 12/16
12/25 13/9 13/12
retired [2] 7/1 8/1
retirement [1] 7/10
reuse [1] 196/18
reusing [1] 212/2
reveal [1] 89/12
reverse [1] 176/3
review [6] 45/6 67/5
97/15 138/3 182/8
182/9
reviewed [2] 66/18
219/4
revise [1] 100/3
revolution [1] 23/11
rewrite [2] 47/10 48/1
rewritten [1] 47/21
Richard [1] 66/24
Richards [1] 149/5
rid [3] 14/23 58/24
58/25
rig [7] 192/12 193/12
204/25 205/1 205/4
207/14 208/13
right [70] 1/19 3/12
4/14 6/4 6/14 6/24 7/8
7/11 7/12 7/13 7/19
8/9 8/11 8/18 9/7
11/13 11/15 12/17
21/5 25/7 25/22 34/21
39/2 39/5 39/11 50/15
55/18 64/14 64/15
76/6 77/7 77/15 84/14
86/13 93/6 97/23
98/24 101/8 101/23
106/7 111/18 113/18
114/17 121/1 121/17
122/3 124/12 138/4
142/14 142/18 142/23)
146/11 149/14 170/2
176/15 177/6 179/10
192/9 195/1 196/19
211/20 218/13 218/18)
218/25 220/17 220/25
222/1 222/25 223/22
224/1
rightly [4] 53/12
rights [2] 25/25
26/13
Riposte [28] 18/10
18/17 18/18 18/19
19/5 19/9 19/12 24/17
38/14 39/2 39/16
39/21 39/22 40/7
186/9 188/10 190/12
192/20 192/23 193/7
193/22 193/25 196/1
203/21 206/20 206/21
206/23 208/14
risk [1] 24/14
risks [1] 24/16
robust [4] 15/17
16/20 17/10 17/12
Robustly [1] 17/9
role [45] 8/8 8/11
8/15 10/23 11/20 18/4
18/9 21/1 22/13 23/2
23/6 23/7 23/12 24/6
27/16 27/21 29/4
30/10 31/18 31/20
32/22 32/23 33/9
46/24 48/11 48/23
49/14 53/8 55/6
107/18 108/10 108/25}
114/10 125/5 125/21
127/18 128/3 143/23
143/23 180/1 180/2
180/4 189/20 206/3
212/14
roles [7] 18/7 24/4
28/7 30/24 34/24
116/17 141/23
roll [2] 59/7 59/24
rolled [2] 21/7 207/21
rolling [1] 216/4
rollout [6] 18/5 21/2
22/15 40/14 49/18
51/22
rollover [4] 214/1
215/9 215/13 216/8
root [7] 186/8 190/1
190/18 195/10 195/16}
195/18 201/15
Rose [4] 118/7 118/9
118/10 120/5
roughly [2] 11/3
211/6
route [2] 28/1 178/2
routinely [1] 221/6
rule [1] 2/10
Rules [1] 68/13
run [5] 93/4 122/21
193/5 216/21 216/21
run-up [1] 122/21
running [4] 107/12
202/4 202/6 215/2
s
$10 [3] 187/22 188/2
189/7
$60 [2] 54/17 188/2
$80 [6] 54/18 188/3
191/21 192/8 192/10
205/10
safe [1] 65/12
said [45] 15/18 15/23
16/9 21/14 30/23
37/11 41/7 45/10 46/6
46/11 46/20 47/2 47/2
47/19 47/24 48/10
48/17 48/25 49/1 72/8
76/16 78/18 78/24
87/4 110/1 117/20
117/22 119/18 120/19]
135/4 135/22 141/15
152/24 153/2 156/17
162/10 164/4 164/19
167/24 169/5 176/11
181/8 184/12 184/14
203/9
salary [1] 109/12
same [27] 8/3 9/15
30/24 31/14 31/21
31/24 37/18 52/23
109/10 111/2 116/9
123/4 123/7 132/10
134/20 140/7 140/8
140/12 140/21 1441/5
141/8 145/9 156/6
166/11 181/5 201/18
201/19
SAP [3] 53/15 53/22
53/24
sat [1] 64/4
satisfactory [1]
188/21
satisfied [1] 60/15
satisfy [1] 186/16
save [1] 58/6
saw [18] 19/8 33/5
36/2 54/2 96/24 119/3}
119/13 142/15 145/24)
153/1 153/9 169/10
178/1 178/2 187/2
207/12 218/12 219/22
say [123] 6/7 14/25
15/6 17/24 20/2 24/14}
25/1 25/4 26/5 26/7
27/8 30/4 36/19 37/2
37/19 47/15 49/4
49/12 50/2 50/5 54/12)
61/7 63/23 71/20 73/2I
76/13 76/20 77/7
77/19 78/5 78/13
79/14 79/16 79/18
80/8 90/25 93/8 97/2
97/3 97/6 98/20 100/9
102/11 103/13 109/25}
112/10 115/22 118/9
118/20 118/23 121/17]
122/3 122/10 126/4
126/22 127/3 127/8
128/5 128/14 130/1
131/12 131/18 134/21
137/4 141/24 143/3
145/2 146/1 147/24
151/14 151/16 153/7
155/3 155/21 158/8
161/11 161/24 162/11
164/17 166/7 166/19
166/23 167/6 167/18
168/1 168/15 168/16
168/16 168/20 168/21
169/12 170/23 172/2
172/12 176/5 176/21
177/8 180/22 180/23
181/4 181/15 181/20
182/18 184/24 185/4
185/22 187/11 189/12
189/17 190/24 193/3
196/16 201/11 201/16)
203/18 207/17 207/23}
208/1 208/10 208/15
217/12 218/10 219/20
saying [59] 17/11
30/20 52/21 56/13
56/19 72/17 77/14
78/4 80/23 83/4 83/11
83/24 85/15 86/5
88/25 89/4 94/20
100/20 101/23 110/3
123/6 143/9 143/21
144/2 151/6 153/8
156/21 156/22 156/24)
157/10 160/5 160/16
161/2 165/6 165/25
167/20 167/23 168/15)
169/2 172/22 173/5
173/7 175/17 175/18
176/17 178/7 181/24
184/6 184/10 184/13
184/15 184/16 184/22)
185/20 192/12 201/24}
202/23 206/7 206/16
says [24] 20/18 43/6
65/6 80/12 81/3 81/7
85/3 88/1 98/2 99/17
101/14 102/1 112/20
116/14 126/19 133/24)
134/9 137/25 175/12
189/13 189/14 192/16)
210/21 218/19
scan [2] 134/8 196/4
scanning [1] 212/20
scans [2] 216/16
218/20
Scardifield [2]
191/16 192/16
scheduled [2] 108/21
117/11
Scheme [1] 11/7
scope [4] 133/18
135/6 147/2 193/24
screen [5] 5/16 54/12
79/3 84/6 210/1
scroll [48] 56/17 68/4
T7IT 88/9 90/2 91/14
92/23 92/24 93/2
95/18 95/22 97/5
99/13 101/16 112/5
112/19 116/7 117/23
118/5 118/6 118/7
118/13 118/18 125/16)
128/25 129/1 129/5
129/10 130/1 132/16
133/4 133/14 133/23
134/10 149/16 166/5
170/15 170/22 187/5
204/15 205/13 206/11
210/20 213/19 215/24I
216/1 216/1 219/2
scrolled [1] 100/5
scrolling [3] 132/25
(86) required... - scrolling
Ss
scrolling... [2] 133/5
133/6
search [7] 220/19
220/19 220/25 221/6
221/9 223/10 223/13
searchable [2]
220/17 220/18
searched [1] 220/22
second [37] 4/5 4/16
38/17 44/13 57/21
66/4 66/7 73/9 75/12
85/2 90/16 94/25 97/8
99/24 118/18 118/23
121/16 131/16 132/17)
174/15 192/25 193/21
196/16 203/16 204/6
204/7 204/9 206/15
206/17 207/16 207/22
213/21 214/17 214/24
218/21 221/14 223/5
secondary [1] 192/24I
secondly [2] 192/20
203/4
section [6] 132/20
137/23 138/14 152/21
153/11 156/19
section 4 [2] 137/23
152/21
section 5 [1] 132/20
sections [1] 15/13
secure [2] 38/13 74/1
security [7] 38/9
73/23 73/24 73/25
79/22 116/13 141/22
Seddon's [1] 210/20
see [103] 1/3 25/7
25/25 30/22 35/21
35/25 36/21 43/25
44/4 44/13 44/19
44/20 47/8 48/3 51/10)
52/18 55/17 56/17
60/6 64/19 65/1 65/4
71/12 71/23 72/25
74/6 75/11 78/5 81/14
84/19 88/7 88/10
88/16 89/22 91/14
92/23 92/25 93/12
94/15 95/18 103/22
106/19 107/20 108/21
117/12 117/25 118/2
123/8 124/6 124/13
125/3 130/24 131/9
132/2 132/17 132/18
132/22 132/23 133/1
135/11 136/22 140/8
140/12 145/2 147/12
147/13 147/14 148/23)
149/17 151/10 162/13}
164/24 166/1 170/16
170/22 173/18 175/6
184/13 184/25 186/24}
188/24 189/1 190/8
192/17 198/13 198/16)
198/17 198/18 202/23)
204/3 204/11 205/13
210/4 210/8 210/21
213/14 213/18 214/2
214/24 215/10 220/5
222/2 223/22
seeing [6] 6/3 30/3
89/19 103/24 127/22
146/12
seek [2] 125/8
169/25
seeking [6] 72/5
84/17 143/24 158/16
164/25 167/3
seeks [1] 138/14
seem [2] 190/8
215/13
Seema [17] 106/24
115/24 122/21 131/16)
136/11 137/9 162/21
162/24 164/22 165/8
165/22 166/9 169/18
169/19 172/9 174/8
176/14
seemed [6] 51/3
110/8 115/21 170/4
178/3 210/10
seeming [1] 170/5
seems [4] 14/19
127/25 147/23 203/23}
seen [32] 11/18 35/8
35/17 45/9 45/17
45/18 45/20 49/7 51/9
61/8 63/19 73/1 97/4
101/14 103/14 144/16)
