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The Post Office Horizon IT Inquiry
Wednesday, 26 June 2024
(10.03 am)
GARETH IDRIS JENKINS (continued)
Questioned by MR BEER (continued)
SIR WYN WILLIAMS: Yes, Mr Beer.
MR BEER: Thank you. Good morning, Mr Jenkins.
A. Good morning, sir.
Q. Before we carry on looking at bugs errors and defects,
which is where we left off yesterday, I'd like, if
I may, to go back over an issue that we addressed
yesterday which is whether you saw the Bond Pearce
letter of 18 November 2005.
Okay.
You remember that letter from --
I remember discussing it yesterday, yes.
Yes, from Bond Pearce to Fujitsu. It was the one that
asked Fujitsu to prepare an expert report, which asked
Fujitsu to address in the report the issues raised by
Lee Castleton in his defence and which explained
an expert's duties and the necessary inclusions in
an expert report; do you remember?
A. I remember discussing it yesterday, yes.
Q. I showed you a copy of that letter yesterday. Can we
have that on screen, please, FUJ00152573. If we scroll
through, please, you remember the way this pack of
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A. That is what I said yesterday, yes.
Q. You agreed yesterday that Bond Pearce had set out in
this letter very clearly, and in an easy-to-understand
way, the duties of an expert witness?
A. I accept that's what I said, yes.
Q. Lastly, you said that you were sure that the letter
never made its way to you because you would, and I quote
here:
"... have done things differently, not necessarily
in this case [the Lee Castleton case] but certainly in
later cases, if I'd been aware of those
responsibilities."
You remember saying that?
A. Yes.
Q. [also asked you yesterday about your attendance
a conference with lawyers at Fujitsu's headquarters on
6 June 2006; do you remember?
A. Ido.
Q. You said, in summary, that there was no discussion about
giving expert evidence or the duties of an expert at
that conference?
A. And I've no recollection of that, no.
Q. Indeed, that's reflected in the attendance note of that
conference: there appears to have been no such
discussion?
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documents was constructed and, if we carry on
scrolling -- and keep scrolling -- to the letter of
18 November 2005 from Bond Pearce to Fujitsu. I showed
you a copy of this letter yesterday; do you remember?
I remember that, yes.
Thank you. When I asked you about the letter and if it
was sent to you, you said no, you had got no
recollection of that. You remember that?
I certainly -- that is certainly what I said yesterday.
Yes. You said yesterday that, if the letter had been
sent to you, then you would have remembered it because
it clearly sets out what duties there are, and you
weren't aware of them until the end of 2020?
I believe I must have been mistaken in what I said
yesterday, in that respect.
Before we come to whether you were mistaken or not, I'm
just going to recap what you said.
I accept that that is what I said yesterday.
So you said that you would have clearly remembered it
because it sets out the duties of an expert and you
weren't aware of them until the end of 2020, yes?
Correct.
You said yesterday that you did not see the letter
because, if you had seen it, then you would have learned
about the existence of an expert witness's duties?
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I agree.
Can we turn to your witness statement, please. Your
third witness statement, at paragraphs 251 and 252,
which is page 86. I'm going to read those in full:
"251. The Inquiry's Rule 9(2) Request has asked me
how I first came to be involved in Mr Castleton's case.
It has also asked what I understood Stephen Dilley to be
asking ... to provide by way of his letter dated
18 November 2005."
Then you give that URN that we've just looked at,
okay?
Yes.
“I don't believe that I had ever seen this letter until
it was shown to me for the purposes of preparing this
witness statement. It appears that at some point Brian
Pinder emailed me and asked me to address a single
question about human error (which I can now see came
from the list of questions asked in the letter) and that
my response to this single question seems to have been
my first involvement in Mr Castleton's case."
We looked over all of that yesterday.
Yes.
"252. I don't think that I had any further involvement
until, over six months later, I was invited to attend
a meeting with [the Post Office's] solicitors on 6 June
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2006. My lawyers have shown me an email from Brian
Pinder to me dated 5 June 2006", and you give the
reference number ending in 601.
Yes.
"This email attached an agenda for the next day's
meeting and a scanned extract from a document", and you
give a reference number 602.
Yes.
"... which recorded issues Mr Castleton had experienced
with Horizon. I probably read both attachments in
advance of the next day's meeting although I don't
recall doing so. Brian Pinder's email stated that he
was ‘not sure how this affects ourselves but reading the
scanned document attached (his queries re Horizon) we
may well require [your] expertise in this'. Looking
back at this email, I cannot recall what my
understanding of the purpose of the next day's meeting
was but I would probably have assumed that I would be
asked to respond to the Horizon issues identified by
Mr Castleton. However, I don't think I knew at this
stage that [the Post Office] intended me to become
a witness in any legal proceedings."
Now, you say, if we go back to 252, at the foot of
the page, "My lawyers have shown me an email", can you
see that in the second line into the third line?
5
It says UTC time, so that's June, summertime.
So that would have been 4.19?
Yeah.
“Please be advised in the email below [this is directly
to you] and the attachments.”
Just stopping there, we can see the attachments, one
is called "letter_doc” and the second attachment is
an eCopy of a scanned copy document.pdf; can you see
that?
Yes, I see that.
"Not sure how this affects ourselves", and then there's
the sentence that you set out in your witness statement;
can you see that?
So, again, essentially two documents, it is
suggested are attached, an agenda and a scanned copy of
Mr Castleton's Part 18 replies.
Now, in you witness statement you said that the
email attached an agenda and a scanned extract from
a document, and you gave that the reference number 602.
Can we look at that, please. FUJ00152602. You'll see
these are statements of case, so legal documents which
used to be called pleadings, in which the parties
exchanged information about their case.
I didn't understand that at the time but I understood
that it was asking technical questions that I thought
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Yes.
"Dated 5 June", and you give that the number ending 601.
So that's the day before the conference.
Yes.
If we look at that, please, FUJ00152601.
Look at the bottom part of the email first. 3.49
from Mr Dilley to Brian Pinder and Graham Ward and
others, not you at this stage:
"Dear Brian and Graham,
"I attach a suggested agenda for tomorrow's 11.30 am
meeting, just for discussion purposes. I also attach
an extract from Mr Castleton's Part 18 Replies setting
out his allegations about Horizon. I think Mared may
also add in a few issues."
So that suggests that the things attached were an
agenda and an extract from some part 18 replies. Okay.
And that was the assumption I made when making my
witness statement.
So ie you read what was in this email and effectively
translated it into your witness statement?
Correct.
Thank you. Then if we go up, please, that's forwarded
to you. There must be a time difference because the
time given is 40 minutes before the earlier email is
sent.
I would need to address.
Okay, so that's not relevant to us at the moment but in
your witness statement that's the only document you
refer to as being attached --
lagree.
-- and that's not relevant. Now, it's true to say that
there was an agenda for that meeting, for 6 June 2006,
but it wasn't attached to this email. The reference
number, we needn't turn it up, for the agenda is
POL00071418.
Now, can we please switch to the native version of
the email, FUJ00152601, and it will be necessary to drop
the YouTube feed for this. You understand, this is the
original version, essentially, of the email that
I showed you yesterday in an imaged form.
Yes, I understand that.
So you'll see it’s exactly the same email, the text is
exactly the same in it, but the difference is we can
see, actually, what the two attachments were?
Yes, I understand that.
If we look at the second attachment first, if we can
just open that on the screen. We'll see that's the
Part 18 replies.
I understand, yes.
So that can be closed, thank you. Then if we open the
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The Post Office Horizon IT Inquiry
first attachment, we can see that, in fact, the first
attachment of the email to you was the letter of
18 November 2005; can you see that?
I can see that and I now understand that to be the case.
Now, when you made your witness statement, you would not
have been able to refer to this document, the
18 November 2005, as being an attachment to the email
because it hadn't been disclosed by the Inquiry on its
eDisclosure platform in a way that associated it with
the covering email; do you understand that?
I accept that, yes.
Thank you. The association between the email and this
attachment, the letter, was only realised yesterday. So
I'm obviously not going to ask you why you said what you
did in your witness statement about the other attachment
being an agenda, when it in fact wasn't.
Yes.
Okay? Nor am I going to ask you why you didn't refer to
this letter of 18 November 2005 in your witness
statement as being provided as an attachment to the
email because you didn't have the evidence then before
you to make that connection?
Correct.
Understood?
Yeah.
the substance of what I needed to look at for the
following day was the other attachment, not this one.
So, yes, I would probably have opened it up and read it
but I have no recollection of doing that.
Why do you think your focus of attention would have been
the Part 18 replies and not this letter?
Because what I was being asked to do was answer
questions. If we go back to the covering email from --
FUJ00152601. Is it the second paragraph there you're
referring to?
“Not sure how this affects ourselves but reading the
scanned document attached (his queries re Horizon) we
may well require you're [sic] expertise on this.”
‘Are you saying that, because of that sentence, you
would have focused only on the scanned document and not
on the letter?
Yes.
Really?
Yes. That was the one that actually had technical
information that I felt I could contribute towards.
Why did you tell me yesterday that, if you had been sent
this letter, you would have read all of it and not half
of it?
I probably would have read all of it but I probably
didn't read it in detail and having -- and, obviously,
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Can we go back, please, to the imaged version of this
letter, FUJ00152573. I think it was page 8 or 9 --
maybe 10. Just scroll on, please. Thank you. I'm just
going to use this imaged version rather than that native
version. The text is exactly the same. So I'm not
going to ask you about why your witness statement was
written in the way that it was. The plain facts are,
I think you'll agree, however, that we can now see that
the letter of 18 November 2005 was sent to you?
I understand that and I accept that, and I apologise for
any mistake I made yesterday.
It was sent directly to you and, therefore, I've got ask
to ask you some questions about that, okay?
I understand that, yes.
So you accept, firstly, the simple fact that, in the
light of the evidence as it now stands, this Bond Pearce
letter was sent directly to you?
Yes, clearly.
Do you remain of the view that you expressed yesterday
that, if the letter had been sent to you, you would have
read all of it and not just half of it?
I would probably have skimmed through it but, clearly,
it hadn't stuck in my mind beyond the time that I read
it because, at the time, I was concentrating of the fact
I was being invited to a meeting the following day and
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it didn't stick in my mind, and sorry if I misled you
yesterday to suggest that it would have stuck. I think
it's a problem of understanding the difference between
it clearly strikes me, reading it now, as being
important, whilst at the time, it probably didn't strike
me as being important.
What I was being asked to do was to go to a meeting
to talk about technical issues with Horizon and so
I would have concentrated on the technical scanned
document, not the letter talking about putting together
the report and, at that stage, I didn't think I was
being asked to put together a report and, in fact,
I don't believe I was ever asked to produce a report in
that sort of form, for this case.
Oris it that you said yesterday that, if you'd received
the letter, you would have read all of it and not just
half of it, because it was acceptable to say that when
you didn't think you'd been sent the letter?
I don't know. As I say, I would probably have read the
whole thing. I'm not suggesting I didn't read the whole
thing but, clearly, it didn't stick in my mind.
Okay, thank you. Can we go back to the letter, please.
FUJ00152573, and I think page 11 -- 12 -- 13, thank you.
Do you remain of the view that you expressed
yesterday that the letter sets out, in a detailed but
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The Post Office Horizon IT Inquiry
easy-to-understand way, the duties that would need to be
complied with in the case of a Fujitsu employee
providing evidence in at least the Lee Castleton case
about the matters raised in the letter?
Yes, I have to accept that.
Do you accept now, in the light of the evidence, that
you were sent a copy of this letter, that you were
therefore informed, in a detailed but easy-to-understand
way, the duties that would need to be complied with in
the event that you provided evidence in the Lee
Castleton case in answer to this letter?
Yes, but I don't believe I was actually asked to provide
that sort of report in the Lee Castleton case.
Well, I'll come to that a little later.
But yes.
If we scan through the letter just slowly -- I think you
will have read it carefully overnight -- the letter
doesn't refer, would you accept, to the provider of
a report from Fujitsu as being an expert witness?
I'm not sure that I'd have spotted that in terms of --
I was concentrating more at looking at what else
happened in the case, rather than the contents of this
letter, last night.
Look at it carefully now. If we just go back to the
top, thank you. If you just read it to yourself slowly,
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never made its way to you, because:
"[You] would have done things differently, not
necessarily in this case, [the Lee Castleton case] but
certainly in later cases."
If I'd understood what that was all about. Now,
I clearly had no recollection that I'd received it at
this point. You've now shown that I did receive it at
this point but I still have no recollection of
remembering anything about that at any later stage.
But you said yesterday that, had you received the
letter, you would have done things differently,
certainly in later cases, if you'd been aware of the
responsibilities set out in this letter.
Maybe I need to qualify that to say, if I'd received and
understood the detail of the letter.
Well, that's not what you said.
I accept that and I was mistaken.
Why were you mistaken that you think that yesterday you
thought, had you received the letter, you would have
certainly done things differently in later cases; today
you don't think, now you know you received the letter,
that you would have done things differently in later
cases?
I think the difference is in terms of understanding what
it was all about. What I was thinking of yesterday was,
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and just indicate when you've read that which is on the
screen.
Yes, I've read what's on the screen.
Thank you. If we go down, please.
Yes, I've read that page.
Thank you. Over the page, thank you.
Yes, I accept that it doesn't say that the expert's
report is a formal report.
Thank you. Maybe you can just read the first two
paragraphs under (4), and then go over the page, and
then read after 14 the next three paragraphs.
Yes, I've read those three paragraphs.
Then just read under (5).
Yes, I've read that.
So the letter does not refer to the provider of the
report that was being sought by the letter by Fujitsu,
at once, as being an expert witness, does it?
No, it doesn't.
Instead, the letter, would you agree, works on the basis
that any person providing evidence from Fujitsu about
the matters mentioned in the letter needs to comply with
the duties set out in the letter?
I understand that now but I almost certainly would not
have realised that at the time.
You said yesterday that you were sure that the letter
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with my knowledge now, of what -- of the implications of
what it actually says in that letter, then I would have
done things differently. If I'd just skimmed through it
and not taken too much -- made too much attention of
what it actually said and it had then gone from my mind
when I was busy concentrating on the other attachment,
then clearly I had not remembered anything about it much
beyond those couple of days.
What were the later cases that you had in mind yesterday
when you told us that, if you'd seen this letter, if
you'd received this letter, you would have done things
differently?
If 'd understood my duties as an expert, and I accept
they're laid out here, and understood at the time, then
I would clearly have approached the reports that
I produced for Seema Misra's case in a different way.
And, as I've said before, I had no recollection of
having been briefed in this way and, after all, that was
about three or four years later and I'd clearly
forgotten all about having seen this letter briefly at
that time.
So when you said yesterday, had you seen this letter,
you would have done things differently in later cases,
you had in mind Seema Misra?
Yes, I think so that was -- and, clearly, there was
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The Post Office Horizon IT Inquiry
a later case as well but that was the next one that came
along.
What about the Hughie Thomas case?
I think that had happened letter.
You'd made a witness statement earlier in the year in
March or April?
But I didn't think that that was an expert report at
all. That was just looking at one specific question of
fact, which was whether -- what was the reason for zero
value transactions. I didn't -- I had no concept of the
fact that that was an expert report in any sort of way.
I should just say, whilst it's on the screen there, just
look under (5), can you see that?
Yes.
The words "expert witnesse:
that?
Yes, yes.
“In performing all your duties ..."
Yes.
included; can you see
So it’s not quite right what I suggested to you earlier
that “expert witness" or "expert witnesses" are not
mentioned in the letter.
No.
They are in that paragraph there. But do you still
agree that, reading the letter now, the requirements
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is by the fact that I just had no recollection of this
letter.
If we go to the top of the previous page, please.
There. Thank you. The six topics set out there are
just asking questions about Horizon, aren't they?
Yes.
The advice from Bond Pearce was that the person that
answers them in a report needs to comply with everything
that follows in the letter?
Yes, but I don't think I was being asked to produce
a report at that time.
Can we look at then what happened subsequently, in
fairness to you, at FUJ00122283. It might be that's
an errant reference -- ah no, perfect.
Can we just look at the email at the foot of the
page, please, and then go up, please. You say in this
email, and we're now in the beginning part of August
2006, so a couple of months after the conference at
Fujitsu?
Yes.
"Ive 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'm happy for you to send it as it is to Stephen
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imposed by or suggested by Bond Pearce don't depend upon
the person giving the report or making the report being
classified as an expert witness?
I'd not really taken that into account. So I think it's
very difficult to talk about hypotheticals in that sort
of way.
So you were told about these responsibilities because
you'd been provided with this letter. What's the
explanation now, then, for not doing things differently
in later cases?
Because I'd clearly not remembered about the fact that
I'd seen this letter in 2006.
Your evidence in your witness statement and in your oral
evidence yesterday was founded on the suggestion that
you didn't need to comply with all of the duties set out
at length by, for example, Professor McLachlan in his
report, nor Mark Turner in his report because they were
independent experts and you were from Fujitsu.
Yes, and I stand by that.
Doesn't you receiving this letter rather undermine that
point?
It could do if I'd remembered that I'd received this
letter. But! where I'm coming from is that
I know that I acted honestly at all times and,
therefore, I'm -- the only way that I can explain that
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Who was the Stephen you had in mind?
Stephen Dilley.
"you may decide it isn't complete enough for that
... [may be able to research some of the areas (such as
Auditing) that I'm claiming ignorance of if that is
required."
You will see there is an attachment, which is
a statement?
Yes.
Can we look at that statement, same reference, but
ending 84 [FUJ00122284]. This was the attachment to
your email and was a draft witness statement, is this
right, that you compiled?
The draft witness statement was compiled by Stephen
Dilley and he'd left various questions in it and, as
I explain on that first page, I made various annotations
and we're back to the problem about being able to tell
the difference between colours in a black and white
document.
I see. So the format of the witness statement was
compiled by Mr Dilley and some of the formal parts of it
were compiled by Mr Dilley. He included some text in it
and he asked you some questions that you were to
responding to and fill in?
Correct.
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And you did that in this version of it?
Yes.
>
Q. If we just scroll down, please, and look at paragraphs 1
and 2, and then scroll on, you address the Horizon
system which you'll remember is question 1 in the letter
of 18 November 2005:
“What's the Horizon system? We need to explain to
a judge how it works.”
A. I don't think I would have been thinking of it in the
context of that letter, at the time I saw this, because
this was clearly a couple of months later.
Q. Right, okay. Then, if we just scroll on, we can scan
it. The detail is not important for the moment. If we
scroll on, and keep scrolling, you can see some examples
there of him asking questions and you replying?
A. Yes.
Q. Carryon.
A. And there's also examples of him asking questions and me
saying I don't think I'm able to reply.
Q. Yes. If we scroll on, and then stop there. You'll see
that it was proposed that you signed off with a standard
declaration:
"I believe that the facts stated in this witness
statement are true."
Can you see that?
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saying that I was to be treated as a witness of fact and
not an expert evidence but, obviously, I didn't see
those at the time.
Q. Thank you very much.
SIR WYN WILLIAMS: Mr Beer, can I take it, because I've only
seen this as we're going along, that, in fact, it
contains a mixture of factual content and opinion?
MR BEER: Very much.
SIR WYN WILLIAMS: So there would have been a need for all
the necessary declarations?
MRBEER: Correct.
‘SIR WYN WILLIAMS: Fine.
MR BEER: It's not a witness statement of fact alone. You
can see that, for example --
‘SIR WYN WILLIAMS: = That's no reflection on you, Mr Jenkins.
A I~
SIR WYN WILLIAMS: I'm just trying to ascertain the true
legal status --
A. I understand.
SIR WYN WILLIAMS: I -- of what this would be. That's all.
A. Yes.
MR BEER: To round this topic off, Mr Jenkins, you didn't,
in fact, sign this witness statement and you weren't
required to give evidence in court?
A. Correct. And, in fact, I don't believe that this
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A. Yes.
Q. So this draft provided by him and further expanded by
you didn't contain any of the declarations or the
matters mentioned by Mr Dilley in his letter of
18 November 2005 as an expert witness?
A. Correct.
Did you give any thought to that at the time?
A. No, is the simple answer. I was given this document,
which was supposedly a draft of something that I should
be saying, and what I did was I commented on that as to
whether I could truthfully say what was in that draft or
not and corrected any factual errors that I saw within
there. I gave no thought to what format it was in.
Q. So, by that time, had the letter of 18 November been
lost by you in your memory?
A. I believe so, yes.
Q. Was there any suggestion by Mr Dilley that you needed to
comply with the duties set out in his letter of
18 November, or say that you had complied with the
duties set out in his letter of 18 November, for the
purposes of giving this evidence?
A. Not that I'm aware of and I don't believe there is
2
anything in the covering email that -- I'm not sure if
we went to there now. And I'm also aware of some emails
which I've seen as part of the Inquiry where he was
22
version of it ever went back to Mr Dilley, and he
decided he didn't want a statement from me at all,
but -- and I think we worked through yesterday the
communication I had from Brian Pinder as to the fact
that it was no longer required.
Q. Thank you, that can go back down.
Right, can we go back to where we were?
SIR WYN WILLIAMS: Before we do, Mr Beer, I want to say this
openly, since obviously it is unfortunate that this
series of documents or these documents you've shown
Mr Jenkins this morning had not been disclosed earlier.
I want the Inquiry to make a further investigation,
just so I can be satisfied about what exactly occurred.
The letter of 18 November, as originally sent, as
l understand it, attached experts’ reports obtained by
Mr Castleton.
MR BEER: Yes.
SIR WYN WILLIAMS: So I would like us to bottom out whether
those reports made their way, in some way or another, to
Mr Jenkins and/or were discussed at the conference which
he attended.
MRBEER: Thank you, sir. We can pursue that.
SIR WYN WILLIAMS: Yes.
MR BEER: Can we go back to bugs, errors and defects,
please, and turn to the Callendar Square bug, please.
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Yes.
You addressed this at significant length in your second
witness statement, it's paragraphs 53 to 82, where you
recount your knowledge of the Callendar Square bug. Can
we just look at a couple of parts of that, please.
Second witness statement at page 16, please, and
paragraph 54. You say:
"In the Technical Appendix to the Horizon Issues
judgment, Mr Justice Fraser grouped together number of
problems under a single heading called 'Callendar
Square/Falkirk’. I understand why the court and now the
Inquiry has taken this approach but it risks creating
the erroneous impression that the bug was homogeneous in
the sense that it was caused by the same factors, and
manifested itself in the same way, in every branch it
affected. This was not the case. As I explain below,
what happened at [the] Callendar Square branch in
Falkirk in 2005 was caused by an underlying bug in the
Riposte software that manifested itself when
a combination of unpredictable factors, including (in
that particular case) steps taken by the [subpostmaster]
to rectify the issue, came together. In other words,
there was an underlying software bug, but how it
manifested itself and whether it caused harm was
contingent on the presence of other circumstances.
25
of time until the particular PC or server was rebooted.
But there were other cases where there was a single
event saying time-out waiting for lock, and what I was
getting at, in the first paragraph that you read to me,
is that, as far as the civil case, they were all
considered as being basically the same problem, and
I didn't feel that that was a correct representation of
how it should be taken.
What was the nature of the other circumstances that were
required when interacting with the underlying Riposte
bug that produced lock errors?
The simple answer is I don't know.
The reason why you don't know is?
It was in the Escher software and it was their propriety
software, they as I understand it, fixed the problem in
2006 and, certainly, the storm of events, which was what
was seen at Callendar Square, did not reoccur, as far as
I'm aware.
But you didn't know then, and you don't know now -- and
even in 2018/19 didn't know -- what circumstances were
required in order, essentially, to trigger the existence
of the bug?
Correct.
Can we look, please, at POL00081928 and can we go down
the page, please, to Ms Chambers’ email. Scroll down,
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These circumstances were not fixed. That is why the
problem was hard to reproduce."
Then page 28, please, and paragraph 80b, which is
beyond the there. You say:
"While many incidences of the locking errors were
not associated with any discrepancies in [branches]
(eg they resulted in operational problems such as screen
freeze), I became aware that it was not just the
Callendar Square branch that had suffered from
discrepancies but other branches where there were
counter occurrences of the timeout waiting for lock
problem."
Can we start with --
Can we qualify that last thing because at the top of the
page it says that this comment arose from the work I did
in 2018/2019, and not at the time.
Yes, sorry, this is later-discovered information.
Yes, yes.
In what respect was the Callendar Square bug not
homogeneous?
I think it comes down to understanding exactly what
people mean by the Callendar Square bug. If we're
talking about the circumstances that actually occurred
in Callendar Square, then that was a storm of events.
which came regularly at every ten seconds for a period
26
please. Hmm. Just scroll back up, please -- and
again -- and again. That's obviously an erroneous
reference. I'll come back to that maybe later this
morning.
Can we turn instead to FUJ00083712. Thank you.
This is an email thread, if we scroll down, please, and
if we keep going, we can see an email from you there.
If we go to the end, thank you, and then scroll up from
the bottom. We can see the start of an email chain. If
we scroll up and keep going, you're not included at the
moment. You come in here, and just in what context
would you be sent an email like this?
I don't recognise this specific email but I recognise
the background to it as being part of the investigation
we were doing for an issue that I believe occurred in
Craigpark and one other branch, which I think is
Tonbridge. So, as a result of that, we then did
a retrospective search of NT events associated that were
related to ARQ data that had previously been supplied to
Post Office.
Why were you doing that?
To make sure that there weren't any problems that we'd
not spotted that could cause any -- there weren't
problems that were occurring at the branch at the time
that the ARQ data was being extracted for.
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Was this a hangover, essentially, from the supposed
resolution of the Callendar Square bug in 2006?
No, this was a separate issue, that was -- as I say,
it's -- I've referred to it in my witness statement as
the Craigpark issue. In fact, having re-read them over
the last few weeks, I'm now aware that, actually, the
first occurrence of it was at a different branch called
Tonbridge but it was Craigpark that was what caused Post
Office to investigate things further, when I actually
got involved in this, in I think it was August 2008.
I see. So if we carry on scrolling up, please -- and
keep scrolling -- and again -- and stop there. Are you
essentially saying that this chain is about another kind
of Riposte lock issue that's separate from the Callendar
Square issue in 2006?
I'm not 100 per cent sure about that as to whether this
was a storm of events or just individual events. If
it's just individual events then it was a separate issue
and it was important, as was done here, to check to see
if anyone was actually logged on to the system at the
time. And that was the sort of check that was being
done when those events were being detected in our
checking of NT events associated with ARQ data.
But I shouldn't see this, I shouldn't read this, as
essentially a continuation of the Callendar Square issue
29
thing to do was to check, if we saw the Riposte lock
problem, to see if anyone was actually using the
terminal at the time and, if no one was using the
terminal at the time, then it was deemed to be safe and
that -- nothing to worry about.
We know you were asked some questions about Callendar
Square in 2010 for the purposes of the Seema Misra case,
yes?
Correct.
And that you in turn asked Anne Chambers for information
about the problem?
Correct.
Did you make any connection with your previous
involvement in Riposte lock issues such as this?
No, I think is the simple answer to that.
Why would that be?
Well, at that stage, I didn't know, actually, what the
root cause in Callendar Square. I'd just been told
"Please can you look into what the Callendar Square
issue was". When I asked Anne for the information about
it, she passed me references to a PEAK and I think
she -- some old emails from the time that it had
occurred, and said that, if I remember rightly, that the
main cause of the issue was these what she called "event
storms", which was repeated events, which is separate
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discovered in 2006?
Not if it's an isolated, a Riposte lock issue, no.
How would you know whether it's an isolated Riposte lock
issue or a continuing manifestation of the Callendar
Square bug?
If it was a Callendar Square issue there would be
hundreds of thousands of events occurring.
Why?
Because the problem was continuing. So a lock was
being -- there was an attempt get a lock, and then
Riposte was continually to do the same thing, process
every ten seconds, and it was failing every ten seconds,
and will carry on doing that until the Riposte service
on that box was restarted.
So you said earlier that you didn't know the full
circumstances that would cause --
What I don't understand is why the lock was being held
all that time. The symptoms of it I do understand, in
that it would be showing all these events, but why the
thing was being locked and not able to process things is
what I don't understand.
Was it possible that the Riposte lock problem had
continued and was impacting on a branch in a way that
was previously unknown to Fujitsu?
I think what we were -- what we'd decided was the safest
30
from these isolated events that we're looking at here.
But would, in 2010, all of the earlier Riposte lock
matters -- I'm going to call them -- have been available
to you on PinICLs, PEAKs and KELs, if you had searched
for relevant key terms?
Yes, I guess they were but, again, in what we were
looking at, in terms of what had happened in West
Byfleet, we did actually extract all the NT events from
2005 to 2008, and we checked all the events, including
lock issues, and I believe there were some found.
I believe there is an email from Anne where she actually
summarises what she had actually found there, and there
were some further checks that Penny Thomas made to see
whether anyone was logged on at the times that these
events had occurred.
I'm just thinking more broadly at the moment, without
getting into the detail of the individual cases, what
you would do if you were preparing a witness statement
in a case, or preparing to give evidence in a case:
would you go back and look at PinICLs, PEAKs and KELs in
order to conduct research about what was known about an
issue, or would you, as I think you just described, just
email or talked to Anne Chambers?
I would probably have asked the SSC because I wasn't
particularly adapt at being able to do searches on
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PinICLs and KELs. I'd probably rely more on PinICLs
than KELs because I found those were useful in terms of
giving me the information I wanted.
But if you were to give evidence about a bug, your
primary source of reference would have been to speak to
people in SSC; is that right?
Correct.
Can we go forwards, please, to 2015 to FUJ00083775 and
look at page 2, please. In 2015, Anne Chambers was
asked to provide a description of the Callendar Square
problem, for the purposes, I think, of some litigation.
We can see here she says to Pete Newsome -- do you
remember him?
Yes.
What function did he perform?
He was a -- I'm trying to think exactly what his job
title was. He was a liaison between Fujitsu and Post
Office, at a fairly senior level.
"I have found a summary of the problem that Gareth
produced when preparing evidence for a court case in
2010."
That's a reference to the Seema Misra case, I think.
l assume so.
Yes:
"I have made a few amendments to make it more
33
mismatches normally showed up. Is it the case that
that's essentially a reflection: that neither you nor
Ms Chambers would be able to categorically to state that
every incident or error would be caught by the
reconciliation process and directed to the Post Office
to take action?
I can't remember now exactly what the reconciliation
report said so I'm afraid I'm unable to help you.
Could you tell, if a problem which led to a discrepancy
was referred to the Post Office, whether it was, in
fact, actioned through the issue of a correction,
a transaction correction?
That was up to the Post Office. There was
an organisation called Management Support Unit, I think
it was, MSU, and they raised things called BIMS reports,
and I can't remember what "BIMS" stands for. But if
a reconciliation error or something unusual was found
they would produce reports for Post Office describing
what had gone on, and what Post Office did with those
reports, in terms of how they affected the branches,
would be something for Post Office to answer.
If we scroll up, please. A further email from
Ms Chambers, you're not copied in.
I'd retired by then.
Yes. In the third paragraph, you'll see that she says:
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generally applicable.
"1. The problem occurred when transferring cash or
stock between stock units.
"2. It manifested itself by the receiving stock
unit not being able to 'see’ the transfer made by the
‘sending’ stock unit and could be compounded by
attempting to make a further transfer. Note that such
transactions usually reappeared the next day.
"3. It was clearly visible to the user as
a'Receipts and Payments mismatch’ at the time that one
of the stock units was balanced.
"4. The problem was also visible when looking at
the system events associated with the branch.
"5, The problem was fixed in S90 release which went
live in March 2006.
“Receipts and payments mismatches normally showed up
‘on one of the reconciliation reports and would have been
investigated and reported to Post Office at the time
(though of course we don't know what action they took)."
Does that summary by Anne Chambers match your
understanding?
Yes, and I've certainly deferred to her to have
a clearer understanding of the detail than I did.
You'll see in the last paragraph, after the numbered
paragraph, she says that receipts and payments
34
"I've found a long email chain ... which I've
attached
She says:
"Having looked at these, I slightly disagree with
Gareth's description of the problem below. My wording
would be:
"2. It manifested itself by the receiving stock
unit not being able to ‘see’ that the transfer made by
the ‘sending’ stock unit had already been accepted in,
and compounded by accepting it again. Other
transactions might have been omitted from the balance
but would have been included in the following week's
balance instead.
"But this is all a very long time ago and it is hard
to be entirely accurate.”
What do you understand her to be saying is the
difference between you and her?
I'm not quite sure, actually. It would be useful to be
able to see the two statements side by side, I don't
know if that's possible --
I don't think --
Or if we find out what the URN is, maybe I can have
a look at it during a break.
Well, let's have look at the lower email. Keep going,
and you'll see how 2 is written there and, if we go up,
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how she rephrases it.
I think it's the extra "has already been accepted in and
compounded by accepting it again", is from -- what
I think is the change, but I can't be 100 per cent sure
of that.
What's the relevance of that?
That's why there's the receipts and payments mismatch,
that you have to actually repeat the transfer for the
problem to occur and, clearly, I'd missed that out of
the description that she was quoting below, but I accept
that that is a -- an important difference to the issue,
and -- in terms of describing what actually happened in
the Callendar Square/Falkirk branch at the time.
Okay. If we scroll up, please. Thank you. I think
that's the end of the chain. Would you agree that this
was a problem, looking at it from the subpostmaster's
perspective, that they would be faced with different
figures on different counters as a result of the bug?
Yes, I accept that would be a way it would show up, yes.
And that would be a situation which would rightly cause
them considerable difficulties and confusion?
I accept that, yes.
This wasn't a problem that could be explained away by
user error?
Correct.
37
a position to know precisely what information was
provided to the Post Office --
Correct.
-- as to the existence of the bug, the extent of the
problem or the fixes proposed?
In general. There were a few cases where I was involved
in the detail because I was called in to actually help
explain the problem to Post Office but, in general, no.
Where did responsibility for that lay within Fujitsu?
There was a team called Problem Management, which was
part of the Customer Services Team, and I think those
have been referred to in some of the -- well, in my
witness statements.
Were you responsible for liaison with the Problem
Management Teams?
No. I was occasionally contacted by the Problem
Management Team or by the SSC to get involved in
discussions with things but, on a regular basis, no.
Thank you. Thank you. Can we turn, please, to the
topic of remote access.
Okay.
Can we look at your third witness statement, please, at
paragraph 473, which page is 164. You are here dealing
with your understanding of remote access at the time of
Seema Misra's case, ie in about, I think, the autumn of
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Were you ever party to the explanations given by the
Service Support Centre or the lines of support below
them?
I'm not quite sure what you mean by that.
Yes. In your work, did you see the kinds of things that
the Helpdesks or the SSC on occasions said directly to
subpostmasters?
Occasionally but, in general, no because what -- when
I saw PEAKs and PinICLs, they were being passed on to
me, or the teams that I was involved in, by the SSC
looking for an explanation, and what was being responded
back by the SSC to the Helpdesk, and also to the
branches, would be based on the information that had
come from the developers or the designers as to what
they had seen and gone on. So we wouldn't necessarily
see what -- the comments they made.
Was there a formalised process for providing the Post
Office with information about bugs, errors and defects
and their effects on their live estate?
I don't know. There were a number of meetings that were
held between the Customer Services team and their
equivalents in Post Office but the scope of what those
discussed, and so on, I'm afraid I don't know. I wasn't
involved in them, usually.
So you, on each bug, error or defect, weren't in
38
October 2010. If we read it, having set out an extract
from a document you had created, you say:
"In this paragraph, I addressed Professor
McLachlan's hypothesis about transaction corrections
(which were the most common means by which [Post Office]
could, externally, impact the accounts of a branch).
I noted this could only happen with the consent of the
[subpostmaster] or an authorised supervisor or manager.
I was not addressing the issue of remote access as it
has been considered in the Group Litigation and [the]
Inquiry. I understand that remote access by Fujitsu is
now regard as an issue of some significance. But at
that time, remote access by Fujitsu didn't occur to me
in the context of responding to Professor McLachlan's
hypothesis, which related to [the Post Office's] ability
to impact branch accounts through transaction
corrections. Aside from the fact that I was responding
to his hypothesis, I understood then that remote access
by Fujitsu was an exceptional and regulated course.
There was nothing in Mrs Misra's case to [suggest] that
a need for remote access that ever arisen or that it
could in any way explain ongoing losses in the region of
£70,000. It was just not something that I had
considered.”
So at that time, in the autumn of 2010, was it your
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understanding that remote access was, firstly,
controlled?
It depends exactly what you mean. I believed that there
were processes that the SSC had by which they recorded
when they did carry out remote access to insert messages
into the message store.
That it was recorded and auditable?
I understood that they had a process whereby it was
recorded. I didn't know the details of what that
process was. I believe it involved things called OCPs
or OCRs, and I don't know that I ever knew the
difference between them, but I have seen both phrases
used and I believe they were different mechanisms.
Was it your understanding that remote access was visible
and identifiable by a subpostmaster who could, for
example, tell that there had been remotely inserted
balancing transaction?
That was my view at the time, though I've since come to
realise, as part of the Group Litigation, that it wasn't
always done in quite the way that I thought it was done.
That was what I wanted to ask you about. It was your
understanding at the time --
Yes.
-- in autumn 2010 that the remote access you're speaking
about here was controlled, recorded, auditable and
a
Perfect.
Then if we just scroll down to page 67. So if we
just go back up to 65. I should read this, just to put
it in context. Line 5, page 68, I said:
"Back when you gave evidence on 3 May, you described
an occasion when the Post Office had wanted to insert
transactions without the branch being aware. (I'll just
read back the [Q&A]. The question was:
"Was there any method to alert others that
corrective action had been taken to insert data or extra
messages into a branch's account?"
"You said:
“The ARQ data would contain both the original
transaction and the corrective transaction, at the point
at which they were done. If the full, unfiltered data
was retrieved and inspected, then that would show the
comment, for example. Certainly, sometimes, for counter
corrections -- and it wasn't done consistently -- but we
often might use a counter number that didn't exist to
make it clear that it was something out of the ordinary
or a.username, including SSC, again to show that it was
something out of the ordinary.
“That wasn't done on this specific one and I cannot
remember whether that was because I was specifically
asked not to or I was just producing a transaction that
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visible by the subpostmaster?
Correct. That was my view then.
What was your understanding based on?
Informal conversations with SSC staff.
Anyone in particular?
People like John Simpkins and Anne Chambers. And
I believe they have both given evidence to the Inquiry
about their understanding of how those processes worked
and how frequently they occurred.
Was that understanding, that any incidences of remote
access would be visible to a subpostmaster, a reason why
you did not the address the issue of remote access in
any of your reports or witness statements as a possible
cause of shortfalls?
It didn't occur to me that that was relevant. With
hindsight, I realise that perhaps it was but it was
something that I didn't think of as being relevant at
the time.
Did you give thought to it and dismiss it or did you not
give thought to it?
I just didn't give thought to it, I'm afraid.
Thank you. Can we turn, please, to INQ00001079. This
is a transcript of Anne Chambers’ evidence. There's
a disclosure issue at the start of the transcript. If
we go to page 17, please, and internal page 65.
42
was absolutely a mirror of the one that shouldn't have
been there in the first place and all I did was change
the signs of the values, effectively, and ... I left all
the other data as it was.’
"So remembering back to what you were saying and
judges to synthesise it, you were saying, sometimes
a fictitious counter number was used to mark out the
transaction correction?
“Answer: As I recall, yes.
"Question: Secondly, you were saying [that] that
wasn't done consistently, ie the use of a fictitious
counter number to mark out the fact that the SSC had
made a correction?
“Answer: Yes.
"Question: Thirdly, you were doing that, or the SSC
was doing that, deliberately, ie using the fictitious
counter number, because you would want to show that an
SSC member had been making the correction?
“Answer: Yes."
Then page 67:
"Question: But, fourthly, there might be occasions
when you were specifically asked not to use the
fictitious one?
“Answer: I don't think we were ever asked not to
use the fictitious one.
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"Question: _ It was just passage of your evidence
where you said 'That wasn't done on this occasion and
I can't remember whether that was because I was
specifically asked not to’, which tended to indicate
that you may have been asked not to use the fictitious
number?
“Answer: I don't recall ever being asked not to do
that and I can't remember which specific instance we're
talking about here. Sorry.
"Question: Overall, does it mean that it was
possible for members of the SSC to insert transactions
using the branch user ID?
"Answer: Right, you're talking about user ID here
now, rather than counter number, but, yes, it was --
I mean, the messages that we inserted could have
contained the branch user ID.
“Question: Would it follow that standard filtered
ARQ data would not distinguish those insertions from
those that were, in fact, carried out in the branch?
“Answer: The standard ARQ data, yes. You might not
be able to see the difference.
"Question: So transactions which appeared in the
standard filtered ARQ data, for example, in
Mr Castleton's case, with his ID user number next to
them, would not necessarily mean that they were carried
45
correspondence server and that was different from the
understanding I had as to how they operated up until
that time.
Do you know why you hadn't been told that previously?
No, is the simple answer.
You said that you'd had conversations with people in the
SSC but they hadn't revealed that to you in previous
conversations?
As I understand it, and from what John Simpkins
explained to me in 2018, normally, they would insert
transactions at the correspondence server in the way
that I was expecting, but there were a few specific
cases where they were doing it at the counter, instead,
in the way that Anne is describing in this exchange.
Did you learn about this practice of generally using
an SSC ID in order to mark them out but that not being
a consistent practice?
When things were inserted in the correspondence server,
I would have expected the details of the SSC user and
why they were doing it to be inserted as part of that,
even though it was also very obvious that it was being
done at a strange counter.
But what about what Ms Chambers has described here?
I -- it was only when I realised that they were actually
really doing things at the counter in 2018 that I was
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out by him?
“Answer: It would have been possible, yes, for SSC
to put transactions in that --
"Question: Using his ID?
"Answer: Using his ID.
"Question: Without leaving a fingerprint on the
standard, filtered ARQ data that that had been done?
“Answer: Yes, I think that would have been
possible.
"Question:
have been done?
It shouldn't have been done but it could
“Answer: Yes, I don't think there's anything that
would have prevented that. I don't believe that was
done but I can't say it's an impossibility."
Then we moved on.
When did you become aware that the SSC were able to
insert transactions into branch accounts in the way
Ms Chambers describes here?
I was aware that technically they could but my
understanding was that they always injected the
transactions at the correspondence server, rather than
the counter. In 2018, as part of the Group Litigation
Order, it was explained to me by John Simpkins, I think,
that, in some circumstances, they actually did it
directly at the counter, rather than at the
46
aware that that was a possibility --
In--
-- or something that was actually done in practice, as
‘opposed to in theory.
In 2018, did you also learn not only that they were
doing it at the counter, which is what is described
here, but they were doing it in a way that might
attribute a change to the subpostmaster, rather than
a change being made by the SSC?
If it was done at a counter and a postmaster was logged
on at the time, then the way Riposte worked, it would
always be attributed to whoever was logged on at the
time. So it all comes down to whether they -- when they
were inserting the transaction, whether they were doing
it when someone was logged on or not. If there was no
one logged on at the counter where they inserted it, or
they were using a fictitious counter, then there would
be no use for ID associated with it.
But if they were doing it in the hours of business when
the subpostmaster was logged on, their work might be
attributed to him or her?
I accept that, yes.
When did you come to learn of that?
As I say, I always knew it was theoretically possible
but it wasn't until 2018 that I realised that SSC on
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some occasions actually did that.
Were actually doing it?
Yeah.
Thank you.
I think I cover that more in my fourth witness
statement.
MR BEER: You do.
Sir, that might be an appropriate moment for the
morning break.
SIR WYN WILLIAMS: By all means. What time shall we resume?
MR BEER:
If we can have a longer break and do one break, if
that's possible. So maybe 20 minutes until 11.40.
SIR WYN WILLIAMS: Fine.
MR BEER: Thank you, sir.
(11.20 am)
(A short break)
(11.40 am)
MR BEER: Thank you.
Mr Jenkins, can we look, please, at INQ00001058.
This is a transcript of the evidence of Richard
Roll. Can we look at page 21, please, and then internal
pagination page 81, which is the top left, from line 11
onwards, which I think is a question by me. I say:
can we go back to you witness statement to
page 6, and look at (c) ...
49
"Answer: Yes.
"Question: Was there any visibility that you or
somebody else in the SSC had done this as opposed to the
subpostmaster themselves having done it?
"Answer: Sometimes yes, sometimes no.
"Question: What would distinguish?
“Answer: We would -- sometimes it would be
recorded. I'm a bit rusty on this now, I'm afraid, but
sometimes we told the postmaster we were going to do it.
While we were doing this, the postmaster couldn't use
the counter. It was very important that nobody used it.
At other times, especially if maybe the postmaster --
I'm just thinking. I'm just trying to remember
something else ... if the postmaster had gone to lunch,
[for example], we could have gone in and done things
without him knowing."
Just stopping there. I think you accept now that
the SSC staff could not only effectively hijack branch
user IDs in this way to insert transactions into branch
accounts but did so?
Yes, I accept that now. In fact, it was as a result of
seeing Mr Roll's witness statement for the Group
Litigation that then I enquired further of the SSC to
understand more as to exactly how they'd done the
injections.
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"We could go directly through the communication
servers to the [Post Office] gateway and then the
counter -- if the [postmaster] wasn't logged in then
there would be no ID attached to the database entries,
which sometimes caused the batch processing to fail
‘overnight; if the [postmaster] was logged on then any
changes we made would have their ID attached -- so as
far as the system (and any auditing) was concerned the
[subpostmaster] would have been responsible for the
transactions."
“Answer: That's what I was trying to say. I think
that's what I was trying to say in the Post Office
transcript we just looked at.
"Question: Thank you. Was this a method that you
used frequently ...
“Answer: We were all pretty adept at it, yeah.
“Question: Whether you were adept at it --
“Answer: Fairly frequently, yes.
"Question: Fairly frequently?
“Answer: Yes.
“Question: ... Why did you use that method?
“Answer: It was the only way to rebuild the
counters to get the data off the counters.
"Question: The footprint that was left would have
been the subpostmaster’s footprint and not yours?
50
Did they tell you for how long they had been doing it?
It was something that was always possible within Legacy
Horizon. What I was told was that it wasn't done very
frequently but I don't think that figure was quantified.
I believe John Simpkins may actually have tried to
quantify it at some stage but I can't remember the
details.
What about the duration of it, rather than the
frequency? Was it throughout the use of Legacy Horizon,
ie from about 2000 to 2010?
It was certainly possible throughout that period, yes.
Did they tell you anything as to whether it had been
done throughout that period?
I can't remember whether I asked that question or not.
That, as I've described it -- hijacking a branch user ID
to insert a transaction into a branch account -- would
that make the entries in the standard, filtered ARQ data
impossible to distinguish from the transactions that
were, in fact, entered by the subpostmaster in the
branch?
In the standard ARQ data, yes, if it was done on a real
counter. Though, again, as Anne Chambers was saying,
they often did it using false counters --
Yes, and --
-- and then it would be obvious that it wasn't done on
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The Post Office Horizon IT Inquiry
areal counter.
When did you discover that this could be done, was being
done and, therefore, when it was done, the entries in
the standard ARQ data were impossible to distinguish
from transactions in fact carried out by the
subpostmaster in branch?
As I say, I always knew it could be done but I didn't
realise it was being done until 2018.
Okay, so you always realised that it could be done --
Yes.
~ right from the year 2000?
Yes.
How did you know that it could be done?
Because I knew what functionality the Riposte provided
and the sort of interfaces it provided to allow it to be
done.
But nobody had told you, from that time onwards, that
they were in fact doing it?
Correct.
You discovered that in 2018/19?
That is my belief, yes.
So you knew that the SSC had the facility to tamper with
branch accounts?
I don't think I'd call it tampering but, yes,
I understand what you're saying.
53
Did you not realise that, whether the SSC told you that
it was being done rarely, wasn't the real issue; it was
the extent to which there was a tamper-proof evidential
chain being presented to a court?
I'd not thought it through in that way at the time, I'm
afraid.
Can I turn to your own knowledge of remote access by
turning up WITN00420100. This is lan Henderson's
witness statement. Do you remember him from Second
Sight?
Yes.
Can we turn to page 13, please, and look at paragraph 43
at the bottom. He says:
"In September 2012, I met with Gareth Jenkins, the
lead engineer for Post Office Horizon, at the Head
Office of Fujitsu in Bracknell. He told me that
approximately 10 members of staff from Post Office were
permanently based in Bracknell, dealing with various
issues including bugs, errors and defects.
"44. Gareth Jenkins told me that Fujitsu routinely
used remote access to branch terminals for various
purposes. This was often without the knowledge or
specific consent of individual subpostmasters. He also
told me that members of his team could connect remotely
to branch terminals and generate keystrokes that were
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Well, it would be tampering, wouldn't it? I know that
carries pejorative overtones --
That's why I didn't like the term. I believe that the
SSC would have been using that facility responsibly and
doing it when they needed to, to correct errors that had
occurred in the branches.
The standard filtered ARQ data used in court proceedings
wouldn't be able to distinguish between those occasions
when a transaction had been made by the subpostmaster
and when it had been made by the SSC?
Not if it had been done at the counter.
Therefore, the standard ARQ data used in cost
proceedings couldn't, of itself, prove that the branch
accounts had not been, in my words, tampered with?
I accept that now but I hadn't thought of it that way at
the time.
When you prepared your witness statements, both the
case-specific witness statements and the generic witness
statements, you didn't mention the facility that the SSC
had to undertake this function, did you?
No, because I didn't think it was relevant. Again, with
hindsight, I realise that perhaps I should have done
but, at the time, it was -- my understanding was, and
still is, that it was a very rare thing for the SSC to
actually do.
54
indistinguishable from a subpostmaster accessing the
terminal directly. They did this for various purposes,
including collecting log files directly from branch
terminals."
Is what Mr Henderson says there accurate?
I don't think so. I don't think that is how I would
have explained things. I mean, particularly the last
bit about collecting log files directly. That's nothing
to do with adding -- changing transactions into the
accounts.
Do you agree that in September 2012 you met lan
Henderson?
Yes, I agree.
Do you agree that was at the Head Office in Bracknell?
Yes.
Did you tell him that members of staff from Post Office
were based in Bracknell permanently, dealing with issues
including bugs, errors and defects.
I was referring to some of the testers, not people --
those Post Office staff members did not have access to
the live system.
You weren't, in your conversation, referring to the SSC
then?
No. Not in terms of paragraph 43.
Did you tell him that Fujitsu routinely used branch
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access to branch terminals for various purposes?
I probably said that SSC had access to the branches for
pulling back things like diagnostic logs, and things
like that, and I may well have suggested that it was
possible for SSC members to inject correcting
transactions. But I would have seen that as being done
through the correspondence server at the time --
Did you -
-- but whether I spelt that out in detail at the time,
I just can't recollect the details of the conversations.
Did you tell him that such remote access was often
without the knowledge or specific consent of individual
subpostmasters?
Well, if it's referring to actually pulling back log
files, there would be no need for the knowledge or
consent of the subpostmasters.
Did you tell him that members of your team could connect
remotely to branch terminals and generate keystrokes
that were indistinguishable from a subpostmaster
accessing the terminal directly?
I don't think I would have said those because the only
people who had that sort of access were the SSC, and
they weren't part of my team.
Did you tell him that anyone in Fujitsu could connect
remotely to branch terminals and generate keystrokes
57
correspondence server, which would be distinguishable.
He was, it seems, told, that there was a form of remote
access that made what had happened indistinguishable
from the subpostmaster carrying out the relevant
functions. That, you say, you didn't know at the time
was happening but you subsequently found to be true in
2018/2019?
Again, I knew it was possible but I didn't know that it
was being regularly done.
What was the context of your conversation with him in
September 2012; why were you talking about remote access
at all?
I can't remember. My recollection was that we had
a meeting when I was talking to him about how he could
actually interpret and analyse the logs.
Do you think you would have spoken about remote access
in that connection, ie what the logs did or didn't show?
I can't remember, I'm afraid.
Can we go back in time a little to 2002 by looking at
FUJ00088036. Can you see that this is a Fujitsu
document, a design document, version 1 of which is dated
2 August 2002?
I can see that, yes.
It's described as 2Secure Support System Outline
Design"?
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that were indistinguishable from a subpostmaster
accessing the terminal directly?
I wouldn't be generating keystrokes, so any injection of
data wasn't done by generating keystrokes.
Did you tell him that Fujitsu staff could connect
remotely to branch terminals and alter branch accounts
in a way that made it indistinguishable from the
subpostmaster doing so?
I don't think I would have said that because my
understanding was it was actually done at the
correspondence server at the time.
In general terms, you say you wouldn't have said this
because you didn't know it at the time: you only
discovered this in 2018/2019?
That's my understanding, yes.
What is he's attributing to you, in September 2012,
never mind the precise details, but generally speaking,
is accurate, isn't it?
That there was remote access, yes, but not in terms of
the gory details of it.
Well, not only that there was remote access, there was
remote access of a kind which made it indistinguishable
from the subpostmasters' activities?
Well, I'm not sure that would be the case because what
I was thinking of was remote access to the
58
Yes.
You're neither an originator nor a contributor?
Correct.
You'll see the abstract:
[It] describes the requirements and outline design
for secure operational support access to counters and
servers."
Then if we scroll down, please, look at the approval
authorities on that page, and then over the page -- and
scroll down -- you're not included in any of those?
Correct.
Is this a document you would have seen at the time?
Probably not.
If you can tell us in general terms why not?
It wasn't an area that I was particularly involved in.
Because it's about the functions of the SSC; is that
right?
It was to do with some tooling that was being provided
for the SSC is what I understand from it from reading it
now.
Can we look, please, at page 15, and look at 4.3.2.
This is describing the position in 2002:
... support access to the Horizon system is from
physically secure areas."
You would know that to be the case: the SSC was, as
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you've told us --
Yes.
-- was in a physically secure area?
"Individuals involved in support processes undergo
more frequent security vetting checks."
Were you were of that?
I wasn't aware of that but I'm not surprised that they
were.
"Other than the above[,] controls are vested in manual
procedures, requiring managerial sign-off controlling
access to Post Office Counters where update of data is
required. Otherwise third line support has:
"Unrestricted and unaudited privileged access
(system admin) to all systems including post office
counter PCs ..
Did you know that was the position in 2002?
I can't remember. I wasn't involved in the detail.
Did you ever come to learn that they, in the SSC, had
unrestricted and unaudited privileged access to all
systems including counters?
I know that later on it was audited. I didn't realise
that this was something that had not been introduced at
day 1.
When did you find out it was controlled in some way or
audited in some way?
61
“Operational risk -- errors as a result of manual
actions causing loss of service to outlets;
"Infringements of the Data Protection Act."
When you were giving evidence about the operation of
Horizon in your witness statements, is this the kind of
information that you ought to have known about?
With hindsight, probably, yes.
When you wrote your witness statements and when you gave
evidence in the Seema Misra case, did you make any
efforts to find out about issues such as this?
My understanding was that, at that time, things were all
being audited and there were processes in place but
I didn't understand the details of the processes and
what auditing was taking place.
When did you gain an understanding that everything was
being audited and processes were taking place?
I don't -- I can't remember, is the simple answer.
Can we look, please, at FUJ00089535. If we just look at
the date of this by scrolling down -- over the page.
There, the foot of the page -- sorry, just at the top.
24 August 2016; do you see that?
Yes.
If we go back up to the first page, "Remote Support
Secure Access Server High Level Design”. Is this
speaking about a similar thing than as in the previous
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Well, what this outline design is to do with the
mechanisms that were introduced to give that control.
What I didn't realise was that that hadn't been there
from the very beginning, until I saw this document as
part of my preparation for the Inquiry.
Okay, so it wasn't until 2021 --
Maybe later, yeah.
-- or even later --
Yes.
-- that you realised that the SSC had unrestricted and
unaudited privileged access to counters?
As far as I can remember, yes.
It says, secondly, third line support has:
"The ability to distribute diagnostic information
outside of the secure environment; this information can
include personal data”, et cetera.
The document continues:
"The current support practices were developed on
aneeds must basis; third line support diagnosticians
had no alternative other than to adopt the approach
taken given the need to support the deployed Horizon ...
"There are ... no automatic controls in place to
audit and restrict user access. This exposes Fujitsu
to the following potential risks:
“Opportunity for financial fraud;
62
document we looked at?
I don't know. I don't recognise that. I see that what
looks like my name is there but that is the other Gareth
Jenkins working on Post Office because I had retired at
that point.
I was about to ask you, if we scroll down, please. The
"HDCR Solution Owner", that's not you?
No, I had retired by that time and I was aware that
there was another Gareth Jenkins working on the account,
which did cause some confusion.
So you didn't see this document at the time?
No.
So the references that I would find in it backed the
2002 document that we looked at, it's a reference
document and there are some extracts from it cited in
the body, you wouldn't have seen at the time in 2016?
No.
Thank you. Can we turn, please, to POLO0097217. If we
scroll down, please, if we go to the foot of the
document -- and scroll up, keep going so we get that
first email. Thank you.
An email from Rachael Panter to you of 26 November
2012, copied to others, asking for an expert report.
This is in the case of Kim Wylie, yes?
Yes.
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She says:
"Dear Gareth
"Request for an urgent expert report
"Further to my previous email, I am writing as
a matter of urgency to request a signed and dated copy
of your report in the case of Kim Wylie ...
"I have attached a copy of [defence solicitors']
request for further disclosure ...
"I have also attached some documents ...
“All of which set out the background to this case.
Please can you consider [this] and include this
paragraph at the beginning of your report:
I have been asked to prove statement in the case
of Kim Wylie. I understand that the integrity of the
system has been questioned and I can say the following.’
"As there have been no specific criticisms of
[Horizon] raised by the defence, your previous report
can be used with the addition of the opening line
referred to above. Please see the Defence Case
Statement which contains the nature of the defendant's
case."
If we scroll up, please, to see your reply:
"I have been advised that I can try to help you [you
say], if it isn't too late.
“I've had a read through the info you sent me
65
to your generic statement of 5 October?
Correct.
"I understand the integrity of the Horizon system has
been questioned and this report provides some general
information regarding the integrity of Horizon."
Then if we skip a paragraph and look at:
"I also note a comment has been made about it being
possible to remotely access the system. It is true that
such access is possible; however in an analysis of data
audited by the system, it is possible to identify any
data that has not been input direct by staff in the
branch. Any such change to data is very rare and would
be authorised by [the Post Office]. As I have not had
an opportunity to examine data related to this Branch,
I cannot categorically say this has not happened in this
case, but would suggest this is highly unlikely."
Dealing with that proposed insertion into the Kim
Wiley statement, which I'm not going to deal with it
now, you in fact entered into the Kim Wiley statement?
Yes.
You say:
"It is true that [remote access to the system] is
possible ..."
Yes.
You say that:
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yesterday and I have also taken my previous witness
statement which I produced in early October and amended
You're there, I think, referring to your generic
witness statement of 5 October 2012.
Correct.
We're going to come back to that generic witness
statement later:
"Reading through the Defence Statement I see it does
make some specific points which my statement doesn't
currently address. Specifically the challenges
regarding Robustness and Remote Access to the system.
Do you want me to try and address these specifics?"
Then scroll down. Then some admin. Then if we go
up, she replies:
"(Thank youl. If you feel you are able to deal with
the issues of robustness and the Remote Access system
fairly swiftly then I would like you to address [these]
points that have been raised, so that we can deal with
every area that they have criticised.”
Then scroll up, you say:
"What I propose is [adding] the following:
"I have been asked to provide a statement in the
case of Kim Wylie."
Just stopping there, this was going to be a bolt-on
66
in an analysis of data audited by the system,
it is possible to identify any data that has not been
input directly by staff in the branch."
That's not accurate, is it?
It was as I understood things at the time but it isn't
in my understanding of things now. Well, sorry, when
I say that, if the SSC had been following their
processes, then it would be -- even if they'd been doing
it at the branch, it should have been visible in the raw
data but not in the ARQ extracts.
What data were you referring to there? You say:
"however in an analysis of data audited by the
system ..."
Whatever data was there. So when I was looking at data
I tended to have the raw data as well as the ARQ data
and I appreciate, and I say here, that I'd not had the
‘opportunity to examine any data from the branch.
On what basis did you understand, here in 2012, that any
change to data was very rare?
From informal conversations that I'd had with the SSC as
I mentioned earlier.
So the people --
Not saying I'd had a conversation as part of this but
just from what I'd picked up over the years.
So informal chats?
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Yes.
Where did you get the understanding that any such change
would be authorised by the Post Office?
I thought that was part of the process. As I understood
it, then any changes -- when they inserted data, then
there would be a mechanism whereby Post Office would
sign it off and I believe that both Anne Chambers and
John Simpkins indicated that as part of their testimony.
You knew, when you were making this addition to the
statement, though, that there was a form of remote
access that could occur that would not be shown in the
data?
I knew that it was theoretically possible. I didn't
think it was something that was routinely done.
Why didn't you say so?
Because I didn't think of it. I was assuming that
things were done in the normal way at that time.
Do you think that that was the right basis to approach
statements made to criminal courts: on the basis of
assumptions, of propriety?
I realise now that that is the wrong basis for doing it
but that is what I felt at the time.
You do say you cannot categorically say this hasn't
happened in the case but suggest it was highly unlikely.
On what basis were you saying it was highly unlikely?
69
Then he continues:
".., the previously supplied email suggests that the
Bracknell Team could access, possibly on an overnight
basis, transactions on the live system.
"Please see the following extracts ...
“Although it is rarely done it is possible to
journal from branch accounts. There are possible P&BA
concerns about how this would be perceived and how
disputes would be resolved'."
Then scroll down, please, and over the page.
"At the moment your response is inconsistent with
what is being said in emails sent between Bracknell Team
members.
"Can you look into this urgently and address this
apparent inconsistency in an updated response?"
So you're being asked, essentially, to comment on
questions from Second Sight about staff at Bracknell
having access to the live system?
Yes.
Did you reply to this?
I can't remember. I may well have done, yes.
If we scroll to the top, I'm not sure that I found
a reply.
Did you have a conversation with Mr Baker about it?
I can't remember. This is part of what I think was
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Because I knew that -- well, I understood that remote --
that inserting transactions by the SSC was a very rare
thing and I believe that has been established, as well.
Can we turn on to POL00098724. This is an email to you
from Simon Baker of June 2013, so the following year.
If we just scroll down, he cites from an email that you
had sent, where he says:
he key message in your response is as follows:
The [Post Office] Bracknell Team had no access to
the live system therefore could not conduct any of these
transactions'."
Is that something that you told him?
Yes, I think so. The Post Office did not have access to
the live system. Yes.
Then -- well, hold on. The Post Office Bracknell team?
Did not have access to the live system. They only had
access to test systems.
If you said that, would you be referring to Post Office
personnel --
Yes.
-- stationed --
That's what I meant by "POL".
-- at Bracknell --
I would have said "POA", if I was referring to the
Fujitsu team.
70
SRO5, one of the spot reviews, and there were emails
about things, but this particular bit of it was talking
about the Post Office team and it was very clear to me,
from the context, that it was referring to the Post
Office team in the basement. I notice there was
a reference to journalling and I think that was.
referring to what Post Office could do in their back-end
systems in Chesterfield, which would have no impact on
the actual branch accounts.
see. So the context of this exchange or these
requests is Post Office staff at Bracknell, rather than
Fujitsu staff?
That is how I understand it from looking through this
now. I can't remember the details of this specific
email off the top of my head but it is one that
I recognise as having looked at as part of my
preparation for the Inquiry.
Thank you. Moving on, can we turn to FUJ00087100. If
we scroll down, please, a little further -- thank you.
Just scroll up, thank you, we can see an email from
Michael Harvey to you and James Davidson, and he says:
"With respect to inserted data -- can you provide
a little more detail as to the audit trail that addition
of data leaves. So notwithstanding that we haven't used
it, if we were to use, would the subpostmaster or Post
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Office be able to see it in the audit record. I assume
[that] this is the case and so can we make it explicit.
We need to be cognisant of the point that these two
individuals are attempting to make -- they are trying to
say that [Fujitsu] have changed data and so in answers
Post Office's explicit questions the underlying answer
must be:
"1. When we have and why (ie the 2010 incident);
and
"2. If we had, the following audit trail would be
left demonstrating we had done it -- no audit trail
means we could not have changed the data."
Scroll up, please. Your reply:
"The answer is slightly different depending on
whether we are talking about the old Horizon (2010 or
earlier) or new Horizon Online (2010 onwards).
“However in both cases the injected transactions
would be visible in any local reports the postmaster may
view and also in the audit extract."
I think you now realise that to be wrong, don't you?
Yes, I do.
On what basis were you saying it?
Because my understanding was that, whenever the SSC were
injecting transactions, they did so at the
correspondence server and not at the counter.
73
in threatened or possible court proceedings, or court
proceedings themselves: you work on the basis of what
you had understood from conversations and what you
thought you knew, rather than properly researching
an issue?
Yes, I guess that has to be the case.
If we scroll back up to your reply. Yes, sorry, we're
there. You say:
“In both cases the audit extract would show (perhaps
not obviously and in different ways depending on the
version of Horizon) that these transactions had been
inserted in the data centre and not taken place on
anormal counter.
That's not correct in relation to standard ARQ data,
is it?
It would be in the ARQ data because one of the bits of
information in the standard ARQ data is the node ID or
the counter position and anything injected at the data
centre would have a node ID that reflected that it was
being done at the data centre.
You say:
"Our processes should ensure that [Post Office] have
signed off on any occasion when such data was inserted.”
What enquiries did you make as to the nature of the
processes?
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Was that based on informal conversations as well?
I can't remember on what basis it was. It was probably
informal conversations and also the fact that it's
actually a lot easier to inject transactions at the
correspondence server than the counter in terms of their
processes.
The context in which you were being asked this, I think
James Davidson was the lawyer, wasn't he?
No, James Davidson was -- at that stage, I think he
was -- he had been employed by Fujitsu as head of
Customer Services.
Okay.
He'd then left and gone freelance and was primarily
involved in liaison along -- for Second Sight between
Fujitsu and Post Office. Michael Harvey was a lawyer,
I believe.
Thank you. You were being asked by a lawyer for quite
precise information, if we go back to his email.
Yes, and that was my belief at the time. I accept now
that I had misunderstood things.
Well, it wasn't misunderstood. What enquiries had you
made in order to provide the answer that you did?
At the time, none. I was relying on what I thought
I knew.
Is that reflective of a general approach when involved
74
At the time, none but my understanding had been that
there were standard processes, which I didn't know the
details of, that the SSC followed, which involved
getting things signed off by Post Office.
‘Again, you say that was based on your understanding.
Was that just through general chat?
Probably, yes.
Can we move forward, then, to the Horizon Issues
judgment, please. RLITO000005. Page 87, please, and
pick up at paragraph 316:
"He [that's Mr Godeseth] had given information in
his first witness statement, namely that in Legacy
Horizon, any transactions injected by [the] SSC would
have used the computer server address as the counter
position which would be a number greater than 32, so it
would be clear that a transaction had been injected in
this way by someone other than the [subpostmaster].
This is important because it would be consistent with
the case originally advanced by the Post Office that any
such injections would be entirely visible as having been
done externally (ie, not within the branch) due to the
counter number used.
"317. However, this important incorrect, and was
corrected by both Mr Godeseth and Mr Parker in
subsequent statements before they were called and as
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a direct result of Mr Roll's evidence. The information
that was incorrect, and therefore had to be corrected,
had come directly from Mr Jenkins. This shows that
Mr Jenkins did, in at least one very important respect,
give Mr Godeseth directly incorrect information about
the visibility of injected transactions, which not only
could have an effect on branch accounts, and whether
this would show (or rather, not show) that the impact on
those accounts had come from the injections made outside
the branch. Mr Godeseth only found out the true
position when Mr Parker was preparing his subsequent
witness statement in the weeks prior to the commencement
of the Horizon Issues trial, in other words in 2019. He
had not known that before. His explanation" --
Sorry. I don't think that is quite an accurate
representation of what actually happened in the --
Just let me get to the end of the paragraph?
Sorry:
"He had known that before. His explanation was as
follows", and then he sets out an explanation.
Firstly, is it right that you told Mr Godeseth that
any transactions injected by the SSC would have used the
computer server address at the counter position using
a number greater than 32?
That was my understanding when I was having
77
John Simpkins, which pointed out the error in my
previous understanding.
We've seen Mr Henderson say that you said to him in 2012
that Fujitsu could remotely access branch terminals and
insert transactions which would be indistinguishable for
those in the branch?
And we've seen him say that, yes.
You subsequently claimed otherwise in your emails that
we've looked at?
Yes.
It appears when you gave your initial account to
Mr Godeseth, for the purposes of him writing a witness
statement, you maintained that position?
Yes, it was a genuine mistake.
So is it the case that it turns out that what
Mr Henderson says you admitted to him in 2012 was, in
fact, in general terms true all along?
I don't believe that I would have said that at the time,
but I just can't remember the conversations that we had.
It was my genuine belief that injections of transactions
were done at the correspondence server, rather than at
the counter.
Thank you. Can we turn to a new topic, please: the use
and reliability of ARQ data. You deal in various points
in your third witness statement with ARQ data. Can we
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a conversation with him -- I can't remember the exact
month now, I think it was probably August or September
in 2018, something like that -- when he was preparing
his first statement.
Why were you having that conversation with him?
To explain my understanding of remote access at that
time.
Why were you having to explain to him your understanding
of remote access?
I think I was commenting on a witness statement that he
was putting together for the GLO.
So is this right: as a result of informal chat, you told
Mr Godeseth something that turned out not to be true, he
included it in a witness statement in the High Court?
I realised my mistake soon after he'd actually put his
witness statement in and I then attempted to correct my
mistake shortly after that. And I sent a -- I produced
a document about two or three weeks after his final
draft of his first witness statement, pointing out that
I'd realised that that was actually incorrect, and
I sent that to the various lawyers and to Torstein and
also, probably, to Steve Parker.
Did your change in approach come about because of you
reading Richard Roll's witness statement?
Yes, and as a result of that, I had a conversation with
78
turn those up, please. Paragraph 127, which is on
page 41. 127, you say:
"The evidence before the Inquiry has shown that
issues sometimes arose in respect of the audit data."
You deal with the issues in greater detail below:
however, there is a distinction I think it is
important to be clear about at the outset. This is the
distinction that exists between (a) data which actually
gets committed to the audit server (which becomes the
audit data), and (b) data being affected by a problem
before it is committed to the audit server (which, at
that stage is not audit data)."
Then paragraph 128, you say:
overall the issues which have been considered
by the Inquiry do not change my mind that the audit data
(including the raw audit trail and the NT events logs)
was a highly reliable and effective means of diagnosing
system issues. I would still agree with Mr Justice
Fraser's judgment that audit data (once the true scope
of that term is understood) was a gold standard for this
purpose. The relevance of audit data not including
information generated by POLSAP or Credence ... is not
clear to me, since neither system was used by
[subpostmasters] in balancing their accounts.”
Some general questions to start with then, please.
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Did you, in general terms, consider that the ARQ data
that you were provided with, in each case that you were
asked to provide a witness statement, was sufficient to
enable you to reach conclusions about whether
a particular branch had or had not experienced issues
with Horizon?
It's not just the ARQ data; it's looking at the
associated NT event logs that come with it.
Yes, so ARQ data plus NT event logs?
Yes.
Did you consider that both species of data were
sufficient for you to reach reliable conclusions about
whether a particular branch had or had not experienced
issues with Horizon?
I was looking -- right. I think, with the use of the NT
events, then, yes, the ARQ data would be reflecting what
had actually been recorded at the branch and, if there
was a problem in recording it, then that would have been
visible in the NT events, so yes.
So is the answer to my question "yes" then?
I think so yes.
Has your view about adequacy of any such data in any way
changed, in the light of any of the evidence given to
the Inquiry by any of the Fujitsu witnesses?
I believe that it is also useful to be able to look at
81
I think I was giving a general view of how I thought --
how the system should be operating. I was expecting to
have some sort of comeback in terms of specifics, if
that was appropriate, and clearly in some of those cases
it didn't happen.
Who were you expecting to give some sort of comeback?
The Post Office Investigators.
Why did you make it clear, in some witness statements,
for example the Grant Allen one, that you were unable to
offer a view as to the cause of specific shortfalls in
that case, without having seen the ARQ data but not in
others?
Because I'd actually been given some specific
information there as to something that might be the
cause and I was agreeing that that could be a cause, and
that was something that I would have needed to
investigate.
Did it ever occur to you to refuse to provide a view,
unless and until you were provided with all of the data
that you considered necessary in order to answer the
questions which you have been asked to address?
Well, taking that specific case of Grant Allen, I was
certainly concerned about that, and not only did I check
with the lawyers from Post Office that it was okay to
sign that statement, I also checked it with the lawyer
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the raw NT event logs as well, and I usually had access
to those raw event logs.
Did you look at them?
Yes. At least when I was given evidence -- I mean,
there was clearly some cases in 2012 where it was
decided that there was no need to look at the ARQ data
at all.
In some cases, in your witness statement, I think you
made clear that you hadn't seen the ARQ data and,
therefore, couldn't comment on the cause of the
shortfall?
Correct.
In other cases in which you provided a witness
statement, you didn't explicitly point that out?
That is correct. I was expecting that, if there were
some specifics to be looked at, then I would be shown
the ARQ data. But, clearly, I -- that didn't happen
in -
In those other cases, in which you provided a witness
statement but didn't state that you were unable to
comment on the cause of the shortfalls without having
seen the ARQ data and NT event logs, should we take it,
nonetheless, that you felt able to offer definitive
views on the causes of shortfalls, without having seen
such data?
82
within Fujitsu that it was okay to sign that statement
before I did so.
Did you assume that those at the Post Office responsible
for pursuing the criminal cases, ie investigating or
prosecuting them, who were asking you to provide reports
and witness statements, were aware of the fact that you
didn't automatically have access to ARQ data and NT
event logs in every case?
I had understood that it was the normal thing to
actually have ARQ data. It wasn't until later that
I realised that they didn't always provide it.
I thought that was the whole purpose of ARQ data, was to
have some sort of information to support any sort of
prosecution or investigation.
Dealing with the distinction that you make in
paragraph 127 -- if we just scroll up -- between data
which is committed to the audit server and that which
isn't -~
Yes.
-- if data is affected by a problem before it is
committed to the audit server, would that mean that
there is a risk that, once the data is committed to the
server, it's unreliable?
If taken into account with the NT events, then that
would make it clear that that has actually happened.
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So, as long as you look at the NT events as well as the
ARQ data, then I felt it would be reliable.
I don't think you addressed that point in any of your
reports or witness statements or any of your advices or
explanations to the Post Office?
I was expecting to be asked to look at the -- at the
audit data, which therefore would have been doing the
checks against the NT event data, but I accept that that
didn't happen.
So again, the reason for not mentioning it is you were
expecting somebody to come back to you about it?
Correct.
When you were looking at audit data which had been
committed to the server, how could you be confident that
that data hadn't been affected by a problem before it
got to the server?
Because I know -- I was aware that the process for
generating -- for generating the ARQ data would include
checking for unexpected NT events at the same time,
which should therefore have detected any such failure.
Can we look, please, at POL00097480, and go to page 3,
please, and scroll down. This is quite a complicated
email chain between you and Helen Rose about the Lepton
report and the logs produced as a result. If you can
try and and help us distinguish or understand what's
85
was one not undertaken by the subpostmaster but was one
generated wrongly by Horizon itself?
No, it wasn't generated wrongly by Horizon itself; it
was one that was generated by Horizon itself as part of
the recovery process following a failure of the system,
and the whole purpose of that reversal being undertaken
by the system was to reflect what the postmaster would
have understood to have occurred at the time of the
failure.
I see. So it was an automated process where the system
generated the reversal?
To reflect what should have been understood by the
subpostmaster in the branch at that particular time.
Okay. Then if we scroll up, please, we see Helen Rose
replies:
"l.can see where this transaction is and now
understand the reason behind it. My main concern is
that we use the basic ARQ logs for evidence in court and
if we don't know what extra reports to ask for then in
some circumstances we would not be giving a true
picture.”
That's right, isn't it: that if they were using, in
court cases the basic ARQ logs, in some cases a true
picture would not be given to the court?
I would dispute that because, in fact, that reversal was
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being said to start with. You refer to some files and
you say:
"[They] are part of the standard ARQ returned."
Yes.
Then in the third paragraph you say:
“If that [which is what you described in
paragraph 2] is sufficient for your purposes, then you
do have all you need in the standard ARQ.
"However what I was able to confirm from my look at
Live data a couple of weeks ago and is also held in the
underlying raw logs is confirmation that the reversal
was generated by the system (and not manually by the
user). What might also be available in underlying logs
is whether or not the system was rebooted -- I suspect
it was but have no evidence one way or the other ...
I can confirm that the [other] user did log on again ...
"Do you need anything further from me ..."
To summarise, you were explaining here, the
limitations of what was included in standard ARQ data;
is that right?
Yes.
You were explaining some additional data that you were
able to find by looking at what you call Live data --
Yes.
-- which in fact revealed that the relevant transaction
86
part of providing the true picture. The reason that
reversal had actually taken place was to reflect what
the subpostmaster would have seen in the branch at the
time.
Well, hold on, if we go up to your -- well, hold on. We
should read the second paragraph first?
"I know you are aware of all the Horizon integrity
issues. I want to ensure that the ARQ logs are used and
understood fully by our operational staff that [we] have
to work with this data both interviews and in court."
What did you understand her to mean by saying to you
that you were aware of all of the Horizon integrity
issues?
She -- I'd been sent, a few months earlier, a report
that she'd produced of branches that were challenging
the integrity of Horizon. So I assumed that she was
referring to that report of hers, which -- which I'd
been sent a copy of.
So not meaning you're aware of all of the integrity
issues with Horizon that in fact exist but, instead,
meaning all of the allegations made by subpostmasters
about Horizon integrity issues?
That is how I would have understood that statement to
have been made.
She says:
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"... [want to ensure that the ARQ logs are used and
understood by operational staff that have to [use them]
in interviews and in court."
If we go back up to your reply, please. You say
you:
"_. understand your concerns.
“It would be relatively simple to add an extra
column into the existing ARQ report spreadsheet, that
would make it clear whether the Reversal Basket was
generated by Recovery or not. I think this would
address your concern."
So was it the case that the existing ARQ data being
relied on by investigators and prosecutors did not give
a full picture; you were less thing a solution to that?
A. It was giving a full picture of what had occurred.
There were some -- these system recoveries were purely
to actually put the branch accounts back into the state
that they should have been in following a failure. It's
a fairly complicated scenario to try to describe.
I don't know if you want me to get into the
technicalities, I suspect not, but it was all to do with
what could happen when a comms failure occurs at the
wrong time.
Q. You don't say in reply "Hold on, Helen [or Ms Rose],
you're wrong, the data you have does present a full
89
Q. The first -- excuse me. I've got a frog in my throat.
It's hayfever.
‘SIR WYN WILLIAMS: = Take your time, Mr Beer.
MR BEER: You authored two reports, the first, 2 October
2009; do you remember?
I remember that report, yes.
The title of that was "Horizon Data Integrity"?
Yes.
That was about Legacy Horizon?
. Correct.
SIR WYN WILLIAMS: Would you prefer an early lunch? It's
a 12.45?
MR BEER: That's most generous, sir.
‘SIR WYN WILLIAMS: = Right. What time shall we resume?
MR BEER: Can we say 1.35, please.
‘SIR WYN WILLIAMS: Right. Fine.
(12.44 pm)
rPoOoOPrPOoP,
(The Short Adjournment)
(1.35 pm)
MR BEER: Thank you, sir. I think I'm back up to full
operating speed.
SIR WYN WILLIAMS: Good.
MR BEER: Mr Jenkins, we were going to look at the two
Horizon data integrity reports that you wrote and I was
summarising that you authored two reports, the first of
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picture". You say there needs to be a change in order
for it to do so?
What I was saying was that, if she wanted to be aware of
those things specifically, then that could be added into
the ARQ -- into the standard ARQ extract.
Was that done --
I don't --
-- to your knowledge?
Not as far as I'm aware.
Why wasn't it done, to your knowledge?
Because it required Post Office to request a change on
Fujitsu to do that and I don't believe they pursued it.
So it was a Post Office decision?
That -- yes.
Do you know why the Post Office did not pursue it?
No.
Thank you. Can we move on, please, to your integrity
reports.
Yes.
Thank you. That can come down. Just looking at it
generally, to start with, you authored two reports
addressing the integrity of data on Horizon?
I think they were narrower than that, in terms of what
their scope was. But I know the reports you're
referring to.
90
which was dated 2 October 2009, and the title of which
was "Horizon Data Integrity" --
Correct.
-- and that was about Legacy Horizon?
Correct.
The second of which was dated 25 November 2011 and was
called "Horizon Online Data Integrity", and that was
obviously about Horizon Online?
There were various versions of it with different dates,
but, yes, that was the date of one of them.
The last version, I think, that we've got is version 4
and is dated 25 November 2011?
There was a variant on that that I used later on in 2012
but, yes.
Can I ask you some general questions about those
reports, then, before looking at the contents in detail.
Firstly, at the time that you prepared the first report,
the one about Legacy Horizon, called "Horizon Data
Integrity", what did you understand the purpose of the
report was?
I was asked to provide a report on some specific failure
scenarios that occurred on Legacy Horizon. I couldn't
remember initially what it was that had caused that but
when Dave Smith gave his evidence to the Inquiry, he
says that he phoned me up and instructed me to do that,
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and I was happy to accept that. I've since seen some
emails saying that I was asked by people in Fujitsu on
his behalf to write that report but I don't think that
really contradicts what I said before.
Did you therefore understand that you were being asked
to produce a report that was narrow in scope about very
specific issues?
Correct.
In relation to the Horizon Online data integrity report,
at the time that you prepared that, what did you
understand its purpose was?
Initially, it was supposed to be a companion document to
that. It then got subsumed into documents to support
a proposed investigation that Fujitsu were having with
KPMG into the integrity of the audit trail.
So originally it was a companion document to the --
But with a similar sort of scope, in other words looking
at primarily at what -- the integrity of the audit
trail.
Why did the reports not cover all bugs, errors and
defects known to Fujitsu at the time that they were
written?
Because that wasn't what I was asked to produce at the
time.
Do you know why you weren't asked to produce a report
93
cutdown version of it in 2012, I saw that purely as
being a description of the integrity of the audit trail,
and I wasn't -- I think there was an email exchange
wanting a report, effectively the equivalent of the
Legacy Horizon one, and I thought it was actually to do
with prosecutions, rather than anything to do with
briefing of MPs, or anything like that.
Were you told at any time that the Post Office intended
to use your report as a basis to address concerns raised
by MPs?
I don't think I was even aware of that now!
Can we look at the detail, then, of each of the two
reports. Can we start, please, with the Legacy Horizon
integrity report, data integrity report. FUJ00080526.
Thank you. We can see the document's title is "Horizon
Data Integrity", and we can see on this page here that
you are the author of it?
Correct.
Correct. If we just go over to page 2, please, and
scroll down -- and over the page, and scroll down --
after the index we can see the document history. Can
you see the version that we're working from here is
version 1.0, dated 2 October 2009?
Correct.
If we just look at the foot of the page, we can see
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that was addressing all known bugs at the time?
No, I was asked to produce a report covering the scope
that the report actually covered.
Were you aware, whilst employed by Fujitsu, that the
Legacy Horizon report was relied on by Mr Ismay of the
Post Office in preparing his report in August 2010 about
the general robustness of Horizon?
No, I was not.
You didn't know it was going to be appropriated and used
for a different purpose than you had prepared it for?
No, I didn't.
Have you seen now, in fact, how it was used by --
Yes, I have seen Mr Ismay's report, as part of the
documentation I've been provided for the Inquiry.
Do you agree that it has been used for a purpose
different from that which you intended?
Yes, it has been.
Were you aware at the time that you wrote the Online
report that the Post Office may intend to use that
report as a basis for briefing or addressing concerns
raised by MPs?
When I wrote the Online report, I don't think it was
prepared for the purpose of the Post Office, that the
KPMG audit was not something that Post Office was
necessarily aware of at the time. When I produced the
94
that. That's on every page, bottom right; can you see
that?
Yes.
Just go back up to the top of the page. Just out of
interest, version 0.1b, which appears before version 1
is described as a first informal draft that is dated
a year after the final version for release?
I think that must be a typo.
Should that be --
That should be 2009. I'd not noticed that until now.
Okay. So does that reflect that you created the report
and finalised the report all on one day?
I think I -- I think the version 0.1a may have been
produced a day or two before that but, yes, the whole
report was produced in a fairly short timescale.
We can see who is required to review it, "Mandatory
Review: Suzie Kirkham and Jeremy Worrell", both Fujitsu?
Yes.
Then "Optional Review’, are the first three of those
Fujitsu?
Yes.
The fourth them is Mr Smith from the Post Office; is
that right?
Correct.
Do you know whether he in fact reviewed it?
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I can't remember now.
It's not marked up with the asterisk, if you look at the
bottom of the page, which indicates that the reviewer
actually returned comments.
Yes. I'm not sure whether it had been sent to him but
the thing was -- I was asked to actually get it signed
off and reviewed quickly. So whether he'd actually seen
it or not, I'm not absolutely certain.
If we go to the top of the page, and this appears on
every page, "Commercial in Confidence and Without
Prejudice". Why was it marked up "Without Prejudice"?
Someone asked me to put that there. I've no idea what
that actually means. I believe it's some sort of legal
thing but I don't understand what it means.
Who asked you to put that there?
I can't remember now.
Were you told that this was being prepared in the
contemplation of any litigation?
No, I don't believe so.
Were you told that this was prepared for the purposes of
obtaining legal advice?
I don't believe so.
Did anyone mention to you before, or as you were
preparing the document, that it was to be used or might
be used in litigation that was reasonably in
97
that are built into Horizon to ensure data integrity,
including a description of several failure scenarios,
and descriptions as to how those measures apply in each
case.
"[The] document only covers Horizon. It does not
cover [Horizon Online]."
Was that dictated to you or was that you writing?
That was me.
So it describes measures that are built into Horizon
Online to ensure data integrity?
I think you mean Legacy Horizon.
Sorry?
I said I think you mean Legacy Horizon.
Did I say Horizon Online?
Yes.
I'm so sorry, Legacy Horizon.
Yes.
To ensure data integrity; is that right?
Then if we go over the page, please, there is, under
the heading, "Horizon Data Integrity" a description in
summary terms of data processing within Horizon; is that
fair?
Yes.
Then, if we scroll down, please, after that summary, you
set out scenarios --
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contemplation or for the purposes of obtaining legal
advice?
Not that I'm aware of.
Can we go forward to page 5, please. We can see the
purpose of the document, it is:
"... submitted to the Post Office for information
purposes only and without prejudice."
You put that?
Again, I don't understand what "without prejudice" means
So someone must have said I needed to add that in but
I can't remember who.
Would that be a lawyer?
I don't know.
"In the event that the Post Office requires information
in support of a legal case, Fujitsu will issue a formal
statement."
Again, you wrote that?
And I think someone must have told me that I needed to
include that in the document.
Do you know why: that this report couldn't be relied on
in support of a legal case; if there was a legal case,
then Fujitsu would issue a formal statement?
No, I'm not aware of why I was asked to include that in
the document.
"This document is a technical description of measures
98
Yes.
-- and you say:
"It should be noted that these scenarios are all to
do with equipment failures and these will always be
visible to Fujitsu through event logs which are
retained."
Yes.
The possible failure scenarios that you then discuss in
the report deal, essentially, would you agree, with
equipment failures —
Yes.
-- and not software failures?
Yes.
So, for example, the Callendar Square bug is not
mentioned, is it?
No, it isn't.
Nor the remming out bug?
No.
Would you agree that, if this document was taken as
providing a picture of Horizon's good health, it only
gave a partial picture because it only dealt with
equipment failure?
That was only what I was actually asked to produce
a report on, so the scope was given to me and I believe
those scenarios were actually provided to me by Post
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Office.
Would you agree that a full and complete explanation of
Horizon data integrity would not only focus on equipment
failures?
I can see that now but, as I say, that wasn't the scope
that I was asked to produce this document for.
Did you say, "Well, hold on, if I'm writing a report
about Horizon data integrity, it should be more than
about pieces of equipment that may fail"?
My -- I'd understood that that was what the report was
required to cover.
Do you know why a narrow focus was selected?
No, I don't.
Did you get any sense that a narrow focus was selected
to provide a commercially acceptable reality that
Fujitsu could present to the Post Office, which only
discussed equipment issues, without referring to bugs,
which, if mentioned officially in a report in a long
series, might lead to a reappraisal of the contract
between the parties?
That hadn't occurred to me at the time. As I say, I was
just asked to produce a document with this particular
focus, which is what I did.
The information in the report, therefore, didn't reflect
a full picture of what you knew of concerns arising over
104
"2. It was resilient in terms of being able to
continue customer service and hold data in a queue in
the event of incidents, and
"3. It had strong back up and integrity features
with data backed up in branch and centrally.
"This provided a strong audit trail. Further
narrative from Fujitsu is included at Appendix 3."
Then if we go to Appendix 3, which is page 17, can
we there see -- it is printed in a different way than
the document we just looked at -- but your Horizon data
integrity report for Legacy Horizon.
Yes.
Is the entirety of the report set out there by Mr Ismay
as his Appendix 3?
I've not checked that it is entirety but I'm happy to
believe that it is.
How did your report come to be included in the Ismay
Report?
I've no idea.
Were you asked for your consent or permission for it to
be reused in this way?
No.
To your knowledge, was anyone in Fujitsu asked if it
could be repurposed in this way?
I don't know.
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data integrity in Horizon. It's only about equipment
failures?
Yes.
Can we go to POL00088935. Thank you. If we just look
at the top of the page, this is the Ismay Report of
2 August 2010. You're not on the distribution list --
No.
-- because it was a Post Office document?
Yeah.
When did you first see it?
I think I first saw it as part of the preparation for
this Inquiry.
Can we look, please, at page 7, under the heading
"Horizon":
"Horizon was developed as an Electronic Point of
Sale to replace archaic paper based accounting
processes. It utilised hardware in branches which had
strong security features and interfaces to a central
data centre with high security. Data was replicated
between units in the branch and once it reached the data
centres it was replicated between those.
"This gave three strengths which are important in
terms of allegations being made:
"1, Horizon infrastructure was robust from
a security and access perspective
102
Were you consulted on any of the wider contents of the
Ismay Report?
No.
To your knowledge, was anyone else in Fujitsu consulted
on the wider content of the Ismay Report to —-
Not to my knowledge, no.
When he gave evidence to the Inquiry, Mr Ismay said that
he relied on your Legacy Horizon data integrity report
in drafting his own report and he accepted that, at the
time, he did not think that the Legacy Horizon data
integrity report had any limitations at all, and he
accepted that that was a failing. To your knowledge,
was anyone in Fujitsu, including yourself, involved in
any way in the use or the misuse of your report in the
Ismay Report?
Not to my knowledge, no.
Thank you. Can we look, please, at FUJ00156064 and look
at page 3, please -- thank you, if we scroll up,
please -- from Suzie Kirkham; do you remember who she
was?
She was an account manager or something -- I think that
was the title that's given on the report. I have
a vague recollection of her but I didn't have very much
to do with her. I think my main interaction with her
was to do with this report.
104
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Who was Gavin Bounds?
He was also an account manager at some stage. How they
related to each other I just don't remember, I'm afraid,
but they were both sort of fairly high up compared with
me.
She says:
"Gavin
"I have detailed below a brief summary of the
subpostmaster claim that Horizon fails to maintain the
integrity of branch accounts if the branch experiences
technical issues.
"Horizon has been running for around 10 years,
during which time Post Office has had to handle a number
of legal cases surrounding system integrity, mostly from
apparently disgruntled or fraudulent subpostmasters.
Fujitsu has twice appeared in court to support Post
Office. Only once has Post Office conceded its case,
and this was at a time when the audit trails were too
short to provide sufficient evidence to refute
a subpostmaster’s claim.
"Recently a number of subpostmasters are again
querying the data integrity of Horizon and are claiming
that they are owed money by the Post Office due to
inaccurate branch accounts. These subpostmasters are
talking to the press and are trying to gain some
105
if required."
Were you involved in any of those first two
paragraphs?
I don't believe so.
Friday, the 25th, the conference call was completed;
Fujitsu's attendees, are set out, not including you?
Correct.
Then over the page:
"During the conference call [the Post Office]
requested from Fujitsu a short paper to describe how
Horizon maintains the integrity of branch accounts when
certain issues affect the branch, eg blue screen,
hardware failure. Report requested to be given to Dave
‘Smith by 2 October."
That's, in fact, the date of your report?
Correct.
"Gareth Jenkins ... spent the best part of one day
completing the report.”
Is that right: you spent a day writing it?
It was something like that because there was fairly
short timescales for actually putting that together,
yes.
"The finished report was passed to Amanda Craib
(Commercial -- at David Roberts’ request) before being
sent to Dave Smith. Report was sent to Dave Smith on
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momentum to support their case -- it is even rumoured
that the BBC is considering a Watchdog programme on the
subject. Post Office is trying to head off this
possible escalation of interest by preparing a stock of
simple responses to possible questions from the media or
interest groups. I have summarised below the timeline
that details when Post Office asked Fujitsu for
assistance in compiling this information.