146/13 151/2 151/9
151/18 151/23 152/21
152/25 154/20 160/10)
161/18 163/19 165/24)
184/15 199/12 208/22)
2221/5
Sefton [3] 121/13
121/24 122/15
selected [1] 104/22
self [4] 1/15 1/24
2/13 14/17
self-contained [1]
14/17
self-incrimination [3]
1/15 1/24 2/13
sell [3] 9/22 20/17
20/18
send [9] 81/10 83/5
84/8 84/11 85/18 86/7
86/18 100/15 170/21
sending [2] 80/3
144/19
sends [1] 93/2
senior [5] 11/20
108/11 108/19 110/15)
212/15
seniority [1] 8/4
sense [10] 85/8 98/7
101/24 121/3 126/17
130/8 130/13 170/6
180/3 189/5
sent [20] 39/15 71/14
71/21 71/23 75/14
84/25 88/22 99/1
112/12 113/4 123/7
138/4 141/15 145/7
145/13 145/17 146/24)
170/20 175/1 214/1
sentence [2] 34/15
59/14
separate [5] 7/15
9/25 186/2 193/20
203/11
separately [1] 113/19)
September [3] 44/1
44/11 205/11
sequence [1] 145/9
series [4] 111/19
120/23 169/8 202/5
serious [10] 14/2
32/7 33/4 35/19 35/21
36/1 50/11 51/3 67/12
137/11
seriousness [2] 37/9
137/13
server [1] 203/20
servers [1] 186/23
service [5] 10/20
24/16 125/20 182/9
213/23
Services [6] 6/16
28/19 29/22 31/15
212/13 215/7
servicing [1] 30/6
set [23] 43/19 69/5
71/23 73/11 88/11
98/10 111/6 126/1
128/7 137/2 138/14
141/5 147/20 149/18
149/23 150/13 151/8
152/15 155/16 156/4
163/8 193/11 207/15
sets [16] 132/22
133/1 133/7 133/13
133/17 133/19 134/2
134/5 137/22 140/1
140/14 140/17 140/20}
148/23 148/24 149/1
setting [5] 56/2 68/20
148/20 163/14 165/15}
seven [1] 198/20
several [1] 74/21
severity [1] 187/19
Sewell [3] 90/3 94/15
97/6
shaded [1] 101/22
share [1] 27/10
shared [1] 191/21
sharing [2] 29/11
29/14
Sharron [1] 129/10
Sharron's [1] 116/19
she [39] 21/17 96/19
97/13 98/1 98/23
98/25 99/1 99/2 99/4
104/1 104/4 104/9
104/13 104/23 104/24)
105/7 105/7 105/12
105/14 105/16 105/19}
105/21 105/22 105/24)
106/1 106/4 106/4
106/9 106/9 110/22
111/2 111/6 112/8
112/9 205/25 210/9
210/13 213/6 217/25
she'd [5] 99/3 99/6
104/12 104/14 104/15}
she's [2] 96/20
104/25
sheets [1] 4/12
shifts [1] 29/8
short [5] 64/17
106/17 130/22 173/16}
209/9
short-term [1] 209/9
shortage [1] 210/15
shortened [1] 88/22
shortfall [1] 65/24
shortfalls [2] 16/11
17/4
shorthand [2] 1/23
21/14
shortly [5] 33/25 53/8}
91/25 99/25 137/7
should [76] 2/10 9/14
9/14 10/9 10/9 11/24
17/8 34/13 51/8 52/22,
56/1 57/10 60/13
60/15 68/23 69/6
69/21 70/2 70/3 70/10
71/6 72/2 77/10 77/13,
83/15 85/24 86/18
95/3 98/9 98/23
103/25 108/25 111/22!
111/23 112/14 119/11
125/14 127/10 127/17}
133/9 135/19 135/20
141/11 143/9 143/9
143/15 144/5 152/15
161/3 161/16 162/1
170/3 172/23 173/1
173/9 174/18 174/20
175/14 176/16 177/14}
177/21 179/21 197/6
197/15 200/7 204/12
209/10 209/13 209/14)
210/3 215/21 215/22
217/10 219/10 222/4
223/24
shouldn't [1] 118/25
show [7] 67/24 77/5
77/13 160/10 160/22
161/4 181/11
showed [2] 76/1
104/20
showing [1] 94/6
shown [8] 43/22 52/7
94/5 103/19 104/19
134/14 135/6 172/18
sic [3] 64/11 125/12
205/20
side [8] 5/15 23/9
47/25 127/23 138/15
138/15 198/1 198/16
sight [1] 221/19
sighted [1] 114/3
sign [10] 42/4 42/15
55/3 55/14 159/7
162/4 162/6 184/13
184/16 207/12
sign-off [2] 42/4
42/15
signature [7] 3/14
3/25 4/7 4/9 4/24 5/6
88/19
signed [5] 42/17
53/19 60/11 158/23
159/2
significance [1]
224/2
significant [3] 22/25
215/10 217/23
significantly [1]
214/25
signing [1] 150/14
silent [1] 206/20
similar [17] 7/15
67/12 96/18 134/10
151/2 151/18 180/12
183/22 199/16 200/4
200/16 201/18 201/19
215/8 215/12 220/6
223/11
similarities [1] 200/5
simple [6] 79/6 82/18
107/16 209/6 220/13
221/8
simpler [1] 119/10
simplest [1] 20/12
simplify [1] 59/18
simply [9] 12/6 67/21
75/21 76/7 76/12
76/14 171/20 190/1
206/1
since [3] 13/3 67/13
148/13
Singh [7] 141/17
142/14 142/20 144/9
145/5 146/7 166/9
Singh's [1] 161/15
single [2] 113/13
203/8
sir [24] 1/3 1/16 2/19
2/22 3/13 4/10 64/10
64/14 64/19 84/14
84/21 85/13 85/22
106/12 106/15 106/19)
130/16 130/20 130/24)
173/13 173/14 173/18)
223/18 224/6
(87) scrolling... - sir
Ss
sit [2] 107/19 178/14
sitting [1] 29/12
situation [1] 109/2
six [6] 13/8 21/4 76/2
86/2 198/20 217/6
skill [2] 70/21 222/13
skills [1] 33/15
skimmed [4] 15/12
73/7 134/16 140/25
skipped [1] 136/25
skipping [1] 211/10
slight [1] 40/9
slightly [11] 4/8
38/12 42/1 56/15 74/7
74/11 84/4 99/6 175/3
203/14 204/23
slow [9] 6/6 41/25
133/1 202/4 202/6
207/3 216/4 216/4
217/11
slowed [1] 208/13
slowing [1] 21/11
slowly [4] 216/21
218/14 218/15 218/18
small [2] 10/19 48/12
SMC [1] 223/4
snapshot [2] 198/22
204/19
snapshots [2] 66/12
66/20
so [251]
so-called [1] 169/5
Sodbury [1] 200/17
software [26] 10/14
18/11 18/14 18/19
19/14 19/16 39/2 47/6
47/10 92/6 92/8 92/10)
92/13 93/9 93/10
93/13 93/21 187/9
190/12 192/3 192/10
192/12 194/14 203/12)
205/9 212/5
sold [1] 27/17
solicitor [6] 71/25
72/4 91/15 98/6 99/15)
116/23
solicitors [6] 65/3
71/18 90/2 91/1 92/2
94/20
solution [1] 206/8
some [120] 7/14
12/12 16/24 17/21
24/14 29/8 29/8 32/9
35/1 36/8 46/15 46/16
47/14 50/11 51/5 51/6)
51/7 58/1 59/2 59/21
64/7 65/16 66/5 71/13,
77/9 77/11 78/5 80/2
80/2 80/25 89/9 89/10
89/24 96/19 98/3
98/10 99/5 100/17
100/24 103/4 103/12
103/14 103/16 104/23}
105/2 106/6 108/5
110/7 110/24 111/3
112/2 112/4 117/10
117/13 119/8 120/5
120/15 123/6 124/22
128/15 128/17 130/3
133/8 138/9 138/13
142/4 142/10 142/25
145/7 146/3 148/15
154/20 154/23 155/6
158/6 165/14 165/22
166/17 167/1 169/11
169/24 172/19 172/22)
172/23 173/6 182/18
182/25 183/1 183/5
183/13 183/14 185/6
186/3 186/4 186/7
186/22 189/24 189/24)
190/1 190/15 190/15
191/2 192/5 192/24
193/11 193/14 194/13)
194/21 197/23 200/10)
203/11 205/21 207/13
208/8 213/14 214/15
215/3 216/11 219/23
223/3
somebody [7] 30/3
33/12 72/10 97/24
135/17 178/13 178/21
someone [12] 23/5
36/18 45/9 94/18
125/20 127/17 129/24)
164/4 164/17 172/1
185/15 220/20
something [65] 7/9
8/1 9/17 12/22 20/20
21/23 23/8 24/20 25/2
25/12 25/13 27/2
31/15 32/6 35/8 35/13)
36/8 44/25 46/17 48/5
62/19 63/8 75/6 95/20
99/10 104/17 106/1
106/2 106/6 106/7
108/13 108/16 111/7
115/14 115/15 127/22)
128/6 128/19 142/13
146/17 151/2 151/18
151/21 164/5 164/18
164/18 164/20 168/21
176/2 176/17 180/12
180/22 181/8 182/20
183/25 189/1 190/11
190/12 190/20 192/21
200/14 213/12 219/20)
221/12 222/3
sometimes [4] 29/7
92/8 165/23 214/24
somewhere [1]
114/15
soon [2] 95/8 95/15
sophisticated [1]
18/25
sorry [22] 9/24 10/1
21/13 21/16 37/25
42/2 48/22 63/16 72/7
72/12 85/11 86/17
105/3 110/20 116/12
117/18 117/22 137/3
191/16 197/3 197/14
200/7
sort [58] 8/2 17/6
26/7 29/1 29/16 29/25
31/17 31/19 35/12
37/14 38/11 42/18
47/15 48/19 48/20
49/15 50/22 52/23