"The initial request from Post Office (Dave Smith
and David Gray -- POL) was made on 24 September asking
us to join a conference call ... hosted by Dave Smith
where Dave would outline his understanding of the
situation and outline his response. Fujitsu would only
comment if he made any factual errors on how Horizon
works.
I [that's Suzie] spoke to Mike Wood, Dave Roberts
and our Press Office as soon as the request was made.
[Fujitsu] Press Office confirmed with [Post Office]
Press Office that the journalist would not be present at
this conference call and that it was only internal [Post
Office] attendees. They also confirmed that they did
not want [Fujitsu] responding to any questions from the
press or external organisations. This was a Post Office
issue as the solution has been formally handed over to
Post Office. They only need Fujitsu for ‘expert’ advice
106
Friday, 2 October late morning just prior to a second
conference call.
"Friday, 2 October -- second conference call -- Dave
thanked Fujitsu for the document -- no further actions
"[She] spoke to Andy McLean on 5 October -- he
didn't expect any further activity for at least a couple
of weeks.
"[She] spoke with Dave Smith on 3 December and he
mentioned that the data integrity issue had reappeared.
It has been taken up by a Welsh MP who also happens to.
be a barrister. He is threatening to bring an Early Day
Motion in the House. Dave is meeting him in Parliament
‘on 10 December but at this stage [he] didn't feel he
needed any [assistance]. However, he was alerting us to
the fact that this has reappeared.
our body of evidence is mature, so we're well
placed to help Post Office today. But when ‘Horizon
Online’ is installed in 2010, much of our existing
material will become irrelevant’, et cetera.
You were copied in on this, weren't you?
Iwas.
So I think you knew due that the data integrity issue
had not gone away as a result of your paper and there
was a possibility that it was going to be raised with
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an MP in the future?
I must have read that in the report. I can't remember
that now but, yes, I accept that I was copied on this
ale.
Yes, and then if we scroll up, please -- and up the
page, just stop there -- some internal emails not
including you. Then scroll up, please, keep going, and
keep going, and then stop there. Ann Sinclair forwards
that chain to Gavin Bounds. What did Ann Sinclair do?
I've no idea. I've not come across the name before.
Ann says:
"... following discussions with our press folks and
Suzie on Monday [night] we have agreed that:
"We need to downplay [the issue] as much as,
possible, we don't want to guilty drawn into the debate
as we are only a supplier.
"There is a document that addresses all the
technical questions that was produced for [Post Office]
for a meeting with MPs last week ..."
Is it right that there was a list of hardware issues
that was produced that you were required to address?
That is my understanding and that is, effectively, what
section 3 of the document was all about. Someone gave
me that list.
So that reference there, there is a document that
109
I believe that someone actually gave me a list of the
‘ones to cover and those were the ones that I covered in
section 3.
So it was sought for a limited purpose, its contents
fulfil that limited purpose and it shouldn't be used for
any other purpose?
That was the situation at the time, yes.
Can we turn to the data integrity report for Horizon
Online, please. FUJ00080534. We see the title again,
"Horizon Online Data Integrity". We see again you're
the author?
Yes.
If we go to the foot of the page, we can see the date of
this version, 25 November 2011, version 4.
Yes.
If we go over the page, please, and, again, past the
index, sorry, to "Document History", we can see that the
first draft was created on 18 January that year and then
if we scroll down -- I'm not going to go through the
summary of changes -- version 4, which I think is the
‘one approved for distribution is 25 November 2011.
Yes.
Did the purpose of the report change in those ten months
or so?
Yes, it got -- one of the versions, I can't remember
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addresses all the technical questions. That's
a reference back to your report of 2 October?
I'm assuming so but I don't know for a definite fact.
I mean, it says that it was "produced for [Post Office]
for a meeting with MPs last week"; do you think that was
a different document?
It could be. As I say, I produced on it 2 October and
I think now we're in December, so it could be something
different. I don't know.
Did you prepare a second or supplemental document --
No.
-- for the purposes of a meeting with MPs?
No.
Thank you. That can come down.
In short, then, you say that your paper was not
a report about or a survey of all issues with Legacy
Horizon.
Correct.
Again, did anyone explain to you why, if questions were
being raised about the integrity of data produced by
Horizon, you were not asked to produce a report, which
was a survey of all of the issues which had affected
Legacy Horizon?
I was asked to produce a report on the fairly narrow
basis of those hardware type issues and, as I say,
110
which of the versions, was -- there was talk about
having a formal review of the integrity of the audit
trail of Horizon Online by an external firm of
consultants.
KPMG?
KPMG, and the report was amended to actually effectively
be a scoping document for what they were being asked to
provide.
What was its original purpose?
I think its original purpose was to be a companion
document with a similar sort of scope to the Legacy
Horizon version.
Why did you need a companion document about hardware
failures in relation to Horizon Online?
Well, it wasn't just the hardware failures; it was also
talking about the way that the audit trail worked and so
this was talking about how the audit trail worked on
Horizon Online because that was very different from
Legacy Horizon.
Why did you need a companion document about how the
audit trail worked?
1.
Why did Fujitsu need one?
I can't remember exactly why I was asked to write this
at the time now.
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I was about to ask: who asked you to write it and why?
I can't remember, I'm sorry. There maybe emails about
it but I've not seen them as part of the Inquiry.
Can we go to page 7, please, terms of reference in bold
at the top:
"Fujitsu would like to instigate an independent
audit of the [Horizon Online] environment currently
delivered to Post Office to provide confidence that the
solution has intrinsic security controls commensurate
with the requirement for legal admissibility. This
would enable a legal review of contract compliance.”
Just trying to decode what that says, is that saying
that this report will show that Horizon Online has
intrinsic security commensurate with the requirement for
legal admissibility or the report that's going to be
prepared by KPMG.
The latter. So this was effectively the terms of
reference for KPMG to produce their report, which never
actually happened.
Whilst you've said that, why didn't it happen, to your
knowledge?
I don't know why it didn’t happen. I think I've
understood since then that the Second Sight review
subsumed it but I think the scope of the Second Sight
review was actually very different from what this was
113,
compliance with its contract obligations and in order to
enable that, would like to undertake an independent
assessment to demonstrate the adequacy of the security
controls that have been designed into the system to
provide assurance in the robustness of the audit of the
transactional data that may be used as evidence in
court."
So, just stopping there, did you understand that the
review to be undertaken by the third party, I'm going to
call them KPMG --
Yeah.
-- to be undertaken by KPMG, had as its focus assurance
in the robustness of data used as evidence in court?
That is what I understood was the purpose of that. So
there were a number of people involved in the
discussions with KPMG, and this document was just
something that I was the author of but a lot of the
input was from the team who were working on the
discussions with KPMG. I remember going to two or three
briefing meetings with KPMG with other people within
Fujitsu as well.
Would you agree that the purpose of providing assurance
in the robustness of the audit of transactional data
that that may be used as evidence in court, is quite
a broad Statement of Purpose?
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intended to be.
Who gave you to understand that the Second Sight piece
of work was the surrogate for a Fujitsu commissioned
review that would provide confidence that Horizon Online
had security controls commensurate with the requirement
for legal admissibility?
It probably -- I'm not sure if I was told explicitly, it
could well be an assumption on my part, that this all
seemed to go away at the same time that the Second Sight
review started up.
What about the suggestion that this will enable a legal
review of contract compliance? To your understanding,
did Fujitsu engage in that process at all, a legal
review of contract compliance?
My understanding is that that was what KPMG were being
asked to do but that never happened.
Did you get told at the time that neither of those
things happened because of Second Sight?
I don't think I was told that explicitly but I can't
remember.
All you knew is that they didn't happen?
Correct.
At paragraph 1.1 "Objective":
"Now that Horizon Online has been operational for
12 months, Fujitsu is undertaking a legal review of its
114
Yes, I've probably not really thought that through
particularly but, as I say, those are not necessarily my
words but I accept that they're included in my document.
"The purpose of this document [ie the one you were
writing, to continue] is to define the terms of
reference for the project and to provide a technical
description of measures that are built into Horizon
Online to ensure data integrity.”
Those are your words; is that right?
Those are my words, yes.
Would you agree that that purpose, as described, is
a broad Statement of Purpose?
Itis a fairly broad statement, yes.
Would you agree that the existence of bugs, errors and
defects in Horizon may affect data integrity?
I don't think -- at the time, I wasn't aware of
‘outstanding bugs, errors and defects in Horizon Online.
That's a different issue.
Right.
Would you accept that the existence of bugs, errors and
defects in Horizon Online may affect data integrity?
I think what we were trying to show here was the
integrity of the audit trail, therefore, if there were
any bugs, errors or defects in the -- in how the system
operated, then it could all go back to looking at the
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integrity of the audit trail from which any reports
produced by the system could then be traced back.
I will try a third time: would you agree that the
existence of bugs, errors and defects in Horizon Online
may affect data integrity?
I don't think they did affect the data integrity in
terms of the integrity of the audit trail, which was the
focus of this document.
Is that why the document does not address whether or not
there are bugs, errors or defects in Horizon Online?
Yes, because it was thought that by actually showing the
integrity of the audit trail, then that bypassed the
need to consider bugs, errors and defects in the other
parts of the system because everything goes back to the
data that's in the audit trail.
Was explicit thought and consideration given to that,
that, if we focus on the audit trail, we can bypass the
existence of bugs, errors and defects?
"Bypass" might be a bad choice of words. The point was
that, having the limited focus of showing that the audit
trail had integrity was something that was practical to
actually be able to prove, as was -- which is what we
were effectively asking KPMG to do.
Is that reflected on page 9, if we go forwards, please,
under "Purpose"? In the last paragraph there under
117
the system was supposed to work --
So that they could then prove that it did.
It was down to them to prove or disprove, presumably,
whether, in fact, it was fit for purpose?
Correct.
But that never happened?
Correct.
So, again, nobody should take your report as being the
description of Horizon Online's overall integrity?
It was showing our belief of how the audit trail was
a way of showing that the system had integrity, yes.
How it's supposed to work, in theory?
Yes.
So the scope of the report was limited by those
commissioning it, correct?
Yes, I guess so, yeah.
In the light of your knowledge of the system by this
time -- it's two years or so in, so November 2011 --
Yes.
-- and the bugs that had arisen in particular in the
course of development, did you ever question the limited
scope of the commission?
No, because I felt that, once the pilot -- I accept the
fact that there were some issues during the pilot phase
of Horizon Online but, once the pilot was over,
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"Purpose":
"The scope of this paper is restricted to showing
the integrity of the audit trail and that it accurately
reflects the transactions entered at the counter."
Yes, that's effectively what I was trying to say before.
You tell us in your witness statement, no need to turn
it up it's paragraphs 164 and 165, that:
"My report was intended to be included in briefing
materials for KPMG so that they had a high-level
technical overview as to how data was recorded in the
audit trail."
Is that right?
Yes.
This report didn't consider when and how the audit
information was interrogated, did it?
No.
It provided only a description of security controls?
I'm sorry, I'm not sure what you mean by "security
controls".
Well, were you asked to conduct any research into the
operation of the controls that are mentioned in the
report, and whether they were in fact functioning
adequately on the ground?
This is what KPMG were being asked to look into.
Ise. So you didn't do that. You were describing how
118
I believed that the audit trail of Horizon Online did
indeed the integrity that I was saying should be proved
as part of this report.
But you had no evidence for that because that was what
KPMG were going to find out?
I had no independent evidence but we had found
empirically that it had the right -- that it had the
information there -- there for doing so. That we hadn't
had -- we hadn't found any outstanding problems in the
way that the audit trail operated and the audit trail
was seen to be accurately recording what had actually
happened within the branches, and we had no evidence to
the contrary. So, no, we hadn't proved it positively,
but we had nothing to actually say that it wasn't
correct.
Why was it necessary for KPMG to investigate at all,
then?
I think the senior management within Fujitsu at the time
felt that it would be helpful to be able to show -- have
an independent proof, not just an internal assessment of
what was happening.
If we go back to page 7, please, the top line of the
terms of reference includes the fact that the
independent report would seek to provide confidence that
Horizon Online has intrinsic security controls
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commensurate with the requirement for legal
admissibility.
By this stage, you were aware that the data being
produced by Horizon, both in fact Legacy Horizon and
Horizon Online, was being used to support criminal
prosecutions?
Yes.
You were, I suspect, in any event, aware that the data
being produced by both systems formed the core
accounting information for any subpostmaster's
business --
Yes.
-- and, indeed, the business of the Post Office itself?
Yes.
So integrity of the data was absolutely critical, for
all three reasons, or all three purposes?
Yes.
From their titles, these reports address Horizon
integrity in the Legacy system and Horizon Online data
integrity, but did not address everything that you knew
about Horizon data integrity either in the online system
or on -- in Legacy, did they?
I think they were trying to show that the audit
information did indeed have integrity and I believed at
the time and I still believe now that it does.
121
before it?
Yes, I think so.
An inadequate substitute would be to produce to a court
your two reports?
I believe that that was covering the integrity of the
audit trail and it was based on information in the audit
trail that was the data that was being presented to the
courts.
So you disagree with my suggestion. You think that
an adequate and proper substitute was to present only
your limited, constrained and narrow reports to a court,
as showing Horizon integrity?
That was how I understood things at the time.
And now?
I think ~ I think they still show the integrity of the
overall audit trail, which is the data that's being
presented to the courts. But I accept now that I don't
understand all the legal niceties, which -- and
I clearly didn't at the time either. But I wasn't aware
of my ignorance then.
Can we, on that note, turn to the second part of my
questions to you, which concerns some of the case
studies --
Okay.
-- and can we start with the case brought against Hughie
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For example, in relation to Legacy Horizon, they didn't
address faults in development or in the operation of the
Riposte system?
No, but I didn't think that was relevant in terms of the
integrity of the actual audit trail, which is what was
the basic subject that it was about.
They didn't address any detail of the Riposte lock
problem, for example?
It doesn't do that. That wasn't the scope of the
document at the time.
It didn't address all of the circumstances in which
a discrepancy might result and require reconciliation?
I'm not quite sure what you mean by that.
Well, the raising of the issue by a subpostmaster,
reporting it, the issue of a transaction correction by
Fujitsu and the Post Office, it didn't address all of
that process?
I didn't see that as being the purpose of the documents.
The purposes of the documents were quite narrow, as
we've already discussed.
If the work that KPMG was supposed to undertake was to
be presented to a court, would you agree that the
purpose would have been to satisfy the court as to both
the integrity and reliability of the Horizon system and
therefore the data that was being produced in the case
122
Thomas, who ran a Post Office in Wales. You explain in
a witness statement to us your involvement in the case
was some months after the Post Office had concluded its
investigation of Mr Thomas and, in fact, he'd been
charged. Correct?
That is what I now understand, yes. I didn't at the
time, necessarily.
Can we start by tracing your earliest involvement in the
case, that I can see, by looking at FUJ00122203. If we
look at page 6, please. I think we can see Mr Ward, at
12.43 on 10 March 2006 emailing a generic Fujitsu email
address; can you see that? It just says, "To Fujitsu”
on the right?
Yes, I see that. I've no idea what email address that
would have gone to.
No. The subject is "ARQs, statement request and
assistance". Then if we scroll down, please. He says:
"... sorry for the length of this email ..."
I'm going to ignore the next two paragraphs, the
‘ones starting "Both of the above" and "Brian". Then if
we scroll down over the page, the third main paragraph,
the one starting "On a separate matter"?
Yes, I see that.
He says:
"On a separate matter, I also require a witness.
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statement in respect of the following ARQs ..."
For some reason, they've been redacted. We know the
numbers --
Yeah.
-- and they appear in other emails:
"... all of which relate to [Mr Thomas' Post
Office]. We need the usual (leave out paragraphs H(b)
and J, but do need para K (calll logs) covering
an analysis over the period 01/11/04 to 30/11/05.
Penny -- you may recall this one which relates to nil
transactions, my previous emails ... refer. Can you add
an extra paragraph in your statement explaining how
online banking transactions are processed and the data
downloaded and how nil transactions can occur."
I think that's all that there is about Mr Thomas’
sub post office. Okay?
Yes.
So a request to either Penny Thomas or Neneh Lowther for
a request for a witness statement that addresses some
ARQs about Mr Thomas' Post Office and explains how nil
transactions can occur.
Yes.
Can we go to FUJ00152582, page 2, please, and scroll
down a little bit. Mr Pinder emails you on 21 March, so
that's 11 days after the email we've just looked at --
125
Yes, I see that.
I don't suppose you remember what Mr Pinder told you of
Post Office's requests?
No, I mean, clearly I can understand what he's saying in
the email but what he actually said on the phone I've no
idea, I'm afraid.
Did you have anything explained to you, by Mr Pinder or
otherwise, as to what was expected of you when creating
a witness statement or other document in response to
this request?
I can't remember. What I believe, from looking at the
documentation, I was asked to do was purely look at zero
value banking transactions and see why they came up as
being zero value banking transactions and that is what
I actually provided a report about.
You'll see that this seems to ask you to provide
a witness statement about those things, doesn't it?
Yes, it does, and I think what I actually did was
provided a report to say "Is this what you want the
scope to be?"
In fact, I think we're going to see that you reply by
email, not providing a witness statement, providing
an answer?
That is my recollection from the emails I've seen
lately, yes.
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Yes.
-- and says:
"Gareth
"Re Tel-con
"As discussed, please see extract from a recent
email below in italics from Graham Ward ... regarding
providing a statement about nil transactions and online
banking. If you are able to put something together for
us I would be very grateful. If you send it back I will
arrange for Neneh or Penny to write a statement for your
signature.”
Then the part of the email we've just read out,
which does include the three ARQ numbers, is set out.
The last part of which is in italics.
Yes.
"Can you add an extra paragraph in your statement
explaining how online banking transactions are processed
and the data downloaded and the nil transactions can
occur."
So you are asked to "put something together for us."
Yes.
Addressing nil transactions and online banking?
Yes.
His email seems to refer to a conversation with you. It
says, "Re Tel-con', at the top?
126
So he's asking you for a witness statement, addressing
those two things. If we go up, please, to page 1, thank
you, same day, 21 March, you reply:
“I've had a look at the ARQs and I think there is
sufficient info there to explain in most cases why there
are zero value transactions. I suggest the following as
a brief explanation:
"There are three main reasons why a zero value
transaction may be generated as part of the banking
system:
"1 the transaction has no financial effect ...
"2. The transaction has been declined by the Bank
"3. There has been some sort of System Failure."
Then you explain response codes. The third
explanation is that a response code with a value greater
than 10 implies some sort of system failure. You say:
"Does that supply you with enough detail?
Identifying exactly why a given response code was
generated in each case and the exact circumstances under
which each one can be generated is much harder, but
I suspect that is unnecessary ..."
Then scroll down, you give some examples of some
response codes. So you respond not by providing
a witness statement: you say, "Here is a brief
explanation"?
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Yes.
Were you clearing with Mr Pinder what you said in
advance of committing it to a witness statement?
I was just providing the information. I don't think at
that stage I even knew what a witness statement was,
though I -- oh, I might have --
I think you'd already provide a draft --
Yes, I'm trying to think but I don't think I'd actually
drafted one myself. It had been drafted for me by
Mr Pinder's team, in terms of getting the formatting
sorted out and --
That was in another case, in the Teja case?
That's the one, yes.
So you did know what a witness statement was by then?
Yes, I must have done.
Just scroll down to the top of the page and, sorry, just
scroll down to the email. You say:
"I suggest the following as a brief explanation ...”
Again, were you clearing with Mr Pinder what to say
in a witness statement before you made a witness
statement?
I'm not sure if it -- I think it was a case of: this is
the basic information, how do you want it presented?
I don't think I was sort of clearing -- I was happy that
technically that was a reasonable description of what
129
I'm not sure that we can actually talk about the term
“usual”, but this was, it was the first case that
I remember being involved in but, clearly, the case of
Teja has been drawn to my attention as part of the
Inquiry, which I had no recollection of whatsoever.
But -- so, in that way, this was the second time that
I'd been involved in doing anything with prosecution
support, so it was a bit difficult to find what is
usual.
So too early to say what is usual?
Yes.
Can we go back to FUJ00122203, which was the chain that
we were in before, and go to page 4, please. We can see
that at 1.01, Neneh Lowther sends Graham Ward a draft
witness statement "for the above re 'Nil Transactions”,
and asks him, Mr Ward, whether it meets his
requirements. Now, you tell us in your witness
statement -- no need to turn it up, it's paragraph 294
at page 98 of your third witness statement -- that you
cannot find a copy of the witness statement that was
attached to this email, and you're in good company: nor
can we. But that may not matter for the moment.
Can we go up to page 3, please. Thank you. We can
see that Mr Ward replies to Ms Lowther and Mr Pinder and
says, in relation to that witness statement that was
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was happening and what the circumstances were, and that
was the basis of the information that I felt that he
needed for whatever witness statement was to be
produced.
By somebody else?
For someone else to actually produce the statement,
though, it may be one that I would need to own and sign
up to at some point.
What do you mean, you might need to own and sign up to
a witness statement?
That it would -- that it would need to be my witness
statement but, basically, at this stage, I was trying to
make sure that we had the scope correct.
So you were clearing the scope for a proposed witness
statement by you?
Yes, okay. Yeah.
If we scroll up to the top of the page. He's grateful
for your speedy response, he will ask Neneh to put if it
into statement form today for your perusal and signature
‘on Thursday if that's okay.
Can we go back then, please, to -- sorry, before we
do, was that a usual or an unusual approach in your
dealings with Fujitsu's litigation or Prosecution
Support Team, that you would draft your own witness
statements or somebody else would draft them for you?
130
sent:
"The layout presumably is unfinished, paragraph,
spacings, etc.
“As per my earlier email, and more importantly the
3 spreadsheets sent with ARQ data need to be produced as
individual exhibits (GlJ/1, 2 and 3) and each column
header must be explained as you do in your usual
statements ...
“Also the line which begins at the foot of [the]
page, "[Response Code] with a value greater than 10..."
appears unfinished?"
This is perhaps, for our purposes, the most
important part:
'm concerned with the words ‘system failure’
which is also in an earlier line ... 'There has been
some sort of a system failure’ -- What does this mean
exactly and is there any indication of a system failure
at this office during the period in question?"
Then if we go further up to page 3 we see that later
that day, at just after 3.00, Ms Lowther forwards that
to you; can you see that?
Yes, I see that.
“Hi, Gareth,
"Please see [below] from Graham ...
"... ignore the ... bit about exhibits. I will
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print out the exhibits and update your statement with
this.
“I understand that you have copies of the
spreadsheets ...
"Please could you look at his second paragraph
[that's the bit which explained concern about the
mention of system failures] and advise with your
comments again.”
She sent your draft statement back and I think the
same comment as earlier applies, that there isn't a copy
of that available that you can find nor we can find.
Can we go up, please, to page 2, and keep going to
see the beginning part of Mr Jenkins’ email. You reply
still later that day, 5.40:
"Neneh,
"I'm not quite sure what his problem is with what
I've said.
"Basically, any value of Response Code that is
greater than 10 does imply some end-to-end system
failure. The actual value makes it clearer what exactly
the failure is and where it has been detected.
“In the example there are two such codes ..."
You'll see what you say about those. You say:
"How do you want to play this? Do you want to add
in specific text to the witness statement to cover these
133
"In particular, I don't feel I can include the last
two paragraphs, which may make the statement useless."
Can we look at the attachment to this email.
FUJ00122204. If we just scroll down, we can see it, it
is dated 23 March. First paragraph: is that something
you had drafted in the original or had been drafted for
you?
I'm not 100 per cent sure. I suspect that this was what
Neneh had produced in the earlier emails in the chain
and that bit of red that you see there is what I've
added in and this latest version is how I'm interpreting
it but I can't be 100 per cent certain.
More generally, before we come to the red parts, if we
look at the black text, which is indented underneath
that first paragraph, we can see, effectively, that your
earlier email has been cut into this witness statement,
hasn't it?
Yes.
Verbatim?
Yes, and perhaps this is what Graham Ward was referring
to, in terms of formatting problems. II'm not sure.
To address the email that you'd received, you've added
in the words underlined, “Such failures are normal
occurrences", is that right?
I thought that may be sufficient to address the fact
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two codes or persuade [Post Office] that the generic
statement is okay (perhaps with some clearer words)?"
So what did you mean by "How do you want to play"
it?
What exactly was she asking me to do? Now I had this
information, what does she want to do next? And I was
giving her a couple of options as to what we could do
moving forward.
Can we go to page 1, please, and scroll down to her
reply, the next day:
"Gareth,
"I have updated your [witness statement] with all
the column headings you explained to me earlier.
"I have not included your response below as I am not
quite sure where to fit it in.
"Can you help out with this.
"... Graham Ward is thinking that ‘system failures’
are drastic events. Could you please explain a little
further on this like you said they are normal system
‘occurrences.
“Please sent back to me when you've finished so
I can send to [Graham Ward] if possible."
Then, on this chain, the last email -- scroll up --
you attach a witness statement and say you've annotated
it with revisions:
134
that I could clearly see that people were concerned
about the use of the term "system failure", and I'm sure
we're going to discuss that further this afternoon but
I felt as a first cut, let's just say, well, they are
normal occurrences.
What do you mean, "let's say as a first cut"?
Well, by "system failure" what this was talking about
was an end-to-end failure within the overall banking
system and so I thought that, just by saying this was
anormal occurrence, then that would be something that
would be sufficient to not make it considered emotive,
and I can clearly see that Graham Ward was concerned
about having the term "system failure” in the witness
statement because that could give the wrong impression
because that could -- I now understand that he was
thinking that meant that was a failure in Horizon. That
is not what I meant by a system failure in this
particular case.
So you thought that your original language had sort of
scared the horses and this was a way of calming --
Calming it town a bit, yes.
Moving on, please, if we scroll on. You've added in, in
red, at the bottom there:
"The actual value provides further information as to
the nature of the failure within the overall system."
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Again, as a way of trying to calm things down and make
it less emotive.
I'm going to skip over, if we go to page 2, the other
amendments, and if we scroll through page 2 and go to
page 3 and scroll down. Thank you. You remember in
your email you said that you didn't feel that you could
include the last two paragraphs. Are they the
paragraphs beginning "There is no reason to believe",
and "Any records to which I refer"?
Yes.
You said that you don't feel that you could include them
and that might make the statement useless; is that
right --
Yes.
-- in your email? You say, by way of comment,
underneath:
“lam not sure that the yellow bit is true. Can
this be deleted? All I've done is interpret the data in
spreadsheets that you've emailed to me."
And, in particular, I was referring to the second of
those two paragraphs, which was saying that I'd actually
got the records out of the audit system, because
I hadn't.
Does the second paragraph actually say that you had got
the records out of the audit system? I don't think it
137
raised by Mr Thomas?
Correct.
Did you ask for any?
I didn't think I needed to because I was being asked
a very simple question: what do these zero value
transactions mean?
So the answer is you didn't ask for any guidance because
you didn't think it was necessary?
Correct.
You tell us in your witness statement -- it's
paragraph 316 of your third witness statement -- that
you do not have a clear memory of anyone mention anyone
the word "expert" at any point and that you understood
that you were giving evidence about Horizon because of
your knowledge and experience of it. It was never
explained to you that there might be a difference
between giving you giving factual evidence about Horizon
and expert evidence, in this context?
Correct.
This witness statement and the drafts of it do not
contain any expert declaration, do they?
No.
Why do you think you were chosen to prepare a witness
statement regarding nil transactions in Mr Thomas’
branch?
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does?
It doesn't actually say that but it does imply that
I had actually got hold of the information and I hadn't
got hold of the information; I had just been sent
a spreadsheet by Neneh to say look to see what it says
in this spreadsheet, and I had no reason -- no
information as to where that spreadsheet had come from.
I want to concentrate on the first paragraph instead,
please. That first paragraph in the second sentence
says:
"To the best of my knowledge and belief at all
material times the computer was operating, or if not,
any respect in which it was not operating properly, or
was out of operation was not such as to affect the
information held on it."
You said that you weren't sure that was true and you
asked for it to be deleted, correct?
Yes.
Now, in terms of the guidance that you'd received about
writing this statement, you tell us in your witness
statement -- no need to turn it up, it's paragraph 313
of your third witness statement -- that you do not
recall receiving any briefing from the Post Office or
anyone else setting out the factual history of the case
or summarising the prosecution evidence, or the issues
138
Because I understood the way that nil transactions could
be generated. I'd been involved in the design of the
banking interfaces, so I actually understood how you
could get zero value banking transactions in the
circumstances and how to interpret them in the ARQ data.
Do you know whether anyone else within Fujitsu was
considered as a provider of this statement?
I don't know that.
Did you encounter any challenges in preparing the
statement requested by Graham Ward from the Post Office,
without the factual history of Mr Thomas' case, or even
a summary of the prosecution case?
I believed that I was being asked a very simple
question: why are there zero value transactions. And
that is all I was trying to address here.
When you received Mr Ward's request via Mr Pinder and
Ms Lowther, was your understanding that you were
providing a factual analysis of Horizon or giving any
opinion evidence?
I think that -- I saw that as being factual information.
Did you understand the legal significance and full
implications of preparing a witness statement for the
purposes of criminal proceedings against the
subpostmaster in a prosecution brought by the Post
Office?
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No.
Did you ask for guidance?
No, I thought I was just doing a simple bit of analysis
identifying the reason why there was zero value
transactions, and I thought that was a relatively
straightforward bit of factual information that I could
provide.
Did you have adequate time to prepare this witness
statement?
I can't remember how much time I had. I clearly had
looked at the data that I had been presented with and
had had time to analyse all the zero value transactions
in the data that I'd been provided with. I can't
remember now how much data that was.
Can we try and display, before the break, two documents
side by side. The one that's on the screen at the
moment, please, and the second document, your third
witness statement, at page 33. Perfect. You say in
your witness statement at paragraph 102:
"I am aware that there is a question in the Inquiry
as to what the two ‘boilerplate’ or ‘standard’
paragraphs that appear at the very end of the standard
Fujitsu witness statement which exhibits the ARQ
spreadsheets actually meant. These two paragraphs are
usually read as follows ..."
141
Horizon system. They do not suggest the standard
Fujitsu witness statement would address the integrity of
the overall Horizon system at a given branch. Indeed,
as I have already noted, paragraph L of this standard
witness statement referred to the integrity of the audit
data exhibited to the witness statement in terms of its
origination, storage and retrieval.
"105. The individuals who signed this standard
witness statement (such as Penny and Neneh) could not
have given an opinion about the integrity of the Horizon
system, whether at the particular branch or generally.
They did not have the technical expertise and would not
have been qualified to do this. They could comment on
the integrity of the ARQ extraction process that they
had personally undertaken.
"106. All of this explains why it makes little
sense to me that the standard closing paragraphs in the
Fujitsu witness statement could have been intended to
have some broader meaning about the integrity of
Horizon. This witness statement was only concerned with
the production of time limited ARQ data and did not (for
example) set out an analysis of the data. I think there
is a clear distinction between a statement that the
Horizon system was working (or a statement to its
overall health) at a given branch during a specific
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You set them out and they broadly match the
paragraphs on the right-hand side, can you see?
Yes, yeah.
Moving on to 103:
"As I understand it, some witnesses to the Inquiry
have suggested that these paragraphs were supposed to
show (or were [intended] to mean) that Horizon was
working properly at a given branch or even that Horizon
was working properly across the whole estate. That is
not what I thought these paragraphs were intended to
mean.
"As I have set out above [paragraph 104], Fujitsu's
operational manuals concerning prosecution support
appear to deal with the integrity of audit data, rather
than the integrity of the Horizon system."
Just stopping there, earlier in the statement you
rehearsed those. You hadn't seen them at the time, in
fact, those manuals?
Correct.
So you're referring here, in support of your position,
to documents that you hadn't seen at the time?
Yes.
"As I have set out above, Fujitsu's operational manuals
concerning prosecution support appear to deal with the
integrity of audit data rather than the integrity of the
142
period and a statement about the way in which the ARQ
data for that branch had been produced (so that it had
integrity).
"There is no explanation (that I have seen) in the
Fujitsu documents as to what these two standard
paragraphs were supposed to mean. I can see from the
communications in the case study of Mr Hughie Thomas
that I raised a question about the two paragraphs.”
That's essentially what we're looking at on the
right-hand side.
Indeed.
“Looking back now, I think my understanding was that the
first of these two paragraphs related to the proper
operation of the computers involved in the production of
the witness statement and that the second standard
paragraph related to the process by which any records
referred to in the witness statement had been obtained
and produced. In Mr Thomas' case, I think that my
concern was that I could not include these paragraphs
because I had not extracted the ARQ spreadsheets that my
draft statement was referring to. By this I mean that
I could not speak to the computer which had extracted
the spreadsheets as working properly."
You deal with the issue in more detail below.
Just going back to the beginning part of that
144
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paragraph 107, thank you. Four lines in, you say,
“Looking back at it now, I think my understanding was
that the first of the two paragraphs related to the
proper operation of the computers involved in the
production of the witness statement ..."
Just stop there. So you're saying, by that, that
the Word Processor or other computer on which the
statement was being typed, or typed for you, was working
properly?
And whatever was being used for doing the analysis, and
so on, yes.
So you're saying that the first paragraph we see on the
right-hand side in yellow relates to the computer on
which the statement was being typed?
That is the only way I can understand that as making any
sort of sense in terms of the people who are producing
that sort of statement.
You ask on the right-hand side that that paragraph is
deleted, yes?
Because I --
Just take it in stages. You asked that it's deleted.
Yeah.
Did you think the computer on which the statement was
being typed was not working properly?
No.
145
summarised it, about the operation, the proper
operation, of the computers being involved to type up
the witness statement?
Yeah.
You can't have honestly have believed that?
Well, I couldn't see any other way that that paragraph
made any sense.
Are you trying to explain away the first paragraph on
the right-hand side through an explanation on the
left-hand side which doesn't hold substance?
I think it does hold substance because I couldn't see it
having any sort of meaning in any other form.
Did you have any reason to believe that the computers
involved in collating the ARQ data were not operating
properly?
I had no knowledge of whether they were operating
properly or not because I wasn't using them. I didn't
have access to them.
So if the first paragraph related to the computers used
to obtain the ARQ data, that might be a proper reason
for the deletion of that paragraph?
Yes.
But that's not the reason that you give in your witness
statement?
Well, that was part of the -- it was the computers
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You were presumably satisfied that your draft witness
statement was not inaccurate because of any improper use
of the computer on which it was being drafted?
Correct.
Put another way, to the best of your knowledge and
belief, the computer on which you drafted the witness
statement was operating properly at the time?
Yes.
If the computer on which you drafted the statement
wasn't operating properly, presumably any such problems.
with the computer wouldn't affect the accuracy of the
content of the witness statement?
Yes, I think so, yeah.
On what basis, therefore, could you have any doubts as
to the truthfulness of the first section highlighted on
the right, on the basis of the reason that you have
given -- you give, as is highlighted in yellow on the
left?
I was just unclear about the whole lot and maybe I must
have had some sort of discussion and then, when they
said, well, that needs to be in there, then I realised
what it must have meant, because that was the only
sensible explanation for what that paragraph could mean.
No, you say; looking back now, your understanding is
that the first of the two paragraphs is, as I've
146
involved in the production of that, so not just the
typing up but, actually, the extraction of the ARQ data
as well, yes.
Is the truth of the matter that what you explain in this
paragraph, 107, one that you've come up with after the
event to seek to explain away this comment in the draft
witness statement that you didn't think you could
include the last two paragraphs?
I just don't remember what it was. I certainly did
include that paragraph and the only way it can make any
sense is with the explanation I've come up with.
Or is the truth of the matter that you know that the
first paragraph on the right refers, and was intended to
refer, to Horizon, and the truth of the matter is that
you didn't think you could include that first paragraph
because you knew that there was no way that you could
say that the Horizon system, ie the computer, was
operating properly or, if not, any respect in which it
was not operating properly wouldn't affect the
information held in it?
I wouldn't have referred to the Horizon system as "the
computer"; I would have referred to it as "the Horizon
system".
SIR WYN WILLIAMS: Well, you didn't write it though it, did
you?
148
(37) Pages 145 - 148
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A. Yes, but as I say
SIR WYN WILLIAMS: Well, no, you didn't write it, did you?
A. No.
‘SIR WYN WILLIAMS: No.
MR BEER: If we go back to page 1, please. On the
right-hand side, if we scroll down, paragraph 1, you
say, second line:
"I have been ... involved in many aspects of design
and implementation of the computer system known as
Horizon ..."
Isn't your reference in the last paragraph
a reference back to that computer system?
A. I didn't think so.
SIR WYN WILLIAMS: I'm sorry to be persistent but you didn't
write that either, did you?
A. I think I probably would have written the first
paragraph but I --
‘SIR WYN WILLIAMS: I thought you told Mr Beer earlier that
that was a paragraph suggested to you, and I'm not
suggesting it was improper to suggest it to you, simply
that it wasn't you who had written it.
A. Right. Okay, I can't remember exactly who wrote which
bits at the time, sorry.
‘SIR WYN WILLIAMS: = All right.
MR BEER: Can we go back to the last page of the statement
149
24 March 2006, in Mr Thomas' case, by looking at
FUJ00122210. If we look at that first page and scroll
down, thank you, an email, from Mr Ward to Ms Lowther,
copied to Brian Pinder, Mr Baines, Mr Dawkins, and Diane
Matthews. So not you at this stage, although we'll see
from the email above in a moment that this was sent on
to you.
A. Yes.
Q. He, Mr Ward, says:
"This statement needs more work ... I've attached
a suggested draft with a number of comments (as
mentioned previously I think the ‘system failure ...
normal occurrence’ line is potentially very damaging).
It may be worth considering someone from our team taking
a statement directly from Gareth (where is he based?)
"Whilst there is some urgency with this, it is more
important to get it right and ensure we are not
embarrassed at court, which we certainly could be if we
produced a statement accepting ‘system failures are
normal occurrences'."
Do you agree that Mr Ward was seeking here directly
to influence the contents of your witness statement in
criminal proceedings before the Crown Court?
A. I think that could be interpreted in that way, yes.
Q. Do you interpret it in that way?
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‘on the right -- sorry, one page up, the second paragraph
in yellow:
“Any records to which I refer in my statement form
part of records relating to the business of Fujitsu
Why couldn't you say that?
Because I thought it was saying that I'd actually
extracted them --
It doesn't say that -- sorry to speak over you. It
doesn't say, "I've extracted them".
That is what I thought that they were saying.
So you're saying that you thought that that last
paragraph said that you personally had exacted them and
that's why you didn't think you could properly say them?
Yes.
MR BEER: Thank you.
Sir, it's 3.00 now. I wonder whether that would be
an appropriate moment.
SIR WYN WILLIAMS: Yes, of course. 3.15, yes?
MR BEER: Thank you very much.
(3.00 pm)
(A short break)
(3.17 pm)
SIR WYN WILLIAMS: Yes, Mr Beer?
MR BEER: Thank you, sir.
Mr Jenkins, can we pick up the chronology with
150
I think he was just looking at getting my meaning made
clearer, in that I -- I can understand why he felt that
the term "system failure” was going to be potentially
causing embarrassment, and I can understand that the way
I was using it was not in the way that he was
interpreting it. So I felt that there was the scope for
improving the wording.
He was seeking to influence, do you agree, the contents
of your witness statement, as it was presently drafted,
because it may be damaging to the prospects of
a prosecution?
Yes, I think you'd have to ... say that, yes.
And that the Post Office could thereby be embarrassed at
court?
Yes.
This was sent to you, if we just look up. What did you
think by this attempt by the Post Office to attempt to
alter your evidence?
I don't think I interpreted it in quite that way at the
time, I just saw it as being a way of improving the
wording of what I had in the statements, rather than
being -- just trying to alter what I was saying. I just
saw it as a way of improving things.
Let's look at how he tried to improve it by looking at
the attachment, FUJ00122211. Can we go to the second
152
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The Post Office Horizon IT Inquiry
page, please, and scroll down. Stop there.
You had typed in your original email, and it had
been cut into a witness statement for you:
"There are three main reasons why a zero value
transaction may be generated as part of the banking
system ...
"The transaction has no financial effect ...
"The transaction has been declined by the Bank
"There has been some sort of System Failure. Such
failures are normal occurrences."
If we stop there, he has struck through, either by
deletion or by typing over -- and the Word system has
thereby struck through because its Track Changes -- the
word "main", hasn't he?
Yes.
He has added a question:
“If these are the main reasons, what are the rest?"
He has struck through again, in the same way that
I've just described, either by direct deletion or by
highlighting and then typing over:
"There has been some sort of system failure. Such
failures are normal occurrences."
Yes.
He has added some comments in brackets afterwards. This
is comments are addressed to you, aren't they?
153
Why did you read it or see it as for him seeking for you
to use less emotive words.
Because clearly he didn't like the words "system
failure" and he had made that clear both in the covering
email and in the document.
And by deleting it?
And by deleting it, yes.
Did Mr Ward, to your knowledge, have any technical
knowledge?
I don't believe so but I don't know.
At the time, did you consider his conduct to be
appropriate?
I saw him as trying to get -- to improve the way that
the statement was worded.
So you thought this was appropriate?
I didn't think it was inappropriate at the time.
You presumably realised that these were very serious
matters, these were proceedings in the Crown Court?
Oh, yes.
This is your evidence and not his?
Yes.
There's a declaration at the top of the statement,
which --
Yes.
-- I think you will have read?
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Yes, I assume so.
"This a really poor choice of words which seems to
accept that failures in the system are normal and
therefore may well support the [subpostmaster's] claim
that the system is to blame for the losses!!!!"
You would agree, would you, that the words in
brackets there that are highlighted seek to explain the
reason for the deletion of the "system failure" reason?
Yes.
That's how it reads and it's how you would read it.
Yes.
It's how you would have read it at the time, do you
agree?
I think so, yes.
What did you think of this? Did you think this was.
an attempt to alter your evidence? If you didn't think
the email was, what about the striking through of
passages of your witness statement?
I saw that as seeking to see whether I was happy to
reword it in using less emotive words, and he's made it
very clear that he doesn't like the words that I've used
there.
Does he say, "Can you explain this by using less emotive
words"?
No, he doesn't.
154
Yes.
If we go back to that at page 1, that statutory
declaration at the top there?
Yes, yes.
It's a personal witness statement?
Yes.
Did you approach anyone within Fujitsu to say, "Is this
appropriate, a Casework Manager suggesting changes to my
evidence?"
I may have discussed it with Neneh or Penny, I don't
know -- or Brian Pinder -- I don't think I would have
discussed it with anyone else.
If we go back to page 3, and scroll down. We can see
that the last two paragraphs, the boilerplate
paragraphs, don't appear there, either as text or as
being deleted.
Yes.
Do you think you had deleted those or you'd removed them
when you sent back your previous version?
I don't know.
Can we go to FUJ00152587, top of page 2, please. You
reply to him, sending that marked-up version of the
witness statement to you:
"I've added some further annotations to your
annotations. Does this move us forward?"
156
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Did you regard this as some kind of negotiation in
which you were required to haggle with the Post Office
about the way in which you described the Horizon system
and whether it had defects?
I suppose in a way I probably did, because that was how
I was used to -- when writing technical documents, then
I would receive comments them and then make up dates
based on the comments I'd received, and then update the
next draft of the document. So I saw this as being
a similar sort of process.
Do I take it from that that you didn't regard it as
inappropriate to be haggling with the prosecutor over
the content of your personal witness statement?
Yes, I think you can take it that way.
Can we look at the attachment that you sent back, asking
whether it moved us forwards. FUJ00122216. Now,
I think the tracked changes have been lost on this but
I think we can make sense of it. If we scroll down,
please, paragraph 1, no changes. Paragraph 2, I think
we can see a subtle difference of change in text in
line 4; can you see that?
Ah, yes.
It looks like a smaller font size. Is that likely to be
your annotation?
Yes, the "I'm not sure about this, I've had nothing to
157
was the one submitted in the prosecution to the court or
disclosed to the court in the prosecution of Mr Thomas,
okay?
Okay, but I'm not aware that you've actually signed it.
No, in this version -- well, I might as well ask you
now: did you sign a version?
I can't remember is the simple answer to that.
Do you remember them coming to see you?
I don't actually remember that, although I can see from
the email exchanges referring to "Meeting you a couple
of weeks ago" that it must have happened but I've no
recollection of that meeting.
Okay, so you would agree that the evidence tends to show
that they did come to see you to take a witness
statement from you?
That appears to be what happened, it's just that I don't
remember the actual meeting.
Then scroll down, please. If we look at the third
paragraph, you say:
"I extracted data from this system ..."
That's the PEAK system.
Yes.
... concerning [the] post office. The data extracted
was for all transactions for three specific time periods
... From this data, I then extracted all the banking
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do with producing the spreadsheets", I think is my text
and, in fact, the rest of that paragraph is mine. So
I think the original must have ended at "GIJ/03" and
I think the "I'm not sure about this" is probably mine
as well.
So the passage which reads:
“I'm not sure about this, I've had nothing to do
with producing the spreadsheets. All I've done is make
some statements based on what is in the spreadsheet.
I assume that Neneh or Penny produced the spreadsheets,
but I have no personal knowledge as to what was included
within them and what was excluded. For all I know, you
could have typed them up from scratch."
So you were saying, "I'm unhappy with the four lines
that appear beforehand. I don't want them included"?
Yes.
“Because I haven't produced any of the spreadsheets,
I've got no personal of what was included or excluded
from the spreadsheets: you could have just made them
up"?
Yes.
Can we look, please, at the same time as this document,
at FUJ00122237. That, on the left-hand side, is the
final version of the witness statement, dated 6 April
2006, which the Post Office in their disclosure tell us
158
transactions which showed a zero value."
Then it continues.
Yes.
Is it right that you obtained the data from the PEAK?
That's what it says there. Therefore, I assume I must
have done so.
The data from the PEAK was not created by the PEAK. It
had already been created, captured and attached to the
PEAK by someone else, hadn't it?
Yes, I realise that now and, clearly, the PEAK is not
a good repository of the data like the ARQ data but
I felt that at least what I was saying there was
correct, in that I had extracted the data from PEAK,
whilst I was unable to say that I had extracted the data
from the ARQ system.
Well, just reading what you say on the left-hand side in
paragraphs 2 and 3, you say there was a fault management
the system called the PEAK system and then you say:
"I extracted data from this system concerning [the]
post office. The data extracted was for all
transactions for three specific time periods requested."
There was no data on the PEAK system for all
transactions for the three specific time periods, was
there?
I think there must have been at the time because, if
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a message store was extracted and put onto the PEAK
system, it will have 35 days' worth of data, so -
Were talking at cross purposes. I'm sorry, it's me.
The PEAK system itself doesn't create that data. It's
not a means of capture of it. We've seen the PEAK
system used. Sometimes people just attach documents to
it
Yes, yeah.
-- almost drag them into the PEAK?
Yeah.
Is that what had happened here, the three sets of data
had been dragged into the PEAK by somebody else?
Yes, it had been.
So when you say, "I extracted data from the system", the
PEAK system, and the data extracted was for all
transactions, what you're doing is not saying that
somebody else had performed the original extraction
function?
Correct.
How was it any better from what you described on the
right-hand side, where you say, "For all I know, you
could have typed them up from scratch"?
Looking at it now I agree but, for some reason, I must
have decided that that was all right at the time but
I can't remember why.
161
Yes, I think the one thing that is slightly different
here is that, in the previous case, the spreadsheets had
been produced from the raw ARQ data by Neneh or Penny,
whilst, in this case, I'd actually extracted the
spreadsheets from the PEAKs myself. So I think that's
the subtle difference here but I accept that it's a very
subtle difference.
Can we look at the first attachment to your email here,
where you say, “I've ... carried out my own analysis of
it and presented the results in [a] Word document", by
looking at that attachment. FUJ00122229, your document
of 30 March 2006:
"This note is provided as input to a witness
statement ...
"What I've Done
“Penny Thomas provided me with extracts from Audited
Data for 3 separate periods.
“I have taken this data and extracted details of all
banking transactions and analysed the zero value
transactions."
Here, you're referring to the data that Penny Thomas
has provided you, rather than data which you have
dragged from the PEAK system.
I accept that that's what that says and I just can't
remember what had actually happened at the time.
163
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Well, can I press you on that. You clearly rightly, on
the right-hand side, say, "I can't exhibit three sets of
ARQs because I've had no role in obtaining the data in
those ARQs"?
Yes.
On the left-hand side, in what appears to be your final
statement, you say, "I have extracted that data from the
PEAK". It was no better than on the right-hand side,
was it?
I accept that now but, clearly, I had not thought it
through in that way at the time.
Can we look, please -- both those documents can come
down -- at FUJ00122230. In between those two drafts,
you sent this email to Brian Pinder and say:
"Brian,
"I've taken the data off the PEAK and carried out my
own analysis of it and presented the results in the
attached Word document."
Then there are the ARQs, 401, 459 and 460,which
I think are Excel documents, and then a Word document,
which is your own analysis; is that right?
I believe so, yes.
So again, this not you extracting data, proprietary data
from the system, it's you dragging data captured by
somebody else from the PEAK system, correct?
162
Well, this is under a heading "What I've Done"?
Yes.
So, presumably, that's what you did?
Yes. Sorry, I just can't remember the details of
exactly what was happening at the time.
Well, you accept here what you're saying is you've in
fact used the data provided by Penny Thomas, not the
data extracted from the PEAK?
I can't explain the difference.
So, in fact, the analysis on the basis of this document
was based on extracts provided for you by Penny Thomas,
which you said you were earlier unhappy to rely on,
because she could have typed them up from scratch, and
then you ended up making a witness statement, if we go
back to it, FUJ00122216, that's the one which said, "For
all I know, you could have typed this up from scratch",
yes?
Yes.
Then you ended up -- if we can also display FUJ00122237.
So, based on your Word document, you'd, in fact, used
the data provided by Penny Thomas. If we scroll down on
the left-hand side, you tell us about the PEAK in the
second paragraph, and then you say:
"I extracted data from this system concerning [the]
post office. The data extracted was for all
164
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transactions for three specific time periods ..."
That wasn't true, was it?
I'm not sure. Whether something had happened between
30 March and 6 April, I just can't remember.
Was the wording you used in this final statement here
a loincloth to cover up what you had done? You rightly
realised that you couldn't say that you'd extracted the
ARQ data nor could you produce it yourself. You said in
your Word document that you didn't in fact analyse data
that you'd taken from the PEAK but, as this document
makes clear, you've used the phrase "I've extracted from
the PEAK" to paper over what, in fact, had happened?
If I said there that I extracted it from the PEAK then
I would have extracted it from the PEAK but I can't
remember exactly when I did that and how I did that.
So, if that's correct, then there's something else that
has occurred after the 30 March document when your
analysis was based on Penny Thomas’ data?
I think there must have been, yes.
If we go back to just FUJ00122216, on the right-hand
side that's it, and if we can go to page 2, please --
and scroll down, thank you -- in the paragraph that
begins "Should the spreadsheets be regenerated”, three
lines in, the statement reads:
"There are three reasons why a zero value
165
the Crown Court?
Because he clearly didn't like the wording that I was
using, so I was asking if he had a better suggestion for
me to use.
Again, did you see it as appropriate to haggle with the
prosecutor over the content of your witness statement?
I didn't see it as inappropriate at that time but
I clearly see now that it was.
You explain that:
"What we have here are genuine failures of the
end-to-end system which are not part of the normal
operation, but are anticipated, and, the system is
designed to cope with them. Some such failures could be
engineered as part of a malicious attack (but that
doesn't apply to those failures that appear in the
evidence presented). In all cases the system is
designed to identify such failures and handle them in
such a way that the Customer, the Postmaster, Post
Office and the Fis ..."
Fis?
Financial institutions. It's a code for banks,
basically.
"... are all clear as to the status of the transaction
and any necessary financial reconciliation takes place.
I guess one option ..."
167
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transaction may be generated as part of the banking
system:
"[1] The transaction has no financial effect ...
“[2] The transaction hacks been declined by the bank
Then the third reason, "system failure", has
disappeared, hasn't it?
Yes, and that, I think, is due to the document we looked
at earlier.
le it had been deleted in the tracked changes --
Yes.
-- by Mr Ward?
Yes.
What remains is his addition "This is a really poor
choice of words", and you reply to that in the passage
after the brackets; is that right?
Yes, so the version that I would have seen would have
had the deleted thing and I'd not twigged that I hadn't
undeleted it or replaced it with something.
Well, I'm not sure you would have undeleted it because
you say, "Can you please suggest something better,
then"?
Yes.
Why were you asking a casework handler to suggest what
you should say in a witness statement for proceedings in
166
This is still you speaking, yes?
Yes.
"I guess one option is to delete the paragraph since it
is purely an introduction to the following more detailed
description.”
So, again, was this part of the continuing dialogue
that you thought it was appropriate to have as to how to
word your witness statement in proceedings before the
Crown Court?
Yes, I think it was.
Can we look, please, at the final witness statement
alongside, FUJ00122237, and on the left-hand side scroll
down, please -- and stop. If we just scroll up a little
bit. Thank you. You explain response codes 3, 4, 6 and
8: the financial institution has declined the
transaction.
You explain codes 23 and 26, which indicate
an unusual response from the financial institution and,
again, no cash should change hands.
You say:
"... Response Code 32 indicates the Horizon's
central system has received no response to the financial
institution within a timeout period and so no Cash
should change hands."
You then add:
168
(42) Pages 165 - 168
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The Post Office Horizon IT Inquiry
"All these are perfectly normal occurrences and
should result in clear instructions being passed to the
counter clerk to ensure that no Cash should change
hands."
Just stopping there, it would appear that Mr Ward
has been successful in pausing the alteration of your
evidence?
Yes. Well, I still stand by what it actually says there
as being an accurate representation of what had actually
happened within the system.
Is that why you were a willing actor in this process?
Yes.
Why you went along with his pushback?
Yes, because it was still accurately reflecting what had
actually happened, but using less emotive words, which
he clearly wasn't happy with.
Then can we see underneath, on the left-hand side, the
objectionable last two paragraphs, the ones that,
remember, had been marked up in yellow, have been
replaced by:
"There is no reason to believe that the information
in this statement is inaccurate because of the improper
use of the computer. To the best of my knowledge and
belief at all material times the computer was operating
properly, or if not, any respect in which it was not
169
"The computer" was intended to refer to, here,
a computer in the wider sense, wasn't it? It refers to
Horizon, doesn't it?
I don't think I was in a position to say that Horizon
was working correctly at the time, as far as this was
concerned.
Why, given what you'd said in your comment on the yellow
highlighted paragraph, "These need to be deleted,
I can't say these", has it now re-emerged?
Because I must have then understood that it was
referring to what I was actually producing the statement
on.
How did you obtain such an understanding?
I don't know.
From whom did you obtain such an understanding?
I don't know.
Can we go back to the email chain, FUJ00152587, and
Mr Ward's reply:
"I do not understand why this statement, which was
originally requested on 10 March is taking so long ...
I appreciate it is slightly unusual, but I do not
understand the confusion as I thought I'd made our
requirements clear.
Gareth's annotations do not take us forward at
all (and I'm sure this is not Gareth's fault). Gareth
171
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26 June 2024
operating properly, or was out of operation was not such
as to affect the information held on it. I hold
a responsible position in relation to the working of the
computer."
You told us in your witness statement that that
paragraph, which is broadly the first of the two yellow
paragraphs in the earlier witness statement, was all
about the computer on which you were typing the
statement?
And doing the analysis.
What do you mean by "and doing the analysis"?
I was doing some analysis in the Excel spreadsheets that
were then attached to the statement.
What is "the computer" referring to, on two occasions in
that witness statement?
The computer on which I was actually doing those. In
other words, the PC on my desk.
Really? You're saying your desktop was working
properly?
Yeah.
So it was typing out the words --
Yeah.
-- when you typed "All these after perfectly normal
occurrences"?
Yes.
170
has indicated in the attachment below that
3 spreadsheets produced by your team (which show the
'NIL' transactions and which were in addition to the
usual event and transaction logs) were not produced by
him, therefore, as he quite rightly points out, he is
not in a position to produce them in his statement."
In the event, that's what you ended up doing,
producing them in your statement, didn't you?
But I got it the information from a different source.
le they were Excel spreadsheets given to you in an email
by Penny or Neneh, you didn't think that was
appropriate; they were attached to a PEAK, you took them
from the PEAK, and thought that was acceptable?
The spreadsheets weren't attached to the PEAK; it was
the message store that would have been attached to the
PEAK.
Yes --
So I had actually extracted the spreadsheets myself and
that's what I thought was the difference.
He continues:
"As already stated, we urgently need a statement
producing these 3 additional spreadsheets explaining in
general terms under what circumstances ‘Nil’
transactions occur and in particular how the ‘Nil’
transactions at Gaerwen occurred ... The same statement
172
(43) Pages 169 - 172
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needs to include a paragraph which states there is no
evidence of a system failure ... in relation to the
‘Nil’ transactions at the office. We do not need to
mention ‘system failures being normal occurrences if
there is no evidence of such a problem at this office."
Was it because you were sent this email that you
modified your evidence?
A. I think that's why I went and extracted the data from
PEAK, yes.
Q. And you modified the contents of your witness statement?
A. Well, to reflect that.
Q. Well, and to delete the "system failures are normal
occurrences" line?
A. Yes.
Q. So Mr Ward expressed his concerns on numerous occasions
‘over your wording, including, in your witness statement,
"system failures". He told you that system failures
were potentially very damaging to mention. He told you
that you should not mention them -- "We do not need to
mention them" -- and that they were a really poor choice
of words.
Did all of that pile pressure upon you to remove the
reference to "system failures" from your witness
statement?
A. Clearly, I did that as a result of that, but I was happy
173
secret about it: because there was a late disclosure of
documents to you, I gave permission for your lawyer to
speak to you about it.
THE WITNESS: Thank you.
‘SIR WYN WILLIAMS: But we're now back to where we were
before that late disclosure, so don't talk to anyone
about your evidence. All right?
THE WITNESS: I understand that. Thank you, sir.
SIR WYN WILLIAMS: All right. Fine.
(3.55 pm)
(The hearing adjourned until 9.45 am the following day)
175
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with the wording that I ended up with.
Q. Okay. Did you ever go back to any lawyer within Fujitsu
to say, "Look, I'm being embroiled in a criminal
prosecution here. I'm being asked to sign witness
statements off and there's this man from the Post Office
who is applying pressure on me to change the substance
of my evidence"?
A. No, I didn't, but I clearly understand now that I should
have done.
MR BEER: Thank you.
Sir, we would now turn to the Seema Misra case
study. Itis probably an appropriate moment to take
a break. I will be able, comfortably, to finish my
questions tomorrow of Mr Jenkins.
SIR WYN WILLIAMS: By “a break", you mean adjourn for the
day, Mr Beer?
MR BEER: Yes, a long break.
‘SIR WYN WILLIAMS: =A long break. Right.
All right, that's what we'll do, and we'll start
again at 9.45 tomorrow?
MR BEER: It is 9.45, please, yes.
SIR WYN WILLIAMS: Yes, fine.
MR BEER: Thank you.
SIR WYN WILLIAMS: Oh, I mentioned last evening, Mr Jenkins,
not to talk about your evidence. There shouldn't be any
174
INDEX
GARETH IDRIS JENKINS (continued) ....
Questioned by MR BEER (continued) ..
176
(44) Pages 173 - 176
1
MR BEER: [26] 1/6
23/8 23/11 23/13
23/22 24/17 24/22
24/24 49/7 49/11
49/14 49/18 91/4
91/13 91/15 91/20
91/23 149/5 149/25
150/15 150/19 150/24
174/10 174/17 174/21
174/23
SIR WYN WILLIAMS:
[31] 1/5 23/5 23/9
23/12 23/15 23/17
23/20 24/8 24/18
24/23 49/10 49/13
91/3 91/11 91/14
91/16 91/22 148/24
149/2 149/4 149/14
149/18 149/24 150/18
150/23 174/15 174/18
174/22 174/24 175/5
17519
THE WITNESS: [2]
175/4 175/8
‘Although [1] 71/6
‘boilerplate’ [1]
141/21
‘Callendar [1] 25/10
expert’ [1] 106/25
"Horizon [1] 108/18
"I [1] 65/13
"Ihave [1] 65/13
"Nil [1] 134/15
'NIL' [4] 172/3 172/23
172/24 173/3
"not [1] 5/13
‘Receipts [1] 34/10
‘see’ [2] 34/5 36/8
‘sending’ [2] 34/6
36/9
‘standard’ [1] 141/21
"system [5] 132/14
134/17 151/12 151/19)
173/4
‘That [2] 43/23 45/2
‘The [2] 43/13 70/9
‘There [1] 132/15
"Was [1] 43/9
1.0 [1] 95/23
1.01 [1] 131/14
44 [1] 114/23
1.35 [2] 91/15 91/19
10 [5] 10/3 55/17
128/16 132/10 133/19
10 December [1]
108/14
10 March [2] 124/11
171/20
10 years [1] 105/12
10.03 [1] 1/2
100 [4] 29/16 37/4
135/8 135/12
102 [1] 141/19
103 [1] 142/4
104 [1] 142/12
105 [1] 143/8
106 [1] 143/16
107 [2] 145/1 148/5
44 [2] 12/23 49/22
11 days [1] 125/25
11.20 [1] 49/15
11.30 am [1] 6/10
11.40 [2] 49/12 49/17
12 [4] 12/23
12 months [1]
114/25
12.43 [4] 124/11
12.44 [1] 91/17
12.45 [1] 91/12
127 [3] 80/1 80/2
84/16
128 [1] 80/13
13 [2] 12/23 55/12
14 [1] 14/11
15 [1] 60/21
16 [1] 25/6
164 [2] 39/23 118/7
165 [1] 118/7
17 [2] 42/25 103/8
18 [5] 6/12 6/16 7/16
8/23 11/6
18 January [1]
111/18
18 November [13]
1/12 2/3 4/9 9/3 9/7
9/19 10/9 21/6 22/5
22/14 22/19 22/20
24/14
"We [1] 50/1 19 [2] 27/20 53/20
. 2
[1] 132/10 2 August [2] 59/22
0 I 10276
0.1a [4] 96/13
0.1b [1] 96/5
01/11/04 [1] 125/9
03 [1] 158/3
04 [1] 125/9
05 [1] 125/9
2 October [7] 91/4
92/1 95/23 107/14
108/1 110/2 110/7
20 [1] 49/12
2000 [2] 52/10 53/11
2002 [5] 59/19 59/22
60/22 61/16 64/14
2005 [11] 1/12 2/3
4/9 9/3 9/7 9/19 10/9
21/6 22/5 25/18 32/9
2006 [15] 3/17 5/1
5/2 8/7 18/12 19/18
27/16 29/2 29/15 30/1
34/15 124/11 151/1
158/25 163/12
2008 [2] 29/10 32/9
2009 [4] 91/5 92/1
95/23 96/10
2010 [13] 31/7 32/2
33/21 40/1 40/25
41/24 52/10 73/8
73/15 73/16 94/6
102/6 108/19
2011 [5] 92/6 92/12
111/14 111/21 119/18
2012 [12] 55/14
56/11 58/16 59/11
64/23 66/5 68/18 79/3
79/16 82/5 92/13 95/1
2013 [1] 70/5
2015 [2] 33/8 33/9
2016 [2] 63/21 64/16
2018 [7] 46/22 47/10
47/25 48/5 48/25 53/8
78/3
2018/19 [2] 27/20
53/20
2018/2019 [3] 26/16
58/14 59/7
2019 [4] 26/16 58/14
59/7 77/13
2020 [2] 2/13 2/21
2021 [1] 62/6
2024 [1] 1/1
24 [4] 49/21
21 March [2] 125/24
128/3
23 [1] 168/17
23 March [1] 135/5
24 August [1] 63/21
24 March [4] 151/1
24 September [1]
106/10
25 November [3]
92/12 111/14 111/21
25 November 2011
[1] 92/6
251 [2] 4/3 4/5
252 [3] 4/3 4/23 5/23
25th [1] 107/5
26 [1] 168/17
26 June 2024 [4] 1/4
26 November [1]
64/22
28 [1] 26/3
294 [1] 131/18
2Secure [1] 59/24
3 December [1]
108/9
3 May [1] 43/5
3 spreadsheets [2]
132/5 172/2
3.00 [3] 132/20
150/16 150/20
3.15 [1] 150/18
3.17 [4] 150/22
3.49 [1] 6/6
3.55 [1] 175/10
30 March [3] 163/12
165/4 165/17
30/11/05 [1] 125/9
313 [1] 138/21
316 [2] 76/10 139/11
317 [1] 76/23
32 [3] 76/15 77/24
168/21
33 [4] 141/18
35 [4] 161/2
4
4.19 [1] 7/2
4.3.2 [1] 60/21
40 minutes [1] 6/24
401 [1] 162/19
44 [1] 80/2
43 [2] 55/12 56/24
44 [1] 55/20
459 [1] 162/19
460,which [1] 162/19
473 [1] 39/23
5
5 June [2] 5/2 6/2
5 October [3] 66/5
67/1 108/6
5.40 [1] 133/14
53 [4] 25/3
54 [4] 25/7
6
6 April [2] 158/24
165/4
6 June [3] 3/17 4/25
8/7
601 [2] 5/3 6/2
602 [2] 5/7 7/19
65 [2] 42/25 43/3
67 [2] 43/2 44/20
68 [1] 43/4
70,000 [1] 40/23
80b [1] 26/3
81 [1] 49/22
82 [1] 25/3
84 [1] 20/11
86 [1] 4/4
87 [1] 76/9
9.45 [3] 174/20
174/21 175/11
98 [4] 131/19
A
ability [2] 40/15
62/14
able [24] 9/6 20/4
20/17 21/19 30/20
32/25 34/5 35/3 36/8
36/19 45/21 46/16
54/8 66/16 73/1 81/25I
82/23 86/9 86/23
103/1 117/22 120/19
126/8 174/13
about [132] 2/6 2/25
3/15 3/19 4/17 6/13
7/23 9/15 10/6 10/13
12/8 12/10 13/4 14/20)
15/5 15/9 15/25 16/7
16/19 16/20 17/3 18/5)
18/7 18/11 19/5 20/17)
24/13 26/23 29/13
29/16 31/5 31/6 31/11
31/20 32/21 32/21
33/4 38/18 39/25 40/4I
41/21 41/25 42/8 45/9
45/13 47/15 47/23
52/8 52/10 56/8 59/11
59/14 59/16 60/16
63/4 63/6 63/10 63/25]
64/6 67/7 71/8 71/17
71/24 72/2 72/3 73/15}
77/5 78/18 78/23 80/7I
81/4 81/12 81/22
83/23 85/11 85/23
88/22 91/9 92/4 92/8
92/15 92/18 93/6 94/6I
101/8 101/9 102/1
109/23 110/16 110/20)
112/1 112/13 112/16
112/17 112/20 113/1
113/2 114/11 121/21
122/6 125/15 125/20
126/7 127/15 127/17
131/1 132/25 133/6
133/23 136/2 136/7
136/13 138/19 139/14)
139/17 143/10 143/19)
144/1 144/8 146/19
147/1 154/17 157/3
157/25 158/4 158/7
164/22 170/8 174/25
175/1 175/3 175/7
above [7] 61/9 65/19
124/20 131/15 142/12)
142/23 151/6
absolutely [3] 44/1
97/8 121/15
abstract [1] 60/4
accept [31] 2/18 3/5
9/11 10/10 10/15 13/5I
13/6 13/18 14/7 15/17)
16/13 37/10 37/19
37/22 48/22 51/17
(45) MR BEER: - accept
A
accept... [15] 51/21
54/15 74/19 85/8 93/1
109/3 116/3 116/20
119/23 123/17 154/3
162/10 163/6 163/24
164/6
acceptable [3] 12/17
101/15 172/13
accepted [4] 36/9
37/2 104/9 104/12
accepting [3] 36/10
37/3 151/19
access [54] 39/20
39/24 40/9 40/11
40/13 40/18 40/21
41/1 41/5 41/14 41/24
42/11 42/12 55/7
55/21 56/20 57/1 57/2
57/11 57/22 58/19
58/21 58/22 58/25
59/3 59/11 59/16 60/6
60/23 61/11 61/13
61/19 62/11 62/23
63/24 66/12 66/17
67/8 67/9 67/22 69/11
70/9 70/13 70/16
70/17 71/3 71/18 78/6
78/9 79/4 82/1 84/7
102/25 147/18
accessing [3] 56/1
57/20 58/2
account [8] 18/4
43/11 52/16 64/9
79/11 84/24 104/21
105/2
accounting [2]
102/16 121/10
accounts [17] 40/6
40/16 46/17 51/20
53/23 54/14 56/10
58/6 71/7 72/9 77/7
77/9 80/24 89/17
105/10 105/24 107/11
accuracy [1] 146/11
accurate [6] 36/15
56/5 58/18 68/4 77/15)
169/9
accurately [3] 118/3
120/11 169/14
across [2] 109/10
142/9
Act [1] 63/3
acted [1] 18/24
action [3] 34/19 35/6
43/10
actioned [1] 35/11
actions [2] 63/2
108/4
activities [1] 58/23
activity [4] 108/7
actor [1] 169/11
actual [5] 72/9 122/5
actually [80] 8/19
11/19 13/12 16/2 16/5)
26/23 29/6 29/9 29/20
31/2 31/17 32/8 32/11
32/12 36/18 37/8
37/12 39/7 46/24
47/24 48/3 49/1 49/2
52/5 54/25 57/14
58/10 59/15 74/4
77/16 78/15 78/20
80/8 81/17 83/13
84/10 84/25 88/2
89/17 94/3 95/5 97/4
97/6 97/7 97/13
100/23 100/25 107/21
111/1 112/6 113/19
113/25 117/11 117/22)
120/11 120/14 127/5
127/15 127/18 129/8
130/6 131/1 137/21
137/24 138/2 138/3
140/3 141/24 148/2
150/6 159/4 159/9
163/4 163/25 169/8
169/9 169/15 170/16
171/11 172/18
adapt [1] 32/25
add [7] 6/14 89/7
98/10 125/11 126/16
133/24 168/25
added [7] 90/4
135/11 135/22 136/22)
153/16 153/24 156/24)
adding [2] 56/9 66/22
addition [5] 65/18
69/9 72/23 166/14
172/3
additional [2] 86/22
172/22
address [28] 1/18
4/16 8/1 21/4 42/12
66/11 66/13 66/18
71/14 76/14 77/23
83/21 89/11 95/9
109/21 117/9 121/18
121/20 122/2 122/7
122/11 122/16 124/12)
124/14 135/22 135/25)
140/15 143/2
addressed [5] 1/10
25/2 40/3 85/3 153/25
addresses [3] 109/17I
110/1 125/19
addressing [6] 40/9
90/22 94/1 94/20
126/22 128/1
adept [2] 50/16 50/17
adequacy [2] 81/22
115/3
adequate [2] 123/10
141/8
adequately [1]
118/23
133/20 136/24 159/17)
adjourn [1] 174/15
adjourned [1] 175/11
Adjournment [1]
91/18
admin [2] 61/14
66/14
admissibility [4]
113/10 113/15 114/6
121/2
admitted [1] 79/16
adopt [1] 62/20
advance [2] 5/11
129/3
advanced [1] 76/19
advice [4] 19/7 97/21
98/2 106/25
advices [1] 85/4
advise [1] 133/7
advised [2] 7/4 65/23
affect [9] 107/12
116/15 116/21 117/5
117/6 138/14 146/11
148/19 170/2
affected [6] 25/16
35/20 80/10 84/20
85/15 110/22
affects [3] 5/13 7/11
11/11
afraid [8] 35/8 38/23
42/21 51/8 55/6 59/18
105/3 127/6
after [17] 14/11 16/18]
19/18 34/24 78/15
78/17 78/18 95/21
96/7 99/24 124/3
125/25 132/20 148/5
165/17 166/16 170/23
afternoon [1] 136/3
afterwards [1]
153/24
again [31] 7/14 28/2
28/2 29/12 32/6 36/10
37/3 43/21 52/22
54/21 59/8 76/5 85/10)
86/16 98/9 98/17
105/21 110/19 111/9
111/10 111/16 119/8
129/19 133/8 137/1
153/18 162/23 167/5
168/6 168/19 174/20
against [3] 85/8
123/25 140/23
agenda [8] 5/5 6/10
6/16 7/15 7/18 8/7 8/9
9/16
ago [3] 36/14 86/10
159/11
agree [25] 4/1 8/5
10/8 14/19 17/25
37/15 56/11 56/13
56/14 80/18 94/15
100/9 100/19 101/2
115/22 116/11 116/14
117/3 122/22 151/21
152/8 154/6 154/13
159/13 161/23
agreeing [1] 83/15
ah [2] 19/14 157/22
ale [1] 109/4
alert [1] 43/9
alerting [1] 108/15
all [94] 4/21 10/21
11/22 11/24 12/16
15/5 15/25 16/18
16/20 17/8 17/18
18/15 18/24 23/9
23/20 24/2 27/5 30/18)
30/19 32/2 32/8 32/9
36/14 44/2 44/3 48/13
49/10 50/16 59/12
61/14 61/19 63/11
65/10 79/17 82/7
83/19 86/8 88/7 88/12
88/19 88/21 89/21
93/20 94/1 96/12
100/3 104/11 109/17
109/23 110/1 110/16
110/22 114/8 114/13
114/21 116/25 120/16}
121/16 121/16 122/11
122/16 123/18 125/6
125/15 134/12 137/18}
138/11 140/15 141/12)
143/16 149/24 158/8
158/12 159/24 159/25}
160/20 160/22 161/15)
161/21 161/24 163/18}
164/16 164/25 167/16
167/23 169/1 169/24
170/7 170/23 171/25
173/22 174/19 175/7
175/9
allegations [3] 6/13
88/21 102/23
Allen [2] 83/9 83/22
allow [1] 53/15
almost [2] 14/23
161/9
alone [1] 23/13
along [5] 17/2 23/6
74/14 79/17 169/13
alongside [1] 168/12
already [7] 36/9 37/2
122/20 129/7 143/4
160/8 172/21
also [29] 3/15 4/7
6/11 6/14 21/18 22/24
34/12 38/12 47/21
48/5 55/23 65/9 66/1
67/7 73/19 74/3 78/22
81/25 83/25 86/10
86/13 105/2 106/21
108/11 112/15 124/25)
132/9 132/15 164/19
alter [4] 58/6 152/18
152/22 154/16
alteration [1] 169/6
agreed [2] 3/2 109/13}
alternative [1] 62/20
although [3] 5/11
151/5 159/9
always [9] 41/20
46/20 48/12 48/24
52/2 53/7 53/9 84/11
100/4
am [10] 1/2 6/10 9/18
49/15 49/17 65/4
134/14 137/17 141/20)
175/11
Amanda [1] 107/23
amended [2] 66/2
112/6
amendments [2]
33/25 137/4
analyse [3] 59/15
141/12 165/9
analysed [1] 163/19
analysis [16] 67/9
68/1 68/12 125/9
140/18 141/3 143/22
145/10 162/17 162/21
163/9 164/10 165/18
170/10 170/11 170/12)
Andy [1] 108/6
Ann [3] 109/8 109/9
109/11
Anne [11] 31/10
31/20 32/11 32/23
33/9 34/20 42/6 42/23
47/14 52/22 69/7
annotated [1] 134/24
annotation [1]
157/24
annotations [4]
20/16 156/24 156/25
171/24
another [5] 24/19
29/13 64/9 129/12
146/5
answer [16] 11/7
13/11 22/8 27/12
31/15 35/21 47/5
63/17 73/6 73/14
74/22 81/20 83/20
127/23 139/7 159/7
answers [2] 19/8
73/5
anticipated [1]
167/12
any [95] 4/23 5/22
10/11 14/20 15/9
17/11 22/3 22/7 22/12
22/17 26/6 28/22
28/23 31/13 40/22
42/10 42/13 43/9 50/6)
50/8 51/2 58/3 60/10
63/9 67/10 67/12 68/2I
68/17 68/18 69/2 69/5
70/10 73/18 75/23
76/13 76/19 77/22
81/22 81/22 81/23
81/24 84/13 85/3 85/4
(46) accept... - any
A
any... [51] 85/20 95/8
97/18 101/14 104/1
104/11 104/14 106/14}
106/22 107/2 108/7
108/15 111/6 116/24
117/1 118/20 120/9
121/8 121/10 122/7
132/17 133/18 137/9
138/13 138/23 139/3
139/7 139/13 139/21
140/9 140/18 144/16
145/15 146/2 146/10
146/14 147/6 147/7
147/12 147/12 147/13)
148/10 148/18 150/3
155/8 158/17 161/20
167/24 169/25 174/2
174/25
anyone [17] 29/20
31/2 32/14 42/5 57/24,
97/23 103/23 104/4
104/13 110/19 138/24
139/12 139/12 140/6
156/7 156/12 175/6
anything [11] 15/9
16/7 22/23 46/12
52/12 75/18 86/17
95/6 95/7 127/7 131/7
apologise [1] 10/10
apparent [1] 71/15
apparently [1]
105/15
appear [8] 125/5
141/22 142/14 142/24}
156/15 158/15 167/15)
169/5
appeared [2] 45/22
105/16
appears [8] 3/24 4/15]
79/11 96/5 97/9
132/11 159/16 162/6
Appendix [4] 25/8
103/7 103/8 103/14
Appendix 3 [2] 103/8
103/14
applicable [1] 34/1
applies [1] 133/10
apply [2] 99/3 167/15
applying [1] 174/6
appreciate [2] 68/16
171/21
approach [7] 25/12
62/20 69/18 74/25
78/23 130/22 156/7
approached [1]
16/15
appropriate [10] 49/8)
83/4 150/17 155/12
155/15 156/8 167/5
168/7 172/12 174/12
appropriated [1] 94/9}
approval [1] 60/8
approved [1] 111/21
approximately [1]
55/17
April [3] 17/6 158/24
165/4
archaic [1] 102/16
are [78] 2/12 7/15
7/21 10/7 11/14 17/21
17/24 19/4 21/24
29/12 39/23 61/9
62/22 64/15 66/16
71/7 73/4 73/4 73/15
86/3 88/7 88/8 89/1
95/17 96/19 99/1 99/9)
100/3 100/5 102/22
105/21 105/22 105/23}
105/24 105/25 107/6
109/16 116/2 116/7
116/9 116/10 117/10
118/21 125/13 126/8
126/17 126/20 128/6
128/8 133/22 134/18
134/19 135/23 136/4
137/7 140/14 141/24
145/16 147/8 151/17
151/19 153/4 153/10
153/17 153/17 153/22)
153/25 154/3 154/7
162/19 162/20 165/25)
167/10 167/11 167/12)
167/23 169/1 173/12
area [3] 60/15 61/3
66/20
areas [2] 20/4 60/24
aren't [2] 19/5 153/25)
arisen [2] 40/21
119/20
arising [1] 101/25
arose [2] 26/15 80/4
around [1] 105/12
ARQ [60] 28/19 28/25
29/23 43/13 45/18
45/20 45/23 46/7
52/17 52/21 53/4 54/7
54/12 68/10 68/15
75/14 75/16 75/17
79/24 79/25 81/1 81/7,
81/9 81/16 82/6 82/9
82/17 82/22 83/11
84/7 84/10 84/12 85/2
85/18 86/3 86/8 86/19)
87/18 87/23 88/8 89/1
89/8 89/12 90/5 90/5
126/13 132/5 140/5
141/23 143/14 143/21
144/1 144/20 147/14
147/20 148/2 160/11
160/15 163/3 165/8
ARQs [7] 124/16
125/1 125/20 128/4
162/3 162/4 162/19
arrange [1] 126/10
as [222]
ascertain [1] 23/17
Aside [1] 40/17
ask [17] 9/14 9/18
10/6 10/12 10/13
41/21 64/6 87/19
92/15 113/1 127/16
130/18 139/3 139/7
141/2 145/18 159/5
asked [67] 1/17 1/17
2/6 3/15 4/5 4/7 4/16
4/18 5/19 11/7 12/7
12/12 12/13 13/12
19/10 20/23 31/6
31/10 31/20 32/24
33/10 43/25 44/22
44/24 45/4 45/5 45/7
52/14 65/13 66/23
71/16 74/7 74/17 81/3
83/21 85/6 92/21 93/2
93/5 93/23 93/25 94/2
97/6 97/12 97/15
98/23 100/23 101/6
101/22 103/20 103/23
106/7 110/21 110/24
112/7 112/24 113/1
114/16 118/20 118/24
126/20 127/12 138/17]
139/4 140/13 145/21
174/4
asking [14] 4/8 7/25
19/5 21/15 21/18
64/23 84/5 106/10
117/23 128/1 134/5
157/15 166/24 167/3
asks [1] 131/16
aspects [1] 149/8
assessment [2]
115/3 120/20
assistance [3] 106/8
108/15 124/17
associated [7] 9/9
26/6 28/18 29/23
34/13 48/18 81/8
association [1] 9/12
assume [6] 33/23
73/1 84/3 154/1
158/10 160/5
assumed [2] 5/18
88/16
assuming [2] 69/16
110/3
assumption [2] 6/17
114/8
assumptions [1]
69/20
assurance [3] 115/5
115/12 115/22
asterisk [1] 97/2
at [321]
attach [4] 6/10 6/11
134/24 161/6
attached [22] 5/5
5/14 6/15 7/15 7/18
8/4 8/8 11/12 24/15
36/2 50/4 50/7 65/7
65/9 131/21 151/10
160/8 162/18 170/13
172/12 172/14 172/15)
attachment [18] 7/7
8/21 9/1 9/2 9/7 9/13
9/15 9/20 11/2 16/6
20/7 20/11 135/3
152/25 157/15 163/8
163/11 172/1
attachments [4] 5/10
7/5 7/6 8/19
attack [1] 167/14
attempt [4] 30/10
152/17 152/17 154/16}
attempted [1] 78/16
attempting [2] 34/7
73/4
attend [4] 4/24
attendance [2] 3/15
3/23
attended [1] 24/21
attendees [2] 106/21
107/6
attention [3] 11/5
16/4 131/4
attribute [1] 48/8
attributed [2] 48/12
48/21
attributing [1] 58/16
audit [57] 62/23
72/23 73/1 73/10
73/11 73/19 75/9 80/4,
80/9 80/10 80/11
80/12 80/15 80/16
80/19 80/21 84/17
84/21 85/7 85/13
93/15 93/18 94/24
95/2 103/6 105/18
112/2 112/16 112/17
112/21 113/7 115/5
115/23 116/23 117/1
4117/7 117/12 117/15
117/17 117/20 118/3
118/11 118/14 119/10)
120/1 120/10 120/10
121/23 122/5 123/6
123/6 123/16 137/22
137/25 142/14 142/25}
143/5
auditable [2] 41/7
41/25
audited [8] 61/21
61/25 63/12 63/16
67/10 68/1 68/12
163/16
auditing [3] 20/5 50/8)
63/14
August [7] 19/17
29/10 59/22 63/21
78/2 94/6 102/6
author [3] 95/17
111/11 115/17
authored [3] 90/21
91/4 91/25
authorised [3] 40/8
67/13 69/3
authorities [1] 60/9
automated [1] 87/10
automatic [1] 62/22
automatically [1]
84/7
autumn [3] 39/25
40/25 41/24
available [3] 32/3
86/13 133/11
aware [34] 2/13 2/21
3/11 15/12 22/22
22/24 26/8 27/18 29/6I
43/7 46/16 46/19 48/1
61/7 64/8 84/6 85/17
88/7 88/12 88/19 90/3}
90/9 94/4 94/18 94/25]
95/11 98/3 98/23
116/16 121/3 121/8
123/19 141/20 159/4
away [5] 37/23
108/24 114/9 147/8
148/6
B
BA [1] 71/7
back [61] 1/10 5/16
5/23 10/1 11/8 12/22
13/24 20/17 24/1 24/6I
24/7 24/24 28/1 28/3
32/20 38/12 43/3 43/5I
43/8 44/5 49/24 57/3
57/14 59/19 63/23
66/7 72/7 74/18 75/7
85/11 89/4 89/17
91/20 96/4 103/4
110/2 116/25 117/2
117/14 120/22 126/9
130/21 131/12 133/9
134/21 144/12 144/25]
145/2 146/24 149/5
149/12 149/25 156/2
156/13 156/19 157/15}
164/15 165/20 171/17
174/2 175/5
back-end [1] 72/7
backed [2] 64/13
103/5
background [2]
28/14 65/10
bad [1] 117/19
Baines [1] 151/4
Baker [2] 70/5 71/24
balance [2] 36/11
36/13
balanced [1] 34/11
balancing [2] 41/17
80/24
bank [3] 128/12
153/8 166/4
banking [14] 125/13
126/8 126/17 126/22
127/13 127/14 128/9
(47) any... - banking
B
banking... [7] 136/8
140/3 140/4 153/5
159/25 163/19 166/1
banks [1] 167/21
barrister [1] 108/12
based [14] 38/13
42/3 55/18 56/17 74/1
76/5 102/16 123/6
151/15 157/8 158/9
164/11 164/20 165/18
basement [1] 72/5
basic [4] 87/18 87/23
122/6 129/23
basically [4] 27/6
130/12 133/18 167/22
basis [19] 14/19
39/18 62/19 68/18
69/18 69/19 69/21
69/25 71/4 73/22 74/2
75/2 94/20 95/9
110/25 130/2 146/14
146/16 164/10
Basket [1] 89/9
batch [1] 50/5
BBC [1] 106/2
be [185]
became [1] 26/8
because [84] 2/11
2/20 2/24 3/7 6/23 9/8
9/21 10/24 11/7 11/14
12/17 15/1 18/7 18/11
18/17 21/10 23/5
26/14 30/9 32/24 33/2
38/8 39/7 43/24 44/17
45/3 53/14 54/21
57/21 58/9 58/13
58/24 60/16 64/4
69/16 70/1 73/23
75/16 76/18 78/23
83/13 85/17 87/25
90/11 93/23 100/21
102/8 107/20 112/18
114/18 117/11 117/14)
119/23 120/4 136/14
136/15 137/22 139/4
139/7 139/14 140/1
144/20 145/20 146/2
146/22 147/11 147/17
148/16 150/6 152/10
153/13 155/3 157/5
158/17 160/25 162/3
164/13 166/20 167/2
169/14 169/22 171/10)
173/6 175/1
become [3] 5/21
46/16 108/20
becomes [1] 80/9
been [132] 2/10 2/14
3/11 3/24 4/19 7/2 9/6
9/8 10/20 11/5 11/21
12/18 15/12 16/18
18/8 21/9 22/14 23/9
24/11 28/19 31/18
32/3 33/5 34/17 36/9
36/11 36/12 37/2
39/12 40/10 41/16
46/2 46/7 46/8 46/10
52/1 52/12 54/4 54/9
67/11 68/2 68/7 68/8
76/1 76/16 76/20
80/14 81/17 81/18
83/13 83/21 85/7
85/13 85/15 87/12
88/14 88/18 88/24
89/18 94/14 94/15
94/17 96/13 97/5
105/12 106/24 108/11
114/24 115/4 122/23
124/4 125/2 128/12
128/13 129/9 131/4
131/7 132/15 133/21
135/6 135/16 138/4
140/2 141/11 141/13
143/13 143/18 144/2
144/17 149/8 153/3
153/8 153/9 153/21
157/17 160/8 160/25
161/12 161/13 163/3
165/19 166/4 166/10
169/6 169/19 169/19
172/15
BEER [9] 1/4 1/5
23/5 24/8 91/3 149/18
150/23 174/16 176/4
before [32] 1/8 2/16
6/3 6/24 9/21 16/17
24/8 76/25 77/14
77/19 80/3 80/11 84/2
84/20 85/15 92/16
93/4 96/5 96/14 97/23
107/24 109/10 118/5
123/1 129/20 130/21
131/13 135/13 141/15)
151/23 168/8 175/6
beforehand [1]
158/15
beginning [6] 19/17
62/4 65/12 133/13
137/8 144/25
begins [2] 132/9
165/23
behalf [1] 93/3
behind [1] 87/17
being [92] 8/4 9/7
9/16 9/20 10/25 11/7
12/4 12/6 12/7 12/12
13/19 14/16 14/17
18/2 19/10 20/17 27/6
28/14 28/25 29/21
43/10 44/2 44/18 45/5
46/11 47/4 50/9 50/25
68/9 70/3 74/10 75/11
29/22 30/10 30/17
53/2 53/8 55/2 55/4
63/16 67/7 71/12
71/16 74/7 74/17
54/10 54/11 54/14 75/20 80/10 86/1 87/6I 108/17
61/22 62/3 65/13 89/12 93/5 95/2 97/17Iboilerplate [1]
65/15 65/16 65/23 102/23 103/1 107/24 I 156/14
66/19 66/23 67/4 67/7I 110/20 112/7 114/15 Ibold [1] 113/4
118/24 119/8 121/3
121/5 121/9 122/18
122/25 123/7 123/16
127/14 131/3 139/4
140/13 140/20 145/8
146/3 147/2 152/20
152/22 156/16 157/9
169/2 169/9 173/4
174/3 174/4
79/20 119/10 138/11
146/6 169/24
believe [38] 2/14
4/13 12/13 13/12
21/23 22/16 22/22
23/25 28/15 32/10
32/11 41/10 41/13
42/7 46/13 52/5 54/3
81/25 90/12 97/13
97/19 97/22 100/24
103/16 107/4 111/1
121/25 123/5 127/11
137/8 147/13 155/10
162/22 169/21
believed [5] 41/3
120/1 121/24 140/13
147/5
below [13] 7/4 25/16
36/5 37/10 38/2 80/5
105/8 106/6 126/6
132/24 134/14 144/24
172/1
best [4] 107/17
138/11 146/5 169/23
better [4] 161/20
162/8 166/21 167/3
between [21] 9/12
12/3 20/18 33/17 34/3
36/17 38/21 41/12
54/8 71/12 74/14 80/8
84/16 85/23 101/20
102/20 102/21 139/17]
143/23 162/13 165/3
beyond [3] 10/23
16/8 26/4
BIMS [2] 35/15 35/16
bit [13] 51/8 56/8
72/2 125/24 131/8
132/25 133/6 135/10
136/21 137/17 141/3
30/20 32/25 34/5 36/8
38/9 38/11 42/17 43/7
45/7 47/16 47/21 48/9
57/6 59/9 60/18 63/12
145/10 145/14 145/24
belief [7] 53/21 74/19
69/7 70/3 74/16 79/18
141/6 168/14
bits [3] 19/23 75/16
149/23
black [2] 20/18
135/14
blame [1] 154/5
blue [1] 107/12
body [2] 64/16
bolt [1] 66/25
Bond [7] 1/11 1/16
2/3 3/2 10/16 18/1
19/7
both [19] 5/10 41/12
73/17 75/9 76/24
81/11 88/10 96/17
105/4 121/4 121/9
122/23 124/20 155/4
162/12
bottom [7] 6/6 24/18
28/9 55/13 96/1 97/3
136/23
Bounds [2] 105/1
109/9
box [1] 30/14
brackets [3] 153/24
154/7 166/16
Bracknell [11] 55/16
55/18 56/14 56/17
70/9 70/15 70/23 71/3}
71/12 71/17 72/11
branch [64] 25/15
25/17 26/9 28/16
28/24 29/7 30/23
34/13 37/13 40/6
40/16 43/7 45/12
45/16 45/19 46/17
51/18 51/19 52/15
52/16 52/20 53/6
53/23 54/13 55/21
55/25 56/3 56/25 57/1
57/18 57/25 58/6 58/6
67/12 67/14 68/3 68/9)
68/17 71/7 72/9 76/21
77/7 T7I10 79/4 79/6
81/5 81/13 81/17
87/13 88/3 89/17
102/20 103/5 105/10
105/10 105/24 107/11
107/12 139/25 142/8
143/3 143/11 143/25
144/2
branch's [1] 43/11
branches [9] 26/6
26/10 35/20 38/13
54/6 57/2 88/15
102/17 120/12
break [11] 36/23 49/9)
49/11 49/11 49/16
141/15 150/21 174/13
42/7 43/13 54/17 69/7
174/15 174/17 174/18)
Brian [11] 4/15 5/1
5/12 6/7 6/9 24/4
124/20 151/4 156/11
162/14 162/15
brief [4] 105/8 128/7
128/24 129/18
briefed [1] 16/18
briefing [5] 94/20
95/7 115/20 118/8
138/23
briefly [1] 16/20
bring [1] 108/12
broad [3] 115/25
116/12 116/13
broader [1] 143/19
broadly [3] 32/16
142/1 170/6
brought [2] 123/25
140/24
bug [17] 24/25 25/4
25/13 25/18 25/23
26/19 26/22 27/11
27/22 29/2 30/5 33/4
37/18 38/25 39/4
100/14 100/17
bugs [17] 1/8 24/24
38/18 55/19 56/18
93/20 94/1 101/17
116/14 116/17 116/20)
116/24 117/4 117/10
117/13 117/18 119/20}
built [3] 99/1 99/9
116/7
business [4] 48/19
121/11 121/13 150/4
busy [1] 16/6
but [174] 3/10 5/13
5/18 7/24 8/2 8/8 8/18I
10/22 11/4 11/11
11/24 12/21 12/25
13/8 13/12 13/15
14/23 15/3 15/8 15/10
17/1 17/7 17/24 18/23)
19/10 20/10 23/2 24/3}
25/12 25/23 26/10
27/2 27/19 28/13 29/8I
29/24 30/19 32/2 32/6)
33/4 35/16 36/12
36/14 37/4 37/10 38/8I
38/22 39/8 39/18
40/12 41/12 42/16
43/18 44/21 45/14
46/10 46/14 46/19
47/7 47/12 47/16
47/23 48/7 48/19
48/25 51/8 51/20 52/4)
52/6 53/7 53/17 53/24I
54/15 54/23 57/6 57/9I
58/17 58/19 59/6 59/8
61/7 63/12 64/3 67/16I
68/5 68/10 68/23
69/22 69/24 72/2
72/15 76/1 79/19
(48) banking... - but
B
but... [81] 82/17
82/20 83/11 85/8
86/15 87/1 88/20
89/21 90/24 92/10
92/14 92/23 93/3
93/17 96/14 97/5
97/14 98/10 101/5
103/10 103/15 104/23}
105/4 108/14 108/18
109/3 110/3 113/3
113/24 114/16 114/19
115/17 116/2 116/3
119/6 119/25 120/4
120/6 120/14 121/20
122/4 123/17 123/19
125/8 127/5 128/20
129/8 130/12 131/2
131/3 131/6 131/22
135/12 136/3 138/2
147/23 148/2 149/1
149/14 149/17 155/10}
157/17 158/11 159/4
159/11 160/11 161/23}
161/24 162/10 163/6
165/10 165/14 167/7
167/12 167/14 169/15
171/21 172/9 173/25
174/18 175/5
Byfleet [1] 32/8
bypass [2] 117/17
117/19
bypassed [1] 117/12
Cc
call [11] 32/3 53/24
86/23 106/11 106/20
107/5 107/9 108/2
108/3 115/10 125/8
called [14] 7/7 7/22
25/10 29/7 31/24
35/14 35/15 39/7
39/10 41/10 76/25
92/7 92/18 160/18
Callendar [19] 24/25
25/4 25/17 26/9 26/19)
26/22 26/24 27/17
29/2 29/14 29/25 30/4
30/6 31/6 31/18 31/19
33/10 37/13 100/14
calm [1] 137/1
calming [2] 136/20
136/21
came [6] 4/6 4/17
17/1 25/22 26/25
127/13
can [173] 1/23 4/2
4/17 5/24 7/6 7/8 7/13
7/20 8/11 8/18 8/21
8/25 9/1 9/3 9/4 10/1
10/8 12/22 14/9 17/13)
17/15 18/25 19/12
19/15 20/10 21/12
21/14 21/25 23/5
23/14 24/6 24/7 24/13
24/22 24/24 25/4
26/13 26/14 27/24
27/24 28/5 28/7 28/9
31/19 33/8 33/12
36/22 39/19 39/22
42/22 49/11 49/19
49/21 49/24 55/7
55/12 59/19 59/20
59/23 60/14 60/21
62/12 62/15 63/18
64/18 65/11 65/15
65/18 65/23 66/19
70/4 71/14 72/18
72/20 72/22 73/2 76/8
79/23 79/25 85/21
85/24 86/16 87/16
90/17 90/20 91/15
92/15 95/12 95/13
95/15 95/16 95/21
95/21 95/25 96/1
96/16 98/4 98/4 101/5
102/4 102/13 103/8
104/17 110/14 111/8
111/13 111/17 113/4
117/17 123/21 123/25)
124/8 124/9 124/10
124/12 125/11 125/14)
125/21 125/23 126/16)
126/18 127/4 128/20
130/21 131/1 131/12
131/13 131/22 131/23)
131/23 132/21 133/11
133/11 133/12 134/9
134/16 134/22 135/1
135/3 135/4 135/15
136/12 137/17 141/15)
142/2 144/6 145/15
148/10 149/25 150/25)
152/2 152/4 152/25
154/23 156/13 156/21
157/14 157/15 157/18)
157/20 157/21 158/22)
159/9 162/1 162/12
162/12 163/8 164/19
165/21 166/21 168/11
169/17 171/17
can't [42] 35/7 35/16
37/4 45/3 45/8 46/14
52/6 52/14 57/10
59/13 59/18 61/17
63/17 71/21 71/25
72/14 74/2 78/1 79/19)
97/1 97/16 98/11
109/2 111/25 112/24
113/2 114/19 127/11
135/12 141/10 141/13)
147/5 149/22 159/7
161/25 162/2 163/24
164/4 164/9 165/4
165/14 171/9
cannot [5] 5/16 43/23)
67/15 69/23 131/20
capture [1] 161/5
captured [2] 160/8
162/24
carefully [2] 13/17
13/24
carried [5] 45/19
45/25 53/5 162/16
163/9
carries [1] 54/2
carry [6] 1/8 2/1
21/17 29/11 30/13
41/5
carrying [1] 59/4
case [79] 3/10 3/10
4/6 4/20 7/21 7/23 9/4
12/14 13/2 13/3 13/11
13/13 13/22 15/3 15/3
16/16 17/1 17/3 25/16
25/21 27/5 31/7 32/19
32/19 33/20 33/22
35/1 39/25 40/20
45/24 54/18 58/24
60/25 63/9 64/24 65/6
65/10 65/13 65/19
65/21 66/24 67/16
69/24 73/2 75/6 76/19}
79/15 81/2 83/11
83/22 84/8 89/12
98/15 98/21 98/21
99/4 105/17 106/1
122/25 123/22 123/25
124/2 124/9 128/19
129/12 129/12 129/22
131/2 131/3 136/18
138/24 140/11 140/12)
144/7 144/18 151/1
163/2 163/4 174/11
case-specific [1]
54/18
cases [25] 3/11 15/4
15/12 15/20 15/23
16/9 16/23 18/10 27/2I
32/17 39/6 47/13
73/17 75/9 82/5 82/8
82/13 82/19 83/4 84/4]
87/23 87/23 105/14
128/5 167/16
casework [2] 156/8
166/24
cash [4] 34/2 168/19
168/23 169/3
Castleton [9] 1/19
3/10 5/9 5/20 13/3
13/11 13/13 15/3
24/16
Castleton's [5] 4/6
4/20 6/12 7/16 45/24
categorically [3] 35/3}
67/15 69/23
caught [1] 35/4
cause [12] 28/23
30/16 31/18 31/24
37/20 42/14 64/10
82/10 82/21 83/10
83/15 83/15
caused [6] 25/14
25/18 25/24 29/8 50/5)
92/23
causes [1] 82/24
causing [2] 63/2
152/4
cent [4] 29/16 37/4
135/8 135/12
central [2] 102/18
168/22
centrally [1] 103/5
centre [5] 38/2 75/12
75/19 75/20 102/19
centres [1] 102/21
certain [3] 97/8
107/12 135/12
certainly [14] 2/9 2/9
3/10 14/23 15/4 15/12)
15/20 27/16 34/22
43/17 52/11 83/23
148/9 151/18
cetera [2] 62/16
108/20
chain [11] 28/9 29/13
36/1 37/15 55/4 85/23
109/9 131/12 134/23
135/9 171/17
challenges [2] 66/11
140/9
challenging [1] 88/15)
Chambers [11] 31/10
32/23 33/9 34/20 35/3)
35/23 42/6 46/18
47/23 52/22 69/7
Chambers' [2] 27/25
42/23
change [17] 37/4
44/2 48/8 48/9 67/12
68/19 69/2 78/23
80/15 90/1 90/11
111/23 157/20 168/19)
168/24 169/3 174/6
changed [3] 73/5
73/12 81/23
changes [8] 50/7
69/5 111/20 153/13
156/8 157/17 157/19
166/10
changing [1] 56/9
charged [1] 124/5
chat [2] 76/6 78/12
chats [1] 68/25
check [4] 29/19
29/21 31/1 83/23
checked [3] 32/9
83/25 103/15
checking [2] 29/23
85/19
checks [3] 32/13
61/5 85/8
Chesterfield [1] 72/8
choice [4] 117/19
154/2 166/15 173/20
chosen [1] 139/23
chronology [1]
150/25
circumstances [13]
25/25 26/1 26/23 27/9
27/20 30/16 46/24
87/20 122/11 128/19
130/1 140/5 172/23
cited [1] 64/15
cites [1] 70/6
civil [1] 27/5
claim [3] 105/9
105/20 154/4
claimed [1] 79/8
claiming [2] 20/5
105/22
classified [1] 18/3
clear [17] 43/20 72/3
76/16 80/7 80/23 82/9
83/8 84/25 89/9
139/12 143/23 154/21
155/4 165/11 167/23
169/2 171/23
clearer [4] 34/23
133/20 134/2 152/2
clearing [4] 129/2
129/19 129/24 130/14I
clearly [34] 2/12 2/19
3/3 10/18 10/22 12/4
12/21 15/6 16/7 16/15}
16/19 16/25 18/11
21/11 34/9 37/9 82/5
82/17 83/4 123/19
127/4 131/3 136/1
136/12 141/10 155/3
160/10 162/1 162/10
167/2 167/8 169/16
173/25 174/8
clerk [1] 169/3
closed [1] 8/25
closing [1] 143/17
code [6] 128/15
128/18 132/10 133/18)
167/21 168/21
codes [6] 128/14
128/23 133/22 134/1
168/14 168/17
cognisant [1] 73/3
collating [1] 147/14
collecting [2] 56/3
56/8
colours [1] 20/18
column [3] 89/8
132/6 134/13
combination [1]
25/20
come [24] 2/16 13/14
28/3 28/11 38/14
41/18 48/23 61/18
66/7 77/3 77/9 78/23
81/8 85/11 90/20
103/17 109/10 110/14)
135/13 138/7 148/5
148/11 159/14 162/12!