58/2 60/18 77/9 92/16
95/24 100/11 108/17
108/22 110/9 111/2
111/3 112/2 117/10
120/5 120/15 120/17
124/23 124/25 125/7
126/9 126/12 126/13
127/17 128/15 128/17]
128/21 151/10 164/20
166/14 170/3 174/25
182/18 183/22 187/25)
196/25 200/10 220/21
220/25 221/10 222/20
sorted [2] 119/19
202/9
sorts [2] 19/3 210/24
sought [5] 138/11
152/17 162/10 178/24)
180/5
sounds [1] 81/1
source [3] 139/23
150/8 154/13
sources [1] 133/14
speak [5] 28/11
29/16 80/18 89/13
120/8
speaking [2] 74/8
74/8
spec [1] 219/18
special [1] 22/5
specialist [1] 55/1
species [2] 92/20
94/2
specific [20] 27/18
28/3 28/21 30/10
39/22 80/25 86/8
103/15 119/8 130/4
159/23 159/23 172/5
180/24 180/24 181/11
182/22 182/22 185/12)
185/13
specifically [6] 27/25
41/3 61/7 107/14
166/12 182/1
specifics [2] 185/9
185/10
specifying [1] 9/10
specs [2] 26/22
26/24
speculate [3] 77/22
87/6 109/2
speculating [2] 87/12
200/13
speculation [3] 78/8
78/11 81/4
spell [1] 169/1
spend [3] 10/19
96/14 112/17
spending [2] 124/15
205/17
spent [5] 14/6 33/4
98/3 119/8 128/5
splits [1] 202/21
spoke [6] 97/9 106/7
142/7 145/21 179/7
200/23
spoken [3] 80/13
80/17 146/20
spreadsheet [1] 99/2
sprung [1] 106/2
Square [3] 174/17
194/1 201/13
SSC [13] 28/18 28/19
29/5 29/7 29/14 29/17,
29/20 36/18 37/22
197/25 220/20 222/12)
222/25
stab [1] 92/11
stabilised [1] 50/7
stable [2] 50/9 51/20
stack [1] 29/10
staff [7] 58/13 61/11
62/4 67/22 77/3 205/3I
205/8
stage [19] 2/14 32/9
60/5 70/15 79/23 89/9
91/4 91/17 97/17 99/5)
101/1 120/4 129/16
135/13 137/14 145/14
169/12 190/23 222/8
stages [2] 7/3 205/7
stamp [5] 9/22 20/13
20/17 20/18 20/19
stamps [3] 20/14
214/5 214/14
stand [3] 31/17 76/17
78/21
standard [16] 53/15
53/15 150/22 150/25
151/16 151/16 151/24)
152/5 152/15 152/19
153/1 153/4 156/14
156/18 156/21 156/22
standards [4] 41/10
42/8 49/2 70/21
stands [2] 53/13
200/12
start [19] 3/1 3/4 6/9
24/16 64/25 81/17
93/25 94/13 96/15
116/24 132/22 134/24
174/14 186/3 187/4
190/6 194/21 194/25
206/14
started [8] 7/24
20/21 23/16 26/19
37/1 188/2 192/6
214/3
starting [4] 98/7
195/2 195/2 217/7
starts [3] 87/4 132/17I
190/6
state [5] 50/9 66/7
66/25 92/4 188/22
stated [1] 210/17
statement [112] 3/4
3/5 3/8 3/19 4/2 4/5
4/11 4/15 4/17 4/21
5/1 5/2 5/5 5/7 5/9
5/11 5/23 6/20 7/25
8/14 9/5 11/5 12/15
14/8 18/7 20/25 27/22)
27/23 36/10 38/18
52/25 54/10 54/24
61/9 61/22 61/23
68/20 68/23 69/4 69/8I
69/8 98/19 99/17
99/19 99/24 100/3
100/11 100/21 110/2
120/23 121/12 122/5
122/11 122/19 122/20)
4125/2 129/13 130/5
131/13 131/19 135/12)
136/7 144/8 144/13
149/1 149/2 157/15
157/18 157/24 158/7
158/23 160/17 161/7
162/5 162/6 164/6
166/3 166/4 166/8
167/4 167/14 167/24
169/25 170/10 174/7
174/13 177/8 178/23
179/3 181/2 181/3
185/2 185/7 185/11
188/13 193/21 193/21
194/5 196/16 201/11
201/16 202/21 203/12
203/15 203/16 203/17
207/16 209/24 212/25
213/10 218/10 221/15
statements [42] 2/23
2/25 3/2 3/11 5/18
51/16 92/18 103/21
106/24 107/3 121/10
134/22 134/25 135/16)
153/12 153/13 153/18)
153/19 158/6 158/24
159/2 159/7 159/19
160/24 162/8 162/21
162/24 162/25 163/6
163/7 163/13 164/7
165/5 165/10 166/12
167/10 169/1 169/6
169/10 169/21 170/3
172/18
states [3] 18/21
102/5 210/9
status [3] 44/14
128/8 128/12
(88) sit - status
Ss
stay [1] 40/2
step [2] 18/18 30/4
Stephen [4] 91/15
94/17 100/15 102/2
steps [2] 9/21 67/10
Steve [4] 198/23
199/5 199/24 201/2
stick [2] 168/22
210/25
sticks [2] 50/23
50/25
still [10] 5/24 15/25
44/15 53/16 100/24
102/3 118/6 146/2
165/15 199/2
stint [1] 35/7
stock [6] 65/12 77/11
198/21 204/18 210/23
216/5
stolen [2] 166/20
168/2
stop [3] 6/6 205/13
210/20
stopping [3] 21/11
75/23 126/12
store [10] 18/23 19/4
19/13 20/5 20/6 39/5
39/21 192/20 196/4
209/21
stored [3] 195/25
196/8 196/11
stores [1] 96/13
straight [1] 35/6
straightforward [1]
119/17
strange [1] 166/1
straws [1] 93/18
Streamline [1] 27/1
stress [1] 2/1
stretching [1] 48/15
strictly [4] 65/11
striking [1] 180/20
strongly [2] 15/24
166/18
struck [4] 221/16
structure [6] 8/7 49/6
134/3 194/23 195/6
195/8
struggling [1] 85/10
stuff [12] 27/8 150/22)
151/10 151/16 151/16
152/5 152/19 156/15
156/18 156/21 157/10)
197/13
style [1] 166/14
SU [1] 191/21
subject [5] 99/16
121/6 141/4 141/8
174/3
submitted [4] 138/1
154/10 154/17 201/5
subpostmaster [16]
55/3 59/6 65/10 74/22
78/2 78/16 79/9 79/10)
89/4 138/23 139/3
139/8 139/16 158/15
158/17 223/14
subpostmaster's [1]
59/5
subpostmasters [16]
16/5 16/12 52/14
55/14 59/23 60/11
61/6 61/24 62/12
63/14 63/17 63/21
139/19 180/18 217/13)
221/17
Subsequent [1] 98/9
subsequently [6]
33/19 45/17 89/16
101/6 150/16 211/19
subset [1] 57/17
substance [7] 68/20
117/16 143/20 143/25)
144/2 164/9 165/20
substantial [1] 5/20
substantiate [1]
66/22
success [1] 170/5
successfully [1]
12/12
such [35] 2/6 2/8 8/7
12/5 13/23 24/16 27/6
30/8 30/12 31/2 31/22
51/3 66/16 66/20
69/19 77/12 100/18
112/14 112/17 116/1
148/11 148/16 151/12)
158/19 169/21 175/22)
186/13 190/11 190/22!
196/22 197/6 197/10
200/5 208/22 212/23
sudden [2] 23/9
193/2
suffered [4] 16/17
66/3 122/24 194/2
sufficient [7] 34/14
77/25 79/18 160/22
184/8 184/19 207/8
suggest [7] 66/14
93/25 144/17 161/19
169/19 178/13 189/22)
suggested [12]
25/24 40/24 70/11
79/22 84/17 108/7
136/6 150/10 154/19
166/14 218/7 223/14
suggesting [4]
103/14 127/16 167/15)
220/1
suggestion [3] 67/15
109/22 191/6
suggestions [3]
155/4 155/8 155/13
suggests [1] 176/24
summarise [7] 50/20
68/23 120/24 121/16
127/24 147/17 211/19}
summarised [1]
69/22
summary [12] 15/15
16/7 38/19 65/6 69/24]
137/22 148/8 181/8
192/16 194/22 195/21
210/8
supervisory [1] 8/11
supplied [2] 129/12
160/25
supplying [1] 129/21
support [55] 10/16
10/17 10/21 11/1 15/3
22/15 22/19 27/21
28/1 28/2 30/11 32/25
33/9 33/13 37/22 38/2
38/5 52/18 52/20
52/21 74/3 74/4 74/5
109/9 111/10 111/24
112/23 113/12 114/3
125/5 125/24 126/8
127/4 162/9 182/9
189/6 192/3 194/10
201/17 201/22 217/10
221/7 221/11 221/16
221/20 221/22 222/8
222/10 222/15 222/17
222/18 222/22 222/23
223/5 223/7
supported [1] 9/9
supporting [3] 10/19
22/21 170/4
suppose [3] 45/14
126/10 137/15
supposed [4] 10/11
11/2 31/16 114/7
supposedly [1] 203/1
sure [53] 1/17 6/17
6/21 10/25 15/4 15/8
16/15 17/20 20/24
21/22 22/9 24/12
25/22 26/9 35/2 35/12
36/17 37/3 37/24
59/15 74/1 75/4 78/18
79/2 80/8 94/9 97/2
113/20 114/21 118/4
119/6 125/19 127/8
128/10 136/4 145/8
145/19 153/17 155/19}
155/21 155/24 162/22
168/22 177/10 183/16
189/20 195/23 201/14]
206/7 209/3 215/7
220/18 223/24
surprise [5] 51/1
51/12 117/9 123/17
173/6
surprised [1] 51/5