(49) but... - come
Cc
comeback [2] 83/3
83/6
comes [2] 26/21
48/13
comfortably [1]
174/13
coming [2] 18/23
159/8
commencement [1]
7712
commensurate [4]
113/9 113/14 114/5
121/1
comment [12] 26/15
43/17 67/7 71/16
82/10 82/21 106/14
133/10 137/15 143/13
148/6 171/7
commented [1]
22/10
commenting [1]
78/10
comments [8] 38/16
97/4 133/8 151/11
153/24 153/25 157/7
157/8
Commercial [2]
97/10 107/24
commercially [1]
101/15
commission [1]
119/22
commissioned [1]
114/3
commissioning [1]
119/15
committed [6] 80/9
80/11 84/17 84/21
84/22 85/14
committing [1] 129/3
common [1] 40/5
comms [1] 89/22
communication [2]
24/4 50/1
communications [1]
144/7
companion [5] 93/12
93/16 112/10 112/13
112/20
company [1] 131/21
compared [1] 105/4
compiled [4] 20/13
20/14 20/21 20/22
compiling [1] 106/8
complete [3] 19/21
20/3 101/2
completed [1] 107/5
completing [1]
107/18
compliance [4]
113/11 114/12 114/14)
115/1
complicated [2]
85/22 89/19
complied [3] 13/2
13/9 22/19
comply [4] 14/21
18/15 19/8 22/18
compounded [3]
34/6 36/10 37/3
computer [23] 76/14
77/23 138/12 144/22
145/7 145/13 145/23
146/3 146/6 146/9
146/11 148/17 148/22)
149/9 149/12 169/23
169/24 170/4 170/8
170/14 170/16 171/41
171/2
computers [6]
144/14 145/4 147/2
147/13 147/19 147/25)
con [2] 126/4 126/25
conceded [1] 105/17
concentrate [1]
138/8
concentrated [1]
12/9
concentrating [3]
10/24 13/21 16/6
concept [1] 17/10
concern [4] 87/17
89/11 133/6 144/19
concerned [7] 50/8
83/23 132/14 136/1
136/12 143/20 171/6
concerning [5]
142/13 142/24 159/23)
160/19 164/24
concerns [7] 71/8
89/6 94/20 95/9
101/25 123/22 173/15)
concluded [1] 124/3
conclusions [2] 81/4
81/12
conduct [4] 32/21
70/10 118/20 155/11
conference [12] 3/16
3/21 3/24 6/3 19/18
24/20 106/11 106/20
107/5 107/9 108/2
108/3
confidence [4] 97/10
113/8 114/4 120/24
confident [1] 85/14
confirm [2] 86/9
86/16
confirmation [1]
86/11
confirmed [2] 106/18
106/21
confusion [3] 37/21
64/10 171/22
connect [4] 55/24
57/17 57/24 58/5
connection [3] 9/22
31/13 59/17
consent [5] 40/7
55/23 57/12 57/16
103/20
consider [6] 65/11
81/1 81/11 117/13
118/14 155/11
considerable [1]
37/21
consideration [1]
117/16
considered [7] 27/6
40/10 40/24 80/14
83/20 136/11 140/7
considering [2]
106/2 151/14
consistent [2] 47/17
76/18
consistently [2]
43/18 44/11
constrained [1]
123/11
constructed [1] 2/1
consultants [1]
112/4
consulted [2] 104/1
104/4
contacted [1] 39/16
contain [3] 22/3
43/13 139/21
contained [1] 45/16
contains [2] 23/7
65/20
contemplation [2]
97/18 98/1
content [5] 23/7
104/5 146/12 157/13
167/6
contents [7] 13/22
92/16 104/1 111/4
151/22 152/8 173/10
context [9] 21/10
28/11 40/14 43/4
59/10 72/4 72/10 74/7
139/18
contingent [1] 25/25
continually [1] 30/11
continuation [1]
29/25
continue [2] 103/2
116/5
continued [5] 1/3 1/4
30/23 176/2 176/4
continues [4] 62/17
71/1 160/2 172/20
continuing [3] 30/4
30/9 168/6
contract [5] 101/19
113/11 114/12 114/14
115/1
contradicts [1] 93/4
contrary [1] 120/13
contribute [1] 11/20
contributor [1] 60/2
control [1] 62/2
controlled [3] 41/2
41/25 61/24
controlling [1] 61/10
controls [9] 61/9
62/22 113/9 114/5
115/4 118/17 118/19
118/21 120/25
conversation [8]
56/22 59/10 68/23
71/24 78/1 78/5 78/25)
126/24
conversations [9]
42/4 47/6 47/8 57/10
68/20 74/1 74/3 75/3
79/19
cope [1] 167/13
copied [5] 35/23
64/23 108/21 109/3
151/4
copies [1] 133/3
copy [10] 1/23 2/4
7/8 7/15 13/7 65/5
65/7 88/18 131/20
133/10
core [1] 121/9
correct [54] 2/22
6/21 9/23 20/25 22/6
23/11 23/25 27/7
27/23 31/9 31/12 33/7
37/25 39/3 42/2 53/19
54/5 60/3 60/11 66/6
67/2 75/14 78/16
82/12 82/15 85/12
91/10 92/3 92/5 93/8
95/18 95/19 95/24
96/24 107/7 107/16
110/18 114/22 119/5
119/7 119/15 120/15
124/5 130/13 138/17
139/2 139/9 139/19
142/19 146/4 160/13
161/19 162/25 165/16}
corrected [3] 22/12
76/24 77/2
correcting [1] 57/5
correction [6] 35/11
35/12 44/8 44/13
44/18 122/15
corrections [3] 40/4
40/17 43/18
corrective [2] 43/10
43/14
correctly [1] 171/5
correspondence [10]
46/21 47/1 47/11
47/18 57/7 58/11 59/1
73/25 74/5 79/21
cost [4] 54/12
could [77] 11/20
18/22 22/11 28/23
34/6 35/9 37/23 40/6
40/7 40/22 41/15
45/15 46/10 46/19
50/1 51/15 51/18 53/2
53/7 53/9 53/13 55/24I
57/17 57/24 58/5
59/14 69/11 70/10
7113 72/7 73/12 77/7
79/4 83/15 85/14
89/22 90/4 101/16
103/24 110/7 110/8
114/8 116/25 117/2
119/2 133/5 134/7
134/18 136/1 136/14
136/15 137/6 137/11
140/1 140/4 141/6
143/9 143/13 143/18
144/19 144/22 146/14)
146/23 148/7 148/15
148/16 150/13 151/18)
151/24 152/13 158/13)
158/19 161/22 164/13)
164/16 165/8 167/13
couldn't [9] 51/10
54/13 82/10 92/22
98/20 147/6 147/11
150/5 165/7
counter [32] 26/11
43/17 43/19 44/7
44/12 44/17 45/14
46/22 46/25 47/13
47/122 47/25 48/6
48/10 48/16 48/17
50/3 51/11 52/22 53/1
54/11 61/15 73/25
74/5 75/13 75/18
76/14 76/22 77/23
79/22 118/4 169/3
counters [8] 37/18
50/23 50/23 52/23
60/6 61/11 61/20
62/11
couple [8] 16/8 19/18
21/11 25/5 86/10
108/7 134/7 159/10
course [4] 34/19
40/19 119/21 150/18
court [29] 23/24
25/11 33/20 54/7 55/4
75/1 75/1 78/14 87/18)
87/23 87/24 88/10
89/3 105/16 115/7
115/13 115/24 122/22)
122/23 123/3 123/11
151/18 151/23 152/14)
155/18 159/1 159/2
167/1 168/9
courts [3] 69/19
123/8 123/17
cover [7] 49/5 93/20
99/6 101/11 111/2
133/25 165/6
covered [2] 94/3
111/2
covering [7] 9/10
11/8 22/23 94/2 123/5)
125/8 155/4
(60) comeback - covering
Cc
covers [1] 99/5
Craib [1] 107/23
Craigpark [3] 28/16
29/5 29/8
create [1] 161/4
created [5] 40/2
96/11 111/18 160/7
160/8
creating [2] 25/12
127/18
Credence [1] 80/22
criminal [6] 69/19
84/4 121/5 140/23
151/23 174/3
critical [1] 121/15
criticised [1] 66/20
criticisms [1] 65/16
cross [1] 161/3
Crown [4] 151/23
155/18 167/1 168/9
current [1] 62/18
currently [2] 66/11
113/7
customer [5] 38/21
39/11 74/11 103/2
167/18
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136/6 153/3
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data [194]
database [1] 50/4
date [4] 63/19 92/10
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100/10 100/22 101/3
101/9 101/17 102/1
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examples [3] 21/14
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170/12 172/10
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20/16 21/7 25/16 39/8
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explicitly [3] 82/14
114/7 114/19
exposes [1] 62/23
expressed [3] 10/19
12/24 173/15
extent [2] 39/4 55/3
external [2] 106/23
112/3
externally [2] 40/6
76/21
extra [6] 37/2 43/10
87/19 89/7 125/12
126/16
extract [10] 5/6 6/12
6/16 7/18 32/8 40/1
73/19 75/9 90/5 126/5
extracted [27] 28/25
144/20 144/22 150/7
150/9 159/20 159/23
159/25 160/13 160/14,
160/19 160/20 161/1
161/14 161/15 162/7
163/4 163/18 164/8
164/24 164/25 165/7
165/11 165/13 165/14}
172/18 173/8
extracting [1] 162/23
extraction [3] 143/14
148/2 161/17
extracts [5] 64/15
68/10 71/5 163/16
164/11
F
faced [1] 37/17
facility [3] 53/22 54/4
54/19
fact [51] 9/1 9/16
10/15 10/24 12/12
17/9 17/11 18/11 19/1
23/1 23/6 23/13 23/23
23/25 24/4 29/5 35/11
40/17 44/12 45/19
51/21 52/19 53/5
53/18 67/19 74/3
79/17 84/6 86/25
87/25 88/20 94/12
96/25 107/15 108/16
110/3 118/22 119/4
119/24 120/23 121/4
124/4 127/21 135/25
142/18 158/2 164/7
164/10 164/20 165/9
165/12
factors [2] 25/14
25/20
facts [2] 10/7 21/23
factual [9] 22/12 23/7
106/14 138/24 139/17,
140/11 140/18 140/20}
141/6
fail [2] 50/5 101/9
failing [2] 30/12
104/12
fails [1] 105/9
failure [30] 85/20
87/5 87/9 89/18 89/22
92/21 99/2 100/8
100/22 107/13 128/13
128/16 132/17 133/20
133/21 136/2 136/7
136/8 136/13 136/16
136/17 136/25 151/12)
152/3 153/9 153/21
154/8 155/4 166/6
173/2
failure’ [2] 132/14
132/16
failures [22] 100/4
100/10 100/12 101/4
102/2 112/14 112/15
133/7 135/23 151/19
153/10 153/22 154/3
167/10 167/13 167/15}
167/17 173/4 173/12
173/17 173/17 173/23)
failures’ [1] 134/17
fair [1] 99/22
fairly [10] 33/18
50/18 50/19 66/18
89/19 96/15 105/4
107/20 110/24 116/13)
fairness [1] 19/13
Falkirk [2] 25/18
37/13
Falkirk’ [1] 25/11
false [1] 52/23
far [6] 27/5 27/17
50/8 62/12 90/9 171/5I
fault [2] 160/17
171/25
faults [1] 122/2
features [2] 102/18
103/4
feed [1] 8/13
feel [6] 27/7 66/16
108/14 135/1 137/6
137/11
felt [11] 11/20 69/22
82/23 85/2 119/23
120/19 130/2 136/4
152/2 152/6 160/12
few [6] 6/14 29/6
33/25 39/6 47/12
88/14
fictitious [7] 44/7
44/11 44/16 44/23
44/25 45/5 48/17
figure [1] 52/4
figures [1] 37/18
files [4] 56/3 56/8
57/15 86/1
fill [1] 20/24
filtered [5] 45/17
45/23 46/7 52/17 54/7
final [6] 78/18 96/7
158/24 162/6 165/5
168/11
finalised [1] 96/12
financial [9] 62/25
128/11 153/7 166/3
167/21 167/24 168/15}
168/18 168/22
find [10] 36/22 61/24
63/10 64/13 86/23
120/5 131/8 131/20
133/11 133/11
fine [5] 23/12 49/13
91/16 174/22 175/9
(63) entered - fine
gerprint [1] 46/6
ish [4] 174/13
ished [2] 107/23
134/21
firm [1] 112/3
first [47] 4/6 4/20 6/6
8/21 9/1 9/1 14/9
20/16 27/4 29/7 44/2
63/23 64/21 76/12
78/4 78/19 88/6 91/1
91/4 91/25 92/17 96/6
96/19 102/10 102/11
107/2 111/18 131/2
135/5 135/15 136/4
136/6 138/8 138/9
144/13 145/3 145/12
146/15 146/25 147/8
147/19 148/13 148/15
149/16 151/2 163/8
170/6
firstly [4] 10/15 41/1
77/21 92/17
Fis [2] 167/19 167/20
fit [2] 119/4 134/15
fixed [3] 26/1 27/15
34/14
fixes [1] 39/5
focus [9] 11/5 101/3
101/12 101/14 101/23
115/12 117/8 117/17
117/20
focused [1] 11/15
folks [1] 109/12
follow [1] 45/17
followed [1] 76/3
following [17] 10/25
11/2 36/12 62/24
66/22 68/7 70/5 71/5
73/10 87/5 89/18
109/12 125/1 128/6
129/18 168/4 175/11
following." [1] 65/15
follows [4] 19/9 70/8
77120 141/25
font [1] 157/23
foot [7] 5/23 19/15
63/20 64/19 95/25
111/13 132/9
footprint [2] 50/24
50/25
forgotten [1] 16/20
form [7] 8/15 12/14
59/2 69/10 130/19
147/12 150/3
formal [5] 14/8 20/21
98/15 98/22 112/2
formalised [1] 38/17
formally [1] 106/24
format [2] 20/20
22/13
formatting [2] 129/10)
135/21
formed [1] 121/9
forward [5] 76/8 98/4
134/8 156/25 171/24
forwarded [1] 6/22
forwards [5] 33/8
109/8 117/24 132/20
157/16
found [11] 32/10
32/12 33/2 33/19
35/17 36/1 59/6 71/22
77/10 120/6 120/9
founded [4] 18/14
four [3] 16/19 145/1
158/14
four years [1] 16/19
fourth [2] 49/5 96/22
fourthly [1] 44/21
Fraser [1] 25/9
Fraser's [1] 80/19
fraud [1] 62/25
fraudulent [1] 105/15
freelance [1] 74/13
freeze [1] 26/8
frequency [1] 52/9
frequent [1] 61/5
frequently [5] 42/9
50/15 50/18 50/19
52/4
Friday [3] 107/5
108/1 108/3
frog [1] 91/1
FUJ00080526 [1]
95/14
FUJ00080534 [1]
111/9
FUJ00083712 [1]
28/5
FUJ00083775 [1]
33/8
FUJ00087100 [1]
72/18
FUJ00088036 [1]
59/20
FUJ00089535 [1]
63/18
FUJ00122203 [2]
124/9 131/12
FUJ00122204 [1]
135/4
FUJ00122210 [1]
151/2
FUJ00122211 [1]
152/25
FUJ00122216 [3]
157/16 164/15 165/20)
FUJ00122229 [1]
163/11
FUJ00122230 [1]
162/13
FUJ00122237 [3]
158/23 164/19 168/12)
FUJ00122283 [1]
19/13
FUJ00122284 [1]
20/11
FUJ00152573 [3]
1/24 10/2 12/23
FUJ00152582 [1]
125/23
FUJ00152587 [2]
156/21 171/17
FUJ00152601 [3] 6/5
8/12 11/9
FUJ00152602 [1]
7/20
FUJ00156064 [1]
104/17
Fujitsu [72] 1/16 1/17
1/18 2/3 13/2 13/19
14/16 14/20 18/18
19/19 30/24 33/17
39/9 40/11 40/13
40/19 55/16 55/20
56/25 57/24 58/5
59/20 62/23 70/25
72/12 73/5 74/10
74/15 79/4 81/24 84/1
90/12 93/2 93/14
93/21 94/4 96/17
96/20 98/15 98/22
100/5 101/16 103/7
103/23 104/4 104/13
105/16 106/7 106/13
106/18 106/22 106/25
107/10 108/4 112/23
113/6 114/3 114/13
114/25 115/21 120/18
122/16 124/11 124/12
140/6 141/23 143/2
143/18 144/5 150/4
156/7 174/2
Fujitsu's [5] 3/16
107/6 130/23 142/12
142/23
fulfil [1] 111/5
full [10] 4/4 30/15
43/15 89/14 89/15
89/25 91/20 101/2
101/25 140/21
fully [1] 88/9
function [3] 33/15
54/20 161/18
functionality [1]
53/14
functioning [1]
118/22
functions [2] 59/5
60/16
further [20] 4/23 22/2
24/12 29/9 32/13 34/7
35/22 51/23 65/4 65/8
72/19 86/17 103/6
108/4 108/7 132/19
134/19 136/3 136/24
156/24
future [1] 109/1
Gaerwen [1] 172/25
gain [2] 63/15 105/25
GARETH [14] 1/3
33/19 55/14 55/20
64/3 64/9 65/2 107/17)
126/3 132/23 134/11
151/15 171/25 176/2
Gareth's [3] 36/5
171/24 171/25
gateway [1] 50/2
gave [13] 7/19 22/13
43/5 63/8 79/11 92/24
100/21 102/22 104/7
109/23 111/1 114/2
175/2
Gavin [3] 105/1 105/7I
109/9
general [15] 38/8
39/6 39/8 58/12 60/14)
67/4 74/25 76/6 79/17,
80/25 81/1 83/1 92/15}
94/7 172/23
generally [6] 34/1
47/15 58/17 90/21
135/13 143/11
generate [3] 55/25
57/18 57/25
generated [13] 80/22
86/12 87/2 87/3 87/4
87/11 89/10 128/9
128/19 128/20 140/2
153/5 166/1
generating [4] 58/3
58/4 85/18 85/18
generic [6] 54/18
66/4 66/7 67/1 124/11
134/1
generous [1] 91/13
genuine [3] 79/14
79/20 167/10
get [13] 30/10 39/17
50/23 64/20 69/2
T7I17 89/20 97/6
101/14 114/17 140/4
151/17 155/13
gets [1] 80/9
getting [5] 27/4 32/17I
76/4 129/10 152/1
GlJ [2] 132/6 158/3
GIJ/03 [1] 158/3
GlJ/1 [1] 132/6
give [19] 4/10 5/2 5/7
6/2 22/7 23/24 32/19
33/4 42/19 42/20
42/21 62/2 77/5 83/6
89/13 128/22 136/14
146/17 147/23
given [22] 6/24 22/8
38/1 42/7 62/21 76/11
81/23 82/4 83/13
87/24 100/24 104/22
107/13 117/16 128/18}
142/8 143/3 143/10
143/25 146/17 1714/7
172/10
giving [13] 3/20 18/2
22/21 33/3 63/4 83/1
87/20 89/15 134/7
139/14 139/17 139/17)
140/18
GLO [1] 78/11
go [70] 1/10 5/23
6/22 10/1 11/8 12/7
12/22 13/24 14/4
14/10 19/3 19/16
19/21 24/6 24/7 24/24
27/24 28/8 32/20 33/8)
36/25 42/25 43/3
49/24 50/1 59/19
63/23 64/19 66/14
74/18 85/21 88/5 89/4)
95/19 96/4 97/9 98/4
99/19 102/4 103/8
111/13 111/16 111/19)
113/4 114/9 116/25
117/24 120/22 125/23)
128/2 130/21 131/12
131/13 131/23 132/19)
133/12 134/9 137/3
137/4 149/5 149/25
152/25 156/2 156/13
156/21 164/14 165/20)
165/21 171/17 174/2
Godeseth [7] 76/11
76/24 77/5 77/10
77/21 78/13 79/12
goes [1] 117/14
going [33] 2/17 4/4
9/14 9/18 10/4 10/6
23/6 28/7 28/10 32/3
36/24 51/9 64/20 66/7I
66/25 67/18 91/23
94/9 108/25 109/7
109/8 111/19 113/15
115/9 115/19 120/5
124/19 127/21 133/12)
136/3 137/3 144/25
152/3
gold [1] 80/20
gone [8] 16/5 35/19
38/15 51/14 51/15
74/13 108/24 124/15
good [6] 1/6 1/7
91/22 100/20 131/21
160/11
gory [1] 58/20
got [14] 2/7 10/12
29/10 85/16 91/1
92/11 93/13 111/25
137/22 137/24 138/3
138/4 158/18 172/9
Graham [10] 6/7 6/9
126/6 131/14 132/24
134/17 134/22 135/20)
136/12 140/10
Grant [2] 83/9 83/22
(64) fingerprint - Grant
G
130/17
Gray [1] 106/10
greater [6] 76/15
77/24 80/5 128/15
132/10 133/19
ground [1] 118/23
Group [4] 40/10
41/19 46/22 51/22
grouped [1] 25/9
groups [1] 106/6
guess [5] 32/6 75/6
119/16 167/25 168/3
guidance [3] 138/19
139/7 141/2
guilty [1] 109/15
H
hacks [1] 166/4
had [194]
hadn't [18] 9/8 10/23
47/4 47/7 54/15 62/3
82/9 85/15 101/21
120/8 120/9 120/13
137/23 138/3 142/17
142/21 160/9 166/18
haggle [2] 157/2
167/5
haggling [1] 157/12
half [3] 10/21 11/22
12/17
hand [17] 142/2
144/10 145/13 145/18)
147/9 147/10 149/6
158/23 160/16 161/21
162/2 162/6 162/8
164/22 165/20 168/12)
169/17
handed [1] 106/24
handle [2] 105/13
167/17
handler [1] 166/24
hands [3] 168/19
168/24 169/4
hangover [1] 29/1
happen [8] 40/7
82/17 83/5 85/9 89/22
113/20 113/22 114/21
happened [24] 13/22
17/4 19/12 25/17 32/7
37/12 59/3 67/15
69/24 77/16 84/25
113/19 114/16 114/18}
119/6 120/12 159/11
159/16 161/11 163/25}
165/3 165/12 169/10
169/15
happening [4] 59/6
120/21 130/1 164/5
happens [1] 108/11
happy [7] 19/24 93/1
103/15 129/24 154/19}
grateful [2] 126/9
169/16 173/25
hard [2] 26/2 36/14
harder [1] 128/20
hardware [6] 102/17
112/13 112/15
harm [1] 25/24
Harvey [2] 72/21
7415
has [57] 4/5 4/7
25/12 37/2 40/10
47/23 61/12 62/13
67/15 68/2 70/3 75/6
80/3 81/22 84/25
94/15 94/17 105/12
113/9 113/13 114/24
128/13 131/4 132/15
133/21 135/16 153/7
153/8 153/9 153/11
165/17 166/3 166/6
168/15 168/22 169/6
171/9 172/1
hasn't [4] 69/23
135/17 153/14 166/7
have [213]
haven't [2] 72/24
158/17
having [21] 11/25
40/1 51/4 71/18 72/16
76/20 77/25 78/5 78/8
82/21 82/24 83/11
93/14 112/2 117/20
136/13 147/12
hayfever [1] 91/2
HDCR [1] 64/7
he [76] 5/12 20/22
20/23 22/25 24/1 24/2
24/21 33/15 33/16
33/17 55/13 55/16
55/23 59/2 59/14 70/6)
70/7 71/1 72/21 74/8
74/9 74/10 76/11
77/13 77/19 77/20
78/3 78/10 78/13
92/24 92/25 96/25
104/7 104/8 104/9
104/10 104/11 105/2
106/14 108/6 108/9
108/12 108/14 108/14)
108/15 124/17 124/24)
127/5 130/2 130/18
136/15 151/9 151/15
152/1 152/2 152/5
152/8 152/24 153/11
153/14 153/16 153/18)
153/24 154/21 154/23)
154/25 155/3 155/4
107/13 109/20 110/25)
65/15 67/3 67/7 67/11
105/13 105/16 105/17;
106/24 108/11 108/16)
120/25 128/11 128/12,
153/12 153/16 153/18)
153/21 153/24 163/22)
16/18 16/20 29/5 36/4
167/2 167/3 169/16
172/5 172/5 172/20
173/17 173/18
he'd [5] 20/15 74/13
78/15 97/7 124/4
he's [5] 58/16 127/4
128/1 130/17 154/20
head [5] 55/15 56/14
72/15 74/10 106/3
header [1] 132/7
heading [4] 25/10
99/20 102/13 164/1
headings [1] 134/13
headquarters [1]
3/16
health [2] 100/20
143/25
hearing [1] 175/11
held [6] 30/17 38/21
86/10 138/15 148/20
170/2
Helen [3] 85/23 87/14
89/24
help [6] 35/8 39/7
65/23 85/25 108/18
134/16
Helpdesk [1] 38/12
Helpdesks [1] 38/6
helpful [1] 120/19
Henderson [4] 56/5
56/12 79/3 79/16
Henderson's [1] 55/8
her [10] 34/22 36/16
36/17 48/21 88/11
104/23 104/24 104/24)
134/7 134/9
here [33] 3/8 16/14
28/11 29/19 32/1
33/12 39/23 41/25
45/9 45/13 46/18
47/23 48/7 68/16
68/18 86/18 95/16
95/22 116/22 128/24
140/15 142/20 151/21
161/11 163/2 163/6
163/8 163/21 164/6
165/5 167/10 171/1
174/4
hers [1] 88/17
Hi [4] 132/23
high [5] 63/24 78/14
102/19 105/4 118/9
highlighted [4]
146/15 146/17 154/7
171/18
highlighting [1]
153/20
highly [4] 67/16
69/24 69/25 80/17
hijack [1] 51/18
hijacking [1] 52/15
him [31] 21/15 21/18
22/2 33/13 46/1 48/21
51/16 55/9 56/16
56/25 57/11 57/17
57/24 58/5 59/10
59/14 70/12 78/1 78/5)
78/8 79/3 79/7 79/12
79/16 97/5 108/13
131/16 155/1 155/13
156/22 172/5
hindsight [3] 42/16
54/22 63/7
his [42] 1/19 4/8 5/14
6/13 11/12 18/16
18/17 22/4 22/18
22/20 33/16 40/18
45/24 46/4 46/5 55/24
74/18 76/12 77/11
77/14 77/19 78/4
78/15 78/18 78/19
92/24 93/3 94/6
103/14 104/9 106/12
106/13 126/24 131/16)
133/5 133/16 155/11
155/20 166/14 169/13}
172/6 173/15
history [4] 95/21
111/17 138/24 140/11
Hmm [1] 28/1
hold [11] 70/15 88/5
88/5 89/24 101/7
103/2 138/3 138/4
147/10 147/11 170/2
homogeneous [2]
25/13 26/20
honestly [2] 18/24
147/5
Horizon [130] 5/10
5/14 5/19 6/13 11/12
12/8 19/5 21/4 21/7
25/8 52/3 52/9 55/15
60/23 62/21 63/5
65/17 67/3 67/5 73/15)
73/16 75/11 76/8
76/13 77/13 81/6
81/14 87/2 87/3 87/4
88/7 88/12 88/16
88/20 88/22 90/22
91/7 91/9 91/24 92/2
92/4 92/7 92/8 92/18
92/18 92/22 93/9 94/5
94/7 95/5 95/13 95/15
99/1 99/5 99/6 99/9
99/11 99/13 99/14
99/16 99/20 99/21
101/3 101/8 102/1
102/14 102/15 102/24}
103/10 103/11 104/8
104/10 105/9 105/12
105/22 106/14 107/11
110/17 110/21 110/23}
111/8 111/10 112/3
112/12 112/14 112/18
112/19 113/7 113/13
114/4 114/24 116/7
116/15 116/17 116/21
117/4 117/10 119/9
119/25 120/1 120/25
121/4 121/4 121/5
121/18 121/19 121/21
122/1 122/24 123/12
136/16 139/14 139/17
140/18 142/7 142/8
142/15 143/1 143/3
143/10 143/20 143/24)
148/14 148/17 148/21
148/22 149/10 157/3
171/3 171/4
Horizon's [2] 100/20
168/21
horses [1] 136/20
hosted [1] 106/11
hours [1] 48/19
House [1] 108/13
how [63] 4/6 5/13
7/11 11/11 21/8 25/23}
27/8 30/3 35/20 36/25
37/1 42/8 42/9 47/2
51/24 52/1 53/13 56/6I
59/14 71/8 71/8 72/13
83/1 83/2 85/14 88/23}
94/12 99/3 103/17
105/2 106/14 107/10
112/17 112/20 116/24I
118/10 118/14 118/25)
119/10 119/12 123/13)
125/12 125/14 125/20)
126/17 129/23 133/24I
134/3 135/11 140/3
140/5 141/10 141/14
152/24 154/10 154/10)
154/12 157/5 161/20
165/15 168/7 171/13
172/24
however [9] 5/20
10/8 67/9 68/12 73/17)
76/23 80/6 86/9
108/15
Hughie [3] 17/3
123/25 144/7
human [1] 4/17
hundreds [1] 30/7
hypothesis [3] 40/4
40/15 40/18
hypotheticals [1]
18/5
l accept [22] 2/18 3/5
9/11 10/10 14/7 15/17
16/13 37/10 37/19
37/22 48/22 51/21
54/15 74/19 85/8
109/3 116/3 119/23
123/17 162/10 163/6
163/24
lacted [1] 18/24
l actually [4] 29/9
127/15 127/18 140/3
l addressed [1] 40/3
lagree [4] 4/1 8/5
(55) grateful - 1 agree
l agree... [2] 56/13
161/23
lalmost [1] 14/23
lalso [5] 3/15 6/11
67/7 83/25 124/25
l always [2] 48/24
53/7
lam [4] 65/4 134/14
137/17 141/20
I apologise [1] 10/10
l appreciate [2]
68/16 171/21
l asked [3] 2/6 31/20
52/14
lassume [5] 33/23
73/1 154/1 158/10
160/5
lassumed [1] 88/16
lattach [1] 6/10
I became [1] 26/8
I believe [18] 2/14
22/16 32/10 32/11
41/10 41/13 42/7 52/5
54/3 69/7 70/3 74/16
81/25 97/13 100/24
111/14 123/5 127/11
I believed [4] 41/3
120/1 121/24 140/13
lcan [22] 4/17 9/4
18/25 24/13 36/22
59/23 62/12 65/15
65/23 86/16 87/16
101/5 124/9 127/4
134/22 135/1 136/12
144/6 145/15 152/2
152/4 159/9
I can't [35] 35/7
35/16 37/4 45/3 45/8
46/14 52/6 52/14
59/13 59/18 61/17
63/17 71/21 71/25
72/14 74/2 78/1 97/1
97/16 98/11 109/2
111/25 112/24 113/2
127/11 135/12 141/10}
141/13 149/22 159/7
161/25 162/2 164/9
165/14 171/9
I cannot [3] 5/16
43/23 67/15
I certainly [2] 2/9
148/9
I check [1] 83/23
I clearly [5] 15/6
123/19 141/10 167/8
174/18
I commented [1]
22/10
I could [6] 11/20
22/11 136/1 141/6
144/19 144/22
I couldn't [3] 92/22
147/6 147/11
I cover [1] 49/5
I covered [1] 111/2
I did [10] 15/7 22/10
26/15 34/23 44/2 84/2
101/23 165/15 165/15)
173/25
I didn't [29] 7/24
12/11 12/20 17/7 23/2
27/7 31/17 4119 42/17
53/7 54/21 59/8 61/21
62/3 63/13 69/13
69/16 76/2 94/11
104/23 122/4 122/18
124/6 139/4 147/17
149/13 155/16 167/7
174/18
Ido [5] 3/18 30/18
73/21 171/19 171/21
I don't [75] 4/13 5/11
5/20 12/13 12/19
13/12 19/10 21/9
21/19 22/22 23/25
27/12 28/13 30/17
30/21 36/19 36/21
38/20 38/23 41/11
44/24 45/7 46/12
46/13 52/4 53/24 56/6
56/6 57/21 58/9 63/17
64/2 64/2 77/15 79/18
85/3 89/20 90/7 93/3
94/22 95/11 97/14
97/19 97/22 98/9
98/13 101/13 103/25
107/4 110/3 110/9
113/22 114/19 116/16)
117/6 123/17 127/2
129/4 129/8 129/24
135/1 137/25 140/8
152/19 155/10 155/10;
156/10 156/11 156/20)
158/15 159/9 159/16
171/4 171/14 171/16
lended [1] 174/1
l enquired [1] 51/23
leven [1] 129/5
lever [1] 41/11
l explain [2] 20/16
25/16
l extracted [5]
159/20 160/19 161/14)
164/24 165/13
I felt [7] 11/20 69/22
85/2 119/23 136/4
152/6 160/12
I first [2] 4/6 102/11
I found [2] 33/2 71/22!