Susan [1] 60/19
susceptible [2] 15/19)
16/23
suspect [5] 66/10
74/11 87/9 191/8
201/24
suspended [1] 65/18
suspense [26] 35/24
57/15 57/17 57/24
57/25 58/1 58/4 58/10
58/19 58/25 59/19
59/21 61/18 61/25
62/10 62/17 62/20
62/22 62/25 63/2 63/8
63/14 63/18 63/22
66/9 66/11
suspension [1] 67/14
suspicion [1] 192/21
switched [1] 208/7
sworn [2] 1/7 225/2
system [104] 7/8
10/20 13/19 15/25
18/5 19/22 22/11
22/19 25/22 26/3
26/14 28/9 28/13
28/16 29/3 29/13
29/19 29/25 30/14
30/22 31/12 31/24
31/25 32/4 32/6 34/1
34/4 34/16 34/19
37/14 39/8 40/5 41/4
44/23 45/2 46/16
48/12 49/19 51/20
51/24 52/1 53/4 53/10)
53/11 53/15 53/22
53/24 54/16 55/2 55/8
59/10 62/7 63/25 66/1
66/10 67/3 67/11
67/13 71/5 74/23 92/5)
92/7 92/10 92/15
93/20 95/2 98/14
99/23 108/1 109/8
119/21 138/10 139/7
140/10 157/3 159/21
159/22 160/1 160/9
162/20 171/22 172/1
181/16 181/21 186/6
190/21 193/2 193/10
193/19 194/15 205/21
211/2 211/5 211/12
213/21 213/24 214/7
217/4 217/17 218/1
219/18 220/9 220/15
220/16
system' [1] 67/2
systems [11] 17/7
17/22 18/3 19/18 20/1
20/8 22/24 38/10 74/1
190/20 223/2
T
take [17] 16/19 45/19
53/18 70/24 83/23
93/14 96/9 114/21
119/17 130/16 130/18}
140/22 158/4 168/5
243/11 217/15 217/22
taken [10] 62/5 83/6
83/15 112/23 151/3
156/16 173/1 173/6
173/9 217/6
takes [1] 215/18
taking [11] 6/20
14/12 14/13 14/14
21/23 31/6 42/11
213/2 213/4 213/7
215/15
Talbot [1] 91/16
talk [5] 32/8 38/7
144/25 175/9 220/20
talked [6] 17/6 27/5
27/6 35/1 188/3
199/11
talking [14] 13/15
13/25 25/6 29/12 33/4I
39/20 62/21 105/9
118/10 124/19 155/23)
159/20 187/25 204/22)
talks [1] 204/24
task [5] 43/19 44/7
44/10 46/9 182/10
tasks [1] 14/18
Tatford [11] 146/8
166/8 166/15 167/18
174/7 175/1 175/4
175/11 177/14 177/7
179/16
Tatford's [1] 166/24
team [59] 7/5 7/7
7IN1 7/13 7/15 7/17
7/22 9/9 10/4 10/5
10/22 23/1 23/3 23/5
23/6 23/13 23/17 24/1
24/10 31/5 31/8 38/5
42/17 42/19 42/22
43/4 43/10 46/5 46/12
46/18 46/20 46/25
48/25 49/1 49/4 49/10
49/15 73/23 73/24
74/20 79/22 85/2
91/19 92/12 107/18
111/24 113/12 114/3
114/10 116/24 132/12)
132/13 180/10 187/7
187/8 191/15 191/19
199/23 221/19
teams [3] 25/20 35/6
199/9
technical [16] 8/8
8/15 9/6 36/8 36/12
38/22 48/14 136/17
136/20 137/6 141/2
145/23 157/6 158/11
165/12 206/13
technicalities [1]
157/1
technician [2] 157/2
220/22
technicians [1]
220/10
technique [1] 9/18
technology [1]
187/13
(89) stay - technology
T
telephone [1] 38/3
tell [40] 2/7 2/16 8/14
9/5 10/13 11/9 12/15
18/9 20/25 23/1 27/21
38/16 52/25 61/9
61/22 73/24 96/10
103/21 111/9 120/22
121/10 122/19 123/18}
124/3 125/2 144/8
152/10 157/24 159/15
159/18 159/21 179/11
179/14 188/12 193/20}
206/18 207/9 219/17
221/14 223/25
telling [4] 43/7
114/19 124/4 217/4
template [1] 166/11
ten [1] 156/20
tend [6] 48/13 80/2
80/2 126/23 171/16
220/20
tended [1] 35/7
tends [1] 80/6
term [7] 55/25 158/20)
171/8 171/15 195/23
200/11 209/9
terminated [1] 66/2
termination [1] 65/21
terminology [1]
62/18
terms [33] 8/6 10/6
16/1 16/3 18/25 23/17
32/15 33/25 36/3
36/13 46/19 51/7 54/9
60/18 74/2 108/25
113/15 123/10 125/14}
128/13 132/1 136/7
140/17 144/6 148/20
165/15 166/13 167/22)
187/9 188/1 188/3
202/18 215/14
Terry [3] 46/2 48/1
48/4
test [17] 10/3 10/20
25/20 69/16 192/12
193/12 204/25 205/1
205/4 207/10 207/14
207/20 208/13 208/16
209/1 209/3 223/2
tested [2] 208/21
209/2
testers [3] 25/21
205/1 208/2
testimony [2] 133/11
139/19
testing [13] 10/9
25/20 25/21 26/6
30/17 42/8 43/3
192/10 203/4 204/25
205/7 205/9 208/17
tests [1] 69/19
text [7] 56/10 75/17
80/12 81/14 85/6
101/22 121/17
than [61] 4/12 13/7
13/17 22/4 23/10 25/2
26/9 26/17 27/17
29/16 38/20 39/18
40/2 50/19 52/10
61/18 71/3 73/2 79/11
84/18 96/14 99/6
104/5 108/3 109/16
110/22 112/15 124/2
124/19 124/20 132/7
136/21 143/23 145/24)
151/8 153/11 154/7
156/19 157/4 162/20
166/18 166/21 168/2
168/16 170/11 175/3
180/8 180/25 181/13
185/17 191/23 193/22!
194/22 205/17 206/10}
211/14 211/19 212/2
214/24 215/19 221/13
thank [65] 1/4 1/5
2/20 2/22 2/24 4/5
4/20 5/5 5/14 6/8 11/4
19/14 38/14 49/17
52/24 64/9 64/21
64/22 65/1 73/18
86/16 86/22 86/24
89/15 91/11 91/14
91/19 99/14 101/5
103/20 106/11 106/15)
106/20 106/21 117/22!
117/24 118/6 118/13
125/17 129/1 130/15
130/19 130/20 130/25)
157/23 164/21 166/5
166/6 173/12 173/14
173/20 173/21 179/25]
186/2 191/10 191/11
194/17 204/5 205/13
209/23 210/1 210/3
210/19 212/9 224/6
Thanks [1] 130/2
that [1527]
that I [2] 184/17
184/24
that's [118] 3/13 4/9
6/12 6/15 6/21 6/25
7/6 7/12 9/8 9/11 9/24
10/21 11/3 11/14
12/18 15/18 15/22
16/1 18/12 30/2 30/21
40/18 46/6 47/17
48/15 48/22 50/15
50/22 50/24 52/18
54/25 61/15 61/20
62/24 64/10 74/17
75/11 78/19 81/11
81/21 84/6 84/9 84/14
85/3 85/7 86/12 86/14
86/19 87/8 90/4 97/20
97/21 97/21 97/23
97/24 99/10 100/5
101/24 102/5 104/22
104/25 106/3 106/7
106/12 109/18 110/9
114/15 116/7 116/11
116/11 117/4 117/18
117/19 117/20 119/16
121/11 123/21 126/16
127/24 129/3 130/11
130/16 132/14 136/8
138/4 141/14 145/11
149/7 149/13 149/14
149/15 151/7 151/14
152/5 154/3 157/16
157/21 159/6 167/6
172/7 175/6 176/15
176/17 178/2 181/8
181/20 184/18 189/10
194/25 195/24 200/17
202/16 203/19 207/8
208/24 213/16 218/21
2221/6
their [32] 10/19 19/19)
22/4 23/14 23/15 24/5
26/23 29/1 29/4 38/7
38/10 38/12 47/10
53/13 54/1 61/2 61/4
62/12 63/14 63/18
63/22 114/6 114/9
127/9 152/16 157/11
166/12 168/20 186/8
187/19 205/8 209/24
them [70] 5/18 5/21
10/3 12/19 31/3 33/14
33/24 36/2 38/7 38/7
50/18 51/6 51/9 51/10
51/15 52/13 59/24
64/5 71/25 79/5 93/16
97/15 103/8 109/10
110/13 110/14 111/21
113/15 120/1 120/4
120/24 124/16 126/2
134/16 134/17 134/18}
134/19 139/4 146/19
146/20 146/25 147/22
156/14 156/17 159/8
160/6 164/16 165/5
165/16 170/25 178/20
178/22 178/22 179/9
186/22 187/21 188/7
189/5 189/8 189/14
189/22 204/3 204/4
204/5 216/21 217/4
218/5 219/11 219/17
223/6
theme [3] 107/1
131/2 131/6
themselves [6] 52/12
52/14 94/22 182/25
183/20 189/4
then [181] 3/19 5/5
6/7 6/17 8/21 9/1 10/2
10/3 17/11 17/14
17/22 18/8 19/5 19/14
19/25 20/10 20/17
22/21 23/22 24/22
27/1 30/21 30/23 32/4
32/6 32/9 35/18 39/24,
44/18 48/10 51/10
64/15 65/18 65/23
66/14 68/4 70/18
74/19 75/12 75/12
75/14 75/17 76/6
76/25 77/2 77/7 77/19
77/17 80/12 80/22
81/12 81/13 81/21
82/1 84/7 85/2 85/4
85/5 86/16 86/22 88/9)
90/3 93/2 93/7 93/11
93/25 94/25 95/18
95/22 96/16 97/14
99/3 99/5 100/3 104/4I
106/24 108/17 108/23}
109/1 109/13 111/14
112/1 112/19 113/19
119/11 119/18 122/10}
124/3 125/10 125/11
126/2 126/7 126/12
127/13 127/13 128/16}
128/22 129/19 130/1
132/17 133/4 133/7
133/13 133/13 133/16
133/16 133/19 133/23}
133/23 134/3 134/5
134/8 134/13 136/6
137/20 138/7 138/21
139/2 139/13 141/17
142/13 144/23 147/21
148/19 148/23 149/2
149/9 149/12 150/22
154/21 155/1 155/3
155/23 162/14 164/23)
165/2 166/16 166/22
170/22 175/2 176/7
176/16 182/20 183/8
183/10 183/18 185/15]
186/2 190/1 191/3
192/5 192/6 197/5
197/23 199/7 199/14
199/17 200/3 200/7
200/20 201/7 202/12
202/15 202/19 202/19)
203/8 207/4 208/4
209/10 210/11 211/10
212/1 213/18 214/4
215/18 215/19 215/20)
215/24 219/11 222/21
223/5
there [233]
there'd [1] 183/10
there's [12] 17/24
47/3 75/17 80/12
100/24 112/6 113/10
128/1 129/21 132/19
137/21 176/3
thereafter [1] 2/10
thereby [1] 16/12
therefore [40] 2/4
5/20 9/16 14/15 16/6
20/15 26/13 34/3 40/8
43/13 53/25 60/6 86/4
87/7 87/12 92/9 94/23]
103/2 104/13 104/15
1241/5 124/18 132/11
136/1 136/2 137/16
140/10 145/1 148/17
151/24 154/23 160/11
162/16 173/10 176/15I
186/25 187/2 196/21
204/3 212/25
these [43] 26/22 29/1
30/5 30/5 30/7 36/15
37/8 43/15 54/20 57/8
64/3 65/20 70/1 93/22
108/13 110/6 114/3
114/20 114/22 117/8
120/17 124/15 133/4
134/10 134/21 135/18I
138/12 146/24 156/13I
157/9 157/19 161/15
161/17 165/7 178/19
189/21 196/12 207/23I
208/17 211/8 212/6
215/14 216/12
they [190] 3/18 4/4
4/49 5/4 5/13 5/15
5/19 8/3 10/7 13/2
13/3 13/4 14/9 14/10
14/12 14/16 16/25
17/1 17/5 17/8 17/14
19/19 22/1 22/2 22/3
22/3 22/23 23/19 25/9I
25/10 26/5 26/23
28/22 29/9 29/9 29/15I
31/17 33/24 35/3 35/4I
35/6 36/2 36/5 37/13
37/13 38/12 42/10
42/16 42/18 42/24
43/8 43/17 45/4 45/11
52/12 53/13 53/14
53/14 53/22 53/22
53/24 54/2 57/11
57/23 58/3 58/5 58/9
58/12 58/13 58/14
58/25 59/1 59/7 59/11
59/24 60/13 60/15
60/16 60/23 61/3 62/6
62/7 62/8 66/6 66/9
66/10 66/12 66/14
66/18 67/1 69/2 73/12
73/13 73/15 73/25
74/1 74/4 78/25 79/3
79/7 92/4 92/9 92/11
92/12 93/21 93/23
94/22 94/23 108/12
108/13 109/7 109/8
109/10 109/24 111/21
111/22 111/23 113/6
114/5 114/5 115/18
115/21 115/22 115/23I
123/2 124/14 127/8
128/16 129/18 134/11
140/2 143/18 143/18
(80) telephone - they
T
they... [57] 144/1
145/1 145/2 152/24
156/11 156/16 157/7
157/10 159/14 160/3
161/1 161/2 161/25
165/15 170/4 176/9
176/13 178/14 178/15
178/16 182/25 183/3
183/14 183/21 186/17)
186/24 187/23 187/24}
187/24 188/1 188/5
188/8 188/15 191/6
197/6 197/8 202/1
204/2 209/21 214/4
216/3 217/24 218/6
218/15 218/17 219/11
219/12 220/10 220/11
220/18 220/24 220/25
221/1 221/17 222/15
222/23 223/1
they'd [3] 16/4 34/8
36/19
they're [4] 78/24 79/3
157/12 188/6
they've [2] 29/6
94/21
thing [16] 22/17
29/16 38/9 43/9 46/23
62/2 104/7 121/16
144/22 153/1 170/2
183/4 187/2 208/3
220/21 222/20
things [93] 8/19 8/23
10/11 12/21 13/15
16/3 19/3 20/15 22/2
22/22 23/9 24/25
26/10 29/2 29/25 32/3
33/5 34/18 35/7 35/17,
36/6 37/3 37/7 37/20
38/4 38/8 41/10 42/17
48/15 51/8 51/25
52/23 54/5 58/14
58/15 58/23 62/6
62/19 64/4 64/7 74/4
74/5 94/10 98/20
108/13 110/6 110/7
110/9 114/18 115/23
120/23 123/10 124/12
124/15 124/18 134/21
135/4 135/18 136/21
136/22 141/2 142/4
143/15 143/16 144/4
144/6 145/24 154/22
155/1 160/23 165/2
165/14 165/17 171/17
172/22 173/6 178/3
178/12 178/13 180/5
183/17 183/18 186/12
186/13 190/15 197/2
198/9 207/6 218/14
220/20 222/2 223/2
223/3
think [226]
thinking [3] 79/7
110/11 165/17
third [30] 3/14 4/20
27/25 37/21 38/2 38/4
81/2 82/1 82/7 87/2
90/17 94/25 115/3
120/23 121/12 122/19)
141/25 144/8 144/20
157/24 161/7 166/4
181/2 201/22 205/15
209/23 218/22 220/2
222/17 223/6
thirdly [2] 122/3
203/8
thirds [1] 205/16
this [322]
Thomas [11] 93/3
113/5 116/10 131/10
141/17 165/8 165/21
167/3 169/17 170/16
171/3
Thomas' [4] 121/22
123/21 172/9 172/18
thorough [2] 95/12
160/21
thoroughly [1]
186/12
those [84] 2/24 5/18
7/15 8/19 9/25 10/2
16/10 17/21 18/2
18/14 20/9 24/17
26/11 30/17 30/17
31/9 35/1 35/20 35/25
36/4 36/24 39/7 42/11
43/6 45/12 47/15
48/19 50/17 50/20
60/18 64/7 65/10
68/25 70/7 71/17
71/25 72/10 72/11
78/20 85/20 86/3
90/23 90/24 94/12
98/20 103/8 112/1
112/4 116/3 126/1
128/20 134/14 149/24)
150/15 151/8 152/19
152/23 154/23 156/7
159/20 160/3 161/1
162/8 162/25 164/12
164/15 169/10 170/3
172/15 173/10 174/5
174/18 175/7 177/3
179/3 185/19 186/21
197/20 198/2 198/5
202/6 203/13 221/23
223/12
though [12] 51/4
56/4 67/23 77/4
114/14 119/1 146/20
166/20 168/2 176/9
210/25 211/7
thought [37] 28/18
29/2 31/20 34/20
40/24 53/22 58/16
60/17 80/8 89/3
108/23 115/6 119/10
119/15 124/10 124/17
124/22 129/18 134/23
134/24 135/15 135/22)
143/16 143/17 144/4
144/22 153/24 154/2
156/10 163/3 165/3
165/7 172/20 176/9
183/24 185/3 200/16
thoughts [2] 142/6
193/6
thoughts/comments
[1] 142/6
three [20] 3/1 3/10
3/10 14/18 39/12
39/24 52/5 66/4 85/20
88/11 90/3 91/12
113/10 145/15 146/19}
177/7 199/14 202/22
203/13 203/19
three days [3] 14/18
52/5 145/15
three pages [2] 3/10
3/10
threshold [1] 36/16
through [37] 9/21
15/12 19/23 22/5 32/4
32/22 38/9 45/19 54/3)
60/17 63/10 64/4
65/13 66/13 73/7 94/7
99/3 100/10 111/23
112/15 112/24 119/11
120/2 132/25 134/16
140/25 141/3 148/7
149/12 152/23 163/20
163/20 187/17 210/2
222/24 222/25 223/6
Throughout [1] 8/8
Thursday [2] 50/20
161/9
tidying [2] 165/4
165/9
tightly [2] 57/15 58/9
time [198] 6/6 7/25
8/8 8/13 9/2 10/13
10/19 11/1 12/25 13/5
13/10 14/25 15/12
17/1 17/18 17/21 21/5}
22/9 22/12 24/3 26/8
26/17 28/9 28/11
28/17 29/1 29/7 31/20
33/4 33/6 34/1 34/10
34/11 34/13 40/1
40/23 41/16 41/17
43/13 43/21 43/23
44/12 44/22 45/16
47/16 47/23 48/9
48/10 49/16 49/18
50/8 50/12 51/10
51/11 52/16 60/16
60/18 61/21 64/8 71/3
71/17 73/22 75/4
76/16 78/18 78/21
78/25 82/16 83/12
83/13 84/1 86/15
86/21 87/21 91/20
95/5 95/25 96/2 96/6
96/24 98/3 99/11
99/12 100/11 103/18
103/23 104/12 104/21
106/8 110/4 111/2
112/17 113/21 113/24
114/21 114/24 119/18}
120/7 122/24 124/15
125/1 125/23 125/23
126/8 126/8 127/2
127/9 127/20 128/16
128/18 128/20 128/21
129/20 135/20 135/24,
136/24 137/4 137/7
141/22 144/12 144/19}
145/20 146/19 148/17]
148/18 150/14 151/9
153/8 153/23 155/15
157/22 160/10 160/14}
160/22 160/23 161/19)
162/4 162/18 163/4
165/1 165/3 165/16
165/18 166/1 166/7
167/2 167/8 169/4
169/16 169/22 170/20}
171/1 171/13 172/8
172/13 174/16 175/24}
176/22 180/14 180/15)
180/19 182/3 182/22
183/3 183/9 183/21
186/15 187/2 188/15
188/19 191/19 192/23
192/25 194/9 197/1
197/19 197/25 198/3
198/9 202/10 203/24
204/8 205/11 207/15
207/25 208/20 209/10)
209/11 211/5 211/25
212/16 212/18 213/2
213/13 214/7 215/15
215/18 222/4
time’ [1] 32/23
timeout [3] 161/13
162/15 194/3
timeout/locking [1]
161/13
times [16] 14/13