I gave [2] 22/13
175/2
I going [1] 9/18
I got [1] 172/9
I guess [5] 32/6 75/6
119/16 167/25 168/3
had [28] 4/13 4/23
16/7 16/17 17/10 24/4]
40/23 47/2 64/4 64/8
74/20 78/25 84/9
120/6 131/5 134/5
138/3 138/4 138/6
141/10 141/11 144/20
147/16 152/21 160/13
160/14 162/10 172/18
I hadn't [4] 54/15
137/23 138/3 166/18
Ihave [24] 11/4 13/5
33/19 33/25 41/12
65/7 65/9 65/23 66/1
66/23 67/13 94/13
104/22 105/8 106/6
134/12 134/14 142/12]
143/4 144/4 149/8
158/11 162/7 163/18
I haven't [1] 158/17
I hold [1] 170/2
l interpreted [1]
152/19
I just [11] 19/1 42/21
57/10 79/19 105/3
148/9 152/20 152/22
163/24 164/4 165/4
I knew [6] 5/20 53/14
59/8 69/13 70/1 74/24
I know [9] 18/24 54/1
61/21 85/17 88/7
90/24 158/12 161/21
164/16
Ileft [1] 44/3
I made [3] 6/17 10/11
20/16
I may [5] 1/10 20/4
57/4 71/21 156/10
I mean [6] 45/15 56/7
82/4 110/4 127/4
144/21
I meant [2] 70/22
136/17
I mentioned [2]
68/21 174/24
I met [1] 55/14
I might [2] 129/6
159/5
I misled [4] 12/1
I must [7] 2/14 109/2
129/15 146/19 160/5
161/23 171/10
Ineed [1] 15/14
I needed [4] 11/1
98/10 98/18 139/4
I noted [1] 40/7
I notice [1] 72/5
I now [3] 9/4 124/6
136/15
I press [1] 162/1
I probably [6] 5/10
11/24 11/24 57/2
149/16 157/5
I produced [5] 16/16
66/2 78/17 94/25
1410/7
I propose [1] 66/22
I quote [1] 3/7
lread [1] 10/23
I realise [4] 42/16
54/22 69/21 160/10
lI realised [5] 47/24
48/25 78/15 84/11
146/21
I recall [1] 44/9
I recognise [2] 28/13
72/16
refer [2] 137/9
150/3
I remember [7] 1/15
1/22 2/5 31/23 91/6
115/19 131/3
I said [9] 2/9 2/14
2/18 3/1 3/5 43/4 93/4
99/13 165/13
I saw [9] 21/10 22/12
38/9 62/4 95/1 140/20)
154/19 155/13 157/9
I say [14] 12/19 29/3
48/24 49/23 53/7 68/7]
68/16 99/14 101/5
101/21 110/7 110/25
116/2 149/1
I see [12] 7/10 20/20
29/11 64/2 66/9 72/10)
87/10 118/25 124/14
124/23 127/1 132/22
I sent [2] 78/17 78/21
I should [5] 17/12
22/9 43/3 54/22 174/8
I shouldn't [2] 29/24
29/24
I showed [3] 1/23 2/3
8/15
I slightly [4] 36/4
I spelt [1] 57/9
Istand [1] 18/19
I still [3] 15/8 121/25
169/8
I suggest [2] 128/6
129/18
I suggested [1] 17/20)
I suppose [1] 157/5
I suspect [5] 86/14
89/21 121/8 128/21
135/8
I take [2] 23/5 157/11
I tended [1] 68/15
I then [2] 78/16
159/25
I think [109] 6/13
10/2 10/8 12/2 12/23
13/16 15/24 16/25
17/4 18/4 24/3 26/21
28/16 29/10 30/25
31/15 31/21 32/22
33/11 33/22 35/14
37/2 37/4 37/14 39/11
39/25 46/8 46/23 49/5
49/23 50/11 51/17
66/4 70/13 71/25 72/6I
73/20 74/7 74/9 78/2
78/10 80/6 81/15
81/21 82/8 83/1 89/10}
90/23 91/20 92/11
95/3 96/8 96/13 96/13}
98/18 99/11 99/13
102/11 104/21 104/24)
108/23 110/8 111/20
112/10 113/22 113/24I
116/22 120/18 121/23)
123/2 123/15 123/15
124/10 125/15 127/18)
127/21 128/4 129/7
129/22 133/9 140/20
143/22 144/12 144/18)
145/2 146/13 147/11
149/16 151/12 151/24)
152/1 152/12 154/14
155/25 157/14 157/17)
157/18 157/19 158/1
158/3 158/4 160/25
162/20 163/1 163/5
165/19 166/8 168/10
173/8
I thought [17] 7/25
41/20 69/4 74/23 83/1
84/12 95/5 135/25
136/9 141/3 141/5
142/10 149/18 150/6
150/10 171/22 172/19)
I turn [1] 55/7
l understand [20]
8/16 8/20 8/24 10/10
10/14 14/23 23/19
24/15 25/11 27/15
40/11 47/9 53/25
60/19 65/14 67/3
72/13 133/3 142/5
175/8
l understood [10] 4/7I
7/24 40/18 41/8 68/5
69/4 70/1 115/14
123/13 140/1
lused [1] 92/13
l usually [1] 82/1
I want [5] 24/8 24/12
88/8 89/1 138/8
I wanted [2] 33/3
41/21
Iwas [101] 4/24
10/24 10/25 11/7 12/7)
12/11 12/13 13/12
13/21 15/17 15/25
16/6 19/10 22/8 23/1
27/3 38/10 39/6 39/7
39/16 40/9 40/17
43/24 43/25 45/3
46/19 47/12 47/25
50/11 50/12 52/3
56/19 58/25 59/14
60/15 64/6 64/8 68/14)
69/16 70/24 74/23
(66) lagree... -Twas
Iwas... [60] 77/25
78/10 81/15 82/4
82/15 83/1 83/2 83/15
83/22 85/6 85/17 86/9
90/3 91/24 92/21 93/1
93/2 93/23 94/2 94/8
95/11 97/6 98/23
100/23 101/6 101/21
108/22 109/3 110/24
112/24 113/1 114/7
114/19 115/17 118/5
120/2 127/12 129/4
129/24 129/24 130/12)
134/6 137/20 139/4
140/15 141/3 146/19
152/5 152/22 154/19
157/6 160/12 160/14
167/2 167/3 170/12
170/16 171/4 171/11
173/25
I wasn't [8] 32/24
38/23 61/7 61/17 95/3
116/16 123/19 147/17)
I went [1] 173/8
I will [4] 117/3 126/9
132/25 174/13
I won't [1] 19/22
I wonder [1] 150/16
I would [33] 5/18
5/18 8/1 10/22 11/3
12/9 12/19 16/2 16/15)
21/9 24/18 32/24
47/19 56/6 57/6 57/21
58/9 64/13 66/18
70/24 79/18 80/18
82/16 83/16 87/25
88/23 126/9 130/7
148/22 156/11 157/7
165/14 166/17
I wouldn't [2] 58/3
148/21
I wrote [1] 94/22
I'd [40] 1/9 3/14
13/20 15/5 15/6 15/14
16/3 16/13 16/19 18/4}
18/11 18/12 18/22
18/22 31/18 33/1
35/24 37/9 53/24 55/5
68/16 68/20 68/23
68/24 78/20 83/13
88/14 88/17 96/10
101/10 129/8 131/7
137/21 140/2 141/13
150/6 157/8 163/4
166/18 171/22
lll [3] 13/14 28/3 43/7
I'm [81] 2/16 4/4 9/14
10/3 10/5 12/20 13/20
18/23 18/25 19/24
20/5 21/19 22/22
22/23 22/24 23/17
27/18 29/6 29/16 32/3
36/18 38/4 38/23
51/13 55/5 58/24
59/18 61/7 67/18
101/7 103/15 105/3
110/3 111/19 113/2
114/7 115/9 118/18
127/16 129/8 129/22
131/1 132/14 133/16
135/8 135/11 135/21
136/2 137/3 149/14
149/19 157/25 158/4
158/7 158/14 159/4
161/3 165/3 166/20
171/25 174/3 174/4
I've [53] 3/22 10/12
14/3 14/5 14/12 14/14
16/17 19/21 22/25
23/5 29/4 34/22 36/1
36/1 41/18 52/15
65/25 91/1 93/1 94/14
97/12 103/15 103/19
109/10 109/10 113/3
113/22 116/1 124/14
127/5 127/24 128/4
133/17 135/10 137/18)
146/25 148/11 150/9
151/10 153/19 154/21
156/24 157/25 158/7
158/8 158/18 159/11
162/3 162/16 163/9
163/15 164/1 165/11
lan [2] 55/8 56/11
ID [13] 45/12 45/13
45/16 45/24 46/4 46/5
47/16 48/18 50/4 50/7
52/15 75/17 75/19
idea [5] 97/12 103/19
109/10 124/14 127/6
identifiable [1] 41/15
identified [1] 5/19
identify [3] 67/10
68/2 167/17
identifying [2]
128/18 141/4
IDRIS [2] 1/3 176/2
IDs [1] 51/19
ie [13] 6/19 39/25
44/11 44/16 52/10
59/17 73/8 76/21 84/4
116/4 148/17 166/10
172/10
ie from [1] 52/10
ie in [1] 39/25
ie investigating [1]
84/4
le it [1] 166/10
ie the [4] 44/11 73/8
116/4 148/17
le they [1] 172/10
32/16 33/16 35/8 35/8)
42/21 51/8 51/8 51/13
71/22 90/9 91/20 97/5)
97/8 98/3 98/23 99/16)
118/18 122/13 124/19)
ie using [1] 44/16
ie what [1] 59/17
ie you [1] 6/19
if [189]
ignorance [2] 20/5
123/20
ignore [2] 124/19
132/25
imaged [3] 8/15 10/1
10/4
impact [4] 40/6 40/16
72/8 77/8
impacting [1] 30/23
implementation [1]
149/9
implications [2] 16/1
140/22
implies [1] 128/16
imply [2] 133/19
138/2
important [13] 12/5
12/6 21/13 29/19
37/11 51/11 76/18
76/23 77/4 80/7
102/22 132/13 151/17
importantly [1] 132/4
imposed [1] 18/1
impossibility [1]
46/14
impossible [2] 52/18
53/4
impression [2] 25/13
136/14
improper [3] 146/2
149/20 169/22
improve [2] 152/24
155/13
improving [3] 152/7
152/20 152/23
inaccurate [3]
105/24 146/2 169/22
inadequate [1] 123/3
inappropriate [3]
155/16 157/12 167/7
incidences [2] 26/5
42/10
incident [2] 35/4 73/8
incidents [1] 103/3
include [14] 62/16
65/11 85/18 98/19
98/23 126/13 135/1
137/7 137/11 144/19
148/8 148/10 148/15
173/1
included [15] 17/15
20/22 28/10 36/12
60/10 78/14 86/19
103/7 103/17 116/3
118/8 134/14 158/11
158/15 158/18
includes [1] 120/23
including [15] 25/20
32/9 43/21 55/19 56/3
56/18 61/14 61/20
80/16 80/21 99/2
104/13 107/6 109/7
173/16
inclusions [1] 1/20
inconsistency [1]
71/15
inconsistent [1]
71/11
incorrect [4] 76/23
77/2 77/5 78/20
indeed [6] 3/23 120/2
121/13 121/24 143/3
144/11
indented [1] 135/14
independent [6]
18/18 113/6 115/2
120/6 120/20 120/24
index [2] 95/21
111/17
indicate [3] 14/1 45/4
168/17
indicated [2] 69/8
172/1
indicates [2] 97/3
168/21
indication [1] 132/17
indistinguishable [7]
56/1 57/19 58/1 58/7
58/22 59/3 79/5
individual [6] 29/17
29/18 32/17 55/23
57/12 132/6
individuals [3] 61/4
73/4 143/8
influence [2] 151/22
152/8
info [2] 65/25 128/5
informal [7] 42/4
68/20 68/25 74/1 74/3,
78/12 96/6
information [45] 7/23
11/20 26/17 31/10
31/20 33/3 38/13
38/18 39/1 62/14
62/15 63/6 67/5 74/18
75/17 76/11 7/1 77/5
80/22 83/14 84/13
98/6 98/14 101/24
106/8 118/15 120/8
121/10 121/24 123/6
129/4 129/23 130/2
134/6 136/24 138/3
138/4 138/7 138/15
140/20 141/6 148/20
169/21 170/2 172/9
informed [1] 13/8
infrastructure [1]
102/24
Infringements [1]
63/3
initial [2] 79/11 106/9
initially [2] 92/23
93/12
inject [2] 57/5 74/4
injected [7] 46/20
73/17 75/18 76/13
76/16 77/6 77/22
injecting [1] 73/24
injection [1] 58/3
injections [4] 51/25
76/20 77/9 79/20
input [4] 67/11 68/3
115/18 163/13
INQ00001058 [1]
49/19
INQ00001079 [1]
42/22
Inquiry [19] 9/8 22/25
24/12 25/12 40/11
42/7 62/5 72/17 80/3
80/15 81/24 92/24
94/14 102/12 104/7
113/3 131/5 141/20
14215
Inquiry's [1] 4/5
insert [9] 41/5 43/6
43/10 45/11 46/17
47/10 51/19 52/16
79/5
inserted [9] 41/16
45/15 47/18 47/20
48/16 69/5 72/22
75/12 75/23
inserting [2] 48/14
70/2
insertion [1] 67/17
insertions [1] 45/18
inspected [1] 43/16
installed [1] 108/19
instance [1] 45/8
instead [6] 14/19
28/5 36/13 47/13
88/20 138/8
instigate [1] 113/6
institution [3] 168/15
168/18 168/23
institutions [1]
167/21
instructed [1] 92/25
instructions [1]
169/2
integrity [77] 65/14
67/3 67/5 88/7 88/12
88/16 88/19 88/22
90/17 90/22 91/7
91/24 92/2 92/7 92/19
93/9 93/15 93/18 95/2
95/14 95/14 95/16
99/1 99/10 99/18
99/20 101/3 101/8
102/1 103/4 103/11
104/8 104/11 105/10
105/14 105/22 107/11
108/10 108/23 110/20)
111/8 111/10 112/2
116/8 116/15 116/21
116/23 117/1 117/5
4117/6 117/7 117/12
(67) I was... - integrity
I
integrity... [25]
117/21 118/3 119/9
119/11 120/2 121/15
121/19 121/20 121/21
121/24 122/5 122/24
123/5 123/12 123/15
142/14 142/15 142/25
142/25 143/2 143/5
143/10 143/14 143/19)
144/3
intend [1] 94/19
intended [10] 5/21
94/16 95/8 114/1
118/8 142/7 142/10
143/18 148/13 171/1
interacting [1] 27/10
interaction [1]
104/24
interest [3] 96/5
106/4 106/6
interfaces [3] 53/15
102/18 140/3
internal [5] 42/25
49/21 106/20 109/6
120/20
interpret [4] 59/15
137/18 140/5 151/25
interpreted [2]
151/24 152/19
interpreting [2]
135/11 152/6
interrogated [1]
118/15
interviews [2] 88/10
89/3
into [34] 5/25 6/20
18/4 31/19 32/17 41/6
43/11 46/17 51/19
52/16 56/9 67/17
67/19 71/14 84/24
89/8 89/17 89/20 90/4
90/5 93/13 93/15 99/1
99/9 109/15 115/4
116/7 118/20 118/24
130/19 135/16 153/3
161/9 161/12
intrinsic [3] 113/9
113/14 120/25
introduced [2] 61/22
62/2
introduction [1]
168/4
investigate [3] 29/9
83/17 120/16
investigated [1]
34/18
investigating [1]
84/4
investigation [5]
24/12 28/14 84/14
93/14 124/4
investigators [2]
83/7 89/13
involved [25] 4/6
29/10 38/10 38/24
39/6 39/17 41/10
60/15 61/4 61/17
74/14 74/25 76/3
104/13 107/2 115/15
1314/3 131/7 140/2
144/14 145/4 147/2
147/14 148/1 149/8
involvement [5] 4/20
4/23 31/14 124/2
124/8
irrelevant [1] 108/20
is [311]
Ismay [8] 94/5 102/5
103/13 103/17 104/2
104/5 104/7 104/15
Ismay's [1] 94/13
isn't [10] 19/21 20/3
58/18 65/24 68/5
84/18 87/22 100/16
133/10 149/11
isolated [3] 30/2 30/3
32/1
issue [33] 1/10 25/22
28/15 29/3 29/5 29/14
29/15 29/18 29/25
30/2 30/4 30/6 31/20
31/24 32/22 35/11
37/11 40/9 40/12
42/12 42/24 55/2 75/5)
98/15 98/22 106/24
108/10 108/23 109/14)
116/18 122/14 122/15)
144/24
issues [34] 1/18 5/9
5/19 6/14 12/8 25/8
31/14 32/10 55/19
56/17 63/10 66/17
76/8 77/13 80/4 80/5
80/14 80/18 81/5
81/14 88/8 88/13
88/20 88/22 93/7
101/17 105/11 107/12)
109/20 110/16 110/22)
110/25 119/24 138/25)
it [585]
it's [45] 8/6 8/17 12/3
17/12 17/20 18/4
23/13 25/3 29/4 29/18
30/2 30/3 37/2 46/14
57/14 59/24 60/16
64/14 74/3 81/7 81/7
84/23 89/18 91/2
91/11 97/2 97/13
102/1 118/7 119/12
119/18 131/18 138/21
139/10 145/21 150/16)
154/10 154/12 156/5
159/16 161/3 161/4
162/24 163/6 167/21
italics [2] 126/6
invited [2] 4/24 10/25)
126/14
its [15] 3/7 9/8 15/1
93/11 105/17 111/4
112/9 112/10 114/25
4115/1 115/12 124/3
143/6 143/24 153/13
itself [11] 25/15
25/19 25/24 34/4 36/7
54/13 87/2 87/3 87/4
121/13 161/4
J
James [3] 72/21 74/8
74/9
January [1] 111/18
JENKINS [19] 1/3 1/6
23/15 23/22 24/11
24/20 49/19 55/14
55/20 64/4 64/9 77/3
77/4 91/23 107/17
150/25 174/14 174/24
176/2
Jenkins’ [1] 133/13
Jeremy [1] 96/17
job [1] 33/16
John [6] 42/6 46/23
47/9 52/5 69/8 79/1
join [1] 106/11
journal [1] 71/7
journalist [1] 106/19
journalling [1] 72/6
judge [1] 21/8
judges [1] 44/6
judgment [3] 25/9
76/9 80/19
June [8] 1/4 3/17
4/25 5/2 6/2 7/1 8/7
70/5
just [111] 2/17 4/10
6/11 7/6 8/22 10/3
10/3 10/21 12/16
13/16 13/24 13/25
14/1 14/9 14/13 16/3
17/8 17/12 17/12 19/1
19/5 19/15 21/3 21/12}
23/17 24/13 25/5 26/8
28/1 28/11 29/17
29/18 31/18 32/16
32/22 32/22 40/23
42/21 43/2 43/3 43/3
43/7 43/25 45/1 50/13}
51/13 51/13 51/17
57/10 63/18 63/20
66/25 68/24 70/6
72/20 76/6 77/17
79/19 81/7 84/16
90/20 95/19 95/25
96/4 96/4 101/22
102/4 103/10 105/3
108/1 109/6 112/15
113/12 115/8 115/16
120/20 124/12 125/25]
126/12 129/4 129/16
129/16 132/20 135/4
136/4 136/9 138/4
141/3 142/16 144/25
145/6 145/21 146/19
148/1 148/9 152/1
152/16 152/20 152/22}
152/22 153/19 158/19}
159/16 160/16 161/6
163/24 164/4 165/4
165/20 168/13 169/5
Justice [2] 25/9
80/18
K
keep [10] 2/2 21/14
28/7 28/10 29/12
36/24 64/20 109/7
109/8 133/12
KELs [4] 32/4 32/20
33/1 33/2
key [2] 32/5 70/8
keystrokes [5] 55/25
57/18 57/25 58/3 58/4
Kim [6] 64/24 65/6
65/14 66/24 67/17
67/19
kind [4] 29/13 58/22
63/5 157/1
kinds [1] 38/5
Kirkham [2] 96/17
104/19
knew [18] 5/20 41/11
48/24 53/7 53/14
53/22 59/8 69/9 69/13
70/1 74/24 75/4
101/25 108/23 114/21
121/20 129/5 148/16
know [59] 12/19
15/21 18/24 27/12
27/13 27/19 27/19
27/20 30/3 30/15 31/6
31/17 34/19 36/20
38/20 38/23 39/1 41/9)
41/11 47/4 53/13 54/1
58/13 59/5 59/8 60/25
61/16 61/21 64/2 76/2
85/17 87/19 88/7
89/20 90/15 90/24
93/25 94/9 96/25
98/13 98/20 101/12
103/25 110/3 110/9
113/22 125/2 129/14
140/6 140/8 148/12
155/10 156/11 156/20}
158/12 161/21 164/16)
171/14 171/16
knowing [1] 51/16
knowledge [23] 16/1
25/4 55/7 55/22 57/12
57/15 90/8 90/10
103/23 104/4 104/6
104/12 104/16 113/21
119/17 138/11 139/15}
146/5 147/16 155/8
155/9 158/11 169/23
known [7] 32/21 63/6)
77/14 77/19 93/21
94/1 149/9
KPMG [18] 93/15
94/24 112/5 112/6
113/16 113/18 114/15)
115/10 115/12 115/16)
115/19 115/20 117/23)
118/9 118/24 120/5
120/16 122/21
L
laid [1] 16/14
language [1] 136/19
last [20] 13/23 26/14
29/6 34/24 56/7 92/11
109/19 110/5 117/25
126/14 134/23 135/1
137/7 148/8 149/11
149/25 150/11 156/14)
169/18 174/24
Lastly [1] 3/6
late [4] 65/24 108/1
175/1 175/6
lately [1] 127/25
later [24] 3/11 4/24
13/14 15/4 15/9 15/12
15/20 15/22 16/9
16/19 16/23 17/1
18/10 21/11 26/17
28/3 61/21 62/7 62/8
66/8 84/10 92/13
132/19 133/14
later-discovered [1]
26/17
latest [1] 135/11
latter [1] 113/17
lawyer [7] 74/8 74/15
TANT 83/25 98/12
174/2 175/2
lawyers [5] 3/16 5/1
5/24 78/21 83/24
lay [1] 39/9
layout [1] 132/2
lead [2] 55/15 101/19
learn [4] 47/15 48/5
48/23 61/18
learned [1] 2/24
least [5] 13/3 77/4
82/4 108/7 160/12
leave [1] 125/7
leaves [1] 72/24
leaving [1] 46/6
led [1] 35/9
Lee [6] 1/19 3/10
13/3 13/10 13/13 15/3}
left [15] 1/9 20/15
44/3 49/22 50/24
73/11 74/13 146/18
147/10 158/23 160/16)
162/6 164/22 168/12
169/17
left-hand [7] 147/10
158/23 160/16 162/6
(68) integrity... - left-hand
bo
left-hand... [3]
Legacy [24] 52/2
52/9 76/12 91/9 92/4
95/13 99/11 99/13
99/16 103/11 104/8
112/11 112/19 121/4
121/19 121/22 122/1
legal [20] 5/22 7/21
23/18 97/13 97/21
98/1 98/15 98/21
98/21 105/14 113/10
113/11 113/15 114/6
121/1 123/18 140/21
length [3] 18/16 25/2
124/18
Lepton [1] 85/23
less [6] 89/14 137/2
154/20 154/23 155/2
169/15
let [1] 77/17
let's [4] 36/24 136/4
136/6 152/24
letter [67] 1/12 1/14
1/23 2/2 2/4 2/6 2/10
2/23 3/3 3/6 4/8 4/13
4/18 7/7 9/2 9/13 9/19
10/2 10/9 10/17 10/20)
11/6 11/16 11/22
12/10 12/16 12/18
12/22 12/25 13/4 13/7)
13/11 13/16 13/17
13/23 14/15 14/16
14/19 14/21 14/22
14/25 15/11 15/13
15/15 15/19 15/21
16/2 16/10 16/11
16/20 16/22 17/4
17/22 17/25 18/8
18/12 18/20 18/23
19/2 19/9 21/5 21/10
22/4 22/14 22/18
22/20 24/14
level [3] 33/18 63/24
118/9
liaison [3] 33/17
39/14 74/14
light [4] 10/16 13/6
81/23 119/17
like [20] 1/9 24/18
28/12 42/6 54/3 57/3
57/4 64/3 66/18 78/3
95/7 107/20 113/6
115/2 134/19 154/21
155/3 157/23 160/11
167/2
likely [1] 157/23
limitations [2] 86/19
104/11
164/22 168/12 169/17)
92/18 92/22 94/5 95/5)
104/10 110/16 110/23)
114/11 114/13 114/25)
limited [7] 1114/4
111/5 117/20 119/14
119/21 123/11 143/21
line [15] 5/25 5/25
43/4 49/22 61/12
62/13 62/19 65/18
120/22 132/9 132/15
149/7 151/13 157/21
173/13
line 4 [1] 157/21
Line 5 [1] 43/4
lines [4] 38/2 145/41
158/14 165/24
list [5] 4/18 102/6
109/20 109/24 111/1
litigation [8] 33/11
40/10 41/19 46/22
51/23 97/18 97/25
130/23
little [8] 13/14 59/19
72/19 72/23 125/24
134/18 143/16 168/13)
live [10] 34/15 38/19
56/21 70/10 70/14
70/16 71/4 71/18
86/10 86/23
local [1] 73/18
lock [15] 26/11 27/3
27/11 29/14 30/2 30/3
30/9 30/10 30/17
30/22 31/1 31/14 32/2
32/10 122/7
locked [1] 30/20
locking [1] 26/5
log [4] 56/3 56/8
57/14 86/16
logged [9] 29/20
32/14 48/10 48/12
48/15 48/16 48/20
50/3 50/6
logs [20] 57/3 59/15
59/17 80/16 81/8 81/9
82/1 82/2 82/22 84/8
85/24 86/11 86/13
87/18 87/23 88/8 89/1
100/5 125/8 172/4
loincloth [1] 165/6
long [8] 36/1 36/14
52/1 85/1 101/18
171/20 174/17 174/18)
longer [2] 24/5 49/11
look [63] 6/5 6/6 7/20
8/21 11/1 13/24 17/13
19/12 19/15 20/10
21/3 25/5 27/24 31/19)
32/20 33/9 36/23
36/24 39/22 49/19
49/21 49/25 55/12
60/8 60/21 60/21
63/18 63/18 67/6
71/14 81/25 82/3 82/6
85/1 85/6 85/21 86/9
91/23 95/12 95/25
97/2 102/4 102/13
124/10 127/12 128/4
133/5 135/3 135/14
138/5 151/2 152/16
159/18 162/12 163/8
168/11 174/3
looked [13] 4/10 4/21
72/16 79/9 82/16
103/10 125/25 141/11
166/8
looking [31] 1/8 5/15
13/21 17/8 32/1 32/7
34/12 37/16 38/11
59/19 68/14 72/13
81/7 81/15 85/13
86/23 90/20 92/16
93/17 116/25 124/9
127/11 144/9 144/12
145/2 146/24 151/1
152/1 152/24 161/23
163/11
looks [2] 64/3 157/23
loss [1] 63/2
losses [2] 40/22
154/5
lost [2] 22/15 157/17
lot [3] 74/4 115/17
146/19
lower [1] 36/24
Lowther [6] 125/18
131/14 131/24 132/20
140/17 151/3
lunch [2] 51/14 91/11
made [40] 3/7 6/17
9/5 10/11 15/1 16/4
17/5 20/16 24/19
32/13 33/25 34/5 36/8
38/16 44/13 48/9 50/7
54/9 54/10 58/7 58/22
59/3 67/7 69/19 74/22
77/9 82/9 88/21 88/24
102/23 106/10 106/14
106/17 129/20 147/7
152/1 154/20 155/4
158/19 171/22
main [8] 31/24 87/17
104/24 124/21 128/8
153/4 153/14 153/17
maintain [1] 105/9
maintained [1] 79/13
maintains [1] 107/11
make [26] 9/22 24/12
28/22 31/13 33/25
34/7 43/20 52/17 63/9}
66/10 73/2 73/4 75/24
83/8 84/15 84/25 89/9
130/13 135/2 136/11
137/1 137/12 148/10
157/7 157/18 158/8
makes [3] 133/20
104/17 104/17 118/24
152/24 157/15 158/22
36/4 50/13 64/1 64/14
143/16 165/11
making [6] 6/17 18/2
44/18 69/9 145/15
164/14
malicious [1] 167/14
man [1] 174/5
management [6]
35/14 39/10 39/15
39/17 120/18 160/17
manager [4] 40/8
104/21 105/2 156/8
managerial [1] 61/10
Mandatory [1] 96/16
manifestation [1]
30/4
manifested [5] 25/15
manual [2] 61/9 63/1
manually [1] 86/12
manuals [3] 142/13
142/18 142/23
many [2] 26/5 149/8
March [11] 17/6
34/15 124/11 125/24
128/3 135/5 151/1
163/12 165/4 165/17
171/20
Mared [1] 6/13
mark [4] 18/17 44/7
44/12 47/16
marked [4] 97/2
97/11 156/22 169/19
marked-up [1]
156/22
match [2] 34/20
142/1
material [3] 108/20
138/12 169/24
materials [1] 118/9
matter [7] 65/5
124/22 124/25 131/22)
148/4 148/12 148/14
matters [5] 13/4
14/21 22/4 32/3
155/18
Matthews [1] 151/5
mature [1] 108/17
may [32] 1/10 5/15
6/13 11/13 20/3 20/4
43/5 45/5 52/5 57/4
71/21 73/18 94/19
96/13 101/9 115/6
115/24 116/15 116/21
117/5 125/10 128/9
130/7 131/22 135/2
135/25 151/14 152/10)
153/5 154/4 156/10
166/1
maybe [10] 10/3 14/9
15/14 28/3 36/22
49/12 51/12 62/7
113/2 146/19
McLachlan [1] 18/16
McLachlan's [2] 40/4
25/19 25/24 34/4 36/7,
40/14
McLean [1] 108/6
me [54] 4/5 4/14 4/16
4/16 5/1 5/2 5/21 5/24
11/21 12/4 12/6 21/18}
24/2 27/4 31/21 33/3
38/10 40/13 42/15
46/23 47/10 49/23
55/16 55/20 55/24
65/25 66/13 72/3
77/17 80/23 86/17
89/20 91/1 92/25
92/25 97/12 98/18
99/8 100/24 100/25
101/21 105/5 109/24
1411/1 129/9 134/5
134/13 134/21 137/19)
143/17 161/3 163/16
167/4 174/6
mean [28] 26/22 38/4
41/3 45/10 45/15
45/25 56/7 82/4 84/21
88/11 99/11 99/13
110/4 118/18 122/13
127/4 130/9 132/16
134/3 136/6 139/6
142/7 142/11 144/6
144/21 146/23 170/11
174/15
meaning [5] 88/19
88/21 143/19 147/12
152/1
means [8] 40/5 49/10
73/12 80/17 97/13
97/14 98/9 161/5
meant [5] 70/22
136/16 136/17 141/24)
146/22
measures [4] 98/25
99/3 99/9 116/7
mechanism [1] 69/6
mechanisms [2]
41/13 62/2
media [1] 106/5
meeting [16] 4/25 5/6)
5/11 5/17 6/11 8/7
10/25 12/7 59/14
108/13 109/19 110/5
110/12 159/10 159/12!
159/17
meetings [2] 38/20
115/20
meets [1] 131/16
member [1] 44/18
members [8] 45/11
55/17 55/24 56/16
56/20 57/5 57/17
7113
memory [2] 22/15
139/12
mention [8] 54/19
97/23 133/7 139/12
173/4 173/18 173/19
173/20
(59) left-hand... - mention
mentioned [10]
14/21 17/22 22/4
68/21 100/15 101/18
108/10 118/21 151/12
174/24
mentioning [1] 85/10
message [4] 41/6
70/8 161/14 172/15
messages [3] 41/5
43/11 45/15
met [2] 55/14 56/11
method [3] 43/9
50/14 50/21
Michael [2] 72/21
74/15
might [20] 19/13
36/11 43/19 44/21
45/20 48/7 48/20 49/8)
83/14 86/13 97/24
101/19 117/19 122/12)
129/6 130/9 137/12
139/16 147/20 159/5
Mike [1] 106/16
mind [9] 10/23 12/1
12/21 16/5 16/9 16/24
20/1 58/17 80/15
mine [2] 158/2 158/4
minutes [2] 6/24
49/12
mirror [1] 44/1
misled [1] 12/4
mismatch [1] 37/7
mismatch’ [1] 34/10
mismatches [2]
34/16 35/1
Misra [5] 16/24 31/7
33/22 63/9 174/11
Misra's [3] 16/16
39/25 40/20
missed [1] 37/9
mistake [4] 10/11
78/15 78/17 79/14
mistaken [4] 2/14
2/16 15/17 15/18
misunderstood [2]
74/20 74/21
misuse [1] 104/14
mixture [1] 23/7
modified [2] 173/7
173/10
moment [11] 8/2
21/13 28/11 32/16
49/8 71/11 131/22
141/17 150/17 151/6
174/12
momentum [1] 106/1
Monday [1] 109/13
money [1] 105/23
month [1] 78/2
months [7] 4/24
19/18 21/11 88/14
111/23 114/25 124/3
more [15] 13/21
32/16 33/1 33/25 49/5)
51/24 61/5 72/23
101/8 132/4 135/13
144/24 151/10 151/16)
168/4
morning [6] 1/6 1/7
24/11 28/4 49/9 108/1
most [4] 40/5 91/13
128/5 132/12
mostly [1] 105/14
Motion [1] 108/13
move [3] 76/8 90/17
156/25
moved [2] 46/15
157/16
moving [4] 72/18
134/8 136/22 142/4
MP [2] 108/11 109/4
MPs [6] 94/21 95/7
95/10 109/19 110/5
110/12
MR [91] 1/4 1/5 1/6
4/6 4/20 5/9 5/20 6/7
6/12 7/16 20/21 20/22
22/4 22/17 23/5 23/15
23/22 24/1 24/8 24/11
24/16 24/20 25/9
45/24 49/19 51/22
56/5 71/24 76/11
76/24 76/24 77/1 77/3
77/4 77/5 77/10 77/11
77/21 78/13 79/3
79/12 79/16 80/18
91/3 91/23 94/5 94/13
96/22 103/13 104/7
124/4 124/10 125/6
125/15 125/20 125/24)
127/2 127/7 129/2
129/10 129/19 131/16)
131/24 131/24 133/13)
139/1 139/24 140/11
140/16 140/16 144/7
144/18 149/18 150/23)
150/25 151/1 151/3
151/4 151/4 151/9
151/21 155/8 159/2
166/12 169/5 171/18
173/15 174/14 174/16)
174/24 176/4
Mr Baines [1] 151/4
Mr Baker [1] 71/24
Mr Beer [7] 1/5 23/5
24/8 91/3 149/18
150/23 174/16
Mr Castleton [3] 5/9
5/20 24/16
Mr Castleton's [5]
4/6 4/20 6/12 7/16
45/24
Mr Dawkins [1]
151/4
Mr Dilley [6] 6/7
20/21 20/22 22/4
22/17 24/1
Mr Godeseth [7]
76/11 76/24 77/5
77/10 77/21 78/13
79/12
Mr Henderson [3]
56/5 79/3 79/16
Mr Hughie [1] 144/7
Mr Ismay [3] 94/5
103/13 104/7
Mr Ismay's [1] 94/13
Mr Jenkins [11] 1/6
23/22 24/11 24/20
49/19 77/3 77/4 91/23
150/25 174/14 174/24
Mr Jenkins’ [1]
133/13
Mr Justice [2] 25/9
80/18
Mr Parker [2] 76/24
77/11
Mr Pinder [7] 125/24
127/2 127/7 129/2
129/19 131/24 140/16
Mr Pinder's [1]
129/10
Mr Roll's [2] 51/22
77M
Mr Smith [1] 96/22
Mr Thomas [3] 124/4
139/1 159/2
Mr Thomas' [7]
125/6 125/15 125/20
139/24 140/11 144/18
151/1
Mr Ward [10] 124/10
131/16 131/24 151/3
151/9 151/21 155/8
166/12 169/5 173/15
Mr Ward's [2] 140/16
171/18
Mrs [1] 40/20
Mrs Misra's [1] 40/20
Ms [10] 27/25 35/3
35/23 46/18 47/23
89/24 131/24 132/20
140/17 151/3
Ms Chambers [4]
35/3 35/23 46/18
47/23
Ms Chambers' [1]
27/25
Ms Lowther [4]
131/24 132/20 140/17]
151/3
Ms Rose [1] 89/24
MSU [1] 35/15
much [12] 16/4 16/4
16/7 23/4 23/8 104/23
108/19 109/14 128/20}
141/10 141/14 150/19}
must [19] 2/14 6/23
62/19 73/7 96/8 98/10
98/18 109/2 129/15
132/7 146/19 146/22
158/3 159/11 160/5
160/25 161/23 165/19}
171/10
my [83] 4/19 4/20 5/1
5/16 5/24 6/17 10/23
12/1 12/21 16/1 16/5
16/13 29/4 36/5 39/12)
41/18 42/2 46/19 49/5
53/21 54/14 54/23
57/23 58/9 58/15
59/13 62/5 63/11 64/3)
65/4 66/1 66/10 68/6
72/15 72/16 73/23
74/19 76/1 77/25 78/6)
78/15 78/16 79/1
79/20 80/15 81/20
86/9 87/17 91/1
101/10 104/6 104/16
104/24 109/22 114/8
114/15 116/2 116/3
116/10 118/8 123/9
123/20 123/21 125/11
127/24 130/11 131/4
132/4 138/11 144/12
144/18 144/20 145/2
150/3 152/1 156/8
158/1 162/16 163/9
169/23 170/17 174/7
174/13
myself [3] 129/9
163/5 172/18
N
name [2] 64/3 109/10)
namely [1] 76/12
narrative [1] 103/7
narrow [6] 93/6
101/12 101/14 110/24}
122/19 123/11
narrower [1] 90/23
native [2] 8/11 10/4
nature [4] 27/9 65/20
75/24 136/25
necessarily [7] 3/9
15/3 38/15 45/25
94/25 116/2 124/7
necessary [7] 1/20
8/12 23/10 83/20
120/16 139/8 167/24
need [33] 8/1 13/1
13/9 15/14 18/15 21/7,
23/9 40/21 57/15
62/21 73/3 82/6 86/8
86/17 106/25 109/14
112/13 112/20 112/23
117/13 118/6 125/7
125/8 130/7 130/9
130/11 131/18 132/5
138/21 171/8 172/21
173/3 173/19
needed [9] 11/1
22/17 54/5 83/16
98/10 98/18 108/15
130/3 139/4
needn't [1] 8/9
needs [7] 14/21 19/8
62/19 90/1 146/21
151/10 173/41
negotiation [1] 157/1
neither [4] 35/2 60/2
80/23 114/17
Neneh [12] 125/18
126/10 130/18 131/14}
133/15 135/9 138/5
143/9 156/10 158/10
163/3 172/11
never [7] 3/7 15/1
58/17 113/18 114/16
119/6 139/15
new [2] 73/16 79/23
Newsome [1] 33/12
next [11] 5/5 5/11
5/17 14/11 17/1 34/8
45/24 124/19 134/6
134/10 157/9
niceties [1] 123/18
night [2] 13/23
109/13
nil [8] 125/10 125/14
125/20 126/7 126/18
126/22 139/24 140/1
no [117] 2/7 2/7 3/19
3/22 3/22 3/24 11/4
14/18 15/6 15/8 16/17
17/10 17/23 19/1
19/14 22/8 22/13
23/15 24/5 29/3 30/2
31/3 31/15 38/8 39/8
39/16 39/18 47/5
48/15 48/18 50/4 51/5)
54/21 56/24 57/15
62/20 62/22 64/8
64/12 64/17 65/16
70/9 72/8 73/11 74/9
82/6 86/15 87/3 90/16
94/2 94/8 94/11 97/12I
97/19 98/23 100/16
100/18 101/13 102/7
103/19 103/22 104/3
104/6 104/16 108/4
109/10 110/11 110/13)
118/6 118/16 119/23
120/4 120/6 120/12
120/13 122/4 124/14
124/16 127/4 127/5
128/11 131/5 131/18
137/8 138/6 138/6
138/21 139/22 141/1
141/3 144/4 145/25
146/24 147/16 148/16
149/2 149/3 149/4
153/7 154/25 157/19
158/11 158/18 159/5
159/11 160/22 162/3
162/8 166/3 168/19
168/22 168/23 169/3
169/21 173/1 173/5
(60) mentioned - no
N
no... [1] 174/8
nobody [3] 51/11
53/17 119/8
node [2] 75/17 75/19
none [2] 74/23 76/1
nonetheless [1]
82/23
nor [8] 9/18 18/17
35/2 60/2 100/17
131/21 133/11 165/8
normal [17] 69/17
75/13 84/9 134/19
135/23 136/5 136/10
151/13 151/20 153/10
153/22 154/3 167/11
169/1 170/23 173/4
173/12
normally [3] 34/16
35/1 47/10
not [242]
note [5] 3/23 34/7
67/7 123/21 163/13
noted [3] 40/7 100/3
143/4
nothing [6] 31/5
40/20 56/8 120/14
157/25 158/7
notice [1] 72/5
noticed [1] 96/10
notwithstanding [1]
72/24
November [19] 1/12
2/3 4/9 9/3 9/7 9/19
10/9 21/6 22/5 22/14
22/19 22/20 24/14
64/22 92/6 92/12
111/14 111/21 119/18
now [73] 4/17 5/23
TINT 8/6 8/11 9/4 9/5
10/8 10/16 12/4 13/6
13/24 14/23 15/5 15/7I
15/21 16/1 17/25 18/9)
19/17 22/24 25/11
27/19 29/6 35/7 40/12
45/14 51/8 51/17
51/21 54/15 60/20
67/19 68/6 69/21
72/14 73/20 74/19
78/2 87/16 94/12
95/11 96/10 97/1
97/16 101/5 109/3
110/8 112/25 114/24
121/25 123/14 123/17)
124/6 131/17 134/5
136/15 138/19 141/14
144/12 145/2 146/24
150/16 157/16 159/6
160/10 161/23 162/10
167/8 171/9 174/8
174/11 175/5
NT [15] 28/18 29/23
32/8 80/16 81/8 81/9
81/15 81/19 82/1
82/22 84/7 84/24 85/1
85/8 85/19
number [21] 5/3 5/7
6/2 7/19 8/9 25/9
38/20 43/19 44/7
44/12 44/17 45/6
45/14 45/24 76/15
76/22 77/24 105/13
105/21 115/15 151/11
number 602 [2] 5/7
79
numbered [1] 34/24
numbers [2] 125/3
126/13
numerous [1] 173/15
[e)
objectionable [1]
169/18
Objective [1] 114/23
obligations [1] 115/1
obtain [3] 147/20
171/13 171/15
obtained [3] 24/15
144/17 160/4
obtaining [3] 97/21
98/1 162/3
obvious [2] 47/21
52/25
obviously [7] 9/14
11/25 23/2 24/9 28/2
75/10 92/8
occasion [3] 43/6
45/2 75/23
occasionally [2] 38/8
39/16
occasions [6] 38/6
44/21 49/1 54/8
170/14 173/15
occur [9] 37/9 40/13
42/15 69/11 83/18
125/14 125/21 126/19)
172/24
occurred [14] 24/13
26/23 28/15 31/23
32/15 34/2 42/9 54/6
87/8 89/15 92/22
101/21 165/17 172/25)
occurrence [2] 29/7
136/10
occurrence’ [1]
151/13
occurrences [9]
26/11 134/20 135/24
136/5 153/10 153/22
169/1 170/24 173/13
occurrences' [2]
151/20 173/4
occurring [2] 28/24
30/7
occurs [1] 89/22
OCPs [1] 41/10
OCRs [1] 41/11
October [13] 40/1
66/2 66/5 67/1 91/4
92/1 95/23 107/14
108/1 108/3 108/6
110/2 110/7
off [13] 1/9 21/21
23/22 50/23 61/10
69/7 72/15 75/23 76/4
97/7 106/3 162/16
1741/5
offer [2] 82/23 83/10
office [104] 5/21
28/20 29/9 33/18
34/18 35/5 35/10
35/13 35/18 35/19
35/21 38/18 38/22
39/2 39/8 40/5 43/6
50/2 50/12 55/15
55/16 55/17 56/14
56/16 56/20 61/11
61/14 64/4 67/13 69/3
69/6 70/9 70/13 70/15)
70/18 72/3 72/5 72/7
72/11 73/1 74/15
75/22 76/4 76/19 83/7
83/24 84/3 85/5 90/11
90/13 90/15 94/6
94/19 94/23 94/24
95/8 96/22 98/6 98/14
101/1 101/16 102/8
105/13 105/17 105/17
105/23 106/3 106/7
106/9 106/17 106/18
106/18 106/19 106/21
106/23 106/25 107/9
108/18 109/18 110/4
113/8 121/13 122/16
124/1 124/3 125/7
125/16 125/20 132/18}
134/1 138/23 140/10
140/25 152/13 152/17]
157/2 158/25 159/23
160/20 164/25 167/19}
173/3 173/5 174/5
Office's [4] 4/25
40/15 73/6 127/3
officially [1] 101/18
often [4] 43/19 52/23
55/22 57/11
oh [3] 129/6 155/19
174/24
okay [27] 1/13 4/11
6/16 8/2 9/18 10/13
12/22 21/12 37/14
39/21 53/9 62/6 74/12
83/24 84/1 87/14
96/11 123/24 125/16
130/16 130/20 134/2
149/22 159/3 159/4
159/13 174/2
old [2] 31/22 73/15
omitted [1] 36/11
on [212]
once [7] 14/17 80/19
84/22 102/20 105/17
119/23 119/25
one [48] 1/16 7/6
11/2 11/19 17/1 17/8
28/16 31/3 34/10
34/17 43/23 44/1
44/23 44/25 48/16
49/11 72/1 72/15
75/16 77/4 83/9 86/15
87/1 87/1 87/4 92/10
92/18 95/5 96/12
107/17 111/21 111/25}