37/16 43/12 45/20
51/19 123/4 126/24
159/23 182/24 196/25]
198/5 202/15 215/13
216/8 216/21 217/23
timescale [1] 187/25
timescales [1] 96/14
timing [1] 110/11
timings [2] 214/1
215/9
title [4] 11/15 12/6
156/19 156/21
today [8] 2/25 16/1
16/16 20/13 20/19
76/17 173/22 181/8
together [8] 9/19
56/11 56/23 97/15
99/2 137/23 178/14
221/21
told [38] 12/13 21/25
22/1 22/6 24/8 29/6
39/1 40/17 42/3 42/11
43/15 45/23 52/13
58/9 58/19 60/19
60/24 61/5 61/13 62/3}
62/9 62/13 62/14
62/15 63/13 104/16
115/19 124/10 124/12)
154/7 164/17 173/22
176/6 176/11 176/15
176/18 215/11 217/17)
Tom [1] 141/21
tomorrow [9] 92/19
155/6 159/1 160/15
161/9 165/7 175/7
223/21 223/22
tone [1] 142/4
too [6] 14/23 62/5
82/22 157/7 195/2
217/9
took [22] 8/15 21/4
23/2 23/5 23/7 30/4
46/25 51/5 59/18 62/1
67/10 93/21 104/18
105/17 110/6 124/2
152/9 153/7 158/3
160/5 177/9 203/6
tools [1] 96/19
top [8] 55/19 75/9
81/6 85/14 95/22
101/18 131/8 204/11
topic [2] 107/1 186/2
total [1] 42/6
totally [4] 47/5 47/9
140/11 169/15
touch [1] 71/18
TP [2] 191/23 215/9
trace [1] 192/22
trading [11] 54/23
55/20 59/8 59/24
192/2 192/6 192/13
202/15 212/25 213/10)
217/22
trail [3] 93/23 94/5
161/4
training [5] 12/1
39/24 130/14 139/4
139/11
transaction [15]
55/21 57/8 94/19
94/21 95/13 97/7
138/22 138/24 139/1
139/5 139/9 139/12
192/19 195/25 209/10}
transactions [26]
16/13 16/14 19/1
19/23 19/24 20/7 20/9)
67/2 67/18 67/25
(91) they... - transactions
T
transactions... [16]
75/19 76/11 77/6
94/24 96/2 97/14
161/14 196/5 202/13
202/16 209/20 211/8
213/1 214/8 214/22
214/23
transcript [2] 174/11
204/1
transient [1] 203/9
transmitted [1] 19/25
Treasury [1] 54/5
treat [1] 24/25
treated [1] 140/13
treating [1] 132/15
tree [33] 50/21 51/14
194/18 195/1 195/6
196/8 196/9 196/12
196/18 196/21 197/8
197/11 198/4 202/19
202/22 203/20 204/10
205/25 206/2 206/5
209/7 209/16 211/23
212/3 212/7 212/21
216/17 218/12 218/21
218/22 220/2 220/22
220/23
tree’ [2] 211/13
211/17
trees [1] 195/22
trial [11] 104/5 106/5
122/21 129/3 137/8
164/22 178/16 211/13}
214/6 214/12 214/17
tried [8] 14/9 46/20
47/19 111/21 112/2
154/3 165/20 167/1
trigger [3] 36/23
129/22 147/5
trips [1] 39/13
true [13] 3/16 4/2
4/17 5/2 5/11 9/8
45/24 69/9 75/10 76/7
76/14 77/8 125/13
trusted [1] 124/12
truth [14] 69/4 69/8
111/9 123/18 124/3
125/2 152/10 158/23
159/15 159/16 159/18}
159/21 159/22 162/6
truthful [2] 156/12
158/2
try [11] 12/11 41/23
65/20 83/10 85/13
102/12 102/22 120/14}
120/15 120/24 216/11
trying [20] 14/22 58/6)
58/12 58/14 61/1 61/3
72/13 75/12 109/24
110/12 117/12 119/6
119/15 120/13 121/16)
127/24 155/3 165/18
168/15 168/20
Tuesday [3] 1/1
41/24 91/20
turn [27] 18/4 18/6
38/14 38/18 42/11
52/24 61/10 64/11
64/22 73/17 91/11
99/13 103/8 106/22
117/23 147/8 157/25
17715 177/5 177/8
181/3 186/2 194/17
196/17 206/8 207/16
209/23
turned [1] 185/9
Turner [3] 147/21
149/17 157/6
Turner's [2] 148/21
148/22
turning [1] 36/8
tweak [1] 164/25
twice [1] 46/13
twigged [4] 61/2
two [26] 13/7 14/18
18/14 18/19 32/19
39/4 39/12 52/5 54/17
81/3 82/14 85/21 92/3
101/22 113/10 117/15)
118/9 144/1 145/15
147/15 170/10 192/17)
197/18 205/16 211/8
216/15
two years [1] 170/10
two-thirds [1] 205/16
typed [1] 157/17
types [4] 18/14 80/1
92/17 192/17
typically [1] 126/20
typing [1] 157/17
typo [2] 76/24 77/1
U
Um [2] 15/21 194/24
unable [7] 47/24
83/17 87/11 139/22
184/25 193/14 200/25)
unacceptable [1]
4117/1
unaware [1] 43/16
unbiased [2] 177/17
179/11
unclear [2] 56/16
129/15
uncomfortable [3]
168/11 168/12 168/14)
under [17] 1/18
10/20 40/19 109/20
150/18 153/14 153/20)
154/9 155/12 155/16
157/12 159/25 174/22)
175/15 196/11 200/22)
204/13
underlying [4] 78/5
169/9 184/4 193/13
undermine [2]
177/20 179/19
underneath [2] 112/6
149/2
understand [71] 2/17
2/19 16/16 20/24
24/23 32/11 36/9 46/2
A7IT 54/6 57/21 58/3
58/8 59/13 68/17
72/14 73/15 74/7
74/16 75/3 79/23 80/6
85/14 86/12 86/22
98/25 101/9 102/12
102/22 115/7 115/11
115/18 118/2 119/7
124/11 126/8 126/17
130/6 130/12 131/24
132/1 132/6 141/4
149/21 149/23 152/7
152/11 153/4 153/13
153/16 153/20 153/23}
154/9 155/12 155/15
155/16 157/21 164/2
165/2 165/25 169/15
172/4 176/5 180/21
181/15 185/22 186/1
193/9 218/16 219/16
222/12
understanding [26]
38/23 40/18 56/12
57/24 62/16 62/22
78/1 86/1 95/12
101/24 102/19 108/24
115/16 121/1 121/6
121/11 131/3 133/12
138/10 158/9 163/23
176/22 185/14 195/3
203/3 215/21
understands [1]
134/6
understood [23]
36/13 54/7 57/23 59/9
59/15 63/7 79/19 85/7
86/14 115/13 129/24
131/21 141/7 148/14
152/2 159/3 159/9
165/16 172/1 175/18
177/10 180/13 221/22
undertake [2] 66/21
95/11
undertaken [8]
100/24 104/1 104/24
147/3 147/3 160/18
160/18 160/20
undertakes [1] 94/18
undertaking [1] 40/6
unexpected [1]
186/20
unhappy [1] 217/6
unit [4] 42/8 43/3
194/22 210/23
United [1] 18/21
units [2] 198/21
216/5
University [1] 6/10
unknown [3] 57/19
190/2 199/2
unless [4] 45/9 72/3
110/13 217/23
unlikely [2] 148/14
153/9
unpredictable [1]
208/14
unstable [1] 42/10
until [30] 7/1 7/10
717 8/20 12/16 12/25)
22/13 38/19 50/17
64/11 71/25 96/16
103/23 106/13 126/18}
130/17 130/18 162/10
173/13 179/2 183/6
198/3 198/11 205/11
211/15 214/4 214/6
214/25 219/22 224/8
unusual [2] 27/13
166/2
up [80] 5/16 11/3
18/6 25/10 25/22 27/7)
38/18 43/19 51/25
54/11 61/10 77/11
77/13 83/6 83/12
83/13 83/15 85/14
87/24 90/14 91/14
93/2 93/7 95/18 95/22,
97/15 98/10 99/5 99/8
100/5 102/2 103/8
104/2 104/4 106/12
107/12 109/9 111/6
112/19 113/2 114/21
118/7 118/13 118/18
120/3 122/21 129/5
129/10 130/1 143/18
146/16 157/18 157/25
165/4 165/9 167/15
167/19 168/6 170/23
177/9 181/3 188/2
193/11 195/2 196/17
197/25 207/4 207/5
207/6 207/15 209/22
213/1 213/4 215/24
216/1 216/1 218/17
219/2 219/11 223/18
update [3] 93/9 93/10)
213/23
updated [1] 92/6
updates [6] 92/8
92/13 93/13 93/21
188/5 188/6
updating [1] 92/10
upheld [1] 2/11
uploaded [1] 5/19
upon [12] 2/3 2/10
6/13 11/15 68/25
108/20 109/20 110/5
121/7 168/8 185/4
221/23
us [54] 1/3 1/11 7/4
8/14 9/5 10/13 11/9
12/13 12/15 18/9
20/25 23/1 23/20
27/22 29/6 36/20
38/17 39/1 42/3 42/11
43/7 43/15 45/23
52/25 60/19 61/9
61/22 62/9 64/19
70/17 71/9 73/24
91/20 99/11 102/3
103/21 106/19 120/23}
121/10 122/19 130/24}
144/8 157/24 173/19
173/22 178/1 180/10
187/6 188/12 193/20
206/22 218/5 219/11
221/14
usage [3] 59/2 59/3
59/4
use [19] 9/10 9/19
9/24 9/25 10/2 10/6
40/8 57/15 57/23
58/10 79/5 112/12
113/21 120/20 167/14)
172/8 195/24 212/6
223/12
used [23] 19/17
39/22 41/19 43/11
45/12 53/13 57/19
62/11 63/5 63/5 78/21
78/25 117/5 162/8
166/11 195/23 196/12!