112/23 116/4 124/22
125/10 128/20 129/9
129/13 130/7 141/16
148/5 150/1 159/1
163/1 164/15 167/25
168/3
ones [4] 111/2 111/2
124/20 169/18
ongoing [1] 40/22
online [33] 73/16
92/7 92/8 93/9 94/18
94/22 99/6 99/10
99/14 111/9 111/10
112/3 112/14 112/18
113/7 113/13 114/4
114/24 116/8 116/17
116/21 117/4 117/10
119/25 120/1 120/25
121/5 121/19 121/21
125/13 126/7 126/17
126/22
Online’ [1] 108/19
Online's [1] 119/9
only [36] 8/3 9/13
11/15 18/25 23/5 40/7,
47/24 48/5 50/22
51/18 57/21 58/13
58/21 70/16 77/6
77/10 83/23 98/7 99/5
100/20 100/21 100/23}
101/3 101/16 102/1
105/17 106/13 106/20}
106/25 109/16 118/17,
123/10 143/20 145/15)
146/22 148/10
onto [1] 161/1
onwards [3] 49/23
53/17 73/16
open [2] 8/22 8/25
opened [1] 11/3
opening [1] 65/18
openly [1] 24/9
operated [3] 47/2
116/25 120/10
operating [12] 83/2
91/21 138/12 138/13
146/7 146/10 147/14
147/16 148/18 148/19
169/24 170/1
operation [10] 63/4
118/21 122/2 138/14
144/14 145/4 147/1
147/2 167/12 170/1
operational [8] 26/7
60/6 63/1 88/9 89/2
114/24 142/13 142/23)
opinion [3] 23/7
140/19 143/10
opportunity [3] 62/25]
67/14 68/17
opposed [2] 48/4
51/3
option [2] 167/25
168/3
Optional [1] 96/19
options [1] 134/7
or [145] 2/16 3/20
10/2 12/15 16/19 17/6I
17/21 18/1 18/2 22/3
22/11 22/19 24/10
24/19 24/20 27/1
29/17 30/4 32/19
32/22 32/23 34/2 35/4I
35/17 36/22 38/2 38/6I
38/10 38/14 38/25
39/5 39/17 40/8 40/8
40/21 41/11 42/13
42/19 43/10 43/21
43/25 44/15 48/3
48/15 48/16 48/21
51/2 52/14 55/22
57/12 57/15 59/17
61/24 62/8 72/10
72/25 73/15 73/16
75/1 75/1 75/17 77/8
78/2 78/18 80/22 81/5I
81/13 84/4 84/14 85/4
85/4 85/4 85/25 86/14
86/15 89/10 89/24
94/20 95/7 96/14 97/8
97/23 97/24 98/1 99/7I
103/20 104/14 104/21
105/15 106/5 106/23
110/10 110/16 111/24I
113/15 115/19 116/24}
117/9 117/10 119/3
119/18 121/16 121/22)
122/2 125/18 126/10
127/7 127/9 130/22
130/23 130/25 134/1
135/6 138/12 138/13
138/23 138/25 138/25)
140/11 140/18 141/21
142/7 142/8 143/11
143/24 145/7 145/8
147/17 148/12 148/18)
153/12 153/19 155/1
156/10 156/11 156/15}
156/18 158/10 158/18)
159/1 163/3 166/19
169/25 170/1 172/11
oral [1] 18/13
order [8] 27/21 32/21
46/23 47/16 74/22
83/20 90/1 115/1
ordinary [2] 43/20
(61) no... - ordinary
[e)
ordinary... [1] 43/22
organisation [1]
35/14
organisations [1]
106/23
original [9] 8/14
43/13 112/9 112/10
135/6 136/19 153/2
158/3 161/17
originally [4] 24/14
76/19 93/16 171/20
origination [1] 143/7
originator [1] 60/2
other [33] 9/15 11/2
16/6 25/22 25/25
26/10 27/2 27/9 28/16
36/10 44/4 51/12 61/9
62/20 64/3 76/17
77/13 82/13 82/19
86/15 86/16 93/17
105/3 111/6 115/20
117/13 125/5 127/9
137/3 145/7 147/6
147/12 170/17
others [4] 6/8 43/9
64/23 83/12
otherwise [3] 61/12
79/8 127/8
ought [1] 63/6
our [11] 29/22 75/22
88/9 106/17 108/17
108/19 109/12 119/10
132/12 151/14 171/22
ourselves [3] 5/13
7/11 11/11
out [65] 2/12 2/20 3/2
6/13 7/12 12/25 14/22
15/13 16/14 18/15
19/4 19/22 22/18
22/20 24/18 27/3
36/22 37/9 40/1 41/5
43/20 43/22 44/7
44/12 45/19 46/1
47/16 53/5 57/9 59/4
61/24 63/10 65/10
77/10 77/20 78/13
78/19 79/1 79/15
82/14 96/4 99/25
100/17 103/13 107/6
120/5 125/7 126/12
126/13 129/11 133/1
134/16 137/22 137/25}
138/14 138/24 142/1
142/12 142/23 143/22)
162/16 163/9 170/1
170/21 172/5
outlets [1] 63/2
outline [5] 59/24 60/5)
62/1 106/12 106/13
outset [1] 80/7
outside [2] 62/15
7719
outstanding [3]
19/23 116/17 120/9
over [28] 1/10 4/21
4/24 14/6 14/10 29/5
60/9 63/19 68/24
71/10 95/19 95/20
99/19 101/25 106/24
107/8 111/16 119/25
124/21 125/9 137/3
150/8 153/12 153/20
157/12 165/12 167/6
173/16
overall [8] 45/10
80/14 119/9 123/16
136/8 136/25 143/3
143/25
overnight [3] 13/17
50/6 71/3
overtones [1] 54/2
overview [1] 118/10
owed [1] 105/23
own [8] 55/7 104/9
130/7 130/9 130/24
162/17 162/21 163/9
Owner [1] 64/7
P
pack [1] 1/25
page [83] 4/4 5/24
10/2 12/23 14/5 14/6
14/10 19/3 19/16
20/16 25/6 26/3 26/15
27/25 33/9 39/23
42/25 42/25 43/2 43/4
44/20 49/21 49/22
49/25 55/12 60/9 60/9)
60/21 63/19 63/20
63/23 71/10 76/9 80/2
85/21 95/16 95/19
95/20 95/25 96/1 96/4
97/3 97/9 97/10 98/4
99/19 102/5 102/13
103/8 104/18 107/8
109/6 111/13 111/16
113/4 117/24 120/22
124/10 124/21 125/23)
128/2 129/16 130/17
131/13 131/19 131/23}
132/10 132/19 133/12)
134/9 137/3 137/4
137/5 141/18 149/5
149/25 150/1 151/2
153/1 156/2 156/13
156/21 165/21
page 1 [4] 128/2
134/9 149/5 156/2
page 11 [1] 12/23
page 13 [1] 55/12
page 15 [1] 60/21
page 16 [1] 25/6
page 17 [1] 103/8
page 2 [8] 33/9 95/19
125/23 133/12 137/3
137/4 156/21 165/21
page 21 [1] 49/21
page 28 [1] 26/3
page 3 [6] 85/21
137/5 156/13
page 33 [1] 141/18
page 4 [1] 131/13
page 41 [1] 80/2
page 5 [1] 98/4
page 6 [2] 49/25
124/10
page 65 [1] 42/25
page 67 [2] 43/2
44/20
page 68 [1] 43/4
page 7 [3] 102/13
113/4 120/22
page 8 [1] 10/2
page 81 [1] 49/22
page 86 [1] 4/4
Page 87 [1] 76/9
page 9 [1] 117/24
page 98 [1] 131/19
pagination [1] 49/22
Panter [1] 64/22
paper [6] 102/16
118/2 165/12
para [1] 125/8
paragraph [69] 11/9
17/24 25/7 26/3 27/4
34/24 34/25 35/25
39/23 40/3 55/12
56/24 65/12 67/6
76/10 77/17 80/1
80/13 84/16 86/5 86/7
88/6 114/23 117/25
124/21 125/12 126/16}
131/18 132/2 133/5
135/5 135/15 137/24
138/8 138/9 138/21
139/11 141/19 142/12)
143/4 144/16 145/1
145/12 145/18 146/23
147/6 147/8 147/19
147/21 148/5 148/10
148/13 148/15 149/6
149/11 149/17 149/19)
150/1 150/12 157/19
157/19 158/2 159/19
164/23 165/22 168/3
170/6 171/8 173/1
paragraph 1 [2]
149/6 157/19
paragraph 1.1 [1]
114/23
paragraph 102 [1]
141/19
paragraph 104 [1]
142/12
paragraph 107 [1]
145/1
paragraph 127 [2]
80/1 84/16
104/18 131/23 132/19}
107/10 108/24 110/15
paragraph 128 [1]
80/13
paragraph 2 [2] 86/7
157/19
paragraph 294 [1]
131/18
paragraph 313 [1]
138/21
paragraph 316 [2]
76/10 139/11
paragraph 43 [2]
55/12 56/24
paragraph 473 [1]
39/23
paragraph 54 [1]
25/7
paragraph 80b [1]
26/3
paragraphs [32] 4/3
14/10 14/11 14/12
21/3 25/3 107/3 118/7,
124/19 125/7 135/2
137/7 137/8 137/21
141/22 141/24 142/2
142/6 142/10 143/17
144/6 144/8 144/13
144/19 145/3 146/25
148/8 156/14 156/15
160/17 169/18 170/7
paragraphs 1 [1]
21/3
paragraphs 164 [1]
118/7
paragraphs 2 [1]
160/17
paragraphs 251 [1]
A4I3
paragraphs 53 [1]
25/3
Parker [3] 76/24
77/11 78/22
Parliament [1]
108/13
part [44] 6/6 6/12
6/16 7/16 8/23 11/6
19/17 22/25 28/14
39/11 41/19 46/22
47/20 57/23 62/5
68/23 69/4 69/8 71/25
72/16 86/3 87/4 88/1
94/13 102/11 107/17
113/3 114/8 120/3
123/21 126/12 126/14
128/9 131/4 132/13
133/13 144/25 147/25}
150/4 153/5 166/1
167/11 167/14 168/6
Part 18 [2] 8/23 11/6
partial [1] 100/21
particular [14] 25/21
27/1 42/5 72/2 81/5
81/13 87/13 101/22
119/20 135/1 136/18
137/20 143/11 172/24
particularly [4] 32/25
56/7 60/15 116/2
parties [2] 7/22
101/20
parts [4] 20/21 25/5
117/14 135/13
party [2] 38/1 115/9
passage [3] 45/1
158/6 166/15
passages [1] 154/18
passed [4] 31/21
38/9 107/23 169/2
past [1] 111/16
pausing [1] 169/6
payments [4] 34/10
34/16 34/25 37/7
PC [2] 27/1 170/17
PCs [1] 61/15
PEAK [31] 31/21
159/21 160/4 160/7
160/7 160/9 160/10
160/13 160/18 160/22)
161/1 161/4 161/5
161/9 161/12 161/15
162/8 162/16 162/25
163/23 164/8 164/22
165/10 165/12 165/13}
165/14 172/12 172/13}
172/14 172/16 173/9
PEAKs [4] 32/4 32/20
38/9 163/5
Pearce [7] 1/11 1/16
2/3 3/2 10/16 18/1
19/7
pejorative [1] 54/2
Penny [15] 32/13
125/10 125/18 126/10)
143/9 156/10 158/10
163/3 163/16 163/21
164/7 164/11 164/21
165/18 172/11
Penny Thomas' [1]
165/18
people [13] 26/22
33/6 42/6 47/6 56/19
57/22 68/22 93/2
115/15 115/20 136/1
145/16 161/6
per [5] 29/16 37/4
132/4 135/8 135/12
perceived [1] 71/8
perfect [3] 19/14
43/1 141/18
perfectly [2] 169/1
170/23
perform [1] 33/15
performed [1] 161/17
performing [1] 17/18
perhaps [6] 42/16
54/22 75/9 132/12
134/2 135/20
period [7] 26/25
52/11 52/13 125/9
132/18 144/1 168/23
(62) ordinary... - period
Pp
periods [5] 159/24
160/21 160/23 163/17)
165/1
permanently [2]
55/18 56/17
permission [2]
103/20 175/2
persistent [1] 149/14
person [3] 14/20
18/2 19/7
personal [5] 62/16
156/5 157/13 158/11
158/18
personally [2] 143/15)
150/12
personnel [1] 70/19
perspective [2]
37/17 102/25
persuade [1] 134/1
perusal [1] 130/19
Pete [1] 33/12
phase [1] 119/24
phone [1] 127/5
phoned [1] 92/25
phrase [1] 165/11
phrases [1] 41/12
physically [2] 60/24
61/3
pick [2] 76/10 150/25
picked [1] 68/24
picture [9] 87/21
87/24 88/1 89/14
89/15 90/1 100/20
100/21 101/25
piece [1] 114/2
pieces [1] 101/9
pile [1] 173/22
pilot [3] 119/23
119/24 119/25
Pinder [14] 4/16 5/2
6/7 24/4 125/24 127/2
127/7 129/2 129/19
131/24 140/16 151/4
156/11 162/14
Pinder's [2] 5/12
129/10
PinICLs [5] 32/4
32/20 33/1 33/1 38/9
place [8] 44/2 62/22
63/12 63/14 63/16
75/12 88/2 167/24
placed [1] 108/18
plain [1] 10/7
platform [1] 9/9
play [2] 133/24 134/3
pleadings [1] 7/22
please [108] 1/24
1/25 4/2 6/5 6/22 7/4
7/20 8/11 10/1 10/3
12/22 14/4 19/3 19/16}
19/16 21/3 24/25
24/25 25/5 25/6 26/3
27/24 27/25 28/1 28/1
28/6 29/11 31/19 33/8
33/9 35/22 37/14
39/19 39/22 42/22
42/25 49/19 49/21
55/12 60/8 60/21
63/18 64/6 64/18
64/19 65/11 65/19
65/22 71/5 71/10
72/19 73/13 76/9 76/9)
79/23 80/1 80/25
85/21 85/22 87/14
89/4 90/17 91/15
95/13 95/19 98/4
99/19 99/24 102/13
104/17 104/18 104/19)
109/5 109/7 111/9
111/16 113/4 117/24
120/22 124/10 124/17)
125/23 126/5 128/2
130/21 131/13 131/23)
132/24 133/5 133/12
134/9 134/18 134/21
136/22 138/9 141/17
149/5 153/1 156/21
157/19 158/22 159/18
162/12 165/21 166/21
168/11 168/13 174/21
plus [1] 81/9
pm [5] 91/17 91/19
150/20 150/22 175/10)
POA [1] 70/24
point [13] 4/15 15/7
15/8 18/21 43/14 64/5
73/3 82/14 85/3
102/15 117/19 130/8
139/13
pointed [1] 79/1
pointing [1] 78/19
points [4] 66/10
66/19 79/24 172/5
POL [2] 70/22 106/10
POL00071418 [1]
8/10
POL00081928 [1]
27124
POL00088935 [1]
102/4
POL00097217 [1]
64/18
POL00097480 [1]
85/21
POL00098724 [1]
70/4
POLSAP [1] 80/22
poor [3] 154/2
166/14 173/20
position [12] 39/1
60/22 61/16 75/18
76/15 77/11 77/23
79/13 142/20 170/3
171/4 172/6
108/25
possible [26] 30/22
36/20 42/13 45/11
46/2 46/9 48/24 49/12)
52/2 52/11 57/5 59/8
67/8 67/9 67/10 67/23
68/2 69/13 71/6 71/7
75/1 100/8 106/4
106/5 109/15 134/22
possibly [1] 71/3
post [100] 4/25 5/21
28/20 29/8 33/17
34/18 35/5 35/10
35/13 35/18 35/19
35/21 38/17 38/22
39/2 39/8 40/5 40/15
43/6 50/2 50/12 55/15)
55/17 56/16 56/20
61/11 61/14 64/4
67/13 69/3 69/6 70/9
70/13 70/15 70/18
72/3 72/4 72/7 72/11
72/25 73/6 74/15
75/22 76/4 76/19 83/7
83/24 84/3 85/5 90/11
90/13 90/15 94/6
94/19 94/23 94/24
95/8 96/22 98/6 98/14
100/25 101/16 102/8
105/13 105/16 105/17,
105/23 106/3 106/7
106/9 106/18 106/20
106/23 106/25 107/9
108/18 109/18 110/4
113/8 121/13 122/16
124/1 124/3 125/6
125/16 125/20 127/3
134/1 138/23 140/10
140/24 152/13 152/17]
157/2 158/25 159/23
160/20 164/25 167/18}
174/5
postmaster [10]
48/10 50/3 50/6 51/9
51/10 51/12 51/14
73/18 87/7 167/18
potential [1] 62/24
potentially [3] 151/13}
152/3 173/18
practical [1] 117/21
practice [3] 47/15
47/17 48/3
practices [1] 62/18
precise [2] 58/17
74/18
precisely [1] 39/1
prefer [1] 91/11
prejudice [4] 97/11
97/11 98/7 98/9
preparation [3] 62/5
72/17 102/11
prepare [4] 1/17
110/10 139/23 141/8
prepared [8] 54/17
92/17 93/10 94/10
94/23 97/17 97/20
113/16
preparing [11] 4/14
32/18 32/19 33/20
77/11 78/3 94/6 97/24,
106/4 140/9 140/22
presence [1] 25/25
present [4] 89/25
101/16 106/19 123/10}
presented [9] 55/4
122/22 123/7 123/17
129/23 141/11 162/17]
163/10 167/16
presently [1] 152/9
press [7] 105/25
106/17 106/18 106/19}
106/23 109/12 162/1
pressure [2] 173/22
174/16
presumably [6]
119/3 132/2 146/1
146/10 155/17 164/3
pretty [1] 50/16
prevented [1] 46/13
previous [11] 19/3
31/13 47/7 63/25 65/4
65/17 66/1 79/2
125/11 156/19 163/2
previously [5] 28/19
30/24 47/4 71/2
151/12
primarily [2] 74/13
93/18
primary [1] 33/5
print [1] 133/1
printed [1] 103/9
prior [2] 77/12 108/1
privileged [3] 61/13
61/19 62/11
probably [23] 5/10
5/18 10/22 11/3 11/24
11/24 12/5 12/19
32/24 33/1 57/2 60/13)
63/7 74/2 76/7 78/2
78/22 114/7 116/1
149/16 157/5 158/4
174/12
problem [32] 12/3
20/17 26/2 26/12 27/6
27/15 30/9 30/22 31/2,
31/11 33/11 33/19
34/2 34/12 34/14 35/9
36/5 37/9 37/16 37/23,
39/5 39/8 39/10 39/14)
39/16 80/10 81/18
84/20 85/15 122/8
133/16 173/5
problems [7] 25/10
26/7 28/22 28/24
120/9 135/21 146/10
procedures [1] 61/10
proceedings [10]
5/22 54/7 54/13 75/1
75/2 140/23 151/23
155/18 166/25 168/8
process [16] 30/11
30/20 35/5 38/17 41/8
41/10 69/4 85/17 87/5)
87/10 114/13 122/17
143/14 144/16 157/10)
169/11
processed [2]
125/13 126/17
processes [12] 41/4
42/8 61/4 63/12 63/13)
63/16 68/8 74/6 75/22I
75/25 76/2 102/17
processing [2] 50/5
99/21
Processor [1] 145/7
produce [17] 12/13
19/10 35/18 93/6
93/23 93/25 94/2
100/23 101/6 101/22
110/21 110/24 113/18)
123/3 130/6 165/8
172/16
produced [30] 16/16
27/11 33/20 66/2
78/17 85/24 88/15
94/25 96/14 96/15
109/18 109/21 110/4
110/7 110/20 117/2
121/4 121/9 122/25
130/4 132/5 135/9
144/2 144/18 151/19
158/10 158/17 163/3
172/2 1721/4
producing [7] 43/25
145/16 158/1 158/8
171/11 172/8 172/22
production [4]
143/21 144/14 145/5
148/1
Professor [3] 18/16
40/3 40/14
Professor
McLachlan [1] 18/16)
Professor
McLachlan's [1]
40/14
programme [1] 106/2
project [1] 116/6
proof [2] 55/3 120/20
proper [5] 123/10
144/13 145/4 147/1
147/20
properly [17] 75/4
138/13 142/8 142/9
144/23 145/9 145/24
146/7 146/10 147/15
147/17 148/18 148/19)
150/13 169/25 170/1
170/19
propose [1] 66/22
proposed [5] 21/21
39/5 67/17 93/14
(63) periods - proposed
P
proposed... [1]
130/14
proprietary [1]
162/23
propriety [2] 27/14
69/20
prosecuting [1] 84/5
prosecution [12]
84/14 130/23 131/7
138/25 140/12 140/24}
142/13 142/24 152/11
159/1 159/2 174/4
prosecutions [2]
95/6 121/6
prosecutor [2]
157/12 167/6
prosecutors [1]
89/13
prospects [1] 152/10
Protection [1] 63/3
prove [5] 54/13 65/13)
117/22 119/2 119/3
proved [2] 120/2
120/13
provide [22] 4/8
13/12 33/10 66/23
72/22 74/22 81/3
83/18 84/5 84/11
92/21 101/15 105/19
112/8 113/8 114/4
115/5 116/6 120/24
127/16 129/7 141/7
provided [25] 9/20
13/10 18/8 22/2 39/2
53/14 53/15 60/18
81/2 82/13 82/19
83/19 94/14 100/25
103/6 118/17 127/15
127/19 141/13 163/13)
163/16 163/22 164/7
164/11 164/21
provider [3] 13/18
14/15 140/7
provides [2] 67/4
136/24
providing [12] 13/3
14/20 38/17 88/1
100/20 115/22 126/7
127/22 127/22 128/23}
129/4 140/18
pulling [2] 57/3 57/14
purely [4] 89/16 95/1
127/12 168/4
purpose [27] 5/17
80/21 84/12 87/6
92/19 93/11 94/10
94/15 94/23 98/5
111/4 111/5 111/6
111/23 112/9 112/10
115/14 115/22 115/25}
116/4 116/11 116/12
117/25 118/1 119/4
122/18 122/23
purposes [19] 4/14
6/11 22/21 31/7 33/11
55/22 56/2 57/1 79/12
86/7 97/20 98/1 98/7
110/12 121/16 122/19)
132/12 140/23 161/3
pursue [2] 24/22
90/15
pursued [1] 90/12
pursuing [1] 84/4
pushback [1] 169/13
put [13] 12/12 43/3
46/3 78/15 89/17
97/12 97/15 98/8
126/8 126/20 130/18
146/5 161/1
putting [3] 12/10
78/11 107/21
Qu
qualified [1] 143/13
qualify [2] 15/14
26/14
quantified [1] 52/4
quantify [1] 52/6
queries [2] 5/14
11/12
querying [1] 105/22
question [15] 4/17
4/19 17/8 21/5 43/8
49/23 52/14 81/20
119/21 132/18 139/5
140/14 141/20 144/8
153/16
questioned [4] 1/4
65/15 67/4 176/4
questions [22] 4/18
7/25 10/13 11/8 19/5
20/15 20/23 21/15
21/18 31/6 71/17 73/6
80/25 83/21 92/15
106/5 106/22 109/18
110/1 110/19 123/22
174/14
queue [1] 103/2
quickly [1] 97/7
quite [14] 17/20
36/18 38/4 41/20
TAIT 77/15 85/22
115/24 122/13 122/19)
133/16 134/15 152/19)
172/15,
quote [1] 3/7
quoting [1] 37/10
R
Rachael [1] 64/22
raised [11] 1/18 13/4
35/15 65/17 66/19
94/21 95/9 108/25
110/20 139/1 144/8
raising [1] 122/14
ran [1] 124/1
rare [4] 54/24 67/12
68/19 70/2
rarely [2] 55/2 71/6
rather [17] 10/4
13/22 18/20 45/14
46/21 46/25 48/8 52/8
72/11 75/4 77/8 79/21
95/6 142/14 142/25
152/21 163/22
raw [7] 68/9 68/15
80/16 82/1 82/2 86/11
163/3
re [7] 5/14 11/12 29/5
126/4 126/25 131/15
171/9
re-emerged [1] 171/9
re-read [1] 29/5
reach [2] 81/4 81/12
reached [1] 102/20
read [37] 4/4 5/10
6/19 10/21 10/23 11/3
11/22 11/24 11/25
12/16 12/19 12/20
13/17 13/25 14/1 14/3
14/5 14/9 14/11 14/12
14/13 14/14 27/4 29/5
29/24 40/1 43/3 43/8
65/25 88/6 109/2
126/12 141/25 154/10
154/12 155/1 155/25
reading [8] 5/13
11/11 12/4 17/25
60/19 66/9 78/24
160/16
reads [3] 154/10
158/6 165/24
real [3] 52/21 53/1
55/2
realise [10] 41/19
42/16 53/8 54/22 55/1
61/21 62/3 69/21
73/20 160/10
realised [12] 9/13
14/24 47/24 48/25
53/9 62/10 78/15
78/20 84/11 146/21
155/17 165/7
reality [1] 101/15
really [9] 11/18 18/4
47/25 93/4 116/1
154/2 166/14 170/18
173/20
reappeared [3] 34/8
108/10 108/16
reappraisal [1]
101/19
reason [19] 17/9
27/13 42/11 85/10
87/17 88/1 125/2
137/8 138/6 141/4
146/16 147/13 147/20
147/23 154/8 154/8
161/23 166/6 169/21
reasonable [1]
129/25
reasonably [1] 97/25
reasons [5] 121/16
128/8 153/4 153/17
165/25
rebooted [2] 27/1
86/14
rebuild [1] 50/22
recall [6] 5/12 5/16
44/9 45/7 125/10
138/23
recap [1] 2/17
receipts [3] 34/16
34/25 37/7
receive [2] 15/7
157/7
received [13] 12/15
15/6 15/10 15/14
15/19 15/21 16/11
18/22 135/22 138/19
140/16 157/8 168/22
receiving [4] 18/20
34/4 36/7 138/23
recent [1] 126/5
Recently [1] 105/21
recognise [4] 28/13
28/13 64/2 72/16
recollect [1] 57/10
recollection [12] 2/8
3/22 11/4 15/6 15/8
16/17 19/1 59/13
104/23 127/24 131/5
159/12
reconciliation [6]
34/17 35/5 35/7 35/17
122/12 167/24
record [1] 73/1
recorded [8] 5/9 41/4
41/7 4119 41/25 51/8
81/17 118/10
recording [2] 81/18
120/11
records [6] 137/9
137/22 137/25 144/16}
150/3 150/4
recount [1] 25/4
recoveries [1] 89/16
recovery [2] 87/5
89/10
rectify [1] 25/22
red [3] 135/10 135/13
136/23
redacted [1] 125/2
refer [12] 8/4 9/6
9/18 13/18 14/15 86/1
125/11 126/24 137/9
148/14 150/3 171/1
reference [20] 5/3
5/7 7/19 8/8 19/14
20/10 28/3 33/5 33/22
64/14 72/6 109/25
110/2 113/4 113/18
116/6 120/23 149/11
149/12 173/23
references [2] 31/21
64/13
referred [8] 29/4
35/10 39/12 65/19
143/5 144/17 148/21
148/22
referring [21] 11/10
56/19 56/22 57/14
66/4 68/11 70/18
70/24 72/4 72/7 88/17,
90/25 101/17 135/20
137/20 142/20 144/21
159/10 163/21 170/14}
171/11
refers [2] 148/13
17112
reflect [6] 87/7 87/12
88/2 96/11 101/24
173/11
reflected [3] 3/23
75/19 117/24
reflecting [2] 81/16
169/14
reflection [2] 23/15
35/2
reflective [1] 74/25
reflects [1] 118/4
refuse [1] 83/18
refute [1] 105/19
regard [3] 40/12
1457/1 157/11
regarding [4] 66/12
67/5 126/6 139/24
regenerated [1]
165/23
region [1] 40/22
regular [1] 39/18
regularly [2] 26/25
59/9
regulated [1] 40/19
rehearsed [1] 142/17
relate [1] 125/6
related [8] 28/19
40/15 67/14 105/3
144/13 144/16 145/3
147/19
relates [2] 125/10
145/13
relating [1] 150/4
relation [7] 75/14
93/9 112/14 122/1
131/25 170/3 173/2
relatively [2] 89/7
141/5
release [2] 34/14
96/7
relevance [2] 37/6
80/21
relevant [9] 8/2 8/6
32/5 42/15 42/17
54/21 59/4 86/25
122/4
reliability [2] 79/24
122/24
(64) proposed... - reliability
R
reliable [3] 80/17
81/12 85/2
relied [4] 89/13 94/5
98/20 104/8
rely [2] 33/1 164/12
relying [1] 74/23
remain [2] 10/19
12/24
remains [1] 166/14
remember [65] 1/14
1/15 1/21 1/22 1/25
2/4 2/5 2/8 3/13 3/17
21/5 31/23 33/13 35/7,
35/16 43/24 45/3 45/8
51/13 52/6 52/14 55/9
59/13 59/18 61/17
62/12 63/17 71/21
71/25 72/14 74/2 78/1
79/19 91/5 91/6 92/23,
97/1 97/16 98/11
104/19 105/3 109/2
111/25 112/24 113/2
114/20 115/19 127/2
127/11 131/3 137/5
141/10 141/14 148/9
149/22 159/7 159/8
159/9 159/17 161/25
163/25 164/4 165/4
165/15 169/19
remembered [5] 2/11
2/19 16/7 18/11 18/22
remembering [2]
15/9 44/5
remming [1] 100/17
remote [31] 39/20
39/24 40/9 40/11
40/13 40/18 40/21
41/1 41/5 41/14 41/24
42/10 42/12 55/7
55/21 57/11 58/19
58/21 58/22 58/25
59/2 59/11 59/16
63/23 66/12 66/17
67/22 69/10 70/1 78/6
78/9
remotely [7] 41/16
55/24 57/18 57/25
58/6 67/8 79/4
remove [1] 173/22
removed [1] 156/18
reoccur [1] 27/17
repeat [1] 37/8
repeated [1] 31/25
rephrases [1] 37/1
replace [1] 102/16
replaced [2] 166/19
169/20
replicated [2] 102/19
102/21
replies [8] 6/12 6/16
7/16 8/23 11/6 66/15
87/15 131/24
reply [15] 21/19
65/22 71/20 71/23
73/13 75/7 89/4 89/24)
127/21 128/3 133/13
134/10 156/22 166/15)
171/18
replying [1] 21/15
report [99] 1/17 1/18
1/21 12/11 12/12
12/13 13/13 13/19
14/8 14/8 14/16 17/7
17/11 18/2 18/2 18/17
18/17 19/8 19/11 35/8)
64/23 65/3 65/6 65/12
65/17 67/4 85/24
88/14 88/17 89/8 91/6
92/17 92/20 92/21
93/3 93/6 93/9 93/25
94/2 94/3 94/5 94/6
94/13 94/19 94/20
94/22 95/4 95/9 95/14)
95/14 96/11 96/12
96/15 98/20 100/9
100/24 101/7 101/10
101/18 101/24 102/5
103/11 103/13 103/17)
103/18 104/2 104/5
104/8 104/9 104/11
104/14 104/15 104/22)
104/25 107/13 107/15)
107/18 107/23 107/25)
109/2 110/2 110/16
110/21 110/24 111/8
111/23 112/6 113/13
113/15 113/18 118/8
118/14 118/22 119/8
119/14 120/3 120/24
127/15 127/19
reported [1] 34/18
reporting [1] 122/15
reports [25] 16/15
24/15 24/19 34/17
35/15 35/18 35/20
42/13 73/18 84/5 85/4
87/19 90/18 90/21
90/24 91/4 91/24
91/25 92/16 93/20
95/13 117/1 121/18
123/4 123/11
repository [1] 160/11
representation [3]
27/7 77/16 169/9
reproduce [1] 26/2
repurposed [1]
103/24
request [13] 4/5 65/3
65/5 65/8 90/11 106/9)
106/17 107/24 124/16)
125/18 125/19 127/10)
140/16
requested [5] 107/10
107/13 140/10 160/21
171/20
requests [2] 72/11
127/3
require [4] 5/15
11/13 122/12 124/25
required [12] 20/6
23/24 24/5 27/10
27/21 61/12 90/11
96/16 101/11 107/1
109/21 157/2
requirement [4]
113/10 113/14 114/5
121/1
requirements [4]
17/25 60/5 131/17
171/23
requires [1] 98/14
requiring [1] 61/10
research [3] 20/4
32/21 118/20
researching [1] 75/4
resilient [1] 103/1
resolution [1] 29/2
resolved’ [1] 71/9
respect [9] 2/15
26/19 72/22 77/4 80/4
125/1 138/13 148/18
169/25
respond [2] 5/19
128/23
responded [1] 38/11
responding [4] 20/24
40/14 40/17 106/22
response [18] 4/19
70/8 71/11 71/15
106/13 127/9 128/14
128/15 128/18 128/23}
130/18 132/10 133/18
134/14 168/14 168/18
168/21 168/22
responses [1] 106/5
responsibilities [3]
3/12 15/13 18/7
responsibility [1]
39/9
responsible [4]
39/14 50/9 84/3 170/3
responsibly [1] 54/4
rest [2] 153/17 158/2
restarted [1] 30/14
restrict [1] 62/23
restricted [1] 118/2
result [12] 28/17
37/18 51/21 63/1 77/1
78/12 78/25 85/24
108/24 122/12 169/2
173/25
resulted [1] 26/7
results [2] 162/17
163/10
resume [2] 49/10
91/14
retained [1] 100/6
retired [3] 35/24 64/4
64/8
retrieval [1] 143/7
retrieved [1] 43/16
retrospective [1]
28/18
returned [2] 86/3
97/4
reused [1] 103/21
revealed [2] 47/7
86/25
reversal [6] 86/11
87/6 87/11 87/25 88/2
89/9
review [13] 96/16
96/17 96/19 112/2
113/11 113/23 113/25)
114/4 114/10 114/12
114/14 114/25 115/9
reviewed [2] 96/25
97/7
reviewer [1] 97/3
reviews [1] 72/1
revisions [1] 134/25
reword [1] 154/20
Richard [2] 49/20
78/24
right [52] 17/20
20/13 21/12 24/7 33/6
45/13 53/11 60/17
69/18 77/21 78/12
81/15 86/20 87/22
91/14 91/16 96/1
96/23 99/18 107/19
109/20 116/9 116/19
118/12 120/7 124/13
135/24 137/13 142/2
144/10 145/13 145/18
146/16 147/9 148/13
149/6 149/22 149/24
150/1 151/17 160/4
161/21 161/24 162/2
162/8 162/21 165/20
166/16 174/18 174/19}
175/7 175/9
right-hand [10] 142/2
144/10 145/13 145/18)
147/9 149/6 161/21
162/2 162/8 165/20
rightly [5] 31/23
37/20 162/1 165/6
17215
Riposte [15] 25/19
27/10 29/14 30/2 30/3)
30/11 30/13 30/22
31/1 31/14 32/2 48/11
53/14 122/3 122/7
risk [2] 63/1 84/22
risks [2] 25/12 62/24
RLITO000005 [1]
76/9
Roberts [1] 106/16
Roberts’ [1] 107/24
robust [1] 102/24
robustness [6] 66/12
66/17 94/7 115/5
115/13 115/23
role [1] 162/3
Roll [1] 49/21
Roll's [3] 51/22 77/1
78/24
root [1] 31/18
Rose [3] 85/23 87/14
89/24
round [1] 23/22
routinely [3] 55/20
56/25 69/14
Rule [1] 4/5
Rule 9 [1] 4/5
rumoured [1] 106/1
running [1] 105/12
rusty [1] 51/8
s
$90 [1] 34/14
safe [1] 31/4
safest [1] 30/25
said [58] 2/7 2/9 2/10
2/14 2/17 2/18 2/19
2/23 3/1 3/5 3/6 3/19
TINT 9/14 12/15 14/25]
15/10 15/16 16/5
16/17 16/22 30/15
31/23 35/8 38/6 43/4
43/12 45/2 47/6 57/2
57/21 58/9 58/12
70/18 70/24 71/12
79/3 79/18 86/1 93/4
98/10 99/13 104/7
113/20 127/5 129/2
133/17 134/19 137/6
137/11 138/16 146/21
150/12 164/12 164/15)
165/8 165/13 1741/7
Sale [1] 102/16
same [15] 8/17 8/18
10/5 20/10 25/14
25/15 27/6 30/11
85/19 114/9 128/3
133/10 153/18 158/22)
172/25
satisfied [2] 24/13
146/1
satisfy [1] 122/23
saw [14] 1/11 21/10
22/12 31/1 38/9 62/4
95/1 102/11 140/20
152/20 152/23 154/19)
155/13 157/9
say [107] 5/23 8/6
12/17 12/19 14/7
15/14 17/12 19/16
22/11 22/19 24/8 25/7I
26/4 29/3 40/2 46/14
48/24 49/23 50/11
50/12 53/7 58/12 59/5
65/15 65/24 66/21
67/15 67/21 67/25
68/7 68/11 68/16
69/15 69/23 69/23
73/5 75/8 75/21 76/5
(65) reliable - say
Ss
say... [68] 79/3 79/7
80/2 80/13 86/2 86/5
99/14 100/2 101/5
101/7 101/21 110/7
110/15 110/25 116/2
118/5 120/14 127/19
133/23 134/24 136/4
136/6 137/15 137/24
138/2 138/5 141/18
145/1 146/24 148/17
149/1 149/7 150/5
150/8 150/9 150/13
152/12 154/23 156/7
159/19 160/14 160/16
160/17 160/18 161/14
161/21 162/2 162/7
162/14 163/9 164/23
165/7 166/21 166/25
168/20 171/4 171/9
174/3
saying [35] 3/13
11/14 21/19 22/10
23/1 27/3 29/13 36/16
44/5 44/6 44/10 52/22
53/25 68/23 69/25
73/22 88/11 90/3 93/2
113/12 120/2 127/4
136/9 137/21 145/6
145/12 150/6 150/10
150/11 152/22 158/14
160/12 161/16 164/6
170/18
says [32] 7/1 16/2
26/15 33/12 34/25
35/25 36/3 55/13 56/5)
62/13 65/1 70/7 72/21
79/16 88/25 92/25
105/6 109/11 110/4
113/12 124/12 124/17)
124/24 126/2 126/25
131/25 138/5 138/10
151/9 160/5 163/24
169/8
scan [2] 13/16 21/12
scanned [8] 5/6 5/14
7/8 7/15 7/18 11/12
11/15 12/9
scared [1] 136/20
scenario [1] 89/19
scenarios [6] 92/22
99/2 99/25 100/3
100/8 100/25
scope [18] 38/22
80/19 90/24 93/6
93/17 94/2 100/24
101/5 112/11 113/24
118/2 119/14 119/22
122/9 127/20 130/13
130/14 152/6
89/4 89/24 90/1 91/15
128/16 128/24 129/17)
129/19 131/10 133/23}
scoping [1] 112/7
scratch [4] 158/13
screen [8] 1/24 8/22
14/2 14/3 17/12 26/7
107/12 141/16
scroll [63] 1/24 10/3
28/8 28/10 35/22
64/6 64/19 64/20
65/22 66/14 66/21
70/6 71/10 71/22
72/19 72/20 73/13
75/7 84/16 85/22
87/14 95/20 95/20
99/24 104/18 109/5
109/7 111/19 124/17
134/9 134/23 135/4
136/22 137/4 137/5
149/6 151/2 153/1
168/13
scrolling [6] 2/2 2/2
21/14 29/11 29/12
63/19
search [1] 28/18
searched [1] 32/4
searches [1] 32/25
second [31] 5/25 7/7
8/21 11/9 25/2 25/6
55/9 71/17 74/14 88/6
92/6 108/1 108/3
110/10 113/23 113/24)
114/2 114/9 114/18
123/21 131/6 133/5
137/20 137/24 138/9
141/17 144/15 149/7
150/1 152/25 164/23
secondly [2] 44/10
62/13
seconds [3] 26/25
30/12 30/12
secret [1] 175/1
section [3] 109/23
111/3 146/15
section 3 [2] 109/23
111/3
secure [5] 60/6 60/24
61/3 62/15 63/24
security [11] 61/5
102/18 102/19 102/25)
113/9 113/14 114/5
115/3 118/17 118/18
120/25
see [114] 2/23 4/17
5/25 7/6 7/8 7/10 7/13)
7/20 8/17 8/19 8/22
9/1 9/3 9/4 10/8 17/13
17/15 20/7 20/20
161/22 164/13 164/16)
21/3 21/4 21/12 21/14
21/20 27/25 28/1 28/6
37/14 43/2 60/8 60/10)
124/21 125/23 128/22
129/16 129/17 130/17)
156/13 157/18 159/18)
164/21 165/22 168/12)
21/14 21/20 21/25
23/2 23/14 28/7 28/9
29/11 29/19 29/24
31/2 32/13 33/12
34/24 35/25 36/19
36/25 38/5 38/16
45/21 59/20 59/23
60/4 63/21 64/2 64/11
72/10 72/20 73/1
87/10 87/14 87/16
95/15 95/16 95/21
95/22 95/25 96/1
96/16 98/4 101/5
102/10 103/9 111/9
118/25 122/18 124/9
124/23 126/5 127/1
127/13 127/16 127/21
132/21 132/22 132/24
133/13 133/23 135/4
135/10 135/15 136/1
136/12 138/5 142/2
144/6 145/12 147/6
147/11 151/5 154/19
155/1 156/13 157/20
157/21 159/8 159/9
159/14 167/5 167/7
167/8 169/17
seeing [1] 51/22
seek [3] 120/24
148/6 154/7
seeking [4] 151/21
152/8 154/19 155/1
Seema [7] 16/16
16/24 31/7 33/22
39/25 63/9 174/11
seemed [1] 114/9
seems [5] 4/19 59/2
126/24 127/16 154/2
seen [33] 2/24 4/13
16/10 16/20 16/22
18/12 22/25 23/6
27/17 38/15 41/12
57/6 60/12 64/16 79/3
T9IT 82/9 82/22 82/24)
83/11 88/3 93/1 94/12
94/13 97/7 113/3
120/11 127/24 142/17
142/21 144/4 161/5
166/17
selected [2] 101/12
101/14
send [3] 19/24 126/9
134/22
sending [1] 156/22
sends [1] 131/14
senior [2] 33/18
120/18
sense [8] 25/14
101/14 143/17 145/16
147/7 148/11 157/18
65/19 65/22 66/9 71/5
111/10 111/13 111/17]
124/10 124/12 124/14
131/13 131/24 132/19}
171/2
sensible [1] 146/23
sent [33] 2/7 2/11
10/20 11/21 12/18
13/7 24/14 28/12
65/25 70/7 71/12
78/17 78/21 88/14
88/18 97/5 107/25
107/25 132/1 132/5
133/9 134/21 138/4
151/6 152/16 156/19
157/15 162/14 173/6
sentence [3] 7/12
11/14 138/9
separate [7] 29/3
29/14 29/18 31/25
September [6] 55/14
56/11 58/16 59/11
78/2 106/10
series [2] 24/10
101/19
serious [1] 155/17
server [21] 27/1
46/21 47/1 47/11
47/18 57/7 58/11 59/1
63/24 73/25 74/5
76/14 77/23 79/21
80/9 80/11 84/17
84/21 84/23 85/14
85/16
servers [2] 50/2 60/7
service [4] 30/13
38/2 63/2 103/2
Services [3] 38/21
39/11 74/11
set [18] 3/2 7/12
14/22 15/13 18/15
19/4 22/18 22/20 40/1
65/10 99/25 103/13
107/6 126/13 142/1
142/12 142/23 143/22}
sets [6] 2/12 2/20
12/25 77/20 161/11
162/2
setting [2] 6/12
138/24
several [1] 99/2
shall [2] 49/10 91/14
she [26] 31/21 31/22
31/24 32/11 32/12
33/12 34/25 35/25
36/3 37/1 37/10 65/1
66/15 88/14 88/16
88/25 90/3 104/19
104/21 105/6 108/6
108/9 133/9 134/5
134/6 164/13
she'd [1] 88/15
short [8] 49/16 91/18
96/15 105/19 107/10
107/21 110/15 150/21
shortfall [1] 82/11
6/25 10/9 10/12 10/17,
124/22 124/25 163/17]
shortfalls [4] 42/14
82/21 82/24 83/10
shortly [1] 78/17
should [27] 17/12
22/9 27/8 43/3 54/22
68/9 75/22 82/22 83/2I
85/20 87/12 88/6
89/18 96/9 96/10
100/3 101/8 119/8
120/2 165/23 166/25
168/19 168/24 169/2
169/3 173/19 174/8
shouldn't [6] 29/24
29/24 44/1 46/10
111/5 174/25
show [16] 37/19
43/16 43/21 44/17
59/17 75/9 77/8 77/8
113/13 116/22 120/19)
121/23 123/15 142/7
159/13 172/2
showed [6] 1/23 2/3
8/15 34/16 35/1 160/1
showing [7] 30/19
117/11 117/20 118/2
119/10 119/11 123/12)
shown [8] 4/14 5/1
5/24 15/7 24/10 69/11
80/3 82/16
shows [1] 77/3
sic [1] 11/13
side [21] 36/19 36/19
141/16 141/16 142/2
144/10 145/13 145/18)
147/9 147/10 149/6
158/23 160/16 161/21
162/2 162/6 162/8
164/22 165/21 168/12!