211/12 211/13 211/24
212/2 212/14 216/9
useful [2] 87/16
219/14
using [4] 13/3 42/25
80/10 171/8
usual [6] 27/13
150/25 151/17 152/5
152/15 153/4
usually [2] 38/3
128/14
vo
vague [5] 40/16
47/17 48/22 89/19
106/3
vaguely [2] 40/16
90/25
validity [1] 70/7
value [3] 124/2
200/18 211/3
van [3] 117/25
118/13 118/15
vanished [1] 210/11
variance [1] 204/20
variation [1] 214/15
variations [1] 210/25
varied [3] 7/14 7/23
10/25
varies [1] 127/1
various [21] 9/19
11/24 12/21 13/25
14/17 15/13 25/7
30/16 30/24 57/2 57/5I
(92) transactions... - various
Vv
various... [10] 58/22
109/19 114/23 115/20)
115/20 118/17 126/23}
180/8 181/4 216/7
vary [1] 216/5
vehicle [1] 58/20
verified [1] 69/8
version [6] 44/3
44/14 74/15 145/12
145/18 167/15
versus [1] 198/5
very [50] 1/4 2/24
5/14 5/23 6/3 16/25
19/9 26/23 31/6 33/23
34/2 34/6 35/19 45/20
47/2 47/16 48/22
48/22 60/10 64/21
73/13 73/15 98/8
105/20 110/23 124/23}
130/20 134/10 134/20)
136/10 140/10 173/14)
174/17 174/22 175/15
184/23 194/25 197/9
207/7 208/14 214/22
216/4 217/6 217/11
218/15 218/18 220/18
222/5 222/9 224/6
via [4] 57/7 57/11
92/5 92/6
viability [1] 24/11
view [21] 17/17 31/2
34/21 56/16 70/12
92/10 107/24 138/23
139/1 139/15 139/18
150/11 163/13 165/19)
184/9 184/17 184/20
185/17 208/20 217/25
218/10
views [2] 140/2 142/8)
visa [1] 46/16
visibility [3] 24/14
24/19 26/14
visible [2] 166/16
183/3
visit [2] 38/7 43/11
volume [2] 6/3 96/8
volunteer [1] 159/25
vouchers [1] 139/8
Ww
waiting [2] 194/3
214/10
waive [1] 72/21
waived [1] 72/9
waiving [1] 72/16
Wannell [4] 189/10
189/15 189/17 201/1
want [22] 6/6 14/21
34/7 56/14 72/23
72/24 80/24 83/22
85/22 89/13 109/25
111/4 127/20 166/17
168/21 170/22 171/1
172/13 175/12 189/8
194/18 219/11
wanted [24] 47/5
53/14 53/17 54/19
56/3 56/12 57/23 58/3)
58/5 58/9 59/9 62/7
72/15 83/17 98/15
144/25 166/19 167/18)
168/1 168/16 168/16
170/21 173/10 220/19)
wants [2] 21/17
189/13
Ward [11] 40/20
40/23 41/16 75/3 86/2
86/7 87/25 91/16
94/14 167/3 167/13
warned [1] 218/5
warning [1] 145/1
Warwick [3] 174/7
198/23 199/5
Warwick's [1] 199/24
was [923]
wasn't [60] 6/21 8/6
13/22 15/8 23/9 24/23
25/4 25/13 26/7 26/17
27/2 29/17 33/3 40/1
41/14 41/22 42/23
43/12 45/12 49/8
51/10 60/4 62/15 63/1
63/23 71/24 83/14
83/18 87/7 91/7 106/9I
114/16 115/2 115/15
115/25 119/15 124/4
124/11 124/23 135/41
151/12 154/12 154/14)
155/20 155/20 156/3
157/14 160/10 167/7
169/15 173/3 183/6
184/25 185/9 190/10
193/8 194/1 198/10
205/2 211/15
waste [1] 216/13
watch [1] 174/10
water [1] 29/13
way [68] 9/15 10/9
10/10 10/17 18/23
21/23 23/12 24/20
26/14 27/13 27/13
27/19 30/15 31/20
34/4 34/16 36/12
42/23 42/24 47/5 47/8
47/9 47/12 48/11
48/23 49/24 50/2
51/24 56/15 58/7
59/17 63/20 73/15
79/7 85/21 94/7 96/11
101/25 109/10 110/6
111/4 111/22 115/6
1417/2 119/1 123/9
123/10 132/10 140/8
144/20 148/7 162/15
165/14 165/24 170/9
176/24 178/12 178/12,
181/5 183/16 192/4
194/14 201/22 203/14
205/16 207/14 209/11
220/13
ways [1] 32/19
we [241]
we'd [6] 99/10
143/16 143/17 144/4
182/4 213/12
we'll [14] 14/23 17/21
64/11 92/23 92/25
95/18 111/10 118/3
123/13 131/9 148/7
159/1 160/15 175/7
we're [18] 30/6 32/7
52/3 60/9 92/19 97/17
132/2 132/19 155/6
161/8 165/6 166/6
180/15 187/25 191/11
198/8 204/22 219/12
we've [21] 29/5 30/4
35/1 40/14 45/20
60/19 88/6 92/25 97/9
146/10 148/5 154/20
163/19 171/23 175/7
186/4 186/7 188/3
202/5 203/2 212/22
website [1] 5/19
week [28] 9/23 13/8
39/10 39/14 39/15
39/18 39/23 39/24
40/10 41/20 43/12
53/20 53/21 94/22
96/9 96/15 96/16
96/20 98/12 128/5
129/13 146/9 182/15
192/2 205/17 217/20
217/21 219/10
week's [1] 202/13
weekends [1] 93/16
weekly [3] 202/12
213/9 216/8
weeks [5] 40/3 45/1
66/16 198/25 217/24
weeks' [1] 213/1
weight [3] 47/20
47/25 48/8
well [58] 14/3 17/1
17/16 17/22 18/3
18/18 20/18 27/6 29/3
30/17 32/10 35/1 40/3)
49/19 50/6 56/14
56/20 60/3 76/17
79/21 83/24 85/7
86/16 87/19 93/16
96/19 108/15 110/2
110/16 111/9 113/10
123/2 123/6 124/3
124/22 126/15 127/11
127/16 134/24 135/15}
140/8 152/9 153/6
154/1 155/23 156/3
157/6 157/9 157/14
164/4 170/1 171/6
172/1 176/15 180/7
181/8 207/7 208/20
Well-known [1]
171/16
well/instead [1]
127/11
Welsh [4] 212/11
212/12 212/13 213/20
went [20] 8/20 9/20
9/21 25/19 28/23
28/24 35/6 39/10
39/12 39/25 40/4 40/7
64/3 92/8 99/3 169/5
197/1 205/9 208/5
222/12
were [345]
weren't [14] 20/15
37/14 88/24 136/13
143/18 154/13 156/16
156/21 157/7 158/12
162/12 184/14 194/8
218/16
West [3] 49/2 139/23
142/2
Westmoreland [1]
200/22
what [348]
what's [9] 11/6 20/13
36/21 52/22 63/4
82/24 120/18 123/14
130/4
whatever [4] 9/23
20/19 32/16 188/19
whatsoever [1] 67/3
when [96] 5/21 6/7
6/17 10/8 11/11 13/5
13/6 14/8 15/7 16/4
19/2 19/11 24/4 24/7
24/14 29/18 30/11
32/6 35/16 36/14 37/1
37/12 38/20 39/15
44/24 45/1 47/10 48/5)
48/14 51/1 52/17
64/11 71/17 72/1 72/2
76/24 92/8 93/21
107/12 108/6 113/5
115/9 117/7 118/9
120/14 120/25 123/6
123/13 128/8 134/19
135/15 142/11 142/15}
145/5 146/23 152/19
153/12 153/18 155/7
159/14 162/12 162/13
162/23 168/19 168/23}
169/12 172/20 180/17}
188/1 189/6 192/5
192/19 193/2 196/3
197/13 197/17 197/20}
198/4 201/12 202/4
202/12 202/14 204/19
204/22 211/11 215/1
215/9 216/4 217/5
217/9 217/18 220/3
220/10 221/17 223/8
224/2
when I [1] 113/5
where [48] 19/1
19/18 21/24 24/15
25/3 28/1 28/2 28/23
36/23 38/10 53/13
54/8 62/24 69/20
98/11 109/24 110/1
111/8 111/25 118/16
119/3 123/18 126/1
127/2 133/22 138/13
138/15 140/2 150/12
154/10 155/17 155/24)
157/22 181/4 182/23
183/6 183/7 186/9
186/20 190/1 190/6
194/2 196/22 201/17
208/6 214/9 218/19
222/19
whereas [2] 88/24
140/11
Wherever [1] 150/7
whether [46] 2/10
2/17 21/11 31/17
33/11 34/8 42/13
42/20 42/24 43/3 50/6
51/8 52/7 67/12 67/15
68/21 71/21 76/23
91/5 92/12 93/23
128/1 128/13 144/14
144/17 153/7 161/16
161/25 163/23 164/24)
166/13 168/25 170/2
170/2 183/25 189/1
190/20 191/4 202/23
206/19 207/19 207/21
207/23 217/7 220/6
220/11
which [165] 2/5 3/5
3/20 4/6 4/12 13/2
13/11 13/25 14/18
15/8 18/23 19/25 21/1
21/8 23/21 28/25
32/17 32/19 33/1
35/14 35/20 37/9
44/10 45/2 46/1 46/16
48/12 49/13 51/8
52/13 53/20 54/14
54/19 55/1 55/13 58/2
58/13 58/16 59/19
66/3 66/25 68/22
68/24 68/25 69/2
69/12 69/15 70/4 70/6
70/6 70/8 70/9 70/19
72/5 TAIT 74/8 74/8
75/10 76/1 77/10
79/16 80/2 80/2 80/12
84/17 84/25 85/2
87/25 88/9 88/19 92/5I
93/21 94/1 96/6 98/19
99/25 101/14 103/15
105/7 105/22 105/25
106/23 109/25 111/7
111/12 115/21 116/9
(93) various... - which
Ww
which... [78] 116/20
120/15 120/20 121/19)
122/20 128/8 129/8
129/17 131/2 131/4
131/11 132/16 133/10)
135/12 136/5 138/10
140/1 145/21 146/17
147/1 149/25 150/2
150/5 150/5 150/9
151/22 152/16 153/3
153/14 153/15 153/21
154/18 157/17 158/11
159/8 160/2 160/17
161/19 162/13 162/15
163/1 166/4 166/16
166/22 170/17 172/20}
173/25 175/20 177/6
178/13 178/24 182/9
182/25 183/1 183/13
183/14 185/2 185/4
188/3 188/8 188/12
189/25 190/9 193/1
193/8 193/8 193/12
194/8 194/9 194/14
195/10 195/12 198/10
199/8 204/10 205/20
211/6 215/4
while [3] 100/12
125/10 183/14
whilst [4] 53/22 68/7
140/11 144/22
who [54] 2/5 10/4
10/15 10/18 11/12