169/17
Sight [8] 55/10 71/17
74/14 113/23 113/24
114/2 114/9 114/18
sign [9] 23/23 61/10
69/7 83/25 84/1 130/7I
130/9 159/6 174/4
sign-off [1] 61/10
signature [2] 126/11
130/19
signed [7] 21/21 65/5
75/23 76/4 97/6 143/8I
159/4
significance [2]
40/12 140/21
significant [1] 25/2
signs [1] 44/3
similar [4] 63/25
93/17 112/11 157/10
Simon [1] 70/5
Simpkins [6] 42/6
46/23 47/9 52/5 69/8
79/1
simple [12] 10/15
22/8 27/12 31/15 47/5I
63/17 89/7 106/5
(66) say... - simple
Ss
simple... [4] 139/5
140/13 141/3 159/7
simply [1] 149/20
since [6] 24/9 41/18
80/23 93/1 113/23
168/3
Sinclair [2] 109/8
109/9
single [4] 4/16 4/19
25/10 27/2
sir [10] 1/7 24/22
49/8 49/14 91/13
91/20 150/16 150/24
174/11 175/8
situation [3] 37/20
106/13 111/7
six [2] 4/24 19/4
size [1] 157/23
skimmed [2] 10/22
16/3
skip [2] 67/6 137/3
slightly [4] 36/4
73/14 163/1 171/21
slowly [2] 13/16
13/25
smaller [1] 157/23
Smith [8] 92/24
96/22 106/9 106/11
107/14 107/25 107/25
108/9
so [177]
software [5] 25/19
25/23 27/14 27/15
100/12
soli rs [1] 4/25
sol rs' [1] 65/7
solution [4] 64/7
89/14 106/24 113/9
some [78] 4/15 6/16
10/13 20/4 20/21
20/22 20/23 21/14
22/24 24/19 31/6
31/22 32/10 32/13
33/11 39/12 40/12
46/24 49/1 52/6 56/19
60/18 61/24 61/25
64/10 64/15 65/9
66/10 66/14 67/4
80/25 82/5 82/8 82/16
83/3 83/4 83/6 83/8
83/13 84/13 86/1
86/22 87/20 87/23
89/16 92/15 92/21
93/1 97/13 105/2
105/25 109/6 119/24
123/22 124/3 125/2
125/19 128/13 128/16)
128/22 128/22 130/8
132/16 133/19 134/2
142/5 143/19 146/20
151/16 153/9 153/21
153/24 156/24 157/1
158/9 161/23 167/13
170/12
somebody [7] 51/3
85/11 130/5 130/25
161/12 161/17 162/25,
someone [10] 48/15
76/17 97/12 98/10
98/18 109/23 111/1
130/6 151/14 160/9
something [31] 22/9
35/17 35/21 40/23
42/17 43/20 43/22
48/3 51/14 52/2 61/22
69/14 70/12 78/3
78/13 83/14 83/16
94/24 104/21 107/20
110/8 115/17 117/21
126/8 126/20 135/5
136/10 165/3 165/16
166/19 166/21
sometimes [9] 43/17
44/6 50/5 51/5 51/5
51/7 51/9 80/4 161/6
soon [2] 78/15
106/17
sorry [22] 12/1 26/17
45/9 63/20 68/6 75/7
77/15 77/18 99/12
99/16 111/17 113/2
118/18 124/18 129/16)
130/21 149/14 149/23}
150/1 150/8 161/3
164/4
sort [28] 12/14 13/13
17/11 18/5 19/22
29/21 53/15 57/22
83/3 83/6 84/13 84/13
93/17 97/13 105/4
112/11 128/13 128/16)
129/24 132/16 136/19)
145/16 145/17 146/20)
147/12 153/9 153/21
157/10
sorted [1] 129/11
sought [2] 14/16
111/4
source [2] 33/5 172/9I
spacings [1] 132/3
speak [4] 33/5
144/22 150/8 175/3
speaking [4] 41/24
58/17 63/25 168/1
species [1] 81/11
specific [22] 17/8
28/13 43/23 45/8
47/12 54/18 55/23
57/12 65/16 66/10
72/14 83/10 83/13
83/22 92/21 93/7
133/25 143/25 159/24)
160/21 160/23 165/1
specifically [5] 43/24
44/22 45/4 66/11 90/4
specifics [3] 66/13
82/16 83/3
speed [1] 91/21
speedy [1] 130/18
spelt [1] 57/9
spent [2] 107/17
107/19
spoke [3] 106/16
108/6 108/9
spoken [1] 59/16
spot [1] 72/1
spotted [2] 13/20
28/23
spreadsheet [5] 89/8
138/5 138/6 138/7
158/9
spreadsheets [20]
132/5 133/4 137/19
141/24 144/20 144/23
158/1 158/8 158/10
158/17 158/19 163/2
163/5 165/23 170/12
172/2 172/10 172/14
172/18 172/22
Square [20] 24/25
25/4 25/11 25/17 26/9
26/19 26/22 26/24
27/17 29/2 29/15
29/25 30/5 30/6 31/7
31/18 31/19 33/10
37/13 100/14
Square/Falkirk [1]
37/13
Square/Falkirk' [1]
25/11
SRO05 [1] 72/1
SSC [45] 32/24 33/6
38/6 38/10 38/12
39/17 41/4 42/4 43/21
44/12 44/15 44/18
45/11 46/2 46/16 47/7
47/16 47/19 48/9
48/25 51/3 51/18
51/23 53/22 54/4
54/10 54/19 54/24
55/1 56/22 57/2 57/5
57/22 60/16 60/19
60/25 61/18 62/10
68/7 68/20 70/2 73/23}
76/3 76/13 77/22
staff [13] 42/4 51/18
55/17 56/16 56/20
58/5 67/11 68/3 71/17
72/11 72/12 88/9 89/2
stage [14] 5/21 6/8
12/11 15/9 31/17 52/6
74/9 80/12 105/2
108/14 121/3 129/5
130/12 151/5
stages [1] 145/21
stand [2] 18/19 169/8}
standard [25] 21/21
45/17 45/20 45/23
46/7 52/17 52/21 53/4
54/7 54/12 75/14
86/8 86/19 90/5
141/22 143/1 143/4
143/8 143/17 144/5
144/15
stands [2] 10/16
35/16
start [10] 26/13 28/9
42/24 80/25 86/1
90/21 95/13 123/25
124/8 174/19
started [1] 114/10
starting [2] 124/20
124/22
state [3] 35/3 82/20
89/17
stated [3] 5/12 21/23
172/21
statement [186]
statements [19] 7/21
36/19 39/13 42/13
54/17 54/18 54/19
63/5 63/8 69/19 76/25
83/8 84/6 85/4 130/25)
132/8 152/21 158/9
174/5
states [1] 173/1
stationed [1] 70/21
status [2] 23/18
167/23
statutory [1] 156/2
Stephen [5] 4/7
19/24 20/1 20/2 20/14)
steps [1] 25/21
Steve [1] 78/22
stick [2] 12/1 12/21
still [10] 15/8 17/24
54/24 80/18 121/25
123/15 133/14 168/1
169/8 169/14
stock [8] 34/3 34/3
34/4 34/6 34/11 36/7
36/9 106/4
stop [8] 21/20 29/12
109/6 109/8 145/6
153/1 153/11 168/13
stopping [6] 7/6
51/17 66/25 115/8
142/16 169/5
storage [1] 143/7
store [3] 41/6 161/1
172/15
storm [3] 26/24
27/16 29/17
storms [1] 31/25
straightforward [1]
141/16
strange [1] 47/22
strengths [1] 102/22
strike [1] 12/5
strikes [1] 12/4
striking [1] 154/17
strong [3] 102/18
103/4 103/6
75/17 76/2 80/20 86/3}
struck [3] 153/11
153/13 153/18
stuck [2] 10/23 12/2
studies [1] 123/23
study [2] 144/7
174/12
sub [1] 125/16
subject [3] 106/3
122/6 124/16
submitted [2] 98/6
159/1
subpostmaster [25]
25/21 40/8 41/15 42/1
42/11 48/8 48/20 50/9)
51/4 52/19 53/6 54/9
56/1 57/19 58/1 58/8
59/4 72/25 76/17 87/1
87/13 88/3 105/9
122/14 140/24
subpostmaster's [5]
37/16 50/25 105/20
121/10 154/4
subpostmasters [9]
38/7 55/23 57/13
57/16 80/24 88/21
105/15 105/21 105/24)
subpostmasters' [1]
58/23
subsequent [2]
76/25 77/11
subsequently [3]
19/12 59/6 79/8
substance [4] 11/1
147/10 147/11 174/6
substitute [2] 123/3
123/10
subsumed [2] 93/13
113/24
subtle [3] 157/20
163/6 163/7
successful [1] 169/6
such [29] 3/24 20/4
26/7 31/14 34/7 57/11
63/10 67/9 67/12 69/2I
75/23 76/20 81/22
82/25 85/20 133/22
135/23 138/14 143/9
146/10 153/9 153/21
167/13 167/17 167/18}
170/1 171/13 171/15
173/5
suffered [1] 26/9
sufficient [7] 81/3
81/12 86/7 105/19
128/5 135/25 136/11
suggest [10] 12/2
40/20 67/16 69/24
128/6 129/18 143/1
149/20 166/21 166/24)
suggested [8] 6/10
7/15 17/20 18/1 57/4
142/6 149/19 151/11
suggesting [3] 12/20
149/20 156/8
(67) simple... - suggesting
Ss
suggestion [5] 18/14
22/17 114/11 123/9
167/3
suggests [2] 6/15
71/2
summarise [1] 86/18
summarised [2]
106/6 147/1
summarises [1]
32/12
summarising [2]
91/25 138/25
summary [8] 3/19
33/19 34/20 99/21
99/24 105/8 111/20
140/12
summertime [1] 7/1
supervisor [1] 40/8
supplemental [1]
110/10
supplied [2] 28/19
71/2
supplier [1] 109/16
supply [1] 128/17
support [26] 35/14
38/2 38/2 59/24 60/6
60/23 61/4 61/12
62/13 62/18 62/19
62/21 63/23 84/13
93/13 98/15 98/21
105/16 106/1 121/5
130/24 131/8 142/13
142/20 142/24 154/4
suppose [2] 127/2
157/5
supposed [7] 29/1
93/12 119/1 119/12
122/21 142/6 144/6
supposedly [1] 22/9
sure [34] 3/6 5/13
7/11 11/11 13/20
14/25 22/23 28/22
29/16 36/18 37/4 38/4
58/24 71/22 97/5
114/7 118/18 122/13
129/22 130/13 131/1
133/16 134/15 135/8
135/21 136/2 137/17
138/16 157/25 158/4
158/7 165/3 166/20
171/25
surprised [1] 61/7
surrogate [1] 114/3
surrounding [1]
105/14
survey [2] 110/16
110/22
suspect [5] 86/14
89/21 121/8 128/21
135/8
Suzie [4] 96/17
104/19 106/16 109/13
swiftly [1] 66/18
switch [1] 8/11
symptoms [1] 30/18
synthesise [1] 44/6
system [108] 21/5
21/7 29/20 34/13 50/8
56/21 59/24 60/23
61/14 65/15 66/12
66/17 67/3 67/8 67/10
67/22 68/1 68/13
70/10 70/14 70/16
71/4 71/18 80/18
80/23 83/2 86/12
86/14 87/5 87/7 87/10
89/16 105/14 115/4
116/24 117/2 117/14
119/1 119/11 119/17
121/19 121/21 122/3
122/24 128/10 128/13)
128/16 132/16 132/17,
133/7 133/19 134/19
136/2 136/7 136/9
136/13 136/17 136/25)
137/22 137/25 142/15)
143/1 143/3 143/11
143/24 148/17 148/21
148/23 149/9 149/12
152/3 153/6 153/9
153/12 153/21 154/3
154/5 154/8 155/3
157/3 159/20 159/21
160/15 160/18 160/18)
160/19 160/22 161/2
161/4 161/6 161/14
161/15 162/24 162/25)
163/23 164/24 166/2
166/6 167/11 167/12
167/16 168/22 169/10)
173/2 173/12 173/17
173/17 173/23
systems [5] 61/14
61/20 70/17 72/8
121/9
T
take [11] 23/5 35/6
82/22 91/3 119/8
145/21 157/11 157/14)
159/14 171/24 174/12)
taken [16] 16/4 18/4
25/12 25/21 27/8
43/10 62/21 66/1
75/12 84/24 88/2
100/19 108/11 162/16)
163/18 165/10
takes [1] 167/24
taking [5] 63/14
63/16 83/22 151/14
171/20
talk [6] 12/8 18/5
112/1 131/1 174/25
175/6
talked [1] 32/23
talking [13] 12/10
26/23 45/9 45/13
59/11 59/14 72/2
73/15 105/25 112/16
112/17 136/7 161/3
tamper [2] 53/22
55/3
tampered [1] 54/14
tampering [2] 53/24
54/1
team [19] 38/21
39/10 39/11 39/17
55/24 57/17 57/23
70/9 70/15 70/25 71/3
71/12 72/3 72/5
115/18 129/10 130/24
151/14 172/2
teams [2] 38/10
39/15
technical [14] 7/25
11/19 12/8 12/9 25/8
98/25 105/11 109/18
110/1 116/6 118/10
143/12 155/8 157/6
technicalities [1]
89/21
technically [2] 46/19
129/25
Teja [2] 129/12 131/4
Tel [2] 126/4 126/25
Tel-con [2] 126/4
126/25
tell [19] 11/21 20/17
35/9 41/16 52/1 52/12,
56/16 56/25 57/11
57/17 57/24 58/5
60/14 118/6 131/17
138/20 139/10 158/25}
164/22
ten [4] 26/25 30/12
30/12 111/23
tended [2] 45/4 68/15I
tends [1] 159/13
term [6] 54/3 80/20
131/1 136/2 136/13
152/3
terminal [5] 31/3
31/4 56/2 57/20 58/2
terminals [8] 55/21
55/25 56/4 57/1 57/18
57/25 58/6 79/4
terms [31] 13/20
15/24 32/5 32/7 33/2
35/20 37/12 56/24
58/12 58/19 60/14
74/5 79/17 81/1 83/3
90/23 99/21 102/23
103/1 113/4 113/17
116/5 117/7 120/23
122/4 129/10 135/21
138/19 143/6 145/16
172/23
test [1] 70/17
testers [1] 56/19
testimony [1] 69/8
text [8] 8/17 10/5
20/22 133/25 135/14
156/15 157/20 158/1
than [32] 10/4 13/22
33/2 34/23 45/14
46/21 46/25 48/8 52/8
61/9 62/20 63/25
72/11 74/5 75/4 76/15
76/17 77/24 79/21
90/23 94/10 95/6
101/8 103/9 128/16
132/10 133/19 142/15]
142/25 152/21 162/8
163/22
thank [57] 1/6 2/6
6/22 8/25 9/12 10/3
12/22 12/23 13/25
14/4 14/6 14/6 14/9
19/4 23/4 24/6 24/22
28/5 28/8 37/14 39/19
39/19 42/22 49/4
49/14 49/18 50/14
64/18 64/21 66/16
72/18 72/19 72/20
74/17 79/23 90/17
90/20 91/20 95/15
102/4 104/17 104/18
110/14 128/2 131/23
137/5 145/1 150/15
150/19 150/24 151/3
165/22 168/14 174/10}
174/23 175/4 175/8
thanked [1] 108/4
that [1212]
that I [2] 28/15 144/8
that's [65] 3/5 3/23
6/3 6/22 7/1 8/2 8/3
8/6 8/22 15/16 19/13
23/15 23/20 28/2
29/14 33/22 35/2
36/20 37/7 37/15
49/12 50/11 50/12
54/3 56/8 58/15 64/7
68/4 70/22 75/14
76/11 87/22 91/13
96/1 104/22 106/16
107/15 110/4 113/15
116/18 117/15 118/5
123/16 125/15 125/25]
129/13 130/20 133/6
141/16 144/9 147/23
150/13 154/10 159/21
160/5 163/5 163/24
164/3 164/15 165/16
165/21 172/7 172/19
173/8 174/19
their [19] 7/23 24/19
27/14 38/19 38/19
38/21 42/8 48/20 50/7
68/7 69/8 72/7 74/5
80/24 90/24 106/1
113/18 121/18 158/25]
them [47] 2/13 2/21
19/8 29/5 32/3 37/21
38/3 38/24 41/12
45/25 47/16 82/3 84/5
89/2 92/10 96/22
113/3 115/10 119/3
130/25 137/11 140/5
142/1 142/17 147/17
147/18 150/7 150/9
150/12 150/13 156/18
157/7 158/12 158/13
158/15 158/19 159/8
161/9 161/22 164/13
167/13 167/17 172/6
172/8 172/12 173/19
173/20
themselves [2] 51/4
75/2
then [130] 2/11 2/24
4/10 6/22 7/11 8/25
9/21 14/10 14/11
14/13 16/2 16/5 16/7
16/14 18/9 19/12
19/16 21/4 21/12
21/20 26/3 26/24
27/19 28/8 28/17
29/18 30/10 31/4
35/24 40/18 42/2 43/2I
43/16 44/20 46/15
48/11 48/17 49/21
50/2 50/3 50/6 51/23
52/25 56/23 60/8 60/9
66/14 66/14 66/14
66/18 66/21 67/6 68/8)
69/5 69/5 70/15 71/1
71/10 74/13 76/8
77/20 78/16 80/13
80/25 81/16 81/18
81/20 82/16 84/24
85/2 86/5 86/7 87/14
87/19 90/4 92/16
93/13 95/12 96/19
98/22 99/19 99/24
100/8 103/8 107/8
109/5 109/7 109/8
110/15 111/18 113/23)
116/25 117/2 117/12
1419/2 120/17 123/20
124/17 124/20 126/12)
128/14 128/22 129/14)
130/21 132/19 134/23}
136/10 146/20 146/21
153/20 157/6 157/7
157/8 159/18 159/25
160/2 160/18 162/19
162/20 164/14 164/19)
164/23 165/13 165/16)
166/6 166/22 168/25
169/17 170/13 171/10}
theoretically [2]
48/24 69/13
theory [2] 48/4
119/12
there [165] 2/12 3/19
3/24 6/23 7/6 8/7 11/9)
16/25 17/12 17/24
(68) suggestion - there
T
there... [155] 19/4
19/4 20/7 21/15 21/20)
22/13 22/17 22/22
22/24 23/9 25/23 26/4
26/10 27/2 27/2 28/7
28/22 28/23 29/12
30/6 30/10 32/10
32/11 32/12 32/12
35/13 36/25 38/17
38/20 39/6 39/10
40/20 41/3 41/16 43/9
44/2 44/21 47/12
48/15 48/17 50/4 51/2)
51/17 55/3 56/5 57/15)
58/19 58/21 58/21
59/2 62/3 62/22 63/12
63/20 64/3 64/9 64/15)
65/16 66/4 66/25
68/11 68/14 69/6
69/10 71/7 72/1 72/5
75/8 76/2 80/6 81/17
82/5 82/6 82/15 83/14
84/22 89/16 90/1 92/9
92/13 95/3 97/12
97/15 98/21 99/19
103/9 103/13 107/20
108/24 109/6 109/8
109/17 109/20 109/25}
109/25 112/1 113/2
115/8 115/15 116/23
117/10 117/25 119/24}
120/8 120/8 125/15
128/4 128/5 128/5
128/8 128/13 132/17
133/10 133/22 135/10)
136/23 137/8 139/16
140/14 141/4 141/20
142/16 143/22 144/4
145/6 146/21 148/16
151/16 152/6 153/1
153/4 153/9 153/11
153/21 154/7 154/22
156/3 156/15 160/5
160/12 160/17 160/22)
160/24 160/25 162/19}
165/13 165/19 165/25)
169/5 169/8 169/21
173/1 173/5 174/25
175/1
there's [8] 7/11 21/18
37/7 42/23 46/12
155/22 165/16 174/5
thereby [2] 152/13
153/13
therefore [18] 10/12
13/8 18/25 53/3 54/12)
70/10 77/2 82/10 85/7,
85/20 93/5 101/24
116/23 122/25 146/14}
154/4 160/5 172/5
these [36] 7/21 18/7
24/10 26/1 30/19
31/24 32/1 32/14 36/4
66/13 66/18 70/10
72/10 73/3 75/11
89/16 100/3 100/4
105/24 121/18 133/25)
139/5 141/24 142/6
142/10 144/5 144/13
144/19 153/17 155/17)
155/18 169/1 170/23
171/8 171/9 172/22
they [99] 17/24 18/17
19/5 26/7 27/5 27/15
32/6 34/19 35/15
35/18 35/20 37/17
38/9 38/15 38/16 41/4
41/5 41/8 41/13 42/7
42/9 43/15 45/25
46/19 46/20 46/24
47/12 47/7 47/10 47/13
47/20 47/24 48/5 48/7
48/13 48/13 48/14
48/16 48/17 48/19
52/1 52/1 52/12 52/23)
53/18 54/5 56/2 57/23)
61/7 61/18 66/20 69/5)
70/16 73/4 73/24
76/25 84/11 86/3
87/22 89/18 90/12
90/23 93/21 105/2
105/4 105/23 106/21
106/21 106/25 112/7
114/21 117/6 118/9
118/22 119/2 121/22
121/23 122/1 122/7
123/15 125/5 127/13
134/19 136/4 137/7
139/21 142/1 143/1
143/12 143/13 143/14)
146/20 147/16 150/10)
153/25 159/14 172/10)
172/12 173/20
they'd [2] 51/24 68/8
they're [2] 16/14
116/3
they've [1] 125/2
thing [15] 12/20
12/21 26/14 30/11
30/20 31/1 54/24
63/25 70/3 84/9 89/14
97/6 97/14 163/1
166/18
things [36] 3/9 6/15
15/2 15/11 15/20
15/22 16/3 16/11
16/23 18/9 29/9 30/20
35/15 38/5 39/18
41/10 47/18 47/25
51/15 56/7 57/3 57/3
63/11 68/5 68/6 69/17
72/2 74/20 76/4 90/4
114/18 123/13 127/17)
128/2 137/1 152/23
think [171] 4/23 5/20
6/13 10/2 10/8 11/5
12/2 12/11 12/18
12/23 13/16 15/18
15/21 15/24 16/25
17/4 17/7 18/4 19/10
21/9 21/19 24/3 26/21
28/16 29/10 30/25
31/15 31/21 32/22
33/11 33/16 33/22
35/14 36/21 37/2 37/4
37/14 39/11 39/25
42/17 44/24 46/8
46/12 46/23 49/5
49/23 50/11 51/17
52/4 53/24 54/21 56/6
56/6 57/21 58/9 59/16I
66/4 69/14 69/16
69/18 70/13 71/25
7216 73/20 74/7 74/9
77/15 78/2 78/10 80/6
81/15 81/21 82/8 83/1
85/3 89/10 90/23
91/20 92/11 93/3
94/22 95/3 95/11 96/8
96/13 96/13 98/18
99/11 99/13 102/11
104/10 104/21 104/24
108/23 110/5 110/8
111/20 112/10 113/22
113/24 114/19 116/16
116/22 117/6 120/18
121/23 122/4 123/2
123/9 123/15 123/15
124/10 125/15 127/18I
127/21 128/4 129/4
129/7 129/8 129/8
129/22 129/24 133/9
137/25 139/4 139/8
139/23 140/20 143/22
144/12 144/18 145/2
145/23 146/13 147/11
148/7 148/15 149/13
149/16 150/13 151/12
151/24 152/1 152/12
152/17 152/19 154/14
154/15 154/15 154/16
155/16 155/25 156/11
156/18 157/14 157/17I
157/18 157/19 158/41
158/3 158/4 160/25
162/20 163/1 163/5
165/19 166/8 168/10
4171/4. 172/11 173/8
thinking [7] 15/25
21/9 32/16 51/13
58/25 134/17 136/16
third [19] 4/3 5/25
35/25 39/22 61/12
62/13 62/19 79/25
86/5 115/9 117/3
124/21 128/14 131/19]
138/22 139/11 141/17I
159/18 16/6
Thirdly [1] 44/15
this [292]
this' [4] 5/15
Thomas [13] 17/3
32/13 124/1 124/4
125/18 139/1 144/7
159/2 163/16 163/21
164/7 164/11 164/21
Thomas’ [8] 125/6
125/15 125/20 139/24I
140/11 144/18 151/1
165/18
those [52] 3/11 4/4
14/12 16/8 23/3 24/19}
29/22 33/2 35/19
38/22 39/11 42/8
45/18 45/19 54/8
56/20 57/21 60/10
77/9 79/6 80/1 82/2
82/19 83/4 84/3 90/4
92/15 96/19 99/3
100/25 102/21 107/2
110/25 111/2 111/23
114/17 116/2 116/9
116/10 119/14 127/17}
128/2 133/23 137/21
142/17 142/18 156/18}
162/4 162/12 162/13
167/15 170/16
though [8] 34/19
41/18 47/21 52/22
69/10 129/6 130/7
148/24
thought [35] 7/25
15/19 22/7 22/13
41/20 42/19 42/20
42/21 54/15 55/5 69/4)
74/23 75/4 83/1 84/12,
95/5 116/1 117/11
117/16 135/25 136/9
136/19 141/3 141/5
142/10 149/18 150/6
150/10 150/11 155/15
162/10 168/7 171/22
172/13 172/19
thousands [1] 30/7
thread [1] 28/6
threatened [1] 75/1
threatening [1]
108/12
three [20] 14/11
14/12 16/19 78/18
96/19 102/22 115/19
121/16 121/16 126/13}
128/8 153/4 159/24
160/21 160/23 161/11
162/2 165/1 165/23
165/25
throat [1] 91/1
through [25] 1/25
10/22 13/16 16/3
19/21 24/3 35/11
40/16 50/1 55/5 57/7
65/25 66/9 72/13 76/6)
100/5 111/19 116/1
137/4 147/9 153/11
153/13 153/18 154/17
162/11
throughout [3] 52/9
52/11 52/13
Thursday [1] 130/20
time [119] 6/23 6/24
7/1 7/24 10/23 10/24
12/5 14/24 16/14
16/21 19/11 19/22
21/10 22/7 22/14 23/3}
26/16 27/1 27/3 28/24I
29/21 30/18 31/3 31/4
31/22 34/10 34/18
36/14 37/13 39/24
40/13 40/25 41/18
41/22 42/18 47/3
48/11 48/13 49/10
53/17 54/16 54/23
55/5 57/7 57/9 58/11
58/13 59/5 59/19
60/12 63/11 64/8
64/11 64/16 68/5
69/17 69/22 74/19
74/23 76/1 78/7 79/18)
85/19 87/8 87/13 88/4I
89/23 91/3 91/14
92/17 93/10 93/21
93/24 94/1 94/18
94/25 95/8 101/21
104/10 105/13 105/18}
4111/7 112/25 114/9
114/17 116/16 117/3
119/18 120/18 121/25)
122/10 123/13 123/19)
124/7 131/6 141/8
141/10 141/12 142/17)
142/21 143/21 146/7
149/23 152/20 154/12!
155/11 155/16 158/22)
159/24 160/21 160/23)
160/25 161/24 162/11
163/25 164/5 165/1
167/7 171/5
time-out [1] 27/3
timeline [1] 106/6
timeout [2] 26/11
168/23
times [5] 18/24 32/14
51/12 138/12 169/24
timescale [1] 96/15
timescales [1]
107/21
title [6] 33/17 91/7
92/1 95/15 104/22
111/9
titles [1] 121/18
to’ [1] 45/4
today [3] 15/20
108/18 130/19
together [8] 12/10
12/12 25/9 25/22
78/11 107/21 126/8
126/20
told [28] 16/10 18/7
(69) there... - told
T
51/9 52/3 53/17 55/1
55/16 55/20 55/24
59/2 61/1 70/12 77/21
78/12 95/8 97/17
97/20 98/18 114/7
114/17 114/19 127/2
149/18 170/5 173/17
173/18
tomorrow [2] 174/14
174/20
tomorrow's [1] 6/10
Tonbridge [2] 28/17
29/8
too [5] 16/4 16/4
65/24 105/18 131/10
took [2] 34/19 172/12
tooling [1] 60/18
top [18] 13/25 19/3
26/14 49/22 63/20
102/5 113/5 120/22
155/22 156/3 156/21
topic [3] 23/22 39/20
79/23
topics [1] 19/4
Torstein [1] 78/21
towards [1] 11/20
town [4] 136/21
traced [1] 117/2
tracing [1] 124/8
Track [1] 153/13
tracked [2] 157/17
166/10
trail [29] 72/23 73/10
73/11 80/16 93/15
93/19 95/2 103/6
112/3 112/16 112/17
112/21 116/23 117/1
4117/7 117/12 117/15
117/17 117/21 118/3
118/11 119/10 120/1
120/10 120/10 122/5
123/6 123/7 123/16
trails [1] 105/18
transaction [27]
35/12 40/4 40/16
A117 43/14 43/14
43/25 44/8 48/14
52/16 54/9 76/16
86/25 87/16 122/15
128/9 128/11 128/12
153/5 153/7 153/8
166/1 166/3 166/4
167/23 168/16 172/4
transactional [2]
115/6 115/23
transactions [57]
17/10 34/8 36/11 43/7)
45/11 45/22 46/3
46/17 46/21 47/11
told... [26] 31/18 47/4
71/22 72/15 96/4 97/9
126/25 129/16 130/17)
51/19 52/18 53/5 56/9
57/6 70/2 71/4 73/17
73/24 74/4 75/11
76/13 77/6 77/22 79/5)
79/20 118/4 125/11
125/13 125/14 125/21
126/7 126/17 126/18
126/22 127/13 127/14)
128/6 139/6 139/24
140/1 140/4 140/14
141/5 141/12 159/24
160/1 160/21 160/23
161/16 163/19 163/20)
165/1 172/3 172/24
172/25 173/3
transactions’ [2]
70/11 131/15
transactions.’ [1]
50/10
transcript [4] 42/23
42/24 49/20 50/13
transfer [4] 34/5 34/7
36/8 37/8
transferring [1] 34/2
translated [1] 6/20
treated [1] 23/1
trial [1] 77/13
tried [2] 52/5 152/24
trigger [1] 27/21
true [16] 8/6 21/24
23/17 59/6 67/8 67/22
77/10 78/13 79/17
80/19 87/20 87/23
88/1 137/17 138/16
165/2
truth [3] 148/4
148/12 148/14
truthfully [1] 22/11
truthfulness [1]
146/15
try [6] 65/23 66/13
85/25 89/19 117/3
141/15
trying [19] 23/17
33/16 50/11 50/12
51/13 73/4 105/25
106/3 113/12 116/22
118/5 121/23 129/8
130/12 137/1 140/15
147/8 152/22 155/13
turn [20] 4/2 8/9
24/25 28/5 31/10
39/19 42/22 55/7
55/12 64/18 70/4
72/18 79/23 80/1
111/8 118/6 123/21
131/18 138/21 174/11
turned [1] 78/13
Turner [1] 18/17
turning [1] 55/8
turns [1] 79/15
twice [1] 105/16
twigged [1] 166/18
two [37] 7/14 8/19
14/9 36/19 73/3 78/18
90/21 91/4 91/23
91/25 95/12 96/14
107/2 115/19 119/18
123/4 124/19 128/2
133/22 134/1 135/2
137/7 137/21 141/15
141/21 141/24 144/5
144/8 144/13 145/3
146/25 148/8 156/14
162/13 169/18 170/6
170/14
two paragraphs [4]
124/19 137/7 146/25
156/14
type [2] 110/25 147/2
typed [10] 145/8
145/8 145/14 145/24
153/2 158/13 161/22
164/13 164/16 170/23
typing [5] 148/2
153/12 153/20 170/8
170/21
typo [1] 96/8
U
unable [4] 35/8 82/20
83/9 160/14
unaudited [3] 61/13
61/19 62/11
unclear [1] 146/19
undeleted [2] 166/19
166/20
under [11] 14/10
14/13 17/13 25/10
99/19 102/13 117/25
117/25 128/19 164/1
172/23
undergo [1] 61/4
underlined [1]
135/23
underlying [6] 25/18
25/23 27/10 73/6
86/11 86/13
undermine [1] 18/20
underneath [3]
135/14 137/16 169/17]
understand [56] 3/3
7/24 8/13 8/16 8/20
8/24 9/4 9/10 10/10
10/14 13/1 13/8 14/23
23/19 24/15 25/11
27/15 30/17 30/18
30/21 36/16 40/11
47/9 51/24 53/25
60/19 63/13 65/14
67/3 68/18 72/13
85/25 87/17 88/11
89/6 92/19 93/5 93/11
97/14 98/9 114/2
115/8 123/18 124/6
127/4 133/3 136/15
140/21 142/5 145/15
152/2 152/4 171/19
171/22 174/8 175/8
understanding [39]
5/17 12/3 15/24 26/21
34/21 34/23 39/24
41/1 41/14 41/22 42/3)
42/8 42/10 46/20 47/2
54/23 58/10 58/15
63/11 63/15 68/6 69/2
73/23 76/1 76/5 77/25
78/6 78/8 79/2 106/12,
109/22 114/12 114/15)
140/17 144/12 145/2
146/24 171/13 171/15}
understood [28] 4/7
7/24 9/24 15/5 15/15
16/13 16/14 40/18
41/8 68/5 69/4 70/1
75/3 80/20 84/9 87/8
87/12 88/9 88/23 89/2
101/10 113/23 115/14
123/13 139/13 140/1
140/3 171/10
undertake [3] 54/20
115/2 122/21
undertaken [5] 87/1
87/6 115/9 115/12
143/15
undertaking [1]
114/25
unexpected [1]
85/19
unfiltered [1] 43/15
unfinished [2] 132/2
132/11
unfortunate [1] 24/9
unhappy [2] 158/14
164/12
unit [5] 34/5 34/6
35/14 36/8 36/9
units [3] 34/3 34/11
102/20
unknown [1] 30/24
unless [1] 83/19
unlikely [3] 67/16
69/24 69/25
unnecessary [1]
128/21
unpredictable [1]
25/20
unreliable [1] 84/23
unrestricted [3]
61/13 61/19 62/10
until [16] 2/13 2/21
4/13 4/24 27/1 30/13
47/2 48/25 49/12 53/8)
62/4 62/6 83/19 84/10
96/10 175/11
unusual [4] 35/17
130/22 168/18 171/21
up [80] 6/22 8/9 11/3
19/16 28/1 28/8 28/10}
29/11 34/16 35/1
35/13 35/22 36/25
37/14 37/19 43/3 47/2
55/8 63/23 64/20
65/22 66/15 66/21
68/24 72/20 73/13
75/7 76/10 80/1 84/16
87/14 88/5 89/4 91/20
92/25 96/4 97/2 97/11
103/4 103/5 104/18
105/4 108/11 109/5
109/5 109/7 114/10
118/7 127/13 128/2
130/8 130/9 130/17
131/18 131/23 132/19)
133/12 134/23 138/21
147/2 148/2 148/5
148/11 150/1 150/25
152/16 156/22 157/7
158/13 158/20 161/22)
164/13 164/14 164/16)
164/19 165/6 168/13
169/19 172/7 174/1
update [3] 61/11
133/1 157/8
updated [2] 71/15
134/12
upon [2] 18/1 173/22
urgency [2] 65/5
151/16
urgent [1] 65/3
urgently [2] 71/14
172/21
URN [2] 4/10 36/22
us [21] 8/2 16/10
24/18 60/14 61/1
85/25 106/11 108/15
118/6 124/2 126/9
126/20 131/17 138/20)
139/10 156/25 157/16
158/25 164/22 170/5
171/24
use [23] 10/4 43/19
44/11 44/22 44/25
45/5 48/18 50/21
51/10 52/9 72/25
79/23 81/15 87/18
89/2 94/19 95/9
104/14 136/2 146/2
155/2 167/4 169/23
used [37] 7/22 41/13
44/7 50/15 51/11 54/7)
54/12 55/21 56/25
65/18 72/24 76/14
76/22 77/22 80/23
88/8 89/1 92/13 94/9
94/12 94/15 97/24
97/25 111/5 115/6
115/13 115/24 121/5
145/10 147/19 154/21
157/6 161/6 164/7
164/20 165/5 165/11
useful [3] 33/2 36/18
81/25
useless [2] 135/2
137/12
user [12] 34/9 37/24
(70) told... - user
U
user... [10] 45/12
45/13 45/16 45/24
47/19 51/19 52/15
62/23 86/13 86/16
username [1] 43/21
using [18] 31/2 31/3
44/16 45/12 46/4 46/5)
47/15 48/17 52/23
54/4 77/23 87/22
147/17 152/5 154/20
154/23 167/3 169/15
usual [7] 125/7
130/22 131/2 131/9
131/10 132/7 172/4
usually [4] 34/8
38/24 82/1 141/25
UTC [1] 7/1
utilised [1] 102/17
Vo
vague [1] 104/23
value [19] 17/10
127/13 127/14 128/6
128/8 128/15 132/10
133/18 133/20 136/24
139/5 140/4 140/14
141/4 141/12 153/4
160/1 163/19 165/25
values [1] 44/3
variant [1] 92/13
various [9] 20/15
20/16 55/18 55/21
56/2 57/1 78/21 79/24
92/9
Verbatim [1] 135/19
version [29] 8/11
8/14 10/1 10/4 10/5
21/1 24/1 59/21 75/11
92/11 92/11 95/1
95/22 95/23 96/5 96/5)
96/7 96/13 111/14
111/14 111/20 112/12)
135/11 156/19 156/22
158/24 159/5 159/6
166/17
versions [3] 92/9
111/25 112/1
very [29] 3/3 18/5
23/4 23/8 36/14 47/21
51/11 52/3 54/24 62/4
67/12 68/19 70/2 72/3
77/4 93/6 104/23
112/18 113/25 126/9
139/5 140/13 141/22
150/19 151/13 154/21
155/17 163/6 173/18
vested [1] 61/9
vetting [1] 61/5
via [1] 140/16
view [9] 10/19 12/24
41/18 42/2 73/19
81/22 83/1 83/10
83/18
views [1] 82/24
lity [2] 51/2
vi
7716
visible [10] 34/9
34/12 41/14 42/1
42/11 68/9 73/18
76/20 81/19 100/5
Wo
waiting [2] 26/11
27/3
Wales [1] 124/1
want [18] 24/2 24/8
24/12 44/17 66/13
88/8 89/1 89/20
106/22 109/15 127/19)
129/23 133/24 133/24)
134/3 134/6 138/8
158/15
wanted [4] 33/3
41/21 43/6 90/3
wanting [1] 95/4
Ward [18] 6/7 124/10
126/6 131/14 131/16
131/24 134/17 134/22)
135/20 136/12 140/10)
151/3 151/9 151/21
155/8 166/12 169/5
173/15
Ward's [2] 140/16
171/18
was [687]
was.' [1] 44/4
wasn't [39] 8/8 9/16
32/24 37/23 38/23
41/19 43/18 43/23
44/11 45/2 48/25 50/3
52/3 52/25 55/2 58/4
60/15 61/7 61/17 62/6
74/8 74/21 84/10 87/3
90/10 93/23 95/3
101/5 112/15 116/16
120/14 122/9 123/19
146/10 147/17 149/21
165/2 169/16 171/2
Watchdog [1] 106/2
way [69] 1/25 3/4 3/7
4/8 9/9 10/7 13/1 13/9
15/1 16/16 16/18
17/11 18/6 18/25
24/19 24/19 25/15
30/23 37/19 40/22
41/20 46/17 47/11
47/14 48/7 48/11
50/22 51/19 54/15
55/5 58/7 61/24 61/25)
69/17 76/17 81/22
86/15 103/9 103/21
103/24 104/14 112/16)
119/11 120/10 131/6
136/20 137/1 137/15
140/1 144/1 145/15
146/5 147/6 148/10
148/16 151/24 151/25}
152/4 152/5 152/19
152/20 152/23 153/18
155/13 157/3 157/5
157/14 162/11 167/18}
ways [1] 75/10
we [282]
we'd [2] 28/22 30/25
we'll [4] 8/22 151/5
174/19 174/19
we're [16] 19/17
20/17 23/6 26/22 32/1
45/8 66/7 75/7 95/22
108/17 110/8 127/21
136/3 144/9 161/3
175/5
we've [9] 4/10 79/3
79/7 79/9 92/11
122/20 125/25 126/12
161/5
Wednesday [1] 1/1
week [2] 109/19
110/5
week's [1] 36/12
weeks [6] 29/6 77/12
78/18 86/10 108/8
159/11
well [54] 5/15 11/13
13/14 15/16 17/1
31/17 36/24 39/12
54/1 57/4 57/14 58/21
58/24 62/1 68/6 68/15)
70/1 70/3 70/15 71/21
74/1 74/21 82/1 83/22
85/1 88/5 88/5 101/7
108/17 112/15 114/8
115/21 118/20 122/14
136/4 136/7 146/21
147/16 147/25 148/3
148/24 149/2 154/4
158/5 159/5 159/5
160/16 162/1 164/1
164/6 166/20 169/8
173/11 173/12
Welsh [1] 108/14
went [5] 22/24 24/1
34/14 169/13 173/8
were [202]
weren't [12] 2/13
2/21 23/23 28/22
28/23 38/25 56/22
57/23 93/25 108/21
138/16 172/14
West [1] 32/7
what [254]
what's [5] 14/3 18/8
21/7 37/6 85/25
whatever [3] 68/14
130/3 145/10
whatsoever [1] 131/5I
when [75] 2/6 6/17
9/5 9/16 12/17 14/1
16/6 16/10 16/22
25/19 27/10 29/9
29/22 31/20 33/20
34/2 34/12 38/8 41/5
43/5 43/6 44/22 46/16)
47/18 47/24 48/13
48/15 48/19 48/23
53/2 53/3 54/5 54/9
54/10 54/17 59/14
61/24 63/4 63/8 63/8
63/15 68/6 68/14 69/5
69/9 73/8 74/25 75/23,
77/11 77/25 78/3
79/11 82/4 85/13
89/22 92/24 94/22
94/25 102/10 104/7
105/18 106/7 107/11
108/18 118/14 127/8
134/21 140/16 146/20}
156/19 157/6 161/14
165/15 165/17 170/23
whenever [1] 73/23
where [27] 1/9 18/23
22/25 24/7 25/3 26/10)
27/2 32/11 39/6 39/9
45/2 47/13 48/16
61/11 69/2 70/7 82/5
87/10 87/16 106/12
133/21 134/15 138/7
151/15 161/21 163/9
175/5
whereby [2] 41/8
69/6
whether [40] 1/11
2/16 17/9 22/11 24/18)
25/24 29/16 30/3
32/14 35/10 43/24
45/3 48/13 48/14
50/17 52/12 52/14
55/1 57/9 73/15 77/7
81/4 81/13 86/14 89/9
96/25 97/5 97/7 117/9)
118/22 119/4 131/16
140/6 143/11 147/16
150/16 154/19 157/4
157/16 165/3
which [154] 1/9 1/11
1/17 1/19 4/4 4/17 5/9)
7/21 7/22 14/1 17/9
20/7 21/5 22/9 22/25
24/20 26/3 26/25
27/16 28/16 31/25
31/25 34/14 35/9 36/1
37/20 39/10 39/23
40/5 40/5 40/15 41/4
43/15 45/4 45/8 45/22
48/6 49/22 49/23 50/5)
55/3 58/22 59/1 59/21
64/10 65/10 65/20
66/2 66/10 67/18 72/8
TAIT 76/2 76/3 76/15
77/6 79/1 79/5 80/1
80/8 80/9 80/11 80/14)
82/13 82/19 83/21
84/17 84/17 85/7
85/13 85/20 86/6
86/25 88/17 88/17
92/1 92/1 92/6 94/16
96/5 97/3 100/5
101/16 101/18 101/23)
102/17 102/22 103/8
105/13 110/21 110/22)
111/20 112/1 113/18
4117/1 117/7 117/22
122/5 122/11 123/16
123/18 123/22 125/6
125/10 126/13 126/14)
128/20 131/5 131/12
132/9 132/15 133/6
135/2 135/14 137/9
137/21 138/13 141/23)
144/1 144/16 144/22
145/7 145/14 145/23
146/3 146/6 146/9
147/10 148/18 149/22)
150/3 151/18 154/2
155/23 157/2 157/3
158/6 158/25 160/1
162/21 163/22 164/12)
164/15 167/11 168/17)
169/15 169/25 170/6
170/8 170/16 171/19
172/2 172/3 173/1
while [3] 19/23 26/5
51/10
whilst [7] 12/5 17/12
94/4 113/20 151/16
160/14 163/4
white [1] 20/18
who [20] 20/1 41/15
57/22 83/6 84/5 96/16
97/15 98/11 104/19
105/1 108/11 113/1
114/2 115/18 124/1
143/8 145/16 149/21
149/22 174/6
whoever [1] 48/12
whole [7] 12/20
12/20 84/12 87/6
96/14 142/9 146/19
whom [1] 171/15
why [66] 9/14 9/18
10/6 11/5 11/21 15/18)
25/11 26/1 27/13
28/21 30/8 30/17
30/19 31/16 37/7
42/11 47/4 47/20
50/21 54/3 59/11
60/14 69/15 73/8 78/5
78/8 83/8 90/10 90/15}
93/20 93/25 97/11
98/20 98/23 101/12
110/19 112/13 112/20}
112/23 112/24 113/1
113/20 113/22 117/9
120/16 127/13 128/5
128/8 128/18 139/23
140/14 141/4 143/16
150/5 150/13 152/2
153/4 155/1 161/25
(71) user... - why
Ww
why... [7] 165/25
166/24 169/11 169/13)
171/7 171/19 173/8
wider [3] 104/1 104/5
171/2
Wiley [2] 67/18 67/19
will [16] 8/12 13/17
20/7 30/13 98/15
100/4 108/20 113/13
114/11 117/3 126/9
130/18 132/25 155/25
161/2 174/13
willing [1] 169/11
within [17] 22/12
39/9 52/2 76/21 84/1
99/21 115/20 120/12
120/18 136/8 136/25
140/6 156/7 158/12
168/23 169/10 174/2
without [15] 32/16
43/7 46/6 51/16 55/22)
57/12 82/21 82/24
83/11 97/10 97/11
98/7 98/9 101/17
140/11
WITN00420100 [1]
55/8
witness [140] 3/4 4/2
4/3 4/15 5/22 6/18
6/20 7/12 7/17 8/3 9/5)
9/15 9/19 10/6 13/19
14/17 17/5 17/21 18/3}
18/13 20/12 20/14
20/20 21/23 22/5 23/1
23/13 23/23 25/3 25/6
29/4 32/18 39/13
39/22 42/13 49/5
49/24 51/22 54/17
54/18 54/18 55/9 63/5)
63/8 66/1 66/5 66/7
76/12 77/12 78/10
78/14 78/16 78/19
78/24 79/12 79/25
81/3 82/8 82/13 82/19
83/8 84/6 85/4 118/6
124/2 124/25 125/19
127/9 127/17 127/22
128/1 128/24 129/3
129/5 129/14 129/20
129/20 130/3 130/10
130/11 130/14 130/24)
131/15 131/17 131/19}
131/20 131/25 133/25)
134/12 134/24 135/16)
136/13 138/20 138/22
139/10 139/11 139/20}
139/23 140/22 141/8
141/18 141/19 141/23}
143/2 143/5 143/6
143/9 143/18 143/20
144/15 144/17 145/5
146/1 146/6 146/12
147/3 147/23 148/7
151/22 152/9 153/3
154/18 156/5 156/23
157/13 158/24 159/14)
163/13 164/14 166/25)
167/6 168/8 168/11
170/5 170/7 170/15
173/10 173/16 173/23)
174/4
witness's [1] 2/25
witnesses [4] 17/15
17/21 81/24 142/5
won't [1] 19/22
wonder [1] 150/16
Wood [1] 106/16
word [10] 139/13
145/7 153/12 153/14
162/18 162/20 163/10)
164/20 165/9 168/8
worded [1] 155/14
wording [7] 36/5
152/7 152/21 165/5
167/2 173/16 174/1
words [24] 17/15
25/22 54/14 77/13
93/17 116/3 116/9
116/10 117/19 132/14)
134/2 135/23 154/2
154/6 154/20 154/21
154/24 155/2 155/3
166/15 169/15 170/17,
170/21 173/21
work [10] 26/15 38/5
48/20 75/2 88/10
114/3 119/1 119/12
122/21 151/10
worked [6] 24/3 42/8
48/11 112/16 112/17
112/21
working [13] 64/4
64/9 95/22 115/18
142/8 142/9 143/24
144/23 145/8 145/24
170/3 170/18 171/5
works [3] 14/19 21/8
106/15
Worrell [1] 96/17
worry [1] 31/5
worth [2] 151/14
161/2
would [199]
wouldn't [9] 38/15
54/1 54/8 58/3 58/12
64/16 146/11 148/19
148/21
write [7] 93/3 112/24
113/1 126/10 148/24
149/2 149/15
writing [8] 65/4 79/12
99/7 101/7 107/19
116/5 138/20 157/6
written [5] 10/7 36/25
93/22 149/16 149/21
wrong [5] 69/21
73/20 89/23 89/25
136/14
wrongly [2] 87/2 87/3}
wrote [6] 63/8 91/24
94/18 94/22 98/17
149/22
Wylie [4] 64/24 65/6
65/14 66/24
Y
yeah [18] 7/3 9/25
49/3 50/16 62/7 102/9
115/11 119/16 125/4
130/16 142/3 145/22
146/13 147/4 161/8
161/10 170/20 170/22
year [5] 17/5 53/11
70/5 96/7 111/18
years [4] 16/19 68/24
105/12 119/18
yellow [7] 137/17
145/13 146/17 150/2
169/19 170/6 171/7
yes [270]
yesterday [32] 1/9
1/11 1/15 1/22 1/23
2/4 2/9 2/10 2/15 2/18
2/23 3/1 3/2 3/15 4/21
8/15 9/13 10/11 10/19
11/21 12/2 12/15
12/25 14/25 15/10
15/18 15/25 16/9
16/22 18/14 24/3 66/1
you [824]
you'd [17] 12/15
12/18 15/12 16/10
16/11 17/5 18/8 47/6
129/7 135/22 138/19
152/12 156/18 164/20
165/7 165/10 171/7
you'll [11] 7/20 8/17
10/8 21/5 21/20 34/24
35/25 36/25 60/4
127/16 133/23
you're [25] 11/9
11/13 28/10 35/23
41/24 45/13 53/25
60/2 60/10 66/4 71/16
88/19 89/25 90/24
102/6 111/10 131/21
142/20 145/6 145/12
150/11 161/16 163/21
164/6 170/18
you've [14] 14/1 15/7
24/10 61/1 113/20
134/21 134/24 135/22)
136/22 137/19 148/5
159/4 164/6 165/11
your [159] 3/15 4/2
4/2 5/15 6/20 7/12 8/3
9/5 9/15 9/19 10/6
11/5 17/18 18/13
18/13 18/13 20/12
22/15 25/2 25/4 31/13)
33/4 34/20 38/5 39/22
39/24 40/25 41/14
41/21 42/3 42/13 45/1
54/17 55/7 56/22
57/17 59/10 63/5 63/8
65/6 65/12 65/17
65/22 66/4 67/1 70/8
71/11 73/13 75/7 76/5)
78/8 78/23 79/8 79/11
79/25 81/22 82/8 85/3,
85/4 86/7 88/5 89/4
89/6 89/11 90/8 90/10
90/17 91/3 95/9
103/10 103/17 103/20}
103/23 104/4 104/8
104/12 104/14 107/15
108/24 110/2 110/15
113/20 114/12 116/9
118/6 119/8 119/17
123/4 123/11 124/2
124/8 125/12 126/10
126/16 130/18 130/19}
130/22 130/24 131/17]
131/19 132/7 133/1
133/7 133/9 134/12
134/14 135/15 136/19}
137/6 137/15 138/20
138/22 139/10 139/11
139/15 140/17 141/17)
141/19 142/20 146/1
146/5 146/24 147/23
149/11 151/22 152/9
152/18 153/2 154/16
154/18 155/8 155/20
156/19 156/24 157/13
157/24 162/6 162/21
163/8 163/11 164/20
165/9 165/17 167/6
168/8 169/6 170/5
170/18 171/7 172/2
172/8 173/7 173/10
173/16 173/16 173/23
174/25 175/2 175/7
yours [1] 50/25
yourself [3] 13/25
104/13 165/8
YouTube [1] 8/13
zero [14] 17/9 127/12
127/14 128/6 128/8
139/5 140/4 140/14
1411/4 141/12 153/4
160/1 163/19 165/25
(72) why... - zero