11/23 28/17 28/20
29/12 29/18 30/4 30/9
33/13 40/23 41/15
56/5 60/19 65/2 67/8
69/16 69/18 84/17
95/11 107/25 108/3
112/8 119/2 124/20
125/12 125/18 127/10}
129/16 129/24 141/18)
141/19 141/21 145/8
145/13 172/1 175/2
178/21 187/6 189/18
191/12 199/22 200/1
201/1 201/19 220/4
221/20 221/22 221/23
222/16 223/4
whoever [2] 35/4
46/1
whole [13] 6/23 18/3
24/25 29/22 60/16
107/17 107/19 136/19
159/15 159/22 180/10
188/1 212/5
whom [2] 26/11
125/4
whose [1] 221/19
why [58] 11/24 13/2
21/20 22/7 27/4 27/4
35/20 36/5 39/18 47/7
58/5 58/9 62/6 62/7
63/21 63/25 71/6
78/14 78/18 79/5
79/16 82/11 82/17
82/19 83/13 83/16
83/16 83/21 83/23
87/8 87/10 87/20 99/8)
102/15 104/13 104/25)
105/16 107/14 113/17,
114/2 119/12 119/20
119/24 120/16 124/6
125/3 143/19 144/3
155/21 156/25 167/23)
168/14 176/17 198/10)
198/23 202/16 209/19)
211/22
whys [1] 63/24
wider [5] 105/4
162/18 181/13 182/13)
193/22
widespread [1]
201/12
Wild [1] 49/2
will [50] 2/9 2/14 5/16
5/18 57/6 57/9 57/11
57/12 57/17 57/19
66/20 67/8 68/8 68/10
68/14 68/18 70/16
70/20 70/20 70/24
71/9 88/7 91/24 95/4
95/6 95/17 97/13
97/15 99/25 116/20
116/24 129/16 129/17)
130/18 134/8 134/16
134/17 134/18 150/15)
150/18 193/4 199/2
199/8 200/19 201/1
205/22 206/2 215/4
215/20 217/8
willing [4] 190/2
Winchester [1] 149/5
wish [4] 2/3 2/6 2/15
50/24
wished [2] 45/4
137/16
with’ [1] 188/7
withdrew [1] 22/7
within [36] 8/4 11/20
23/6 26/2 28/7 28/8
28/16 29/14 29/19
30/24 30/24 31/11
34/23 43/4 52/11 57/2
57/6 57/16 68/10 69/1
125/20 135/6 141/20
150/3 150/21 153/11
156/20 181/16 182/11
183/13 206/20 206/21
206/24 210/16 216/8
220/5
without [20] 69/9
70/11 72/16 76/20
77/20 77/25 79/14
81/4 87/5 121/1
129/17 142/10 143/4
146/2 148/15 150/11
153/2 169/8 190/17
223/7
WITN00460100 [2]
3/20 54/11
WITN00460200 [1]
4/6
WITN00460300 [1]
4/21
WITN00460400 [1]
5/6
WITN00460500 [1]
3/6
WITN09610100 [1]
174/14
witness [138] 1/18
2/23 2/25 3/2 3/4 3/5
3/8 3/11 3/16 3/19 4/2
4/5 4/17 4/20 5/2 5/7
5/10 5/18 5/23 6/20
7/25 8/14 9/5 11/5
12/15 14/8 18/7 20/25
27/22 27/22 36/10
38/17 51/16 52/25
54/10 61/9 61/22
61/23 71/7 73/12
92/17 98/18 99/19
102/6 102/15 103/21
104/25 105/13 105/15}
105/16 106/23 107/3
107/15 108/3 108/11
116/19 120/23 121/2
121/7 121/10 121/12
121/19 122/11 122/19]
122/20 122/22 123/14I
125/2 126/13 126/14
129/13 130/6 130/9
131/13 131/19 131/22]
131/24 133/19 133/19}
134/22 134/25 135/12
135/16 136/1 136/7
144/8 144/13 145/21
157/15 157/18 157/24
158/1 158/6 158/7
158/23 159/2 159/7
159/19 160/17 160/24]
161/7 162/5 162/20
162/24 162/25 163/6
163/7 163/13 164/5
164/7 166/3 166/4
167/4 167/10 167/14
167/24 170/14 173/24
1747 174/13 177/11
178/23 180/2 181/2
181/2 185/2 185/7
188/13 193/21 193/21
194/5 196/16 203/12
203/16 203/17 207/16
218/10 221/15
witness’ [1] 126/10
witness's [2] 73/3
122/12
witnesses [6] 70/23
129/15 129/16 133/11
159/14 175/8
won't [4] 18/2 100/11
102/12 102/22
wonder [2] 21/11
74/24
word [7] 15/14 75/13
111/4 117/4 117/5
195/24 217/15
wording [2] 155/4
165/13
words [16] 56/21
58/11 74/19 78/20
78/25 85/16 85/17
85/20 99/8 102/4
109/25 110/12 110/13)
151/8 153/11 192/11
work [54] 7/5 7/15
9/3 9/14 10/9 10/10
10/11 13/13 13/19
13/24 20/21 21/5
22/20 23/3 26/16
26/20 38/21 40/6
40/10 41/20 46/17
50/10 50/17 54/20
98/22 98/24 100/24
104/1 104/12 104/16
104/24 107/22 108/22,
108/23 109/4 114/11
114/18 117/10 119/7
127/21 133/18 147/2
147/3 148/7 178/11
180/24 180/25 181/6
193/24 219/6 219/8
219/12 219/19 222/6
worked [26] 6/13
7/10 8/16 8/20 8/21
9/5 10/17 26/1 26/9
26/10 26/11 27/15
39/16 40/5 40/7 40/19)
48/11 53/18 59/17
62/17 62/23 108/1
164/3 188/2 194/14
221/23
working [32] 7/7 13/6]
17/16 17/22 18/3 19/2}
21/24 23/16 24/7
26/22 27/13 27/14
27/18 29/7 29/7 29/8
29/8 31/24 34/20
39/21 112/9 157/3
160/23 178/5 192/4
192/6 192/13 211/11
217/4 217/17 219/18
221/25
works [2] 67/9 74/6
workshops [3] 56/9
64/3 64/4
world [1] 76/24
worried [1] 128/23
worry [4] 25/12
115/14 163/3 215/13
worrying [1] 26/9
worse [1] 217/1
worth [2] 202/13
213/1
worthwhile [1] 91/23
would [203] 1/21
9/19 9/25 10/15 12/3
12/22 14/25 15/15
17/13 18/13 19/23
19/24 20/17 25/13
25/15 25/16 26/4
27/24 28/18 28/18
28/20 28/22 29/4
29/15 30/4 30/9 30/11
30/19 31/7 31/21
32/25 33/1 33/3 33/11
34/2 35/10 35/14
35/19 36/17 37/17
37/19 41/8 43/8 43/13
45/4 45/15 47/13 48/4
48/24 49/20 49/23
53/18 53/24 54/15
55/4 56/14 59/6 59/11
59/22 62/5 62/10
63/19 67/24 68/1
71122 72/16 73/1 73/5I
73/7 74/11 74/12 75/3
75/4 75/9 76/9 76/16
77/5 77/10 77/18
78/18 78/21 78/22
80/16 82/3 86/14 87/8
87/15 89/7 91/19
91/21 92/3 92/12 93/4
93/12 93/20 94/9
95/11 96/3 96/8 97/3
101/12 102/6 105/18
109/1 109/4 119/18
120/3 120/3 120/25
128/16 128/19 134/15I
137/4 137/16 140/4
140/5 140/24 140/25
141/3 148/8 151/17
152/18 152/22 155/1
156/15 157/20 158/2
158/14 158/20 159/14I
162/5 163/24 164/6
164/18 164/22 175/10I
176/1 176/2 176/7
176/9 176/16 176/17
176/23 180/5 180/7
181/21 181/25 182/5
182/10 182/20 182/25I
183/3 183/10 183/13
184/5 184/10 184/21
185/20 189/8 189/17
190/5 190/12 190/19
191/3 191/3 192/15
194/7 196/4 196/7
196/10 196/10 196/11
196/18 196/21 197/3
199/22 199/23 199/25I
200/1 205/8 208/18
209/6 209/7 209/13
209/15 209/16 211/11
213/11 217/9 217/22
217/25 218/6 218/9
219/14 220/4 220/20
(94) which... - would
Wo
would... [7] 221/10
223/5 223/8 223/18
wouldn't [27] 17/24
45/9 49/4 49/24 50/1
50/5 51/9 73/8 83/11
101/6 110/13 117/5
140/24 156/7 156/14
185/6 187/1 204/5
218/10 223/24
writer [1] 21/14
writes [1] 81/7
71/9 74/17 1414/9
144/12 171/3
written [12] 36/14
45/5 51/16 56/4 68/21
68/22 75/9 82/4
114/14 121/18 149/3
173/23
wrong [13] 17/23
47/3 52/22 67/20
67/22 75/20 76/12
77/3 154/24 157/21
169/23 183/25 218/15}
wrongful [1] 65/21
wrongly [4] 37/12
66/2 151/5 211/15
wrote [5] 56/10 56/21
75/7 99/5 152/19
Wylie [2] 147/11
148/2
Wylie's [1] 147/20
:
XDMF [1] 200/9
Y
Yate [1] 200/17
yeah [33] 25/23
32/24 44/6 49/25
50/15 53/7 55/8 72/20)
72/22 76/16 79/2 79/4
83/3 91/18 94/16
100/7 102/25 104/3
106/25 123/19 123/24
132/14 135/8 140/23
140/23 167/6 167/12
168/4 194/6 194/6
200/15 204/14 209/25)
year [7] 5/25 12/23
56/6 128/6 172/9
197/22 198/2
years [8] 13/3 21/4
24/3 64/6 147/15
167/7 170/10 219/14
yes [296]
yesterday [4] 3/6
53/25 98/18 123/7
yet [3] 100/22 118/2
221/12 221/18 222/23] YOU [1013]
27/19 32/17 34/7 45/8
167/21 176/11 176/13}
writing [7] 20/8 70/17I
216/2
Yip [1] 213/19
you'd [13] 30/20
32/18 45/5 49/18
51/15 83/1 120/7
145/5 158/19 165/22
165/23 172/8 182/8
you'll [9] 55/17 88/10
132/17 132/18 132/22)
133/1 148/23 149/17
204/11
you're [28] 17/11
43/7 63/3 72/3 72/25
77/14 83/11 89/1
96/21 100/20 112/20
117/16 127/8 151/6
155/21 155/23 156/21
160/5 161/10 165/25
1714/3 171/8 171/14
195/2 201/24 202/23
216/2 219/2
you've [34] 1/17 2/23
5/22 12/13 19/15
30/20 31/18 37/16
39/1 41/12 42/11
45/17 48/15 52/4 52/5)
71/20 72/15 75/14
78/10 82/20 83/25
123/18 146/14 149/2
150/22 160/16 172/2
173/22 174/2 178/6
181/8 187/13 202/13
202/15
your [237]
yours [2] 70/15 140/2
yourself [7] 45/5
126/13 130/8 134/9
153/24 154/9 186/17
Zo
zone [1] 105/17
(95) would... - zone